Document A-5721

Case 1:20-cv-10033-PAE Document 61-02 Filed 08/24/22 Page 38 of 130 A-5721 C2GFDAU1 264 Brune - direct 1 A. Well, not necessarily all at once, but we certainly had 2 resources and I certainly did not ask that more be done 3 awaiting the answers from the prospective juror on voir dire. 4 Q. And you could have told the Court at that point, correct? 5 A. I certainly could have said to the Court that there is a 6 Google search out there that reveals that there's a suspended 7 lawyer by the name of Catherine Conrad. 8 Q. And you didn't do that? 9 A. I did not do that. 10 Q. Now you appreciated, it sounds to me just from what you 11 said, pretty instantly, that this is potentially significant 12 information, correct? 13 A. If it's the same person, it's very significant information. 14 I certainly appreciated that. 15 Q. No one -- you didn't require anyone to have to explain that 16 to you, correct? 17 A. No. I mean, we had a lot of Google-type information on a 18 lot of jurors and, you know, it's a big metropolitan area. 19 Some of that -- 20 Q. Ms. Brune, I asked you a very specific question. 21 A. Can -- 22 Q. You did not require anybody else to explain to you the 23 significance of that information. Is that true? 24 A. If that's your question, the answer is no, I did not ask 25 anyone to do any further research. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009325 --- PAGE BREAK --- C2GFDAU1 Brune - direct 264 1 A. Well, not necessarily all at once, but we certainly had 2 resources and I certainly did not ask that more be done 3 awaiting the answers from the prospective juror on voir dire. 4 Q. And you could have told the Court at that point, correct? 5 A. I certainly could have said to the Court that there is a 6 Google search out there that reveals that there's a suspended 7 lawyer by the name of Catherine Conrad. 8 Q. And you didn't do that? 9 A. I did not do that. 10 Q. Now you appreciated, it sounds to me just from what you 11 said, pretty instantly, that this is potentially significant 12 information, correct? 13 A. If it's the same person, it's very significant information. 14 I certainly appreciated that. 15 Q. No one -- you didn't require anyone to have to explain that 16 to you, correct? 17 A. No. I mean, we had a lot of Google-type information on a 18 lot of jurors and, you know, it's a big metropolitan area. 19 Some of that -- 20 Q. Ms. Brune, I asked you a very specific question. 21 A. Can -- 22 Q. You did not require anybody else to explain to you the 23 significance of that information. Is that true? 24 A. If that's your question, the answer is no, I did not ask 25 anyone to do any further research. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010004