{
  "document_metadata": {
    "page_number": "73",
    "document_number": "A-5762",
    "date": "08/24/22",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cv-03363-PAE Document 616-2 Filed 08/24/22 Page 73 of 130 A-5762\n305\nC2grdau2 Brune - direct\n1 A. There was no question that he did investigative work in the\n2 wake of the letter, and I think that's laid out in our brief.\n3 But he did no work pertaining to Juror No. 1 until we received\n4 the letter.\n5 Q. Is it your claim that the Nardello firm's work was\n6 identified in your brief?\n7 A. I think so. I think what our brief says is we hired a\n8 private investigator. It lays out the materials that we\n9 gathered.\n10 Q. You didn't see fit to tell Judge Pauley on the conference\n11 call, by the way, we had this investigative firm?\n12 A. I was involved. I really think it is in the brief. I\n13 could be mistaken, but I think it was in the brief. The\n14 question was, who are your jury consultants, which is what Mr.\n15 Schoeman and I were trying to respond to.\n16 Q. The judge says he's trying to understand who was involved.\n17 He didn't say which jury consultants. He was trying to\n18 understand who was involved. Natdello was involved, correct?\n19 MR. GAIR: I'm going to object to the compound form of\n20 the question.\n21 THE COURT: Sustained.\n22 Q. You knew Nardello had done jury research, correct? It's a\n23 very simple yes or no.\n24 A. That is certainly so.\n25 Q. It's a very simple question.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "Case 1:20-cv-03363-PAE Document 616-2 Filed 08/24/22 Page 73 of 130 A-5762",
      "position": "header"
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    {
      "type": "printed",
      "content": "305\nC2grdau2 Brune - direct",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "1 A. There was no question that he did investigative work in the\n2 wake of the letter, and I think that's laid out in our brief.\n3 But he did no work pertaining to Juror No. 1 until we received\n4 the letter.\n5 Q. Is it your claim that the Nardello firm's work was\n6 identified in your brief?\n7 A. I think so. I think what our brief says is we hired a\n8 private investigator. It lays out the materials that we\n9 gathered.\n10 Q. You didn't see fit to tell Judge Pauley on the conference\n11 call, by the way, we had this investigative firm?\n12 A. I was involved. I really think it is in the brief. I\n13 could be mistaken, but I think it was in the brief. The\n14 question was, who are your jury consultants, which is what Mr.\n15 Schoeman and I were trying to respond to.\n16 Q. The judge says he's trying to understand who was involved.\n17 He didn't say which jury consultants. He was trying to\n18 understand who was involved. Natdello was involved, correct?\n19 MR. GAIR: I'm going to object to the compound form of\n20 the question.\n21 THE COURT: Sustained.\n22 Q. You knew Nardello had done jury research, correct? It's a\n23 very simple yes or no.\n24 A. That is certainly so.\n25 Q. It's a very simple question.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Brune",
      "Judge Pauley",
      "Mr. Schoeman",
      "Mr. Gair",
      "Natdello",
      "Nardello"
    ],
    "organizations": [
      "Nardello firm",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/24/22"
    ],
    "reference_numbers": [
      "1:20-cv-03363-PAE",
      "616-2",
      "A-5762"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}