+
+10 [REDACTED]
+
+#### second, that the correct response would have provided a valid basis for a challenge for cause.
+
+Federal Rule of Criminal Procedure 33 provides that, "[u]pon the defendant's motion, the court may vacate any judgment and grant a new trial if the interest of justice so requires." Fed. R. Crim. P. 33(a).
+
+The Sixth Amendment guarantees a criminal defendant the right to a trial by an impartial jury. U.S. Const. amend. VI. In McDonough Power Equipment, Inc. v. Greenwood, the Supreme Court recognized that "[o]ne touchstone of a fair trial is an impartial trier of fact—`a jury capable and willing to decide the case solely on the evidence before it.' 464 U.S. 548, 554 (1984) (quoting v. M, 455 U.S. 209, 217 (1982)). "The right to trial bcforc an impartial trier of fact—be it a jury or a judge therefore implicates Due Process as well as Sixth Amendment rights." United States v. Nelson, 277 F.3d 164, 201 (2d Cir. 2002).
+
+In turn, ligoir dire plays an essential role in protecting the right to trial by an impartial jury." United States v. Daugerdas, 867 F. Supp. 2d 445, 468 (S.D.N.Y. 2012) (granting new trial to three defendants based on juror dishonesty during voir dire and concluding one defendant, Parse, waived his new trial motion), vacated and remanded sub nom. United States v. Parse, 789 F.3d 83 (2d Cir. 2015) (reversing district court's conclusion that the defendant Parse waived his new trial motion). It is bedrock constitutional law that defendants have a right to "a full and fair opportunity to expose bias or prejudice on the part of veniremen" and that "there must be sufficient information elicited on voir dire to permit a defendant to intelligently exercise not only his challenges
+
+for cause, but also his peremptory challenges." United States v. Barnes, 604 F.2d 121, 139 (2d Cir. 1979) (internal quotations and citations omitted). "A juror's dishonesty during voir dire undermines a defendant's right to a fair trial." Daugerdas, 867 F. Supp. 2d at 468; U.S. Const. amend. VI.
+
+"[A] party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause." United States v. Stewart, 433 F.3d 273, 303 (2d Cir. 2006) (citing McDonough, 464 U.S. at 556).
+
+A defendant need not demonstrate prejudice when a juror gives a false answer to a material question during voir dire if the juror would have been subject to a challenge for cause if he had answered honestly. See United States v. 528 U.S. 304, 316 (2000) (the "seating of any juror who should have been dismissed for cause" "would require reversal"). When a biased juror deliberates on a jury, structural error occurs, and a new trial is required without a showing of actual prejudice. See Arizona v. Fuiminante, 499 U.S. 279, 307-10 (1991).
+
+#### B. An intentionally false answer during voir dire is not a prerequisite to obtaining a new trial.
+
+"Intentionally false" juror answers are not a prerequisite to a finding that a defendant's constitutional right to a fair and impartial jury have been violated. McDonough, 464 U.S. at 553-56; id. at 556-57 (Blackmun, J., concurring); id. at 557-59 (M, J., concurring in judgment). So long as a truthful answer would have subjected the juror to a challenge for cause based on bias, an inadvertent false answer is just as
+
+invidious as an intentionally false answer. United States v. Langford, 990 F.2d 65, 68 (2d Cir. 1993)." As the Second Circuit held in Langford:
+
+We read [McDonough] multi-part test as governing not only inadvertent nondisclosures but also nondisclosures or misstatements that were deliberate, for though the McDonough Court began with the inadvertent response before it, it stated that the further showing of cause must be made even after a juror's "failure to answer honestly," and it hypothesized that there could be various "motives for concealing." Concurring in the judgment, Justice similarly stated that a second element—bias—should be required even if the juror's erroneous response was deliberate. Thus, he stated that the
+
+proper focus when ruling on a motion for new trial in this situation should be on the bias of the juror and the resulting prejudice to the litigant. . .
+
+. . . Whether the juror answered a particular question on voir dire honestly or dishonestly, or whether an inaccurate answer was inadvertent or intentional, are simply factors to be considered in th[e] . . . determination of actual bias.
+
+Langford, 990 F.2d at 68 (quoting McDonough, 464 U.S. at 557-58 ( , J., concurring in judgment)).
+
+The seminal case addressing a juror's false answers during voir dire is McDonough Power Equipment, Inc. v. Greenwood. McDonough was a products liability action in which Juror Payton remained silent when the district court asked, "how many of you [potential jurors] have yourself or any members of your immediate family sustained any severe injury [in] an accident at home, or on the farm or at work that result in any disability or prolonged pain and suffering?" 464 U.S. at 550. After trial, it was discovered
+
+" This caselaw uses "deliberate" and "intentional" interchangeably.
+
+that Juror Payton's son had been injured in an explosion of a fire truck. Id. at 551. The district court denied a motion for a new trial without holding a hearing. Id.
+
+The court of appeals reversed, ordering a new trial instead of remanding for a hearing. Id. at 551-52. The court of appeals held that if "an average prospective juror would have disclosed the information, and that information would have been significant and cogent evidence of the juror's probable bias, a new trial is required to rectify the failure to disclose it." Id. at 552. "Good faith," said the court, was "irrelevant to the inquiry." Id.
+
+The Supreme Court reversed the court of appeals, concluding that it employed the wrong standard and erred in reaching the merits instead of remanding the case to the district court for an evidentiary hearing. Id. at 556. As for the correct legal standard, the Court said that
+
+to obtain a new trial in such a situation, a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause.
+
+Id. The Court remanded to the court of appeals to consider any outstanding issues and, assuming the judgment wasn't reversed for other reasons, to remand to the district court for an evidentiary hearing applying the new legal standard. Id.
+
+The court emphasized that "(vJoir dire examination serves to protect [the fair ti ial right by exposing possible biases, both known and unknown, on the part of potential jurors" and that the "necessity of truthful answers by prospective jurors if [voir dire] is to serve its purpose is obvious." Id. at 554. The Court did not expressly disavow the court of appeals' statement that the good faith of a potential juror was "irrelevant" to the inquiry. Id. at 553-56.
+
+There were two concurring opinions in McDonough, joined by a total of five justices, which make clear that an intentionally false answer is not a prerequisite to obtaining a new trial. Writing for himself and Justices Stevens and Justice Blackmun said:
+
+I agree with the Court that the proper inquiry in this case is whether the defendant had the benefit of an impartial trier of fact. I also agree that, in most cases, the honesty or dishonesty of a juror's response is the best initial indicator of whether the juror in fact was impartial. I therefore join the Court's opinion, but I write separately to state that I understand the Court's holding not to foreclose the normal avenue of relief available to a party who is asserting that he did not have the benefit of an impartial jury. Thus, regardless of whether a juror's answer is honest or dishonest, it remains within a trial court's option, in determining whether a jury was biased, to order a post-trial hearing at which the movant has the opportunity to demonstrate actual bias or, in exce tional circumstances, that the facts are such that bias is to be inferred. See v. M, 455 U.S. 209, 215-16 J., concurring).
+
+Id. at 556-57 (Blackmun, J., concurring (emphasis added)). This was the entirety of Justice Blackmun's dissent. Id.
+
+For his part, Justice joined by Justice Marshall recognized that "the bias of a juror will rarely be admitted by the juror himself, `partly because the juror may have an interest in concealing his own bias and partly because the juror may be unaware of it.'" Id. at 558 (M, J., concurring in judgment) (quoting majority opinion). "Necessarily," then, Justice explained, bias "must be inferred from surrounding facts and circumstances." Id. "Whether the juror answered a particular question on voir dire honestly or dishonestly, or whether an inaccurate answer was inadvertent or
+
+intentional, are simply factors to be considered in this latter determination of actual bias." Id. "One easily can imagine cases in which a prospective juror provides what he subjectively believes to be an honest answer, yet that same answer is objectively incorrect and therefore suggests that the individual would be a biased juror in the particular case." Id. at 559.
+
+The Second Circuit adopted this reading of McDonough, endorsing the view expressed by Justice (and shared by Justice Blackmun) that an intentionally false answer is not a prerequisite to obtaining a new trial. United States v. Langford, 990 F.2d 65, 68 (2d Cir. 1993) ("We read this multi-part test as governing not only inadvertent nondisclosures but also nondisclosures or misstatements that were deliberate."); id. at 68 (adopting Justice reasoning). Accordingly, in the Second Circuit, "a party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause." United States v. Stewart, 433 F.3d 273, 303 (2d Cir. 2006).
+
+Of course, individuals cannot be allowed to lie their way onto a jury. Writing for a unanimous Supreme Court, Justice Cardozo concluded: "If the answers to the questions [during voir dire] are willfully evasive or knowingly untrue, the talesman, when accepted, is a juror in name only . . . His relation to the court and to the parties is tainted in its origin; it is a mere pretense and sham." Clark v. United States, 289 U.S. 1, 11 (1933). "[A] juror who lies [his] way onto a jury is not really a juror at all; []he is an interloper akin `to a stranger who sneaks into the jury room."' Daugerdas, 867 F. Supp.
+
+2d at 468 (quoting Dyer v. Calderon, 151 F.3d 970, 983 (9th Cir.1998) (en banc)). "[C]ouds cannot administer justice in circumstances in which a juror can commit a federal crime in order to serve as a juror in a criminal case and do so with no fear of sanction so long as a conviction results." United States v. Colombo, 869 F.2d 149, 152 (2d Cir. 1989).
+
+## Argument
+
+### I. Ms. Maxwell is entitled to a new trial.
+
+This Court must order a new trial if Ms. Maxwell can make two showings: First, that Juror No. 50's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause. Stewart, 433 F.3d at 303. Even without an evidentiary hearing, Ms. Maxwell has made that showing here.
+
+### A. Juror No. 50 did not truthfully answer material questions during voir dire, including Questions 25 and 48.
+
+There is no reasonable dispute that Juror No. 50's voir dire responses were false. Juror No. 50 has told several media outlets that he was a victim of sexual assault and sexual abuse as a child. Necessarily, then, Juror No. 50 did not provide truthful answers when he denied being the victim of a crime (Question 25) or being a victim of sexual harassment, sexual abuse, or sexual assault (Question 48).
+
+And because being a victim of sexual assault or sexual abuse is material to an individual's ability to serve as a fair and impartial juror in a case about sexual assault and sexual abuse, Ms. Maxwell has satisfied the first prong of the McDonough test. See United States v. Sampson, 820 F. Supp. 2d 151, 172 (D. Mass. 2011) ("[A] matter is
+
+material if it has a natural tendency to influence, or be capable of influencing, the judge who must decide whether to excuse a juror for cause." (citing Neder v. United States, 527 U.S. 1, 16 (1999) (giving general definition of materiality))).
+
+#### B. Had Juror No. 50 answered Questions 25 and 48 truthfully, his answers would have provided a valid basis for a challenge for cause.
+
+The second question is whether truthful responses from Juror No. 50 would have provided a valid basis for a challenge for cause. See Stewart, 433 F.3d at 303. "[T]he test is not whether the true facts would compel the Court to remove a juror for cause, but rather whether a truthful response `would have provided a valid basis for a challenge for cause."' Daugerdas, 867 F. Supp. 2d at 470 (quoting McDonough, 464 U.S. at 556).
+
+"An impartial jury is one in which every juror is `capable and willing to decide the case solely on the evidence before [him]."' Id. (quoting McDonough, 464 U.S. at 554). "Jurors are instructed that they are to decide the question of a defendant's guilt based solely on the evidence presented." Id. (citing United States v. , 116 F.3d 606, 616- 17 n.10 (2d Cir. 1997). A juror is biased—i.e., not impartial—if his experiences "would `prevent or substantially impair the performance of his duties as a juror in accordance with his instructions and his oath."' Wainwright v. Witt, 469 U.S. 412, 424 (1985) (quoting v. Texas, 448 U.S. 38, 45 (1980)); see also United States v. 128 F.3d 38, 43 (2d Cir. 1997) (juror who structured financial transactions properly excused for cause in case involving structuring of cash deposits).
+
+Challenges for cause can be based on implied bias, inferable bias, or actual basis. See=, 128 F.3d at 43; see also Sampson, 820 F. Supp. 2d at 162-67 (discussing at length each type of bias).
+
+#### 1. Implied bias
+
+"Implied or presumed bias is `bias conclusively presumed as a matter of law.'" , 128 F.3d at 45 (quoting M, 299 U.S. at 133). "It is attributed to a prospective juror regardless of actual partiality." Id. "In contrast to the inquiry for actual bias, which focuses on whether the record at voir dire supports a finding that the juror was in fact partial, the issue for implied bias is whether an average person in the position of the juror in controversy would be prejudiced." Id. (citing Haynes, 398 F.2d at 984). "And in determining whether a prospective juror is impliedly biased, `his statements upon voir dire [about his ability to be impartial] are totally irrelevant." Id. (quoting Haynes, 398 F.2d at 984).
+
+As is relevant here, there are two ways in which courts imply bias. First, "[c]ourts imply bias `when there are similarities between the personal experiences of the juror and the issues being litigated.'" Daugerdas, 867 F. Supp. 2d at 472 (quoting Sampson, 820 F. Supp. 2d at 163-64); see also Skaggs v. Otis Elevator Co., 164 F.3d 511, 517 (10th Cir. 1998) (collecting cases where bias was implied based on the juror's experiences); see, e.g., Hunley v. Godinez, 975 F.2d 316, 319-20 (7th Cir. 1992) (holding, in a case charging murder in the course of a burglary, that bias should be implied where two jurors were the victims of similar burglaries during deliberations); Burton v. 948 F.2d 1150, 1159 (10th Cir. 1991) (holding, in murder case in which the defendant presented a
+
+defense based on having suffered domestic violence at the hands of the victim, that a juror living in similarly abusive circumstances at the time of trial, and who gave dishonest answers regarding that subject at voir dire, was impliedly biased); United States v. Eubanks, 591 F.2d 513, 517 (9th Cir. 1979) (per curiam) (implying bias where, in a trial for participation in a heroin distribution conspiracy, a juror failed to disclose at voir dire that he had two sons who were serving long prison sentences for heroin-related crimes).
+
+Second, courts imply bias when "repeated lies in voir dire imply that the juror concealed material facts in order to secure a spot on the particular jury." Daugerdas, 867 F. Supp. 2d at 472 (quotation omitted). "A juror . . . who lies materially and repeatedly in response to legitimate inquiries about her background introduces destructive uncertainties into the process." Dyer, 151 F.3d at 983.
+
+Under both theories, Juror No. 50 was impliedly biased. First, bias should be implied because this is a case in which "there are similarities between the personal experiences of the juror and the issues being litigated."' Daugerdas, 867 F. Supp. 2d at 472. "When a juror has life experiences that correspond with evidence presented during the trial, that congruence raises obvious concerns about the juror's possible bias." Sampson v. United States, 724 F.3d 150, 167 (1st Cir. 2013) (citing =, 128 F.3d at 4748; Burton, 948 F.2d at 1158-59). "In such a situation, the juror may have enormous difficulty separating her own life experiences from evidence in the case." Id. The First Circuit has commented, for example, that "it would be natural for a juror who had been
+
+the victim of a home invasion to harbor bias against a defendant accused of such a crime." Id.
+
+The same is true here: "It would be natural for a juror who had been the victim of [sexual assault and sexual abuse] to harbor bias against a defendant accused of such a crime." See id. Like Jane, Carolyn, Kate, and Juror No. 50 claims to be a victim of child sexual abuse. Like Jane, Carolyn, Kate, and , Juror No. 50 delayed disclosing the abuse he suffered. Like Jane, Carolyn, Kate, and Juror No. 50 says the memories of the abuse he suffered can be "replayed like a video." And like Jane, who described Mr. Epstein's New York apartment and said it had a "red mood," TR at 320, Juror No. 50 says he can remember the "color of the carpet, [of] the walls" in the room where he was abused.
+
+These similarities are profound because they bear on the principal argument Ms. Maxwell made against her accusers' claimed memories: They were corrupted and unreliable. Juror No. 50's claim that the memory of his abuse can be "replayed like a video" is perhaps most significant, because it directly contradicts Dr. Loftus's expert testimony:
+
+Q. Memory has been termed a constructive process; correct?
+
+A. Yes.
+
+Q. Could you explain what that means to the jury.
+
+A. What we mean by that is as I testified earlier, we don't just record events and play it back later like a recording device would work, like a video machine, but rather, we are actually constructing our memories when we retrieve memories. We often take bits and pieces of experience sometimes that occurred at different times and places, bring it together, and construct what feels like a recollection.
+
+TR at 2427. Given Juror No. 50's personal experience and belief about memory and its reliability, there was no way he could fairly evaluate Ms. Maxwell's challenge to the credibility of her accusers' memories or the expert testimony of Dr. Loftus.12
+
+Several decisions support this conclusion. In Sampson v. United States, for example, the First Circuit affirmed the district court's decision to order a new penaltyphase hearing in a death penalty case after a juror falsely denied, among other things, having been a victim of a crime. 724 F.3d at 154, 162. In fact, however, the juror repeatedly had been menaced by her husband with a shotgun. Id. at 168. But because the juror had not told the truth during voir dire, she was seated on a jury in a case involving a bank robbery in which the defendant threatened bank tellers at gunpoint. Id. "These parallels," the Court said, "raise a serious concern as to whether an ordinary person in [the juror's] shoes would be able to disregard her own experiences in evaluating the evidence." Id.
+
+To be sure, the juror in Sampson did not limit her false answers to a single question. She also answered falsely to several other questions during voir dire, some material and some not. Id. at 162-63, 166. A combination of factors led the First Circuit to affirm the order for a new penalty-phase hearing. Id. at 168. Here, Juror No. 50's false
+
+12 Juror No. 50's confidence in his memory is not necessarily a predictor of the memory's reliability. As Dr. Loftus testified, "when you have post-event suggestion or intervention, people get very confident about their wrong answers, and you can see that even wrong answers or false information, false memories can be expressed with a high degree of confidence." TR at 2430.
+
+answers to Questions 25 and 48 are reason enough to order a new trial because they relate to the core allegations against Ms. Maxwell. Moreover, if this Court orders an evidentiary hearing, it is likely additional false answers will come to light, further supporting the conclusion that Ms. Maxwell is entitled to a new trial.
+
+In State v. Ashfar, the defendant was convicted of aggravated sexual assault based on the allegation that he touched the genitals of his 12-year-old client during a therapy session. 196 A.3d 93, 94 (N.H. 2018).13 The empaneled jury, however, included an individual who had been sexually assaulted by a babysitter when he was five or six years old. Id. at 95. The juror had not disclosed this during voir dire and had, instead, answered "no" when asked if "[he] or a close member of your family or a close friend ever been a victim of a crime?" Id. at 95. The trial court ordered a new trial, relying both on the juror's false answer during voir dire but also his post-verdict conduct, which included communications with a female victim of sexual assault who wrote a book on the subject and the juror's self-identification as "an advocate for people." Id. at 96. The New Hampshire Supreme Court affirmed.
+
+The decisions in Sampson and Ashfar support a new trial here. Like those cases, Juror No. 50 falsely denied having a personal experience strikingly similar to the conduct at issue in the criminal case. Juror No. 50's experience as a sexual assault victim "raise[s]
+
+13 Because state courts are more often the venue for prosecution of crimes involving sexual assault, state court decisions are particularly helpful. The New Hampshire Supreme Court "assum[ed] without deciding that McDonough provides the applicable analytical framework" and concluded that the trial court "sustainably exercised its discretion in finding the juror "was not impartial." 196 A.3d at 97.
+
+a serious concern as to whether an ordinary person in [Juror No. 50's] shoes would be able to disregard [his] own experiences in evaluating the evidence." Id. Moreover, like the juror in Ashfar, Juror No. 50's post-trial conduct further supports a finding of implied bias. The juror in Ashfar communicated with a victim of sexual assault; here, Juror No. 50 communicated with Annie Famer. The juror in Ashfar viewed himself as "advocate for people;" here, Juror No. 50 proclaimed that the verdict against Ms. Maxwell was a verdict "for all the victims."
+
+The bias of Juror No. 50 should be implied for another reason: "[R]epeated lies in voir dire imply that the juror concealed material facts in order to secure a spot on the particular jury." Daugerdas, 867 F. Supp. 2d at 472. Here, not only did Juror No. 50 falsely deny on the questionnaire that he had been a victim of a crime and a victim of sexual assault and sexual abuse, he also falsely answered the Court's questions about social media. According to Juror No. 50, he used only Facebook and Instagram and he deleted all his social media accounts. In fact, Juror No. 50 was a Twitter user, having joined Twitter in April 2021. His Twitter account appears to have been active during trial and voir dire, notwithstanding his claim that he deleted all his social media accounts. Moreover, after trial, Juror No. 50 used Twitter to publicize his interviews with the press and to communicate directly to It also appears Juror No. 50 did not delete his Instagram account.
+
+Crucially, "[e]ven when prospective jurors are dishonest for reasons other th❑n a desire to secure a seat on the jury, dishonest answers to voir dire questions indicate that a juror is unwilling or unable `to apply the law as instructed by the court to the evidence
+
+presented by the parties' and, therefore, are indicative of a lack of impartiality because a fundamental instruction in every federal case is that a juror must render a verdict `solely on the evidence presented at trial."' Sampson, 820 F. Supp. 2d at 165 (quoting M, 116 F.3d at 617 & n.10 (citing The Federal Judicial Center's Benchbook for U.S. District Court Judges)). Therefore, dishonest answers are a factor that can contribute to a finding of implied bias. See Skaggs, 164 F.3d at 517.
+
+The false answers Ms. Maxwell knows about so far, by themselves, provide a basis for a new trial because, if they had been exposed during voir dire, this Court would have treated Juror No. 50 just as it treated Juror No. 55. As explained above, Juror No. 55 was dismissed for cause when the Court, at defense counsel's request, confronted him with his Twitter account after he falsely denied using Twitter. TR 11/16/2021, pp 155-59.
+
+Here, too, Juror No. 50 falsely denied having a Twitter account. It also appears that he was not telling the truth when he said he deleted his Instagram account. But he also did much more, falsely denying that he had been a victim of sexual assault or sexual abuse. If Juror No. 55's false answers "provided a valid basis for a challenge for cause," Stewart, 433 F.3d at 303, Juror No. 50's false answers do as well.
+
+This Court should treat Juror No. 50 just as it treated Juror No. 55, and on that ground order a new trial. Should this Court hold a hearing, however, it would not be surprising if additional false answers come to light.
+
+"Inferable' or 'inferred' bias exists `when a juror discloses a fact that bespeaks a risk of partiality sufficiently significant to warrant granting the trial judge discretion to excuse the juror for cause, but not so great as to make mandatory a presumption of bias.' Daugerdas, 867 F. Supp. 2d at 474 (quoting United States v. Greer, 285 F.3d 158, 171 (2d Cir. 2002)). A court should dismiss a potential juror for inferable bias "after having received responses from the juror that permit an inference that the juror in question would not be able to decide the matter objectively." =, 128 F.3d at 47. "[T]his is so even though the juror need not be asked the specific question of whether he or she could
+
+"Moreover, once facts are elicited that permit a finding of inferable bias, then, just as in the situation of implied bias, the juror's statements as to his or her ability to be impartial become irrelevant." Id. "The crux of the implied bias analysis in a case like this one is found in an examination of the similarities between the juror's experiences and the incident giving rise to the trial." 128 F.3d at 48 (quoting v. M, 99 F.3d 978, 989 (10th Cir. 1996)). Assuming this Court does not imply bias, it should nevertheless infer bias.
+
+In United States v. the defendant was convicted of conspiracy to launder the proceeds of a heroin trafficking scheme by structuring financial transactions. 128 F.3d at 41. Over the defense's objection, the district court (Judge Preska) dismissed for cause a potential juror who admitted that she "had at one time engaged in the 'structuring' of cash transactions." Id. at 42. On appeal, the Second Circuit affirmed, concluding that the
+
+district court did not err in inferring bias. Id. at 4748. "Given the similarity of Juror No. 7's structuring activity to the conduct alleged against appellant Devery in this case, it was reasonable for Judge Preska to conclude that the average person in Juror No. 7's position might have felt personally threatened." Id. at 48. Although the Court in declined to define the "precise scope of a trial judge's discretion to infer bias," Judge Calabresi further explained:
+
+It is enough for the present to note that cases in which a juror has engaged in activities that closely approximate those of the defendant on trial are particularly apt. The exercise of the trial judge's discretion to grant challenges for cause on the basis of inferred bias is especially appropriate in such situations.
+
+Id. at 47 (emphasis added).
+
+Just as it is "especially appropriate" for a court to infer bias when a potential juror has engaged in "activities that closely approximate those of the defendant on trial," so too is it "especially appropriate" for a court to infer bias when a potential juror has been subject to conduct "that closely approximate[d] [that] of the defendant on trial." See id. In such a case, there is just too great a risk that such a juror will not be able to decide the case purely based on the applicable law and the evidence or lack of evidence, even though that inability may be unconscious. This is one such case.
+
+## 3. Actual bias
+
+"Actual bias is `bias in fact'—the existence of a state of mind that leads to an inference that the person will not act with entire impartiality." 128 F.3d at 43 (citing United States v. M, 299 U.S. 123, 133 (1936)). "A juror is found by the judge to be partial either because the juror admits partiality, or the judge finds actual partiality
+
+based upon the juror's voir dire answers." Id. (citing United States v. Haynes, 398 F.2d 980, 984 (2d Cir. 1968) (actual bias is "based upon express proof, e.g., by a voir dire admission by the prospective juror of a state of mind prejudicial to a party's interest"); Rosales-My. United States, 451 U.S. 182, 188 (1981) (plurality opinion) ("Without an adequate voir dire the trial judge's responsibility to remove prospective jurors who will not be able impartially to follow the court's instructions and evaluate the evidence cannot be fulfilled.")).
+
+This Court need not decide whether Juror No. 50 was actually biased, since this Court can and should imply and infer bias. Assuming this Court holds an evidentiary hearing at which Juror No. 50 is compelled to give truthful answers to the questions he would have been asked if he had not falsely responded to the questionnaire, Ms. Maxwell reserves the right to argue that Juror No. 50 was actually biased.
+
+## C. Juror No. 50's answers to Questions 25 and 48 were intentionally false.
+
+Ms. Maxwell does not need to prove that Juror No. 50's voir dire answers were intentionally false. As explained above, she need only prove "first, that the juror's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause." Stewart, 433 F.3d at 303. Nevertheless, assuming this Court concludes that Ms. Maxwell must prove Juror No. 50 intentionally misled the Court in falsely answering Questions 25 and 48, Ms. Maxwell has easily met that burden.
+
+There are at least six reasons to believe Juror No. 50 acted intentionally. First, this Court need only watch the video of Juror No. 50 being confronted with his false answers to appreciate that he acted intentionally. Juror No. 50's face immediately flushed and
+
+turned red, and he grasped for words when the Daily Mail reporter told him about Question 48. "Interesting," Juror No. 50 said, struggling for an explanation. Unable to credibly explain away his false answer, Juror No. 50 eventually put together a nonsensical response: "No, No! I know my face is red because I can feel the blood but, I honestly—that's why I answered it that way."
+
+Second, Juror No. 50's attempt to justify his false answer by claiming he "flew through" the questionnaire is not worthy of belief. The questionnaire instructed potential jurors to "carefully" compete it. No time limitation was imposed for completion of the questionnaire. It emphasized that only the parties and the Court would know the identities of the jurors. It advised that there are no "right or wrong" answers, "only truthful answers." And it assured jurors that their privacy would be respected and that if an answer to any question was embarrassing or caused the juror particular concern, they could alert the Court. The Court must presume Juror No. 50 heeded these instructions. Indeed, there is compelling evidence that Juror No. 50 carefully followed these instructions and did not "fly through" the questionnaire, as he now claims. For example, he correctly skipped follow-up questions that he did not need to answer if he answered "no" to the initial question and provided written explanations for some questions when called to do so. Ex. 1, p 17 (Question 34.a); p 18 (Question 37.a). Juror No. 50 also certified, under the penalty of perjury, that his answers were "true and correct." Ex. 1, p 27.
+
+Third, it is simply not credible that Juror No. 50 would not recognize and then not remember that the questionnaire asked if he was a victim of sexual assault, sexual abuse,
+
+or sexual harassment. Juror No. 50 said he did remember the questionnaire's asking whether his family or friends had been victims of sexual assault, sexual abuse, or sexual harassment. But as the questionnaire itself explained and as this Court told Juror No. 50 during his voir dire, the entire point of the process was to evaluate whether Juror No 50 could be fair and impartial. Ex. 1, p 3 ("The purpose of this questionnaire is to determine whether prospective jurors can decide this case impartially based upon the evidence presented at trial and the legal instructions given by the presiding judge."). The questionnaire also told potential jurors that it would ask personal questions. Id. ("Although some of the questions may appear to be of a personal nature, please understand that the Court and the parties must learn enough information about each juror's background and experience to select a fair and impartial jury."). A personal experience as a victim of sexual assault, sexual abuse, or sexual harassment is far more relevant to fairness and impartiality than a family member's or friend's experience with such assault, abuse, or harassment. Given the content of the questionnaire and its obvious purpose, remembering a question about the latter but not the former is simply not credible.
+
+Fourth, Juror No. 50's post-verdict conduct shows his false answers to the questionnaire were intentional. Juror No. 50 went on a media press to promote himself, his experience as a victim, and his role on the jury. He has given multiple interviews to
+
+several different news outlets (some of which he was likely paid for) 14, and he sat for an interview as part of an hour-long "documentary" called "Ghislaine, Prince Andrew and the Paedophile," which aired on the British channel ITV. He has engaged on Twitter with the journalist who wrote about him. and he has communicated directly with-
+
+\_. See Ashfar, 196 A.3d at 95-96 (relying on juror's post-trial conduct as a basis for concluding juror was biased and new trial was required because juror falsely answered material question during voir dire). Juror No. 50's publicity tour appears to have stopped (at least temporarily) only because the government publicly filed a letter asking this Court to inquire into Juror No. 50's truthfulness and suggesting that he needed a lawyer. The clear message from the government to Juror No. 50 was to stop talking.°
+
+The government recognized that Juror No. 50 had dug a very deep hole—a hole that looked to be getting deeper. Without conferring as to either the submission of the letter or any redactions, the government publicly filed Docket No. 568. This letter communicated to Juror No. 50, and the media, that Juror No. 50 had done something wrong, that his conduct would be subject to scrutiny, and that the conduct was serious enough to warrant appointment of a lawyer, free of charge if necessary.
+
+Had Ms. Maxwell been asked, she would have objected to the public filing of this letter, which caused Juror No. 50 to delete his social media accounts and alerted Juror No. 50 that he needed to stop giving media presentations and to work on his story.
+
+The government knows how to file a letter under seal, and this Court's protocol throughout this case has been for the parties to file letters or pleadings under restriction with a conferral and briefing as to what portion of the document should be redacted. The
+
+14 It is common for the British press to pay for crime victims' stories. See, e.g, https://www.mirror.co.uk/sell-my-story/; https://trianglenews.co.uk/sell-my-story-to-thedaily-maill; https://www.dailymail.co.uldhome/contactus/index.html
+
+IS Juror No. 50 was clearly enjoying his fifteen minutes of fame in early January 2022, giving multiple interviews in which he congratulated himself as the person who persuaded the other jurors to adopt his biased view of the evidence and to vote to convict Ms. Maxwell.
+
+Fifth, Juror No. 50's false answer to question 48 was not a one-off mistake. He also falsely answered question 25. Then, during voir dire, he claimed that he used only Facebook and Instagram and that he had deleted both. In fact, he also used Twitter, and it appears he did not delete his Instagram account. This pattern of false answers supports a finding of intent and belies mere inadvertence.
+
+Finally, this case is not like other cases in which a juror may have given a false answer to avoid embarrassment,. Juror No. 50 has spoken to numerous media outlets about his service as a juror, has freely admitted that he is the victim of sexual abuse and sexual assault, and has done the bare minimum to conceal his identity, allowing himself to be identified by his first name while posing for pictures and being video recorded. Juror No. 50 has not shunned the limelight. He has reveled in it.
+
+#### D. Had Juror No. 50 answered Questions 25 and 48 truthfully, the parties and the Court would have explored whether his other answers were false.
+
+Regardless of whether Juror No. 50's answers were intentional lies or inadvertent misstatements, his false answers to Questions 25 and 48 cast doubt on the truthfulness of all his answers, including most particularly those questions designed to expose bias based on the nature of charges against Ms. Maxwell—Questions 42-50.
+
+At the October 21 hearing, this Court emphasized the importance of voir dire, and it expressed confidence that it could "smoke out" jurors who did not tell the truth:
+
+letter was written by the government with full knowledge that it would be published by the media and effectively silence Juror No. 50. The submission of the letter was an end run around this Court's orders regarding Local Rule 23.1 and Rule 3.6 of the Rules of Professional Conduct.
+
+I will individually, one-on-one, question[] the jurors, and with the parties present, I feel confident that I can discern any clear dishonesty. This is not just going to be a summary voir dire; it will be probing. ... If a juror's going to lie and be dishonest, we will smoke that out.
+
+TR 10/21/2021, p 25-26. Because Juror No. 50 did not honestly answer these material questions, however, the Court and the defense were not alerted to probe these issues and instead relied on Juror No. 50's claim that he could be fair and impartial. In hindsight, that claim is not credible.
+
+This is not speculation. Rather, based on what Juror No. 50 has said to the media, it's clear he was not fair and impartial because his personal experiences "prevent[ed] or substantially impair[ed] the performance of his duties as a juror in accordance with his instructions and his oath." Wainwright, 469 U.S. at 424. If Juror No. 50 had truthfully disclosed that he was a victim of sexual assault and sexual abuse as a child, the Court and parties would have probed, among other things, whether he was able (1) to assess the credibility of alleged sex assault victim like all other witnesses; (2) to fairly evaluate the testimony of Dr. Loftus; (3) to impartially assess Ms. Maxwell's defense that her accusers' memories were unreliable and tainted by money and manipulation; and (4) set aside his own traumatic experience when evaluating whether the government met its burden of proof beyond a reasonable doubt.
+
+Juror No. 50's failure to disclose that he was a victim of sexual abuse (Question 48) was further compounded by his failure to disclose that he was merely a victim of a crime (Question 25). Disclosing that he was a crime victim would have invited inquiry by counsel and the Court regarding the nature of the crime and would have provided a
+
+basis for a cause challenge or a peremptory challenge. Juror No. 50's false answers to both questions deprived the Court of any basis for any meaningful inquiry on a topic bearing directly on his ability to serve impartially and the basis for a cause challenge. In addition, the failure to be truthful on both questions cannot be purely accidental; rather, it suggests the juror's intention to shield disqualifying information to advance a desire to serve, which he has now exploited for self-promotion.16
+
+We know, moreover, that Juror No. 50 gave at least one other false answer during voir dire. He falsely said he only used Facebook and Instagram, and he did not mention Twitter, despite being specifically asked about it. He also said that he deleted his social media accounts. That was not true since, as we now know, he used Twitter to publicize his interviews with the press and to communicate directly to and then posted on Instagram about his service as a juror.
+
+Truthful answers from Juror No. 50 would have led the Court and the parties to probe much more deeply into his biases and prejudices, both known and unknown." Had that happened, the record shows that he would have been removed as a potential juror.
+
+16 Juror No. 50 continues his media exploits despite being the subject of this Motion and represented by counsel. On January 18, 2022, he appeared in a documentary produced by ITV. See https://www.youtube.com/watch?v=SvnwRuDfrdM at timestamps 01:53, 02:32, 04:10, 05:10, 34:36, 38:41, 39:15.
+
+" This follow-up questioning would not have been a mere formality. We know, for example, that that Juror No. 55 did not truthfully answer the Court's questions about social media use, and it took follow-up questioning proposed by defense counsel to "smoke out" his falsehoods.
+
+#### E. Juror 50's material misstatements (and those of the second unidentified juror) prevented Ms. Maxwell from exercising her peremptory challenges, denying her a fair trial.
+
+Proper voir dire plays a vital role in assuring a defendant's Sixth Amendment right to an impartial jury. Without an adequate voir dire the trial judge's responsibility to remove prospective jurors who may not be able impartially serve cannot be fulfilled. "Similarly, lack of adequate voir dire impairs the defendant's right to exercise peremptory challenges where provided by statute or rule, as it is in the federal courts." Rosales= v. United States, 451 U.S. 182, 188 (1981) (citation omitted).
+
+The role of peremptory challenges in a criminal trial cannot be overstated:
+
+Peremptory challenges have been an integral aspect of criminal trial procedure for over six hundred years and continue to be universally employed throughout the country. The underlying thesis is that, with the exception of challenges for cause, the suitability of a particular juror is counsel's decision and not the court's. Consistent with that thesis and subject to constitutional strictures, a peremptory challenge can rest on a good reason, a bad reason, or no reason at all.
+
+State v. Scher, 278 N.J. Super. 249, 263, 650 A.2d 1012, 1019 (App. Div. 1994) (cleaned up).
+
+Fed. R. Crim. P. 24 entitles a number of peremptory challenges to prospective jurors. Here, Ms. Maxwell exercised all of her peremptory challenges and, whether for cause or peremptory, would not have knowing allowed a juror who: (1) claimed to be a victim of sexual abuse; or (2) neglected to disclose that the juror had been a victim of sexual abuse; (3) misrepresented the status of the juror's social media to remain on the jury. Had Juror 50 disclosed any of these issues, Ms. Maxwell would have used a peremptory challenge against this juror and not as to any of the other remaining jurors.
+
+As discussed in v. Nogam, No. CV 14-4268 (KM), 2018 WL 278735, at \*25 (D.N.J. Jan. 3, 2018), affd sub nom. v. Adm'r E. Jersey State Prison, No. 18- 2825, 2021 WL 2822179 (3d Cir. July 7, 2021), New Jersey courts have repeatedly
+
+invalidated judgments where a juror's inaccurate answer to a question propounded in the jury voir dire precluded a litigant from exercising a peremptory challenge. State v. Scher, 278 N.J. Super. L49 263 (App.Div.1994), cert. denied, 140 N.J. 276 (1995) (citing v. Bernstein, 23 N.J. 284 (1957); State v. 190 N.J.Super. 111 (App. Div. 1983); State v. Thompson, 142 N.J. Super. 274 (App. Div. 1976)).
+
+Of course, the material omissions by Juror 50 were not made in New Jersey. The prejudice to Ms. Maxwell and the concept of fundamental fairness, however, are the same regardless of which side of the Hudson the misstatements occurred. In a very close, contested trial where the only real issue was the credibility of the accusers, the failure of Juror 50 to disclose his claimed victim status in jury selection cheated Ms. Maxwell of her ability to intelligently exercise her peremptory challenges and robbed her of a fair trial. In this case truthful responses would have revealed Juror 50's claimed victim status. He would have been excused for cause on that basis alone and would never answered any questions in person.
+
+Even if Juror 50 had claimed on the questionnaire that he could be fair, despite his victim status, the result would have been the same. He would have been asked to describe to the Court and the parties, under oath, what he claimed happened to him, when it happened, the impact on him, and how he could still be fair. Had Juror 50 revealed to the Court, as he did to the media, that he believed that his memory "was like a video" and that he would advocate that the alleged victims here were credible, based on his own
+
+experiences, he would have been excused, if not for cause, then as a defense peremptory strike.
+
+#### II. The scope of any evidentiary hearing
+
+Ms. Maxwell does not believe an evidentiary hearing is required because the undisputed evidence shows (1) that Juror No. 50 falsely answered a material question during voir dire and (2) that, had he answered truthfully, he would have been subject to a challenge for cause. If this Court disagrees, however, a formal evidentiary hearing is appropriate.
+
+When, as here, there is a plausible claim of juror misconduct, "an unflagging duty falls to the district court to investigate the claim." United States v. , 904 F.3d 111, 117 (1st Cir. 2018) (quotation omitted). "[A] formal evidentiary hearing [is] the gold standard for an inquiry into alleged juror misconduct." United States v. , 977 F.3d 114, 122 (1st Cir. 2020), cert. denied, 141 S. Ct. 2601 (2021), cert. denied sub nom. v. United States, 141 S. Ct. 2601 (2021).
+
+## A. Pre-hearing discovery
+
+Ms. Maxwell requests that the Court authorize subpoenas to:
+
+- I. Juror No. 50 to produce:
+ - a. Emails or other written communications between Juror No. 50 and any alleged victim or witness in this case;
+ - b. Emails or other written communications between Juror No. 50 and any other juror in this case;
+
+- c. Non-privileged emails or other written communications between Juror No. 50 and any other person, including any news or media organization about Juror No. 50's service as a juror in this case;
+- d. Any record of payments to Juror No. 50 in exchange for any interview or information about his service as a juror in this case;
+- 2. Facebook, Twitter, Linkedln, Instagram, or other social media networking platforms identified by the parties, to produce:
+ - a. All communications to and from Juror No. 50 regarding his service as a juror in this case;
+ - b. All posts, comments, or photographs posted by Juror No. 50 regarding his service as a juror in this case.
+ - c. All documents reflecting dates on which Juror No. 50 opened or closed his accounts.
+
+## B. The hearing itself
+
+The misconduct identified potentially implicates all 12 jurors who rendered a verdict here. According to Juror No. 50 and the New York Times, one other juror did not disclose that he or she was the victim of sexual abuse as a child. Nevertheless, that juror's experiences were discussed apparently in support of Juror No. 50's position. What these two jurors disclosed to the (presumably) ten jurors who responded to the questionnaire truthfully will be relevant to determine the identity of the second juror and what Juror No. 50 said to the other jurors.
+
+Ms. Maxwell requests that any hearing begin with the questioning of Juror No. 50. Ms. Maxwell requests that the Court first advise Juror No. 50 about the nature of the hearing and then allow defense counsel to question Juror No. 50 followed by questioning from the government, re-cross examination by defense counsel, followed by any questions from the Court and any additional questions from counsel based on the Court's questions.
+
+If, after this examination further inquiry is required, Ms. Maxwell suggests that the second juror be summoned to Court for an identical process. If necessary, this process should be repeated as to all remaining jurors.
+
+After the examination of the jurors the parties should be afforded a period of time to conduct any further investigation warranted by the information presented at the hearing followed by post-hearing arguments, either oral or written.
+
+Federal Rule of Evidence 606(b) does not prohibit this inquiry, because Ms. Maxwell does not seek to impeach the verdict based on the content of deliberations. Cf. Fed. R. Evid. 606(b) (providing that, with certain exceptions, "a juror may not testify about any statement made or incident that occurred during the jury's deliberations" during "an inquiry into the validity of a verdict"). Instead, she intends to show that her jury was not fair and impartial as required by the Sixth Amendment because at least two jurors gave false answers during voir dire to material questions that, if answered truthfully, would have subject them to a challenge for cause.
+
+To the extent Rule 606 might apply to certain questions asked at the hearing, Ms. Maxwell need not inquire into the content of deliberations to establish her jury bias
+
+claim. See Cunningham v. Shoop, F.4th 2022 WL 92594, at \*14-15 (6th Cir. Nos. 11-3005/20-3429, Jan. 10, 2022) (granting habeas relief as to juror bias claim because it is "possible for Cunningham to prove that [the juror] was actually biased without relying on juror testimony in violation of Federal Rule of Evidence 606(b)"); compare Pena-Rodriguez v. Colorado, 137 S. Ct. 855 (2017) ("Where a juror makes a clear statement indicating that he or she relied on racial stereotypes or animus to convict a criminal defendant, the Sixth Amendment requires that the no-impeachment rule give way in order to permit the trial court to consider the evidence of the juror's statement and any resulting denial of the jury trial guarantee."). Without relying on juror testimony, it is already clear that Juror No. 50 did not truthfully answer the questionnaire; Juror No. 50 has publicly admitted he is a victim of sexual assault and sexual abuse.
+
+As for identifying the other juror who was also a victim of sexual assault and abuse, the Court and parties can identify the juror without eliciting testimony about what was said during deliberations. The remaining eleven jurors can be asked, under oath, whether their answer to question 48 is correct and whether they have been a victim of sexual assault or abuse. Presumably the second juror will self-identify.
+
+## III. Juror No. 50 has no right to intervene.
+
+## A. Juror No. 50 lacks standing.
+
+Juror No. 50 seeks to intervene suggesting that "it is indisputable that precedent supports intervention by interested third parties in criminal matters...." Memo. at 8. This claim is not supported by "the long line of precedent hold[ing] that a non-party lacks a judicially cognizable interest in a defendant's prosecution." United States v. Stoerr, 695
+
+F.3d 271, 278 (3d Cir. 2012). Juror No. 50 is not a party here and there is no legal basis for Juror No. 50 to intervene in this matter. This is not a request by a journalist to intervene for public access. See United States v. Aref, 533 F.3d 72, 81 (2d Cir. 2008) (motion to intervene to assert the public's First Amendment right of access to criminal proceedings is proper). Nor is the request from a subpoena respondent. See United States v. RMI Co., 599 F.2d 1183, 1186 (3d Cir. 1979) (persons affected by the disclosure of allegedly privileged materials may intervene in pending criminal proceedings and seek protective orders). Although Juror No. 50 has expressed a questionable interest in the outcome of this case, that does not afford him standing to intervene. Notably, the Federal Rules of Criminal Procedure make no reference to a motion to intervene in a criminal case. This is a recognition of the general rule that "a private citizen lacks a judicially cognizable interest in the prosecution or nonprosecution of another." Linda R.S. v. Richard D., 410 U.S. 614, 619 (1973). And as one court has noted, "[e]ven crime victims, who enjoy various statutory rights of participation, have no right to intervene in the district court in a criminal case." United States v. 2013 WL 4780927, at \*1 (E.D. Wis. 2013).
+
+#### B. This Court should refuse Juror No. 50's discovery request because Juror No. 50 is under investigation and the release of the information requested would prejudice that investigation.
+
+It is the conduct of Juror No. 50 that is under investigation here. Like many suspects, Juror No. 50 would like to learn as much information about the investigation so that he can tailor responses to any potential questions and change the focus of the investigation. Once he was thoroughly tipped off by the government, Juror No. 50 has
+
+sought to distance himself from his original statements, attempted to destroy evidence, and tried to flee from the media.
+
+Under analogous circumstances courts have refused discovery to individuals or entities under investigation. See John Doe Agency v. John Doe Corp., 493 U.S. 146, (1989) (recipient of a grand jury subpoena for certain records relating to a cost allocation appropriately denied access to records pursuant to a FOIA request).
+
+Any advance disclosure to Juror No. 50 of the questionnaire will undoubtably color Juror No. 50's testimony and allow him to place himself in the best possible posture. Although there may come a time when Juror No. 50 is entitled to this discovery—if he is charged with perjury, criminal contempt, or some other crime, for example—the time is not now.
+
+## C. Juror No. 50's filings should be stricken or, alternatively, remain under sad.
+
+Whether a claimant has standing is "the threshold question in every federal case, determining the power of the court to entertain the suit." In re Gucci, 126 F.3d 380, 387- 88 (2d Cir. 1997) (citing Warth v. Seldin, 422 U.S. 490, 498, (1975)). Striking the pleading of a putative litigant is appropriate where the litigant lacks standing. United States v. All Right, Title & Int. in Prop., Appurtenances, & Improvements Known as 479 Tamarind Drive, Hallendale, Fla., No. 98 CIV. 2279 DLC, 2011 WL 1045095, at \*2 (S.D.N.Y. Mar. 11, 2011). A stricken pleading is a nullity with no legal effect. v. Bombardier Recreational Prod., Inc., No. 3:11CV236-TSL-MTP, 2012 WL 112202, at \*3 (S.D. Miss. Jan. 12, 2012) (stricken amended complaint deemed a nullity and of
+
+no legal effect). Although Rule 12(f) of the Federal Rules of Civil Procedure references "pleadings," "a district court has the inherent power to strike a party's submissions other than pleadings." Mazzeo v. Gibbons, No. 2:08-CV-01387-RLH-PA, 2010 WL 3910072, at \*3 (D. Nev. Sept. 30, 2010); see also Metzger v. Hussman, 682 F. Supp. 1109, 1110 (D. Nev. 1988) (motion to strike granted and motion in opposition not considered by the court). This Court should strike all the filings made by Juror No. 50.
+
+Alternatively, Ms. Maxwell requests that the "Memorandum of Law in Support of Motion to Intervene and for Release of Sealed Jury Questionnaire and Transcript, on Behalf of Proposed Intervenor, Juror 50" and its companion Motion remain under seal, at least until a resolution of Ms. Maxwell's motion for new trial based on this Juror's failure to answer truthfully during jury selection. Juror No. 50's Motion and accompanying Memorandum are an attempt to obtain discovery by a non-party to this criminal case, made by someone who lacks standing to participate in this prosecution. Accordingly, these pleadings are not "judicial documents" and are afforded no presumption of public access. United States v. 985 F. Supp. 2d 506, 519 (S.D.N.Y. 2013) ("experience and logic show that there is no right of access to discovery materials"). See SEC v. The Street.Com, 273 F.3d 222, 233 (2d Cir.2001) (rejecting claim that deposition testimony became a "judicial document" "because the Court reviewed it in order to decide whether or not to enter [a] protective order").
+
+The fact that Juror No. 50 filed these pleadings does not make them "judicial documents." United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995) ("We think that the mere filing of a paper or document with the court is insufficient to render that paper a judicial document subject to the right of public access. We think that the item filed must be relevant to the performance of the judicial function and useful in the judicial process in order for it to be designated a judicial document."). Moreover, if stricken, the documents enjoy no presumption of public access. v. Maxwell, 929 F.3d 41, 51-52 (2d Cir. 2019) ([under Civil Rule 12], "the district court may strike such material from the filings on the grounds that it is "redundant, immaterial, impertinent, or scandalous." Because such rejected or stricken material is not "relevant to the performance of the judicial function" it would not be considered a "judicial document" and would enjoy no presumption of public access.").
+
+The Second Circuit established a framework in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) for courts to utilize in determining when the public has a right of access to particular documents. The Court of Appeals held that "[b]efore any such common law right can attach, however, a court must first conclude that the documents at issue are indeed `judicial documents?" Lugosch, 435 F.3d at 119. "Once the court has determined that the documents are judicial documents and that therefore a common law presumption of access attaches, it must determine the weight of that presumption." Id. "Finally, after determining the weight of the presumption of access, the court must `balance competing considerations against it.' Id. at 120.
+
+There exists no compelling reason to release Juror No. 50's pleadings. Any public release of the documents will set off another round of publicity, speculation, and commentary, all of which is prejudicial to the truth finding process and Ms. Maxwell's rights to fair and impartial proceedings.
+
+The submissions by Juror No. 50 have questionable merit, have not been ruled upon, and implicate an ongoing investigation by the parties and the Court into juror misconduct. Certainly, at least at this stage of the proceedings, the submissons are not "judicial documents" and until the issues around Juror No. 50's motion for intervention and discovery have been resolved they should remain sealed. If the Court believes Juror No. 50's requests merit judicial document status the seal should remain. The requests would be afforded the lowest presumption of public access and compelling reasons to maintain the sealed status exist.
+
+Juror No. 50 has demonstrated a lack of reliability and an appetite for publicity. Should the documents be released the sotto voce comments regarding Juror No. 50's intent, state of mind, and actions will be fodder for the media and may influence the memories of other potential witnesses. Documents regularly remain sealed where public release would "compromis[e] the interest in the integrity and security of [an] investigation," In re Sealed Search Warrants Issued June 4 & 5, 2008, No. 08-M-208 (DRH), 2008 WL 5667021, at \*5 (N.D.N.Y. July 14, 2008).
+
+## Conclusion
+
+The purpose of voir dire is "to expose bias or prejudice on the part of veniremen," and there "there must be sufficient information elicited on voir dire to permit a defendant to intelligently exercise not only his challenges for cause, but also his peremptory challenges." Barnes, 604 F.2d at 139. "Voir dire [thus] plays an essential role in protecting the right to trial by an impartial jury." Daugerdas, 867 F. Supp. 2d at 468.
+
+For its part, this Court expressed "confidence" that its voir dire process would "smoke out" a juror who was dishonest. Ms. Maxwell relied on the Court's process. And the Court and the parties relied on the presumption to which everyone is entitled: that potential jurors would carefully and honestly engage in voir dire.
+
+Unfortunately, we now know that Juror No. 50 (and at least one other juror) did not honor their obligations to give "only truthful answers." Ex. 1, p 3. They are no longer entitled to the presumption of honesty.
+
+Because Ms. Maxwell's jury was not the fair and impartial one guaranteed her by the United States Constitution, this Court should vacate the jury's verdict and order a new trial. In the alternative, this Court should hold an evidentiary hearing and examine all twelve jurors.
+
+Dated: January 19, 2022
+
+Respectfully submitted,
+
+s/ Jeffrey S. Pagliuca
+
+Jeffrey S. Pagliuca Laura A. Mennin er HADDON, 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 P.C.
+
+Christian R. Everdell & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600
+
+Bobbi C. Stemheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York, NY 10007 Phone: 212-243-1100
+
+Attorneys for Ghislaine Maxwell
+
+## Certificate of Service
+
+I hereby certify that on January 19, 2022, I electronically filed the foregoing Ghislaine Maxwell's Motion for a New Trial, with the Court and counsel for the government:
+
+Alison Moe Maurene Comey Andrew Rohrbach Lara Pomerantz U.S. Attorney's Office SDNY One Saint Andrew's Plaza New York, NY 10007 Alison.moe@usdoj.gov Maurene.comey@usdoj.gov Andrew.Rohrbach@usdoj.gov Lara.Pomerantz@usdoj.gov
+
+s/ Nicole
\ No newline at end of file
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+
+
+NEWS INDEPENDENT TV POLITICS CUMATE VOICES INDYI00 SPORT CULTURE INDY LIFE INDYBEST MY INDEPENDENT CONVERSATIONS
+
+Nears World Americas
+
+## Ghislaine Maxwell juror breaks silence to The Independent: `This verdict is for all the victims'
+
+'For those who testified. for those who came forward and for those who haven't come forward. I'm glad that Maxwell has been held accountable: a juror in Maxwell's sex-trafficking trial tells Lucia Osborne-Crowley
+
+Varinr.day 05 January 2022 10 13 • c•,71.11:----•-t:
+
+
+
+
+
+(REUTERS)
+
+
+
+juror in the Ghislaine Maxwell sex-trafficking trial has told The Independent that he voted to find Maxwell guilty of the majority of the charges against her because he believed the stories told by the victims and because he believed the pattern of abuse they all described.
+
+Scotty David, who wishes to be identified by his first and middle name, told The Independent in his first media interview that he believed all of the victims who testified against Ghislaine Maxwell in her sex-trafficking trial that took place in lower Manhattan over the past four weeks. All of the accusers corroborated each other and were backed up by other evidence, he said.
+
+David said he is proud to be part of holding Maxwell accountable for her crimes.
+
+"This verdict is for all the victims: David told The Independent. "For those who testified, for those who came forward and for those who haven't come forward. I'm glad that Maxwell has been held accountable.
+
+"This verdict shows that you can be found guilty no matter your status."
+
+David told The Independent that he found all of the accusers who testified to be believable and credible, despite the defence's many attacks on their credibility and their attempts to poke holes in their memory.
+
+"They were all believable. Nothing they said felt to me like a lie: he said.
+
+David knows that sometimes you can misremember small details of traumatic memories without ever doubting the core of the memory. He knows that because he is himself a survivor of sexual abuse.
+
+"I know what happened when I was sexually abused. I remember the colour of the carpet. the walls. Some of it can be replayed like a video: he said. He explained this to the jury.
+
+"But I can't remember all the details, there are some things that run together."
+
+So he knew that some misremembered details doesn't mean the memory itself didn't happen.
+
+There were also questions from the jury about why the girls didn't come forward earlier.
+
+But David said he knows what that's like, too. "I didn't disclose my abuse until I was in high school," he said.
+
+The jury room went dead silent when he shared his story. he told The Independent.
+
+David believes this helped the jury understand that it's possible that these women were telling the truth.
+
+You might forget some things, he said, but the core of a traumatic memory stays with you.
+
+There were also questions about why the girls kept going back to Epstein and Maxwell, why they accepted their help.
+
+"We are not here to judge these victims," David told The Independent.
+
+"We are here to judge whether we believe their stories, but we are not here to judge the decisions they made or didn't make.
+
+"We cannot judge what they did or didn't do afterward," he said. "It doesn't change that it happened."
+
+David felt that the defence were continually attacking the accusers on the stand, and he said these attempts did little to change his mind.
+
+At one point, the accuser testifying under the name "Carolyn" threw her binder of evidence down beside her because she was so distressed by the questioning she was being subjected to.
+
+"It just made me feel more compassion for her," David said.
+
+The juror said that, ultimately, the jury found that all the victims were credible.
+
+The defence team focused strongly on its memory expert, Professor Elizabeth Loftus. Loftus testified about experiments that had been conducted in which researchers had successfully implanted a false memory into the mind of research subjects.
+
+In one study, the researchers were able to change a detail of a memory about witnessing a car accident. They were able to convince participants that the scene featured a stop sign rather than a yield sign.
+
+-None of that relates to traumatic memory," he said. Loftus said herself that she had never conducted a study on whether these tactics would work with memories of sexual abuse, David recalled.
+
+Since the trial, there has been speculation that the fact a juror had been a victim of sexual abuse could be used by Maxwell as grounds for appeal.
+
+Speaking separately to MailOnline, David said he could not remember the details of the 50 question pre-trial questionnaire each potential juror was asked about whether they were a victim of sexual abuse or a relative or a friend of a victim, but felt he had answered all questions honestly.
+
+David told The Independent that the accusers' testimony was corroborated by a significant amount of evidence.
+
+He specifically mentioned Kate - an accuser who testified but was not allowed to be considered for the actual charges because she was over the age of consent in the UK when she was abused - and said her testimony powerfully corroborated the other accusers' stories.
+
+"She was able to show us that this was a pattern," David said. "We knew we couldn't use her testimony to convict Maxwell. but she showed the pattern of how those girls were groomed.
+
+"She showed us the pattern that happened to all of these girls.
+
+"It was about confusing their boundaries; he said. "For Jane, it started with seeing Maxwell topless. For-, it started with Maxwell showing her how to give Epstein a foot massage.
+
+"The pattern is that Ghislaine talks to you like she is also a teenager. Then it moves into massage. She tries to make you comfortable, to see what they can get away with.
+
+"What she did was wrong."
+
+story was backed up by her teenage diary, as well as her high school boyfriend. That was important to the jury, he said.
+
+Carolyn's story was backed up by Shawn, her ex-boyfriend who testified that he used to drive her to Epstein's Palm Beach mansion.
+
+Jane's story was backed up by her high school boyfriend. who remembered being told about Epstein when they were younger.
+
+The accuser's stories were backed up by flight logs which placed Jane on at least one flight with Maxwell, David said.
+
+Their stories were backed up by Maxwell's "little black book" - an address book found in Epstein's home that listed the names of "masseuses" including Jane and Carolyn.
+
+David said the little black book also gave the jurors clues about how Maxwell and Epstein had evaded accountability in the past. There were names of several Palm Beach police officers listed on a first-name basis in that book. David said.
+
+"Those girls' names and phone numbers were listed next to the words 'mom' and 'dad'," he said. "Professional masseuses do not need their parents with them."
+
+Many speculated that the jury chose to acquit Maxwell on count two because that count related solely to Jane, and that Jane was less credible than other victims.
+
+But David told The Independent that wasn't the case.
+
+"We simply didn't see enough direct evidence to convict on count two." he said. "It wasn't about not believing Jane."
+
+Count two was a substantive charge that required proof that Maxwell "enticed" Jane to travel across state lines. David said there just wasn't any direct evidence for any specific trip that Maxwell took any action to entice Jane to get on those flights.
+
+"I personally was willing to find her guilty on count two," he said. "But we all decided in the end that there wasn't enough evidence."
+
+David also explained that he was convinced by the closeness of Maxwell and Epstein's relationship and the key role she played in his life.
+
+"Of course she knew what was going on." he said.
+
+The schedule for Maxwell's sentencing hearing has not yet been set.
+
+More about: Ghislaine Maxwell Juror Maxwell Victims
+
+
+
+Join our new commenting forum
+
+Join thought-provoking conversations, follow other Independent readers and see their replies
+
+Vi) Comments 4,
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+
+Home U.K. Sports I U.S. Showbiz I Australia I Femail I Health Science I Money I Video I Travel I Shop I DailyMailTV
+
+## EXCLUSIVE: 'Ghislaine was a predator as guilty as Epstein': Maxwell juror describes moment he 'locked eyes' with sex trafficker and reveals his own abuse ordeal
+
+- Scotty David, a juror in the Ghislaine Maxwell trial, was one of the 12 men and women who convicted Maxwell on five of the six counts of sex-trafficking last week
+- Scotty says he went into the trial firmly believing that Maxwell was 'innocent until proven guilty' but 'After all I've learned, she's just as guilty as Epstein. I don't want to call her a monster, but a predator is the right word
+- During the trial Scotty, who works in finance, was seated in the third row of the jury box, in the back corner. From his vantage point, he said, he had a vista of the entire court and the 'perfect view' of Maxwell herself
+- Scotty said that Maxwell's manner in court was discussed during deliberations. He said, 'We did discuss that we thought she was a little standoffish and not necessarily cold, more like she was paying attention
+- Scotty revealed that he was not the only juror to share a story of sexual abuse and that it did not affect his ability to view Maxwell as innocent until proven guilty
+- Scotty is completely satisfied that they reached the right verdict and that, with Maxwell's conviction, justice has been done. He says that he believes she will spend the rest of her life in prison unless a deal is done
+- He said, 'It satisfies me to know that we did our due diligence and that we brought justice for these victims, for these girls who are now women'
+
+By LAURA CHIEF INVESTIGATIVE REPORTER FOR DAILYMAIL.COM and DANIEL FOR DAILYMAIL.COM PUBLISHED: 00:26 5 January 20221 UPDATED: 09:04 EST, 5 January 2022
+
+7h2.2 1.1k View COMMA'S
+
+A juror in the Ghislaine Maxwell trial has revealed how he viewed her as a 'predator', describing the moment he 'locked eyes' with Jeffrey Epstein's accomplice - and revealed his own child sex abuse ordeal to the jury.
+
+Scotty David said he had helped the other members of the jury understand things from a victim's point of view and explained how 'you can't remember all the details' of traumatic memories - this was a crucial line of attack by Maxwell's lawyers who called a 'false memory' expert witness.
+
+David also claimed that the five guilty verdicts returned in New York last week, possibly condemning Maxwell to spend the rest of life behind bars, were for 'all the victims'.
+
+
+
+Legal experts said that if David failed to disclose his past experiences before the jury deliberations, Maxwell could have grounds to claim a mistrial and have her convictions quashed.
+
+However, the question of whether a potential juror was a victim of sexual abuse or a relative or friend of a victim was asked in the 5O-question survey completed by each juror ahead of selection.
+
+David said he went into the trial firmly believing that Maxwell was 'innocent until proven guilty' and viewing the victims with a skeptical eye.
+
+But, he said, 'After all I've learned, she's just as guilty as Epstein. I don't want to call her a monster, but a predator is the right word.
+
+'She knew what was happening. She knew what Epstein was doing and she allowed it to happen. She participated in getting these girls comfortable so that he could have his way with them.
+
+'And, to me, them returning repeatedly for the money has nothing to do with anything because these girls were minors, and it doesn't matter what incentivized them. It matters what happened to them:
+
+Ghislaine Maxwell juror speaks out after guilty verdict
+
+
+
+\\latch tin full video
+
+
+
+Scotty, who spoke on condition that only his first and middle names are used, said he went into the trial firmly believing that Maxwell was Innocent until proven guilty' and viewing the victims with a skeptical eye
+
+
+
+During the trial Scotty, who works in finance, was seated in the third row of the jury box, in the back corner. From his vantage point, he said, he had a vista of the entire court and the 'perfect view' of Maxwell herself.
+
+He recalled, 1 could literally see her [all the time). There were times when it felt like she was staring right at me and we would lock eyes...it didn't feel real.'
+
+'She was constantly taking notes, and constantly passing post-it notes over to her attorneys especially when they were on cross examination.'
+
+At times, he said, 'I felt like she was watching what we were doing because there were times when some jurors, not during when the victims presented their testimony, but when certain other people presented on things that maybe they didn't feel mattered...some people would nod off.'
+
+Scotty said that Maxwell's manner in court was discussed during deliberations. He said, 'We did discuss that we thought she was a little standoffish and not necessarily cold, more like she was paying attention.'
+
+In an insight that will surely come as a gut blow to Maxwell herself, who reportedly wanted to testify but was advised against it, Scotty revealed that if she had taken the stand, 'It would have shown maybe that she was a little more human.
+
+'Maybe if she gave her version of the story, who knows, maybe if she gave us a story of how she was manipulated...I don't know. But then that would have been an admission I feel like of guilt.'
+
+Jurors were instructed not to draw any inference of guilt or otherwise from Maxwell's decision not to testify and, Scotty said, it was simply set to one side and not discussed during deliberations.
+
+Asked if, at any stage, he had experienced any sympathy for Maxwell he said, 'Absolutely. Because this is the rest of her life, right? We were deciding what happens based off the evidence provided.
+
+'We took that very seriously because we took at as, this could be our sister, our sister could be on trial here. We have to really comb through the evidence and make sure we have enough proof to say that she's either guilty or not.'
+
+David told The Independent he found all the accusers to be credible, despite the defence's attacks on their stories and memories.
+
+## How Maxwell could claim a mistrial after juror reveals he was victim of child sex abuse and shared his experience with the jury
+
+Ghislaine Maxwell could lodge a claim of mistrial after it emerged one of the jurors who convicted her was a victim of child sex abuse.
+
+Scotty David said he had helped the other members of the jury understand things from a victim's point of view.
+
+He also claimed the five guilty verdicts returned last week, possibly condemning Maxwell to spend the rest of her life behind bars, were for 'all the victims'.
+
+David said that after he revealed his ordeal, another juror came forward with to share that they too had been sexually abused.
+
+Legal experts said that if David failed to disclose his past experiences before the jury deliberations, Maxwell could have grounds to claim a mistrial and have her convictions quashed.
+
+Moira Penn, a former federal prosecutor in New York, said: 'I certainly hope the juror disclosed this fully on his questionnaire.
+
+'A little strange the defence didn't strike him. It could definitely be an issue.
+
+'In the first instance it would likely form the basis for a motion to Judge [Alison] Nathan for a new trial.'
+
+However, the question of whether a potential juror was a victim of sexual abuse or a relative or friend of a victim was asked in the 50'question questionnaire completed by each juror ahead of selection.
+
+Scotty could not remember that question when asked by DailyMail.com but was certain that he had answered all questions honestly.
+
+
+
+'I know what happened when I was sexually abused. I remember the color of the carpet, the walls. Some of it can be replayed like a video,' he said, and he explained this to fellow jurors.
+
+'But I can't remember all the details, there are some things that run together:
+
+Scotty said when he chose to share his own experience of sexual abuse the room 'went silent'.
+
+It has since been speculated that the fact that a juror was a victim of sexual abuse could be used by Maxwell as grounds of appeal.
+
+### SHARE THIS RELATED ARTICLES
+
+
+
+# ARTICLE
+
+'Brutal' Prince Andrew court I III Ohklaine Maxwell juror was hearing 'couldn't have abuse Vienne Convicted
+
+
+
+
+
+New York judge leaves Prince Andrew sweating as
+
+
+
+Scotty recalled looking directly at Maxwell, 'I could literally see her [all the time]. There were times when it felt like she was staring right at me and we would lock eyes...it didn't feel real'
+
+
+
+Scotty is completely satisfied that they reached the right verdict and that, with Maxwell's conviction, justice has been done. He says that he believes she will spend the rest of her tife in prison unless a deal is done
+
+
+
+\*VALHI Scotty said that Maxwell's manner in court was discussed during deliberations. He said, 'We did discuss that we thought she was a little standoffish and not necessarily cold, more like she was paying attention'
+
+However, the question of whether a potential juror was a victim of sexual abuse or a relative or friend of a victim was asked in the 50-question questionnaire completed by each juror ahead of selection.
+
+Scotty could not remember that question when asked by DailyMail.com but was certain that he had answered all questions honestly.
+
+He also revealed that he was not the only juror to share a story of sexual abuse and that it did not affect his ability to view Maxwell as innocent until proven guilty.
+
+It did, however, he believes give him access to a better understanding of the testimony of victims.
+
+To that end, he said, the defense's tactic of 'going hard' on the victims did not play well with him or other jurors.
+
+Scotty pointed to defense attorney Laura Menninger's use of air-quotes when questioning Jane about her story of 'escaping' Epstein at one point.
+
+He said, 'Everything, her tone, using air-quotes with escape ... I think she was acting in order to convince us that this girl's lying and lying for money.'
+
+Instead, he said, all it did was convince jurors that the defense team were showing a complete lack of respect for the victims.
+
+He said, 'I just felt terrible I'm like, 'I can't believe you're treating this woman like this.' Like even if she's lying there's better ways to go about it...l don't feel attacking them that way or degrading her based on what she said was the way to go.'
+
+The jury was sent out with a daunting 80 pages of instructions after a trial that was often dizzying in detail with lengthy testimony from the victims alone, and six counts to consider.
+
+At first, Scotty admitted, jurors struggled to know where to start or how to make any progress at all.
+
+He said that they did not take an initial vote of opinions but instead, on the first day they were sent out simply chose a foreperson and began by reading the instructions page by page.
+
+He said, 'It was overwhelming. I mean 80 pages of how you interpret the law on each count, and it flips back and forth between different pages, and you have to flip 20 pages in order to get a definition of something else that can apply to one specific count.'
+
+### 'Brutal' Prince Andrew court hearing 'couldn't one worse' for him: hopes of having case thrown out hang by a thread after judge 'made it ver r he did not accept' dilawyers' arguments, experts say
+
+Prince Andrew's hopes of getting the case by his US sex accuser thrown out of court were hanging by a thread last night following a 'brutal' hearing in New York.
+
+A judge told the he would find out 'pretty soon' most likely within days - if his bid to have the lawsuit dismissed would be successful.
+
+But the early signs were not good for the Queen's son after Judge= Kaplan put his legal team through a bruising encounter during a make-or-break hearing in New York yesterday.
+
+One legal expert said that the hearing 'could not have gone worse' and pointed out that the fact that his lawyers were reduced to saying they 'respectfully disagree' with the judge did not bode well- adding 'respectfully disagreeing with the judge means you are about to lose.'
+
+
+
+Prince Andrew is interviewed for the BBC's Newsni ht in November 2019. In the interview, Andrew denied claim that they had shared a sweaty dance at a London nightclub, saying that at the time he could not sweat due to a condition
+
+Andrew's lawyer was seeking to persuade the court that his accuser, MIM, now known as had waived her right to sue him when she
+
+A fifth victim, Kate, was called only to show a pattern of grooming behavior and was not directly implicated in any of the counts.
+
+At first jurors struggled to agree, Scotty said, over the legal definitions of terms such as 'enticing.'
+
+He said, 'It was super confusing. It didn't get heated. It was just confusing, and when people are confused, tones can get raised. Nobody ever yelled at other people. People would just speak, sounding frustrated.
+
+'So, we (realized) we had to come up with a new game plan and that game plan was, we're going to talk to each other with compassion.'
+
+According to Scotty once the jurors had found a way to 'understand' each other they worked methodically through each count starting with count 2.
+
+This was the only charge on which they did not convict Maxwell and related to the charge of 'enticing' Jane to travel for sexual exploitation.
+
+An initial vote saw 7 jurors vote guilty and 5 not guilty. Those 'not guilty' votes turned to 'not sure' on further discussion. Ultimately, he said, it was not a question of Jane's credibility but rather the fact that they simply did not feel the evidence was there to meet the necessary bar of beyond reasonable doubt.
+
+Working throurach charge jurors wrote out lists of evidence on a board and attached post-it notes as they built the case for each as they saw it and deliberated towards consensus.
+
+On counts two and four - both relating to Jane - there was a 7/5 split of guilty/not sure. On counts one, three and five - all conspiracy charges - there was a 10/2 guilty/not sure split and on count six, the sex trafficking charge relating to Carolyn, all voted guilty from the start.
+
+Scotty said he never felt pressure from either the judge or the rest of the jurors to reach a verdict. In fact, he said, when the judge sent a note on Wednesday 29 December informing them that if they had not reached a verdict she would recall them the following day, they were about to send her a note saying they had reached consensus on all counts.
+
+Misss 38, one of the billionaire sex offender's most high•prof ile victims, claims she was trafficked by him and girlfriend Ghislaine Maxwell to have sex with Andrew on three occasions when she was 17.
+
+The 61-year-old prince vehemently denies the claims and says he has no recollection of even meeting her.
+
+Judge Kaplan appeared mostly dismissive of the arguments by the lawyer, Andrew Brettler.
+
+He said that part of the 2009 settlement protecting 'other potential defendants' that Andrew's lawyers had appeared to be leaning on was 'unclear' and pointed to two sentences in the text that seemed to suggest it could not be used by Andrew.
+
+Judge Kaplan also pointed to language in the agreement stating it is 'not intended to be used by any other person' to protect themselves from lawsuits without the agreement of Miss and Epstein again suggesting Andrew could not rely on it.
+
+While he did not immediately rule at the end of the hearing, he made clear that he was not leaning Andrew's way as he rejected much of the reasoning offered by Mr Brettler, who said the case 'should absolutely be dismissed'.
+
+Judge Kaplan told the two sides: 'I appreciate the arguments and the passion. You'll have the decision pretty soon.' But he directed that the exchange of potential evidence in the case was to proceed as scheduled - which was seen as an indication he would likely rule against Andrew's motion.
+
+Sources close to the proceedings yesterday described them as 'brutal' for Andrew. During the hour-long hearing, held via video conference due to Covid, Judge Kaplan interjected several times in Mr Brettler's arguments.
+
+He told him once: 'With all due respect, Mr Brettler, that's not a dog that's going to hunt here' and another time asked the lawyer outright: So what?'
+
+
+
+© US District Attorney's Office
+
+
+
+**Maxwell (pictured with Epstein) faced six counts relating to sex trafficking which centered on the stories of four victims**
+
+
+
+
+
+
+
+Scotty revealed that he was not the only juror to share a story of sexual abuse and that it did not affect his ability to view Maxwell as innocent until proven guilty
+
+Today Scotty is completely satisfied that they reached the right verdict and that, with Maxwell's conviction, justice has been done.
+
+He says that he believes she will spend the rest of her life in prison unless a deal is done to reduce her sentence. But said that he had no idea of the severity of the potential sentence until after the verdict was reached and that it would not have influenced anything if he had.
+
+He said. 'It satisfies me to know that we did our due diligence and that we brought justice for these victims, for these girls who are now women.'
+
+He said that, ultimately, he and the rest of the jurors were convinced that Epstein and Maxwell's lives were so 'intertwined' that it was inconceivable that she was not fully aware of his crimes.
+
+She aided and abetted, he said. And with her conviction she wasn't paying or being held accountable for Epstein's crimes as her attorneys have argued, Scotty said, instead she was answering to her own guilt because she was 'every bit as culpable' as he.
+
+According to Scotty, 'The prosecution proved their case beyond reasonable doubt.'
+
+#### Share or comment on this article: Ghislaine Maxwell juror says evidence convinced panel she was a 'predator'
+
+792
+
+Urea by 0.09 8044 It is detrimental sad wrong in multiple
+
+These Top-Of-The-Line Luxury SUVs Are Shockingly Affordable Luxury SUV Savings
+
+He Is Probably The World's Oldest Living Hollywood Actor Lawyers Favorite
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\ No newline at end of file
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+
+
+
+
+
+
+January 5, 2022 2:33 PM EST
+
+Last Updated 21days ago
+
+## United States
+
+## Some Ghislaine Maxwell jurors initially doubted accusers, juror says
+
+By Luc
+
+
+
+
+
+
+
+
+
+
+
+
+
+1 / Jeffrey Epstein associate Chislaine Maxwell sits as the guilty verdict in her s courtroom sketch in New York City, U.S., December 29, 2021. REUTERS/Jane id in a
+
+NEW YORK, Jan 5 (Reuters) - During jury deliberations after the trial of British socialite Chislaine Maxwell, some jurors initially doubted the accounts of two of her accusers, one member of the jury said on Tuesday night.
+
+This juror, who asked to be identified only by his first and middle names, said some of the jurors had issues with the credibility of witnesses known as Jane and Carolyn, two of the four women who testified that Maxwell set them up with the late financier Jeffrey Epstein as teenagers.
+
+He said that after some of the jurors questioned the accuracy of the two women's memories, he decided to share his own experience of being sexually abused as a child. He said that he remembered most important elements of what happened to him, but not every single detail. That swayed some jurors, he said.
+
+Register now for FREE unlimited access to Reuters.com Register
+
+'When I shared that, they were able to sort of come around on, they were able to come around on the memory aspect of the sexual abuse," Scotty David, a 35-year-old Manhattan resident, told Reuters in a phone interview. He gave an earlier interview to The Independent.
+
+He added that coming to a unanimous verdict "wasn't easy, to be honest."
+
+"There's a room of 12 people and we all have to be on the same page and we all have to understand what's going on," he said. "And then we have to agree. So that's partly why it took so long."
+
+Maxwell, 60, was convicted on Dec. 29 of recruiting and grooming teenage girls for sexual encounters with Epstein. The conviction followed five full days of deliberations.
+
+During jury selection, hundreds of prospective jurors were given questionnaires asking, among other things, if they or anyone in their families had experienced sexual abuse, court records show.
+
+For those who answered yes, the judge in the case asked during follow-up questioning if it would affect their ability to serve as a fair or impartial juror, the records show.
+
+Scotty David said he did not recall being asked about his experience during follow-up questioning, known as voir dire. He said he "flew through" the initial questionnaire and also did not recall being asked on the form about personal experiences with sexual abuse, but that he would have answered honestly.
+
+The U.S. Attorney's office in Manhattan wrote a letter to U.S. District Judge Alison Nathan on Wednesday asking her to conduct an inquiry into the juror's description of being a victim of sexual abuse and his responses to the questionnaire, in light of the juror's statements to outlets including Reuters.
+
+'While the court instructed jurors that they were free to discuss their jury service with anyone of their choosing, some of the statements, as related in the media, merit attention by the court," the letter read.
+
+Maxwell's defense attorneys did not respond to requests for comment about Scotty David's account of the jury deliberations or his responses to questions during jury selection.
+
+Jurors were not identified by name during the trial. Scotty David shared with Reuters a photograph of an instruction sheet from the court telling him to return on Nov. 29 for the final day of jury selection. His juror number, which is listed on the sheet, was among the 18 chosen as jurors or alternates.
+
+Maxwell's defense lawyers argued that the women's memories had been corrupted over the years and that they were motivated by money to implicate Maxwell.
+
+Scotty David said several jurors initially were not sure whether to convict Maxwell on the sex trafficking count, which is backed up by the testimony of a woman named Carolyn who said she was 14 when Epstein began abusing her in 2002.
+
+But he said some jurors changed their minds after hearing the personal story of one juror who said she grew up poor. Carolyn said she dropped out of school in seventh grade and was paid \$300 - sometimes by Maxwell - each time she gave Epstein an erotic massage. Carolyn said she used the cash to buy drugs.
+
+"For Carolyn, it took one of the jurors sharing their story of growing up in the same socioeconomic background," he said. "She grew up poor, and said had there been an Epstein or Ghistaine in her neighborhood, some of the girls would have fallen prey to them as well."
+
+Scotty David said he was skeptical of the defense's argument that Maxwell was being treated as a scapegoat for Epstein, who died by suicide at age 66 in a Manhattan jail cell while awaiting trial on sex abuse charges.
+
+"She participated, she was complicit, she did nothing to stop it," he said.
+
+Register now for FREE unlimited access to Reuters.com Register
+
+Reporting by Luc in New York Editing by Noeleen Walder and Amy Stevens
+
+Our Standards: The Thomson Reuters Trust Principles.
+
+## More from Reuters
+
+RFK Jr. 'sorry' for Anne reference at rally
+
+VIE
+
+0B
+
+Read Next
+
+United Shit(-^,
+
+Conservative SCOTUS plunges into culture wars
+
+Biden caught on hot mic: 'Stupid son of a bitch'
+
+Sarah Patin set to battle NYT at defamation trial
+
+African Americans vote as much as 'Americans' -McConnell
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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA
+
+S2 20 Cr. 330 (MN)
+
+GHISLA1NE MAXWELL,
+
+Defendant.
+
+------------------------------------------x
+
+### THE GOVERNMENT'S MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTION FOR A NEW TRIAL
+
+DAMIAN United States Attorney Southern District of New York Attorney for the United States of America
+
+Maurene Comey Alison Moe Lam Pomerantz Andrew Rohrbach Assistant United States Attorneys - Of Counsel -
+
+#### TABLE OF CONTENTS
+
+| I. I. 1. 2. | PRELIMINARY STATEMENT BACKGROUND The Jury Selection Process H. Juror 50's Questionnaire and Voir Dire HI. Juror 50's Public Statements Following the Verdict ARGUMENT The Defendant's Motion for a New Trial Should Be Denied on the Current Record A. Applicable Law B. Discussion The Defendant Has Failed To Satisfy the First Prong of The Defendant Has Failed to Satisfy the Second Prong of H. The Court Should Schedule a Limited Hearing Regarding Juror 50 A. Applicable Law B. Discussion | 1 2 2 6 8 10 10 10 13 McDonough 13 McDonough 19 30 30 31 |
+|-------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------|
+| 1. | The Court Should Conduct the Questioning | 32 |
+| 2. | The Scope of the Hearing Should Be Limited | 33 |
+| 3. | There Is No Basis to Call Any Other Juror as a Witness | 37 |
+| 4. | The Defendant's "Discovery" Request Should Be Denied | 40 |
+| III. | The Court Should Provide Juror 50 with a Copy of His Questionnaire | |
+| | Before Any Hearing | 42 |
+| | CONCLUSION | 47 |
+
+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA
+
+S2 20 Cr. 330 (MN)
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+# PRELIMINARY STATEMENT
+
+The Government respectfully submits this memorandum in opposition to the defendant's motion for a new trial, dated January 19, 2022 (the "Defense Motion").
+
+A defendant "is entitled to a fair trial but not a perfect one, for there are no perfect trials." McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548, 553 (1984) (quotations and citations omitted). "A trial represents an important investment of private and social resources, and it ill serves the important end of finality to wipe the slate clean simply to recreate the peremptory challenge process because counsel lacked an item of information which objectively he should have obtained from a juror on voir dire examination." Id. at 555. In keeping with these principles, a defendant seeking a new trial based on a juror's statements during voir dire faces the heavy burden of establishing both that the juror deliberately lied, and that the juror otherwise would have been struck for cause. Id. at 556; United States v. Shaoul, 41 F.3d 811, 818 (2d Cir. 1994). On the present record, the defendant has not come close to establishing that the extraordinary remedy of a new trial is warranted.
+
+For the reasons set forth below, the Court should deny the defendant's motion based on the present record. The Court should further deny the defendant's alternative requests for extensive discovery and an expansive hearing—requests that present exactly the sort of "evil consequences" of which the Second Circuit has warned: "subjecting juries to harassment, inhibiting juryroom deliberation, burdening courts with meritless applications, increasing temptation for jury tampering and creating uncertainty in jury verdicts." United States v. lanniello, 866 F.2d 540, 543 (2d Cir. 1989). While the Government consents to a hearing, its scope "should be limited to only what is absolutely necessary to determine the facts with precision." Id. at 544. Such a hearing should be limited to questioning of Juror 50 by the Court, in order to determine: (1) whether he deliberately lied in response to Question 48, regarding being a victim of sexual abuse, and, if so, (2) whether the Court would have struck Juror 50 for cause if he had accurately responded to that question, i.e., based on a finding that he could not be fair and impartial.
+
+# BACKGROUND
+
+# I. The Jury Selection Process
+
+Before trial, the jury department for the Southern District of New York conducted five sessions over the course of November 4, 5, and 12, 2021 during which 694 jurors completed a juror questionnaire approved by the Court. Nov. 15, 2021 Tr. at 2:20-21. The juror questionnaire was 29 pages and comprised of 51 questions, many of which contained subparts. The parties reviewed the completed questionnaires and then conferred, submitting a joint list delineating four categories of prospective jurors: (1) prospective jurors that both the Government and defense counsel agreed should proceed to voir dire; (2) prospective jurors that both the Government and defense counsel agreed should be excused or struck for cause; (3) prospective jurors that defense counsel, but not the Government, believed should be excused or struck for cause; and (4) prospective jurors that the Government, but not defense counsel, believed should be excused or struck for cause. Id. at 2:22-3:4. In addition, the Court sent the parties a list of 13 prospective
+
+jurors—that were included on the list of jurors that the parties agreed should proceed to voir dire that the Court "thought should be considered for excusing." Id. at 3:5-11. While the Government did not object to the Court's proposal, defense counsel objected to excusing four of the 13 prospective jurors; those four proceeded to voir dire. Id. at 3:12-16. On November 15, 2021, the Court calculated that the parties had agreed that 231 of the 694 prospective jurors should proceed to voir dire, which the Court determined was a "sufficient number to get to the number of jurors that we need." Id. at 4:9-13. Thus, the Court had no occasion to and did not rule on whether to strike the prospective jurors whom only one party had challenged for cause.' The Court indicated at the November 15 conference that it planned to qualify 50 to 60 of the 231 jurors after voir dire. Id. at 4:19-20.
+
+On November 16, 2021, the Court commenced the voir dire portion of the jury selection process. The Court asked prospective jurors several follow-up questions to questions in the jury questionnaire which prospective jurors had answered affirmatively, including, for example, the prospective jurors' familiarity through the media with the defendant and Jeffrey Epstein; the prospective jurors' history (or that of a friend or family member) of prior sexual harassment, sexual abuse, or sexual assault; and the prospective jurors' experience (or that of a relative or close friend)
+
+The defendant is therefore incorrect when she asserts that "[t]he Court granted all 23 of then challenges for cause made by the defense" that the Government did not agree with. (Def. Mem. at 10). Similarly misleading is the defendant's statement that "the parties jointly agreed to excuse 67 of the 114 who answered `yes' when asked if they had been a victim of sexual abuse, sexual assault, or sexual harassment." (Def. Memo. at 9). That assertion fails to note that a significant number of those prospective jurors had stated that they could not be fair and impartial for a number of reasons, including their familiarity through the media with the defendant and Epstein; that the Government agreed to strike or excuse many of those jurors for reasons other than their responses to Question 48; and that the Court did not ultimately rule on whether any of those jurors should be struck for cause.
+
+of being a victim of a crime. The Court asked the prospective jurors whether that information or those experiences would interfere with their ability to be fair and impartial.
+
+At the conclusion of voir dire, the Court qualified 58 jurors. Nov. 18, 2021 Tr. at 717. Of the 58 individuals who were qualified to serve as jurors, eight individuals responded to Question 48 of the juror questionnaire that they themselves had been a victim of sexual harassment, sexual abuse, or sexual assault, and that this experience would not affect their ability to serve fairly and impartially as a juror in the case.2 In particular:
+
+- • Juror 8 answered Question 48 in the affirmative. During voir dire, Juror 8 stated that she and other women she knows have experienced sexual harassment, but that neither she nor anyone she knows has been the victim of “serious sexual harassment or assault or abuse.” Nov. 16, 2021 Tr. at 18:13-22. Neither the Government nor defense counsel challenged Juror 8 for cause.
+
+- • Juror 21 wrote in response to Question 48 in her juror questionnaire that [REDACTED]. Juror 21 also reported that a friend of hers was sexually harassed and coerced into a sexual relationship with his professor. Juror 21 indicated that these experiences would not affect her ability to be fair and impartial.3 [REDACTED]
+
+In response to additional questioning, she explained that she had reported to her school that her friend was “coerced into a sexual relationship with their professor, kind of blackmailed into it, and then paid off by the school to keep it quiet.” *Id.* at 54:6-12. She reiterated that this would not affect her ability to serve as a juror. *Id.* Defense counsel requested that the Court inquire further into whether Juror 21’s role in the reporting would “color her views.” *Id.* at 56:8-11. In response, the Court inquired whether Juror 21’s ability to be fair and impartial would be affected “[t]o the extent there may be issues in the case that arise around reporting or not reporting allegations related to sexual abuse or harassment or the like,” to which Juror 21 responded no. Neither the Government nor defense counsel challenged Juror 21 for cause.
+
+- • Juror 62 wrote in response to Question 48 in his juror questionnaire [REDACTED]
+
+[REDACTED]
+
+---
+
+2 Twelve of the 58 qualified prospective jurors indicated that a friend or family member had been a victim of sexual harassment, sexual abuse, or sexual assault.
+
+[Redacted text block]
+
+- • Juror 63 also answered Question 48 in the affirmative and said her experience would not affect her ability to be fair and impartial. [Redacted]
+
+[Redacted text block]
+
+She indicated several times during voir dire that she could be fair and impartial in the case. *See, e.g., id.* at 216:19-217:2. Neither the Government nor defense counsel challenged Juror 63 for cause.
+
+- • Juror 93 wrote that [Redacted]
+
+During voir dire, in response to questioning, Juror 93 said that she was sexually molested by an uncle when she was 12 or 13, as was her sister and an aunt, but that would not affect her ability to be fair and impartial in the case and that the allegations in the case would not upset her in a way that would distract from her duty as a juror. *Id.* at 259:4-13. Neither the Government nor defense counsel challenged Juror 93 for cause.
+
+- • Juror 113 indicated that he had experienced sexual harassment, along with “pretty much every woman I know,” but that would not affect his ability to be fair and impartial. During voir dire, Juror 113 stated that he did not believe his experience would make it difficult for him to serve as a juror and that he could be fair and impartial. *Id.* at 293:10-20. Neither the Government nor defense counsel challenged Juror 113 for cause.
+
+- • Juror 189 wrote about [Redacted]
+
+She indicated that it would not affect her ability to be fair and impartial. During voir dire, Juror 189 reiterated that her experiences would not interfere in any way with her ability to be fair and impartial. Nov. 17, 2021 Tr. at 532:13-18. [Redacted]
+
+[Redacted text block]
+
+- • Juror 239 wrote in response to Question 48 of the juror questionnaire [Redacted]
+
+During voir dire, Juror 239 reiterated that her experience would not interfere in any way with her ability to be fair to both sides. Nov. 18, 2021 Tr. at 635:2-8. Neither the Government nor defense counsel challenged Juror 239 for cause.
+
+In sum, there were eight jurors who were ultimately qualified who had answered Question 48 affirmatively. Each confirmed that he or she could be fair and impartial. Defense counsel
+
+moved to strike only one of these jurors for cause—for reasons unrelated to Question 48—and the Court denied that motion.
+
+Fifty-eight jurors were qualified at the conclusion of voir dire on November 18, 2021. Nov. 18, 2021 Tr. at 717. The Court agreed to ask the qualified jurors before the parties exercised their peremptory strikes on November 29, 2021 whether they had read or heard anything about the defendant or Epstein and, at defense counsel's suggestion, whether there was any reason they could not be fair and impartial. See Nov. 17, 2021 Tr. at 622:23-625:2; Nov. 29, 2021 Tr. 727:2-14. At the conclusion of that process, the parties exercised their peremptory strikes. Twelve jurors and six alternates were seated.
+
+# II. Juror 50's Questionnaire and Voir Dire
+
+Juror 50 completed the juror questionnaire and was questioned by the Court during voir dire. In his juror questionnaire, Juror 50 repeatedly made clear that he could be fair and impartial. For example, in response to Question 13, he indicated that he could decide the case "based solely on the evidence or lack of evidence presented in Court, and not on the basis of conjecture, suspicion, bias, sympathy, or prejudice." See Def. Ex. 1. He also indicated that he accepted the principle that the law provides that a defendant in a criminal case is presumed innocent and the Government is required to prove guilt beyond a reasonable doubt. See Def. Ex. 1, Question II.
+
+Juror 50 disclosed in his questionnaire that he had read on CNN's website that the defendant was Epstein's girlfriend, but he stated that he had not formed an opinion about the defendant's guilt or innocence, and that he had not formed any opinions that might make it difficult for him to be fair and impartial. See Def. Ex. 1, Questions 34-35. He also wrote that he learned about Epstein from CNN, but that he could be fair and impartial and render a verdict based solely on the evidence presented at trial. See Def. Ex. I, Questions 3641.
+
+Juror 50 indicated that there was nothing about the nature of the case and the accusations as summarized in the questionnaire that might make it difficult for him to be fair and impartial. See Def. Ex. I, Question 42. He also wrote that he did not have any views about laws concerning the age of consent or laws governing sex trafficking and sex crimes against minors that would affect his ability to be fair and impartial. See Def. Ex. 1, Questions 43-44. Juror 50 answered that he would not have any difficulty assessing the credibility of a witness claiming sexual assault or abuse just like he would any other witness. See Def. Ex. 1, Question 47. Juror 50 checked the "no" box in response to the question of whether he or a friend or family member had ever been the victim of sexual harassment, sexual abuse, or sexual assault, including actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member. See Def. Ex. 1, Question 48. He also checked the "no" box in response to the question of whether he or any of his relatives or close friends had ever been a victim of a crime. See Def. Ex. I, Question 25.
+
+Juror 50 was one of the 231 prospective jurors that the parties agreed should proceed to voir dire. During voir dire, Juror 50 confirmed that he was able to follow the Court's instruction that the defendant is "presumed innocent of all charges unless and until the government proves her guilt beyond a reasonable doubt." Nov. 16, 2021 Tr. at 128:15-19. In response to questioning by the Court about his knowledge of the defendant from the media, Juror 50 explained that he "heard when Jeffrey Epstein had died that he had a girlfriend," and reaffirmed that he was laibsolutely" able to put aside anything that he read or heard about the defendant and decide the case based on the facts and evidence, or lack of evidence, presented in court, and follow the Court's instructions as to the law. Id. at 130:3-18; see also id. at 130:19-131:7.
+
+When asked "[d]o you use social media," he responded: "I do, but I actually just deleted them because I got out of a relationship and I didn't want to see anything regarding them. So I am fully off of it right now." The Court asked, "What did you use, Facebook, Twitter?" Juror 50 responded, "I used Facebook and Instagram," but that he had deleted his accounts "last week" and that before that his use consisted of "[p]ersonal stuff, like selfies." See id. at 133:10-21.
+
+At the conclusion of voir dire, in response to questions from the Court, Juror 50 stated that he had no doubt about his ability to be fair to both sides and that he did not have any reason to think he could not be fair and impartial. See id. at 134:15-22.
+
+Juror 50 was one of the 58 qualified prospective jurors and was ultimately one of the 12 jurors who deliberated.
+
+# HI. Juror 50's Public Statements Following the Verdict
+
+Following the verdict in this case, Juror 50 discussed his experience as a juror during interviews with multiple journalists.
+
+First, on or about January 4, 2022, The Independent published an article reporting an interview with Juror 50 regarding his jury service. (See Gov't Ex. A). According to the article, Juror 50 stated during this interview that he is "a survivor of sexual abuse." (Id. at 2). Juror 50 reportedly indicated that he did not disclose the sexual abuse he experienced until "high school." (Id. at 2). According to the article, Juror 50 "said he could not remember the details" of the juror questionnaire, "but felt he had answered all questions honestly." (Id. at 5).
+
+Second, on or about January 5, 2022, The Daily Mail published an article reporting another interview with Juror 50 regarding his jury service. (See Gov't Ex. B). The online version of this article was accompanied by an approximately 19-minute video of Juror 50 discussing his jury service.' According to this article, Juror 50 "went into the trial firmly believing that Maxwell was 'innocent until proven guilty' and viewing the victims with a skeptical eye." (Id. at 2). During this same interview, Juror 50 indicated that he "could not remember" the part of the questionnaire asking whether he had experienced sexual abuse, but he "was certain that he had answered all questions honestly." (Id. at 8). Juror 50 also told this interviewer that his own experience of sexual abuse "did not affect his ability to view Maxwell as innocent until proven guilty." (Id.).
+
+Third, on or about January 5, 2022, Reuters published an article reporting an interview with Juror 50 regarding his jury service. (See Gov't Ex. C). When asked about the juror questionnaire, Juror 50 reportedly said "he `flew through' the initial questionnaire and also did not recall being asked on the form about personal experiences with sexual abuse, but that he would have answered honestly." (Id. at 3).5
+
+This video is different from the video attached as Defense Exhibit 3 to the defense's motion. The lengthier video is viewable at https://www.dailymail.co.uk/news/article-10370193/Ghislaine-Maxwell-juror-says-evidence-convinced-panel-predator.html.
+
+5 Pursuant to Federal Rule of Evidence 606(b), the foregoing recitation of Juror 50's public statements excludes any reference to statements that Juror 50 made about what "occurred during the jury's deliberations; the effect of anything on that juror's or another juror's vote; or any juror's mental processes concerning the verdict or indictment." The defendant's brief, in an apparent attempt to show bias or prejudice, contains a recitation of certain of Juror 50's statements about what happened during deliberations. (See Def. Mem. at 12-15). Those statements are not admissible in these proceedings. See Warger v. Shauers, 574 U.S. 40, 44 (2014). But the Court should not be misled by the defendant's selective presentation of Juror 50's statements, because a review of the full interviews reveals the impartiality with which he approached this case and the care that the jury took when deliberating. For example, Juror 50 told The Independent that the jury "didn't see enough direct evidence to convict on count two" because "there just wasn't any direct evidence for any specific trip that Maxwell took any action to entice Jane to get on those flights." (Gov't Ex. A at 5). During that same interview, Juror 50 explained that he voted to convict the defendant on the remaining counts because "he believed all of the victims who testified" because "the accusers corroborated each other and were backed up by other evidence." (Id. at 2). He further explained that he rejected Professor Loftus's testimony because "she had never conducted a study on whether [the tactics she studied] would work with memories of sexual abuse." (Id. at 4).
+
+#### ARGUMENT
+
+#### 1. The Defendant's Motion for a New Trial Should Be Denied on the Current Record
+
+#### A. Applicable Law
+
+Federal Rule of Criminal Procedure 33(a) provides that, "[u]pon the defendant's motion, the court may vacate any judgment and grant a new trial if the interest of justice so requires." "The defendant bears the burden of proving that he is entitled to a new trial under Rule 33, and before ordering a new trial pursuant to Rule 33, a district court must find that there is 'a real concern that an innocent person may have been convicted." United States v. McCourty, 562 F.3d 458, 475 (2d Cir. 2009) (quoting United States v. 246 F.3d 129, 134 (2d Cir. 2001)). "It is well settled that motions for new trials are not favored and should be granted only with great caution." United States v. Costello, 255 F.2d 876, 879 (2d Cir. 1958). "[Rule 33] motions are granted only in 'extraordinary circumstances,' and are committed to the trial court's discretion." McCourty, 562 F.3d at 475 (citing United States v. =, 128 F.3d 38, 48 (2d Cir. 1997)) (alterations in
+
+Similarly, Juror 50 told The Daily Mail that the July "did our due diligence" before reaching a verdict, and that the defendant's decision not to testify "was simply set to one side and not discussed during deliberations." (Gov't Ex. B at 5). Juror 50 also indicated that he "[a]bsolutely" felt "sympathy" for the defendant, and that the jury took their job "very seriously because we took it as, this could be our sister, our sister could be on trial here," and therefore "[w]e really have to comb through the evidence and make sure we have enough proof to say that she's either guilty or not." (Id. at 5). When describing deliberations, Juror 50 indicated that the jury began its deliberations "by reading the instructions page by page" and then "worked methodically through each count starting with count 2," which was the only charge on which the jury did not convict. (Id. at 8-9). Juror 50 further explained how the jury "wrote out lists of evidence on a board and attached post-it notes as they built the case for each as they saw it and deliberated towards consensus." (Id. at 9). He also "said he never felt pressure from either the judge or the rest of the jurors to reach a verdict," and that "[t]he prosecution proved their case beyond a reasonable doubt." (Id. at 9, 12).
+
+To be clear, the Government does not believe that the foregoing statements are admissible in this proceeding; they are described here in response to the defendant's selective presentation of Juror 50's description of deliberations.
+
+original). "The ultimate test on a Rule 33 motion is whether letting a guilty verdict stand would be a manifest injustice." 246 F.3d at 134.
+
+Courts strongly disfavor post-verdict inquiries into juror conduct. As the Supreme Court explained: "Allegations of juror misconduct, incompetency, or inattentiveness, raised for the first time . . . after the verdict, seriously disrupt the finality of the process. Moreover, full and discussion in the jury room, jurors' willingness to return an unpopular verdict, and the community's trust in a system that relies on the decisions of laypeople would all be undermined by a barrage of post-verdict scrutiny of juror conduct." Tanner v. United States, 483 U.S. 107, 120-21 (1987) (citations omitted). The Second Circuit has cautioned that "post-verdict inquiries may lead to evil consequences: subjecting juries to harassment, inhibiting juryroom deliberation, burdening courts with meritless applications, increasing temptation for jury tampering and creating uncertainty injury verdicts." lanniello, 866 F.2d at 543.
+
+A defendant seeking Rule 33 relief based on alleged juror misrepresentations during voir dire must satisfy a two-part test: "a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause." McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548, 556 (1984). The Second Circuit has held that these two requirements are conjunctive: "in order to obtain a new trial, a defendant must show both that a juror gave a dishonest answer, and that the correct answer would have provided a basis for the defendant to challenge the juror for cause." Shaoul, 41 F.3d at 816 (emphasis in original). The first prong requires a deliberate misconduct, not an honest mistake. See id.; see also Part 11.B.1.a, infra. The second prong requires the Court to determine whether, if the juror had answered truthfully, it would have granted a hypothetical strike for cause. See United States v. Stewart, 433 F.3d 273, 304 (2d
+
+Cir. 2006); see also Part II.B.2.a, Mira. The McDonough test is "an exacting hurdle" because "motions to set aside a jury verdict are disfavored." United States v. Ventura, No. 09 Cr. 1015 (JGK), 2014 WL 259655, at \*3 (S.D.N.Y. Jan. 21, 2014). Indeed, the Second Circuit "has only on rare occasions overturned a verdict or remanded for an evidentiary hearing" based on the failure of a juror to disclose information during jury selection. United States v. Teman, 465 F. Supp. 3d 277, 330 (S.D.N.Y. 2020); see also United States v. Sattar, 395 F. Supp. 2d 66, 72 (S.D.N.Y. 2005) (describing the "difficulty" of meeting both prongs of the test).\*
+
+During any inquiry into the validity of a verdict, "a juror may not testify about any statement made or incident that occurred during the jury's deliberations; the effect of anything on that juror's or another juror's vote; or any juror's mental processes concerning the verdict or indictment. The court may not receive a juror's affidavit or evidence of a juror's statement on these matters." Fed. R. Evid. 606(bX1). Thus, with limited exceptions not relevant here,' statements or testimony from jurors about what happened or was said during deliberations may not be offered in support of a motion for a new trial based on alleged juror lies during voir dire.
+
+The Court should reject the defendant's invitation to apply New Jersey state law instead of the McDonough test. (Def. Mem. at 46-48). In New Jersey state court, a defendant may seek a new trial "where a juror's inaccurate answer to a question propounded in the jury voir dire precluded a litigant from exercising a peremptory challenge." State v. Scher, 278 N.J. Super. 249, 263 (App. Div. 1994). The Supreme Court rejected that standard in McDonough, as a New Jersey decision cited in the defendant's brief acknowledges. Id. at 265 ("Our rule differs from its federal counterpart"); (Def. Mem. at 46-47 (citing Scher, 278 N.J. Super. at 263)).
+
+7 The only exceptions to this are inquiries as to whether "(A) extraneous prejudicial information was improperly brought to the jury's attention; (B) an outside influence was improperly brought to bear on any juror; or (C) a mistake was made in entering the verdict on the verdict form." Fed. R. Evid. 606(b)Stror's personal experience ... does not constitute 'extraneous prejudicial information.'" v. City of Albuquerque, 399 F.3d 1216, 1223 (10th Cir. 2005) (quail Jack B. Weinstein & Margaret A. Berger, Weinstein's Federal Evidence § 606.03(1Xb) M. McLaughlin, ed., Matthew Bender 2d ed. 2004)); see also U.S. ex rel. Owen v. McMann, 435 F.2d 813, 818 n.5 (2d Cir. 1970) (distinguishing between "any matters not of record" and "specific extra-record facts relating to the defendant"—the latter of which are not permissible influences on jury deliberations if prejudicial).
+
+See Warger v. Shatters, 574 U.S. 40, 44 (2014). This rule promotes "the public interest in maintaining both the finality of verdicts and full and free discussion within the confines of the jury room." United States v. Radonjich, I F.3d 117, 120 (2d Cir. 1993).
+
+### B. Discussion
+
+Based on the current record, the defendant has failed to satisfy either prong of the McDonough test. However, the Government consents to a limited hearing, as set forth in more detail in Part II, infra.
+
+# 1. The Defendant Has Failed to Satisfy the First Prong of McDonough
+
+#### a. The Defendant Must Prove a Deliberate Falsehood
+
+The defendant argues that, under the McDonough test, "[a]n intentionally false answer during voir dire is not a prerequisite to obtaining a new trial." (Def. Mem. at 23). This argument is foreclosed by binding Second Circuit precedent, which requires "dishonesty," i.e., a deliberate falsehood or deceit, rather than an honest mistake. Sham!, 41 F.3d at 815-16. "In other words, the Court must assess whether [the juror] deliberately lied or consciously deceived the Court, as opposed to providing inaccurate responses as a result of a mistake, misunderstanding or embarrassment." United States v. Mx, 275 F. Supp. 3d 420, 437 (W.D.N.Y. 2017) (citing Shaoul, 41 F.3d at 815), ofd sub nom. United States v. 995 F.3d 32 (2d Cir. 2021). That rule exists for good reason: "To invalidate the result of a three-week trial because of a juror's mistaken, though honest response to a question, is to insist on something closer to perfection than our judicial system can be expected to give." McDonough, 464 U.S. at 555.
+
+In Shaoul, the Second Circuit considered McDonough and, specifically, its holding "'that to obtain a new trial in . . . a situation [where a juror makes a mistaken response to a question], a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause.' Id. at 815 (quoting McDonough, 464 U.S. at 556). The Second Circuit held: "Clearly, this is a two-part test." Id. Specifically, "in order to obtain a new trial, a defendant must show both that a juror gave a dishonest answer, and that the correct answer would have provided a basis for the defendant to challenge the juror for cause." Id. at 816 (emphasis in original). Because the defendant in Shaoul, as in McDonough, had failed to satisfy the "threshold requirement" of dishonesty, the Circuit affirmed the district court's denial of his motion for a new trial. Id.
+
+In so doing, the Second Circuit specifically rejected the argument that "a new trial is mandated when the correct disclosure would have sustained a challenge for cause, regardless of the juror's honesty in failing to answer the question correctly." Id. at 815 (quotation omitted). As the Circuit explained, that argument relied on a "contorted" and "incorrect" reading of its prior decision in United States v. Langford, 990 F.2d 65 (2d Cir. 1993). Shaoul, 41 F.3d at 815. Here, the defendant's argument relies in significant part on the very same reading of Langford that was explicitly rejected in Shaoul. Compare Shaoul, 41 F.3d at 815, with Def. Mem. at 24, 27.
+
+The defendant's reliance on two concurring opinions in McDonough fares no better. Justice Rehnquist's opinion for the Court in McDonough was joined by six other justices! That opinion, and not the concurrences, therefore sets forth the Court's holding. Cf. Marks v. United States, 430 U.S. 188, 193 (1977) (determining court's holding by reference to concurring opinions only "[w]hen a fragmented Court decides a case and no single rationale explaining the result enjoys the assent of five Justices"). And to the extent those concurrences may be considered in construing the holding of McDonough, they were clearly available to the Second Circuit when it did so in
+
+8 While the vote count is not always clearly listed on Westlaw or other legal research sites, the official version in the U.S. Reports indicates as much. See https://tile.loc.govistorageservices/serviceM/usrep/usrep464/usrep464548/usrep464548.pdf.
+
+Shaoul. Thus, in the Second Circuit,9 it is a "threshold requirement" to establish that a juror intentionally lied or consciously deceived the court. See Shaoul, 41 F.3d at 815; Nix, 275 F. Supp. 3d at 437; Sattar, 395 F. Supp. 2d at 72 ("The failure to answer honestly must be deliberate; a 'juror's good faith failure to respond, though mistaken, [does] not satisfy even the first prong of the test.'" (quoting Shaoul, 41 F.3d at 815)); United States v. Ruggiero, No. 97 Civ. 2925 (HB), 2001 WL 286751, at \*3 (S.D.N.Y. Mar. 22, 2001) (rejecting claim of juror misconduct in voir dire, concluding "it is not clear that [the juror's] failure to respond to the Court's question was a deliberate attempt at dishonesty, as she only failed to answer the court's question."); v. Manhattan Jeep Eagle, No. 92 Civ. 9521 (DLC), 1997 WL 403458, at \*5 (S.D.N.Y. July 17, 1997) ("[T]he first prong of the test requires a determination of whether juror number one deliberately lied to the Court during voir dire, or whether his answer was the result of a good faith misunderstanding of the question.").
+
+In sum, to satisfy the first prong of the governing test, the defendant must establish dishonesty by Juror 50—a deliberate falsehood or deceit, rather than an honest mistake.
+
+### b. The Current Record Does Not Support a Finding of Deliberate Falsehood
+
+On the current record, there is no basis for the Court to find that Juror 50 gave any deliberately false answer during voir dire. To be sure, if his public statements regarding being a victim of sexual abuse were truthful,10 it would appear that Juror 50 answered Question 48
+
+9 While some circuits have reached a different result, the Second Circuit's view appears to be the prevailing one. See, e.g., Fitzgerald v. 150 F.3d 357, 364 n.3 (4th Cir. 1998) (collecting cases).
+
+1° It is of course possible that Juror 50's unworn public statements were not truthful, while his sworn answers on the questionnaire were. This is a threshold fact that must be determined at a hearing. But for purposes of discussion in this brief, the Government assumes that Juror 50's public statements on this subject were truthful.
+
+inaccurately. But, as noted, that is not the end of the inquiry. And based on the currently available information, there is substantial reason to believe that any inaccuracy was an honest mistake, not a deliberate falsehood.
+
+Juror 50's only statements on the subject to date undermine the defendant's claim that he lied. Juror 50 has publicly stated that he "flew through" the questionnaire and did not recall being asked about his own history of sexual abuse. (Gov't Ex. C at 3). He repeatedly stated that he believed he had answered all the questions honestly. (Gov't Ex. A at 4; Gov't Ex. B at 8; Gov't Ex. C at 3). Indeed, when asked by an interviewer about whether he had disclosed his history of sexual abuse on the questionnaire, he confidently replied: "No, they don't ask your sexual abuse history." (Def. Ex. 3 at :21). When the interviewer said that Question 48 asks about sexual abuse history, Juror 50 responded, in a puzzled tone, "I don't remember." (Id. at :35). He continued, "I would have definitely marked 'yes' but I honestly don't remember that question." (Id. at :54). The defendant makes much of the fact that Juror 50 apparently began blushing, but that reaction is perfectly consistent with someone realizing they had just made a serious though honest mistake.
+
+Indeed, Juror 50 remembered a question about a family member or relative being sexually abused. (Id. at 1:09). And Question 48 asks: "Have you or a friend or family member ever been the victim of sexual harassment, sexual abuse, or sexual assault?" This question was nearly the last in a lengthy questionnaire composed of 51 questions, many with multiple sub-questions. Thus, a juror who was indeed flying through the questionnaire may have, by the 48' question (not including sub-questions), failed to notice that this question also asked about personal experiences. Though careful lawyers may have difficulty crediting that explanation, jurors can and do make mistakes. See, e.g., McDonough, 464 U.S. at 555 ("[J]urors are not necessarily experts in English usage. Called as they are from all walks of life, many may be uncertain as to the meaning of terms which are relatively easily understood by lawyers and judges."); Dyer v. Calderon, 151 F.3d 970, 973 (9th Cir. 1998) ("[W]e must be tolerant, as jurors may forget incidents long buried in their minds, misunderstand a question or bend the truth a bit to avoid embarrassment."); United States v. Fell, No. 01 Cr. 12, 2014 WL 3697810, at \*13 (D. Vt. July 24, 2014) ("[T]he written juror questionnaires must be viewed in context. The long questionnaire in particular consisted of 75 questions not including sub-parts.")." And, in any event, the credibility of Juror 50's explanation as to why, if he was indeed a victim of sexual abuse, he answered this question in the negative is properly resolved not based on a review of unswom public statements, but at a hearing at which the Court can question him on this subject and assess his credibility.
+
+Furthermore, the defendant's suggestion that Juror 50 deliberately lied in order to serve on the jury is undermined by several aspects of Juror 50's conduct. For example, when answering the questions about exposure to pretrial publicity, Juror 50 disclosed that he had read about the defendant and her connection to Epstein. If a juror was willing to lie about sexual abuse to ensure that he was seated on the jury, he would, presumably, have lied about other potentially disqualifying facts, too. Similarly, if Juror 50 deliberately lied under penalty of perjury in order to serve on the jury, it would make little sense for him to immediately publicize that fact, thus exposing himself to criminal liability. See M, 1997 WL 403458, at \*6 ("I fmd it improbable that a juror who lied on voir dire in order to be empaneled on a jury in an age discrimination case to avenge himself against a discriminatory employer who was not a party to the lawsuit would reveal this motivation after rendering a verdict. If this had been the juror's intent, there was no reason why he would expose himself to defense counsel immediately following the verdict.").
+
+Indeed, Juror 50's counsel, in his motion to intervene, discussed infra at Part III, wrote that Juror 50 "does not recall answering questions [in the questionnaire] regarding his prior experience with sexual assault." (Juror 50 Mem. at 5).
+
+The defendant also fails to establish that Juror 50 falsely answered Question 25, when he gave a negative response to the question whether he or relatives or close friends have been the victim of a crime. Juror 50 has not publicly disclosed the particulars of any sexual abuse that he suffered, and thus it is not apparent whether it was in fact a crime. Nor is it apparent that, if the abuse was criminal, Juror 50 deliberately lied when he answered Question 25 in the negative, as lay persons often may not think of themselves as victims of a crime even where lawyers and judges would. See, e.g., Fell, 2014 WL 3697810, at \*6-7, \*13 (crediting juror's explanation that she did not disclose past sexual abuse in response to question about whether she had been a victim of a crime because she did not consider the abuse, for which the abuser was never prosecuted, a crime); see also McDonough, 464 U.S. at 555.
+
+Finally, the available information does not support the defendant's claim that Juror 50 lied during voir dire when he (1) stated that he used Facebook and Instagram, without mentioning that he had a Twitter account, and (2) stated that he had deleted his social media accounts prior to trial. (See Nov. 16, 2021 Tr. at 133). First, the screenshot of Juror 50's Twitter account provided by the defense states that he joined Twitter in April 2021, had only one follower, and only followed 39 people. (Def. Mem. at 18). That hardly bespeaks an active Twitter user, so it was not even inaccurate, much less deliberately false, for Juror 50 not to mention Twitter when asked "What did you use, Facebook, Twitter?" (Nov. 16, 2021 Tr. at 133 (emphasis added)). Second, in support of the argument that Juror 50 lied about deleting his Facebook and Instagram accounts, the defendant cites only post-trial activity on his Instagram account, but as the defendant must acknowledge (Def. Mem. at 20), a deleted account can be reactivated with a few clicks. Indeed, one can delete the Instagram app from one's phone without deleting the account at al1.12 And the defendant's screenshots show that Juror 50 was not hiding anything: His Instagram use did appear, as he stated, to consist of Ipiersonal stuff, like selfies." (Nov. 16, 2021 Tr. at 133; see Def. Mem. at 20). There is no basis for concluding that Juror 50 deliberately lied during voir dire about his social media activity.
+
+In sum, the defendant's argument that the Court should grant her motion based purely on unswom public statements by Juror 50 is unpersuasive. That said, given the apparent inconsistency between Juror 50's public statements that he was a victim of sexual abuse and his answer to Question 48 on the questionnaire, the Government believes that a limited evidentiary hearing on that subject is warranted to determine whether he answered Question 48 falsely and, if so, whether that answer was deliberate or inadvertent. The Government addresses the proper scope of that hearing in Part II, infra.
