Case 1:20-cv-03363-PAE Document 616-2 Filed 08/24/22 Page 73 of 130 A-5762
305
C2grdau2 Brune - direct
1 A. There was no question that he did investigative work in the
2 wake of the letter, and I think that's laid out in our brief.
3 But he did no work pertaining to Juror No. 1 until we received
4 the letter.
5 Q. Is it your claim that the Nardello firm's work was
6 identified in your brief?
7 A. I think so. I think what our brief says is we hired a
8 private investigator. It lays out the materials that we
9 gathered.
10 Q. You didn't see fit to tell Judge Pauley on the conference
11 call, by the way, we had this investigative firm?
12 A. I was involved. I really think it is in the brief. I
13 could be mistaken, but I think it was in the brief. The
14 question was, who are your jury consultants, which is what Mr.
15 Schoeman and I were trying to respond to.
16 Q. The judge says he's trying to understand who was involved.
17 He didn't say which jury consultants. He was trying to
18 understand who was involved. Natdello was involved, correct?
19 MR. GAIR: I'm going to object to the compound form of
20 the question.
21 THE COURT: Sustained.
22 Q. You knew Nardello had done jury research, correct? It's a
23 very simple yes or no.
24 A. That is certainly so.
25 Q. It's a very simple question.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Full Text
Case 1:20-cv-03363-PAE Document 616-2 Filed 08/24/22 Page 73 of 130 A-5762
305
C2grdau2 Brune - direct
1 A. There was no question that he did investigative work in the
2 wake of the letter, and I think that's laid out in our brief.
3 But he did no work pertaining to Juror No. 1 until we received
4 the letter.
5 Q. Is it your claim that the Nardello firm's work was
6 identified in your brief?
7 A. I think so. I think what our brief says is we hired a
8 private investigator. It lays out the materials that we
9 gathered.
10 Q. You didn't see fit to tell Judge Pauley on the conference
11 call, by the way, we had this investigative firm?
12 A. I was involved. I really think it is in the brief. I
13 could be mistaken, but I think it was in the brief. The
14 question was, who are your jury consultants, which is what Mr.
15 Schoeman and I were trying to respond to.
16 Q. The judge says he's trying to understand who was involved.
17 He didn't say which jury consultants. He was trying to
18 understand who was involved. Natdello was involved, correct?
19 MR. GAIR: I'm going to object to the compound form of
20 the question.
21 THE COURT: Sustained.
22 Q. You knew Nardello had done jury research, correct? It's a
23 very simple yes or no.
24 A. That is certainly so.
25 Q. It's a very simple question.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
--- PAGE BREAK ---
C2grdau2 Brune - direct 305
1 A. There was no question that he did investigative work in the wake of the letter, and I think that's laid out in our brief.
2 But he did no work pertaining to Juror No. 1 until we received
3 the letter.
4 Q. Is it your claim that the Nardello firm's work was
5 identified in your brief?
6 A. I think so. I think what our brief says is we hired a
7 private investigator. It lays out the materials that we
8 gathered.
9 Q. You didn't see fit to tell Judge Pauley on the conference
10 call, by the way, we had this investigative firm?
11 A. I was involved. I really think it is in the brief. I
12 could be mistaken, but I think it was in the brief. The
13 question was, who are your jury consultants, which is what Mr.
14 Schoeman and I were trying to respond to.
15 Q. The judge says he's trying to understand who was involved.
16 He didn't say which jury consultants. He was trying to
17 understand who was involved. Natdello was involved, correct?
18 MR. GAIR: I'm going to object to the compound form of
19 the question.
20 THE COURT: Sustained.
21 Q. You knew Nardello had done jury research, correct? It's a
22 very simple yes or no.
23 A. That is certainly so.
24 Q. It's a very simple question.
25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
DOJ-OGR-00010045
Individual Pages
Page 73 - DOJ-OGR-00009366
Page 305 - DOJ-OGR-00010045
C2grdau2 Brune - direct 305
1 A. There was no question that he did investigative work in the wake of the letter, and I think that's laid out in our brief.
2 But he did no work pertaining to Juror No. 1 until we received
3 the letter.
4 Q. Is it your claim that the Nardello firm's work was
5 identified in your brief?
6 A. I think so. I think what our brief says is we hired a
7 private investigator. It lays out the materials that we
8 gathered.
9 Q. You didn't see fit to tell Judge Pauley on the conference
10 call, by the way, we had this investigative firm?
11 A. I was involved. I really think it is in the brief. I
12 could be mistaken, but I think it was in the brief. The
13 question was, who are your jury consultants, which is what Mr.
14 Schoeman and I were trying to respond to.
15 Q. The judge says he's trying to understand who was involved.
16 He didn't say which jury consultants. He was trying to
17 understand who was involved. Natdello was involved, correct?
18 MR. GAIR: I'm going to object to the compound form of
19 the question.
20 THE COURT: Sustained.
21 Q. You knew Nardello had done jury research, correct? It's a
22 very simple yes or no.
23 A. That is certainly so.
24 Q. It's a very simple question.
25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
DOJ-OGR-00010045