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Case 1:20-cv-13038-PAE Document 616-1 Filed 02/24/22 Page 33 of 117 A-5818 C2grdau4 Schoeman - direct 361 1 Q. Sometime after the reading of the note from Juror No. 1, did you speak to Ms. Trzaskoma about Ms. Conrad, Juror No. 1? 2 A. Yes. 3 Q. Would you tell the Court what was said between you and Ms. 4 Trzaskoma at that time. 5 A. Yes. I recall that we had a conversation. I believe it 6 was as we were walking across Foley Square towards Duane 7 Street. She told me that there was a person with the same name 8 as -- I don't recall whether she said Juror No. 1 or Ms. 9 Conrad, but a person with the same name who was a disbarred 10 lawyer but that it was not the same person as Juror No. 1. 11 I began formulating a question to say, how do you 12 know? She anticipated that question and said, because of the 13 voir dire. I began formulating the question of, what question 14 during the voir dire would have disclosed that? She 15 anticipated that question as I was speaking it and said 16 something to the effect that her educational background did not 17 include law school. I said, then it's not the same person? 18 19 And she said right. By that time we had finished crossing the 20 street. 21 Q. Any further discussion about Juror No. 1? 22 A. Not with Ms. Trzaskoma during that time period. 23 Q. Any further discussion with anyone at the Brune firm 24 regarding Juror No. 1 during that time period? 25 A. No. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009422