Case 1:20-cv-03638-PAE Document 6166120 Filed 02/24/22 Page 240 of 67 A-5658 UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2FFDAU6 Conrad - direct Page 193 1 complete the witness. 2 (Recess) 3 THE COURT: Mr. Gair, you may continue. 4 BY MR. GAIR: 5 Q. Ms. Conrad, do you have a driver's license? 6 A. Yes. 7 Q. What name is on your drivers license? 8 A. My married name, Rosa. 9 Q. So when you said you use Rosa socially, in fact you use it 10 for legal purposes too, correct? 11 A. Just on my license. 12 Q. And when you were arrested, correct? 13 A. I don't think it matters what name a person uses when 14 they're arrested. Your NYSID follows you. 15 Q. Now, would it be right in thinking that you identified with 16 the prosecutors in this case? 17 A. I don't know what you think, sir. 18 Q. Did you identify with the prosecutors in this case? 19 A. I don't know what that question means. 20 Q. Well, you wrote to the prosecutors after the trial was 21 over, correct? 22 A. Correct. 23 Q. You didn't write to any of the defense lawyers, correct? 24 A. That's correct. 25 Q. And not only did you write to the prosecutors, but you C2FFDAU6 Conrad - direct Page 195 1 Q. And you were so anxious to speak with them that you wrote a 2 letter to Mr. Okula the very next day, right? 3 A. I don't know couching in those terms "so anxious" really is 4 the correct way to do it, but -- 5 Q. Well, you wrote a letter to him in which you told him you 6 wished that you would have had the opportunity to talk to him, 7 correct? 8 A. Oh, that's correct, yes. 9 Q. And you would have welcomed the pleasure to do so, right? 10 A. Yes. 11 Q. Now, you never made any attempt to contact any of the 12 defense lawyers and tell them you would have liked to talk to 13 them, right? 14 A. There was no reason to. 15 Q. But there was a reason to contact the prosecutor? 16 A. Yes. 17 Q. And not only -- now, and you wrote a letter to Mr. Okula, 18 now, this is not preprinted stationery, right, that you wrote 19 on? 20 A. No, no. 21 Q. This is just a caption that you made up for the letter, 22 correct? 23 A. Yeah, on my computer, yes. 24 Q. On your computer. And where were you sitting when you 25 wrote that letter on your computer? C2FFDAU6 Conrad - direct Page 194 1 wrote to the prosecutors the very day after the verdict, isn't 2 that correct? 3 A. I'm not really sure the exact date, sir. It was late May. 4 MR. GAIR: Your Honor, I'd move the admission of PMD 5 Exhibit 7. 6 THE COURT: Any objection? 7 MR. OKULA: No objection, your Honor. 8 THE COURT: PMD Exhibit 7 is received in evidence. 9 (Exhibit PMD 7 received in evidence) 10 Q. And if you would look at Exhibit 7, tab 7, you wrote the 11 prosecutors on May 25th of 2011, is that correct? 12 A. Yes. 13 Q. And that was one day after the verdict, the very day after. 14 A. I believe the verdict was the 24th. Correct. 15 Q. And you were very anxious to talk to the prosecutors, 16 weren't you? 17 A. Not just myself. 18 Q. Of course, I didn't ask you about anybody else. Were you 19 very anxious to talk to the prosecutors? 20 A. Yes. And along with the other eleven jurors, we had wanted 21 to speak with them after the verdict, when Judge Pauley had 22 come into the jury room to speak with us after. 23 Q. Without worrying about what the eleven other people wanted 24 or didn't want, were you anxious to speak with them? 25 A. Oh, sure. C2FFDAU6 Conrad - direct Page 196 1 A. In front of my cat. 2 Q. In front of your cat. Was your cat located at 2385 South 3 Barker Avenue or at 16 Parkview Drive at the time? 4 A. Neither. It's Barker. 5 Q. Where was your cat located at the time you wrote this 6 letter, ma'am? 7 A. Next to my screen. On Barker Avenue, sir. 8 Q. Yeah. And yet you put, once again, that the return address 9 was 16 Parkview Avenue in Bronxville, New York, correct? 10 A. No, Drive. 11 Q. You put the address was 16 Parkview Drive in Bronxville, 12 correct? 13 A. Yes, mm-hmm. Yes. 14 Q. That's not where you were when you wrote the letter, right? 15 A. Correct. 16 Q. And that was not the address you were living at when you 17 wrote the letter, correct? 18 A. I still consider it both. 19 Q. And that is not the address that goes with the phone number 20 that you put right under that, is it? 21 A. Excuse me, that's my cell number. 22 Q. That's exactly right. That is not your parents' home phone 23 number at 16 Parkview Drive, is it, ma'am? 24 A. No, it's my cell. 25 Q. It's your cell number. Why don't you tell Judge Pauley why SOUTHERN DISTRICT REPORTERS (49) Page 193 - Page 196
