DOJ-OGR-00009323.jpg
484 KB
Extraction Summary
4
People
1
Organizations
0
Locations
1
Events
2
Relationships
1
Quotes
Document Information
Type:
Deposition transcript
File Size:
484 KB
Summary
This document is a deposition transcript page where a witness named Brune recounts discussions about a potential juror, Catherine Conrad, during voir dire. A colleague named Theresa discovered a suspended lawyer with the same name, and a jury consultant advised striking Conrad from the jury, arguing that as a recovering alcoholic, she would likely focus more on personal responsibility than the government's burden of proof.
People (4)
| Name | Role | Context |
|---|---|---|
| Brune | Witness/Deponent |
The individual being questioned under direct examination.
|
| Catherine Conrad | Potential Juror |
A potential juror who was discovered to be a suspended lawyer and a recovering alcoholic, leading to a discussion abo...
|
| Theresa | Unknown |
An individual who used Google to find information that a suspended lawyer shared the name Catherine Conrad.
|
| Unnamed jury consultant | Jury Consultant |
Provided advice to strike Catherine Conrad from the jury, reasoning that as a recovering alcoholic, she would focus m...
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| SOUTHERN DISTRICT REPORTERS, P.C. | Company |
The court reporting agency that transcribed the deposition, listed at the bottom of the page.
|
Timeline (1 events)
A discussion occurred regarding potential juror Catherine Conrad. It was discovered via a Google search that a suspended lawyer had the same name. A jury consultant advised striking her, not due to the suspended license, but because her status as a recovering alcoholic might make her prioritize personal responsibility over the government's burden of proof.
Relationships (2)
Brune recounts receiving professional advice from the jury consultant regarding jury selection strategy.
Key Quotes (1)
"you do not want this lady on your jury because recovering alcoholic tends to be all about taking and imposing personal responsibility and that she'll be more focused on that than on the government's burden of proof, so if this is the same person you should strike her for cause and if that doesn't work you should get her off with a peremptory."Source
— Unnamed jury consultant
(Recalled by Brune as the advice given by the jury consultant on why Catherine Conrad should be removed from the jury pool.)
DOJ-OGR-00009323.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,751 characters)
Case 1:20-cr-00330-PAE Document 616-20 Filed 02/24/22 Page 34 of 130
A-5719
A-5719
C2GFDAU1
Brune - direct
262
Brune - direct
262
1 Q. What were those discussions?
2 A. We didn't have really any information about Catherine
3 Conrad. And I think it was sort of not on the list to search
4 because it was sort of a common name, and Theresa explained,
5 and I can't do this verbatim because at the time this was not
6 such a huge event, but I think Theresa explained that she had
7 gotten on Google, that she had found that there was a suspended
8 lawyer with the name Catherine Conrad and we were going to be
9 doing voir dire of this Catherine Conrad that day. So we
10 talked about it with the jury consultant, and I said something
11 to the jury consultant to the effect of, wow, this is very
12 interesting and odd, because the trial is going to be about the
13 law of economic substance and virtually every defendant in the
14 case has a law degree, and so which way does that cut?
15 And my best recollection is that the jury consultant
16 said you do not want this lady on your jury because
17 recovering alcoholic tends to be all about taking and imposing
18 personal responsibility and that she'll be more focused on that
19 than on the government's burden of proof, so if this is the
20 same person you should strike her for cause and if that doesn't
21 work you should get her off with a peremptory.
22 Q. Now, this opinion that your firm had in its hand had not
23 just a first name and last name but a middle initial, correct?
24 A. When you say in hand, I don't know that I ever saw the
25 thing and I certainly never saw a printout. But we certainly,
2 A. We didn't have really any information about Catherine
3 Conrad. And I think it was sort of not on the list to search
4 because it was sort of a common name, and Theresa explained,
5 and I can't do this verbatim because at the time this was not
6 such a huge event, but I think Theresa explained that she had
7 gotten on Google, that she had found that there was a suspended
8 lawyer with the name Catherine Conrad and we were going to be
9 doing voir dire of this Catherine Conrad that day. So we
10 talked about it with the jury consultant, and I said something
11 to the jury consultant to the effect of, wow, this is very
12 interesting and odd, because the trial is going to be about the
13 law of economic substance and virtually every defendant in the
14 case has a law degree, and so which way does that cut?
15 And my best recollection is that the jury consultant
16 said you do not want this lady on your jury because
17 recovering alcoholic tends to be all about taking and imposing
18 personal responsibility and that she'll be more focused on that
19 than on the government's burden of proof, so if this is the
20 same person you should strike her for cause and if that doesn't
21 work you should get her off with a peremptory.
22 Q. Now, this opinion that your firm had in its hand had not
23 just a first name and last name but a middle initial, correct?
24 A. When you say in hand, I don't know that I ever saw the
25 thing and I certainly never saw a printout. But we certainly,
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
(212) 805-0300
DOJ-OGR-00009323
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