Document A-5666

UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2frdau7 Conrad - redirect Page 225 C2frdau7 Conrad - redirect Page 227 1 Q. Well, did you follow all of Judge Pauley's instructions or 1 A. No, but I did. 2 only the ones that you wanted to follow? 2 Q. Do I look like I know what the PJI is? 3 A. That's the job of the trier of fact, which I was a trier of 3 A. Yes. You're a professor. 4 fact. 4 Q. Would you agree with me then that since you did for the 5 Q. Did you follow all of Judge Pauley's instructions or only 5 follow Judge Pauley's initial instruction at the start of the 6 those instructions that you wanted to follow? 6 trial, you did not in fact follow all of his instructions? 7 A. Probably all of them. 7 A. You're mischaracterizing it. 8 Q. All of them, every single one, right? 8 Q. It's a simple question, yes or no. Since you did not 9 A. I don't have the PJI in front of me. 9 follow the instruction to tell the truth, did you follow all of 10 Q. But as far as you know, of all the ones Mr. Okula 10 his instructions? 11 mentioned, you followed them, right? 11 A. Regarding the verdict, yes. 12 A. More likely than not. 12 Q. Did you follow all of Judge Pauley's instructions? 13 Q. And of all the other instructions he gave you, you followed 13 A. Not with respect to the voir dire. 14 them, is that correct? 14 Q. Therefore, you did not follow all of his instructions, is 15 A. I can't answer that. 15 that correct? 16 Q. You know for a fact you didn't follow all those 16 A. If you need to connect the dots like that. 17 instructions, don't you? 17 Q. Did you follow all of his corrections? 18 A. No, I don't think that's correct. 18 A. Yes. In rendering a correct verdict, yes. 19 Q. Didn't he tell you at the very start of the trial that you 19 Q. Now you're saying you did follow all of his instructions. 20 had to speak the truth to tell about your background in order 20 Let me try and get this very simply. Can you answer my 21 to even be seated as a juror? 21 question? Taking into account the fact that you perjured 22 A. He also told us to render a fair verdict -- 22 yourself repeatedly at voir dire, did you follow all of his 23 Q. No, no. 23 instructions? 24 A. -- which we did. 24 A. I think you just answered the question. 25 Q. Do you see the difference between your answers to my 25 Q. Why don't you answer it. C2frdau7 Conrad - redirect Page 226 C2frdau7 Conrad - redirect Page 228 1 questions and Mr. Okula's questions? 1 A. Besides the voir dire, yes. 2 A. Sure: Splitting hairs and semantics. 2 Q. Including the voir dire, did you follow all of Judge 3 Q. Exactly. You're splitting hairs and you're engaging in 3 Pauley's instructions? 4 semantics? 4 A. Not with my omissions, no. 5 MR. OKULA: Objection, your Honor. 5 Q. Not with your lies, right? 6 THE COURT: Overruled. 6 A. However you want to characterize it. 7 Q. Let me ask you this, Ms. Conrad. Did Judge Pauley give you 7 Q. Therefore, you picked which of Judge Pauley's instructions 8 an instruction as a juror to tell the truth? 8 you were going to follow and which of those that you were not 9 A. I'm sure he did. 9 going to follow, is that correct? 10 Q. Did you tell the truth? 10 A. No. 11 A. By rendering an unbiased verdict. 11 Q. Was it random that you followed some of his instructions 12 Q. Did you tell the truth? 12 and didn't follow others? 13 A. Yes. 13 A. I didn't follow the instructions in voir dire. 14 Q. You told the truth, the whole truth, and nothing but the 14 Q. You chose, you picked that instruction not to follow, 15 truth? 15 correct? 16 A. You're asking me about the voir dire? 16 A. Yes. 17 Q. Yes. That was an instruction he gave you, wasn't it? 17 Q. You want us to take your assurance that you didn't pick any 18 A. That's correct. 18 other instructions not to follow, correct? 19 Q. Did you tell the truth? Did you follow that instruction? 19 MR. OKULA: Objection. 20 A. No. 20 THE COURT: Sustained. 21 Q. So, when you just said a couple of moments ago that you 21 Q. In your opinion, Ms. Conrad, did your perjury in voir dire 22 followed those instructions, you were lying right then? 22 affect your ability to act as a fair and impartial juror? 23 A. That's incorrect. I thought we were on the same page 23 A. No, not at all. 24 talking about the PJI at the end of the trial. 24 Q. Ms. Conrad, did I understand you to say that you thought 25 Q. Did I ever mention the PJI? 25 that it was basically no harm/no foul as far as the defense was SOUTHERN DISTRICT REPORTERS (57) Page 225 - Page 228 DOJ-OGR-00009949 --- PAGE BREAK --- Case 1:20-cv-03038-PAE Document 616-201 Filed 02/24/22 Page 48 of 67 A-5666 UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2frdau7 Conrad - redirect Page 225 ... (rest of the text from the image)