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Case 1:20-cv-03638-PAE Document 6166120 Filed 02/24/22 Page 240 of 67 A-5658 UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2FFDAU6 Conrad - direct Page 193 1 complete the witness. 2 (Recess) 3 THE COURT: Mr. Gair, you may continue. 4 BY MR. GAIR: 5 Q. Ms. Conrad, do you have a driver's license? 6 A. Yes. 7 Q. What name is on your drivers license? 8 A. My married name, Rosa. 9 Q. So when you said you use Rosa socially, in fact you use it 10 for legal purposes too, correct? 11 A. Just on my license. 12 Q. And when you were arrested, correct? 13 A. I don't think it matters what name a person uses when 14 they're arrested. Your NYSID follows you. 15 Q. Now, would it be right in thinking that you identified with 16 the prosecutors in this case? 17 A. I don't know what you think, sir. 18 Q. Did you identify with the prosecutors in this case? 19 A. I don't know what that question means. 20 Q. Well, you wrote to the prosecutors after the trial was 21 over, correct? 22 A. Correct. 23 Q. You didn't write to any of the defense lawyers, correct? 24 A. That's correct. 25 Q. And not only did you write to the prosecutors, but you C2FFDAU6 Conrad - direct Page 195 1 Q. And you were so anxious to speak with them that you wrote a 2 letter to Mr. Okula the very next day, right? 3 A. I don't know couching in those terms "so anxious" really is 4 the correct way to do it, but -- 5 Q. Well, you wrote a letter to him in which you told him you 6 wished that you would have had the opportunity to talk to him, 7 correct? 8 A. Oh, that's correct, yes. 9 Q. And you would have welcomed the pleasure to do so, right? 10 A. Yes. 11 Q. Now, you never made any attempt to contact any of the 12 defense lawyers and tell them you would have liked to talk to 13 them, right? 14 A. There was no reason to. 15 Q. But there was a reason to contact the prosecutor? 16 A. Yes. 17 Q. And not only -- now, and you wrote a letter to Mr. Okula, 18 now, this is not preprinted stationery, right, that you wrote 19 on? 20 A. No, no. 21 Q. This is just a caption that you made up for the letter, 22 correct? 23 A. Yeah, on my computer, yes. 24 Q. On your computer. And where were you sitting when you 25 wrote that letter on your computer? C2FFDAU6 Conrad - direct Page 194 1 wrote to the prosecutors the very day after the verdict, isn't 2 that correct? 3 A. I'm not really sure the exact date, sir. It was late May. 4 MR. GAIR: Your Honor, I'd move the admission of PMD 5 Exhibit 7. 6 THE COURT: Any objection? 7 MR. OKULA: No objection, your Honor. 8 THE COURT: PMD Exhibit 7 is received in evidence. 9 (Exhibit PMD 7 received in evidence) 10 Q. And if you would look at Exhibit 7, tab 7, you wrote the 11 prosecutors on May 25th of 2011, is that correct? 12 A. Yes. 13 Q. And that was one day after the verdict, the very day after. 14 A. I believe the verdict was the 24th. Correct. 15 Q. And you were very anxious to talk to the prosecutors, 16 weren't you? 17 A. Not just myself. 18 Q. Of course, I didn't ask you about anybody else. Were you 19 very anxious to talk to the prosecutors? 20 A. Yes. And along with the other eleven jurors, we had wanted 21 to speak with them after the verdict, when Judge Pauley had 22 come into the jury room to speak with us after. 23 Q. Without worrying about what the eleven other people wanted 24 or didn't want, were you anxious to speak with them? 25 A. Oh, sure. C2FFDAU6 Conrad - direct Page 196 1 A. In front of my cat. 2 Q. In front of your cat. Was your cat located at 2385 South 3 Barker Avenue or at 16 Parkview Drive at the time? 4 A. Neither. It's Barker. 5 Q. Where was your cat located at the time you wrote this 6 letter, ma'am? 7 A. Next to my screen. On Barker Avenue, sir. 8 Q. Yeah. And yet you put, once again, that the return address 9 was 16 Parkview Avenue in Bronxville, New York, correct? 10 A. No, Drive. 11 Q. You put the address was 16 Parkview Drive in Bronxville, 12 correct? 13 A. Yes, mm-hmm. Yes. 14 Q. That's not where you were when you wrote the letter, right? 15 A. Correct. 16 Q. And that was not the address you were living at when you 17 wrote the letter, correct? 18 A. I still consider it both. 19 Q. And that is not the address that goes with the phone number 20 that you put right under that, is it? 21 A. Excuse me, that's my cell number. 22 Q. That's exactly right. That is not your parents' home phone 23 number at 16 Parkview Drive, is it, ma'am? 24 A. No, it's my cell. 25 Q. It's your cell number. Why don't you tell Judge Pauley why SOUTHERN DISTRICT REPORTERS (49) Page 193 - Page 196
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