+
+# 2. The Defendant Has Failed to Satisfy the Second Prong of McDonough
+
+#### a. The Second Prong of McDonough Requires the Court to Determine Whether It Would Have Granted a Hypothetical Challenge
+
+The defendant's brief states: "The second question is whether truthful responses from Juror No. 50 would have provided a valid basis for a challenge for cause." (Def. Mem. at 29 (citing Stewart, 433 F.3d at 303)). This omits an important aspect of the relevant standard, which provides that in order to make that decision, "the district court must `determine if it would have granted the hypothetical challenge.'" Stewart, 433 F.3d at 304 (quoting United States v. Greer, 285 F.3d 158, 171 (2d Cir. 2002)). Critically, that determination is reviewed for abuse of discretion, and "'[t]here
+
+12 See, e.g., https://www.guidingtech.com/what-happens-when-you-uninstall-instagram-fromphone/.
+
+are few aspects of a jury trial where [the Second Circuit] would be less inclined to disturb a trial judge's exercise of discretion, absent clear abuse, then in ruling on challenges for cause in the empanelling of a jury.'" Id. (quoting Greer, 285 F.3d at 172). This is because the district court "observes the jury on a day to day basis" and therefore "is in the best position to sense the atmosphere of the courtroom." Greer, 285 F.3d at 171 (quotations and citations omitted) .
+
+How, then, would the Court have ruled on a hypothetical for cause challenge if Juror 50 had disclosed that he was a survivor of sexual abuse? The Court's decisions with respect to similarly situated jurors provide clear evidence. Of the 58 jurors who were ultimately qualified, eight jurors disclosed that they themselves had been a victim of sexual harassment, sexual abuse, or sexual assault. With respect to each, the Court asked a few follow-up questions (and sometimes only one question), focusing on the ultimate issue of whether the juror could be fair and impartial notwithstanding the juror's experience. (See Nov. 16, 2021 Tr. at 18-19, 52-57, 200, 207-08, 259, 293, 532, 635). In each case, the juror affirmed that he or she could be fair, and not only did the Court not strike the juror for cause, neither party even moved to do so on these grounds. For good reason: People who have experienced sexual harassment, sexual abuse, or sexual assault can be fair and impartial jurors.
+
+Thus, if Juror 50 had disclosed a history of sexual abuse, the Court would not have immediately granted a challenge for cause, as the defendant's brief suggests. Instead, the Court properly would have asked follow-up questions designed to determine whether Juror 50 could be fair and impartial notwithstanding that experience and could decide the case based on the evidence and the law. Here, because Juror 50 did not disclose any history of sexual abuse, the Court did not have occasion to ask such follow-up questions. Accordingly, the Government believes that a limited hearing is warranted to ask Juror 50 such questions. If Juror 50 credibly states that he would have truthfully affirmed that he could be fair and impartial, then the record is clear that the Court would not have struck him for cause, and the defendant's motion should be denied.
+
+# b. The Defendant's Arguments Regarding Bias Are Unpersuasive
+
+A party may challenge a juror for cause based only on "narrowly specified, provable and legally cognizable bases." United States v.=, 128 F.3d 38, 43 (2d Cir. 1997) (quotation and citation omitted). In the context of voir dire, challenges for cause generally fall into one of three "limited" categories: actual bias, implied bias, or inferable bias. Id. However, in the different context presented here—a post-trial allegation of juror bias, in a retrospective determination of a hypothetical challenge for cause—the Second Circuit has stated that it is an open question whether the second and third of these categories are applicable. See Greer, 285 F.3d at 172. That is, "the remedy for allegations of juror partiality is a hearing in which the defendant has the opportunity to prove actual bias," v. , 455 U.S. 209, 215 (1982) (emphasis added), and, as such, it is unclear that bias may be implied or inferred, see Greer, 285 F.3d at 172. The Government submits that actual bias is the only relevant inquiry in this context, see 455 U.S. at 215, but nevertheless addresses each category in turn.
+
+# i. Actual Bias
+
+"Actual bias is `bias in face—the existence of a state of mind that leads to an inference that the person will not act with entire impartiality." =, 128 F.3d at 43 (quoting United States v. M, 299 U.S. 123, 133 (1936)). "[A] finding of actual bias is based upon determinations of demeanor and credibility that are peculiarly within a trial judge's province." Id. at 44 (quotation and citation omitted). Actual bias "cannot be found unless a prospective juror is adequately questioned on voir dire with respect to his or her ability to apply the law impartially." Id. at 44. The district court has "broad discretion" in such questioning and "Where is no particular script
+
+that must be followed," but a standard question, approved by the Second Circuit, is: "If you are selected to sit on this case, will you be able to render a verdict solely on the evidence presented at the trial and in the context of the law as I will give it to you in my instructions, disregarding any other ideas, notions, or beliefs about the law that you may have encountered in reaching your verdict?" Id. at 43-44.
+
+With respect to Juror 50, the defendant has presented no evidence to support a claim of actual bias. In a public interview, Juror 50 stated that he "went into the trial firmly believing that Maxwell was 'innocent until proven guilty' and viewing the victims with a skeptical eye" and that his own experience of sexual abuse "did not affect his ability to view Maxwell as innocent until proven guilty." (Gov't Ex. B at 2, 8). These statements are corroborated by the apparent care with which the jury approached its deliberations—asking for testimony and other evidence in numerous questions submitted over the course of multiple days of deliberations—and by its return of a split verdict, in which it acquitted the defendant on one count. See United States v. Aiello, 771 F.2d 621, 631 (2d Cir. 1985) (citing apparent care with which jury approached deliberations and split verdict as evidence of impartiality); Greer, 285 F.3d at 174 (citing split verdict as evidence of impartiality). And Juror 50's public statements are further corroborated by his answers during voir dire, during which he unequivocally stated that he would be able to follow the law as instructed by the Court, that he would decide the case based on the facts and evidence, or lack of evidence, presented in court, and that, other than what he had been asked, there was no reason to think he could not be fair and impartial. See Nov. 16, 2021 Tr. at 128, 130, 134.
+
+While the defendant has not argued for a finding of actual bias (Def. Mem. at 38-39), she at times alludes to the argument. For example, the defendant makes much of the fact that Juror 50 called the defendant a "predator," said the verdict was for "all the victims," and commented on a
+
+Twitter post by (Def. Mem. at 13, 15-16). But he did these things after trial, having heard all the evidence that proved that, as the Government argued, the defendant was in fact a predator and that the victims, including were credible. Juror 50's attitudes towards the defendant and the victims after he heard compelling evidence of the defendant's guilt and the victims' credible testimony says nothing about the relevant inquiry here: whether he was biased "before he heard the evidence presented." United States v. Stewart, 317 F. Supp. 2d 432, 440 (S.D.N.Y. 2004), gird, 433 F.3d 273, 306 (2d Cir. 2006) (emphasis in original); see also id. at 439 n.4 (finding no bias where juror in Martha Stewart trial said the verdict was "a victory for the little guy who loses money in the markets" and that the defendant "thought she was above everything").
+
+Similarly, the defendant gestures at an actual bias argument when she states that it is "clear," based on Juror 50's statements to the media,13 that he was not fair and impartial "because his personal experiences `prevent[ed] or substantially impair[ed] the performance of his duties as a juror."' (Def. Mem. at 44 (quoting Wainwright v. Win, 469 U.S. 412, 424 ( I 985))). There and elsewhere, the defendant's brief seems to suggest that jurors are required to check their lived experiences at the jury room door. Not so:
+
+> We cannot expunge from jury deliberations the subjective opinions of jurors, their additudinal expositions, or their philosophies. These involve the very human elements that constitute one of the strengths of our jury system, and we cannot and should not excommunicate them from jury deliberations.
+
+U.S. a rel. Owen v. McMann, 435 F.2d 813, 818 (2d Cir. 1970); see also United States v. Bangiyev, No. 07 Cr. 331 (NG) (RLM), 2008 WL 4240005, at \*10 (E.D.N.Y. Sept. 12, 2008) (explaining
+
+13 As noted above, many if not all of the statements upon which the defendant relies describe deliberations and are thus inadmissible under Rule 606(b). And even if they were not, Juror 50's public statements about deliberations in fact demonstrate that he (and the jury more generally) was impartial. See infra n.5.
+
+that "personal experiences" are "permissible influences on jury deliberations"); Arreola v. Choudry, 533 F.3d 601, 606 (7th Cir. 2008) (jurors "are entitled to evaluate the evidence presented at trial in light of their own experience"). Thus, so long as they do not introduce extra-record facts about the defendant, there is nothing improper about jurors bringing their personal experiences to bear during deliberations. McMann, 435 F.2d at 818 & n.5.
+
+Here, if Juror 50 had disclosed a history of sexual abuse, there is every indication that the voir dire would have proceeded as it did with the numerous similarly situated jurors. The Court would have asked follow-up questions—substantially similar to the Second Circuit-approved question above—designed to determine whether he could be fair and impartial. If he had credibly disclaimed partiality, he would not have been struck from the jury.
+
+# Implied Bias
+
+Implied bias, also called "presumed bias," is "bias conclusively presumed as a matter of law."' = 128 F.3d at 45 (quoting M, 299 U.S. at 133). That is, a finding of implied bias does not turn on the juror's answers to questions during voir dire, but rather whether an "average man" in a similar situation would be biased. Id. at 4546. The Second Circuit has emphasized that this category is "narrow," and "reserved for 'exceptional situations."' Id. at 46. Generally, it is limited to circumstances in which there is a relationship between the juror and the parties or the crime itself. See id. at 45 ("[A]utomatically presumed bias deals mainly with jurors who are related to the parties or who were victims of the alleged crime itself."); Greer, 285 F.3d at 172 ("[T]he District Court refused to find implied bias because it found the issues affecting juror Baker to be insufficiently 'drastic.' Juror Baker was, after all, neither related to a party nor a victim of the defendants' crimes.").
+
+Keeping with that "narrow" view of implied bias, the Second Circuit has "consistently refused to create a set of unreasonably constricting presumptions that jurors be excused for cause due to certain occupational or other special relationships which might bear directly or indirectly on the circumstances of a given case, where . . . there is no showing of actual bias or prejudice." 128 F.3d at 46 (quotations and citations omitted). For example, the Second Circuit has declined to follow a Ninth Circuit precedent stating that it was error not to excuse two bank tellers as jurors in a bank robbery case. United States v.IM, 644 F.2d 101, 104-05 (2d Cir. 1981) (declining to follow United States v. Allsup, 566 F.2d 68 (9th Cir. 1977)); see also Mikus v. United States, 433 F.2d 719, 724 (2d Cir. 1970) (similar). And it has held that a juror's prior service at a trial involving similar but unrelated offenses which involved the testimony of a common witness does not give rise to implied bias. See United States v.=, 936 F.2d 648, 652 (2d Cir. 1991); see also Curry v. 323 F. App'x 63, 65 (2d Cir. 2009) (rejecting argument that a juror had implied bias because he owned a printing business that did business with defense counsel).
+
+Here, there is no suggestion that Juror 50 is related to a party in this case, or that he is a victim of or has any personal knowledge of the defendant's crimes. Accordingly, the circumstances of this case do not fall within the narrow categories of implied bias that the Second Circuit has recognized. This is not one of the rare, extreme circumstances where a mandatory presumption of bias may be applied. See, e.g., 128 F.3d at 45; Greer, 285 F.3d at 172.
+
+The defendant principally argues that implied bias should be found based on alleged similarities between the personal experiences of Juror 50 and the issues being litigated. (Def. Mem. at 30-35). But the Second Circuit has not recognized this as a proper basis to make a finding of mandatory, presumed bias. Indeed, it has specifically rejected such a notion:
+
+> Just as we have refused to carve out an overly broad category of presumed bias based on occupational or status relationships, so we
+
+also decline to hold as a general matter that, where a juror has engaged in conduct similar to that of the defendant at trial, the trial judge must presume bias. Such cases are unlikely to present the "extreme situations" that call for mandatory removal.
+
+128 F.3d at 46; see also id. at 46 & n.11 (rejecting Allsup decision from Ninth Circuit that court must presume that jurors who had "particular .. . prior experiences were biased"). Thus, to the extent the cases cited by the defendant purport to require such a presumption of bias, they are inconsistent with binding Second Circuit precedent. (See, e.g., Def. Mem. at 31 (citing United States v. Eubanks, 591 F.2d 513, 517 (9th Cir. 1979), which relied on Allsup)).
+
+The remaining cases cited by the defendant are inapposite. Some merely state a general proposition that similarity of experiences may give rise to a presumption of bias, but then go on to resolve the case on other grounds. See, e.g., Skaggs v. Otis Elevator Co., 164 F.3d 511, 517-18 (10th Cir. 1998); United States v. Daugerdas, 867 F. Supp. 2d 445, 472 (S.D.N.Y. 2012), vacated by United States v. Parse, 789 F.3d 83 (2d Cir. 2015). Others find that a juror should have been struck not merely because of similarity of experiences, but also based on a number of other factors not present here. For example, in one case prominently cited by the defendant, a juror in the penalty phase of a death penalty case told a "litany of lies," and the First Circuit declined to rest its decision on any particular category of bias, but instead cited the combination of the juror's interpersonal relationships, inability to separate emotion from duty, similarity of experiences, scope and severity of dishonesty, and motive for lying, any one of which "taken in isolation, may be insufficient to ground a finding of a valid basis for a challenge for cause." Sampson v. United States, 724 F.3d 150, 161, 166-68 (1st Cir. 2013); see also Hunley v. Godinez, 975 F.2d 316, 319- 20 (7th Cir. 1992) (citing combination of factors in "extreme" case where two jurors were burglarized during deliberations and then changed their votes as a result, and stating that "our holding is limited to the very unique facts stated herein" and "[i]t is unlikely these rare
+
+circumstances will ever recur"). And the New Hampshire state decision prominently cited by the defendant does not hold that a mandatory presumption of bias applies based on similarity of experiences, but merely finds that the trial court acted within its discretion when it found, after a post-verdict hearing, that the juror's demeanor, actions, and communications before, during, and after trial demonstrated bias. See State v. Ashfar, 196 A.3d 93, 94 (N.H. 2018); see also id. at 98 (noting that "when called for jury service in another sexual assault case involving an alleged victim who was a minor, Juror 6 acknowledged that he could not sit on that jury due to his feelings about his daughter; and .. . there appears to be little in the way of logical explanation for how he could have differentiated between the two cases.").
+
+Moreover, this Court's handling of similarly situated jurors in this case is again relevant to the hypothetical inquiry at issue. See. e.g., 128 F.3d at 45 (implied bias finding based on "average man" test). If it were correct that a juror's experience with sexual abuse required a mandatory presumption of bias in a sexual abuse case, the defense would have sought to strike, and the Court would have struck, the numerous other jurors who reported a history of sexual abuse (or at the very least would have pursued detailed follow-up questioning to establish the particulars of the abuse and the extent of any similarities to the charged conduct). But that is not what happened here: Where jurors indicated a history of sexual abuse or harassment, the Court conducted a targeted follow-up inquiry, focused on whether they can be fair and impartial. And rightly so: It is not the law in this Circuit that a victim of sexual abuse is presumed to be biased. On that score, it bears emphasizing how prevalent sexual abuse is, and how common federal trials involving sex trafficking and child enticement are. If it were the law that survivors of sexual abuse—who make up a significant percentage of the prospective jury pool in any trial—could not
+
+serve as jurors in such cases, the defendant would have cited case law that actually supports that proposition.
+
+Finally, the defendant also argues that bias should be implied because she alleges that Juror 50 has repeatedly lied. (Def. Mem. at 35-36 (citing Daugerdas, 867 F. Supp. 2d at 472)). As discussed in greater detail above, the record does not support this, and, as a result, this is a far cry from the extreme circumstances in Daugerdas, where Judge Pauley concluded after a hearing that the juror "created a totally fictitious persona in her drive to get on the jury" and was "a pathological liar who does not know the difference between truth and lie." Id. at 473, 475.
+
+The record also does not support the defendant's attempt to compare Juror 50 to Juror 55, who was dismissed for cause
+
+As noted above, there is no evidence that Juror 50 lied about his social media accounts. Moreover, the defendant's analogy misunderstands the nature of the current inquiry, in which the Court must consider the hypothetical question whether, if the juror had truthfully answered the relevant question, the Court would have struck him for cause. See Stewart, 433 F.3d at 304. But here, in a post-verdict posture, if the Court were to find that Juror 50 intentionally lied about using social media accounts, the question would be whether the Court would have struck him if he had truthfully answered that question. There is nothing in the record about Juror 50's use of social media accounts that would have supported a challenge for cause at voir dire.
+
+In sum, the defendant has failed to establish implied bias.
+
+#### iii. Inferred Bias
+
+While the category of cases in which bias must be implied or presumed is limited to "exceptional" or "extreme situations," the district court retains discretion to dismiss a juror for cause when "a juror discloses a fact that bespeaks a risk of partiality sufficiently significant to warrant granting the trial judge discretion to excuse the juror for cause, but not so great as to make mandatory a presumption of bias." =, 128 F.3d at 46-47. This doctrine of "inferred bias" is "closely linked" to the "traditional categories" of actual and implied bias, and a finding of inferred bias is permitted "only after having received responses from the juror that permit an inference that the juror in question would not be able to decide the matter objectively." Id. at 47. "[A] finding of inferred bias is, by definition, within the discretion of the trial court." Greer, 285 F.3d at 172. And, as with actual bias, "a district court's evaluation of the juror's impartiality is accorded deference." Id.; see also id. ("There are few aspects of a jury trial where we would be less inclined to disturb a trial judge's exercise of discretion, absent clear abuse, than in ruling on challenges for cause in the empanelling of a jury." (quoting United States v. Ploof, 464 F.2d 116, 118-19 n.4 (2d Cir. 1972))).
+
+Here, the record refutes any suggestion that, had Juror 50 disclosed a history of sexual abuse, the Court would have struck him based on a finding of inferred bias. As set forth above, the record is clear that the Court would have in fact conducted targeted follow-up questioning and, absent some indication in such questioning that would have permitted an inference of bias, the Court would not have struck him. See =, 128 F.3d at 47 (finding of inferable bias "must be grounded in facts developed at voir dire").
+
+upon which the defendant exclusively relies, is not to the contrary. In that case, the district court struck a juror for cause where she had engaged in the structuring of cash deposits,
+
+conduct which was similar to the charged offenses such that the juror may have felt that she was "confronting the legality of [her] own past acts as well." , 128 F.3d at 48. While the Second Circuit held that the district court did not abuse its discretion in inferring bias under the circumstances presented there, it also made clear that the district would not have erred in declining to infer bias. Id. thus underscores the ample discretion which district judges have in striking jurors for cause—discretion which this Court has properly exercised not to infer bias where jurors have disclosed being victims of sexual abuse or harassment.
+
+The defendant has failed to establish inferred bias.
+
+# II. The Court Should Schedule a Limited Hearing Regarding Juror 50
+
+# A. Applicable Law
+
+A post-verdict hearing into alleged juror misconduct is proper only where there is "clear, strong, substantial and incontrovertible evidence . . . that a specific, non-speculative impropriety has occurred." United States v. Stewart, 590 F.3d 93, 133 (2d Cir. 2009) (quoting Jennie °, 866 F.2d at 543). This standard can only be met by "concrete allegations of inappropriate conduct that constitute competent and relevant evidence," though such allegations "need not be irrebuttable because if the allegations were conclusive, there would be no need for a hearing." United States v. Baker, 899 F.3d 123, 130 (2d Cir. 2018) (quoting lanniello, 866 F.2d at 543).
+
+In the rare instances where an inquiry into potential juror misconduct is warranted, the scope of the hearing must be narrowly tailored. The Second Circuit has emphasized that the inquiry "should be limited to only what is absolutely necessary to determine the facts with precision." lanniello, 866 F.2d at 544. "A hearing is not held to afford a convicted defendant the opportunity to `conduct a fishing expedition?" United States v. Sun Myung Moon, 718 F.2d 1210, 1234 (2d Cir. 1983) (quoting United States v. Moten, 582 F.2d 654, 667 (2d Cir. 1978)). Instead, "[t]he object of the proceeding is to permit the truth to be discovered with the least possible harm to other interests." United States v. Gagnon, 282 F. App'x 39, 40 (2d Cir. 2008) (quoting Moten, 582 F.2d at 666); see also v. United States, 403 F.2d 77, 82 (2d Cir. 1969) (court should avoid "dangers presented by inquiries that go beyond objective facts: inhibition of jury-room deliberations, harassment of jurors, and increased incidence of jury tampering."). Indeed, "the proper functioning of the jury system requires that the courts protect jurors from being harassed and beset by the defeated party in an effort to secure from them evidence of facts which might establish misconduct sufficient to set aside a verdict." Mogen, 582 F.2d at 664 (quotation omitted). Thus, "when and if it becomes apparent that the ... reasonable grounds to suspect prejudicial jury impropriety do not exist, the inquiry should end." Sun Myung Moon, 718 F.2d at 1234.
+
+The district court "has the power and the duty to supervise and closely control such inquiries." United States v. Calbas, 821 F.2d 887, 896 (2d Cir. 1987). For example, the Court may choose to personally conduct the questioning of a juror in order to avoid intruding on the jury's deliberations. See, e.g., Calbas, 821 F.2d at 896. A district court may also determine to hold the hearing in camera. See lanniello, 866 F.2d at 544; see also United States v. Shalair, 723 F. Supp. 925, 928 (S.D.N.Y. 1988), afrd 888 F.2d 234 (2d Cir. 1989).
+
+# B. Discussion
+
+For the reasons set forth above, the Government believes that the exacting standard for a post-verdict hearing has been met only with respect to Juror 50 and the apparent inconsistency between his several public statements (including one on video) about being a victim of sexual abuse and his answer to Question 48 on the juror questionnaire. Thus, the Government consents to a hearing in order to determine (1) whether Juror 50 deliberately lied in response to Question
+
+48, and, if so, (2) whether the Court would have struck Juror 50 for cause if he had accurately responded to that question, i.e., whether he was actually biased.
+
+For the reasons set forth below, the Government submits that: (1) the Court should conduct the questioning; (2) the questions for Juror 50 should be narrowly tailored; (3) there is no basis to call any other jurors as witnesses; and (4) the defendant's request for "pre-hearing discovery" should be denied.
+
+# 1. The Court Should Conduct the Questioning
+
+First, as noted, given the dangers of harassment and embarrassment presented by juror inquiries, the Court has the power and duty to closely control the proceedings. The Court can and courts in this District frequently do—choose to personally question the jurors, often giving the parties an opportunity to propose to the Court questions for the Court to ask. See, e.g., Calbas, 821 F.2d at 896 (district court conducted examination of juror, and Second Circuit concluded that the district court "wisely refrained from allowing the inquiry to become an adversarial evidentiary hearing, so as to minimize intrusion on the jury's deliberations"); Loliscio v. Goord, 263 F.3d 178, 191 (2d Cir. 2001) ("[T]he scope of such a post-verdict inquiry, and the extent, if any, to which the parties may participate therein are matters left to the sound discretion of the trial court."); Chase Manhattan Bank, N.A. v. T&N, No. 87 Civ. 4436 (JGK), 1997 WL 221203, at •8 (S.D.N.Y. Apr. 28, 1997) ("The Court examined Juror No. 5 under oath in the presence of counsel for both parties, after both parties were given the opportunity to submit proposed questions. To protect the juror from harassment or embarrassment, the Court personally conducted the questioning of the juror."); United States v. Shakur, 723 F. Supp. 925, 928 (S.D.N.Y. 1988) (district court examined juror in camera, after permitting counsel to file suggested questions), aff'd 888 F.2d 234 (2d Cir. 1989); United States v. Greer, 998 F. Supp. 399, 404 (D. Vt. 1998) ("All of the jurors were
+
+interviewed by the Court; the parties were permitted to propose questions before and during the hearing."), aff'd, 285 F.3d 158 (2d Cir. 2002).
+
+That course of action is especially appropriate here for several reasons. First, the subject matter—the juror's history of sexual abuse—presents a particularly high danger of harassment or embarrassment. Second, as noted above, the defendant's brief is littered with information barred by Rule 606(b), suggesting a real danger she will seek to question Juror 50 about improper and inadmissible subjects. The Court should exercise its discretion to supervise the hearing by conducting the questioning itself.
+
+# 2. The Scope of the Hearing Should Be Limited
+
+The scope of the hearing should be tightly limited to "only what is absolutely necessary to determine the facts with precision." lanniello, 866 F.2d at 544; see also Sun Myung Moon, 718 F.2d at 1234; Gagnon, 282 F. App'x at 40.14 Here, the only issues relevant under McDonough are whether Juror 50 intentionally lied in response to Question 48, and whether Juror 50 was actually biased against the defendant. No other subjects are appropriate for inquiry.15
+
+14In particular, Juror 50 cannot be asked to testify about what was said by any juror (including him) in the jury room, or what his mental process was as a deliberating juror. He also cannot be asked whether he or any other juror discussed personal experiences with sexual abuse during deliberations. Fed. R. Evid. 606(b); Warger, 574 U.S. at 43-44 ("We hold that Rule 606(b) applies to juror testimony during a proceeding in which a party seeks to secure a new trial on the ground that a juror lied during voir dire.").
+
+15 For the reasons discussed above, the defendant has not met her burden with respect to Juror 50's voir dire statements about his social media use and accordingly a hearing regarding such statements is not warranted. Similarly, as discussed above, the defendant has also not met her burden with respect to whether Juror 50 answered Question 25 incorrectly, namely, whether Juror 50 considers himself to be a victim of a crime. However, in the event that Juror 50's testimony at the hearing regarding Question 48 makes clear that Juror 50 answered Question 25 incorrectly as well, the Government would consent to the Court questioning Juror 50 regarding that question. However, that questioning should be limited in the same manner as discussed throughout with respect to Question 48.
+
+This inquiry should be tightly focused. As a threshold matter, the Court should inquire whether Juror 50's public statements are true—i.e., whether he was in fact a victim of sexual abuse.16 If the answer is yes, then the Court should determine why Juror 50 nevertheless answered "no" to Question 48. Finally, the Court should ask such questions as to permit it to make the hypothetical determination posed by McDonough's second prong: If Juror 50 had accurately answered Question 48, would the Court have struck him for cause?
+
+On this last subject, the defendant claims that had Juror 50 answered Question 48 in the affirmative, the Court and the parties would have "probed" him about various topics, which the defendant suggests are necessary topics of examination. (Def. Mem. at 44). The record refutes that assertion, and inquiry along the lines proposed by the defendant is not necessary.
+
+The defendant argues that the Court would have inquired whether Juror 50 was able to assess the credibility of a witness claiming sexual assault or abuse just like he would any other witness. (Id.). As an initial matter, Juror 50 already stated in the juror questionnaire that he could assess the credibility of a witness claiming sexual assault or abuse just like he would any other witness. (Def. Ex. 1, Question 47). Moreover, the Court did not ask jurors who answered Question 48 in the affirmative any follow up questions about Question 47. Accordingly, there is no need to inquire about this subject any further at a hearing, beyond perhaps reaffirming that Juror 50's answer to Question 47 was correct.
+
+16 The Court need not inquire about the details of the victim's sexual abuse, just as the Court did not probe such details with respect to other jurors who answered Question 48 affirmatively. (See Nov. 16, 2021 Tr. at 18-19, 52-57, 200, 207-08, 259, 293, 532, 635). In the event the Court believes that details need to be elicited, beyond those few details Juror 50 has provided publicly, such inquiry should be conducted at sidebar or in camera. See lanniello, 866 F.2d at 544; Shakur, 723 F. Supp. at 928.
+
+The defendant also argues that the Court and the parties would have "probed" Juror 50 about whether he was able to "set aside his own traumatic experience" when evaluating whether the Government met its burden of proof. (Def. Mem. at 44). Juror 50 confirmed both in writing and during oral voir dire that he could "[a]bsolutely" "decide the case based on the facts and evidence, or lack of evidence, presented in court." Nov. 16, 2021 Tr. at 130:12-16; see id. at 131:1-7 (stating that he had "[n]o doubt" that he "could decide the case based on the facts and evidence, or lack of evidence, here presented in court"); see also Del Ex. 1, Questions 13 & 41. There is no need for any further inquiry on this subject, beyond perhaps reaffirming that Juror 50 was truthful when he stated that he could decide the case based on the facts and evidence presented in court.
+
+Finally, the defendant claims that the Court and the parties would have specifically inquired as to whether Juror 50 was able to fairly evaluate Dr. Loftus's testimony and impartially assess the defendant's "defense that her accusers' memories were unreliable and tainted by money and manipulation." (Def. Mem. at 44). This claim is belied by the voir dire record. The Court did not ask jurors who answered Question 48 in the affirmative such follow up questions, and rightly so. The purpose of voir dire is not to educate prospective jurors on the defense theories of the case or to determine if prospective jurors agree with such theories or would credit specific, as-yet-uncalled witnesses. Instead, the purpose of voir dire is to "screen individuals who are unable to sit in a fair and impartial manner." United States v. Pirk, 15 Cr. 142 (EAW), 2018 WL 1027441, at \*4 (W.D.N.Y. Feb. 21, 2018); see also United States v. Barnes, 604 F.2d 121, 138 (2d Cir. 1979) ("[T]he purpose of the voir dire is to ascertain disqualifications, not to afford individual analysis in depth to permit a party to choose a jury that fits into some mold that he believes appropriate for his case." (quotation marks and citation omitted)). Accordingly, it is clear that the Court would
+
+not have questioned Juror 50 during voir dire about his views about Dr. Loftus or memory, and it would be inappropriate to do so now.
+
+Instead, the inquiry of Juror 50 should be similar to the inquiry the Court conducted of other prospective jurors who answered "yes" to Question 48 of the juror questionnaire. For example, during the voir dire inquiry of Juror 189, after directing the prospective juror to a blank version of the questionnaire, the Court's examination on this subject was as follows:
+
+> THE COURT: Based on your response, what I want to ask is if there is anything about what you describe here that would interfere in any way with your ability to be fair and impartial here?
+
+JUROR: No.
+
+(Nov. 17, 2021 Tr. at 532:11-18). Similarly, the following is the voir dire inquiry of Juror 239, who answered "yes" to Question 48:
+
+> THE COURT: The first tab is just a blank version of the questionnaire that you filled out. If you turn to page 24, question 48. Do you recall your response to question 48?
+
+JUROR: Yes.
+
+THE COURT: Anything about that experience, in light of what I have told you about this case, that would interfere in any way with your ability to be fair to both sides?
+
+JUROR: There is nothing there.
+
+(Nov. 18, 2021 Tr. at 634:25-635:8). These jurors were not asked any further questions about their experiences as victims of sexual abuse, and they were qualified as jurors without objection from either party. Thus, while the defendant claims that Juror 50's responses to the questionnaire deprived the Court of the opportunity to conduct a probing voir dire examination of Juror 50 regarding his views about the defense's theories in this case, the record proves otherwise. (Def.
+
+Mem. at 44). Instead, the questioning of Juror 50 should be limited to only what is strictly necessary to determine the relevant issues.
+
+There is no basis to call any other witness at a hearing aside from Juror 50. The questioning of Juror 50 is sufficient to address the only questions as to which the rigorous standard for an evidentiary hearing has been met.
+
+The defendant nevertheless proposes calling each of the twelve jurors for testimony about whether they have experienced sexual abuse. (Def. Mem. at 50, 57). It would be difficult to imagine a spectacle more damaging to the jury process than requiring each of the jurors to return to court weeks or months after their service was complete to testify about such a deeply personal and sensitive subject. The defendant's request is exactly the sort of "fishing expedition" that presents the "evil consequences" of which the Second Circuit has repeatedly warned. See
+
+The defendant's request for such an inquisition is based on a single sentence in a newspaper article, which reports that an anonymous "second juror described in an interview with The New York Times having been sexually abused as a child." See https://www.nytimes.com/2022/01/05/nyregion/maxwell-trial-jury-inquiry.htm1.17 It is questionable that this report itself may be considered under Rule 606(b), insofar as the next sentence refers to the juror's experience in the context of jury deliberations, so it is not clear from the article whether the anonymous juror made any statements to the reporter that were separate
+
+17 The defendant's motion also states that Juror 50 has made public statements about another juror who discussed experiences with sexual abuse in the context of deliberations. Rule 606(13) precludes the Court from considering this. See Warger, 574 U.S. at 43 (affirming denial of motion for a new trial under McDonough, where the only evidence of juror dishonesty was an affidavit from another juror regarding statements a juror had made during deliberations).
+
+from his or her discussion of deliberations. But even if it were properly considered, this onesentence, hearsay report of an anonymous speaker is not a sufficient basis for dragging the entire jury in for questioning at a hearing in an effort to root out the identity of this particular juror. As noted, a hearing is warranted only where there is "clear, strong, substantial and incontrovertible evidence that a specific, non-speculative impropriety has occurred." Stewart, 590 F.3d at 133-34 (quotation omitted). "Gossip and anonymous tips do not satisfy this standard." United States v. Stewart, 317 F. Supp. 2d 432, 443 (S.D.N.Y. 2004), aff'd, 433 F.3d 273, 306 (2d Cir. 2006). The Second Circuit and courts in this district have thus repeatedly found that a hearing is not necessary on similar facts.
+
+For example, in United States v. Loera, a magazine article published shortly after the verdict stated that an unnamed juror alleged that jurors followed media coverage of the trial in violation of the court's instructions, and that they heard prejudicial information not admitted during the trial, including that the defendant had drugged and raped underaged girls. No. 19-2239, 2022 WL 211199, at \*12 (2d Cir. Jan. 25, 2022). During trial, the district court had repeatedly instructed the jury to avoid media coverage and on two occasions had canvassed the jury and spoke with jurors individually about particular articles. Id. One juror acknowledged seeing the relevant headline before turning away and another acknowledged seeing part of a headline before closing the application. Id. & n.15. The anonymous juror's statements in the magazine article, however, suggested that the extent of juror exposure to this prejudicial media information was far more extensive, and that some jurors had discussed lying to the judge when he inquired about their exposure to that coverage. See Brief for Appellant, 2020 WL 5757930, at \*157-\*61 (2d Cir. Sept. 4, 2020) (quoting article). Nevertheless, the district court concluded that the defendant had failed to meet his burden to establish that an evidentiary hearing was warranted, and the Second Circuit
+
+affirmed, holding that "the unworn, uncorroborated statements that one unidentified juror made to a magazine reporter do not constitute the 'clear, strong, substantial and incontrovertible evidence' requiring any juror inquiry beyond that already made." Loera, 2022 WL 211199, at \*12 (quoting Moon, 718 F.2d at 1234). The same is true here: a newspaper report about an anonymous juror who had experienced sexual abuse is not "incontrovertible evidence" that juror misconduct occurred.
+
+Similarly, in United States v. Bin Laden, one defendant sought a new trial based on a sentence in a newspaper article, which, based on interviews with jurors, stated that "[o]ne juror used the Internet at home to research a difficult legal concept concerning [one] defendant." The district court declined to hold an evidentiary hearing, holding that "[t]his single sentence, an unswom snippet of hearsay within a newspaper article, is far less substantial than the sworn affidavits present in cases where evidentiary hearings have been ordered." United States v. Bin Laden, No. S7R 98 Cr. 1023 (KTD), 2005 WL 287404, at 112 (S.D.N.Y. Feb. 7, 2005), aff'd sub nom. In re Terrorist Bombings of U.S. Embassies in E. Afr., 552 F.3d 93 (2d Cir. 2008).
+
+Finally, in Martha Stewart, the defendant brought a post-trial motion alleging a host of deliberate omissions by a juror. 317 F. Supp. 2d at 438. Among the alleged deliberate omissions was that the juror had been fired from his job at Citibank for abusing drugs or improper expense accounting. Id. at 442. The district court denied a hearing with regard to this (and the other) allegations, as it was based on (a) statements of an individual who "appears to be reporting rumors," and (b) an anonymous call to the defendant's lawyer from an individual purporting to work for Citibank. Id. The Second Circuit affirmed that decision, noting that the defendant's factual proffer as to this (and certain other) allegations was "insufficient." Stewart, 433 F.3d at 305 & n.7. And although the Second Circuit stated in dicta that it might have held a hearing in the
+
+first instance, it held that the district court's decision not to do so was within its broad discretion. Id. at 306.
+
+As the foregoing cases reflect, given the dangers of post-verdict hearings into jurors' conduct, to warrant a hearing, allegations of impropriety must be "concrete allegations of inappropriate conduct that constitute competent and relevant evidence." Baker, 899 F.3d at 130 (quotation omitted). A single, anonymous sentence found in a newspaper article does not meet that standard. Such a report is classic hearsay and suffers from the risks inherent on relying on such information. See Schering Corp. v. Pfizer Inc., 189 F.3d 218, 232 (2d Cir. 1999) (describing the "four classes of risk peculiar to this kind of evidence: those of (1) insincerity, (2) faulty perception, (3) faulty memory and (4) faulty narration"). As such, in the foregoing cases and numerous others, courts have routinely declined to grant evidentiary hearings based solely on hearsay statements. See also, e.g., United States v. Sonar, 395 F. Supp. 2d 66, 77 (S.D.N.Y. 2005), aff'd sub nom. United States v. Stewart, 590 F.3d 93 (2d Cir. 2009); Daniels v. Hollins, No. CV-02-4495FBLB, 2006 WL 47412, at \*8 (E.D.N.Y. Jan. 9, 2006); United States v. Menendez, 440 F. App'x 906, 911-12 (11th Cir. 2011). As one court observed, "to permit an inquiry based on such scant evidence in a case that continues to receive an unprecedented level of publicity would do serious damage to the policies that justify limitations on postverdict juror scrutiny." Stewart, 317 F. Supp. 2d at 443. So too here.
+
+The Court should deny the defendant's request to expand the hearing to call every juror merely to inquire into a single anonymous statement in a newspaper article.
+
+# 4. The Defendant's "Discovery" Request Should Be Denied
+
+The Court should deny the defendant's motion for "pre-hearing discovery" in its entirety. Given the "evil consequences" of post-verdict juror inquiries, courts may not permit such inquiries to become a "fishing expedition" but rather must limit the scope of any inquiry "to only what is absolutely nececcary to determine the facts with precision." lanniello, 866 F.2d at 543-44. It is hard to imagine a request more likely to "subject[] juries to harassment" and "inhibit juryroom deliberation," id. at 543, than the defendant's request to compel production of a juror's emails and other written communications, as well as content from his Facebook, Twitter, LinkedIn, Instagram, and other social media accounts. (Def. Mem. at 48-49). Not surprisingly, the defendant cites no precedent for this sweeping and invasive request. The Court should reject it.
+
+Moreover, each specific request is improper. Requests 1(b) and 1(c) call for communications between jurors and communications "about Juror No. 50's jury service," and thus call for information that, if it exists, is almost certainly inadmissible under Rule 606(b). Moreover, the fact that Juror 50 made some public statements about his jury service does not give the defendant license to compel the production of any statements he may have made to anyone—such as a friend or loved one—about his jury service. This is a classic fishing expedition and should not be permitted. Request 1(a) calls for communications with victims and witnesses, but this too is a fishing expedition: Juror 50's public comment on a victim's public Twitter post after trial does not give the defense license to compel his private communications in the vague hope that, contrary to the Court's instructions, he had some improper communications before or during trial. And Request 1(d) calls for communications about any payment Juror 50 received for media interviews, but even if he received compensation for post-trial interviews that says nothing whatsoever about whether the Court would have struck him for cause before trial based on his alleged experience with sexual abuse.
+
+Requests 2(a) and 2(b) ask the Court to direct numerous social media companies to produce all communications to and from Juror 50 about his jury service and all posts or comments regarding his jury service. These requests similarly call for information barred by Rule 606(b). And the overbreadth of this information is evidenced by the impracticality of production: Even in criminal investigations, the Government cannot obtain such communications with a subpoena; the Government must obtain a search warrant upon a showing of probable cause. See Stored Communications Act, 18 U.S.C. § 2703. In response to such warrants, social media platforms provide the entirety of the electronic communications within the account for the relevant timeframe—often a high volume of material—and the Government reviews the warrant returns to determine what specific materials are responsive. Thus, if the subpoena the defendant requests were issued, the defendant would likely obtain a high volume of Juror 50's irrelevant personal social media communications. A convicted defendant cannot be permitted to invade the privacy of a juror in this manner. Finally, Request 2(c) seeks documentation of the dates on which Juror 50 opened and closed his social media accounts, but as discussed above, the defendant has failed to establish that a hearing is warranted as to Juror 50's statements about his use of social media, so there is no basis to compel the production of such irrelevant information.
+
+# III. The Court Should Provide Juror 50 with a Copy of His Questionnaire Before Any Hearing
+
+On January 10, 2022, counsel for Juror 50 filed a motion to intervene and a supporting memorandum of law in the case in order to "protect [Juror 50's] privacy rights and his right to avoid self-incrimination, and to further ensure that he will not be prejudiced by any investigation ordered by this Court." (Juror 50 Mem. at 4). Counsel for Juror 50 requested that he be permitted to intervene, in part, to "assist this Court in determining how to conduct an appropriate inquiry
+
+into the subject, by allowing [him] an opportunity to fully and fairly brief the Court on the relevant issues." (Id. at 7).
+
+In his motion, Juror 50's counsel requested a copy of Juror 50's questionnaire, as well as the transcript of his testimony during voir dire. (Juror 50 Mem. at 4). The defendant opposes Juror 50's request, describing it as a "discovery request" and claiming that the release of Juror 50's questionnaire would prejudice the "investigation" of Juror 50's "conduct" and "undoubtably color Juror No. 50's testimony and allow him to place himself in the best possible posture." (Def. Mem. at 52-53). As an initial matter, the Government notes that Juror 50's voir dire was conducted in open court and is therefore available to Juror 50 and his counsel. As to the request for his questionnaire, the Government submits that Juror 50 should get a copy of his own questionnaire.
+
+The defendant has characterized Juror 50's request for his own questionnaire as a "discovery request," but Juror 50 is not a defendant and he is not seeking discovery." He is asking for access to his questionnaire: a document that he himself prepared and swore under penalty of perjury, and which, now that trial is complete, is maintained under seal principally if not entirely to protect his own privacy interests. See, e.g., Press-Enter. Co. v. Superior CL of California, Riverside Cty., 464 U.S. 501, 511-12 (1984). The privacy concerns that otherwise might require limiting access to Juror 50's questionnaire plainly do not apply to Juror 50 himself or his counsel.19
+
+IS The defendant claims that courts have "refused discovery to individuals or entities under investigation" "[u]nder analogous circumstances." (Def. Mem. at 53). But in support of that argument, the defendant cites only John Doe Agency v. John Doe Corp., 493 U.S. 146 (1989), which is clearly not analogous as it involved a request under the Freedom of Information Act and an ongoing grand jury proceeding.
+
+19 On January 24, 2022, the New York Times Company moved to unseal, among other things, the filled-out questionnaires for the twelve seated jurors. (Dkt. No. 583). The Government intends to address that motion on or before February II, 2022 in accordance with the Court's January 26, 2022 order (Dkt. No. 585).
+
+Moreover, there can be no real concern, as the defendant claims, that providing Juror 50 with his questionnaire will "color" Juror 50's testimony and interfere with the integrity of a hearing. (Def. Mem. at 53). Should the Court decide to conduct a limited hearing, as the Government has proposed, the Court will undoubtedly ask Juror 50 about his questionnaire. Juror 50 should have access to his own questionnaire in advance of any such hearing so that he can speak with his counsel and assess whether he plans to invoke his rights under the Fifth Amendment. More broadly speaking, "[t]he object of the proceeding is to permit the truth to be discovered with the least possible harm to other interests." Gagnon, 282 F. App'x at 40. That endeavor is not furthered by surprising Juror 50 on the stand with a document he does not seem to recall with specificity. See Juror 50 Mem. at 4 (stating that Juror 50 "does not recall answering questions [in the questionnaire] regarding his prior experience with sexual assault"). To deny Juror 50 access to his own document means, practically speaking, that after being shown the questionnaire and asked questions about the document at a hearing. Juror 50 will need to speak with his counsel, assuredly delaying the hearing.
+
+To the extent Juror 50's motion seeks leave to submit briefing on the merits of this inquiry, the Government agrees with the defendant that Juror 50 need not be permitted to intervene or be heard on the scope of the Court's inquiry, at least not at this juncture. The parties are well situated to brief the appropriate scope of any hearing without intervention from the witness at that hearing. However, if the Court does authorize the subpoenas compelling production of Juror 50's communications and other information—though it should not, for the reasons set forth above— Juror 50 should have an opportunity to move to quash those subpoenas. See, e.g., City of Almaty, Kazakhstan v. Ablyazov, No. 1:15 Civ. 05345 (AJN) (KHP), 2020 WL 1130670, at \*I (S.D.N.Y.
+
+Mar. 9, 2020); Strike 3 Holdings, LLC v. Doe, 19 Civ. 2552 (LAK) (OTW), 2019 WL 4855039, at \*2 (S.D.N.Y. Oct. 2, 2019).
+
+Finally, the defendant requests that that the Court strike Juror 50's motion to intervene and the supporting memorandum of law or, alternatively, permit his filings to remain under seal pending resolution of the Defense Motion. (Def. Mem. at 53-56). The cases cited by the defendant in support of its motion to strike are inapposite,20 and in any event Juror 50's motion, whether or not ultimately granted, is hardly "redundant, immaterial, impertinent or scandalous." The defendant further claims that the pleadings are not "judicial documents" at the current stage of the proceedings as they have not been ruled upon by the Court and, therefore, "are afforded no presumption of public access." (Id. at 54, 56). She is wrong. Juror 50's motion to intervene is quite obviously "relevant to the performance of a judicial function and useful in the judicial process." United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995); see also S.E.C. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001) (noting that a "document which is presented to
+
+20 The defendant cites United States v. All Right, Title & Int. in Prop., Appurtenances, & Improvements Known as 479 Tamarind Drive, Hallendale, Fla., No. 98 Civ. 2279 (DLC), 2011 WL 1045095, at \*2 (S.D.N.Y. Mar. 11, 2011), a civil forfeiture action in which the Government filed a motion to strike, which is explicitly governed by Rule G of the Supplemental Rules for Certain Admiralty and Maritime Claims and Asset Forfeiture Actions. The defendant also cites civil cases involving discussions of Federal Rule of Civil Procedure 12(0 under which "[a] court may strike from a pleading ... any redundant, immaterial, impertinent, or scandalous matter." The defendant ignores that even in that context, "motions to strike are disfavored and should not be granted 'unless there is a strong reason for so doing.'" v. Pataki, No. 08 Civ. 8563 (JSR), 2010 WL 234995, at \*3 (S.D.N.Y. Jan. 19, 2010) (citation omitted); see also Velez v. Lisi, 164 F.R.D. 165, 166 (S.D.N.Y. 1995) ("A motion to strike is an extraordinary remedy which will not be granted unless it is clear that the allegations in question can have no possible bearing on the subject matter of the litigation."). Metzger v. Hussman, 682 F. Supp. 1109, 1110 (D. Nev. 1988), which the defendant cites (Def. Mem. at 54), is also inapposite. Metzger is a civil case in which the court granted a motion to strike an opposition to a motion to dismiss that was filed in an untimely manner because "[a]pplicable rules of procedure .. . must be enforced in this case, as in any case, so that the Court may maintain control over the progress of litigation before it." Metzger, 682 F. Supp. at 1111.
+
+the court to invoke its powers or affect its decisions" stands on a "different footing" than items merely passed between parties in discovery (quotations omitted)). The defendant's challenge to the merits of Juror 50's motion to intervene ignores that the motion is a judicial document whether or not the Court ultimately grants the motion. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006) (rejecting the argument that "until a district court knows the disposition of the underlying motion, any attempt at calling something a judicial document is premature"). And the defendant's assertion that the motion is not a judicial document because it is a "discovery request" is supported only by cases addressing whether discovery materials themselves should be docketed, not whether a motion for discovery can be. (See Def. Mem. at 54).
+
+At bottom, the defendant fails to credibly explain how publicly docketing Juror 50's own motion to intervene will interfere with Juror 50's own testimony. There is no need to litigate Juror 50's motion to intervene under seal just because the Court and the parties are contemplating a hearing where Juror 50 may be a witness. Throughout the course of this case, the parties have publicly litigated evidentiary issues implicating witness testimony, such that witnesses or their counsel could access the briefing if they so wished. There is no reason that Juror 50's motion to intervene should be treated differently and litigated in secret.2'
+
+21 Contrary to the defendant's suggestion (Def. Mem. at 42 n.15), there is nothing nefarious about the Government's decision to publicly docket the letter in which it brought Juror 50's public statements to the Court's attention and sought an inquiry. That letter is clearly a judicial document, and as such must be publicly filed unless there are compelling interests for sealing, such as thirdparty privacy interests and identifying information for witnesses testifying under pseudonyms. None of those interests were implicated by this short letter, which merely recites public information and sought certain relief. And contrary to the defendant's representation, the Government sought to confer with the defense counsel before filing the letter, but received no response, as the letter notes. (Dkt. 568 at 2).
+
+#### CONCLUSION
+
+For the foregoing reasons, the Court should deny the defendant's motion for a new trial on the present record and schedule a hearing to resolve the motion.
+
+Dated: New York, New York February 2, 2022
+
+Respectfully submitted,
+
+DAMIAN United States Attorney
+
+By: s/ Maurene Comey Alison Moe Lam Pomerantz Andrew Rohrbach Assistant United States Attorneys
\ No newline at end of file
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diff --git a/marker2/court-us-v-maxwell-cr/EFTA02837708/EFTA02837708.md b/marker2/court-us-v-maxwell-cr/EFTA02837708/EFTA02837708.md
new file mode 100644
index 0000000000000000000000000000000000000000..018100009abb61ae1c88d31050aa74dd7788141b
--- /dev/null
+++ b/marker2/court-us-v-maxwell-cr/EFTA02837708/EFTA02837708.md
@@ -0,0 +1,2650 @@
+# EXHIBIT 3
+
+# 13-1388-cr
+
+IN THE
+
+## United States Court of Appeals FOR THE SECOND CIRCUIT
+
+UNITED STATES OF AMERICA,
+
+—against—
+
+*Appellee,*
+
+PAUL M. DAUGERDAS, ERWIN MAYER, DONNA GUERIN, DENIS FIELD,
+ROBERT GREISMAN, RAYMOND CRAIG BRUBAKER, BDO USA, LLP,
+
+*Defendants,*
+
+DAVID PARSE,
+
+*Defendant-Appellant.*
+
+ON APPEAL FROM THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+### APPENDIX VOLUME XVI OF XVII (Pages A-5633 to A-6085)
+
+UNITED STATES ATTORNEY'S
+OFFICE FOR THE SOUTHERN
+DISTRICT OF NEW YORK
+One St. Andrew's Plaza
+New York, New York 10007
+(212) 637-2346
+
+UNITED STATES DEPARTMENT
+OF JUSTICE
+TAX DIVISION, APPELLATE SECTION
+P.O. Box 502
+Washington, DC 20044
+(202) 514-8030
+
+*Attorneys for Appellee*
+*United States of America*
+
+SHAPIRO, ARATO & ISSERLES LLP
+500 Fifth Avenue, 40th Floor
+New York, New York 10110
+(212) 257-4880
+
+*Attorneys for Defendant-Appellant*
+*David Parse*
+
+# TABLE OF CONTENTS
+
+| | PAGE |
+|-------------------------------------------------|-------|
+| Docket Entries | A- I |
+| Indictment—Redacted S3 | A-84 |
+| November 2, 2010, attaching bill of particulars | A-157 |
+| Transcript—Conference, December 8, 2010 | A-166 |
+| Transcript—Conference, February 9, 2011 | A-I82 |
+| Transcript—Conference, February 28, 2011 | A-207 |
+| Transcript—Jury Selection, Day 1, March 1, 2011 | A-222 |
+| Transcript—Jury Selection, Day 2, March 2, 2011 | A-290 |
+| Transcript—Jury Selection, Day 3, March 3, 2011 | A-338 |
+| Transcript—Trial, Day 1, March 3, 2011 | A-345 |
+| Transcript—Trial, Day 2, March 4, 2011 | A-378 |
+| Transcript—Trial, Day 3, March 7, 2011 | A-404 |
+| Transcript—Trial, Day 4, March 8, 2011 | A-462 |
+| Transcript—Trial, Day 5, March 9, 2011 | A-525 |
+| Transcript—Trial, Day 6, March 10, 2011 | A-587 |
+| Transcript—Trial, Day 7, March 11, 2011 | A-642 |
+| Transcript—Trial, Day 8, March 14, 2011 | A-677 |
+
+| ii | PAGE |
+|-------------------------------------------|--------|
+| Transcript—Trial, Day 9, March 15, 2011 | A-730 |
+| Transcript—Trial, Day 10, March 16, 201 1 | A-788 |
+| Transcript—Trial, Day 11, March 17, 201 1 | A-851 |
+| Transcript—Trial, Day 12, March 18, 201 1 | A-913 |
+| Transcript—Trial, Day 13, March 21, 201 1 | A-949 |
+| Transcript—Trial, Day 14, March 23, 201 1 | A-958 |
+| Transcript—Trial, Day 15, March 24, 2011 | A-1020 |
+| Transcript—Trial, Day 16, March 25, 2011 | A-1089 |
+| Transcript—Trial, Day 17, March 28, 201 1 | A-1139 |
+| Transcript—Trial, Day 18, March 29, 201 1 | A-1204 |
+| Transcript—Trial, Day 19, March 31, 201 1 | A-1274 |
+| Transcript—Trial, Day 20, April 1, 2011 | A-1342 |
+| Transcript—Trial, Day 21, April 4, 2011 | A-1383 |
+| Transcript—Trial, Day 22, April 5, 2011 | A-1449 |
+| Transcript—Trial, Day 23, April 11, 2011 | A-I514 |
+| Transcript—Trial, Day 24, April 12, 2011 | A-1580 |
+| Transcript—Trial, Day 25, April 13, 2011 | A-1645 |
+| Transcript—Trial, Day 26, April 14, 2011 | A-1724 |
+| Transcript—Trial, Day 27, April 15, 2011 | A-1786 |
+
+# iii
+
+| | PAGE |
+|------------------------------------------|--------|
+| Transcript—Trial, Day 28, April 26, 2011 | A-1826 |
+| Transcript—Trial, Day 29, April 27, 2011 | A-1897 |
+| Transcript—Trial, Day 30, April 28, 2011 | A-1962 |
+| Transcript—Trial, Day 31, April 29, 2011 | A-2022 |
+| Transcript—Trial, Day 32, May 2, 2011 | A-2060 |
+| Transcript—Trial, Day 33, May 3, 2011 | A-2128 |
+| Transcript—Trial, Day 34, May 4, 2011 | A-2200 |
+| Transcript—Trial, Day 35, May 5, 2011 | A-2288 |
+| Transcript—Trial, Day 36, May 6, 2011 | A-2356 |
+| Transcript—Trial, Day 37, May 9, 2011 | A-2389 |
+| Transcript—Trial, Day 38, May 10, 2011 | A-2445 |
+| Transcript—Trial, Day 39, May 11, 2011 | A-2499 |
+| Transcript—Trial, Day 40, May 12, 2011 | A-2566 |
+| Transcript—Trial, Day 41, May 13, 2011 | A-2594 |
+| Transcript—Trial, Day 42, May 16, 2011 | A-2598 |
+| Transcript—Trial, Day 43, May 17, 2011 | A-2610 |
+| Transcript—Trial, Day 44, May 18, 2011 | A-2616 |
+| Transcript—Trial, Day 45, May 19, 2011 | A-2625 |
+| Transcript—Trial, Day 46, May 20, 2011 | A-2632 |
+
+# iv
+
+| | PAGE |
+|----------------------------------------------------------------|--------|
+| Transcript—Trial, Day 47, May 23, 2011 | A-2637 |
+| Transcript—Trial, Day 48, May 25, 2011 | A-2644 |
+| Requests To Charge Of The United States, May 2, 2011 | A-2652 |
+| Letter from Stanley J. Okula, Jr. to Judge Pauley, May 3, 2011 | A-2734 |
+| Letter from Laurie Edelstein to Judge Pauley, May 4, 2011 | A-2742 |
+| Letter from Laurie Edelstein to Judge Pauley, May 5, 2011 | A-2746 |
+| jury charge | A-2814 |
+| Letter from Laurie Edelstein to Judge Pauley, May 8, 2011 | A-2882 |
+| Court Exhibit 3—Note from Catherine Conrad, May 10, 2011 | A-2955 |
+| To Rule 29, June 7, 2011 | A-3021 |
+
+# Government's Trial Exhibits
+
+| GX12-60 Deutsche Bank Alex. | Confirmation A-3027 |
+|----------------------------------------|-------------------------|
+| August 29, 2002 | A-3035 |
+| GX24-16 Deutsche Bank Alex. | Client Statement A-3076 |
+| December 24, 2001 | A-3083 |
+| December 28, 2001 | A-3085 |
+| GX37-4 Documents Relating To C.R. Gibb | A-3360 |
+
+GX43-1 Letter from Paul M. Daugerdas to Michael Hammer, August 28, 2002 A-3486
+
+GX54-1 Letter from Donna Guerin to David K. Parse, January 24, 2001 A-3594
+
+GX73-5 Documents Relating To Oxford Bloomfield Investors, Inc. A-3875
+
+GX82-2a Letter from Donna Guerin to Michael Toporek, February 18, 2002 A-3984
+
+GX82-20 Deutsche Bank Alex. Client Statement A-4149
+
+GX82-21 Deutsche Bank Alex. Client Statement A-4159
+
+GX201-3a Letter from Michael Toporek to David Parse, December 28, 2001 A-4168
+
+GX201-39a Letter from Michael Toporek to David Parse, December 28, 2001 A-4325
+
+GX201-253 Fax from John Beery to Michael Hammer, December 4, 2001 A-4327
+
+GX300-28a Email from Robert Greisman to Charles Bee and others, November 6, 2001 A-4446
+
+GX300-40 Email from Lisa Hurley to Nicole Bencik, February 26, 2001 A-4449
+
+GX400-23 Email from Carrie Yackee to Sheila D. Denzler, April 4, 2002 A-4450
+
+GX400-24 Email from Carrie Yackee to Sheila D. Denzler, February 9, 2001 A-4457
+
+GX400-29 Email from Carrie Yackee to Heather Loeser, February 11, 2002 A-4461
+
+GX400-43 Email from Carrie Yackee to Dawn Forbes, December 21, 1999 A-4463 vi
+
+PAGE
+
+GX400-50 Email from Carrie Yackee to Sheila D. Denzler, February 11, 2002 A-4464
+
+GX400-195 Email from R. Craig Brubaker to Todd Clendening, November 15, 2000 A-4473
+
+GX400-260 Email from R. Craig Brubaker to emayer@jenkens.com, October 18, 1999 A-4475
+
+GX401-9 Deutsche Bank Alex. Client Statement A-4492
+
+GX401-10 Fax from Carrie Yackee to Judy Gagnon, April 25, 2002 A-4496
+
+GX401-44 Letter from Matt Coleman to David Parse A-4499
+
+GX401-47a Letter from Daniel Aronoff to David Parse, December 19, 2000 A-4500
+
+GX401-48 Deutsche Bank Alex. Client Statement A-4503
+
+GX401-74 Deutsche Bank Alex. Client Statement A-4508
+
+GX401-97 Fax from Carrie Yackee to Nicole Bencik, March 13, 2001 A-4513
+
+GX401-98 Letter from Daniel Aronoff to David Parse, December 19, 2000 A-4544
+
+GX401-99 Letter from Daniel Aronoff to David Parse, December 19, 2000 A-4545
+
+GX401-100 Letter from Daniel Aronoff to David Parse, December 19, 2000 A-4546
+
+GX401-101 Change Form A-4547
+
+GX700-19 Fax from Judi Gagnon to John Beary, April 29, 2002 A-4549
+
+GX1000-52 IRS Certificate Of Official Record, March 11, 2009 A-4565
+
+GX1001-209 Fax from John V. Ivsan to John Beery, April 6, 2001 A-4756 vii
+
+PAGE
+
+GX1002-64 Fax from Lisa Hurley to James D. Beumel, May 16, 2003 A-4777
+
+GX1002-122 Letter from Lisa Hurley to James D. Beumel, March 3, 2003 A-4810
+
+GX1002-124 IRS Form 4564 for Larry H. and Nancy C. Moore . A-4816
+
+# Defendants' Trial Exhibits
+
+DX2I69 Letter from Erwin Mayer to R. Craig Brubaker, December 16, 1998 A-4852
+
+DX2635a Letter from Erwin Mayer to Bob Price, December 17, 1998 A-4886
+
+DX2667 Email from r.craig.brubaker@db.com to emayer@jenkens.com, November 5, 1999 A-4887
+
+DX2703 Memorandum from Michael L. and Bryan W. Lee to Board of Directors, Roger Hayse, November 16, 2000 A-4891
+
+DX3278 Confidential J&G Notes A-4892
+
+DX3396 Email from R. Craig Brubaker to Crawford, October 27, 1999 A-4894
+
+DX5577 Change Form A-4913
+
+Letter from Stanley J. Okula, Jr. to Judge Pauley, June 22, 2011 A-4936
+
+Memorandum Of Law In Support Of Defendants' Motion For A New Trial Or, In The Alternative, For An Evidentiary Hearing Concerning Juror No. 1, July 8, 2011 A-4941
+
+Declaration Of Theresa Trzaskoma In Support Of Defendants' Motion For A New Trial Or, In The Alternative, For An Evidentiary Hearing, Concerning Juror No. 1, redacted version, July 8, 2011 . A-4979
+
+Exhibit 1 to Trzaskoma Declaration— Page 6 from the Jury Department's Panel Selection Report A-4984
+
+| Exhibit 2 to Trzaskoma Declaration— | |
+|---------------------------------------------------------------------------------------|---------------|
+| Juror Questionnaire Exhibit 3 to Trzaskoma Declaration— | A-4986 |
+| May 25, 2011 Exhibit 4 to Trzaskoma Declaration— | A-4989 |
+| as of June 24, 2011 Exhibit 5 to Trzaskoma Declaration— | A-4994 |
+| In the Matter of Catherine M. Conrad, | 48 A.D.3d 187 |
+| (1st Dep't Dec. 18, 2007) Exhibit 6 to Trzaskoma Declaration— | A-4996 |
+| In the Matter of Catherine M. Conrad, | 80 A.D.3d 187 |
+| (1st Dep't Dec. 9, 2010) Exhibit 7 to Trzaskoma Declaration— | A-4999 |
+| Deed for 16 Parkview Drive, Eastchester, New York Exhibit 8 to Trzaskoma Declaration— | A-5003 |
+| Bronxville, New York Exhibit 9 to Trzaskoma Declaration— | A-5006 |
+| Nevada Marria e License for | Rosa and |
+| Catherine Conrad, June 20, 2007 Exhibit 10 to Trzaskoma Declaration— | A-5021 |
+| Nevada Marria e Certificate for | Rosa and |
+| Catherine Conrad, June 20, 2007 Exhibit 11 to Trzaskoma Declaration— | A-5023 |
+| Catherine Conrad Exhibit 12 to Trzaskoma Declaration— | A-5026 |
+| City of New York, County of Bronx, People v. | Catherine |
+| Conrad, August 21, 1998 | A-5031 |
+
+Exhibit 13 to Trzaskoma Declaration—
+Certificate of Disposition from the Criminal Court of the City of
+New York, County of Bronx, *People v. Catherine Conrad*,
+May 17, 1998. .... A-5033
+
+Exhibit 14 to Trzaskoma Declaration—
+Winslow, Arizona Police Department records for
+Catherine Conrad ..... A-5035
+
+Exhibit 15 to Trzaskoma Declaration—
+Records from the Criminal Court of the City of Yonkers related
+to May 6, 2009 arrest of Catherine Rosa, Docket No. 09-2763.... A-5057
+
+Exhibit 16 to Trzaskoma Declaration—
+Records from the Criminal Court of the City of New Rochelle for
+the May 6, 2009 arrest of Catherine Rosa ..... A-5061
+
+Exhibit 17 to Trzaskoma Declaration—
+Records from New Jersey and Westlaw relating to [REDACTED] Rosa ... A-5076
+
+Exhibit 18 to Trzaskoma Declaration—
+State of New Jersey Department of Corrections information sheet
+for [REDACTED] J. Rosa ..... A-5124
+
+Exhibit 19 to Trzaskoma Declaration—
+Criminal records from Nassau County, New York for [REDACTED] Rosa A-5127
+
+Exhibit 20 to Trzaskoma Declaration—
+Summons and Verified Complaint, *Conrad v. Manessis, et al.*,
+Index No. 27056-03 (N.Y. Sup. Ct., Bronx County),
+November 10, 2003 ..... A-5183
+
+Exhibit 21 to Trzaskoma Declaration—
+Note of Issue, *Conrad v. Manessis*, March 7, 2009. .... A-5192
+
+Exhibit 22 to Trzaskoma Declaration—
+Order with Notice Of Entry, *Conrad v. Manessis*,
+December 5, 2008 ..... A-5198
+
+Exhibit 23 to Trzaskoma Declaration—
+Affidavit of Catherine Conrad, *Conrad v. Manessis*,
+January 19, 2009 ..... A-5205
+
+Exhibit 24 to Trzaskoma Declaration—
+
+Order, Conrad v. Manessis, February 5, 2009 A-5212
+
+Exhibit 25 to Trzaskoma Declaration—
+
+Affirmation of Victor M. Serby in Opposition to Defendants'
+
+Motion to Dismiss the Complaint, Conrad v. Manessis,
+
+June 4, 2010 A-5215
+
+Exhibit 26 to Trzaskoma Declaration—
+
+Judgment, Verdict Sheet and Exhibit List, Conrad v. Manessis A-5257
+
+Exhibit 27 to Trzaskoma Declaration—
+
+Excerpts of the trial testimony of Catherine Conrad,
+
+Conrad v. Manessis A-5267
+
+Exhibit 28 to Trzaskoma Declaration—
+
+Order, Conrad v. Manessis, March 24, 2011 A-5315
+
+Exhibit 29 to Trzaskoma Declaration—
+
+Federal Election Commission contribution records for
+
+Robert J. Conrad at 16 Parkview Drive, Bronxville, NY 10708... A-5392
+
+Transcript—Conference regarding motion for new trial (unsealed),
+
+July 15, 2011 A-5399
+
+Letter from Susan E. Brune to Judge Pauley, July 21, 2011
+
+attaching Westlaw Report A-5416
+
+Affidavit of Paul H. Schoeman, Esq., dated August 17, 2011 A-5438
+
+Affidavit of Susan E. Brune, dated September 15, 2011 A-5441
+
+Exhibit A to Brune Affidavit—
+
+Juror Questionnaire A-5446
+
+Exhibit B to Brune Affidavit—
+
+Email from Randy to Viviann Stapp, February 25, 2011 A-5449
+
+Exhibit C to Brune Affidavit—
+
+Juror Snapshot A-5451
+
+Exhibit D to Brune Affidavit— Email from Viviann Stapp to Randy M, March 1, 2011 A-5466
+
+Exhibit E to Brune Affidavit— Jury Selection Materials A-5475
+
+Exhibit F to Brune Affidavit— Jury Selection Materials A-5479
+
+Exhibit G to Brune Affidavit— Jury Selection Materials A-5481
+
+Exhibit H to Brune Affidavit— Jury Selection Materials A-5489
+
+Exhibit Ito Brune Affidavit— Email from Suann Ingle to Kendra Melrose, May 11, 2011 A-5494
+
+Exhibit I to Brune Affidavit— Internal Brune & Richard emails A-5496
+
+Exhibit K to Brune Affidavit— Memorandum from DB to Parse File, May 17, 2011 A-5559
+
+# Supplemental Memorandum Of Law Of United States In Opposition To Defendants' Motion For A New Trial Pursuant To Rule 33 Of The Federal Rules Of Criminal Procedure, October 7, 2011 A-5563
+
+Exhibit 1— Affidavit of Daniel Nardello, September 28, 2011 A-5593
+
+Transcript—Telephone Conference, August 8, 2011 A-5595
+
+Transcript—New Trial Hearing, Day 1, February 15, 2012 A-5608
+
+Transcript—New Trial Hearing, Day 2, February 16, 2012 A-5699
+
+Hearing Exhibit 20—/n re Conrad, 80 A.D.3d 168 (1st Dep't 2010) A-5840
+
+Declaration of Steven Gillers, April 6, 2012 A-5843
+
+| Exhibit A to Gillers Declaration— | |
+|---------------------------------------------------------------------------|----------|
+| Curriculum Vitae of Stephen Gillers | A-5852 |
+| Affidavit of David Parse, August 3, 2012 | A-5872 |
+| Transcript—Oral Argument, October 12, 2012 | A-5903 |
+| Letter from Paul Shechtman to Judge Pauley, March 7, 2013 March 15, 2013— | A-5930 |
+| Jenkens and Gilchrist Clients—Restitution Calculation | A-6041 |
+| Defendant David Parse, March 18, 2013 | A-6074 |
+| Letter from Paul Schechtman to Judge Pauley, March 18, 2013 | A-6 I 15 |
+| March 20, 2013 | A-6125 |
+| Transcript—Sentencing of David Parse, March 22, 2013 | A-6134 |
+| Letter from Paul Schechtman to Judge Pauley, March 22, 2013 | A-6161 |
+| Notice Of Appeal, March 29, 2013 | A-6163 |
+| Judgment, April 12, 2013 | A-6168 |
+
+| C21rdau3 | Trzaskoma - redirect | Page 93 | C21rdau3 | Trzaskoma - redirect | Page 95 |
+|----------|-----------------------------------------------------------------|---------|----------|-----------------------------------------------------------------|---------|
+| 1 | A. No. I actually thought that the more likely explanation | | 1 | together. And we were benefited greatly by the fact that Ms. | |
+| 2 | was that the Westlaw report was conflating two people, two | | 2 | Conrad had included her phone number at the top of her letter | |
+| 3 | people named Catherine Conrad, one who was our juror and one | | 3 | to Mr. Okula. | |
+| 4 | who was the suspended lawyer. | | 4 | Q. You are conflating two issues. My question is about the | |
+| 5 | Q. During your conversation with Ms. Edelstein and Ms. Brune | | 5 | civil lawsuit. You had a chance to review those documents | |
+| 6 | or at any point afterwards, did anyone discourage you from | | 6 | after the trial, right? | |
+| 7 | pursuing any additional information about Catherine Conrad or | | 7 | A. I did. | |
+| 8 | the Westlaw report that had been sent to you? | | 8 | Q. You know that in Ms. Conrad's testimony in that suit she | |
+| 9 | A. No. I believe, as I told you earlier, at the conclusion of | | 9 | says she has a law degree, right? | |
+| 10 | my discussion with Ms. Edelstein and Ms. Brune I said something | | 10 | A. I did. But it took me days to pull all that together and | |
+| 11 | along the lines of, do we need to do anything further, and Ms. | | 11 | to find that in the files. | |
+| 12 | Brune said, no, just leave it. Based on that, I called Mr. | | 12 | Q. Weren't there several days between May 12th and the jury | |
+| 13 | Benhamou. | | 13 | verdict? | |
+| 14 | I went to my children's school to pick them up for the | | 14 | A. Yes. | |
+| 15 | first time in many months, maybe years, and on my way to pick | | 15 | Q. With respect to the motion that you filed, did you make a | |
+| 16 | them up at school, my recollection is I called Mr. Benhamou to | | 16 | conscious decision not to disclose the information that you had | |
+| 17 | ask him whether he had gotten the lawsuit. He said that he | | 17 | in your possession during the trial in your motion? | |
+| 18 | hadn't, that they couldn't find it online, and if we wanted to | | 18 | A. No, it was not, in my mind. | |
+| 19 | get it, our managing clerk would have to go to the Bronx in the | | 19 | MR. [REDACTED]: May I have a moment, your Honor? | |
+| 20 | morning. I said, we don't think it is her, so you can stand | | 20 | THE COURT: Yes. Take your time. | |
+| 21 | down. | | 21 | MR. [REDACTED]: No further questions, your Honor. | |
+| 22 | Q. Did at any point anyone suggest that you not send any | | 22 | THE COURT: Go ahead, Mr. Shechtman. | |
+| 23 | emails about Conrad any further? | | 23 | RECROSS-EXAMINATION | |
+| 24 | A. No. | | 24 | BY MR. SHECHTMAN: | |
+| 25 | Q. You said that you weren't aware of any other juror | | 25 | Q. Ms. Trzaskoma, at any time were you trying to sandbag the | |
+| C21rdau3 | Trzaskoma - redirect | Page 94 | C21rdau3 | Trzaskoma - recross | Page 96 |
+| 1 | misconduct case where the lies of this magnitude were involved. | | 1 | Court or plant error in the record as to Juror No. 1, Ms. | |
+| 2 | Do you remember that testimony? | | 2 | Conrad? | |
+| 3 | A. I do. | | 3 | A. Absolutely not. | |
+| 4 | Q. Do you recall on direct you testified that in your mind on | | 4 | MR. SHECHTMAN: No further questions. | |
+| 5 | May 12th there were two possibilities: There was either the | | 5 | THE COURT: Ms. Trzaskoma, I have a question for you. | |
+| 6 | possibility that Conrad had lied during voir dire or the | | 6 | On the third day of jury deliberations, May 16th, this Court | |
+| 7 | information you had was for the wrong person? | | 7 | was confronted with a juror who needed to have an emergency | |
+| 8 | A. Yes. | | 8 | medical procedure. After conferring with all counsel and over | |
+| 9 | Q. Is it fair to say that in your mind on May 12th they were | | 9 | the government's objection, I excused Juror No. 11, replaced | |
+| 10 | not just lies that you were contemplating but in your mind | | 10 | Juror No. 11 with an alternate, and instructed the jury to | |
+| 11 | unprecedented lies as one possibility? | | 11 | restart anew their jury deliberations. During that entire | |
+| 12 | A. I think that what I understood Mr. Shechtman to be asking | | 12 | episode did you ever revisit the question of Juror No. 1 and | |
+| 13 | me was about the totality of Ms. Conrad's lies. I can tell you | | 13 | the possibility that she might be someone other than who she | |
+| 14 | that on May 12th I certainly did not contemplate that Ms. | | 14 | said she was in voir dire? | |
+| 15 | Conrad was not only a suspended lawyer but was on criminal | | 15 | THE WITNESS: I did not. I genuinely believed that | |
+| 16 | probation, had been arrested numerous times, had a bench | | 16 | Juror No. 1 was who she said she was. | |
+| 17 | warrant for her arrest, was a severe alcoholic, and was married | | 17 | THE COURT: Any further inquiry based upon the Court's | |
+| 18 | to a man who himself had served 7 years in a New Jersey state | | 18 | inquiry? | |
+| 19 | prison. That never entered my head. | | 19 | MR. [REDACTED]: No, your Honor. | |
+| 20 | Q. Those facts that you had you didn't have during the trial, | | 20 | MR. SKLARSKY: No, your Honor. | |
+| 21 | right? | | 21 | MR. SHECHTMAN: No, your Honor. | |
+| 22 | A. We did not. | | 22 | MR. ROTERT: No, your Honor. | |
+| 23 | Q. If you had researched Ms. Conrad's civil lawsuit, you might | | 23 | MS. McCARTHY: No, your Honor. | |
+| 24 | have learned about them during the trial, right? | | 24 | THE COURT: Ms. Trzaskoma, you are excused as a | |
+| 25 | A. It's possible, but it took us a long time to put things | | 25 | witness. You may step down. | |
+
+### UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL.,
+
+| | C2Irdau3 Page 97 | C2Irektu3 Page 99 |
+|----|-----------------------------------------------------------------|-------------------|
+| 1 | (Witness excused) | 1 |
+| 2 | THE COURT: Before the defendants call Juror No. I, | 2 |
+| 3 | have before me an application on behalf of Juror No. I | 3 |
+| 4 | concerning closure of the courtroom. I have reviewed the | 4 |
+| 5 | letter submissions of the parties. Ms. Sternheim, do you wish | 5 |
+| 6 | to be heard further on that application? | 6 |
+| 7 | MS. STERNHEIM: Very brief briefly, your Honor. | 7 |
+| a | THE COURT: Please. Take the podium. | |
+| 9 | MS. STERNHEIM: I am aware that aspects of Ms. | 9 |
+| 10 | Conrad's alcohol dependence are in the record. as we have heard | to |
+| 11 | today. However. I maintain that she does have the right to | ix |
+| 12 | confidentiality regarding her condition and any treatment she | 12 |
+| 13 | may have received. I do not suggest that it should not be an | 13 |
+| 14 | arca of inquiry, but I don't believe that it needs to be an | 14 |
+| 15 | arca disclosed publicly. The record can be created so that all | 15 |
+| 16 | the parties of interest in this matter have the facts that they | 16 |
+| 17 | need to make their respective arguments. | 17 |
+| 18 | The other past of my letter, which I don't have with | 1a |
+| 19 | me for the moment. concerns aspects -- does the Court have the | 19 |
+| 20 | letter there? May I see it? Or does any counsel have a copy? | 20 |
+| 21 | THE COURT: I've got it. | 21 |
+| 22 | MS. STERNHEIM: Thank you. | 22 |
+| 23 | THE COURT: These letters will he docketed and tiled | 23 |
+| 24 | if they haven't already been. | 24 |
+| 25 | MS. STERNHEIM: The 'the, aarc4 IS nit HIPA A .ancern, | 25 |
+
+| | C2frdau3 Page 96 | | |
+|----|-----------------------------------------------------------------|----|----------------------------------------------------------------|
+| 1 | regarding her personal medical conditions. | | |
+| 2 | With regard to inquiry concerning the disciplinary | | |
+| 3 | committee, my request is based on the fact that disciplinary | | |
+| 4 | proceedings. at least in the First Department, arc not public | | |
+| 5 | proceedings, and it is my understanding that sealed records | | |
+| 6 | were unsealed for the purpose of this matter. However. again. | | |
+| 7 | that I believe was so that the parties would have opportunity | | |
+| 8 | to make their record here. I still maintain because it is a | | |
+| 9 | pending matter in the First Department, it should not be opened | | |
+| 10 | to the public. | | |
+| 11 | Once again, I AM not stating in any way that counsel | | |
+| 12 | for either party should not be permitted to inquire. I | | |
+| 13 | understand the relevance of it. However, again. I do not | | |
+| 14 | believe that the inquiry into a matter which in and of itself | | |
+| 15 | was a closed proceeding. although revealed for purposes of | | |
+| 16 | this, and still pending should be a matter dealt with in open | | |
+| 17 | court. | | |
+| 18 | So. my request again is should counsel wish to inquire | | |
+| 19 | into the underlying aspects of an alcohol dependency and the | | |
+| 20 | disciplinary committee and the proceedings. that that be a | | |
+| 21 | matter that is not for public consideration. | | |
+| 22 | THE COURT: Thank you. Ms. Sternheim. Is mere any | | |
+| 23 | other matter that you want to bring to the Court's attention | | |
+| 24 | before the witness is called? | | |
+| 25 | MS. STERNHEIM: Yes. your Honor In CAMICC1106 with | | |
+| | | | C2frdau3 Page 100 |
+| | | 1 | v. Georgia, 130 S.O 721,724 (2010) quoting v. Georgia, |
+| | | 2 | 467 U.S. 39, 48 (1984). |
+| | | 3 | The information Ms. Conrad seeks to shield from public |
+| | | 4 | view has already been disseminated. But the various court |
+| | | 5 | filings in support of the defendants motion for a new trial |
+| | | 6 | include, among other things. Conrad's disciplinary records and |
+| | | 7 | related court filings and her psychological evaluations. Given |
+| | | 9 | Conrad that is likely to be prejudiced. Moreover, the rights |
+| | | 10 | of the defendants in this criminal case to a public proceeding |
+| | | 12 | application is denied. |
+| | | 13 | I'd ask at this time that the marshals bring Ms. |
+| | | 14 | Conrad out. |
+| | | 15 | MR. OKULA: Your armor. before they Dune her out. may |
+| | | 16 | I be heard briefly? |
+| | | 17 | THE COURT: Certainly. |
+| | | 18 | MR. OKULA: I have spoken with Mr. Gam, and we |
+| | | 19 | understand that the procedure is that Mr Gair is going to call |
+| | | 30 | Ms. Conrad and that she is going to invoke her Fifth Amendment |
+| | | 22 | submitted requesting that she be compelled to testify and be |
+| | | 23 | given use immunity in connection with that testimony. |
+| | | 24 | I want to be perfectly clear that in connection with |
+| | | 25 | this hearing. although Mr. Gair is calling Ms. Conrad as a |
+
+February IS, 2012
+
+| | Page 101 C2frelau3 Conrad direct |
+|-----------|-------------------------------------------------------------------|
+| 1 | witness, we would have otherwise called Ms. Conrad in order to |
+| 2 | elicit these facts, so somebody looking back an this record |
+| 3 | later on has no misimpression of a defendant calling a witness |
+| 4 | who the government selectively decides to immunize. We were |
+| 5 | going to call this witness conches. We made a decision that |
+| 6 | her testimony is in the public interest: that's why we an |
+| 7 | seeking the immunity. I just wanted to make that clear to your |
+| 9 | THE COURT: Fine. Ms. Statham. if you would like. |
+| 10 | you may take a scat in the jury box during her examination. |
+| 11 | MS. STERNHEIM: Thank you, Judge. |
+| 12 | THE COURT: Let's bring out Ms. Conrad. |
+| 13 | MS. STERNHEIM: Your Honor. may I take the seal |
+| 14 | closest? |
+| 15 | THE DEPENDANT: Ycs, come on down. |
+| 16 | CATHERINE M. CONRAD. |
+| 17 | called as a witness by the defendant, |
+| 18 | having been duly sworn, testified as follows: |
+| 19 | THE COURT: Would you take a seat and state your full |
+| 20 | name and spell your name slowly for the court reporter. |
+| 21 | THE WITNESS: Catherine with a C. C-A-T.H.E-R•IN.E. |
+| 22 | Conrad, C-O-N-R-A-D. |
+| 23 | THE COURT: Mr. Gan% you may inquire. |
+| 24 | DIRECT EXAMINATION |
+| 25 | BY MR. GA1R: |
+| CSIrtlau3 | Conrad direct |
+| | 1 this proceeding? |
+| | 2 A. Yes, sir. |
+| | 3 Q. Ms. Conrad, did you take the same oath on March 1. 201 I, to |
+| | 4 tell the forth in this courtroom that you took a few moments |
+| | 7 Q. Apart from the dale. do you recall that in connection with |
+| | 9 prospective juror, correct? |
+| | 12 not? |
+| | 13 A. I'm not exactly sure when, sir. |
+| | 14 Q. At some point during the voir dirt, did you take an oath to |
+| | 15 tell the truth, the whole truth, and nothing but the truth? |
+| | 16 A. Probably, yes, sir. |
+| | 17 Q. You didn't do that, did you? |
+| | 19 Q. There were omissions in your testimony. is that cornet? |
+| | 20 A. Yes, sir. |
+| | 21 Q. There were lies in your testimony, were there not? |
+| | 22 A. Yes, sir. |
+| | 23 Q. So you didn't tell the truth, the whole truth, and nothing |
+| | 21 but the truth, isn't that correct? |
+| | 25 A. Yes, sir. |
+| 2 | oath that you took to tell the truth in voir dire on March I st |
+| 3 | of 2011 in this case? |
+| 4 | A. Upon advice of my counsel, I plead the Fifth. Thank you. |
+| 5 | Q. On March 1st and 2nd of 2011, were you present in this |
+| 6 | courtroom for the trial of United States v. Daugerdas? |
+| 7 | A. Upon advice of my counsel, I plead the Fifth. Thank you. |
+| a Q. | Let me ask you one more question. Is it your intention to |
+| 9 | assert your Fifth Amendment pnvilege to any question that I |
+| 10 | ask you concerning your service in United States v. Daugerdas? |
+| 12 | MR. GAIR: Your Honor? |
+| 13 | THE COURT: noes the governrreau have an application si |
+| 14 | this time, Mr. Okula? |
+| 15 | MR. OKULA: We do. your Honor. We have submitted to |
+| 16 | your Honor papers applying for an immunity order, and we |
+| 17 | respectfully ask that your Honor sign that order. |
+| 18 | THE COURT: Ms. Conrad, in view or your aiserlion of |
+| 19 | the Fifth Amendment privilege, I have signed just now an order |
+| 20 | granting you immunity, that is, use immunity, with respect to |
+| 21 | your testimony in this proceeding. |
+| 22 | You may proceed, Mr. Gair. |
+| 23 | BY MR. GAIR: |
+| 24 | Q. Do you understand. Ms. Conrad. that given the grant of use |
+| 25 | immunity, you arc required to answer appropriate questions in |
+| | C2frdau3 Dmirad-amd Page 100 |
+| | 1 Q. Today did you call the -of Judge Patty at about IO |
+| | 2 minutes to 8:00 this morning? |
+| | 3 A. Yes, sir. |
+| | 1 Q. Did you inform the deputy clerk in Judge Pauley's |
+| | s that you would not be coming to court today? |
+| | 6 A. Yes, sir. |
+| | 7 (Continued on next page) |
+
+#### UNITED STATES OF AMERICA, v PAUL NI, DAUGERDAS, ET AL.,
+
+| C2FFDAU4 | Conrad - direct | Page 105 | C2FFDAU4 | Conrad - direct | Page 107 |
+|--------------------------------------------------------------------|-----------------|----------|--------------------------------------------------------------------|-----------------|----------|
+| 1 Q. Did you know that you were under court order to appear in | | | 1 A. I don't know how to answer that question, I'm sorry. | | |
+| 2 court today? | | | 2 Q. Do you understand what rational behavior is? | | |
+| 3 A. Yes, sir. | | | 3 A. I'm not a psychologist, but yes, I understand you. | | |
+| 4 Q. And did you know that a United States -- | | | 4 Q. And you don't know whether that was a rational thing for | | |
+| 5 A. Well, there was a subpoena. | | | 5 you to say or an irrational one? | | |
+| 6 Q. Did you know that a United States district judge had the | | | 6 A. I don't know how to answer you. | | |
+| 7 power to subpoena you to court today? | | | 7 Q. It might have been either one? | | |
+| 8 A. Probably. | | | 8 A. I don't know how to answer you. | | |
+| 9 Q. Well, you're a trained lawyer. You know that the Court can | | | 9 Q. Okay. And did you further tell the deputy clerk that you | | |
+| 10 issue a subpoena, correct? | | | 10 would not be testifying today? | | |
+| 11 A. Yes, sir. | | | 11 A. I believe so. | | |
+| 12 Q. And you were standing in front of Judge Pauley when the | | | 12 Q. And did you understand that the government had prepared an | | |
+| 13 subpoena was served on you on December 20th, is that right? | | | 13 order of immunity that when conferred by Judge Pauley would | | |
+| 14 A. The 20th, yes. | | | 14 require you to testify? | | |
+| 15 Q. Okay. So you knew you were under court order to appear | | | 15 A. No. | | |
+| 16 today, correct? | | | 16 Q. So you had no idea that you were going to receive immunity | | |
+| 17 A. Yes, sir. | | | 17 when you came here to testify today? | | |
+| 18 Q. And you knew that court order was lawful. In other words, | | | 18 A. That's correct, sir. | | |
+| 19 you knew by your training as a lawyer that Judge Pauley had the | | | 19 Q. You're represented by counsel? | | |
+| 20 power to issue that order to you, correct? | | | 20 A. Yes, sir and it was -- yes, sir. | | |
+| 21 A. Yes, sir. | | | 21 Q. And it's your testimony -- have you had a chance to meet | | |
+| 22 Q. And yet you told Judge Pauley's clerk that you were not | | | 22 with your counsel? | | |
+| 23 coming today, did you not? | | | 23 A. Yes, sir. | | |
+| 24 A. Yes. | | | 24 Q. Can you point her out? | | |
+| 25 Q. And you would agree with me that that is irrational | | | 25 A. Right to my left. | | |
+| C2FFDAU4 | Conrad - direct | Page 106 | C2FFDAU4 | Conrad - direct | Page 108 |
+| 1 behavior, is it not? | | | 1 Q. How many times have you met with Ms. Sternheim? | | |
+| 2 MR. OKULA: Objection, objection. | | | 2 A. Six. | | |
+| 3 A. I'm not University of Chicago trained -- | | | 3 Q. And in the six times you met with Ms. Sternheim -- strike | | |
+| 4 MR. OKULA: Objection. | | | 4 that. All those times occurred before today, correct? | | |
+| 5 THE COURT: Sustained as to form. | | | 5 A. Yes, sir. | | |
+| 6 Q. Interesting question. How did you know I was University of | | | 6 Q. And you came into this courtroom today not understanding | | |
+| 7 Chicago trained -- | | | 7 that you were going to be immunized so that you could testify | | |
+| 8 A. I Googled you after the trial. | | | 8 here today? | | |
+| 9 Q. After the trial, is that correct? | | | 9 A. You're correct. | | |
+| 10 A. Yes, sir. | | | 10 Q. Would you agree with me that telling the Court I'm not | | |
+| 11 Q. You didn't Google me during the trial, is that correct? | | | 11 coming and I'm not going to testify shows a lack of respect for | | |
+| 12 A. No. Yes, you're correct. | | | 12 the judicial process? | | |
+| 13 Q. Okay. Now, Ms. Conrad, can you explain how a person with | | | 13 A. No, not at all. | | |
+| 14 legal training recognizing that they are under court order to | | | 14 Q. Can you explain to me your thinking and telling the deputy | | |
+| 15 appear could call a federal judge and say "I'm not coming"? | | | 15 clerk "I will not be coming today"? | | |
+| 16 A. No. | | | 16 A. No. | | |
+| 17 Q. There's no rational explanation for that conduct is there-- | | | 17 Q. Is that because you do not wish to or for some other | | |
+| 18 A. Object -- | | | 18 reason? | | |
+| 19 MR. OKULA: Objection, your Honor. What kind of | | | 19 A. I don't know how to answer you. | | |
+| 20 question is that? | | | 20 Q. What was the reason for your saying to the deputy clerk I | | |
+| 21 MR. GAIR: May I be heard, your Honor? | | | 21 will not be coming today? | | |
+| 22 THE COURT: On this question I'm going to overrule the | | | 22 A. I don't know. | | |
+| 23 government. All right? She can answer that question. | | | 23 Q. Do you know if you had a reason? | | |
+| 24 Q. There's no rational basis for your having stated to the | | | 24 A. I'm not sure. | | |
+| 25 deputy this morning that you were not coming to court, correct? | | | 25 Q. Do you find yourself at times doing things that you do not | | |
+
+| C2FFDAU4 Conrad - direct Paps 109 | |
+|------------------------------------------------------------------|-----------------------------------------------------------------|
+| 1 know whether you have a reason for doing or not? | |
+| 3 psychologist. | |
+| e Q. How much did you have to drink last night? | |
+| is drinking? | |
+| 16 A. Sunday. January 8th. | |
+| 20 courthouse on December 20th to appear before Judge Pauley and | |
+| 21 received instructions, is that correct? | |
+| C2FFDAU4 | Conrad • direct Pape 111 |
+| 1 | correct? |
+| 6 | and I know you went toMI and God bless you because I love |
+| 7 | all the players there. hut, you know, come on, this is anything |
+| 8 | in favor of the delendants and they brought the motion against |
+| 9 | the prosecution. It's ndiculous. If you want another Clinton |
+| 10 | appointment, it's not going to happen." |
+| '1.2 | recollection. |
+| 14 | 'You're being very stupid. Judge.' what were you referring to? |
+| 18 Q. And when you said, "I know you went to | and God bless |
+| 19 | you," what were you referring to there? |
+| 21 Q. You like | football team? |
+| 25 Q. You like | football? |
+
+UNITED STATES OF AMERICA, v PAUL N. DAUGERDAS, ET AL,
+
+| C2FFDAU4 Conrad direct | Page 110 | |
+|-------------------------------------------------------------------|-----------------------------------------------------------------|-----------------------------------------------------------------|
+| | | C2FFDAU4 Conrad - Wee Page 112 |
+| 2 Q. When was the last time before your court appearance on | | 2 Q. Is that what you like about them? |
+| 3 December 20th that you had anything to drink? | | 3 A. I'm not going to answer this. |
+| 4 A. The night before. | 4 | MR. OKULA: 0ttelion. your Honor Why the likes t►e |
+| 5 Q. And had the effects of that alcohol worn off by the time | 5 | football team? |
+| 6 you arrived in court at noon on December 20th? | 6 | THE COURT: Sustained. |
+| 9 | December 20th was not caused by alcohol intoxication, is that 9 | will not answer? |
+| 10 correct? | | 10 A. No. sir. |
+| 11 A. I believe it was caused by a subpoena that I had to appear | | 11 Q. And yet that's what you just did, correct? |
+| 12 here, sir. | | 12 A. I think even yourself sees the ridiculosity (sic) of that |
+| 13 Q. The things that you said to the Court on that day were not | 13 | question. |
+| 14 | influenced by being intoxicated at the time, is that correct? | 14 Q. Let me try to repeat that question again. Didn't you just |
+| 15 A. 1 believe you're correct. | 15 | state. contrary to your own knowledge of legal procedures, that |
+| 16 Q. And was your behavior, would you charactenre your behavior | 16 | you were not going to answer my question? |
+| 17 as rational or irrational? | | 17 A. I don't understand your question. I'm sorry. |
+| is A. I can't answer that. That's in your eyes, sir. | | 16 Q. Now, do you feel like you have the same level of |
+| 19 Q. Now, do you recall that you received some instructions from | 19 | understanding of what's going on around you today that you had |
+| 20 the Court? | 20 | during the trial? |
+| 21 A. I don't know what you're talking about. When? | | 21 A. I don't understand the meaning of that question. |
+| 22 Q. On December 20th did you receive some instructions from | | 22 Q. Now, can you explain to us what Judge Pauley having |
+| 23 Judge Pauley? | 23 | attended University had to do with the discussion about |
+| 24 A. Of course. I received a subpoena. | 24 | your appearing for a hearing today? |
+| 25 Q. And Judge Pauley ordered you to appear today, is that | | 25 A. Absolutely nothing. |
+
+| C2FFDAU4 | Conrad - direct | Page 113 | C2FFDAU4 | Conrad - direct | Page 115 |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------|----------|----------|-----------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| 1 Q. It was irrational, was it not?
2 MR. OKULA: Objection, your Honor.
3 THE COURT: Overruled.
4 A. I don't know what "irrational" means. I'm not a
5 psychologist.
6 Q. And would you agree with me that at least there was no
7 logical connection between Judge Pauley having attended [REDACTED]
8 University 30 years or more ago and the hearing that you were
9 present for and the instructions you were receiving on
10 December 20th.
11 A. You went there too, but I really don't know what your
12 question means.
13 Q. When you say you went there too, you mean I went there too?
14 A. Yes. I Googled you.
15 Q. And you know that I attended that as an undergraduate?
16 A. I believe so.
17 Q. Is that responsive to the question I just asked you?
18 A. I told you, I can't answer your question, sir.
19 Q. I have now posed a different question. I am now asking you
20 to explain for us whether there's a logical connection between
21 Judge Pauley's attendance at [REDACTED] University and your statement
22 to the Court in the proceedings on December 20th?
23 A. I can't parse it down. I'm not a psychologist, sir.
24 Q. Now, then you went on to say, "Come on, this is anything in
25 favor of the defendants and they brought the motion against the
| | | | | 1 filed in the court, sir. Everyone can look it up. It's a
2 matter of public record.
3 Q. And in your judgment the motion was ridiculous, is that
4 what you meant to convey?
5 A. I don't recall, no. I don't recall.
6 Q. Well, when you said it was ridiculous, what did you mean?
7 A. I don't recall.
8 Q. Well, did you mean that you thought there was no merit to
9 it?
10 A. I don't recall.
11 Q. I mean, you know there's merit to it, right?
12 A. I don't recall.
13 Q. Do you know -- I'm not asking about your recall right now.
14 I'm asking you whether or not there is merit to a motion that
15 said you came into court and lied and lied and lied on March 1,
16 2011.
17 MR. OKULA: Objection to the form, your Honor.
18 THE COURT: Sustained as to form.
19 Q. So you don't know why you said it was ridiculous?
20 A. You're correct. I'm not a psychologist.
21 Q. Now, when you went on to tell Judge Pauley "If you want
22 another Clinton appointment, it's not going to happen" -- do
23 you remember saying that?
24 A. I don't recall.
25 Q. So you do not remember saying that?
|
+| C2FFDAU4
| Conrad - direct
| Page 114 | C2FFDAU4 | Conrad - direct | Page 116 |
+| 1 prosecution. It's ridiculous." Now, what were you trying to
2 get at when you said "this is anything in favor of the
3 defendants"?
4 A. I don't recall.
5 Q. Well, what you were trying to get at is --
6 A. Are you testifying for me, sir?
7 Q. What you were trying to get at, [REDACTED], you thought that
8 anything that might be in favor of the defendants would be
9 ridiculous, is that correct?
10 A. Absolutely not.
11 Q. Because you had decided that they were fricken crooks,
12 isn't that correct?
13 A. Absolutely not.
14 Q. You haven't decided that?
15 A. Absolutely not.
16 Q. Did you think -- and when you said and they brought the
17 motion against the prosecution did you think that Judge Pauley
18 was unaware of who filed the motion and who was responding to
19 the motion concerning the request for a new trial?
20 A. You have to break that question down for me, because Pacer
21 is a public record, sir.
22 Q. Can you explain to me what the fact that Pacer is a public
23 record has to do with the question of whether Judge Pauley
24 would know who filed the motion?
25 A. Of course. It's a matter of public record and it's what's
| | | | | 1 A. If it's in the record, I probably did say that, sir.
2 Q. Okay, so it's in the record. So why did you say it?
3 A. Probably just being smart.
4 Q. Just being smart.
5 A. Smart a-s-s.
6 Q. So you were being a smart ass to a federal judge, is that
7 what you call it?
8 A. If you need to say it that way, that's your words, not
9 mine.
10 Q. Okay, well, let me ask you this: Are you under the
11 impression that the President of the United States is named
12 Clinton?
13 A. I Googled -- no. Please, stop. No.
14 Q. Why did you refer to another Clinton appointment?
15 A. Because I Googled the judge after the trial was over and I
16 saw he was a Clinton appointee. End of story. Why don't we
17 get on to the meat of this?
18 Q. Ms. Conrad, can you explain for us the connection between
19 Judge Pauley ordering you to appear for a hearing on
20 February 15th and the prospect that Judge Pauley would receive
21 another appointment to the bench from somebody --
22 A. No.
23 Q. -- who is not President?
24 A. No.
25 Q. Would you agree with me that in the common parlance that
|
+
+February IS, 2012
+
+| C2FFDAU4 | Conrad - direct | Page 117 | C2FFDAU4 | Conrad - direct | Page 119 |
+|--------------------------------------------------------------------|-----------------|----------|--------------------------------------------------------------------|-----------------|----------|
+| 1 was crazy talk? | | | 1 A. I can't dispute if you're reading from the transcript, sir. | | |
+| 2 MR. OKULA: Objection. | | | 2 So -- | | |
+| 3 A. No, I'm not a psychologist. | | | 3 Q. I'm asking if you remember saying it. | | |
+| 4 THE COURT: Sustained. | | | 4 A. If you're reading from the transcript then I said it. It | | |
+| 5 Q. Can you explain the connection, if any, between what you | | | 5 doesn't matter, I guess, if I remember it or not. But I recall | | |
+| 6 said about Judge Pauley receiving another Clinton appointment | | | 6 that. | | |
+| 7 and the matters that were going to be discussed? | | | 7 Q. You do recall? | | |
+| 8 A. No. | | | 8 A. Vaguely. | | |
+| 9 Q. And did you have any special insight when you said "it's | | | 9 Q. Now, would you agree with me in your career as a lawyer | | |
+| 10 not going to happen" that Judge Pauley would not receive | | | 10 that it is an uncommon response for a person ordered by a judge | | |
+| 11 another appointment? | | | 11 to appear in court to testify to say no, I'm not going to do | | |
+| 12 A. No. | | | 12 that? | | |
+| 13 Q. Now, when you came to the hearing on December 20th, did you | | | 13 MR. OKULA: Objection, your Honor. | | |
+| 14 understand that you had been compelled to come to that hearing | | | 14 THE COURT: Overruled. | | |
+| 15 by having an order served on you at your home? | | | 15 A. Could you please repeat the question? | | |
+| 16 A. Yes, I had a subpoena served upon me. | | | 16 Q. Based on your experience as a lawyer, would you agree with | | |
+| 17 Q. By two deputy U.S. marshals, correct? | | | 17 me that your conduct in responding to the judge's instructions | | |
+| 18 A. I believe so, yes. | | | 18 by saying you were not going to appear was unusual? | | |
+| 19 Q. And you understood that you had to obey that order, | | | 19 A. I'm not a psychologist. I don't know. I don't know how to | | |
+| 20 correct? | | | 20 answer you, sir. | | |
+| 21 A. Yes, sir. | | | 21 Q. Well, you are a lawyer, correct? | | |
+| 22 Q. And you understood that you couldn't leave, correct, till | | | 22 A. No. I was. | | |
+| 23 Judge Pauley told you you could leave? | | | 23 Q. Have you been disbarred? | | |
+| 24 A. I don't really know what that means. | | | 24 A. No. | | |
+| 25 Q. Well, do you remember telling the deputy clerk at that time | | | 25 Q. So you're a suspended lawyer? | | |
+| C2FFDAU4 | Conrad - direct | Page 118 | C2FFDAU4 | Conrad - direct | Page 120 |
+| 1 that your time was being wasted and you were going to walk out | | | 1 A. Correct. | | |
+| 2 of the courtroom? | | | 2 Q. You had legal training? | | |
+| 3 A. No, I don't. | | | 3 A. Yes. I went to law school. | | |
+| 4 Q. Did you do that? | | | 4 Q. How many times have you ever heard a person ordered by a | | |
+| 5 A. If I told you I don't remember, how can you ask me the next | | | 5 judge to appear and testify say "I'm not going to"? | | |
+| 6 question? | | | 6 A. I have no idea. | | |
+| 7 Q. Did Judge Pauley explain to you at that hearing you're | | | 7 Q. It might happen all the time? | | |
+| 8 ordered to appear as a witness at a hearing on February 15th | | | 8 A. I don't know how to answer your question, sir. | | |
+| 9 concerning your role as a juror in United States v. Daugerdas? | | | 9 Q. Would you agree that that is not -- to tell a federal | | |
+| 10 A. I don't specifically recall him. | | | 10 judge, and I quote, "I'm not showing up" when you've been | | |
+| 11 Q. Do you recall something like that? | | | 11 ordered to show up is conduct that is not rational? | | |
+| 12 A. Yes, sir. | | | 12 A. I am not a psychologist. I am not part of the disciplinary | | |
+| 13 Q. And do you recall that your response, or do you recall that | | | 13 committee, so I don't know how to answer your question, sir. | | |
+| 14 later in that hearing he told you again you're going to have to | | | 14 Q. Do you know what the word "rational" means? | | |
+| 15 testify at a hearing. Do you recall that? | | | 15 A. I'm not a psychologist. There are variations that are | | |
+| 16 A. Not specifically, no, sir. | | | 16 shades of gray. | | |
+| 17 Q. Do you recall that your initial response to being told that | | | 17 Q. Have you ever been treated for a mental illness? | | |
+| 18 you had to appear at a hearing is to say, "No, I don't. No, | | | 18 A. I'm not going to answer this. | | |
+| 19 no, no"? | | | 19 THE COURT: You are directed to answer it. | | |
+| 20 A. If you're reading from the transcript, then that's what I | | | 20 A. No. | | |
+| 21 said, sir. | | | 21 Q. [REDACTED] has anybody ever told you that you suffer from | | |
+| 22 Q. And do you recall that when the Judge gave you instructions | | | 22 bipolar disorder? | | |
+| 23 about retaining a lawyer you said, and I quote, "For what? I'm | | | 23 A. Not at all. | | |
+| 24 no, I'm not. I'm not going to court for anything. I'm not | | | 24 Q. What medications do you take? | | |
+| 25 testifying for anything, | | | | | |
+
+UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL.,
+
+| C2FFDAU4 | Conrad - direct | Page 121 | C2FFDAU4 | Conrad - direct | Page 123 |
+|--------------------------------------------------------------------|-----------------|----------|-------------------------------------------------------------------|-----------------|----------|
+| 1 Q. Do you regard water as a medication? | | | 1 Q. Would your conduct be sane if irrational? | | |
+| 2 A. It calms me down. Sure. | | | 2 A. I'm not going to answer that. Of course not. Insanely? | | |
+| 3 Q. Besides water, what other medications do you take? | | | 3 Is that what you said, sir? | | |
+| 4 A. Tylenol for PMS. | | | 4 THE COURT: Why don't you put another question? | | |
+| 5 Q. Do you take any prescription medication? | | | 5 Q. Was your conduct in rejecting the subpoena that the judge | | |
+| 6 A. Not at all. | | | 6 ordered served on you and saying that you were not going to | | |
+| 7 Q. At any time in the last, say, two years have you taken any | | | 7 appear and the judge would have to have you arrested, was that | | |
+| 8 prescription medication? | | | 8 conduct irrational? | | |
+| 9 A. No, sir. | | | 9 A. Absolutely not. Nobody wants a subpoena served on them. | | |
+| 10 Q. Now, did you tell the judge that, after he reminded you | | | 10 Q. Now, have you ever witnessed an officer of the court in | | |
+| 11 that a subpoena had just been served on you on December 20, did | | | 11 your career as a lawyer, have you ever witnessed an officer of | | |
+| 12 you tell the judge, "I reject the subpoena. I reject it and | | | 12 the court telling a judge that the judge would have to have | | |
+| 13 you're going to have to arrest me because nothing is going to | | | 13 them arrested because they weren't going to appear as ordered? | | |
+| 14 change." | | | 14 A. I don't know how to answer that. I don't know. | | |
+| 15 A. I don't specifically remember that, but I'm sure I told him | | | 15 Q. Do you know what your own experiences are? | | |
+| 16 that if it's in your record. | | | 16 A. If you're asking if I did it? You just told me I did it. | | |
+| 17 Q. Would you agree with me that that is uncommon conduct for | | | 17 Q. I'm asking you -- are you able to understand my question? | | |
+| 18 an officer of the Court? | | | 18 A. Yes, but these questions are ridiculous. | | |
+| 19 A. I'm not a psychologist. I don't know what common conduct | | | 19 Q. Why are they ridiculous? | | |
+| 20 quote-unquote, what your terms mean. | | | 20 A. Pose it again, please. | | |
+| 21 Q. So you're not really in a position to judge whether | | | 21 Q. Can you answer me why -- you just said my questions are | | |
+| 22 something is common or uncommon, correct? | | | 22 ridiculous. What did you mean when you said they were | | |
+| 23 A. I'm not a judge, like you just said. | | | 23 ridiculous? | | |
+| 24 Q. And you're not in a position to judge whether something is | | | 24 A. How would I know whether an attorney, what another attorney | | |
+| 25 rational or irrational, right? | | | 25 said to another judge? I don't understand your questions. | | |
+| C2FFDAU4 | Conrad - direct | Page 122 | C2FFDAU4 | Conrad - direct | Page 124 |
+| 1 A. Common knowledge is common knowledge, sir. | | | 1 Q. Okay. Now, would you agree with me that a good part of | | |
+| 2 Q. Are you in a position to judge whether something is | | | 2 that hearing on December 20th was about Judge Pauley advising | | |
+| 3 rational or irrational? | | | 3 you that you should get a lawyer. | | |
+| 4 MR. OKULA: Objection, Judge. We're getting into this | | | 4 A. Yes, sir. I understand the underlying reason why we're | | |
+| 5 rational/irrational. Different people have different ideas | | | 5 here is not lawyer or lawyer up, whether I did or didn't, it's | | |
+| 6 about it. | | | 6 whether the underlying fact of the verdict. | | |
+| 7 THE COURT: And he's exploring the witness' view of | | | 7 Q. Did you understand that the hearing on December 20th was to | | |
+| 8 that. Overruled. | | | 8 give you instructions which included instructing you about your | | |
+| 9 A. Can you please say that again, sir? | | | 9 right to a lawyer? | | |
+| 10 MR. GAIR: Your Honor, can I ask that the court | | | 10 A. I guess partly, sir. | | |
+| 11 reporter read back the question? | | | 11 Q. Okay. And Judge Pauley told you that he would appoint a | | |
+| 12 THE COURT: Madam court reporter, would you kindly | | | 12 lawyer for you if you qualified financially, correct? | | |
+| 13 read back the question for Ms. Conrad? | | | 13 A. I don't recall specifically. I don't recall. | | |
+| 14 (Record read) | | | 14 Q. Well, didn't you -- you don't recall whether the judge told | | |
+| 15 A. In what context, sir? | | | 15 you that you would have to -- that he could only appoint a | | |
+| 16 Q. In the context of conduct of a lawyer appearing before a | | | 16 lawyer if you couldn't afford to hire one yourself? | | |
+| 17 federal judge, do you know what kind of conduct is rational and | | | 17 A. Sir, I don't specifically remember that. | | |
+| 18 what kind of conduct is irrational? | | | 18 Q. Did you say that you didn't have the money to pay for | | |
+| 19 A. Probably, sir. | | | 19 counsel? | | |
+| 20 Q. Was your conduct irrational when you said, "I reject the | | | 20 A. ■■■ I don't recall. | | |
+| 21 subpoena. I reject it and you're going to have to arrest me | | | 21 Q. Did you have the money to pay for counsel? | | |
+| 22 because nothing is going to change"? | | | 22 A. No. | | |
+| 23 A. I consider it irrelevant. | | | 23 Q. Well, let me just ask you to look, there's a big black | | |
+| 24 Q. I beg your pardon? | | | 24 binder in front of you, and I'm going to ask you about a | | |
+| 25 A. Irrelevant, not irrational. | | | 25 document in that binder, Exhibit 3. | | |
+
+# February IS, 2012
+
+| C2FFDAU4 | Conrad - direct | Page 125 | C2FFDAU4 | Page 127 |
+|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------|----------|-----------------|----------|
+| 1 A. Sir, tab 3?
2 Q. Tab 3, yes.
3 A. All right.
4 MR. GAIR: Your Honor, at this time I would move the
5 admission of PMD3.
6 THE COURT: Any objection?
7 MR. OKULA: No, your Honor.
8 THE COURT: PMD 3 is received in evidence.
9 (Exhibit PMD 3 received in evidence)
10 Q. If you would look at page 10 of the transcript, it's got
11 page 5 at the bottom, but then on the right side there are page
12 numbers 9, 10 and 11. Tell me when you've got that.
13 A. Okay. Yes, sir.
14 Q. Okay, and if you look at beginning at line 8, the Court
15 says, "Do you want to complete this affidavit now so that I can
16 make a determination as to whether or not you can afford
17 counsel?"
18 And you said, "I can't afford counsel, that's correct,
19 sir."
20 Do you remember that happening?
21 A. If it's here then it happened, sir.
22 Q. And I'm asking you now do you remember it?
23 A. Yeah, probably.
24 Q. Okay. And you understood that you needed to qualify in
25 order to have an attorney appointed for you, correct?
| | | | |
+| C2FFDAU4
| Conrad - direct
| Page 126 | C2FFDAU4
| Page 128 |
+| 1 A. I didn't know specifically, specifically what the
2 qualifications are or were.
3 Q. But you knew it was a financial qualification, correct?
4 A. Probably.
5 Q. Okay. And you understood that you would have to fill out a
6 financial affidavit, did you not?
7 A. I don't know how to answer that. Maybe eventually.
8 Q. Well, when the Court said do you want to complete this
9 affidavit now so that I can make a determination as to whether
10 or not you can afford counsel, did you understand at that point
11 that you had to complete a financial affidavit?
12 A. I don't know, sir.
13 Q. All right. Look back on page 8. It's on the facing page
14 of this exhibit, line 6, Judge Pauley says if you would like a
15 lawyer but do not have the funds to retain one, you may make an
16 application to this Court to have an attorney appointed
17 provided that you make such application and submit a completed
18 financial affidavit that demonstrates your inability to retain
19 counsel by December 23rd 2011, and then a form was tendered to
20 you. Do you remember that happening?
21 A. █████, yes, sir.
22 Q. And do you remember what you said to Judge Pauley when you
23 got the form?
24 A. █████, yes. "This is garbage."
25 Q. You said, "this is garbage"?
| | | | |
+| C2FFDAU4
| | Page 126 | C2FFDAU4
| Page 128 |
+| 1 A. It was probably a kneejerk reaction, sir.
2 Q. So you do know why you did it, it was a kneejerk reaction?
3 A. If you want to characterize it that way.
4 Q. Was it irrational for you to tell Judge Pauley --
5 A. I'm not a psychologist.
6 Q. Because you're not a psychologist you can't penetrate
7 mental states of other people and yourself, correct?
8 A. I don't know how to answer that.
9 Q. Are you able to form a conclusion whether or not somebody
10 is acting rational or irrationally?
11 A. Yes, and I was a very unbiased juror.
12 Q. Ms. Conrad, would you agree with me that your conduct in
13 telling Judge Pauley that the affidavit was garbage was
14 irrational?
15 A. No. And it has nothing to do with the jury verdict that
16 was rendered against your client.
17 Q. Are you under the impression that you are the determinant
18 in this proceeding of what is relevant and irrelevant
19 information?
20 A. I'm not the judge, sir.
21 Q. But yet you just told me that my question was in essence
22 irrelevant, correct?
23 A. I'm not going to mischaracterize your statements.
24 THE COURT: Mr. Gair, is this an appropriate place for
25 a luncheon recess?
| | | | |
+
+#### UNITED STATES OF AMERICA. v PAUL Nt. DAUGERDAS, ET AL..
