Case 1:20-cr-00336-PAE Document 616-2 Filed 08/24/22 Page 78 of 130 A-5763
C2grdau2 Brune - direct 306
1 A. Except by jury research I want to be sure you understand.
2 He had done this database work during jury selection but not
3 pertaining to the juror we were focused on in the call,
4 Catherine Conrad.
5 Q. That was the point you made before. That wasn't my
6 question. You had knowledge here that he did the jury search,
7 correct?
8 A. He certainly researched online about prospective jurors,
9 and then, after we got the letter, we retained him to do an
10 investigation about whether this was the same person.
11 Q. The judge on the July 22nd telephone call was clearly
12 trying to identify all the people who had been involved in that
13 process, correct?
14 MR. GAIR: Your Honor, I'm going to object to this
15 question.
16 THE COURT: Sustained.
17 Q. You didn't identify Mr. Nardello's firm to the judge on
18 that phonecall? Yes or no.
19 A. I did not on that phonecall talk about Mr. Nardello, you're
20 correct on that.
21 Q. Subsequently, the government requested discovery
22 specifically about what your firm knew, correct?
23 A. That's right.
24 Q. You strongly resisted that discovery, correct?
25 A. We filed a brief pertaining to our client's work product
(212) 805-0300
DOJ-OGR-00009367
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AEb4NmMJF2x5kcp19M13RiXZuAGyajWSKLaioqBrpump
Document A-5763
AI Analysis
Summary: The witness, Brune, testifies about their firm's involvement in jury research and investigation, including work done by Mr. Nardello's firm. Brune confirms that they did not disclose Nardello's firm's involvement to the judge during a phone call and resisted government discovery requests related to their firm's knowledge.
Significance: This document reveals details about the jury research and investigation conducted by the witness's firm and their resistance to government discovery requests.
Key Topics:
jury research and investigation
discovery process
involvement of Mr. Nardello's firm
Key People:
- Brune - witness being deposed
- Nardello - investigator or researcher hired by the witness's firm
- Catherine Conrad - juror or prospective juror being investigated
Full Text
Case 1:20-cr-00336-PAE Document 616-2 Filed 08/24/22 Page 78 of 130 A-5763
C2grdau2 Brune - direct 306
1 A. Except by jury research I want to be sure you understand.
2 He had done this database work during jury selection but not
3 pertaining to the juror we were focused on in the call,
4 Catherine Conrad.
5 Q. That was the point you made before. That wasn't my
6 question. You had knowledge here that he did the jury search,
7 correct?
8 A. He certainly researched online about prospective jurors,
9 and then, after we got the letter, we retained him to do an
10 investigation about whether this was the same person.
11 Q. The judge on the July 22nd telephone call was clearly
12 trying to identify all the people who had been involved in that
13 process, correct?
14 MR. GAIR: Your Honor, I'm going to object to this
15 question.
16 THE COURT: Sustained.
17 Q. You didn't identify Mr. Nardello's firm to the judge on
18 that phonecall? Yes or no.
19 A. I did not on that phonecall talk about Mr. Nardello, you're
20 correct on that.
21 Q. Subsequently, the government requested discovery
22 specifically about what your firm knew, correct?
23 A. That's right.
24 Q. You strongly resisted that discovery, correct?
25 A. We filed a brief pertaining to our client's work product
(212) 805-0300
DOJ-OGR-00009367
--- PAGE BREAK ---
C2grdau2 Brune - direct
1 A. Except by jury research I want to be sure understand.
2 He had done this database work during jury selection but not
3 pertaining to the juror we were focused on in the call,
4 Catherine Conrad.
5 Q. That was the point you made before. That wasn't my
6 question. You had knowledge here that he did the jury search,
7 correct?
8 A. He certainly researched online about prospective jurors,
9 and then, after we got the letter, we retained him to do an
10 investigation about whether this was the same person.
11 Q. The judge on the July 22nd telephone call was clearly
12 trying to identify all the people who had been involved in that
13 process, correct?
14 MR. GAIR: Your Honor, I'm going to object to this
15 question.
16 THE COURT: Sustained.
17 Q. You didn't identify Mr. Nardello's firm to the judge on
18 that phonecall? Yes or no.
19 A. I did not on that phonecall talk about Mr. Nardello, you're
20 correct on that.
21 Q. Subsequently, the government requested discovery
22 specifically about what your firm knew, correct?
23 A. That's right.
24 Q. You strongly resisted that discovery, correct?
25 A. We filed a brief pertaining to our client's work product
(212) 805-0300 SOUTHERN DISTRICT REPORTERS, P.C.
DOJ-OGR-00010046
Individual Pages
Page 78 - DOJ-OGR-00009367
Page 306 - DOJ-OGR-00010046
C2grdau2 Brune - direct
1 A. Except by jury research I want to be sure understand.
2 He had done this database work during jury selection but not
3 pertaining to the juror we were focused on in the call,
4 Catherine Conrad.
5 Q. That was the point you made before. That wasn't my
6 question. You had knowledge here that he did the jury search,
7 correct?
8 A. He certainly researched online about prospective jurors,
9 and then, after we got the letter, we retained him to do an
10 investigation about whether this was the same person.
11 Q. The judge on the July 22nd telephone call was clearly
12 trying to identify all the people who had been involved in that
13 process, correct?
14 MR. GAIR: Your Honor, I'm going to object to this
15 question.
16 THE COURT: Sustained.
17 Q. You didn't identify Mr. Nardello's firm to the judge on
18 that phonecall? Yes or no.
19 A. I did not on that phonecall talk about Mr. Nardello, you're
20 correct on that.
21 Q. Subsequently, the government requested discovery
22 specifically about what your firm knew, correct?
23 A. That's right.
24 Q. You strongly resisted that discovery, correct?
25 A. We filed a brief pertaining to our client's work product
(212) 805-0300 SOUTHERN DISTRICT REPORTERS, P.C.
DOJ-OGR-00010046