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Document A-5649

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UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 Page 157 - Page 160 (40) C2frdau5 Conrad - direct Page 157 1 Q. How often do the police come to your apartment? 2 A. The last time someone came to my apartment was when the 3 marshals served me to come here back in December. 4 Q. When was the last time a New York police officer came to 5 your apartment? 6 A. Maybe three, four years ago. 7 Q. So, you have been living there for at least three or four 8 years, right? 9 A. Haven't we established this? 10 Q. I guess we have, ma'am. Have we established that you told 11 this lie on purpose? 12 A. No. 13 Q. Let's move on to the next question you were asked. You 14 told a deliberate lie in response to that question, did you 15 not? 16 A. You didn't ask me a question. What are you talking about, 17 sir? 18 Q. Let's look at again page 203, lines 10 through 12. 19 A. Of what exhibit? I'm sorry. 20 Q. Exhibit number 2. 21 A. OK. 22 Q. The second question Judge Pauley asked you was, "How long 23 have you lived at your current address?" and your answer was, 24 "My whole life"? 25 A. That's correct. C2frdau5 Conrad - direct Page 158 1 Q. Now, ma'am, am I right in thinking that that was a lie? 2 A. No. 3 Q. Had you lived in Bronxville your whole life? 4 A. It's my permanent address my whole life. I went to school 5 in Boston, I went to school in Brooklyn, I studied abroad for 6 two summers in Israel. That has been my permanent address, 7 sir. 8 Q. When Judge Pauley asked you how long you have lived at your 9 current address, you said your whole life, correct? 10 A. I just said that, correct. 11 Q. OK. We have established that you live on a day-to-day 12 basis on Barker Avenue and that you have for years, right? 13 A. Correct. 14 Q. So you lied to the judge? 15 A. I consider myself having two residences. 16 Q. Let me try and ask a more specific question. If a person 17 were to say "Where do you live?" and you were to say a place 18 where you do not live on a regular basis as the answer to that, 19 do you consider that to be a lie? 20 A. I consider your hypothetical a little silly. 21 Q. It's actually what happened, right? Let me ask you this. 22 Do you understand that the main job of a juror is to determine 23 who is telling the truth and who is lying? 24 A. Of course. 25 Q. Did you apply that same acumen in determining whether you C2frdau5 Conrad - direct Page 159 1 were telling the truth or lying to determining whether 2 witnesses were telling the truth or lying? 3 A. That's a nice spin on it. 4 Q. Do you have an answer to it? 5 A. After all the evidence in the trial, it was overwhelming, 6 and our verdict was a true, unbiased, fair verdict. 7 Q. So the end justifies the means, is that right? 8 MR. OKULA: Objection, your Honor. 9 THE COURT: Sustained to form. 10 Q. Let me try one more time. Did you apply your personal 11 sense of truthfulness to your evaluation of the witnesses who 12 testified in this case? 13 A. I believe all 12 of us jurors did. 14 Q. I didn't ask about anybody but you. Did you apply your 15 personal sense of truthfulness to evaluating the witnesses that 16 you heard in this case? 17 A. I can say so. 18 Q. You agree with me that when you said you had lived in 19 Bronxville your whole life, that was not true, correct? 20 A. I've lived many places. That is my permanent residence 21 and -- the horse is dead. 22 Q. Did you make a deliberate decision to say that you lived 23 there your whole life when in fact you had lived in the Bronx 24 or Brooklyn or other places? 25 A. Please repeat it. I didn't say Brooklyn on voir dire. C2frdau5 Conrad - direct Page 160 1 Q. You have lived various places in your life, have you not? 2 A. Oh, yes. 3 Q. That statement that you just made, "oh, yes," is 4 inconsistent with the statement that you made to Judge Pauley 5 when he asked how long have you lived in Bronxville? 6 A. I consider it my whole life because that is my other 7 residence and that's my permanent residence. 8 Q. Then the Court asked you, "Do you own or rent?" So we have 9 two questions. You were asked where you lived, and you didn't 10 tell the truth about that. You were asked how long you lived 11 there -- 12 A. That's your interpretation. 13 Q. OK. And you didn't tell the truth about that either. 14 Let's go to the third question, "Do you own or rent?" You said 15 "We own." 16 A. That was a lie, to skip questions 10 to a hundred. 17 Q. That was a lie, too? 18 A. Correct. 19 Q. Why did you tell it? 20 A. I thought I would seem more juror marketable (gesturing). 21 Q. You really wanted to be on this jury? 22 A. Yeah. I knew I could do a fair, unbiased job. 23 Q. Seems like a strange way to start, by lying, doesn't it? 24 MR. OKULA: Objection. 25 THE COURT: Sustained. Page 157 - Page 160 (40) SOUTHERN DISTRICT REPORTERS DOJ-OGR-00009932