Full Text
Case 1:20-cv-30033 Document 616-1 Filed 02/24/22 Page 25 of 67 A-5643
UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL.,
February 15, 2012
C2FFDAU4 Conrad - direct Page 133
1 Q. So my question is, did you understand at that moment that
2 there was a logical connection between the question Judge
3 Pauley was asking you about your finances and the matter he was
4 discussing with you, that is, appointment of a lawyer?
5 A. Yes, sir.
6 Q. You did understand?
7 A. Yes, sir.
8 Q. And yet you refused to answer those questions, correct?
9 A. At that time.
10 Q. And in fact, you said your personal finances have nothing
11 to do with this, correct?
12 A. And had nothing to do with the guilty verdict I rendered
13 against your client.
14 Q. But it did have something to do with what you were being
15 asked about, that is, your right to a lawyer, correct?
16 A. I guess if that's what it says.
17 Q. Now, it turns out that you do have some cash resources?
18 A. I'm not discussing my finances in open court, sir.
19 THE COURT: I'm directing you to answer questions that
20 are put before you.
21 Q. Ms. Conrad, isn't it true that you have cash on hand or
22 money in savings or checking accounts of approximately $12,000?
23 A. If that's the affidavit of financial statement you received
24 from my attorney this morning, then that is correct.
25 Q. Well, I'm not -- I didn't make any reference to an
C2FFDAU4 Conrad - direct Page 135
1 A. She's only the person that I care about whose opinion
2 matters to me.
3 Q. Do you know whether you are a financial success as a
4 lawyer?
5 A. No, I have no idea. It's a sliding scale.
6 Q. How much money did you make as a lawyer the last year you
7 were practicing law?
8 A. Could I make? I have no idea.
9 MR. OKULA: Judge, relevance.
10 THE COURT: Overruled.
11 Q. How much did you make practicing as a lawyer in 2007?
12 A. I wasn't a practicing lawyer.
13 Q. What were you doing in 2007?
14 A. Being a suspended lawyer.
15 Q. How much money did you make in 2006 as a lawyer?
16 A. I don't recall.
17 Q. Was it over $400?
18 A. An hour?
19 Q. No, $400 total in the year.
20 A. Probably, sir.
21 Q. Probably. And were you self-employed?
22 A. Yes, at that time.
23 Q. When was the last time you filed a tax return, Ms. Conrad?
24 A. 2008 or 2009.
25 Q. 2008 or 2009. Didn't you tell the Bar in a sworn affidavit
C2FFDAU4 Conrad - direct Page 134
1 affidavit --
2 A. I didn't have to, sir. How else would you know that?
3 Q. Ms. Conrad, my question for you is a simple one. Do you
4 have $12,000 cash on hand?
5 A. Approximately. That has nothing to do with the guilty
6 verdict I rendered against Mr. Daugerdas, your client.
7 Q. And do you also have about $2,000 in stocks and bonds?
8 A. You can read my affidavit very correctly, yes. That you
9 received this morning.
10 Q. Is the answer to my question, yes, you do have $2,000?
11 A. I don't know the exact amount. Approximately.
12 Q. So all together you have about $14,000 in either cash or
13 stocks and bonds, is that correct?
14 A. Correct. Much less than your client.
15 Q. You haven't been a very successful person, have you,
16 Ms. Conrad?
17 MR. OKULA: Objection, your Honor.
18 A. I don't know what that means. Ask my mother.
19 THE COURT: Sustained as to form.
20 Q. Have you been a successful -- have you achieved financial
21 success as a lawyer?
22 A. Ask my mother. I have no idea. I don't know what that
23 means.
24 Q. I have to ask your mother whether or not you have achieved
25 financial success as a lawyer?
C2FFDAU4 Conrad - direct Page 136
1 on February 28th of 2011 that you hadn't been -- the question
2 attach your last two years federal and state tax returns the
3 answer was none, not applicable.
4 A. Absolutely, because that was the truth.
5 Q. So you filed a tax return in 2009?
6 A. I filed the document about which you are speaking on
7 February 28, 2011.
8 Q. When was the last time you filed a tax return?
9 A. Either 2008 or 2009. I'm not sure.
10 Q. Well, if it was filed in 2009, then your answer to the
11 disciplinary committee question would have been untruthful,
12 correct?
13 A. If you want to parse semantics.
14 Q. Well, that's kind of what we do in court, Ms. Conrad.
15 MR. OKULA: Objection, your Honor.
16 THE COURT: Sustained.
17 MR. GAIR: Sorry, your Honor. My apologies.
18 Q. Ms. Conrad, do you know whether you gave a truthful answer
19 to that question on the disciplinary committee affidavit you
20 filed on February 28th of 2011?
21 A. I believe I did.
22 Q. Now, can you give us an idea, just to go back to finish off
23 this issue, would you characterize yourself by your own
24 standards as a financially successful lawyer?
25 A. I don't know what your question means.
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SOUTHERN DISTRICT REPORTERS
DOJ-OGR-00009247