DOJ-OGR-00009486.pdf

--- Page 1 --- **Document Header** * **Case Number:** 120-cf-90330-PAE * **Document Number:** 616:620 * **Filing Date:** 2011-08-24 * **Page Number:** 67 of 117 * **Document Type:** A-5910 **Conversation Transcript** * **Page Number:** 8 * **Conversation Number:** 1 * **Speaker:** CAC3PARC * **Text:** "GAC3PARC conversation -- THE COURT: I'm really thinking about beyond the plaza conversation, at the time a month and a half later when they filed their motion, they failed to disclose the Court was they knew and when they knew it. And a series of proceedings then ensued, essentially initiated by both the Court and the government to find out what they knew and when they knew it. And their statements in their memorandum to the Court on their motion that they knew were wrong or misleading at the time that they made them to me. MR. SHECHTMAN: You're not going to get much argument from me on the point. The Court has a sort of lovely phrase in the opinion about disclosure by iteration or something like that. There is no doubt when you go from the telephone conversation to the document itself, and then to and not wanting further discovery, wanting your Honor to somehow address a preliminary issue and issues of privilege. Your Honor knows I got in this case late and the first thing I did was to say, what are we kidding ourselves? We are going to turn over those documents to the Court because worse comes to worst, the Court is going to look at them in camera. And if it is going to look at them in camera, it is going to look at them, I don't know you can say out of camera, but it's going to look at them. This is not a game. I think what happened, though, is lawyers said to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300" **Footer** * **Document ID:** DOJ-OGR-00009486