Document A-5651

UNITED STATES OF AMERICA, v. PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2frdau5 Conrad - direct Page 165 1 A. Sir, are we still on 203? 2 Q. Yes. 3 A. All right. 4 Q. Actually, it goes over to 204. 5 A. OK, thank you. Yes. 6 Q. Did you have any trouble understanding the question that 7 Judge Pauley asked you? 8 A. Not at all. 9 Q. Did you know that Judge Pauley was going to ask you that 10 question or something very like it? 11 A. Yes, because the prior day the same questions were asked of 12 the other potential jurors. 13 Q. When did you make the decision about how you were going to 14 answer that question? Was it right then when he asked you or 15 was it before then? 16 A. I think it was during the break between the two days. 17 Q. Can you remember how you reached the conclusion that you 18 should tell a lie in answer to that question? 19 A. Because I knew that anybody with a JD or legal experience 20 would be bounced. 21 Q. That's because there were lawyers who were on trial, right? 22 A. I don't think the jury knew at that point that there were 23 attorneys on trial. I'm not sure. I'm not sure. 24 Q. You knew, because Judge Pauley summarized the charges for 25 you before the voir dire started, that there were lawyers on C2frdau5 Conrad - direct Page 167 1 Q. Because you suspected that it would stop you from getting 2 on the jury, you made a deliberate decision, having sworn an 3 oath to tell the truth, you made a deliberate decision to lie 4 to this Court? 5 A. I don't know if I was sworn at that point, but I did not 6 reveal the fact that I had a JD and was an attorney. 7 Q. No, no, that's not the question I asked. The question I 8 asked is, did you make a deliberate decision to lie to the 9 Court? 10 A. Are we getting into the semantics of omissions again? 11 Q. Did you make a deliberate decision to lie to the Court 12 about your highest level of education? 13 A. Yes. 14 Q. Did you do that because you believed that otherwise you 15 would not be permitted to be on this jury? 16 A. Yes. 17 Q. So it was your idea to thwart the voir dire process by 18 telling the Court something that wasn't true about your 19 background? 20 A. I guess if you want to characterize it that way. 21 Q. You said, "I have a BA in English literature in classics 22 and I studied archeology abroad," right? 23 A. Correct. 24 Q. Did you remember at that moment that you studied law at the 25 Brooklyn Law School? C2frdau5 Conrad - direct Page 166 1 trial charged with tax fraud in connection with a tax shelter 2 scheme, didn't you? 3 A. Yes, I remember now, yes. 4 Q. Now that you remember, you knew that there's no way that a 5 lawyer would be left on a jury to decide the conduct of lawyers 6 who were being charged with a crime, right? 7 A. No, I didn't know that. 8 Q. Didn't you just say that? 9 A. I didn't know that for a fact. 10 Q. Did you strongly suspect that you would not be allowed to 11 sit on the jury if you revealed that you were a lawyer? 12 A. Of course. 13 Q. That was connected, was it not, to the fact that there were 14 lawyers on trial here, right? 15 A. No, no. In any jury nobody wants an attorney. A jury 16 trial does not want an attorney sitting as a juror. 17 Q. If you were trying a case as a lawyer, you wouldn't want an 18 attorney on your jury either, would you? 19 A. That's incorrect. 20 Q. So you're not included in the "no one" just referred 21 to? 22 A. I'm not sure. 23 Q. Didn't you just say no one would want an attorney on their 24 jury? 25 A. That generally seems to be the trend, yes. C2frdau5 Conrad - direct Page 168 1 A. Of course. 2 Q. At any point after you told these lies about your 3 residence, about how long you lived there, about your owning 4 your place, about your highest level of education, at any time 5 did you think to yourself, wow, what I just did was wrong? 6 A. Of course I knew it was wrong. 7 Q. But did you think to yourself, what I just did was wrong? 8 A. You just asked me that question. 9 Q. And I'm asking it again because I didn't get an answer. 10 Did you think that? 11 A. Yes. 12 Q. How many times did you think that? 13 A. I really don't know, sir. 14 Q. Was it present in your mind throughout the trial that you 15 had lied in order to get on the jury? 16 A. Probably. 17 Q. Did you tell other people that you had lied to get on the 18 jury? 19 A. I don't think so, not that I recall. 20 Q. Did you tell other people that you had concealed things to 21 get on the jury? 22 A. I don't think so. 23 Q. Did you tell other people you were a lawyer? 24 A. I don't know how to construe your question. But if your 25 question is did the other jurors know that I was an attorney, Page 165 - Page 168 (42) SOUTHERN DISTRICT REPORTERS --- PAGE BREAK --- Case 1:20-cv-03038-PAE Document 616-1 Filed 02/14/22 Page 33 of 67 A-5651 UNITED STATES OF AMERICA, v. PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2frdau5 Conrad - direct Page 165 ... C2frdau5 Conrad - direct Page 168 ... Page 165 - Page 168 (42) SOUTHERN DISTRICT REPORTERS