Case 1:20-cv-10033-PAE Document 61-2 Filed 08/24/22 Page 78 of 130 A-5761
304
C2rdau2 Brune - direct
1 prompted us to doubt the voir dire and to investigate.
2 Q. One of the questions that the judge asked on the July 22nd
3 phonecall related to the jury consultants in this case,
4 correct?
5 A. That's right.
6 Q. You identified Mr. Donohue, correct?
7 A. That's right.
8 Q. I believe Mr. Gair also made some statements about Mr.
9 Donohue's relationship with his law firm, correct?
10 A. Right.
11 Q. Julie Blackman was identified, correct?
12 A. That's right.
13 Q. The Court specifically said that he was looking to
14 understand who was involved in the process, meaning the voir
15 dire process, between the time that the juror questionnaires
16 were completed and the time the voir dire commenced on March
17 1st. Do you recall that?
18 A. I looked back at the transcript in preparation for the
19 hearing. I think the Court in context was asking about the
20 jury consultants, which is Mr. Schoeman responded to the
21 Court's question by saying -- either he responded or it was in
22 the whole thing. We were talking about the jury consultants,
23 and Mr. Nardello was simply not a jury consultant.
24 Q. He did investigate work related to the very topic that the
25 judge had just indicated he was interested in, correct?
(212) 805-0300
SOUTHERN DISTRICT REPORTERS, P.C.
DOJ-OGR-00009365
Full Text
Case 1:20-cv-10033-PAE Document 61-2 Filed 08/24/22 Page 78 of 130 A-5761
304
C2rdau2 Brune - direct
1 prompted us to doubt the voir dire and to investigate.
2 Q. One of the questions that the judge asked on the July 22nd
3 phonecall related to the jury consultants in this case,
4 correct?
5 A. That's right.
6 Q. You identified Mr. Donohue, correct?
7 A. That's right.
8 Q. I believe Mr. Gair also made some statements about Mr.
9 Donohue's relationship with his law firm, correct?
10 A. Right.
11 Q. Julie Blackman was identified, correct?
12 A. That's right.
13 Q. The Court specifically said that he was looking to
14 understand who was involved in the process, meaning the voir
15 dire process, between the time that the juror questionnaires
16 were completed and the time the voir dire commenced on March
17 1st. Do you recall that?
18 A. I looked back at the transcript in preparation for the
19 hearing. I think the Court in context was asking about the
20 jury consultants, which is Mr. Schoeman responded to the
21 Court's question by saying -- either he responded or it was in
22 the whole thing. We were talking about the jury consultants,
23 and Mr. Nardello was simply not a jury consultant.
24 Q. He did investigate work related to the very topic that the
25 judge had just indicated he was interested in, correct?
(212) 805-0300
SOUTHERN DISTRICT REPORTERS, P.C.
DOJ-OGR-00009365
--- PAGE BREAK ---
C2rdau2 Brune - direct 304
1 prompted us to doubt the voir dire and to investigate.
2 Q. One of the questions that the judge asked on the July 22nd
3 phonecall related to the jury consultants in this case,
4 correct?
5 A. That's right.
6 Q. You identified Mr. Donohue, correct?
7 A. That's right.
8 Q. I believe Mr. Gair also made some statements about Mr.
9 Donohue's relationship with his law firm, correct?
10 A. Right.
11 Q. Julie Blackman was identified, correct?
12 A. That's right.
13 Q. The Court specifically said that he was looking to
14 understand who was involved in the process, meaning the voir
15 dire process, between the time that the juror questionnaires
16 were completed and the time the voir dire commenced on March
17 1st. Do you recall that?
18 A. I looked back at the transcript in preparation for the
19 hearing. I think the Court in context was asking about the
20 jury consultants, which is Mr. Schoeman responded to the
21 Court's question by saying -- either he responded or it was in
22 the whole thing. We were talking about the jury consultants,
23 and Mr. Nardello was simply not a jury consultant.
24 Q. He did investigate work related to the very topic that the
25 judge had just indicated he was interested in, correct?
(212) 805-0300
Individual Pages
Page 78 - DOJ-OGR-00009365
Page 304 - DOJ-OGR-00010044
C2rdau2 Brune - direct 304
1 prompted us to doubt the voir dire and to investigate.
2 Q. One of the questions that the judge asked on the July 22nd
3 phonecall related to the jury consultants in this case,
4 correct?
5 A. That's right.
6 Q. You identified Mr. Donohue, correct?
7 A. That's right.
8 Q. I believe Mr. Gair also made some statements about Mr.
9 Donohue's relationship with his law firm, correct?
10 A. Right.
11 Q. Julie Blackman was identified, correct?
12 A. That's right.
13 Q. The Court specifically said that he was looking to
14 understand who was involved in the process, meaning the voir
15 dire process, between the time that the juror questionnaires
16 were completed and the time the voir dire commenced on March
17 1st. Do you recall that?
18 A. I looked back at the transcript in preparation for the
19 hearing. I think the Court in context was asking about the
20 jury consultants, which is Mr. Schoeman responded to the
21 Court's question by saying -- either he responded or it was in
22 the whole thing. We were talking about the jury consultants,
23 and Mr. Nardello was simply not a jury consultant.
24 Q. He did investigate work related to the very topic that the
25 judge had just indicated he was interested in, correct?
(212) 805-0300