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    "page_number": "145",
    "document_number": "1:20-cv-03308",
    "date": "02/24/22",
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  "full_text": "Case 1:20-cv-03308 Document 615 Filed 02/24/22 Page 145 of 130 A-5800 C2GFDAU3 Edelstein 343 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 DOJ-OGR-00009404",
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      "content": "C2GFDAU3 Edelstein 343",
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      "content": "1 Q. Who initiated that discussion?\n2 A. I can't recall who initiated it. I think Susan and I were\n3 discussing the brief and how we should structure it, and --\n4 Q. Stop right there. Did that conversation occur before or\n5 after you received the draft of the brief from Theresa\n6 Trzaskoma?\n7 A. Before.\n8 Q. So you and Susan Brune then specifically discussed about\n9 what you should say about your level of knowledge before you\n10 received the note, is that correct?\n11 A. Yes.\n12 Q. And what was the ultimate decision that was made?\n13 A. Well, after some discussion and then reviewing the case law\n14 about the state of knowledge involved regarding the juror\n15 misconduct issue and potential waiver, and seeing that actual\n16 knowledge was the standard, we decided that the fact that we\n17 knew that there was a suspended lawyer with the same name, we\n18 did need to address that in the brief and that the focus of the\n19 brief was to be on whether they were the same person, because\n20 at that point I wasn't even sure they were the same person and\n21 trying to convince everyone else they were the same person. I\n22 didn't think people were going to actually believe us.\n23 Q. You ultimately edited the fact section of the brief,\n24 correct?\n25 A. Yes.",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00009404",
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  "entities": {
    "people": [
      "Susan",
      "Theresa Trzaskoma",
      "Susan Brune"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "02/24/22"
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    "reference_numbers": [
      "1:20-cv-03308",
      "615",
      "A-5800",
      "C2GFDAU3",
      "DOJ-OGR-00009404"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}