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C2GFDAU3 Edelstein 327
1 Catherine Conrad, you have another Catherine Conrad. Can you
2 take some simple steps to try to investigate and look to see
3 whether they're the same people? Can you do that?
4 A. Yes.
5 Q. And how about this: Can you look to see if they have a
6 similar middle initial? Do you think that that increases the
7 likelihood that you're going to narrow the chances that it's
8 the same people? Would you agree with me that that's the case?
9 A. I mean, if you have the tools. I guess I'm not quite sure
10 what you're asking. If you're doing an investigation, yes, you
11 can look to see whether they have the same middle initial.
12 Q. Did you ask Theresa Trzaskoma what's the middle initial for
13 the suspended New York attorney?
14 A. No, I did not.
15 Q. Did you -- well, withdrawn. You were aware, were you not,
16 that your firm was in possession of the information showing
17 that Juror No. 1 was Catherine with middle initial M. Conrad,
18 correct?
19 A. No, I was not aware of that.
20 Q. So are you telling me that when Theresa Trzaskoma gives you
21 these two different names or two similar names, Catherine
22 Conrad and Catherine Conrad, you didn't suggest to her any
23 steps that she could take to try to determine whether it's the
24 same person?
25 A. No. We did SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300