Document A-5715

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