Document A-5820

Case 1:20-cv-03038-PAE Document 616-1 Filed 02/24/22 Page 53 of 117 A-5820 363 C2grdau4 Schoeman - cross 1 A. Yes. 2 Q. That's what any good lawyer or investigator does when 3 somebody tells them a broad fact; you ask what supports that, 4 correct? 5 A. It's the question I asked. 6 Q. Do you disagree with my proposition that a good 7 investigator or lawyer, when somebody gives them a broad 8 proposition, asks the follow-up question, what is that based 9 on? 10 A. I don't disagree with it. 11 Q. Did you ask Ms. Trzaskoma what had led her to conclude or 12 what led to her belief that there was a possible connection 13 between Juror No. 1 and the suspended attorney? 14 A. I think she told me that there was someone with the same 15 name as Juror No. 1. I don't recall whether we actually used 16 the person's name. Then, as I described, I asked questions 17 about why she had determined it was not the same person, and 18 the answer was based on the voir dire responses. 19 Q. Is it correct that you didn't ask any other follow-up 20 questions that led to her initial belief that there was a 21 connection between Juror No. 1 and the suspended attorney? 22 A. I think all she told me was that they had the same name, 23 and I inferred that was the basis of her considering it 24 possible that they were the same person. 25 Q. Did she tell you that they had the same middle initials? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009424 --- PAGE BREAK --- C2grdau4 Schoeman - cross 363 1 A. Yes. 2 Q. That's what any good lawyer or investigator does when 3 somebody tells them a broad fact; you ask what supports that, 4 correct? 5 A. It's the question I asked. 6 Q. Do you disagree with my proposition that a good 7 investigator or lawyer, when somebody gives them a broad 8 proposition, asks the follow-up question, what is that based 9 on? 10 A. I don't disagree with it. 11 Q. Did you ask Ms. Trzaskoma what had led her to conclude or 12 what led to her belief that there was a possible connection 13 between Juror No. 1 and the suspended attorney? 14 A. I think she told me that there was someone with the same 15 name as Juror No. 1. I don't recall whether we actually used 16 the person's name. Then, as I described, I asked questions 17 about why she had determined it was not the same person, and 18 the answer was based on the voir dire responses. 19 Q. Is it correct that you didn't ask any other follow-up 20 questions that led to her initial belief that there was a 21 connection between Juror No. 1 and the suspended attorney? 22 A. I think all she told me was that they had the same name, 23 and I inferred that was the basis of her considering it 24 possible that they were the same person. 25 Q. Did she tell you that they had the same middle initials? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010103