DOJ-OGR-00010090.jpg
469 KB
Extraction Summary
3
People
1
Organizations
0
Locations
3
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
469 KB
Summary
This document is a transcript of a legal proceeding where a witness named Edelstein is being questioned about the drafting of a legal brief. Edelstein testifies about a discussion with a colleague, Ms. Brune, regarding whether to disclose their prior knowledge of a suspended lawyer named Catherine Conrad. The testimony centers on their intent and state of mind at the time, stating they were not focused on the legal concept of 'waiver' but rather on establishing facts.
People (3)
| Name | Role | Context |
|---|---|---|
| Edelstein | Witness/Deponent |
The person being questioned in the transcript.
|
| Ms. Brune |
Mentioned as having had a discussion with Edelstein about what to omit from a brief.
|
|
| Catherine Conrad | suspended lawyer |
Mentioned as a suspended lawyer about whom Edelstein and Ms. Brune had information.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| SOUTHERN DISTRICT REPORTERS, P.C. | company |
Listed at the bottom of the transcript, likely the court reporting agency.
|
Timeline (3 events)
Key Quotes (3)
"Well, it was worded that way because you and Ms. Brune had had a discussion previously about what you were going to omit from this brief, right?"Source
— Questioner
(Questioning Edelstein about the phrasing in a legal brief.)
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Quote #1
"The discussion I had with Ms. Brune was whether or not we were going to say that prior to voir dire we had information that there was a suspended lawyer named Catherine Conrad."Source
— Edelstein
(Answering the question about the discussion with Ms. Brune.)
DOJ-OGR-00010090.jpg
Quote #2
"I was not focused, when we were writing the brief, I was not focused on waiver. We didn't know they were the same person."Source
— Edelstein
(Explaining his state of mind and lack of focus on the legal concept of 'waiver' when writing the brief.)
DOJ-OGR-00010090.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,604 characters)
Case: 2:20-cr-00339-ABN Document #: 646-2 Filed: 03/24/22 Page: 222 of 330
A-5807
A-5807
C2GFDAU3
350
Edelstein
1 in hindsight with respect to this proceeding, but I can see
2 with hindsight now how it might be construed in the way you
3 have suggested. But at the time when we were writing it we
4 were describing what happened when we received the letter on
5 June 20th.
6 Q. Well, it was worded that way because you and Ms. Brune had
7 had a discussion previously about what you were going to omit
8 from this brief, right?
9 A. No. The discussion I had with Ms. Brune was whether or not
10 we were going to say that prior to voir dire we had information
11 that there was a suspended lawyer named Catherine Conrad.
12 Q. And you agreed --
13 A. We discussed it in the context of what was the standard for
14 waiver, what was the standard for juror misconduct cases, which
15 was actual knowledge. I was not focused, when we were writing
16 the brief, I was not focused on waiver. We didn't know they
17 were the same person. We just were trying to actually
18 establish that they were the same person and that, it took me a
19 long time for me to believe that they were the same person.
20 I really was not thinking about waiver. I know that
21 may be difficult for you to believe now when you're taking a
22 brief and looking at every sentence and trying to impart some
23 meaning to it or an impression that we were trying to create.
24 But that's not how we were writing it.
25 Q. Can you just answer the question that I asked? You just
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
350
Edelstein
1 in hindsight with respect to this proceeding, but I can see
2 with hindsight now how it might be construed in the way you
3 have suggested. But at the time when we were writing it we
4 were describing what happened when we received the letter on
5 June 20th.
6 Q. Well, it was worded that way because you and Ms. Brune had
7 had a discussion previously about what you were going to omit
8 from this brief, right?
9 A. No. The discussion I had with Ms. Brune was whether or not
10 we were going to say that prior to voir dire we had information
11 that there was a suspended lawyer named Catherine Conrad.
12 Q. And you agreed --
13 A. We discussed it in the context of what was the standard for
14 waiver, what was the standard for juror misconduct cases, which
15 was actual knowledge. I was not focused, when we were writing
16 the brief, I was not focused on waiver. We didn't know they
17 were the same person. We just were trying to actually
18 establish that they were the same person and that, it took me a
19 long time for me to believe that they were the same person.
20 I really was not thinking about waiver. I know that
21 may be difficult for you to believe now when you're taking a
22 brief and looking at every sentence and trying to impart some
23 meaning to it or an impression that we were trying to create.
24 But that's not how we were writing it.
25 Q. Can you just answer the question that I asked? You just
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010090
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