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Document A-5730

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C2GFDAU1 Brune - direct 273 1 instances, correct, Ms. Brune? 2 A. I think you know what I did is I listened to the voir dire 3 that the juror gave and her answers and I credited her answers. 4 Q. Well, that wasn't my question, Ms. Brune. My question was, 5 you can acquire knowledge by asking questions, correct? 6 A. I certainly cannot disagree with you. One way of acquiring 7 knowledge is to ask questions. 8 Q. Did you tell the other defense counsel about the suspension 9 opinion that you all had found? 10 A. During voir dire, I don't believe that we did. 11 Q. And at some point in time, and correct me if I'm wrong, but 12 I believe based on something I think you said in court that 13 all the defense counsel met with Dennis Donahue prior to voir 14 dire or prior to the actual selection of the jury? 15 A. Prior to the actual selection of the jury, all defense 16 counsel did meet with Dennis Donahue. 17 Q. And you could have raised it at that point in time with the 18 other defense counsel, correct? 19 A. And had I believed it was the same person I certainly would 20 have. 21 Q. But you could have? 22 A. Oh, I certainly could have raised that this was information 23 that I had discarded as not pertaining to the prospective 24 juror, which would be true of a whole host of other information 25 that we discarded. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010013