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Case cetiideetieemaieaeniay Wr, - 1 maneeumaameniadel of 130 260 C2GFDAU1 Brune — direct 1 from voir dire all the way through the verdict, right? 2 A. Yes. 3 Q. Now, Ms. Brune, you are an officer of this court, correct? 4 A. I am. os Q. And as an officer of the court you have ethical 6 obligations, correct? 7 A. I do indeed. 8 QO. And you have an obligation to be truthful to the Court? 9 A. Yes. 10 Q. And you have an obligation to promptly disclose to the 11 court any information that you might have suggesting juror 12 misconduct, correct? 13 A. I don't agree with your characterization. I had an ethical 14 obligation to bring whatever material that I thought was 15 accurate to the Court and that's what I tried to do throughout 16 the trial. cig | Q. On May 12, 2011, you received information, significant 18 information that related potentially to Juror No. 1, correct? 19 A, On May 12 I had a discussion with Theresa Trzaskoma in 20 which she described her sort of wondering whether the juror who 21 had sent that note referring to respondeat superior and 22 vicarious liability was the lawyer whom she'd earlier located 23 by a Google search. I don't think that I received significant 24 information, but I did have a conversation with Ms, Trzaskoma 25 about the note, which was at that point new to us, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR- 00009321