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Document A-5790

AI Analysis

Summary: The witness discusses receiving a memo from David Benhamou, which included information about Juror No. 1's voir dire responses and an Appellate Division order. The witness confirms noticing details in the Appellate Division order and a suspension report related to Catherine M. Conrad.
Significance: This deposition transcript reveals details about the receipt and contents of a memo related to an investigation or case, potentially shedding light on the handling of information and the investigation process.
Key Topics: receipt of a memo by David Benhamou contents of the memo and related documents investigation or case details involving Catherine Conrad
Key People:
  • David Benhamou - author of the memo
  • Theresa Trzaskoma - witness's partner
  • Catherine M. Conrad - subject of a suspension report
Document Type
Court Filing
Date
02/24/22
Pages
2
Folder
IMAGES004

Full Text

Case 1:20-cr-00330 Document #:612/20 Filed:02/24/22 Page#105 of 130 A-5790 C2GFDAU3 Edelstein 333 1 put together and the Westlaw report. 2 Q. At what point did you become familiar with the fact that 3 your own partner, Theresa Trzaskoma, characterized it as a 4 dossier? 5 A. Several weeks later. 6 Q. So you received this information in the form of the file or 7 the memo to file by David Benhamou, is that correct? 8 A. Yes. 9 Q. You were where when you received it? San Francisco? 10 A. I was in San Francisco. 11 Q. Who sent it to you? 12 A. I was given a link to it, attachment in the e-mail. 13 Q. And the link was to what? 14 A. Was to the memo that David Benhamou had written. 15 Q. And the memo said what? 16 A. It just laid out I think Juror No. 1's voir dire responses, 17 it I think mentioned that there was the Appellate Division 18 order and that there was a link to the Westlaw report. 19 Q. Did you look at the Appellate Division order? 20 A. Yes. 21 Q. And did you notice that the Catherine Conrad in the 22 suspension report had a middle initial of M.? 23 A. Yes. 24 Q. Did you notice also that the Catherine M. Conrad in the 25 suspension report had a Bronxville address? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009394 --- PAGE BREAK --- C2GFDAU3 Edelstein 333 1 put together and the Westlaw report. 2 Q. At what point did you become familiar with the fact that 3 your own partner, Theresa Trzaskoma, characterized it as a 4 dossier? 5 A. Several weeks later. 6 Q. So you received this information in the form of the file or 7 the memo to file by David Benhamou, is that correct? 8 A. Yes. 9 Q. You were where when you received it? San Francisco? 10 A. I was in San Francisco. 11 Q. Who sent it to you? 12 A. I was given a link to it, attachment in the e-mail. 13 Q. And the link was to what? 14 A. Was to the memo that David Benhamou had written. 15 Q. And the memo said what? 16 A. It just laid out I think Juror No. 1's voir dire responses, 17 it I think mentioned that there was the Appellate Division 18 order and that there was a link to the Westlaw report. 19 Q. Did you look at the Appellate Division order? 20 A. Yes. 21 Q. And did you notice that the Catherine Conrad in the 22 suspension report had a middle initial of M.? 23 A. Yes. 24 Q. Did you notice also that the Catherine M. Conrad in the 25 suspension report had a Bronxville address? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010073

Individual Pages

Page 105 - DOJ-OGR-00009394
Case 1:20-cr-00330 Document #:612/20 Filed:02/24/22 Page#105 of 130 A-5790 C2GFDAU3 Edelstein 333 1 put together and the Westlaw report. 2 Q. At what point did you become familiar with the fact that 3 your own partner, Theresa Trzaskoma, characterized it as a 4 dossier? 5 A. Several weeks later. 6 Q. So you received this information in the form of the file or 7 the memo to file by David Benhamou, is that correct? 8 A. Yes. 9 Q. You were where when you received it? San Francisco? 10 A. I was in San Francisco. 11 Q. Who sent it to you? 12 A. I was given a link to it, attachment in the e-mail. 13 Q. And the link was to what? 14 A. Was to the memo that David Benhamou had written. 15 Q. And the memo said what? 16 A. It just laid out I think Juror No. 1's voir dire responses, 17 it I think mentioned that there was the Appellate Division 18 order and that there was a link to the Westlaw report. 19 Q. Did you look at the Appellate Division order? 20 A. Yes. 21 Q. And did you notice that the Catherine Conrad in the 22 suspension report had a middle initial of M.? 23 A. Yes. 24 Q. Did you notice also that the Catherine M. Conrad in the 25 suspension report had a Bronxville address? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009394
Page 333 - DOJ-OGR-00010073
C2GFDAU3 Edelstein 333 1 put together and the Westlaw report. 2 Q. At what point did you become familiar with the fact that 3 your own partner, Theresa Trzaskoma, characterized it as a 4 dossier? 5 A. Several weeks later. 6 Q. So you received this information in the form of the file or 7 the memo to file by David Benhamou, is that correct? 8 A. Yes. 9 Q. You were where when you received it? San Francisco? 10 A. I was in San Francisco. 11 Q. Who sent it to you? 12 A. I was given a link to it, attachment in the e-mail. 13 Q. And the link was to what? 14 A. Was to the memo that David Benhamou had written. 15 Q. And the memo said what? 16 A. It just laid out I think Juror No. 1's voir dire responses, 17 it I think mentioned that there was the Appellate Division 18 order and that there was a link to the Westlaw report. 19 Q. Did you look at the Appellate Division order? 20 A. Yes. 21 Q. And did you notice that the Catherine Conrad in the 22 suspension report had a middle initial of M.? 23 A. Yes. 24 Q. Did you notice also that the Catherine M. Conrad in the 25 suspension report had a Bronxville address? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010073