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Document A-5789

Document Type
Court Document
Date
02/24/22
Pages
2
Folder
IMAGES004

Full Text

Case 1:20-cr-00333 Document 616-2 Filed 02/24/22 Page 104 of 130 A-5789 C2GFDAU3 Edelstein 332 1 A. Subsequent to the July 15th conference. 2 Q. Can you put a date on that? 3 A. Actually, I'm not sure when I first saw it. I was informed 4 about it I think July 20th or so. I'm not sure. 5 Q. So Theresa Trzaskoma never told you about the Jesus e-mail 6 prior to her participation in the July 15th conference, is that 7 fair? 8 A. Yes. 9 Q. Did Theresa Trzaskoma tell you that a dossier had been 10 created at her request with respect to Catherine Conrad when 11 she was gathering information on May 12? 12 A. After we received the letter from Juror No. 1 on June 20th, 13 I had a conversation with Theresa Trzaskoma where she mentioned 14 that there was some information that had been gathered. 15 Q. And you said in response to that what? 16 A. I asked where it was and she was actually overseas at the 17 time and didn't have access to the computer, so she didn't, 18 wasn't sure exactly what, the file that was there, what had 19 been gathered, but she let me know where I could try to find 20 it. 21 Q. Just so we're clear, what date is this? 22 A. I believe the night of June 20th. 23 Q. And is it fair to say that you received the dossier? 24 A. I wouldn't characterize it as a dossier, but the next day I 25 was directed to the memo that David Benhamou our paralegal had SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009393 --- PAGE BREAK --- C2GFDAU3 Edelstein 332 1 A. Subsequent to the July 15th conference. 2 Q. Can you put a date on that? 3 A. Actually, I'm not sure when I first saw it. I was informed 4 about it I think July 20th or so. I'm not sure. 5 Q. So Theresa Trzaskoma never told you about the Jesus e-mail 6 prior to her participation in the July 15th conference, is that 7 fair? 8 A. Yes. 9 Q. Did Theresa Trzaskoma tell you that a dossier had been 10 created at her request with respect to Catherine Conrad when 11 she was gathering information on May 12? 12 A. After we received the letter from Juror No. 1 on June 20th, 13 I had a conversation with Theresa Trzaskoma where she mentioned 14 that there was some information that had been gathered. 15 Q. And you said in response to that what? 16 A. I asked where it was and she was actually overseas at the 17 time and didn't have access to the computer, so she didn't, 18 wasn't sure exactly what, the file that was there, what had 19 been gathered, but she let me know where I could try to find 20 it. 21 Q. Just so we're clear, what date is this? 22 A. I believe the night of June 20th. 23 Q. And is it fair to say that you received the dossier? 24 A. I wouldn't characterize it as a dossier, but the next day I 25 was directed to the memo that David Benhamou our paralegal had (212) 805-0300 SOUTHERN DISTRICT REPORTERS, P.C.

Individual Pages

Page 104 - DOJ-OGR-00009393
Case 1:20-cr-00333 Document 616-2 Filed 02/24/22 Page 104 of 130 A-5789 C2GFDAU3 Edelstein 332 1 A. Subsequent to the July 15th conference. 2 Q. Can you put a date on that? 3 A. Actually, I'm not sure when I first saw it. I was informed 4 about it I think July 20th or so. I'm not sure. 5 Q. So Theresa Trzaskoma never told you about the Jesus e-mail 6 prior to her participation in the July 15th conference, is that 7 fair? 8 A. Yes. 9 Q. Did Theresa Trzaskoma tell you that a dossier had been 10 created at her request with respect to Catherine Conrad when 11 she was gathering information on May 12? 12 A. After we received the letter from Juror No. 1 on June 20th, 13 I had a conversation with Theresa Trzaskoma where she mentioned 14 that there was some information that had been gathered. 15 Q. And you said in response to that what? 16 A. I asked where it was and she was actually overseas at the 17 time and didn't have access to the computer, so she didn't, 18 wasn't sure exactly what, the file that was there, what had 19 been gathered, but she let me know where I could try to find 20 it. 21 Q. Just so we're clear, what date is this? 22 A. I believe the night of June 20th. 23 Q. And is it fair to say that you received the dossier? 24 A. I wouldn't characterize it as a dossier, but the next day I 25 was directed to the memo that David Benhamou our paralegal had SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009393
Page 332 - DOJ-OGR-00010072
C2GFDAU3 Edelstein 332 1 A. Subsequent to the July 15th conference. 2 Q. Can you put a date on that? 3 A. Actually, I'm not sure when I first saw it. I was informed 4 about it I think July 20th or so. I'm not sure. 5 Q. So Theresa Trzaskoma never told you about the Jesus e-mail 6 prior to her participation in the July 15th conference, is that 7 fair? 8 A. Yes. 9 Q. Did Theresa Trzaskoma tell you that a dossier had been 10 created at her request with respect to Catherine Conrad when 11 she was gathering information on May 12? 12 A. After we received the letter from Juror No. 1 on June 20th, 13 I had a conversation with Theresa Trzaskoma where she mentioned 14 that there was some information that had been gathered. 15 Q. And you said in response to that what? 16 A. I asked where it was and she was actually overseas at the 17 time and didn't have access to the computer, so she didn't, 18 wasn't sure exactly what, the file that was there, what had 19 been gathered, but she let me know where I could try to find 20 it. 21 Q. Just so we're clear, what date is this? 22 A. I believe the night of June 20th. 23 Q. And is it fair to say that you received the dossier? 24 A. I wouldn't characterize it as a dossier, but the next day I 25 was directed to the memo that David Benhamou our paralegal had (212) 805-0300 SOUTHERN DISTRICT REPORTERS, P.C.