Document C2FFDAU6

Case 1:20-ec1-00330-PAE Document 1616120 Filed 02/24/22 Page 241 of 67 A-5659 UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL., February 15, 2012 C2FFDAU6 Conrad - direct Page 197 1 you put your cell number on your letter to Mr. Okula? 2 A. Because that's how I'm most accessible, sir. 3 Q. Because you wanted him to call you, didn't you, ma'am? 4 A. No, not at all. 5 Q. Well, then why did you care if you were most accessible that way or not? 6 7 A. Just a heading I use. That's all. 8 Q. No, you just told us that you put that on that letter because that's where you're most accessible. 9 10 A. That's true. But not with any forethought to an expectation of a call from Mr. Okula. 11 12 Q. Why did you care whether you were accessible or not? Why did you put a phone number on there? 13 14 A. Because that's usually what a heading has. 15 Q. And you made a conscious decision to put your phone number on there, right? 16 17 A. Sir, this is minutiae. I don't know. I can't answer that. 18 Q. You were hoping to be accessible for a phone call from Mr. Okula, correct? 19 20 A. Absolutely not. 21 Q. And would you agree with me that at times the tone of your letter was playful? 22 23 A. Oh, sure. 24 Q. Maybe even flirtatious, right? 25 A. That's -- please. Judge. C2FFDAU6 Conrad - direct Page 198 1 THE COURT: You can answer the question. 2 A. Absolutely not. 3 Q. Did you tell Mr. Okula that something, words to the effect that maybe he was on track to take Mr. Bharara's job from him? 4 5 A. Oh, yes. 6 Q. Now, did you hope that he would call you back, ma'am? 7 A. I'm not playing into this fantasy stuff. No, not at all. Please. 8 9 Q. Did you feel, did you think about putting the phone number that went with this address 16 Parkview Drive, did you think about putting that phone number on the letterhead? 10 11 A. No. 12 13 Q. Did you think about putting your real address on the letterhead? 14 15 A. That is my real address as well. 16 Q. Did you think about putting your Barker Avenue address on the letterhead? 17 18 A. Sir, it was probably just and pasted from another letter I had done. It wasn't conscious. 19 20 Q. Did you just make that up, just this moment, it was probably cut and pasted from another letter? Did you just make that up? 21 22 23 A. I'm answering your question, sir. 24 Q. No, I want to know if you just made that up or if you had any reason to believe that you cut and pasted this from another that up? 25 C2FFDAU6 Conrad - direct Page 199 1 letter. 2 A. Yes, I probably did cut and paste it. 3 Q. What other letter? 4 A. I have no idea. 5 Q. Okay. Now, in this letter you told Mr. Okula, and I quote, "I solely held out for two days on the conspiracy charge for him," referring to David Parse. "I wanted to convict 100 percent not only on that charge." Do you remember that? 6 7 8 9 A. Yes. 10 Q. And you're sure about that, right? You wouldn't lie to Mr. Okula, would you? 11 12 MR. OKULA: Judge, object on 606 grounds. 13 MR. GAIR: May I respond, your Honor? 14 THE COURT: No. Overruled. 15 Q. Did you tell Mr. Okula, "I solely held out for two days on the conspiracy charge for Parse. I wanted to convict 100 percent not only on that charge." Did you tell him that? 16 17 18 A. You're reading it correctly. 19 Q. Did you tell Judge Pauley on December 20th that "in my mind Parse should not have been convicted of number 1"? 20 21 A. Oh, I don't recall, sir. 22 Q. Well, let's look at Exhibit 3, page 16. Beginning at line 3. "For what? For what? I'll retain myself or my husband, the convicted felon. For what? For what, sir? To say that I convicted everybody except the stupid Brubaker? Parse was an idiot but we let him go because I had evidence enough that he really, he didn't really, in my mind he shouldn't have been convicted of number 1." C2FFDAU6 Conrad - direct Page 200 1 Did you say that to Judge Pauley on December 20th? 2 3 4 5 A. Yes, you're reading correctly. 6 Q. And that's a contradiction of what you said to Mr. Okula 7 day after the trial, correct? 8 A. I wasn't the only holdout. 9 MR. GAIR: Your Honor, I'm going to ask that this witness be instructed not to discuss the jury deliberations. I didn't ask about them. 10 11 THE COURT: Please -- 12 13 A. But in essence -- 14 THE COURT: Don't discuss the deliberations or the split of the vote among the jury. Respect the sanctity of jury deliberations, Ms. Conrad. 15 16 THE WITNESS: Yes. 17 18 THE COURT: And respond directly to counsel's questions. 19 20 Q. Ma'am, isn't it true that the statement you made to Judge Pauley on December 20th was directly contradictory to the statement you made to Mr. Okula in his letter of May 25th? 21 22 23 A. I don't know. 24 Q. Well, is it contradictory to say that a person should have Page 197 - Page 200 (50) SOUTHERN DISTRICT REPORTERS