mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010043.json

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  "full_text": "C2grdau2 Brune - direct 303\n1 Q. The question was that you were willing to provide a\n2 complete and accurate set of facts if and only if the\n3 government asked, is that what you are saying?\n4 A. No, that's not what I'm saying at all. I tried very hard\n5 to be accurate in the brief that we submitted. It has the\n6 shortcomings that we have talked about.\n7 Q. It has material omissions, Ms. Brune?\n8 A. I certainly have tried to be accurate.\n9 Q. It has material omissions, correct?\n10 A. I do not believe that it was written with the goal of\n11 making a material omission. I believed then and believe now\n12 that the standard is actual knowledge. We did not have actual\n13 knowledge or anything near that. We were shocked when we\n14 received the letter.\n15 Q. It has material omissions in it?\n16 MR. SHECHTMAN: Asked and answered.\n17 MR. DAVIS: No, I don't believe she has answered it,\n18 your Honor.\n19 THE COURT: Overruled.\n20 A. I did not believe that it had material omissions in the\n21 sense that anyone writing the brief or in my case signing the\n22 brief intended to make material omissions. I think that what\n23 we were trying to do was we were trying to describe the post-\n24 letter investigation that we undertook and we were trying to\n25 convey what is accurate, which is that it was the letter that\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00010043",
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      "content": "1 Q. The question was that you were willing to provide a\n2 complete and accurate set of facts if and only if the\n3 government asked, is that what you are saying?\n4 A. No, that's not what I'm saying at all. I tried very hard\n5 to be accurate in the brief that we submitted. It has the\n6 shortcomings that we have talked about.\n7 Q. It has material omissions, Ms. Brune?\n8 A. I certainly have tried to be accurate.\n9 Q. It has material omissions, correct?\n10 A. I do not believe that it was written with the goal of\n11 making a material omission. I believed then and believe now\n12 that the standard is actual knowledge. We did not have actual\n13 knowledge or anything near that. We were shocked when we\n14 received the letter.\n15 Q. It has material omissions in it?\n16 MR. SHECHTMAN: Asked and answered.\n17 MR. DAVIS: No, I don't believe she has answered it,\n18 your Honor.\n19 THE COURT: Overruled.\n20 A. I did not believe that it had material omissions in the\n21 sense that anyone writing the brief or in my case signing the\n22 brief intended to make material omissions. I think that what\n23 we were trying to do was we were trying to describe the post-\n24 letter investigation that we undertook and we were trying to\n25 convey what is accurate, which is that it was the letter that",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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    "people": [
      "Ms. Brune",
      "MR. SHECHTMAN",
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