Document 1:20-cv-03339

Case 1:20-cv-03339 Document 616-2 Filed 02/24/22 Page 102 of 130 A-5787 C2GFDAU3 Edelstein 330 1 had subsequently looked at a Westlaw report that led her to 2 send an e-mail to somebody else in your firm saying, "Jesus, I 3 think this is the one," meaning Juror No. 1 was the Catherine 4 M. Conrad the suspended attorney? Did she tell that you? 5 A. No. 6 Q. Did you learn of the Westlaw report during the conversation 7 with her? 8 A. No. 9 Q. At what point did you learn about the Westlaw report 10 conversation? 11 A. I learned about the Westlaw report -- 12 Q. I'm sorry the report? 13 A. After we received the letter and jury verdict. 14 Q. Before the July -- 15 A. By the letter I mean the letter that was written in May and 16 received on June 20. 17 Q. Did you review the Westlaw report before Theresa Trzaskoma 18 participated in the court conference on July 15? 19 A. Yes. 20 Q. Did you yourself notice the similarities between the 21 address for Catherine M. Conrad, Juror No. 1, the existence of 22 a personal injury report, same name for her father? Did you 23 note those things? 24 A. When -- 25 Q. Did you note those things? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009391 --- PAGE BREAK --- Case 1:20-cv-03339-PAE Document 612-2 Filed 02/24/22 Page 143 of 130 A-5798 341 C2GFDAU3 Edelstein 1 Q. You knew from the voir dire, didn't you, that the Catherine 2 Conrad who sat as Juror No. 1 referred to being involved in a 3 personal injury lawsuit, correct? 4 A. Yes. 5 Q. Did Theresa Trzaskoma tell you that document she had seen 6 in the form of the Westlaw report had indicated Catherine M. 7 Conrad as a party to a lawsuit? 8 A. No. 9 Q. Would you agree with me that you had the resources 10 available to you, that all you had to do was pick up the phone 11 and call Nardello or anyone else and ask them to go to a 12 courthouse or do investigating for you to try to establish a 13 link, or the link that Theresa Trzaskoma had suggested? Would 14 you agree that you had those resources? 15 A. We could have done that, but we didn't believe they were 16 the same person. We thought -- 17 Q. So the answer is yes. You had those resources, right? 18 It's a simple question. 19 A. Yes, we could have called someone to investigate if we 20 thought that there was a reason to investigate. 21 Q. Now, after you received the juror letter that was sent to 22 you, you did call Nardello in to assist you in gathering 23 information, correct? 24 A. Yes. 25 Q. And that led to the preparation of your brief, correct? 1 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009402