Case 1:20-cr-00336-PAE Document 612 Filed 08/24/22 Page 49 of 130 A-5725
C2GFDAU1 Brune - direct 268
1 Q. That's based on your experience as a trial attorney, correct?
2 A. I certainly understand the voir dire process.
3 Q. And I take it one of your goals of jury selection, primary goal was to get jurors that you believed would be sympathetic to the case that you were going to be presenting to the jury, correct?
4 A. I believed in our case and I wanted to be sure to have jurors I thought would be attentive and understand the arguments we were presenting, and of course you want to find jurors who are more likely to be sympathetic or open minded to defense themes.
5 Q. And you try to eliminate jurors you don't like for whatever the reason, correct?
6 A. That's certainly right.
7 Q. And the more information that you have, I take it, the better you can shape or try to shape the jury, correct?
8 A. That's the reason for the database and Google efforts that I've described.
9 Q. And hiring the Nardello firm, correct?
10 A. The Nardello firm, as I explained, was for the database effort, correct.
11 Q. And Dennis Donahue as well?
12 A. Yes.
13 Q. And it's why you submitted a lengthy proposed juror
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
DOJ-OGR-00009329
Full Text
Case 1:20-cr-00336-PAE Document 612 Filed 08/24/22 Page 49 of 130 A-5725
C2GFDAU1 Brune - direct 268
1 Q. That's based on your experience as a trial attorney, correct?
2 A. I certainly understand the voir dire process.
3 Q. And I take it one of your goals of jury selection, primary goal was to get jurors that you believed would be sympathetic to the case that you were going to be presenting to the jury, correct?
4 A. I believed in our case and I wanted to be sure to have jurors I thought would be attentive and understand the arguments we were presenting, and of course you want to find jurors who are more likely to be sympathetic or open minded to defense themes.
5 Q. And you try to eliminate jurors you don't like for whatever the reason, correct?
6 A. That's certainly right.
7 Q. And the more information that you have, I take it, the better you can shape or try to shape the jury, correct?
8 A. That's the reason for the database and Google efforts that I've described.
9 Q. And hiring the Nardello firm, correct?
10 A. The Nardello firm, as I explained, was for the database effort, correct.
11 Q. And Dennis Donahue as well?
12 A. Yes.
13 Q. And it's why you submitted a lengthy proposed juror
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
DOJ-OGR-00009329
--- PAGE BREAK ---
C2GFDAU1 Brune - direct 268
1 Q. That's based on your experience as a trial attorney,
2 correct?
3 A. I certainly understand the voir dire process.
4 Q. And I take it one of your goals of jury selection, primary
5 goal was to get jurors that you believed would be sympathetic
6 to the case that you were going to be presenting to the jury,
7 correct?
8 A. I believed in our case and I wanted to be sure to have
9 jurors I thought would be attentive and understand the
10 arguments we were presenting, and of course you want to find
11 jurors who are more likely to be sympathetic or open minded to
12 defense themes.
13 Q. And you try to eliminate jurors you don't like for whatever
14 the reason, correct?
15 A. That's certainly right.
16 Q. And the more information that you have, I take it, the
17 better you can shape or try to shape the jury, correct?
18 A. That's the reason for the database and Google efforts that
19 I've described.
20 Q. And hiring the Nardello firm, correct?
21 A. The Nardello firm, as I explained, was for the database
22 effort, correct.
23 Q. And Dennis Donahue as well?
24 A. Yes.
25 Q. And it's why you submitted a lengthy proposed juror
(212) 805-0300
DOJ-OGR-00010008
Individual Pages
Page 49 - DOJ-OGR-00009329
Page 268 - DOJ-OGR-00010008
C2GFDAU1 Brune - direct 268
1 Q. That's based on your experience as a trial attorney,
2 correct?
3 A. I certainly understand the voir dire process.
4 Q. And I take it one of your goals of jury selection, primary
5 goal was to get jurors that you believed would be sympathetic
6 to the case that you were going to be presenting to the jury,
7 correct?
8 A. I believed in our case and I wanted to be sure to have
9 jurors I thought would be attentive and understand the
10 arguments we were presenting, and of course you want to find
11 jurors who are more likely to be sympathetic or open minded to
12 defense themes.
13 Q. And you try to eliminate jurors you don't like for whatever
14 the reason, correct?
15 A. That's certainly right.
16 Q. And the more information that you have, I take it, the
17 better you can shape or try to shape the jury, correct?
18 A. That's the reason for the database and Google efforts that
19 I've described.
20 Q. And hiring the Nardello firm, correct?
21 A. The Nardello firm, as I explained, was for the database
22 effort, correct.
23 Q. And Dennis Donahue as well?
24 A. Yes.
25 Q. And it's why you submitted a lengthy proposed juror
(212) 805-0300
DOJ-OGR-00010008