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Document A-5830

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C2rdau4 Berke - cross 373 1 juror herself had said in response to a question about other 2 litigation that she had been involved in a personal injury 3 case. That's what I'm referring to. 4 Q. Right. My question to you is, would that information as 5 background, if Susan Brune came to you and told you that we not 6 only found a Catherine Conrad who was a suspended lawyer but we 7 also found a Catherine Conrad who was involved in a personal 8 injury lawsuit, is that something that you would have wanted to 9 know at the time? 10 A. I'm not sure I understand. We knew that Catherine Conrad 11 had said that she was involved in a personal injury suit. We 12 knew that from her answers in the voir dire. 13 Q. If you saw a piece of paper that connected Catherine Conrad 14 who was Juror No. 1 and Catherine Conrad who was a personal 15 injury lawyer and a suspended attorney who had the same address 16 as the person involved in the lawsuit, would that have been of 17 interest to you? 18 A. You know, I really am not comfortable speculating. What I 19 can tell you is I told you what I knew. I did not believe that 20 the person who had been a disbarred lawyer could have been or 21 was this Juror No. 1 based on what I knew. That's really all I 22 can tell you. 23 Q. So, your answer to my direct question is that you can't 24 answer the question? 25 A. Well, I would object if I was sitting over there, but I'm SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010113