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C2GFDAU1 Brune - direct 260
1 from voir dire all the way through the verdict, right?
2 A. Yes.
3 Q. Now, Ms. Brune, you are an officer of this court, correct?
4 A. I am.
5 Q. And as an officer of the court you have ethical
6 obligations, correct?
7 A. I do indeed.
8 Q. And you have an obligation to be truthful to the Court?
9 A. Yes.
10 Q. And you have an obligation to promptly disclose to the
11 court any information that you might have suggesting juror
12 misconduct, correct?
13 A. I don't agree with your characterization. I had an ethical
14 obligation to bring whatever material that I thought was
15 accurate to the Court and that's what I tried to do throughout
16 the trial.
17 Q. On May 12, 2011, you received information, significant
18 information that related potentially to Juror No. 1, correct?
19 A. On May 12 I had a discussion with Theresa Trzaskoma in
20 which she described her sort of wondering whether the juror who
21 had sent that note referring to respondeat superior and
22 vicarious liability was the lawyer whom she'd earlier located
23 by a Google search. I don't think that I received significant
24 information, but I did have a conversation with Ms. Trzaskoma
25 about the note, which was at that point new to us.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010000