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C2GFDAU1 Brune - direct 256
1 A. Nancy is a paralegal from the San Francisco office.
2 Q. You also had someone with the title of managing clerk, is
3 that correct?
4 A. Correct.
5 Q. What does the managing clerk do for your office?
6 A. He is, he works primarily on the civil side, and is
7 responsible for making sure that our filings go in properly.
8 He also sort of the last check on any brief that goes
9 in, and he just helps out in any way on to sort of make sure
10 things get to court and get filed properly.
11 Q. What's his name?
12 A. Ken Renta.
13 Q. And you also, I take it, have secretaries and other
14 administrative staff at your firm, correct?
15 A. We have one secretary at the firm.
16 Q. And with regard to this specific case, you also hired
17 outside help, is that correct?
18 A. Can you explain? By "help," do you mean were there
19 contract lawyers or some other kind of help you're thinking of?
20 Q. Let's talk about the jury consultants.
21 A. Okay.
22 Q. Did you specifically hire a jury consultant for this case?
23 A. I hired Dennis Donahue.
24 Q. And Mr. Donahue was present during voir dire, correct?
25 A. He was.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009996