DOJ-OGR-00009365.pdf

Case 1:20-cv-10033-PAE Document 61-2 Filed 08/24/22 Page 78 of 130 A-5761 304 C2rdau2 Brune - direct 1 prompted us to doubt the voir dire and to investigate. 2 Q. One of the questions that the judge asked on the July 22nd 3 phonecall related to the jury consultants in this case, 4 correct? 5 A. That's right. 6 Q. You identified Mr. Donohue, correct? 7 A. That's right. 8 Q. I believe Mr. Gair also made some statements about Mr. 9 Donohue's relationship with his law firm, correct? 10 A. Right. 11 Q. Julie Blackman was identified, correct? 12 A. That's right. 13 Q. The Court specifically said that he was looking to 14 understand who was involved in the process, meaning the voir 15 dire process, between the time that the juror questionnaires 16 were completed and the time the voir dire commenced on March 17 1st. Do you recall that? 18 A. I looked back at the transcript in preparation for the 19 hearing. I think the Court in context was asking about the 20 jury consultants, which is Mr. Schoeman responded to the 21 Court's question by saying -- either he responded or it was in 22 the whole thing. We were talking about the jury consultants, 23 and Mr. Nardello was simply not a jury consultant. 24 Q. He did investigate work related to the very topic that the 25 judge had just indicated he was interested in, correct? (212) 805-0300 SOUTHERN DISTRICT REPORTERS, P.C. DOJ-OGR-00009365