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    "page_number": "346",
    "document_number": "A-5803",
    "date": null,
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  "full_text": "C2GFDAU3 Edelstein 346\n1 knew beforehand in the brief, right?\n2 A. No, that's not accurate.\n3 Q. Didn't you tell us a few moments ago that you and Ms. Brune\n4 had specifically decided that you were not going to include\n5 what your firm knew prior to receiving the government letter in\n6 your brief, yes or no?\n7 A. Yes.\n8 Q. So are you saying, then, that you were not trying to convey\n9 the notion through the facts section of your brief that you had\n10 learned of the Appellate Division report only after you had\n11 received the letter from the government?\n12 A. No, we weren't trying to convey that impression.\n13 MR. OKULA: May I have a moment, your Honor?\n14 THE COURT: Take your time.\n15 (Pause)\n16 Q. Could you turn to Government Exhibit -- I'm sorry, it's defense Exhibit PMD 54. Do you recognize that document?\n17 A. Yes.\n18 Q. What is it?\n19 A. It's the brief that we submitted in support of the motion\n20 for a new trial.\n21 Q. Can you explain, why does your firm sign it twice? In\n22 other words, why do you include it on the front page separate\n23 and apart from Susan Brune in New York and you in San\n24 Francisco?\n25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00010086",
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      "content": "1 knew beforehand in the brief, right?\n2 A. No, that's not accurate.\n3 Q. Didn't you tell us a few moments ago that you and Ms. Brune\n4 had specifically decided that you were not going to include\n5 what your firm knew prior to receiving the government letter in\n6 your brief, yes or no?\n7 A. Yes.\n8 Q. So are you saying, then, that you were not trying to convey\n9 the notion through the facts section of your brief that you had\n10 learned of the Appellate Division report only after you had\n11 received the letter from the government?\n12 A. No, we weren't trying to convey that impression.\n13 MR. OKULA: May I have a moment, your Honor?\n14 THE COURT: Take your time.\n15 (Pause)\n16 Q. Could you turn to Government Exhibit -- I'm sorry, it's defense Exhibit PMD 54. Do you recognize that document?\n17 A. Yes.\n18 Q. What is it?\n19 A. It's the brief that we submitted in support of the motion\n20 for a new trial.\n21 Q. Can you explain, why does your firm sign it twice? In\n22 other words, why do you include it on the front page separate\n23 and apart from Susan Brune in New York and you in San\n24 Francisco?",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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  "entities": {
    "people": [
      "Edelstein",
      "Ms. Brune",
      "Susan Brune",
      "MR. OKULA"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [
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      "San Francisco"
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    "reference_numbers": [
      "C2GFDAU3",
      "A-5803",
      "PMD 54",
      "DOJ-OGR-00010086"
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