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    "document_number": "Case 1:20-cr-00336-PAE Document 616-2 Filed 08/24/22 Page 79 of 130",
    "date": "08/24/22",
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  "full_text": "Case 1:20-cr-00336-PAE Document 616-2 Filed 08/24/22 Page 79 of 130 A-5764 307 C2grdau2 Brune - direct 1 doctrine protection for the work we had done. 2 Q. You knew that those documents would significantly advance 3 the government's position on the waiver issue, correct? 4 A. No, because the July 21st letter lays it out, lays it out 5 accurately, including the fact that Ms. Trzaskoma had that 6 initial thought that it was one and the same. 7 Q. Are you referring to the \"Jesus, I do think that it's her\" 8 email? 9 A. Yes. 10 Q. You met with Ms. Trzaskoma and Ms. Edelstein prior to this 11 hearing, correct? 12 A. We worked together. I've certainly talked with her on many 13 occasions about the issues that are before the judge in this 14 hearing. I'm testifying from my own best recollection, but 15 I've certainly talked with them about the issues. 16 Q. How many times did you meet with them to discuss this 17 hearing? 18 A. Never. What I'm saying is I've talked about the issues 19 with them. We worked very hard on the July 21st letter to try 20 to get it accurate, but we did not meet in preparation for this 21 hearing. 22 Q. So, you didn't discuss what your answers would be? 23 A. I think that they know what my recollection is, and I think 24 I know what their recollection is, because we worked so hard on 25 the letter to reconstruct what had happened. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009368",
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  "entities": {
    "people": [
      "Brune",
      "Trzaskoma",
      "Edelstein"
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
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