DOJ-OGR-00009351.pdf

--- Page 1 --- **Document Extraction** **Case Number and Page Information** * Case Number: C2GFDAU1 * Page Number: 290 * Total Pages: 130 **Header Information** * Case Number: C2GFDAU1 * Page Number: 290 * Total Pages: 130 **Footer Information** * Southern District Reporters, P.C. * Phone Number: (212) 805-0300 * Document ID: DOJ-OGR-00009351 **Transcript** * **C2GFDAU1** + **at any point.** + **Q. Now, when you got a copy of Ms. Conrad's letter to Mr. Okula, you subsequently had conversations with the defense counsel, correct?** + **A. I did.** + **Q. And did you tell them at or around that time what you previously found out?** + **A. The communications were joint defense communications. I don't mind answering the question so long as there's no contention that there's a broader waiver of the joint defense privilege and so long as no other party to the --** + **MR. GAIR: We have no objection, your Honor, on behalf of Mr. Daugeerdas.** + **A. I got the jury note, read it, very upset, set it aside.** + **Ms. Edelstein looked at the letter which had the phone number and went on the Bar website and saw that the phone number matched. We still --** + **Q. Can I stop you there, Ms. Brune?** + **A. Yes, I'm sorry, I'm trying to answer your question and you're right that it does not in the way that you want me to.** + **What I'm trying to say is it took us a couple of days after we received the note to communicate with our co-counsel.** + **(Continued next page)** **Note** * **SOUTHERN DISTRICT REPORTERS, P.C.** + **(212) 805-0300** **Document ID** * **DOJ-OGR-00009351**