DOJ-OGR-00010087.json 4.0 KB

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  3. "page_number": "1310",
  4. "document_number": "A-5804",
  5. "date": "03/20/2022",
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  10. "full_text": "Case#: 2020-0130338-AE No Document 64402 Filed 03/20/22 Page# 1310 of 3080\nA-5804\n347\nCZGFDAU3 Edelstein\n1 A. Simply because there are two different addresses.\n2 Q. Now, could I ask you to look at page 32, footnote 13. And\n3 specifically the last sentence of that footnote. Do you see\n4 where it says, \"Defendants had no basis to inquire whether\n5 Conrad was lying in response to each of the Court's\n6 questions,\" do you see that?\n7 A. Yes.\n8 Q. Do you think that was an accurate statement, Ms. Edelstein?\n9 A. Yes.\n10 Q. Were you aware that Theresa Trzaskoma had been, had\n11 discovered the Appellate Division suspension report at that\n12 time with the name Catherine Conrad?\n13 A. I was aware that Theresa, when we were writing the brief I\n14 was aware that Theresa had known that there was an Appellate\n15 Division order.\n16 Q. And would you turn to page 9 and look at the first full\n17 paragraph there. Would you read that first sentence aloud for\n18 us?\n19 A. \"The tone and content of the letter, which were in sharp\n20 contrast to the image Conrad had projected through the trial,\n21 always head down, taking notes, caused defendants concern and\n22 prompted them to investigate.\"\n23 Q. Well, you were aware when that sentence went into the final\n24 version of the brief, that Theresa Trzaskoma had already done a\n25 bit of investigation, correct?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00010087",
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  24. "content": "347\nCZGFDAU3 Edelstein\n1 A. Simply because there are two different addresses.\n2 Q. Now, could I ask you to look at page 32, footnote 13. And\n3 specifically the last sentence of that footnote. Do you see\n4 where it says, \"Defendants had no basis to inquire whether\n5 Conrad was lying in response to each of the Court's\n6 questions,\" do you see that?\n7 A. Yes.\n8 Q. Do you think that was an accurate statement, Ms. Edelstein?\n9 A. Yes.\n10 Q. Were you aware that Theresa Trzaskoma had been, had\n11 discovered the Appellate Division suspension report at that\n12 time with the name Catherine Conrad?\n13 A. I was aware that Theresa, when we were writing the brief I\n14 was aware that Theresa had known that there was an Appellate\n15 Division order.\n16 Q. And would you turn to page 9 and look at the first full\n17 paragraph there. Would you read that first sentence aloud for\n18 us?\n19 A. \"The tone and content of the letter, which were in sharp\n20 contrast to the image Conrad had projected through the trial,\n21 always head down, taking notes, caused defendants concern and\n22 prompted them to investigate.\"\n23 Q. Well, you were aware when that sentence went into the final\n24 version of the brief, that Theresa Trzaskoma had already done a\n25 bit of investigation, correct?",
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  38. "entities": {
  39. "people": [
  40. "Edelstein",
  41. "Theresa Trzaskoma",
  42. "Catherine Conrad",
  43. "Conrad"
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  45. "organizations": [
  46. "SOUTHERN DISTRICT REPORTERS, P.C.",
  47. "Appellate Division"
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  50. "dates": [
  51. "03/20/22"
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  54. "2020-0130338-AE",
  55. "64402",
  56. "A-5804",
  57. "DOJ-OGR-00010087"
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