Document A-5767

Case 1:20-cr-00336-PAE Document 616 Filed 08/24/22 Page 82 of 130 A-5767 C2rdau2 Brune - cross 310 1 would have been very distracting and would have not made her a 2 good juror. Second, I have a great deal of faith in our jury 3 consultant, and he told us that he did not think it was a good 4 idea to have a recovering alcoholic on the jury. 5 Third, the most important thing that any juror is 6 supposed to do is follow the judge's instructions. If I had 7 known that a person was prepared to defy the Court by lying on 8 voir dire, I would never have had any confidence that the 9 person would follow the Court's instructions. So there's no 10 way that I wanted this person, if indeed she was a suspended 11 lawyer, to sit on this jury. 12 Q. Ms. Brune, would I be correct that your firm received Ms. 13 Conrad's letter to Mr. Okula approximately June 20th of 2011? 14 A. That's right. It was about three weeks after it was posted 15 to the government. 16 Q. At any time between the verdict in this case on May 24th 17 and the receipt of Ms. Conrad's letter on June 20th, had your 18 firm given any consideration to raising a juror misconduct 19 issue relating to Ms. Conrad as a basis for post-trial motions? 20 A. No. 21 Q. Why not? 22 A. I didn't think there had been juror misconduct. 23 Q. At any time during that same period did your firm give any 24 consideration to raising a juror misconduct issue as to Ms. 25 Conrad as an appellate issue? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009371 --- PAGE BREAK --- C2grdau2 Brune - cross 310 1 would have been very distracting and would have not made her a 2 good juror. Second, I have a great deal of faith in our jury 3 consultant, and he told us that he did not think it was a good 4 idea to have a recovering alcoholic on the jury. 5 Third, the most important thing that any juror is 6 supposed to do is follow the judge's instructions. If I had 7 known that a person was prepared to defy the Court by lying on 8 voir dire, I would never have had any confidence that the 9 person would follow the Court's instructions. So there's no 10 way that I wanted this person, if indeed she was a suspended 11 lawyer, to sit on this jury. 12 Q. Ms. Brune, would I be correct that your firm received Ms. 13 Conrad's letter to Mr. Okula approximately June 20th of 2011? 14 A. That's right. It was about three weeks after it was posted 15 to the government. 16 Q. At any time between the verdict in this case on May 24th 17 and the receipt of Ms. Conrad's letter on June 20th, had your 18 firm given any consideration to raising a juror misconduct 19 issue relating to Ms. Conrad as a basis for post-trial motions? 20 A. No. 21 Q. Why not? 22 A. I didn't think there had been juror misconduct. 23 Q. At any time during that same period did your firm give any 24 consideration to raising a juror misconduct issue as to Ms. 25 Conrad as an appellate issue? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300