Document A-5724

Case 1:20-cr-00336-PAE Document 616 Filed 08/24/22 Page 39 of 130 A-5724 C2GFDAU1 Brune - direct 267 1 A. My primary method of narrowing the information was to 2 listen to the sworn testimony on voir dire. But certainly if 3 what your question is could I have launched some kind of full 4 scale private investigative effort on each member of the voir 5 dire or each seated juror, I did not do that. 6 Q. Did you even ask Ms. Trzaskoma what was the middle initial? 7 Because you had a middle initial, correct? 8 A. I did not ask that question. 9 Q. That would have been one way to narrow down the 10 information, correct? 11 A. You know, when you say you had the middle initial, I'm 12 answering the firm had the middle initial. As to whether Ms. 13 Trzaskoma was focusing on the middle initial at that point, I 14 don't know, but I did not focus on the middle initial until 15 after the juror sent her letter to the government and then 16 three weeks later the government disclosed it to us. 17 Q. Well, when you're asking -- I mean, I think you said that 18 Nardello did not search Catherine Conrad, correct? 19 A. That's so. 20 Q. You had a Catherine M. Conrad of Bronxville, that was what 21 was on the juror list, correct? 22 A. That's my understanding now. 23 Q. And in voir dire you understood going into, before it ever 24 started, what the process is all about, correct? 25 A. I did. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009328 --- PAGE BREAK --- C2GFDAU1 Brune - direct 1 A. My primary method of narrowing the information was to 2 listen to the sworn testimony on voir dire. But certainly if 3 what your question is could I have launched some kind of full 4 scale private investigative effort on each member of the voir 5 dire or each seated juror, I did not do that. 6 Q. Did you even ask Ms. Trzaskoma what was the middle initial? 7 Because you had a middle initial, correct? 8 A. I did not ask that question. 9 Q. That would have been one way to narrow down the 10 information, correct? 11 A. You know, when you say you had the middle initial, I'm 12 answering the firm had the middle initial. As to whether Ms. 13 Trzaskoma was focusing on the middle initial at that point, I 14 don't know, but I did not focus on the middle initial until 15 after the juror sent her letter to the government and then 16 three weeks later the government disclosed it to us. 17 Q. Well, when you're asking -- I mean, I think you said that 18 Nardello did not search Catherine Conrad, correct? 19 A. That's so. 20 Q. You had a Catherine M. Conrad of Bronxville, that was what 21 was on the juror list, correct? 22 A. That's my understanding now. 23 Q. And in voir dire you understood going into, before it ever 24 started, what the process is all about, correct? 25 A. I did. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300