Document A-5763

Case 1:20-cr-00336-PAE Document 616-2 Filed 08/24/22 Page 78 of 130 A-5763 C2grdau2 Brune - direct 306 1 A. Except by jury research I want to be sure you understand. 2 He had done this database work during jury selection but not 3 pertaining to the juror we were focused on in the call, 4 Catherine Conrad. 5 Q. That was the point you made before. That wasn't my 6 question. You had knowledge here that he did the jury search, 7 correct? 8 A. He certainly researched online about prospective jurors, 9 and then, after we got the letter, we retained him to do an 10 investigation about whether this was the same person. 11 Q. The judge on the July 22nd telephone call was clearly 12 trying to identify all the people who had been involved in that 13 process, correct? 14 MR. GAIR: Your Honor, I'm going to object to this 15 question. 16 THE COURT: Sustained. 17 Q. You didn't identify Mr. Nardello's firm to the judge on 18 that phonecall? Yes or no. 19 A. I did not on that phonecall talk about Mr. Nardello, you're 20 correct on that. 21 Q. Subsequently, the government requested discovery 22 specifically about what your firm knew, correct? 23 A. That's right. 24 Q. You strongly resisted that discovery, correct? 25 A. We filed a brief pertaining to our client's work product (212) 805-0300 DOJ-OGR-00009367 --- PAGE BREAK --- C2grdau2 Brune - direct 1 A. Except by jury research I want to be sure understand. 2 He had done this database work during jury selection but not 3 pertaining to the juror we were focused on in the call, 4 Catherine Conrad. 5 Q. That was the point you made before. That wasn't my 6 question. You had knowledge here that he did the jury search, 7 correct? 8 A. He certainly researched online about prospective jurors, 9 and then, after we got the letter, we retained him to do an 10 investigation about whether this was the same person. 11 Q. The judge on the July 22nd telephone call was clearly 12 trying to identify all the people who had been involved in that 13 process, correct? 14 MR. GAIR: Your Honor, I'm going to object to this 15 question. 16 THE COURT: Sustained. 17 Q. You didn't identify Mr. Nardello's firm to the judge on 18 that phonecall? Yes or no. 19 A. I did not on that phonecall talk about Mr. Nardello, you're 20 correct on that. 21 Q. Subsequently, the government requested discovery 22 specifically about what your firm knew, correct? 23 A. That's right. 24 Q. You strongly resisted that discovery, correct? 25 A. We filed a brief pertaining to our client's work product (212) 805-0300 SOUTHERN DISTRICT REPORTERS, P.C. DOJ-OGR-00010046