DOJ-OGR-00009432.pdf

--- Page 1 --- **Document Extraction** **Header:** * Case: 1:20-cf-00330-PAE * Document Number: 616320 * Filed: 02/24/22 * Page: 13 of 117 * A-5828 **Body:** * **C2grdau4** * **Berke - cross** * **371** * **1** **other obligations. I never will act on a piece of information that I think invokes my duties as an advocate for my client as well as an officer of the court without first looking at the rules. I will read the rules. As we all know, at times you will read the rules, they will be absolutely clear what my obligations are. Sometimes they will be less clear and we will research it. That's what I do. I never act on information until I do that, and I've never done that on that issue. That's what I can tell you.** * **Q. I don't think you answered my question, though. Can you answer the question that I asked? If you formed a belief as an attorney in a courtroom that a juror has engaged in misconduct, do you have to bring that to the attention of the court?** * **A. What I can tell you is if I had confronted that issue --** * **Q. Is this another one that you can't answer yes or no?** * **A. I'm going to answer your question.** * **Q. Would you do that.** * **A. I will. What I will tell you is my reaction to that information if I confronted it would be that I believe I have an obligation to tell the court. Before I did anything, though, I would do exactly what I said. I would look at the rule, look at the law, and make sure I was complying with all my obligations.** * **Q. Did Susan Brune explain to you why she felt it important to bring the information to your attention that her firm had** * **SOUTHERN DISTRICT REPORTERS, P.C.** * **(212) 805-0300** **Footer:** * **DOJ-OGR-00009432**