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- "page_number": "305",
- "document_number": "A-5762",
- "date": null,
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- "full_text": "C2grdau2 Brune - direct 305\n1 A. There was no question that he did investigative work in the wake of the letter, and I think that's laid out in our brief.\n2 But he did no work pertaining to Juror No. 1 until we received\n3 the letter.\n4 Q. Is it your claim that the Nardello firm's work was\n5 identified in your brief?\n6 A. I think so. I think what our brief says is we hired a\n7 private investigator. It lays out the materials that we\n8 gathered.\n9 Q. You didn't see fit to tell Judge Pauley on the conference\n10 call, by the way, we had this investigative firm?\n11 A. I was involved. I really think it is in the brief. I\n12 could be mistaken, but I think it was in the brief. The\n13 question was, who are your jury consultants, which is what Mr.\n14 Schoeman and I were trying to respond to.\n15 Q. The judge says he's trying to understand who was involved.\n16 He didn't say which jury consultants. He was trying to\n17 understand who was involved. Natdello was involved, correct?\n18 MR. GAIR: I'm going to object to the compound form of\n19 the question.\n20 THE COURT: Sustained.\n21 Q. You knew Nardello had done jury research, correct? It's a\n22 very simple yes or no.\n23 A. That is certainly so.\n24 Q. It's a very simple question.\n25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00010045",
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- "content": "1 A. There was no question that he did investigative work in the wake of the letter, and I think that's laid out in our brief.\n2 But he did no work pertaining to Juror No. 1 until we received\n3 the letter.\n4 Q. Is it your claim that the Nardello firm's work was\n5 identified in your brief?\n6 A. I think so. I think what our brief says is we hired a\n7 private investigator. It lays out the materials that we\n8 gathered.\n9 Q. You didn't see fit to tell Judge Pauley on the conference\n10 call, by the way, we had this investigative firm?\n11 A. I was involved. I really think it is in the brief. I\n12 could be mistaken, but I think it was in the brief. The\n13 question was, who are your jury consultants, which is what Mr.\n14 Schoeman and I were trying to respond to.\n15 Q. The judge says he's trying to understand who was involved.\n16 He didn't say which jury consultants. He was trying to\n17 understand who was involved. Natdello was involved, correct?\n18 MR. GAIR: I'm going to object to the compound form of\n19 the question.\n20 THE COURT: Sustained.\n21 Q. You knew Nardello had done jury research, correct? It's a\n22 very simple yes or no.\n23 A. That is certainly so.\n24 Q. It's a very simple question.",
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- "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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- "content": "DOJ-OGR-00010045",
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- "entities": {
- "people": [
- "Judge Pauley",
- "Mr. Schoeman",
- "Mr. Gair",
- "Nardello",
- "Natdello"
- ],
- "organizations": [
- "Nardello firm",
- "SOUTHERN DISTRICT REPORTERS, P.C."
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- "locations": [],
- "dates": [],
- "reference_numbers": [
- "A-5762",
- "DOJ-OGR-00010045"
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