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adieemmededandiimmmataly Wa 7+ Frc OAPP ab &teig 6 636F aifsrB0 294 C2grdau2z Brune — direct iL A. She certainly was aware of what had been done, that's 2 correct. 3 QO. Are you shying away from using the word "investigate" to 4 describe what it was that you and Mr. Benhamou and Mr. Kim and 5 Ms. Stapp were doing on the morning of May 12th? 6 A. It's not that I'm shying away. I just don’t think it is Tt accurate. To me "investigation" means more than looking at a 8 database search. What I think of as an investigation is what 9 we ended up doing once we received the jury letter. 10 0. You also stated in your memorandum at page 32 note 13 that 11 the defendants had no basis to inquire whether Conrad was lying 12 in response to the Court's questions, That is just wrong, Ms. 13 Brune, 14 A. I have I think already said that having reflected on all LS this, I think there are a number of things that I wish had been 16 said differently. What I was trying to convey to the Court in ar} the brief was the reality, which is that we didn't think it was 18 the same person and we were shocked when we received the note 19 and found out about the phone number matching. 20 Q. Had you seen the email traffic at that point in time when 21 you filed the brief, Ms. Brune? 22 A. No, I had not. 23 Q. But you know now that Ms. Trzaskoma knew about that email 24 traffic, correct? 25 A. She did. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010034