+
+| C2FFDAU4 | Conrad - direct | Page 129 | C2FFDAU4 | Conrad - direct | Page 131 |
+|----------|-----------------------------------------------------------------|----------|----------|----------------------------------------------------------------|----------|
+| 1 | MR. GAIR: Yes, your Honor. | | 1 | Q. Did you refuse to tell Judge Pauley whether you had money | |
+| 2 | THE COURT: We're going to take a luncheon recess at | | 2 | in checking or savings accounts? | |
+| 3 | this time. We'll resume at 2:05. | | 3 | A. I don't recall. | |
+| 4 | (Luncheon recess) | | 4 | Q. And this was just about two months ago that you had this | |
+| 5 | o0o | | 5 | conversation with Judge Pauley, correct? | |
+| 6 | AFTERNOON SESSION | | 6 | A. If we've established it was December 20th, right | |
+| 7 | 2:05 p.m. | | 7 | Q. And you don't recall whether he asked you whether you had | |
+| 8 | MR. GAIR: I want to draw to counsel's attention two | | 8 | money in checking or savings accounts and you refused to | |
+| 9 | matters that developed over the luncheon recess. First, | | 9 | answer? | |
+| 10 | Ms. Sternheim presented me with a financial affidavit which she | | 10 | A. Are you directing me to look at a specific page of the | |
+| 11 | received from Ms. Conrad. Copies have been made and circulated | | 11 | transcript? | |
+| 12 | to all counsel and I've marked it as Court Exhibit 1. | | 12 | Q. Actually, I was directing you to look at what I thought was | |
+| 13 | Second, during the luncheon recess we discovered on | | 13 | on page 11, but I am not finding it right now. It might be -- | |
+| 14 | our voice mail system that there is a voice mail message from | | 14 | █ yeah, I'm sorry. My notes were wrong. It's the bottom of | |
+| 15 | Ms. Conrad. Much like a picture that's worth a thousand words | | 15 | page 10 of the transcript. | |
+| 16 | I'm going to play the voice mail message for all parties in | | 16 | "The Court: Have you any cash on hand or money in | |
+| 17 | open court now. | | 17 | savings or checking accounts?" | |
+| 18 | | | 18 | And your answer was, "As opposed to what? As opposed | |
+| 19 | MS. CONRAD: (Voice mail) "Hi, it's Catherine Conrad. | | 19 | to paying my rent next month or as opposed to what? That's not | |
+| 20 | I won't be showing up to the hearing today. Thank you." | | 20 | a fair question. I don't understand what you're saying, sir." | |
+| 21 | THE COURT: Play the time. | | 21 | Now, do you recall, does that refresh your | |
+| 22 | "8:33 a.m. on February 15th." | | 22 | recollection that you were asked about whether you had cash or | |
+| 23 | All right. There you have it. That was after her | | 23 | money in checking or savings accounts? | |
+| 24 | conversation with my deputy at 7:52. Are there any matters | | 24 | A. Yes. Now it does, sir. | |
+| 25 | that counsel want to raise before we bring Ms. Conrad out and | | 25 | Q. And did you tell the judge that your personal finances had | |
+| C2FFDAU4 | Conrad - direct | Page 130 | C2FFDAU4 | Conrad - direct | Page 132 |
+| 1 | resume the inquiry? | | 1 | nothing to do with this? | |
+| 2 | MR. GAIR: No, your Honor. | | 2 | A. I can't read as quickly as you're trying to lead me to, | |
+| 3 | THE COURT: All right. | | 3 | but -- | |
+| 4 | MR. OKULA: Judge, do you anticipate that we'll go to | | 4 | Q. I don't want to make you go any more quickly than you can. | |
+| 5 | 5 today? | | 5 | If you look on page 11, line 19, did you say, beginning line | |
+| 6 | THE COURT: Do you anticipate finishing with | | 6 | 19, "My personal finances have nothing to do with this. Thank | |
+| 7 | Ms. Conrad this afternoon? | | 7 | you. They have nothing to do with this. I can get counsel any | |
+| 8 | MR. GAIR: I do so anticipate. | | 8 | time I want, federal or state. Thank you, sir." Did you say | |
+| 9 | THE COURT: Good. Then I anticipate going to five. | | 9 | that to Judge Pauley? | |
+| 10 | If we have to work a little later to complete Ms. Conrad, I'd | | 10 | A. Yes, before he told me to sit down. | |
+| 11 | like to do that. | | 11 | Q. We're going to get to where he told you to sit down, but | |
+| 12 | Mr. Gair, you may continue with your examination. | | 12 | when you told Judge Pauley your personal finances have nothing | |
+| 13 | BY MR. GAIR: | | 13 | to do with this, did you understand that in fact your personal | |
+| 14 | Q. On December 20th when you were here pursuant to the Court's | | 14 | finances had a great deal to do with whether or not he could | |
+| 15 | order, Judge Pauley attempted to determine whether you had the | | 15 | appoint a lawyer for you? | |
+| 16 | financial ability to hire a lawyer. Do you recall that? | | 16 | A. Had nothing to do with the guilty verdict I rendered | |
+| 17 | A. Generally. Not specifically. | | 17 | against your client. | |
+| 18 | Q. And you understood -- well, he asked you whether you had | | 18 | Q. So you were not telling the judge that your personal | |
+| 19 | any money in checking or savings account, did he not? | | 19 | finances had nothing to do with whether or not you could be | |
+| 20 | A. I don't recall. | | 20 | appointed a lawyer? | |
+| 21 | Q. If we can look at Exhibit 3, it's tab 3, page 11 of the | | 21 | A. Can you please rephrase that? | |
+| 22 | transcript -- | | 22 | Q. Sure. What you said is that your personal finances had | |
+| 23 | MR. GAIR: If I may have a moment, your Honor. | | 23 | nothing to do with it and you could get a lawyer federal or | |
+| 24 | THE COURT: Take your time. | | 24 | state any time you wanted. Isn't that what you said? | |
+| 25 | (Pause) | | 25 | A. If that's what it sets, then that's what I said, sir. | |
+
+February LS, 2012
+
+| | C2FFDAU4 Conrad - direct Page 133 | | |
+|----|-----------------------------------------------------------------|----|---------------------------------------------------------------|
+| 2 | there was a logical connection between the question Judge | | |
+| 3 | Fauky was asking you about your finances and the matter he was | | |
+| 4 | discussing with you, that is, appointment of a lawyer? | | |
+| 11 | to do with this, correct? | | |
+| 13 | against your client. | | |
+| 15 | asked about, that is. your right to a lawyer, correct? | | |
+| 19 | THE COURT: Um directing lost to answer questions Qui | | |
+| 20 | are put before you. | | |
+| 22 | money in savings or checking accounts of approximately 512.000? | | |
+| 24 | from my attorney this morning, then that is correct. | | |
+| | C2FFDAU4 Conrad- Met Page 134 | | |
+| 1 | affidavit -- | | |
+| 4 | have 512.000 cash on hand? | | |
+| 6 | verdict I rendered against Mr. Daugerdas, your client. | | |
+| 9 | received this morning. | | |
+| 13 | stocks and bonds, is that correct? | | |
+| 16 | Ms. Conrad? | | |
+| 17 | MR. OKULA: Objection, your Honor. | | |
+| 19 | THE COURT: Sustained as to form. | | |
+| | 20 Q. ithc you been a successful have you achieved financial | | |
+| 21 | success as a lawyer? | | |
+| 23 | means. | | |
+| 25 | financial success as a lawyer? | | |
+| | | | C2FFDAU4 Cents • direct Page 135 |
+| | | 2 | matters to me. |
+| | | 4 | lawyer? |
+| | | 9 | MR. OKULA: Judge, relevance. |
+| | | 10 | THE COURT: Overruled. |
+| | | | C2FFDAU4 Conrad direct Pape 138 |
+| | | 1 | on February 28th of 2011 that you hadn't been -- the question |
+| | | 2 | attach your last two years federal and state tax returns the |
+| | | 3 | answer was none, not applicable. |
+| | | 7 | February 28, 2011. |
+| | | 12 | correct? |
+| | | 15 | MR. OKULA: Objection, your Honor. |
+| | | 16 | THE COURT: Sustained. |
+| | | 17 | MR. GAIR: Sony. your Honor. My apologies. |
+| | | 19 | to that question on the disciplinary committee affidavit you |
+| | | 20 | filed on February 28th of 2011? |
+| | | 23 | this issue, would you characterize yourself by your own |
+| | | 24 | standards as a financially successful lawyer? |
+
+#### UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL
+
+| C2FFDAU4 | Conrad - direct | Page 137 | C2FFDAU4 | Conrad - direct | Page 139 |
+|-------------------------------------------------------------------|-----------------|----------|--------------------------------------------------------------------|-----------------|----------|
+| 1 Q. Okay. | | | 1 correct? | | |
+| 2 A. I don't live an extravagant lifestyle like Mr. Daugerdas. | | | 2 A. I don't recall. | | |
+| 3 Q. Would you consider that Mr. Daugerdas was a financially | | | 3 Q. And when Judge Pauley advised you that you should get a | | |
+| 4 successful lawyer? | | | 4 lawyer, retain a lawyer, you told him, "I'll retain myself or | | |
+| 5 A. Sure, ripping off the government. | | | 5 my husband, the convicted felon," is that correct? | | |
+| 6 Q. And would you consider that -- | | | 6 A. If it's written somewhere I probably said it. I don't | | |
+| 7 A. And this was only after the trial, might I add. | | | 7 specifically recall, sorry. | | |
+| 8 Q. Would you consider -- | | | 8 Q. So you don't remember telling the Court that you would | | |
+| 9 A. In keeping with the verdict that myself and eleven other | | | 9 either retain yourself or your husband the convicted felon? | | |
+| 10 jurors rendered against your client. | | | 10 A. Where are you directing me to look at? | | |
+| 11 Q. Would you agree with me that you have not been very | | | 11 Q. I'm asking you if you remember it, [REDACTED]? | | |
+| 12 financially successful as a lawyer? | | | 12 A. Not specifically. | | |
+| 13 A. I am fine, thank you. | | | 13 Q. Do you have memory problems? | | |
+| 14 Q. Okay. How is it that you're able to pay your \$800 a month | | | 14 A. Certainly not. | | |
+| 15 in rent? | | | 15 Q. Certainly not. Never had blackouts, I take it? | | |
+| 16 A. You got that from the financial affidavit as well this | | | 16 A. I remember every day of this trial. | | |
+| 17 morning. Yes. From savings. | | | 17 Q. Have you ever had a blackout? | | |
+| 18 Q. And is that how you pay all your expenses, from savings? | | | 18 A. No. | | |
+| 19 A. I don't have a lot of expenses, so, yes. I'm going to need | | | 19 Q. And you have no memory problems? | | |
+| 20 a job soon. I'm sure your office is not going to hire me, | | | 20 A. No, sir. | | |
+| 21 but -- | | | 21 Q. And yet you don't remember telling the Court, "I'll retain | | |
+| 22 Q. Now, Ms. Conrad, when you filled out this affidavit today | | | 22 myself or my husband the convicted felon"? | | |
+| 23 did you understand that the purpose of this affidavit was to | | | 23 A. Not specifically. | | |
+| 24 allow the Court to determine whether or not you had the | | | 24 Q. Is your husband a convicted felon? | | |
+| 25 financial need for Ms. Sternheim to be appointed and funded by | | | 25 A. Yes, sir. | | |
+| C2FFDAU4 | Conrad - direct | Page 138 | C2FFDAU4 | Conrad - direct | Page 140 |
+| 1 the federal court? | | | 1 Q. Did you remember that on March 1 and 2nd of 2011 or did you | | |
+| 2 A. However that's relevant, but yes. | | | 2 forget? | | |
+| 3 Q. Now, when you were asked back on December 20th if you owned | | | 3 A. Sir, I did not reveal that to the Court. | | |
+| 4 any stocks or bonds, you replied to the Court "none of your | | | 4 Q. Did you remember it was my question. | | |
+| 5 business." Is that correct? | | | 5 A. Well, I'm answering part two of your question that's not | | |
+| 6 A. If it's in the transcript, I probably said it, sir. I | | | 6 asked yet, but yes. | | |
+| 7 don't specifically recall. | | | 7 Q. So you did remember that, right? | | |
+| 8 Q. First I'm just asking if you remember it. | | | 8 A. To repeat it a third time, yes. | | |
+| 9 A. No, not offhand. | | | 9 Q. Now, Ms. Conrad, do you remember that at the start of the | | |
+| 10 Q. So let's look at the transcript on page 12. You are asked | | | 10 voir dire in this case Judge Pauley explained the purpose of | | |
+| 11 on line 13, "Do you own any stocks or bonds?" | | | 11 voir dire? | | |
+| 12 And you said to the Court on line 14, "None of your | | | 12 A. I believe so, yes. | | |
+| 13 business." | | | 13 Q. Do you remember that he explained that voir dire means to | | |
+| 14 Does that refresh your memory that when the Court | | | 14 speak the truth. Do you remember that? | | |
+| 15 asked a question about your ownership of stocks and bonds you | | | 15 A. Yes, sir. | | |
+| 16 said "none of your business"? | | | 16 Q. And do you remember that Judge Pauley explained to you and | | |
+| 17 A. Not specifically, but I see it written in front of me, so I | | | 17 everybody else on the venire that that's precisely what you had | | |
+| 18 must have said it. | | | 18 just been sworn to do, to speak the truth. | | |
+| 19 Q. But it was the Court's business, was it not? | | | 19 A. Veneer, yes. | | |
+| 20 A. That I -- I don't know. | | | 20 Q. Do you remember that he explained to you that the purpose, | | |
+| 21 Q. Why did you say "none of your business"? | | | 21 the purpose of voir dire was to make sure that we have a jury | | |
+| 22 A. It's probably what I felt at the time. | | | 22 of citizens who will decide the issues in this case fairly and | | |
+| 23 Q. Now, when Judge Pauley asked you or instructed you to take | | | 23 impartially and without any bias or prejudice in favor of | | |
+| 24 the oath so that he could ask you questions about your | | | 24 either side or against either side. Do you remember saying | | |
+| 25 financial situation, you refused to take the oath, is that | | | 25 that? | | |
+
+February IS, 2012
+
+| C2FFDAU4 | Conrad - direct | Page 141 | C2FFDAU4 | Conrad - direct | Page 143 |
+|--------------------------------------------------------------------|-----------------|----------|------------------------------------------------------------------|-----------------|----------|
+| 1 A. Exactly. Yes. And that's what we did. | | | 1 Q. Was it during the voir dire? | | |
+| 2 Q. So you knew from the outset of this trial that there was a | | | 2 A. I don't recall. | | |
+| 3 connection between speaking the truth on voir dire and | | | 3 Q. Was it before you showed up for court the first day? | | |
+| 4 ferreting out jurors who might have biases, didn't you, then? | | | 4 A. No, I don't think so. | | |
+| 5 MR. OKULA: Objection, your Honor. | | | 5 Q. Was it after Judge Pauley told you that you had to speak | | |
+| 6 THE COURT: Overruled. | | | 6 the truth? | | |
+| 7 A. Can you please repeat that? | | | 7 A. I don't recall, sir. | | |
+| 8 Q. You understood based on what Judge Pauley told you in voir | | | 8 Q. In response to what question did you make the decision to | | |
+| 9 dire that there was a connection between speaking the truth in | | | 9 lie to the Court? | | |
+| 10 answer to what you were being asked and the ability of the | | | 10 A. I didn't lie. | | |
+| 11 Court to ferret out biases or other things that might make a | | | 11 Q. You did not lie? | | |
+| 12 juror unsuitable? | | | 12 A. I omitted the fact that I was an attorney. | | |
+| 13 A. Yes, there is a nexus. | | | 13 Q. I just want to make sure I heard you right. You did not | | |
+| 14 Q. There is a nexus? | | | 14 lie under oath, is that correct? | | |
+| 15 A. Mm-hmm. | | | 15 A. In my mind I didn't. I omitted the fact that I had a JD. | | |
+| 16 Q. And yet you deliberately decided to defy the Court, isn't | | | 16 Q. And that was not a lie in your mind? | | |
+| 17 that correct? | | | 17 A. It was an omission. | | |
+| 18 A. If you want to mischaracterize it like that. | | | 18 Q. Is it a lie? | | |
+| 19 Q. I don't want to mischaracterize anything. I want you to | | | 19 A. You're the evidence professor. | | |
+| 20 tell me whether you deliberately decided to mislead the Court | | | 20 Q. Did you lie to the Court -- | | |
+| 21 here. | | | 21 A. I omitted. | | |
+| 22 A. I did not reveal that I was an attorney. | | | 22 Q. Okay. So there's a distinction in your mind between | | |
+| 23 Q. That was not my question, [REDACTED]. | | | 23 omitting a truth and lying, is that correct? | | |
+| 24 A. Then please rephrase it. | | | 24 A. I'm not sure. | | |
+| 25 Q. Did you make a deliberate decision to lie to this Court? | | | 25 Q. Well, is the lie that you, or the omission that you | | |
+| C2FFDAU4 | Conrad - direct | Page 142 | C2FFDAU4 | Conrad - direct | Page 144 |
+| 1 A. I did omit the fact that I had a JD. | | | 1 remember an omission about being a lawyer? | | |
+| 2 Q. Was that the only fact you omitted? | | | 2 A. I don't know what that question means, sir. | | |
+| 3 A. No. | | | 3 Q. Well, let me try another question. Do you remember that | | |
+| 4 Q. We're going to come back to that, but right now I'd like to | | | 4 the very first question that Judge Pauley asked you was where | | |
+| 5 try to get an answer to my question. Did you make the | | | 5 do you live. | | |
+| 6 deliberate decision I'm going to lie to the Court? | | | 6 A. Yes. And we had to, I believe, state the county. | | |
+| 7 A. Not at first. | | | 7 Q. Okay, and in answer to the very first question that Judge | | |
+| 8 Q. Not at first. | | | 8 Pauley asked you, you told a deliberate lie to Judge Pauley, | | |
+| 9 A. I -- | | | 9 isn't that true, [REDACTED]? | | |
+| 10 Q. When did you make the deliberate decision that you were | | | 10 A. No. I don't know what you're talking about. | | |
+| 11 going to lie to the Court? | | | 11 Q. Well, didn't you tell Judge Pauley that you lived in Bronx | | |
+| 12 A. It was omission. | | | 12 Village in Westchester? | | |
+| 13 Q. So you did not tell any active lie to the Court, is that | | | 13 A. There is no such thing as Bronx Village. | | |
+| 14 correct? | | | 14 Q. Well, that's what the transcript says. Did you tell Judge | | |
+| 15 A. I'm not really sure. | | | 15 Pauley that you lived in Bronxville in Westchester? | | |
+| 16 Q. Is that because you don't remember what you said or because | | | 16 A. Yes. | | |
+| 17 you don't know the difference between truth and lie? | | | 17 Q. And that's a lie, wasn't it? | | |
+| 18 A. Of course I know the difference, and the character | | | 18 A. No, it's my official address. | | |
+| 19 assassination is, you know, well done, but the fact of the | | | 19 Q. [REDACTED], Judge Pauley didn't ask you what your official | | |
+| 20 matter is that you're here to discredit me and to discredit the | | | 20 address is, he asked you where you live, right? | | |
+| 21 fact that myself and eleven other jurors convicted your client | | | 21 A. Anyone can have more than one residence. | | |
+| 22 across the board. | | | 22 Q. Did he ask you where you lived? | | |
+| 23 Q. Ms. Conrad, when did you make the deliberate decision to | | | 23 A. I don't remember the exact question. It might have been -- | | |
+| 24 lie to the Court? | | | 24 no, it was, you had to give your county. | | |
+
+### UNITED STATES OF AMERICA, s PAUL M. DAUGERDAS, ET AL.,
+
+| C2FFDAU4 | Conrad - direct | Page 145 | C2FFDAU4 | Conrad - direct | Page 147 |
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25 | MR. GAIR: Your Honor, I move the admission of PMD
Exhibit 2.
THE COURT: Any objection?
MR. OKULA: No, your Honor.
THE COURT: PMD Exhibit 2 is received in evidence.
(Exhibit PMD 2 received in evidence)
Q. Let me ask you to direct your attention to page 203 of the
transcript. And I just want you to focus on lines 4 through 9.
Judge Pauley asked you, I think Ms. Conrad, Juror No. 3, that I
was about to begin with you when we suspended yesterday. So
first, would you tell us what neighborhood you reside in? And
you answered Bronxville in Westchester. Is that correct?
A. No, you're reading it in correctly. It says Bronx Village.
Q. Okay, was your answer at the time Bronxville but possibly
the court reporter got it down wrong?
A. Absolutely.
Q. So in answer to the question where you resided, you said
you resided in Bronxville, that's in Westchester County,
correct?
A. Yes.
Q. And you don't reside in Bronxville in Westchester County,
isn't that correct?
A. No.
Q. No, it's not correct?
A. I have two addresses.
| 1 were living.
2. A. I sometimes stay in Bronxville as well.
3. Q. And my question to you was on the day of voir dire when you
4. woke up --
5. A. ██████████ but that wasn't your question. The day of voir dire.
6. then that was in the Barker Avenue address, correct.
7. Q. Okay. How about on February 28th, the day before voir
8. dire. Where did you live on that day?
9. A. The same.
10. Q. The same what?
11. A. Address.
12. Q. You lived on Barker Avenue in the Bronx?
13. A. Yes, sir.
14. Q. And we know you lived there on March 1 because that's the
15. first day of voir dire, right?
16. A. I'm not sure. I think March 1 was a Monday or a Tuesday.
17. I'm not specifically sure.
18. Q. In fact, ██████████ you had lived on Barker Avenue in the Bronx
19. for the past two years at least, correct?
20. A. ██████████ sure.
21. Q. ██████████ sure.
22. A. And this has everything to do with why Mr. Daugerdas, your
23. client, is guilty or not?
24. Q. And when the Judge said where do you reside, you made
25. deliberate decision to tell the judge that you resided in
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25 | Q. Let me ask you this: When you woke up on the morning of
March 1 of 2011 and you got out of bed and you walked out the
front door, were you on Barker Avenue in the Bronx?
A. That's confidential.
Q. Or were you in Bronxville in Westchester?
A. Same answer.
THE COURT: It's not confidential. I'm directing you
to answer the question.
A. Barker.
Q. Because that's where you live.
A. And what does this have to do with convicting your client?
Q. ██████████ --
A. I --
Q. Do you -- the truth of the matter is that you lived on
March 1 and 2nd and every other day in March of 2011, you lived
at 2385 Barker Avenue, apartment 3H in the Bronx, isn't that
correct?
A. No.
Q. What days did you not live there?
A. Probably the beginning of March.
Q. At the beginning of March you did not live in, you did not
live in the Bronx?
A. That's my address and I also have a Westchester address,
sir.
Q. I didn't ask what your addresses were. I asked where you
| 1 Bronxville as opposed to on Barker Avenue in the Bronx,
2. correct?
3. A. That -- both are correct.
4. Q. So you were not trying to mislead this Court when you said
5. I live in -- I live in Bronxville in Westchester County?
6. A. And myself and the other eleven jurors did not mislead this
7. Court when we rendered our fair and just and unbiased verdict.
8. MR. GAIR: Move to strike as non-responsive, your
9. Honor.
10. THE COURT: Application granted.
11. Q. Okay, Ms. Conrad, the fact is -- let me just get a little
12. background. Do you live with your husband?
13. A. Yes.
14. Q. Your husband is a career criminal, right?
15. A. So are most attorneys.
16. Q. And, Ms. Conrad, your father is an immigration judge for
17. the United States Department of Justice?
18. A. DOJ.
19. Q. Yeah. Are you trying to tell me that sometimes you and
20. your husband, the convicted felon, are living with your father?
21. A. Love has no bounds.
22. Q. So do sometimes you and your husband live in the Bronx?
23. A. We don't sleep in the same bedroom as my parents, sir.
24. Q. Do you sometimes sleep in the Bronx with your husband, same
25. house?
| | | |
+
+February IS, 2012
+
+| C2FFDAU4 | Conrad - direct | Page 149 | C2frdau5 | Conrad - direct | Page 151 |
+|--------------------------------------------------------------------|-----------------|----------|-------------------------------------------------------------------|-----------------|----------|
+| 1 A. I hope so. | | | 1 Yes, that's the date it was signed and notarized. | | |
+| 2 Q. Let me -- | | | 2 Q. This was a statement that was sworn by you before you | | |
+| 3 A. These are semantics, sir. Your client is still guilty as | | | 3 submitted it to the First Department, correct, before you | | |
+| 4 charged with our verdict, and that's it. | | | 4 submitted it to the disciplinary authorities? | | |
+| 5 Q. Well, I think -- | | | 5 A. Yes, sir. | | |
+| 6 A. Myself and eleven other unbiased jurors determined that. | | | 6 Q. They asked you the same question Judge Pauley asked you | | |
+| 7 Q. Do you have a better handle on what the word "bias" means | | | 7 three or four days later, didn't they? | | |
+| 8 than you do on what the word "irrational" means? | | | 8 A. I'm not specifically sure. | | |
+| 9 A. Absolutely. I've been a plaintiff and a defendant and I've | | | 9 Q. Let's look at the second page. Page 2, item number 2, asks | | |
+| 10 also represented plaintiffs and defendants. | | | 10 for your residence, and it says, "I reside at 2385 Barker | | |
+| 11 Q. Okay. So is it your testimony that you resided at both | | | 11 Avenue, apartment 3H, Bronx, New York, 10467," correct? | | |
+| 12 places, both the Bronx and Bronxville, when you were questioned | | | 12 A. Yes. | | |
+| 13 on voir dire on March 1? | | | 13 Q. When you were asked that question on February 26th, the | | |
+| 14 A. If that was the date, yes. | | | 14 date you executed the affidavit, you lived on Barker Avenue in | | |
+| 15 (Continued next page) | | | 15 the Bronx, but a few days later, on March 2nd, when Judge | | |
+| 16 | | | 16 Pauley asked you the identical question, you resided in | | |
+| 17 | | | 17 Bronxville in Westchester, correct? | | |
+| 18 | | | 18 A. Yes, I answered that, correct. | | |
+| 19 | | | 19 Q. Why? | | |
+| 20 | | | 20 A. Because I just thought of myself having two residences. | | |
+| 21 | | | 21 Q. Why didn't you put them both down? | | |
+| 22 | | | 22 A. I really don't know. At that time I don't know. | | |
+| 23 | | | 23 Q. Why did you put the Bronx down on one and tell Judge Pauley | | |
+| 24 | | | 24 Bronx Village on the other. | | |
+| 25 | | | 25 A. Bronxville. | | |
+| C2frdau5 | Conrad - direct | Page 150 | C2frdau5 | Conrad - direct | Page 152 |
+| 1 Q. Look at the heading "March 2nd." Do you see the heading on | | | 1 Q. Bronxville. | | |
+| 2 the transcript "March 2, 2011"? | | | 2 A. Probably because it was a little more reputable. | | |
+| 3 A. ██████, yes. | | | 3 Q. Were you embarrassed by living in the Bronx? | | |
+| 4 Q. You were asked where you resided, and you said you resided | | | 4 A. No. | | |
+| 5 in Bronxville, but you actually resided in two places? | | | 5 Q. What does the fact that Bronxville is more reputable than | | |
+| 6 A. Both, yes. | | | 6 the Bronx have to do with anything? | | |
+| 7 Q. You resided both places, I see. Now, you filed two days | | | 7 A. The average household income. | | |
+| 8 earlier a sworn affidavit with the First Department | | | 8 Q. Why did it matter to you that you portray yourself in this | | |
+| 9 disciplinary committee, is that correct? | | | 9 court as living in a more affluent area than you actually lived | | |
+| 10 A. Yes. I don't know if it was two days prior, but around | | | 10 in? | | |
+| 11 there. | | | 11 A. You're from Chicago. You don't really know that. So I | | |
+| 12 Q. They asked you where you lived, didn't they? | | | 12 don't know how to answer your question. | | |
+| 13 A. I don't specifically recall. | | | 13 Q. You don't know how to answer my question because you don't | | |
+| 14 Q. Let's see if we can help. | | | 14 know what I don't know? | | |
+| 15 A. Thank you. | | | 15 A. I don't know how to answer that even. | | |
+| 16 Q. If you would look at Exhibit 21, tab 21 in your book. Is | | | 16 Q. That I'm not surprised by. | | |
+| 17 this the affidavit you filed in support of your application to | | | 17 MR. OKULA: Objection, your Honor. | | |
+| 18 be reinstated to the practice of law? | | | 18 THE COURT: Sustained. Put a question to the witness. | | |
+| 19 A. It seems to be, yes, sir. | | | 19 The last question was unanswerable. | | |
+| 20 Q. Was it filed on February 28th in the Supreme Court | | | 20 Q. Ms. Conrad, was it your intention to portray yourself to | | |
+| 21 Appellate Division First Department? | | | 21 this Court as living in a more affluent area than you actually | | |
+| 22 A. Yes. | | | 22 lived in? | | |
+| 23 Q. Was the affidavit executed by you two days earlier, on | | | 23 A. No, not really. No, I never thought of it like that. | | |
+| 24 February 26th? | | | 24 Q. Isn't that what you just said? | | |
+| 25 A. Let me get there. If that's the date I signed, it is. | | | 25 A. Bronxville is an affluent community. My parents are there, | | |
+
+#### UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL
+
+| C2frdau5 | Conrad - direct | Page 153 | C2frdau5 | Conrad - direct | Page 155 |
+|----------|------------------------------------------------------------------|----------|----------|--------------------------------------------------------------------|----------|
+| 1 | I'm from there. I live there sometimes. I live at my Bronx | | 1 | A. I did not wake up in Bronxville that day, probably not. | |
+| 2 | address also. | | 2 | Q. So you told a deliberate lie that day, correct? | |
+| 3 | Q. [REDACTED], my question is, did you say that you lived in | | 3 | A. No. | |
+| 4 | Bronxville in order to portray yourself as living in a more | | 4 | Q. Was it an accidental misstatement? | |
+| 5 | affluent community than you actually live in? | | 5 | A. No. | |
+| 6 | A. No, not specifically, no. | | 6 | Q. Was it an oversight? | |
+| 7 | Q. When you said a few minutes ago that the reason that you | | 7 | MR. OKULA: Judge, we have been through this several | |
+| 8 | gave the Bronxville address was because it was a little bit | | 8 | times. | |
+| 9 | more of an affluent community, that wasn't true? | | 9 | THE COURT: Overruled. | |
+| 10 | A. My statement was true, but you're twisting it, obviously. | | 10 | A. No. I consider myself having two residences. | |
+| 11 | Q. Why don't you tell me why, having sworn to the bar | | 11 | Q. Then why didn't you tell the truth when you were asked that | |
+| 12 | authorities on February 26th that you lived in the Bronx, you | | 12 | question? | |
+| 13 | swore to Judge Pauley on March 2nd that you lived in | | 13 | A. I did. | |
+| 14 | Bronxville. Tell us why. | | 14 | Q. Did you say, I have two residences and, by the way, I've | |
+| 15 | A. I consider myself living in both places. | | 15 | been on both sides of criminal cases? Did you say that? | |
+| 16 | Q. Why didn't you tell the Court that you lived both places? | | 16 | A. I wasn't asked that, sir. | |
+| 17 | A. Probably so I would be more marketable as a juror. | | 17 | Q. We'll come to that. Did you say that you had two | |
+| 18 | Q. Have you done any jury trials as a lawyer? | | 18 | residences? | |
+| 19 | A. Nonjury. No. One a few years ago. | | 19 | A. No. | |
+| 20 | Q. Why did you want to be more marketable as a juror? | | 20 | Q. Did you tell the disciplinary authorities that you had two | |
+| 21 | A. Because I knew I could be fair and unbiased. As I did | | 21 | residences? | |
+| 22 | mention a few minutes ago, I've been a plaintiff and a | | 22 | A. They know. | |
+| 23 | defendant on both the civil and the criminal sides, and I have | | 23 | Q. Did you tell the disciplinary authorities in your affidavit | |
+| 24 | also represented plaintiffs and defendants on both sides, and | | 24 | that you resided in Bronxville? | |
+| 25 | been unemployed, out of the courtroom. And I had never had a | | 25 | A. Not in this one. | |
+| C2frdau5 | Conrad - direct | Page 154 | C2frdau5 | Conrad - direct | Page 156 |
+| 1 | tax shelter case or experience with tax law, and I knew I could | | 1 | Q. Not in this one. Do you remember that a couple of years | |
+| 2 | be an unbiased juror. | | 2 | before this you were sworn to give a deposition under oath? | |
+| 3 | Q. Because you knew that you could be an unbiased juror, you | | 3 | A. March 24, 2009. | |
+| 4 | decided to lie to get on a jury, is that right? | | 4 | Q. You do remember, don't you. | |
+| 5 | A. Probably subconsciously. | | 5 | A. Yes, I do. | |
+| 6 | Q. Subconsciously, Ms. Conrad, you wanted to do something | | 6 | Q. You were asked where you lived, weren't you? | |
+| 7 | worthwhile, is that right? | | 7 | A. Probably. | |
+| 8 | MR. OKULA: Objection to the form, your Honor. | | 8 | Q. You said, truthfully, that you lived on Barker Avenue in | |
+| 9 | THE COURT: Overruled. | | 9 | the Bronx, didn't you? | |
+| 10 | A. I don't know how you can characterize "worthwhile." If | | 10 | A. I don't recall specifically. | |
+| 11 | it's sending a -- rendering a verdict which I felt was just. | | 11 | Q. [REDACTED], you've lived on Barker Avenue in the Bronx for many | |
+| 12 | then I can agree with you. But if there's something ulterior | | 12 | years, isn't that true? | |
+| 13 | to your question, I don't know how to answer that. | | 13 | A. Sure. | |
+| 14 | Q. When you started just then to say "sending a" and then you | | 14 | Q. And every one of your neighbors on the third floor knows | |
+| 15 | stopped, were you going to say sending a criminal to jail? Is | | 15 | who you are, don't they? | |
+| 16 | that what you were about to say? | | 16 | A. Probably. | |
+| 17 | A. No. | | 17 | Q. Because you and your husband are constantly, every day and | |
+| 18 | Q. You wanted to be part of the process, didn't you. [REDACTED]? | | 18 | night, engaged in screaming and fights and insults and threats, | |
+| 19 | A. Sure. | | 19 | right? | |
+| 20 | Q. You wanted to be part of this process so badly that you | | 20 | MR. OKULA: Objection, your Honor. Relevance. | |
+| 21 | made yourself look like a different juror than you were, | | 21 | THE COURT: Overruled. | |
+| 22 | different person than you were? | | 22 | A. Probably. | |
+| 23 | A. That's not for me to judge. | | 23 | Q. Yeah, probably. The police are there all the time, aren't | |
+| 24 | Q. Can we agree that you lied about where you resided on March | | 24 | they? | |
+| 25 | 2nd? | | 25 | A. No. | |
+
+| C2frdau5 | Conrad - direct | Page 157 | C2frdau5 | Conrad - direct | Page 159 |
+|----------|-----------------------------------------------------------------|----------|----------|---------------------------------------------------------------------------|----------|
+| 1 | Q. How often do the police come to your apartment? | | 1 | were telling the truth or lying to determining whether | |
+| 2 | A. The last time someone came to my apartment was when the | | 2 | witnesses were telling the truth or lying? | |
+| 3 | marshals served me to come here back in December. | | 3 | A. That's a nice spin on it. | |
+| 4 | Q. When was the last time a New York police officer came to | | 4 | Q. Do you have an answer to it? | |
+| 5 | your apartment? | | 5 | A. After all the evidence in the trial, it was overwhelming. | |
+| 6 | A. Maybe three, four years ago. | | 6 | and our verdict was a true, unbiased, fair verdict. | |
+| 7 | Q. So, you have been living there for at least three or four | | 7 | Q. So the end justifies the means, is that right? | |
+| 8 | years, right? | | 8 | MR. OKULA: Objection, your Honor. | |
+| 9 | A. Haven't we established this? | | 9 | THE COURT: Sustained as to form. | |
+| 10 | Q. I guess we have, ██████. Have we established that you told | | 10 | Q. Let me try one more time. Did you apply your personal | |
+| 11 | this lie on purpose? | | 11 | sense of truthfulness to your evaluation of the witnesses who | |
+| 12 | A. No. | | 12 | testified in this case? | |
+| 13 | Q. Let's move on to the next question you were asked. You | | 13 | A. I believe all 12 of us jurors did. | |
+| 14 | told a deliberate lie in response to that question, did you | | 14 | Q. I didn't ask about anybody but you. Did you apply your | |
+| 15 | not? | | 15 | personal sense of truthfulness to evaluating the witnesses that | |
+| 16 | A. You didn't ask me a question. What are you talking about, | | 16 | you heard in this case? | |
+| 17 | sir? | | 17 | A. I can say so. | |
+| 18 | Q. Let's look at again page 203, lines 10 through 12. | | 18 | Q. You agree with me that when you said you had lived in | |
+| 19 | A. Of what exhibit? I'm sorry. | | 19 | Bronxville your whole life, that was not true, correct? | |
+| 20 | Q. Exhibit number 2. | | 20 | A. I've lived many places. That is my permanent residence | |
+| 21 | A. OK. | | 21 | and -- the horse is dead. | |
+| 22 | Q. The second question Judge Pauley asked you was, "How long | | 22 | Q. Did you make a deliberate decision to say that you lived | |
+| 23 | have you lived at your current address?" and your answer was, | | 23 | there your whole life when in fact you had lived in the Bronx | |
+| 24 | "My whole life"? | | 24 | or Brooklyn or other places? | |
+| 25 | A. That's correct. | | 25 | A. Please repeat it. I didn't say Brooklyn on voir dire. | |
+| C2frdau5 | Conrad - direct | Page 158 | C2frdau5 | Conrad - direct | Page 160 |
+| 1 | Q. Now, ██████, am I right in thinking that that was a lie? | | 1 | Q. You have lived various places in your life, have you not? | |
+| 2 | A. No. | | 2 | A. ██████, yes. | |
+| 3 | Q. Had you lived in Bronxville your whole life? | | 3 | Q. That statement that you just made, "██████, yes," is | |
+| 4 | A. It's my permanent address my whole life. I went to school | | 4 | inconsistent with the statement that you made to Judge Pauley | |
+| 5 | in Boston, I went to school in Brooklyn, I studied abroad for | | 5 | when he asked how long have you lived in Bronxville? | |
+| 6 | two summers in Israel. That has been my permanent address, | | 6 | A. I consider it my whole life because that is my other | |
+| 7 | sir. | | 7 | residence and that's my permanent residence. | |
+| 8 | Q. When Judge Pauley asked you how long you have lived at your | | 8 | Q. Then the Court asked you, "Do you own or rent?" So we have | |
+| 9 | current address, you said your whole life, correct? | | 9 | tell the truth about that. You were asked where you lived, and you didn't | |
+| 10 | A. I just said that, correct. | | 10 | there -- | |
+| 11 | Q. OK. We have established that you live on a day-to-day | | 11 | A. That's your interpretation. | |
+| 12 | basis on Barker Avenue and that you have for years, right? | | 12 | Q. OK. And you didn't tell the truth about that either. | |
+| 13 | A. Correct. | | 13 | Let's go to the third question, "Do you own or rent?" You said | |
+| 14 | Q. So you lied to the judge? | | 15 | "We own." | |
+| 15 | A. I consider myself having two residences. | | 16 | A. That was a lie, to skip questions 10 to a hundred. | |
+| 16 | Q. Let me try and ask a more specific question. If a person | | 17 | Q. That was a lie, too? | |
+| 17 | were to say "Where do you live?" and you were to say a place | | 18 | A. Correct. | |
+| 18 | where you do not live on a regular basis as the answer to that, | | 19 | Q. Why did you tell it? | |
+| 19 | do you consider that to be a lie? | | 20 | A. I thought I would seem more juror marketable (gesturing). | |
+| 20 | A. I consider your hypothetical a little silly. | | 21 | Q. You really wanted to be on this jury? | |
+| 21 | Q. It's actually what happened, right? Let me ask you this. | | 22 | A. Yeah. I knew I could do a fair, unbiased job. | |
+| 22 | Do you understand that the main job of a juror is to determine | | 23 | Q. Seems like a strange way to start, by lying, doesn't it? | |
+| 23 | who is telling the truth and who is lying? | | 24 | MR. OKULA: Objection. | |
+| 24 | A. Of course. | | 25 | THE COURT: Sustained. | |
+| 25 | Q. Did you apply that same actumen in determining whether you | | | | |
+
+#### UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL..
+
+| C2frdau5 | Conrad - direct | Page 161 | C2frdau5 | Conrad - direct | Page 163 |
+|-------------------------------------------------------------------|-----------------|----------|--------------------------------------------------------------------|-----------------|----------|
+| 1 Q. Had it occurred to you when you were telling these lies | | | 1 that date? | | |
+| 2 that it was an odd way to start service as a juror, to lie to | | | 2 A. Maybe 25. I'm not really sure. | | |
+| 3 the Court? | | | 3 Q. What was the truthful answer to "What is he retired from," | | |
+| 4 A. I don't know. | | | 4 [REDACTED]? | | |
+| 5 Q. You don't remember whether it occurred to you or not? | | | 5 A. Being a businessman. | | |
+| 6 A. It's a weird question, sir. | | | 6 Q. When was the last time he was a businessman? | | |
+| 7 Q. It's a weird answer, [REDACTED]. | | | 7 A. I guess maybe 20 years ago. | | |
+| 8 MR. OKULA: Objection, Judge. | | | 8 Q. What he was actually retired from was being a criminal, | | |
+| 9 THE COURT: Sustained. Please put a question to the | | | 9 right? | | |
+| 10 witness. | | | 10 A. Please. | | |
+| 11 Q. [REDACTED], was it a deliberate lie? Did you know you were | | | 11 Q. Well -- | | |
+| 12 lying when you said it? | | | 12 A. I don't understand your question. | | |
+| 13 A. Yes. | | | 13 Q. What has your husband done since he left the New Jersey | | |
+| 14 then the judge asked you "Who are the other members of your | | | 14 penitentiary in 2004? | | |
+| 15 household?" You said, "I live with my husband. He's retired | | | 15 A. He's been a very faithful, good husband. | | |
+| 16 at the present time," correct? | | | 16 Q. Has he had a job? | | |
+| 17 A. Yes. | | | 17 A. No. | | |
+| 18 Q. That was true, that you lived with your husband, correct? | | | 18 Q. Did you think that you were misleading the Court by saying, | | |
+| 19 A. Yes. | | | 19 in answer to the question "What is he retired from," "He owns | | |
+| 20 Q. But you never lived with your husband at the address you | | | 20 some bus companies"? | | |
+| 21 had given, correct? | | | 21 A. Owned. | | |
+| 22 A. I didn't give any address on voir dire. | | | 22 Q. That's not what the transcript says. But let's say you | | |
+| 23 Q. You never lived with your husband at your parents' house in | | | 23 said "owned." Did you think you were misleading the Court when | | |
+| 24 Bronxville, did you? | | | 24 the judge said, "What is he retired from?" and you said, "He | | |
+| 25 A. No, no. | | | 25 owned some bus companies"? | | |
+| | | | | | |
+| C2frdau5 | Conrad - direct | Page 162 | C2frdau5 | Conrad - direct | Page 164 |
+| 1 Q. So, you created a false impression that you and your | | | 1 A. No, of course not. | | |
+| 2 husband owned a house there, correct? | | | 2 Q. That wasn't misleading at all? | | |
+| 3 A. I don't know what the judge's impression was. | | | 3 A. No. | | |
+| 4 Q. You were trying to create a false impression that you and | | | 4 Q. Did you apply that same standard of what is or is not | | |
+| 5 your husband were homeowners who owned a house and lived in | | | 5 misleading in acquitting your function as a juror? | | |
+| 6 Bronxville, correct? | | | 6 A. I don't really know what your question means. | | |
+| 7 MR. OKULA: Objection, your Honor. I don't think | | | 7 Q. My question means you have an idea of what is misleading | | |
+| 8 there is anything mentioned about a house there. | | | 8 and what is not misleading, right? | | |
+| 9 THE COURT: Overruled. | | | 9 A. Of course. | | |
+| 10 A. I don't know. | | | 10 Q. You think that what you said here about the bus companies | | |
+| 11 Q. You told the juror that he was retired, and the Court said, | | | 11 is not misleading, correct? | | |
+| 12 "What is he retired from"? | | | 12 A. Not at all. Maybe it's a transcription, "own" or "owned." | | |
+| 13 A. Yes. | | | 13 That's it. | | |
+| 14 Q. You said he owned some bus companies? | | | 14 Q. In fact, did you apply that same standard in your mind of | | |
+| 15 A. Bus companies, yes. | | | 15 what is or is not misleading in evaluating the evidence in this | | |
+| 16 Q. What bus companies does he own? | | | 16 case? | | |
+| 17 A. That was 30 years ago. My husband is 21 years older than I | | | 17 A. Of course we had to, and I had to, and I did. | | |
+| 18 am. Somewhere in Jersey. | | | 18 Q. Then the Court asked you, "Do you work outside the home?" | | |
+| 19 Q. Do you know the name of a bus company? | | | 19 And you answered, "No, I'm a stay-at-home wife," right? | | |
+| 20 A. Chinese ones that explode on I-95. I don't know. No, not | | | 20 A. Correct. | | |
+| 21 really. | | | 21 Q. Then the Court asked you, "Do you have any children," and | | |
+| 22 Q. You said he owns some bus companies. Did he own any bus | | | 22 you said, "No." | | |
+| 23 companies at the time of the voir dire? | | | 23 A. I should have said that I know of. But no, you're correct. | | |
+| 24 A. [REDACTED], no, no. | | | 24 Q. Then the judge said, "What is the highest level of | | |
+| 25 Q. He had not owned any bus companies for some 30 years before | | | 25 education you have attained?" | | |
+
+| C2frdau5 | Conrad - direct | Page 165 | C2frdau5 | Conrad - direct | Page 167 |
+|-------------------------------------------------------------------|-----------------|----------|-------------------------------------------------------------------|-----------------|----------|
+| 1 A. Sir, are we still on 203? | | | 1 Q. Because you suspected that it would stop you from getting | | |
+| 2 Q. Yes. | | | 2 on the jury, you made a deliberate decision, having sworn an | | |
+| 3 A. All right. | | | 3 oath to tell the truth, you made a deliberate decision to lie | | |
+| 4 Q. Actually, it goes over to 204. | | | 4 to this Court? | | |
+| 5 A. OK, thank you. Yes. | | | 5 A. I don't know if I was sworn at that point, but I did not | | |
+| 6 Q. Did you have any trouble understanding the question that | | | 6 reveal the fact that I had a JD and was an attorney. | | |
+| 7 Judge Pauley asked you? | | | 7 Q. No, no, that's not the question I asked. The question | | |
+| 8 A. Not at all. | | | 8 asked is, did you make a deliberate decision to lie to the | | |
+| 9 Q. Did you know that Judge Pauley was going to ask you that | | | 9 Court? | | |
+| 10 question or something very like it? | | | 10 A. Are we getting into the semantics of omissions again? | | |
+| 11 A. Yes, because the prior day the same questions were asked of | | | 11 Q. Did you make a deliberate decision to lie to the Court | | |
+| 12 the other potential jurors. | | | 12 about your highest level of education? | | |
+| 13 Q. When did you make the decision about how you were going to | | | 13 A. Yes. | | |
+| 14 answer that question? Was it right then when he asked you or | | | 14 Q. Did you do that because you believed that otherwise you | | |
+| 15 was it before then? | | | 15 would not be permitted to be on this jury? | | |
+| 16 A. I think it was during the break between the two days. | | | 16 A. Yes. | | |
+| 17 Q. Can you remember how you reached the conclusion that you | | | 17 Q. So it was your idea to thwart the voir dire process by | | |
+| 18 should tell a lie in answer to that question? | | | 18 telling the Court something that wasn't true about your | | |
+| 19 A. Because I knew that anybody with a JD or legal experience | | | 19 background? | | |
+| 20 would be bounced. | | | 20 A. I guess if you want to characterize it that way. | | |
+| 21 Q. That's because there were lawyers who were on trial, right? | | | 21 Q. You said, "I have a BA in English literature in classics | | |
+| 22 A. I don't think the jury knew at that point that there were | | | 22 and I studied archeology abroad," right? | | |
+| 23 attorneys on trial. I'm not sure. I'm not sure. | | | 23 A. Correct. | | |
+| 24 Q. You knew, because Judge Pauley summarized the charges for | | | 24 Q. Did you remember at that moment that you studied law at the | | |
+| 25 you before the voir dire started, that there were lawyers on | | | 25 Brooklyn Law School? | | |
+| C2frdau5 | Conrad - direct | Page 166 | C2frdau5 | Conrad - direct | Page 168 |
+| 1 trial charged with tax fraud in connection with a tax shelter | | | 1 A. Of course. | | |
+| 2 scheme, didn't you? | | | 2 Q. At any point after you told these lies about your | | |
+| 3 A. Yes, I remember now, yes. | | | 3 residence, about how long you lived there, about your owning | | |
+| 4 Q. Now that you remember, you knew that there's no way that a | | | 4 your place, about your highest level of education, at any time | | |
+| 5 lawyer would be left on a jury to decide the conduct of lawyers | | | 5 did you think to yourself, wow, what I just did was wrong? | | |
+| 6 who were being charged with a crime, right? | | | 6 A. Of course I knew it was wrong. | | |
+| 7 A. No, I didn't know that. | | | 7 Q. But did you think to yourself, what I just did was wrong? | | |
+| 8 Q. Didn't you just say that? | | | 8 A. You just asked me that question. | | |
+| 9 A. I didn't know that for a fact. | | | 9 Q. And I'm asking it again because I didn't get an answer. | | |
+| 10 Q. Did you strongly suspect that you would not be allowed to | | | 10 Did you think that? | | |
+| 11 sit on the jury if you revealed that you were a lawyer? | | | 11 A. Yes. | | |
+| 12 A. Of course. | | | 12 Q. How many times did you think that? | | |
+| 13 Q. That was connected, was it not, to the fact that there were | | | 13 A. I really don't know, sir. | | |
+| 14 lawyers on trial here, right? | | | 14 Q. Was it present in your mind throughout the trial that you | | |
+| 15 A. No, no. In any jury nobody wants an attorney. A jury | | | 15 had lied in order to get on the jury? | | |
+| 16 trial does not want an attorney sitting as a juror. | | | 16 A. Probably. | | |
+| 17 Q. If you were trying a case as a lawyer, you wouldn't want an | | | 17 Q. Did you tell other people that you had lied to get on the | | |
+| 18 attorney on your jury either, would you? | | | 18 jury? | | |
+| 19 A. That's incorrect. | | | 19 A. I don't think so, not that I recall. | | |
+| 20 Q. So you're not included in the "no one" you just referred | | | 20 Q. Did you tell other people that you had concealed things to | | |
+| 21 to? | | | 21 get on the jury? | | |
+| 22 A. I'm not sure. | | | 22 A. I don't think so. | | |
+| 23 Q. Didn't you just say no one would want an attorney on their | | | 23 Q. Did you tel | | |
+
+UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL,
+
+| | C2trdau5 Conrad • &act | | |
+|----|-----------------------------------------------------------------|----|-----------------------------------------------------------------|
+| | Page 169 C2trdau5 | | Conrad • SKI |
+| 1 | the answer is no. | | |
+| 4 | I just handed it to Juror No. 2, who was our forewoman, and she | | |
+| s | submitted it to the Court. | | |
+| 7 | present in your mind that you had lied to get on to this jury? | | |
+| 9 | room deliberations, sir. | | |
+| 10 | THE COURT: You can answer that question. | | |
+| 13 | present in your mind that you had lied to get on the jury? | | |
+| 16 | rendered your verdict, when did you stop having it present in | | |
+| 17 | your mind thinking about the fact that you had lied to get on | | |
+| 16 | theiliry? | | |
+| | C2trdau5 Conrad • *met | | |
+| | | 3 | fall and nobody sees it. No. of course the answer is no. |
+| | | S | lawyer? |
+| | | 10 | you whether you were a lawyer? |
+| | | 13 | school, you would have been asked, right? |
+| | | 15 | me from the jury? |
+| | | 17 | were being asked specific questions, did you tell the judge |
+| | | 18 | anything that was true besides your admiration for Swann, |
+| | | 19 | the fact that you have no children" Did you tell him anything |
+| | | 20 | that was true? |
+| 3 | just like he did? | | |
+| 6 | December 15th to tell you to come to court. did you tell the | | |
+| 7 | marshals that you had lied about not being a lawyer? | | |
+| 10 | serve you at your house? | | |
+| is | I know what this is about? | | |
+| 17 | stay outside. But specifically I don't really recall what I | | |
+| 18 | said. | | |
+| 21 | lawyer? | | |
+| 23 | me the subpoena. and that was about it. | | |
+| 25 | had the belief that you didn't lie about being a lawyer because | | |
+| | | | C2trdauS Conrad direct one 172 |
+| | | 1 | residence in Brunxville, not Bronx Village. There were only |
+| | | 2 | seven questions that were posed, I believe. |
+| | | 5 | questions that were asked to the jury panel as a white and then |
+| | | 6 | individually. I revealed the fact that well, whatever you |
+| | | 7 | said before. |
+| | | 9 | last question. That question is, "The Court: All right. Is |
+| | | 10 | thtle anything you think it would be important for us to know |
+| | | 12 | as a juror in this case?" Do you remember him asking that |
+| | | 13 | question? |
+| | | 16 | still available." |
+| | | 24 | important for us to know about you in making a decision as to |
+| | | 25 | whether you should serve as a juror? |
+
+| C2frdau5 | Conrad - direct | Page 173 | C2frdau5 | Conrad - direct | Page 175 |
+|--------------------------------------------------------------------|-----------------|----------|--------------------------------------------------------------------|-----------------|----------|
+| 1 A. I'm sorry. Are you reading from the transcript? | | | 1 A. I answered the question. | | |
+| 2 Q. Just asking you a question. | | | 2 Q. Did you think it would be important for us to know that? | | |
+| 3 A. ██████████ | | | 3 A. No, because remission is remission. | | |
+| 4 Q. When you said that the only thing you thought was relevant | | | 4 THE WITNESS: And I don't think this is the proper | | |
+| 5 for us to know was that you were willing to serve three months | | | 5 forum to me to give a blank HIPAA authorization for the world. | | |
+| 6 or more, did you think there was anything else that we might be | | | 6 Judge. | | |
+| 7 interested in? | | | 7 Q. Let me just ask my questions and go from there. Your | | |
+| 8 A. Of course. The fact that I had a JD. | | | 8 belief was it would not have been of any relevance to us to | | |
+| 9 Q. The fact that the Appellate Division had found in December | | | 9 know that you were an alcoholic, is that right? | | |
+| 10 2007 that your conduct "evinces a shocking disregard for the | | | 10 A. However you want to characterize it. | | |
+| 11 judicial system," would that have been relevant? | | | 11 Q. Would it have been of any relevance to the Court, do you | | |
+| 12 A. No, because it's boilerplate in the First Department to say | | | 12 think it would have been of importance to the Court to know | | |
+| 13 that. | | | 13 that you had been suspended from the practice of law on grounds | | |
+| 14 MR. GAIR: Your Honor, at this point I move the | | | 14 of disability by reason of mental or physical infirmity? | | |
+| 15 admission of PMD Exhibit 14, which is the December 18, 2007 | | | 15 A. Do I think it would have been important? | | |
+| 16 report. | | | 16 Q. Yes. | | |
+| 17 THE COURT: Any objection? | | | 17 A. It's not the truth. It's the boilerplate First Department | | |
+| 18 MR. OKULA: No, your Honor. | | | 18 renderings. | | |
+| 19 THE COURT: PMD Exhibit 14 is received in evidence. | | | 19 MR. GAIR: Your Honor, I move the admission of PMD | | |
+| 20 (Exhibit PMD 14 received in evidence) | | | 20 Exhibit 20, which is the Supreme Court Appellate Division's | | |
+| 21 Q. Whether or not you think it is boilerplate, do you think | | | 21 order of December 9, 2010, Presiding Justice Sachs, Justices | | |
+| 22 that I might want to know that an appellate panel had found | | | 22 ██████████, Sweeney, Nardelli, and McGuire. | | |
+| 23 that your conduct evinces a shocking disregard for the judicial | | | 23 MR. OKULA: No objection, your Honor. | | |
+| 24 system? | | | 24 THE COURT: PMD Exhibit 20 is received in evidence. | | |
+| 25 A. If you take the boilerplate language literally. | | | 25 (Exhibit PMD 20 received in evidence) | | |
+| C2frdau5 | Conrad - direct | Page 174 | C2frdau5 | Conrad - direct | Page 176 |
+| 1 Q. Do you think Judge Pauley would have wanted to know that? | | | 1 MR. GAIR: Your Honor, I'd also like to offer PMD 17. | | |
+| 2 A. Of course. | | | 2 which is the March 29, 2009, testimony of Catherine Conrad in | | |
+| 3 Q. But you didn't tell him that, did you? | | | 3 the Supreme Court Appellate Division departmental disciplinary | | |
+| 4 A. No. | | | 4 committee. | | |
+| 5 Q. Did you think that we might want to know that you had | | | 5 MR. OKULA: No objection. | | |
+| 6 suffered from a terrible disease of alcoholism for more than a | | | 6 THE COURT: PMD Exhibit 17 is received in evidence. | | |
+| 7 decade? Did you think we might want to know that? | | | 7 (Exhibit PMD 17 received in evidence) | | |
+| 8 A. That's your twist on it. | | | 8 Q. Now, you told the disciplinary committee in March of 2009 | | |
+| 9 Q. Do you suffer from alcoholism? | | | 9 that you were an alcoholic, correct? | | |
+| 10 A. One's never cured. | | | 10 A. I'm not sure of my specific words, sir. | | |
+| 11 Q. Have you suffered from alcoholism for more than a decade? | | | 11 Q. If you look at Exhibit 17, page 54, line 3, the question | | |
+| 12 A. I don't know. | | | 12 was asked of you, "Have you been diagnosed by any doctor or any | | |
+| 13 Q. Have you been in and out of treatment programs? | | | 13 facility as an alcoholic? | | |
+| 14 A. Yes, I did. | | | 14 "A. Yes, and I have pancreatitis." | | |
+| 15 Q. Have you admitted under oath you're an alcoholic? | | | 15 Was that the question and did you give that answer | | |
+| 16 A. I'm not sure. | | | 16 under oath? | | |
+| 17 Q. Are you an alcoholic? | | | 17 A. Yes, sir. | | |
+| 18 A. Probably. | | | 18 Q. The pancreatitis in fact is related to alcoholism? | | |
+| 19 Q. Do you think that we would have wanted to know, that the | | | 19 A. Yes. | | |
+| 20 Court would have wanted to know, that you had suffered from | | | 20 Q. Did you think it would be important for the Court to know. | | |
+| 21 alcoholism? | | | 21 in judging your fitness as a juror, that your first attempt to | | |
+| 22 A. I'm not the Court. I can't judge that. | | | 22 be reinstated to the practice of law was rejected by the court | | |
+| 23 | | | | | |
+
+#### UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL.,
+
+| C2trdau5 | Conrad - direct | Page 177 | C2trdau5 | Conrad - direct | Page 179 |
+|------------------------------------------------------------------------|-----------------|----------|-------------------------------------------------------------------|-----------------|----------|
+| 1 Q. Did you attempt to be reinstated to the practice of law | | | 1 Q. 2½ years before February of 2011 would have been -- | | |
+| 2 before February of 2011? | | | 2 A. August 2009. | | |
+| 3 A. I submitted my reinstatement papers, which we have already | | | 3 Q. No, that would have been August 2008. 2½ years before | | |
+| 4 gone over, on February 28th, and they were signed on February | | | 4 February of 2011? | | |
+| 5 26th of 2011. | | | 5 A. Yes, you're correct. | | |
+| 6 Q. Before that, though, you had tried to be reinstated a | | | 6 Q. You were not abstinent from August 2008 on, were you | | |
+| 7 couple of years earlier, right? | | | 7 [REDACTED]? | | |
+| 8 A. I was suspended indefinitely. | | | 8 A. No. | | |
+| 9 Q. You tried to be reinstated, saying that your alcoholism was | | | 9 Q. In fact, you got kicked out of a treatment program in | | |
+| 10 in remission, right? | | | 10 August 2009 because you were drinking, correct? | | |
+| 11 A. The chronology of it is that you have to formally submit | | | 11 A. It was either 2008 or 2009. I'm not specifically certain | | |
+| 12 the reinstatement documents, which happened on February 28, | | | 12 on that. | | |
+| 13 2011. I did not submit any reinstatement documents before that | | | 13 Q. Let's see if we can help you on that. Exhibit Number 29, | | |
+| 14 time. | | | 14 if you would. | | |
+| 15 Q. Let's go to this reinstatement petition, which is | | | 15 MR. GAIR: Your Honor, I move the admission of PMD | | |
+| 16 Exhibit 21, which I believe is already in evidence. Can you | | | 16 number 29, which is a multipage document relating to a case | | |
+| 17 look at Exhibit 21. In particular I'd like you to look at | | | 17 called the People of the State of New York v. Catherine M. | | |
+| 18 Exhibit 4 to that submission, which is a report from Dr. [REDACTED] | | | 18 Rosa? | | |
+| 19 Seligman. | | | 19 THE COURT: Any objection? | | |
+| 20 THE WITNESS: Judge, do I have to go through this in | | | 20 MR. OKULA: No objection, your Honor. | | |
+| 21 open court? | | | 21 THE COURT: PMD Exhibit 29 is received in evidence. | | |
+| 22 THE COURT: Yes. I have ruled on that. I'm directing | | | 22 (Exhibit PMD 29 received in evidence) | | |
+| 23 you to answer. I overruled your counsel's application. | | | 23 Q. Do you sometimes go by the name of Catherine Rosa? | | |
+| 24 Q. Do you see Dr. Seligman's report? | | | 24 A. Socially. | | |
+| 25 A. Yes, sir. | | | 25 Q. When you were arrested for petit larceny in 2009, did you | | |
+| C2trdau5 | Conrad - direct | Page 178 | C2trdau5 | Conrad - direct | Page 180 |
+| 1 Q. You submitted this report as part of your petition for | | | 1 give the name to the police Catherine Rosa? | | |
+| 2 reinstatement, correct? | | | 2 A. Yes, sir. | | |
+| 3 A. Yes. | | | 3 Q. If you look at page 4, a number at the lower right-hand | | |
+| 4 Q. Did you review the report before you submitted it? | | | 4 corner of the document says 16-4. It's a report from the | | |
+| 5 A. Yes. | | | 5 Westchester Department of Community Mental Health. Do you see | | |
+| 6 Q. Did you write the report or did he? | | | 6 that? | | |
+| 7 A. I think it was a combination of him and my attorney. | | | 7 A. Yes. | | |
+| 8 Q. Him and your attorney wrote the report? | | | 8 Q. You were receiving treatment at the Maxwell Institute? | | |
+| 9 A. Mm-hm. | | | 9 A. Yes. It was part of St. Vincent's, yes. | | |
+| 10 Q. If you would look on the second page of Dr. Seligman's | | | 10 Q. Maxwell Institute reported in October of 2009 that you were | | |
+| 11 report, it says near the bottom of the middle paragraph, "She | | | 11 negatively discharged from the program in August 2009 due to | | |
+| 12 has taken the appropriate and effective actions to help | | | 12 ongoing use of alcohol? | | |
+| 13 herself." Do you see that? | | | 13 A. Yes, that's true. | | |
+| 14 A. Which paragraph, sir? | | | 14 Q. You were recommended for a higher level of care, correct? | | |
+| 15 Q. The middle paragraph, the third paragraph on the second | | | 15 A. That's what the report says. | | |
+| 16 page. | | | 16 Q. Were you recommended for a higher level of care? | | |
+| 17 A. [REDACTED], yes. | | | 17 A. No. | | |
+| 18 Q. "She has taken the appropriate and effective actions to | | | 18 Q. You didn't get it, right, a higher level of care? | | |
+| 19 help herself," correct? | | | 19 A. Clinically what do you mean? | | |
+| 20 A. Yes. | | | 20 Q. If you don't understand what I mean, I'll move on to | | |
+| 21 Q. Then it says, "She has been abstinent for over 2½ years and | | | 21 another question. | | |
+| 22 has been committed to her recovery plan." | | | 22 A. Thank you. | | |
+| 23 A. Yes. | | | 23 Q. You submitted a report from Dr. Seligman that was | | |
+| 24 Q. Correct? | | | 24 inaccurate in that it said that you had been abstinent for 2½ | | |
+| 25 A. Yes. | | | 25 years when you had not been abstinent for 2½ years? | | |
+
+| C21frdau5 | Conrad - direct | Page 181 | C21frdau5 | Conrad - direct | Page 183 |
+|--------------------------------------------------------------------|-----------------|----------|--------------------------------------------------------------------|-----------------|----------|
+| 1 A. I was at that time, yes, I was. | | | 1 influence, correct? | | |
+| 2 Q. Now I'd like you to look at Exhibit 21, which is your | | | 2 A. 1997? | | |
+| 3 petition, and specifically paragraph 24 of that petition. This | | | 3 Q. In April of 1998 you were convicted of DUI, correct? | | |
+| 4 is the petition you filed at the end of February 2011, right? | | | 4 A. That was the second one, yes, sir. | | |
+| 5 A. February 28, correct. | | | 5 Q. In the first incident you were charged not only with DUI | | |
+| 6 Q. Under oath. You said that you had not been arrested, | | | 6 but with assault, correct? | | |
+| 7 charged with, indicted, convicted, tried, and/or pleaded guilty | | | 7 A. Either the first or the second. I'm not sure. | | |
+| 8 to the following violations, misdemeanors, and/or felonies | | | 8 Q. In the one where you were charged with assault, who did you | | |
+| 9 during the period of your discipline, correct? | | | 9 assault? | | |
+| 10 A. Correct. | | | 10 A. I believe I punched the cop in his stomach. But that was | | |
+| 11 Q. An outright lie, correct? | | | 11 dropped. | | |
+| 12 A. Yes. | | | 12 Q. That conviction for DUI that involved an arrest for | | |
+| 13 Q. Because you were arrested not once but twice in shoplifting | | | 13 assault, resisting arrest, harassment, and leaving the scene of | | |
+| 14 cases, were you not? | | | 14 the accident, do you think that would have been something that | | |
+| 15 A. Yes. | | | 15 was responsive to Judge Pauley's question about arrests? | | |
+| 16 Q. You were shoplifting very small items from convenience | | | 16 A. Yes. | | |
+| 17 stores, correct? | | | 17 Q. Did you make a deliberate decision to lie about that? | | |
+| 18 A. They obviously weren't that convenient. | | | 18 A. I omitted deliberating, yes. | | |
+| 19 Q. Is there something that you think is funny about these | | | 19 Q. That's the same as a lie, right? | | |
+| 20 proceedings? | | | 20 A. If it has to be folded into that characterization. | | |
+| 21 A. Not at all. | | | 21 Q. In your mind, in your norms, does that have to be folded | | |
+| 22 Q. Do you know that you lied your way on to a jury and your | | | 22 into that characterization? | | |
+| 23 conduct could send people to prison? | | | 23 MR. OKULA: Objection to the form, your Honor. | | |
+| 24 MR. OKULA: Objection, your Honor. | | | 24 THE COURT: Overruled. | | |
+| 25 THE COURT: Sustained. | | | 25 A. Yes. | | |
+| C21frdau5 | Conrad - direct | Page 182 | C21frdau5 | Conrad - direct | Page 184 |
+| 1 Q. Why did you steal envelopes and newspapers and greeting | | | 1 Q. So, you lied about that first arrest and conviction, and | | |
+| 2 cards from a convenience store? | | | 2 then you lied by not revealing that you had another arrest and | | |
+| 3 A. I didn't. It was a bag of shrimp. | | | 3 conviction in September of 1998, correct? | | |
+| 4 Q. So, if the indictment said that you were stealing greeting | | | 4 A. ■, no. It was I believe April of '98 was the second DUI. | | |
+| 5 cards, you never stole any greeting cards, you only stole a bag | | | 5 Q. So you had two DUI convictions? | | |
+| 6 of shrimp? | | | 6 A. Yes, sir. | | |
+| 7 A. Yes, sir. | | | 7 Q. You also had a conviction for aggravated harassment, | | |
+| 8 Q. In both cases, did you steal two bags of shrimp, one in | | | 8 correct? | | |
+| 9 each store? | | | 9 A. Yes. | | |
+| 10 A. I don't recall what the other one was. | | | 10 Q. And criminal contempt? | | |
+| 11 Q. Why did you steal a bag of shrimp? | | | 11 A. I believe so. | | |
+| 12 A. I was drunk. | | | 12 Q. That was because you had violated the protection order and | | |
+| 13 Q. Was that during the period of your abstinence? | | | 13 you were threatening a romantic rival? | | |
+| 14 A. The question sort of doesn't make sense, right? | | | 14 A. It was phonecalls. | | |
+| 15 Q. Do you even remember what you stole from the other store? | | | 15 Q. You were threatening her over the phone? | | |
+| 16 A. It might have been a videotape. | | | 16 A. Correct. | | |
+| 17 Q. The whole venire was asked questions at jury selection | | | 17 Q. Would you say that that was rational behavior? | | |
+| 18 about whether or not they had ever been arrested for or | | | 18 A. Not when one is drinking. | | |
+| 19 convicted of a crime, correct? | | | 19 Q. It's not even rational when one is not drinking, correct? | | |
+| 20 A. I remember, correct. | | | 20 A. I can't be the judge of that. | | |
+| 21 Q. You knew at the time that that question was asked that the | | | 21 Q. Did you think that you should have revealed that answer in | | |
+| 22 truthful answer was that you had been arrested and convicted of | | | 22 response to the Court's question? | | |
+| 23 crimes, correct? | | | 23 A. Yes. | | |
+| 24 A. Yes. | | | 24 Q. You made a deliberate decision not to do so, correct? | | |
+| 25 Q. You had been arrested and convicted for driving under the | | | 25 A. Yes. | | |
+
+UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL,
+
+| C2Frdau5 | Conrad - direct | Page 185 | C2FFDAU6 | Conrad - direct | Page 187 |
+|----------|----------------------------------------------------------------|----------|----------|-----------------------------------------------------------------|----------|
+| 1 | Q. When you did you make the deliberate decision not to reveal | | 1 | Q. How did a judge in the Bronx come to rule upon whether or | |
+| 2 | your criminal arrests and convictions? | | 2 | not a warrant was issued by a different sovereign was defective | |
+| 3 | A. Monday, March 1st, I believe was the first day of voir | | 3 | or not? | |
+| 4 | dire, and I was sitting in the third seat. Judge Pauley | | 4 | A. Because I was a plaintiff in a personal injury case, and | |
+| 5 | started the questioning the second day, I believe that was | | 5 | the defense, I guess ran, ran me, for lack of better terms, and | |
+| 6 | Tuesday, March 2nd, with me. It was probably that evening | | 6 | they came up with this warrant and they wanted to bring it up | |
+| 7 | between the 1st and the 2nd. | | 7 | at trial, and the judge said it's a defective warrant. | |
+| 8 | Q. You thought that you would get thrown off the jury if you | | 8 | Q. I see. So the judge excluded it from evidence, correct? | |
+| 9 | told the truth, right? | | 9 | A. Yes, sir. | |
+| 10 | A. Probably. | | 10 | Q. Did the judge tell you that the warrant -- when was this | |
+| 11 | Q. That's why you lied about it? | | 11 | hearing that the judge did this on? | |
+| 12 | A. Yes. | | 12 | A. July 2, 2010. | |
+| 13 | Q. You also lied in not disclosing the fact that you were | | 13 | Q. Now -- | |
+| 14 | arrested in Winslow, Arizona, on August 4th of 2007, correct? | | 14 | A. Somewhere about. | |
+| 15 | A. I have no idea what the date was. | | 15 | Q. At any time between August 4, 2007 and July 2, 2010, did | |
+| 16 | Q. Do you know that you were arrested in a place called | | 16 | you have reason to believe that there was a warrant for your | |
+| 17 | Winslow, Arizona? | | 17 | arrest? | |
+| 18 | A. Yes, where I was -- yes. | | 18 | A. Just because I know what happens to people who don't show | |
+| 19 | Q. When you were arrested in Winslow, Arizona, that was a | | 19 | up for court, but besides that, no physical proof, no. | |
+| 20 | pretty memorable incident, right? | | 20 | Q. So although you did not physically have a copy of the | |
+| 21 | A. I remember it, of course. | | 21 | warrant, you knew that people who do not show up for court get | |
+| 22 | Q. Of course, because you called the police and told them that | | 22 | a warrant issued by the Court, correct? | |
+| 23 | your husband was beating you, but you ended up being the one | | 23 | A. Yes, sir. | |
+| 24 | who got arrested, correct? | | 24 | Q. Did you think that that is something that if Judge Pauley | |
+| 25 | A. Yes, sir. | | 25 | knew about it that you had skipped on an OR bond and a warrant | |
+| C2Frdau5 | Conrad - direct | Page 186 | C2FFDAU6 | Conrad - direct | Page 188 |
+| 1 | Q. For disorderly conduct, right? | | 1 | had been issued, did you think that would keep you off this | |
+| 2 | A. Yes. | | 2 | jury? | |
+| 3 | Q. You were released on a recognizance bond, correct? | | 3 | A. I'm not in a position to answer that. | |
+| 4 | A. There was no bond. | | 4 | Q. Why did you hide it, then? | |
+| 5 | Q. Do you know what a cognizance bond means? | | 5 | A. I wasn't really thinking about that specific instance. | |
+| 6 | A. I know I was ROR'd. | | 6 | Q. Had you -- when Judge Pauley asked those questions about | |
+| 7 | Q. OR'd? | | 7 | your being -- you understood what the word "arrest" meant? | |
+| 8 | A. ROR'd. | | 8 | A. Yes, sir. | |
+| 9 | Q. So you were let go on a bond that was simply your promise | | 9 | Q. And you were arrested in August 2007 in Arizona, right? | |
+| 10 | to appear for the next hearing, correct? | | 10 | A. If that's the date, yes. | |
+| 11 | A. I'm not sure. | | 11 | Q. Had you forgotten about that incident? | |
+| 12 | Q. Did you appear for the next hearing? | | 12 | A. Of course not. | |
+| 13 | A. ██████, no. | | 13 | Q. So did you make a deliberate decision not to disclose that | |
+| 14 | Q. Have you ever appeared for the next hearing? | | 14 | incident to Judge Pauley? | |
+| 15 | A. I've never subsequently been in Arizona. | | 15 | A. No. It was part of the larger decision not to mention any | |
+| 16 | Q. So you have never appeared for that next hearing, correct? | | 16 | of the arrests, sir. | |
+| 17 | A. There was a defective warrant. | | 17 | Q. Now, you recall that Judge Pauley also asked whether | |
+| 18 | Q. There was a defective warrant, what does that mean? | | 18 | anybody's spouse or family, close family member had any arrests | |
+| 19 | A. I believe there was no date or time or address on it. | | 19 | or convictions. Do you recall that? | |
+| 20 | Q. So you knew a warrant was issued for you? | | 20 | A. He addressed the chosen panel that was sitting there, yes, | |
+| 21 | A. Not really. | | 21 | correct. | |
+| 22 | Q. How do you know it was defective if you don't know it it | | 22 | Q. And you understood that that included you. | |
+| 23 | was issued? | | 23 | A. And my husband. | |
+| 24 | A. The judge in the Bronx deemed it that. | | 24 | Q. You understood that you were being asked has your husband | |
+| 25 | (Continued on next page) | | 25 | ever been arrested or convicted. | |
+
+February IS, 2(112
+
+| C2FFDAU6 | Conrad - direct | Page 189 | C2FFDAU6 | Conrad - direct | Page 191 |
+|----------|-----------------------------------------------------------------|----------|----------|-----------------------------------------------------------------|----------|
+| 1 | A. I understood that, sir. | | 1 | voir dire commenced a year ago on March 1, because that was his | |
+| 2 | Q. And did you know in March of 2011 that your husband had | | 2 | birthday. | |
+| 3 | been in fact arrested and convicted a number of times? | | 3 | Q. Now, another question that was asked of the whole panel was | |
+| 4 | A. Yes, sir. | | 4 | whether you or a close relative had ever been involved in or | |
+| 5 | Q. And did you know that he had been sentenced to prison in | | 5 | appeared as a witness in a variety of types of investigations | |
+| 6 | 1980 for receiving stolen property? | | 6 | including investigations by licensing authorities. | |
+| 7 | A. No, not 1980. | | 7 | A. Yes, sir. And in retrospect, I should have mentioned the | |
+| 8 | Q. Did you know that in 1981 he had been convicted of | | 8 | disciplinary committee proceeding. I didn't just connect the | |
+| 9 | possession of a controlled substance? | | 9 | two at that time. And that was obviously a pertinent issue | |
+| 10 | A. Sir, I don't know the dates. I thought it was in the '70s. | | 10 | that should have been raised. | |
+| 11 | I'm not sure. | | 11 | Q. I see. So on March 1st or 2nd, you didn't think about the | |
+| 12 | Q. Did you know that he had been convicted of a probation | | 12 | fact that you'd participated in a disciplinary proceeding? | |
+| 13 | violation and of making terroristic threats? | | 13 | A. Please say it again. | |
+| 14 | A. That might have been '93. Vaguely I remember. | | 14 | Q. When you were testifying as a juror, potential juror here | |
+| 15 | Q. Did you know that he'd been indicted for check fraud and | | 15 | on March 1 and 2nd, you weren't thinking about the fact that | |
+| 16 | unlawful possession of weapons? | | 16 | you had participated in disciplinary proceedings? | |
+| 17 | A. That was in Manhattanville, Kentucky in like 1976 when he | | 17 | A. No. I thought about testifying in my mind about having my | |
+| 18 | tried to board an airplane with a gun. | | 18 | personal injury case and more along those lines. No, it didn't | |
+| 19 | Q. So that's not the incident in August of 1985 in New Jersey? | | 19 | occur to me. | |
+| 20 | A. Sir, I was ten years old probably then. I don't know. I | | 20 | Q. Even though you had filed your petition for reinstatement a | |
+| 21 | can't tell you. | | 21 | day or two before that? | |
+| 22 | Q. Was he indicted a second time for receiving stolen property | | 22 | A. I just didn't look at it that way. | |
+| 23 | and burglary? | | 23 | Q. You believed that by serving on this jury you could get | |
+| 24 | A. Sir, I don't know. | | 24 | some measure of vindication for yourself, didn't you? | |
+| 25 | Q. Did he get 18 months in prison in 1993 for harassment, | | 25 | A. Not at all. Vindication for what? | |
+| C2FFDAU6 | Conrad - direct | Page 190 | C2FFDAU6 | Conrad - direct | Page 192 |
+| 1 | burglary and terroristic threats? | | 1 | Q. You believed that you could somehow vindicate yourself as | |
+| 2 | A. I don't know. | | 2 | having done something worthwhile after a career that was in | |
+| 3 | Q. Did you know that he was convicted for auto theft and | | 3 | disgrace at that point? | |
+| 4 | served, got a ten-year prison sentence for that? | | 4 | A. Are you trying to say that serving three months on a jury | |
+| 5 | A. No. Seven years, seven months. | | 5 | is akin to some sort of penance? I don't understand really | |
+| 6 | Q. Served seven years and seven months. | | 6 | what you're trying to tell me. It was my civic duty, which I | |
+| 7 | A. Paroled out, yes. | | 7 | performed to the best of my capability and ability and I | |
+| 8 | Q. Did you know him while he was in prison? | | 8 | believe I did it fairly, justly and unbiased. | |
+| 9 | A. No. | | 9 | Q. Was it your civic duty to perjure yourself in this court? | |
+| 10 | Q. You met him afterwards? | | 10 | A. It's nobody's. | |
+| 11 | A. Yes, sir. | | 11 | Q. So you didn't really do your civic duty, did you? | |
+| 12 | Q. And he disclosed his criminal history to you? | | 12 | A. Of course. Rendering the just verdict in an unbiased | |
+| 13 | A. Yes. | | 13 | fashion, I certainly did. | |
+| 14 | MR. OKULA: Objection, your Honor, to marital | | 14 | Q. If you were on trial for a crime, would you want to know | |
+| 15 | communications. | | 15 | that one of the jurors who was judging the credibility of | |
+| 16 | THE COURT: I'll sustain any further inquiry along | | 16 | witnesses and had your fate in his or her hands had perjured | |
+| 17 | that line. | | 17 | themselves repeatedly at voir dire? Would you want to know | |
+| 18 | Q. And you concealed your knowledge about your husband's | | 18 | that? | |
+| 19 | criminal career in order to make sure that you would get a seat | | 19 | MR. OKULA: Objection, your Honor. | |
+| 20 | on this jury, is that correct? | | 20 | THE COURT: Overruled. | |
+| 21 | A. Yes, I concealed his career. | | 21 | A. Probably not, if I was a good criminal. | |
+| 22 | Q. Does your father work for the Justice Department right now? | | 22 | MR. GAIR: Your Honor, this would be a good place to | |
+| 23 | A. Yes, sir. | | 23 | break. | |
+| 24 | Q. How old is he? | | 24 | THE COURT: All right. We're going to take a | |
+| 25 | A. On March 1 he'll be 80. And I remember specifically that | | 25 | ten-minute recess and then we'll reconvene and endeavor to | |
+
+#### UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL.,
+
+| C2FFDAU6 | Conrad - direct | Page 193 | C2FFDAU6 | Conrad - direct | Page 195 |
+|----------|----------------------------------------------------------------|----------|----------|----------------------------------------------------------------|----------|
+| 1 | complete the witness. | | 1 | Q. And you were so anxious to speak with them that you wrote a | |
+| 2 | (Recess) | | 2 | letter to Mr. Okula the very next day, right? | |
+| 3 | THE COURT: Mr. Gair, you may continue. | | 3 | A. I don't know couching in those terms "so anxious" really is | |
+| 4 | BY MR. GAIR: | | 4 | the correct way to do it, but -- | |
+| 5 | Q. Ms. Conrad, do you have a driver's license? | | 5 | Q. Well, you wrote a letter to him in which you told him you | |
+| 6 | A. Yes. | | 6 | wished that you would have had the opportunity to talk to him | |
+| 7 | Q. What name is on your drivers license? | | 7 | correct? | |
+| 8 | A. My married name, Rosa. | | 8 | A. ██████ that's correct, yes. | |
+| 9 | Q. So when you said you use Rosa socially, in fact you use it | | 9 | Q. And you would have welcomed the pleasure to do so, right? | |
+| 10 | for legal purposes too, correct? | | 10 | A. Yes. | |
+| 11 | A. Just on my license. | | 11 | Q. Now, you never made any attempt to contact any of the | |
+| 12 | Q. And when you were arrested, correct? | | 12 | defense lawyers and tell them you would have liked to talk to | |
+| 13 | A. I don't think it matters what name a person uses when | | 13 | them, right? | |
+| 14 | they're arrested. Your NYSID follows you. | | 14 | A. There was no reason to. | |
+| 15 | Q. Now, would I be right in thinking that you identified with | | 15 | Q. But there was a reason to contact the prosecutor? | |
+| 16 | the prosecutors in this case? | | 16 | A. Yes. | |
+| 17 | A. I don't know what you think, sir. | | 17 | Q. And not only -- now, and you wrote a letter to Mr. Okula. | |
+| 18 | Q. Did you identify with the prosecutors in this case? | | 18 | now, this is not preprinted stationery, right, that you wrote | |
+| 19 | A. I don't know what that question means. | | 19 | on? | |
+| 20 | Q. Well, you wrote to the prosecutors after the trial was | | 20 | A. No, no. | |
+| 21 | over, correct? | | 21 | Q. This is just a caption that you made up for the letter, | |
+| 22 | A. Correct. | | 22 | correct? | |
+| 23 | Q. You didn't write to any of the defense lawyers, correct? | | 23 | A. Yeah, on my computer, yes. | |
+| 24 | A. That's correct. | | 24 | Q. On your computer. And where were you sitting when you | |
+| 25 | Q. And not only did you write to the prosecutors, but you | | 25 | wrote that letter on your computer? | |
+| C2FFDAU6 | Conrad - direct | Page 194 | C2FFDAU6 | Conrad - direct | Page 196 |
+| 1 | wrote to the prosecutors the very day after the verdict, isn't | | 1 | A. In front of my cat. | |
+| 2 | that correct? | | 2 | Q. In front of your cat. Was your cat located at 2385 South | |
+| 3 | A. I'm not really sure the exact date, sir. It was late May. | | 3 | Barker Avenue or at 16 Parkview Drive at the time? | |
+| 4 | MR. GAIR: Your Honor, I'd move the admission of PMD | | 4 | A. Neither. It's Barker. | |
+| 5 | Exhibit 7. | | 5 | Q. Where was your cat located at the time you wrote this | |
+| 6 | THE COURT: Any objection? | | 6 | letter, ██████? | |
+| 7 | MR. OKULA: No objection, your Honor. | | 7 | A. Next to my screen. On Barker Avenue, sir. | |
+| 8 | THE COURT: PMD Exhibit 7 is received in evidence. | | 8 | Q. Yeah. And yet you put, once again, that the return address | |
+| 9 | (Exhibit PMD 7 received in evidence) | | 9 | was 16 Parkview Avenue in Bronxville, New York, correct? | |
+| 10 | Q. And if you would look at Exhibit 7, tab 7, you wrote the | | 10 | A. No, Drive. | |
+| 11 | prosecutors on May 25th of 2011, is that correct? | | 11 | Q. You put the address was 16 Parkview Drive in Bronxville, | |
+| 12 | A. Yes. | | 12 | correct? | |
+| 13 | Q. And that was one day after the verdict, the very day after. | | 13 | A. Yes, mm-hmm. Yes. | |
+| 14 | A. I believe the verdict was the 24th. Correct. | | 14 | Q. That's not where you were when you wrote the letter, right? | |
+| 15 | Q. And you were very anxious to talk to the prosecutors, | | 15 | A. Correct. | |
+| 16 | weren't you? | | 16 | Q. And that was not the address you were living at when you | |
+| 17 | A. Not just myself. | | 17 | wrote the letter, correct? | |
+| 18 | Q. Of course, I didn't ask you about anybody else. Were you | | 18 | A. I still consider it both. | |
+| 19 | very anxious to talk to the prosecutors? | | 19 | Q. And that is not the address that goes with the phone number | |
+| 20 | A. Yes. And along with the other eleven jurors, we had wanted | | 20 | that you put right under that, is it? | |
+| 21 | to speak with them after the verdict, when Judge Pauley had | | 21 | A. Excuse me, that's my cell number. | |
+| 22 | come into the jury room to speak with us after. | | 22 | Q. That's exactly right. That is not your parents' home phone | |
+| 23 | Q. Without worrying about what the eleven other people wanted | | 23 | number at 16 Parkview Drive, is it, ██████? | |
+| 24 | or didn't want, were you anxious to speak with them? | | 24 | A. No, it's my cell. | |
+| 25 | A. ██████, sure. | | 25 | Q. It's your cell number. Why don't you tell Judge Pauley why | |
+
+February IS. 2012
+
+## February IS, 2012
+
+| | C2FFDAU6 Conrad • direct Page 197 | | C2FFDAU6 |
+|----|--------------------------------------------------------------------|-------|----------------------------------------------------------------|
+| 1 | you put your cell number on your letter to Mr. Okula? | | |
+| 6 | that way or not? | | |
+| 9 | because that's where you're most accessible. | | |
+| 11 | expectation of a call from Mr. Okula. | | |
+| 13 | did you put a phone number on there? | | |
+| 16 | on there, right? | | |
+| 19 | Mr. Okula, correct? | | |
+| 12 | letter was playful? | | |
+| | C2FFDAU6 Conrad • direct Page 190 | | |
+| 1 | THE COURT: You can answer the question. | | |
+| 4 | that maybe he was on track to take Mr Bharara's job from him? | | |
+| it | Please. | | |
+| 10 | that went with this address 16 Parks ins Drive. did you think | | |
+| ii | about putting that phone number on the letterhead? | | |
+| 14 | letterhead? | | |
+| 17 | the letterhead? | | |
+| 19 | letter I had done. It wasn't conscious. | | |
+| | 21 probably cut and pasted from another letter', Did you just make | | |
+| 22 | that up? | | |
+| 25 | any reason to believe that you cut and pasted this from another | | |
+| | | | Cared • Sect Page 199 |
+| | | 1 | letter. |
+| | | 6 | -I solely held out for two days on the conspiracy charge for |
+| | | 7 | him." referring to David Pane. "I wanted to convict |
+| | | 8 | 100 percent not only on that charge." Do you remember that? |
+| | | 12 | MR. OKULA: Judge, object on 606 grounds. |
+| | | 13 | MR. GAIR: May I respond, your Honor? |
+| | | 14 | THE COURT: No. Overruled. |
+| | | 16 | the conspiracy charge for Parse. I wanted to convict |
+| | | 17 | IOC percent not only on that charge.' Did you tell him that? |
+| | | 20 | Parse should not have been convicted of number I"? |
+| | | | 21 A. •, I don't recall, sir. |
+| | | 23 | 3. "For what? For what? I'll retain myself or my husband. |
+| | | 24 | the convicted felon. For what? For what. sir? To say that I |
+| | | 25 | convicted everybody except the stupid Brubaker? Parse was an |
+| | | | C2FFDAU6 Conrad direct Page 200 |
+| | | 1 | idiot but we let him go because I had es idence enough that he |
+| | | 2 | really, he didn't really, in my mind he shouldn't have been |
+| | | 3 | convicted of number I." |
+| | | 4 | Did you say that to Judge Pauley on December 20th? |
+| | | 7 | the day after the trial, correct? |
+| | | 9 | MR. GAIR: Your ;tenor, I'm going to ask that this |
+| | | 10 | witness be instructed not to discuss the jury deliberations. I |
+| | | 11 | didn't ask about them. |
+| | | 12 | THE COURT: Please -- |
+| | | la | THE COURT: Don't discuss the deliberations or the |
+| | | 15 | split of the vote among the jury. Respect the sanctity of jury |
+| | | 16 | deliberations, Ms. Conrad. |
+| | | 17 | THE WITNESS: Yes. |
+| | | is | THE COURT: And respond directly to counsel's |
+| | | 19 | questions. |
+| | | 20 Q. | isn't it true that the statement you made to Judge |
+| | | 22 | statement you made to Mr. Okula in his letter, in your letter |
+| | | 23 | of May 25th? |
+
+### UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, El' Al..,
+
+| C2FFDAU6 | Conrad - direct | Page 201 | C2FFDAU6 | Conrad - direct | Page 203 |
+|----------|-----------------------------------------------------------------|----------|----------|----------------------------------------------------------------|----------|
+| 1 | been convicted of Count One and that a person should not have | | 1 | Q. Did you believe that Mr. Brubaker was an idiot? | |
+| 2 | been convicted of Count One? Do you see the contradiction | | 2 | A. Yes. | |
+| 3 | there? | | 3 | Q. Did you believe Mr. Parse was just stupid? | |
+| 4 | MR. OKULA: Objection, Judge. Those are not the | | 4 | A. For the backdating, yes. | |
+| 5 | facts. | | 5 | Q. And do you believe that there's really no reason for this | |
+| 6 | THE COURT: Yes, sustained. | | 6 | hearing to be undertaken at all because these people are just | |
+| 7 | Q. Now, in the letter, in the letter you say -- by the way, | | 7 | fricken crooks and it doesn't matter? | |
+| 8 | did you choose the stamp specially for this letter that you put | | 8 | A. Is that a question? | |
+| 9 | on? | | 9 | Q. Yes, it is. | |
+| 10 | A. What? | | 10 | A. Well, the answer is no. | |
+| 11 | Q. Did you choose the stamp that you put on the letter | | 11 | Q. Did you tell the Court that you thought this was all | |
+| 12 | specially? | | 12 | ridiculous on December 20th because these people are fricken | |
+| 13 | A. I don't know what you're talking about. | | 13 | crooks? | |
+| 14 | Q. Well, do you see the copy of the envelope? | | 14 | A. I'm not sure. | |
+| 15 | A. That was, that was the eternity stamps or something like | | 15 | MR. GAIR: May I have a moment, your Honor? | |
+| 16 | that. | | 16 | THE COURT: Yes. Take your time. | |
+| 17 | Q. Do you see -- | | 17 | Q. Were you suspended in the Southern District of New York? | |
+| 18 | A. -- | | 18 | A. Sure. I must have been. Yes. | |
+| 19 | Q. Do you see what the stamp says? | | 19 | Q. Did you know you were suspended in the Southern District of | |
+| 20 | A. Sorry. You're going a little too far here, Mr. Gair. | | 20 | New York when you testified at voir dire? | |
+| 21 | Q. I'm just asking you if you chose that stamp specially. | | 21 | A. Yes. Yes. | |
+| 22 | A. I'm sure I didn't. | | 22 | MR. GAIR: Your Honor, I would move the admission of | |
+| 23 | Q. So you didn't have any other stamps, this was just one that | | 23 | several exhibits. PMD 1, 24, 25, 26 and 45. | |
+| 24 | was laying around? | | 24 | MR. OKULA: No objection, your Honor. | |
+| 25 | A. A book of stamps is a book of stamps, sir. | | 25 | THE COURT: All right. PMD Exhibits 1, 24, 25, 26 and | |
+| C2FFDAU6 | Conrad - direct | Page 202 | C2FFDAU6 | Conrad - direct | Page 204 |
+| 1 | Q. Now, in the letter in the second paragraph, you say, "I | | 1 | 45 are received in evidence. | |
+| 2 | thought that you, Miss ██████ and Mr. ██████ did an | | 2 | (Exhibits PMD 1, 24, 25, 26 and 45 received in | |
+| 3 | outstanding job on behalf of our government." Do you see that? | | 3 | evidence) | |
+| 4 | A. Yes, sir. | | 4 | MR. GAIR: Nothing further, your Honor. Thank you. | |
+| 5 | Q. Is there anything unusual that you see with your knowledge | | 5 | THE COURT: Mr. Okula. | |
+| 6 | of English literature in that sentence? | | 6 | MR. OKULA: I didn't know if there were any other | |
+| 7 | MR. OKULA: Objection to the form, your Honor. | | 7 | defense lawyers who intend to question. | |
+| 8 | A. I don't know what that means. | | 8 | THE COURT: Any other defense counsel wish to inquire? | |
+| 9 | THE COURT: Overruled. | | 9 | MR. ROTERT: Thank you, your Honor, no inquiry for | |
+| 10 | Q. Okay. Did you capitalize the word "our"? | | 10 | Ms. Guerin. | |
+| 11 | A. ██████, yes. | | 11 | THE COURT: Mr. Schectman? | |
+| 12 | Q. And did you capitalize the word "government"? | | 12 | MR. SCHECTMAN: Briefly, Judge. | |
+| 13 | A. Yes. | | 13 | THE COURT: Go ahead. | |
+| 14 | Q. Is it your opinion that in that sentence "our government" | | 14 | DIRECT EXAMINATION | |
+| 15 | is a proper noun? | | 15 | BY MR. SCHECTMAN: | |
+| 16 | A. Government is. | | 16 | Q. Ms. Conrad, could you look at your letter to Mr. Okula | |
