Document 1:20-cv-03038-PAE

Case 1:20-cv-03038-PAE Document 616-1 Filed 02/24/22 Page 23 of 117 A-5817 C2grdau4 Schoeman - direct 360 1 which we concluded the summations in the case, yes. 2 Q. Do you recall the subject matter of that note? 3 A. I recall in general that there was a question regarding respondeat superior. 4 Q. Again just to be clear, what stage was the trial at? 5 A. I believe that that was after all of the summations had 6 been concluded, I think including the rebuttal summation. 7 8 Q. Do you know a lawyer named Theresa Trzaskoma? 9 A. I do. 10 Q. How do you know her? 11 A. I think I first met Ms. Trzaskoma in approximately 2,000. 12 My babysitter and her babysitter became friends. Being a 13 first- time parent, I did a little diligence on the parents of 14 my 3 month old's playmate and learned that it was Ms. Trzaskoma 15 and her husband. We became family friends at that point. 16 Q. I'm loathe to ask this question, but you Googled her? 17 A. Actually, I think I knew her husband, who had been an 18 associate with me at Paul Weiss and had clerked in the Eastern 19 District at the same time that my wife had clerked. So I think 20 I knew them in advance. 21 Q. Was Ms. Trzaskoma also a lawyer during the course of the 22 trial in this courtroom, the David Parse trial? 23 A. She was. 24 Q. Who did she and her firm represent? 25 A. She and her firm represented David Parse. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009421 --- PAGE BREAK --- UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2frdau5 Conrad - direct Page 153 ... (39) Page 153 - Page 156 SOUTHERN DISTRICT REPORTERS DOJ-OGR-00009252 --- PAGE BREAK --- UNITED STATES OF AMERICA v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2frdau5 Conrad - direct Page 161 ... (rest of the text from the image) --- PAGE BREAK --- Case 1:20-cv-03038-PAE Document 616-1 Filed 02/24/22 Page 43 of 117 A-5819 362 C2grdau4 Schoeman - direct 1 Q. Did you take any action based on that conversation? 2 A. No. 3 Q. We know that it was after the juror's note. Do you recall when it was? 4 A. I can't say exactly when it was. I believe it was during 5 the deliberations either that Friday or sometime the following 6 week. 7 8 MR. SHECHTMAN: No further questions. 9 THE COURT: Cross-examination? 10 MR. OKULA: Briefly, your Honor. 11 CROSS-EXAMINATION 12 BY MR. OKULA: 13 Q. Good afternoon, Mr. Schoeman. How are you? 14 A. Good, thank you. Good afternoon. 15 Q. Dr. DeRosa sends his regards? 16 A. I send mine right back. 17 Q. You said you had this conversation with Ms. Trzaskoma after 18 the note was received in court, is that correct? 19 A. Yes. 20 Q. Was it the same day or the following day? 21 A. I don't believe it was either the same day or the following 22 day. I believe it was sometime a couple of days or several 23 days later. 24 Q. You talked about the follow-up questions that you asked to 25 try to get to the bottom of the information, is that correct? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009423 --- PAGE BREAK --- Case 1:20-cv-03038-PAE Document 616-1 Filed 02/24/22 Page 63 of 117 A-5821 C2grdau4 Schoeman - cross 364 1 A. No. 2 Q. Did she tell you that she had viewed a Westlaw report that 3 had certain information on it that was connected to Juror No. 4 1, Catherine Conrad? 5 A. No. 6 Q. Did she tell you that she had communicated with somebody 7 internally in her firm where she had exclaimed, "Jesus, I think 8 Juror No. 1 is the suspended attorney"? 9 A. No. 10 Q. If you had that information from Theresa Trzaskoma, would 11 you have done further investigation yourself? 12 A. I don't know. 13 Q. How many years did you spend as an Assistant U.S. Attorney, 14 Mr. Schoeman? 15 A. A total of about seven or eight. 16 Q. I would stipulate to the fact, because I've heard it, that 17 you were a terrific investigator, correct? 18 A. I'll stipulate with you. 19 Q. Are you telling us really that you wouldn't have looked 20 into that further yourself if you had seen these further 21 connections tying Juror No. 1 to the suspended attorney? 22 A. Forgive me. I thought your question was if I had heard 23 that she had written an email that had that exclamation. I 24 don't know what I would have done. I guess I can only tell you 25 what I did do, which was ask about the voir dire. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009425 --- PAGE BREAK --- Case 1:20-cv-03038-PAE Document 616 Filed 02/24/22 Page 93 of 67 UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2frdau3 Trzaskoma - redirect Page 93 ... (rest of the text from the image)