Document A-5652

UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2frdau5 Conrad - direct Page 169 1 the answer is no. 2 Q. How did you explain the note about respondeat superior? 3 A. Common knowledge. Actually, I didn't have to explain it. 4 I just handed it to Juror No. 2, who was our forewoman, and she 5 submitted it to the Court. 6 Q. When you were deliberating in this case, did you have it 7 present in your mind that you had lied to get on to this jury? 8 A. I don't think I'm supposed to answer questions about jury 9 room deliberations, sir. 10 THE COURT: You can answer that question. 11 A. Could you please restate it. 12 Q. When you were deliberating in this case, did you have it 13 present in your mind that you had lied to get on the jury? 14 A. No, no. 15 Q. Between the time when you told the lies and the time you 16 rendered your verdict, when did you stop having it present in 17 your mind thinking about the fact that you had lied to get on 18 the jury? 19 A. Oh, sir, I don't know. 20 Q. Was it when we were cross-examining witnesses and exposing 21 untruths that they had told? 22 A. I don't have a time estimate for it. 23 Q. Do you remember when Mr. Shanbrom was on the witness stand? 24 A. Shambron, yes. 25 Q. Do you remember what a liar he was? C2frdau5 Conrad - direct Page 170 1 A. I'm not the judge. 2 Q. Do you remember at that time thinking, wow, I've told lies 3 just like he did? 4 A. No, I never thought that. 5 Q. When the marshals came out to serve you with an order on 6 December 15th to tell you to come to court, did you tell the 7 marshals that you had lied about not being a lawyer? 8 A. Will you please restate the question. 9 Q. Yes, I can. Do you remember when the marshals came out to 10 serve you at your house? 11 A. Yes, of course. 12 Q. By the way, was that on Barker Avenue? 13 A. Yes. 14 Q. When they came out to serve you, did you tell them, I think 15 I know what this is about? 16 A. Oh, first I told them we have cats, and if you're allergic, 17 stay outside. But specifically I don't really recall what I 18 said. 19 Q. Do you recall telling them that in your view you had not 20 lied, because no one asked you about whether or not you were a 21 lawyer? 22 A. I don't recall. They were there for maybe a minute handing 23 me the subpoena, and that was about it. 24 Q. At any time since last August, have you thought, have you 25 had the belief that you didn't lie about being a lawyer because C2frdau5 Conrad - direct Page 171 1 no one asked you about being a lawyer? 2 A. Sir, that's posing the quantum theory if the tree doesn't 3 fall and nobody sees it. No, of course the answer is no. 4 Q. Do you believe that you lied to the Court about being a 5 lawyer? 6 A. I know I omitted that very pertinent fact. 7 Q. Do you believe that was a lie? 8 A. Yes. 9 Q. Do you believe that it was the Court's fault for not asking 10 you whether you were a lawyer? 11 A. No, of course not. 12 Q. No, because if you had told the Court that you went to law 13 school, you would have been asked, right? 14 A. I would have been asked or axed, like they would have axed 15 me from the jury? 16 Let me pose a different question. In voir dire when you 17 were being asked specific questions, did you tell the judge 18 anything that was true besides your admiration for Lynn Swann, 19 the fact that you have no children? Did you tell him anything 20 that was true? 21 A. Of course. 22 Q. What? 23 A. I have a BA in English literature. 24 Q. OK. 25 A. And I studied archeology abroad. And I consider my C2frdau5 Conrad - direct Page 172 1 residence in Bronxville, not Bronx Village. There were only 2 seven questions that were posed, I believe. 3 Q. You told the truth in just about all of them, right? 4 A. You have to qualify your question, because there were 5 questions that were asked to the jury panel as a whole and then 6 individually. I revealed the fact that -- well, whatever you 7 said before. 8 Q. One question we haven't covered there on page 204 is the 9 last question. That question is, "The Court: All right. Is 10 there anything you think it would be important for us to know 11 about you in making a decision as to whether you should serve 12 as a juror in this case?" Do you remember him asking that 13 question? 14 A. Absolutely. 15 Q. You said, "If the trial lasts more than three months, I'm 16 still available." 17 A. Correct. 18 Q. Because you really wanted to be on this jury? 19 A. And I was available. 20 Q. You said it because you really wanted to be on this jury, 21 right? 22 A. I can't pinpoint at that time. I'm sorry. 23 Q. Did you think that there was nothing else that was 24 important for us to know about you in making a decision as to 25 whether you should serve as a juror? SOUTHERN DISTRICT REPORTERS (43) Page 169 - Page 172 DOJ-OGR-00009935 --- PAGE BREAK --- Case 1:20-cv-03038-PAE Document 616-1 Filed 02/24/22 Page 34 of 67 UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2frdau5 Conrad - direct Page 169 1 the answer is no. 2 Q. How did you explain the note about respondeat superior? 