Full Text
C2GFDAU3 Edelstein 341
1 Q. You knew from the voir dire, didn't you, that the Catherine
2 Conrad who sat as Juror No. 1 referred to being involved in a
3 personal injury lawsuit, correct?
4 A. Yes.
5 Q. Did Theresa Trzaskoma tell you that document she had seen
6 in the form of the Westlaw report had indicated Catherine M.
7 Conrad as a party to a lawsuit?
8 A. No.
9 Q. Would you agree with me that you had the resources
10 available to you, that all you had to do was pick up the phone
11 and call Nardello or anyone else and ask them to go to a
12 courthouse or do investigating for you to try to establish a
13 link, or the link that Theresa Trzaskoma had suggested? Would
14 you agree that you had those resources?
15 A. We could have done that, but we didn't believe they were
16 the same person. We thought --
17 Q. So the answer is yes. You had those resources, right?
18 It's a simple question.
19 A. Yes, we could have called someone to investigate if we
20 thought that there was a reason to investigate.
21 Q. Now, after you received the juror letter that was sent to
22 you, you did call Nardello in to assist you in gathering
23 information, correct?
24 A. Yes.
25 Q. And that led to the preparation of your brief, correct?
1 SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010081