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    "page_number": "302",
    "document_number": "A-5759",
    "date": null,
    "document_type": "Court Transcript",
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  "full_text": "C2grdau2 Brune - direct 302\n1 government and the Court accurately when the issue was\n2 presented.\n3 Q. Is that the ethical standard that governed you when you\n4 were an AUSA, Ms. Brune?\n5 A. That I was supposed to raise the other side's point in my\n6 brief when I didn't know what position they were taking? I\n7 don't think that governs any Assistant U.S. Attorney.\n8 Q. No, I think it is really more that you were willing to lay\n9 out the accurate set of facts if and only if the government\n10 would ask you to do so.\n11 A. We've already talked about the brief and how I in some\n12 respects missed the issue, which I regret. Of course, both\n13 defense counsel AUSA's are obliged to lay things out for the\n14 court accurately. It is something that throughout my career I\n15 have always strived to do.\n16 Q. But for the Court's pressing and the government's pressing,\n17 you would have never disclosed those facts to the government,\n18 isn't that right, Ms. Brune?\n19 A. If the government chose not to raise the waiver issue, and\n20 as I thought about it I actually thought that the government\n21 had far more information or at least had access to far more\n22 information, my sense at the time was that the government had\n23 probably Googled her, too. But I thought that if the\n24 government chose to make it an issue, I was prepared to respond\n25 and respond accurately, which I tried very hard to do.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00010042",
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      "content": "C2grdau2 Brune - direct 302",
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      "type": "printed",
      "content": "1 government and the Court accurately when the issue was\n2 presented.\n3 Q. Is that the ethical standard that governed you when you\n4 were an AUSA, Ms. Brune?\n5 A. That I was supposed to raise the other side's point in my\n6 brief when I didn't know what position they were taking? I\n7 don't think that governs any Assistant U.S. Attorney.\n8 Q. No, I think it is really more that you were willing to lay\n9 out the accurate set of facts if and only if the government\n10 would ask you to do so.\n11 A. We've already talked about the brief and how I in some\n12 respects missed the issue, which I regret. Of course, both\n13 defense counsel AUSA's are obliged to lay things out for the\n14 court accurately. It is something that throughout my career I\n15 have always strived to do.\n16 Q. But for the Court's pressing and the government's pressing,\n17 you would have never disclosed those facts to the government,\n18 isn't that right, Ms. Brune?\n19 A. If the government chose not to raise the waiver issue, and\n20 as I thought about it I actually thought that the government\n21 had far more information or at least had access to far more\n22 information, my sense at the time was that the government had\n23 probably Googled her, too. But I thought that if the\n24 government chose to make it an issue, I was prepared to respond\n25 and respond accurately, which I tried very hard to do.",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010042",
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  ],
  "entities": {
    "people": [
      "Brune",
      "Ms. Brune"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "Department of Justice"
    ],
    "locations": [],
    "dates": [],
    "reference_numbers": [
      "A-5759",
      "DOJ-OGR-00010042"
    ]
  },
  "additional_notes": "The document appears to be a court transcript. The text is clear and legible, with no visible redactions or damage."
}