3 A. Common knowledge. Actually, I didn't have to explain it. 4 I just handed it to Juror No. 2, who was our forewoman, and she 5 submitted it to the Court. 6 Q. When you were deliberating in this case, did you have it 7 present in your mind that you had lied to get on to this jury? 8 A. I don't think I'm supposed to answer questions about jury 9 room deliberations, sir. 10 THE COURT: You can answer that question. 11 A. Could you please restate it. 12 Q. When you were deliberating in this case, did you have it 13 present in your mind that you had lied to get on the jury? 14 A. No, no. 15 Q. Between the time when you told the lies and the time you 16 rendered your verdict, when did you stop having it present in 17 your mind thinking about the fact that you had lied to get on 18 the jury? 19 A. Oh, sir, I don't know. 20 Q. Was it when we were cross-examining witnesses and exposing 21 untruths that they had told? 22 A. I don't have a time estimate for it. 23 Q. Do you remember when Mr. Shanbrom was on the witness stand? 24 A. Shambron, yes. 25 Q. Do you remember what a liar he was? C2frdau5 Conrad - direct Page 170 1 A. I'm not the judge. 2 Q. Do you remember at that time thinking, wow, I've told lies 3 just like he did? 4 A. No, I never thought that. 5 Q. When the marshals came out to serve you with an order on 6 December 15th to tell you to come to court, did you tell the 7 marshals that you had lied about not being a lawyer? 8 A. Will you please restate the question. 9 Q. Yes, I can. Do you remember when the marshals came out to 10 serve you at your house? 11 A. Yes, of course. 12 Q. By the way, was that on Barker Avenue? 13 A. Yes. 14 Q. When they came out to serve you, did you tell them, I think 15 I know what this is about? 16 A. Oh, first I told them we have cats, and if you're allergic, 17 stay outside. But specifically I don't really recall what I 18 said. 19 Q. Do you recall telling them that in your view you had not 20 lied, because no one asked you about whether or not you were a 21 lawyer? 22 A. I don't recall. They were there for maybe a minute handing 23 me the subpoena, and that was about it. 24 Q. At any time since last August, have you thought, have you 25 had the belief that you didn't lie about being a lawyer because C2frdau5 Conrad - direct Page 171 1 no one asked you about being a lawyer? 2 A. Sir, that's posing the quantum theory if the tree doesn't 3 fall and nobody sees it. No, of course the answer is no. 4 Q. Do you believe that you lied to the Court about being a 5 lawyer? 6 A. I know I omitted that very pertinent fact. 7 Q. Do you believe that was a lie? 8 A. Yes. 9 Q. Do you believe that it was the Court's fault for not asking 10 you whether you were a lawyer? 11 A. No, of course not. 12 Q. No, because if you had told the Court that you went to law 13 school, you would have been asked, right? 14 A. I would have been asked or axed, like they would have axed 15 me from the jury? 16 Q. Let me pose a different question. In voir dire when you 17 were being asked specific questions, did you tell the judge 18 anything that was true besides your admiration for Lynn Swann, 19 the fact that you have no children? Did you tell him anything 20 that was true? 21 A. Of course. 22 Q. What? 23 A. I have a BA in English literature. 24 Q. OK. 25 A. And I studied archeology abroad. And I consider my C2frdau5 Conrad - direct Page 172 1 residence in Bronxville, not Bronx Village. There were only 2 seven questions that were posed, I believe. 3 Q. You told the truth in just about all of them, right? 4 A. You have to qualify your question, because there were 5 questions that were asked to the jury panel as a whole and then 6 individually. I revealed the fact that -- well, whatever you 7 said before. 8 Q. One question we haven't covered there on page 204 is the 9 last question. That question is, "The Court: All right. Is 10 there anything you think it would be important for us to know 11 about you in making a decision as to whether you should serve 12 as a juror in this case?" Do you remember him asking that 13 question? 14 A. Absolutely. 15 Q. You said, "If the trial lasts more than three months, I'm 16 still available." 17 A. Correct. 18 Q. Because you really wanted to be on this jury? 19 A. And I was available. 20 Q. You said it because you really wanted to be on this jury, 21 right? 22 A. I can't pinpoint at that time. I'm sorry. 23 Q. Did you think that there was nothing else that was 24 important for us to know about you in making a decision as to 25 whether you should serve as a juror? SOUTHERN DISTRICT REPORTERS (43) Page 169 - Page 172 DOJ-OGR-00009256