+| 17 | Q. Is "our government" a proper known? | | 17 | again, Government Exhibit 1, I believe. | |
+| 18 | A. I don't know. | | 18 | A. Number 7, correct? | |
+| 19 | Q. You capitalized it not because you believed it was a proper | | 19 | THE COURT: PMD 7. | |
+| 20 | noun, but because you wanted to emphasize that you were talking | | 20 | Q. PMD 7. Do you have that? | |
+| 21 | about his government and your government, correct? | | 21 | A. Yes, sir. | |
+| 22 | A. You're slanting that. No. | | 22 | Q. And I think your testimony was that as you sit here today | |
+| 23 | Q. Well, I didn't use the word "our government" and I didn't | | 23 | you don't recall why you capitalized "our government," is that | |
+| 24 | capitalize it. Why did you do it? | | 24 | correct? | |
+| 25 | A. I don't know. | | 25 | A. Yes. | |
+
+February IS. 2012
+
+| C2FFDAU6 | Conrad - direct | Page 205 | C2FFDAU6 | Conrad - direct | Page 207 |
+|-------------------------------------------------------------------|-----------------|----------|--------------------------------------------------------------------|-----------------|----------|
+| 1 Q. You also say that you fought the good fight, correct? | | | 1 Q. Well, you knew most of that stuff. | | |
+| 2 A. Yes. | | | 2 A. I don't even know if I knew most of it. | | |
+| 3 Q. And that was your way of telling Mr. Okula that you were | | | 3 Q. You knew when you married him that he just finished a seven | | |
+| 4 fighting for his side. | | | 4 and a half year sentence. | | |
+| 5 A. Not necessarily. After all of the evidence and | | | 5 A. We got married three years after he finished his sentence. | | |
+| 6 deliberations, the jury felt that we reached a fair verdict. | | | 6 Q. And you knew he was unemployed. | | |
+| 7 Q. I'm not asking about the jury. I'm asking about your | | | 7 A. Yes. | | |
+| 8 writing "I fought the good fight." That was your way of | | | 8 Q. And you knew he hadn't owned a bus company since 25 years? | | |
+| 9 telling Mr. Okula that you were fighting for his side. | | | 9 A. About that. | | |
+| 10 A. At one point. | | | 10 Q. And so when you said today "so are most lawyers," that was | | |
+| 11 Q. And when you say you threw in the towel, I take it that's | | | 11 just smart ass. | | |
+| 12 also a sports image? | | | 12 A. Sure. | | |
+| 13 A. I can't answer that. | | | 13 Q. And when you were asked and the jurors were asked whether | | |
+| 14 Q. At some point you stopped fighting the good fight. | | | 14 you had any unpleasant experiences with lawyers, accountants. | | |
+| 15 A. Meaning? | | | 15 financial planners, you didn't raise your hand on that question | | |
+| 16 Q. That's when you threw in the towel. | | | 16 or in voir dire, did you? | | |
+| 17 A. That was probably an incorrect way to describe the taking | | | 17 A. That's correct. | | |
+| 18 into consideration all of the evidence at the end of the day. | | | 18 Q. And you had had unpleasant experiences with lawyers, hadn't | | |
+| 19 Q. What did you call it? An odd way? A what sort of way? | | | 19 you? | | |
+| 20 A. I said at the end of the day. | | | 20 A. I don't know what you mean. | | |
+| 21 Q. You said some sort of way, improper way? I couldn't | | | 21 Q. Well, I mean, two of them referred you to the Bar | | |
+| 22 remember the objective. | | | 22 Association for disciplinary action. | | |
+| 23 MR. GAIR: Incorrect. | | | 23 A. I don't look at it that way, sir. | | |
+| 24 Q. An incorrect way. That was an incorrect way of saying it. | | | 24 Q. That was a pleasant experience? | | |
+| 25 A. Maybe I said improper, I'm not sure. | | | 25 A. It's just an experience. I don't have my endorphins go | | |
+| C2FFDAU6 | Conrad - direct | Page 206 | C2FFDAU6 | Conrad - direct | Page 208 |
+| 1 Q. So when you said you fought the good fight and you've | | | 1 ██████ over it, so I don't really know what you're getting at. | | |
+| 2 thrown in the towel that was just an incorrect way of saying | | | 2 Q. So you didn't feel you had any obligation to tell the Court | | |
+| 3 you were unbiased. | | | 3 when the Court asked whether you had any unpleasant experiences | | |
+| 4 A. At the end of the day after all the evidence was pored | | | 4 with lawyers that two had referred you to the disciplinary | | |
+| 5 over. | | | 5 committee, that the disciplinary committee brought charges | | |
+| 6 Q. When you say numbers don't lie, what numbers were you | | | 6 against you and that a panel of judges, indeed two panels, | | |
+| 7 referring to? | | | 7 right, suspended you? | | |
+| 8 A. From Dr. DeRosa, the expert. | | | 8 A. A job's a job, sir. That's how I see it. | | |
+| 9 Q. His numbers. | | | 9 Q. So you didn't think you had any obligation to tell the | | |
+| 10 A. Sure, and, to not get specific, but the lack of economic | | | 10 Court any of that because a job's a job. | | |
+| 11 substance in the transactions. | | | 11 A. I don't think that was your original question, but -- that | | |
+| 12 Q. So that's what you were referring to, Mr. Parse's knowledge | | | 12 was another omission, sir. | | |
+| 13 of the lack of economic substance in the transactions? | | | 13 Q. That was an omission? | | |
+| 14 A. No. Not at all. | | | 14 A. Yes. | | |
+| 15 Q. So what is it you were referring to? | | | 15 Q. Now, I take it that one of the things we've learned today. | | |
+| 16 A. It was one component of the whole big picture. | | | 16 Ms. Conrad, is that all of your omissions and lies, whatever | | |
+| 17 Q. I see. Now, I think you told us earlier today you were | | | 17 you call them, were done to make you more marketable as a | | |
+| 18 asked whether your husband is a convicted felon, and you said | | | 18 juror, is that correct? | | |
+| 19 so are most lawyers. And lots of people laughed. Do you | | | 19 A. Those were my words. | | |
+| 20 remember saying that? | | | 20 Q. And that would be correct, right? | | |
+| 21 A. Yes. | | | 21 A. That's what I said. Whether it was correct or not, that's | | |
+| 22 Q. And was that being, I think your word is smart a-s or smart | | | 22 not for me to decide. | | |
+| 23 A-blank-blank? | | | 23 Q. No, that's totally for you to decide. Are those words | | |
+| 24 A. Sure. Mr. Gair was asking me things about my husband that | | | 24 accurate? Were you trying to be a more marketable juror? | | |
+| 25 I'm finding out right now today. | | | 25 A. I said this, yes. | | |
+
+UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET Al..,
+
+| C2FFDAU6 | Conrad - direct | Page 209 | C2FFDAU6 | Conrad - direct | Page 211 |
+|----------|------------------------------------------------------------------|----------|----------|-----------------------------------------------------------------|----------|
+| 1 | Q. So those words are not an omission and they're not a lie, | | 1 | THE COURT: Any inquiry, Ms. McCarthy? | |
+| 2 | they're true? | | 2 | MS. McCARTHY: Your Honor, just a housekeeping master. | |
+| 3 | A. Correct. | | 3 | I'm not sure if this is admitted. PMD 23. Has that been | |
+| 4 | Q. And that is to say that you thought that if these lawyers | | 4 | offered in evidence yet? Mr. Gair offered some at the end. | |
+| 5 | knew who you actually were, and maybe if that judge knew who | | 5 | I'm not sure. | |
+| 6 | you actually were, you wouldn't have been a juror in this case. | | 6 | THE COURT: No. You're offering PMD 23? | |
+| 7 | A. I knew I could be unbiased and fair. | | 7 | MS. McCARTHY: I am your Honor. | |
+| 8 | Q. No, no. Let's try to answer some questions. You knew if | | 8 | THE COURT: Any objection? | |
+| 9 | people knew who you actually were, if these lawyers knew who | | 9 | MR. OKULA: None, your Honor. | |
+| 10 | you actually were, perhaps if that judge knew who you actually | | 10 | THE COURT: All right, PMD 23 is received in evidence. | |
+| 11 | were, you wouldn't have been a juror in this case? You knew | | 11 | (Exhibit PMD 23 received in evidence) | |
+| 12 | that. | | 12 | THE COURT: Mr. Okula, you may inquire. | |
+| 13 | A. Probably not, right. | | 13 | MR. OKULA: Thank you, your Honor. | |
+| 14 | Q. Let's not say probably. Let's see if we can get you to be | | 14 | CROSS-EXAMINATION | |
+| 15 | accurate. | | 15 | BY MR. OKULA: | |
+| 16 | THE COURT: Just stay back by the podium, | | 16 | Q. Ms. Conrad, let me pick up where Mr. Schectman left off | |
+| 17 | Mr. Schectman. | | 17 | where he asked you a question and you answered something about | |
+| 18 | Q. Let's try to be accurate. | | 18 | connecting the dots about determining whether the defendants | |
+| 19 | MR. OKULA: Judge, could we stop the speeching, have | | 19 | were crooks. Do you remember that question? | |
+| 20 | him ask a question? | | 20 | A. Yes. | |
+| 21 | THE COURT: If you have an objection as to form, you | | 21 | Q. Did you make up your mind about those defendants that you | |
+| 22 | can state it. And Mr. Schectman is going to stay behind the | | 22 | found guilty prior to hearing all of the evidence and prior to | |
+| 23 | podium. | | 23 | hearing the judge's instructions in this case? | |
+| 24 | MR. SCHECTMAN: He is indeed. | | 24 | A. Absolutely not. | |
+| 25 | Q. You knew that if these lawyers knew who you really were, | | 25 | Q. Ms. Conrad, you didn't attempt to try to get on this jury | |
+| C2FFDAU6 | Conrad - direct | Page 210 | C2FFDAU6 | Conrad - cross | Page 212 |
+| 1 | there was no chance of your being on this jury? | | 1 | in order to carry out some personal vendetta or agenda with | |
+| 2 | A. I can't read people's minds, sir. | | 2 | respect to the defendants, did you? | |
+| 3 | Q. Well, you read their minds well enough to keep an enormous | | 3 | A. No, sir. | |
+| 4 | amount of information from them, didn't you? | | 4 | Q. And you didn't have any vendetta against the government, | |
+| 5 | A. I can't qualify enormous. | | 5 | correct? | |
+| 6 | Q. Ms. Conrad, I don't want to go through it -- | | 6 | A. Correct. | |
+| 7 | A. More likely than not I wouldn't have been picked, yes. | | 7 | Q. And similarly, you didn't think that you would cast | |
+| 8 | Q. Try a higher standard. Beyond a reasonable doubt you | | 8 | yourself in a good light with the government if you voted in | |
+| 9 | wouldn't have been picked. | | 9 | favor of the government, notwithstanding what the evidence was, | |
+| 10 | A. I can't put words into your mouth, I'm sorry. | | 10 | is that correct? | |
+| 11 | Q. If they knew you were a suspended lawyer with a history of | | 11 | A. I believe so. | |
+| 12 | alcoholism with three misdemeanor convictions, with a husband | | 12 | Q. So when you failed to tell the truth about your education | |
+| 13 | who had seven felony convictions, who had involvement with | | 13 | and failed to reveal your criminal record and your status as a | |
+| 14 | licensing authorities, who had an outstanding warrant from | | 14 | suspended attorney, it was not because you were biased against | |
+| 15 | Arizona, is it your view that these lawyers would have seen you | | 15 | one party or another, is that correct? | |
+| 16 | as a different person, a far different person than the one you | | 16 | A. Correct. | |
+| 17 | portrayed yourself to be? | | 17 | Q. Did you have any personal bias or animus against Paul | |
+| 18 | A. I would think the defense counsel would be ██████ to have me. | | 18 | Daugerdas at the beginning of the case? | |
+| 19 | Q. Why is that, Ms. Conrad? | | 19 | A. No, not at all. I didn't know anybody. | |
+| 20 | A. Well, my husband seems to be a professional defendant, so I | | 20 | Q. So you didn't know any of the defendants, is it fair to say | |
+| 21 | probably would have in their mind been a keeper for their side. | | 21 | that you had no personal bias or animus or feelings one way or | |
+| 22 | Q. Because your view is they wanted people who were crooks | | 22 | another with respect to them, is that fair? | |
+| 23 | because they were crooks. | | 23 | A. That's absolutely correct. | |
+| 24 | A. If that's connecting the dots logically. | | 24 | Q. And it's true, isn't it, Ms. Conrad, that you hadn't made | |
+| 25 | MR. SCHECTMAN: I'll stop there. | | 25 | up your mind once you were selected to be a juror in this case | |
+
+| C2FFDAU6 | Conrad - cross | Page 213 | C2FFDAU6 | Conrad - cross | Page 215 |
+|----------|-----------------------------------------------------------------|----------|----------|-----------------------------------------------------------------|----------|
+| 1 | before you started hearing any evidence, is that correct? In | | 1 | A. No. | |
+| 2 | other words, you hadn't prejudged the case after you were | | 2 | Q. Now, Mr. Gair went through and Mr. Schectman did also to | |
+| 3 | selected that you were going to find the defendants guilty or | | 3 | some extent some of your criminal cases with you. Do you | |
+| 4 | rule in favor of the government, is that correct? | | 4 | remember that? | |
+| 5 | A. That's correct, yes. | | 5 | A. Yes. | |
+| 6 | Q. And is it also true that you didn't make up your mind with | | 6 | Q. For instance, you went through your driving under the | |
+| 7 | respect to the guilt or innocence of any of the defendants | | 7 | influence offenses and your harassment offense, the contemp | |
+| 8 | until you heard all the evidence in the case and listened to | | 8 | offense and the shoplifting offenses. Do you remember that? | |
+| 9 | the judge's instructions, is that fair? | | 9 | A. Yes. | |
+| 10 | A. Absolutely. | | 10 | Q. And were you also asked about the disorderly conduct | |
+| 11 | Q. Let me pick up on a section where Mr. Gair was asking you | | 11 | offense that you were arrested for that you didn't appear on in | |
+| 12 | about things you said with respect to David Parse. Do you | | 12 | Winslow, Arizona. Do you recall that? | |
+| 13 | remember those questions? | | 13 | A. Yes, sir. | |
+| 14 | A. Yes. | | 14 | Q. Now, none of those cases, Ms. Conrad, had anything to do | |
+| 15 | Q. And Mr. Gair referenced the letter that you sent to me | | 15 | with the subject matter involved in this trial, correct? | |
+| 16 | after the return of the verdict, do you remember that? | | 16 | A. That's correct. | |
+| 17 | A. Yes. | | 17 | Q. In other words, these offenses, those local offenses that | |
+| 18 | Q. And you were also asked questions about the fact that you | | 18 | you were arrested for, none of them had anything to do with | |
+| 19 | referred to fighting the good fight. Do you recall that? | | 19 | taxes or tax evasion or tax shelters, is that fair? | |
+| 20 | A. Yes. | | 20 | A. That's correct. | |
+| 21 | Q. Without getting into your deliberations with the other | | 21 | Q. And is it also fair, Ms. Conrad, that your involvement in | |
+| 22 | jurors, is it correct that as you said in the letter that you | | 22 | those criminal cases did not cause you to be biased in one | |
+| 23 | viewed initially during your, when you began deliberating, that | | 23 | matter or another against any party or any attorney in this | |
+| 24 | Mr. Parse should have been found guilty? | | 24 | case? | |
+| 25 | A. Yes. | | 25 | A. That's correct. | |
+| C2FFDAU6 | Conrad - cross | Page 214 | C2FFDAU6 | Conrad - cross | Page 216 |
+| 1 | Q. And you also note in your letter, though, that you | | 1 | Q. Now, let me ask you this, Ms. Conrad. Did the fact that | |
+| 2 | ultimately relented after hearing a jury charge from Judge | | 2 | you were a criminal defendant in a prior case affect you from | |
+| 3 | Pauley about the definition of knowingly and willfully, | | 3 | fairly and impartially judging the evidence in this case and | |
+| 4 | correct? | | 4 | weighing and applying Judge Pauley's legal instruction? | |
+| 5 | A. Yes. | | 5 | A. Absolutely not. | |
+| 6 | Q. So is it fair to say that when you personally deliberated | | 6 | Q. Did the fact that you were arrested by a police officer on | |
+| 7 | with respect to Mr. Parse, you reached your conclusion based on | | 7 | a number of occasions in your criminal cases in any way affect | |
+| 8 | the legal instruction that Judge Pauley gave you and without | | 8 | your ability to be fair and impartial? | |
+| 9 | bias to any side. Fair? | | 9 | A. No. | |
+| 10 | A. 100 percent. Correct. | | 10 | Q. Did your involvement in the disciplinary proceedings where | |
+| 11 | Q. Now, when you were selected to serve on the jury, did you | | 11 | lawyers made complaints about you and you were asked questions | |
+| 12 | have any personal knowledge with respect to any of the | | 12 | by disciplinary counsel, did that affect your ability to | |
+| 13 | defendants in this case? | | 13 | carefully and appropriately and fairly weigh the evidence and | |
+| 14 | A. No, none. | | 14 | the legal instructions in this case? | |
+| 15 | Q. And is it also fair that you didn't have any personal | | 15 | A. No, not at all. | |
+| 16 | knowledge of any of the defense lawyers, correct? | | 16 | Q. Did the fact that you were a suspended attorney affect your | |
+| 17 | A. Correct. | | 17 | impartiality in this case? | |
+| 18 | Q. You didn't know any of the prosecutors in the case or any | | 18 | A. No. | |
+| 19 | of the IRS agents, correct? | | 19 | Q. Now, do you remember you received legal instructions from | |
+| 20 | A. No. That's correct. | | 20 | Judge Pauley on a number of occasions during the case, both | |
+| 21 | Q. And you weren't factually involved in any of the underlying | | 21 | during voir dire at the beginning of the trial and at the end | |
+| 22 | events at trial, correct? | | 22 | of the trial? | |
+| 23 | A. Never. | | 23 | A. Yes. | |
+| 24 | Q. And did you have any financial motive in the outcome of the | | 24 | Q. And in particular, do you remember a jury instruction that | |
+| 25 | case? | | 25 | went somewhat, I know it's a long time ago and you may not | |
+
+#### UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL,
+
+## UNITED STATES OF AMERICA. v PAUL NI. DAUGERDAS, ET AL., February 15, 2012
+
+| C2FFDAU6 | Conrad - cross | Page 217 | C2FFDAU6 | Conrad - cross | Page 219 |
+|----------|-----------------------------------------------------------------|----------|----------|-----------------------------------------------------------------|----------|
+| 1 | remember every word, but do you remember an instruction that | | 1 | Q. And that was in a way justifying the result that you | |
+| 2 | went along these lines: You will have to decide what the facts | | 2 | reached, correct, personally? | |
+| 3 | are from the evidence that will be presented in this courtroom | | 3 | A. That's fair, yes. | |
+| 4 | and then apply those facts to the law as I give it to you. | | 4 | Q. And when you referred to Dr. DeRosa when Mr. Schectman was | |
+| 5 | Do you recall that? | | 5 | asking you, I think you mentioned that you found it personally. | |
+| 6 | A. Yes. | | 6 | not going into your deliberations, but convincing, Dr. DeRosa's | |
+| 7 | Q. Did you follow that instruction, Ms. Conrad? | | 7 | testimony about the lack of economic substance, is that fair? | |
+| 8 | A. Yes. | | 8 | A. ██████ yes. | |
+| 9 | Q. And another instruction went something along the lines that | | 9 | Q. Did you pay careful attention to the testimony of all | |
+| 10 | the law requires your decision be based solely on the evidence | | 10 | witnesses? | |
+| 11 | before you. Anything I direct you to disregard as being | | 11 | A. Shanbrom lost me, but yes. | |
+| 12 | excluded because it's not legally admissible, further, anything | | 12 | Q. And in fact you noted in your letter that you didn't find | |
+| 13 | that you may see or hear when the Court is not in session may | | 13 | very compelling the testimony of Mr. Shanbrom, correct? | |
+| 14 | not be considered. The only competent evidence is evidence | | 14 | A. That's correct. | |
+| 15 | received in this courtroom. Do you remember that instruction? | | 15 | Q. So is it fair to say that that example is emblematic of | |
+| 16 | A. Not word-for-word, but the general gist, yes. | | 16 | your view that you didn't call everything in the government's | |
+| 17 | Q. The substance of it, do you remember that? | | 17 | favor because you found government witness Paul Shanbrom | |
+| 18 | A. Yes. | | 18 | unconvincing, is that a fair word? | |
+| 19 | Q. And did you follow that instruction? | | 19 | A. More than fair. | |
+| 20 | A. Yes. | | 20 | Q. Now, is that indicative, Ms. Conrad, of what you said | |
+| 21 | Q. Did you render your verdict, Ms. Conrad, based solely on | | 21 | earlier, that you based your verdict in this case based on what | |
+| 22 | the evidence presented at trial and in the context of the law | | 22 | you saw in this courtroom from the witness stand and the | |
+| 23 | that Judge Pauley gave to you in his instructions and not based | | 23 | evidence you heard and applying the instructions from Judge | |
+| 24 | on any bias, prejudice or sympathy? | | 24 | Pauley? | |
+| 25 | A. Yes. | | 25 | A. Yes, in totality. | |
+| C2FFDAU6 | Conrad - cross | Page 218 | C2FFDAU6 | Conrad - cross | Page 220 |
+| 1 | Q. Now, Ms. Conrad, you noted earlier in your testimony that | | 1 | Q. After all, you voted to acquit Mr. Brubaker, correct? | |
+| 2 | you obtained your law degree from Brooklyn law school, correct? | | 2 | A. Yes. | |
+| 3 | A. Yes. | | 3 | Q. And you voted to acquit Mr. Parse on certain charges, | |
+| 4 | Q. Your practice consisted, did it not, of litigation, | | 4 | correct? | |
+| 5 | primarily in personal injury matters, is that fair? | | 5 | A. Correct. | |
+| 6 | A. For the most part yes. | | 6 | Q. Just a few more questions with respect to some of the | |
+| 7 | Q. And you served as a contract attorney for certain | | 7 | instructions you were given. Do you remember Judge Pauley | |
+| 8 | plaintiffs' lawyers, is that correct? | | 8 | instructed you at the end of the case in his instructions that | |
+| 9 | A. Yes. | | 9 | under your oath as jurors you are not to be swayed by fear, | |
+| 10 | Q. In carrying out your role as a juror is it fair to say that | | 10 | prejudice, bias or sympathy, you're to be guided solely by the | |
+| 11 | you disregarded any other ideas or notions or beliefs about the | | 11 | evidence in the case. Do you remember an instruction along | |
+| 12 | law that you previously had in reaching your verdict in this | | 12 | that line? | |
+| 13 | case? | | 13 | A. Yes. | |
+| 14 | A. That's a fair statement, yes. | | 14 | Q. And is it true, Ms. Conrad, that in spite of all that we | |
+| 15 | Q. Let's go back for just one moment to the letter that you | | 15 | spoke about earlier today that you based your verdict which | |
+| 16 | were asked about and you referred to Dr. DeRosa and the numbers | | 16 | involved an acquittal of Mr. Brubaker and a partial acquittal | |
+| 17 | with respect to Mr. Schectman's questions, do you remember | | 17 | of Mr. Parse based on the evidence in this courtroom and the | |
+| 18 | that? | | 18 | instructions that Judge Pauley gave you? | |
+| 19 | A. Yes. | | 19 | A. That's correct. | |
+| 20 | Q. He asked you, Mr. Schectman did, about a statement that you | | 20 | Q. Were you biased against the defendants in any manner or | |
+| 21 | made that numbers don't lie. Do you recall that? | | 21 | form? | |
+| 22 | A. Just from looking at the letter. | | 22 | A. Not at all. | |
+| 23 | Q. Yes, if you look four lines from the bottom where you said, | | 23 | (Continued next page) | |
+| 24 | quote, "I'm a purist and numbers don't lie"? | | 24 | | |
+| 25 | A. Yes. | | 25 | | |
+
+February IS. 2012
+
+UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL,
+
+| C2frdau7 | Conrad - cross | Page 221 | C2frdau7 | Conrad - redirect | Page 223 |
+|----------|-----------------------------------------------------------------|----------|----------|-----------------------------------------------------------------|----------|
+| 1 | MR. OKULA: Let me have one moment, your Honor. | | 1 | BY MR. GAIR: | |
+| 2 | Q. Ms. Conrad, a few more questions. I'm sorry. Are you | | 2 | Q. Can you explain to us how it is you can remember the | |
+| 3 | ready? | | 3 | substance of many specific jury instructions that you received | |
+| 4 | A. Yes. | | 4 | 8½ months ago when you cannot remember things that you said to | |
+| 5 | Q. At the time that you were selected to serve as a juror in | | 5 | Judge Pauley on December 20th when you appeared in this court? | |
+| 6 | this case, your status was a suspended New York attorney, | | 6 | A. Because I'm familiar with the PJI and they are sort to | |
+| 7 | correct? | | 7 | basically the same IN state court as in federal court. | |
+| 8 | A. Yes. | | 8 | Q. Did you have any trouble understanding my questions when I | |
+| 9 | Q. You were not working, correct? | | 9 | was asking you questions earlier? | |
+| 10 | A. Correct. | | 10 | A. To which are you referring? | |
+| 11 | Q. Is it fair to say that even though the daily witness fee | | 11 | Q. Any of them. | |
+| 12 | that you received for your service was rather meager, it was | | 12 | A. I don't have the transcript written in my head. | |
+| 13 | not irrelevant to you in your service as a juror? | | 13 | Q. You certainly didn't have any trouble with Mr. Okula's | |
+| 14 | A. Yes, that's correct. | | 14 | questions, correct? | |
+| 15 | Q. After all, you were basically out of work, correct? | | 15 | A. He's pretty straightforward. | |
+| 16 | A. Yes. | | 16 | Q. You didn't find anything that Mr. Okula said that you | |
+| 17 | Q. You referred earlier during Mr. Gair's questioning to a | | 17 | disagreed with, correct? | |
+| 18 | motivation that you had in the form of intellectual curiosity | | 18 | A. Correct. | |
+| 19 | with respect to tax shelters, is that correct? | | 19 | Q. Did you know what Mr. Okula was going to ask you today? | |
+| 20 | MR. GAIR: Objection to the form of the question, your | | 20 | A. No, I don't. This is the first time I've ever actually | |
+| 21 | Honor. | | 21 | spoken to Mr. Okula. | |
+| 22 | MR. OKULA: I'll rephrase it, your Honor. | | 22 | Q. Mr. Okula asked you about whether or not you wanted to see | |
+| 23 | THE COURT: All right. | | 23 | through this trial as a juror. Do you remember that question? | |
+| 24 | Q. You remember in Judge Pauley's initial instructions he | | 24 | A. Yes. | |
+| 25 | described in general terms the subject matter of the case, in | | 25 | Q. You did, right? | |
+| C2frdau7 | Conrad - cross | Page 222 | C2frdau7 | Conrad - redirect | Page 224 |
+| 1 | particular tax charges, correct? | | 1 | A. Yes. | |
+| 2 | A. Yes. | | 2 | Q. You did that in the context of just a day or two before the | |
+| 3 | Q. You heard certain things about tax shelters in the | | 3 | trial having filed a petition for readmission or reinstatement | |
+| 4 | introductory instructions, correct? | | 4 | to the bar, is that correct? | |
+| 5 | A. Vaguely. | | 5 | A. That's the correct chronology, yes. | |
+| 6 | Q. Is it correct that the subject matter of the case was of | | 6 | Q. You believed that by seeing through this trial, by serving | |
+| 7 | some interest to you when you were answering questions during | | 7 | as a juror for a lengthy trial, you could help demonstrate your | |
+| 8 | voir dire and considering your motives for serving on the jury? | | 8 | stability to the bar authorities, correct? | |
+| 9 | A. Yes, it piqued my curiosity. I had no experience ever with | | 9 | A. No. It's apples and oranges. The two thoughts never | |
+| 10 | tax work. | | 10 | crossed. | |
+| 11 | Q. Had you ever sat as a juror in a federal criminal case | | 11 | Q. Never occurred to you once that seeing this through might | |
+| 12 | before? | | 12 | be something that would be helpful to you with the bar | |
+| 13 | A. No. | | 13 | authorities? | |
+| 14 | Q. Was one of your motivations a desire to see a trial through | | 14 | A. Not at all. It was my civic duty. | |
+| 15 | with this complexity from beginning to end? | | 15 | Q. Which part was your civic duty? The part where you lied? | |
+| 16 | A. Partially. | | 16 | A. No, of course not. | |
+| 17 | Q. One final question, Ms. Conrad. Is it correct that you | | 17 | Q. Mr. Okula asked you some questions about the instructions | |
+| 18 | waited until Judge Pauley told you it was appropriate for you | | 18 | that Judge Pauley gave you. Do you remember those? | |
+| 19 | to begin your deliberations and the consideration of the | | 19 | A. I remember both. | |
+| 20 | evidence based on his instructions, and that's what guided your | | 20 | Q. You said that you had followed Judge Pauley's instructions. | |
+| 21 | verdict in this case? | | 21 | correct? | |
+| 22 | A. Yes. | | 22 | A. Yes. | |
+| 23 | MR. OKULA: I have nothing further, Judge. | | 23 | Q. But the truth is you only followed those of Judge Pauley's | |
+| 24 | THE COURT: Redirect examination, Mr. Gair. | | 24 | instructions that you wanted to follow, correct? | |
+| 25 | REDIRECT EXAMINATION | | 25 | A. I don't | |
+
+| C2frdau7 | Conrad - redirect | Page 225 | C2frdau7 | Conrad - redirect | Page 227 |
+|----------|----------------------------------------------------------------|----------|----------|-----------------------------------------------------------------|----------|
+| 1 | Q. Well, did you follow all of Judge Pauley's instructions or | | 1 | A. No, but I did. | |
+| 2 | only the ones that you wanted to follow? | | 2 | Q. Do I look like I know what the PJI is? | |
+| 3 | A. That's the job of the trier of fact, which I was a trier of | | 3 | A. Yes. You're a professor. | |
+| 4 | fact. | | 4 | Q. Would you agree with me then that since you did for the | |
+| 5 | Q. Did you follow all of Judge Pauley's instructions or only | | 5 | follow Judge Pauley's initial instruction at the start of the | |
+| 6 | those instructions that you wanted to follow? | | 6 | trial, you did not in fact follow all of his instructions? | |
+| 7 | A. Probably all of them. | | 7 | A. You're mischaracterizing it. | |
+| 8 | Q. All of them, every single one, right? | | 8 | Q. It's a simple question, yes or no. Since you did not | |
+| 9 | A. I don't have the PJI in front of me. | | 9 | follow the instruction to tell the truth, did you follow all of | |
+| 10 | Q. But as far as you know, of all the ones Mr. Okula | | 10 | his instructions? | |
+| 11 | mentioned, you followed them, right? | | 11 | A. Regarding the verdict, yes. | |
+| 12 | A. More likely than not. | | 12 | Q. Did you follow all of Judge Pauley's instructions? | |
+| 13 | Q. And of all the other instructions he gave you, you followed | | 13 | A. Not with respect to the voir dire. | |
+| 14 | them, is that correct? | | 14 | Q. Therefore, you did not follow all of his instructions, is | |
+| 15 | A. I can't answer that. | | 15 | that correct? | |
+| 16 | Q. You know for a fact you didn't follow all those | | 16 | A. If you need to connect the dots like that. | |
+| 17 | instructions, don't you? | | 17 | Q. Did you follow all of his corrections? | |
+| 18 | A. No, I don't think that's correct. | | 18 | A. Yes. In rendering a correct verdict, yes. | |
+| 19 | Q. Didn't he tell you at the very start of the trial that you | | 19 | Q. Now you're saying you did follow all of his instructions. | |
+| 20 | had to speak the truth to tell about your background in order | | 20 | Let me try and get this very simply. Can you answer my | |
+| 21 | to even be seated as a juror? | | 21 | question? Taking into account the fact that you perjured | |
+| 22 | A. He also told us to render a fair verdict -- | | 22 | yourself repeatedly at voir dire, did you follow all of his | |
+| 23 | Q. No, no. | | 23 | instructions? | |
+| 24 | A. -- which we did. | | 24 | A. I think you just answered the question. | |
+| 25 | Q. Do you see the difference between your answers to my | | 25 | Q. Why don't you answer it. | |
+| C2frdau7 | Conrad - redirect | Page 226 | C2frdau7 | Conrad - redirect | Page 228 |
+| 1 | questions and Mr. Okula's questions? | | 1 | A. Besides the voir dire, yes. | |
+| 2 | A. Sure: Splitting hairs and semantics. | | 2 | Q. Including the voir dire, did you follow all of Judge | |
+| 3 | Q. Exactly. You're splitting hairs and you're engaging in | | 3 | Pauley's instructions? | |
+| 4 | semantics? | | 4 | A. Not with my omissions, no. | |
+| 5 | MR. OKULA: Objection, your Honor. | | 5 | Q. Not with your lies, right? | |
+| 6 | THE COURT: Overruled. | | 6 | A. However you want to characterize it. | |
+| 7 | Q. Let me ask you this, Ms. Conrad. Did Judge Pauley give you | | 7 | Q. Therefore, you picked which of Judge Pauley's instructions | |
+| 8 | an instruction as a juror to tell the truth? | | 8 | you were going to follow and which of those that you were not | |
+| 9 | A. I'm sure he did, yes. | | 9 | going to follow, is that correct? | |
+| 10 | Q. Did you tell the truth? | | 10 | A. No. | |
+| 11 | A. By rendering an unbiased verdict. | | 11 | Q. Was it random that you followed some of his instructions | |
+| 12 | Q. Did you tell the truth? | | 12 | and didn't follow others? | |
+| 13 | A. Yes. | | 13 | A. I didn't follow the instructions in voir dire. | |
+| 14 | Q. You told the truth, the whole truth, and nothing but the | | 14 | Q. You chose, you picked that instruction not to follow, | |
+| 15 | truth? | | 15 | correct? | |
+| 16 | A. You're asking me about the voir dire? | | 16 | A. Yes. | |
+| 17 | Q. Yes. That was an instruction he gave you, wasn't it? | | 17 | Q. You want us to take your assurance that you didn't pick any | |
+| 18 | A. That's correct. | | 18 | other instructions not to follow, correct? | |
+| 19 | Q. Did you tell the truth? Did you follow that instruction? | | 19 | MR. OKULA: Objection. | |
+| 20 | A. No. | | 20 | THE COURT: Sustained. | |
+| 21 | Q. So, when you just said a couple of moments ago that you | | 21 | Q. In your opinion, Ms. Conrad, did your perjury in voir dire | |
+| 22 | followed those instructions, you were lying right then? | | 22 | affect your ability to act as a fair and impartial juror? | |
+| 23 | A. That's incorrect. I thought we were on the same page | | 23 | A. No, not at all. | |
+| 24 | talking about the PJI at the end of the trial. | | 24 | Q. Ms. Conrad, did I understand you to say that you thought | |
+| 25 | Q. Did I ever mention the PJI? | | 25 | that it was basically no harm/no foul as far as the defense was | |
+
+| | C2Irdau7 Conrad rednect Page 229 | | |
+|----|-----------------------------------------------------------------|----|------------------------------------------------------------------|
+| 1 | concerned at the von dire that you didn't reveal your criminal | | |
+| 2 | history because the defendants would want criminals on the | | |
+| 3 | jury? | | |
+| 5 | mouths. | | |
+| 7 | you thought at the time that they would be jumping up and down | | |
+| e | if they knew that you had a husband for a criminal -- | | |
+| 9 | criminal for a husband? Didn't you say that? | | |
+| 12 | of the defendants, which I was not, either the prosecution or | | |
+| 13 | the defense. I was unbiased. | | |
+| 15 | defendants' perspective because, if anything. somebody who was | | |
+| 16 | marred to a criminal would tend to favor other criminals, | | |
+| 17 | right? | | |
+| 19 | MR. GAIR: Nothing further, your Honor. | | |
+| 20 | THE COURT: Mr. Shechtman? | | |
+| 21 | MR. SHECHTMAN: be brief, your Honor. | | |
+| 22 | CROSS-EXAMINATION | | |
+| 23 | BY MR. SHECHTMAN: | | |
+| 25 | correct, and you're reluctant to use the word "lie"? | | |
+| | C2Irlau7 Conrad cross | | |
+| | | | C2Irdau7 Conrad cross Page 231 |
+| | | 3 | part, and you agreed, on the \$40 per day. is that correct" Was |
+| | | 4 | that one of your motives for wanting to be on the jury? |
+| | | 7 | legal career for \$40 a day. were you? |
+| | | 9 | December 18, 2007, when I got suspended. |
+| | | 12 | didn't you? |
+| | | 15 | description of the case piqued your curiosity. Was that one of |
+| | | 16 | your motives? |
+| | | 23 | motives that you wanted to be on this case because it piqued |
+| | | 24 | your curiosity? |
+| 3 | Government Exhibit 2, when you told the Court. "we travel: you | | |
+| 4 | and your husband, was that a true statement? | | |
+| 11 | Jersey? | | |
+| 14 | MR. OKULA: I'm sorry. I'm having a hard time | | |
+| is | hearing. | | |
+| 23 | omitted New Jersey and the elderly aunt, so that you would seem | | |
+| 24 | like you were a more marketable juror? | | |
+| | | | Conrad cross Page 232 |
+| | | | 1 Q. And you thought it was worth lying about your background to |
+| | | 2 | be on a case because it piqued your curiosity? |
+| | | s | the S40 a day -- |
+| | | 10 | stipend was partly a factor? |
+| | | 13 | didn't lie because the case piqued your curiosity, are we |
+| | | 14 | correct on that? |
+| | | 20 | dollars and cents. the \$40 and change or whatever- and keeping |
+| | | 22 | the dynamics of it. |
+| | | 24 | you would say. because I wanted to be in a courtroom? |
+
+UNITED STATES OF AMERICA, v PAUL M. DA CGERDAS, ET AL,
+
+| | C2frdau7 Conrad • cross Page 233 | | |
+|----|----------------------------------------------------------------|----|-----------------------------------------------------------------|
+| 1 | sir. | | |
+| 3 | considering bringing perjury charges against you? | | |
+| 4 | MR. OKULA: Objection, your Honor. | | |
+| 6 | MR. OKULA: Unfair characterization. | | |
+| 7 | THE COURT: Sustained. | | |
+| 9 | lied repeatedly in this courtroom, the government might bring | | |
+| 10 | criminal charges against you? | | |
+| 13 | today, did you? | | |
+| 18 | testimony you gave this morning, what conclusions should we | | |
+| 19 | draw from that? | | |
+| 22 | get use immunity, and this afternoon you told us, just now, it | | |
+| 23 | was a large possibility. Which of those is true? | | |
+| 25 | invoked my Fifth Amendment privilege. | | |
+| | | | C2frdau7 Conrad • cross Page 235 |
+| | | 3 | put off? |
+| | | 8 | likely consequences to you other than this unpleasant hearing |
+| | | 9 | for having perjured yourself in this courtroom? |
+| | | 12 | you? |
+| | | 15 | you will be determined by what you refer to as "our |
+| | | 16 | government," is that correct? |
+| | | 17 | MR. OKULA: Objection. |
+| | | is | THE COURT: Overruled. |
+| | | 22 | government"? |
+| | | 24 | government it would be. But we're sitting here in the Southern |
+| | | 25 | District, so kudos, I guess you're correct. |
+| | C21rdau7 Conrad • cross Page 234 | | |
+| 2 | immunity or not. a distinct possibility that you would be | | |
+| 3 | charged with perjury? | | |
+| 6 | charge? | | |
+| 10 | MR. OKULA: Objection. | | |
+| 11 | THE COURT: Sustained. | | |
+| 13 | there was a possibility that charges would be brought against | | |
+| 14 | you for perjury during the voir dire process of this trial? | | |
+| 17 | jurors lie during voir dire? | | |
+| 20 | dire repeatedly. caused this entire process. and that there | | |
+| 21 | will be no consequences for it? | | |
+| 22 | MR. OKULA: To the form, your Honor. | | |
+| 23 | THE COURT: Sustained as to form. | | |
+| | | | C2fitau7 Conrad • cross Page 236 |
+| | | 2 | displease the government, there is no likelihood of those |
+| | | 3 | criminal charges being brought? |
+| | | 4 | MR. OKULA: Objection, your Honor. |
+| | | s | THE COURT: Sustained. |
+| | | e | MR. SHECHTMAN: No further questions. |
+| | | 9 | THE COURT: Anything funher on redirect, Mr Roten |
+| | | ao | or Ms. McCarthy? |
+| | | 11 | MR. ROTERT: Thank you. your Honor. no. nothing for |
+| | | 12 | Ms. Guerin. |
+| | | 13 | MS. McCARTHY: Nothing further. |
+| | | 14 | THE COURT: Anything further, Mr. Okula? |
+| | | 15 | MR. OKULA: Nothing. Thank you, your Honor. |
+| | | 16 | THE COURT: Ms Conrad. I would like io 44 you. given |
+| | | 17 | your acknowledgment here today that you misrepresented any |
+| | | 18 | number of material things about yourself during voir dire |
+| | | 19 | because you wanted to make yourself marketable for the jury. |
+| | | 20 | and you perjured yourself, why did you do that? |
+| | | 21 | THE WITNESS: As I had rriumoned.1 Ian I could et a |
+| | | 22 | fair. unbiased juror, and substantivelywise it seemed as if it |
+| | | 23 | would be an interesting trial experience. And having been |
+| | | 24 | suspended for so long. I guess mentally I would think maybe I'm |
+| | | 25 | back in the swing of things now. |
+
+| | C2trdau7 Conrad cross Page 237 I know misrepresenting myself and the perjury was | C2trdau7 1 | Page 239 with the marshals, and then we are going to head into I think |
+|----|----------------------------------------------------------------------------------|------------|----------------------------------------------------------------------------------------------------------------------------|
+| 2 | wrong, and I apologize to the Court and to everybody else who | 2 | the rest of the waiver portion. |
+| 3 | has. Ern sure. devoted immeasurabk amount of time, hours:. | 3 | MR. GAIR: Judge, as far as I'm concerned, the only |
+| 4 | Maybe it Just wasn't for the 5440. That's basically it. I know | 4 | reason to call the marshal. I need to to perfect impeachment |
+| 5 | a lot of resources were spent because of this, and I apologize | S | unless the Court is ready to decide the substantive issue that |
+| 6 | to everybody. It wasn't a calculated folly. it was just maybe | 6 | the witness has shown herself to be a pathological liar, not to |
+| 7 | folly. But I know I served and I did my civic duty and I | 7 | know what the truth is. probably to be severely mentally |
+| 8 | believe I was fair and just in rendering the verdict. | 8 | disabled, and to base committed innumerable direct contempt, in |
+| 9 | I know my disclosures definitely would not have | 9 | front of your Honor today by petitions herself. So I would |
+| 10 | allowed me to serve as a tutor, I also know that I could have | 10 | renew our motion at this time, and then we could dispense with |
+| | 11 requested a side bar to speak with your Honor and the other | 11 | the marshal. |
+| 12 | attorneys during the voir dire, and I didn't do that. I | 12 | THE COURT: We are in the middle of a hearing I can |
+| 13 | apologize to everybody. | 13 | see that Mr. Okula is ready to respond. but we are not going to go down that mute. You will call your next witness and you |
+| 14 | THE COURT: Anything further from counsel? | 14 | will do it tomorrow morning We'll have Deputy Weiss here at |
+| 15 | MR. OKULA: No, your Honor. | 15 | |
+| 16 | THE COURT: Mr. Gair? | 16 | that time. |
+| 17 | MR. GAIR: Not of this witness, your Honor. | 17 | Are you calling anyone else from the Marshals Service? |
+| 18 | THE COURT: Mr. Roten? | 18 | MR. GAIR: No, your Honor. |
+| 19 | MR. ROTERT: No. your Honor. | 19 | THE COURT: All right. Mr. Shechtman? MR. SHECHTMAN: Judge.,t may be thatweshoutdat |
+| 20 | MS. McCARTHY: No. | 20 | |
+| 21 | MR. SHECHTMAN: No. your Honor. | 21 | call it a day. If the Court wants what I think is a short witness, Mr. Benhamou is here. He is a law student, he has |
+| 22 | THE COURT: Is there any mason at this juncture that | 22 | |
+| 23 | the arrest warrant that was issued this morning to bring the | 23 | classes tomorrow. THE COURT: He is in class? |
+| 24 | witness to court should not at this time be released? | 24 | MR. SHECHTMAN: He missed today. |
+| 25 | MR. OKULA: No, your Honor. | 25 | Page 240 |
+| | Cactau7 Page 238 | | THE COURT: Bring him on. |
+| 1 | MR. GAIR: Not the arrest warrant, your Honor. | | MR. OKULA: May I haw a moment with Mt Shechunan. |
+| 2 | THE COURT: I'm not going to vacate it. Its an | | |
+| 3 | existing arrest warrant. She was arrested. But I'm going to | | your Honor? THE COURT: Right wen take a witness out of order. |
+| 4 | release her now. | | |
+| | You're free to go. You may step down as a witness. I | s | MR. SHECHTMAN: halo I dunk n ate e ben nett( we |
+| 6 | think the Marshals Service will assist you. You are excused. | 6 | have just decided that we don't need his testimony and we are |
+| 7 | (Witness excused) | 7 | going to send him back to school. |
+| | THE WITNESS: Would the defense can as neat witness. | 8 | THE COURT: I hope he didns have much of a class load |
+| 9 | MR. GAIR: Yes. your Honor. The defense calls deputy | 9 | today. |
+| 10 | U.S. Marshal Eric Weiss. | 10 | MR. OKULA: It's early in the semester, your Honor. |
+| 11 | MR. OKULA: Your Honor. I understand that he was | 11 | THE COURT: It's those early sessions that are most |
+| 12 | supposed to be communicating with the other marshals because he | 12 | important though. |
+| 13 | let the people in the courtroom know that he was downstairs and | 13 | MR. SHECHTMAN: I woukl .ay Nal he nUtwd INCCI3Mel |
+| 14 | ready to go. I think it is going to take three or four minutes | 14 | on tesponcleat superior by order of the Court. |
+| 15 | for him to get up. I don't know if counsel is in favor of | 15 | THE COURT: Are there any matte" that counsel want to |
+| 16 | waiting until tomorrow morning. | 16 | raise before we suspend for the evening? |
+| 17 | MR. GAIR: Fine with me. Judge. | 17 | MR. OKULA: No, your Honor. |
+| 18 | THE COURT: I just want to make certain that we | 18 | THE COURT: Anything from defense counsel? |
+| 19 | complete this hearing tomorrow. I'm prepared to work a little | 19 | MR. GAIR: No. your Honor. |
+| 20 | later right now to get that, to achieve that purpose. | 20 | MR. ROTERT: 9:30 tomorrow, Judge? |
+| 21 | MR. OKULA: Judge. I think, based on getting through | 21 | THE COURT: Let's make it 9 43, since I'm assured that |
+| 22 | Ms. Conrad today, there is a substantial likelihood that we | 22 | we are going to comfortably finish tomorrow. Have a good |
+| 23 | will be done by midday tomorrow. I am highly confident we will | 23 | evening. |
+| 24 | get done Itnurtninw if we break now I undentand from speaking | 24 | (Adjourned to 9:45 a.m., February 16. 2012) |
+| 25 | with Mr. Gair or indirectly that he is going to be fairly quick | 25 | |
+
+#### UNITED STATES OF AMERICA, v PAUL. M. DAUGERDAS, ET AL.,
+
+Page 241
+
+| INDEX OF EXAMINATION | | |
+|----------------------|------------------------------|---------------|
+| 1 | Examination of: | Page |
+| 3 | THERESA [REDACTED] TRZASKOMA | |
+| 4 | Direct By Mr. [REDACTED] | . . . . . 8 |
+| | Cross By Mr. Shechtman | . . . . . .84 |
+| 5 | Redirect By Mr. [REDACTED] | . . . . . .90 |
+| | Recross By Mr. Shechtman | . . . . . .95 |
+| 6 | | |
+| 7 | CATHERINE M. CONRAD | |
+| 8 | Direct By Mr. Gair | . . . . . 101 |
+| | Direct By Mr. Schechtman | . . . . . 204 |
+| 9 | Cross By Mr. Okula | . . . . . 211 |
+| | Redirect By Mr. Gair | . . . . . 223 |
+| 10 | Cross By Mr. Shechtman | . . . . . 229 |
+| 11 | | |
+| 12 | | |
+| GOVERNMENT EXHIBITS | | |
+| 13 | Exhibit No. | Received |
+| 14 | 4 | . . . . . 65 |
+| 15 | 5 | . . . . . 17 |
+| 16 | 9 | . . . . . 75 |
+| 17 | 14 | . . . . . 20 |
+| 18 | 28 | . . . . . 76 |
+| 19 | | |
+| 20 | | |
+| 21 | | |
+| 22 | | |
+| 23 | | |
+| 24 | | |
+| 25 | | |
+
+Page 242
+
+| PMD EXHIBITS | | |
+|--------------|--------------------------|---------------|
+| 1 | Exhibit No. | Received |
+| 3 | PMD 1, 24, 25, 26 and 45 | . . . . . 204 |
+| 4 | PMD 2 | . . . . . 145 |
+| 5 | PMD 3 | . . . . . 125 |
+| 6 | PMD 7 | . . . . . 194 |
+| 7 | PMD 14 | . . . . . 173 |
+| 8 | PMD 17 | . . . . . 176 |
+| 9 | PMD 20 | . . . . . 175 |
+| 10 | PMD 23 | . . . . . 211 |
+| 11 | PMD 29 | . . . . . 179 |
+| 12 | PMD 40 | . . . . . 36 |
+| 13 | PMD 54 | . . . . . 65 |
+| 14 | | |
+| 15 | | |
+| 16 | | |
+| 17 | | |
+| 18 | | |
+| 19 | | |
+| 20 | | |
+| 21 | | |
+| 22 | | |
+| 23 | | |
+| 24 | | |
+| 25 | | |
+
+**This Page Intentionally Left Blank**
+
+| \$ | 40:25
11:15 (1)
42:17
11:17 (1)
44:8
11:22 (1)
45:4
11 (2)
55:10;82:21
118 (2)
63:15;82:15
11th (2)
39:8;42:21
12 (16)
18:19;25;19:1,3;
22:12;26:22;39:14;
42:14;57:15;58:5;59:18;
72:8;86:15;138:10;
157:18;159:13
120 (3)
63:15;82:15,16
12th (23)
39:9;42:21,24;43:14;
44:8;49:19;64:6;68:23,
24;69:21,23;70:14;
79:22;86:17;20:87;16;
90:7;22;92:17;94:5,9,14;
95:12
13 (1)
138:11
130 (1)
100:1
13th (1)
69:21
14 (12)
18:17;19:20,24;20:1,
5;26:19;39:11;82:15;
138:12;173:15,19,20
14-12 (1)
19:11
15 (2)
75:13;84:6
15th (7)
74:12;77:24;85:1;
116:20;118:8;129:22;
170:6
16 (7)
196:3,9,11,23;198:10;
199:22;240:24
16-4 (1)
180:4
16th (1)
96:6
17 (6)
63:16;64:1;176:1,6,7,
11
18 (3)
173:15;189:25;231:9
19 (2)
132:5,6
1932 (1)
47:5
1976 (1) | 189:17
1980 (2)
189:6,7
1981 (1)
189:8
1984 (1)
100:2
1985 (1)
189:19
1993 (1)
189:25
1997 (2)
42:4;183:2
1998 (2)
183:3;184:3
1999 (1)
9:24
1's (6)
25:13;38:20;49:22;
59:4;60:4;92:15
1st (6)
23:13;102:2,5;185:3,
7;191:11 | 26:22;36:12;39:14;
52:18,19;53:2;64:19;
69:18;72:8;74:12;75:13;
76:3;78:5;102:3,5;
103:3;115:16;126:19;
136:1,7,20;140:1;146:2,
15;150:2;177:2,5,13;
179:1,4;181:4;189:2;
194:11
2012 (2)
99:15;240:24
203 (3)
145:7;157:18;165:1
204 (2)
165:4;172:8
20th (22)
88:6,18;105:13,14;
109:20;110:3,6,9,22;
113:10,22;117:13;124:2,
7;130:14;131:6;138:3;
199:19;200:4,21;
203:12;223:5
2½ (5)
178:21;179:1,3;
180:24,25
21 (8)
76:3;78:4;150:16,16;
162:17;177:16,17;181:2
23 (4)
211:3,6,10,11
2385 (3)
146:16;151:10;196:2
23rd (1)
126:19
24 (5)
156:3;181:3;203:23,
25;204:2
24th (1)
194:14
25 (6)
18:24;163:2;203:23,
25;204:2;207:8
25th (3)
87:22;194:11;200:23
26 (3)
203:23,25;204:2
26th (4)
150:24;151:13;
153:12;177:5
27 (6)
10:11,13,22;11:4,9;
12:6
27th (1)
19:8
28 (8)
76:1,8,12,14,25;136:7;
177:12;181:5
28th (6)
67:4;136:1,20;147:7;
150:20;177:4
29 (5)
176:2;179:13,16,21,22
2nd (14) | 23:19;34:2;69:16;
102:5;140:1;146:15;
150:1;151:15;153:13;
154:25;185:6,7;191:11,
15
3
3 (11)
124:25;125:1,2,8,9;
130:21,21;145:9;
176:11;199:22,23
30 (4)
49:15;113:8;162:17,
25
39 (1)
100:2
3H (2)
146:16;151:11
4
4 (10)
65:10,16,21,23,25;
80:5;145:8;177:18;
180:3;187:15
40 (4)
29:12;36:24,25;49:14
400 (2)
13:16;28:24
41 (2)
48:21;49:3
45 (3)
203:23;204:1,2
467 (1)
100:2
48 (1)
100:2
4th (1)
185:14
5
5 (9)
17:3,10,16,18;20:19,
22;33:1;125:11;130:5
50 (4)
49:14,16,16,17
52 (3)
31:3,4;70:5
54 (5)
64:23;65:16,21,24;
176:11
6
6 (1)
126:14
606 (1)
199:12
7 |
+|----|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+|----|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+
+| 7 (9)
94:18;194:5,8,9,10,10;
204:18,19,20
7:52 (2)
5:2;129:24
70s (1)
189:10
72 (4)
21:23;22:10;39:11,12
721 (1)
100:1
724 (1)
100:1
73 (1)
24:2
78 (1)
26:18
| A
abide (1)
7:6
ability (6)
130:16;141:10;192:7;
216:8,12;228:22
A-blank-blank (1)
206:23
able (5)
47:16;57:2;123:17;
128:9;137:14
above (2)
22:23;47:3
abroad (3)
158:5;167:22;171:25
absolutely (19)
18:13;64:14;96:3;
111:11;112:25;114:10,
13,15;123:9;136:4;
145:16;149:9;172:14;
197:20;198:2;211:24;
212:23;213:10;216:5
abstinence (1)
182:13
abstinent (4)
178:21;179:6;180:24,
25
accelerate (1)
7:7
access (5)
20:25;21:2,2,3,12
accessible (6)
21:18;197:2,5,9,12,18
accident (1)
183:14
accidental (1)
155:4
accomplice (1)
32:20
according (1)
71:1
accordingly (2)
53:25;100:11
account (2)
130:19;227:21
accountants (1)
207:14
accounts (5)
131:2,8,17,23;133:22
accuracy (1)
28:13
accurate (6)
46:8,17;79:19;208:24;
209:15,18
accused (1)
59:12
achieve (1)
238:20
achieved (2)
134:20,24
acknowledge (3)
| 38:12;91:7,10
acknowledging (1)
91:6
acknowledgment (1)
236:17
acquit (2)
220:1,3
acquittal (2)
220:16,16
acquitted (1)
74:24
acquitting (1)
164:5
across (1)
142:22
act (1)
228:22
acting (2)
32:20;128:10
action (4)
38:17;53:10,14;
207:22
actions (2)
178:12,18
active (1)
142:13
actual (1)
80:20
actually (24)
13:9;20:9;28:6;53:12;
60:8,14;68:17;87:1;
93:1;131:12;150:5;
152:9,21;153:5;158:21;
163:8;165:4;169:3;
209:5,6,9,10,10;223:20
acumen (1)
158:25
Adam (2)
4:19;40:1
add (2)
76:18;137:7
added (1)
231:17
addition (1)
13:14
additional (9)
14:3,11;18:23;34:10;
44:25;57:18;59:23;
85:12;93:7
address (38)
6:22;45:11;50:17,21,
25;51:5,8,9,9,11,20,22;
52:3;56:2;85:13;144:18,
20;146:23,23;147:6,11;
153:2,8;157:23;158:4,6,
9;161:20,22;186:19;
196:8,11,16,19;198:10,
13,15,16
addressed (2)
5:17;188:20
addresses (4)
51:10,21;145:25;
146:25
| addressing (1)
72:19
adequate (1)
99:25
Adjourned (1)
240:24
admin (5)
39:17,18,22,24;40:4
admiration (1)
171:18
admired (1)
59:13
admissible (1)
217:12
admission (13)
11:4;19:11;36:20;
65:15;75:18;76:7;125:5;
145:1;173:15;175:19;
179:15;194:4;203:22
admit (1)
19:10
admitted (3)
9:23;174:15;211:3
adopt (2)
127:6,20
advance (4)
11:22;19:7;20:14;
29:18
advice (3)
99:2;102:4,7
advised (3)
5:4;6:1;139:3
advising (1)
124:2
affect (5)
216:2,7,12,16;228:22
affidavit (20)
125:15;126:6,9,11,18;
128:13;129:10;133:23;
134:1,8;135:25;136:19;
137:16,22,23;150:8,17,
23;151:14;155:23
affluent (5)
152:9,21,25;153:5,9
afford (4)
124:16;125:16,18;
126:10
afternoon (17)
7:5;49:6;56:5,19;
69:22;70:14;83:15;
86:20,23;87:15,16;
90:22;92:16,20;129:6;
130:7;233:22
afterwards (2)
93:6;190:10
again (19)
20:23;55:6;71:20;
80:2;92:6;98:6,11,13,18;
112:14;118:14;122:9;
123:20;157:18;167:10;
168:9;191:13;196:8;
204:17
against (26)
| 10:25;52:14;62:12,16;
99:3;111:8;113:25;
114:17;128:16;132:17;
133:13;134:6;137:10;
140:24;208:6;212:4,14,
17;215:23;220:20;
233:3,10;234:13;235:11,
14,21
age (1)
48:21
agenda (1)
212:1
agents (1)
214:19
aggravated (1)
184:7
ago (15)
90:5;103:5;113:8;
131:4;153:7,19,22;
157:6;162:17;163:7;
191:1;216:25;223:4;
226:21;230:7
agree (30)
9:25;21:20;26:10;
29:20;30:6;46:10;56:6;
67:23;73:2,21;81:8;
87:2;90:7;92:23;105:25;
108:10;113:6;116:25;
119:9,16;120:9;121:17;
124:1;128:12;137:11;
154:12,24;159:18;
197:21;227:4
agreed (2)
31:21;231:3
agreement (1)
68:1
ahead (2)
95:22;204:13
airplane (1)
189:18
akin (1)
192:5
al (1)
8:21
alcohol (7)
24:7;25:13;97:10;
98:19;110:5,9;180:12
alcoholic (8)
41:4,21;94:17;174:15,
17;175:9;176:9,13
alcoholics (1)
109:18
alcoholism (9)
25:13;89:14;174:6,9,
11,21;176:18;177:9;
210:12
alerted (1)
5:15
alerting (1)
63:2
alleged (2)
74:19;75:3
██████████ (1)
|
+|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+
+| 4:7 | apologies (1) | 133:22;134:5,11 | asserting (1) | 219:9 |
+|--------------------------|--------------------------|--------------------------|-------------------------|--------------------------|
+| allergic (1) | 136:17 | April (2) | 99:3 | attentive (1) |
+| 170:16 | apologize (4) | 183:3;184:4 | assertion (1) | 35:24 |
+| allow (1) | 88:17;237:2,5,13 | archeology (2) | 102:18 | Attorney (23) |
+| 137:24 | Aponte (2) | 167:22;171:25 | assessment (1) | 4:5;54:11,14;123:24, |
+| allowed (2) | 32:10,15 | area (4) | 90:13 | 24:125:25;126:16; |
+| 166:10;237:10 | appear (22) | 97:14,15;152:9,21 | assigned (2) | 133:24;141:22;143:12; |
+| almost (2) | 5:13;10:12;40:21; | argument (2) | 18:1;24:13 | 166:15,16,18,23;167:6; |
+| 16:22;53:6 | 42:22;48:14;105:1,15; | 46:5;89:21 | assist (8) | 168:25;178:7,8;212:14; |
+| alone (1) | 106:15;109:20;110:11, | arguments (1) | 13:2,13;15:22;20:13, | 215:23;216:16;218:7; |
+| 67:11 | 25;116:19;118:8,18; | 97:17 | 14:65;4:66;12:238:6 | 221:6 |
+| along (11) | 119:11,18;120:5;123:7, | Arizona (7) | assistance (2) | attorneys (3) |
+| 44:6;58:22;63:5; | 13:186:10,12;215:11 | 185:14,17,19;186:15; | 12:11;66:22 | 148:15;165:23;237:12 |
+| 85:20;93:11;190:16; | appearance (5) | 188:9;210:15;215:12 | Assistant (1) | Attorney's (1) |
+| 191:18;194:20;217:2,9; | 5:19;8:16;109:23; | arose (1) | 4:4 | 5:6 |
+| 220:11 | 110:2,8 | 37:11 | assisted (1) | August (10) |
+| aloud (2) | appearances (2) | around (3) | 12:13 | 170:24;179:2,3,6,10; |
+| 37:3,18 | 4:2;9:14 | 112:19;150:10;201:24 | assisting (2) | 180:11;185:14;187:15; |
+| alternate (6) | appeared (6) | arrangement (1) | 10:25;12:21 | 188:9;189:19 |
+| 34:16;90:11,12;92:8, | 103:8;109:19;186:14, | 35:6 | associate (4) | aunt (4) |
+| 14:96:10 | 16:191:5;223:5 | arrest (17) | 11:19;12:3,4,5 | 230:13,16,17,23 |
+| alternates (2) | appearing (2) | 5:6,21;6:11,13,20; | associates (1) | authorities (8) |
+| 29:5;34:24 | 112:24;122:16 | 94:17;121:13;122:21; | 9:17 | 151:4;153:12;155:20, |
+| alternatively (1) | 23:1;24:1;88:11,12; | 183:12,13;184:1,2; | Association (1) | 23;191:6;210:14;224:8, |
+| 71:24 | 150:21;173:9,22; | 187:17;188:7;237:23; | 207:22 | 13 |
+| alternatives (1) | 175:20;176:3 | 238:1,3 | assume (1) | authorization (1) |
+| 99:24 | apples (1) | arrested (24) | 21:9 | 175:5 |
+| although (4) | 224:9 | 6:23;89:18;94:16; | assumed (1) | auto (1) |
+| 50:12;98:15;100:25; | applicable (2) | 123:7,13;179:25;181:6, | 27:18 | 190:3 |
+| 187:20 | 42:22;136:3 | 13;182:18,22,25;185:14, | assurance (1) | available (8) |
+| amended (1) | application (12) | 16,19,24;188:9,25; | 228:17 | 7:7;13:5,10,12;39:21; |
+| 75:16 | 7:4;35:2;97:3,6; | 189:3;193:12,14;215:11, | assured (1) | 44:18;172:16,19 |
+| Amendment (5) | 100:12,21;102:13; | 18;216:6;238:3 | 240:21 | Avenue (16) |
+| 99:3;100:20;102:9,19; | 126:16,17;148:10; | arrests (4) | ate (1) | 146:3,16;147:6,12,18; |
+| 233:25 | 150:17;177:23 | 18 | 70:2 | 148:1;151:11,14;156:8, |
+| among (2) | apply (6) | arrived (2) | attach (1) | 11;158:12;170:12; |
+| 100:6;200:15 | 158:25;159:10,14; | 6:8;110:6 | 136:2 | 196:3,7,9;198:16 |
+| 74:1 | 164:4,14;217:4 | artiful (2) | attached (7) | average (1) |
+| amount (5) | 102:16;216:4;219:23 | 75:6;85:9 | 16:19;40:16;46:7; | 152:7 |
+| 69:12;85:23;134:11; | appoint (3) | A's (1) | attaches (5) | avoid (1) |
+| 210:4;237:3 | 124:11,15;132:15 | 16:22 | attaches (5) | 82:3 |
+| and/or (2) | appointed (4) | a-s (1) | 40:10;41:10;42:9; | aware (14) |
+| 181:7,8 | 125:25;126:16; | 206:22 | attachment (1) | 14:10;28:15;34:16; |
+| anew (1) | 132:20;137:25 | ascertain (1) | 22:24 | 36:3;72:22;24:75:4; |
+| 96:11 | appointee (1) | 74:18 | attack (1) | 78:1;85:5;89:5,10,11; |
+| animus (2) | 116:16 | ascribed (1) | 6:23 | 93:25;97:9 |
+| 212:17,21 | appointment (7) | 41:17 | attained (1) | axed (2) |
+| answered (6) | appointment (1) | Aside (3) | 164:25 | 171:14,14 |
+| 145:12;151:18; | 116:14,21;117:6,11; | 13:12,20,20 | attempt (4) | B |
+| 164:19;175:1;211:17; | 133:4 | aspects (5) | 176:21;177:1;195:11; | BA (2) |
+| 227:24 | appreciate (1) | 98:19 | attempted (1) | 167:21;171:23 |
+| anticipate (4) | 49:8 | ass (2) | 130:15 | bachelor's (3) |
+| 130:4,6,8,9 | appreciated (3) | 116:6;207:11 | attendance (1) | 44:3;59:11;86:13 |
+| anxious (5) | 92:4,7,7 | a-s-s (1) | 113:21 | back (38) |
+| 194:15,19,24;195:1,3 | appropriate (7) | 116:5 | attended (3) | 5:12,16;13:15;23:7; |
+| anymore (1) | 85:7,14;102:25; | assassination (1) | 112:23;113:7,15 | 27:9,15,19;31:4;43:1,8, |
+| 230:5 | 128:24;178:12,18; | 142:19 | attention (16) | 20:44;13:45;7:9;46:18; |
+| apart (2) | 222:18 | assault (4) | 11:11;17:19;22:11; | 57:5;58:23;61:15;67:4, |
+| 9:9;103:7 | appropriately (1) | 183:6,8,9,13 | 25:16;26:21;36:1;40:6; | 12;71:12;72:10;81:3; |
+| apartment (5) | 216:13 | assert (1) | 63:8,13;64:16;66:6; | 83:13;86:4;101:2; |
+| 146:16;151:11;157:1, | approximately (3) | 102:9 | 90:8;98:23;129:8;145:7; | 122:11,13;126:13; |
+| 2,5 | | | | |
+
+| 136:22;138:3;142:4;
157:3;198:6;209:16;
218:15;236:25;240:7 | 125:14;132:5;146:20;
21:199:22;212:18;
216:21;222:15 | biographical (1)
66:2 | 48:14 | 78:2 |
+|----------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| backdating (1)
203:4 | behalf (7)
4:7;12;16;6;16;11;14;
97:3;202:3 | bipolar (1)
120:22 | break (8)
64:9;13;86:21;111:13;
114:20;165:16;192:23;
238:24 | Brune (48)
8:25;9:2,6,9,17;12:1;
16:1;21:11;35:4,11,12;
38:7;40:2;42:2;44:24;
56:20,24;57:8;58:2;
59:18;60:18,19,21;
61:17,23;63:1,19,23;
67:20;69:22;70:13;
73:12;74:1;76:22,24;
77:1,5;79:24;86:7;87:8,
12,17,24;88:10;92:17;
93:5,10,12 |
+| background (5)
34:5;148:12;167:19;
225:20;232:1 | behavior (5)
106:1;107:2;110:16,
16;184:17 | birth (7)
47:5;48:1,8,15,15;
49:10;54:20 | brief (15)
25:16,17;67:2,10;
68:5,6,8;73:14,22;74:6,
8;79:11,23;97:7;229:21 | burglarizing (1)
32:21 |
+| badly (1)
154:20 | behind (2)
88:15;209:22 | birthday (1)
191:2 | briefly (14)
5:3;21:1;24:1;30:17;
49:7,20;55:6,7;67:2;
84:5;92:22;97:7;100:16;
204:12 | burglary (2)
189:23;190:1 |
+| bag (3)
182:3,5,11 | belind (2)
88:15;209:22 | bit (2)
111:13;153:8 | bring (13)
7:1;84:16;92:8;98:23;
100:13,15;101:12;
129:25;187:6;233:9;
235:11;237:23;240:1 | bus (11)
162:14,15,16,19,22,
22,25;163:20,25;164:10;
207:8 |
+| bags (1)
182:8 | belief (2)
170:25;175:8 | black (1)
124:23 | bringing (1)
233:3 | bus (11)
162:14,15,16,19,22,
22,25;163:20,25;164:10;
207:8 |
+| bar (10)
9:21,23;30:23;135:25;
153:11;207:21;224:4,8,
12;237:11 | beliefs (1)
218:11 | blackout (1)
139:17 | broader (1)
99:22 | business (5)
138:5,13,16,19,21 |
+| Barker (17)
146:3,9,16;147:6,12,
18;148:1;151:10,14;
156:8,11;158:12;
170:12;196:3,4,7;198:16 | below (1)
52:4 | blackouts (1)
139:15 | broader (1)
99:22 | businessman (2)
163:5,6 |
+| based (23)
24:6;28:8,22;30:3,4;
64:19;91:11,17;93:12;
96:17;98:3;119:16;
141:8;214:7;217:10,21,
23;219:21,21;220:15,17;
222:20;238:21 | bench (3)
35:9;94:16;116:21 | blank (1)
175:5 | bringing (1)
233:3 | busy (1)
232:21 |
+| basically (6)
32:21;91:17;221:15;
223:7;228:25;237:4 | benhamou (38)
12:15;22:12,23;23:7;
26:22;40:8,9;41:8,17;
42:9,17;44:22;45:4,9;
49:8;55:18;56:8,17;
57:5;62:11,15;63:16;
64:3;70:24;81:14;82:7,
13,24;83:2,6,13;87:1;
91:4,11;92:19;93:13,16;
239:22 | bless (2)
111:6,18 | broader (1)
99:22 | bus (11)
162:14,15,16,19,22,
22,25;163:20,25;164:10;
207:8 |
+| basis (6)
16:9;24:6;88:4;
106:24;158:12,18 | Benhamou (38)
12:15;22:12,23;23:7;
26:22;40:8,9;41:8,17;
42:9,17;44:22;45:4,9;
49:8;55:18;56:8,17;
57:5;62:11,15;63:16;
64:3;70:24;81:14;82:7,
13,24;83:2,6,13;87:1;
91:4,11;92:19;93:13,16;
239:22 | Block (1)
77:7 | Bronx (43)
38:17;45:13;50:25;
51:9,14,22;52:5,8;53:4,
18;56:10;60:8,9;62:13,
16;87:5;93:19;144:11,
13;145:13;146:3,16,22;
147:12,18;148:1,22,24;
149:12;151:11,15,23,24;
152:3,6;153:1,12;156:9,
11;159:23;172:1;
186:24;187:1 | business (5)
138:5,13,16,19,21 |
+| beating (1)
185:23 | Benhamou's (4)
55:13;56:6;62:23;87:2 | Block (1)
77:7 | broader (1)
99:22 | businessman (2)
163:5,6 |
+| became (2)
16:25;18:3 | besides (5)
76:24;121:3;171:18;
187:19;228:1 | bond (5)
186:3,4,5,9;187:25 | broader (1)
99:22 | busy (1)
232:21 |
+| become (1)
18:5 | best (4)
12:7;82:11;86:24;
192:7 | bonus (1)
231:17 | Bronxville (47)
18:1;45:11,24;46:9;
50:17,18,22;51:3,6,7,8,
11,20;52:3,7;56:1;71:2;
87:6;144:15;145:12,14,
18,21;146:5;147:2;
148:1,5;149:12;150:5;
151:17,25;152:1,5,25;
153:4,8,14;155:1,24;
158:3;159:19;160:5;
161:24;162:6;172:1;
196:9,11 | called (17)
4:1;5:2,12,12;8:3;
19:6;57:7;64:5,93;12,
16;98:24;99:4;101:1,17;
179:17;185:16,22 |
+| bed (1)
146:2 | Beth (1)
90:12 | book (3)
150:16;201:25,25 | brother (1)
32:21 | called (17)
4:1;5:2,12,12;8:3;
19:6;57:7;64:5,93;12,
16;98:24;99:4;101:1,17;
179:17;185:16,22 |
+| bedroom (1)
148:23 | better (4)
85:18;149:7;187:5;
240:5 | Borough (1)
52:8 | brought (17)
6:24;10:25;36:1;
52:14;53:25;61:13;63:7;
90:7;111:8;113:25;
114:16;208:5;234:13;
235:14,21;236:3,7 | calls (2)
7:25;238:9 |
+| began (1)
213:23 | Beyond (2)
210:8;232:19 | Boston (1)
158:5 | brother (1)
32:21 | calls (1)
121:2 |
+| begin (2)
145:10;222:19 | Bharara's (1)
198:4 | both (18)
61:17;148:3;149:11,
12;150:6,7;151:21;
153:15,16,23,24;155:15;
182:8;196:18;216:20;
224:19;230:22;233:24 | Brooklyn (6)
51:9;158:5;159:24,25;
167:25;218:2 | came (23)
13:9,11;23:24;30:19;
49:7;67:4;71:12,13;
87:8,12;107:17;108:6;
115:15;117:13;157:2,4;
170:5,9,14;187:6;
231:11;233:12;234:1 |
+| bias (8)
26:12;140:23;149:7;
212:17,21;214:9;
217:24;220:10 | biased (5)
15:4;212:14;215:22;
220:20;229:11 | bother (1)
57:6 | brother (1)
32:21 | calling (4)
60:25;100:25;101:3;
239:17 |
+| biases (2)
141:4,11 | biased (5)
15:4;212:14;215:22;
220:20;229:11 | bottom (9)
17:25;20:22;39:14;
47:2;77:3;125:11;
131:14;178:11;218:23 | brought (17)
6:24;10:25;36:1;
52:14;53:25;61:13;63:7;
90:7;111:8;113:25;
114:16;208:5;234:13;
235:14,21;236:3,7 | calls (2)
7:25;238:9 |
+| big (3)
91:25;124:23;206:16 | binder (2)
124:24,25 | bounced (1)
165:20 | Brubaker (9)
68:14,16,23;69:19;
74:24;199:25;203:1;
220:1,16 | calms (1)
121:2 |
+| bio (1)
12:6 | binder (2)
124:24,25 | box (2)
35:14;101:10 | Brubaker's (5)
69:2,25;74:22;77:25; | came (23)
13:9,11;23:24;30:19;
49:7;67:4;71:12,13;
87:8,12;107:17;108:6;
115:15;117:13;157:2,4;
170:5,9,14;187:6;
231:11;233:12;234:1 |
+
+backdating - came (4)
+
+SOUTHERN DISTRICT REPORTERS
+
+| can (83) | 179:16;187:4;191:18;
193:16;18;209:6,11;
211:23;212:18,25;213:2,
8;214:13,18,25;215:24;
216:2,3,14,17,20;
218:13;219:21;220:8,
11;221:6,25;222:6,11,
21;231:15,23;232:2,13 | 139:14,15;192:13;
223:13
chairs (1)
7:22
challenge (5)
15:20,20;31:23;32:5,
13
challenged (1)
32:12
challenges (3)
30:3;86:7,8
[REDACTED] (6)
5:2,11,14,16;104:1,4
chance (5)
68:6;95:5;107:21;
210:1;234:5
change (4)
70:16;121:14;122:22;
232:20
changed (3)
27:25;28:1;86:24
changes (1)
76:21
character (1)
142:18
characterization (8)
56:6,8;87:3;127:6;
183:20,22;232:3;233:6
characterize (7)
110:16;128:3;136:23;
154:10;167:20;175:10;
228:6
characterized (1)
229:18
charge (6)
199:6,8,16,17;214:2;
234:6
charged (8)
11:20;149:4;166:1,6;
181:7;183:5,8;234:3
charges (11)
165:24;208:5;220:3;
222:1;233:3,10;234:13;
235:11,14,20;236:3
Charles (1)
4:6
cheap (1)
109:13
check (3)
28:13;29:15;189:15
checking (6)
130:19;131:2,8,17,23;
133:22
Chicago (3)
106:3,7;152:11
children (2)
164:21;171:19
children's (1)
93:14
Chinese (1)
162:20
choices (3)
15:19;29:19,24 | choose (2)
201:8,11
chose (2)
201:21;228:14
chosen (1)
188:20
[REDACTED] (1)
4:6
chronology (3)
176:24;177:11;224:5
circulated (1)
129:11
circumstance (1)
68:17
circumstances (1)
14:5
cited (1)
24:5
cites (1)
72:11
citizens (1)
140:22
civic (6)
192:6,9,11;224:14,15;
237:7
civil (16)
9:10;38:2,10,12;
51:23;52:6,8,13,17,23,
25;62:16;66:9;94:23;
95:5;153:23
claim (2)
13:19,22
claims (1)
13:20
clarify (2)
22:3;72:6
clarity (1)
56:4
class (3)
12:5;239:24;240:8
classes (2)
239:23;240:13
classics (1)
167:21
clear (6)
13:20;27:18;56:14;
85:25;100:24;101:7
cleared (1)
6:25
clearly (2)
41:4;43:13
clerk (9)
66:17;70:1;93:19;
104:4;105:22;107:9;
108:15,20;117:25
client (14)
5:9;10:5;35:5,10;
128:16;132:17;133:13;
134:6,14;137:10;
142:21;146:11;147:23;
149:3
clients (1)
42:7 | Clinically (1)
180:19
Clinton (6)
111:9;115:22;116:12,
14,16;117:6
Close (6)
49:16,16;64:10;99:20;
188:18;191:4
closed (2)
98:15;99:19
closer (2)
16:21;49:14
closest (2)
35:9;101:14
closing (1)
99:24
closure (3)
97:4;99:22,25
Coffee (4)
52:11,15;62:12,17
cognizance (1)
186:5
colleagues (1)
11:18
collect (1)
82:13
collected (2)
66:20;81:17
collection (1)
82:12
Columbia (1)
42:4
combination (1)
178:7
comfortably (1)
240:22
coming (11)
5:4;15:11;64:9;83:12;
104:5;105:23;106:15,
25;108:11,15,21
commenced (1)
191:1
comment (1)
47:18
Commission (1)
66:9
committed (3)
178:22;231:11;239:8
committee (16)
40:10;41:11;60:23;
80:17;98:3,20;99:18;
120:13;136:11,19;
150:9;176:4,8;191:8;
208:5,5
common (12)
14:6;23:22;24:24;
38:10;50:14;53:17;
116:25;121:19,22;122:1,
1;169:3
communicate (2)
14:13;75:7
communicating (3)
67:9;81:19;238:12 |
+|------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| SOUTHERN DISTRICT REPORTERS | | | | |
+| (5) can - communicating | | | | |
+
+| communication (1) | 97:12 | 48:9,25;50:10,14;52:1,5,14;53:25;54:16,17;55:5,8;57:9,19,23;58:19,24;60:23;61:1,1,5,7,10,16,19;62:19;66:3;67:18;68:10,13,19;69:1,2,17,20;70:21;71:2;73:18,23;77:15;78:6;79:8,13,20;81:5,15;83:21;84:16;86:9,18,22;87:18;89:12;90:4,10,14;93:3,7,23;94:6,15;95:2;96:2;99:3,15;100:3,9,14,20,25;101:1,12,16,22;102:1,18,24;103:3;106:13;109:4,19;116:18;122:13;127:11;128:12;129:11,15,19,19,25;130:7,10;133:21;134:3,16;135:23;136:14,18;137:22;140:9;142:23;145:9;148:11,16;152:20;154:6;176:2;193:5;200:16;204:16;208:16;210:6,19;211:16,25;212:24;215:14,21;216:1;217:7,21;218:1;219:20;220:14;221:2;222:17;226:7;228:21,24;229:24;236:6,16;238:22 | 56:1
conspiracy (2)
199:6,16
constantly (1)
156:17
construe (1)
168:24
consultant (5)
14:19;23:20;29:22;61:17;77:6
contact (2)
195:11,15
contacted (2)
5:5,12
contemplate (1)
94:14
contemplating (1)
94:10
contempt (2)
184:10;215:7
contempts (1)
239:8
content (1)
79:4
context (8)
38:3,6,11;122:15,16;217:22;224:2;229:10
continue (5)
54:5;64:10;130:12;193:3;229:24
Continued (6)
33:12;78:13;104:7;149:15;186:25;220:23
contract (1)
218:7
contradiction (2)
200:6;201:2
contradictory (2)
200:21,25
contrary (2)
35:22;112:15
controlled (1)
189:9
controlling (1)
72:21
convenience (2)
181:16;182:2
convenient (1)
181:18
conversation (32)
5:16;56:20,21,24;57:8;58:15,17,21;59:22,24;60:3,21;61:8;67:10;68:22,24,25;69:19,22;70:12;77:13;78:5,10;79:1,4,23,25;87:12,16;93:5;129:24;131:5
conversations (2)
29:22;66:25
convey (1)
115:4
conveyed (2)
74:9;80:13 | conveying (1)
31:16
convict (2)
199:7,16
convicted (23)
139:5,9,22,24;142:21;148:20;181:7;182:19,22,25;183:3;188:25;189:3,8,12;190:3;199:20,24,25;200:3;201:1,2;206:18
convicting (1)
146:11
conviction (7)
32:18,20;33:1;183:12;184:1,3,7
convictions (7)
89:14,15;184:5;185:2;188:19;210:12,13
convince (1)
234:7
convinced (1)
234:5
convincing (1)
219:6
cop (1)
183:10
copied (1)
42:17
copies (2)
18:15;129:11
copy (9)
36:18;59:6,20;64:25;65:2;75:13;97:20;187:20;201:14
corner (1)
180:4
corporate (1)
38:4
corporations (2)
38:7,9
corrected (1)
75:16
corrections (1)
227:17
correctly (6)
33:4;37:13;134:8;145:13;199:18;200:5
couching (1)
195:3
counsel (51)
4:23;5:1;6:10;8:15,18,24;17:22;67:1,15,24;68:2,6,9,13,16,22;69:19,19,25;74:22;77:10,25;78:2;84:7;96:8;97:20;98:11,18;99:1,2,8;102:4,7;107:19,22;124:19,21;125:17,18;126:10,19;129:12,25;132:7;204:8;210:18;216:12;237:14;238:15;240:15,18
counseled (1) |
+|--------------------------|-------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| communication (1) | 97:12 | 48:9,25;50:10,14;52:1,5,14;53:25;54:16,17;55:5,8;57:9,19,23;58:19,24;60:23;61:1,1,5,7,10,16,19;62:19;66:3;67:18;68:10,13,19;69:1,2,17,20;70:21;71:2;73:18,23;77:15;78:6;79:8,13,20;81:5,15;83:21;84:16;86:9,18,22;87:18;89:12;90:4,10,14;93:3,7,23;94:6,15;95:2;96:2;99:3,15;100:3,9,14,20,25;101:1,12,16,22;102:1,18,24;103:3;106:13;109:4,19;116:18;122:13;127:11;128:12;129:11,15,19,19,25;130:7,10;133:21;134:3,16;135:23;136:14,18;137:22;140:9;142:23;145:9;148:11,16;152:20;154:6;176:2;193:5;200:16;204:16;208:16;210:6,19;211:16,25;212:24;215:14,21;216:1;217:7,21;218:1;219:20;220:14;221:2;222:17;226:7;228:21,24;229:24;236:6,16;238:22 | 56:1
conspiracy (2)
199:6,16
constantly (1)
156:17
construe (1)
168:24
consultant (5)
14:19;23:20;29:22;61:17;77:6
contact (2)
195:11,15
contacted (2)
5:5,12
contemplate (1)
94:14
contemplating (1)
94:10
contempt (2)
184:10;215:7
contempts (1)
239:8
content (1)
79:4
context (8)
38:3,6,11;122:15,16;217:22;224:2;229:10
continue (5)
54:5;64:10;130:12;193:3;229:24
Continued (6)
33:12;78:13;104:7;149:15;186:25;220:23
contract (1)
218:7
contradiction (2)
200:6;201:2
contradictory (2)
200:21,25
contrary (2)
35:22;112:15
controlled (1)
189:9
controlling (1)
72:21
convenience (2)
181:16;182:2
convenient (1)
181:18
conversation (32)
5:16;56:20,21,24;57:8;58:15,17,21;59:22,24;60:3,21;61:8;67:10;68:22,24,25;69:19,22;70:12;77:13;78:5,10;79:1,4,23,25;87:12,16;93:5;129:24;131:5
conversations (2)
29:22;66:25
convey (1)
115:4
conveyed (2)
74:9;80:13 | conveying (1)
31:16
convict (2)
199:7,16
convicted (23)
139:5,9,22,24;142:21;148:20;181:7;182:19,22,25;183:3;188:25;189:3,8,12;190:3;199:20,24,25;200:3;201:1,2;206:18
convicting (1)
146:11
conviction (7)
32:18,20;33:1;183:12;184:1,3,7
convictions (7)
89:14,15;184:5;185:2;188:19;210:12,13
convince (1)
234:7
convinced (1)
234:5
convincing (1)
219:6
cop (1)
183:10
copied (1)
42:17
copies (2)
18:15;129:11
copy (9)
36:18;59:6,20;64:25;65:2;75:13;97:20;187:20;201:14
corner (1)
180:4
corporate (1)
38:4
corporations (2)
38:7,9
corrected (1)
75:16
corrections (1)
227:17
correctly (6)
33:4;37:13;134:8;145:13;199:18;200:5
couching (1)
195:3
counsel (51)
4:23;5:1;6:10;8:15,18,24;17:22;67:1,15,24;68:2,6,9,13,16,22;69:19,19,25;74:22;77:10,25;78:2;84:7;96:8;97:20;98:11,18;99:1,2,8;102:4,7;107:19,22;124:19,21;125:17,18;126:10,19;129:12,25;132:7;204:8;210:18;216:12;237:14;238:15;240:15,18
counseled (1) |
+
+| 5:17 | 148:4,7,10;150:20; | crime (3) | David (20) | 95:16;101:5;141:25; |
+|---------------------------|--------------------------|----------------------------|-------------------------|----------------------------|
+| counsels (1) | 152:9,18,21;153:16; | 166:6;182:19;192:14 | 12:15;22:12,23;26:22; | 142:6,10,23;143:8; |
+| 69:2 | 154:9;155:9;156:21; | crimes (1) | 40:8;41:8;44:22;45:4; | 147:25;159:22;165:13; |
+| counsel's (4) | 159:9;160:8,25;161:3,9; | 182:23 | 47:2;49:6,8;50:2,3; | 167:2,3,8,11;172:11,24; |
+| 35:13;129:8;177:23; | 162:9,11;163:18,23; | criminal (34) | 55:22;62:11;63:16; | 183:17;184:24;185:1; |
+| 200:18 | 164:18,21;167:4,9,11, | 9:10;10:25;11:12; | 70:24;83:13;199:7; | 188:13,15;197:15; |
+| Count (2) | 18:169;5,10;170:6; | 32:16;38:5,7;66:8,8; | 213:12 | 217:10;235:20 |
+| 201:1,2 | 171:4,12;172:9;173:17, | 94:15;100:10;148:14; | David's (1) | decision-making (1) |
+| counts (1) | 19:174;20,22,23;175:11, | 153:23;154:15;155:15; | 47:18 | 10:4 |
+| 74:24 | 12,20,24;176:3,6,20,22; | 163:8;184:10;185:2; | 4:5;8:21;40:9;202:2 | decisions (1) |
+| county (5) | 177:21,22;179:19,21; | 190:12,19;192:21; | 4:5;8:21;40:9;202:2 | 14:24 |
+| 144:6,24;145:18,21; | 181:25;183:24;187:19, | 212:13;215:3,22;216:2, | day (44) | declaration (4) |
+| 148:5 | 21,22;190:16;192:9,20, | 7;222:11;229:1,8,9,16; | 23:13,13;39:6;57:7; | 65:12;66:1;80:5,24 |
+| couple (5) | 24,193:3;194:6,8;198:1; | 233:10;235:14,20;236:3 | 58:5,7;59:9;61:24;64:5; | deemed (1) |
+| 22:1;67:3;156:1; | 199:14;200:12,14,18; | criminals (2) | 69:23;71:9,10;96:6; | 186:24 |
+| 177:7;226:21 | 201:6;202:9;203:11,16, | 229:2,16 | 110:13;127:11;139:16; | deems (1) |
+| course (26) | 25;204:5,8,11,13,19; | crooks (6) | 143:3;146:15;147:3,5,7, | 85:6 |
+| 5:13;21:14;48:24; | 208:2,3,10;209:16,21; | 114:11;203:7,13; | 8,15;155:1,2;156:17; | deeply (1) |
+| 110:24;114:25;123:2; | 211:1,6,8,10,12;217:13; | 210:22,23;211:19 | 165:11;185:3,5;191:21; | 53:12 |
+| 142:18;158:24;164:1,9, | 221:23;222:24;223:5,7, | crossed (2) | 194:1,13,13;195:2; | defective (5) |
+| 17;166:12;168:1,6; | 730:3;231:11;233:7; | 80:2;224:10 | 200:7;205:18,20;206:4; | 186:17,18,22;187:2,7 |
+| 170:11;171:3,11,21; | 234:11,23;235:18;236:5, | 84:23;211:14;229:22 | 224:2;231:3,7;232:5,18; | defendant (8) |
+| 173:8;174:2;185:21,22; | 9,14,16;237:2,14,16,18, | cross-examining (1) | 239:21 | 4:18;101:3,15,17; |
+| 188:12;192:12;194:18; | 22,24;238:2,18;239:5, | 169:20 | days (13) | 149:9;153:23;210:20; |
+| 224:16 | 12,19,21,24;240:1,4,8, | crossing (1) | 64:19;150:7,10,23; | 216:2 |
+| COURT (321) | 11,14,15,18,21 | 63:5 | 151:7,15;165:16;199:6, | defendants (22) |
+| 4:2,8,9,12,13,17,21; | courthouse (4) | Crownmayer (1) | 15 | defendants (22) |
+| 5:1,13,17,19,20,23;6:1,5, | 6:24;58:8,13;109:20 | 90:12 | day-to-day (1) | defendants (22) |
+| 9,10,13,17,20;7:14,17, | courtroom (24) | cup (1) | 158:11 | defense (23) |
+| 23:8;5,6,9;9:15;11:9; | 4:24;7:1;18:16;86:8; | 109:9 | dead (1) | 10:25;15:1,6;16:13, |
+| 13:16;17:7,11,16;19:12, | 97:4;99:5,9,19,20;102:6; | cured (1) | 159:21 | 14,22;68:2,6,18;73:13; |
+| 19,24;35:2;36:4,21,24; | 103:4;108:6;118:2; | 174:10 | dealt (1) | 87:19;187:5;193:23; |
+| 37:3,7,17;38:17;48:5,6; | 153:25;217:3,15; | curiosity (7) | debate (1) | 195:12;204:7,8;210:18; |
+| 52:8;53:6,23;54:4; | 219:22;220:17;232:21, | 221:18;222:9;231:15, | 28:16 | 214:16;228:25;229:13; |
+| 61:17;63:2;64:12,15; | 24;233:9;234:12;235:9; | 24;232:2,13,15 | decade (2) | 238:8,9;240:18 |
+| 65:17,21;69:4,17;72:11; | 238:13 | current (2) | 174:7,11 | defensing (1) |
+| 74:12;75:23;76:12; | Court's (10) | 157:23;158:9 | December (27) | 67:24 |
+| 77:23;79:9;80:25;81:6, | 63:7,13;70:1,6;96:17; | currently (1) | 105:13;109:20;110:3, | definitely (2) |
+| 12;82:4;84:3,7,12,15,18, | 98:23;130:14;138:19; | 6:22 | 6,9,22;113:10,22; | 15:21;237:9 |
+| 89:16,21,24;95:20,22; | 171:9;184:22 | cut (4) | 117:13;121:11;124:2,7; | definition (1) |
+| 96:1,5,6,17,24;97:2,8,19, | covered (1) | D | 126:19;130:14;131:6; | 214:3 |
+| 21,23;98:17,22;99:1,2,7, | 172:8 | Daily (1) | 138:3;157:3;170:6; | defy (1) |
+| 14,23,24;100:4,7,17; | cow (3) | date (20) | 173:9,15;175:21; | 141:16 |
+| 101:9,12,19,20,23; | 50:5;91:17,19 | 25:11;47:5;48:8; | 199:19;200:4,21; | degree (5) |
+| 102:13,18;104:5;105:1, | Craig (2) | 54:25;55:2;68:25;103:6, | 203:12;223:5;231:9 | 45:4;59:11;86:13; |
+| 2,7,9,15,18;106:5,14,22, | 68:14;74:22 | 7;109:17;149:14; | decide (6) | 95:9;218:2 |
+| 25;108:10;109:23; | crazy (1) | 150:25;151:1,14;163:1; | 140:22;166:5;208:22, | deliberate (18) |
+| 110:2,6,8,13,20;112:6; | created (13) | 185:15;186:19;188:10; | 23;217:2;239:5 | 141:25;142:6,10,23; |
+| 113:3,22;115:1,15,18; | 19:6;20:3,4,6,12,14; | 194:3;234:25;235:2 | decided (7) | 144:8;147:25;155:2; |
+| 117:4;118:24;119:11, | 82:7;97:15;162:1 | dated (4) | 85:17;114:11,14; | 157:14;159:22;161:11; |
+| 14;120:19;121:18; | creation (1) | 22:12;26:21;63:16; | 141:16,20;154:4;240:6 | 167:2,3,8,11;183:17; |
+| 122:7,10,12,12;123:4, | 20:7 | 99:15 | decides (1) | 184:24;185:1;188:13 |
+| 10,12;125:6,8,14;126:8, | credibility (1) | dates (3) | 101:4 | deliberated (1) |
+| 16;127:12,15;128:24; | 192:15 | 48:1;54:20;189:10 | deciding (1) | 214:6 |
+| 129:2,8,12,17,21;130:3, | credit (1) | Daugerdas (12) | 112:8 | deliberately (3) |
+| 6,9,24;131:16;133:18, | creditor (1) | 4:7,10;77:10;102:6, | decision (27) | 43:10;141:16,20 |
+| 19;134:19;135:10; | credibility (1) | 10;103:8;118:9;134:6; | 14:22;23:1;72:11; | deliberating (4) |
+| 136:14,16;137:24;138:1, | 52:10 | 137:2,3;147:22;212:18 | | |
+| 4,12,14;139:8,21;140:3; | | | | |
+| 141:6,11,16,20,25; | | | | |
+| 142:6,11,13,24;143:3,9, | | | | |
+| 20;145:3,5,15;146:7; | | | | |
+
+| 169:6,12;183:18;
213:23 | determining (3)
158:25;159:1;211:18 | disabled (1)
239:8 | 239:10 | 60:17;62:18;82:24;
83:14;84:19;91:5;92:20;
93:21;96:25;101:15;
111:13;113:23;114:20;
121:2;132:10,11;
145:15;151:21,23;
229:7;238:5;239:14 |
+|----------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| deliberations (10)
96:6,11;169:9;200:10,
14,16;205:6;213:21;
219:6;222:19 | developed (1)
129:9 | disagree (1)
15:12 | displease (1)
236:2 | Dr (8)
177:18,24;178:10;
180:23;206:8;218:16;
219:4,6 |
+| demonstrate (2)
99:21;224:7 | devoted (1)
237:3 | disagreed (1)
223:17 | dispute (1)
119:1 | drafted (1)
65:7 |
+| demonstrate (2)
99:21;224:7 | diagnosed (1)
176:12 | disappoint (1)
235:2 | disregard (3)
173:10,23;217:11 | downstairs (1)
238:13 |
+| demonstrates (1)
126:18 | difference (3)
142:17,18;225:25 | disbarred (1)
119:23 | disregarded (1)
218:11 | Dr (8)
177:18,24;178:10;
180:23;206:8;218:16;
219:4,6 |
+| denied (2)
35:2;100:12 | different (20)
16:11;19:10;31:10;
51:10;66:1,2,6;76:20;
87:8,11;91:14;113:19;
122:5,5;154:21,22;
171:16;187:2;210:16,16 | discharged (1)
180:11 | disseminated (1)
100:4 | Drafted (1)
65:7 |
+| Department (19)
23:2,16;26:3,6;30:12;
32:1;55:8;89:13;98:4,9;
99:19;148:17;150:8,21;
151:3;173:12;175:17;
180:5;190:22 | dire (126)
11:12,13,16,17,22,24;
12:12,19;13:2,13;14:18,
19;16:24;17:23;18:6,11,
16;19:8;20:13,14,15,24,
25;21:5,7,21;22:4,18;
23:10,12,14,15;24:17,
20;25:9;28:2,5,9,23;
29:2,15,18,21;30:1,5,7,
11,18;32:15;33:5;34:2,
3;35:3;38:16;42:18;
43:3,9,16,19;44:2,9;
47:13;49:22,24;50:18,
20;59:4;60:4;64:20;
69:4,8,17;70:22;71:13,
19,24;72:20;83:4;86:15;
89:6,12,92:10;94:6;
96:14;102:2;103:14;
140:10,11,13,21;141:3,
9;143:1;147:3,5,8,15;
149:13;159:25;161:22;
162:23;165:25;167:17;
171:16;185:4;191:1;
192:17;203:20;207:16;
216:21;222:8;226:16;
227:13,22;228:1,2,13,
21;229:1;230:2;232:16;
234:14,17,20;236:18;
237:12 | disciplinary (26)
40:10;41:10;60:22;
80:17;98:2,3,20;99:18;
100:6;120:12;136:11,
19;150:9;151:4;155:20,
23;176:3,8;191:8,12,16;
207:22;208:4,5;216:10,
12 | distinction (1)
143:22 | drafter (4)
65:8,72;17;73:8,9 |
+| deposition (1)
156:2 | dire (126)
11:12,13,16,17,22,24;
12:12,19;13:2,13;14:18,
19;16:24;17:23;18:6,11,
16;19:8;20:13,14,15,24,
25;21:5,7,21;22:4,18;
23:10,12,14,15;24:17,
20;25:9;28:2,5,9,23;
29:2,15,18,21;30:1,5,7,
11,18;32:15;33:5;34:2,
3;35:3;38:16;42:18;
43:3,9,16,19;44:2,9;
47:13;49:22,24;50:18,
20;59:4;60:4;64:20;
69:4,8,17;70:22;71:13,
19,24;72:20;83:4;86:15;
89:6,12,92:10;94:6;
96:14;102:2;103:14;
140:10,11,13,21;141:3,
9;143:1;147:3,5,8,15;
149:13;159:25;161:22;
162:23;165:25;167:17;
171:16;185:4;191:1;
192:17;203:20;207:16;
216:21;222:8;226:16;
227:13,22;228:1,2,13,
21;229:1;230:2;232:16;
234:14,17,20;236:18;
237:12 | disclosed (13)
43:11;67:15;77:13;
79:8,16;80:24;81:6;
83:20,25;85:17,19;
95:16;188:13 | district (5)
30:20;105:6;203:17,
19;235:25 | drafters (1)
73:10 |
+| deputy (11)
5:3;104:4;106:25;
107:9;108:14,20;117:17,
25;129:24;238:9;239:15 | disclosing (1)
185:13 | disclose (13)
43:11;67:15;77:13;
79:8,16;80:24;81:6;
83:20,25;85:17,19;
95:16;188:13 | docket (1)
51:19 | drafting (6)
25:16;65:6;76:15,18;
79:11;85:24 |
+| DeRosa (3)
206:8;218:16;219:4 | disclosed (7)
32:15;43:5;44:3;68:9;
83:4;97:15;190:12 | disclosing (1)
185:13 | document (19)
17:5,19,22,25;18:8,12,
21,25;19:15;20:2,12,25;
21:4,8,20;124:25;136:6;
179:16;180:4 | drafts (1)
76:20 |
+| DeRosa's (1)
219:6 | discovered (1)
129:13 | discourage (1)
93:6 | docket (1)
51:19 | draw (4)
64:16;66:5;129:8;
233:19 |
+| describe (5)
14:17;58:20;70:19;
82:6;205:17 | discredit (2)
142:20,20 | discovery (1)
81:24 | doctor (1)
176:12 | draws (1)
52:22 |
+| described (3)
49:8;50:4;221:25 | discuss (3)
58:19;200:10,14 | discussed (4)
7:5;61:20;76:5;117:7 | dollars (1)
232:20 | drink (3)
109:8,25;110:3 |
+| description (1)
231:15 | discussion (7)
69:14;74:1,3;83:24;
87:17;93:10;112:23 | discussing (3)
63:4;133:4,18 | DOJ (1)
148:18 | drinking (6)
109:4,6,15;179:10;
184:18,19 |
+| designed (2)
20:8;29:24 | discussions (5)
67:8;83:20;87:23;
88:3,9 | done (11)
13:24;23:10;81:8;
142:19;153:18;163:13;
192:2;198:19;208:17;
238:23,24 | Donna (1)
4:12 | drivers (1)
193:7 |
+| desire (1)
222:14 | directing (8)
6:17;17:19;131:10,12;
133:19;139:10;146:7;
177:22 | done (11)
13:24;23:10;81:8;
142:19;153:18;163:13;
192:2;198:19;208:17;
238:23,24 | Donna (1)
4:12 | drivers (1)
193:7 |
+| destroy (1)
231:6 | directed (4)
5:6;43:13;67:13;
120:19 | door (1)
146:3 | Douna (1)
70:5 | driving (2)
182:25;215:6 |
+| destroyed (2)
231:8,8 | directing (8)
6:17;17:19;131:10,12;
133:19;139:10;146:7;
177:22 | door (1)
146:3 | Due (1)
180:11 | drivers (1)
183:3,5,12;184:4,5 |
+| details (2)
29:7;62:24 | direction (1)
48:5 | dossier (7)
43:25;44:11,21;81:15,
17;82:6,12 | Due (1)
70:5 | driver (1)
183:3,5,12;184:4,5 |
+| determinant (1)
128:17 | direction (1)
48:5 | dots (3)
210:24;211:18;227:16 | Due (1)
180:11 | Duane (1)
111:6,18;112:5,23;
113:7,21 |
+| determination (3)
14:2;125:16;126:9 | directly (2)
200:18,21 | doubt (1)
210:8 | Due (1)
111:21,25 | due (1)
180:11 |
+| determine (3)
130:15;137:24;158:22 | disability (1)
175:14 | down (30)
29:3,6,14;45:15;
50:15;55:17;56:2,17; | Duly (2)
8:4;101:18 | during (87)
8:24;12:21;20:23; |
+| determined (3)
43:10;149:6;235:15 | | | | |
+
+deliberations - during (8)SOUTHERN DISTRICT REPORTERS
+
+| 21:5,7;28:9;30:5,7,10,
18:32;15:33;5:34;17,17,
20:35;3,3,20;36:17;
39:20;42:18;43:2,4;
44:2,9;46:11;47:13;
48:24;50:13;56:5;59:22;
60:21;61:8;63:1,8,13;
64:9,20;66:20;67:17;
69:4,25;71:19,24;72:20,
25;74:17,19;75:3,8;
79:20;80:7,8,21;25:85:4;
88:18;89:5,12;92:10;
93:5;94:6,20,24;95:17;
96:11;99:16;101:10;
103:14;106:11;109:23;
112:20;129:13;143:1;
165:16;181:9;182:13;
213:23;216:20,21;
221:17;222:7;234:14,17,
19;236:18;237:12 | 178:12,18
effects (1)
110:5
either (25)
10:11;20:6;24:22;
29:23;41:16;47:15;
48:22;69:19;71:17,22;
77:14;80:20;94:5;98:12;
107:7;134:12;136:9;
139:9;140:24,24;
160:13;166:18;179:11;
183:7;229:12
elderly (3)
230:13,16,23
Election (1)
66:9
eleven (6)
137:9;142:21;148:6;
149:6;194:20,23
elicit (1)
101:2
else (14)
44:24;56:17;60:18;
67:20;76:24;83:24;
134:2;140:17;172:23;
173:6;174:24;194:18;
237:2;239:17
else's (1)
235:23
email (25)
14:13;22:11,11,16,23;
26:21,25;27:4,7,22;
81:14;82:23;83:6,7,7,9,
13:90;22:91;3,4,8,11,15;
92:16,19
e-mail (27)
39:6,9,14,14,15,19,22;
40:7,25;42:18;45:9;
47:1,25;48:1,8;50:4;
55:11,13,21;56:4;57:10;
58:6;62:11,15,23;70:1,
15
emails (3)
80:10;83:12;93:23
e-mails (7)
40:6,21,22;42:13;
57:9,12;59:18
e-mail's (1)
43:24
embarrassed (1)
152:3
emblematic (1)
219:15
emergency (1)
96:7
emphasize (1)
202:20
employ (1)
10:4
employee (2)
30:21;31:7
employment (1)
26:11 | end (25)
28:5;30:1;35:9;38:19;
56:19;57:7;58:7;59:24;
60:5;64:5;71:9,10;
86:23;92:14;116:16;
159:7;181:4;205:18,20;
206:4;211:4;216:21;
220:8;222:15;226:24
endeavor (1)
192:25
ended (1)
185:23
endorphins (1)
207:25
enforcement (2)
32:2,4
engaged (1)
156:18
engaging (1)
226:3
English (3)
167:21;171:23;202:6
enjoy (1)
232:21
enlisted (1)
88:22
enlisting (1)
88:19
enormous (2)
210:3,5
enormously (1)
234:9
enough (7)
46:22;47:9;49:20;
53:18;88:14;200:1;
210:3
ensure (1)
30:7
entered (2)
94:19;234:12
entire (5)
19:15;50:21;51:5;
96:11;234:20
entirely (1)
28:19
enumerated (1)
232:25
envelope (1)
201:14
envelopes (1)
182:1
episode (1)
96:12
Eric (1)
238:10
error (1)
96:1
essence (2)
128:21;200:13
established (4)
131:6;157:9,10;
158:11
estimate (1) | 169:22
et (1)
8:21
eternity (1)
201:15
evaluate (1)
16:2
evaluating (2)
159:15;164:15
evaluation (2)
159:11;176:23
evaluations (1)
100:7
evasion (1)
215:19
even (18)
30:10;31:23;39:4;
46:21;47:15;70:18;
87:14;91:10;112:12;
152:15;182:15;184:19;
191:20;197:24;207:2;
221:11;225:21;240:5
evening (5)
69:23;70:14;185:6;
240:16,23
event (3)
7:6;34:17;70:15
events (2)
176:24;214:22
eventually (5)
16:25;18:3,5;49:6;
126:7
everybody (6)
39:23;140:17;199:25;
237:2,6,13
Everyone (1)
115:1
eviction (2)
52:4,6
evidence (58)
11:10;17:17,18;19:25;
20:1;35:21;36:24,25;
65:22,23,24;75:24,25;
76:13,14;125:8,9;
143:19;145:5,6;159:5;
164:15;173:19,20;
175:24,25;176:6,7;
177:16;179:21,22;
187:8;194:8,9;200:1;
204:1,3;205:5,18;206:4;
211:4,10,11,22;212:9;
213:1,8;216:3,13;217:3,
10,14,14,22;219:23;
220:11,17;222:20
evinces (2)
173:10,23
exact (3)
134:11;144:23;194:3
exactly (8)
12:13;44:1;58:21;
85:19;103:13;141:1;
196:22;226:3
EXAMINATION (11) | 8:11,20;44:7;84:25;
90:1;101:10,24;130:12;
204:14;222:24,25
example (3)
34:14;38:5;219:15
examples (1)
13:7
except (1)
199:25
excerpt (2)
17:6;70:25
excerpted (2)
70:25;91:12
excluded (2)
187:8;217:12
exclusively (2)
38:1,12
Excuse (2)
196:21;231:21
excused (6)
90:10;96:9,24;97:1;
238:6,7
execute (1)
6:18
executed (3)
5:21;150:23;151:14
exercised (3)
30:6;32:12;86:7
exercising (2)
29:8;30:2
Exhibit (86)
10:11,13,15,22;11:4,9;
12:6;17:3,10,16,18;
18:17,18;19:9,11,19,24;
20:1,5,19,22;21:24;
26:19;31:1;36:15,24,25;
39:11;64:23;65:10,16,
21,23,24,25;75:11,19,23,
25;76:1,8,12,14,25;80:5;
82:8,15,20;83:11;85:2;
87:23;124:25;125:9;
126:14;129:12;130:21;
145:2,5,6;150:16;
157:19,20;173:15,19,20;
175:20,24,25;176:6,7,
11;177:16,17,18;179:13,
21,22;181:2;194:5,8,9,
10;199:22;204:17;
211:11;230:3
exhibits (4)
65:2;203:23,25;204:2
existence (2)
43:11;70:20
existing (1)
238:3
expectation (1)
197:11
expected (1)
62:18
expenses (2)
137:18,19
experience (14)
10:7;28:8;31:18; |
+|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+
+| 52:23;53:5,8,17;119:16;154:1;165:19;207:24,25;222:9;236:23 | 171:6,19;172:6;173:8,9;176:18;179:9;185:13;189:3;191:12,15;193:9;213:18;216:1,6,16;219:12;225:3,4,16;227:6,21;235:5 | 26:11
fault (2)
44:17;171:9
favor (11)
111:8;113:25;114:2,8;140:23;212:9;213:4;219:17;229:11,16;238:15
favorable (1)
28:4
FBI (1)
32:4
fear (1)
220:9
February (21)
99:15;116:20;118:8;129:22;136:1,7,20;147:7;150:20,24;151:13;153:12;177:2,4,4,12;179:1,4;181:4,5;240:24
federal (14)
9:14;31:25;66:9;106:15;109:19;116:6;120:9;122:17;132:8,23;136:2;138:1;222:11;223:7
fee (1)
221:11
feel (3)
112:18;198:9;208:2
feelings (1)
212:21
felon (7)
139:5,9,22,24;148:20;199:24;206:18
felonies (1)
181:8
felony (2)
89:15;210:13
felt (5)
60:16;91:10;138:22;154:11;205:6
ferret (1)
141:11
ferreting (1)
141:4
few (16)
18:23;20:5;37:11;44:7;67:3;81:13;82:2;90:5;103:4;151:15;153:7,19,22;220:6;221:2;232:17
Field (3)
4:16,18;77:11
██████ (1)
20:8
Fifth (7)
99:3;100:20;102:4,7,9,19;233:25
fight (5)
205:1,8,14;206:1;213:19 | fighting (4)
205:4,9,14;213:19
fights (1)
156:18
figure (1)
50:6
file (7)
23:6;44:22;63:19;82:7,9,14,19
filed (31)
46:4;53:11,14;62:19;64:17,19,24;65:12;66:25;68:5,8;72:10,22;73:15;95:15;97:23;114:18,24;115:1;135:23;136:5,6,8,10,20;150:7,17,20;181:4;191:20;224:3
files (3)
44:16;66:9;95:11
filing (4)
67:1,9;72:14;83:18
filings (2)
100:5,7
fill (1)
126:5
filled (1)
137:22
final (4)
29:5;53:8;73:14;222:17
finances (9)
131:25;132:6,12,14,19,22;133:3,10,18
financial (15)
126:3,6,11,18;129:10;130:16;133:23;134:20,25;135:3;137:16,25;138:25;207:15;214:24
financially (4)
124:12;136:24;137:3,12
find (7)
60:1,93;18:95;11:108;25:213:3;219:12;223:16
findable (1)
81:23
finding (2)
131:13;206:25
findings (1)
99:25
fine (6)
19:17,19;84:7;101:9;137:13;238:17
finish (4)
50:24;64:12;136:22;240:22
finished (2)
207:3,5
finishing (2)
64:11;130:6
Fink (1) | 77:8
firm (37)
9:2,6;12:6,23;13:1;16:1;18:11;21:11,12,17;24:22;25:3,5,8;28:12;30:4;42:2;44:14,24;45:2;66:17,23;67:20;74:2;75:2,4;77:16;78:3,10;79:2;83:21,24;86:7;87:24;88:10,19,22
firms (1)
77:10
firm's (3)
10:19;79:7;81:4
First (43)
5:1;6:25;7:11,24;23:1,13,13;37:7;43:8;50:24;55:8;65:7;73:9;75:4;83:9;86:25;89:13;93:15;98:4,9;99:18;129:9;138:8;142:7,8;143:3;144:4,7;145:11;147:15;150:8,21;151:3;170:16;173:12;175:17;176:21,24;183:5,7;184:1;185:3;223:20
fit (1)
31:14
fitness (1)
176:21
five (3)
58:16;63:22;130:9
fix (1)
69:14
flash (1)
39:21
flirtatious (1)
197:24
floor (1)
156:14
focus (7)
15:8,9;25:17,18;44:7;50:12;145:8
focused (9)
23:9;24:10,10;25:11;42:21;49:5;55:6;61:3;72:18
folded (2)
183:20,21
folders (3)
21:11,15,18
Foley (1)
58:12
follow (25)
217:7,19,224:24;225:1,2,5,6,16;226:19;227:5,6,9,9,12,14,17,19,22;228:2,8,9,12,13,14,18
followed (6)
224:20,23;225:11,13;226:22;228:11
following (1)
181:8 |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| F | | | | |
+| facility (1) | | | | |
+| 176:13 | | | | |
+| facing (2) | | | | |
+| 35:13;126:13 | | | | |
+| fact (64) | | | | |
+| 26:4;28:20;30:24;34:20;46:4,6;47:16;49:4,7;59:14;61:20;63:12;65:7;68:1;73:7,8;74:4;85:21;91:15;95:1;98:3;114:22;124:6;127:11;132:13;133:10;142:1,2,19,21;143:12,15;147:18;148:11;152:5;159:23;164:14;166:9,13;167:6;169:17; | 171:6,19;172:6;173:8,9;176:18;179:9;185:13;189:3;191:12,15;193:9;213:18;216:1,6,16;219:12;225:3,4,16;227:6,21;235:5
factor (8)
15:10,11,13;231:5;232:8,10,11,18
factors (1)
26:10
facts (19)
32:3;56:23;72:18;73:17;74:19;75:3,4;78:1;79:7;81:5,9;85:5;25:94;20:97;16:101;201:5;217:2,4
factual (1)
25:19
factually (1)
214:21
failed (2)
212:12,13
fair (39)
15:3;28:3;30:7;31:20;66:3,19;71:16,21;94:9;131:20;148:7;153:21;159:6;160:22;205:6;209:7;212:20,22;213:9;214:6,9,15;215:19,21;216:8;218:5,10,14;219:3,7,15,18,19;221:11;225:22;228:22;231:19;236:22;237:8
fairly (5)
140:22;192:8;216:3,13;238:25
faithful (1)
163:15
fall (1)
171:3
false (5)
28:19,20;72:24;162:1,4
familiar (1)
223:6
family (3)
32:3;188:18,18
fantasy (1)
198:7
far (7)
63:9;71:15;201:20;210:16;225:10;228:25;239:3
fashion (1)
192:13
fate (1)
192:16
father (11)
23:16;26:2;46:19,24;47:10,12,17,22;148:16,20;190:22
father's (1) | 26:11
fault (2)
44:17;171:9
favor (11)
111:8;113:25;114:2,8;140:23;212:9;213:4;219:17;229:11,16;238:15
favorable (1)
28:4
FBI (1)
32:4
fear (1)
220:9
February (21)
99:15;116:20;118:8;129:22;136:1,7,20;147:7;150:20,24;151:13;153:12;177:2,4,4,12;179:1,4;181:4,5;240:24
federal (14)
9:14;31:25;66:9;106:15;109:19;116:6;120:9;122:17;132:8,23;136:2;138:1;222:11;223:7
fee (1)
221:11
feel (3)
112:18;198:9;208:2
feelings (1)
212:21
felon (7)
139:5,9,22,24;148:20;199:24;206:18
felonies (1)
181:8
felony (2)
89:15;210:13
felt (5)
60:16;91:10;138:22;154:11;205:6
ferret (1)
141:11
ferreting (1)
141:4
few (16)
18:23;20:5;37:11;44:7;67:3;81:13;82:2;90:5;103:4;151:15;153:7,19,22;220:6;221:2;232:17
Field (3)
4:16,18;77:11
██████ (1)
20:8
Fifth (7)
99:3;100:20;102:4,7,9,19;233:25
fight (5)
205:1,8,14;206:1;213:19 | fighting (4)
205:4,9,14;213:19
fights (1)
156:18
figure (1)
50:6
file (7)
23:6;44:22;63:19;82:7,9,14,19
filed (31)
46:4;53:11,14;62:19;64:17,19,24;65:12;66:25;68:5,8;72:10,22;73:15;95:15;97:23;114:18,24;115:1;135:23;136:5,6,8,10,20;150:7,17,20;181:4;191:20;224:3
files (3)
44:16;66:9;95:11
filing (4)
67:1,9;72:14;83:18
filings (2)
100:5,7
fill (1)
126:5
filled (1)
137:22
final (4)
29:5;53:8;73:14;222:17
finances (9)
131:25;132:6,12,14,19,22;133:3,10,18
financial (15)
126:3,6,11,18;129:10;130:16;133:23;134:20,25;135:3;137:16,25;138:25;207:15;214:24
