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C2rdau4 Berke - cross 375 1 suspended attorney named Catherine Conrad, the same name as 2 Juror No. 1? 3 A. I was never in a position where I needed to or had to make 4 decisions about the investigation. I don't understand that I'm 5 here as an expert witness. I can tell you as a matter of fact 6 what I knew, what I was told, the conversations I had, but I 7 really can't go beyond that, Mr. Okula. 8 Q. You're not going to answer my question? You've hired 9 private investigators many times as a lawyer, right? 10 A. I have. 11 Q. Are you unwilling to answer the question that I just asked 12 about what steps you would take if you learned that Catherine 13 Conrad, a suspended attorney, was in existence and you knew you 14 had Catherine Conrad sitting in seat number 1? Are you not 15 going to answer that question? 16 A. What you are ignoring is it's such a far-fetched idea that 17 any citizen would come in here and lie to be a juror. I have 18 never experienced it as a practicing lawyer. It never occurred 19 to me it happened in this trial, and it's not something I have 20 ever thought about it. When I've used investigators it's 21 because I'm defending someone in a criminal case or civil case 22 and I want to look at facts. You're asking me to speculate and 23 give opinions about an experience I've never had. 24 MR. OKULA: Judge, I have no further questions for Mr. 25 Berke. BERKE SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010115