Document A-5768

Case 1:20-cr-00336-PAE Document 616 Filed 08/24/22 Page 83 of 130 A-5768 311 C2grdau2 Brune - cross 1 A. No. 2 Q. I ask you the same question. Why not? 3 A. We spent a lot of time thinking about appellate issues, but 4 we didn't think that there had been juror misconduct and 5 therefore didn't think that there was an appellate issue. 6 Q. At any time between the verdict on May 24th and the receipt 7 of the letter on June 20th, did your firm contact the Nardello 8 firm to do additional investigation about Ms. Conrad? 9 A. No. 10 Q. Why not? 11 A. I didn't think there was anything to investigate. 12 Q. At any time during these proceedings, "these proceedings" 13 meaning between the initial voir dire and today, have you tried 14 to sandbag this Court or plant error in the record as to Juror 15 No. 1, Ms. Conrad? 16 A. No. 17 MR. SHECHTMAN: No further questions, Judge. 18 THE COURT: Redirect, Ms. Davis? 19 MR. DAVIS: I assume there is no other defense counsel 20 who wishes to inquire? 21 THE COURT: Does any defense counsel wish to inquire? 22 MR. GAIR: No, thank you, your Honor. 23 MR. ROTERT: No, thank you, Judge. 24 MS. McCARTHY: No, your Honor. 25 MR. DAVIS: Just briefly, your Honor. MR. DAVIS SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009372 --- PAGE BREAK --- C2grdau2 Brune - cross 311 1 A. No. 2 Q. I ask you the same question. Why not? 3 A. We spent a lot of time thinking about appellate issues, but 4 we didn't think that there had been juror misconduct and 5 therefore didn't think that there was an appellate issue. 6 Q. At any time between the verdict on May 24th and the receipt 7 of the letter on June 20th, did your firm contact the Nardello 8 firm to do additional investigation about Ms. Conrad? 9 A. No. 10 Q. Why not? 11 A. I didn't think there was anything to investigate. 12 Q. At any time during these proceedings, "these proceedings" 13 meaning between the initial voir dire and today, have you tried 14 to sandbag this Court or plant error in the record as to Juror 15 No. 1, Ms. Conrad? 16 A. No. 17 MR. SHECHTMAN: No further questions, Judge. 18 THE COURT: Redirect, Ms. Davis? 19 MR. DAVIS: I assume there is no other defense counsel 20 who wishes to inquire? 21 THE COURT: Does any defense counsel wish to inquire? 22 MR. GAIR: No, thank you, your Honor. 23 MR. ROTERT: No, thank you, Judge. 24 MS. McCARTHY: No, your Honor. 25 MR. DAVIS: Just briefly, your Honor. MR. DAVIS SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010051