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Document A-5715

AI Analysis

Summary: The witness, Brune, discusses the role of the Nardello firm in researching potential jurors using database research, and the involvement of Suann Ingle in creating graphics for the case. Brune clarifies that the Nardello firm's instructions were to limit their research to database work only.
Significance: This document is potentially important as it reveals details about the defense team's preparation and research on potential jurors, as well as the roles of various team members.
Key Topics: Research on potential jurors Role of the Nardello firm in the case Team members involved in the case preparation
Key People:
  • Brune - Witness being deposed
  • Nardello - Head of the Nardello firm, involved in juror research
  • Suann Ingle - Member of the defense team, responsible for graphics and PowerPoint presentation
Document Type
Court Filing
Date
02/24/22
Pages
2
Folder
IMAGES004

Full Text

Case 1:20-cr-00338-PAE Document 1616-2 Filed 02/24/22 Page 30 of 130 A-5715 258 C2GFDAU1 Brune - direct 1 research about the jurors in this case, is that correct, 2 potential jurors? 3 A. That was one of the things that he did for us. And to be 4 clear, when I say research, what I'm talking about is accessing 5 computer databases concerning the jurors. There was a 6 relatively short period to accomplish that, and so a 7 combination of the paralegal team and the Nardello firm 8 accomplished that. 9 Q. And are you distinguishing that from, say, out in the field 10 work, going to visit people, talking to them? 11 A. Yes. His specific instructions were that no one should 12 leave his office, that it was to be simply database research. 13 Q. And were those your instructions? 14 A. Those were my instructions, although I think Mr. Nardello 15 is an ethical man and I don't think he would have done 16 otherwise, but I wanted to be very clear with him. 17 Q. You also had Suann Ingle of Ingle Communications work on 18 your team? 19 A. Yes. 20 Q. What was her role for your team? 21 A. Suann did graphics for the opening statement and the 22 closing statement and perhaps some for Dr. DeRosa, and in 23 addition she was in court to just sort of play the PowerPoint 24 during the opening and the closing. 25 Q. So she was one of the people along the wall, is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009319 --- PAGE BREAK --- C2GFDAU1 Brune - direct 258 1 research about the jurors in this case, is that correct, 2 potential jurors? 3 A. That was one of the things that he did for us. And to be 4 clear, when I say research, what I'm talking about is accessing 5 computer databases concerning the jurors. There was a 6 relatively short period to accomplish that, and so a 7 combination of the paralegal team and the Nardello firm 8 accomplished that. 9 Q. And are you distinguishing that from, say, out in the field 10 work, going to visit people, talking to them? 11 A. Yes. His specific instructions were that no one should 12 leave his office, that it was to be simply database research. 13 Q. And were those your instructions? 14 A. Those were my instructions, although I think Mr. Nardello 15 is an ethical man and I don't think he would have done 16 otherwise, but I wanted to be very clear with him. 17 Q. You also had Suann Ingle of Ingle Communications work on 18 your team? 19 A. Yes. 20 Q. What was her role for your team? 21 A. Suann did graphics for the opening statement and the 22 closing statement and perhaps some for Dr. DeRosa, and in 23 addition she was in court to just sort of play the PowerPoint 24 during the opening and the closing. 25 Q. So she was one of the people along the wall, is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009998

Individual Pages

Page 30 - DOJ-OGR-00009319
Case 1:20-cr-00338-PAE Document 1616-2 Filed 02/24/22 Page 30 of 130 A-5715 258 C2GFDAU1 Brune - direct 1 research about the jurors in this case, is that correct, 2 potential jurors? 3 A. That was one of the things that he did for us. And to be 4 clear, when I say research, what I'm talking about is accessing 5 computer databases concerning the jurors. There was a 6 relatively short period to accomplish that, and so a 7 combination of the paralegal team and the Nardello firm 8 accomplished that. 9 Q. And are you distinguishing that from, say, out in the field 10 work, going to visit people, talking to them? 11 A. Yes. His specific instructions were that no one should 12 leave his office, that it was to be simply database research. 13 Q. And were those your instructions? 14 A. Those were my instructions, although I think Mr. Nardello 15 is an ethical man and I don't think he would have done 16 otherwise, but I wanted to be very clear with him. 17 Q. You also had Suann Ingle of Ingle Communications work on 18 your team? 19 A. Yes. 20 Q. What was her role for your team? 21 A. Suann did graphics for the opening statement and the 22 closing statement and perhaps some for Dr. DeRosa, and in 23 addition she was in court to just sort of play the PowerPoint 24 during the opening and the closing. 25 Q. So she was one of the people along the wall, is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009319
Page 258 - DOJ-OGR-00009998
C2GFDAU1 Brune - direct 258 1 research about the jurors in this case, is that correct, 2 potential jurors? 3 A. That was one of the things that he did for us. And to be 4 clear, when I say research, what I'm talking about is accessing 5 computer databases concerning the jurors. There was a 6 relatively short period to accomplish that, and so a 7 combination of the paralegal team and the Nardello firm 8 accomplished that. 9 Q. And are you distinguishing that from, say, out in the field 10 work, going to visit people, talking to them? 11 A. Yes. His specific instructions were that no one should 12 leave his office, that it was to be simply database research. 13 Q. And were those your instructions? 14 A. Those were my instructions, although I think Mr. Nardello 15 is an ethical man and I don't think he would have done 16 otherwise, but I wanted to be very clear with him. 17 Q. You also had Suann Ingle of Ingle Communications work on 18 your team? 19 A. Yes. 20 Q. What was her role for your team? 21 A. Suann did graphics for the opening statement and the 22 closing statement and perhaps some for Dr. DeRosa, and in 23 addition she was in court to just sort of play the PowerPoint 24 during the opening and the closing. 25 Q. So she was one of the people along the wall, is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009998