DOJ-OGR-00009368.pdf

--- Page 1 --- **Document Extraction** **Header:** Case 1:20-cv-003368PAB Document 6162 Filed 02/24/22 Page 79 of 130 A-5764 **Text:** CZgrdau2 Brune - direct doctrine protection for the work we had done. Q. You knew that those documents would significantly advance the government's position on the weaver issue, correct? A. No, because the July 21st letter says it out, lays it out accurately, including the fact that Ms. Trzaskoma had that initial thought that it was one and the same. Q. Are you referring to the "Jesus, I do think that it's her" email? A. Yes. Q. You met with Ms. Trzaskoma and Ms. Edelstein prior to this hearing, correct? A. We worked together. I've certainly talked with her on many occasions about the issues that are before the judge in this hearing. I'm testifying from my own best recollection, but I've certainly talked with them about the issues. Q. How many times did you meet with them to discuss this hearing? A. Never. What I'm saying is I've talked about the issues with them. We worked very hard on the July 21st letter to try to get it accurate, but we did not meet in preparation for this hearing. Q. So, you didn't discuss what your answers would be? A. I think that they know what my recollection is, and I think I know what their recollection is, because we worked so hard on the letter to reconstruct what had happened. **Footer:** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009368