Deposition Transcript: 1620ser1003309
The witness discusses their reaction to receiving a letter from a juror, which they found disturbing due to its tone and content. They mention discussing the letter with their partner Randy Kim and connecting it to information previously shared by Theresa Trzaskoma.
Summary
The witness discusses their reaction to receiving a letter from a juror, which they found disturbing due to its tone and content. They mention discussing the letter with their partner Randy Kim and connecting it to information previously shared by Theresa Trzaskoma.
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deposition transcript: A-5794
The deponent discusses receiving a letter from a juror and connects it to a previous conversation with Theresa Trzaskoma. The letter's tone and content are described as disturbing and odd, differing from the juror's observed behavior during the trial.
court transcript: A-5788
The witness testifies that they discussed a Westlaw report with their partner Randy Kim, but did not discuss it with Susan Brune or Theresa Trzaskoma. The witness also states they did not see certain email exchanges until after a court conference.
deposition transcript: A-5799
The witness testifies about their involvement in drafting a brief, discussions with Susan Brune about including certain facts, and the lack of discussion about sharing information with co-counsel. The witness edited the facts section of the brief and had a discussion with Susan Brune about whether to include certain facts.
court transcript: A-5919
The document appears to be a court transcript where the speaker is arguing that the defense counsel's decision not to disclose certain information about a juror was a deliberate strategy, and therefore, not ineffective assistance of counsel. The speaker references evidence and testimony that supports their claim. The discussion centers around the defense counsel's actions during voir dire and subsequent investigation regarding Juror No. 1.
transcript of a court hearing or deposition: A-5920
The document discusses the defense's decision not to disclose information about a juror during voir dire or after an investigation, and the government's argument that this was a tactical choice that cannot form the basis of ineffective assistance of counsel. The defense considered several alternatives but chose to do nothing. The government's view is that this conscious and deliberate choice was a strategic decision.
deposition transcript: A-5809
The witness is questioned about their firm's omissions and potential dishonesty, specifically regarding a phone call with the Court on July 15, and whether Theresa Trzaskoma was prepared for the call. The witness confirms their firm's omissions but denies knowledge of discussions about what Trzaskoma would disclose during the call.
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