financially (4)
124:12;136:24;137:3,12
find (7)
60:1,93;18:95;11:108;25:213:3;219:12;223:16
findable (1)
81:23
finding (2)
131:13;206:25
findings (1)
99:25
fine (6)
19:17,19;84:7;101:9;137:13;238:17
finish (4)
50:24;64:12;136:22;240:22
finished (2)
207:3,5
finishing (2)
64:11;130:6
Fink (1) | 77:8
firm (37)
9:2,6;12:6,23;13:1;16:1;18:11;21:11,12,17;24:22;25:3,5,8;28:12;30:4;42:2;44:14,24;45:2;66:17,23;67:20;74:2;75:2,4;77:16;78:3,10;79:2;83:21,24;86:7;87:24;88:10,19,22
firms (1)
77:10
firm's (3)
10:19;79:7;81:4
First (43)
5:1;6:25;7:11,24;23:1,13,13;37:7;43:8;50:24;55:8;65:7;73:9;75:4;83:9;86:25;89:13;93:15;98:4,9;99:18;129:9;138:8;142:7,8;143:3;144:4,7;145:11;147:15;150:8,21;151:3;170:16;173:12;175:17;176:21,24;183:5,7;184:1;185:3;223:20
fit (1)
31:14
fitness (1)
176:21
five (3)
58:16;63:22;130:9
fix (1)
69:14
flash (1)
39:21
flirtatious (1)
197:24
floor (1)
156:14
focus (7)
15:8,9;25:17,18;44:7;50:12;145:8
focused (9)
23:9;24:10,10;25:11;42:21;49:5;55:6;61:3;72:18
folded (2)
183:20,21
folders (3)
21:11,15,18
Foley (1)
58:12
follow (25)
217:7,19,224:24;225:1,2,5,6,16;226:19;227:5,6,9,9,12,14,17,19,22;228:2,8,9,12,13,14,18
followed (6)
224:20,23;225:11,13;226:22;228:11
following (1)
181:8 |
+
+| follows (3)
8:4;101:18;193:14
folly (2)
237:6,7
Foods (2)
52:11,14
football (5)
111:20,21,24,25;112:5
forethought (1)
197:10
forewoman (1)
169:4
forget (1)
140:2
forgotten (1)
188:11
form (21)
10:11;77:21,23;81:17;106:5;115:17,18;126:19,23;128:9;134:19;154:8;159:9;183:23;202:7;209:21;220:21;221:18,20;234:22,23
formally (1)
177:11
former (2)
7:13;30:20
forth (2)
31:4;73:22
forthright (1)
10:8
forthwith (2)
5:21;6:24
forum (1)
175:5
forward (1)
59:17
fought (3)
205:1,8;206:1
foul (1)
228:25
found (18)
22:18;41:3;44:18;60:22;61:6,18;66:16,17,18;68:19;69:6;79:12;173:9,22;211:22;213:24;219:5,17
four (7)
7:9,12;151:7;157:6,7;218:23;238:14
fourth (1)
7:13
Francisco (2)
11:19;12:2
[REDACTED] (1)
6:7
frankly (1)
18:10
fraud (2)
166:1;189:15
free (1)
238:5
frequently (1)
| 91:7
fricken (3)
114:11;203:7,12
Friday (1)
69:23
[REDACTED] (1)
175:22
front (11)
10:12;59:6;73:3;105:12;124:24;138:17;146:3;196:1,2;225:9;239:9
fruitful (2)
28:16;69:12
fruitless (2)
14:9;24:25
frustration (1)
44:12
full (5)
8:5;37:18;77:5;82:16;101:19
function (1)
164:5
funded (1)
137:25
funds (1)
126:15
funny (1)
181:19
furnished (1)
99:1
further (22)
71:4;84:2;88:19;89:22;93:11,23;95:21;96:4,17;97:6;99:8;107:9;190:16;204:4;217:12;222:23;229:19;236:8,9,13,14;237:14
G
| gather (1)
13:22
gathered (1)
27:1
gathering (1)
66:12
gave (20)
6:6;15:24;26:2,14,16;27:5;28:5;30:4;34:8;49:24;118:22;136:18;153:8;214:8;217:23;220:18;224:18;225:13;226:17;233:18
gears (1)
83:18
general (4)
23:15;31:21;217:16;221:25
generally (3)
109:18;130:17;166:25
genuinely (1)
96:15
Georgia (2)
100:1,1
gesturing (1)
160:20
gist (1)
217:16
given (16)
25:22;26:1;27:5,13;28:17;33:1;69:12;70:20;88:13,19;100:7,23;102:24;161:21;220:7;236:16
gives (1)
50:7
giving (1)
49:13
glanced (2)
62:21;83:16
glasses (1)
49:13
God (2)
111:6,18
goes (5)
27:4;37:10,11;165:4;196:19
[REDACTED] (6)
30:12,16,19,20,24;31:7
Good (29)
4:3,9,11,13,15,17,21,24,25;8:13,14;9:21;16:13;28:6;41:25;67:12;84:17;124:1;130:9;163:15;192:21,22;205:1,8,14;206:1;212:8;213:19;240:22
Google (8)
13:24;41:24;71:23;77:6,14;78:6;85:20;106:11
Googled (11)
| 23:20,23,25;26:17;41:19;61:16;86:4;106:8;113:14;116:13,15
Gosnell (2)
5:14;6:6
government (82)
4:2;6:16;7:11,24,25;8:3;10:11,13,22;11:3,4,9;12:6;17:3,9,10,16;18:17;19:11,19,24;20:5,19,22;26:4,7,11,18;36:19;39:11;65:9,15,16,21,25;74:15;75:11,18,19,23;76:1,7,8,12,25;79:6;80:5;81:4,24;82:15;85:2;87:22;101:4;102:13;106:23;107:12;137:5;202:3,12,14,16,17,21,21,23;204:17,23;212:4,8,9;213:4;219:17;230:3;233:2,9;234:16;235:10,11,16,22,24;236:2
government's (9)
7:4;15:4;17:18;20:1;65:23;75:25;76:14;96:9;219:16
grab (1)
39:23
[REDACTED] (1)
230:19
gradations (1)
16:16
grade (4)
16:9,11;27:5,25
grade-inflated (1)
16:23
grades (1)
16:20
grading (6)
15:22,25;16:1,6,7,23
graduate (1)
42:4
graduated (1)
12:10
graduation (1)
12:8
grant (1)
102:24
granted (2)
99:5;148:10
granting (1)
102:20
gray (1)
120:16
great (2)
30:6;132:14
greatly (1)
95:1
greeting (3)
182:1,4,5
grounds (2)
175:13;199:12
| group (2)
13:21;39:19
groups (1)
13:18
Guerin (5)
4:12,14;77:10;204:10;236:12
guess (13)
7:10;119:5;124:10;133:16;157:10;163:7;167:20;187:5;229:18;231:25;233:24;235:25;236:24
guided (2)
220:10;222:20
guilt (1)
213:7
guilty (9)
132:16;133:12;134:5;147:23;149:3;181:7;211:22;213:3,24
gun (1)
189:18
GX-14 (2)
82:8,9
|
+|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| H | | | | |
+| hairs (2)
226:2,3
half (2)
109:9;207:4
hand (4)
131:16;133:21;134:4;207:15
handed (1)
169:4
handing (1)
170:22
handle (1)
149:7
handling (1)
11:23
hands (1)
192:16
happen (4)
111:10;115:22;117:10;120:7
happened (6)
43:4;55:21;56:19;125:21;158:21;177:12
happening (4)
67:5;92:14;125:20;126:20
happens (2)
67:7;187:18
happy (1)
64:10
harassment (4)
183:13;184:7;189:25;215:7
hard (3)
30:9;65:2;230:14
| | | | |
+
+| hardcopies (1)
31:2 | highest (8)
34:4;43:20;44:3;
59:10;86:12;164:24;
167:12;168:4 | 22:226:5;229:19,21;
233:4;234:22;236:4,11,
15:237:11,15,17,19,21,
25;238:1,9,11;239:9,18;
240:3,10,17,19 | 28:18
idiot (2)
200:1;203:1
illness (1)
120:17
image (1)
205:12
immeasurable (1)
237:3
immediately (1)
51:1
immigration (5)
46:19;47:10,13,14;
148:16
immunity (14)
99:5;100:23;101:7;
102:16,20,20,25;107:13,
16;233:11,12,22,24;
234:2
immunize (1)
101:4
immunized (1)
108:7
impartial (4)
30:8;31:20;216:8;
228:22
impartiality (1)
216:17
impartially (2)
140:23;216:3
impeachment (1)
239:4
implying (1)
127:22
importance (1)
175:12
important (10)
10:8,9;127:18;172:10,
24;174:25;175:2,15;
176:20;240:12
importantly (1)
7:12
impression (7)
74:9;112:7;116:11;
128:17;162:1,3,4
impressionistic (1)
58:20
improper (4)
35:25;36:4;205:21,25
improperly (1)
15:4
inability (1)
126:18
inaccurate (2)
55:2;180:24
incident (5)
183:5;185:20;188:11,
14;189:19
inclined (1)
26:5
include (9)
9:14;62:12;73:17,25;
74:2,6,22;77:18;100:6 | included (6)
16:8;42:10;95:2;
124:8;166:20;188:22
includes (1)
45:21
including (3)
35:16;191:6;228:2
income (1)
152:7
inconsistent (1)
160:4
incorrect (9)
47:4,20;166:19;
205:17,23,24,24;206:2;
226:23
indeed (3)
89:16;208:6;209:24
indefinitely (1)
177:8
independent (1)
18:25
indicate (1)
26:12
indicated (1)
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indicates (1)
6:23
indicative (1)
219:20
indicted (3)
181:7;189:15,22
indictment (1)
182:4
indirectly (1)
238:25
individual (5)
23:14;24:20;28:1;
34:3;69:17
individually (1)
172:6
infirmity (1)
175:14
influence (2)
183:1;215:7
influenced (1)
110:14
info (2)
26:25;47:19
inform (1)
104:4
information (99)
6:4;11:21,22;13:5,7,9,
12,13,22;14:20,22;
15:25;18:10;20:10;
21:12;23:8,21;28:17,18,
20,20;30:12;34:5;39:10;
40:23;42:14,20;43:1,10,
13;44:13,17,20,23;
45:18,21;46:1,13,23;
47:1,3,9;49:5,21;50:1,8;
51:1,53;18:54;10,19;
55:3,14,23,24,25;56:18;
57:3,6;58:24;62:12; |
+|-------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| heads (1)
234:18 | hillary (1)
77:2
himself (2)
32:24;94:18
HIPAA (2)
97:25;175:5
hire (3)
124:16;130:16;137:20
history (7)
62:25;86:2;89:14,15;
190:12;210:11;229:2
hits (2)
23:24,24
hold (1)
59:1
holding (1)
54:2
holdout (1)
200:8
hole (1)
60:17
Hollander (1)
40:1
holy (3)
50:5;91:17,19
home (3)
117:15;164:18;196:22
homeowners (1)
162:5
honeymoon (1)
89:18
Honor (143)
4:3,11,15,25;5:10;6:3,
14,16;7:9,16,18,19,20;
8:10;11:3,6,7;17:9,13,
14,15;19:9,13,18,21,22,
23:34;25:36;19,23;64:8;
65:18,19;77:22;81:11,
25;84:2,5,9,10,11,22;
85:5,6,12;89:25;95:19,
21;96:19,20,21,22,23;
97:7;98:25;99:10,11,12,
13;100:15,21;101:8,13;
102:12,15,16,17;106:19,
21;112:4;113:2;115:17;
119:13;122:10;125:4,7;
129:1;130:2,23;134:17;
136:15,17;141:5;145:1,
4;148:9;152:17;154:8;
156:20;159:8;162:7;
173:14,18;175:19,23;
176:1;179:15,20;
181:24;183:23;190:14;
192:19,22;194:4,7;
199:13;200:9;202:7;
203:15,22,24;204:4,9;
211:2,7,9,13;221:1,21, | hope (3)
149:1;198:6;240:8
hoping (2)
71:7;197:18
horse (1)
159:21
hospital (2)
5:25;6:8
hour (1)
135:18
hours (2)
61:23;237:3
house (6)
148:25;161:23;162:2,
5,8;170:10
household (4)
47:3,19;152:7;161:15
housekeeping (1)
211:2
hundred (1)
160:16
husband (35)
6:7;46:23;47:17;
89:15;139:5,9,22,24;
148:12,14,20,22,24;
156:17;161:15,18,20,23;
162:2,5,17;163:13,15;
185:23;188:23,24;
189:2;199:23;206:18,
24;210:12,20;229:8,9;
230:4
husband's (1)
190:18
hyperlink (1)
82:17
hypothetical (1)
158:20
I | 28:18
idiot (2)
200:1;203:1
illness (1)
120:17
image (1)
205:12
immeasurable (1)
237:3
immediately (1)
51:1
immigration (5)
46:19;47:10,13,14;
148:16
immunity (14)
99:5;100:23;101:7;
102:16,20,20,25;107:13,
16;233:11,12,22,24;
234:2
immunize (1)
101:4
immunized (1)
108:7
impartial (4)
30:8;31:20;216:8;
228:22
impartiality (1)
216:17
impartially (2)
140:23;216:3
impeachment (1)
239:4
implying (1)
127:22
importance (1)
175:12
important (10)
10:8,9;127:18;172:10,
24;174:25;175:2,15;
176:20;240:12
importantly (1)
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impression (7)
74:9;112:7;116:11;
128:17;162:1,3,4
impressionistic (1)
58:20
improper (4)
35:25;36:4;205:21,25
improperly (1)
15:4
inability (1)
126:18
inaccurate (2)
55:2;180:24
incident (5)
183:5;185:20;188:11,
14;189:19
inclined (1)
26:5
include (9)
9:14;62:12;73:17,25;
74:2,6,22;77:18;100:6 | included (6)
16:8;42:10;95:2;
124:8;166:20;188:22
includes (1)
45:21
including (3)
35:16;191:6;228:2
income (1)
152:7
inconsistent (1)
160:4
incorrect (9)
47:4,20;166:19;
205:17,23,24,24;206:2;
226:23
indeed (3)
89:16;208:6;209:24
indefinitely (1)
177:8
independent (1)
18:25
indicate (1)
26:12
indicated (1)
7:6
indicates (1)
6:23
indicative (1)
219:20
indicted (3)
181:7;189:15,22
indictment (1)
182:4
indirectly (1)
238:25
individual (5)
23:14;24:20;28:1;
34:3;69:17
individually (1)
172:6
infirmity (1)
175:14
influence (2)
183:1;215:7
influenced (1)
110:14
info (2)
26:25;47:19
inform (1)
104:4
information (99)
6:4;11:21,22;13:5,7,9,
12,13,22;14:20,22;
15:25;18:10;20:10;
21:12;23:8,21;28:17,18,
20,20;30:12;34:5;39:10;
40:23;42:14,20;43:1,10,
13;44:13,17,20,23;
45:18,21;46:1,13,23;
47:1,3,9;49:5,21;50:1,8;
51:1,53;18:54;10,19;
55:3,14,23,24,25;56:18;
57:3,6;58:24;62:12; |
+
+| 63:23;66:3;67:16,24;
68:2,10,13;69:6,13;
70:25;71:17,22;73:18,
22;79:9,12;80:12,12,20,
25;81:6,20,21;83:15,20,
25;85:21;90:4,8;91:5,12,
14,17;93:7;94:7;95:16;
100:3;128:19;210:4 | 6:7;109:21;110:19,22;
113:9;118:22;119:17;
124:8;211:23;213:9;
216:14,19;217:23;
219:23;220:7,8,18;
221:24;222:4,20;223:3;
224:17,20,24;225:1,5,6,
13,17;226:22;227:6,10,
12,14,19,23;228:3,7,11,
13,18 | investigator (1)
60:2
invoke (1)
100:20
invoked (1)
233:25
involve (1)
39:1
involved (16)
12:19,21;15:24;27:13;
38:20;76:15,19,24;
87:23;88:9;94:1;183:12;
191:4;214:21;215:15;
220:16
involvement (3)
210:13;215:21;216:10
involving (1)
38:9
irrational (15)
105:25;107:5;110:17;
113:1,4;121:25;122:3,
18,20,25;123:1,8,128:4,
14;149:8
irrationally (1)
128:10
irrelevant (5)
122:23,25;128:18,22;
221:13
IRS (1)
214:19
Israel (1)
158:6
issue (16)
30:19;31:9;37:10;
53:13;61:6;70:2;74:6;
79:14;87:25;88:11,11;
105:10,20;136:23;
191:9;239:5
issued (7)
6:11;186:20,23;187:2,
22;188:1;237:23
issues (3)
88:12;95:4;140:22
item (1)
151:9
items (1)
181:16
iterative (1)
76:19 | Jersey (7)
94:18;162:18;163:13;
189:19;230:9,11,23
Jesus (7)
55:16;57:11;62:5;
90:23;91:8,9,19
jibe (1)
49:21
job (9)
137:20;158:22;
160:22;163:16;198:4;
202:3;208:8,10;225:3
job's (2)
208:8,10
joined (1)
67:16
joint (1)
67:1
Judge (187)
7:21;19:14;33:5,8;
34:10,16;36:6,12;37:3,
17;43:6;46:19;47:10,14;
48:4;53:3;54:3,6;57:23;
72:6;73:5;74:17,21;
75:2;76:4;77:24;78:4;
82:5;89:23;90:10;
101:11;104:1,4;105:6,
12,19,22;106:15;107:13;
109:20;110:23,25;111:5,
14;112:8,22;113:7,21;
114:17,23;115:21;116:6,
15,19,20;117:6,10,23;
118:7,22;119:10;120:5,
10;121:10,12,21,23,24;
122:2,4,17;123:5,7,12,
12,25;124:2,11,14;
126:14,22;128:4,13,20;
130:4,15;131:1,5,25;
132:9,12,18;133:2;
135:9;138:23;139:3;
140:10,16;141:8;143:5;
144:4,7,8,11,14,19;
145:9;147:24,25;
148:16;151:6,15,23;
153:13;154:23;155:7;
157:22;158:8,14;160:4;
161:8,14;163:24;
164:24;165:7,9,24;
170:1;171:17;174:1,22;
175:6;177:20;183:15;
184:20;185:4;186:24;
187:1,7,8,10,11,24;
188:6,14,17;194:21;
196:25;197:25;199:12,
19;200:4,20;201:4;
204:12;209:5,10,19;
214:2,8;216:4,20;
217:23;219:23;220:7,
18;221:24;222:18,23;
223:5;224:18,20,23;
225:1,5;226:7;227:5,12;
228:2,7;233:24;238:17,
21;239:3,20;240:5,20 | judges (1)
208:6
judge's (7)
36:1;76:4;90:8;
119:17;162:3;211:23;
213:9
judging (3)
176:21;192:15;216:3
judgment (7)
49:2;51:20,22,24;
52:7;53:9;115:3
judgments (1)
51:17
Judicial (6)
23:2;53:6;99:18;
108:12;173:11,23
July (10)
64:2,19;74:12;75:13;
76:3;77:24;78:4;85:1;
187:12,15
jumping (2)
32:18;229:7
juncture (1)
237:22
June (5)
67:4;80:1,1;88:6,18
Juror (162)
16:25;18:3,5;19:6;
20:2,8,16,18,18,21;
24:13,14,18;25:12;27:2;
28:4,7,9;30:2,11,13,18,
22,24;31:6,10,11,13,14,
14,15,16,24;32:9;33:6,9,
10;34:8,22;35:16,19;
36:4,9;38:16,20;39:7;
42:24;43:4,5,11;46:6,10;
47:7;49:2,11,22;50:10,
18,20;51:2,3,13;56:1;
57:9,12;58:25;59:4,15;
60:4;61:15,21,25;62:2;
63:3,11;69:9;70:10,19;
71:18,18,24,24,25;
72:19,24;75:9;79:15,21;
80:3;83:3,11;85:23;
86:1,9,16,22;87:5,18,24;
88:10,11,20,24;89:12;
90:15,20;91:1,21,24;
92:15,24;93:3,25;96:1,7,
9,10,12,16;97:2,3;103:8,
9,118:9;128:11;141:12;
145:9;153:17,20;154:2,
3,21;158:22;160:20;
161:2;162:11;164:5;
166:16;169:4;172:12,
25;176:21;191:14,14;
208:18,24;209:6,11;
212:25;218:10;221:5,
13;222:11;223:23;
224:7;225:21;226:8;
228:22;230:24;231:19;
236:22;237:10
jurors (54)
11:21;13:5,6,16,17; |
+|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+
+| 14:23,24,25;15:3,5,16,
20,23,25;16:2,8,12,13,
14,14;17:8;19:7;20:9;
28:12,18,21,25;29:6,9,
11,14,19,25;30:4;34:11,
11,17,17,20;89:5;
137:10;141:4;142:21;
148:6;149:6;159:13;
165:12;168:25;192:15;
194:20;207:13;213:22;
220:9;234:17 | 179:9
kid's (1)
35:7
(13)
11:18,25;14:13;18:8;
19:6;20:3,6;23:21;
27:19;40:25;41:16,22,25
kind (8)
60:6;67:5;88:14;
106:19;109:12;122:17,
18;136:14
kindly (1)
122:12
kneejerk (2)
128:1,2
knew (60)
16:8,24;17:2;18:7;
33:5;34:3,22;37:4,5;
38:1,15;46:22,25;47:9;
50:17;51:2;54:17,18;
74:18;77:24;86:5;
105:15,18,19;126:3;
127:18;141:2;153:21;
154:1,3;160:22;165:19,
22,24;166:4;168:6;
182:21;186:20;187:21,
25;207:1,2,3,6,8;209:5,
5,7,8,9,9,10,11,25,25;
210:11;229:8;231:19;
233:14;236:21
knowing (1)
127:12
knowingly (1)
214:3
knowledge (16)
53:17;75:3;79:7,14;
81:5;82:11;88:23;
112:15;122:1,1;169:3;
190:18;202:5;206:12;
214:12,16
known (2)
89:12;202:17
knows (1)
156:14
Kostelanetz (1)
77:8
Kramer (4)
77:16;78:3,10;79:1
kudos (1)
235:25 | 233:14,23
larger (1)
188:15
last (21)
9:4;34:25;58:15;77:4;
109:6,7,8,14,19;110:2;
121:7;135:6,23;136:2,8;
152:19;157:2,4;163:6;
170:24;172:9
lasts (1)
172:15
late (3)
70:14;80:1;194:3
later (11)
40:16;41:9;49:6;58:5;
83:15;101:3;118:14;
130:10;151:7,15;238:20
latter (1)
33:1
laughed (1)
206:19
Laurie (4)
8:25;71:10,12;86:6
law (28)
12:8;32:2,4;37:24;
42:4;54:18;55:9;72:16,
16;79:13;95:9;120:3;
135:7;150:18;154:1;
167:24,25;171:12;
175:13;176:22;177:1;
217:4,10,22;218:2,2,12;
239:22
lawful (1)
105:18
lawsuit (19)
55:17,17;56:2,17,18,
23;57:3;60:10;62:19;
66:9;71:4;82:24;83:3,
14;91:5;92:20;93:17;
94:23;95:5
lawyer (112)
9:25;10:2,19;22:19;
24:6,8,19;26:15;27:6,10;
28:8;33:9,11;34:6,7;
41:25;43:17,22;45:13;
50:4;52:17;55:5;56:9;
59:1,16;60:14,24;61:4,7,
9,15,19;63:3,11;67:18;
68:19;69:1,8;70:10,20;
71:3;72:3;75:9;79:12,
21;80:4;85:22;86:2,9,14,
18,23;87:4;89:3,13,16;
90:21;91:1,25;92:2,4,25;
93:4;94:15;105:9,19;
118:23;119:9,16,21,25;
122:16;123:11;124:3,5,
5,9,12,16;126:15;
130:16;132:15,20,23;
133:4,15;134:21,25;
135:4,6,11,12,14,15;
136:24;137:4,12;139:4,
4;144:1;153:18;166:5,
11,17;168:23;170:7,21,
233:14,23
lawyers (25)
10:21,24;67:8;68:18;
73:13;88:16;165:21,25;
166:5,14;193:23;
195:12;204:7;206:19;
207:10,14,18;208:4;
209:4,9,25;210:15;
214:16;216:11;218:8
laying (1)
201:24
lead (1)
132:2
leading (1)
11:12
learn (2)
43:7;61:20
learned (8)
10:7;37:23;38:15;
62:22;63:23;90:4;94:24;
208:15
least (5)
46:17;98:4;113:6;
147:19;157:7
leave (4)
60:20;93:12;117:22,
23
leaving (1)
183:13
left (6)
58:7;67:11;107:25;
163:13;166:5;211:16
legal (12)
37:21;42:6;106:14;
112:15;120:2;165:19;
193:10;214:8;216:4,14,
19;231:7
legally (1)
217:12
lengthy (2)
18:18;224:7
less (2)
84:6;134:14
letter (55)
16:7,8,27;25;76:3,16,
22,25;77:13,18;78:4;
85:7,13,17;87:22;88:6,8,
9,89:1,95;2,97;5,18,20;
99:1,15;195:2,5,17,21,
25;196:6,14,17;197:1,8,
22;198:19,21;199:1,3,5;
200:22,22;201:7,7,8,11;
202:1;204:16;213:15,
22;214:1;218:15,22;
219:12;235:23
letterhead (4)
63:20;198:11,14,17
letters (1)
97:23
level (12)
34:4;43:20;44:3;
59:10;86:12;112:18;
164:24;167:12;168:4;
25;171:1,5,10;210:11
lawyers (25)
10:21,24;67:8;68:18;
73:13;88:16;165:21,25;
166:5,14;193:23;
195:12;204:7;206:19;
207:10,14,18;208:4;
209:4,9,25;210:15;
214:16;216:11;218:8
laying (1)
201:24
lead (1)
132:2
leading (1)
11:12
learn (2)
43:7;61:20
learned (8)
10:7;37:23;38:15;
62:22;63:23;90:4;94:24;
208:15
least (5)
46:17;98:4;113:6;
147:19;157:7
leave (4)
60:20;93:12;117:22,
23
leaving (1)
183:13
left (6)
58:7;67:11;107:25;
163:13;166:5;211:16
legal (12)
37:21;42:6;106:14;
112:15;120:2;165:19;
193:10;214:8;216:4,14,
19;231:7
legally (1)
217:12
lengthy (2)
18:18;224:7
less (2)
84:6;134:14
letter (55)
16:7,8,27;25;76:3,16,
22,25;77:13,18;78:4;
85:7,13,17;87:22;88:6,8,
9,89:1,95;2,97;5,18,20;
99:1,15;195:2,5,17,21,
25;196:6,14,17;197:1,8,
22;198:19,21;199:1,3,5;
200:22,22;201:7,7,8,11;
202:1;204:16;213:15,
22;214:1;218:15,22;
219:12;235:23
letterhead (4)
63:20;198:11,14,17
letters (1)
97:23
level (12)
34:4;43:20;44:3;
59:10;86:12;112:18;
164:24;167:12;168:4;
25;171:1,5,10;210:11
lawyers (25)
10:21,24;67:8;68:18;
73:13;88:16;165:21,25;
166:5,14;193:23;
195:12;204:7;206:19;
207:10,14,18;208:4;
209:4,9,25;210:15;
214:16;216:11;218:8
laying (1)
201:24
lead (1)
132:2
leading (1)
11:12
learn (2)
43:7;61:20
learned (8)
10:7;37:23;38:15;
62:22;63:23;90:4;94:24;
208:15
least (5)
46:17;98:4;113:6;
147:19;157:7
leave (4)
60:20;93:12;117:22,
23
leaving (1)
183:13
left (6)
58:7;67:11;107:25;
163:13;166:5;211:16
legal (12)
37:21;42:6;106:14;
112:15;120:2;165:19;
193:10;214:8;216:4,14,
19;231:7
legally (1)
217:12
lengthy (2)
18:18;224:7
less (2)
84:6;134:14
letter (55)
16:7,8,27;25;76:3,16,
22,25;77:13,18;78:4;
85:7,13,17;87:22;88:6,8,
9,89:1,95;2,97;5,18,20;
99:1,15;195:2,5,17,21,
25;196:6,14,17;197:1,8,
22;198:19,21;199:1,3,5;
200:22,22;201:7,7,8,11;
202:1;204:16;213:15,
22;214:1;218:15,22;
219:12;235:23
letterhead (4)
63:20;198:11,14,17
letters (1)
97:23
level (12)
34:4;43:20;44:3;
59:10;86:12;112:18;
164:24;167:12;168:4;
25;171:1,5,10;210:11
lawyers (25)
10:21,24;67:8;68:18;
73:13;88:16;165:21,25;
166:5,14;193:23;
195:12;204:7;206:19;
207:10,14,18;208:4;
209:4,9,25;210:15;
214:16;216:11;218:8
laying (1)
201:24
lead (1)
132:2
leading (1)
11:12
learn (2)
43:7;61:20
learned (8)
10:7;37:23;38:15;
62:22;63:23;90:4;94:24;
208:15
least (5)
46:17;98:4;113:6;
147:19;157:7
leave (4)
60:20;93:12;117:22,
23
leaving (1)
183:13
left (6)
58:7;67:11;107:25;
163:13;166:5;211:16
legal (12)
37:21;42:6;106:14;
112:15;120:2;165:19;
193:10;214:8;216:4,14,
19;231:7
legally (1)
217:12
lengthy (2)
18:18;224:7
less (2)
84:6;134:14
letter (55)
16:7,8,27;25;76:3,16,
22,25;77:13,18;78:4;
85:7,13,17;87:22;88:6,8,
9,89:1,95;2,97;5,18,20;
99:1,15;195:2,5,17,21,
25;196:6,14,17;197:1,8,
22;198:19,21;199:1,3,5;
200:22,22;201:7,7,8,11;
202:1;204:16;213:15,
22;214:1;218:15,22;
219:12;235:23
letterhead (4)
63:20;198:11,14,17
letters (1)
97:23
level (12)
34:4;43:20;44:3;
59:10;86:12;112:18;
164:24;167:12;168:4;
25;171:1,5,10;210:11
lawyers (25)
10:21,24;67:8;68:18;
73:13;88:16;165:21,25;
166:5,14;193:23;
195:12;204:7;206:19;
207:10,14,18;208:4;
209:4,9,25;210:15;
214:16;216:11;218:8
laying (1)
201:24
lead (1)
132:2
leading (1)
11:12
learn (2)
43:7;61:20
learned (8)
10:7;37:23;38:15;
62:22;63:23;90:4;94:24;
208:15
least (5)
46:17;98:4;113:6;
147:19;157:7
leave (4)
60:20;93:12;117:22,
23
leaving (1)
183:13
left (6)
58:7;67:11;107:25;
163:13;166:5;211:16
legal (12)
37:21;42:6;106:14;
112:15;120:2;165:19;
193:10;214:8;216:4,14,
19;231:7
legally (1)
217:12
lengthy (2)
18:18;224:7
less (2)
84:6;134:14
letter (55)
16:7,8,27;25;76:3,16,
22,25;77:13,18;78:4;
85:7,13,17;87:22;88:6,8,
9,89:1,95;2,97;5,18,20;
99:1,15;195:2,5,17,21,
25;196:6,14,17;197:1,8,
22;198:19,21;199:1,3,5;
200:22,22;201:7,7,8,11;
202:1;204:16;213:15,
22;214:1;218:15,22;
219:12;235:23
letterhead (4)
63:20;198:11,14,17
letters (1)
97:23
level (12)
34:4;43:20;44:3;
59:10;86:12;112:18;
164:24;167:12;168:4;
25;171:1,5,10;210:11
lawyers (25)
10:21,24;67:8;68:18;
73:13;88:16;165:21,25;
166:5,14;193:23;
195:12;204:7;206:19;
207:10,14,18;208:4;
209:4,9,25;210:15;
214:16;216:11;218:8
laying (1)
201:24
lead (1)
132:2
leading (1)
11:12
learn (2)
43:7;61:20
learned (8)
10:7;37:23;38:15;
62:22;63:23;90:4;94:24;
208:15
least (5)
46:17;98:4;113:6;
147:19;157:7
leave (4)
60:20;93:12;117:22,
23
leaving (1)
183:13
left (6)
58:7;67:11;107:25;
163:13;166:5;211:16
legal (12)
37:21;42:6;106:14;
112:15;120:2;165:19;
193:10;214:8;216:4,14,
19;231:7
legally (1)
217:12
lengthy (2)
18:18;224:7
less (2)
84:6;134:14
letter (55)
16:7,8,27;25;76:3,16,
22,25;77:13,18;78:4;
85:7,13,17;87:22;88:6,8,
9,89:1,95;2,97;5,18,20;
99:1,15;195:2,5,17,21,
25;196:6,14,17;197:1,8,
22;198:19,21;199:1,3,5;
200:22,22;201:7,7,8,11;
202:1;204:16;213:15,
22;214:1;218:15,22;
219:12;235:23
letterhead (4)
63:20;198:11,14,17
letters (1)
97:23
level (12)
34:4;43:20;44:3;
59:10;86:12;112:18;
164:24;167:12;168:4;
25;171:1,5,10;210:11
lawyers (25)
10:21,24;67:8;68:18;
73:13;88:16;165:21,25;
166:5,14;193:23;
195:12;204:7;206:19;
207:10,14,18;208:4;
209:4,9,25;210:15;
214:16;216:11;218:8
laying (1)
201:24
lead (1)
132:2
leading (1)
11:12
learn (2)
43:7;61:20
learned (8)
10:7;37:23;38:15;
62:22;63:23;90:4;94:24;
208:15
least (5)
46:17;98:4;113:6;
147:19;157:7
leave (4)
60:20;93:12;117:22,
23
leaving (1)
183:13
left (6)
58:7;67:11;107:25;
163:13;166:5;211:16
legal (12)
37:21;42:6;106:14;
112:15;120:2;165:19;
193:10;214:8;216:4,14,
19;231:7
legally (1)
217:12
lengthy (2)
18:18;224:7
less (2)
84:6;134:14
letter (55)
16:7,8,27;25;76:3,16,
22,25;77:13,18;78:4;
85:7,13,17;87:22;88:6,8,
9,89:1,95;2,97;5,18,20;
99:1,15;195:2,5,17,21,
25;196:6,14,17;197:1,8,
22;198:19,21;199:1,3,5;
200:22,22;201:7,7,8,11;
202:1;204:16;213:15,
22;214:1;218:15,22;
219:12;235:23
letterhead (4)
63:20;198:11,14,17
letters (1)
97:23
level (12)
34:4;43:20;44:3;
59:10;86:12;112:18;
164:24;167:12;168:4;
25;171:1,5,10;210:11
lawyers (25)
10:21,24;67:8;68:18;
73:13;88:16;165:21,25;
166:5,14;193:23;
195:12;204:7;206:19;
207:10,14,18;208:4;
209:4,9,25;210:15;
214:16;216:11;218:8
laying (1)
201:24
lead (1)
132:2
leading (1)
11:12
learn (2)
43:7;61:20
learned (8)
10:7;37:23;38:15;
62:22;63:23;90:4;94:24;
208:15
least (5)
46:17;98:4;113:6;
147:19;157:7
leave (4)
60:20;93:12;117:22,
23
leaving (1)
183:13
left (6)
58:7;67:11;107:25;
163:13;166:5;211:16
legal (12)
37:21;42:6;106:14;
112:15;120:2;165:19;
193:10;214:8;216:4,14,
19;231:7
legally (1)
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diff --git a/marker2/court-us-v-maxwell-cr/EFTA02837775/EFTA02837775.md b/marker2/court-us-v-maxwell-cr/EFTA02837775/EFTA02837775.md
new file mode 100644
index 0000000000000000000000000000000000000000..5b9b19de5af305fe490e99d17ac29b3791e853a2
--- /dev/null
+++ b/marker2/court-us-v-maxwell-cr/EFTA02837775/EFTA02837775.md
@@ -0,0 +1,2773 @@
+UNITED STATES OF AMERICA, v
+PAUL M. DAUGERDAS, ET AL.,
+
+| 132:5,5;138:11,12;
176:11;190:17;199:22;
220:12 | load (1)
240:8 | 111:6;148:21 | 53:1;61:16;69:16;102:2,
5;103:3;115:15;140:1;
146:2,15,15,20,21;
147:14,16;149:13;150:1,
2;151:15;153:13;
154:24;156:3;176:2,8;
185:3,6;189:2;190:25;
191:1,11,15 | 7:23;8:9;13:24;14:4;
15:6;22:2,12;25:1;
26:21;31:2;36:12;37:18;
38:23,24;39:14;42:14;
44:8;47:4,15,19;52:18,
19;53:1,1,17;54:4,5;
55:2;57:15;58:5;59:2,
18,25;63:16;64:1,6;
68:23,24;69:18,21,21,
23;70:14;72:8;79:22;
84:19,21;86:15,15,20;
87:16,22;90:7,22;92:5,
16;94:5,9,14;95:12,19;
96:6,25;97:13,20;99:13;
100:15;101:10,13,23;
102:22;106:21;126:15;
130:12,23;193:3;194:3,
11;199:13;200:23;
203:15;211:12;216:25;
217:13,13;238:5;
239:20;240:2 | | |
+|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|
+| lines (10)
58:22;63:6;85:20;
93:11;145:8;157:18;
191:18;217:2,9;218:23 | load (1)
240:8 | lower (1)
180:3 | lower (2)
Ltd (3)
52:11,14;77:8 | marital (1)
190:14 | marriage (1)
66:7 | |
+| link (4)
41:9;47:16;80:20;
82:18 | located (2)
196:2,5 | lunch (5)
69:24,25,25;70:2;
86:21 | luncheon (5)
128:25;129:2,4,9,13 | marital (1)
190:14 | married (12)
46:2,22;47:3,7,11,19,
21;94:17;193:8;207:3,5;
229:16 | |
+| linking (1)
71:1 | logical (3)
113:7,20;133:2 | lunchtime (1)
7:7 | lying (9)
89:5;143:23;158:23;
159:1,2;160:23;161:12;
226:22;232:1 | marked (2)
10:10;129:12 | marshal (4)
6:21;238:10;239:4,11 | |
+| links (1)
80:10 | logically (1)
210:24 | lunch (5)
69:24,25,25;70:2;
86:21 | lunchtime (1)
7:7 | marketable (7)
153:17,20;160:20;
208:17,24;230:24;
236:19 | marshals (14)
5:5;6:1,18,21;100:13;
117:17;157:3;170:5,7,9;
238:6,12;239:1,17 | |
+| linking (1)
71:1 | long (11)
44:13;58:15;89:15;
94:25;157:22;158:8;
160:5,10;168:3;216:25;
236:24 | luncheon (5)
128:25;129:2,4,9,13 | lying (9)
89:5;143:23;158:23;
159:1,2;160:23;161:12;
226:22;232:1 | marketable (7)
153:17,20;160:20;
208:17,24;230:24;
236:19 | marriage (1)
66:7 | |
+| listed (1)
48:21 | look (53)
10:10;17:3;18:17,18;
20:4,10;21:23;22:23;
26:18;31:1;36:15;39:11;
40:8;43:1;49:5;60:3;
63:15;64:23;65:9;71:3;
75:11;76:1;80:15;115:1;
124:23;125:10,14;
126:13;130:21;131:10,
12;132:5;138:10;
139:10;150:1,16;151:9;
154:21;157:18;176:11;
177:17,17;178:10;
180:3;181:2;191:22;
194:10;199:22;204:16;
207:23;218:23;227:2;
230:2 | look (5)
10:10;17:3;18:17,18;
20:4,10;21:23;22:23;
26:18;31:1;36:15;39:11;
40:8;43:1;49:5;60:3;
63:15;64:23;65:9;71:3;
75:11;76:1;80:15;115:1;
124:23;125:10,14;
126:13;130:21;131:10,
12;132:5;138:10;
139:10;150:1,16;151:9;
154:21;157:18;176:11;
177:17,17;178:10;
180:3;181:2;191:22;
194:10;199:22;204:16;
207:23;218:23;227:2;
230:2 | look (13)
22:5;24:14;37:6;43:8;
47:2;49:7,11;54:15;
55:23;56:5,13;58:23,23;
62:2;70:11,25;71:4;87:1 | look (22)
114:7;120:21;139:11;
141:23;144:9,19;
146:12;147:18;153:3;
154:18;156:11;157:10;
158:1;161:7,11;163:4;
179:7;196:6,23;197:3;
198:6;200:20 | married (12)
46:2,22;47:3,7,11,19,
21;94:17;193:8;207:3,5;
229:16 | married (3)
72:11,19,23 |
+| listened (1)
213:8 | look (5)
10:10;17:3;18:17,18;
20:4,10;21:23;22:23;
26:18;31:1;36:15;39:11;
40:8;43:1;49:5;60:3;
63:15;64:23;65:9;71:3;
75:11;76:1;80:15;115:1;
124:23;125:10,14;
126:13;130:21;131:10,
12;132:5;138:10;
139:10;150:1,16;151:9;
154:21;157:18;176:11;
177:17,17;178:10;
180:3;181:2;191:22;
194:10;199:22;204:16;
207:23;218:23;227:2;
230:2 | look (4)
129:14,14,16,19 | magnitude (2)
89:10;94:1 | match (2)
45:11;62:22 | material (3)
73:11,19,23 | |
+| listening (1)
35:20 | looked (18)
22:5;24:14;37:6;43:8;
47:2;49:7,11;54:15;
55:23;56:5,13;58:23,23;
62:2;70:11,25;71:4;87:1 | mail (4)
129:14,14,16,19 | main (2)
35:12;158:22 | matches (1)
49:23 | material (3)
72:11,19,23 | |
+| lists (1)
46:1 | look (18)
22:5;24:14;37:6;43:8;
47:2;49:7,11;54:15;
55:23;56:5,13;58:23,23;
62:2;70:11,25;71:4;87:1 | main (2)
35:12;158:22 | maintain (2)
97:11;98:8 | material (1)
236:18 | maternal (1)
230:17 | |
+| literally (2)
7:21;173:25 | looking (15)
14:21;19:7;20:9;
24:16;43:18;49:23,25;
50:6;55:24;60:19;62:24;
91:14;92:21;101:2;
218:22 | makes (1)
78:5 | making (6)
14:24;46:11;49:10;
172:11,24;189:13 | matter (30)
13:3;17:22;23:4;
24:22;25:19;40:17;
41:13;52:17;63:12;
97:16;98:6,9,14,16,21,
23;114:25;115:2;119:5;
127:18;133:3;142:20;
146:14;152:8;203:7;
211:2;215:15,23;
221:25;222:6 | matter (3)
11:18;15:24;22:5;
47:24;67:10;70:18;
72:16;91:3;92:10;
111:23;113:13;115:6,8,
11;121:20;123:22;
180:19,20;186:18;
207:20,21 | |
+| litigation (4)
9:12;52:23;62:24;
218:4 | look (1)
27:5 | man (1)
94:18 | managing (2)
66:17;93:19 | matters (12)
9:12;38:2,2;117:7;
129:9,24;135:2;193:13;
218:5;234:7,9;240:15 | mean (21)
11:18;15:24;22:5;
47:24;67:10;70:18;
72:16;91:3;92:10;
111:23;113:13;115:6,8,
11;121:20;123:22;
180:19,20;186:18;
207:20,21 | |
+| litigator (1)
52:25 | lose (1)
34:20 | manner (1)
189:17 | managing (2)
66:17;93:19 | matters (2)
16:19;48:2,3;81:21;
112:21;205:15 | meaning (6)
16:19;48:2,3;81:21;
112:21;205:15 | |
+| little (12)
28:18;35:7;43:25;
67:6;111:13;130:10;
148:11;152:2;153:8;
158:20;201:20;238:19 | losers (1)
112:1 | manner (1)
220:20 | manner (1)
220:20 | means (21)
71:6;113:4,12;117:24;
120:14;127:14;134:18,
23;136:25;140:13;
144:2;149:7,8;159:7;
164:6,7;186:5;193:19;
202:8,224;25;233:20 | | |
+| live (19)
137:2;144:5,20;
146:10,19,21,22;147:8;
148:5,5,12,22;153:1,1,5;
158:11,17,18;161:15 | lookout (1)
32:21 | man (1)
94:18 | manner (1)
220:20 | mean (4) | | |
+| lived (44)
50:18,20;51:3,5;59:9;
71:2;87:5,5,6;144:11,15,
22;146:14,15;147:12,14,
18;150:12;151:14;
152:9,22;153:3,12,13,
16;156:6,8,11;157:23;
158:3,8;159:18,20,22,
23;160:1,5,9,10;161:18,
20,23;162:5;168:3 | look (1)
27:5 | manner (1)
220:20 | manner (1)
220:20 | mean (4) | | |
+| lives (1)
46:9 | look (1)
27:5 | manner (1)
220:20 | manner (1)
220:20 | mean (4) | | |
+| living (10)
43:12;147:1;148:20;
152:3,9,21;153:4,15;
157:7;196:16 | lot (6)
35:23;49:20;83:10;
86:5;137:19;237:5 | lot (6)
35:23;49:20;83:10;
86:5;137:19;237:5 | lot (6)
35:23;49:20;83:10;
86:5;137:19;237:5 | lot (6)
35:23;49:20;83:10;
86:5;137:19;237:5 | | |
+| LLP (2)
77:7,8 | lots (1)
206:19 | lots (1)
206:19 | lots (1)
206:19 | lots (1)
206:19 | | |
+
+February 15, 2012
+
+16:11;90:25;115:4;
+188:7
+**measure (1)**
+191:24
+**meat (1)**
+116:17
+**medical (4)**
+6:25;96:8;98:1;99:17
+**medication (3)**
+121:1,5,8
+**medications (2)**
+120:24;121:3
+**meet (1)**
+107:21
+**meeting (6)**
+58:1,3,9;63:1,22;
+70:13
+**Melrose (1)**
+40:1
+**member (4)**
+9:6,20;32:3;188:18
+**members (4)**
+21:3,12;35:16;161:14
+**memo (5)**
+63:16,21,22;64:1;82:9
+**memorable (1)**
+185:20
+**memorialize (1)**
+58:17
+**memory (4)**
+63:4;138:14;139:13,
+19
+**mental (4)**
+120:17;128:7;175:14;
+180:5
+**mentally (2)**
+236:24;239:7
+**mention (3)**
+153:22;188:15;226:25
+**mentioned (12)**
+11:25;12:3;59:2;61:2,
+16;68:21;74:21;162:8;
+191:7;219:5;225:11;
+236:21
+**merit (3)**
+115:8,11,14
+**Mersa (1)**
+45:23
+**message (3)**
+83:2;129:14,16
+**met (5)**
+23:19;92:17;108:1,3;
+190:10
+**midday (1)**
+238:23
+**middle (9)**
+13:21;23:12;43:5,8;
+50:15;67:6;178:11,15;
+239:12
+**might (26)**
+15:16;26:5,12;28:9,
+14;31;19;71;14;86:18;
+94:23;96:13;107:7;
+
+114:8;120:7;131:13;
+137:7;141:4,11;144:23;
+173:6,22;174:5,7;
+182:16;189:14;224:11;
+233:9
+**million (2)**
+23:24,24
+**mind (28)**
+15:13;43:14;47:16;
+51:1;63:5;71:22;72:5;
+80:2;94:4,9,10;95:18;
+143:15,16,22;164:14;
+168:14;169:7,13,17;
+183:21;191:17;199:19;
+200:2;210:21;211:21;
+212:25;213:6
+**mindful (1)**
+43:3
+**minds (3)**
+210:2,3;229:4
+**mine (1)**
+116:9
+**minute (3)**
+7:22;41:9;170:22
+**minutes (7)**
+58:16;84:6;90:5;
+104:2;153:7,22;238:14
+**minutiae (1)**
+197:17
+**mischaracterization (1)**
+127:20
+**mischaracterize (3)**
+128:23;141:18,19
+**mischaracterized (1)**
+127:21
+**mischaracterizing (1)**
+227:7
+**misconduct (3)**
+87:24;88:10;94:1
+**misdemeanor (2)**
+89:14;210:12
+**misdemeanors (1)**
+181:8
+**misimpression (1)**
+101:3
+**mislead (3)**
+141:20;148:4,6
+**misleading (8)**
+163:18,23;164:2,5,7,8,
+11,15
+**misrepresented (1)**
+236:17
+**misrepresenting (1)**
+237:1
+**miss (4)**
+43:16;70:21,23;202:2
+**missed (3)**
+43:2;239:25;240:13
+**misstatement (1)**
+155:4
+**mistaken (1)**
+47:16
+**Mm-hm (1)**
+
+178:9
+**Mm-hmm (2)**
+141:15;196:13
+**moment (21)**
+6:2,17;19:1;27:1;31:3;
+37:12;53:24;70:9;79:23;
+81:11;95:19;97:19;
+130:23;133:1;167:24;
+198:20;203:15;218:15;
+221:1;233:11;240:2
+**moments (2)**
+103:4;226:21
+**Monday (2)**
+147:16;185:3
+**money (10)**
+124:18,21;130:19;
+131:1,8,16,23;133:22;
+135:6,15
+**month (3)**
+92:6;131:19;137:14
+**months (9)**
+93:15;131:4;172:15;
+173:5;189:25;190:5,6;
+192:4;223:4
+**more (49)**
+11:23;13:25;31:17;
+41:3,3;50:8;54:22;57:9,
+12;61:3;81:13;83:14,18;
+85:13;86:16,17,22;
+87:14;91:5;92:24;93:1;
+102:8;113:8;132:4;
+144:21;152:2,5,9,21;
+153:4,9,17,20;158:16;
+159:10;160:20;172:15;
+173:6;174:6,11;191:18;
+208:17,24;210:7;
+219:19;220:6;221:2;
+225:12;230:24
+**Moreover (1)**
+100:9
+**morning (34)**
+4:3,9,11,13,15,17,21,
+24,25;8:13,14;23:19,20;
+42:21,23;43:14;61:18;
+69:3,16,16;86:16;93:20;
+104:2;106:25;109:4;
+133:24;134:9;137:17;
+146:1;233:18,21;
+237:23;238:16;239:15
+**most (17)**
+7:11;16:12,15;41:9;
+69:11;75:6;85:9;148:15;
+197:2,5,9;206:19;207:1,
+2,10;218:6;240:11
+**mother (4)**
+32:1;134:18,22,24
+**motion (47)**
+40:16;42:10;46:4;
+52:13;64:16,19,23,24;
+65:3,4,12;66:13,25;67:1,
+9,16;72:10,11,14,22;
+73:14;74:14,19;75:3;
+78:1;80:6,13,16,18;81:9;
+
+83:19;85:24,25;87:25;
+88:4;95:15,17;100:5;
+111:8;113:25;114:17,18,
+19,24;115:3,14;239:10
+**motivating (1)**
+232:11
+**motivation (2)**
+221:18;231:1
+**motivations (1)**
+222:14
+**motive (2)**
+214:24;231:18
+**motives (5)**
+222:8;231:4,14,16,23
+**mouth (1)**
+210:10
+**mouths (1)**
+229:5
+**move (16)**
+6:12;7:2;19:11;31:4;
+34:25;44:6;125:4;145:1;
+148:8;157:13;173:14;
+175:19;179:15;180:20;
+194:4;203:22
+**moved (3)**
+25:24;89:18;234:25
+**moves (5)**
+11:3;36:19;65:15;
+75:18;76:7
+**Mrs (1)**
+4:14
+**much (11)**
+29:6;46:8;49:13;
+109:8;129:15;134:14;
+135:6,11,15;230:5;240:8
+**multipage (1)**
+179:16
+**multiple (2)**
+18:15;54:16
+[REDACTED] (1)
+4:19
+**must (7)**
+99:21,22,23,25;
+138:18;203:18;235:2
+**myself (16)**
+49:13;78:9;137:9;
+139:4,22;142:21;148:6;
+149:6;151:20;153:15;
+155:10;158:15;194:17;
+199:23;234:7;237:1
+**mystery (1)**
+71:8
+
+14:20;24:6,19;25:18;
+45:23;55:5,8;61:7,9;
+67:17;68:19;69:1;70:20;
+79:12;93:3;116:11
+**Namely (1)**
+87:10
+**names (4)**
+13:25;14:2,10;69:7
+**Nanette (1)**
+4:5
+**Nardelli (1)**
+175:22
+**Nardello (24)**
+12:23;13:9,11,12,25;
+14:3,8,15;15:22;24:22;
+25:3,8;26:25;29:23;
+30:4;45:2,3,15;57:18;
+59:23;66:17,22;88:19,22
+**narrow (1)**
+50:15
+**near (2)**
+48:14;178:11
+**necessarily (1)**
+205:5
+**necessary (2)**
+99:14,22
+**need (12)**
+49:12;60:18;71:3;
+92:12;93:11;97:17;
+116:8;137:19,25;
+227:16;239:4;240:6
+**needed (4)**
+63:5;86:6;96:7;125:24
+**needs (1)**
+97:14
+**negatively (1)**
+180:11
+**neighborhood (1)**
+145:11
+**neighbors (1)**
+156:14
+**Neither (2)**
+77:5;196:4
+**New (40)**
+9:20;23:2,11,25;
+27:23;40:16;42:10;
+45:24;46:4;51:19;52:13;
+54:11;55:5;64:16,19;
+65:13;71:2;72:10,23;
+80:6,13,16,18;83:19;
+85:24;92:10;94:18;
+100:5;114:19;151:11;
+157:4;163:13;179:17;
+189:19;196:9;203:17,
+20;221:6;230:10,23
+**newspapers (1)**
+182:1
+**next (24)**
+20:5;33:12;35:5,12;
+69:23;78:13;85:11;
+86:16;90:12;104:7;
+118:5;131:19;149:15;
+157:13;186:10,12,14,16,
+
+UNITED STATES OF AMERICA, v
+PAUL M. DAUGERDAS, ET AL.,
+
+| 25:195;2;196:7;220:23;
238:8;239:14 | 198:9,11;199:20;200:3;
204:18;216:7;20;236:18 | occur (8)
52:20;68:8,11,12;
73:24;79:16;80:23;
191:19 | 12,13,15;221:1,22;
222:23;223:16,19,21,22;
224:17;225:10;226:5;
228:19;230:14;231:1,
14;232:9;233:4,6;
234:10,22;235:17;236:4,
14,15;237:15,25;238:11,
21;239:13;240:2,10,17 | 180:12
online (1)
93:18
only (25)
6:3;58:2;70:15;72:4;
85:12,16;94:15;124:15;
135:1;137:7;142:2;
172:1;173:4;182:5;
183:5;193:25;195:17;
199:8,17;200:8;217:14;
224:23;225:2,5;239:3 |
+|-----------------------------------------|---------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| nexus (2)
141:13,14 | numbers (7)
125:12;206:6,6,9;
218:16,21,24 | occurred (5)
74:9;108:4;161:1,5;
224:11 | Okula's (2)
223:13;226:1
old (4)
47:8;49:3;189:20;
190:24
older (1)
162:17
omission (9)
78:8;142:12;143:17,
25;144:1;208:12,13;
209:1;230:1
omissions (6)
103:18,19;167:10;
208:16;228:4;229:24 | open (6)
62:8;82:20;98:16;
129:17;133:18;177:21
opened (2)
83:16;98:9
opening (2)
69:15;92:21
open-minded (1)
15:3
operational (1)
11:16
opinion (9)
41:10,13;42:9;73:2,6;
135:1;202:14;228:21;
235:4
opinions (1)
60:22
opportunities (1)
48:25
opportunity (3)
84:12;98:7;195:6
opposed (4)
131:18,18,19;148:1
opposite (2)
232:9;233:17
oranges (1)
224:9
OR'd (1)
186:7
order (42)
6:13;24:1,2,3,5,8,19;
25:9,10,14,19;40:10,13,
16;42:11;61:7;101:1;
102:16,17,19;105:1,15,
18,20;106:14;107:13;
117:15,19;125:25;
130:15;153:4;168:15;
170:5;175:21;184:12;
190:19;212:1;225:20;
232:4,12;240:4,14
ordered (8)
99:6;110:25;118:8;
119:10;120:4,11;123:6,
13
ordering (1)
116:19
orders (4)
55:7;61:2;80:9,17
original (1)
208:11
others (2)
41:1;228:12 |
+| nobody (3)
123:9;166:15;171:3 | O | off (9)
90:23;91:8;110:5;
136:22;137:5;185:8;
188:1;211:16;235:3 | offense (3)
215:7,8,11
offenses (4)
215:7,8,17,17
offer (2)
85:12;176:1
offered (2)
211:4,4
offering (1)
211:6
offers (1)
17:9
offhand (1)
138:9
office (7)
5:6;11:19,20;12:2;
27:23;70:4;137:20
officer (6)
47:13;121:18;123:10,
11;157:4;216:6
official (2)
144:18,19
often (3)
67:7;157:1;230:20
OK (6)
157:21;158:11;
160:13;165:5;171:24;
229:14
OKULA (100)
4:3,3;6:15;7:16;30:22;
95:3;99:11;100:15,18;
102:14,15;106:2,4,19;
112:4;113:2;115:17;
117:2;119:13;122:4;
125:7;130:4;134:17;
135:9;136:15;141:5;
145:4;152:17;154:8;
155:7;156:20;159:8;
160:24;161:8;162:7;
173:18;175:23;176:5;
179:20;181:24;183:23;
190:14;192:19;194:7;
195:2,17;197:1,11,19;
198:3;199:5,11,12,15;
200:6,22;201:4;202:7;
203:24;204:5,6,16;
205:3,9;209:19;211:9, | offense (2)
62:8;82:20;98:16;
129:17;133:18;177:21
open (6)
62:8;82:20;98:16;
129:17;133:18;177:21
opened (2)
83:16;98:9
opening (2)
69:15;92:21
open-minded (1)
15:3
operational (1)
11:16
opinion (9)
41:10,13;42:9;73:2,6;
135:1;202:14;228:21;
235:4
opinions (1)
60:22
opportunities (1)
48:25
opportunity (3)
84:12;98:7;195:6
opposed (4)
131:18,18,19;148:1
opposite (2)
232:9;233:17
oranges (1)
224:9
OR'd (1)
186:7
order (42)
6:13;24:1,2,3,5,8,19;
25:9,10,14,19;40:10,13,
16;42:11;61:7;101:1;
102:16,17,19;105:1,15,
18,20;106:14;107:13;
117:15,19;125:25;
130:15;153:4;168:15;
170:5;175:21;184:12;
190:19;212:1;225:20;
232:4,12;240:4,14
ordered (8)
99:6;110:25;118:8;
119:10;120:4,11;123:6,
13
ordering (1)
116:19
orders (4)
55:7;61:2;80:9,17
original (1)
208:11
others (2)
41:1;228:12 |
+| nexus (2)
141:13,14 | numbers (1)
94:16 | offered (1)
117:19
Object (2)
106:18;199:12
objection (66)
11:5,6,7,8;17:11,12;
19:12,15,19;36:21;
65:17,20;75:20,21,22;
76:9,10,11;77:21;89:20;
96:9;106:2,2,4,19;112:4;
113:2;115:17;117:2;
119:13;122:4;125:6;
134:17;136:15;141:5;
145:3;152:17;154:8;
156:20;159:8;160:24;
161:8;162:7;173:17;
175:23;176:5;179:19,
20;181:24;183:23;
190:14;192:19;194:6,7;
201:4;202:7;203:24;
209:21;211:8;221:20;
226:5;228:19;233:4;
234:10;235:17;236:4
objective (1)
205:22
obligation (3)
36:3;208:2,9
observe (2)
35:19;48:25
observed (1)
36:6
obtain (1)
13:4
obtained (2)
34:16;218:2
obtaining (1)
11:21
obvious (2)
86:3,5
obviously (5)
7:5;99:5;153:10;
181:18;191:9
occasions (2)
216:7,20 | offense (3)
57:7;157:1;230:20
OK (6)
157:21;158:11;
160:13;165:5;171:24;
229:14
OKULA (100)
4:3,3;6:15;7:16;30:22;
95:3;99:11;100:15,18;
102:14,15;106:2,4,19;
112:4;113:2;115:17;
117:2;119:13;122:4;
125:7;130:4;134:17;
135:9;136:15;141:5;
145:4;152:17;154:8;
155:7;156:20;159:8;
160:24;161:8;162:7;
173:18;175:23;176:5;
179:20;181:24;183:23;
190:14;192:19;194:7;
195:2,17;197:1,11,19;
198:3;199:5,11,12,15;
200:6,22;201:4;202:7;
203:24;204:5,6,16;
205:3,9;209:19;211:9, | offense (2)
62:8;82:20;98:16;
129:17;133:18;177:21
open (6)
62:8;82:20;98:16;
129:17;133:18;177:21
opened (2)
83:16;98:9
opening (2)
69:15;92:21
open-minded (1)
15:3
operational (1)
11:16
opinion (9)
41:10,13;42:9;73:2,6;
135:1;202:14;228:21;
235:4
opinions (1)
60:22
opportunities (1)
48:25
opportunity (3)
84:12;98:7;195:6
opposed (4)
131:18,18,19;148:1
opposite (2)
232:9;233:17
oranges (1)
224:9
OR'd (1)
186:7
order (42)
6:13;24:1,2,3,5,8,19;
25:9,10,14,19;40:10,13,
16;42:11;61:7;101:1;
102:16,17,19;105:1,15,
18,20;106:14;107:13;
117:15,19;125:25;
130:15;153:4;168:15;
170:5;175:21;184:12;
190:19;212:1;225:20;
232:4,12;240:4,14
ordered (8)
99:6;110:25;118:8;
119:10;120:4,11;123:6,
13
ordering (1)
116:19
orders (4)
55:7;61:2;80:9,17
original (1)
208:11
others (2)
41:1;228:12 |
+
+| otherwise (2)
101:1;167:14
ourselves (1)
101:5
out (44)
24:17;28:24;39:19;
41:10;50:6;51:13;55:24,
25:60;1:69;9:24;71:15;
80:9;83:12;84:16;86:15;
92:13;100:14;15;
101:12;107:24;118:1;
126:5;129:25;133:17;
137:22;141:4,11;146:2,
2;153:25;170:5,9,14;
174:13;179:9;190:7;
199:6,15;206:25;212:1;
218:10;221:15;240:4
outcome (1)
214:24
outright (1)
181:11
outset (1)
141:2
outside (5)
34:11;36:7;58:13;
164:18;170:17
outstanding (3)
89:17;202:3;210:14
over (24)
28:24;29:4;35:7;40:7;
43:24;49:16;59:18;70:4,
6,7;77:3;92:6;96:8;
116:15;129:9;135:17;
165:4;177:4;178:21;
184:15;193:21;206:5;
208:1;230:7
overriding (2)
99:21;100:8
overrule (1)
106:22
Overruled (16)
113:3;119:14;122:8;
135:10;141:6;154:9;
155:9;156:21;162:9;
177:23;183:24;192:20;
199:14;202:9;226:6;
235:18
overseeing (1)
11:16
oversight (1)
155:6
overstated (1)
91:4
overstates (1)
87:11
overwhelming (1)
159:5
own (16)
15:13;29:24;44:17;
47:16;78:3;100:11;
112:15;123:15;136:23;
138:11;160:8,14,15;
162:16,22;164:12
owned (10)
138:3;162:2,5,14,25;
163:21,23,25;164:12;
207:8
ownership (1)
138:15
owning (1)
168:3
owns (2)
162:22;163:19
P
Pacer (2)
114:20,22
page (59)
17:6;18:19;19:3;
20:11;21:23;22:1,10;
24:2;26:18;31:3,4;
33:12;39:11,11;40:19,
21;42:12,13,19;48:11;
50:24;51:16,23;53:21;
54:7;55:10;66:6;77:3,3;
78:13;82:15,16,21;
104:7;125:10,11,11;
126:13,13;130:21;
131:10,13,15;132:5;
138:10;145:7;149:15;
151:9,9;157:18;172:8;
176:11;178:10,16;
180:3;186:25;199:22;
220:23;226:23
pages (4)
18:23;19:10;20:5;
63:15
paid (1)
25:16
pancreatitis (2)
176:14,18
panel (9)
17:20;23:15;28:24;
29:5;172:5;173:22;
188:20;191:3;208:6
panels (1)
208:6
panic (1)
6:23
paper (2)
10:11;65:9
papers (3)
74:19;102:16;177:3
paragraph (7)
77:5;178:11,14,15,15;
181:3;202:1
paralegal (5)
7:13;12:14;14:4;41:8;
45:4
paralegals (6)
9:17;12:11,18,18;
13:23;39:25
pardon (1)
122:24
parents (2) | 148:23;152:25
parents' (2)
161:23;196:22
Parkview (5)
196:3,9,11,23;198:10
parlance (1)
116:25
parochial (1)
100:11
Paroled (1)
190:7
Parse (28)
4:20;8:21,22;11:1,14;
28:4;30:7,15;35:10;
39:17,18,22,24;40:4;
42:22;63:19;113:23;
136:13;199:7,16,20,25;
203:3;213:12,24;214:7;
220:3,17
Parse's (3)
4:22;15:6;206:12
part (26)
11:16,17;26:25;28:12;
40:4;45:9;53:21;54:8;
74:3;82:8,9,19;97:18;
120:12;124:1;140:5;
154:18,20;178:1;180:9;
188:15;218:6;224:15,
15:230:10;231:3
partial (1)
220:16
Partially (2)
222:16;231:25
participants (1)
58:2
participated (5)
67:2;74:11;79:11;
191:12,16
participating (1)
67:8
participation (1)
67:14
particular (9)
14:17;15:11;30:14;
33:6;44:7;54:25;177:17;
216:24;222:1
particularly (3)
28:4;30:23;43:3
parties (6)
7:15;74:12;97:5,16;
98:7;129:16
partly (2)
124:10;232:10
partner (6)
9:6,8,8;12:1;42:2;
43:12
partners (1)
9:18
party (6)
72:23;83:19;98:12;
99:20;212:15;215:23
past (2)
32:23;147:19 | paste (1)
199:2
pasted (5)
42:17;45:18;198:18,
21,25
pathological (1)
239:6
Paul (4)
4:7,19;212:17;219:17
Pauley (84)
33:6;34:10,16;37:3,
17;74:17,21;75:2;77:25;
104:1;105:12,19;
107:13;109:20;110:23,
25;112:22;113:7;
114:17,23;115:21;
116:19,20;117:6,10,23;
118:7;124:2,11;126:14,
22;128:4,13;130:15;
131:1,5;132:9,12;133:3;
138:23;139:3;140:10,
16;141:8;143:5;144:4,8,
8,11,15,19;145:9;151:6,
16,23;153:13;157:22;
158:8;160:4;165:7,9,24;
174:1;185:4;187:24;
188:6,14,17;194:21;
196:25;199:19;200:4,
21;214:3,8;216:20;
217:23;219:24;220:7,
18;222:18;223:5;
224:18;226:7
Pauley's (14)
104:4;105:22;113:21;
183:15;216:4;221:24;
224:20,23;225:1,5;
227:5,12;228:3,7
Pause (1)
130:25
pay (5)
124:18,21;137:14,18;
219:9
paying (1)
131:19
penance (1)
192:5
pending (7)
38:17;51:14;52:18;
53:1;60:8;98:9,16
penetrate (1)
128:6
penitentiary (1)
163:14
people (30)
11:25;13:21,25;15:24;
45:5,8,13;56:12;77:19;
82:17;87:4;91:23;93:2,
3;122:5;128:7;168:17,
20,23;179:17;181:23;
187:18,21;194:23;203:6,
12;206:19;209:9;
210:22;238:13
people's (1) | 210:2
per (1)
231:3
percent (3)
199:8,17;214:10
peremptory (3)
30:3;32:13;86:8
perfect (2)
62:7;239:4
perfectly (1)
100:24
performed (1)
192:7
Perhaps (5)
5:10;45:13;56:7,11;
209:10
period (7)
5:11;11:12;53:19;
88:13,18;181:9;182:13
perjure (2)
192:9;231:6
perjured (5)
192:16;227:21;
232:23;235:9;236:20
perjuring (1)
239:9
perjury (7)
228:21;231:11;233:3;
234:3,14;235:11;237:1
permanent (4)
158:4,6;159:20;160:7
permitted (3)
68:2;98:12;167:15
perpendicular (1)
35:8
person (53)
11:13,15;14:7;16:25;
18:3;34:9;43:17,21;
46:5,15;47:21;50:3,5,10;
54:13;55:2;56:15;61:21,
24;62:1,4,10;65:6;69:9;
70:23;71:18,23;72:2;
75:8;79:15;80:2;86:1,1,
13:90;15,24;91:2,6,16;
92:9;94:7;106:13;
119:10;120:4;134:15;
135:1;154:22;158:16;
193:13;200:25;201:1;
210:16,16
personal (25)
38:16,20,23;39:1;
51:13;60:8,10;98:1;
131:25;132:6,12,13,18,
22;133:10;159:10,15;
187:4;191:18;212:1,17,
21;214:12,15;218:5
personally (5)
25:7,8;214:6;219:2,5
perspective (1)
229:15
pertinent (2)
171:6;191:9
petit (1) |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------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+
+UNITED STATES OF AMERICA, v
+PAUL M. DAUGERDAS, ET AL.,
+
+February 15, 2012
+
+| 179:25 | 96:1 | 168:2;173:14;192:3; | practice (11) | printout (1) |
+|-------------------------|-------------------------|--------------------------|--------------------------|------------------------|
+| petition (7) | plausible (2) | 205:10,14 | 21:17;44:19;54:18; | 20:6 |
+| 177:15;178:1;181:3,3, | 13:19,22 | pointed (1) | 55:9:64:8;79:13;150:18; | printouts (1) |
+| 4;191:20;224:3 | play (3) | 51:13 | 175:13;176:22;177:1; | 10:19 |
+| phone (11) | 10:24;129:16,21 | poles (1) | 218:4 | prior (9) |
+| 5:14,15;95:2;184:15; | players (1) | 16:17 | practicing (4) | 32:15;48:8;99:2; |
+| 196:19,22;197:13,15,18; | 111:7 | police (6) | 89:16;135:7,11,12 | 100:8;150:10;165:11; |
+| 198:9,11 | playful (1) | 156:23;157:1,4;180:1; | precise (1) | 211:22,22;216:2 |
+| phonecalls (1) | 197:22 | 185:22;216:6 | 57:15 | prison (6) |
+| 184:14 | playing (1) | popped (1) | precisely (2) | 94:19;181:23;189:5, |
+| phoned (1) | 198:7 | 70:21 | 48:7;140:17 | 25;190:4,8 |
+| 5:14 | plaza (4) | pored (1) | prejudged (1) | private (1) |
+| phrase (2) | 58:12,13;87:16;92:17 | 206:4 | 213:2 | 13:1 |
+| 26:7,8 | plead (2) | portion (2) | prejudice (3) | privilege (3) |
+| physical (2) | 102:4,7 | 57:1;239:2 | 140:23;217:24;220:10 | 102:9,19;233:25 |
+| 175:14;187:19 | pleaded (1) | portions (1) | prejudiced (2) | pro (7) |
+| physically (2) | 181:7 | 47:25 | 99:22;100:9 | 15:16;16:15;26:4,7, |
+| 18:14;187:20 | pleasant (1) | portray (3) | prelitigation (1) | 11:87;18,18 |
+| physician (1) | 207:24 | 152:8,20;153:4 | 9:13 | probability (1) |
+| 6:9 | please (19) | portrayed (1) | preparation (2) | 233:14 |
+| pick (5) | 55:16;97:8;116:13; | 210:17 | 65:4;76:25 | probably (43) |
+| 93:14,15;211:16; | 119:15;122:9;123:20; | Pose (2) | prepare (1) | 16:22;18:15;27:6; |
+| 213:11;228:17 | 132:21;141:7,24; | 123:20;171:16 | 8:17 | 53:3;60:13;83:10; |
+| picked (7) | 159:25;161:9;163:10; | posed (2) | prepared (3) | 103:16;105:8;116:1,3; |
+| 45:10,14;56:12;210:7, | 169:11;170:8;191:13; | 113:19;172:2 | 5:7;107:12;238:19 | 122:19;125:23;126:4; |
+| 9:228:7,14 | 197:25;198:8;200:12; | posing (1) | preparing (6) | 128:1;135:20,21;138:6, |
+| picture (2) | 235:19 | 171:2 | 11:13,16;12:11;20:15; | 22;139:6;146:20;152:2; |
+| 129:15;206:16 | pleasure (1) | position (5) | 80:15;85:24 | 153:17;154:5;155:1; |
+| piece (1) | 195:9 | 35:13;121:21,24; | preprinted (1) | 156:7,16,22,23;168:16; |
+| 23:8 | plenty (1) | 122:2;188:3 | 195:18 | 174:18;185:6,10; |
+| pieces (2) | 48:24 | possessed (1) | prescription (2) | 189:20;192:21;198:18, |
+| 20:10;91:12 | plucked (2) | 18:14 | 121:5,8 | 21;199:2;205:17; |
+| pinpoint (1) | 55:24;91:13 | possession (5) | presence (6) | 209:13,14;210:21; |
+| 172:22 | pm (8) | 67:17;80:7;95:17; | 4:9,14,18,22;34:11; | 225:7;239:7 |
+| pique (1) | 55:11,13;57:10;58:6; | 189:9,16 | 36:7 | probation (4) |
+| 232:15 | 62:5,15;83:7;129:7 | possibilities (5) | present (11) | 33:1,3;94:16;189:12 |
+| piqued (5) | PMD (37) | 71:17,21;72:5,9;94:5 | 4:7,12,20;58:9;102:5; | problems (2) |
+| 222:9;231:15,23; | 31:1;36:24,25;64:23; | possibility (33) | 113:9;161:16;168:14; | 139:13,19 |
+| 232:2,13 | 65:2,16,21,24;125:8,9; | 43:16;59:15;60:1; | 169:7,13,16 | procedure (2) |
+| PJI (5) | 145:1,5,6;173:15,19,20; | 61:14;62:9;63:2,10; | presented (3) | 96:8;100:19 |
+| 223:6;225:9;226:24, | 175:19,24,25;176:1,6,7; | 71:11;72:2;74:10;86:18, | 129:10;217:3,22 | procedures (1) |
+| 25;227:2 | 179:15,21,22;194:4,8,9; | 21,24;87:7,13,24;88:10; | President (2) | 112:15 |
+| place (13) | 203:23,25;204:2,19,20; | 90:18,20;91:2,6,7,11; | 116:11,23 | proceedings (8) |
+| 9:4;32:21;34:23; | 211:3,6,10,11 | 92:13,24;94:6,11;96:13; | Presiding (1) | 98:4,5,20;99:17; |
+| 59:10;64:6;69:15;70:14; | PMD3 (1) | 233:8,23;234:2,13;236:6 | 175:21 | proceeding (10) |
+| 92:15;128:24;158:17; | 125:5 | possible (9) | Presley (1) | 59:13;85:4;98:15; |
+| 168:4;185:16;192:22 | PMD40 (3) | 28:11,19;50:5;58:25; | 99:25 | 99:24;100:10;102:21; |
+| places (9) | 36:15,15,20 | 62:4,9;70:10;71:14; | pretty (6) | 103:1;128:18;191:8,12 |
+| 91:14;149:12;150:5,7; | PMS (1) | 94:25 | 28:6;61:20;64:10; | proceedings (8) |
+| 153:15,16;159:20,24; | 121:4 | possibly (2) | 185:20;223:15;235:6 | 98:4,5,20;99:17; |
+| 160:1 | podium (4) | 34:7;145:14 | preventing (3) | 113:22;181:20;191:16; |
+| plaintiff (4) | 88:15;97:8;209:16,23 | Post-it (1) | 67:23;73:21,24 | 216:10 |
+| 60:10;149:9;153:22; | point (45) | 18:7 | previous (1) | process (13) |
+| 187:4 | 10:24;24:21;25:24; | post-trial (2) | 83:6 | 5:25;6:22;12:20; |
+| plaintiffs (2) | 27:6,10,20,23;28:12,15; | 25:17;87:25 | previously (4) | 13:15;29:2;76:19; |
+| 149:10;153:24 | 29:11;30:10,15;31:23; | potential (8) | 40:7;44:18;68:21; | 108:12;154:18,20; |
+| plaintiffs' (1) | 33:8;34:6;41:16;45:3; | 28:24;29:9,11;49:23; | 218:12 | 167:17;231:10;234:14, |
+| 218:8 | 49:18;50:1,12;55:4; | 62:22;88:12;165:12; | primarily (5) | 20 |
+| plan (2) | 56:4;60:16;61:14;67:5, | 191:14 | 11:13,15;65:6,7;218:5 | processing (1) |
+| 7:2;178:22 | 15;69:18;72:25;79:25; | potentially (3) | primary (2) | 11:22 |
+| planners (1) | 83:15;90:18,20;92:20; | 62:10;80:3;92:10 | 72:17;73:8 | produced (1) |
+| 207:15 | power (2) | power (2) | printed (1) | 81:24 |
+| plant (1) | 126:10;165:22;167:5; | 105:7,20 | 80:9 | product (1) |
+
+| 44:15
production (1)
82:1
professional (1)
210:20
professor (2)
143:19;227:3
profiles (2)
10:19,21
pro-government (1)
26:12
program (2)
179:9;180:11
programs (1)
174:13
promise (2)
57:1;186:9
promptly (1)
36:4
proof (1)
187:19
proper (4)
175:4;202:15,17,19
property (3)
66:7;189:6,22
propose (1)
19:10
proposing (2)
71:13,14
prosecution (8)
15:17;16:15;30:20;
87:18;111:9;114:1,17;
229:12
prosecutor (1)
195:15
prosecutors (9)
193:16,18,20,25;
194:1,11,15,19;214:18
prospect (1)
116:20
prospective (24)
11:21;13:5,6,16;
14:22,24;15:23,25;17:7;
19:7;20:9;28:9,18,21,25;
30:11,13;31:6,11,24;
34:8;61:21;69:8;103:9
protect (1)
99:23
protection (1)
184:12
protocol (1)
39:20
provide (1)
56:4
provided (3)
13:8;54:19;126:17
provides (1)
20:18
providing (1)
15:22
psychiatric (1)
176:23
psychological (1) | 100:7
psychologist (12)
107:3;109:3;113:5,23;
115:20;117:3;119:19;
120:12,15;121:19;128:5,
6
public (18)
14:1;23:10;28:22;
32:24;33:4;66:20;69:11;
98:4,10,21;99:20;100:3,
10;101:6;114:21,22,25;
115:2
publicly (4)
13:4,10,12;97:15
pull (3)
31:2;70:5;95:10
pulled (2)
21:6;55:25
pulling (1)
55:2
punched (1)
183:10
purist (1)
218:24
purpose (9)
29:16;88:22;98:6;
137:23;140:10,20,21;
157:11;238:20
purposes (3)
29:13;98:15;193:10
pursuant (2)
48:5;130:14
pursuing (1)
93:7
put (27)
64:6;78:11,11,11;
79:2,3;81:20;82:4;
94:25;123:4;133:20;
151:21,23;152:18;
161:9;196:8,11,20;
197:1,8,13,15;201:8,11;
210:10;229:4;235:3
putting (5)
78:3;198:9,11,13,16
Q | quickly (7)
20:10;23:20,23;47:6;
61:20;132:2,4
quite (1)
43:7
quote (5)
111:5;118:23;120:10;
199:5;218:24
quote-unquote (1)
121:20
quoting (2)
100:1;235:23 | read (16)
31:4;37:2,3,12,18;
39:8;41:19;72:14;83:6;
122:11,13,14;132:2;
134:8;210:2,3
readily (1)
44:18
reading (11)
37:17,18;72:15;73:1;
118:20;119:1,4;145:13;
173:1;199:18;200:5
readmission (1)
224:3
ready (7)
7:12,15,17;221:3;
238:14;239:5,13
real (2)
198:13,15
reality (1)
16:22
realize (1)
91:13
realized (1)
91:24
really (39)
45:14;47:18;49:21;
56:7;70:12;71:5;99:14;
113:11;117:24;121:21;
127:3,14;142:15;
151:22;152:11,23;
160:21;162:21;163:2;
164:6;168:13;170:17;
172:18,20;186:21;
188:5;192:5,11;194:3;
195:3;200:2,2;203:5;
208:1;209:25;231:5;
234:7,15;236:7
reason (23)
5:20;6:11;12:9;25:1;
33:10;34:1;47:4;88:3;
91:4;108:18,20,23;
109:1;124:4;153:7;
175:14;187:16;195:14,
15;198:25;203:5;
237:22;239:4
reasonable (2)
99:23;210:8
reasons (3)
26:14;232:17,25
recall (76)
14:16;17:21;22:3,5,6;
23:25;30:18;31:10;32:9;
33:4;54:21;58:14;59:1;
60:4,5;67:14;72:15;
73:1;81:14;85:2,7;
90:15;92:21;94:4;103:7;
110:19;111:15,17;
114:4;115:5,5,7,10,12,
13,24;118:10,11,13,13,
15,17,22;119:5,7;
124:13,13,14,20;130:16,
20;131:3,7,21;135:16;
138:7;139:2,7;142:25; | 143:2,7;150:13;156:10;
168:19;170:17,19,22;
182:10;188:17,19;
199:21;204:23;213:19;
215:12;217:5;218:21
recalled (1)
41:18
receipt (3)
87:22;88:5,8
receive (6)
55:17;64:1;107:16;
110:22;116:20;117:10
received (55)
5:11;11:9;13:16;
14:20;17:7,16,18,22;
18:9;19:24;20:1;23:16;
30:7;36:24,25;48:19;
65:22,23,24;70:1;75:23,
25;76:12,14;80:1;88:24;
97:13;109:21;110:19,
24;125:8,9;129:11;
133:23;134:9;145:5,6;
173:19,20;175:24,25;
176:6,7;179:21,22;
194:8,9;204:1,2;211:10,
11;216:19;217:15;
221:12;223:3
receiving (5)
113:9;117:6;180:8;
189:6,22
recent (1)
41:9
Recess (11)
6:19;84:3,18,20;
128:25;129:2,4,9,13;
192:25;193:2
recognizance (1)
186:3
recognize (9)
10:15,21;17:5,6;
18:21;19:3;36:16,17;
72:12
recognizing (1)
106:14
recollection (11)
12:7;31:5;58:12,21;
69:3;70:7;77:1;83:12;
93:16;111:12;131:22
recommended (2)
180:14,16
reconvene (1)
192:25
record (17)
14:1;32:16;66:20;
96:1;97:10,15;98:8;
101:2;114:21,23,25;
115:2;116:1,2;121:16;
122:14;212:13
records (10)
44:15,16;66:7,8,8,8,
10;69:11;98:5;100:6
recovery (1)
178:22 |
+|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+
+UNITED STATES OF AMERICA, v
+PAUL M. DAUGERDAS, ET AL.,
+
+| RECROSS-EXAMINATION (1) | 123:5 | 217:21;225:22 | request (4) | 45:7 |
+|--------------------------------|--------------------------|--------------------------|-------------------------|-------------------------|
+| 95:23 | relate (1) | rendered (7) | 42:14;98:3,18;114:19 | responding (3) |
+| redacted (8) | 66:2 | 128:16;132:16; | requested (1) | 47:18;114:18;119:17 |
+| 46:25,25;47:25;48:1, | | 133:12;134:6;137:10; | 237:11 | response (14) |
+| 5,15,19,21 | | 148:7;169:16 | 100:22 | 40:8,9;41:8;55:13,22; |
+| redirect (5) | 176:18 | rendering (5) | 100:22 | 70:6,12;76:4;118:13,17; |
+| 89:24;90:1;222:24,25; | | 154:11;192:12; | requests (1) | 119:10;143:8;157:14; |
+| 236:9 | | 226:11;227:18;237:8 | 99:16 | 184:22 |
+| refer (9) | 179:16 | renderings (1) | require (1) | responses (6) |
+| 24:8;25:14,20;37:15; | | 175:18 | 107:14 | 43:9,19;59:5,6;60:4; |
+| 38:2,4;77:10;116:14; | | renew (1) | required (2) | 64:20 |
+| 235:15 | 238:4 | 239:10 | 43:11;102:25 | responsible (4) |
+| reference (6) | 186:3;237:24 | rent (4) | 217:10 | 11:13,15,17;65:6 |
+| 25:12;27:2;41:5; | | 131:19;137:15;160:8, | | responsive (2) |
+| 62:16;78:5;133:25 | | 14 | research (9) | 113:17;183:15 |
+| referenced (3) | 214:2 | repeat (5) | 14:3,11;24:22;25:3; | rest (4) |
+| 52:13;61:2;213:15 | | 112:14;119:15;140:8; | 29:23;44:25;57:19; | 8:20;14:14;35:8;239:2 |
+| referred (7) | 98:13;135:9;156:20; | 141:7;159:25 | 59:23;90:14 | restart (1) |
+| 166:20;207:21;208:4; | | repeatedly (5) | 94:23 | 96:11 |
+| 213:19;218:16;219:4; | | 192:17;227:22; | | restate (2) |
+| 221:17 | | 232:23;233:9;234:20 | researching (3) | 169:11;170:8 |
+| referring (14) | 73:7,8,17;74:4;81:8; | rephrase (5) | 28:12;29:13,16 | result (1) |
+| 22:21,22;36:13;39:15; | 128:18;138:2;173:4,11 | 77:24;132:21;141:24; | reside (4) | 219:1 |
+| 41:24;83:3;111:14,16, | | 221:22;235:19 | 145:11,21;147:24; | results (1) |
+| 19;199:7;206:7,12,15; | | replaced (2) | 151:10 | 77:6 |
+| 223:10 | | 34:22;96:9 | resided (11) | resume (2) |
+| refers (2) | 229:25 | replied (1) | 145:17,18;147:25; | 129:3;130:1 |
+| 20:21;40:13 | | 138:4 | 149:11;150:4,4,5,7; | retain (7) |
+| reflect (1) | 12:5;15:11;29:7,8; | report (79) | 151:16;154:24;155:24 | 126:15,18;139:4,4,9, |
+| 12:7 | | 5:1,8;6:9;9:17;17:20; | residence (8) | 21:199:23 |
+| reflecting (1) | 30:13,13,22,22,23;31:8, | 45:10,18;46:5,7,8,10,17, | 6:2;144:21;151:10; | retaining (1) |
+| 91:9 | 8,9;38:22;43:7;58:21; | 21:47;15:48:9,12;49:5,7, | 159:20;160:7,7;168:3; | 118:23 |
+| refresh (2) | 61:1;62:24;63:4;68:17, | 8,18;50:2,3,6,9,24;51:8, | 172:1 | retired (7) |
+| 131:21;138:14 | 79:11;83:10;85:14,15, | 19:53;21:54:8,10,13,15, | residences (6) | 161:15;162:11,12; |
+| refreshes (1) | 19:90;5:24;94:2;109:17; | 19:20,24;55:24;56:5,13; | 151:20;155:10,14,18, | 163:3,8,19,24 |
+| 31:5 | 111:3;115:23,25; | 59:20;60:7,9;61:25; | 21:158:15 | retrospect (1) |
+| refreshing (1) | 117:25;118:5,25;119:3, | 62:2,3,20;63:24;70:17, | resisting (1) | 191:7 |
+| 111:11 | 5;121:15;124:17; | 24:71;1,5,22;80:12,15; | 183:13 | return (5) |
+| refuse (1) | 125:20,22;126:20,22; | 82:17,18;83:1,5,7,9,16; | resolved (3) | 135:23;136:5,8;196:8; |
+| 131:1 | 138:8;139:8,11,16,21; | 87:1;91:16,20;92:18,21, | 52:19;53:1,19 | 213:16 |
+| refused (3) | 140:1,4,7,9,13,14,16,20, | 23:93;2,8;173:16; | resource (1) | 136:2 |
+| 131:8;133:8;138:25 | 24;142:16;144:1,3,23, | 177:18,24;178:1,4,6,8, | 28:23 | reveal (7) |
+| regard (2) | 25;156:1,4;161:5; | 11:180:4,15,23 | resources (2) | 36:3;140:3;141:22; |
+| 98:2;121:1 | 165:17;166:3,4;167:24; | reported (8) | 133:17;237:5 | 167:6;185:1;212:13; |
+| regarding (4) | 169:23,25;170:2,9; | 38:16;46:10;50:17,18; | respect (18) | 229:1 |
+| 7:4;97:12;98:1;227:11 | 172:12;182:15,20; | 51:3;54:13,14;180:10 | 30:19;31:11;58:19; | revealed (4) |
+| regret (4) | 185:21;189:14;190:25; | reporter (5) | 83:18;95:15;102:20; | 98:15;166:11;172:6; |
+| 74:5,5,8;79:17 | 199:8;205:22;206:20; | 8:6;101:20;122:11,12; | 108:11;200:15;212:2, | 184:21 |
+| regular (1) | 211:19;213:13,16;215:4, | 145:15 | 22:213:7,12;214:7,12; | revealing (1) |
+| 158:18 | 8;216:19,24;217:1,1,15, | reporting (6) | 218:17;220:6;221:19; | 184:2 |
+| rehabilitated (1) | 17;218:17;220:7,11; | 6:3;54:16;55:1,14; | 227:13 | review (10) |
+| 32:24 | 221:24;223:2,4,23; | 56:15;91:15 | respectfully (2) | 10:15;22:8;42:19; |
+| reinstated (5) | 224:18,19 | reports (3) | 6:12;102:17 | 49:18;68:6;73:14;76:20; |
+| 150:18;176:22;177:1, | | 52:1;54:10;55:4 | respecting (1) | 83:1;95:5;178:4 |
+| 6,9 | | represent (1) | 88:11 | reviewed (16) |
+| reinstatement (7) | 121:10 | 38:7 | respective (1) | 43:19;49:20;55:4,6,7; |
+| 177:3,12,13,15;178:2; | | represented (5) | 97:17 | 59:8;62:20;70:17,22; |
+| 191:20;224:3 | remission (3) | 8:15,22;107:19; | respond (3) | 73:11,12,13;83:9;92:18, |
+| reject (4) | 175:3,3;177:10 | 149:10;153:24 | 199:13;200:18;239:13 | 23:97:4 |
+| 121:12,12;122:20,21 | remote (6) | representing (1) | respondeat (7) | reviewing (2) |
+| rejected (1) | 59:15;63:9;71:15; | 10:4 | 37:8,20;38:21;42:25; | 23:25;50:1 |
+| 176:22 | 86:24;87:14;92:13 | reputable (2) | 60:12;169:2;240:14 | revised (1) |
+| rejecting (1) | render (2) | 152:2,5 | responded (1) | |
+
+| 73:11 | | 23:6 | | 13:24;23:11;28:16,22; | 136:13;149:3;167:10; |
+|-------------------------|--|-------------------------|--|-------------------------|-------------------------|
+| revisit (1) | | savings (8) | | 66:20;69:12;71:23 | 226:2,4 |
+| 96:12 | | savings (8) | | searching (1) | semester (1) |
+| Richard (13) | | 130:19;131:2,8,17,23; | | 14:8 | 240:10 |
+| 9:2,6,9,17;12:1;16:1; | | 133:22;137:17,18 | | seasoned (5) | send (7) |
+| 21:11;38:7;44:24;63:19; | | 21:1;22:2,6;24:4,5; | | 9:25;52:17,25;89:3,4 | 14:2;57:9,12;83:7; |
+| 67:20;77:2,5 | | 25:9;70:25;80:8;82:7,7, | | seasoning (1) | 93:22;181:23;240:7 |
+| ridiculosity (1) | | 8:116;16:219;22 | | 89:3 | |
+| 112:12 | | saying (25) | | seat (7) | 154:11,14,15 |
+| ridiculous (11) | | 41:18;47:20;59:1; | | 49:2;99:14;101:10,13, | sends (1) |
+| 111:9;114:1,9;115:3, | | 60:5,23;75:7;85:14,15; | | 19:185:4;190:19 | 22:23 |
+| 6,19;123:18,19,22,23; | | 91:17;108:20;115:23, | | seated (13) | senior (1) |
+| 203:12 | | 25:118;25:119;3,18; | | 8:24;32:9;35:9,10,11, | 12:18 |
+| right (116) | | 123:6;127:13;131:20; | | 12:49;2,12;50:10;71:18, | sense (7) |
+| 6:11,18;28:10;33:2; | | 140:24;163:18;177:9; | | 23:75;9:225:21 | 29:17,17;56:1;159:11, |
+| 35:11;36:1;37:24;48:7, | | 205:24;206:2,20;227:19 | | seating (1) | 15:176;24;182:14 |
+| 17,25;49:3;52:10;54:14; | | saysAttached (1) | | 35:6 | sent (29) |
+| 62:13;63:8,13;67:1; | | 45:10 | | second (13) | 13:25;14:6,10,15; |
+| 72:5,23;73:23;74:19; | | scale (1) | | 22:11;40:7;129:13; | 23:7;39:9;40:25;41:9; |
+| 77:19;80:18;81:9;91:21; | | 135:5 | | 151:9;157:22;178:10, | 56:4;58:5;62:11,15; |
+| 92:1,6;94:21,24;95:6,9; | | scene (1) | | 15:183:4,7;184:4;185:5; | 64:3,4;70:24;80:10; |
+| 97:11;99:3;105:13; | | 183:13 | | 189:22;202:1 | 81:14,22;83:1,9,12; |
+| 106:23;107:25;115:11, | | SCHECTMAN (19) | | section (10) | 86:15;87:2;91:12,15; |
+| 13;121:25;124:9;125:3, | | 36:22;48:4,7;53:3; | | 51:16;65:7;72:16,16; | 92:16,19;93:8;213:15 |
+| 11;126:13;129:23; | | 65:18;72:6;75:20;76:9; | | 73:7,8,17;81:9;85:25; | sentence (10) |
+| 130:3;131:6,13;133:15; | | 204:11,12,15;209:17,22, | | 213:11 | 77:4,4;85:4,9,11; |
+| 140:7;142:4;143:13; | | 24;210:25;211:16; | | seeing (5) | 190:4;202:6,14;207:4,5 |
+| 144:20;147:15;148:14; | | 215:2;218:20;219:4 | | 22:3,5;50:2;224:6,11 | sentenced (1) |
+| 154:4,7;156:19;157:8; | | Schectman's (1) | | seeking (2) | 189:5 |
+| 158:1,12,21;159:7; | | 218:17 | | 99:20;101:7 | sentencing (2) |
+| 163:9;164:8,19;165:3, | | schedule (1) | | seeks (1) | 234:25;235:2 |
+| 14,21;166:6,14;167:22; | | 7:8 | | 100:3 | separate (1) |
+| 171:13;172:3,9,21; | | scheduling (1) | | seem (3) | 13:11 |
+| 175:9;177:7,10;180:18; | | 7:5 | | 55:25;160:20;230:23 | separated (1) |
+| 181:4;182:14;183:19; | | scheme (2) | | seemed (3) | 13:17 |
+| 185:9,20;186:1;188:9; | | 28:6;166:2 | | 45:11;87:3;236:22 | September (1) |
+| 190:22;192:24;193:15; | | Schoeman (7) | | seems (6) | 184:3 |
+| 195:2,9,13,18;196:14, | | 69:5,10,10;70:3,8; | | 60:11;86:3;150:19; | series (3) |
+| 20,22;197:16,24;199:10; | | 77:14;78:6 | | 160:23;166:25;210:20 | 40:6,22;42:13 |
+| 203:25;206:25;208:7, | | school (14) | | sees (2) | serve (9) |
+| 20;209:13;211:10; | | 12:8;32:24;33:4; | | 112:12;171:3 | 170:5,10,14;172:11, |
+| 221:23;223:25;225:8, | | 37:24;42:4;93:14,16; | | select (2) | 25;173:5;214:11;221:5; |
+| 11;226:22;228:5; | | 120:3;158:4,5;167:25; | | 14:25;15:2 | 237:10 |
+| 229:17;235:5;238:20; | | 171:13;218:2;240:7 | | selected (6) | served (13) |
+| 239:19;240:4 | | screaming (1) | | 29:5;31:12;212:25; | 33:3;94:18;105:13; |
+| right-hand (1) | | 156:18 | | 213:3;214:11;221:5 | 117:15,16;121:11;123:6, |
+| 180:3 | | screen (4) | | selecting (1) | 9;157:3;190:4,6;218:7; |
+| rights (2) | | 10:12;31:3;65:1;196:7 | | 15:5 | 237:7 |
+| 100:9,21 | | SCt (1) | | selection (2) | server (1) |
+| ripping (1) | | 100:1 | | 17:20;182:17 | 21:11 |
+| 137:5 | | sealed (1) | | selectively (1) | servers (1) |
+| rival (1) | | 98:5 | | 101:4 | 21:10 |
+| 184:13 | | sealing (1) | | self-employed (1) | Service (11) |
+| Robert (8) | | 99:9 | | 135:21 | 5:5,11;6:1;31:12;32:9; |
+| 46:2,18,22;47:5,9,12, | | Sean (1) | | self-evident (1) | 102:10;161:2;221:12, |
+| 17,21 | | 8:19 | | 235:6 | 13;238:6;239:17 |
+| role (7) | | search (11) | | self-incrimination (1) | serving (4) |
+| 10:24;14:17,19;60:15; | | 14:1;23:23;24:25; | | 99:4 | 191:23;192:4;222:8; |
+| 76:18;118:9;218:10 | | 25:8;41:24;45:5,8;77:6, | | Seligman (2) | 224:6 |
+| roll (2) | | 14;78:6;85:20 | | 177:19;180:23 | SESSION (2) |
+| 17:7;18:9 | | searched (1) | | Seligman's (2) | 129:6;217:13 |
+| romantic (1) | | 23:12 | | 177:24;178:10 | sessions (1) |
+| 184:13 | | searches (7) | | semantics (5) | 240:11 |
+
+| set (2)
13:19,20 | showing (3)
67:17;120:10;129:20 | small (3)
35:8;70:4;181:16 | 70:4
speak (14)
5:2;6:8;77:17;86:6;
140:14,18;143:5;194:21,
22,24;195:1;225:20;
233:11;237:11 | stamps (4)
201:15,23,25,25 |
+|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------|
+| sets (1)
132:25 | shown (1)
239:6 | smaller (2)
29:6,14 | stand (3)
93:20;169:23;219:22 | stand (3)
164:4,14;210:8 |
+| setting (1)
73:22 | shows (1)
108:11 | smart (7)
116:3,4,5,6;206:22,22;
207:11 | speaking (6)
70:17;87:7;136:6;
141:3,9;238:24 | standard (3)
164:4,14;210:8 |
+| seven (8)
74:14;172:2;190:5,5,
6,6;207:3;210:13 | shrimp (4)
182:3,6,8,11 | snapshot (7)
19:6;20:2,8,16,21;
22:2,4 | special (2)
16:19;117:9 | standards (1)
136:24 |
+| seventh (1)
12:4 | side (10)
26:5;30:23;125:11;
140:24,24;205:4,9;
210:21;214:9;237:11 | snapshots (1)
22:8 | special (3)
201:8,12,21 | standing (2)
9:21;105:12 |
+| several (4)
89:14;95:12;155:7;
203:23 | sidebar (1)
34:14 | somebody (4)
179:24;193:9 | specific (10)
20:10;25:12;61:6;
131:10;158:16;171:17;
176:10;188:5;206:10;
223:3 | Stanley (1)
4:3 |
+| severe (1)
94:17 | sides (3)
153:23,24;155:15 | somehow (3)
43:16;55:22;192:1 | specifically (26)
22:6;24:5;61:2;74:21;
118:10,16;121:15;
124:13,17;126:1,1;
130:17;138:7,17;139:7,
12,23;147:17;150:13;
151:8;153:6;156:10;
170:17;179:11;181:3;
190:25 | Stapp (8)
11:20;12:3,7;14:13;
18:8;26:22;27:4,9 |
+| severely (1)
239:7 | sign (1)
102:17 | sometime (1)
80:1 | spell (2)
8:5;101:20 | start (12)
16:24;17:23;18:11;
21:20;24:17;25:9;48:11;
140:9;160:23;161:2;
225:19;227:5 |
+| shades (1)
120:16 | signed (6)
6:20;76:22;102:19;
150:25;151:1;177:4 | sometimes (8)
9:12;28:9;147:2;
148:19,22,24;153:1;
179:23 | spent (3)
60:15;85:23;237:5 | starting (2)
51:16;91:8 |
+| Shambron (1)
169:24 | silly (1)
158:20 | somewhat (1)
216:25 | spite (1)
220:14 | starts (4)
24:2;42:19;57:10;
90:22 |
+| Shanbrom (4)
169:23;219:11,13,17 | similarly (1)
212:7 | somewhere (6)
21:9;81:21,22;139:6;
162:18;187:14 | split (1)
200:15 | State (14)
8:5;9:14;81:4;89:17;
94:18;101:19;112:15;
132:8,24;136:2;144:6;
179:17;209:22;223:7 |
+| share (2)
60:21;68:2 | simple (3)
6:15;134:3;227:8 | soon (5)
5:4;6:7;7:3,7;137:20 | spoken (2)
100:18;223:21 | statements (3)
69:15;111:3;128:23 |
+| shared (6)
21:15,18;68:12,13,15;
77:6 | simply (4)
43:15;47:20;186:9;
227:20 | sorry (15)
62:14;65:1;89:1;
107:1;112:17;131:14;
136:17;139:7;157:19;
172:22;173:1;201:20;
210:10;221:2;230:14 | spooke (4)
5:3;71:6;77:19;220:15 | States (12)
4:4,4;8:21;102:6,10;
103:8;105:4,6;116:11;
118:9;128:7;148:17 |
+| sharing (1)
67:23 | single (2)
30:2;225:8 | sort (6)
112:1;182:14;192:5;
205:19,21;223:6 | sprin (1)
159:3 | statement (14)
35:1;72:24;113:21;
127:12;133:23;151:2;
153:10;160:3,4;200:20;
22;218:14,20;230:4 |
+| Sharon (1)
4:15 | sit (10)
35:3;112:7;132:10,11;
166:11;204:22;233:2;
234:19,24;235:7 | sounds (1)
17:21 | spot (2)
80:3;90:11 | stating (1)
98:11 |
+| Shechtman (38)
4:19,19,21;7:4,9,14,
21,23;11:5;17:12;19:14;
81:25;82:3;84:4,5,21,22,
24;88:14,17;89:22;90:3;
94:12;95:22,24;96:4,21;
229:20,21,23;236:8;
237:21;239:19,20,25;
240:2,5,13 | sitting (7)
43:6;80:3;166:16;
185:4;188:20;195:24;
235:24 | sources (1)
13:13 | spot (2)
80:3;90:11 | stationery (1)
195:18 |
+| shed (1)
71:8 | sliding (1)
19:13,21;84:9;96:20 | sources (2)
13:13 | spouse (4)
43:6;66:4,5;188:18 | status (2)
212:13;221:6 |
+| shelter (2)
154:1;166:1 | sleep (2)
148:23,24 | sounds (1)
17:21 | spreadsheet (2)
20:6,7 | stay (6)
52:7;88:15;147:2;
170:17;209:16,22 |
+| shelters (3)
215:19;221:19;222:3 | sliding (1)
13:5 | sources (1)
31:16 | spot (1)
50:12 | stay-at-home (1)
164:19 |
+| shield (1)
100:3 | slowly (2)
8:6;101:20 | southern (3)
203:17,19;235:24 | spot (1)
180:9 | steal (3)
182:1,8,11 |
+| shock (1)
91:9 | slightly (1)
31:16 | sovereign (1)
187:2 | stability (1)
224:8 | stealing (1)
182:4 |
+| shocking (2)
173:10,23 | slowly (1)
8:6;101:20 | space (1) | stamp (4)
201:8,11,19,21 | step (5)
4:24;13:14;84:19; |
+| shoplifting (3)
181:13,16;215:8 | | | | |
+| short (2)
53:19;239:21 | | | | |
+| show (4)
6:12;120:11;187:18,
21 | | | | |
+| showed (1)
143:3 | | | | |
+
+February 15, 2012
+
+| 96:25;238:5 | student (1) | suggested (3) | 240:16 | tab (5) | |
+|---------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------|-----------------------------------|
+| Sternheim (30) | 239:22 | 35:20;41:4;231:14 | suspended (69) | 125:1,2;130:21;
150:16;194:10 | |
+| 4:23,24,25;5:8,10,22,
24;6:3,6;54:1,2,3;84:12,
14,17;97:5,7,9,22,25;
98:22,25;99:7;101:9,11,
13;108:1,3;129:10;
137:25 | studied (4) | suggesting (1) | 22:19;24:19;26:15;
33:9,11;34:6,7;43:17,21;
45:12;50:4;54:11,14,18;
55:5,9;56:9;58:25;
59:16;60:23;61:4,7,9,15,
19:63;3,11;67:18;69:1,
7;70:10,20;71:3;72:2;
75:9;79:13,21;80:3;
85:22;86:2,9,18,22;87:4;
89:13,13,16;90:21;91:1,
25;92:2,4,24;93:4;
94:15;119:25;135:14;
145:10;175:13;177:8;
203:17,19;208:7;
210:11;212:14;216:16;
221:6;231:9;236:24 | subsending (1) | 59:1;117:1;194:15,19;
195:6,12 |
+| Stetler (1) | subconsciously (2) | summarized (1) | suspension (1) | table (5) | |
+| 77:7 | 154:5,6 | 165:24 | summerized (1) | tables (1) | |
+| still (11) | subject (3) | summers (1) | suspending (1) | talk (6) | |
+| 87:7;98:8,16;149:3;
165:1;172:16;196:18 | 215:15;221:25;222:6 | 158:6 | 24:6 | 59:1;117:1;194:15,19;
195:6,12 | |
+| stimulation (1) | submission (1) | Sunday (7) | suspension (1) | talked (3) | |
+| 232:19 | 177:18 | 19:8;21:1,22;22:2,4;
109:16,17 | supervised (1) | 59:9,14;71:10 | |
+| stipend (3) | submit (5) | superior (7) | supervised (1) | tax (14) | |
+| 232:8,10,12 | 77:17;85:7;126:17;
177:11,13 | 37:8,20;38:21;42:25;
60:12;169:2;240:14 | suppending (1) | 135:23;136:2,5,8;
154:1,1;166:1,1;215:19,
19;221:19;222:1,3,10 | |
+| stipulate (1) | submitted (14) | supervised (1) | suspension (1) | taxes (1) | |
+| 73:5 | 36:11;74:14;76:3;
78:4;100:22;102:15;
151:3,4;169:5;176:23;
177:3;178:1,4;180:23 | 20:7 | suspension (1) | 215:19 | |
+| stomach (1) | subsequent (1) | support (5) | suspicious (1) | team (15) | |
+| 183:10 | subpoena (13) | suppose (1) | suspension (1) | 6:21;12:19;13:23;
14:14,21;20:13;21:3;
39:9,19,25;44:15;
111:20,21,23;112:5 | |
+| stop (7) | subsequently (3) | supposed (2) | Sustained (19) | technology (1) | |
+| 27:1;37:12;116:13;
167:1;169:16;209:19;
210:25 | 62:20;79:18;186:15 | 169:8;238:12 | 77:23;89:21;106:5;
112:6;115:18;117:4;
134:19;136:16;152:18;
159:9;160:25;161:9;
181:25;201:6;228:20;
233:7;234:11,23;236:5 | 30:12 | |
+| stopped (2) | subsequent (1) | sure (65) | Swan (1) | telephone (1) | |
+| 154:15;205:14 | subsequently (3) | 12:14;15:2;25:11;
31:2;43:2;44:19;45:7,8,
15;68:5;72:7;79:20;
103:6,13;108:24;109:2;
111:4;121:2,15;132:22;
136:9;137:5,20;140:21;
142:15;143:13,24;
147:16,17,20,21;151:8;
154:19;156:13;163:2;
165:23,23;166:22;
174:16;176:10;183:7;
186:11;189:11;190:19;
194:3,25;197:23;
199:10;201:22;203:14,
18;205:25;206:10,24;
207:12;211:3,5;226:2,9;
230:12,25;231:13;
233:16;234:25;237:3 | 59:13 | telling (17) | |
+| store (3) | substance (6) | surprise (1) | Swann (1) | telling (17) | |
+| 182:2,9,15 | 189:9;206:11,13;
217:17;219:7;223:3 | 91:22 | Swann (1) | 57:5;108:10,14;
117:25;123:12;128:13;
132:18;139:8,21;
158:23;159:1,2;161:1;
167:18;170:19;205:3,9 | |
+| stored (1) | substantial (1) | surprised (2) | Swayed (1) | tells (1) | |
+| 21:8 | 238:22 | 43:7;152:16 | swayed (1) | 50:7 | |
+| stores (1) | substantive (3) | Susan (4) | sweater (1) | template (1) | |
+| 181:17 | substantivelywise (1) | 8:25;71:10,12;86:6 | sweeney (1) | 63:21 | |
+| story (1) | subways (1) | suspect (2) | swing (1) | ten (2) | |
+| 116:16 | 58:14 | 84:15;166:10 | swing (1) | 60:16;189:20 | |
+| straightforward (1) | success (3) | suspected (1) | switch (2) | tend (1) | |
+| 223:15 | successful (5) | 167:1 | switch (2) | 229:16 | |
+| strange (1) | suffer (2) | suspected (1) | switch (2) | tendered (1) | |
+| 160:23 | 120:21;174:9 | 167:1 | switch (2) | 126:19 | |
+| strategic (2) | suffered (3) | suspected (1) | switch (2) | 126:19 | |
+| 10:4;15:19 | suffered (3) | suspected (1) | switch (2) | ten-minute (1) | |
+| Street (1) | suffering (1) | suspected (1) | switch (2) | 192:25 | |
+| 70:5 | suffering (1) | suspected (1) | switch (2) | ten-year (1) | |
+| stressed (4) | suggest (5) | suspected (1) | system (8) | 190:4 | |
+| 31:12,13,15,17 | 45:14;53:3;63:2;
93:22;97:13 | suspected (1) | sympathetic (2) | term (1) | |
+| strike (4) | suffered (3) | suspected (1) | sympathetic (2) | 33:3 | |
+| 34:25;89:18;108:3;
148:8 | suffered (3) | suspend (1) | sympathy (2) | terms (10) | |
+| strikes (1) | suffering (1) | suspend (1) | sympathy (2) | 37:21,23;38:1,10;
84:6;91:25;121:20;
187:5;195:3;221:25 | |
+| 29:8 | suffering (1) | suspend (1) | sympathy (2) | terrible (1) | |
+| strong (1) | suffering (1) | suspend (1) | sympathy (2) | 174:6 | |
+| 91:9 | sufficient (1) | suspect (2) | system (8) | terroristic (2) | |
+| strongly (1) | suggest (5) | suspected (1) | system (8) | 189:13;190:1 | |
+| 166:10 | suggest (5) | suspected (1) | system (8) | testified (10) | |
+| struck (4) | suffered (3) | suspend (1) | T | 8:4;24:12;86:20,23; | |
+| 30:3;32:6;42:24;50:4 | suffering (1) | suspend (1) | T | | |
+
+UNITED STATES OF AMERICA, v
+PAUL M. DAUGERDAS, ET AL.,
+
+| 90:25;94:4;101:18;
159:12;203:20;232:6 | 228:24;229:7;232:1;
233:8;236:6 | 132:10,11,12;139:4;
141:8;143:5;144:8;
155:2;157:10,14;
162:11;168:2;169:15,
21;170:2,16;171:12;
172:3;176:8;185:9,22;
195:5;197:8;199:5;
206:17;222:18;225:22;
226:14;229:14;230:3;
233:21,22 | 120:17
treatment (4)
97:12;174:13;179:9;
180:8
tree (1)
171:2
tremendous (1)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | 146:14;155:11;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 | |
+|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------|
+| testify (9)
5:4;100:22;107:14,17;
108:7,11;118:15;
119:11;120:5 | thoughts (2)
224:9;229:4 | tomorrow (8)
238:16,19,23,24;
239:15,23;240:20,22 | trial (1)
86:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | trial (4)
159:11,15
try (12)
29:17;50:6;112:14;
142:5;144:3;158:16;
159:10;209:8,18;210:8;
211:25;227:20
trying (18)
14:25;15:2;69:14;
75:7;91:19;95:25;114:1,
5,7;132:2;148:4,19;
162:4;166:17;192:4,6;
208:24;231:10
Trzaskoma (41)
8:1,2,7,13,15,20;
10:13;11:11;15:5;17:19;
18:11;20:2;28:24;29:8;
30:6,10;41:5;50:22;
51:11;52:6;53:10,14;
54:7;56:16,22;57:1;
59:17;65:25;76:15;79:6,
19;80:5;81:13;84:8,19,
25;87:21;90:3;95:25;
96:5,24
TRzaskoma (41)
8:1,2,7,13,15,20;
10:13;11:11;15:5;17:19;
18:11;20:2;28:24;29:8;
30:6,10;41:5;50:22;
51:11;52:6;53:10,14;
54:7;56:16,22;57:1;
59:17;65:25;76:15;79:6,
19;80:5;81:13;84:8,19,
25;87:21;90:3;95:25;
96:5,24
TRzaskoma's (1)
84:16
TT (2)
41:3,5
Tuesday (2)
147:16;185:6
turn (4)
40:19;42:12;48:11;
55:10
turned (1)
92:13
turning (2)
22:10;40:6
turns (1)
133:17
turnstile (1)
32:18
turtleneck (2)
31:24;32:4
twice (3)
55:4;181:13;230:21
twist (1)
174:8
twisting (1)
153:10
two (47)
16:16;56:12;60:14; | |
+| testimonies (1)
37:11 | Three (14)
7:9,12;9:2;13:18;58:9;
151:7;157:6,7;172:15;
173:5;192:4;207:5;
210:12;238:14 | top (7)
40:7,9;48:14;54:10;
55:10;82:23;95:2 | topic (1)
59:22
tort (3)
38:2,11,13
torts (1)
39:4
total (1)
135:19
totality (2)
94:13;219:25
totally (2)
43:20;208:23
towards (2)
58:14;229:11
towel (3)
205:11,16;206:2 | trials (1)
153:18
tried (5)
15:21;177:6,9;181:7;
189:18
trier (2)
225:3,3
trouble (3)
165:6;223:8,13
true (25)
26:16;28:14;29:13;
30:15;92:14;133:21;
144:9;153:9,10;156:12;
159:6,19;161:18;
167:18;171:18,20;
180:13;197:10;200:20;
209:2;212:24;213:6;
220:14;230:4;233:23 | 146:14;155:11;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+| testimonies (1)
37:11 | three- (1)
92:5
three-month (1)
48:24 | thrown (2)
185:8;206:2 | trouble (3)
60:14;105:9;106:3,7
training (3)
105:19;106:14;120:2
transactions (2)
206:11,13
transcript (17)
31:3;75:13;118:20;
119:1,4;125:10;130:22;
131:11,15;138:6,10;
144:14;145:8;150:2;
163:22;173:1;223:12 | treatment (4)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | treatment (4)
157:11,15;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+| Texas (1)
37:23 | threw (2)
205:11,16 | total (1)
135:19 | trials (1)
153:18
tried (5)
15:21;177:6,9;181:7;
189:18
trier (2)
225:3,3
trouble (3)
165:6;223:8,13
true (25)
26:16;28:14;29:13;
30:15;92:14;133:21;
144:9;153:9,10;156:12;
159:6,19;161:18;
167:18;171:18,20;
180:13;197:10;200:20;
209:2;212:24;213:6;
220:14;230:4;233:23 | treatment (4)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | treatment (4)
157:11,15;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+| theft (1)
190:3 | throughout (1)
168:14 | total (1)
135:19 | trials (1)
153:18
tried (5)
15:21;177:6,9;181:7;
189:18
trier (2)
225:3,3
trouble (3)
165:6;223:8,13
true (25)
26:16;28:14;29:13;
30:15;92:14;133:21;
144:9;153:9,10;156:12;
159:6,19;161:18;
167:18;171:18,20;
180:13;197:10;200:20;
209:2;212:24;213:6;
220:14;230:4;233:23 | treatment (4)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | treatment (4)
157:11,15;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+| theories (3)
38:4,21;39:1 | thrown (2)
185:8;206:2 | total (1)
135:19 | trials (1)
153:18
tried (5)
15:21;177:6,9;181:7;
189:18
trier (2)
225:3,3
trouble (3)
165:6;223:8,13
true (25)
26:16;28:14;29:13;
30:15;92:14;133:21;
144:9;153:9,10;156:12;
159:6,19;161:18;
167:18;171:18,20;
180:13;197:10;200:20;
209:2;212:24;213:6;
220:14;230:4;233:23 | treatment (4)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | treatment (4)
157:11,15;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+| theory (4)
16:12,21;21:6;171:2 | till (1)
117:22 | total (1)
135:19 | trials (1)
153:18
tried (5)
15:21;177:6,9;181:7;
189:18
trier (2)
225:3,3
trouble (3)
165:6;223:8,13
true (25)
26:16;28:14;29:13;
30:15;92:14;133:21;
144:9;153:9,10;156:12;
159:6,19;161:18;
167:18;171:18,20;
180:13;197:10;200:20;
209:2;212:24;213:6;
220:14;230:4;233:23 | treatment (4)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | treatment (4)
157:11,15;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+| Therefore (2)
227:14;228:7 | times (10)
94:16;108:1,3,4,25;
120:4;155:8;168:12;
189:3;197:21 | total (1)
135:19 | trials (1)
153:18
tried (5)
15:21;177:6,9;181:7;
189:18
trier (2)
225:3,3
trouble (3)
165:6;223:8,13
true (25)
26:16;28:14;29:13;
30:15;92:14;133:21;
144:9;153:9,10;156:12;
159:6,19;161:18;
167:18;171:18,20;
180:13;197:10;200:20;
209:2;212:24;213:6;
220:14;230:4;233:23 | treatment (4)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | treatment (4)
157:11,15;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+| thinking (10)
53:12;68:15;87:14;
108:14;158:1;169:17;
170:2;188:5;191:15;
193:15 | today (44)
8:16;89:2;97:11;99:2;
104:1,5;105:2,7,16,23;
107:10,17;108:4,6,8,15,
21;110:25;112:7,19,24;
129:20;130:5;137:22;
204:22;206:17,25;
207:10;208:15;220:15;
223:19;233:2,13;234:1,
12,19,24;235:7;236:1,
17;238:22;239:9,25;
240:9 | total (1)
135:19 | trials (1)
153:18
tried (5)
15:21;177:6,9;181:7;
189:18
trier (2)
225:3,3
trouble (3)
165:6;223:8,13
true (25)
26:16;28:14;29:13;
30:15;92:14;133:21;
144:9;153:9,10;156:12;
159:6,19;161:18;
167:18;171:18,20;
180:13;197:10;200:20;
209:2;212:24;213:6;
220:14;230:4;233:23 | treatment (4)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | treatment (4)
157:11,15;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+| third (6)
96:6;140:8;156:14;
160:14;178:15;185:4 | together (7)
27:24;70:4,5,8;95:1,
10;134:12 | total (1)
135:19 | trials (1)
153:18
tried (5)
15:21;177:6,9;181:7;
189:18
trier (2)
225:3,3
trouble (3)
165:6;223:8,13
true (25)
26:16;28:14;29:13;
30:15;92:14;133:21;
144:9;153:9,10;156:12;
159:6,19;161:18;
167:18;171:18,20;
180:13;197:10;200:20;
209:2;212:24;213:6;
220:14;230:4;233:23 | treatment (4)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | treatment (4)
157:11,15;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+| though (11)
46:21;47:15;49:18;
73:2;77:18;92:9;177:6;
191:20;214:1;221:11;
240:12 | told (53)
5:3;6:6;25:6;29:15;
30:4;47:13;50:20;86:12;
93:9;105:22;113:18;
117:23;118:5,14,17;
120:21;121:15;123:16;
124:11,14;128:21; | total (1)
135:19 | trials (1)
153:18
tried (5)
15:21;177:6,9;181:7;
189:18
trier (2)
225:3,3
trouble (3)
165:6;223:8,13
true (25)
26:16;28:14;29:13;
30:15;92:14;133:21;
144:9;153:9,10;156:12;
159:6,19;161:18;
167:18;171:18,20;
180:13;197:10;200:20;
209:2;212:24;213:6;
220:14;230:4;233:23 | treatment (4)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | treatment (4)
157:11,15;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+| thought (67)
14:25;15:3,16;16:12,
14:26;4,5,10,12;27:6,10;
28:6,22;31:16;38:6,10;
41:3;43:15;44:1,2;
47:20;55:1;56:13;59:3,
3;70:9,11,21;71:3,5,11,
16,25,25;79:22;86:16,
17,24;87:7,13;88:13,19;
90:20;91:16;92:11;93:1;
114:7;115:8;131:12;
151:20;152:23;160:20;
170:4,24;173:4;185:8;
189:10;191:17;202:2;
203:11;209:4;226:23; | together (7)
27:24;70:4,5,8;95:1,
10;134:12 | total (1)
135:19 | trials (1)
153:18
tried (5)
15:21;177:6,9;181:7;
189:18
trier (2)
225:3,3
trouble (3)
165:6;223:8,13
true (25)
26:16;28:14;29:13;
30:15;92:14;133:21;
144:9;153:9,10;156:12;
159:6,19;161:18;
167:18;171:18,20;
180:13;197:10;200:20;
209:2;212:24;213:6;
220:14;230:4;233:23 | treatment (4)
85:23
trend (1)
166:25
trial (103)
8:21,22,24;9:4,10,20;
12:21;14:14;16:25;
20:13;21:3;34:17,18,20;
35:3,20;36:17;38:19;
39:20;40:17;42:10;43:4,
5,8;46:4,12;48:24;
52:13;63:8,13;64:9,17,
19;65:13;67:17;70:4;
72:10,24,25;74:19,24;
75:3,8;79:16,20;80:6,7,
8,14,16,18,21;81:1;
83:19;85:24;92:1,6,10;
94:20,24;95:6,17;99:23,
24;100:5;102:6;103:11;
106:8,9,11;112:20;
114:19;116:15;137:7;
139:16;141:2;159:5;
165:21,23;166:1,14,16;
168:14;172:15;187:7;
192:14;193:20;200:7;
214:22;215:15;216:21,
22;217:22;222:14;
223:23;224:3,6,7;
225:19;226:24;227:6;
234:14;236:23 | treatment (4)
157:11,15;158:23;
159:1,2;160:10,13;
167:3;172:3;175:17;
185:9;212:12;224:23;
225:20;226:8,10,12,14,
14,15,19;227:9;239:7 |
+
+| 71:16,21;72:4;80:17;81:21;86:25;87:4;91:23;93:2,2;94:5;95:4;117:17;121:7;129:8;131:4;136:2;140:5;145:25;147:19;150:5,7,10,23;151:20;155:10,14,17,20;158:6,15;160:9;165:16;182:8;184:5;191:9,21;199:6,15;207:21;208:4,6;224:2,9 | 42:7
undestroy (1)
231:10
unemployed (3)
153:25;207:6;232:17
Unfair (1)
233:6
unfortunately (2)
67:7;73:25
unit (1)
6:25
United (11)
4:4,4;8:21;102:6,10;103:8;105:4,6;116:11;118:9;148:17
Unity (4)
52:11,14;62:12,17
University (6)
37:23;106:3,6;112:23;113:8,21
unlawful (1)
189:16
unless (2)
43:20;239:5
unnecessarily (1)
60:17
unpleasant (4)
207:14,18;208:3;235:8
unprecedented (1)
94:11
unsealed (1)
98:6
unsuitable (1)
141:12
untruthful (1)
136:11
untruths (1)
169:21
unusual (2)
119:18;202:5
unwritten (1)
68:1
up (51)
6:21;7:1;11:12;15:11;21:6;23:24;30:19;31:2;39:4;42:23;44:19;59:23;60:13;61:6,7,13;64:11,12;65:1;79:18;92:14;93:14,16;112:7;115:1;120:10,11;124:5;129:20;143:3;146:1;147:4;155:1;185:23;187:6,6,19,21;195:21;198:20,22,24;211:16,21;212:25;213:6,11;229:7;235:1;236:7;238:15
upon (7)
5:19;50:1;96:17;102:4,7;117:16;187:1
urged (1)
5:13
use (17) | 16:1;18:15;24:7;53:24;100:23;102:20,24;180:12;193:9,9;197:7;202:23;229:25;233:11,12,22;234:1
used (4)
15:25;18:6,10;19:7
useful (1)
28:17
uses (1)
193:13
using (5)
14:21;21:7;31:18;45:3;230:1
Usually (4)
9:13;35:23;197:14;230:9 | 37:10,15
vicarious (5)
37:15,21;38:21;42:25;60:12
videotape (1)
182:16
view (10)
70:16,18;100:4;102:18;122:7;170:19;210:15,22;219:16;235:7
viewed (1)
213:23
views (1)
70:1
Village (5)
144:12,13;145:13;151:24;172:1
Vincent's (1)
180:9
vindicate (1)
192:1
vindication (2)
191:24,25
violated (1)
184:12
violation (1)
189:13
violations (1)
181:8
Viviann (7)
11:20;12:3,13;14:4;26:22;27:12,13
Vivien (1)
40:1
vodka (1)
109:13
VOICE (5)
99:13;129:14,14,16,19
voir (126)
11:12,13,16,17,22,23;12:12,19;13:2,13;14:17,19;16:24;17:23;18:6,11,16;19:8;20:13,14,15,23,25;21:5,7,21;22:4,18;23:10,12,14,15;24:17,20;25:9;28:1,5,9,23;29:2,15,18,21;30:1,5,7,10,18;32:15;33:5;34:2,3;35:3;38:16;42:18;43:2,9,16,19;44:2,9;47:13;49:22,24;50:18,20;59:4;60:4;64:20;69:4,8,17;70:22;71:13,19,24;72:20;83:4;86:15;89:5,12;92:10;94:6;96:14;102:2;103:14;140:10,11,13,21;141:3,8;143:1;147:3,5,7,15;149:13;159:25;161:22;162:23;165:25;167:17;171:16;185:3;191:1;192:17;203:20;207:16;216:21;222:8;226:16; | 227:13,22;228:1,2,13,21;229:1;230:2;232:16;234:14,17,19;236:18;237:12
vote (1)
200:15
voted (3)
212:8;220:1,3 |
+|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| W | | | | |
+| | | waited (2)
67:11;222:18
waiting (1)
238:16
waive (1)
72:23
waiver (2)
7:4;239:2
wake (1)
155:1
walk (1)
118:1
walked (4)
59:4;67:5;70:4;146:2
██████████ (1)
100:1
walking (4)
58:7;70:3,5,8
wants (3)
123:9;166:15;239:21
warrant (22)
5:6,21;6:11,18,20;89:17;94:17;186:17,18,20;187:2,6,7,10,16,21,22,25;210:14;237:23;238:1,3
██████████ (1)
177:18
wasted (1)
118:1
Water (3)
120:25;121:1,3
way (46)
7:13;16:9;19:16;38:19;50:7,7;58:10,17;60:1;61:17;69:4;70:6,7,18;75:6;80:13;85:18;93:15;98:11;116:8;128:3;155:14;160:23;161:2;166:4;167:20;170:12;181:22;191:22;195:4;197:6;201:7;205:3,8,17,19,19,21,21,24,24;206:2;207:23;212:21;216:7;219:1
weapons (1)
189:16
wearing (1)
31:24
website (1)
10:20
week (1) | | |
+| U | U | U | | |
+| ulterior (1)
154:12
ultimately (2)
63:7;214:2
unanswerable (1)
152:19
unaware (1)
114:18
unbiased (15)
128:11;148:7;149:6;153:21;154:2,3;159:6;160:22;192:8,12;206:3;209:7;226:11;229:13;236:22
uncommon (3)
119:10;121:17,22
unconvincing (1)
219:18
under (23)
23:4;51:16,19,21;52:10;54:10;66:13;73:17;105:1,15;106:14;112:7;116:10;128:17;143:14;156:2;174:15;176:16;181:6;182:25;196:20;215:6;220:9
undergraduate (1)
113:15
underlying (5)
78:1;98:19;124:4,6;214:21
Underneath (1)
52:7
understood (21)
13:15;37:19,20;41:18,24;44:8;56:11;77:16;78:2;81:20;94:12;117:19,22;125:24;126:5;130:18;141:8;188:7,22,24;189:1
undertaken (1)
203:6
undertakes (1) | unlawful (1)
189:16
unless (2)
43:20;239:5
unnecessarily (1)
60:17
unpleasant (4)
207:14,18;208:3;235:8
unprecedented (1)
94:11
unsealed (1)
98:6
unsuitable (1)
141:12
untruthful (1)
136:11
untruths (1)
169:21
unusual (2)
119:18;202:5
unwritten (1)
68:1
up (51)
6:21;7:1;11:12;15:11;21:6;23:24;30:19;31:2;39:4;42:23;44:19;59:23;60:13;61:6,7,13;64:11,12;65:1;79:18;92:14;93:14,16;112:7;115:1;120:10,11;124:5;129:20;143:3;146:1;147:4;155:1;185:23;187:6,6,19,21;195:21;198:20,22,24;211:16,21;212:25;213:6,11;229:7;235:1;236:7;238:15
upon (7)
5:19;50:1;96:17;102:4,7;117:16;187:1
urged (1)
5:13
use (17) | vacate (1)
238:2
vacation (5)
67:2,3,4,7,12
vague (1)
69:3
Vaguely (3)
119:8;189:14;222:5
validated (1)
46:13
variations (1)
120:15
variety (1)
191:5
various (2)
100:4;160:1
vendetta (2)
212:1,4
Veneer (1)
140:19
venire (2)
140:17;182:17
verdict (40)
24:21;57:16;68:10;73:19,23;83:21;87:21;88:5,8,18;95:13;124:6;128:15;132:16;133:12;134:6;137:9;148:7;149:4;154:11;159:6,6;169:16;192:12;194:1,13,14,21;205:6;213:16;217:21;218:12;219:21;220:15;222:21;225:22;226:11;227:11,18;237:8
version (2)
47:1;48:22
versions (1)
37:18
versus (2)
13:10,11
via (2)
14:13;39:6
VIC (2) | vindicate (1)
192:1
vindication (2)
191:24,25
violated (1)
184:12
violation (1)
189:13
violations (1)
181:8
Viviann (7)
11:20;12:3,13;14:4;26:22;27:12,13
Vivien (1)
40:1
vodka (1)
109:13
VOICE (5)
99:13;129:14,14,16,19
voir (126)
11:12,13,16,17,22,23;12:12,19;13:2,13;14:17,19;16:24;17:23;18:6,11,16;19:8;20:13,14,15,23,25;21:5,7,21;22:4,18;23:10,12,14,15;24:17,20;25:9;28:1,5,9,23;29:2,15,18,21;30:1,5,7,10,18;32:15;33:5;34:2,3;35:3;38:16;42:18;43:2,9,16,19;44:2,9;47:13;49:22,24;50:18,20;59:4;60:4;64:20;69:4,8,17;70:22;71:13,19,24;72:20;83:4;86:15;89:5,12;92:10;94:6;96:14;102:2;103:14;140:10,11,13,21;141:3,8;143:1;147:3,5,7,15;149:13;159:25;161:22;162:23;165:25;167:17;171:16;185:3;191:1;192:17;203:20;207:16;216:21;222:8;226:16; | waited (2)
67:11;222:18
waiting (1)
238:16
waive (1)
72:23
waiver (2)
7:4;239:2
wake (1)
155:1
walk (1)
118:1
walked (4)
59:4;67:5;70:4;146:2
██████████ (1)
100:1
walking (4)
58:7;70:3,5,8
wants (3)
123:9;166:15;239:21
warrant (22)
5:6,21;6:11,18,20;89:17;94:17;186:17,18,20;187:2,6,7,10,16,21,22,25;210:14;237:23;238:1,3
██████████ (1)
177:18
wasted (1)
118:1
Water (3)
120:25;121:1,3
way (46)
7:13;16:9;19:16;38:19;50:7,7;58:10,17;60:1;61:17;69:4;70:6,7,18;75:6;80:13;85:18;93:15;98:11;116:8;128:3;155:14;160:23;161:2;166:4;167:20;170:12;181:22;191:22;195:4;197:6;201:7;205:3,8,17,19,19,21,21,24,24;206:2;207:23;212:21;216:7;219:1
weapons (1)
189:16
wearing (1)
31:24
website (1)
10:20
week (1) |
+
+UNITED STATES OF AMERICA, v
+PAUL M. DAUGERDAS, ET AL.,
+
+| 230:21 | 99:8;108:17;204:8 | 110:5 | | |
+|-------------------------|--------------------------|--------------------------|---|--|
+| weeks (3) | wished (2) | worrying (1) | | |
+| 60:16;67:3,3 | 6:8;195:6 | 194:23 | | |
+| weigh (1) | withholding (1) | worst (1) | | |
+| 216:13 | 43:10 | 16:14 | | |
+| weighing (1) | within (1) | worth (2) | | |
+| 216:4 | 5:10 | 129:15;232:1 | | |
+| weird (3) | without (5) | worthwhile (3) | | |
+| 35:7;161:6,7 | 127:12;140:23; | 154:7,10;192:2 | | |
+| Weiss (2) | 194:23;213:21;214:8 | wow (2) | | |
+| 238:10;239:15 | witness (40) | 168:5;170:2 | | |
+| welcomed (1) | 4:23;7:6,24;8:3,7; | write (9) | | |
+| 195:9 | 59:12;82:4;96:15,25; | 23:7;27:9,15,19; | | |
+| weren't (13) | 97:1;98:24;101:1,3,5,17, | 46:18;57:5;178:6; | | |
+| 15:5;28:21;49:23; | 21:118:8;152:18; | 193:23,25 | | |
+| 60:25;93:25;95:12; | 161:10;169:23;175:4; | writes (2) | | |
+| 123:13;156:6;181:18; | 177:20;191:5;193:1; | 41:9;45:9 | | |
+| 191:15;194:16;214:21; | 200:10,17;219:17,22; | writing (1) | | |
+| 231:6 | 221:11;236:21;237:17, | 205:8 | | |
+| Westchester (10) | 24;238:5,7,8,8;239:6,14, | written (4) | | |
+| 144:12,15;145:12,18, | 22;240:4 | 47:2;138:17;139:6; | | |
+| 21;146:5,23;148:5; | witness' (1) | 223:12 | | |
+| 151:17;180:5 | 122:7 | wrong (12) | | |
+| Westlaw (56) | witnessed (2) | 23:8;27:12,14;45:14; | | |
+| 45:5,10,12;46:5,7,8, | 123:10,11 | 56:12;94:7;131:14; | | |
+| 10,16,21;48:11;49:5,7; | witnesses (8) | 145:15;168:5,6,7;237:2 | | |
+| 50:2,3,6,24;51:8;53:21; | 7:3,10;159:2,11,15; | wrongdoing (1) | | |
+| 54:8,13,15,18,20,24; | 169:20;192:16;219:10 | 59:12 | | |
+| 55:1,14,23;56:5,9,13; | WITS (1) | wrote (24) | | |
+| 59:20;61:24;62:2,3,20; | 37:11 | 22:18;41:22,23,23; | | |
+| 63:24;70:17,24;71:1,5, | woke (3) | 43:19;44:1,5;47:4; | | |
+| 22;80:12,15;82:18;83:1, | 42:23;146:1;147:4 | 55:16;62:3,5;90:22; | | |
+| 5,16;87:1;91:13,16,20; | woman (3) | 178:8;193:20;194:1,10; | | |
+| 92:18,21,23;93:2,8 | 46:11;49:11;58:25 | 195:1,5,17,18,25;196:5, | | |
+| what's (5) | wonder (1) | 14,17 | | |
+| 10:10;34:4;41:17; | 53:16 | | | |
+| 112:19;114:25 | word (15) | | Y | |
+| whereby (1) | 57:10;90:23;91:8; | | | |
+| 68:2 | 120:14;149:7,8;188:7; | year (15) | | |
+| whittled (1) | 202:10,12,23;206:22; | 9:4;12:4,5,7,9;48:15, | | |
+| 29:2 | 217:1;219:18;229:25; | 15:49;9,10,12;135:6,19; | | |
+| whole (18) | 230:1 | 191:1;207:4;230:7 | | |
+| 35:3;59:10;87:6;92:5; | word-for-word (1) | years (29) | | |
+| 103:15,23;157:24;158:3, | 217:16 | 47:8;49:3;93:15; | | |
+| 4,9;159:19,23;160:6; | words (12) | 94:18;113:8;121:7; | | |
+| 172:5;182:17;191:3; | 105:18;116:8;129:15; | 136:2;147:19;153:19; | | |
+| 206:16;226:14 | 176:10;198:3;208:19, | 156:1,12;157:6,8; | | |
+| who's (2) | 23;209:1;210:10;213:2; | 158:12;162:17,17,25; | | |
+| 58:25;69:7 | 215:17;229:4 | 163:7;177:7;178:21; | | |
+| whose (4) | work (13) | 179:1,3;180:25,25; | | |
+| 10:21;61:4,19;135:1 | 9:9,10,14;42:6;44:15; | 189:20;190:5,6;207:5,8 | | |
+| wife (1) | 72:15,16;130:10; | years' (1) | | |
+| 164:19 | 164:18;190:22;221:15; | 33:1 | | |
+| (2) | 222:10;238:19 | yesterday (3) | | |
+| 208:1;210:18 | worked (11) | 7:5;70:9;145:10 | | |
+| willfully (1) | 9:2;13:15;23:16;26:2; | York (17) | | |
+| 214:3 | 30:9,11,15,19,24;32:1,3 | 9:20;23:2,11,25; | | |
+| willing (1) | working (4) | 27:23;45:24;51:19; | | |
+| 173:5 | 14:19;32:24;33:3; | 54:11;55:57;71:2;151:11; | | |
+| Winslow (4) | 221:9 | 157:4;179:17;196:9; | | |
+| 185:14,17,19;215:12 | world (1) | 203:17,20;221:6 | | |
+| wish (6) | 175:5 | younger (2) | | |
+| 81:10;97:5;98:18; | worn (1) | 49:10,12 | | |
+
+C2GFDAU1 Hearing
+
+I UNITED STATES DISTRICT COURT 1 SOUTHERN DISTRICT OF NEW YORK
+
+2 2
+
+3 UNITED STATES OF AMERICA,
+
+3
+
+4 v. 09 Cr. 581 (WHP)
+
+4
+
+S PAUL M. DAUGERDAS, DONNA M. Hearing re
+
+5 GUERIN, DENIS M. FIELD, Catherine M. Conrad
+
+6 DAVID K. PARSE,
+
+6
+
+7 Defendants.
