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Cébas@AROAS URE PAN 1 BemorReniGie 0 FeSO DAP ab &hey 6464 dfS080 OwoiuisTg wn fw Me A-5749 292 C2grdau2 Brune —- direct A... That's: right. ®. It was filed under your signature? A. It was. Q. With your ECF number? A. That"s so. QO. You were ultimately responsible for the factual assertions in that brief, correct? A. Yes. I reviewed it and I signed it and I am responsible for it. Q. That set of facts was not accurate and complete, was it, Ms. Brune? A. When I reflect on that brief, and I certainly have done so repeatedly and at length, it's the thing that I regret. What I mean by that is we kind of missed it. There were two things that were going on. One is we were spending a lot of energy trying to persuade ourselves that what we were going to say to the judge was right, that is, that there was this fraud that happened, and we were very focused on not having Mr. Parse's application kicked out the way that it was kicked out in Martha Stewart for not sort of having proved it enough. I certainly thought about the waiver issue. But what I really missed is I thought that the government would likely inquire and we would say we didn't know, because we didn't know. I certainly never imagined that the reality that we did not know was going to assume the sort of debate level SOUTHERN DISTRICT REPORTERS, P.C, (212) 805-0300 DOJ-OGR-00010032