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C2GFDAU1 Brune - direct 263
1 Ms. Trzaskoma certainly accessed it on the computer, and I now
2 know that that opinion or decision includes the middle initial.
3 Q. And it was the identical name, Catherine M. Conrad, that
4 appeared on the potential juror list that the clerk's office
5 provided, correct?
6 A. I now know that to be so.
7 Q. Well, and that opinion was not just any suspension opinion,
8 it was a New York court opinion, correct?
9 A. That's right.
10 Q. And you could have asked your team prior to the start of
11 voir dire to do additional research on this issue, correct?
12 A. I certainly could have.
13 Q. And you chose not to?
14 A. I don't think I put it that way. The plan was to hear from
15 her on voir dire and find out based on her answers to Judge
16 Pauley whether she was the same person.
17 Q. Well, you didn't do it, correct, Ms. Brune?
18 A. If the question is --
19 Q. It's a simple question.
20 A. I know, and I'm trying really hard to answer it.
21 Q. It's really a yes or no. Did you or did you not ask any of
22 your team prior to voir dire to do additional research?
23 A. Oh, I did not. That's absolutely so.
24 Q. You had everybody, you had a team of literally almost two
25 dozen people available to you, correct?
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
DOJ-OGR-00010003