DOJ-OGR-00009404.jpg
436 KB
Extraction Summary
5
People
2
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Deposition transcript
File Size:
436 KB
Summary
This document is page 343 of a deposition transcript involving a witness named Edelstein (likely regarding the Ghislaine Maxwell trial, given the context of juror misconduct). The testimony details legal strategy discussions between Edelstein and Susan Brune regarding a juror who shared a name with a suspended lawyer. They discussed how to address their knowledge of this potential identity match in a legal brief drafted by Theresa Trzaskoma.
People (5)
| Name | Role | Context |
|---|---|---|
| Edelstein | Witness/Deponent |
Answering questions regarding legal strategy and brief drafting.
|
| Susan Brune | Attorney/Colleague |
Discussed brief structure and juror misconduct strategy with Edelstein.
|
| Theresa Trzaskoma | Attorney |
Sent a draft of the brief to the witness.
|
| Juror | Subject of discussion |
Discussed in relation to misconduct and potential identity issues.
|
| Suspended Lawyer | Subject of discussion |
Individual with the same name as the juror.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Southern District Reporters, P.C. |
Court reporting firm.
|
|
| DOJ |
Department of Justice (implied by Bates stamp DOJ-OGR).
|
Timeline (1 events)
Unspecified
Relationships (2)
Discussed legal strategy and brief drafting together.
Trzaskoma provided a draft brief to Edelstein.
Key Quotes (3)
"we decided that the fact that we knew that there was a suspended lawyer with the same name, we did need to address that in the brief"Source
DOJ-OGR-00009404.jpg
Quote #1
"at that point I wasn't even sure they were the same person and trying to convince everyone else they were the same person."Source
DOJ-OGR-00009404.jpg
Quote #2
"I didn't think people were going to actually believe us."Source
DOJ-OGR-00009404.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,427 characters)
Case 1:20-cv-03330-PAE Document 616-2 Filed 02/24/22 Page 115 of 130
A-5800
A-5800
343
C2GFDAU3 Edelstein
1 Q. Who initiated that discussion?
2 A. I can't recall who initiated it. I think Susan and I were
3 discussing the brief and how we should structure it, and --
4 Q. Stop right there. Did that conversation occur before or
5 after you received the draft of the brief from Theresa
6 Trzaskoma?
7 A. Before.
8 Q. So you and Susan Brune then specifically discussed about
9 what you should say about your level of knowledge before you
10 received the note, is that correct?
11 A. Yes.
12 Q. And what was the ultimate decision that was made?
13 A. Well, after some discussion and then reviewing the case law
14 about the state of knowledge involved regarding the juror
15 misconduct issue and potential waiver, and seeing that actual
16 knowledge was the standard, we decided that the fact that we
17 knew that there was a suspended lawyer with the same name, we
18 did need to address that in the brief and that the focus of the
19 brief was to be on whether they were the same person, because
20 at that point I wasn't even sure they were the same person and
21 trying to convince everyone else they were the same person. I
22 didn't think people were going to actually believe us.
23 Q. You ultimately edited the fact section of the brief,
24 correct?
25 A. Yes.
C2GFDAU3 Edelstein
1 Q. Who initiated that discussion?
2 A. I can't recall who initiated it. I think Susan and I were
3 discussing the brief and how we should structure it, and --
4 Q. Stop right there. Did that conversation occur before or
5 after you received the draft of the brief from Theresa
6 Trzaskoma?
7 A. Before.
8 Q. So you and Susan Brune then specifically discussed about
9 what you should say about your level of knowledge before you
10 received the note, is that correct?
11 A. Yes.
12 Q. And what was the ultimate decision that was made?
13 A. Well, after some discussion and then reviewing the case law
14 about the state of knowledge involved regarding the juror
15 misconduct issue and potential waiver, and seeing that actual
16 knowledge was the standard, we decided that the fact that we
17 knew that there was a suspended lawyer with the same name, we
18 did need to address that in the brief and that the focus of the
19 brief was to be on whether they were the same person, because
20 at that point I wasn't even sure they were the same person and
21 trying to convince everyone else they were the same person. I
22 didn't think people were going to actually believe us.
23 Q. You ultimately edited the fact section of the brief,
24 correct?
25 A. Yes.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
(212) 805-0300
DOJ-OGR-00009404
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