+
+7 8 8
+
+9 New York, N.Y. 9 February 16, 2012 10 9:45 a.m.
+
+10
+
+11 Before:
+
+11
+
+12 HON. WILLIAM. H. PAULEY III
+
+12
+
+13 District Judge
+
+13 14
+
+14 APPEARANCES
+
+15 15
+
+16 PREET BHARARA
+
+16 United States Attorney for the 17 Southern District of New York
+
+17 BY: STANLEY J. OKULA, ESQ.
+
+18 NANETTE , ESQ.
+
+18 JASON , ESQ.
+
+19 Assistant United States Attorneys
+
+19 20
+
+20 JENNER 6 BLOCK LLP
+
+21 Attorneys for Defendant Daugerdas
+
+21 BY: CHRIS C. GATR, ESQ.
+
+22 CHARLES B. SKLARSKY, ESQ.
+
+22 NICOLE
+
+23 23
+
+24 STETLER DUFFY 6 ROTERT, LTD.
+
+24 Attorneys for Defendant Guerin
+
+25 BY: MARK L. ROTERT, ESQ.
+
+25
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+- 1
+- 2
+- 3
+- 4
+- 5
+- 6
+- 7
+- 8
+- 9
+- 10
+- 11
+- 12
+- 13
+- 14
+- 15
+- 16
+- 17
+- 18
+- 19
+- 20
+- 21
+- 22
+- 23
+- 24
+- 25
+
+C2GFDAU1
+
+Hearing
+
+243
+
+244
+
+C2GFDAU1 Hearing
+
+1 APPEARANCES (Cont'd)
+
+1
+
+2
+
+3
+
+KOSTELANETZ & FINK, LLP
+Attorneys for Defendant Field
+BY: CAROLINE RULE, ESQ.
+SHARON McCARTHY, ESQ.
+
+4
+
+5
+
+PAUL SHECHTMAN
+
+6
+
+ADAM [REDACTED]
+Attorneys for Defendant Parse
+
+7
+
+8
+
+BOBBI C. STERNHEIM, ESQ.
+Attorney for Ms. Conrad
+
+9
+
+10
+
+Also Present: Christine Mazzella,
+Special Agent - IRS
+
+11
+
+12
+
+13
+
+14
+
+15
+
+16
+
+17
+
+18
+
+19
+
+20
+
+21
+
+22
+
+23
+
+24
+
+25
+
+C2GFDAUI Hearing
+
+1 THE DEPUTY CLERK: Continued case of United States of 2 America v. Paul Daugerdas.
+
+3 THE COURT: Are you ready to call your next witness? 4 MR. GAIR: Your Honor, the government and the defense S have reached a stipulation that would supplant the necessity 6 for Deputy Weiss to testify. We simply agreed that Deputy 7 Weiss would testify consistently with his report which is 8 marked as PMD Exhibit 4, which we would now move into evidence.
+
+9 M.R. °KULA: No objection, your Honor, and we can 10 confirm on behalf of the government that we have reached that 11 stipulation with Mr. Gair.
+
+12 THE. COURT: Very well, then. PMD Exhibit 4 is
+
+13 received in evidence. 14 MR. GAIR: There was one other document I forgot to 15 put in yesterday, the Winslow police records, PMD 27. I would 16 move their admission.
+
+17 THE COURT: Any objection?
+
+18 MR. OKULA: No, your Honor. 19 THE COURT: All right, PMD 27 is received in evidence. 20 (Exhibits PMD 4 and PMD 27 received in evidence)
+
+21 MR. GAIR: The defense rests.
+
+22 THE COURT: Is the government ready to proceed? 23 : We arc, your Honor. The government calls
+
+24 Susan Brune.
+
+25 SUSAN BRUNE,
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+C2GFDAU1 Hearing
+
+1 called as a witness by the Government, 2 having been duly sworn, testified as follows: 3 THE COURT: Take a seat, state your full name and 4 spell your last name slowly for the court reporter. 5 THE WITNESS: My name is Susan Elizabeth Brune. My 6 last name is spelled B-r-u-r.-e.
+
+7 THE COURT: You
+
+: Thank you, your Honor.
+
+9 DIRECT EXAMINATION
+
+10 BY •
+
+11 Q. Good morning Ms. Brune.
+
+12 A. Good morning.
+
+13 Q. Are you represented by counsel for purposes of this 14 hearing?
+
+15 A. No.
+
+16 Q. You went. to Harvard Law School, correct?
+
+17 A. Correct.
+
+18 Q. Graduating in 1988?
+
+19 A. That's right.
+
+20 Q. So you've been a practicing lawyer for almost 25 years, is 21 that right?
+
+22 A. That's right.
+
+23 Q. And you're a member of the New York Bar?
+
+24 A. I am.
+
+25 Q. And you were an. Assistant United States Attorney for SOUTHERN DISTRICT REPORTERS, P.C.
+
+247
+
+C2GFDAU1 Brune - direct
+
+1 approximately seven years, correct?
+
+2 A. That's correct, too.
+
+3 Q. And that was here in the Southern District of New York?
+
+4 A. Yes.
+
+5 Q. And you handled many [REDACTED] collar cases while you were an
+6 assistant?
+
+7 A. Yes.
+
+8 Q. And then you left the United States Attorney's Office and
+9 you started your own firm, is that correct?
+
+10 A. That's right.
+
+11 Q. And did you immediately jump to your own firm out of the
+12 United States Attorney's Office?
+
+13 A. I -- yes.
+
+14 Q. And that was approximately 1998, correct?
+
+15 A. I left the United States Attorney's Office around November
+16 of 1997 and we started the firm February 2nd of 1998.
+
+17 Q. The law firm is Brune & Richard, correct?
+
+18 A. That's correct.
+
+19 Q. And you are the Brune in Brune Richard?
+
+20 A. I am indeed.
+
+21 Q. And Richard is Hillary Richard, correct?
+
+22 A. Yes.
+
+23 Q. She's primarily a civil lawyer, do I have that right?
+
+24 A. Yes. She's done criminal cases, but she's primarily a
+25 civil lawyer.
+
+1 O. Do I understand correctly that she generally was not 2 involved in the litigation of this matter on trial? 3 A. She helps out. She helped me certainly with the closing 4 statement, but you're right, she was not on the trial team. 5 Q. She generally did not appear at court appearances, though, 6 is that correct? 7 A. That's correct. 8 Q. And you've had many trials, both in your government 9 experience and your experience as private counsel, correct? 10 A. You know, I've had three trials as a defense lawyer. So I 11 don't know if that would qualify as many. But I certainly have 12 handled quite a few between work in the government and work on 13 the defense. 14 O. And I take it that when you were an assistant you also 15 conducted many Grand Jury investigations, correct? 16 A. Many. 17 Q. And you know that an important part of any Grand Jury 18 investigation are the details, correct? 19 A. That's certainly so. 20 Q. And you know how to pay attention to details, is that 21 correct? 22 A. I try very hard to pay attention to detail. 23 Q. And I take it that you would agree that you were vested in 24 the success of you law firm, correct? 25 A. I am very vested, very proud of it.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Q. And part of the success of your law firm lies in the 2 success that you have in any particular case, correct? 3 A. I think that that's certainly part of what I hope is the 4 success of our firm, yes. 5 Q. Well, am I correct in assuming that in your view the more 6 cases that you win the more likely you might\_ get additional 7 clients, correct? 8 A. That's certainly so, yes. 9 Q. And your website, you have a website for Brune 6 Richard, 10 correct? 11 A. Right. 12 Q. And it has a biography for you? 13 A. Yes. 14 Q. And it touts your ability to make sound strategic choices, 15 is that correct? 16 A. I don't know if "tout" is the word I would use, but I 17 certainly describe myself in favorable terms on my own website, 18 correct. 19 Q. Well, it certainly talks about your ability to make sound 20 strategic choices, correct? 21 A. I don't remember exactly, but I certainly do think of 22 myself as a person who makes sound strategic choices. 23 Q. And your website biography also emphasizes your meticulous 24 preparation and forceful advocacy, correct? 25 A. That part I recall, it does. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+- 1 Q. And making strategic choices is a major part of 2 representing any client, correct? 3 A. That's right. 4 Q. And that was a major part of representing David Parse in 5 this case? 6 A. Certainly.
+- Q. And you didn't necessarily clear every decision that you 8 made with Mr. Parse, correct? 9 A. That's right. 10 Q. And he in fact trusted you to make decisions on his behalf 11 as his lawyer, correct? 12 A. Yes. 13 Q. And that was true of the other attorneys in your firm who 14 worked on this case, correct? 15 A. I'm sorry, what was true? 16 Q. That Mr. Parse trusted not only you but the people in your 17 employ, correct? 18 A. I believe so. We had a very good working relationship. 19 Q. Now, you're not afraid, are you, to raise issues with a 20 Court about any issues that might come up with regard to your 21 clients, correct? 22 A. Well, I'm certainly not afraid to speak to the Court if 23 that's what you're asking. 24 Q. You raised many issues with the Court, with this Court 25 before trial, correct?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. II, I did indeed, yes, understood. 2 Q. And during trial? 3 A. Yes. 4 Q. And you don't hesitate to do that if it helps your client, 5 correct? 6 A. Certainly not. 7 Q. And you're not afraid of being aggressive on behalf of your 8 client, correct? 9 A. That's correct. 10 Q. That's what you mean in part when you use the phrase 11 "forceful advocacy" on your website, correct? 12 A. Yes. It's important to be aggressive but not too 13 aggressive. You want to be a forceful advocate. 14 Q. And many times you and the other defense counsel in this 15 case raised issues with the Court about which you had less than 16 a hundred percent certainty, correct? 17 A. I disagree. 18 Q. Is it your testimony here that with regard to every issue, 19 every question that you raised with the Court you knew with a 20 hundred percent certainty what the underlying facts were? 21 A. No, that's not what I'm saying. What I am saying is that 22 if I made a representation to the Court I tried very hard to 23 make it accurate and I did not raise issues with the Court if I 24 didn't think that they had merit. 25 Q. Now, with regard to David Parse, you represented him for a SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 long time prior Lo the start of the criminal case, correct? 2 A. I have represented him since 2004. 3 Q. And you've gotten close to him as a person, correct? 4 A. Yes. 5 Q. And you wanted to obtain an acquittal for him on a 6 professional level, is that right? 7 A. Both on a personal and professional level. B Q. And on a personal level because you like and care about him 9 as a person, correct? 10 A. And I believe in his innocence. 11 Q. But you like and care about him as a person? 12 A. I do. 13 Q. Now, with regard to the hierarchy of Brune s Richard, as 14 the named partners I would take it that you and Ms. Richard are 15 basically at the top of the heap there? 16 A. Well, we try to treat everyone with respect, but you're 17 right, it's our firm in the sense that we're the named partners 18 and we're certainly at the top of the hierarchy. 19 Q. And everyone answers to you on your particular cases who 20 work for you, correct? 21 A. That's typically the way it's structured. 22 Q. And you are the ultimate decision maker? 23 A. Not. on every case, but on those where I'm the lead counsel 24 working, yes. 25 Q. And that was true of this case, correct? SOUTHERN DISTRICT REPORTERS, P.C. (2121 805-0300
+
+1 A. That's right. 2 Q. And everyone at your firm knew and understood that, 3 correct? 4 A. Sure. 5 Q. Now, Ms. Trzaskoma is a partner at your firm, correct? 6 A. Yes, she is. 7 Q. And one of her responsibilities with regard to this 8 particular case was jury selection details, correct? 9 A. That's right. 10 Q. And you entrusted her with that task, correct? 11 A. Well, yes and no. I'm ultimately responsible and I was 12 responsible at trial for jury selection, but you're correct 13 that she was much more immersed in the details and in the 14 effort. 15 Q. One of the things that your team did was to gather 16 information about potential jurors? 17 A. Yes. 18 Q. And Ms. Trzaskoma was supervising other people within the 19 firm about gathering information? 20 A. Well, it was a combination. There were two lawyers from 21 San Francisco who were doing a lot of the work, but then 22 ultimately it was Theresa who was going to be responsible for 23 the courtroom work. 24 Q. And you were supervising her in that regard, correct? 25 A. That's right.
+
+1 Q. And she communicated to you about the issues that came up 2 during jury selection? 3 A. She did. 4 Q. Now, Ms. Edelstein was also a partner who was part of the 5 team of this case, correct? 6 A. Yes. 7 Q. She's in San Francisco, is that right? Or, well, 8 theoretically she lived in San Francisco? 9 A. She moved to New York for the trial, but in general she 10 works in the San Francisco office. 11 O. And you assembled a large team to assist you on this case, 12 correct? 13 A. We did. 14 Q. That would include Adam Hollander? 15 A. That's right. 16 Q. At that time he was an associate in your New York office? 17 A. Yes. 18 Q. And Randy III I think you referenced a partner in San 19 Francisco? 20 A. Yes. 21 Q. And Vivienne Stapp? 22 A. Yes, Vivienne Stapp. 23 Q. She's an associate in the San Francisco office? 24 A. That's correct. 25 Q. And Kendra Melrose?
+
+1 A. That's right. 2 Q. You also had paralegals working on the case? 3 A. We did. 4 Q. Let me ask you, did I cover all the attorneys assigned to 5 work on the Parse matter? 6 A. Melissa Desori, who I think at the time was an associate 7 also worked with Ms. Edelstein on the legal issues. I believe 8 David Elbaum worked briefly on the expert testimony issues that 9 came up with Dr. DeRosa and I think others may have pitched in 10 over the many years when we worked on the matter, but I think 11 you've gotten the core team. 12 Q. And then you had non-attorney personnel as well, correct? 13 Paralegals? 14 A. Paralegals, yes. 15 Q. David Benhamou? 16 A. Yes. 17 Q. Tell me, who is Brendan Henry? 18 A. There's a paralegal named Brendan in our office and I 19 assume this is Brendan. Henry, but as I sit here, I can't recall 20 Brendan's last name. 21 Q. And who is Jenson 7 22 A. Jenson is a paralegal in our office. 23 Q. Ariel Stoddard? 24 A. The same. 25 Q. Nancy II?
+
+1 A. Nancy is a paralegal from the San Francisco office. 2 Q. You also had someone with the title of managing clerk, is 3 that correct? 4 A. Correct. 5 Q. What does the managing clerk do for your office? 6 A. He is, he works primarily on the civil side, and is 7 responsible for making sure that our filings go in properly. 8 He also does sort of the last cite check on any brief that goes 9 in, and he just helps out in any way on to sort of make sure 10 things get to court and get filed properly. 11 Q. What's his name? 12 A. Ken. Renta. 13 Q. And you also, I take it, have secretaries and other 14 administrative staff at your firm, correct? 15 A. We have one secretary at the firm. 16 Q. And with regard to this specific case, you also hired 17 outside help, is that correct? 18 A. Can you explain? By "help," do you mean were there 19 contract lawyers or some other kind of help you're thinking of? 20 Q. Let's talk about the jury consultants. 21 A. Okay. 22 Q. Did you specifically hire a jury consultant for this case? 23 A. I hired Dennis Donahue. 24 Q. And Mr. Donahue was present during voir dire, correct? 25 A. He was.
+
+1 Q. And provided assistance to you up to the point of voir 2 dire, correct? 3 A. He -- 4 Q. Prior to trial? S A. He provided assistance through voir dire, correct. 6 Q. And there was also Julie Blackman who was hired by Kramer 7 Levin, correct? 8 A. Correct. 9 Q. You all were working somewhat collaboratively at least with 10 Kramer Levin? 11 A. That's right. 12 Q. And tell me about your hiring of the Nardello firm? 13 A. That was something that was done together with the Kramer 14 Levin firm. Mr. Nardello, as you may know, was an Assistant 15 United States Attorney and is now a private investigator. 16 Q. And his motto, at least according to his website, is "We 17 find out." Do you recall that? 18 A. I have to say it's been a while since I've looked at his 19 site, but that sounds like an accurate description of what he 20 strives to do. 21 Q. Although he is obviously a lawyer having been an assistant, 22 he specializes now investigative work, is that correct? 23 A. That's my understanding of what he does. 24 Q. And you all -- I'll use that south of the Mason line 25 term for you and the Kramer Levin firm -- hired him to do SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 research about the jurors in this case, is that correct, 2 potential jurors? 3 A. That was one of the things that he did for us. And to be 4 clear, when I say research, what I'm talking about is accessing 5 computer databases concerning the jurors. There was a 6 relatively short period to accomplish that, and so a 7 combination of the paralegal team and the Nardello firm 8 accomplished that. 9 Q. And are you distinguishing that from, say, out in the field 10 work, going to visit people, talking to them? 11 A. Yes. His specific instructions were that no one should 12 leave his office, that it was to be simply database research. 13 Q. And were those your instructions? 14 A. Those were my instructions, although I think Mr. Nardello 15 is an ethical man and I don't think he would have done 16 otherwise, but I wanted to be very clear with him. 17 Q. You also had Suann Ingle of Ingle Communications work on 18 your team? 19 A. Yes. 20 Q. What was her role for your team? 21 A. Suann did graphics for the opening statement and the 22 closing statement and perhaps some for Dr. DeRosa, and in 23 addition she was in court to just sort of play the PowerPoint 24 during the opening and the closing. 25 Q. So she was one of the people along the wall, is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 A. She wasn't there every day. That was someone else we 2 shared with Kramer Levin. But when it came to the jury 3 addresses, she was there, because she was the person who made 4 the graphics. S Q. And who was that someone else that you just referenced? 6 A. I'm blacking on her name. 7 Q. tees Donna Kane ring a bell? 8 A. Yes, Donna Kane. 9 Q. She was with a firm called Decision Quest, is that right? 10 A. That's correct. 11 Q. You made sure your team had courtroom access to a-mails and 12 internet here in the courtroom, right? 13 A. I think Ms. Trzaskoma handled it, but yes, we made those 14 arrangements. 15 Q. So you had from voir dire forward access to the internet, 16 correct? 17 A. That's right. 18 Q. Your e-mails, correct? 19 A. 1 didn't have a computer and I tried very hard not to look 20 at my BlackBerry other than far from the courtroom, but those 21 on our team, I think both Lori Edelstein and Theresa Trzaskoma, 22 had laptops and access to e-mails in court. 23 Q. And you had that same access during jury deliberations? 24 A. Yes. 25 Q. And in fact your team used the internet and e-mail during, SOUTHERN DISTRICT REPORTERS, P.C. (2121 805-0300
+
+1 from voir dire all the way through the verdict, right? 2 A. Yes. 3 Q. Now, Ms. Brune, you are an officer of this court, correct? 4 A. I am. 5 Q. And as an officer of the court you have ethical 6 obligations, correct? 7 A. I do indeed. 8 Q. And you have an obligation to be truthful to the Court? 9 A. Yes. 10 O. And you have an obligation to promptly disclose to the 11 court any information that you might have suggesting juror 12 misconduct, correct? 13 A. I don't agree with your characterization. I had an ethical 14 obligation to bring whatever material that I thought was 15 accurate to the Court and that's what I tried to do throughout 16 the trial. 17 Q. On May 12, 2011, you received information, significant 18 information that related potentially to Juror No. 1, correct? 19 A. On May 12 I had a discussion with Theresa Trzaskoma in 20 which she described her sort of wondering whether the juror who 21 had sent that note referring to respondeat superior and 22 vicarious liability was the lawyer whom she'd earlier located 23 by a Google search. I don't think that I received significant 24 information, but I did have a conversation with Ms. Trzaskoma 25 about the note, which was at that point new to us. SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+261
+
+C2GFDAU1 Brune - direct
+
+1 Q. All right. Well, let's talk about the pre voir dire stage. 2 Now, your firm received the juror list from the juror clerk, 3 correct? 4 A. That's my understanding, yes. 5 Q. And your team analyzed it and other information that you 6 all had gathered at that point, correct? 7 A. I think what happened, and I wasn't as close to it as 8 others, is that we received the questionnaires together with 9 the jury list and then started kind of focusing on the 10 questionnaires. But I agree with you that we received both. 11 Q. And the Nardello firm provided to you the results of the 12 research that it was asked to do prior to the start of voir 13 dire, correct? 14 A. That's right. 15 Q. Now, you conceded in your papers that you had in your 16 possession the 2010 suspension opinion related to Catherine M. 17 Conrad prior to the start of voir dire, correct? 18 A. I certainly said that and it's so. 19 Q. And in fact, Theresa Trzaskoma told you and showed you that 20 opinion prior to the start of voir dire, correct? 21 A. I don't think it was prior to the start of voir dire, but 22 it was in the morning before court, maybe some point mid-voir 23 dire, and I don't know that she showed it to me, but we 24 certainly discussed it in the presence of Dennis Donahue, the 25 jury consultant.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Q. What were those discussions? 2 A. We didn't have really any information about Catherine 3 Conrad. And I think it was sort of not on the list to search 4 because it was sort of a common name, and Theresa explained, 5 and I can't do this verbatim because at the time this was not 6 such a huge event, but I think Theresa explained that she had 7 gotten on Googles that she had found that there was a suspended 8 lawyer with the name Catherine Conrad and we were going to be 9 doing voir dire of this Catherine Conrad that day. So we 10 talked about it with the jury consultant, and I said something 11 to the jury consultant to the effect of, wow, this is very 12 interesting and odd, because the trial is going to be about the 13 law of economic substance and virtually every defendant in the 14 case has a law degree, and so which way does that cut?
+
+15 And my best recollection is that the jury consultant 16 said you do not want this lady on your jury because a 17 recovering alcoholic tends to be all about taking and imposing 18 personal responsibility and that she'll be more focused on that 19 than on the government's burden of proof, so if this is the 20 same person you should strike her for cause and if that doesn't 21 work you should get her off with a peremptory.
+
+22 Q. Now, this opinion that your firm had in its hand had not 23 just a first name and last name but a middle initial, correct? 24 A. When you say in hand, I don't know that I ever saw the 25 thing and I certainly never saw a printout. But we certainly, SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Ms. Trzaskoma certainly accessed it on the computer, and I row 2 know that that opinion or decision includes the middle initial. 3 Q. And it was the identical name, Catherine M. Conrad, that 4 appeared on the potential juror list that the clerk's office 5 provided, correct? 6 A. I now know that to be so. 7 Q. Well, and that opinion was not just any suspension opinion, 8 it was a New York court opinion, correct? 9 A. That's right. 10 Q. And you could have asked your team prior to the start of 11 voir dire to do additional research on this issue, correct? 12 A. I certainly could have. 13 Q. And you chose not to? 14 A. I don't think I put it that way. The plan was to hear from 15 her on voir dire and find out based on her answers to Judge 16 Pauley whether she was the same person. 17 Q. Well, you didn't do it, correct, Ms. Brune? 18 A. If the question is -- 19 Q. It's a simple question. 20 A. I know, and I'm trying really hard to answer it. 21 Q. It's really a yes or no. Did you or did you not ask any of 22 your team prior to voir dire to do additional research? 23 A. II, I did not. That's absolutely so. 24 Q. You had everybody, you had a team of literally almost two 25 dozen people available to you, correct? SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. Well, not necessarily all at once, but we certainly had 2 resources and I certainly did not ask that more be done 3 awaiting the answers from the prospective juror on voir dire. 4 Q. And you could have told the Court at that point, correct? 5 A. I certainly could have said to the Court that there is a 6 Google search out there that reveals that there's a suspended 7 lawyer by the name of Catherine Conrad. 8 Q. And you didn't do that? 9 A. I did not do that. 10 Q. Now you appreciated, it sounds to me just from what you 11 said, pretty instantly, that this is potentially significant 12 information, correct? 13 A. If it's the same person, it's very significant information. 14 I certainly appreciated that. 15 Q. No one -- you didn't require anyone to have to explain that 16 to you, correct? 17 A. No. I mean, we had a lot of Google-type information on a 18 lot of jurors and, you know, it's a big metropolitan area. 19 Some of that -- 20 Q. Ms. Brune, I asked you a very specific question. 21 A. Can -- 22 Q. You did not require anybody else to explain to you the 23 significance of that information. Is that true? 24 A. If that's your question, the answer is no, I did not ask 25 anyone to do any further research.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 2 Q. And you didn't -- that is actually not answering the question I asked.
+
+3 A. I'm sorry. Do it again and I'll try to get it.
+
+4 Q. You understood this was significant information
+
+5 potentially, yes?
+
+6 MR. LAIR: Objection, asked and answered, your Honor.
+
+8 A. If it was the same person it was significant information, 9 that's correct.
+
+C2GFDAU1 Brune - direct
+
+THE COURT: Overruled.
+
+10 Q. And you didn't need anyone Co explain to you that it was 11 potentially significant information?
+
+12 A. No.
+
+13 Q. And that it would be significant to Judge Paulcy, correct?
+
+14 A. I believe that it was certainly going to be significant to 15 Judge Pauley if it was the same person.
+
+16 Q. And one way you find out if it's the same person is to ask 17 Judge Pauley to ask the potential juror, correct?
+
+18 A. No. If the person has sworn under oath that her highest
+
+19 level of education is college and has disclaimed any contact
+
+20 with any disciplinary authority, I don't think that was the
+
+21 reasonable course at all. What happened --
+
+22 Q. Let me stop you there, Ms. Brune. Are you saying --
+
+23 MR. SCHECTMAN: Judge, I'm okay with some stopping, 24 but really not in the middle of answers.
+
+25 THE COURT: Right. Did you complete your answer, SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Ms. Brune?
+
+2 THE WITNESS: I didn't, your Honor.
+
+3 THE COURT: Go ahead and complete your answer, please.
+
+4 A. We had a lot of Google-type information on a lot of
+
+5 different jurors. There were occasions where the information
+
+6 was obviously pertaining to the same person. That was tine.
+
+7 There was certainly situations where we were able to say, well,
+
+8 just not the same person and set it aside. I didn't sort of go
+
+9 to the judge each time and say, you know, Mr. there says
+
+10 that he's -- and now I'm just giving the example -- a retired
+
+11 car mechanic, but. I know there's a Mr. who has some other
+
+12 occupation. I listened to the voir dire responses and I
+
+13 credited them.
+
+14 Q. The question, though, Ms. Brune, and just so I'm clear
+
+15 about what your testimony is, are you saying that you could not
+
+16 have asked Judge Pauley to ask the question, just a very
+
+17 specific question of the juror, right then and there?
+
+18 A. I certainly understood that I could have asked Judge Pauley
+
+19 to inquire.
+
+20 Q. And you didn't do that?
+
+21 A. I did not.
+
+22 Q. And you knew you could have done that, correct?
+
+23 A. Of course.
+
+24 Q. Now, you had ways to narrow down the information that you
+
+25 had, correct?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 A. My primary method of narrowing the information was to 2 listen to the sworn testimony on voir dire. But certainly if 3 what your question is could I have launched some kind of full 4 scale private investigative effort on each member of the voir S dire or each seated juror, I did not do that. 6 Q. Did you even ask Ms. Trzaskoma what was the middle initial? 7 Because you had a middle initial, correct? 8 A. I did not ask that. question. 9 Q. That would have been one way to narrow down the 10 information, correct? 11 A. You know, when you say you had the middle initial, i'm 12 answering the firm had the middle initial. As to whether Ms. 13 Trzaskoma was focusing on the middle initial at that point, 7 14 don't know, but I did not focus on the middle initial until 15 after the juror sent her letter to the government and then 16 three weeks later the government disclosed it to us. 17 Q. Well, when you're asking -- I mean, I think you said that 18 Nardello did not search Catherine Conrad, correct? 19 A. That's so. 20 Q. You had a Catherine M. Conrad of Bronxville, that was what 21 was on the juror list, correct? 22 A. That's my understanding now. 23 Q. And in voir dire you understood going into, before it ever 24 started, what the process is all about, correct? 25 A. I did.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Q. That's based on your experience as a trial attorney, 2 correct? 3 A. I certainly understand the voir dire process. 4 Q. And I take it one of your goals of jury selection, primary 5 goal was to get jurors that you believed would be sympathetic 6 to the case that you were going to be presenting to the Jury, 7 correct? 8 A. I believed in our case and I wanted to be sure to have 9 jurors I thought would be attentive and understand the 10 arguments we were presenting, and of course you want to find 11 jurors who are more likely to be sympathetic or open minded to 12 defense themes. 13 Q. And you try to eliminate jurors you don't like for whatever 14 the reason, correct? 15 A. That's certainly right. 16 Q. And the more information that you have, I take it, the 17 better you can shape or try to shape the jury, correct? 18 A. That's the reason for the database and Google efforts that 19 I've described. 20 Q. And hiring the Nardello firm, correct? 21 A. The Nardello firm, as I explained, was for the database 22 effort, correct. 23 Q. And Dennis Donahue as well? 24 A. Yes. 25 Q. And it's why you submitted a lengthy proposed juror SOUTHERN DISTRICT REPORTERS, P.C. 1212) 805-0300
+
+1 questionnaire, correct?
+
+2 A. I did. I wanted as much information as we were able to get 3 about every prospective juror.
+
+4 Q. Now, you understood that the voir dire process would be the 5 judge asking the questions of the potential jurors, correct?
+
+6 A. I did, but I also understood that the Court would likely
+
+7 ask other questions if we proposed them.
+
+8 Q. So you understood that you could request of Judge Pauley to 9 further inquire?
+
+10 A. YeS.
+
+11 Q. And you also understood that sometimes jurors don't give a
+
+12 full picture when they're giving the answers in response to 13 voir dire questions, correct?
+
+14 A. Yes. I certainly think that it's something that's within
+
+15 the realm of possibility that a juror might. not be complete.
+
+16 Q. And it's also possible, would you agree, during voir dire,
+
+17 that you could ask the judge to inquire about a completely new
+
+18 area if it occurs to you as the questioning is going on,
+
+19 correct?
+
+20 A. Sure.
+
+21 O. And it was the Court's decision, would you agree, whether
+
+22 or not to ask any particular question.
+
+23 A. Of course.
+
+24 Q. It's not a decision that rests with you or the other
+
+25 defense counsel, correct?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. That's correct, it's Judge Pauley's courtroom. 2 Q. And other than the peremptory challenges it was not your 3 decision whether or not to seat any particular juror, correct? 4 A. He was the arbiter of the challenges for cause. 5 Q. And you and your team in fact raised questions and concerns 6 with the Court during the voir dire? 7 A. Yes, we did. 8 Q. That includes Ms. Trzaskoma raising a concern about a, or 9 an issue about a potential juror who worked at Sachs, 10 correct? 11 A. I'm sure it's so. I can't remember this as I sit here, but 12 she certainly raised questions about prospective jurors. 13 Q. And prior to the -- well, you recall, do you not, that the 14 voir dire extended over several days? 15 A. I do. 16 Q. And prior to the start of the second day of voir dire, 17 Judge Pauley solicited of counsel whether or not they had any 18 additional questions to pose to the jury pool? 19 A. I'm sure he did. I can't remember it, but he certainly was 20 open to questions proposed by defense counsel and government 21 counsel. 22 Q. And do you recall that at that point Ms. Trzaskoma 23 specifically asked the Court to ask another question of the 24 jurors, that was, did they have any negative experiences with 25 lawyers or accountants or financial advisers? SOUTHERN DISTRICT REPORTERS, P.C. (2121 805-0300
+
+1 A. I do remember that.
+
+2 Q. And at that point you could have asked Judge Pauley to 3 inquire specifically of Juror No. 1, if i could call her Juror 4 No. 1, I know the juror numbers changed, but Catherine Conrad?
+
+5 A. I know who you mean.
+
+6 Q. About the potentiality that she was a suspended attorney, 7 correct?
+
+8 A. Certainly could have asked him to do that.
+
+9 Q. You had this potentially highly pertinent piece of 10 information in your hands at that point and you did nothing
+
+11 with it with regard to what the Court was asking of the jurors. 12 A. As I think you know, we concluded it was a different person
+
+13 and therefore did not view it as the highly significant 14 information that, unfortunately, it turned out to be.
+
+15 Q. Well, you had a way, you had information in your hand that. 16 could have further illuminated this issue, correct?
+
+17 A. When you say "in your hand" I think what you mean is that
+
+18 we knew it. We did not have in our hands a printout. But
+
+19 certainly we had the discussion that. I've described and Ms.
+
+20 Trzaskoma had done the Google search that we've talked about.
+
+21 Q. And that Google search resulted in her finding a document, 22 correct?
+
+23 A. That's my understanding, yes.
+
+24 Q. And even if she didn't have a printout of it in court, she
+
+25 had it on the computer that she had sitting in front of her, SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 correct?
+
+2 A. I don't know about that. I know that we had it or she had 3 it or had read it on the computer that morning in the office.
+
+4 My recollection is that we were kind of laptops down during
+
+5 jury selection.
+
+6 Q. Did you have access to a printer here in court?
+
+7 A. We did.
+
+8 Q. It was back somewhere in the nether regions?
+
+9 A. Yes, it was back in that room that's right in the entryway.
+
+10 Q. Now, at the beginning of the third day of voir dire, do you
+
+11 recall Ms. Trzaskoma raising a concern about the person I'll
+
+12 called Juror No. 20 whose mother worked at the FBI and who
+
+13 showed up the third day wearing the FBI turtleneck?
+
+14 A. I will never forget that. I remember it very clearly.
+
+15 Q. You found that very significant?
+
+16 A. I did indeed.
+
+17 Q. More significant can than the potentiality that someone
+
+18 might be a suspended attorney?
+
+19 A. I think you understand I didn't believe there was a
+
+20 potentiality.
+
+21 Q. You didn't know, Ms. Brune, did you?
+
+22 A. At the time based on the juror's sworn statements, I
+
+23 believed she was someone else entirely. I obviously didn't
+
+24 know that she was the suspended lawyer.
+
+25 Q. Well, you acquire knowledge by asking questions in many
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 instances, correct, Ms. Brune?
+
+2 A. I think you know what I did is I listened to the voir dire 3 that the juror gave and her answers and I credited her answers.
+
+4 Q. Well, that wasn't my question, Ms. Brune. My question was, S you can acquire knowledge by asking questions, correct?
+
+6 A. I certainly cannot disagree with you. One way of acquiring 7 knowledge is to ask questions.
+
+8 Q. Did you tell the other defense counsel about the suspension 9 opinion that you all had found?
+
+10 A. During voir dire, I don't believe that we did.
+
+11 Q. And at some point in time, and correct me if I'm wrong, but 12 I believe based on something I think you had said in court that 13 all the defense counsel met with Dennis Donahue prior to voir 14 dire or prior to the actual selection of the jury?
+
+15 A. Prior to the actual selection of the jury, all defense
+
+16 counsel did meet with Dennis Donahue.
+
+17 Q. And you could have raised it at that point in time with the 18 other defense counsel, correct?
+
+19 A. And had I believed it was the same person I certainly would 20 have.
+
+21 Q. But you could have?
+
+22 A. II, I certainly could have raised that this was information 23 that I had discarded as not pertaining to the prospective
+
+24 juror, which would be true of a whole host of other information 25 that we discarded.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Q. You could have, but you didn't, correct? 2 A. That's correct. 3 Q. Now, other defense counsel raised questions or concerns 4 about various potential jurors, correct? 5 A. Now, you know that there was a joint defense agreement and 6 I'm not by my answers in any way intending to waive it, but 7 there certainly was a discussion and I think all of the defense 8 counsel spoke their minds about prospective jurors. We were 9 making our challenges collectively, so we had to work it. out. 10 Q. And here in court during the process of voir dire with the 11 judge, various defense counsel were raising issues and 12 concerned, correct? 13 A. That's right. 14 Q. And some of those issues and concerns were not based on a 15 hundred percent knowledge, correct? 16 A. That's certainly so. 17 Q. And some of it was just based on gut feelings about the way 18 people were acting or looking, correct? 19 A. That's right. 20 Q. So it wasn't based on perfect knowledge, correct? 21 A. Unfortunately, that's true of jury selection in general. 22 It certainly was not based on perfect knowledge. 23 Q. Now, you recall Mr. Aponte? 24 A. I think so. 25 Q. Well, do you recall that there was a juror who had criminal SOUTHERN DISTRICT RE?ORTERS, P.C. (212! 805-0300
+
+I convictions, correct?
+
+2 A. Yes.
+
+3 Q. He was the one who had the turnstile jumping conviction,
+
+4 correct?
+
+5 A. Did he have a burglary case as well?
+
+6 Q. Yes, the one who was the lookout for the burglary, correct?
+
+7 A. Sounds like I'm right. That's what I recollect.
+
+8 Q. And you didn't object to someone with a criminal conviction 9 serving on the jury, correct?
+
+10 A. We had to make choices among the panel and he wasn't my
+
+11 favorite, but we did not use a challenge for him.
+
+12 Q. So am I correct, Ms. Brune, that the fact that someone has
+
+13 a criminal conviction in and of itself was not dispositive for
+
+14 you, correct?
+
+15 A. It was not.
+
+16 Q. And one of the issues that was raised from the very
+
+17 beginning and ran through the voir dire process was any
+
+18 particular person's availability to sit for what promised and
+
+19 in fact turned out to be a very long trial, correct?
+
+20 A. The availability issue was a big one during voir dire.
+
+21 Q. And in fact Judge Pauley opened up with the statement about
+
+22 the length of the trial and the scheduling issues, correct?
+
+23 A. That's right.
+
+24 Q. And you recall that Judge Pauley asked many jurors about,
+
+25 specifically about their availability during the three-month
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 trial?
+
+2 A. Yes.
+
+3 Q. You would agree it was an appropriate area for the Court to 4 inquire?
+
+5 A. Yes.
+
+6 Q. Indeed a necessary area?
+
+7 A. Yes.
+
+8 Q. And it was appropriate for the jurors to tell the Court
+
+9 whether or not they would be available, correct?
+
+10 A. Not only was it appropriate, I think that the Court's
+
+11 instructions to them were that they had to.
+
+12 Q. Now, you were present for every day of the trial, correct?
+
+13 A. Yes.
+
+14 Q. And because of the way the tables were set up, you indeed
+
+15 had a direct view of the jury box, correct?
+
+16 A. That's right.
+
+17 Q. Unlike virtually anyone else in the courtroom, you were
+
+18 squarely facing them, correct?
+
+19 A. Yes. I couldn't see the witness stand at all, but I could
+
+20 see the jury very well.
+
+21 Q. And that included Ms. Conrad, correct?
+
+22 A. Yes.
+
+23 Q. You saw that during the trial she was an attentive juror?
+
+24 A. Yes.
+
+25 Q. She took a lot of notes?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+- 1 A. I noticed that, yes. 2 Q. And you saw nothing chat caused you concern about her 3 demeanor or behavior during the trial, correct? 4 A. No. To the contrary, she seemed to be who she had 5 presented herself to be. 6 Q. You in fact did not raise any concerns with the Court at 7 any point during trial about her behavior as a juror? 8 A. No, I saw no cause for concern. 9 Q. Now, you were also present for the process leading up to 10 jury deliberations, correct? 11 A. when you say the process, I'm sorry. 12 Q. I'll withdraw the question. You were present in court when 13 Juror No. 1 sent I think a note, I think it might have been 14 marked as Court Exhibit 3, prior to the start of jury 15 deliberations, correct? 16 A. I was present in court, although I don't think I knew at 17 that point what -- because I think what happened, I may be 18 getting it a little wrong, but on May 10th, judging from the 19 date on the note, she sent the note and then I recollect that 20 Judge Pauley disclosed the note after all counsel had summed up 21 and my recollection was that he did that because he didn't 22 think it was fair to provide the note in the middle of 23 summations. So he must have received it somewhere along the 24 middle of the summations. 25 Q. And you were present when the judge read the note to SOUTHERN DISTRICT REPORTERS, P.C.
+ - (212) 805-0300
+
+1 counsel, correct? 2 A. I was. 3 Q. And that prompted, that note prompted Ms. Trzaskoma and 4 others in your firm to do additional research on Catherine 5 Conrad, correct? 6 A. That's now my understanding, yes. 7 O. Did you know that at the time? 8 A. No, I don't think so. But I'm not, I really don't think 9 so. 10 Q. So is it your testimony here today that from 7:30 in the 11 morning when Ms. Trzaskoma sends out the first e-mail -- 12 MR. SCHECTMAN: Judge, just for the record, that 7:30 13 is the west coast time on the note, I'm almost certain it's 14 10:30 and I think we can probably stipulate to that. 15 I'm not willing to stipulate to that, your 16 Honor, and I'll move on, but I'm not willing to stipulate to 17 that. 18 A. I'm sorry -- 19 THE COURT: Why don't you put a new question to the 20 witness? 21 Q. So is it your testimony here today that you were neither 22 included on the e-mail traffic nor made aware of the e-mail 23 traffic up through the beginning of jury deliberations? 24 A. I certainly was not included on any e-mail traffic. What 25 I'm saying is I don't have a recollection of being made aware SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 that Ms. Trzaskoma was, as I now know, investigating via the 2 internet. 3 Q. At what point did you become aware? 4 A. I think it was May 18th. 5 Q. Are you telling us that on May 12th you knew nothing about 6 the research that Ms. Trzaskoma did? 7 A. Well, as I have already said, I certainly knew that she had 8 looked on Google and had found this disciplinary decision or 9 opinion, and on May 12th I knew that she had sort of thought 10 about it and I assumed looked at it again. 11 Q. Let's talk about the conversation that you had with Ms. 12 Trzaskoma. 13 A. Okay. 14 O. On May 12th. 15 A. Yes. 16 Q. It was you and Ms. Trzaskoma and Ms. Edelstein present, 17 correct? 18 A. That's correct. 19 Q. And it was at the end of the court day on May 12th. 20 A. That's correct. 21 Q. And you were in the process of leaving court, correct? 22 A. We had left court and as far as I can recollect we were 23 across Foley Square, maybe close to 52 Duane. 24 Q. Where you had some sort of satellite office, is that right? 25 A. Yes.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+C2GFDADI. Brune - direct
+
+1 Q. And as best as you can recall and with as much precision as 2 you can muster, what exactly did Ms. Trzaskoma say to you as 3 you were headed to 52 Duane? 4 A. So the three of us were together and Ms. Trzaskoma said 5 something to me along these lines: You know, I'm starting to 6 wonder in light of the juror note whether this Juror No. 1 7 could be the same person as this suspended lawyer. 8 And Ms. Edelstein said, "Well, what did she say in 9 voir dire?" And Theresa reminded us of the stay at home wife 10 and the education and the other aspects of the voir dire and 11 she reminded us that this person had some kind of a personal 12 injury suit in the Bronx. And at that point, I think it was 13 Ms. Edelstein, but I may have been the person who said it, one 14 of us said well, that makes perfect sense. That explains why 15 She's making references to these concepts. They must have been 16 at issue in her case, and here I'm having a little bit of a 17 hard time separating what I thought and what was said, but I 18 either thought or said, well, you know, Judge Pauley will set 19 her straight in the jury charge and, you know, it's sort of 20 just a silly note. 21 I thought that it all made sense because of the 22 personal injury suit and that no lawyer would be so dumb as to 23 think that vicarious liability or respondeat superior had any 24 place in a criminal case. 25 So then, so back to the conversation, and again I got
+
+1 the same problem of trying to remember what was said versus 2 what was thought, but I think what was discussed is, look, it's 3 not her. She's sworn before Judge Pauley,the note doesn't 4 change the picture and, you know, this is kind of crazy. You 5 can't start sending a private investigator out on a juror. She 6 said she's someone else, she seems like a housewife from 7 Bronxville. It would be unfathomable or inconceivable or 8 something for a person who was in fact a lawyer to have sworn 9 under oath that she was someone else. It was something where 10 we discussed it and concluded that it made no sense, and Juror 11 No. 1 was who she said she was. 12 Q. So just so I'm clear, Ms. Brune, Ms. Trzaskoma did tell you 13 in that conversation that she thought Juror No. 1 could be 14 Catherine Conrad the suspended attorney? 15 A. What she said is that note makes me wonder if it could be 16 the same person. 17 Q. And are you telling me that Ms. Trzaskoma made no mention 18 whatsoever of the Westlaw report that she had found? 19 A. I'm confident that's so, and here's why. Laurie Edelstein 20 is the kind of person who will always kind of say, well, show 21 me the case, show me the document. She's extremely thorough, 22 and if she had referenced the document in the conversation 23 that's what Ms. Edelstein would have said. So I know that 24 there was no reference to it in the conversation. 25 Q. So even as you're standing there, Ms. Brune, the thought SOUTHERN DISTRICT REPORTERS, P.C.
+
+I occurred to you that you could have your team look into this, 2 correct?
+
+3 A. I certainly thought, well, here's this information on
+
+4 Google. Here's the sworn statement. We could have certainly
+
+S done more. I didn't think it was proper in light of the fact
+
+6 that I didn't think there was anything to the idea that she was 7 a suspended lawyer.
+
+8 Q. Based on what information, actual information?
+
+9 A. I credited her sworn voir dire responses. I went through
+
+10 the reasoning that I described that the note in a way ruled out
+
+11 the idea that she was a lawyer, and matched up with the idea
+
+12 that she was a litigant in the personal injury suit, and it
+
+13 made no sense that a lawyer would sit in a voir dire and lie
+
+14 that way.
+
+IS Q. Did you read the indictment in this case, Ms. Brune?
+
+16 A. I read the indictment in this case.
+
+17 Q. And you understood that much of the indictment focused
+
+18 around the misconduct of lawyers, correct?
+
+19 A. That is certainly what the indictment alleged.
+
+20 Q. And a number of the defendants were lawyers, correct?
+
+21 A. Yes.
+
+22 Q. And a number of the cooperators and codefendants who
+
+23 pleaded guilty were lawyers, correct?
+
+24 A. If what you're asking me is --
+
+25 Q. It's a simple question, Ms. Brune.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. Okay, that's fine. it's certainly so that many of the 2 government witnesses were lawyers and that some of them had 3 pleaded guilty. 4 Q. And their pleas included pleas to making false statements 5 to the TRS, correct? 6 A. That's true. 7 Q. So it's not inconceivable that attorneys lie, correct? B A. I don't think that's what I said, but it's certainly not 9 inconceivable that lawyers lie. 10 Q. And at the end of that conversation, you told Theresa 11 Trzaskoma to leave it, correct? 12 A. I don't remember the words, but something to that effect. 13 Q. Now, she had been the partner in charge of the jury 14 selection, correct, in terms of the detail work? 15 A. I was in charge of the jury selection. But you're right, 16 she was closer Co it than I. 17 Q. Did she tell you in that conversation that she had had 18 basically an "Ill, Jesus" moment? 19 A. She certainly did not say that. 20 Q. There was a possibility, Ms. Brune, that this was in fact 21 true information. As you're standing there out in the plaza, 22 that information existed, correct? 23 A. I didn't believe that at the time. 24 Q. Well, you didn't know, bottom line is you didn't know one 25 way or the other, correct?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. I certainly did not know.
+
+2 Q. And you could have turned right around and contacted
+
+3 about it, correct?
+
+4 A. Had I thought that the information was accurate, I would
+
+5 have immediately contacted
+
+6 Q. Why the qualifier, Ms. Brune? Bottom line is, you have a 7 significant piece of information. You could have brought it to 8 the Court's attention, then, correct?
+
+9 A. I did not accord it significance at the time.
+
+10 Q. You had an entire team and an investigative firm at your
+
+11 disposal, correct?
+
+12 A. There's no question that we had resources.
+
+13 Q. And you had a telephone with you, correct?
+
+14 A. I did.
+
+15 Q. And a BlackBerry?
+
+16 A. My phone and my BlackBerry are the same thing, but yes.
+
+17 Q. And you had access to, immediate access to e-mail, correct?
+
+18 A. I certainly could have communicated with
+
+19 Q. And you're confident, are you not, that if you had said to
+
+20 your team let's investigate this further, this is important, 21 they would have done so, correct?
+
+22 A. Yes. The team was very diligent.
+
+23 Q. And they would have worked as long as it took to get the
+
+24 job done to your satisfaction, correct?
+
+25 A. They worked hard, and they would have done whatever I asked
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+them to do, I believe. 2 O. And that would have included working late at night, 3 correct? 4 A. That is for sure. 5 Q. And you were present in court when the judge had to restart 6 jury deliberations the next week, correct? 7 A. Yes. 8 Q. Because of a juror's illness, correct, or health condition? 9 A. Was that when Mr. Rosenbaum had to leave? 10 Q. Correct. 11 A. Yes. 12 Q. And there were still alternates left at that point in time, 13 correct? 14 A. There were. 15 Q. More Chan one? 16 A. There were a whole row of alternates. I don't know how 17 many, but at least four. 18 Q. Exactly. Did you think at that point in time that you 19 might want to raise with the Court, hey, there's this issue out 20 here, we don't know one way or the other, but it's important so 21 wouldn't you like to know? 22 A. I did not believe there was an issue. Had I believed there 23 was one, I would have raised it immediately with the Court. I 24 certainly is not a benefit that I waited until Mr. Rosenbaum 25 had taken ill. If I believed it was so, I would have let the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 Court know.
+
+2 Q. And you understood that the Court had the resources and 3 ability to get information on its own, correct?
+
+4 A. II, yes.
+
+5 Q. And you chose not to bring either what you had found before 6 voir dire or what you had found on March 12th to the Court's 7 attention, correct?
+
+8 A. I made no particular choice relating to May 12th because I 9 didn't know that there was any more out there, but I certainly 10 did not bring the Google search results to the Court.
+
+11 Q. When you were an AUSA, would you have felt an obligation to 12 bring that kind of information to the Court's attention?
+
+13 A. I have the same obligation to the Court now as I did when I 14 was an AUSA and had I believed that that information was 15 accurate. I would have immediately brought it to the Court's 16 attention.
+
+17 Q. But you had no basis Co know, Ms. Brune, one way or the 18 other, about the accuracy of the information, correct?
+
+19 A. I believed, based on the juror's sworn statements and the 20 other factors, that she was someone else entirely.
+
+21 Q. Let me ask you this question: In the papers and in court 22 you all -- talking about her, II, she was a stay at home wife. 23 That does not preclude the possibility that she's an attorney. 24 correct?
+
+25 A. I think that's so. There certainly people are who arc SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 lawyers who choose not to practice. What I was very focused on 2 was her highest level of education that did not include any law 3 school.
+
+4 Q. You said that you found out more on May 18th?
+
+5 A. That's right.
+
+6 Q. What happened on May 18th?
+
+7 A. Well, on May 15th while I was out of the country, Ms.
+
+8 Trzaskoma handled the telephone conference with the Court where 9 this issue was first raised. Is this right? Is this right?
+
+10 No. I'm wrong. What I'm talking about, the first time I
+
+11 learned about the voir dire is I think July 18th. What I'm
+
+12 trying to say is that --
+
+13 Q. Could I stop you there? Because I'm trying to keep in 14 somewhat chronological order.
+
+15 A. I'm sorry, I got it wrong what I said earlier. What I'm
+
+16 trying to say is I learned about the Westlaw report atter that
+
+17 conference with the Court that Ms. Trzaskoma handled so I think
+
+18 that puts us to July 18th.
+
+19 Q. All right, so now that we've got the days straightened 20 out --
+
+21 A. Sorry about that.
+
+22 Q. You said a moment ago that Ms. Edelstein is the kind of
+
+23 person who wants to see documents, cases.
+
+24 A. She's a very thorough person.
+
+25 Q. Did she ask to see the suspension opinion that had been
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 found prior to voir dire? 2 A. Now we're back to the conversation on Foley Square? 3 Q. I'm just asking a question, I'm not putting a date on it. 4 MR. SCHECTMAN: Judge, it would be helpful if we had a 5 date. 6 Q. t don't know the answer so I'm going to ask the broad 7 question. 8 A. Okay. 9 Q. At the time, around the time before the verdict came in -- 10 A. Ckay, that's helpful. 11 Q. Do you know whether Ms. Edelstein asked to see the 12 suspension opinion? 13 A. I don't think that she did, but I don't know one way or the 14 other. She certainly didn't in the conversation on Foley 15 Square that we've been talking about. 16 Q. You do know, don't you, though, that on 17 Trzaskoma told not the Court about the suspension issue but 18 Mr. Schoeman and Mr. Berke, correct? 19 MR. SCHECTMAN: Judge, I object. I don't think the 20 date is accurate. I think it's leading. I mean, I don't 21 object to much leading, but the date's not accurate. 22 : Your Honor if I might, 611(c) allows us to 23 lead with a witness identified as an adverse party. 24 THE COURT: He's not objecting to leading. He's 25 objecting to leading with an erroneous assumption or statement SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 of fact in the question, that's all. He's concerned about the 2 date. I don't know whether he's right or wrong, but why don't 3 you sec if you can establish a date with the witness. 4 A. I'm sorry. 5 Q. Ms. Brune, you know that. Ms. Trzaskoma had a conversation 6 with Barry Berke and Paul Schoeman about the possibility that 7 she was a suspended attorney. 8 A. I know that now because I've seen these affidavits that 9 have come in. I don't think I knew it at the time. 10 Q. She did not tell you? 11 A. I don't have a very clear recollection of this, but I don't 12 think she did. 13 Q. Now, let's move to June 23rd. Let me -- withdrawn. You 14 will agree, would you not, that jury deliberations took a 15 relatively long time in this case. 16 A. It took eight days, as I recall. 17 Q. And pursuant to the judge's order, a member of your team 18 was in court or nearly in court that whole time, correct? 19 A. I personally was there throughout the deliberations. 20 Q. And at any point in time prior to the time of the verdict 21 you could have raised what your firm had learned both before 22 voir dire started and on May 12th, correct? 23 A. There is no question -- 24 Q. And it's a could have. It's a could have. 25 A. There is no question that we could have addressed the Court SOUTHERN DISTRICT REPORTERS, ?.C.
+
+(2121 805-0300
+
+1 at any point. 2 Q. Now, when you got a copy of Ms. Conrad's letter to 3 Mr. Okula, you subsequently had conversations with the defense 4 counsel, correct? 5 A. I did. 6 Q. And did you tell them at or around that time what you 7 previously found out? 8 A. The communications were joint defense communications. 1 9 don't mind answering the question so long as there's no 10 contention that there's a broader waiver of the joint defense 11 privilege and so long as no other party to the -- 12 MR. GAIR: We have no oojection, your Honor, on behalf 13 of Mr. Daugerdas. 14 A. I got the jury note, read it, very upset, set it aside. 15 Ms. Edelstein looked at the letter which had the phone number 16 and went on the Bar website and saw that the phone number 17 matched. We still -- 18 Q. Can I stop you there, Ms. Brune? 19 A. Yes, I'm sorry, I'm trying to answer your question and 20 you're right that it does not in the way that you want me to. 21 What I'm trying to say is it took us a couple of days after we 22 received the note to communicate with our co-counsel. 23 (Continued next page) 24 25
+
+291
+
+C2grdau2 Brune - direct
+
+1 Q. But my question was a far more specific one that you still 2 haven't answered, Ms. Brune.
+
+3 A. I'm going to.
+
+4 Q. Which was, just so we are clear, did you tell the defense 5 counsel within that several-day period about what you had 6 previously learned from Google, the suspension opinion, and the 7 Westlaw report?
+
+8 A. T did not at that point know anything about the Westlaw 9 report. T did not discuss the Google search with co-counsel.
+
+10 Q. Did you at any point advise them about the Google search? 11 A. No.
+
+12 Q. At some point in time am I correct in assuming that you 13 actually reviewed the Westlaw report?
+
+14 A. Here is where I got the dates wrong. There was the 15 conference with the Court which Ms. Trzaskoma handled and we 16 had to submit a letter to the Court. So Chen on that Monday,
+
+17 which I think is July 18th, I had a discussion with Ms. 18 Edelstein and Ms. Trzaskoma, and at that point I learned that
+
+19 there was this Westlaw report floating around. 20 Q. You learned specifically that this was the Westlaw report 21 that Ms. Trzaskoma had found or had been provided by Mr.
+
+22 Benhamou on May 12th, correct?
+
+23 A. Yes. We were very focused on making sure what we said in 24 the letter was accurate, and that was a part of it.
+
+25 Q. Before this time period you had filed a brief, right?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. That's right. 2 Q. It was filed under your signature? 3 A. It was. 4 Q. With your ECF number? 5 A. That's so. 6 Q. You were ultimately responsible for the factual assertions 7 in that brief, correct? 8 A. Yes. I reviewed it and I signed it and I am responsible 9 for it. 10 Q. That set of facts was not accurate and complete, was it, 11 Ms. Brune? 12 A. When. I reflect on that brief, and I certainly have done so 13 repeatedly and at length, it's the thing that. I regret. What I 14 mean by that is we kind of missed it. There were two things 15 that were going on. One is we were spending a lot of energy 16 trying to persuade ourselves that what we were going to say to 17 the judge was right, that is, that there was this fraud that 18 happened, and we were very focused on not having Mr. Parse's 19 application kicked out the way that it was kicked out in Martha 20 Stewart for not sort of having proved it enough. 21 I certainly thought about the waiver issue. But what 22 I really missed is I thought that the government would likely 23 inquire and we would say we didn't know, because we didn't 24 know. I certainly never imagined that the reality that we did 25 not know was going to assume the sort of debate level SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+prominence it has here. I missed the issue, and I really 2 regret that. It was, I think, a good brief, but it missed it. 3 Q. Do you think good briefs omit material facts, Ms. Brune? 4 A. I certainly do not think that about briefs. 5 Q. You knew when you wrote that brief about the suspension 6 opinion that Ms. Trzaskoma had found, correct? 7 A. That's correct. 8 Q. There is no mention of that in the brief, correct? 9 MR. SHECHTMAN: Judge, there is mention of the 10 suspension opinion in the brief.
+
+11 THE COURT: Overruled.
+
+12 A. You are right that the brief does not include a discussion 13 of our having accessed the suspension opinion during the trial. 14 Q. In fact, it's worse than that, Ms. Brune. You claim in 15 that brief that it was the letter of Ms. Conrad that prompted 16 you to investigate. That was simply not accurate, correct? 17 A. I think it was accurate in that we did not launch an 18 investigation of the sort that was described in the brief until 19 after the government disclosed the letter. But as I've said, I 20 missed that issue in terms of how the brief was written. 21 Q. Ms. Trzaskoma drafted in the first instance the set of 22 facts for that brief, correct?
+
+23 A. Yes, that's right. 24 Q. She was well aware of the investigation that she asked be 25 done on. May 12th, correct?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. She certainly was aware of what had been done, that's 2 correct. 3 Q. Are you shying away from using the word "investigate" to 4 describe what it was that you and Mr. Benhamou and Mr. II. Stapp were doing on the morning of May 12th? 6 A. It's not that I'm shying away. I just don't think it is 7 accurate. To me "investigation" means more than looking at a 8 database search. What I think of as an investigation is what 9 we ended up doing once we received the jury letter. 10 Q. You also stated in your memorandum at page 32 note 13 that 11 the defendants had no basis to inquire whether Conrad was lying 12 in response to the Court's questions. That is just wrong, Ms. 13 Brune. 14 A. I have I think already said that having reflected on all 15 this, I think there are a number of things that I wish had been 16 said differently. What I was trying to convey to the Court in 17 the brief was the reality, which is that we didn't think it was 18 the same person and we were shocked when we received the note 19 and found out about the phone number matching. 20 Q. Had you seen the email traffic at that point in time when 21 you filed the brief, Ms. Brune? 22 A. No, I had not. 23 Q. But you know now that Ms. Trzaskoma knew about that email 24 traffic, correct? 25 A. She did.
+
+1 Q. She is under the same ethical obligations 2 correct? 3 A. She is. 4 Q. She is a partner in the law firm, correct? S A. That's right. 6 Q. She made an appearance in this court, correct? 7 A. She did. 8 Q. She, notwithstanding your role as the 9 cannot evade those ethical obligations by 10 the person in charge, correct? 11 A. No. She has independent ethical oblig 12 question. 13 Q. Obligations to bring 14 attention, correct? 15 A. She has the same ethical obligations as I do or any other 16 lawyer in this court does. 17 Q. Did she review the final brief? 18 A. I'm certain she did. 19 Q. I may have it wrong, so correct me if I am wrong, Ms. 20 Brune -- but let me ask you, on what date did you see the email 21 traffic? 22 A. We gathered the email traffic as part of this period 23 leading up to our submitting the July 21st letter. So I saw 7 24 think all of it before we submitted the letter. I was very 25 focused on making sure that I had the information to convey to SOUTHERN DISTRICT REPORTERS. P.C. ultimate supervisor, claiming that you're ations, there's no material information that you are, to the Court's
+
+C2grdau2 Brune - direct
+
+1. 1 the Court.
+2. 2 Q. Do you think it was before the July 15th conference call
+3. 3 with the Court?
+4. 4 A. I did not see it before the July 15th conference call with
+5. 5 the Court.
+6. 6 Q. Do you think it was before you filed your July 21st letter?
+7. 7 A. Yes, it was.
+8. 8 Q. You were not on the July 15th conference call, correct?
+9. 9 A. That's correct.
+10. 10 Q. You saw a transcript of the conference call?
+11. 11 A. Ms. Trzaskoma let me know about it immediately after that,
+12. 12 and I also read the transcript when it became available.
+13. 13 Q. Approximately when was that? Was that before you filed
+14. 14 your July 21st letter?
+15. 15 A. █, yes, within a day.
+16. 16 Q. You're accustomed to get daily or -- in other words, this
+17. 17 was not an instance where you ordered like a 30-day-out
+18. 18 transcript?
+19. 19 A. █, no. We had to respond, so I read the transcript to
+20. 20 make sure that I knew what Judge Pauley was directing us to do.
+21. 21 Q. At the point at which you saw those emails, Ms. Brune, at
+22. 22 the very least you knew that Ms. Trzaskoma's statements to the
+23. 23 Court in that conference call were not correct?
+24. 24 A. I disagree.
+25. 25 Q. Did she reveal to the Court what she knew?
+
+1 A. What she did was what the judge had sort of given people 2 the option of saying that they would do, which is that she said 3 that she would submit a letter, and then we worked very hard to 4 submit a letter that was accurate.
+
+5 MR. : Mr. Wooten, could I have Government
+
+6 Exhibit 9, page 12, please.
+
+7 Could I have a moment, your Honor?
+
+8 THE COURT: Take your time.
+
+9 Q. Can you see it up there?
+
+10 A. Yes.
+
+11 Q. Do you see where Ms. Trzaskoma, in response to the Court's 12 inquiry, said, "Your Honor, we were not aware of the facts Chat 13 have come to light, and I think if your Honor deems it 14 appropriate, we can submit a letter"? Correct?
+
+15 A. She did say that.
+
+16 Q. One of the facts that had come to light was the very same 17 suspension opinion that she had found before vol.: dire ever 18 started, correct?
+
+19 A. I think what she is trying to convey there --
+
+20 Q. That's not my question.
+
+21 A. I'm Sorry. If you could say it again.
+
+22 Q. I'm just asking a very straightforward question, Ms. Brune.
+
+23 A. I know it, but it's not a yes or no, I don't think.
+
+24 Q. Sure it is. The question is, one of the facts that came to 25 light that you attached was the Westlaw report, correct? You SOUTHERN DISTRICT REPORTERS, P.C.
+
+attached that to your July 21st letter, correct? 2 A. When we submitted the letter, as she had promised to do, we 3 certainly attached the Westlaw opinion. 4 Q. That was a fact that had come to light, correct? 5 A. Yes, that's correct. 6 Q. She's telling the Court, we were not aware of them, clearly 7 trying to imply that you all found this well after the trial 8 was over, correct? 9 A. I don't think that's what she meant to imply at all. I 10 think what she is saying is that we were going to submit a 11 letter and the plan was then to submit a letter laying it out, 12 which is what we did. 13 I don't believe Ms. Trzaskoma was trying to mislead 14 the Court. I Chink she was not as precise as she should have 15 been, and she would have done better to say we are going to 16 submit a letter, but I don't believe she was trying to mislead 17 the Court. Indeed, we laid it out in the letter. 18 Q. Let me stop you there. You are so far beyond the question 19 that I asked that I would like to get us bacx on track, if I 20 could. In your brief you told this Court and painted a picture 21 like the beginning of your knowledge was the letter from Ms. 22 Conrad. You omitted everything chat had happened prior to 23 that, correct? 24 A. I believe that it's true that our knowledge came after we 25 received the letter. That's what the brief was intended to SOUTHERN DISTRICT REPORTERS, P.C.
+
+C2grdau2
+
+1 convey. As I think I've 2 on the brief, I think we 3 greatly regret, there is 4 Q. The Court convened a 5 A. Yes, that's right. 6 Q. You participated on 7 A. I did. already said, though, when I reflect missed it. And it's something that I no question about that. conference call on July 22nd, correct? that call, correct? 8 Q. Indeed, the Court inquired of the defense counsel why he 9 was getting two different versions of the facts, correct? 10 A. Something along those lines, yes. 11 Q. When you compare what you said in the July 21st letter to 12 the facts as laid out in the brief, those are two very 13 different set of facts, correct? 14 A. I can't sort of say for sure what Judge Pauley was 15 thinking, but he certainly was conveying that he wanted to get 16 to the bottom of things and that he was not happy with us. 17 Q. That wasn't my question, Ms. Brune. My question was, if 18 you compare the facts as they are laid out in your letter to 19 the facts as they are laid out in the brief, those are two very 20 different sets of facts, correct? 21 A. I don't agree with you. I thought what you were asking me 22 to say was what Judge Pauley was thinking. 23 Q. No, that wasn't my question. Is it your testimony here, 24 Ms. Brune, that you did not find it a material fact, the things 25 that you uncovered prior to the return of the jury's verdict? SOUTHERN DISTRICT REPORTERS, P.C.
+
+Brune - direct
+
+(2121 805-0300
+
+1 It's a simple question.
+
+2 A. The standard under McDonough is actual knowledge. We
+
+3 didn't know. I don't think it is material to the legal
+
+4 analysis. That having been said, I think if had we to do it
+
+5 over again, the equivalent of the July 21st letter should have
+
+6 been submitted alongside the brief. I missed the issue of what
+
+7 the government's position was going to be.
+
+8 Q. You're familiar, are you not, Ms. Brune, with the cases
+
+9 subsequent to McDonough that have held that full knowledge is
+
+10 not required, that defense counsel has an obligation to bring
+
+11 potential misconduct to the Court's attention so that the court
+
+12 can deal with it, correct?
+
+13 A. I've certainly read a lot more of the waiver cases since
+
+14 this whole issue has been joined. As an ethical matter,
+
+15 though, the standard is if the lawyer has actual knowledge of
+
+16 juror misconduct. We did not have actual knowledge of juror
+
+17 misconduct. Indeed, we believed, erroneously it now appears
+
+18 for certain, there was no juror misconduct.
+
+19 Q. I wasn't asking about the New York ethical rule that I
+
+20 think you're referring to, Ms. Brune.
+
+21 A. I'm sorry. If you asked me about an ethical matter, that's
+
+22 my understanding.
+
+23 Q. I'll withdraw the question. You acknowledged in that July
+
+24 22nd telephone call that you, your firm, or defendant Parse,
+
+25 was differently situated than other defendants, correct?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. Yes.
+
+2 Q. You knew that at the time you filed the brief?
+
+3 A. I believed it to be so. My basis for that is when I called 4 the other lawyers in the case to let them know what our several 5 days of investigating in the wake of the letter made us believe 6 could be true -- we still weren't sure but we were getting a
+
+7 lot surer -- they all expressed complete surprise. Based on 8 that, I believed that we were somewhat differently situated.
+
+9 Although, as I think you know, we were surprised.
+
+10 Q. You could have filed a separate brief, correct?
+
+11 A. We could have, yes.
+
+12 Q. With an accurate statement of the facts, correct?
+
+13 A. We certainly could have filed a separate brief. As it 14 turned out, because the resources were different, we took by 15 far the laboring oar with the brief.
+
+16 Q. Isn't it true that on that July 22nd call you said
+
+17 essentially, and I can bring up the transcript if you would
+
+18 like to see it, that you intended to lay out the facts as it 19 related to waiver essentially when and if the government asked?
+
+20 A. That is pretty much what I said. I certainly thought it
+
+21 was the case that the government might well raise the waiver
+
+22 issue. As I said, I kind of missed where this was all going.
+
+23 But I certainly thought the government was likely going to
+
+24 inquire did we know. I didn't know and I don't believe anyone
+
+25 else at our firm did, so I certainly planned to answer the
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 government and the Court accurately when the issue was 2 presented. 3 Q. Is that the ethical standard that governed you when you 4 were an AUSA, Ms. Brune? 5 A. That I was supposed to raise the other side's point in my 6 brief when I didn't know what position they were taking? I 7 don't think that governs any Assistant U.S. Attorney. 8 Q. No, I think it is really more that you were willing to lay 9 out the accurate set of facts if and only if the government 10 would ask you to do so. 11 A. We've already talked about the brief and how I in some 12 respects missed the issue, which I regret. Of course, both 13 defense counsel AUSA's are obliged to lay things out for the 14 court accurately. It is something that throughout my career I 15 have always strived to do. 16 Q. But for the Court's pressing and the government's pressing, 17 you would have never disclosed those facts to the government, 18 isn't that right, Ms. Brune? 19 A. If the government chose not to raise the waiver issue, and 20 as I thought about it I actually thought that the government 21 had far more information or at least had access to far more 22 information, my sense at the time was that the government had 23 probably Googled her, too. But I thought that if the 24 government chose to make it an issue, I was prepared to respond 25 and respond accurately, which I tried very hard to do.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Q. The question was that you were willing to provide a 2 complete and accurate set of facts if and only if the 3 government asked, is that what you are saying?
+
+4 A. No, that's not what I'm saying at all. I tried very hard 5 to be accurate in the brief that we submitted. It has the 6 shortcomings that we have talked about.
+
+7 Q. It has material omissions, Ms. Brune?
+
+8 A. I certainly have tried to be accurate.
+
+9 Q. It has material omissions, correct?
+
+10 A. I do not believe that it was written with the goal of 11 making a material omission. I believed then and believe now 12 that the standard is actual knowledge. We did not have actual 13 knowledge or anything near that. We were shocked when we 14 received the letter.
+
+15 Q. It has material omissions in it?
+
+16 MR. SHECHTMAN: Asked and answered.
+
+17 MR. No, I don't believe she has answered it, 18 your Honor.
+
+19 THE COURT: Overruled.
+
+20 A. I did not believe that it had material omissions in the 21 sense that anyone writing the brief or in my case signing the 22 brief intended to make material omissions. I think that what 23 we were trying to do was we were trying to describe the post-24 letter investigation that we undertook and we were trying to 25 convey what is accurate, which is that it was the letter that SOUTHERN DISTRICT REPORTERS, P.C.
+
+prompted us to doubt the voir dire and to investigate. 2 Q. One of the questions that the judge asked on the July 22nd 3 phonecall related to the jury consultants in this case, 4 correct? 5 A. That's right. 6 Q. You identified Mr. Donohue, correct? 7 A. That's right. 8 Q. I believe Mr. Gair also made some statements about Mr. 9 Donohue's relationship with his law firm, correct? 10 A. Right. 11 Q. Julie Blackman was identified, correct? 12 A. That's right. 13 Q. The Court specifically said that he was looking to 14 understand who was involved in the process, meaning the voir 15 dire process, between the time that the juror questionnaires 16 were completed and the time the voir dire commenced on March 17 1st. Do you recall that? 18 A. I looked back at the transcript in preparation for the 19 hearing. I think the Court an context was asking about the 20 jury consultants, which is Mr. Schoeman responded to the 21 Court's question by saying -- either he responded or it was in 22 the whole thing. We were talking about the jury consultants, 23 and Mr. Nardello was simply not a jury consultant. 24 Q. He did investigated work related to the very topic that the 25 judge had just indicated he was interested in, correct? SOUTHERN DISTRICT REPORTERS, P.C.
+
+- 1 A. There was no question that he did investigative work in the 2 wake of the letter, and I think that's laid out in our brief. 3 But he did no work pertaining to Juror No. 1 until we received 4 the letter. 5 O. Is it your claim that the Nardello firm's work was 6 identified in your brief? 7 A. I think so. I think what our brief says is we hired a 8 private investigator. It lays out the materials that we 9 gathered. 10 O. You didn't see fit to tell Judge Pauley on the conference 11 call, by the way, we had this investigative firm? 12 A. I was involved. I really think it was in the brief. 13 could be mistaken, but I think it was in the brief. The 14 question was, who are your jury consultants, which is what Mr. 15 Schoeman and I were trying to respond to. 16 O. The judge says he's trying to understand who was involved. 17 He didn't say which jury consultants. He was trying to 18 understand who was involved. Natdello was involved, correct? 19 MR. GAIR: I'm going to object to the compound form of 20 the question. 21 THE COURT: Sustained. 22 Q. You knew Nardello had done jury research, correct? It's a 23 very simple yes or no. 24 A. That is certainly so. 25 0. It's a very simple question. SOUTHERN DISTRICT REPORTERS, P.C.
+ - (212) 805-0300
+
+1 A. Except by jury research I want to be sure you understand. 2 He had done this database work during jury selection but not 3 pertaining to the juror we were focused on in the call, 4 Catherine Conrad. 5 Q. That was the point you made before. That wasn't my 6 question. You had knowledge here that he did the jury search, 7 correct? 8 A. He certainly researched online about prospective jurors, 9 end then, after we got the letter, we retained him to do an 10 investigation about whether this was the same person. 11 O. The judge on the July 22nd telephone call was clearly 12 trying to identify all the people who had been involved in that 13 process, correct? 14 MR. GAIR: Your Honor, I'm going to object to this 15 question.
+
+16 THE COURT: Sustained. 17 Q. You didn't identify Mr. Nardello's firm to the judge on 18 that phonecall? Yes or no. 19 A. I did not on that phonecall talk about Mr. Nardello, you're 20 correct on that. 21 Q. Subsequently, the government requested discovery 22 specifically about what your firm knew, correct? 23 A. That's right. 24 Q. You strongly resisted that discovery, correct? 25 A. We filed a brief pertaining to our client's work product SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 doctrine protection for the work we had done. 2 Q. You knew that those documents would significantly advance 3 the government's position on the waiver issue, correct? 4 A. No, because the July 21st letter lays it out, lays it out 5 accurately, including the fact that Ms. Trzaskoma had that 6 initial thought that it was one and the same. 7 Q. Are you referring to the "Jesus, I do think that it's her" email? 9 A. Yes. 10 Q. You met with Ms. Trzaskoma and Ms. Edelstein prior to this 11 hearing, correct? 12 A. We worked together. I've certainly talked with her on many 13 occasions about the issues that are before the judge in this 14 hearing. I'm testifying from my own best recollection, but 15 I've certainly talked with them about the issues. 16 Q. How many times did you meet with them to discuss this 17 hearing? 18 A. Never. What I'm saying is I've talked about the issues 19 with them. We worked very hard on the July 21st letter to try 20 to get it accurate, but we did not meet in preparation for this 21 hearing. 22 Q. So, you didn't discuss what your answers would be? 23 A. I think that they know what my recollection is, and I think 24 I know what their recollection is, because we worked so hard on 25 the letter to reconstruct what had happened.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 Q. Just a few more questions, Ms. Brune. You used the phrase 2 a couple of times in discussing your brief "missed the issue." 3 What precisely do you mean by that? 4 A. we were so focused on establishing that this was the same 5 person. And on the waiver issue I was very focused on the 6 reality, which is that we didn't know. So, the issue that 7 missed was that there are things in the brief, without knowing 8 what we knew, could be read to understand that the first time 9 we even did the Google search was after we got the letter. And 10 that's not right and that's the thing that I really regret. 11 What we were trying to convey was we were shocked, 12 which was true. But I think that there are phrases in the 13 brief which, if you don't know what we knew, could be read 14 differently. That's not the standard that we aspire to as a 15 firm, and in that we fell short. 16 Q. David Parse was convicted of some of the charges, correct? 17 A. Two of the six, that's right. 18 Q. He was acquitted of the other four charges, correct? 19 A. Yes. 20 O. You thought that the jury rendered a fair and impartial 21 verdict on those acquitted charges, didn't you? 22 A. Yes, I did. 23 N.R. : No further questions. 24 THE COURT: Mr. Shechtman, do you have inquiry to 25 make?
+
+8 6 THE COURT: 7 recess and resume. (Recess) It's all right. We'll take a ten-minute
+
+9 10 THE COURT: Mr. MR. SHECHTMAN: Shechtman, you may inquire. Thank you, Judge.
+
+11 CROSS-EXAMINATION
+
+12 13 14 15 BY MR. SHECHTMAN: Q. Ms. Brune, when your cause and its peremptory Conrad, Juror No. 1, was firm exercised its challenges for challenges, did you believe Catherine a suspended lawyer?
+
+16 A. No.
+
+17 Q. Why not?
+
+18 19 A. During the voir dire to Judge Pauley's questions ruled that out. we believed that her sworn responses
+
+20 21 22 O. If you had believed that she was a suspended lawyer, indeed a suspended lawyer with an alcohol dependency, would you have wanted her on the jury?
+
+23 A. No.
+
+24 Q. Why not?
+
+25 A. First of all, the case involved lawyers, and I think that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+2 3 4 1 MR. SHECHTMAN: I do, your Honor. appropriate time to Lake a short break? THE COURT: Yes, it would be. : I apologize, your Honor. Would it be an I lost track of
+
+5 the time.
+
+C2grdau2 Brune - direct
+
+C2grdau2 Brune - cross
+
+1 would have been very distracting and would have not made her a 2 good juror. Second, I have a great deal of faith in our jury 3 consultant, and he told us that he did not think it was a good 4 idea to have a recovering alcoholic on the jury. 5 Third, the most important thing that any juror is 6 supposed to do is follow the judge's instructions. If I had 7 known that a person was prepared to defy the Court by lying on 8 voir dire, I would never have had any confidence that the 9 person would follow the Court's instructions. So there's no 10 way that I wanted this person, if indeed she was a suspended 11 lawyer, to sit on this jury. 12 Q. Ms. Brune, would I be correct that your firm received Ms. 13 Conrad's letter to Mr. Okula approximately June 20th of 2011? 14 A. That's right. It was about three weeks after it was posted 15 to the government. 16 Q. At any time between the verdict in this case on May 24th 17 and the receipt of Ms. Conrad's letter on June 20th, had your 18 firm given any consideration to raising a juror misconduct 19 issue relating to Ms. Conrad as a basis for post-trial motions? 20 A. No. 21 Q. Why not? 22 A. I didn't think there had been juror misconduct. 23 O. At any time during that same period did your firm give any 24 consideration to raising a juror misconduct issue as to Ms. 25 Conrad as an appellate issue?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+C2grdau2
+
+Brune - cross
+
+1 A. No.
+
+2 Q. I ask you the same question. Why not?
+
+3 A. We spent a lot of time thinking about appellate issues, but
+4 we didn't think that there had been juror misconduct and
+5 therefore didn't think that there was an appellate issue.
+
+6 Q. At any time between the verdict on May 24th and the receipt
+7 of the letter on June 20th, did your firm contact the Nardello
+8 firm to do additional investigation about Ms. Conrad?
+
+9 A. No.
+
+10 Q. Why not?
+
+11 A. I didn't think there was anything to investigate.
+
+12 Q. At any time during these proceedings, "these proceedings"
+13 meaning between the initial voir dire and today, have you tried
+14 to sandbag this Court or plant error in the record as to Juror
+15 No. 1, Ms. Conrad?
+
+16 A. No.
+
+17 MR. SHECHTMAN: No further questions, Judge.
+
+18 THE COURT: Redirect, [REDACTED]?
+
+19 MR. [REDACTED]: I assume there is no other defense counsel
+20 who wishes to inquire?
+
+21 THE COURT: Does any defense counsel wish to inquire?
+
+22 MR. GAIR: No, thank you, your Honor.
+
+23 MR. ROTERT: No, thank you, Judge.
+
+24 MS. MCCARTHY: No, your Honor.
+
+25 MR. [REDACTED]: Just briefly, your Honor.
+
+312
+
+C2grdau2 Brune - cross
+
+1 REDIRECT EXAMINATION
+
+2 BY MR. [REDACTED]:
+
+3 Q. Do you have Government Exhibit 28 in front of you, Ms.
+
+4 Brune?
+
+5 A. I might. Is it in one of these binders?
+
+6 Q. It should be. If not, we will certainly get you a copy.
+
+7 A. Let me look.
+
+8 Q. I think it might be in the folders.
+
+9 A. There is a tab that says 28. Let me take a look.
+
+10 Q. I don't know if those are the defense or the government
+11 exhibits.
+
+12 A. This is probably not it. I have it.
+
+13 Q. Do you recognize that document?
+
+14 A. I do indeed.
+
+15 Q. It's your July 21st letter at the Court, correct?
+
+16 A. That's correct.
+
+17 MR. [REDACTED]: Your Honor, the government moves to admit
+18 Government Exhibit 28.
+
+19 THE COURT: Any objection?
+
+20 MR. SHECHTMAN: No objection.
+
+21 THE COURT: Government Exhibit 28 is received in
+22 evidence.
+
+23 (Government's Exhibit 28 received in evidence)
+
+24 Q. If you could, Ms. Brune, turn to the Westlaw report that is
+25 attached as an exhibit.
+
+1 A. OK. 2 Q. You have 3 report prior 4 A. Yes. Q. I'd like MR. scope. THE COURT: Overruled. Q. The top of it says Catherine M. Conrad, correct? A. Yes, it does. Q. That is the identical name that was provided to your firm with the jury list at the very beginning before voir dire ever started, correct? 5 6 7 8 9 10 11 12 13 14 A. 15 Q. 16 A. 17 Q. 18 A. 19 Q. 20 A. 21 O. 22 23 24 O. 25 A. had a chance, I take it, to review this Westlaw to this very moment, correct? to take you through it very briefly. GAIR: Objection, your Honor. Way beyond the That's right. It has the year of birth of 1969, correct? I'm sure you're right. I'm going front page. OK. Do you see that? It says that the person's age is 41. It also has a year of birth 1969? MR. SHECHTMAN: Objection. THE COURT: It's redacted in the exhibit. Very well. It has her age? It does.
+
+1 Q. Further down, under "Addresses" it has a Bronxville 2 address, correct?
+
+3 A. At the top it has the Bronx address. Then there are a
+
+4 whole bunch of other addresses, including the Bronxville
+
+5 address.
+
+6 Q. If you turn the page, there arc listings of various
+
+7 lawsuits, correct?
+
+8 A. I am now on page 2, and you're right, there are some
+
+9 lawsuits listed there.
+
+10 Q. Including one that relates or has listed a Bronxville 11 address, correct, under New York docket judgment at the bottom 12 there on page 2?
+
+13 A. Yes.
+
+14 Q. If you turn to what's numbered as page 9, it's a couple of 15 pages in, do you see there is a head of household description 16 on that page?
+
+17 A. Yes.
+
+18 Q. One of the people that's listed as an individual in the 19 household is Robert J. Conrad, correct?
+
+20 A. Not under "Head of Household." But where it says
+
+21 "Additional Individuals," it has "Robert J. Conrad, spouse."
+
+22 Q. Spouse, correct?
+
+23 A. Right.
+
+24 Q. You know now, looking at the email traffic from May 12th, 25 that Ms. Trzaskoma had identified Robert J. Conrad as an SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 immigration judge, her father, correct?
+
+2 A. I certainly read that in the email that we produced.
+
+3 Q. That's what the email says, correct?
+
+4 A. That's what the email says.
+
+5 Q. Going to page 11, it has information from the New York
+
+6 State Office of Court Administration, correct?
+
+7 A. It does.
+
+8 Q. It references license status as a suspended attorney,
+
+9 correct?
+
+10 A. Yes, it does.
+
+11 Q. You have just testified on cross-examination that you
+
+12 didn't think you had anything to investigate about her,
+
+13 correct?
+
+14 A. That's right.
+
+15 Q. If you had seen this Westlaw report on May 12th, you would
+
+16 have thought you had something to investigate, correct?
+
+17 A. I didn't, but I have to say that I don't believe it would
+
+18 have changed what happened here. By that I mean that this
+
+19 thing to me, without having any particular expertise in these
+
+20 things, looks like it flushed two people with the same name
+
+21 together. I was convinced that she was the Bronxville
+
+22 stay-at-home wife and not the suspended lawyer.
+
+23 (Continued on next page)
+
+24
+
+25
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Q. And none of these pieces of information would have been 2 important to you, is that what you're saying? 3 A. What I'm saying is, is this thing to me looks, and I think 4 would have looked had I seen it at the time, as kind of like a 5 credit report, and I think it would have confirmed what I 6 thought I already knew, which is that there were two people who 7 had the same name. Now that we know the truth, it seems like 8 this is information that could point the other way, but I think 9 if I had it I wouldn't have seen it as changing the picture 10 that we had.
+
+11 Q. And you wouldn't have chosen to investigate?
+
+12 A. I would not. 13 Q. Despite your training as an AUSA conducting many Grand Jury 14 investigations?
+
+15 A. That's right.
+
+16 No further questions.
+
+17 MR. SCHECTMAN: Just one, Judge.
+
+18 RECROSS EXAMINATION
+
+19 BY MR. SCHECTMAN: 20 Q. Ms. Brune. the Social Security numbers are redacted from 21 that document, am I correct?
+
+22 A. That's correct.
+
+23 Q. Have you had a chance to look at the unredacted version?
+
+24 A. Yes.
+
+25 Q. And what have you learned about the Social Security
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1212) 805-0300
+
+C2GFDAU3 Brune - recross
+
+1 numbers? 2 A. The thing has something that said fraud alert and it 3 indicates that there were two Social Security numbers, and so, 4 of course I'm just testifying about what I would have thought, 5 but I thought that would be consistent with what I thought I 6 knew, that there were two people floating around with the same 7 name.
+
+8 MR. SCHECTMAN: Thank you. 9 THE COURT: Anything further, : No, your Honor.
+
+11 THE COURT: Ms. Brune, I have a question for you. 12 Would your firm have disclosed the information in your firm's 13 July 21 letter and the investigation into Juror No. 1 if the 14 Court had not inquired or the government failed to raise the 15 waiver issue?
+
+16 THE WITNESS: I don't think we would have, your Honor. 17 And as I think about it, we have an ethical obligation to be 18 accurate and honest, and it's something that we take very 19 seriously. But I don't think that we're obliged to identify 20 arguments that the government might make in our opening brief. 21 I mean, when we go through the case law, of course, we have to 22 say the authority and then if we think there's contrary 23 authority out there we have to stale that, but as I said to the 24 Court on the call, I kind of assumed it was coming and I was 25 going to respond accurately. So I didn't spend a lot of time SOUTHERN DISTRICT REPORTERS, P.C.
+
+12
+
+16 17 18
+
+20 21 22
+
+25
+
+1 sure I completely understand your question, but the point is, 2 if it became an issue I of course would lay out the accurate 3 facts.
+
+4 THE COURT: But then how would the Court or the 5 government have anticipated that your firm had knowledge about 6 certain matters if you didn't disclose it?
+
+7 THE WITNESS: Well, the way that it came up, Judge, is 8 that the government said something like, well, anybody can see 9 that if you Google this it comes up. And it was sort of lying 10 there right on the surface, that if you Google it, it comes up. 11 And that's why I said to the Court that I assumed it was going 12 to come up. But I didn't think I was supposed to make 13 arguments if the government wasn't going to make it.
+
+14 It would have been a different matter if we had 15 knowledge. We didn't know. I didn't think it was a 16 meritorious argument or an issue that in any way undercut the 17 application that we made. But if the government wanted to 18 raise the argument and it was sort of their choice, then we 19 followed that wherever it led.
+
+20 I mean, I really thought that the government had 21 Googled too, and that we were in the same place with respect Co 22 Juror No. 1. But the government clearly Googled her at the 23 point that they received the letter. So it was not like it was 24 some mysterious thing that one can conduct a Google search on 25 this juror. I did not know about the Westlaw report at the
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+320
+
+C2GFDAU3
+
+Brune - redirect
+
+1 time that I took that approach. I don't think it changes the
+2 picture because I don't think the Westlaw report itself has the
+3 picture. But what I had in making this decision was I figured
+4 they'd Googled, I Googled. I figured they didn't think she was
+5 a suspended lawyer based on the Google search and the note to
+6 the Court. I didn't think it was the suspended lawyer. But I
+7 figured if they were going to raise the Google issue, I'd lay
+8 it out.
+
+9 THE COURT: Did you ever consider consulting with the
+10 government about the [REDACTED] possibility that Juror No. 1 was in
+11 fact a suspended lawyer, given your testimony right now that it
+12 was your assumption that the government was also looking into
+13 jurors on the internet?
+
+14 THE WITNESS: I did not. I think that the government
+15 and I come to different conclusions sometimes about things, but
+16 I know --
+
+17 THE COURT: Why not? Why not? If you knew that -- if
+18 it was your assumption that they were expending the same kind
+19 of resources researching the matter as you were.
+
+20 THE WITNESS: I'm a little bit in a zone where I'm not
+21 describing my thought processes, because I didn't think about
+22 raising it with the government. But what I'm trying to say is
+23 I assumed that the government and its paralegals and all the
+24 rest Googled the jurors and I don't always agree with them, but
+25 they're pretty good investigators and they have access to more
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+C2GFDAU3 Brune - redirect 1 information than I do, so I figured if they thought there was 2 something to it, they'd raise it. 3 So I didn't think, II, wow, here's the Google search 4 and here's the note, let me bring this to the government's 5 attention. I thought the government had the same thing that we 6 had.
+
+7 THE COURT: All right. Anything further? 8 MR. OKULA: No, your Honor, not with respect to this 9 witness. But before we go on to the next witness, I just want 10 to make a representation to the Court and I'd be happy to set 11 forth in a declaration if the Court requires, but Ms. Brune in 12 the end of her testimony was I think speculating about what the 13 state of the government's knowledge was and what we were doing 14 after we received the note.
+
+15 As a matter of fact, Judge, we didn't think that on 16 the face of the note that it suggested Brady or any violation. 17 We turned it over nonetheless, but we didn't conduct any 18 independent investigation after we got the letter because we 19 viewed it as pretty much innocuous. So to the extent that 20 Ms. Brune was speculating that I assume or I think or I 21 believed the government was doing its own Google research and 22 found the same thing in fact that is not true. The first time 23 we found out about it was when we saw the motion that the 24 defendants filed.
+
+25 THE COURT: All right. Anything further, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+C2GPDAU3 Brune - redirect
+
+1 Mr. Schectman?
+
+2 MR. SCHECTMAN: No, your Honor.
+
+3 THE COURT: All right, Ms. Brune, you are excused as a 4 witness. You may step down.
+
+5 (Witness excused)
+
+6 THE COURT: Would the government call its next
+
+7 witness.
+
+B N.R. OKULA: Yes, your Honor. United States calls
+
+9 Laurie Edelstein.
+
+10 LAURA EDELSTEIN,
+
+11 called as a witness by the Government,
+
+12 having been duly sworn, testified as follows:
+
+13 THE COURT: Take a seat. State your full name, spell
+
+14 your last name slowly for the court reporter.
+
+15 THE WITNESS: Laura Joy Edelstein.
+
+16 THE COURT: You may inquire, Mr. Okula.
+
+17 N.R. OKULA: Thank you, Judge Pauley.
+
+18 DIRECT EXAMINATION
+
+19 BY N.R. OKULA:
+
+20 Q. Good morning Ms. Edelstein.
+
+21 A. Good morning.
+
+22 Q. Would you agree with me that if a lawyer in the course of a 23 jury selection or during a trial forms a belief that a Jury has 24 engaged in misconduct that that lawyer is under the obligation
+
+25 to bring it to the attention of the Court?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1212) 805-0300
+
+1 A. Yes. 2 Q. Is it not true, Ms. Edelstein, that on May 12, Theresa 3 Trzaskoma, your partner, came to you and articulated to you her 4 belief about possible juror misconduct by Juror No. 1? Yes or 5 no? 6 A. No. 7 Q. Did Ms. Trzaskoma tell you that she had sent an e-mail 8 earlier that day to the effect that Jesus, I think she's the 9 one, meaning that she thought Juror No. 1 was the suspended New 10 York attorney. Did she tell you that? 11 A. No. 12 Q. Did you learn that at any point during the conversation 13 with her? 14 A. No. 15 Q. Would you be surprised, Ms. Edelstein, if Susan Brune, your 16 partner, described you earlier in her testimony today as a 17 person who when confronted with an issue, you're someone who 18 demands the paper, wants to look at the underlying documents. 19 Is that fair? 20 A. Yes. 21 Q. So when Theresa Trzaskoma came to you, tell us your best 22 recollection what she said to you? 23 A. I can't recall exactly. It was after Court that day on 24 May 12th. We were walking across -- 25 Q. We being?
+
+1 A. -- the plaza. Susan Brune, Theresa Trzaskoma and I were 2 walking across Centre Street and I recall that Theresa said she 3 just wanted to let us know that after receiving the note that 4 we had received from Juror No. 1, which raised certain legal S concepts, she had recalled that there was a suspended lawyer 6 with the same name. 7 Q. And had you previously been aware of the discovery by your 8 firm of the report relating to the suspended New York lawyer? 9 A. No. 10 Q. Did you ask Ms. Trzaskoma what she saw, what piece of paper 11 or what information she saw that led her to understand that 12 there was information relating to a suspended New York 13 attorney? 14 A. As far as I recall, she had just mentioned that during voir 15 dire she knew that there was a suspended lawyer with the same 16 name. I didn't realize that there was any piece of paper or 17 particular document at the time. 18 Q. But you just agreed that you were a person who asked for 19 the paper when an issue comes up, right? 20 A. Yes. 21 Q. Okay. 22 A. I didn't realize that there was a paper here that I should 23 be asking about. 24 Q. At what point did you ask Ms. Trzaskoma to show you the 25 paper concerning what formed her belief about the New York SOUTHERN DISTRICT REPORTERS, P.C.
+
+325
+
+C2GFDAU3 Edelstein
+
+1 attorney?
+
+2 A. I don't believe she had formed a belief about the New York 3 attorney. She mentioned that there was an attorney, a 4 suspended attorney with the same name, and that after having 5 received the note from Juror No. 1 that mentioned several legal 6 concepts, she had thought that could it possibly be they were 7 the same person.
+
+8 Q. And at what point did you ask Ms. Trzaskoma for the 9 evidence, the underlying documents or information that led her 10 to believe that there was a possible connection between Juror 11 No. 1 and the suspended New York attorney?
+
+12 A. I didn't realize that there was a document that she was 13 basing any belief on. it was the fact that there was a 14 suspended lawyer with the same name.
+
+15 Q. Well, didn't you ask how did you form this belief or what 16 did you look at to see that there was a suspended New York 17 attorney? Did you ask that question?
+
+18 MR. GAIR: Objection. Three questions. Compound. 19 THE COURT: Overruled.
+
+20 A. No, I did not.
+
+21 Q. So do you mean to tell us that you at no point asked
+
+22 Theresa Trzaskoma for what underlying information she saw that 23 led her to believe that there was a possible connection between 24 Juror No. 1 and the suspended New York attorney? Yes or no.
+
+25 A. I'm not sure that was a yes or no question, but she
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 mentioned there was a suspended lawyer with the name of 2 Catherine Conrad. The connection that I think she was drawing 3 was that we had received a note from Juror No. 1 that raised 4 certain legal concepts, and that was the connection. I did not 5 ask what the basis was for knowing that there was a suspended 6 lawyer named Catherine Conrad, no, I did not. 7 Q. Wasn't that a highly significant fact to find out that 8 there was a suspended New York attorney with the same name as 9 Juror No. 1? 10 A. Actually, my reaction was it was, I thought it was 11 impossible that they would be the same person based on Juror 12 No. l's voir dire responses. 13 Q. It is correct, is it not, that if you have two people with 14 similar names that you can do simple, take simple steps to try 15 to increase or decrease the possibility that the two people 16 were the same one. Would you agree with me? 17 A. Hypothetical, if that's what you were doing in a different 18 situation. We were discussing the fact that there was a 19 suspended lawyer with the name of Catherine Conrad. We then 20 were discussing that Juror No. 1 on voir dire in response to 21 the unambiguous question what is your highest level of 22 education said that she had a BA in English. To me that ruled 23 out the possibility that they were the same person. 24 Q. Ms. Edelstein, could you just answer my question that 25 asked? Are there steps that you can take if you have one SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 Catherine Conrad, you have another Catherine Conrad. Can you 2 take some simple steps to try to investigate and look tc see 3 whether they're the same people? Can you do that?
+
+4 A. Yes.
+
+5 Q. And how about this: Can you look to see if they have a 6 similar middle initial? Do you think that that increases the 7 likelihood that you're going to narrow the chances that it's 8 the same people? Would you agree with me that that's the case?
+
+9 A. I mean, if you have the tools. I guess I'm not quite sure 10 what you're asking. If you're doing an investigation, yes, you 11 can look to see whether they have the same middle initial. 12 Q. Did you ask Theresa Trzaskoma what's the middle initial for 13 the suspended New York attorney?
+
+14 A. No, I did not.
+
+15 Q. Did you -- well, withdrawn. You were aware, were you not, 16 that your firm was in possession of the information showing 17 that Juror No. 1 was Catherine with middle initial M. Conrad, 18 correct?
+
+19 A. No, I was not aware of that.
+
+20 Q. So are you telling me that when Theresa Trzaskoma gives you 21 these two different names or two similar names, Catherine
+
+22 Conrad and Catherine Conrad, you didn't suggest to her any 23 steps that she could take to try to determine whether it's the 24 same person?
+
+25 A. No. We discussed Juror No. I's responses to the voir dire, SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 which was the information that we had and Ms. Conrad had 2 unambiguously stated that she had a BA in English literature, 3 that that was her highest level of education, that she was a 4 stay-at-home wife, and I assumed that Ms. Conrad was telling 5 the truth when she responded on voir dire.
+
+6 It just was inconceivable to me that she was the same 7 person. I wasn't thinking about middle initials. I know that 8 in hindsight we now know that they're the same person and that 9 they have the same middle initial, but at the time I had no 10 idea that Juror No. l's middle initial was M. 11 Q. Theresa Trzaskoma didn't tell you that the report that she 12 had seen on either e-mail or otherwise had the middle initial 13 with M. for Catherine M. Conrad, the suspended New York 14 attorney?
+
+15 A. Ms. Trzaskoma did not mention any report.
+
+16 Q. Did Ms. Trzaskoma mention to you the Westlaw printout that 17 she had seen that had various biographical information for 18 someone named Catherine M. Conrad?
+
+19 A. No.
+
+20 Q. Did you ask Ms. Trzaskoma for any of the underlying 21 documents that led to her belief that Juror No. I may be the 22 same Catherine M. Conrad who was a suspended New York attorney? 23 Yes or no, did you ask for any documents?
+
+24 A. I did not ask for any documents, no.
+
+25 Q. How long did this conversation between you and Ms.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Trzaskoma take?
+
+2 A. Five minutes. 3 Q. And I think you said earlier, let me take you through this 4 again, that Ms. Trzaskoma articulated something to the effect 5 of, correct me if I'm wrong, that she just wanted to let you 6 know that she saw the suspension report. Is that fair?
+
+7 A. No. I think what she said was she wanted to let us know 8 that after thinking about the note that we had received from
+
+9 Juror No. 1 she had recalled that there was a suspended lawyer 10 with the same name and that she had wondered whether it was
+
+11 possible that they were the same person.
+
+12 Q. Did she say anything else to you? 13 A. Well, we then discussed Juror No. l's responses on voir 14 dire and after that discussion my response was there's no way 15 they're the same person.
+
+16 Q. So how would you describe the level of knowledge that Ms.
+
+17 Trzaskoma had when she came to you with respect to her degree 18 of certainty that Juror No. 1 was the Catherine M. Conrad in 19 the suspension report?
+
+20 A. I think that she had thought that there was a possibility 21 that they were the same person, but she had reviewed the voir 22 dire responses and they were entirely inconsistent with her 23 being a lawyer.
+
+24 Q. Well, did she tell you, did Ms. Trzaskoma tell you that 25 earlier that day she had reviewed the voir dire responses but
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+had subsequently looked at a Westlaw report that led her to 2 send an e-mail to somebody else in your firm saying, "Jesus, I 3 think this is the one," meaning Juror No. 1 was the Catherine 4 M. Conrad the suspended attorney? Did she tell that you? A. No. 6 Q. Did you learn of the Westlaw report during the conversation 7 with her? 8 A. No. 9 Q. At what point did you learn about the Westlaw report 10 conversation? 11 A. I learned about the Westlaw report 12 O. I'm sorry the report? 13 A. After we received the letter and jury verdict. 14 O. Before the July -- 15 A. By the letter 1 mean the letter that was written in May and 16 received on June 20. 1/ Q. Did you review the Westlaw report before Theresa Trzaskoma 18 participated in the court conference on July 15? 19 A. Yes. 20 Q. Did you yourself notice the similarities between the 21 address for Catherine M. Conrad, Juror No. 1, the existence of 22 a personal injury report, same name for her father? Did you 23 note those things? 24 A. When -- 25 Q. Did you note those things?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. I'm not sure I understand -- 2 MR. SCHECTMAN: May I be heard? I object to same name 3 for her father. No one knew her father's name, so I object to 4 that.
+
+5 MR. OKULA: I'll rephrase it, your Honor.
+
+6 THE COURT: Very well.
+
+7 Q. You reviewed the Westlaw report, correct?
+
+8 A. Yes.
+
+9 O. Did you discuss it with Susan Brune?
+
+10 A. No.
+
+11 Q. Did you discuss it with Theresa Trzaskoma?
+
+12 A. No.
+
+13 O. Whom did you discuss it with?
+
+14 A. I discussed it with my partner, Randy III in San Francisco.
+
+15 Q. Did Mr. III tell you about the e-mail exchanges that he had 16 had with Theresa Trzaskoma earlier on May 12th that led Ms.
+
+17 Trzaskoma to conclude that Juror No. 1 was the suspended
+
+19 attorney?
+
+19 A. I discussed several of the e-mail exchanges, but he was
+
+20 only on a number of them.
+
+21 Q. Did you see the May 12 series of e-mail exchanges involving
+
+22 Theresa Trzaskoma including the Jesus e-mail before Theresa
+
+23 Trzaskoma took part in the July 15 court conference?
+
+24 A. No.
+
+25 O. When did you see that e-mail?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. Subsequent to the July 15th conference.
+
+2 Q. Can you put a date on that?
+
+3 A. Actually, I'm not sure when I first saw it. I was informed 4 about it I think July 20th or so. I'm not sure.
+
+S Q. So Theresa Trzaskoma never told you about the Jesus e-mail 6 prior to her participation in the July 15th conference, is that 7 fair?
+
+8 A. Yes.
+
+9 Q. Did Theresa Trzaskoma tell you that a dossier had been 10 created at her request with respect to Catherine Conrad when 11 she was gathering information on May 12?
+
+12 A. After we received the letter from Juror No. 1 on June 20th,
+
+13 I had a conversation with Theresa Trzaskoma where she mentioned 14 that there was some information that had been gathered.
+
+15 Q. And you said in response to that what?
+
+16 A. I asked where it was and she was actually overseas at the 17 time and didn't have access to the computer, so she didn't,
+
+18 wasn't sure exactly what, the file that was there, what had 19 been gathered, but she let me know where I could try to find 20 it.
+
+21 Q. Just so we're clear, what date is this?
+
+22 A. I believe the night of June 20th.
+
+23 Q. And is it fair to say that you received the dossier?
+
+24 A. I wouldn't characterize it as a dossier, but the next day I 25 was directed to the memo that David Benhamou our paralegal had SOUTHERN DISTRICT REPORTERS, P.C.
+
+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 rile or 7 the memo to file by David Benhamou, is that correct?
+
+B 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. T 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.
+
+IS Q. And the memo said what?
+
+16 A. It just laid out I think Juror No. l'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 61 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.
+
+(2121 805-0300
+
+1 A. I don't believe the suspension report has a Bronxville 2 address. If you're referring to the Appellate Division. 3 Q. Did you look at the Westlaw report? 4 A. Yes. 5 O. And did you notice the Bronxville address in the Westlaw 6 report? 7 A. There was a Bronxville address listed somewhere in the B Westlaw report. 9 O. And did you note a reference to someone that had been 10 identified by your firm previously as having the same name as 11 the father of Catherine Conrad, immigration judge? 12 A. I'm not sure what you're referring to as someone having 13 been identified earlier. There was, I think there was a 14 mention -- well, I don't know that in the report there's a 15 mention of any father. I think that there's talks about head 16 of household of a house that was owned and it lists two people. 17 I didn't know who Catherine Conrad's father was. 18 Q. That was Robert Conrad, is that correct, the one you saw 19 was head of household? 20 A. That's correct. 21 Q. And when you saw the e-mail traffic at some point, did you 22 see there was a reference by people in your firm who had 23 referred to Robert Conrad in the e-mail traffic? 24 A. Later on when I saw the e-mail exchange. 25 0. And those e-mail exchanges existed during the course of the SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 trial, correct? 2 A. Yes. 3 Q. Do you remember who was on those e-mail exchanges that 4 identified Robert Conrad as the father? 5 A. I believe Theresa Trzaskoma and David Benhamou. 6 Q. Were you informed of that at the time? 7 A. No. 8 Q. By the way, what was your role, what was your principal 9 duty in connection with the trial, the defense of David Parse? 10 A. I don't know that I had a principal role. I was involved 11 in various parts of it. I focused on the opening and the 12 closing statements, the expert testimony, several of the 13 witnesses. 14 Q. Voir dire? 15 A. No. 16 Q. Did you assist in voir dire? 17 A. No. 18 Q. Not at all? 19 A. Well, I participated in a couple of meetings where jurors 20 were discussed prior to voir dire and then my role really at 21 that time was to focus on the opening statement. 22 Q. Now, you received the dossier from, well, the link to the 23 dossier and examined it, are you saying after you received a 24 copy of the Catherine Conrad letter? 25 A. 7 wouldn't characterize it as a dossier. I received the SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 memo that had been put together and the link to the Westlaw 2 report after we received the letter from Catherine Conrad. 3 Q. And did you discuss it with Susan Brune? 4 A. Discuss what? 5 O. The Westlaw report and your examination of it as well as 6 your examination of the suspension report. 7 A. I believe I -- well, the suspension report, if you mean the 8 Appellate Division order? 9 O. Yes. 10 A. I believe I discussed the Appellate Division order. I did 11 not discuss the Westlaw report with her. 12 Q. What was the nature of your discussion with her? 13 A. Well, I believe that after we received the June 20th 14 letter, I first had a conversation with Susan just upon receipt 15 of the letter and reading it and the substance of it, you know, 16 I was very disturbed by the letter. This has nothing to do 17 with Catherine Conrad being the suspended lawyer because at 18 that point I didn't know. When I first received the letter I 19 was sort of, I was disturbed and shocked by it. We had spent 20 three months in the courtroom where everyone wants to know what 21 the jury is thinking about various subjects. We then receive a 22 letter that gives us some insight into the jury deliberations 23 and I was very taken aback by some of the things that she said. 24 I felt that we had sat here trying to read the tea leaves with 25 various juror notes on the one hand and it was just very
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 surprising and shocking to hear what a member of the jury had 2 to say.
+
+3 I think when I first called Susan, we spoke about the
+
+4 letter and that was our first conversation of that letter.
+
+5 O. And in that first conversation did you and Ms. Brune
+
+6 discuss the feeling that what had been -- or after you received
+
+7 the letter or reviewed the other document, that that related to
+
+8 the exact same issue that Theresa Trzaskoma related to you on
+
+9 May 12. When did you put that together?
+
+10 MR. GAIR: Objection to the form of the question.
+
+11 Unintelligible.
+
+12 THE COURT: Sustained as to form.
+
+13 O. At some point did you connect the dots as to what Theresa
+
+14 Trzaskoma told you on May 12 and the jury letter that you
+
+15 received?
+
+16 A. What happened next was that it took me, I sat in my office
+
+17 for a while mulling over the letter. I then was speaking later
+
+18 that afternoon with my partner Randy III in our San Francisco
+
+19 office. I mentioned I found the note, the letter, it was very
+
+20 disturbing to me. The tone was very odd, there arc all these
+
+21 exclamation points, the underlining, the parentheticals with
+
+22 her speaking to herself, commenting on her own words, and it
+
+23 just seemed so at odds with what I had observed of Juror No. 1
+
+24 during the trial.
+
+25 He's the one who mentioned to me, he said, well, come
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 to think of it, at one point we knew there was a suspended 2 lawyer with the same name, and it was only at that point that I 3 recalled any conversation I had had about the suspended lawyer, 4 and I was sitting at my computer. I put the name Catherine S Conrad into Google and I pulled up the Appellate Division 6 orders. 7 Q. Did you tell Randy III, by the way, that refreshes my 8 recollection Theresa Trzaskoma cold me the same thing on 9 May 12th? 10 A. Well, that's not exactly what Theresa had said, but I -- 11 Q. Did you say to him in substance that, yes, Theresa had told 12 me something to that effect on May 12? 13 A. No. I was -- I looked at the Google search and then opened 14 up the Appellate Division order, I think the 2010 order, and 15 that was the first time I had seen it. 16 O. And that led you to do what? 17 A. So I then said, you know, I said, well, you know, here's a 18 suspended lawyer with the name Catherine Conrad. I went to the 19 New York State 8ar Association registration site and put in the 20 name Catherine Conrad and pulled up the registration 21 information. 22 Q. Which showed? 23 A. Which showed an address in the Bronx and then it had a 24 phone number, a 646 number and I looked at the letter and 25 couldn't believe it but there was the Parkview Drive address in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 Bronxville, but the same phone number. 2 Q. You would agree with me, would you not, that that's the 3 very same computer research over the course of a couple of 4 minutes that you could have done on May 12th, right? 5 A. Well, one could have done that on May 12th. We didn't have 6 Ms. Conrad's phone number on May 12. 7 Q. So the answer is yes, you could have done that research on 8 May 12th, right? 9 A. I could have done a Google search -- 10 Q. Was there something unintelligible about my question? 11 M.R. SCHECTMAN: There's nothing unintelligible about 12 the answer, if you would allow the witness to finish. 13 THE COURT: Overruled. 14 Q. Could you answer? Could you have done that research on 15 May 12? 16 A. No. I can explain. 17 Q. Well, you were informed there was a Catherine Conrad 18 suspension report by Theresa Trzaskoma, correct? 19 A. No. 20 Q. Didn't Theresa Trzaskoma tell you that she had seen 21 evidence that there was a suspended New York attorney named 22 Catherine Conrad? Didn't you just tell that to us a few 23 minutes ago? 24 A. No. What f said was she had told me there was a suspended 25 lawyer with the name Catherine Conrad. She did not mention a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 suspension report, she did not characterize it in that way. 2 All she said was there was a suspended lawyer with the name 3 Catherine Conrad. 4 Q. And you asked nothing of her on what facts she had that 5 demonstrated that to her? 6 A. No, I didn't. 7 Q. And is it correct that Ms. Trzaskoma asked you or threw out 8 the possibility of doing further research on this Catherine 9 Conrad that she had found information about? 10 A. I'm sorry, I'm not sure I understand the question. 11 O. Did she ask whether anything more should be done to look 12 into this? 13 A. We discussed after she raised the issue with us, you know, 14 what Juror No. l's responses were on voir dire. We concluded 15 that we did not believe they were the same person and we 16 decided that we didn't need to do any more research at that 17 point. 18 Q. Well, you say "we discussed." Tell us your best 19 recollection what was said. 20 A. I can't recall precisely what was said. I think what we 21 did was we reviewed what Catherine Conrad had said on voir 22 dire, what her responses were and to us that ruled out the 23 possibility that she was the suspended lawyer. It was just 24 inconceivable Co me that she was a suspended lawyer. Why would 25 she lie about her highest level of education?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1212) 805-0300
+
+1 O. 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 O. 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 O. 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 O. 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?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. Yes. 2 Q. Were you involved in the drafting of the facts section of 3 the brief? 4 A. I edited that section, yes. 5 Q. Now, by the way, did you have discussions with Susan Brune 6 or anyone else at the firm about whether people at your firm 7 were going to discuss with other defense counsel what Theresa 8 Trzaskoma had talked to you about on May 12th? 9 A. No 10 Q. Are you telling us that there was no discussion at all 11 about whether you were going to inform your co-counsel about 12 the facts that you had learned or Theresa Trzaskoma had learned 13 during voir dire and during, on or about May 12? 14 A. I don't recall any discussion about speaking with other IS defense counsel. 16 Q. Did you discuss with anyone at your firm about whether you 17 were going to reveal in the brief that you were going to submit 18 to the Court the facts that your firm were aware of that you 19 and Randy III talked about? 20 A. Yes, Susan Brune and I had a discussion. 21 Q. So you discussed about whether you should or should not 22 include in the facts section of your brief the facts that you 23 learned either during voir dire or on May 12 but prior to 24 receipt of the juror letter, correct? 25 A. Yes.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Q. Who initiated that discussion? 2 A. I can't recall who initiated it. I think Susan and I were 3 discussing the brief and how we should structure it, and -- 4 Q. Stop right there. Did that conversation occur before or S after you received the draft of the brief from Theresa 6 Trzaskoma? 7 A. Before. 8 Q. So you and Susan Brune then specifically discussed about 9 what you should say about your level of knowledge before you 10 received the note, is that correct? 11 A. Yes. 12 Q. And what was the ultimate decision that was made? 13 A. Well, after some discussion and then reviewing the case law 14 about the state of knowledge involved regarding the juror 15 misconduct issue and potential waiver, and seeing that actual 16 knowledge was the standard, we decided that the fact that we 17 knew that there was a suspended lawyer with the same name, we 18 did need to address that in the brief and that the focus of the 19 brief was to be on whether they were the same person, because 20 at that point T wasn't even sure they were the same person and 21 trying to convince everyone else they were the same person. I 22 didn't think people were going to actually believe us. 23 Q. You ultimately edited the fact section of the brief, 24 correct? 25 A. Yes.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 Q. In the brief, is it fair to say that the facts section 2 conveys the notion that you discovered or you commenced your 3 discovery and attained your knowledge of the Appellate Division 4 suspension report only after you received the letter of 5 Catherine Conrad? Yes or no? 6 A. I can see now that that might be the impression. 7 Q. Ms. Edelstein, I asked you a simple question. Weren't you 8 the one who stood at this podium and raised your voice with Dr. 9 DeRosa about him not answering your questions? Do you remember 10 Chat.? 11 A. Yes. 12 Q. Okay, can you answer my questions the way I asked them or 13 in response to my question? Would you do that, please? 14 A. Yes. 15 Q. Wouldn't you agree with me that the facts as laid out in 16 your brief convey the notion that you learned of the Appellate 17 Division report only after you received the juror note; true or 18 false? 19 A. I find that a difficult answer, question to answer true or 20 false. I can see now how that might be the impression that is 21 conveyed by the brief. 22 Q. And that -- 23 A. That certainly was not our intention at the time. I 24 certainly did not, we did not intend to create a misleading 25 impression. Our focus at the time was trying to show that
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 Catherine Conrad, Juror No. 1, was the suspended lawyer. It 2 took us two weeks to feel sure enough to even start writing the 3 brief that they were the same person. That's why the brief 4 goes through in excruciating detail the overlapping addresses, 5 the phone numbers, the data. I can see now in hindsight in 6 reading it that perhaps that is the impression that was 7 conveyed. 8 Q. And again you could see -- 9 A. But it was not the intent. 10 Q. You can see the impression or one reading of the impression 11 that's created is a false one, would you agree with me? 12 A. No. 13 Q. Well, the impression that's created in the brief is that 14 you learned of the suspension only after you received the 15 letter from the government, correct? 16 A. I think the brief can also be read in a different way. I 17 mean, if you start with the premise -- 18 Q. I'm sorry, it was a simple question. It was a simple 19 question. Doesn't the brief convey the notion that you learned 20 of the suspension report after you received the letter from. the 21 government, yes or no? 22 A. I can see now that it may be read that way, but that was 23 not the intent. 24 Q. Well, it was the intent because you and Ms. Brune had 25 specifically decided that you weren't going to include what you SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 knew beforehand in the brief, right?
+
+2 A. No, that's not accurate.
