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Document A-5719
AI Analysis
Summary: The witness discusses a conversation about Catherine Conrad, a potential juror, and how the jury consultant advised striking her due to her background as a recovering alcoholic. The witness also mentions that the potential juror's name matched that of a suspended lawyer, which was considered during the voir dire process.
Significance: This document reveals the thought process behind the jury selection process and the discussion around Catherine Conrad, a potential juror with the same name as a suspended lawyer.
Key Topics:
Discussion about Catherine Conrad, a potential juror
Voir dire and jury selection process
Jury consultant's opinion on Catherine Conrad
Key People:
- Theresa - Person who researched Catherine Conrad
- Catherine Conrad - Potential juror
- The jury consultant - Provided opinion on Catherine Conrad
Full Text
C2GFDAU1 Brune - direct 262
1 Q. What were those discussions?
2 A. We didn't have really any information about Catherine
3 Conrad. And I think it was sort of not on the list to search
4 because it was sort of a common name, and Theresa explained,
5 and I can't do this verbatim because at the time this was not
6 such a huge event, but I think Theresa explained that she had
7 gotten on Google, that she had found that there was a suspended
8 lawyer with the name Catherine Conrad and we were going to be
9 doing voir dire of this Catherine Conrad that day. So we
10 talked about it with the jury consultant, and I said something
11 to the jury consultant to the effect of, wow, this is very
12 interesting and odd, because the trial is going to be about the
13 law of economic substance and virtually every defendant in the
14 case has a law degree, and so which way does that cut?
15 And my best recollection is that the jury consultant
16 said you do not want this lady on your jury because a
17 recovering alcoholic tends to be all about taking and imposing
18 personal responsibility and that she'll be more focused on that
19 than on the government's burden of proof, so if this is the
20 same person you should strike her for cause and if that doesn't
21 work you should get her off with a peremptory.
22 Q. Now, this opinion that your firm had in its hand had not
23 just a first name and last name but a middle initial, correct?
24 A. When you say in hand, I don't know that I ever saw the
25 thing and I certainly never saw a printout. But we certainly,
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010002