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C2GFDAU1 Brune - direct 262
1 Q. What were those discussions?
2 A. We didn't have really any information about Catherine
3 Conrad. And I think it was sort of not on the list to search
4 because it was sort of a common name, and Theresa explained,
5 and I can't do this verbatim because at the time this was not
6 such a huge event, but I think Theresa explained that she had
7 gotten on Google, that she had found that there was a suspended
8 lawyer with the name Catherine Conrad and we were going to be
9 doing voir dire of this Catherine Conrad that day. So we
10 talked about it with the jury consultant, and I said something
11 to the jury consultant to the effect of, wow, this is very
12 interesting and odd, because the trial is going to be about the
13 law of economic substance and virtually every defendant in the
14 case has a law degree, and so which way does that cut?
15 And my best recollection is that the jury consultant
16 said you do not want this lady on your jury because a
17 recovering alcoholic tends to be all about taking and imposing
18 personal responsibility and that she'll be more focused on that
19 than on the government's burden of proof, so if this is the
20 same person you should strike her for cause and if that doesn't
21 work you should get her off with a peremptory.
22 Q. Now, this opinion that your firm had in its hand had not
23 just a first name and last name but a middle initial, correct?
24 A. When you say in hand, I don't know that I ever saw the
25 thing and I certainly never saw a printout. But we certainly,
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