+
+3 O. Didn't you tell us a few moments ago that you and Ms. Brune 4 had specifically decided that you were not going to include 5 what your firm knew prior to receiving the government letter in 6 your brief, yes or no?
+
+7 A. Yes.
+
+8 Q. So are you saying, then, that you were not trying to convey 9 the notion through the facts section of your brief that you had 10 learned of the Appellate Division report only after you had 11 received the letter from the government?
+
+12 A. No, we weren't trying to convey that impression.
+
+13 MR. OKULA: May I have a moment, your Honor?
+
+14 THE COURT: Take your time.
+
+15 (Pause)
+
+16 Q. Could you turn to Government Exhibit -- I'm sorry, it's 17 defense Exhibit PMD 54. Do you recognize that document?
+
+18 A. Yes.
+
+19 Q. What is it?
+
+20 A. It's the brief that we submitted in support of the motion 21 for a new trial.
+
+22 Q. Can you explain, why does your firm sign it twice? In 23 other words, why do you include it on the front page separate 24 and apart from Susan Brune in New York and you in San
+
+25 Francisco?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+A. Simply because there are two different addresses. 2 Q. Now, could I ask you to look at page 32, footnote 13. And 3 specifically the last sentence of that footnote. Do you see 4 where it says, "Defendants had no basis to inquire whether 5 Conrad was lying in response to each of the Court's, 6 questions," do you see that? 7 A. Yes. 8 Q. Co you think that was an accurate statement, Ms. Edelstein? 9 A. Yes. 10 Q. Were you aware that Theresa Trzaskoma had been, had 11 discovered the Appellate Division suspension report at that 12 time with the name Catherine Conrad? 13 A. I was aware that Theresa, when we were writing the brief I 14 was aware that Theresa had known that there was an Appellate 15 Division order. 16 Q. And would you turn to page 9 and look at the first full 17 paragraph there. Would you read that first sentence aloud for 18 us? 19 A. "The tone and content of the letter, which were in sharp 20 contrast to the image Conrad had projected through the trial, 21 always head down, taking notes, caused defendants concern and 22 prompted them to investigate." 23 Q. Well, you were aware when that sentence went into the final 24 version of the brief, that Theresa Trzaskoma had already done a 25 bit of investigation, correct?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. Yes.
+
+2 Q. So would you agree with me that to the extent that that 3 sentence suggested that only after the letter was received did 4 you and the others begin investigating, it was untrue because 5 you knew Theresa Trzaskoma had previously done some 6 investigation?
+
+7 A. Someone might read that that way, but --
+
+8 Q. Can you answer --
+
+9 A. This is a truthful statement.
+
+10 Q. Can you answer my question, please? Yes or no? You just 11 acknowledged that Theresa Trzaskoma had previously done an 12 investigation, some of the results of which she reported to you 13 on May 12th, correct? Correct?
+
+14 A. On May 12th I knew that there was a suspended lawyer with 15 the same name.
+
+16 Q. That Theresa Trzaskoma had discovered pursuant to her 17 correspondence with others in your firm in that little mini 18 investigation, correct?
+
+19 A. I was not aware --
+
+20 MR. SCHECTMAN: Judge --
+
+21 THE COURT: Overruled.
+
+22 A. I was not aware on May 12th of any investigation.
+
+23 Q. Well, Theresa Trzaskoma didn't tell you that her
+
+24 information about the suspended lawyer came out of thin air, 25 did she?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 A. She didn't mention what the basis was. 2 Q. But she told you that she had learned of it, correct? 3 A. Yes. 4 Q. And is it fair that you inferred that she through her 5 Google search or some sort of investigation had learned that 6 fact? 7 A. Yes. 8 Q. So that's what led you just a moment ago to say you knew 9 that Theresa Tczaskoma had previously learned certain facts 10 pursuant to an investigation, right? 11 A. Well, no. What I was trying to distinguish was what I knew 12 on May 12th, versus what I knew by the time we were writing the 13 brief. 14 Q. Okay, and in this brief, the sentence that you just read 15 conveys the notion, does it not, that you learned of the facts 16 concerning the suspension and the other things only after you 17 received a note, correct? 18 A. Again, that's a difficult question to answer yes or no. 19 can see now how it might\_ be construed that way, but when it was 20 written, and I still believe it was accurate, that it's 21 describing what we did when we -- and I think it's what I 22 testified to earlier, that when I received the letter it caused 23 us concern and prompted us to investigate. We were describing 24 that. 25 I can see now with hindsight -- I see many things now SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 in hindsight with respect to this proceeding, but I can see 2 with hindsight now how it might be construed in the way you 3 have suggested. But at the time when we were writing it we 4 were describing what happened when we received the letter on 5 June 20th. 6 Q. Well, it was worded that way because you and Ms. Brune had 7 had a discussion previously about what you were going to omit 8 from this brief, right? 9 A. No. The discussion I had with Ms. Brune was whether or not 10 we were going to say that prior to voir dire we had information 11 that there was a suspended lawyer named Catherine Conrad. 12 Q. And you agreed -- 13 A. We discussed it in the context of what was the standard for 14 waiver, what was the standard for juror misconduct cases, which 15 was actual knowledge. I was not focused, when we were writing 16 the brief, I was not focused on waiver. We didn't know they 17 were the same person. We just were trying to actually 18 establish that they were the same person and that, it took me a 19 long time for me Co believe that they were the same person. 20 I really was not thinking about waiver. I know that 21 may be difficult for you to believe now when you're taking a 22 brief and looking at every sentence and trying to impart some 23 meaning to it or an impression that we were trying to create. 24 But that's not how we were writing it. 25 Q. Can you just answer the question that I asked? You just
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 said that you had a conversation with Susan Brune, yes or no? 2 A. Yes. 3 Q. Okay, and as a result of that discussion you decided what 4 you would omit from the brief, correct? S A. I wouldn't characterize it as omit. 6 Q. Okay, let's just stop there. You and Susan Brune discussed 7 the fact that you wouldn't include certain things you knew 8 about before the juror note in your brief, yes or no? 9 A. Yes. 10 Q. So isn't that a decision that you made with Susan Brune 11 about what you would omit from the brief, yes or no? 12 A. Yes 13 Q. So when you answered my questions a few minutes ago when I 14 asked you whether you decided with Susan Brune that you would 15 omit something, you said no. Was that an untrue answer before? 16 A. Well, I'm not sure if that was the exact question. I'm 17 not -- I'm not trying to lie here or give you a hard time. 18 These are difficult questions to answer. In looking back and 19 trying to figure out what the process was for writing this 20 brief, if I had to do it over again would I do it differently? 21 Yes. In hindsight should we have dropped a footnote saying 22 that we, you know, knew that there was a suspended lawyer with 23 the same name? If I had to do it over again I would certainly 24 do that. And I'm very sorry for any misimpression the brief 25 has created.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1 O. Well, would you agree with me that an omission can be 2 construed as a lie? 3 A. Yes. 4 Q. And the omissions that your firm made didn't end with 5 filing a brief, would you agree with me? 6 A. No. 7 Q. well, Theresa Trzaskoma participated in the phone call with 8 the Court on July 15, correct? 9 A. Yes. 10 Q. Are you aware that that phone conversation was going to 11 take place? 12 A. Yes. 13 Q. Did you talk with Theresa Trzaskoma before she participated 14 in that call? 15 A. No. 16 Q. Do you know if Susan Brune did? 17 A. I don't know. 18 Q. Do you know if anybody had a conversation with Theresa 19 Trzaskoma where it was discussed that she would not 20 affirmatively tell the Court about the facts that your firm 21 knew prior to the receipt of the letter? 22 A. No. 23 N.R. OKULA: Just one moment, your Honor. 24 (Pause) 25 MR. OKULA: I have nothing else, your Honor. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 THE COURT: Mr. Schect.man? 2 MR. SCHECTMAN: Yes, your Honor.
+
+3 CROSS-EXAMINATION
+
+4 BY MR. SCHECTMAN:
+
+5 Q. 12th at the end of the conversation 6 that you had on the plaza with Ms. Brune and Ms. Trzaskoma, why 7 didn't you bring information about there being a suspended 8 lawyer with the same name as Juror No. 1, why didn't you bring 9 that to the Court's attention?
+
+10 A. At some point during the conversation we had discussed 11 whether we should bring it to the Court's attention, but after 12 we discussed the issue and concluded that it was inconceivable 13 that Juror No. 1 was the suspended lawyer, we didn't see a 14 reason to bring the fact that there was a suspended lawyer with 15 the name Catherine Conrad to the Court's attention, that there 16 was nothing we were going to ask the Court to do at that point. 17 O. At any time were you trying to sandbag the Court or tamper 18 with the record?
+
+19 A. No.
+
+20 Q. At any time between the juror's verdict on May 24th and the 21 receipt of Ms. Conrad's post-trial letter on June 30, was there 22 any discussion in the Brune firm about raising a juror 23 misconduct issue as an issue on a post-trial motion?
+
+24 A. There was none.
+
+25 O. And why not?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+4212) 805-0300
+
+1 2 A. We didn't know and we didn't know that Juror No. I was the suspended lawyer we had a motion.
+
+3 Q. Any discussion of raising it as an appellate issue?
+
+4 A. No.
+
+5 Q. And why not?
+
+6 7 A. the suspended lawyer. For the same reasons. We didn't know that Juror No. 1 was
+
+8 N.R. SCHECTMAN: No further questions, your Honor.
+
+9 THE COURT: Mr. Okula?
+
+10 11 12 MR. OKULA: I'm waiting for the defense, but I see absence from here. May I ask one or two questions from, here, your Honor?
+
+13 THE COURT: You may.
+
+14 REDIRECT EXAMINATION
+
+15 BY MR. OKULA:
+
+16 17 18 Q. Do I understand you to just testify that you specifically discussed with Susan Brune and Theresa Trzaskoma in the park about whether you were going to bring it to the Court's
+
+19 attention or not?
+
+20 A. Yes.
+
+21 Q. And you decided you would not?
+
+22 A. Yes.
+
+23 24 Q. And the ultimate decision of that discussion was that you were going to call it off and not even do an investigation,
+
+25 right?
+
+C2GFDAU3 Edelstein - cross
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+C2GFDAU3 Edelstein - redirect
+
+1 A. Yes. 2 THE COURT: Mr. Schectman? 3 MR. SCIIECTMAN: And I take it because you thought it 4 was in conceivable that this was the same person. 5 THE WITNESS: That's right. 6 THE COURT: Anything further, Mr. Okula? 7 MR. OKULA: Nothing, thank you, your honor. 8 Just one housekeeping matter, your Honor? 9 THE COURT: We don't need housekeeping. 10 It's in regard to one of the exhibits we 11 want to move into evidence. 12 THE COURT: Let's complete the inquiry, 13 that's the way it proceeds. I have a few questions for the 14 witness.
+
+15 I apologize, your Honor. 16 THE COURT: Ms. Edelstein, I want to put a question to 11 you that I put to Ms. Brune. Focusing on the July 21 letter to 18 the Court, would your law firm have disclosed the information 19 set forth in that letter and the investigation of Juror No. 1 20 if the Court had not inquired or the government failed to raise 21 the waiver issue?
+
+22 THE WITNESS: I think by that point, I mean, I think 23 yes, that we had thought that it would come out at some point 24 during
+
+25 (Continued next page)
+
+C2grdau4 Edelstein
+
+1 THE COURT: No. My question is not whether it would 2 have come out. If It had not come out, if the Court had not 3 pressed your law firm and the government failed to raise the 4 issue, would your law firm have disclosed the information set forth in the July 21 letter?
+
+6 THE WITNESS: I don't know.
+
+7 THE COURT: Did you ever have any discussion with 8 anyone in the firm about that?
+
+9 THE WITNESS: I think that our, at least my, frame of 10 mind was that we didn't know they were the same person, so I 11 just didn't think that there was a waiver issue.
+
+12 THE COURT: In the middle of jury deliberations, this
+
+13 Court displaced Juror No. 11 because of a health emergency, 14 replaced him with an alternate after much discussion with 15 counsel and over the objection of the government, and directed 16 the jury to restart its jury deliberations. Did you give any 17 consideration at that time to raising the issue that you 18 discussed in the park on . Brune and Ms.
+
+19 Trzaskoma regarding Juror No. 1?
+
+20 THE WITNESS: No. I continued to believe that Juror
+
+21 No. 1 was who she said she was. That didn't occur to me, no.
+
+22 THE COURT: Any further inquiries?
+
+23 MR. OKULA: May I follow up on one or two questions,
+
+24 your Honor?
+
+25 THE COURT: Yes.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+C2grdau4 Edelstein
+
+1 BY MR. OKULA:
+
+2 Q. Do you mean to say that if the government hadn't asked and 3 the Court hadn't asked, you were comfortable from an ethical
+
+4 and a professional standpoint to have the judge decide the S motion without ever learning the facts about what Theresa
+
+6 Trzaskoma and you and Susan Brune and the others knew at the 7 firm prior to receiving the government note? Is that what you 8 are saying?
+
+9 THE WITNESS: I find this a difficult question to 10 answer trying to put out of my mind all the things I now know 11 and where we are. I firmly believe that. the standard is actual 12 knowledge. We just didn't know they were the same person.
+
+13 MR. OKULA: Let me try again. From a professional and 14 ethical standpoint, are you saying that you would have felt 15 comfortable that you had fulfilled all your obligations if the 16 Court had decided this motion without learning of the facts 17 concerning what your firm knew prior to receiving the Catherine 18 Conrad letter? Yes or no.
+
+19 THE WITNESS: Yes.
+
+20 MR. OKULA: Nothing further, Judge.
+
+21 THE COURT: Anything further?
+
+22 You are excused, Ms. Edelstein.
+
+23 (Witness excused)
+
+24 THE COURT: Would the government call its next.
+
+25 witness.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+C2grdau4
+
+1 MR. OKULA: Your Honor, we have no other witnesses. 2 As a housekeeping matter, I'd like to move into evidence 3 Government Exhibit 10. And we rest at that point. 4 THE COURT: Any objection to Government Exhibit 10? 5 MR. SKLARSKY: No, your Honor. 6 MR. ROTERT: No, your Honor. 7 MS. McCARTHY: No objection. 8 MR. SHECHTMAN: None, Judge. 9 THE COURT: Government Exhibit 10 is received in 10 evidence. 11 (Government's Exhibit 10 received in evidence) 12 THE COURT: Mr. Shechtman, do you have evidence to 13 offer the Court? 14 MR. SHECHTMAN: T. do, Judge, two witnesses. It should 15 be short. 16 THE COURT: Would you call your first witness. 17 MR. SHECHTMAN: Defendant Parse calls Paul Schoeman. 18 PAUL SCHOEMAN, 19 called as a witness by defendant Parse, 20 having been duly sworn, testified as follows: 21 THE COURT: State your full name and spell it for the 22 court reporter. 23 THE WITNESS: My name is Paul Schoeman, 24 S-C-H-O-E-M-A-N. 25 THE COURT: You may inquire, Mr. Shechtman. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
\ No newline at end of file
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diff --git a/marker2/court-us-v-maxwell-cr/EFTA02837905/EFTA02837905.md b/marker2/court-us-v-maxwell-cr/EFTA02837905/EFTA02837905.md
new file mode 100644
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+++ b/marker2/court-us-v-maxwell-cr/EFTA02837905/EFTA02837905.md
@@ -0,0 +1,2212 @@
+359
+
+C2grdau4
+
+1. 1 MR. SHECHTMAN: Thank you, Judge.
+2. 2 DIRECT EXAMINATION
+3. 3 BY MR. SHECHTMAN:
+4. 4 Q. Mr. Schoeman, how are you employed?
+5. 5 A. I'm a lawyer at Kramer, Levin, Naftalis & Frankel.
+6. 6 Q. You're a partner there?
+7. 7 A. I am.
+8. 8 Q. How long have you been practicing law?
+9. 9 A. I graduated from law school in 1995. I first started at
+10. 10 Kramer Levin in 2003. I left there in 2007 to return to the
+11. 11 U.S. Attorney's office in the Eastern District of New York, and
+12. 12 I returned back to Kramer Levin in the fall of 2009.
+13. 13 Q. Were you a lawyer in this courtroom during the trial of
+14. 14 David Parse and other defendants?
+15. 15 A. I was.
+16. 16 Q. Whom did you and your firm represent?
+17. 17 A. We represented Raymond Craig Brubaker.
+18. 18 Q. What other members -- what other partners, let's keep it
+19. 19 simple, at your firm were involved in that trial?
+20. 20 A. Barry Berke. My partner Barry Berke tried the case with
+21. 21 me.
+22. 22 Q. Let me direct your attention, if you would, to May 11,
+23. 23 2011, and ask you, did the Court that day, that afternoon, read
+24. 24 aloud a note from Juror No. 1, Catherine Conrad?
+25. 25 A. I believe that's the correct date if that is the date on
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+C2grdau4 Schoeman - direct
+
+1 which we concluded the summations in the case, yes. 2 Q. Do you recall the subject matter of that note? 3 A. I recall in general that there was a question regarding 4 respondeat superior. 5 Q. Again just to be clear, what stage was the trial at? 6 A. I believe that chat was after all of the summations had 7 been concluded, I think including the rebuttal summation. 8 Q. Do you know a lawyer named Theresa Trzaskoma? 9 A. I do. 10 Q. How do you know her? 11 A. I think I first met Ms. Trzaskoma in approximately 2,000. 12 My babysitter and her babysitter became friends. Being a 13 first- time parent, I did a little diligence on the parents of 14 my 3 month old's playmate and learned that it was Ms. Trzaskoma 15 and her husband. We became family friends at that point. 16 Q. I'm loathe to ask this question, but you Googled her? 17 A. Actually, I think I knew her husband, who had been an 18 associate with me at Paul Weiss and had clerked in the Eastern 19 District at the same time that my wife had clerked. So I think 20 I knew them in advance. 21 Q. Was Ms. Trzaskoma also a lawyer during the course of the 22 trial in this courtroom, the David Parse trial? 23 A. She was. 24 Q. Who did she and her firm represent? 25 A. She and her firm represented David Parse. SOUTHERN DISTRICT REPORTERS, P.C. (2121 805-0300
+
+C2grdau4 Schoeman - direct
+
+1 Q. Sometime after the reading of the note from Juror No. 1, 2 did you speak to Ms. Trzaskoma about Ms. Conrad, Juror No. 1? 3 A. Yes. 4 Q. Would you tell the Court what was said between you and Ms. 5 Trzaskoma at that time. 6 A. Yes. I recall that we had a conversation. I believe it 7 was as we were walking across Foley Square towards Duane 8 Street. She told me that there was a person with the same name 9 as -- I don't recall whether she said Juror No. 1 or Ms. 10 Conrad, but a person with the same name who was a disbarred 11 lawyer but that it was not the same person as Juror No. 1. 12 I began formulating a question to say, how do you 13 know? She anticipated that question and said, because of the 14 voir dire. I began formulating the question of, what question 15 during the voir dire would have disclosed that? She 16 anticipated that question as I was speaking it and said 17 something to the effect that\_ her educational background did not 18 include law school. I said, then it's not the same person? 19 And she said right. By that time we had finished crossing the 20 street. 21 Q. Any further discussion about Juror No. 1? 22 A. Not with Ms. Trzaskoma during that time period. 23 Q. Any further discussion with anyone at the Brune firm 24 regarding Juror No. 1 during that time period? 25 A. No.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+C2grdau4 Schoeman - direct
+
+1 Q. Did you take any action based on that conversation? 2 A. No. 3 Q. We know that it was after the juror's note. Do you recall 4 when it was? 5 A. I can't say exactly when it was. I believe it was during 6 the deliberations either chat Friday or sometime the following 7 week.
+
+B MR. SHECHTMAN: No further questions.
+
+9 THE COURT: Cross-examination?
+
+10 MR. OKULA: Briefly, your Honor.
+
+11 CROSS-EXAMINATION
+
+12 BY MR. OKULA:
+
+13 Q. Good afternoon, Mr. Schoeman. How are you?
+
+14 A. Good, thank you. Good afternoon.
+
+15 Q. Dr. DeRosa sends his regards?
+
+16 A. I send mine right back.
+
+1? Q. You said you had this conversation with Ms. Trzaskoma after 18 the note was received in court, is that correct?
+
+19 A. Yes.
+
+20 Q. Was it the same day or the following day?
+
+21 A. I don't believe it was either the same day or the following 22 day. I believe it was sometime a couple of days or several 23 days later.
+
+24 Q. You talked about the follow-up questions that you asked to
+
+25 try to get to the bottom of the information, is that correct?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+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 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 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.
+
+(2121 805-0300
+
+1 A. No. 2 Q. Did she tell you that she had viewed a Westlaw report that 3 had certain information on it that was connected to Juror No. 4 1, Catherine Conrad? 5 A. No. 6 Q. Did she tell you that she had communicated with somebody 7 internally in her firm where she had exclaimed, "Jesus, I think 8 Juror No. 1 is the suspended attorney"? 9 A. No. 10 Q. If you had that information from Theresa Trzaskoma, would 11 you have done further investigation yourself? 12 A. I don't know. 13 Q. How many years did you spend as an Assistant U.S. Attorney, 14 Hr. Schoeman? 15 A. A total of about seven or eight. 16 Q. I would stipulate to the fact, because I've heard it, that 17 you were a terrific investigator, correct? 18 A. I'll stipulate with you. 19 Q. Are you telling us really that you wouldn't have looked 20 into that further yourself if you had seen these further 21 connections tying Juror No. 1 to the suspended attorney? 22 A. Forgive me. I thought your question was if I had heard 23 that she had written an email that had that exclamation. I 24 don't know what I would have done. I guess I can only tell you 25 what I did do, which was ask about the voir dire. SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+1 Q. Would you have liked to receive that information in order 2 to make a better assessment of your own about whether Juror No.
+
+3 1 was the suspended attorney? After all, more information is 4 better, isn't it?
+
+5 A. It did not occur to me at the time to ask for more 6 information.
+
+7 Q. I didn't ask you whether it occurred to you at the time.
+
+B Would you have wanted more information? Would that have helped 9 your analysis?
+
+10 A. I don't know whether it would have helped my analysis. I
+
+11 concluded from the fact that she was telling me that the voir
+
+12 dire answer had said that this person had not gone to law
+
+13 school, that this was not an issue.
+
+14 Q. Do you really mean what you just said, that you don't think
+
+15 more information would have helped your analysis, Mr. Schoeman?
+
+16 A. I'm telling you I don't know whether more information would
+
+17 have helped my analysis. I'm telling you that I reached a
+
+18 conclusion based on that information.
+
+19 Q. Would you agree with me that if you have two people, one
+
+20 named Catherine Conrad, another named Catherine Conrad, and you
+
+21 were given information about their middle initials, that they
+
+22 share the same middle initial, that it made it statistically
+
+23 more likely that was the same person?
+
+24 A. Yes.
+
+25 MR. OKULA: Judge, I have nothing further. Thank you.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 THE COURT: Mr. Shechtman. 2 REDIRECT EXAMINATION 3 BY MR. SHECHTMAN: 4 Q. Mr. Schoeman, just to be clear, on May 13th or sometime 5 thereafter Ms. Trzaskoma told you that she had rejected the 6 conclusion that Juror No. 1 was a suspended attorney, is that 7 correct? 8 A. Yes. 9 MR. SHECHTMAN: Very good. 10 MR. OKULA: Nothing else, your Honor. 11 THE COURT: Mr. Schoeman, did you get any 12 understanding from Ms. Trzaskoma as to why it was that she was 13 sharing this information or her deliberative process with you? 14 THE WITNESS: I didn't have an understanding. We, 15 having spent many months of trial together, often shared 16 information. It was consistent with our pattern of sharing 17 information during the course of the trial. But I have 18 described I think the entirety of the conversation. 19 THE COURT: Anything further? 20 MR. OKULA: Nothing. Thank you, your Honor. 21 THE COURT: You're excused. You may step down. 22 (Witness excused) 23 MR. SHECHTMAN: Mr. Parse calls Barry Berke of the 24 same law firm. 25 BARRY H. BERKE,
+
+C2grdau4 Berke - direct
+
+1 called as a witness by defendant Parse,
+
+2 having been duly sworn, testified as follows:
+
+3 THE COURT: State your full name and spell it slowly
+
+4 for the court reporter.
+
+5 THE WITNESS: Barry H. Berke, B-E-R-K-E.
+
+6 THE COURT: Mr. Shechtman, you may inquire.
+
+7 DIRECT EXAMINATION
+
+8 BY MR. SHECHTMAN:
+
+9 O. Mr. Berke, how are you employed?
+
+10 A. I am a partner at Kramer, Levin, Naftalis 6 Frankel.
+
+11 Q. How long have you been a partner at that firm?
+
+12 A. I have been a partner at that firm since I believe 2001.
+
+13 Q. Prior to that were you involved in the law --
+
+14 A. I'm sorry. Since 1999 I was a partner there. Prior to
+
+15 Chat I was an associate at Kramer Levin.
+
+16 Q. Prior to that?
+
+17 A. Prior to that I began my career as a clerk in this
+
+18 courthouse for a judge here. I was then at the Federal
+
+19 Defenders office in the Southern District of New York until
+
+20 1995, when I joined Kramer Levin. I had a brief period when I
+
+21 was a visiting associate professor at NYU teaching courses
+
+22 there right in between.
+
+23 Q. Were you a lawyer in this courtroom during the trial of
+
+24 David Parse and other defendants?
+
+25 A. I certainly was.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+C2grdau4 Berke - direct
+
+1 Q. Whom did you and your firm represent?
+
+2 A. We represented Craig Brubaker.
+
+3 Q. Let me direct your attention to May 11th of 2011. Did the
+
+4 Court that afternoon read a note from Juror No. 1, Catherine 5 Conrad?
+
+6 A. I recall that.
+
+7 Q. Do you recall the subject matter of that note?
+
+8 A. T recall generally that there was a note from Juror 1
+
+9 asking whether the judge was going to instruct I believe on
+
+10 cespondeat superior. I think there were some other things, but
+
+11 I recall that to be the overall gist of the note, as I recall
+
+12 it.
+
+13 Q. Do you know a lawyer named Susan Brune?
+
+14 A. I do.
+
+15 Q. How do you know her?
+
+16 A. I've known Ms. Brune for a long time. I can tell you the
+
+17 background, but I certainly know her as counsel for David Parse
+
+18 in this action.
+
+19 Q. Sometime after the nudge's reading of that note from Juror
+
+20 No. 1, did you speak to Ms. Brune about Ms. Conrad?
+
+21 A. I did. I'll tell you what I recall. I recall that after
+
+22 we heard the note that day, I believe it was the following
+
+23 day -- although I can't say that with a hundred percent
+
+24 certainty, it could have been the day after that -- I recall
+
+25 being in the witness room in the back, which we used and had
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+C2grdau4 Berke - direct
+
+1 copy machines and other things and often spent time back there, 2 I remember talking to Ms. Brune about the note.
+
+3 I recall her saying that they had identified a person
+
+4 with the same name who had been a disbarred lawyer. I recall
+
+5 saying to her, well, that can't be, because she certainly isn't
+
+6 a lawyer. I said, I assume she was asked what her educational
+
+7 background was. I remember Ms. Brune said she did, she was
+
+8 asked, she said that she had a BA degree. Ms. Brune told me
+
+9 what it was in. I don't recall as I sit here. But it was some
+
+10 humanities. I recall saying, well, definitely it can't be the
+
+11 same person. She said, that's what I think as well.
+
+12 That was really the end of it. I would say the
+
+13 conversation probably did not last more than two, three minutes
+
+14 at most. Then I recall we left the room and that was it.
+
+15 Q. She said, that's what I think as well?
+
+16 A. That's what I recall.
+
+17 M.R. SHECHTMAN: No further questions.
+
+18 THE COURT: Cross-examination.
+
+19 CROSS-EXAMINATION
+
+20 BY MR. OKULA:
+
+21 Q. Good afternoon, Mr. Berke.
+
+22 A. Good afternoon, Mr. Okula.
+
+23 Q. I get to check one of the things off my bucket list.
+
+24 A. I just hope you didn't prepare too much for it.
+
+25 Q. Would you agree with me, Mr. Berke, that if an attorney
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+12121 805-0300
+
+1 forms a belief that a juror has engaged in misconduct, that 2 attorney is obligated to bring the misconduct to the attention 3 of the Court?
+
+4 A. You're asking me an ethical question, a legal opinion. I 5 will tell you this --
+
+6 Q. Can you not answer that yes or no, Mr. Berke?
+
+7 A. Well, I'd like --
+
+8 Q. I'm asking you a question, and I'll repeat it again. Maybe 9 you can't answer it yes or no; tell me it that's the case. If 10 an attorney forms a belief that a juror has engaged in
+
+11 misconduct, do you believe that the attorney has an obligation 12 to bring it to the attention of the court?
+
+13 A. I can't answer that yes or no. I can answer it, but I just 14 can't answer it yes or no.
+
+15 Q. Really? You can't answer that question yes or no? That's 16 your testimony?
+
+17 A. That's not how I would answer that question.
+
+18 Q. Tell us how you would answer that question.
+
+19 A. I will tell you that I have never confronted that issue at 20 trial in any trial I have done; that whenever I have an issue
+
+21 that I think raises an ethical issue, I always do the same 22 thing. I always look to the ethics rules. i always look to 23 the ethics commentary.
+
+24 I'm very familiar with the ethical rules. I'm
+
+25 familiar with my obligations to my client, to the court, my SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 other obligations. I never will act on a piece of information 2 that I think invokes my duties as an advocate for my client as 3 well as an officer of the court without first looking at the 4 rules. I will read the rules.
+
+5 As we all know, at Limes you will read the rules, they 6 will be absolutely clear what my obligations are. Sometimes 7 they will be less clear and we will research St. That's what I 8 do. I never act on information until I do that, and I've never 9 done that on that. issue. That's what I can tell you.
+
+10 Q. I don't think you answered my question, though. Can you 11 answer the question that I asked? If you form a belief as an 12 attorney in a courtroom that a juror has engaged in misconduct, 13 do you have to bring that to the attention of the court?
+
+14 A. What I can tell you is if I had confronted that issue
+
+15 Q. Is this another one that you can't answer yes or no?
+
+16 A. I'm going to answer your question.
+
+17 Q. Would you do that.
+
+18 A. I will. What I will tell you is my reaction to that
+
+19 information if I confronted it would be that I believe I have 20 an obligation to tell the court. Before I did anything, 21 though, I would do exactly what I said. I would look at the 22 rule, look at the law, and make sure I was complying with all 23 my obligations.
+
+24 Q. Did Susan Brune explain to you why she felt it important to 25 bring the information to your attention that her firm had
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+1 learned about the juror or believed or the connection between 2 the juror?
+
+3 A. No. I think I have told you the substance of what. I recall 4 of that conversation.
+
+5 Q. She didn't explain in any fashion why she thought it was 6 important to tell you at that period of time?
+
+7 A. No.
+
+8 Q. Did she tell you anything else that her firm had learned 9 that gave rise to the belief by one of their attorneys that 10 there was a connection between Juror No. I and the suspended
+
+11 New York attorney?
+
+12 A. No.
+
+13 Q. Did she tell you any of the underlying facts?
+
+14 A. No. The only other thing that I recall is that when 15 talking about the note, we both noted that we believed that 16 Juror 1 had said she had been a plaintiff in a personal injury 17 case, which might explain the respondeat superior. I can't say
+
+18 for certain it was in that identical conversation, I believe it 19 was probably was, but I do remember talking about that as well.
+
+20 Q. Let me ask you this. If you had learned from somebody at
+
+21 the Brune firm that they had a written report showing somebody 22 named Catherine Conrad had a personal injury or had a private 23 lawsuit, would that be a piece of information that you would 24 want to have had at the time in order to do your own analysis?
+
+25 A. Just to be clear, what I'm referring to, I believe the
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+1 juror herself had said in response to a question about other 2 litigation that she had been involved in a personal injury 3 case. That's what I'm referring to. 4 Q. Right. My question to you is, would that information as S background, if Susan Brune came to you and Cold you that we not 6 only found a Catherine Conrad who was a suspended lawyer but we 7 also found a Catherine Conrad who was involved in a personal 8 injury lawsuit, is that something that you would have wanted to 9 know at the time? 10 A. I'm not sure I understand. We knew that Catherine Conrad 11 had said that she was involved in a personal injury suit. We 12 knew that from her answers in the voir dire. 13 Q. If you saw a piece of paper that connected Catherine Conrad 14 who was Juror No. 1 and Catherine Conrad who was a personal 15 injury lawyer and a suspended attorney who had the same address 16 as the person involved in the lawsuit, would that have been of 17 interest to you? 18 A. You know, I really am not comfortable speculating. What I 19 can tell you is I told you what I knew. I did not believe that 20 the person who had been a disbarred lawyer could have been or 21 was this Juror No. 1 based on what I knew. That's really all I 22 can tell you. 23 Q. So, your answer co my direct question is that you can't 24 answer the question? 25 A. Well, I would object if I was sitting over there, but I'm SOUTHERN DISTRICT REPORTERS, P.C.
+
+1212) 805-0300
+
+1 not. You're asking me to speculate. I'm just not comfortable 2 speculating.
+
+3 Q. I think that's on your bucket list, to move up there,
+
+4 right?
+
+5 A. No, not at all. I'm just not comfortable speculating.
+
+6 Q. Isn't more information better than less when you are trying 7 to make an assessment of possible juror misconduct and a
+
+8 connection in names between a person who may be acting as an 9 imposter and a juror on trial?
+
+10 M.R. SHECHTMAN: Judge, I'm going to object on Mr.
+
+11 Berke's behalf.
+
+12 THE COURT: Overruled.
+
+13 A. I wasn't making that assessment.
+
+14 Q. I didn't ask you if you were making that assessment. Is 15 more information better when you are trying to find out whether 16 somebody who shares the same name as a suspended attorney is 17 the juror? Yes or no.
+
+18 A. I'm going to tell you, Mr. Okula, it sounds like you're
+
+19 arguing with me. It depends on what that information is. All 20 I can tell you is what I know from my personal experience.
+
+21 From what I heard, it did not occur to me for a moment that
+
+22 there was any issue with Juror 1 and the suspended lawyer at
+
+23 the time. That's all I can tell you. I can't speculate or
+
+24 answer your argument, I really can't.
+
+25 Q. What is the type of investigation you'd do if you found a
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+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 1 7 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 Co 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.
+
+1 2 MR. SHECHTMAN: I do. THE COURT: Mr. Shechtman.
+
+3 REDIRECT EXAMINATION
+
+4 BY N.R. SHECHTMAN:
+
+5 7 Q. You were told by Ms. Brune that there was a suspended lawyer with the name Catherine Conrad which was the same as Juror No. 1?
+
+8 A. That is correct.
+
+9 Q. And you didn't do any further investigation?
+
+10 A. I did not.
+
+11 12 Q. That's because you agreed with her that based on the voir dire, this couldn't be the same person?
+
+13 A. Exactly.
+
+14 MR. SHECHTMAN: No further questions.
+
+15 THE COURT: Anything further?
+
+16 MR. °KULA: No, your Honor. Thank you.
+
+17 18 down. THE COURT: Mr. Berke, you're excused. You may step
+
+19 THE WITNESS: Thank you, Judge.
+
+20 (Witness excused)
+
+21 THE COURT: You're still talking as fast as ever.
+
+22 THE WITNESS: I made a promise I wanted to keep.
+
+23 24 THE COURT: Mr. Shechtman, does the defendant Parse have any additional witnesses to call?
+
+25 MR. SHECHTMAN: No, your Honor.
+
+C2grdau4 Berke - redirect
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+C2grdau4
+
+1 THE COURT: Does the defendant Parse rest? 2 MR. SHECHTMAN: We do, your Honor. 3 THE COURT: Does any defendant have any additional 4 evidence to offer to the Court on this hearing? 5 MS. McCARTHY: Not from Mr. Field, your Honor. 6 MR. ROTERT: We do not, your Honor. 7 MR. SKLARSKY: No, your Honor. 8 THE COURT: Does the government have anything further? 9 MR. OKULA: Thank you, your Honor. We do not. 10 THE COURT: The government rests? 11 MR. OKULA: We do indeed, your Honor. 12 THE COURT: I would like to get some post-hearing 13 briefing from the parties. It seems to me that the simplest 14 way to do it would be to have the parties submit simultaneous 15 briefs and then I give you a very short responsive brief if you 16 felt it was necessary to respond Lo something Chat the other 17 side said. We'll fix a schedule in a moment. 18 Obviously, in the briefs I want the parties to provide 19 the Court with what they believe the strongest results are of 20 Lhis evidentiary hearing. Second, in the post-hearing briefs 21 I'd like the question of whether the attorneys for Brune is 22 Richard involved in this matter would have satisfied their 23 ethical obligations if they failed to disclose the contents of 24 the July 21 letter and their complete investigation into Juror 25 No. 1.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+1212) 805-0300
+
+C2grdau4
+
+1 Finally, in the past I asked the parties to brief what
+2 they believed might occur depending upon various rulings by the
+3 Court. It seems to me that one scenario was left out. You are
+4 not to conclude from this request that this is the Court's
+5 thinking, but I want to receive briefing on the following
+6 question.
+
+7 If this Court were to grant the defendants' motion for
+8 a new trial and also conclude that the defendant Parse had
+9 waived, what would be the shake-out of that in terms of Parse's
+10 ability to take that issue to the Court of Appeals at the same
+11 time that the government would be taking the underlying issue
+12 on motion for a new trial to the Court of Appeals, as is the
+13 government's right under a specific statute? I have
+14 preliminarily looked at the matter, but I'd appreciate your
+15 wisdom on the question.
+
+16 Are there any other issues that counsel want to raise?
+17 Mr. Shechtman?
+
+18 MR. SHECHTMAN: Can I try to sharpen that last
+19 question?
+
+20 THE COURT: Go ahead, certainly.
+21 MR. SHECHTMAN: I take it the notion would be could
+22 Mr. Parse take that appeal interlocutorily before sentencing?
+
+23 THE COURT: Bingo.
+24 MR. SHECHTMAN: The after one is easy. So it's really
+25 an interlocutory.
+
+C2grdau4
+
+1 THE COURT: Right. In the end, whatever happens with 2 respect to these matters before the Court., I think that it is 3 in everyone's interest that they travel together wherever 4 they're going.
+
+5 Are there any other matters that. counsel want\_ to raise 6 at this time before we fix a schedule far the submission of 7 these briefs?
+
+8 N.R. OKULA: No, your Honor. I was just going to 9 suggest most respectfully that perhaps if counsel for the 10 government and defendants could confer momentarily about a 11 proposed schedule, then we could propose one to the Court.
+
+12 THE COURT: That's fine with me.
+
+13 M.R. GAIR: Judge, Mr. Okula is on vacation next week, 14 so I'd like to suggest one week.
+
+15 MR. SHECHTMAN: judge, if we might be heard?
+
+16 THE COURT: Go ahead.
+
+17 MR. SHECHTMAN: We want very much Lo accommodate Mr.
+
+18 Okula's vacation, seriously. He has suggested three weeks. I
+
+19 start a trial on Tuesday, a month-long trial. I fully 20 appreciate that I have to write this brief on weekends, and I 21 will, but an extra week would be very helpful. If we could get 22 a month, that would be grand.
+
+23 THE COURT: Fine. You've got it. Do you want to file 24 your briefs on March 16, your initial briefs, or do you want
+
+25 March 23?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+C2grdau4
+
+M.R. SHECHTMAN: I'd be happy it we could have March 2 19th so we can't get that extra weekend. 3 THE COURT: I'll give you until the 23rd if you want. 4 MR. OKULA: That's fine. It separates it from St. 5 Day more, Judge. 6 THE COURT: All right. March 23 for the initial 7 briefs. Why don't you provide your responses by April 5th. 8 MR. OKULA: That's fine, Judge. 9 THE COURT: Will that work? 10 MR. SHECHTMAN: Yes. 11 THE COURT: I'll take the matter then on submission. 12 Is there anything else that counsel want to raise? 13 MR. OKULA: Not other than our thanks, Judge. 14 THE COURT: My thanks to all of you for conducting the 15 hearing in the customary professional and efficient manner. 16 Certainly there are some aspects of it that have been 17 memorable, and that's an understatement. Have a good 18 afternoon. 19 (Adjourned) 20 21 22 23 24 25
+
+| | | INDEX OF EXAMINATION | | | | | | | | | |
+|----|----------------------------|----------------------|--|--|--|--|--|--|--|--|--|
+| | | Examination of: | | | | | | | | | |
+| 2 | Examination of: | | | | | | | | | | |
+| 3 | SUSAN BRUNE | | | | | | | | | | |
+| 4 | Direct By [REDACTED] | 246 | | | | | | | | | |
+| 5 | Cross By Mr. Shechtman | 309 | | | | | | | | | |
+| 6 | Redirect By Mr. [REDACTED] | 312 | | | | | | | | | |
+| 7 | Recross By Mr. Shechtman | 316 | | | | | | | | | |
+| 8 | Redirect By [REDACTED] | 318 | | | | | | | | | |
+| 9 | LAURA EDELSTEIN | | | | | | | | | | |
+| 10 | Direct By Mr. Okula | 322 | | | | | | | | | |
+| 11 | Cross By Mr. Shechtman | 353 | | | | | | | | | |
+| 12 | Redirect By Mr. Okula | 354 | | | | | | | | | |
+| 13 | PAUL SCHOEMAN | | | | | | | | | | |
+| 14 | Direct By Mr. Shechtman | 359 | | | | | | | | | |
+| 15 | Cross By Mr. Okula | 362 | | | | | | | | | |
+| 16 | Redirect By Mr. Shechtman | 366 | | | | | | | | | |
+| 17 | BARRY H. BERKE | | | | | | | | | | |
+| 18 | Direct By Mr. Shechtman | 367 | | | | | | | | | |
+| 19 | Cross By Mr. Okula | 369 | | | | | | | | | |
+| 20 | Redirect By Mr. Shechtman | 376 | | | | | | | | | |
+| 21 | | | | | | | | | | | |
+| 22 | | | | | | | | | | | |
+| 23 | | | | | | | | | | | |
+| 24 | | | | | | | | | | | |
+| 25 | | | | | | | | | | | |
+
+382
+
+| | | GOVERNMENT EXHIBITS | | | | | | | | | | | | | |
+|----|------------------|---------------------|---|---|---|---|---|---|---|---|---|---|---|----------|-----|
+| | | Exhibit No. | | | | | | | | | | | | Received | |
+| 1 | | | | | | | | | | | | | | | |
+| 2 | Exhibit No. | 10 | . | . | . | . | . | . | . | . | . | . | . | . | 358 |
+| 3 | | 28 | . | . | . | . | . | . | . | . | . | . | . | . | 312 |
+| 4 | | | | | | | | | | | | | | | |
+| 5 | | | | | | | | | | | | | | | |
+| | | DEFENDANT EXHIBITS | | | | | | | | | | | | | |
+| | | Exhibit No. | | | | | | | | | | | | Received | |
+| 6 | | | | | | | | | | | | | | | |
+| 7 | PMD 4 and PMD 27 | | . | . | . | . | . | . | . | . | . | . | . | . | 245 |
+| 8 | | | | | | | | | | | | | | | |
+| 9 | | | | | | | | | | | | | | | |
+| 10 | | | | | | | | | | | | | | | |
+| 11 | | | | | | | | | | | | | | | |
+| 12 | | | | | | | | | | | | | | | |
+| 13 | | | | | | | | | | | | | | | |
+| 14 | | | | | | | | | | | | | | | |
+| 15 | | | | | | | | | | | | | | | |
+| 16 | | | | | | | | | | | | | | | |
+| 17 | | | | | | | | | | | | | | | |
+| 18 | | | | | | | | | | | | | | | |
+| 19 | | | | | | | | | | | | | | | |
+| 20 | | | | | | | | | | | | | | | |
+| 21 | | | | | | | | | | | | | | | |
+| 22 | | | | | | | | | | | | | | | |
+| 23 | | | | | | | | | | | | | | | |
+| 24 | | | | | | | | | | | | | | | |
+| 25 | | | | | | | | | | | | | | | |
+
+Westlaw
+
+Page 1
+
+80 A.D.3d 168, 913 N.Y.S.2d 187, 2010 N.Y. Slip Op. 09090
+(Cite as: 80 A.D.3d 168, 913 N.Y.S.2d 187)
+
+**H**
+
+Supreme Court, Appellate Division, First Department, New York.
+In the Matter of Catherine M. CONRAD, a suspended attorney:
+Departmental Disciplinary Committee for the First Judicial Department, Petitioner,
+Catherine M. Conrad, Respondent.
+
+Dec. 9, 2010.
+
+**Background:** Departmental Disciplinary Committee instituted disciplinary proceedings against attorney. The Supreme Court, Appellate Division, 48 A.D.3d 187, 846 N.Y.S.2d 912, suspended attorney from practice of law for failure to respond to requests made by Committee pursuant to its investigations of complaints made against her. Committee subsequently moved for order suspending attorney on ground that she suffered from disability by reason of physical or mental infirmity or illness. Attorney cross-moved for order converting her current suspension to medical suspension nunc pro tunc and order vacating suspension and reinstating her to practice of law.
+
+**Holdings:** The Supreme Court, Appellate Division, held that:
+
+- (1) attorney's immediate reinstatement was not warranted, and
+- (2) attorney was required to prove her fitness to be reinstated.
+
+Suspension ordered.
+
+West Headnotes
+
+11 Attorney and Client 45 ↙ 61
+
+45 Attorney and Client
+
+45[ ] The Office of Attorney
+
+45[(C) ] Discipline
+
+45k61 k. Reinstatement. Most Cited Cases
+
+Immediate reinstatement of suspended attorney to practice of law was not warranted; alcohol dependence rendered attorney unfit to practice law, and attorney acknowledged during her deposition that her failure to cooperate and her underlying conduct was related to alcohol dependency. N.Y.Ct.Rules, §§ 603.16(c)(1), (f).
+
+12 Attorney and Client 45 ↙ 61
+
+45 Attorney and Client
+
+45[ ] The Office of Attorney
+
+45[(C) ] Discipline
+
+45k61 k. Reinstatement. Most Cited Cases
+
+Attorney who was suspended from practice of law due to her alcohol dependence was required to prove her fitness to be reinstated, and that burden could not be satisfied by attorney's own self-assessment; rather, evaluation by
+
+
+
+80 A.I3.3d 168,913 N.YS2d 187,2010N.Y.Slip Op. 09090 (Cite as: 80 A.D3d 168, 913 N-Y-S.2d 187)
+
+mental health provider attesting to attorney's current fitness to re-commence practice of law was necessary. N Ct.Rules. 66 603.164cX II. tn.
+
+\*0188 Alan W. Friedberg Chief Counsel, Departmental Disciplinary Committee, New York (Kevin E.F. of counsel). for petitioner.
+
+Victor M. Starr. for respondent.
+
+DAVID B. SAXE Justice Presiding. DAVID JOHN W. SWEENY. JR EUGENE NARDELL1, JAMES M. Justices.
+
+PER CURIANI
+
+•169 Respondent Catherine M. Conrad was admitted to the practice of law in the State of New York by the Second Judicial Department on January 26, 2000. and, at all times relevant to this proceeding, has maintained an office for the practice of law within the First Judicial Department.
+
+In a previous order dated December I8, 2007, this Court suspended respondent from the practice of law for failure to respond to requests made by the Departmental Disciplinary Committee pursuant to its investigation of two complaints made against her (22 NN'CRR 601.41c11111i1 ). After receiving a response by respondent six months later seeking an opportunity to respond to the complaints, the Committee conducted an investigation. Based upon respondent's admitted problem with alcohol dependency, which she acknowledged was connected to her failure to cooperate and the underlying conduct, the Committee obtained a psychiatric evaluation of respondent in November 2009. and a subsequent re-evaluation in May 2010. The psychiatrist determined that respondent's prognosis is good. but did not go as far as to assert that she is now fit to re-commence the practice of law.
+
+The Departmental Disciplinary Committee now moves for an order suspending respondent from the practice of law on the ground that she suffers from a "disability by reason of physical or mental infirmity or illness" (.1.2\_NY, CAR 603,161c ID ). In her cross motion respondent seeks to convert the current suspension to a medical suspension nunc pro tune, but further seeks an order vacating the suspension and reinstating her to the practice of law, due to her year-long sobriety.
+
+The Committees motion, and the first branch of respondent's cross motion, are granted to the extent that the prior finding of non-cooperation is vacated and an order "189 of suspension based upon the attorney's medical disability is granted mine pro tune tree Wafer of KaPl(m. 65 A.D3d 287. 683 N.Y.S.24 18212009L .1funer pf Fusco IR A Ltd, 81\_798 N,Y S 2d 164j290511.
+
+DEA However, that branch of respondent's cross motion seeking immediate reinstatement is denied at this lime. The cross motion itself concedes the existence of the alcohol dependence rendering her unfit to practice law; additionally, she acknowledged during her deposition that her failure to cooperate and •I70 her underlying conduct was related to alcohol dependency. To support her cross motion, respondent implies that the examining psychiatrist failed to satisfy an obligation to establish that she continues to be unfit to resume her practice. However, to be entitled to reinstatement, since the initial infirmity has been conceded, it is respondent who must prove her fitness to be reinstated (see 22 NYCRR 603.16(f) ), and that burden is not satisfied here by her own self-assessment (see Matter 91.Sten arr. 47 A.D.3d 43. 846 N.Y.S.2d 1 T 120071 ). The branch of respondent's cross motion seeking reinstatement to the practice of law therefore must be denied at this time, without prejudice to a further application, supported by an evaluation by a mental health provider attesting to her current fitness to re-commence the practice of law (see .Halter of Surino. 23 A.D.34 I I, la, 806 N.Y.S.2d 17812200'1 I
+
+Accordingly, the Committees motion and respondent's cross motion should be granted to the extent that the prior order's finding of non-cooperation is vacated, and respondent is suspended from the practice of law for an indefi-
+
+80 A.D.3d 168, 913 N.Y.S.2d 187, 2010 N.V. Slip Op. 09090 (Cite as: 80 A.D.3d 168, 913 N.Y.S.2d 187)
+
+nue period until further order of this Court, nunc pro tunc to December 18. 2007. and the branch of respondents cross motion seeking reinstatement to the practice of law should be denied without prejudice to a further motion for the same relief, supported by an expert's evaluation attesting to her present fitness to practice law.
+
+Respondent suspended from the practice of law in the State of New York for an indefinite period until further order of this Court, effective nunc pro tune to December I8, 2007. Cross motion denied. without prejudice to a further motion, as indicated. So much of the Opinion Per ('uriam and order of this Court entered on December 18, 2007 1M-4837) incorporating a finding of non-cooperation vacated. as indicated.
+
+All concur.
+
+N.Y.A.D. I Dept..2010. In re Conrad 80 A.D.3d 168, 913 N.Y.S.2d 187. 2010 N.Y. Slip Op. 09090
+
+END OF DOCUMENT
+
+# IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+Plaintiff,
+
+vs.
+
+PAUL M. DAUGERDAS, et al.,
+
+Defendants.
+
+Case No. S3 09 Cr. 581 (WHP)
+
+The Honorable William H. Pauley, III
+
+# DECLARATION OF STEPHEN GILLERS
+
+I, Stephen Gillers, under penalty of perjury, declare as follows:
+
+# Qualifications
+
+1. My name is Stephen Gillers. I am a law professor at New York University School of Law, where I have taught the rules and law governing lawyers and judges ("legal ethics") regularly since 1978. I am author of a leading casebook in the field, Regulation of Lawyers: Problems of Law and Ethics (9th ed. 2012). I have spoken hundreds of times on the subject of legal ethics at state and local bar associations nationwide and at American Bar Association meetings, at state and federal judicial conferences, and at law firms and corporate law offices in the United States and abroad. For more than a decade, I have been and remain active in the legal ethics work of the ABA's Center for Professional Responsibility, spending hundreds of hours yearly on this work. Most recently, I have been a member of the ABA's Ethics 20/20 Commission, a three and a half year project to review the rules of ethics governing lawyers in light of globalization and advance in technology. I have written widely in the area, including for law journals and the law and popular press. Legal ethics is the primary focus of my academic research. My resume is annexed as Exhibit A.
+
+# Question Addressed And Summary Of Conclusion
+
+2. I have been asked to address the question the Court posed on February 16, 2012 namely, "whether the attorneys for Brune & Richard involved in this matter would have satisfied their ethical obligations if they failed to disclose the contents of the July 21 letter and their complete investigation into Juror No. 1." The question does not specify a time frame for any possible "fail[ure) to disclose." I have been asked, therefore, to address any disclosure duty in March, May, and July of 2011. I have not been asked to address, and I am not addressing, the
+
+separate question of whether the motion for a new trial based on the conduct of juror Conrad is meritorious. That is not a question of legal ethics.
+
+3. In summary, my opinion is that (0 the Brune & Richard lawyers had no ethical obligation to disclose the results of their March 2011 research in March, or the results of their March and May 2011 research in May; (ii) the Brune & Richard lawyers had no ethical obligation to disclose the existence or the results of their March and May research in their July 8 motion for a new trial or during the July 15 conference call with the Court; and (iii) nothing the Brunc & Richard lawyers said or did in the July 8 memorandum or the July 15 conference call violated their ethical obligations.
+
+# Factual Assumptions
+
+4. I have read the following documcnts: •
+
+--Catherine Conrad's letter to the Government dated May 25, 2011;
+
+--Defendants' Brief in Support of a New Trial dated July 8.2011;
+
+—Transcript of Telephone Conference with Court dated July 15, 2011;
+
+—Letter from Susan Brune dated July 21, 2011;
+
+--Letter from Susan Brune dated July 29, 2011;
+
+—Affidavit of Susan Brune with Exhibits (including Catherine Conrad's jury questionnaire and voir dire responses) dated September 15, 2011;
+
+--Government's Waiver Brief dated October 7, 2011;
+
+--Defendant Parse's Waiver Brief dated October 27, 2011; and
+
+—Transcript of Hearing dated February 15 and 16, 2012.
+
+5. My opinion is based on the cited documents and I assume as true the facts that emerge from the sworn testimony at the hearing held February 15 and 16, 2012. I note that the testimony at that hearing was subject to robust adverse direct examination by Government attorneys.
+
+# General Observations And Legal Standards
+
+6. The New York Rules of Professional Conduct (hereafter "New York Rules") specifically identify when a lawyer is obligated to disclose information to the Court. The New York Rules are incorporated in the local rules of this Court. See Southern District of New York Local Rule I .5(3X5).
+
+7. Relevant here is New York Rule 3.3(a) and (b), which provides:
+
+(a) A lawyer shall not knowingly: (1) make a false statement of fact or law to a tribunal or fail to correct a false statement of material fact or law previously
+
+made to the tribunal by the lawyer; (2) fail to disclose to the tribunal controlling legal authority known to the lawyer to be directly adverse to the position of the client and not disclosed by opposing counsel; or (3) offer or use evidence that the lawyer knows to be false. If a lawyer, the lawyer's client, or a witness called by the lawyer has offered material evidence and the lawyer comes to know of its falsity, the lawyer shall take reasonable remedial measures, including, if necessary, disclosure to the tribunal. A lawyer may refuse to offer evidence, other than the testimony of a defendant in a criminal matter, that the lawyer reasonably believes is false.
+
+(b) A lawyer who represents a client before a tribunal and who knows that a person intends to engage, is engaging or has engaged in criminal or fraudulent conduct related to the proceeding shall take reasonable remedial measures, including, if necessary, disclosure to the tribunal.
+
+- 8. Also relevant is New York Rule 3.5(d), which provides:
+
+A lawyer shall reveal promptly to the court improper conduct by a member of the venire or a juror, or by another toward a member of the venue or a juror or a member of his or her family of which the lawyer has knowledge.
+
+- 9. Each of these rules requires knowledge on the part of the lawyer, and that knowledge must be "actual" knowledge. The standard is a subjective one. New York Rule 1.0(k) contains this definition:
+
+Knowingly, known, know, or knows denotes actual knowledge of the fact in question. A person's knowledge may be inferred from circumstances.'
+
+- 10. A leading Second Circuit case addresses the knowledge requirement. In Doe v. Federal Grievance Committee, 847 F.2d 57 (2nd Cir. 1988), a district judge in Connecticut disciplined a lawyer who did not report his belief that an opposing witness had lied in a deposition. The Connecticut (and the New York) rule at the time required a "lawyer who receives information clearly establishing that... kJ person other than his client has perpetrated a fraud upon a tribunal
+
+1 I have also been asked to address the potential relevance of Rule 8.4(d) of the New York Rules, which says that a lawyer or law firm shall not...engage in conduct that is prejudicial to the administration of justice." This rule should not be read to expand Rule 3.3's mens. requirement of knowledge. When the New York Rules of Professional Conduct were adopted to replace the Code of Professional Responsibility, the courts chose the standard of "knowledge," the same standard as in the ABA Model Rules, to replace "clearly established," which the Second Circuit had already interpreted to mean "knowledge" (see 1110-11 infra). When a specific and considered rule requires knowledge, another and general rule should not be interpreted to impose a duty based on a lower standard. There would be obvious notice and fairness interests implicated in doing so.
+
+• shall promptly reveal the fraud to the tribunal." Id. at 61 (emphasis addedXquoting DR 7- 102(3X2) of the Code of Professional Responsibility). The district judge concluded that Doe had "information clearly establishing" deposition perjury because he had "clear and convincing evidence of [the) witness's perjury." Id. Doe himself testified that "he believed that [the) witness had lied at the deposition." Id. at 59.
+
+1. Without rejecting the lower court's factual finding that Doe had clear and convincing evidence of fraud on the tribunal, the Doe Court held that "clearly establishing" required more. It held that "knowledge is required before the disclosure duty arises." Id. at 62. Clear and convincing proof, which is an objective test, did not trigger a reporting duty. That a lawyer "strongly suspected" fraud on the tribunal (a subjective test) was also insufficient. Id. at 63. As the Court noted:
+
+Our experience indicates that if any standard less than actual knowledge was adopted in this context [i.e., DR 7-102(BX2)], serious consequences might follow. If attorneys were bound as part of their ethical duties to report to the court each time they strongly suspected that a witness lied, courts would be inundated with such reports. Court dockets would quickly become overburdened with conducting these collateral proceedings which would necessarily hold up the ultimate disposition of the underlying action. We do not believe that the Code's drafters intended to throw the court system into such a morass. Instead, it seems that the only reasonable conclusion is that the drafters intended disclosure of only that information which the attorney reasonably knows to be a fact and which, when combined with other facts in his knowledge, would clearly establish the existence of a fraud on the tribunal.
+
+To interpret the rule to mean otherwise would be to require attorneys to disclose mere suspicions of fraud which are based upon incomplete information or information which may fall short of clearly establishing the existence of a fraud. We do not suggest, however, that by requiring that the attorney have actual knowledge of a fraud before he is bound to disclose it, he must wait until he has proof beyond a moral certainty that fraud has been committed. Rather, we simply conclude that he must clearly know, rather than suspect, that a fraud on the court has been committed before he brings this knowledge to the court's attention.
+
+Id. Discipline was reversed.2
+
+12. In an adversary legal system like ours, mandatory disclosure rules, which operate as a check on the premises of that system, receive scrutiny and debate from the courts and the bar over their proper scope. Furthermore, American jurisdictions do not all agree on how to reconcile competing interests — those of the client, the tribunal, and the adversary. New York, like most (but not all) jurisdictions, has adopted Rules 3.3 (a) and (b) in identical or substantially
+
+z was the expert for Doe in the Connecticut disciplinary hearing.
+
+identical form3 and it has also adopted Rule 3.5(d). These rules mandate disclosure of certain information to a court even if disclosure may harm the client and, for Rule 3.3 explicitly and Rule 3.5(d) implicitly, even if the information is protected as confidential client information. See New York Rule 3.3(c).4 But the duty arises only if the lawyer has "actual knowledge."
+
+13. A second decision also recognizes the delicate balance between the adversary system and duties to a litigation opponent or the tribunal. In re Pennie & Edmonds LLP, 323 F.3d 86 (2nd Cir. 2003) was an appeal of Rule 11 sanctions. When a party seeks Rule 11 sanctions, the target of the motion has a 21-day "safe harbor" within which to withdraw or correct the challenged submission. If it does not, the "mental state applicable to liability for Rule 11 sanctions is objective unreasonableness." *Id.* at 90. When, however, a court initiates a sanction proceeding, as by order to show cause, there is no safe harbor. Because the lawyer cannot take it back, *Pennie & Edmonds* holds that the required mental state is "bad faith," a subjective test like actual knowledge. The Court explained that "[a]ny regime of sanctions for a lawyer's role in the course of representing a client inevitably has implications for the functioning of the adversary system." *Id.* In support of its holding, the Court cited the interest of "[a] vigorous adversary system." *Id.* at 91.
+
+14. In sum, from the perspective of a lawyer's ethical obligations, the premises of our "vigorous adversary system" control unless the situation is governed by an express exception in ethics rules, statutes, judicial decisions, or other law. These exceptions, which are written with appreciation of the need for precision, give lawyers notice of the duties that override their adversarial obligations. As the Supreme Court wrote in a different context in Polk County v. Dodson, 454 U.S. 312 (1981):
+
+Within the context of our legal system, the duties of a defense lawyer are those of a personal counselor and advocate. It is often said that lawyers are "officers of the court." But the Courts of Appeals are agreed that a lawyer representing a client is not, by virtue of being an officer of the court, a state actor "under color of state law" within the meaning of § 1983. In our system a defense lawyer characteristically opposes the designated representatives of the State. The system assumes that adversarial testing will ultimately advance the public interest in truth and fairness. But it posits that a defense lawyer best serves the public, not by acting on behalf of the State or in concert with it, but rather by advancing "the undivided interests of his client."
+
+*Id.* at 318 (footnotes omitted). The question I turn to now is whether lawyers from Brune & Richard LLP acted in violation of any of the exceptions to their duties in the adversary system by not disclosing certain information prior to their July 21, 2011, letter to the Court.
+
+---
+
+3 See [http://www.americanbar.org/content/dam/aba/migrated/cpr/pic/3\\_3.authcheckdam.pdf](http://www.americanbar.org/content/dam/aba/migrated/cpr/pic/3_3.authcheckdam.pdf) (last visited April 5, 2012).
+
+4 The ABA Model Rules do not contain Rule 3.5(d). In my view, its mandate appears duplicative of a lawyer's obligations under New York and Model Rule 3.3(b).
+
+# DISCUSSION
+
+# Events in March 2011
+
+IS. The Brune & Richard lawyers had no duty to reveal to the court Trzaskoma's discovery of a 2010 court order suspending a Bronx lawyer with the same name as juror Conrad. None of the lawyers had knowledge that the Bronx lawyer and juror Conrad were the same person. None even had "clear and convincing" evidence or "strongly suspected" — the objective and subjective tests Doe rejected — they were the same person. Trzaskoma and Brune (who was told of the discovery though not shown the suspension order that Trzaskoma discovered but did not print) resolved to await juror Conrad's voir dire answers. Those answers, including juror Conrad's Bronxville address, directly contradicted any identity between the juror and the lawyer. This was in fact compelling. If the sworn answers were true, the juror was not the lawyer. A contrary conclusion would require the lawyers to believe that a suspended lawyer would repeatedly perjure herself in federal court in order to sit on a jury.
+
+# Events in May 2011
+
+16. Juror Conrad gave the Court a note asking if the jury was going to be instructed on vicarious liability and respondeat superior. The contents of the note led Trzaskoma, assisted by others at the firm, to take another look at the issue the next day. The 2010 suspension order and an earlier suspension order from 2007 were found. Both identified a Bronx lawyer. A paralegal discovered the Westlaw profile and forwarded it to Trzaskoma in an email that highlighted selected information. After seeing the selected information but before reviewing the entire profile, Trzaskoma wrote "Jesus, I do think it's her," but then, after reviewing the entire profile, changed her mind in light of the contradiction between the juror's voir dire answers and the limited information about lawyer Conrad (different levels of education, different addresses, etc.). In addition, Trzaskoma did not believe that the given age of the Bronx lawyer agreed with the apparent age of juror Conrad.
+
+17. Trzaskoma discussed the issue with Brune and Edelstein later in the day. All three concluded that juror Conrad was not the suspended lawyer. Co-counsel with whom the matter was thereafter informally discussed thought the question not worth pursuing. Because the Brune & Richard lawyers did not believe — let alone have actual knowledge — that the juror and the suspended lawyer were the same person, they did not present their information to the Court. At least five lawyers, based on what they had seen or been told, reached this conclusion.
+
+18. At this time, as earlier, no Brune & Richard lawyer had actual knowledge that juror Conrad was lawyer Conrad. Actual knowledge is the mental state that creates the disclosure duty under New York Rules 3.3(b) and 3.5(d). There was no ethical duty to reveal a suspicion, even a strong suspicion.
+
+19. Any notion that silence was intended to preserve undetected a basis for a new trial motion in the event of conviction is belied by the lawyers' actions. There was no effort to seek a new
+
+trial based on juror misconduct (nor did the firm give any consideration to that possibility) from the time of the verdict and until after receipt on June 20 of juror Conrad's letter to the prosecutor and the ensuing investigation.
+
+# Events in July 2011
+
+# The July 8 Memo►andum **of Law**
+
+20. The memorandum does not reference the discoveries in March or May. There was no duty to do so. I accept that the Brune & Richard lawyers could anticipate a possible waiver claim and could see how the government could cite the information that they had in March and May to bolster that claim. But the lawyer ethics rules impose no general duty to volunteer information that an opponent might use to support its argument and the exceptions in the rules cited do not create one specifically.5
+
+21. To put it otherwise, in order to find a duty to reveal there must be a source of the duty. Professional conduct rules do impose duties to reveal, but they do so in a way that gives lawyers notice of their requirements. No rule required disclosure of the information discovered in March or May. Any such rule would have to specify the information required to be revealed and the level of confidence in the accuracy of that information. Here, the rules imposing a duty to disclose to the tribunal are Rules 3.3(b) and 3.5(d). These rules use actual knowledge as the level of confidence required for the duty to disclosure. The information the lawyers had about the material they had gathered in March and May negates actual knowledge; the actions of the lawyers are consistent only with a conclusion of a lack of actual knowledge. In sum, only if the lawyers had had actual knowledge in March or May would they have had to reveal that in July, and they did not have actual knowledge.
+
+22. In certain places, the memorandum contains statements that arc apparently alleged to imply that the Brune & Richard lawyers did not have information about juror Conrad's identity prior to June 20, when they received a copy of her letter to the government.
+
+The primary purpose of Rule 11 is to deter baseless court filings, but this goal must be considered in light of the fact that, in an adversary system of litigation, the essence of the lawyer's task is to present issues of facts and law "as favorably as fairly possible" in support of the client's claim. See United Nat. Ins. Co. v. R & D Latex Corp., 242 F.3d 1102, 1115 (9hCir. 2001). Therefore, judges should "impose sanctions on lawyers for their mode of advocacy only in the most egregious situations, lest lawyers be deterred from vigorous representation of their clients." Id. (citing Schlaifer & Co., Inc. v. Estates of Warhol, 194 F.3d 323, 341(2"" Cir. 1999).
+
+'Because the premises of the adversary system are central here, instruction from the contiguous world of Rule 11 is again apt:
+
+23. The lawyers wrote: "The tone and content of the letter, which were in sharp contrast to the image Conrad had projected through the trial (`always head down, taking notes'), caused defendants concern and prompted them to investigate." Memorandum at 9. And they later wrote: "This is not a situation where Conrad disclosed sufficient information to warrant inquiry by counsel. Defendants had no basis to inquire whether Conrad was lying in response to each of the Court's questions." Memorandum at 32, n.13 (internal citation and parenthetical quote omitted).
+
+24. In my opinion, these statements should be seen as true, not merely literally true in a hypertechnical or crabbed sense of the word, but true as reasonably read. They do not become untrue because a reader may draw a false inference that the lawyers did not intend. The juror's letter did cause concern and did prompt an investigation, as the first quotation in the memorandum states. That statement does not disclaim a prior search, whether that prior search is called an investigation or something else. I believe that focus on the word "investigate," which is not a term of art, would be misguided here. The sentence correctly describes what the letter caused the lawyers to do.
+
+25. The second quote focuses on the voir dire in March and is also true as reasonably read. The lawyers had concluded that the order suspending a lawyer with the same name as juror Conrad was not a "basis" for an inquiry into the truthfulness of juror Conrad's answers. Just the opposite. lier voir dire answers, in their view, dispelled reason for inquiry. A suspended lawyer would not lie under oath at voir dire, they reasoned, given the consequences to the lawyer's ability ever to regain admission to practice. In my opinion, this conclusion was compelling.
+
+26. It is also my opinion that the July 8, 2011, memorandum, taken as a whole, does not show a "knowing[]" violation of the provisions of Rule 3.3. It is true that even when a lawyer does not have a duty to speak, if she does speak, she may not knowingly misrepresent to a court or adversary. But an unintended inference is not a misrepresentation. The lack of disclaimer language in the memorandum's true statements — the fact that the lawyers, while focused on the new trial motion, did not anticipate what a reader might infer and what they did not mean to imply — is not an action that can support a finding of unethical behavior under the New York Rules.
+
+27. The lawyers understandably now wish they had not included these pacsages as written. Greater focus might have led them to anticipate how others might read them differently than intended, and to omit them (they were unnecessary to the motion), rephrase them, or add the history of their earlier research.
+
+# The July 15 Telephone Conference
+
+28. In the July 15 telephone conference, the Court said that it wanted to "ascertain from each of the defendants ...whether any of them were aware of the disturbing things that have been revealed by defense on this motion concerning Juror Number One [Conrad]." The Court invited a response on the call or via letter. Trzaskoma's response was:
+
+Trzaskoma: We were not aware of the facts that have come to light, and I think if your Honor deems it appropriate, we can submit a letter.
+
+The Court: All right. I do. Because I would like to make certain that any defendant who had a jury consultant on the matter also make certain that the jury consultant did not have any information on Juror Number One.
+
+Trzaskoma: The only thing additional that I would offer your Honor is—well, we can address this in a letter. I think it's more appropriate.
+
+29. This colloquy must be read in its (rather brief) entirety, that is, as a whole. Trzaskoma's statement implies that the answer to the Court's question from Brune & Richard would not be that it had no information at all. It would not require a letter to say only that. It is, instead, clear that Trzakoma had something "additional...to offer," and chose to accept the Court's invitation to say it in a letter, which was done on July 21 in a fashion that adequately disclosed the firm's earlier research and internal communications on the subject. "The general rule is that statements must be taken in context, and that related parts of a document must be taken together. That a hasty reader might take the first paragraph out of context is not in the present circumstances enough to brand the memorandum as false." The memorandum must be "read as a whole." Young v. City of Providence, 404 F.3d 33, 4041 (lnCir. 2005) (Rule II appeal) (citations omitted).
+
+# CONCLUSION
+
+30. For the reasons stated, my opinion is that the actions of the Brune & Richard lawyers throughout the trial and in the months following with respect to the information they had obtained about Catherine Conrad were entirely consistent with their responsibilities under the lawyer ethics rules.
+
+S phen Gillers
+
+## EXHIBIT A
+
+[January 2012]
+
+# STEPHEN GILLERS
+
+Elihu Root Professor of Law (vice 1999-2004) New York University School of Law 40 Washington Square South New York, NY 10012
+
+(212) 998-6264 (tel) (212) 995-4658 (fax) stephen.gillers®nyu.edu
+
+AREAS OF TEACHING Regulation of Lawyers and Professional Responsibility Evidence; Law and Literature; Media Law
+
+PRIOR COURSES Civil Procedure, Agency, Advocacy of Civil Claims, Federal Courts
+
+# PUBLICATIONS BOOKS AND ANTHOLOGIES:
+
+Regulation of Lawyers: Problems of law and Ethics (Aspen Law & Business, 9th cd., April 2012). The first edition of this popular casebook was published in 1985. Norman Dorsen was a co-author on the first two editions. Stephen Gillers is the sole author of the third through ninth editions. The first four editions were published by Little, & Co., which then sold its law book publishing operation to Aspen.
+
+Regulation of Lawyers: Statutes and Standards(with Roy and Andrew Perlman) (Aspen Law & Business) This is a compilation with editorial comment. The first volume was published in 1989. Updated versions have been published annually thereafter. As of the 2009 edition, Andrew Perlman has joined as a co-editor.
+
+Regulation of the Legal Profession (Aspen 2009). This is 400+ page book in the Aspen "Essentials" series explains ethics rules and laws governing American lawyers and judges.
+
+Getting Justice: The Rights of People (Basic Books, 1971; revised paperback, New American Library, May 1973).
+
+PUBLICATIONS Investigating the FBI (co-Editor with P. Waiters)
+
+(continued) (Doubleday, 1973; Ballantine, 1974)
+
+None of Your Business: Government Secrecy in America (co-Editor with N. Dorsen) (Viking, 1974; Penguin, 1975).
+
+I'd Rather Do It Myself: How to Set Up Your Own Law Firm (Law Journal Press, 1977).
+
+Looking At Law School: A Student Guide From the Society of American Law Teachers(editor and contributor) (Taplinger, 1977; NAL, 1977; revised ed., NAL, 1984; third ed., NAL, 1990).
+
+The Rights of Lawyers and Clients(Avon, 1979).
+
+"Four Policemen in London and Amsterdam," in It Schrank (ed.) American Workers Abroad (MIT Press, 1979).
+
+"Dispute Resolution in Prison: The California Experience," and "New Faces in the Neighborhood Mediating the Forest Hills Housing Dispute," both in IL Goldmann (S.) Roundtable Justice: Case Studies in Conflict Resolution (Westview Press, 1980).
+
+"The American Legal Profession," in A. (ed.), Fundamentals of American Law (Oxford University Press 1996).
+
+The Elsinore Appeal: People v. Hamlet (St. Press 1996).
+
+This book contains the text of Hamlet together with briefs and oral argument for and against affirmance of Prince Hamlet's (imaginary) murder convictions. The book arose out of a symposium sponsored by the Association of the Bar of the City of New York.
+
+"In the Pink Room," in Legal Ethics: Law Stories(D. Rhode & D. Luban, eds.) (Foundation Press, 2006) (also published as a freestanding monograph).
+
+# ARTICLES:
+
+Guns. Fruit. Drugs. and Documents: A Criminal Defense Lawyer's Responsibility for Real Evidence, 63 Stan. L. Rev. 813 (2011)
+
+Is Law (Still) An Honorable Profession? 19 Professional Lawyer 23 (2009)(based on a talk at Central Synagogue in Manhattan).
+
+Stephen Gillers
+
+PUBLICATIONS Professional Identity: 2011 Michael Franck Award Acceptance ARTICLES (continued) Speech, 21 Professional Lawyer 6 (2011).
+
+> Choosing and Working with Estate and Foundation Counsel to Secure an Artistic and Philanthropic Legacy in The Artist as Philanthropist, volume 2, page 293 (The Aspen Institute Program on Philanthropy and Social Innovation 2010)
+
+Virtual Clients: An Idea in Search of a Theory (with Lime), 42 Valparaiso L. Rev. 797 (2008) (Tabor lecture).
+
+The "Charles Stinson" Rule and Three Other Proposals to Protect Lawyers From Lawyers 36 Hofstra L. Rev. 323 (2007)
+
+A Tendency to Deprave and Corrupt: The Transformations& American Obscenity Law from Hicklin to Ulysses II, 85 Washington U. L. Rev. 215 (2007)
+
+Some Problem with Model Rule 5.6(a) Professional Lawyer (ABA 2007 Symposium Issue).
+
+Monroe Solution to the Criminal Defense Lawyer's Trilemma Is Wrong as a Matter of Policy and Constitutional Law, 34 Hofstra L. Rev. 821 (2006)
+
+"In the Pink Room," TriQuarterly 124.
+
+Free the Lawyers: A Proposal to Permit No-Sue Promises in Settlement Agreements, 18 Georgetown J. Legal Ethics 291 (2005) (with Richard W. Painter).
+
+Lessons from the Multiiurisdictional Practice Commission: The Art of Making Change 44 Ariz. L. Rev. 685 (2002).
+
+Speak No Evil: Settlement Agreements Conditioned On Noncooperation Are Illegal and Unethical, 31 Hofstra L. Rev. 1 (2002) (reprinted at 52 Defense L.J. 769 (2003)).
+
+"If Elected, I Promise ( 1"—What Should Judicial Candidates Be Allowed to Say? 35 Ind. L. Rev. 735 (2002).
+
+Legal Ethics: Art or Theory? 58 Annual Survey Am. L. 49 (2001).
+
+The Anxiety of Influence, 27 Fla. St. L. Rev. 123 (1999) (discussing rules that restrict multidisciplinary practice.
+
+Cana Good Lawyer Bea Bad Person? 2 J. Inst. Study of Legal
+
+Stephen Gillers
+
+PUBLICATIONS Ethics 131 (1999) (paper delivered at conference "Legal Ethics: ARTICLES (continued) Access to Justice" at Hofstra University School of Law, April 5-7, 1998).
+
+> More About Us: Another Take on the Abusive Use of Legal Ethics Rules, 11 Geo. J. Legal Ethics 843 (1998).
+
+> Caveat Client: How the Proposed Final Draft of the Restatement of the Law Governing Lawyers Fails to Protect Unsophisticated Consumers in Fee Agreements With Lawyers, 10 Geo. J. Legal Ethics 581 (1997).
+
+> Participant, Ethical Issues Arising From Congressional Limitations on Legal Services Lawyers, 25 Fordham Urban Law Journal 357 (1998) (panel discussion).
+
+> The Year: 2075, the Product: Law 1 J. Inst. Study of Legal Ethics 285 (1996) (paper delivered on the future of the legal profession at Hofstra University Law School's conference "Legal Ethics: The Core Issues").
+
+> Getting Personal 58 Law & Contemp. Probs. 61 (Summer/Autumn 1995) (contribution to symposium on teaching legal ethics).
+
+Against the Wall, 43 J. Legal Ed. 405 (1993) (ethical considerations for the scholar as advocate).
+
+Participant, Disqualification of Judges (The Sarokin Matter): Is It a Threat to Judicial Independence?, 58 Brooklyn L Rev. 1063 (1993) (panel discussion).
+
+The New Old Idea of Professionalism, 47 The Record of the Assoc Bar of the City of N.Y. 147 (March 1992).
+
+The Case of Jane Loring-Kraft: Parent. Lawyer, 4 Geo. J. Legal Ethics 115 (1990).
+
+Taking L.A. Law More Seriously, 98 Yale L.J. 1607 (1989) (contribution to symposium on popular legal culture).
+
+Protecting Lawyers Who Just Say No 5 Ga. St. L. Rev. 1 (1988) (article based on Henry J. Distinguished Lecture delivered at Georgia State University College of Law).
+
+Model Rule 1.13(c) Gives the Wrong Answer to the Ouestion of Corporate Counsel Disclosure, 1 Geo. J. Legal Ethics 289 (1987).
+
+Stephen Gillers
+
+PUBLICATIONS The Compelling Case Against Robert H. Boric, 9 Cardozo L. Rev.
+
+# ARTICLES (continued) 33 (1987).
+
+Ethics That Bite: Lawyers' Liability to Third Parties, 13 Litigation 8 (Winter 1987).
+
+Can a Good Lawyer Bea Bad Person?, 84 Mich. L. Rev. 1011 (1986).
+
+Proving the Prejudice of Leath-Qualified Juries After v. Texas: An Essa Review of Life in the Balance, 47 Pitt. L. Rev. 219 (1985), cited in v. McCree 476 U.S. 162, 197, 201 (1986) (Marshall, J., dissenting).
+
+What We Talked About When We Talked About Ethics: A Critical View of the Model Rules, 46 Ohio St. L.J. 243 (1985).
+
+The Quality of Mercy: Constitutional A at the Selection Stage of Capital Sentencing, 18 U.C. iracy L. Rev. 1037 (1985).
+
+Berger Redwy 92 Yale L.J. 731 (1983) (Review of Death Penalties by Raoul Bagel).
+
+Selective Incapacitation: Does It Offer More or Less? 38 The Record of the Assoc. Bar City of N.Y. 379 (1983).
+
+Great Expectations: Conceptions of Lawyers at the Angle of Entrv, 33 J. Legal Ed. 662 (1983).
+
+Perspectives on the Judicial Function in Criminal Justice (Monograph, Assoc. Bar City of N.Y., 1982).
+
+Deciding Who Dies 129 U. Pa. L Rev. 1 (1980) (quoted and cited as "valuable" in Spaziano v. Florida, 468 U.S. 447, 487 n.33 (1984) (Stevens, L, dissenting); also cited in Zant v. h 462 U.S. 862, 878 n.17, 879 n.19 (1983); v. M 76 U.S. 162, 191 (1986) (Marshall, J., dissenting); Calms v. 114 S.Ct. 1127, 1134 n.4 (1994) (Blackmun, J., dissenting); and Hams v. Alabama, 115 S.Ct. 1031, 1038-39 (1995) (Stevens, J., dissenting).
+
+Numerous articles in various publications, including The New York Times, The Nation, American Lawyer, The New York Law Journal, The National Law Journal, Newsday, and the ABA Journal. See below for selected bibliography.
+
+Stephen Gillers
+
+AWARDS 2011 Recipient, Michael Franck Award. Michael Franck Award from the ABA's Center for Professional Responsibility. The Award is given annually for "significant contributions to the work of the organized bar....noteworthy scholarly contributions made in academic settings, [and] creative judicial or legislative initiatives undertaken to advance the professionalism of lawyers...are also given consideration."
+
+VIDEOTAPES "Adventures in Legal Ethics and Further Adventures in Legal Ethics": videotape of thirteen dramatic vignettes professionally produced and directed and raising issues of legal ethics. Author, Producer. (1994)
+
+> "Dinner at Sharswood's Cafe," a videotape raising legal ethics issues. Author, Producer. (1996)
+
+"Amanda Kurnar's Case," a 38-minute story raising more than two dozen legal ethics issues. Author. (1998)
+
+TRIBUTES To Honorable Gus J. MI, printed at 749 Federal Supplement LXXXI and XCII (1991).
+
+## OTHER TEACHING
+
+Truth. Justice, and Paper, 27 Harv. Civ. R. Civ. Lib. L. Rev. 315 (1992) (to Norman Dorsen).
+
+Irving Younger: Scenes from the Public Life, 73 Minn. L. Rev. 797 (1989).
+
+Visiting Professor of Law, Harvard Law School, Winter 1988 Semester;
+
+Adjunct Professor of Law, Yeshiva University, Cardozo Law School, Spring 1986, Spring 1987, and Fall 1988 Semesters.
+
+Course: The Legal Profession.
+
+Adjunct Associate Professor of Law, Brooklyn Law School, 1976-78.
+
+Stephen Gillers
+
+# PRIOR EMPLOYMENT 1973 - 1978
+
+Private practice of law Warner and Gillers, P.C. (1975-78)
+
+1974 - 1978 Executive Director Society of American Law Teachers, Inc.
+
+1971 - 1973 Executive Director, Committee for Public Justice
+
+1969 - 1971 Associate, Paul, Weiss, Rifkind, Wharton & Garrison
+
+1968 - 1969 Judicial Clerk to Chief Judge Gus J. Federal District Court for the District of Oregon, Portland, Oregon
+
+SELECTED Testimony on "Nomination of Sandra Day to the TESTIMONY Supreme Court of the United States", Hearings, before the Senate Committee on the Judiciary, 97th Congress, 1st Sess., Sept. 11, 1981.
+
+> Testimony on S. 2216, "Habeas Corpus Reform Act of 1982", Hearings, before the Senate Committee on the Judiciary, 97th Congress, 2d Sess., April 1, 1982.
+
+Testimony on H.R. 5679, "Criminal Code Revision Act of 1981", Hearings, before the House of Representatives, Committee on the Judiciary, 97th Congress, 2d Sess., April 22, 1982.
+
+Testimony on S. 653, "Habeas Corpus Procedures Amendment Act of 1981", Hearings, before the Senate Committee on the Judiciary, 97th Congress, 1st Sess., November 13, 1981.
+
+Testimony on S. 8875 and A. 11279, "A Proposed Code of Evidence for the State of New York", before Senate and Assembly Codes and Judiciary Committees, February 25, 1983.
+
+Testimony before A.B.A. Commission on Women in the Profession, Philadelphia, February 6, 1988.
+
+Stephen Gillers
+
+**SELECTED
+TESTIMONY**
+(continued)
+
+Testimony on the nomination of William Lucas to be Assistant Attorney General for Civil Rights, before the Senate Committee on the Judiciary, 101st Congress, 1st Sess., July 20, 1989.
+
+Testimony on the nomination of Vaughn [REDACTED] to be United States District Judge for the Northern District of California, before the Senate Committee on the Judiciary, 101st Congress, 1st Sess., November 9, 1989.
+
+**PUBLIC
+LECTURES**
+(partial list)
+
+Tabor Lecture, Valparaiso University School of Law, April 12, 2007. This event consisted of two lectures. A public lecture was entitled "Here's the Gun: A Lawyer's Responsibility for Real Evidence." The Bench and Bar lecture, which will be published in the school's law review, is entitled "Virtual Clients: An Idea in Search of a Theory (With Limits)."
+
+Paul M. Van Arsdell, Jr., Memorial Lecture, University of Illinois, College of Law, March 7, 2005: "Do Lawyers Share Moral Responsibility for Torture at Guantanamo and Abu Ghraib?"
+
+Howard Lichtenstein Distinguished Professorship of Legal Ethics Lecture Series, "In Praise of Confidentiality (and Its Exceptions)," delivered at Hofstra University School of Law, November 12, 2003.
+
+Henry J. [REDACTED] Distinguished Lecture, Georgia State University College of Law, May 11, 1988. "Protecting Lawyers Who Just Say No."
+
+First Annual South Carolina Bar Foundation Lecture, April 9, 1992, University of South Carolina Law School, Columbia, South Carolina. "Is the Legal Profession Dead? Yearning to Be Special in an Ordinary Age."
+
+Philip B. Blank Memorial Forum on Attorney Ethics, Pace University School of Law, April 8, 1992. "The Owl and the Fox: The Transformation of Legal Work in a Commodity Culture."
+
+Speaker on Judicial Ethics, ABA Appellate Judges' Seminar and Flaschner Judicial Institute, September 29, 1993, Boston, Massachusetts.
+
+Baker-McKenzie Ethics Lecture, Loyola University Chicago School of Law, October 13, 1993, Chicago, Illinois ("Bias Issues in Legal Ethics: Two Unfinished Dramas").
+
+The Sibley Lecture, University of Georgia School of Law, Athens, Georgia, November 10, 1993 ("Telling Stories in School: The Pedagogy of Legal Ethics").
+
+Stephen Gillers
+
+## PUBLIC LECTURES (continued)
+
+## LEGAL AND PUBLIC SERVICE ACTIVITIES
+
+Participant, "Ethics in America" series (to be) broadcast on PBS 2007, produced by Columbia University Seminars on Media and Society.
+
+Participant, "Ethics in America" series, broadcast on PBS February and March 1989, produced by Columbia University Seminars on Media and Society.
+
+Participant, "The Constitution: That Delicate Balance, Part II" series, broadcast on PBS February and March 1992, produced by Columbia University Seminars on Media and Society.
+
+Lecturer on legal ethics and allied subjects in the U.S. and abroad at hundreds of seminars, CLE events, and conferences organized by private law firms, corporate law departments, the District of Columbia, Second, Fourth, Sixth, Ninth and Federal Circuit Judicial Conferences; American Bar Association; Federal Bar Council; New York State Judiciary; New York City Corporation Counsel; American Museum of Natural History; Practicing Law Institute; Law Journal Seminars; state, local and specialty bar associations (including in Oregon, Nebraska, Illinois, New York, New Jersey, Pennsylvania, Rhode Island, Vermont, and Georgia); corporate law departments; law schools; and law firms.
+
+Member, ABA 20/20 Commission, 2009- (appointed by the ABA President to study the future of lawyer regulation).
+
+Chair, American Bar Association Center for Professional Responsibility, Policy Implementation Committee, 2004-2008 (Member 2002-2010).
+
+Member, American Bar Association Commission on Multijurisdictional Practice, 2000-2002.
+
+Consultant, Task Force on Lawyer Advertising of the New York State Bar Association (2005).
+
+Retained by the New Jersey Supreme Court, in connection with the Court's review of the lawyer disciplinary system in New Jersey, to provide an "analysis of the strengths and weaknesses of California's 'centralized' disciplinary system" and to "report on the quality, efficiency, timeliness, and cost effectiveness of the California system...both on its own and compared with the system recommended for New Jersey by the Ethics Commission." Report filed December 1993. Oral presentation to the Court, March 1994.
+
+Stephen Gillers
+
+LEGAL AND Reporter, Appellate Judges Conference, Commission on Judicial PUBLIC SERVICE participation in the American Bar Association, (October 1990-August
+
+# ACTIVITIES 1991). (continued)
+
+Member David Dinkins Mayoral Transition Search Committee (Legal and Law Enforcement, 1989).
+
+Member, Committee on the Profession, Association of the Bar of the City of New York (1989-1992)
+
+Member. Executive Committee of Professional Responsibility Section, Association of American Law Schools (1985-1991).
+
+Chair, 1989-90 (organized and moderated Section presentation at 1990 AALS Convention on proposals to change the ABA Code of Judicial Conduct).
+
+Counsel, New York State Blue Ribbon Commission to Review Legislative Practices in Relation to Political Campaign Activities of Legislative Employees (1987-88).
+
+Administrator, Independent Democratic Judicial Screening Panel, New York State Supreme Court (1981).
+
+Member. Departmental Disciplinary Committee, First Judicial Department (1980- 1983).
+
+Member, Committee on Professional and Judicial Ethics, Association of the Bar of the City of New York (1979 - 1982).
+
+# BAR MEMBERSHIPS STATE:
+
+New York (1968)
+
+# FEDERAL:
+
+United States Supreme Court (1972); Second Circuit (1970); Southern District of New York (1970); Eastern District of New York (1970)
+
+Stephen Gillers
+
+LEGAL EDUCATION J.D. cum laude, NYU Law School, 1968 Order of the Coif (1968) List (1966-68) University Honors Scholar (1967-68)
+
+## PRELEGAL EDUCATION
+
+B.A. June 1964, City University of New York (Brooklyn College)
+
+DATE OF BIRTH November 3, 1943
+
+# OTHER ARTICLES (Selected Bibliography 1978-present)
+
+- 1. Carter and the Lawyers, The Nation, July 22-29, 1978.
+- 2. Standing Before the Bar, Bearing Gifts, New York Times, July 30, 1978.
+- 3. Judgeships on the Merits, The Nation, September 22, 1979.
+- 4. Entrapment, Where Is Thy Sting?, The Nation, February 23, 1980.
+- 5. Advice and Consent, New York Times, September 12, 1981.
+- 6. Lawyers' Silence: Wrong . . ., New York Times, February 14, 1983.
+- 7. The= Court It Still Lives, The Nation, September 17, 1983.
+- 8. Burger's Court, New York Times, September 25, 1983.
+- 9. "I Will Never Forget His Face!", New York Times, April 21, 1984.
+- 10. Court's Landmarks Still Stand, Newsday, July 29, 1984.
+- 11. Von Bulow, And Other Soap Operas, New York Times, May 5, 1985.
+- 12. Statewide Study of Sanctions Needed for Lawyers' Misconduct, New York Law Journal, June 6, 1985.
+- 13. Preventing Unethical Behavior Something New in Model Rules, New York Law Journal, August 30, 1985.
+- 14. Proposed Model Rules Superior to State's Code, New York Law Journal, October 21, 1985.
+
+- 15. Five Ways Proposed to Improve Lawyer Discipline in New York, New York Law Journal, January 8, 1986.
+- 16. Poor Man, Poor Lawyer, New York Times, February 28, 1986.
+- 17. Proposals To Repair Cracks in Ethical Legal Behavior, New York Law Journal, April 17, 1986. IS. Unethical Conduct: Ilow to Deter It Through Education, Bar Leader (May/June 1986).
+- 19. The New Negotiation Ethics Or Did Herb's Lawyer Do Wrong? New York Law Journal, June 2, 1986.
+- 20. The Real Stakes in Tort Reform, The Nation, July 19-26, 1986.
+- 21. Bernhardt Goetz: Vigilante Or Victim?, Toronto Star, September 10, 1986.
+- 22. The Message That the Goetz Trial Will Send, Newsday, August 31, 1986.
+- 23. Amending the Ethics Code Solicitation, Pre-Paid Plans, Fees, New York Law Journal, November 10, 1986.
+- 24. Amending the Ethics Code Conflicts of Interest, Screening, New York Law Journal, November 12, 1986.
+- 25. Amending the Ethics Code Confidentiality and Other Matters, New York Law Journal, November 13, 1986.
+- 26. No-Risk Arbs Meet Risk Justice, New York Times, November 23, 1986.
+- 27. The Meese Lie, The Nation, February 21, 1987.
+- 28. Amending State Ethics Code Conflicts of Interest Gone Awry, New York Law Journal, May 18, 1987.
+- 29. "The Lawyers Said It Was Legal," New York Times, June 1, 1987.
+- 30. Feminists vs. Civil Libertarians, New York Times, November 8, 1987.
+- 31. Lessons for the Next Round in Picking a Justice, Newsday, November 11, 1987.
+- 32. We've Winked For Too Long, National Law Journal, December 21, 1987 (judicial membership in exclusionary clubs).
+- 33. No More Meeses, New York Times, May I, 1988.
+- 34. In Search of Roy Cohn, ABA Journal, June I, 1988 (book review).
+
+- 35. Do Brawley Lawyers Risk Serious Discipline?, New York Law Journal, June 22, 1988.
+- 36. Have the Brawley Lawyers Broken the Law?, New York Times, July 2, 1988.
+- 37. Report Demonstrates Why Meese is Unfit to Be Attorney General, Atlanta Journal and Constitution, July 24, 1988.
+- 38. Ethical Questions for Prosecutors in Corporate-Crime Investigations, New York Law Journal, September 6, 1988.
+- 39. Restoring Faith at Justice, National Law Journal, November 21, 1988.
+- 40. Is Bush Repeating Rockefeller's Folly?, New York Times, September 11, 1989.
+- 41. Standards Time, The Nation, January 29, 1990 (on the subject of legislative ethics).
+- 42. Abused Children vs. The Bill of Rights, New York Times, August 3, 1990.
+- 43. Words Into Deeds: Counselor, Can You Spare a Buck?, ABA Journal, November 1990.
+- 44. Bad Apples, ABA Journal at 96 (March 1991) (book review).
+- 45. The Gotti Lawyers and the Sixth Amendment, New York Law Journal, August 12, 1991.
+- 46. Justice or Just Us? The Door to Dan Quayle's Courthouse Only Swings One Way, ABA Journal (June 1992) at 109.
+- 47. Fighting Words (What was once comical is now costly), ABA Journal (August 1992) at 102.
+- 48. Sensitivity Training: A New Way to Sharpen Your Skills At Spotting Ethics Conflicts, ABA Journal (October 1992) at 107.
+- 49. Under Color of Law: Second Circuit Expands Section 1983 Liability for Government Lawyers, ABA Journal (December 1992) at 121.
+- 50. Cleaning Up the S&L Mess: Courts Are Taking the Duty to Investigate Seriously, ABA Journal (February 1993) at 93.
+- 51. All Non-Refundable Fee Agreements Are Not Created Equal, New York Law Journal (February 3, 1993) at I. (Analyzing appellate decision prohibiting non-refundable fees.)
+- 52. The Packwood Case: The Senate Is Also on Trial, The Nation (March 29, 1993) at 404.
+- 53. Conflict of Laws: Real-World Rules for Interstate Regulation of Practice, ABA Journal (April 1993) at II!.
+
+- 54. Packwood II, The Nation (May 10, 1993) at 617.
+- 55. Generation Gap, ABA Journal (June 1993) at 101. (On the use of a boycott in response to the Colorado anti-gay initiative.)
+- 56. Future Shocks, ABA Journal (August 1993) at 104. (Looking back on the practice of law in the 21st century from the year 2103.)
+- 57. A Rule Without a Reason, ABA Journal (October 1993) at 118. (Criticism of the prohibition in Rule 5.6(b) against a lawyer agreeing not to restrict future practice in connection with a settlement.)
+- 58. Too Old to Judge?, ABA Journal (December 1993) at 94. (Supreme Court justices have life tenure. Maybe they should not.)
+- 59. Truth or Consequences, ABA Journal (February 1994) at 103. (Discovery obligations.)
+- 60. "Ethical Cannons," in Symposium Twenty Years of Change, Litigation (Fall 1993).
+- 61. Stretched Beyond the Limit, Legal Times (March 21, 1994) at 37. (Analysis of the office of Counsel to the President in light of Bernard Nussbaum's resignation.) [Same article was reprinted in the Connecticut Law Tribune, the Fulton County (Atlanta) Daily Report, and the Recorder (San Francisco).]
+- 62. Putting Clients First, ABA Journal (April 1994) at 11 I. (Discussing cases on lawyers' fiduciary duty.)
+- 63. Grisham's Law, The Nation (April 18, 1994) at 509. (The effect of popular culture on Whitewater reporting.)
+- 64. The Elsinore Appeal: "People v. Hamlet", New York Law Journal (October II, 1994) at 3. (Brief for Appellee, State of Denmark). (This was a mock appeal from Hamlet's conviction for the murder of Claudius, Polonius, Ophelia, Laertes, Rosencrantz & Gildenstem, held at the Association of the Bar of the City of New York on October II, 1994.)
+- 65. Billing for Costs and Disbursements: What Law Firms Can Charge and Clients Can Expect, monograph published 1995 by Pitney Bowes Management Services.
+- 66. Clinton Has A Right To Privacy, N.Y. Times, 12/21/95, at
+- 67. "'Filegate' Was Bad Enough. Now This?," N.Y. Times, 7/5/96, at A23. (Article criticizing proposal to privatize certain security investigations of government personnel.)
+- 68. "Whitewater: How to Build a Case Using a Tainted Witness," Los Angeles Times, 2/16/97, at Ml.
+- 69. "Hillary Clinton Loses Her Rights," New York Times, 5/4/97, at El 5.
+
+- 70. "Shakespeare on Trials," IV Federal Bar Council News 16 (June 1997).
+- 71. "Florida Backs Out On a Deal," New York Times, 10/10/97, at A23.
+- 72. "The Perjury Loophole," New York Times, 2/18/98, at A21 (discussion of perjury in connection with Kenneth Starr's investigation of President Clinton).
+- 73. "Any Method to Ginsburg's Madness?" Los Angeles Times, 3/15/98, at MI (discussion of William Ginsburg's public defense of Monica Lewinsky).
+- 74. "Whitewatcr Made Easy," The Nation, 6/1/98, at 8.
+- 75. "A Highly Strategic Legal Chess Game," Los Angeles Times, June 7, 1998, at MI (Starr-Clinton legal maneuvers).
+- 76. "To Sleep . Perchance, to Dream," New York Law Journal, July 8, 1998, at 2. (Humorous article about bored jurors.)
+- 77. "Clinton Is No Ordinary Witness," New York Times, 7/28/98, at A15.
+- 78. "The High Cost of an Ethical Bar," The American Lawyer, July/August 1998, at 87.
+- 79. "Clinton's Choice: Tell Truth or Dare to Gamble," Los Angeles Times, August 2, 1998, at M1.
+- 80. "Accurate Lies: The Legal World of Oxymorons," Los Angeles Times, August 30, 1998, at M I .
+- 81. "A Fool For a Client?" The American Lawyer, October 1998, at 74. (President Clinton's legal representation in the Lewinsky representation.)
+- 82. "The Presidency: Out to End Clinton's Mess and Be Happy," Los Angeles Times, October 4, 1998, at MI.
+- 83. "Protecting Their Own," The American Lawyer, November 1998, at 118.
+- 84. "Can't We All Just Practice Together: Taking Down `Trade Barriers' on Lawyers Here and Abroad," Legal Times, November 9, 1998, at 32.
+- 85. "Beyond the Impeachment Spectacle," Los Angeles Times, November 22, 1998, at MI.
+- 86. "The Perjury Precedent," New York Times, December 28, 1998, at A27.
+- 87. "From the Same Set of Facts: A Tale of Two Stories," Los Angeles Times, January 17, 1999, at MI (about the Clinton impeachment trial).
+
+- 88. "The Decline and Fall of Kenneth Starr," Los Angeles Times, February 7, 1999, at Ml.
+- 89. "The Truth About Impeachment," The American Lawyer, March 1999, p. 131.
+- 90. "The Double Standard," New York Times Book Review, March 21, 1999, at 13 (review of No Equal Justice by David M).
+- 91. "Four Officers, One Likely Strategy," New York Times, Saturday, April 3, 1999, at A15.
+- 92. "The Man in the Middle: Did Ventura Step Over the Ethical Line?" The American Lawyer, May 1999, p. 80 (discussion of lawyer whistleblowing in light of Stare v. Ventura). (Reprinted as "Whistleblower, Esq." in New York Law Journal, May 26, 1999 at page 2.)
+- 93. "Your Client Is A Corporation Are Its Affiliates Clients Too?" The New York Professional Responsibility Report, May 1999 , at 1.
+- 94. "Job Talk (Scenes from the Academic Life)," The American Lawyer, July 1999, at 161. (Satire about law school hiring.)
+- 95. "The Other Y2K Crisis," The Nation, July 26/August 2, 1999, at 4 (editorial about the year 2000 electoral races).
+- 96. "Walking the Confidentiality Tightrope," ACCA Docket 20 (September/October 1999) (remarks at ACCA's national conference in 1998).
+- 97. "Things Old & New The Code Amendments," New York Professional Responsibility Report (September 1999), at 1.
+- 98. "Clinton's Chance to Play the M," New York Times, Sept. 20, 1999 at A17.
+- 99. "Ovcrprivileged," American Lawyer, October 1999 at 37. (Discussion of First Amendment protection for journalists.)
+- 100. "Controlling Conflicts Between Old and New Clients," New York Professional Responsibility Report, January 2000 at 3.
+- 101. "How To Spank Bad Lawyers," American Lawyer, February 2000 at 41.
+- 102. "A Weak Case, But a Brave Prosecution," New York Times, Wednesday, March 1, 2000 at A23 (the Diallo case).
+- 103. "Conflicts of Interest in Malpractice Cases," New York Professional Responsibility Report, March 2000 at 1.
+- 104. "The Court's Picayune Power," New York Times, Thursday, April 20, 2000 at A29.
+
+- 105. "Some Misrepresentations Among Corporate Lawyers," New York Professional Responsibility Report, June 2000 at I.
+- 106. "Was Hubbell Case About Getting Justice or Getting Even?" Los Angeles Times, June 18, 2000 at M2 (comment on the U.S. Supreme Court's decision in United States v. Hubbell, decided June 5, 2000).
+- 107. "Who Owns the Privilege After a Merger?" New York Professional Responsibility Report, July 2000 at 1.
+- 108. "Fighting the Future," The American Lawyer, July 2000 at 55.
+- 109. "Campus Visits Deconstnicted," Newsweek: How To Get Into College, 2001 Edition at 46.
+- 110. "The Court Should Boldly Take Charge," New York Times, Tuesday, November 21, 2000 at A25 (Florida's presidential election recount).
+- Ill. "Who Says the Election Has a Dec. 12 Deadline?" New York Times, Saturday, December 2, 2000 at A19.
+- 112. "Motive Is Everything in the Marc Rich Pardon," New York Times, Saturday, February 17, 2001.
+- 113. "For Justice To Be Blind, Must Judges Be Mute?" New York Times, Sunday, March 4, 2001 at Section 4, page 3.
+- 114. "Should Supreme Court Justices Have Life Tenure?" Reprinted in The Supreme Court and Its Justices (Choper J., ed.) (ABA 2001).
+- 115. Professionalism Symposium, 52 South Carolina L. Rev. 55 (2001) (closing remarks).
+- 116. "No Lawyers To Call," New York Times, Monday, December 3, 2001 at Al9 (ethical and constitutional obligations that will prevent lawyers from participating in military tribunals).
+- 117. "Let Judicial Candidates Speak," New York Times, Thursday, March 28, 2002 at A31.
+- 118. "The Flaw in the Andersen Verdict," New York Times, Tuesday, June 18, 2002 at A23.
+- 119. "Why Judges Should Make Court Documents Public," New York Times, Saturday, November 30, 2002 at A17.
+- 120. "It's an MJP World," ABA Journal, December 2002 at 51.
+- 121. "Upholding the Law as Pretrial Publicity Goes Global," New York Times, Sunday, April 27, 2003, Sec. 4 at 14.
+
+1. 122. "Court-Sanctioned Secrets Can Kill," Los Angeles Times, Wednesday, May 14, 2003 (reprinted May 15, 2003 in Newsday).
+2. 123. "Make a List," New York Times, June 11, 2003 at 31 (advocating changes in the methods of judicial selection).
+3. 124. "Conflicted About Martha?" American Lawyer (September 2003) (analysis of Martha Stewart indictment).
+4. 125. "The Prudent Jurist," Legal Affairs, January/February 2004.
+5. 126. "On Knowing the Basic Rules of Advocacy," New York Times, February 8, 2004, Sec. 4 at 2 (cross-examination in the Martha Stewart trial).
+6. 127. "The Prudent Jurist," Legal Affairs, March/April 2004.
+7. 128. "Scalia's Flawed Judgment," The Nation, April 19, 2004 at 21.
+8. 129. "Scholars, Hucksters, Copycats, Frauds," Washington Post, April 25, 2004 at B3 (Outlook) (discussion of ethics of academics who put their names on newspaper opinion pieces written by industry).
+9. 130. "The Prudent Jurist," Legal Affairs, May/June 2004 at 17.
+10. 131. "Multijurisdictional Practice of Law: Merging Theory With Practice," 73 The Bar Examiner 28 (May 2004).
+11. 132. "Tortured Reasoning," American Lawyer (July 2004) (analysis of government lawyer memos addressing the application of various treaties and laws to the treatment of Afghan prisoners).
+12. 133. "Paying the Price of a Good Defense," New York Times, August 13, 2004.
+13. 134. "Improper Advances: Talking Dream Jobs with the Judge Out of Court," Slate.com, August 17, 2005 (with D. Luban and S. Lubet).
+14. 135. "[REDACTED] Bad Decision," Los Angeles Times, September. 13, 2005 (with D. Luban and S. Lubet).
+15. 136. "No Privilege for Miers," The Nation, November 7, 2005
+16. 137. "Senators, Don't Rubber-Stamp," USA Today, January 5, 2006 at 13A (discussing the Senate's advise and consent responsibility in connection with Alito nomination).
+17. 138. Ethics Column, American Lawyer, page 61 (January 2006) (with Deborah Rhode).
+18. 139. Ethics Column, American Lawyer, page 63 (April 2006) (with Deborah Rhode).
+
+- 140. "Bush Postpones 2008 Election," The Nation, August 14/21, 2006 (satire).
+- 141. "Free the Ulysses Two: Joyce's First U.S. Publishers Were Convicted of Obscenity. It's Time to Clear Them." The Nation, February 19, 2007.
+- 142. "Twenty Years of Legal Ethics: Past, Present, and Future," 20 Georgetown J. Legal Ethics 321 (2007) (symposium celebrating the 20th anniversary of the journal).
+- 143. "The Torture Memos," The Nation, April 28, 2008.
+- 144. "Bar None," American Lawyer (October 2008) (globalization of law practice and how it will effect regulation of the bar).
+
+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+v.
+
+PAUL M. DAUGERDAS. DONNA GUERIN. DENIS FIELD, and DAVID PARSE,
+
+Defendants.
+
+STATE OF NEW YORK ) ss.: COUNTY OF NEW YORK )
+
+ECF CASE
+
+Case No. S3 09 Cr. 581 (WHP)
+
+AFFIDAVIT OF DAVID PARSE
+
+DAVID PARSE, being duly sworn, deposes and says:
+
+- 1. My name is David Parse, and I am a defendant in the above-captioned case.
+- 2. During jury selection (or shortly thereafter), I heard one of the lawyers at the Brune firm (I believe it was Theresa Trzaskoma) say that there was a prospective juror (or a juror) who had the same name as a suspended attorney but that it was not the same person. I cannot recall if the lawyer was speaking to me or if I overheard her speaking to someone else.
+- 3. A week after the verdict, I met with the Brune lawyers to discuss possible posttrial motions and appellate issues. The possibility of a juror misconduct issue was not raised.
+- 4. It was not until after the Brune firm tiled its motion for a new trial that I learned that prior to jury deliberations the issue of Conrad being a suspended lawyer had resurfaced. More precisely, to the best of my memory. it was alter the July 15, 2011 conference call that I learned (i) that on Trzaskoma had considered the possibility that Juror No. I
+
+was the suspended lawyer, (ii) that a paralegal had generated a Westlaw report, and (iii) that the Brune lawyers had concluded that Conrad was not the suspended attorney and determined that there was no need to inform the Court.
+
+![]()Sworn to before me this
+3rd day of August, 2012
+
+![]()OFFICIAL SEAL
+WILLIAM B KAVANAUGH
+NOTARY PUBLIC - STATE OF ILLINOIS
+MY COMMISSION EXPIRES 12/14/12
+
+**[PAGES A-5874 TO A-5902 INTENTIONALLY LEFT BLANK]**
+
+1 UNITED STATES DISTRICT COURT 1 SOUTHERN DISTRICT OF NEW YORK
+
+2 2
+
+3 UNITED STATES OF AMERICA,
+
+3
+
+4 v. 09 CR 581 (WHP)
+
+4
+
+5 DAVID K. PARSE,
+
+5
+
+6 Defendant..
+
+6 7 7
+
+8 New York, N.Y. 8 Octoser 12, 2012 9 3:00 p.m.
+
+9 10
+
+10 Before:
+
+11
+
+11 HON. WILLIAM H. PAULEY III,
+
+12
+
+12 District Judge
+
+13 13
+
+## 14 APPEARANCES
+
+14
+
+15 PREET BHARARA
+
+15 United States Attorney for the 16 Southern District of New York
+
+16 STANLEY J. OKULA
+
+17 NANETTE 17 Assistant United States Attorneys
+
+18
+
+18 ZUCKERMAN SPAEDER
+
+19 Attorneys for Defendant
+
+19 PAUL SHECHTMAN
+
+1 (In open court) 2 THE DEPUTY CLERK: Case of United States of America v. 3 David Parse. Appearances for the government?
+
+4 : Good afternoon, your Honor. Nanette S and Stanley J. Okula, Jr. for the government.
+
+6 THE COURT: Good afternoon,
+
+7 MR. SHECHTMAN: Paul Shechtman for Mr. Parse. III 8 Fell:gold who is a paralegal who has worked on this matter is
+
+9 with me, and obviously Mr. Parse is here. 10 THE COURT: Good afternoon, Mr. Shcchtman. And I note 11 the presence of Mr. Parse at counsel table.
+
+12 This is oral argument on the defendant Parse's motion 13 for a new trial. Do you wish to be heard, Mr. Shechtman?
+
+14 MR. SHECHTMAN: I do, your Honor. As your Honor now 15 knows and from the papers, there is only one issue here which
+
+16 is a question of ineffective assistance of counsel. 17 THE COURT: If you can just pull the mike a little
+
+18 closer. It has been a long week. 19 MR. SHECHTMAN: I understand. I think for all of us.
+
+20 Justice once said that Strickland was the 21 most cited case that she ever wrote, and I say that. because I
+
+22 assume the Court is quite familiar with it and the legal 23 standard. And obviously the standard is two part.
+
+24 I would like to think though, I may be proven wrong, 25 that if we get to prejudice, we should prevail. But we can
+
+1 have that discussion.
+
+2 The first question obviously is was the performance 3 deficient here. And that I think turns on the question of did 4 the Brune firm make a strategic judgment on that fateful 5 May 12, 2011 day, maybe even earlier during the voir dire 6 itself. And I'm not sure there is a great definition of 7 strategic judgment, but there is very good language in Justice 8 Stevens' dissent, but I don't think the majority disagreed with 9 it, that talks about a conscious choice between two 10 alternatives borne of deliberation not happenstance, 11 inattention or neglect.
+
+12 The Second Circuit has told us that it is not. a 13 strategic judgment when what is going on is oversight or 14 carelessness or ineptitude.
+
+15 I like to think about this as strategic judgments are 16 situations where lawyers say, one of two courses could have 17 answered my client's interests. I choose A after some thought. 18 It may be that B is the wiser course. But we'd retry a lot of 19 cases if we second guess lawyers in that situation and 20 obviously the Supreme Court says we shouldn't.
+
+21 I say in our papers that if what went on here was one 22 of two things. If the Brune firm in that plaza conversation 23 said the equivalent of let's sandbag the Court, let's go 24 forward. We know this information and we get a free bite at 25 the apple. It's hard to think that's not a strategic decision, SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 and that of course is very similar to the Chappee case in the 2 First Circuit. Justice Stevens talks about it being a 3 legitimate decision, but even an unethical one like sandbagging 4 I think is going to turn out to bind the client. S The other way this could be a strategic decision, if 6 what they said to themselves, let's sandbag, but more, look, 7 she is a pro-defense juror given what we know about this 8 checkered history, let's keep her on because we're likely to 9 get an acquittal now. That's the government's view here. 10 That's what they've advanced in their papers. And I think 11 that's not at all what happened in this case. 12 I think the testimony, and the Court referred to the 13 testimony and said the facts were largely undisputed. That 14 doesn't mean the inferences from them were ones that all sides 15 were ready to adopt. But I don't think the core facts were 16 much in dispute at the hearing. And what happened here, 17 particularly on that day of May the 12th, is that Ms. I will 18 say Theresa because I have trouble with her last name, I 19 apologize, had real second thoughts when she thought about that 20 juror note and the legal words in it. She then sent paralegals 21 to work -- as your Honor knows, the one thing about the Brune 22 firm is they had an army of them. And she got information 23 back, and her e-mail said something like, Jesus, I think it's 24 her. And whether that is characterized as fleeting or a belief 25 held longer than that, there is no doubt that she thought it.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 What's always been odd to me is when she gets to the 2 plaza, how quickly she abandons it. And whether it is because 3 she's exhausted at the end of a long trial, whether it's 4 because, as she said, she looked more at this report and she 5 thought it was more complicated, whether it was because her 6 seniors cowed her. But, as your Honor says, the discussion 7 there was superficial and never addressed the information that 8 she had accumulated over the last 12 hours. And she simply 9 goes along. And she goes along with her two seniors who don't 10 know of the Westlaw report, but say to themselves it can't be 11 her. There is no need to tell the judge. Let's go home, it's 12 been a long day, a long trial.
+
+13 Now, we differed back at the time as to whether that 14 was a waiver or not. But there is no doubt that that is nol a 15 judgment that a lawyer should have made in that situation.
+
+16 Your Honor referred to it as a tragic misjudgment, and it was.
+
+17 One of two things should have happened. There should 18 have been an investigation, or there should have been someone 19 saying, why me investigate? Let's just tell the Court and 20 we'll go from there. And neither of those things happened.
+
+21 Instead, people went home, they spoke to their colleagues a day
+
+22 or two later, and said, geez, she has the same name, but it
+
+23 can't be her. And nobody said, well, let's do the easy thing
+
+24 and let's tell the Court. As your Honor says, a few days
+
+25 later, we substituted a new juror and nobody thinks to
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+1 themselves we could just tell the judge. 2 Strickland talks about counsel has a duty to make 3 reasonable investigations or make a reasonable decision that 4 makes particular investigation unnecessary. And if ever there 5 was a reason either to investigate more, to unleash the 6 Nardello firm, or, I say this respectfully, unleash the Court. 7 Because as crazy as this woman was, I've always thought if your 8 Honor brought her out and said are you the same person, I'm not 9 sure her lying would have gone that far. You may disagree with 10 me on that, but I think she would have had trouble there. 11 But nobody does it. And nobody does it not because 12 they were playing a strategic game that they were out to 13 sandbag a court or they were out to get an acquittal. They 14 didn't do it because, to use the Second Circuit's word, it was 15 an oversight, it was careless, it was inept. And if I'm right 16 about that, then I think one has met the first prong here, and 17 then the question becomes prejudice. 18 And I can talk more, your Honor, the government 19 doesn't argue sandbagging. I can talk more about why I think 20 this wasn't -- look, 7've read the Court's opinion, I think 21 only seven times. And I know that the Court at the end of it 22 talks about gambling. But, I don't think the Court is making 23 findings in that opinion that there was a great strategy going 24 on in that court. I think your Honor's findings are that these 25 people really dropped the ball, and they failed to do what they SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 should have done as lawyers. And then after that, I've always 2 thought, partly because they dropped the ball, they were less 3 than candid in what they said to the Court going forward. 4 THE COURT: That last point is really another part of 5 the analysis, isn't it, that, why shouldn't this Court view 6 Brune 6 Richard's lack of candor with the Court in making their 7 motion as circumstantial evidence that they were in fact trying 8 to conceal from the Court a strategic decision they made?
