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Document A-5717
AI Analysis
Summary: The deposition involves questioning Ms. Brune about her role as an officer of the court and her obligations to disclose information about potential juror misconduct. Ms. Brune discusses a conversation she had with Theresa Trzaskoma regarding Juror No. 1 and a note related to legal concepts. The questioning highlights a potential issue with the timeliness and nature of Ms. Brune's disclosure to the court.
Significance: This deposition is potentially important because it reveals the witness's understanding of their ethical obligations and their actions regarding potential juror misconduct, which could impact the validity of a trial verdict.
Key Topics:
Ethical obligations of an officer of the court
Disclosure of information regarding juror misconduct
Discussion about Juror No. 1 and potential misconduct
Key People:
- Ms. Brune - Witness being deposed, officer of the court
- Theresa Trzaskoma - Person who had a discussion with Ms. Brune about Juror No. 1
Full Text
C2GFDAU1 Brune - direct 260
1 from voir dire all the way through the verdict, right?
2 A. Yes.
3 Q. Now, Ms. Brune, you are an officer of this court, correct?
4 A. I am.
5 Q. And as an officer of the court you have ethical
6 obligations, correct?
7 A. I do indeed.
8 Q. And you have an obligation to be truthful to the Court?
9 A. Yes.
10 Q. And you have an obligation to promptly disclose to the
11 court any information that you might have suggesting juror
12 misconduct, correct?
13 A. I don't agree with your characterization. I had an ethical
14 obligation to bring whatever material that I thought was
15 accurate to the Court and that's what I tried to do throughout
16 the trial.
17 Q. On May 12, 2011, you received information, significant
18 information that related potentially to Juror No. 1, correct?
19 A. On May 12 I had a discussion with Theresa Trzaskoma in
20 which she described her sort of wondering whether the juror who
21 had sent that note referring to respondeat superior and
22 vicarious liability was the lawyer whom she'd earlier located
23 by a Google search. I don't think that I received significant
24 information, but I did have a conversation with Ms. Trzaskoma
25 about the note, which was at that point new to us.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010000