Case 1:20-cr-00336-PAE Document 612 Filed 08/24/22 Page 43 of 130 A-5726
C2GFDAU1 Brune - direct 269
1 questionnaire, correct?
2 A. I did. I wanted as much information as we were able to get
3 about every prospective juror.
4 Q. Now, you understood that the voir dire process would be the
5 judge asking the questions of the potential jurors, correct?
6 A. I did, but I also understood that the Court would likely
7 ask other questions if we proposed them.
8 Q. So you understood that you could request of Judge Pauley to
9 further inquire?
10 A. Yes.
11 Q. And you also understood that sometimes jurors don't give a
12 full picture when they're giving the answers in response to
13 voir dire questions, correct?
14 A. Yes. I certainly think that it's something that's within
15 the realm of possibility that a juror might not be complete.
16 Q. And it's also possible, would you agree, during voir dire,
17 that you could ask the judge to inquire about a completely new
18 area if it occurs to you as the questioning is going on,
19 correct?
20 A. Sure.
21 Q. And it was the Court's decision, would you agree, whether or
22 not to ask any particular question.
23 A. Of course.
24 Q. It's not a decision that rests with you or the other
25 defense counsel, correct?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Full Text
Case 1:20-cr-00336-PAE Document 612 Filed 08/24/22 Page 43 of 130 A-5726
C2GFDAU1 Brune - direct 269
1 questionnaire, correct?
2 A. I did. I wanted as much information as we were able to get
3 about every prospective juror.
4 Q. Now, you understood that the voir dire process would be the
5 judge asking the questions of the potential jurors, correct?
6 A. I did, but I also understood that the Court would likely
7 ask other questions if we proposed them.
8 Q. So you understood that you could request of Judge Pauley to
9 further inquire?
10 A. Yes.
11 Q. And you also understood that sometimes jurors don't give a
12 full picture when they're giving the answers in response to
13 voir dire questions, correct?
14 A. Yes. I certainly think that it's something that's within
15 the realm of possibility that a juror might not be complete.
16 Q. And it's also possible, would you agree, during voir dire,
17 that you could ask the judge to inquire about a completely new
18 area if it occurs to you as the questioning is going on,
19 correct?
20 A. Sure.
21 Q. And it was the Court's decision, would you agree, whether or
22 not to ask any particular question.
23 A. Of course.
24 Q. It's not a decision that rests with you or the other
25 defense counsel, correct?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
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C2GFDAU1 Brune - direct 269
1 questionnaire, correct?
2 A. I did. I wanted as much information as we were able to get
3 about every prospective juror.
4 Q. Now, you understood that the voir dire process would be the
5 judge asking the questions of the potential jurors, correct?
6 A. I did, but I also understood that the Court would likely
7 ask other questions if we proposed them.
8 Q. So you understood that you could request of Judge Pauley to
9 further inquire?
10 A. Yes.
11 Q. And you also understood that sometimes jurors don't give a
12 full picture when they're giving the answers in response to
13 voir dire questions, correct?
14 A. Yes. I certainly think that it's something that's within
15 the realm of possibility that a juror might not be complete.
16 Q. And it's also possible, would you agree, during voir dire,
17 that you could ask the judge to inquire about a completely new
18 area if it occurs to you as the questioning is going on,
19 correct?
20 A. Sure.
21 Q. And it was the Court's decision, would you agree, whether or
22 not to ask any particular question.
23 A. Of course.
24 Q. It's not a decision that rests with you or the other
25 defense counsel, correct?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010009
Individual Pages
Page 43 - DOJ-OGR-00009330
Page 269 - DOJ-OGR-00010009
C2GFDAU1 Brune - direct 269
1 questionnaire, correct?
2 A. I did. I wanted as much information as we were able to get
3 about every prospective juror.
4 Q. Now, you understood that the voir dire process would be the
5 judge asking the questions of the potential jurors, correct?
6 A. I did, but I also understood that the Court would likely
7 ask other questions if we proposed them.
8 Q. So you understood that you could request of Judge Pauley to
9 further inquire?
10 A. Yes.
11 Q. And you also understood that sometimes jurors don't give a
12 full picture when they're giving the answers in response to
13 voir dire questions, correct?
14 A. Yes. I certainly think that it's something that's within
15 the realm of possibility that a juror might not be complete.
16 Q. And it's also possible, would you agree, during voir dire,
17 that you could ask the judge to inquire about a completely new
18 area if it occurs to you as the questioning is going on,
19 correct?
20 A. Sure.
21 Q. And it was the Court's decision, would you agree, whether or
22 not to ask any particular question.
23 A. Of course.
24 Q. It's not a decision that rests with you or the other
25 defense counsel, correct?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010009