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
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
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