DOJ-OGR-00010112.pdf

C2grdau4 Berke - cross 372 1 learned about the juror or believed or the connection between 2 the juror? 3 A. No. I think I have told you the substance of what I recall 4 of that conversation. 5 Q. She didn't explain in any fashion why she thought it was 6 important to tell you at that period of time? 7 A. No. 8 Q. Did she tell you anything else that her firm had learned 9 that gave rise to the belief by one of their attorneys that 10 there was a connection between Juror No. 1 and the suspended 11 New York attorney? 12 A. No. 13 Q. Did she tell you any of the underlying facts? 14 A. No. The only other thing that I recall is that when 15 talking about the note, we both noted that we believed that 16 Juror 1 had said she had been a plaintiff in a personal injury 17 case, which might explain the respondeat superior. I can't say 18 for certain it was in that identical conversation, I believe it 19 was probably was, but I do remember talking about that as well. 20 Q. Let me ask you this. If you had learned from somebody at 21 the Brune firm that they had a written report showing somebody 22 named Catherine Conrad had a personal injury or had a private 23 lawsuit, would that be a piece of information that you would 24 want to have had at the time in order to do your own analysis? 25 A. Just to be clear, what I'm referring to, I believe the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010112