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UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2FFDAU4 Conrad - direct Page 121 C2FFDAU4 Conrad - direct Page 123 1 Q. Do you regard water as a medication? 1 Q. Would your conduct be sane if irrational? 2 A. It calms me down. Sure. 2 A. I'm not going to answer that. Of course not. Insanely? 3 Q. Besides water, what other medications do you take? 3 Is that what you said, sir? 4 A. Tylenol for PMS. 4 THE COURT: Why don't you put another question? 5 Q. Do you take any prescription medication? 5 Q. Was your conduct in rejecting the subpoena that the judge 6 A. Not at all. 6 ordered served on you and saying that you were not going to 7 Q. At any time in the last, say, two years have you taken any 7 appear and the judge would have to have you arrested, was that 8 prescription medication? 8 conduct irrational? 9 A. No, sir. 9 A. Absolutely not. Nobody wants a subpoena served on them. 10 Q. Now, did you tell the judge that, after he reminded you 10 Q. Now, have you ever witnessed an officer of the court in 11 that a subpoena had just been served on you on December 20, did 11 your career as a lawyer, have you ever witnessed an officer of 12 you tell the judge, "I reject the subpoena. I reject it and 12 the court telling a judge that the judge would have to have 13 you're going to have to arrest me because nothing is going to 13 them arrested because they weren't going to appear as ordered? 14 change." 14 A. I don't know how to answer that. I don't know. 15 A. I don't specifically remember that, but I'm sure I told him 15 Q. Do you know what your own experiences are? 16 that if it's in your record. 16 A. If you're asking if I did it. You just told me I did it. 17 Q. Would you agree with me that that is uncommon conduct for 17 Q. I'm asking you -- are you able to understand my question? 18 an officer of the Court? 18 A. Yes, but these questions are ridiculous. 19 A. I'm not a psychologist. I don't know what common conduct 19 Q. Why are they ridiculous? 20 quote-unquote, what your terms mean. 20 A. Pose it again, please. 21 Q. So you're not really in a position to judge whether 21 Q. Can you answer me why -- you just said my questions are 22 something is common or uncommon, correct? 22 ridiculous. What did you mean when you said they were 23 A. I'm not a judge, like you just said. 23 ridiculous? 24 Q. And you're not in a position to judge whether something is 24 A. How would I know whether an attorney, what another attorney 25 rational or irrational, right? 25 said to another judge? I don't understand your questions. C2FFDAU4 Conrad - direct Page 122 C2FFDAU4 Conrad - direct Page 124 1 A. Common knowledge is common knowledge, sir. 1 Q. Okay. Now, would you agree with me that a good part of 2 Q. Are you in a position to judge whether something is 2 that hearing on December 20th was about Judge Pauley advising 3 rational or irrational? 3 you that you should get a lawyer. 4 MR. OKULA: Objection, Judge. We're getting into this 4 A. Yes, sir. I understand the underlying reason why we're 5 rational/irrational. Different people have different ideas 5 here is not lawyer or lawyer up, whether I did or didn't, it's 6 about it. 6 whether the underlying fact of the verdict. 7 THE COURT: And he's exploring the witness' view of 7 Q. Did you understand that the hearing on December 20th was to 8 that. Overruled. 8 give you instructions which included instructing you about your 9 A. Can you please say that again, sir? 9 right to a lawyer? 10 MR. GAIR: Your Honor, can I ask that the court 10 A. I guess partly, sir. 11 reporter read back the question? 11 Q. Okay. And Judge Pauley told you that he would appoint a 12 THE COURT: Madam court reporter, would you kindly 12 lawyer for you if you qualified financially, correct? 13 read back the question for Ms. Conrad? 13 A. I don't recall specifically. I don't recall. 14 (Record read) 14 Q. Well, didn't you -- you don't recall whether the judge told 15 A. In what context, sir? 15 you that you would have to -- that it could only appoint a 16 Q. In the context of conduct of a lawyer appearing before a 16 lawyer if you couldn't afford to hire one yourself? 17 federal judge, do you know what kind of conduct is rational and 17 A. Sir, I don't specifically remember that. 18 what kind of conduct is irrational? 18 Q. Did you say that you didn't have the money to pay for 19 A. Probably, sir. 19 counsel? 20 Q. Was your conduct irrational when you said, "I reject the 20 A. Oh, I don't recall. 21 subpoena. I reject it and you're going to have to arrest me 21 Q. Did you have the money to pay for counsel? 22 because nothing is going to change"? 22 A. No. 23 A. I consider it irrelevant. 23 Q. Well, let me just ask you to look, there's a big black 24 Q. I beg your pardon? 24 binder in front of you, and I'm going to ask you about a 25 A. Irrelevant, not irrational. 25 document in that binder, Exhibit 3. SOUTHERN DISTRICT REPORTERS (31) Page 121 - Page 124 DOJ-OGR-00009244