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  "full_text": "C2GFDAU3 Edelstein 343\n1 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.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00010083",
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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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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
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      "content": "DOJ-OGR-00010083",
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  "entities": {
    "people": [
      "Susan",
      "Theresa Trzaskoma",
      "Susan Brune",
      "Edelstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [],
    "reference_numbers": [
      "A-5800",
      "C2GFDAU3",
      "DOJ-OGR-00010083"
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}