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    "page_number": "34",
    "document_number": "Case 1:20-cr-00336-PAE Document 616-2 Filed 08/24/22 Page 34 of 130",
    "date": "08/24/22",
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  "full_text": "Case 1:20-cr-00336-PAE Document 616-2 Filed 08/24/22 Page 34 of 130 A-5719 262 C2GFDAU1 Brune - direct Q. What were those discussions? A. We didn't have really any information about Catherine Conrad. And I think it was sort of not on the list to search because it was sort of a common name, and Theresa explained, and I can't do this verbatim because at the time this was not such a huge event, but I think Theresa explained that she had gotten on Google, that she had found that there was a suspended lawyer with the name Catherine Conrad and we were going to be doing voir dire of this Catherine Conrad that day. So we talked about it with the jury consultant, and I said something to the jury consultant to the effect of, wow, this is very interesting and odd, because the trial is going to be about the law of economic substance and virtually every defendant in the case has a law degree, and so which way does that cut? And my best recollection is that the jury consultant said you do not want this lady on your jury because a 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. Q. Now, this opinion that your firm had in its hand had not just a first name and last name but a middle initial, correct? A. When you say in hand, I don't know that I ever saw the thing and I certainly never saw a printout. But we certainly, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009323",
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      "content": "Case 1:20-cr-00336-PAE Document 616-2 Filed 08/24/22 Page 34 of 130 A-5719 262 C2GFDAU1 Brune - direct Q. What were those discussions? A. We didn't have really any information about Catherine Conrad. And I think it was sort of not on the list to search because it was sort of a common name, and Theresa explained, and I can't do this verbatim because at the time this was not such a huge event, but I think Theresa explained that she had gotten on Google, that she had found that there was a suspended lawyer with the name Catherine Conrad and we were going to be doing voir dire of this Catherine Conrad that day. So we talked about it with the jury consultant, and I said something to the jury consultant to the effect of, wow, this is very interesting and odd, because the trial is going to be about the law of economic substance and virtually every defendant in the case has a law degree, and so which way does that cut? And my best recollection is that the jury consultant said you do not want this lady on your jury because a 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. Q. Now, this opinion that your firm had in its hand had not just a first name and last name but a middle initial, correct? A. When you say in hand, I don't know that I ever saw the thing and I certainly never saw a printout. But we certainly,",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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  "entities": {
    "people": [
      "Catherine Conrad",
      "Theresa",
      "Brune"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/24/22"
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    "reference_numbers": [
      "Case 1:20-cr-00336-PAE",
      "Document 616-2",
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      "DOJ-OGR-00009323"
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}