+
+9 MR. SHECHTMAN: Look, I think, and the Court does in 10 its opinion consider it as circumstantial evidence and it's not 11 a pretty picture. But the question to me has always been what 12 is it circumstantial evidence of? And I think it is 13 circumstantial evidence of a realization that they had a 14 responsibility to tell the Court, and they walked away that 15 night and really left the Court in an untenable position such 16 that at least two, and I hope three, defendants may be on trial 17 again in the spring.
+
+18 So, I don't have any doubt that you can take that 19 conduct and look back. The question is, do you look back and 20 say to yourself, these are people who knew they dropped the 21 ball and were careless and inattentive and didn't fulfill their 22 obligations to the Court? Or do you go back and say these are 23 people who made a strategic decision to game the system at an 24 earlier time. I don't think there is any evidence to support 25 that. As I've said before, there is nothing in that plaza
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
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+1 conversation -- 2 THE COURT: I'm really thinking about beyond the plaza 3 conversation, at the time a month and a half later when they 4 filed their motion, they failed to disclose to the Court what 5 they knew and when they knew it. And a series of proceedings 6 then occur, essentially initiated by both the Court and the 7 government to find out what they knew and when they knew it. 8 And their statements in their memorandum to the Court on their 9 motion that they knew were wrong or misleading at the time that 10 they made them to me. 11 MR. SHECHTMAN: You're not going to get much argument 12 from me on the point. The Court has a sort of lovely phrase in 13 the opinion about disclosure by iteration or something like 14 that. There is no doubt when you go from the telephone 15 conversation to the document itself, and then to and not 16 wanting further discovery, wanting your Honor to somehow 17 address a preliminary issue and issues of privilege. Your 18 Honor knows I got in this case late and the first thing I did 19 was to say, what are we kidding ourself? We are going to turn 20 over those documents to the Court because worse comes to worst, 21 the Court is going to look at them in camera. And if it is 22 going to look at them in camera, it is going to look at them, I 23 don't know you can say out of camera, but it's going to look at 24 them. This is not a game.
+
+25 I think what happened, though, is lawyers said to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 themselves we failed the Court. I have said to myself a 2 hundred times, it is so easy the next morning or even that 3 afternoon to walk back in and say to the judge, Judge, we 4 think -- we don't really believe this, for a variety of 5 reasons, but you should know the following. That she has the 6 same name, there is other information here, and whatever your 7 Honor wants to do with it, we don't think it's her, but we 8 would be foolish if we didn't bring this to your attention.
+
+9 I think what happened to the Brune firm was after this 10 revelation, they said to themselves II God, we really did drop 11 the ball. But dropping the ball is ineffectiveness. Dropping 12 the ball to me is not strategy.
+
+13 Look, if your Honor looks at that conduct, and I know, 14 and I say this respectfully, I know how much that conduct eats 15 at the Court because it's wrong, and the result of it is a very 16 long trial in this courtroom has to be done again. But, I also 17 don't think that one looks at it and says ah-ha, there was a 18 strategy going on.
+
+19 I think the lawyers thought to themselves that the 20 Court is going to be very disappointed in us if it realizes 21 that we didn't come forward. Right. If it realizes we took 22 for an answer it can't be her, when investigation or telling 23 the Court was the better course.
+
+24 If the Court concludes that that conduct is so 25 egregious that circumstantially it proves strategy, I'm not SOUTHERN DISTRICT REPORTERS, P.C.
+
+1212) 805-0300
+
+1 going to win. We're going to have a sentencing in January and 2 not a trial in the spring. But I don't think you can read that 3 much into it, and I don't think that in fairness to Mr. Parse 4 the record supports that. But I understand your Honor's views 5 of the matter. I can't say more.
+
+6 THE COURT: Other than the alleged deficiencies by the 7 Brune firm regarding Juror No. 1, was Parse's counsel otherwise 8 constitutionally effective?
+
+9 MR. SHECHTMAN: Look, I've never read a trial record 10 where I didn't say I wish they would have preserved Chat issue, 11 I wish they would have made that argument, I think that 12 cross-examination could have been stronger. I came away from 13 that trial thinking, boy, that Barry Berke is a great 14 cross-examiner.
+
+15 If you asked me was it constitutionally adequate, you 16 bet. It was very solid defense by a group of very good 17 lawyers. So, that one's easy for me.
+
+18 THE COURT: Can you think of any circumstance where a 19 Court could find both a waiver to an impartial jury and 20 effective assistance of counsel?
+
+21 MR. SHECHTMAN: Yes. I think. The simplest one is if 22 it really was a strategic decision, take the most blatant case, 23 the lawyer said to themselves tree bite at the apple, don't 24 tell the judge. If we get an acquittal the great thing about 25 the double jeopardy clause is it's over. That is a waiver
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+under any definition. 2 7t's also under Chappee in the First Circuit, and I 3 would bet it is also effective assistance. Or it's not 4 ineffective assistance, even though one can say that's back 5 alley -- I can't remember the words in Chappee, but they are 6 not very flattering. Even though you can say those things, 7 it's got to be effective assistance because you're not going to 8 let people get away with that game. There is a perfect 9 example.
+
+:0 You can have, I've done this as a grid, and you can 11 have, if you put waiver and ineffective assistance, you can 12 fill out most of the four boxes. There is a case in the Second 13 Circuit that I stumbled across which is Flores. It is old 14 enough there is a Judge Van Graafeiland dissent. Flores is one 15 where there is a waiver. The trial lawyer I think says after 16 trial, look, I've come across this 3500 material, this Rosario 17 material, but it wouldn't have helped me very much. And he 18 says it at a time when it is per se reversible not to have 19 turned over that 3500 material. There is no harmless error 20 standard, that's how crazy New York law was. And the First 21 Department in New York Court of Appeals says waiver. You say 22 right on the record you're not pressing the issue. The Second 23 Circuit said ineffective assistance, right. How can a lawyer 24 possibly having been handed a piece of paper which is a new 25 trial card, how can you not play it. So there is a situation SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+1 where you can have waiver, but ineffective assistance. And I 2 think it is that that Judge Easterbrook had in mind when he 3 said you have to think about each of these doctrines separately 4 and you can probably have every combination of them.
+
+5 THE COURT: All right.
+
+6 MR. SHECHTMAN: Look, on the prejudice prong, I would 7 just say this. There were acquittals on all but two of these 8 counts. Mr. Parse is not situated that much differently than 9 Mr. Brubaker, and the proof as it came in didn't come in much 10 differently. There is a sort of lovely irony here that the 11 government cooperator who the Jenkins lawyer dealt with him was 12 actually a witness, and so, the Kramer Levin firm got to 13 cross-examine him. And in a sense having him as a cooperator 14 was helpful to their side because they established that their 15 client, like the taxpayers and everyone else, was told 16 repeatedly this is lawful. What distinguishes these two men is 17 the, quote, backdate.
+
+18 And what I've tried to say in my papers is I think the 19 government was very good at trial in turning this into a 20 backdating case. I don't think that's what the Deutsche Bank 21 records show. They are doing these in February and March and 22 putting them on February and March statements and they're 23 putting "as of." They're then going out to what are very 24 accomplished tax preparers who were getting February, March 25 statements. And know there was a mistake and are then filing
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212> 805-0300
+
+1 tax returns. 2 At the end of the day, the government's brief takes 3 you at great pains through each of those three backdating 4 transactions. And I should say, quote, backdating 5 transactions. What you learn is what is undisputed is that's 6 what happened. Mistakes in the craziness of this law firm where you were churning these things out every December and taking a portion of the losses into income, the tax loss, in 9 the craziness of that and mistakes were made. And trades were 10 done to try to correct the mistakes. You can't dispute that. 11 The only question at the end of the day, as I say in 12 the papers, is mens III. And the mens III when you read the 13 government's evidence, the bottom line is he must have known. 14 And he must have known because he was an accountant.
+
+15 And what we know on that is I think for two years, in 16 the '80s, he was a junior accountant at 20 some thousand 17 dollars a year. There is not a shred of evidence that he ever 18 took a class that taught, quote, the annual accounting rule, 19 and I think the Court knows the Second Circuit precedent that 20 says "must have known" is an argument, but it's not of great 21 weight.
+
+22 And I'll stop with this. I have to say, I wasn't in 23 the must've known category. This wasn't something that I was 24 taught in tax law. Maybe I forgot it and maybe the answer is 25 it's so obvious you didn't have to teach it. But I said to SOUTHERN DISTRICT REPORTERS, P.C.
+
+1212) 805-0300
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+1 myself the other night, if somebody had said to me, and again I 2 apologize for the example, I won't try Co belabor it. But 3 December 28 in year one if I gave 10,000 shares of IBM to a 4 charity and 10,000 shares Co my daughter, right, and I said to 5 my broker just move them into those -- 10,000 to charity, 6 10,000 to my daughter. And the broker made a mistake. And 7 here's what makes it so tricky. The shares to the charity were 8 IBM; the shares to my daughter were Philip Morris. They 9 reversed it. The charity calls January 2nd and says we can't 10 take tobacco . We can't accept your gift. I call the 11 broker, I say what about this. He says we'll just reverse it. 12 It was our mistake. We'll send the Philip Morris to your 13 daughter and we'll send the IBM to the charity. And they 14 reverse it and they put as of December 28 because they reverse 15 it and do it at December 28 prices and it all shows up on the 16 January statement.
+
+17 If I said to Mr. Parse, if I said to me -- the Court 18 may be situated differently, the Court's been educated by this 19 trial. If I said can 1 put that tax deduction on my year one 20 return, in that situation, even though it was mistake, it never 21 got accepted, I'd say I don't know, you should ask a tax 22 lawyer. And that's what Mr. Parse said. He made the 23 transactions, he made the change, not a single document at 24 Deutsche Bank reflected that this happened other than the as of 25 which was a reflection of what the pricing was.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+1 I'm sitting here with a tolling agreement from the 2 Southern District in a case of mine which says as of 3 January 14. Which is faxed on January 16. But everybody 4 wanted it to be effective two days before because that was the 5 agreement, as happens in the Southern District. It happens 6 everywhere. And it doesn't mean backdating. In this case it 7 means this is the price.
+
+8 But all that is a long way of saying there is no proof 9 that he knew this rule. There is no proof it was discussed 10 with him. There is no proof he thought he knew these 11 transactions were wrong. And at the end of the day, when one's 12 argument is he must've known, that's a weak IIII, particularly 13 when this prejudice notion is harmless error like. After all, 14 you have Justice Marshall's dissent in Strickland that says it 15 should have been harmless error, it should have been under the 16 government's burden. When you do harmless error analysis, you 17 say two things: What is the nature of the error, and what's 18 the proof. The nature of the error here is that a government 19 partisan out to get him in particular was on the jury. That's 20 a pretty serious error. The proof, far from overwhelming.
+
+21 As I say, I think if I can get you to the prejudice 22 prong, we ought to see you in April and not in January and I 23 hope that's the case.
+
+24 THE COURT: Thank you, Mr. Shechtman.
+
+25 , does the government want to be heard?
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+CAC3PARC 1 Yes, please, your Honor. 2 Good afternoon, your Honor. I'm glad to see that 3 Mr. Shechtman has conceded that other than this particular 4 area, Mr. Parse did in fact receive what can only be described S as a platinum plated defense with a defense team that most 6 defendants can only dream of. 7 MR. SHECHTMAN: I don't think I quite went that far, 8 your Honor. 9 I do think, though, that had Mr. Shechtman 10 been here at trial and seen the forces that were mustered in 11 Mr. Parse's favor, he would have to admit that it is a rare 12 scene in such a courtroom for an individual defendant. 13 Your Honor, the crux of it is that defendant Parse is 14 seeking to be rewarded now for the strategic choices of his 15 attorney regarding Catherine Conrad and their knowledge of her. 16 Choices for which he has already benefited in the form of 17 acquittals on the conspiracy and the tax evasion counts. We 18 submit, as we said in our papers, that we believe that 19 Mr. Shechtman has met neither prong of the Strickland standard 20 in that he cannot show ineffective assistance of counsel and he 21 cannot show prejudice. 22 This Court in its ruling on the motion for new trial 23 regarding Catherine Conrad has already found that the Brune 24 Richard law firm knew that Catherine Conrad and Juror No. 1 25 were the same person and chose to gamble with the jury that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 they had. Your Honor, that in our view ends the inquiry 2 completely. That finding alone is sufficient to defeat a 3 finding of ineffective assistance of counsel. 4 The Second Circuit has made very clear, as have other 5 circuits, that you cannot as a defense counsel basically engage 6 in a heads-we-win-tails-you-lose strategy when it comes to your 7 trial conduct. We know that based on the documentary evidence 8 and the evidence that was adduced at the hearing as well as the 9 evidence that was put forth in the affidavit of Susan Brune, 10 that the Brune 6 Richard law firm had the suspension opinion 11 prior to volt dire, and chose not bring it to this Court's 12 attention. As we all know engaged in subsequent investigation 13 regarding Juror No. 1, when Theresa Trzskoma started to have 14 certain doubts about her after the receipt of Juror No. l's 15 note.
+
+16 It's quite clear that this is not a case where the 1 7 defense counsel had been given a piece of information and did 18 nothing. That's quite, quite not what happened here. In fact, 19 we know that prior to voir dire, they discussed the suspension 20 opinion, they chose not to bring it to the Court's attention. 21 Instead relying simply on the voir dire answers, even though as 22 this Court pointed out, far more trivial issues were aired by 23 all of the parties, by the government and indeed by the Court, 24 in terms of trying to figure out who would be good jurors.
+
+25 They chose not to bring that to the Court's attention then
+
+1 which I think is very significant. And it is significant in 2 part because I think if we can say anything, that we all know 3 based on the Brune c Richard's defense of Mr. Parse, that if 4 they had any actual and real concern about a suspended attorney 5 being on this jury, if they really thought that that was not in 6 their client's interest, you know, we all know that they would have brought it to the Court's attention during voir dire. And 8 if not at voir dire, then after the results of the Theresa 9 Trzskoma investigation.
+
+10 This is absolutely a situation where the Brune 11 Richard lawyers, on May 12, after the investigation that they 12 had, they looked at all the alternatives. We know because 13 Laurie Edelstein testified at the hearing, they considered the 14 three possible alternatives. They considered whether or not 15 they should do more investigation, and Susan Brune said no. 16 They considered whether or not they should bring it to the 17 Court's attention, and they said no. So they decided to do 18 nothing. And it is that conscious and deliberate choice that 19 we believe means that they made a strategic choice that cannot 20 form the basis of ineffective assistance of counsel.
+
+21 How do we know in the government's view that this 22 indeed was a tactical choice? As this Court just pointed out 23 with regard to the questioning of Mr. Shechtman, they did not 24 bring that knowledge to the attention of the Court either in 25 the brief, where they made it appear as if they first learned SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212> 805-0300
+
+1 of this after the receipt of the jury -- of Ms. Conrad's letter 2 to the government in May after the verdict. And worse, even in 3 the conference calls with the Court, they continued to make it 4 appear and resist the Court and the government learning that 5 knowledge.
+
+6 Mr. Shechtman seems to want to characterize this as 7 them wanting to hide their mistakes. But it's quite clear, and 8 Susan Brune and Laurie Edelstein testified, we would not have 9 told this Court but for the Court pressing. That to me speaks 10 of a decision made early on and continuing through the briefing 11 that they wanted the juror on the panel, but they wanted the 12 Court not to know exactly what they knew because they 13 understood, and, as was acknowledged at the hearing, that that 14 was damaging to their client.
+
+15 THE COURT: Would you address the prejudice prong. 16 : Yes, your Honor. Your Honor, we believe 17 that there is more than adequate evidence, indeed overwhelming 18 evidence, of defendant Parse's criminal involvement in the 19 corrupt endeavor to obstruct the IRS and in the mail fraud 20 count. The defense conceded in its papers that. Mr. Parse was 21 involved in the backdated transactions. We think backdated 22 transactions is a perfectly adequate description of them.
+
+23 We also submit, your Honor, that Mr. Parse's 24 background as a CPA, even a non-practicing CPA, is under case 25 law relevant to his intent and circumstantial evidence of his SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+1 incident. We know he was instrumental and indeed Carrie Yackee 2 cited to more than a dozen instances during her testimony where 3 she made clear that she was acting at the instructions of and 4 with the knowledge of David Parse in implementing all of these 5 complex and varied transactions that had to be effectuated in 6 order to change the results of the three sets of transactions. 7 It's actually four because Coleman and Blair were two separate 8 taxpayers. She understood that this was being done for tax 9 purposes. This is Carrie Yackee the sales assistant. Nice 10 woman, but not nearly as sophisticated as Mr. Parse. To 11 suggest that the jury could not find or infer that he knew 12 exactly why these transactions were being effectuated, not for 13 any real investment reason, not because they had figured out 14 that in February and March, the year after the transactions had 15 been done, that somehow it would have been a better investment 16 to have not invested in Cisco , but instead to have 17 invested in foreign currency. To suggest that the jury could 18 not have found that Mr. Parse knew that the reason that these 19 were being done was to effectuate tax losses for the prior year 20 Is simply ludicrous.
+
+21 Your Honor, the defendant was faxed information 22 relating to the tax returns themselves. This wasn't just a 23 one-way street between David Parse's office and Jenkins 24 Gilchrist, but it was at least a two-way street between 25 Deutsche Bank and Jenkins 6 Gilchrist and also the accountants.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(212) 805-0300
+
+1 So it's quite clear the jury was entitled to infer that he knew 2 that this was being done to change the results of the tax 3 losses. He also knew, and there is more than a plethora of 4 evidence on this, that each of these tax shelter transactions 5 had to be completed by year end. And that's why, as Mr. Bair 6 testified and others testified, it was a real effort.
+
+7 Sandra Burnside, you might recall, Mr. Daugerdas' 8 secretary, testified about the avalanche of work that went on 9 in December at the end of the tax years in order to finalize 10 these transactions. Well, that avalanche of work hit the 11 offices of Mr. Parse's desk. And as Carrie Yackee testified, 12 Carrie Yackee's desk as well.
+
+13 So to suggest that he was not aware this was being 14 done in order to defraud the IRS as the true results of the 15 transaction we submit is unsupportable.
+
+16 There was a suggestion in Mr. Shechtman's brief, I 17 don't think he touched on it today, but the suggestion was that 18 these transactions, these as of transactions were approved by 19 Deutsche Bank.
+
+20 Well, first of all, Carrie Yackee's testimony here 21 that she was going to Mr. Parse for approval on these 22 transactions. There is also no evidence to suggest that anyone 23 other than Mr. Parse and Carrie Yackee at Deutsche Bank knew 24 the full picture of what went on, which was that these 25 transactions for these particular taxpayers were tax shelter
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 transactions that had to be done by the end of the year, that 2 had been done by the end of the year, pursuant to instructions 3 that had been given by Jenkins 6 Gilchrist to Deutsche Bank, 4 had been implemented properly by Mr. Parse in the first S instance, and now were being requested to redo them to achieve 6 a different result.
+
+7 This i think is a distinction that makes
+
+B Mr. Shechtman's example of the broker's mistake an apple to our 9 orange or an orange to our apple, which is that this is not an 10 instance where Mr. Parse takes an instruction from a client and 11 screws it up. Implements it wrong. Rather, they did 12 everything that they were supposed to do the way it was 13 supposed to be done, and there are results to show for that. 14 It's only because the tax loss that they wanted to get from 15 these results was not correct that it required anything to be 16 done after the end of the year.
+
+17 We suggest that the evidence was overwhelming to 18 support Mr. Parse's knowing and criminal involvement in both 19 the corrupt endeavor to obstruct and impede the IRS and in mail 20 fraud.
+
+21 THE COURT: Anything further? 22 Your Honor, there are other pieces of 23 evidence which we've detailed in our briefing but which I will 24 not go through again here.
+
+25 I did want to just note though that the Second Circuit SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+I has stated that you can find that where there has been a split 2 verdict, as is the case with Mr. Parse, that is evidence of a 3 lack of prejudice. We had argued in the original motion for 4 new trial and we renew that as well.
+
+5 Finally, your Honor, with regard to the letter of 6 Catherine Conrad to the government which was referenced in the 7 defendant's briefing, she talked about their discussions and 8 deliberations with regard to David Parse. And interestingly 9 what she also said, which was not mentioned by Mr. Shechtman in 10 his brief, was that that struggle ended when they asked the 11 Court to reread the definitions of wilfully and knowingly. 12 Different states for different counts.
+
+13 MR. SHECHTMAN: Well, I'll wait. I apologize to the 14 Court.
+
+15 : And interestingly, their verdict exactly 16 tracked that difference between wilfully, this was required in 17 the conspiracy count and for the tax evasion counts, and 18 knowingly which was really the mens III relating to other ones. 19 So you might say that they had a struggle.
+
+20 To the extent we can even be considering that letter 21 at all because of Rule 606(b), but I think it's quite clear 22 that they made a deliberate and informed decision about making 23 a distinction drawn on the evidence as apply to the law. Thank 24 you.
+
+25 THE COURT: Thank you, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
+
+1 2 3 4 5 6 7 8 9 10 11 12 13 14 Mr. Shechtman, do you want Co be heard further? MR. SHECHTMAN: I will and I will try to be brief, Judge. I think really four points. The government has repeated at the argument here what it said in its brief. Which was that. Mr. Parse benefited from the strategic choice that his clients made and I'll hold the strategic choice point for second. But I take that to mean that he got acquitted here because she was on the jury. And that, my father used to say arguments were nonsense on stilts, and that is nonsense on stilts. I mean, your Honor knows exactly what happened here. There was a partisan in the jury room, a woman who couldn't follow instructions and the like. Your opinion couldn't be stronger on the point. And she was fighting the good fight to convict him on 100 percent.
+
+15 16 17 So to say we got the benefit of having her on there because we were acquitted isn't worthy, respectfully, of the government.
+
+18 19 20 21 And the related point this was a split verdict, it is a split verdict because she couldn't carry the ball as far as she wanted to, but not because Mr. Parse benefited by her presence.
+
+22 23 24 25 The second thing I'd say is this. I take it there arc two competing visions of what happened here, and at the end of the day, your Honor is going to have to decide. One is that what happened in that court, your Honor, in the plaza, is that SOUTHERN DISTRICT REPORTERS, P.C.
+
+## CAC3PARC
+
+(212) 805-0300
+
+25
+
+CAC3PARC
+
+1 what was said was, look, don't be stupid, it can't be her, to 2 do any more would be a waste of the court's time. That's what 3 I think happened. That's what I think the record shows.
+
+4 The other is, let's be smart. She'll be a great juror
+
+5 because she is a suspended lawyer. Or, let's be smart. If we 6 leave her on, we get two bites at the apple. The latter two I 7 think are strategic, but be careful in the following sense.
+
+The first one is a choice. It is a choice to do nothing. You
+
+9 cannot have a case in which there is not in a sense a choice if
+
+10 it's coming up in an ineffective assistance claim. I can cite
+
+11 you to Breakiron and v. Armontrout. In our brief
+
+12 lawyers are making choices. In those cases the question is are
+
+13 they informed choices, arc they reasonable choices, arc they
+
+14 competent choices, are they strategic choices. And if the
+
+15 choice is don't be stupid, it can't be her, that is not a
+
+16 strategic choice, that is a tragic misjudgment. Implicit in
+
+17 the word "misjudgment" is that someone's making a choice. But
+
+18 if it is a tragic misjudgment, I think it's ineffective
+
+19 assistance.
+
+20 The next thing I'd say is this. We're told that there
+
+21 can't be any doubt that these transactions were effectuated so
+
+22 that there would be tax lawyers and tax losses in the prior
+
+23 year and it's ludicrous to think otherwise. Of course that's
+
+24 why the transactions were being done. There is no doubt that's
+
+25 why these transactions were being done in February or March.
+
+SOUTHERN DISTRICT REPORTERS, P.C.
+
+(2121 805-0300
+
+1 But the real question is, did Mr. Parse know that that was 2 defrauding the government. Right. 3 Look, the avalanche of work here was in December. But 4 the question is, if you made a mistake, like in my example, can 5 you undo it. And you have to appreciate what the government 6 has said to you today. It has essentially said if it is a 7 broker's mistake, like in my hypothetical, then maybe a 8 reasonable broker could think you could undo it. But if it is 9 a lawyer's mistake, you can't. And that's a very different 10 version of the annual accounting rule than I've ever heard 11 before. Right. And if my hypothetical is one in which a 12 reasonable broker could think leave it up to the tax lawyers, 13 am not sure what happened in this case isn't in that same 14 category.
+
+15 We ended up with an argument about the contents of the 16 note and how your Honor should interpret them to show whether 17 there was prejudice here. All of this began with the 18 government saying to us be careful, Rule 606(b) has its limits. 19 The one thing I know, and the Third Circuit case in Breakiron 20 is quite good on talking about whether one looks at this 21 subjectively or objectively, you can't draw inferences from 22 that juror's note in deciding whether there was prejudice here 23 for two reasons. One, 606(b) precludes it, and two, that note 24 was written by Catherine Conrad and I still don't think the 25 United States wants to be standing up in a court and saying SOUTHERN DISTRICT REPORTERS, P.C.
+
+12121 805-0300
+
+rely on what Catherine Conrad said. 2 THE COURT: All right. Counsel, thank you for your 3 arguments on the motion. Decision reserved. Have a good 4 afternoon. Thank you.
+
+
+
+**ZUCKERMAN SPAEDER LLP**
+
+1185 AVENUE OF THE AMERICAS 31ST FLOOR
+NEW YORK, NY 10036-2603
+212.704.9600 212.704.4256 fax www.zuckerman.com
+
+PAUL SHECHTMAN
+Partner
+212-704-9600
+Pshechtman@zuckerman.com
+
+BY HAND
+
+March 7, 2013
+
+The Honorable William H. Pauley, III
+United States District Judge
+Southern District of New York
+500 Pearl Street, Room 2210
+New York, NY 10007
+
+Re: United States v. David Parse, et al., 09 Cr. 581 (WHP)
+
+Dear Judge Pauley:
+
+This letter is respectfully submitted on behalf of David Parse, who is scheduled to be sentenced for tax-related crimes on March 22, 2013. For the reasons discussed below, we believe that a non-incarcerative sentence would be a fair and parsimonious one. See United States v. Dorvee, 616 F.3d 174, 182 (2d Cir. 2010)("it is the sentencing court's duty to impose a sentence sufficient, but not greater than necessary to comply with the specific purposes set forth at 18 U.S.C. § 3553(a)(2)").
+
+A. Background
+
+David Parse was born in Detroit, Michigan, on December 7, 1961. He was the youngest of five children of Sylvia and Henry Parse. A World War II veteran, David's father worked two jobs for most of his life. He was a mailman by day, and a factory worker at night. David's mother worked part-time as a laundress in a local restaurant. The two parents instilled
+
+WASHINGTON, DC
+
+NEW YORK
+
+TAMPA
+
+BALTIMORE
+
+
+
+FA ZUCKERMAN SPAE DER Lip
+
+The Honorable William H. Pauley, Ill March 7. 2013 Page 2
+
+in their children the importance of work, education, family and respect for others. See letter of Bridget Rodgers ("Dave comes from a blue-collar background: his dad was a mailman and his mom was a saint"),I
+
+David attended local Catholic schools, where he excelled in academics and sports. See letter of Scott Mordell ("David was an academic, sports and social leader among our [high school] class"). He started on the varsity basketball team as a freshman and was among the top players in the state his senior year. Although recruited by several colleges, he chose to attend the University of Michigan. a state school, and gave up playing organized sports.
+
+What he did not give up was his work ethic. David got his first job at age 11. delivering the Detroit News to his neighbors. Every day after school and on weekends, he rode his bicycle on his route. In eighth grade. he began working part-time in a local restaurant as a busboy (the sante restaurant where his mother cleaned linens). He worked there on weekends during the school year and 30 to 40 hours a week in the summer. The job enabled him to purchase a used car for \$600. With a car, he could drive across town to work at a famous seafood restaurant: beginning his senior year in high school, it became his regular employer.
+
+David graduated from Michigan in 1984 with a bachelor's degree in Business Administration. He put himself through college, commuting from Ann Arbor to Detroit to work as a waiter in the seafood restaurant. Although most of his time went to studies and work, David
+
+Letters from David's family and supporters arc attached as an appendix to this submission.
+
+
+
+FA ZUCKERMAN SPAE DER LLP
+
+The Honorable William H. Pauley, Ill March 7, 2013 Page 3
+
+enjoyed his college years immensely, and many of his closest friends are Michigan classmates. To this day, he "tailgates" with friends before Michigan football games and donates generously to the school. See letter of Kenneth Norwick (our "tailgate [group] .. . has become like an extended family ... focused on the children"); letter of Bridget Rodgers nelven though he has never mentioned it, I know [David] has been a generous donor to the University").
+
+# B. Business Degree and Brokerage Industry Employment
+
+After graduating from Michigan. David worked two years at Touche.' as an accountant, doing audits for local businesses and not-for-profit institutions. In August 1986, he left the firm and reenrolled in Michigan to get an MBA degree. Again, he paid his own way. He lived at home, commuted to school, and went back to waiting tables. He graduated in 1988 with a major in Finance and Economics and obtained employment ats Sachs in Detroit as a broker.
+
+From 1988 to his indictment in 2009, David enjoyed considerable success as an investment consultant for institutions and high net worth individuals. When le ft Detroit, David moved to Kidder Peabody in Troy, Michigan, and then to Credit Suisse First Boston in Chicago. In 1995. he was recruited to join Alex & Sons, which was subsequently acquired by Bankers [rust and then Deutsche Bank. The name on the front door changed, but David's responsibilities did not.
+
+
+
+FA ZUCKERMAN SPAE DER ILP
+
+The Honorable William H. Pauley, Ill March 7, 2013 Page 4
+
+As a broker, David had 30 to 40 long-term customers, and his goal was to assist them to invest their money wisely. A former business associate writes this about him:
+
+> (A]t the Chicago offices of Credit Suisse First Boston . . . I interacted with David on a constant basis during our tenure at the firm. I literally could overhear his phone calls with clients ... . In all of (our] interactions I found David to be diligent, intelligent, and most of all honest. David always put his client's interests first. and prided himself on his ability to protect 'their] assets. He took very seriously his fiduciary duty, and our entire group relied upon him as a sounding board when evaluating the appropriateness of investment vehicles. As an example of how much I trust David in business. years ago I asked him to consult on the endowment fund for an inner city high school that I oversee . . . . (As) you can imagine . .. I would only ask David to participate if I was completely convinced of his character.
+
+Letter of Phil IM
+
+Others who have worked with David sound the same theme. tics letter of Jeffrey DeYoung (he would "always put clients first and do the right thing: when the market was starting to unravel . Dave was the first to pull his clients out in spite of his loss of revenue"); letter of Susan Manske ("I'M my opinion. Dave has always been a straight shooter, a conservative investor protecting his clients from downside risk, land] a staunch supporter of ethical behavior"); letter of John and Kathryne McGuire ("David chose the securities business so that he could help his clients protect their assets; he truly understood his fiduciary obligations and )put] his client's interest first"). In all his years as a broker, David received no complaints from his customers for his investment advice.2
+
+David has been sued by several taxpayers whose tax shelters were disallowed.
+
+
+
+FA ZUCKERMAN SPAE DER Lip
+
+The Honorable William H. Pauley, III March 7, 2013 Page 5
+
+in 1998, David was introduced to Paul Daugerdas; his relationship with Daugerdas and the Jenkens & Gilchrist firm is discussed in Part D below.
+
+# C. Family, Community and Friends
+
+David met Theresa Austerberry in 1987, when they were at business school together. and they have been married for 20 years. They have supported each other's careers - when Theresa found a better position at McKinsey's Chicago office, David left Kidder Peabody to move with her -- and have devoted themselves to family and community. They have three boys -- ages 17. 15, and 12 -- whom they have raised conscientiously. The letter of David's brother-in-law. James Yetter, describes it best:
+
+> (David'sl three sons (my nephews) are wonderful young men with exceptional character traits that I know are a direct result of Dave's strong parenting .. . . Pile treats them with a very good combination of love, caring and high expectations. They all have chores to do and household responsibilities. They are expected to have jobs in the summer. They have a healthy regard and respect for others. Study time is sacred. Responsibilities are not to be taken lightly. It's not "enforced," it's an expectation.
+
+Letter of James W. Vetter.
+
+Other letters confirm Mr. Yetter's observations. See letter of Andrew ("lhfis emphasis and influence on his children have also resulted in good, respectful, wellrounded and academic kids"); letter of Phil (David 'leaches by example, and extolls the values of hard work and mutual respect: everyone pitches in, whether it is preparing a family
+
+
+
+FA ZUCKERMAN SPAE DER LLp
+
+The Honorable William H. Pauley, Ill March 7, 2013 Page 6
+
+meal or helping a younger sibling ... do [his) homework"); letter of a. Carnaghi (David "is truly a model father [who) sets the bar high for his boys").3
+
+For the past IS years, David has devoted much of his free time to coaching youth sports teams in his community. In his letter to the Court. Phil describes the depth of David's commitment:
+
+> In our town's Little League Baseball organization, David has held every volunteer position from an assistant coach to a team mane er. I have seen him do everything from raking baseball ... to throwing batting practice . ... During basketball season, David has also been the coach or assistant coach for numerous grammar school teams. If there is one example of the depth of David's commitment to coaching, it is the basketball training sessions he designed and managed for students outside of the organized teams he coached. On his own initiative, David arranged for a gym to be available during the week for all children, even those who didn't make a team . ... There are not many of us . .. who would find the time to make such an impact on the lives of the children in their community.
+
+Letter of Phil .= Leg also letter of John and Kathryne Maguire ("[cloaching children is often a difficult and thankless job in a small community; David has been a leader in Hinsdale in volunteering his time and knowledge to help our community").
+
+3 As the Presentence Report notes, Theresa has had serious health problems since 2008. In February 2008, Theresa began experiencing severe dizziness, and the episodes often lasted hours and sometimes days. Neck pain, heart palpitations and stomach pain followed. g letter of Theresa Parse. A battery of tests has proven negative, and medication and a change of diet have given her some relief. But health issues, which may be stress-related, continue to plague her.
+
+
+
+FA ZUCKERMAN SPAE DER Ltp
+
+The Honorable William H. Pauley, Ill March 7, 2013 Page 7
+
+As the letters reflect, coaching for David is about more than teaching a 12-yearold to turn a double play. "He wants the kids to develop their athletic .. . skills and For them to be as successful .. . as possible, but he clearly believes that there are things more important than winning games." Letter of Charles Austerberry; see also letter of Theresa Parse ("Dave understands how sports can teach children valuable life lessons"). David relates to each child individually and gives each a chance to play. When a boy with severe disabilities was on the basketball team, David "made sure every other boy .. . went out of [his] way to . .. help him make a basket before the end of the season." As one observer notes, David's "measured, personal approach contrasts markedly with the loud cacophony typically employed by [those] . who attempt to coach [children's] sports teams." Letter of Charles Austerberry.4
+
+What may best reflect David's character is his commitment to his friends. In their letters to the Court. many of them recount stories of David's support in their times of need. See c.g., letter of Bridget Rodgers (when I was pregnant and "told I had an infection that would cause
+
+The thing that has endeared me most to Dave is the way he coaches the 1):).ys i basketball. Over the years, he has coached . .. my son a . .. [Dave] is always calm, guiding, teaching and encouraging the boys in a way that is so helpful. Dave has gone out of his way to tell my wife Kimberly and me how special is as an athlete and he encourages us to continue his development. The vast majority of coaches in our community arc screamers and not teachers and are singularly focused on their [own] kids. Dave is different. I sincerely appreciate the many hours Dave has spent with my son.
+
+Letter of Venanzio Arquilla.
+
+One parent whose child is a gifted athlete writes this about David:
+
+
+
+PPA ZUCKERMAN SPAE DER LP
+
+The I lonorable William II. Pauley, 111 March 7, 2013 Page 8
+
+horrific birth defects. Dave cried openly with us" and discussed the "moral, ethical and emotional dilemmas this raised"); letter of James Yetter ("[w]hen our friend's daughter was on her death bed. Dave .. . flew in from Chicago . . . to provide support"); letter of Andrew ("when my son was diagnosed and hospitalized with a mental illness .. ., David was there to .. . counsel and encourage me"); letter of Camaghi (when "my then 12 year old daughter had a brain aneurysm burst .. . [David) drove in from Chicago to spend time with me and my family; he spoke with me every day during the three plus weeks of this ordeal"). As one friend puts it. "Dave is a giver, not a taker; if you need some help, he is the friend you can call." Letter of Kenneth Norwich.
+
+Notably, David's good deeds have involved his time and effort and not his money. Nor has he sought recognition for what he has done. Just the opposite is true: he has been reluctant to ask others to write on his behalf because asking for something in return has never been his way. Sec United States v. 394 F.3d 172, 177 (3d Cir. 2005gnoting that defendant's actions were not "detached acts of charity .. . [but were] in a very real way, handson personal sacrifices, which have had a . .. positive impact on the lives of others").
+
+# D. The Instant Offense
+
+As noted above, David met Paul Daugerdas in 1998, but the relationship between Deutsche Bank and Daugerdas began earlier. In the early 1990's. Jason Shih was one of a group of brokers in Alex San Francisco office, who began executing bond shorts for Daugerdas' clients. When Shih was transferred to Chicago to supervise the office, he continued
+
+
+
+ZUCKERMAN SPAE DER LLP
+
+The Honorable William H. Pauley, Ill March 7, 2013 Page 9
+
+the relationship. Shih introduced David and his partner Rod McKay to Daugerdas, and they began doing business.
+
+As the Court knows, Deutsche Bank's participation in the tax shelters was approved at the hank's highest levels.` That fact, coupled with the prominence of the Jenkins firm and the knowledge that other law and accounting firms were marketing similar products. gave David comfort that the tax shelters were lawful. Like many others, he believed that Daugerdas and his partners had found a "loophole" that could be exploited until it was closed. From 1998 to 2001, tax shelter trades became a part of David's business.
+
+As we see it, the jury accepted the proposition that David was not a culpable participant in the overall Jenkins tax shelter scheme. His acquittal on the tax conspiracy count and the substantive tax evasion counts (and the complete acquittal of his co-defendant Craig Brubaker) confirm the point. The jury. it seems, concluded that David did not know that a lack of economic substance made the Jenkins shelters illegal. If that is correct, then David's convictions for mail fraud and tax obstruction reflect his involvement in the three "backdating" transactions. In each instance, trades effected in one year (e.g., 2002) were used to generate tax
+
+See, c&, Tr. 2965 (discussing letter from !twin Mayer to Bob Price. Alex general counsel); Tr. 5678-79 (confirming that approvals from legal, credit, tax and compliance had been obtained for the Homer transaction).
+
+
+
+FA ZUCKERMAN SPAE DER 1.1..
+
+The Honorable William H. Pauley, III March 7, 2013 Page 10
+
+losses in the prior year (e.g.. 2001). The prosecution focused on those transactions in its summations, as did the jury in its deliberations.°
+
+# E. Guidelines Calculation
+
+In its preliminary Report, the Probation Office calculates an offense level of 40 and a Guidelines range of 292 to 365 months. It assumes a tax loss amount of 51.5 billion and adds "points" for sophisticated means (§ 2TI.1(bX2)) and special skill (§ 3B1.3). We have written to Probation and asked it to reconsider that calculation. Under the Court's rules, its final Report is due after ours, and so we summarize here our argument that the Guidelines range should be far lower than where Probation has preliminarily put it.
+
+[W]e did have qualms with Mr. David Parse. 1 solely held out for two days on the conspiracy charge for him -- 1 wanted to convict 100%, (not only on that charge) -- but on Tuesday, May 24, 2011, we had asked for the Judge's clarification of "willfully" and "knowingly", I believe, and I had to throw in the towel. I did fight the good fight, however, and l felt that Mr. Parse played his integral part and was a key element in the elaborate scheme/scam. The backdating was enough for the other charges.
+
+Letter of Catherine Conrad 5/25/11 (emphasis added).
+
+6Juror No. l's letter to AUSA Okula goes far to show that David's conviction was only for the "backdating" transactions:
+
+
+
+FA ZUCKERMAN SPAE DER Lip
+
+The Honorable William H. Pauley, III March 7, 2013 Page 11
+
+Our lower Guidelines calculation begins from the premise that Mr. Parse was convicted only of the three "backdating" transactions If that is so, then the proper loss calculation is this:
+
+| Coleman | 52.738.630 |
+|---------|------------|
+| Blair | 5 470.035 |
+| Aronoff | 536.770 |
+| Toporek | S 62,553 |
+
+TOTAL 53,807,988
+
+These numbers are based on the additional assessments calculated by the IRS, which are in evidence.
+
+Moreover, if the Guidelines calculation is based only upon the three "backdating" transactions, then the enhancement for "sophisticated means" should not apply. While it is true that the tax shelters created fraudulent tax losses through a series of complex transactions, the "backdating" involved only correcting certain trades -- es, canceling a transaction in IM and effecting one in foreign currency. The new transactions were shown in Deutsche Bank's books in the month in which they occurred. No records were altered. Thus, this is not an instance of "hiding assets or transactions. or both. through the use of fictitious entities. corporate shells, or offshore financial accounts." See Commentary § 2T I .I Application Note 4.
+
+Likewise, an enhancement for "special skills" under \*381.3 is unwarranted. The Report states that Mr. Parse "used his special skills as a forcer broker and CPA to materially facilitate his design and implementation of the highly-complex financial products that were involved in different tax shelters." 164. Mr. Parse, however, had no role in designing the
+
+
+
+ZUCKERMAN SPAE DER t
+
+The Honorable William H. Pauley, III March 7.2013 Page 12
+
+tax shelters and did not function as a ('PA. He gave no investment advice. and the trades were executed by his assistant. In short, his role as a broker in the three "backdating" transactions is too thin a ■ **to support this enhancement.**
+
+**If all of this is correct. then Mr. Parse should be at offense level 24, with a Guidelines range of 51 to 63 months. Of course, we believe that even that calculation produces a range that is still far too harsh. See, e.g., Smirlock v. United States, 2005 U.S. Dist. Lexis 7321 at •6 (noting that "the amount of loss that actually winds up resulting from a person's conduct . . . can he arbitrary" and may not reflect culpability); Bowman, The Failure of the Federal Sentencing Guidelines: A Structural Analysis, 105 Colum L. Rev. 1315. 1328 (2005)("(alt or near the root of virtually every serious criticism of the guidelines is the concern that they are too harsh").**
+
+# **F. Conclusion**
+
+**In her sentencing submission, Donna Guerin catalogued the sentences that have been imposed on those who designed and marketed illegal tax shelters. See Guerin's Am. Sentencing Mem. 13-16, ECF No. 592. They have varied greatly in length. What makes this case different is that David Parse did not design or market tax shelters; he was a broker executing trades. Indeed, to our knowledge, of all of the brokers who performed that function for Jenkins and other law 'inns. he and Craig Brubaker were the only two people who were prosecuted, and he is the only one who stands convicted.**
+
+
+
+FA ZUCKERMAN SPAE DER llP
+
+The Honorable William H. Pauley, Ill March 7.2013 Page 13
+
+As noted above, we believe that the jury convicted David for his involvement in three backdating transactions from which he barely profited. He has already suffered greatly for that conduct. Since 2004, when the criminal investigation commenced, this matter has hung over him. His once-thriving brokerage business has collapsed. His wife's health has suffered. See supra n.3. His children have felt the sting of comments from others who have learned of David's conviction. And the stigma of the conviction haunts David, especially because it is antithetical to the values with which he was raised. See letter of Theresa Parse ("our lives [have] essentially (been] placed on hold, as we try to raise our three sons in a safe and secure environment").
+
+More than 15 years ago, the United States Supreme Court reminded that the "uniform and constant . . . tradition for the sentencing judge [is] to consider every convicted person as an individual and every case as a unique study in the human failings that sometimes mitigate. sometimes magnify. the crime and the punishment to ensue." Koon v. United States 518 U.S. 81, 1 13 (1996). In this submission, we have tried to show that David Parse is a fundamentally decent man. He believes in family, hard work, helping others, and being actively involved in community. The conduct for which he was convicted, we believe, was at the periphery of the Jenkins scheme. On this record, we respectfully submit that a non-incarcerative sentence would be just. It would not diminish respect for the law. See United States v. Adelson. 441 F.Supp.2d 506, 513-14 (S.D.N.Y. 2006X"if ever a man is to receive credit for the good he
+
+
+
+FA ZUCKERMAN SPAE DER Lt..
+
+The Honorable William H. Pauley,111 March 7, 2013 Page 14
+
+has done, and his immediate misconduct assessed in the context of his overall life hitherto, it should be at the moment of his sentencing"):
+
+Respectfully submitted,
+
+ar vit
+
+Paul Shechtman
+
+PS/wr
+
+cc: AUSA Stanley J. Okula, Jr. AUSA Nanette
+
+We recognize that custodial sentences are qualitatively more severe than probationary sentences of equivalent terms. Offenders on probation arc nonetheless subject to several standard conditions that substantially restrict their liberty. Probationers may not leave the judicial district, move, or change jobs without notifying, and in some cases receiving permission from, their probation officer or the court. They must report regularly to their probation officer, permit unannounced visits to their homes, refrain from associating with any person convicted of a felony, and refrain from excessive drinking. Most probationers are also subject to individual "special conditions" imposed by the court.
+
+7In Gall v. United States, 552 U.S. 38 (2007), the Supreme Court emphasized that a nonincarecrative sentence does not mean "letting an offender off easily." The Court wrote:
+
+Id. at 59.
+
+**[PAGES A-5944 TO A-6040 INTENTIONALLY LEFT BLANK]**
+
+# EXHIBIT G
+
+# Jenkens and Gilchrist Clients Restitution Calculation
+
+| Client | Transaction Type | Year | Tax Benefit Taken per Return | Tax Deficiency per RAR | Interest thru | | Interest 12/31/2012 - 3/1/2013 | Total Interest | Total |
+|-------------------------|------------------|------|------------------------------|------------------------|--------------------|----------|--------------------------------|----------------|-------|
+| | | | | | 12/31/2012 per RAR | 3/1/2013 | | | |
+| Allenduff, Phillip | SOS | 1999 | 2,116,153 | 607,293 | 635,773 | 8,304 | 644,077 | 1,251,370 | |
+| Augustine, William | SOS | 1999 | 5,443,789 | 2,220,413 | 2,324,546 | 30,358 | 2,354,904 | 4,575,317 | |
+| Ballstrieri, James | SOS | 1999 | 1,295,704 | 509,840 | 533,750 | 6,971 | 540,721 | 1,050,561 | |
+| Ballstrieri, Rosemarie | SOS | 1999 | 488,166 | 174,257 | 182,429 | 2,383 | 184,812 | 359,069 | |
+| Basler, Wayne G | SOS | 1999 | 4,923,914 | 1,079,073 | 1,129,679 | 14,754 | 1,144,433 | 2,223,506 | |
+| ██████████ Abigail | SOS | 1999 | 427,884 | 154,580 | 161,829 | 2,114 | 163,943 | 318,523 | |
+| ██████████ H & Marcia | SOS | 1999 | 427,884 | 92,567 | 96,908 | 1,266 | 98,174 | 190,741 | |
+| ██████████ Henry III | SOS | 1999 | 927,082 | 325,231 | 340,484 | 4,446 | 344,930 | 670,161 | |
+| Bernard, Stephen F. | SOS | 1999 | 3,951,064 | 804,309 | 842,029 | 10,997 | 853,026 | 1,657,335 | |
+| Cairo, Louis | Short Sale | 1998 | 683,826 | 278,919 | 339,894 | 4,134 | 344,028 | 622,947 | |
+| Calbert, Michael | SOS | 1999 | 5,445,579 | 2,010,877 | 2,105,183 | 27,493 | 2,132,676 | 4,143,553 | |
+| Carlins, Joel M. | SOS | 1999 | 4,949,045 | 1,097,489 | 1,148,959 | 15,005 | 1,163,964 | 2,261,453 | |
+| Carruth, Herman | SOS | 1999 | 5,142,787 | 1,169,563 | 1,224,434 | 15,991 | 1,240,425 | 2,410,008 | |
+| Denning, Richard | SOS | 1999 | 742,987 | 155,473 | 162,764 | 2,126 | 164,890 | 320,363 | |
+| Devetter, Dennis M. | SOS | 1999 | 8,093,882 | 2,259,810 | 2,365,790 | 30,897 | 2,396,687 | 4,656,497 | |
+| Dolson, Kenneth | SOS | 1999 | 4,944,392 | 1,911,747 | 2,001,404 | 26,138 | 2,027,542 | 3,939,289 | |
+| Eigel, C&C | SOS | 1999 | 1,500,024 | 604,289 | 632,629 | 8,262 | 640,891 | 1,245,180 | |
+| Frigo, Arthur | Short Sale | 1998 | 47,490,958 | 18,568,165 | 22,627,401 | 275,165 | 22,902,566 | 41,470,731 | |
+| Gecsey, William | Short Sale | 1999 | 1,849,245 | 754,270 | 789,644 | 10,312 | 799,956 | 1,554,226 | |
+| Georgius, John R. | SOS | 1999 | 30,018,220 | 11,489,491 | 12,185,410 | 0 | 12,185,410 | 23,674,901 | |
+| Goldberg, M | Short Sale | 1998 | 1,291,133 | 526,628 | 641,756 | 5,775 | 647,531 | 1,174,159 | |
+| ██████████ Robert | Short Sale | 1998 | 545,820 | 200,473 | 244,299 | 2,971 | 247,270 | 447,743 | |
+| Gorman, Robert | SOS | 1999 | 7,326,125 | 2,971,595 | 3,110,956 | 40,629 | 3,151,585 | 6,123,180 | |
+| Guy, Jerry | SOS | 1999 | 517,554 | 200,275 | 209,667 | 2,739 | 212,406 | 412,681 | |
+| Harvanek, Steven | SOS | 1999 | 19,654,299 | 4,270,448 | 4,470,723 | 58,386 | 4,529,109 | 8,799,557 | |
+| Jensen, Robert & Debra | SOS | 1999 | 5,148,261 | 1,604,155 | 1,701,319 | 0 | 1,701,319 | 3,305,474 | |
+| Kelley, Phillip & Kathy | Short Sale | 1998 | 11,876,759 | 4,741,316 | 5,803,796 | 44,294 | 5,848,090 | 10,589,406 | |
+| Koenig, ██████████ | Short Sale | 1999 | 1,514,982 | 615,486 | 644,351 | 8,415 | 652,766 | 1,268,252 | |
+| Lowenberg, James A. | SOS | 1999 | 2,475,423 | 704,214 | 737,240 | 9,628 | 746,868 | 1,451,082 | |
+| Lusvardi, Laurence C. | SOS | 1999 | 11,476,629 | 2,201,073 | 2,334,392 | 0 | 2,334,392 | 4,535,465 | |
+| ██████████ James | SOS | 1999 | 1,657,646 | 340,556 | 356,527 | 4,657 | 0,864,084 | 701,740 | |
+
+# Jenkens and Gilchrist Clients Restitution Calculation
+
+| Client | Transaction Type | Year | Tax Benefit | | Tax Deficiency | | Interest thru | | Interest | | Total Interest | Total |
+|--------------------------------|------------------|------|------------------|-------------|--------------------|-----------|---------------|--------------------|-----------|----|----------------|-------|
+| | | | Taken per Return | Rar | 12/31/2012 per RAR | 3/1/2013 | 3/1/2012 - | 12/31/2012 - | Total | | | |
+| Merchant, William | SOS | 1999 | 3,960,459 | 1,615,392 | 1,713,236 | 1,713,236 | 0 | 1,713,236 | 3,328,628 | ** | | |
+| Owen, Dennis | SOS | 1999 | 8,851,963 | 1,770,393 | 1,853,421 | 24,205 | 24,205 | 1,877,626 | 3,648,019 | | | |
+| Pape, Mark | SOS | 1999 | 3,711,793 | 1,472,661 | 1,541,726 | 20,134 | 20,134 | 1,561,860 | 3,034,521 | | | |
+| Peterson, Ronald A. | SOS | 1999 | 2,971,727 | 512,416 | 536,447 | 7,006 | 543,453 | 1,055,869 | | | | |
+| Pollitt, Hunter | SOS | 1999 | 5,445,573 | 2,046,426 | 2,142,399 | 27,979 | 2,170,378 | 4,216,804 | | | | |
+| Poncher, Lyle | SOS | 1999 | 1,584,257 | 529,086 | 560,595 | 538 | 561,133 | 1,090,219 | | | | |
+| Postorivo, Jr., Eugenio | SOS | 1999 | 3,958,160 | 1,604,318 | 1,679,557 | 21,935 | 1,701,492 | 3,305,810 | | | | |
+| Purcel, Morris | SOS | 1999 | 10,517,045 | 4,284,575 | 4,485,512 | 58,580 | 4,544,092 | 8,828,667 | | | | |
+| Ragsdale, C&E | Short Sale | 1999 | 7,024,447 | 2,782,380 | 2,951,380 | (471) | 2,950,909 | 5,733,289 | | >> | | |
+| Ragsdale, HV | Short Sale | 1999 | 517,475 | 188,809 | 200,277 | (32) | 200,245 | 389,054 | >> | | | |
+| Ragsdale, T&L | Short Sale | 1999 | 7,307,819 | 2,798,322 | 2,968,290 | (473) | 2,967,817 | 5,766,139 | >> | | | |
+| Ragsdale, TS IV | Short Sale | 1999 | 517,475 | 188,797 | 200,264 | (32) | 200,232 | 389,029 | >> | | | |
+| ███ Ralph F. | Short Sale | 1998 | 786,621 | 320,848 | 390,989 | 4,755 | 395,744 | 716,592 | | | | |
+| Schuett Sr., William G. | SOS | 1999 | 8,162,118 | 1,677,490 | 1,756,161 | 22,935 | 1,779,096 | 3,456,586 | | | | |
+| Schuett, Jr., William G. | SOS | 1999 | 8,162,118 | 1,636,216 | 1,712,951 | 22,371 | 1,735,322 | 3,374,538 | | | | |
+| Small, Richard & Adene | SOS | 1999 | 16,831,914 | 3,366,382 | 3,524,258 | 46,026 | 3,570,284 | 6,936,666 | | | | |
+| Spector, Donald | SOS | 1999 | 2,012,684 | 797,375 | 834,770 | 10,902 | 845,672 | 1,643,047 | | | | |
+| Sluart, ███ | SOS | 2000 | 4,628,056 | 1,878,052 | 1,637,363 | 23,481 | 1,660,844 | 3,538,896 | | | | |
+| Tale, ███ P. | SOS | 1999 | 39,573,266 | 11,048,595 | 11,566,751 | 151,058 | 11,717,809 | 22,766,404 | | | | |
+| Vanek, Greg | SOS | 1999 | 992,081 | 389,312 | 407,570 | 5,323 | 412,893 | 802,205 | | | | |
+| Walsh, Carol | SOS | 1999 | 7,675,366 | 3,054,180 | 3,197,415 | 41,757 | 3,239,172 | 6,293,352 | | | | |
+| Wiggins, Glenn | SOS | 1999 | 9,209,607 | 1,841,921 | 1,928,303 | 25,183 | 1,953,486 | 3,795,407 | | | | |
+| Yang, Julie | SOS | 1999 | 180,876 | 72,467 | 75,866 | 990 | 76,856 | 149,323 | | | | |
+| Total Clients - J&G | | | 348,930,116 | 110,520,308 | 119,951,466 | 1,188,760 | 121,140,226 | 231,660,534 | | | | |
+
+Page
+
+**[PAGES A-6044 TO A-6073 INTENTIONALLY LEFT BLANK]**
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+
+-----x
+:
+UNITED STATES OF AMERICA, :
+- v. - : S3 09 Cr. 581 (WHP)
+PAUL DAUGERDAS, :
+DONNA GUERIN, :
+DENIS FIELD, and :
+DAVID PARSE, :
+Defendants. :
+-----x
+
+AMENDED SENTENCING MEMORANDUM OF THE
+UNITED STATES REGARDING DEFENDANT DAVID PARSE
+
+PREET BHARARA
+United States Attorney for the Southern
+District of New York
+
+STANLEY J. OKULA, JR.,
+NANETTE L. [REDACTED],
+Assistant United States Attorneys
+
+- Of Counsel -
+
+# TABLE OF CONTENTS
+
+| Preliminary Statement | 1 |
+|----------------------------------------------------------------------------|----|
+| I. Relevant Facts. | 3 |
+| A. The Defendant's Educational Background and Work History | 3 |
+| B. The Offense Conduct. | 3 |
+| I. Parse' Participation in the Fraudulent Kasperzak/Calphalon Tax Shelter. | 3 |
+| 2. Parse's Personal Tax Evasion | 5 |
+| 3. Parse's Participation in the Fraudulent Backdating of Transactions | 5 |
+| C. The Indictment, Trial, New Trial Rulings, and the PSR | 8 |
+| D. The Objections to the PSR | 9 |
+| E. Restitution | 21 |
+| II. Sentencing Guidelines Discussion. | 22 |
+| III. 3553(a) Analysis | 24 |
+| I. The Nature and Circumstances of the Offense. | 24 |
+| 2. History and Characteristics of the Defendant. | 25 |
+| 3. The Need To Afford Adequate Deterrence | 26 |
+| 4. The Need To Avoid Unwarranted Sentence Disparities. | 33 |
+| 5. The Appropriate Sentence | 36 |
+| Conclusion | 37 |
+
+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA, S3 09 Cr. 581 (WHP) PAUL DAUGERDAS, DONNA GUERIN, DENIS FIELD, and DAVID PARSE, Defendants.
+
+## AMENDED SENTENCING MEMORANDUM OF THE UNITED STATES REGARDING DEFENDANT DAVID PARSE
+
+The United States respectfully submits this memorandum for the Court's consideration in connection with the sentencing of defendant David Parse ("Parse" or "the defendant"), which is scheduled for March 22, 2013 at 2:30 p.m.
+
+# Preliminary Statement
+
+Following an eleven-week trial that included over 1300 exhibits, 41 witnesses, eight days of jury deliberations, and 46 jury notes, the jury on May 24, 2011 convicted David Parse on one count of corruptly obstructing and impeding the due administration of the Internal Revenue Laws in violation of 26 U.S.C. § 7212(a) (Count Twenty of the Redacted S3 Indictment), and one count of mail fraud in violation of 18 U.S.C. §§ 1341 and 2 (Count Twenty-Five of the Redacted S3 Indictment). The jury acquitted Parse of the conspiracy count and three counts of tax evasion. Those convictions stemmed from David Parse's integral role in one of the largest tax fraud schemes ever charged, the details of which arc spelled out in the indictment against him, S3 09 Cr. 581 (WHP), and the trial record. Incorporating the factual allegations in the conspiracy count, Count Twenty
+
+charged Parse, Donna Guerin, Denis Field and Craig Brubaker with a wide-ranging corrupt endeavor to obstruct and impede the IRS in connection with the design, marketing, implementation, and defense of four tax shelters known as Short Sale, Short Option, SWAPS, and HOMER. Likewise incorporating the factual allegations of the conspiracy count, Count Twenty-Five charged Parse. along with Paul Daugerdas, Guerin, Field, and Brubaker, with mail fraud as to the overarching scheme to defraud the IRS through the design, marketing, implementation, and defense of the Jenkens & Gilchrist tax shelters.
+
+The proof at trial demonstrated that Parse — an investment representative at Deutsche Bank Alex and certified public accountant — participated as a key actor in the largest criminal tax fraud in history. That fraud, which featured Parse's five-year involvement in four fraudulent tax shelters, resulted in the creation of over S7 billion of fraudulent tax deductions or benefits, \$1.6 billion in Guidelines tax loss, and well in excess of \$230 million in actual loss to the United States Treasury. Parse's role in the fraud - as one of the principal Deutsche Bank employees who steered bank clients to the J&G tax shelters, established the evanescent brokerage accounts for those shelters, executed the crucial Treasury short sale and options "investments," executed the pivotal transfers between accounts, and who helped facilitate the fashioning of the options and other financial instruments used in the shelters - was indispensable to the shelters' success. Consequently, Parse earned substantial commission income from his role in the tax shelters — over S3 million.
+
+For the reasons spelled out below and in the Probation Department Presentence Investigation Report ("PSR"), we submit that Parse's conduct, and the resulting harm, is deserving of a significant prison sentence.
+
+# I. RELEVANT FACTS'
+
+# A. Defendant's Educational Background and Work History
+
+Parse obtained his bachelor's degree in business administration from the University of Michigan in 1984 and his degree in business administration from the same school in 1988. PSR 11189-90. Parse also was a licensed stockbroker and investment adviser, and passed various securities and investment adviser exams. From 1988 to 1995, Parse acted as an investment adviser at Sachs, Kidder Peabody, and Credit Suisse First Boston. From 1995 through Apri12006, Parse was employed as an investment representative at Deutsche Bank Alex in its Chicago office. From April 2006 to the present, Parse has been self-employed at his company Union Capital LLC, a financial consulting firm, which is currently dormant.
+
+# B. The Offense Conduct
+
+The facts concerning Parse's offense conduct will not be repeated herein at length, as those facts are comprehensively set forth in the trial record and the PSR. Accordingly, we are confident that, as a result of the foregoing and the submissions made by the parties, the Court is thoroughly familiar with the scope and nature of the defendant's criminal conduct.
+
+Several aspects of that offense conduct bear additional discussion.
+
+# 1. Parse's Participation in the Fraudulent Kasperzak/Calphalon Tax Shelter
+
+Parse assisted in advising the shareholders of the Calphalon cookware company (primarily members of the Kasperzak family, owners of the company, and several key employees) on the orderly disposition of their shares of Newell acquired in a swap as a result of the sale of
+
+The facts described in this section are based on the Probation Department's Presentence Report ("PSR"), the trial record, documents that the Government has produced to the defendant in discovery, and Government interviews of various witnesses.
+
+the Calphalon company to Newell. Parse was introduced to Peter Barnhart, Calphalon's Executive Vice-President, Sara Jane ICasperzak, Kasperzak, and other members of the Kasperzak family in 1998. As a result of the work that Parse was doing in helping the Calphalon stockholders dispose of their Newell shares, Parse became aware of the large taxable gains that the stockholders would receive. In a meeting at Parse's office, Parse introduced Peter Barnhart to Paul Daugerdas (then an Altheimer & Gray partner) for the purpose of having Daugerdas pitch a MG tax shelter to the Calphalon shareholders. Parse subsequently attended a meeting with Daugerdas, the Calphalon shareholders, and several attorneys from the law firm of Shumaker Loop & Kendrick. In that meeting and in Parse's presence, as Kasperzak testified at trial, Daugerdas opened with the redflag statement that the information that he was about to provide was completely confidential and that the shareholders could not even share it with the shareholders' own investment advisors or accountants. (Tr. 6243). Daugerdas then described the tax shelter which he said would result in the shareholders' paying virtually no taxes on the gains. Kasperzak further testified, "We were told that the profit potential was very low and that going forward, should we choose to go forward, if we were questioned about the matter, that our intent was in fact to make a profit, but in order for this tax shelter to work, there had to be, in effect, a loss to balance off the gains from the sale.s2 (Tr. 6244). The urging by Daugerdas for the shareholders to make false statements about their intent is wholly inconsistent with good faith — all of which Parse witnessed.
+
+2 The testimony of Erwin Mayer and other trial witnesses made clear that the expected shortterm duration of the Treasury note transactions, combined with the lack of volatility of the specific Treasury notes chosen for the transactions, meant that the short sale was virtually certain to produce only a small loss or gain on this purported "investment."
+
+# 2. Parse's Personal Tax Evasion
+
+Parse executed his own fraudulent SOS tax shelter transaction to eliminate the gains he earned in 2000, and received a free fraudulent opinion letter from J&G. The losses Parse created — \$3,000,000 — were larger than Parse needed for the 2000 year, suggesting that he intended to eliminate taxes in more than one year. On his 2000 tax return, Parse claimed a \$1,278,706 fraudulent loss, evading \$517,542 in taxes on over \$2.1 million in income. See GX 1001-132 (Parse 2000 Tax Return); GX 1000-52 (IRS Certificate of Assessment and Payments for Parse's 2000 Taxes); GX 54-1 (J&G Opinion Letter for Parse). Parse's receipt of a free opinion letter, which would have otherwise cost him no less than \$90,000 (and likely more)) had he paid the going rate for a MG opinion letter, violated Deutsche Bank's gift prohibition policy and almost certainly violated the law, in that it constituted his receipt of an unlawful commission or gift by a bank official. See 18 U.S.C. § 215 (unlawful for any bank employee to accept anything of value intended to be rewarded in connection with business of bank).
+
+# 3. Pane's Participation in the Fraudulent Backdating of Transactions
+
+As detailed in paragraphs 44-52 of the PSR, Parse's conduct involved not only assisting in the design, marketing, and implementation of the fraudulent AG tax shelters, but also the implementation of fraudulently backdated when Donna Guerin and others at MG realized that the shelters had been implemented incorrectly, or not consistent with the clients' wishes with respect to
+
+Parse executed a \$3,000,000 short options deal through J&G. Using a conservative 3% fee results in a \$90,000 opinion letter value. Parse only deducted just over \$1.2 million of the \$3,000,000 in losses on his 2000 return, and thus had available just under \$1.8 million in losses to use on future tax returns. Although Parse ultimately did not utilize those additional losses (because he reversed his own transaction when the IRS began investigating), the proper view of Parse's own fraudulent transaction should take into account the full amount of fraudulent benefit he produced.
+
+the amount or nature of the tax loss.
+
+The facts concerning all of the backdating will not be repeated at length herein. It is useful to note, however, the following facts as they relate to Parse: (i) Parse was the key to the success of the backdated transactions — without his agreement and participation, the J&G attorneys were powerless to correct the mistakes; (ii) the corrections needed for the Aronoff transactions are reflected in David Parse's own handwriting on GX 401-99 (reflecting the original transaction) and GX 401-100 (reflecting the revised transaction), showing that he fully understood the nature of the backdating; (iii) the correction of the transactions required a complex series of steps. including reversals of transfers of assets between accounts, reversals of already-completed and foreign currency transactions, and execution of new "as of foreign currency and trades; and (iv) the backdating occurred with not just one client, but several and occurred in two different tax years tax year 2000 for the Aronoff family members, and tax year 2001 for Michael Toporek, Greg Blair, and Matthew Coleman.
+
+In his sentencing memorandum, Parse attempts to excuse the backdating by claiming, "He gave no investment advice, and the trades were executed by his assistant." (Parse Sent. Mem. at 12). This statement is not only a shameless attempt by Parse to throw his subordinate under the bus, but also a testament as to just how perverted these tax shelters were that the investment broker, who otherwise touts his treatment of his long-time clients, (it at 4 "As a broker, David had 30 to 40 longterm customers, and his goal was to assist them to invest their money wisely."), now attempts to make much of the fact that he was not giving investment advice to the backdating clients (or, as the evidence showed, to any of the other tax shelter clients). As to Parse's suggestion that the backdating transactions were done not by Parse, but by Carrie Yackee, his sales assistant (Parse Sentencing Mem. at 12), the evidence showed and Yackee testified persistently, consistently, and credibly that she acted at all times at the instruction of David Parse. Given the foregoing, Parse's attempt to blame her for his criminal conduct is inconsistent with the facts; it is also, in a larger sense, inexcusable.
+
+To the extent that Parse trial and current counsel have suggested and continue to suggest that the backdating transactions were approved by Deutsche Bank, the only approvals were from Parse himself, and on some of the trade tickets, the signature of the branch manager appears.' Moreover, there is no evidence that the branch manager knew of the purpose and animus for the backdated transactions. To the extent that a branch manager actually knew what was occurring, that fact would only render the branch manager a co-conspirator, and not excuse Parse's criminal conduct.
+
+However complex the tax shelters, the fraudulent backdating was nothing more than gardenvariety fraud committed to achieve impermissible tax results. Basic principles of tax reporting such as the annual accounting rule — prohibit the changing of tax results through transactions carried out after the close of the tax year. Carrie Yackee testified that she understood, based on her
+
+(Tr. 5699).
+
+4 Yackee made clear that the "Deutsche Bank approvals" on the backdated transaction were actually instructions from David Parse:
+
+Q. You also testified about acting in accordance with Deutsche Bank policy, correct?
+
+A. Correct.
+
+Q. Are you aware what Deutsche Bank's policy is for the use of as of dates on trades?
+
+A. I don't know of the specific policy.
+
+Q. How do you know you acted in accordance with the policy?
+
+A. I was directed what to do by my boss.
+
+Q. So when you say you acted in accordance with policy, you mean you followed your boss's orders?
+
+A. And I presumed that he would follow policy. So . . .
+
+conversations with David Parse, that the steps of the transactions had to be completed by the end of the year to achieve the tax benefits. Given this clear legal imperative, Parse's willingness to participate in such conduct can only be viewed as brazen misconduct.
+
+# C. The Indictment, Trial, New Trial Rulings, and the PSR
+
+On March 4, 2010, the grand jury returned a third superseding Indictment charging Parse, Guerin, Daugerdas, Mayer, and Brubaker in thirty-one counts. Parse in particular was charged with a conspiracy to the defraud the IRS, to commit tax evasion, and to commit mail and wire fraud (Count One), as well as three counts of tax evasion relating to the tax shelter transactions of three separate tax shelter clients (Counts Seventeen, Eighteen, and Nineteen). Parse was also charged in Counts Twenty and Twenty-Five with engaging in a corrupt endeavor to obstruct and impede the IRS and mail fraud, respectively, essentially through the same conduct underlying the Count One conspiracy charge.
+
+On February 28, 2011, trial commenced against Parse and his co-defendants. On May 24, 2011, the jury found Parse guilty on Counts Twenty and Twenty-Five, and not guilty on Count One and Counts Seventeen through Nineteen. Subsequently, the Court denied Parse motions for new trial based on juror misconduct and ineffective assistance of counsel. As a result of Parse's convictions, he faces a maximum of 23 years in prison.
+
+In connection with Parse's sentencing, the Probation Office has prepared a Presentence Investigation Report (the "PSR"), which calculates the defendant's Sentencing Guidelines offense levels. As calculated by Probation, the final offense level is 40, calling for a Sentencing Guidelines sentence at the statutory maximum, 23 years' imprisonment. PSR 1103. The breakdown of Parse's Guidelines calculation is as follows:
+
+A base offense level of 36 pursuant to §§ 2T1.9, 2T1.1, and 2T4.1(tax table). PSR ¶ 62. An increase of 2 levels pursuant to U.S.S.G. § 2T1.1(bX2) because the offense involved sophisticated means. PSR 1 63. An increase of 2 levels pursuant to U.S.S.G. § 3B1.3 because the defendant used his skills as a broker and CPA to materially facilitate his design and implementation of the highly-complex financial products that were involved in the different tax shelters. PSR¶ 64.
+
+Parse has no criminal history points. Thus, with a final offense level of 40, Parse's Guidelines analysis, according to the PSR, yields a final advisory Guidelines range of 292-365 months. However, due to the combined statutory maxima of Counts Twenty and Twenty-Five, the Guidelines term of imprisonment is limited to 276 months. PSR ¶ 103.
+
+# D. The Objections to the PSR
+
+Parse has leveled three objections to the calculation of the Guidelines: specifically, to (i) the loss calculations for Guidelines purposes; (ii) the application of the sophisticated means enhancement, and (iii) the application of the use of a special skill. Parse objects to being held responsible, for Guidelines loss calculations purposes, for the full amount of loss generated by the corrupt endeavor and scheme to defraud the Internal Revenue Service. Parse argues that "a fair reading of the jury's verdict is that Parse was convicted only for his role in what the [Presentence] Report describes as three instances of fraudulent 'backdating."
+
+Defendant Parse's position is contrary to law and has no basis in reliable fact. First, Parse's contention that he is being held responsible for acquitted conduct ignores the fact that he was convicted on the broad corrupt endeavor and scheme to defraud. Indeed, the Second Circuit Court of Appeals has held as follows:
+
+Under § 1B1.3(a), the court, in calculating a defendant's offense level, was to take
+
+into account, inter alia, the defendant's own acts and omissions, see id. § I B1.3(a)(IXA), as well as "all reasonably foreseeable acts and omissions of others in furtherance of the jointly undertaken criminal activity," id. § 1B1.3(a)(IXB), and "all harm that resulted from the acts and omissions specified in subsection[ (a) (1) . . . above, and all harm that was the object of such acts and omissions," id. § I B1.3(a)(3) (emphasis added).
+
+United States v. Reifler,446 F.3d 65, 108 (2d Cir. 2006) (alterations in original). See also United States v. Nash, 338 Fed. Appx. 96, 98, 2009 WL 2901565, at \*1 (2d Cir. 2009) (summary order) (rejecting defendant's claim that he be held liable only for the fraudulent transactions in which he was directly involved; loss should be based on foreseeable loss from fraudulent scheme); United States v. Singh, 390 F.3d 168, 192 (2d Cir. 2004) (court upheld finding of full loss for sentencing guidelines purposes, despite some acquittals: "It matters not that various phases of the execution of the scheme were rejected by the jury for reason or reasons unknown. Singh's opinions regarding the legality of his billing practices were rejected by the jury, which clearly found the existence of an overall fraudulent scheme."); United States v. Zichittello, 208 F.3d 72 (2d Cir. 2000) (upholding loss computations in RICO case: "As to the campaign finance scheme, Hartman is liable as a co-conspirator for 'all reasonably foreseeable acts and omissions' in furtherance of the conspiracy. U.S.S.G. § I B1.3(a)(1XB). Because there was evidence that Hartman was well aware of the larger scheme, the district court did not err in finding that Hartman was liable for the entire loss suffered by the NYCCFB."); United States v. Senninger,429 Fed. Appx. 762, 767, 2011 WL 2688988, at \*4 (10th Cir. 2011) (summary order) (court upheld attributing full loss from mail fraud scheme to defraud the IRS and Colorado Department of Revenue; "[The court looked at the totality of Senninger's involvement in that scheme, concluding her actions did not involve 'simply filling in blanks on amended returns.' The district court found Senninger 'len[t] credibility to the entire operation. She lent her credibility as having been an IRS auditor to this operation, and she knew she
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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+x
+
+UNITED STATES OF AMERICA
+
+v.
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+x
+
+S2 20 Cr. 330 (MN)
+
+### GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTION FOR A NEW TRIAL
+
+Jeffrey S. Pagliuca
+
+Laura A. Mennin er
+
+HADDON, & P.C.
+
+950 17th Street, Suite 1000
+
+Denver, CO 80202
+
+Phone: 303-831-7364
+
+Christian R. Everdell
+
+& GRESSER LLP
+
+800 Third Avenue
+
+New York, NY 10022
+
+Phone: 212-957-7600
+
+Bobbi C. Sternheim
+
+Law Offices of Bobbi C. Sternheim
+
+225 Broadway, Suite 715
+
+New York, NY 10007
+
+Phone: 212-243-1100
+
+Attorneys for Ghislaine Maxwell
+
+# Table of Contents
+
+| Introduction The Facts The Law I. E. | Table of Contents Table of Authorities Ms. Maxwell is entitled to a new trial. A. The government's policy concerns—the abstract interest in "finality" and the so-called "disfavor" with which new trial motions are viewed—are misplaced . Maxwell does not have to prove that Juror No. 50's voir dire answers were deliberately false C. Juror No. 50's answers were deliberately false D. If Juror No. 50 had truthfully answered Questions 25 and 48, the correct responses would have provided a valid basis for a challenge for cause. This Court should reject the government's attempt to manufacture a "Show Hearing" | ii iii 1 3 6 6 6 9 14 16 19 |
+|--------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------|
+| 1. | The lawyers should conduct the questioning | 19 |
+| 2. | The questioning should encompass any topic on which actual bias may be based | 21 |
+| 3. | The Additional Biased Juror Should Be Questioned | 23 |
+| 4. | Ms. Maxwell is entitled to Discovery | 24 |
+| 5. | Juror No. 50 is not entitled to discovery in advance of the hearing. | 25 |
+| Conclusion | | 25 |
+| | Certificate of Service | 27 |
+
+## Table of Authorities
+
+#### Cases
+
+| Amirault v. Fair, | 968 F.2d 1404 (1st Cir. 1992) | 9 |
+|---------------------------------------------------------------------|--------------------------------|------------------------|
+| Burton v. M, | 948 F.2d 1150 (10th Cir. 1991) | 18 |
+| | 850 F.2d 437 (8th Cir. 1988) | 9 |
+| cf. Pena-Rodriguez v. Colorado, | 137 S. Ct. 855 (2017) | 23 |
+| Cf. United States v. James, | 609 F.2d 36 (2d Cir. 1979) | 21 |
+| Connick v. Thompson, | 563 U.S. 51 (2011) | 9 |
+| Diorio v. Kreisler-Borg Const. Co., | 407 F.2d 1330 (2d Cir. 1969) | 15 |
+| Dyer v. Calderon, | 151 F.3d 970 (9th Cir. 1998) | 9, 18, 20 |
+| Gomez v. United States, | 490 U.S. 858 (1989) | 7 |
+| Gray v. Mississippi, | 481 U.S. 648 (1987) | 7 |
+| Haynes v. | 88 F.3d 898 (10th Cir. 1996) | 13 |
+| Indep. Onty. Bankers of Am. v. Bd. of Governors of Fed. Rsrv. Sys., | | 195 F.3d 28 (D.C. Cir. |
+| 1999) | | 12 |
+| lama v. Immigr. & Customs Ent' t, | 543 U.S. 335 (2005) | 12 |
+| Leonard v. United States, | 378 U.S. 544 (1964) | 10 |
+| McDonough Power Equip. v. Greenwood, | 464 U.S. 548 (1984) | passim |
+| P. Beiersdotf & Co. v. McGohey, | 187 F.2d 14 (2d Cir. 1951) | 13 |
+| v. Gladden, | 385 U.S. 363 (1966) | 1, 6 |
+| Purvis v. Oest, | 614 F.3d 713 (7th Cir. 2010) | 19 |
+| Schacht v. Wis. Dept of Corr., | 175 F.3d 497 (7th Cir. 1999) | 19 |
+| v. M, | 455 U.S. 209 (1982) | 10, 14, 18 |
+| Tanner v. United States, | 483 U.S. 107 (1987) | 7, 8 |
+| Texaco Inc. v. Louisiana Land & Exploration Co., | 995 F.2d 43 (5th Cir. 1993) | 13 |
+
+| United States v. Daugerdas, 867 F. Supp. 2d 445 (S.D.N.Y. 2012)..... | 16 |
+|--------------------------------------------------------------------------------------|----------------|
+| United States v. Daugerdas, No. 1:09-cr-00581-DLC, Sept. 9, 2011 ..... | 2, 16, 18, 19 |
+| United States v. [REDACTED], 246 F.3d 129 (2d Cir. 2001)..... | 6, 7 |
+| United States v. [REDACTED], 904 F.3d 111 (1st Cir. 2018) ..... | 3 |
+| United States v. Greer, 285 F.3d 158 (2d Cir. 2002)..... | 13, 14, 17, 21 |
+| United States v. Haynes, 398 F.2d 980 (2d Cir. 1968) ..... | 11 |
+| United States v. Ianniello, 866 F.2d 540 (2d Cir. 1989)..... | 7, 8 |
+| United States v. Langford, 990 F.2d 65 (2d Cir. 1993) ..... | passing |
+| United States v. [REDACTED], [REDACTED], 528 U.S. 304 (2000)..... | passing |
+| United States v. McCourty, 562 F.3d 458 (2d Cir. 2009) ..... | 6, 7 |
+| United States v. Moon, 718 F.2d 1210 (2d Cir. 1983)..... | 8 |
+| United States v. Nelson, 277 F.3d 164 (2d Cir. 2002) ..... | 6 |
+| United States v. Parse, 789 F.3d 83 (2d Cir. 2015) ..... | 16 |
+| United States v. Shaoul, 41 F.3d 811 (2d Cir. 1994) ..... | 12, 13, 17 |
+| United States v. Stewart, 433 F.3d 273 (2d Cir. 2006) ..... | passing |
+| United States v. [REDACTED], 282 F.2d 547 (2d Cir. 1960) ..... | 15 |
+| United States v. [REDACTED], 128 F.3d 38 (2d Cir. 1997)..... | 16, 18 |
+| United States v. Wilkerson, 361 F.3d 717 (2d Cir. 2004) ..... | 12 |
+| Warger v. Shauers, 574 U.S. 40..... | 23 |
+| Zerka v. [REDACTED], 49 F.3d 1181 (6th Cir. 1995) ..... | 9, 10 |
+
+### Other Authorities
+
+Jeremy Peterson, Unpacking Show Trials: Situating the Trial of Saddam Hussein, 48 Harv. L.J. 257, 260 (2007) 19
+
+## Rules
+
+| Fed. R. Crim. P. 33 | 1 |
+|----------------------|--------|
+| Fed. R. Evid. 606(b) | 23, 24 |
+
+#### Constitutional Provisions
+
+| U.S. Const. amends. V ..... | 1, 6, 23 |
+|-----------------------------|----------|
+| U.S. Const. amends. VI..... | 1, 6, 23 |
+
+Ghislaine Maxwell submits this reply in support of her motion under Federal Rule of Criminal Procedure 33 for a new trial.
+
+## Introduction
+
+Ms. Maxwell "was entitled to be tried by 12, not 9 or even 10, impartial and unprejudiced jurors." v. Gladden, 385 U.S. 363, 366 (1966). That did not happen. Juror No. 50's presence on the jury deprived Ms. Maxwell of the fair and impartial jury the due process and the Sixth Amendment guarantee. U.S. Const. amends. V, VI.' "[T]he seating of any juror who should have been dismissed for cause ... require[s] reversal." United States v. 528 U.S. 304, 316 (2000).
+
+The government's response to this suffers from two fundamental errors. The first is to insist that a new trial is required only if Juror No. 50 was "dishonest" by "deliberately" providing false answers to Questions 25 and 48. That is not the law. Neither the United States Supreme Court nor the Second Circuit requires a showing of a "deliberate falsehood." United States v. Stewart, 433 F.3d 273, 303 (2d Cir. 2006) (applying McDonough Power Equip. v. Greenwood, 464 U.S. 548 (1984) and holding that the requirement of a fair and impartial jury is "reflected in the McDonough standard for analyzing allegations that a juror's false voir dire concealed bias that affected the fairness of the trial: a party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror's voir dire response was false and second, that the correct
+
+Although this Court need not hold a hearing since the record already establishes that Ms. Maxwell was deprived of her Sixth Amendment right to trial by an impartial jury, any such hearing must also serve to identify this other juror. Such a hearing likely would also show that Juror No. 50 was actually biased, in addition to being impliedly and inferably biased.
+
+It appears that, at best, Ms. Maxwell had 10 fair and impartial jurors, not the 12 guaranteed her by the United States Constitution. We know at least one other juror in addition to Juror No. 50 falsely denied having been a victim of sexual abuse or assault.
+
+response would have provided a valid basis for a challenge for cause"). That's because, as the Supreme Court held in United States v. "the seating of any juror who should have been dismissed for cause ... require[s] reversal." 528 U.S. at 316. Thus, irrespective of whether Juror No. 50 deliberately provided false answers to Questions No. 25 and 48 (though the record shows he did), his presence on the jury requires reversal if he was impliedly, inferably, or actually biased.
+
+Second, the government misunderstands this Court's role during any evidentiary hearing. Ours is an adversarial system, not an inquisitorial system. Ms. Maxwell has a right to present her arguments to the Court, to call material witnesses in support of those arguments, and to confront and cross-examine those witnesses. The government's request for a narrow and limited hearing in which only Juror No. 50 would testify and only the Court would ask questions flies in the face of this adversarial process. A hearing conducted on the government's terms would violate Ms. Maxwell's constitutional right to assistance of counsel, hamstring the search for the truth, and contravene the tradition and precedent of this judicial district. See, e.g., ExHisrr 3, United States v. Daugerdas, Case No. 09 Cr. 581 (Hon. William H. Pauly III) (Trans. of Motion for New Trial). As the government itself argued in Daugerdas, a juror who "conceal[ed] personal background material so analogous to the case on trial" had "bias [] implied as a matter of law" and the affected defendant therefore would be entitled to a new trial. Doc. 487, p 21, United States v. Daugerdas, No. 1:09-cr-00581-DLC, Sept. 9, 2011. This is just such a case.
+
+The government's response to Ms. Maxwell's motion for a new trial elides the stakes involved and the significance of the constitutional right at issue. Ms. Maxwell was on trial for her life. That trial required 12 fair and impartial jurors. While paying lip service to the requirement of a fair trial, the government incants the words "finality" and "disfavor" as a basis for turning a blind eye to Juror No. 50's misconduct and the constitutional right to a fair and impartial jury, and it then proposes a superficial inquiry that would make it all but impossible for Ms. Maxwell to meet the erroneously high burden the government asks this Court to apply.
+
+Yet this Court has "an unflagging duty ... to investigate [Ms. Maxwell's] claim."2 Properly understood and properly considered, Ms. Maxwell's claim has evident merit. For all the reasons given in the motion and elaborated below, this Court should reject the government's attempt to cripple Ms. Maxwell's vindication of her constitutional right to a trial by a fair and impartial jury.
+
+## The Facts
+
+The government's response relies heavily on the fact that several potential jurors who admitted to being victims of sexual assault, sexual abuse, or harassment were not excluded for case. That is nothing but misdirection.
+
+Those potential jurors admitted to being victims of conduct nothing like the alleged conduct in this case. For example, potential jurors said they were groped or harassed on the subway, harassed at work, or touched inappropriately in a social setting. Resp. at 4-5.
+
+Juror No. 50, by contrast, has now admitted to being the victim of child sexual abuse the very same conduct at issue in this case. And he has also admitted to responding to that abuse in much the same way the alleged victims in this case responded—delaying disclosure, relying on memories that can be replayed like a video, etc. This Court should not be misled by the government's misleading comparisons.
+
+2 United States v. 904 F.3d 111, 117 (1st Cir. 2018) (quotation omitted).
+
+ms\*
+
+This is a case where alleged child victims of sexual abuse delayed disclosure of their claimed abuse for many years. The central issue in the trial was the credibility of the accusers about those claims. Accordingly, it was important for Ms. Maxwell to screen prospective jurors and eliminate any juror with a background that would, consciously or unconsciously, make the juror more sympathetic to the accusers, dismiss challenges to the accusations as overly aggressive defense tactics, and credit the alleged victims' stories because of abuse suffered by the juror as a child.
+
+The Court denied Ms. Maxwell's request to have her lawyers question prospective jurors on this topic, denied Ms. Maxwell's request to include additional questions on the written questionnaire on this topic, but assured Ms. Maxwell that the Court would "smoke out" potential jurors who did not tell the truth:
+
+I will individually, one-on-one, question[] the jurors, and with the parties present, I feel confident that I can discern any clear dishonesty. This is not just going to be a summary voir dire; it will be probing.... If a juror's going to lie and be dishonest, we will smoke that out.
+
+Tr. 10/21/21 Hrg. at 26:12.
+
+Although given multiple opportunities to identify himself as a victim of child sexual abuse, Juror No. 50 failed to truthfully respond to very clear and pointed questions such as "were you the victim of a crime" and specifically, whether
+
+Have you or a friend or family member [have] ever been the victim of sexual harassment, sexual abuse, or sexual assault? (This includes actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member.)
+
+Had Juror No. 50 truthfully disclosed his child-victim status he would have been immediately challenged for cause by Ms. Maxwell regardless of his answers to any other questions. In the unlikely event this challenge was denied, Juror No. 50 would have been questioned, in camera, by the Court. Juror No. 50 would have been asked to explain what happened to him as a child and the impact it had on him. He would have been asked if his own traumatic, scarring, and lifechanging abuse would make him more sympathetic towards the accusers in this case and less sympathetic towards Ms. Maxwell. He would have been probed about any claimed ability to be fair and impartial.
+
+Of course, everyone wants to believe that they can be fair and impartial and can set aside any bias they may have based on their prior experiences, but we know that this is difficult, if not impossible for any human to do. Regardless of Juror No. 50's answers to questions about his purported ability to disregard his own childhood victimization, Ms. Maxwell would have challenged Juror No. 50 for cause and, consistent with other prospective juror challenges, the request would have been granted by the Court.
+
+Assuming Juror No. 50 recounted any of his beliefs during jury selection, subsequently disclosed by him in the media—such as the abusive event is like a video and victims remember the event accurately—there is no doubt a challenge would have been made, unopposed, and granted.
+
+Now, after having been alerted by the government that he may be in trouble, Juror No. 50 has predictably, either with the assistance of counsel or simple common sense, attempted to disavow his earlier comments and actions, going to great lengths to stress his now claimed ignorance of the questions and his ability to be fair.
+
+If we, the lawyers and jurist in this matter, are being truthful, the essential facts surrounding this issue are not really subject to dispute: (1) whether a prospective juror suffered childhood sexual abuse was a material fact; (2) Juror No. 50 was (or claims to be) a victim of
+
+childhood sexual abuse; and (3) had he answered the questions accurately he would have been challenged for cause and disqualified.
+
+### The Law
+
+### I. Ms. Maxwell is entitled to a new trial.
+
+#### A. The government's policy concerns—the abstract interest in "finality" and the so-called "disfavor" with which new trial motions are viewed are misplaced.
+
+The government's response is conspicuous in that it does not begin with the law governing new trial motions based on juror bias. Instead, the government sets the table with appeals to "finality," statements that new trial motions are "disfavored," and implications that courts should turn a blind eye to juror misconduct because to do otherwise would expose jurors to harassment and intimidation. Resp. at 10-11. None of these concerns has any purchase here.
+
+In the government's view, the jury in this case "finally" determined Ms. Maxwell's guilt. To be entitled to a new trial, says the government, "a district court must find that there is 'a real concern that an innocent person may have been convicted."' Resp. at 10 (quoting United States v. McCourry, 562 F.3d 458, 475 (2d Cir. 2009) (quoting United States v. 246 F.3d 129, 134 (2d Cir. 2001))). That is not correct.
+
+Everyone accused of a crime is entitled a trial by a fair trial and impartial jury. U.S. Const. amends. V, VI. That constitutional promise demands twelve fair and impartial jurors. 385 U.S. at 366. "[T]he seating of any juror who should have been dismissed for cause" is structural error and it "require[s] reversal." 528 U.S. at 316; United States v. Nelson, 277 F.3d 164, 204 (2d Cir. 2002) ("[T]he empanelment of a jury on which [a] biased juror sat [means that] the defendants in this case were convicted, in contravention of the Sixth Amendment and due process, by a jury that cannot be deemed to have been fully impartial.").
+
+Ms. Maxwell is not required to show prejudice, nor must the Court have "a real concern that an innocent person may have been convicted" before a new trial is required. The government's contrary contention is specious.3
+
+The government next invokes cases in which appellate courts have purported to view new trial motions with "disfavor." Resp. at II. These cases, warn the government, counsel against "inquiries into juror conduct." Id. Quoting Tanner v. United States, the government says: "Allegations of juror misconduct, incompetency, or inattentiveness, raised for the first time ... after the verdict, seriously disrupt the finality of the process. Moreover, full and discussion in the jury room, jurors' willingness to return an unpopular verdict, and the community's trust in a system that relies on the decisions of laypeople would all be undermined by a barrage of postverdict scrutiny of juror conduct." Id. (quoting Tanner v. United States, 483 U.S. 107, 120-21 (1987)). The government also quotes the Second Circuit's decision in United States v. lanniello. in which the Court said that "post-verdict inquiries may lead to evil consequences: subjecting juries to harassment, inhibiting juryroom deliberation, burdening courts with meritless applications, increasing temptation for jury tampering and creating uncertainty in jury verdicts." 866 F.2d 540, 534 (2d Cir. 1989).
+
+3 The government draws the "real concern" language from cases addressing new trial motions based on the conduct of the trial itself—e.g., the admissibility or truthfulness of testimony of witnesses, McCourty, 562 F.3d at 475, or the quality and sufficiency of the evidence, 246 F.3d at 134.
+
+The cases cited by the government do not address the fundamental right to trial by an impartial jury, and they do not undermine the blackletter law that "[a]mong those basic fair trial rights that `can never be treated as harmless' is a defendant's 'right to an impartial adjudicator, be it judge or jury." Gomez v. United States, 490 U.S. 858, 876 (1989) (quoting Gray v. Mississippi, 481 U.S. 648, 668 (1987)).
+
+The government's invocation of Tanner and lanniello is strikingly disingenuous. Both cases involved alleged conduct during trial and, crucially, during deliberations. The interest in "shielding jury deliberations from public scrutiny" is what motivated the Supreme Court's decision in Tanner, 483 U.S. at 119, and the Second Circuit's cautionary note in lanniello, 866 F.24 at 543.
+
+In this case, by contrast, there is at least one juror who falsely answered voir dire questions to gain a seat on the jury, conduct that occurred outside the jury room. The reluctance of courts to second-guess jury deliberations by inquiring into how the jury reached its decision simply has no relevance here, and neither do Tanner or lanniello.
+
+In fact, the government's reliance on lanniello is doubly wrong, because the Second Circuit there set aside any reluctance it might have had to question the conduct of deliberations by ordering the defendant's requested evidentiary hearing. As the Court explained, "a post-trial jury hearing must be held when a party comes forward with 'clear, strong, substantial and incontrovertible evidence ... that a specific, non-speculative impropriety has occurred.' lanniello, 866 F.2d at 543 (quoting United States v. Moon, 718 F.2d 1210, 1234 (2d Cir. 1983)).4 Here, of course, the government concedes Ms. Maxwell's entitlement to an evidentiary hearing.
+
+The government cannot with a straight face claim that Ms. Maxwell's motion risks exposing Juror No. 50 to harassment and intimidation. Let's be clear. The only reason Ms. Maxwell knows of Juror No. 50's false answers during voir dire is that Juror No. 50 has sought out the limelight. He has sat for several interviews with journalists, he has allowed himself to be videotaped, he has Tweeted and publicized himself on social media, and he has even participated
+
+To be clear, this standard does not apply to Ms. Maxwell's claim; it applies when a new trial motion alleges misconduct during deliberations. lanniello, 866 F.3d at 543; Moon, 718 F.3d at 1234.
+
+in a "documentary." Inquiring into the false answers Juror No. 50 has publicly admitted making risks nothing that Juror No. 50 hasn't already brought on himself.
+
+Ms. Maxwell's motion has nothing to do with her innocence or guilt. It involves no strategy or artifice by the defense. And it risks no unauthorized inquiry into the jury room. The motion is about one thing, and one thing only: Every person's constitutional right to a fair and impartial jury. The government hopes to deprive Ms. Maxwell of that right in the name of "finality."
+
+This Court should disregard the government's policy arguments, which address arguments and claims Ms. Maxwell is not making. In turn, the government's policy arguments betray the weakness of its legal position. And they cast significant doubt on the United States solemn duty to seek justice and not merely to convict. Connick v. Thompson, 563 U.S. 51, 65-66 (2011) ("Prosecutors have a special "duty to seek justice, not merely to convict.").
+
+Maxwell does not have to prove that Juror No. 50's ',air dire answers were deliberately false.
+
+The government insists that Ms. Maxwell is entitled to a new trial only if she can prove that Juror No. 50 deliberately provided false answers during voir dire. Not so.
+
+Contrary to the government's argument, the decision McDonough Power Equip. v. Greenwood, "does not entirely foreclose a party from seeking a new trial on the basis of a prospective juror's honest, though mistaken, response." Zerka v. 49 F.3d 1181, 1186 n.7 (6th Cir. 1995); accord Dyer v. Calderon, 151 F.3d 970, 981 (9th Cir. 1998) (en bane) ("In extraordinary cases, courts may presume bias based on the circumstances."); Amirault v. Fair, 968 F.2d 1404, 1405-06 (1st Cir. 1992) ("[T]he majority vote in McDonough.. . require[s] a further determination on the question of juror bias even where a juror is found to have been honest...."), cert. denied, 506 U.S. 1000; Cannon v. , 850 F.2d 437, 440 (8th Cir.
+
+1988) (interpreting McDonough and holding that "a juror's dishonesty is not a predicate to obtaining a new trial. The focus is on bias"). To the contrary, as five justices recognized in McDonough and as the Second Circuit held in United States v. Langford, a new trial is required when a biased juror is seated even if the juror's false voir dire answers were the result of inadvertence rather than the product of a deliberate effort. McDonough, 464 U.S. at 556-57 (Blackmun. J.. concurring (citing v. M, 455 U.S. 209, 215-16 (1982); id. at 220-24 . I . concurring))); id. at 557-58 J., concurring in judgment); United States v. Langford, 990 F.2d 65, 68 (2d Cir. 1993) ("We read [the McDonough] multi-part test as governing not only inadvertent nondisclosures but also nondisclosures or misstatements that were deliberate....').5 See also Leonard v. United States, 378 U.S. 544 (1964) (per curiam) (reversing conviction based on implied bias and holding that prospective jurors who had heard the trial court announce the defendant's guilty verdict in the first trial should be automatically disqualified from sitting on a second trial on similar charges). In Justice Blackmun's words, which were joined by Justices Stevens and and expressed a view shared by Justice and Justice Marshall, "regardless of whether a juror's answer is honest or dishonest, it remains within a trial court's option, in determining whether a jury was biased, to order a post-
+
+Contrary to the government's implication, however, Ms. Maxwell's motion accurately described McDonough and its holding, noting that Justice Blackmun oined by Justices Stevens and "concurred" in the majority opinion while Justice (joined by Justice Marshall) "concurred in judgment." Mot. at 26. Most importantly, any way you look at it, five votes is five votes. Zerka, 49 F.3d at 1186, n.7 (counting the votes in McDonough and explaining the holding). And in McDonough, as the Court recognized in Langford when it quoted and adopted Justice reasoning, the McDonough decision "govem[s] not only inadvertent nondisclosures but also nondisclosures or misstatements that were deliberate." 990 F.2d at 68 (citing McDonough, 464 U.S. at 557-58 J., concurring in judgment)).
+
+5 The governmentagomerning deceitful by Ms. Maxwell's reliance on Justice Blackmun'sand Justice concurrences, noting that six justices joined Justice Rehnquist's McDonough majority opinion. Resp. at 14 & n.8.
+
+trial hearing at which the movant has the opportunity to demonstrate actual bias or, in exceptional circumstances, that the facts are such that bias is to be inferred." McDonough, 464 U.S. at 556-57 (Blackmun, J., concurring) (citing M, 455 U.S. at 215-16; id. at 220-24 3., concurring)).
+
+This is the only fair reading of McDonough and Langford, and it is only conclusion the Sixth Amendment permits. Imagine the counterfactual scenario in which Juror No. 50 truthfully answered Questions 25 and 48. If Ms. Maxwell had challenged Juror No. 50 for cause and this Court had denied that challenge, Ms. Maxwell would be able to raise the issue in a new trial motion and, if that were denied, on appeal. In the new trial motion or on appeal, Ms. Maxwell's only burden would be to prove that Juror No. 50 was impliedly, inferably, or actually biased. E.g., United States v. Haynes, 398 F.2d 980, 983 (2d Cir. 1968) (new trial required when a deliberating juror is actually or impliedly biased). She would not have to prove any inadvertent falsehoods or deceit by Juror No. 50.
+
+In the government's view, however, Ms. Maxwell must carry a heavier burden than she otherwise would because Juror No. 50 did not tell the truth. That neither makes sense nor is fair. Ms. Maxwell should not be punished because Juror No. 50 did not tell the truth, particularly when Ms. Maxwell could not have challenged Juror No. 50 for cause at the time precisely because he did not tell the truth and she lacked any ability to question the juror.
+
+Fortunately, the government's view is wrong, as five justices in McDonough made clear and the Second Circuit held in Langford. Under Second Circuit law, as the Court held in United States v. Stewart, "[A] party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause." United States v. Stewart,
+
+433 F.3d 273, 303 (2d Cir. 2006) (citing McDonough, 464 U.S. at 556). Ms. Maxwell need not prove a deliberate falsehood. Id.
+
+The government all but ignores Stewart, relying on United States v. Shaoul, 41 F.3d 811 (2d Cir. 1994), in an effort to minimize Langford. The government's invocation of Shaoul fails.
+
+First, Shaoul did not reject the argument Ms. Maxwell makes here. Nowhere in Shaoul does the Court cite or discuss Justice Blackmun's concurring opinion or Justice opinion concurring in judgment, which together were supported by five justices. See Shaoul, 41 F.3d at 815-17. This Court should not read Shaoul to have rejected an argument it did not even consider.
+
+Second, the language from Shaoul on which the government relies is dictum. That's because the Shaoul Court held that the defendant could not "satisfy the second part of the McDonough test—that the juror could have been challenged for cause." Id. at 816. The Court's discussion of deliberate-versus-inadvertent false answers thus was not necessary to its conclusion, and this Court is not bound by it. Jama v. Immigr. & Customs Ent t, 543 U.S. 335, 352 n.12 (2005) ("Dictum settles nothing, even in the court that utters it.").
+
+Third, if the government's reading of Shaoul were correct, then Shaoul is inconsistent with Langford, not to mention McDonough. Because Langford was decided first, and because McDonough is a United States Supreme Court opinion, this Court is bound by both and not by Shaoul. Compare United States v. Wilkerson, 361 F.3d 717, 732 ad Cir. 2004) (one panel of the Court of Appeals is "bound by the decisions of prior panels until such time as they are overruled either by an en banc panel of our Court or by the Supreme Court"), with Indep. Cmty. Bankers of Am. v. Bd. of Governors of Fed. Rsrv. Sys., 195 F.3d 28, 34 (D.C. Cir. 1999) ("In the event of conflicting panel opinions ... the earlier one controls, as one panel of this court may not overrule another." (quoting Texaco Inc. v. Louisiana Land & Exploration Co., 995 F.2d 43, 44 (5th Cir. 1993))); see also Haynes v. 88 F.3d 898, 900 n. 4 (10th Cir. 1996) ("[W]hen faced with an intra-circuit conflict, a panel should follow earlier, settled precedent over a subsequent deviation therefrom."); P. Beiersdolf & Co. v. McGohey, 187 F.2d 14, 15 (2d Cir. 1951) (when there is an intra-circuit conflict, courts must follow the earlier decision).
+
+Of course, this Court need not conclude that Shaoul is inconsistent with McDonough and Langford in order to reject the government's argument. As described above, Shaoul does not address the reading of McDonough that Ms. Maxwell advocates for here, since it did not discuss or even cite the McDonough concurring opinions.
+
+Moreover, Second Circuit cases following Lanford and Shaoul have reaffirmed that a deliberate falsehood is not a prerequisite to a new trial. Cf. United States v. Mansfield, 2019 WL 3858511, at \*4 & n.4 (D. Colo. No. 18-cr-00466-PAB, Aug. 16, 2019) (in face of infra-circuit conflict, following first-decided case and noting that subsequent cases had followed first decision was as well). In Stewart, for example, decided in 2006, the Court cited and quoted McDonough and yet did not require a deliberately false answer, stating instead that "a party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause." Stewart, 433 F.3d at 303 (citing McDonough, 464 U.S. at 556).
+
+Then there's United States v. Greer, which reads McDonough and Langford just as Ms. Maxwell reads them, even while citing Shaoul. United States v. Greer, 285 F.3d 158, 171-72 (2d Cir. 2002). As the Court explained in Greer, "McDonough establishes a multi-part test in which a juror's dishonesty is among the factors to be considered' in the ultimate determination of bias. ..." Id. at 173 (citing Langford, 990 F.2d at 68-70 (emphasis added)). Thus, just as Ms. Maxwell explained in the motion, the "deliberateness" of a prospective juror's "particular lies [may] evidence[] partiality"6—think of a juror who deliberately lies because of a desire to sit on a jury and punish one of the parties to the case—but the lack of a deliberately false answer does not prove the absence of partiality.
+
+In the end, under McDonough, Langford, Stewart and Greer, a deliberately false answer is not required.'
+
+### C. Juror No. 50's answers were deliberately false.
+
+Even so, the record more than supports the conclusion that Juror No. 50's answers to Questions 25 and 48 (not to mention his answers during in-person voir dire about social media use) were deliberately false. Juror No. 50 knew he was the victim of a crime. He was a prospective juror in a case where the accused was on trial for alleged sexual misconduct with minors. As the childhood victim of a sex crime, answering questions in a case about a childhood sex crime, there is no plausible explanation for why Juror No. 50 did not answer Question 25, "Yes." The only believable answer is that he knew that answering that question "Yes" would lead to further questions like, what was the crime, which would then lead to questions about what happened to him, which would end with his disqualification.
+
+6 Greer, 285 F.3d at 173.
+
+' A deliberately false answer by a juror in voir dire is thus neither necessary nor sufficient to entitle a defendant to a new trial. It's not necessary because, if a biased juror actually serves on a jury, structural error occurs, and a new trial is r uired even if the juror did not provide a deliberately false answer during voir dire. . 528 U.S. at 316; McDonough, 464 U.S. at 556-57 (Blackmun, J., concurring ; id. at 557-58 J., concurring in judgment); 455 U.S. at 215-16; id. at 220-24 , J., concurring); Stewart, 433 F.3d at 303; Greer, 285 F.3d t 171-72; Langford, 990 F.2d at 68. And it's not sufficient because a juror may not be biased even if he dishonestly answers a question during voir dire. Greer, 285 F.3d at 173 ("[A]n analysis of bias is required even if the juror's erroneous response was deliberate.").
+
+Question 48 was not confusing or complicated and, again, there is no credible explanation for why the victim of a sexual assault, in a case about sexual assault, would not have taken a long look at that question. The claim that he just "missed it" or "forgot" or "didn't understand" is after-the-fact, self-serving, nonsense, the type of nonsense repeatedly rejected by courts, not to mention the government, when addressing material omissions or false oaths by omission.
+
+For example, in bankruptcy proceedings the failure to truthfully answer questions about assets or ownership interests regularly leads the government to move to dismiss the debtor's petition. Not surprisingly, debtors often claim confusion, mistake, or inadvertence as the reason for the false answer. However, success of a bankruptcy program (like jury trials) "hangs heavily on the veracity of statements made by the bankrupt"—or here, the prospective jurors. See Diorio v. Kreisler-Borg Const. Co., 407 F.2d 1330, 1330-31 (2d Cir. 1969). See also United States v. M, 282 F.2d 547, 553 (2d Cir. 1960) (the purpose of a debtor filling out a detailed financial disclosure (SOFA) "is to give dependable information without need of going further"). When a false-oath-giver claims carelessness as the mason for the untruthful statement, courts are skeptical because in a system that relies on a person's word, the answers "must be regarded as serious business; reckless indifference to the truth, is the equivalent of fraud." Diorio, 407 F.2d at 1330-31.
+
+In a case like this one, which charges the defendant with perjury, it's ironic the lengths to which the government has gone to excuse Juror No. 50's false answers as nothing but an innocent mistake, an indulgence the government is unwilling to afford Ms. Maxwell.
+
+### D. If Juror No. 50 had truthfully answered Questions 25 and 48, the correct responses would have provided a valid basis for a challenge for cause.
+
+It is both unnecessary and premature for this Court to consider whether Juror No. 50 was actually biased.
+
+It's unnecessary because any bias is sufficient to require a new trial, and here the record shows that Juror No. 50 was both impliedly and inferably biased. Because Juror No. 50 was impliedly and inferably biased, a new trial is required. , 528 U.S. at 316. And it's premature because the actual bias inquiry depends in part on the statements a prospective juror makes during voir dire. United States v. 128 F.3d 38, 43 (2d Cir. 1997) ("A juror is found by the judge to be partial either because the juror admits partiality, or the judge finds actual partiality based upon the juror's voir dire answers."). Here, Juror No. 50 hasn't had to answers the questions that would have been posed to him if he had answered Questions 25 and 48 truthfully. Only a hearing—if this Court orders one—will permit the Court and parties to evaluate actual partiality.
+
+The government here attempts to raise the bar for relief, just as it did in United States v. Daugerdas: "The Government urges this Court to adopt a narrow reading of McDonough unsupported by law. But contrary to the Government's contention, the test is not whether the true facts would compel the Court to remove a juror for cause, but rather whether a truthful response 'would have provided a valid basis for a challenge for cause.' United States v. Daugerdas, 867 F. Supp. 2d 445, 468 (S.D.N.Y. 2012) (ordering new trial for two of three defendants based on juror providing false answers during voir dire and concluding that the third defendant waived the new trial argument), vacated and remanded sub nom. United States v. Parse, 789 F.3d 83 (2d Cir. 2015) (reversing district court's waiver conclusion) (quoting McDonough, 464 U.S. at 556).
+
+"This means that 'the district court must determine if it would have granted the hypothetical challenge' if it had known the true facts." Id. (quoting Stewart, 433 F.3d at 304) (citing Greer, 285 F.3d at 171; United States v. Shaoul, 41 F.3d 811, 816 (2d Cir. 1994) (noting that under the second prong of McDonough. a defendant must have a basis for arguing that the district court is required to sustain his challenge for cause)). As in Daugerdas, and under any reading of McDonough, Juror No. 50's misconduct demonstrates that he was incapable of being an impartial juror and the Court would have struck him for cause. See id.
+
+The government's contrary arguments do not withstand scrutiny. Foremost, the government mischaracterizes Ms. Maxwell's argument and then attempts to shoot down the strawman. Ms. Maxwell does not argue that every person who has been a victim of sexual assault or sexual abuse was subject to a "mandatory" challenge for cause based on implied bias. Ms. Maxwell's argument is simply that Juror No. 50 was impliedly biased—an argument more than supported by the record, Juror No. 50's pattern and practice of telling falsehoods to the Court, and the statements of Juror No. 50 himself.
+
+Likewise, the government misunderstands Ms. Maxwell's argument about Juror No. 50's false claims regarding his social media accounts. (Put aside for the moment the government's implausible contention that on this score as well, Juror No. 50 didn't mislead the Court, and surely didn't do so deliberately.) Ms. Maxwell does not contend that Juror No. 50 would have been excluded for cause if he had admitted to being a Twitter user. The point is that Juror No. 50's false denial of being a Twitter user is part of his pattern and practice of giving false answers under oath during voir dire, in a (successful) attempt to serve as a juror. "The deliberateness of the particular lies evidence[] partiality." Greer, 285 F.3d at 173.
+
+The government fails to distinguish United States v. , 128 F.3d 38 (2d Cir. 1997). The government admits the case is analogous because the juror in engaged in conduct similar to that charged against the defendant, while here Juror No. 50 was the victim of conduct similar to that charged against Ms. Maxwell. The best the government can muster is to say that this Court has discretion—"ample discretion," says the government—to chart a different path here. But the government doesn't offer any mason why this Court's discretion should not be guided by the Second Circuit's reasoning in . And that's because there's no good reason to treat the two cases differently—indeed, for all the reasons given, the case for inferred bias here is stronger than in
+
+Finally, the government's argument here is directly contrary to the argument it made in opposition to the new trial motion in Daugerdas. In that case, the government argued that the defendants were not entitled to a new trial in part because the juror did not "conceal personal background material so analogous to the case on trial that bias was implied as a matter of law." Doc. 487, p 21, United States v. Daugerdas, No. 1:09-cr-00581-DLC, Sept. 9, 2011. In the government's words:
+
+[Those courts have granted a new trial or conducted a post-verdict evidentia hearing only when . . .1tUDIlowing the reasoning of Justice concurrence in v. 455 U.S. at 221, where the juror in question concealed personal background information so analogous to the case on trial that bias was implied as a matter of law. See Dyer v. Calderon, 151 F.3d 970, 975 (9th Cir. 1998) (juror in a murder trial concealed the fact that her brother had been murdered in manner similar to that alleged against defendant); Burton v. 948 F.2d 1150, 1154 (10th Cir. 1991) (implied bias found in case involving juror who suffered from domestic abuse similar to that of defendant, who was accused of killing her husband).
+
+Id. The government was right then about when a new trial is required—when, as here, the juror in question concealed personal background information so analogous to the case on trial that bias is implied as a matter of law—and it is wrong now.
+
+#### E. This Court should reject the government's attempt to manufacture a "Show Hearine.
+
+To read the government's brief, one would think this Court could hold a meaningful hearing at which it (and not the parties) would pose two softball questions of Juror No. 50: were your false answers to Questions 25 and 48 merely inadvertent; and, even though you were a victim of child sexual abuse, isn't it true that you were a fair and impartial juror (even though you have admitted using your own experience to convince 10 other jurors to convict Ms. Maxwell)? The government implies that an affirmative to either question would end the hearing. Not so.
+
+### 1. The lawyers should conduct the questioning.
+
+First, the parties should be permitted to question Juror No. 50, as occurred recently in this judicial district? United States v. Stewart, 433 F.3d 273, 306 (2d Cir. 2006) ("We therefore caution district courts that, if any significant doubt as to a juror's impartiality remains in the wake of objective evidence of false your dire responses, an evidentiary hearing generally should be held. Such a hearing is often the most reliable way for discerning the true motivations behind a juror's false replies.") (citations omitted).
+
+8 "[A] show trial can be defined by the presence of two elements. The first element is increased probability of the defendant's conviction resulting from the planning and control of the trial. The second element is a focus on the audience outside of the courtroom rather than on the accused—the extent to which the trial is designed or managed for the benefit of external observers rather than for securing justice for the defendant." Jeremy Peterson, Unpacking Show Trials: Situating the Trial of Saddam Hussein, 48 Harv. Int'l L.J. 257, 260 (2007); see also Purvis v. Oest, 614 F.3d 713, 718 (7th Cir. 2010) ("fundamentally biased process is not due process"); Schacht v. Wis. Dept of Corr., 175 F.3d 497, 503 (7th Cir. 1999) ("sham procedures do not satisfy due process").
+
+9 E.g., United States v. Daugerdas, Exhibit 3.
+
+At any hearing it is the Court's job to evaluate the evidence presented, not present the evidence. The evidence elicited should be the product of all available investigation and research. In Dyer v. Calderon, 151 F.3d 970, 976 (9th Cir. 1998), cited favorably by the government, Judge Kozinski explained the perils of a court conducting a juror bias inquiry with incomplete information or failing to ask critical questions. "[A] judge investigating juror bias must find facts, not make assumptions . [I]t was the trial court's obligation to develop the relevant facts on the record, not merely presume them. The judge's lack of verve in pursuing the matter casts doubt on his findings." Id. at 976-77. The Ninth Circuit en bane opinion also was critical of the trial judge's refusal to allow the defense to subpoena a critical witness of the bias. "Where juror misconduct or bias is credibly alleged, the trial judge cannot wait for defense counsel to spoon feed him every bit of information which would make out a case of juror bias; rather, the judge has an independent responsibility to satisfy himself that the allegation of bias is unfounded." Id. at 978.
+
+If the Court is charged with the responsibility questioning Juror No. 50, what resources will the Court use to uncover any statements and misstatements made by Juror No. 50? Will the Court investigate Juror No. 50's motives? Will the Court hire an investigator to find all of the posts made by Juror No. 50 about the trial? Having witnessed Juror No. 50 during the trial and having previously questioned Juror No. 50 -- both through a written questionnaire and in person - - under the government's farcical hearing the Court would be a (1) witness, (2) inquisitor, (3) factfinder and (4) sole decision maker. These multiple, conflicted, roles are no model of due process.
+
+### 2. The questioning should encompass any topic on which actual bias may be based.
+
+Moreover, the questioning should be significantly broader than proposed by the government. Although Ms. Maxwell need not prove Juror No. 50's intent, whether he acted deliberately is "is among the 'factors to be considered' in the ultimate determination of bias...." Greer, 285 F.3d at 173. An analysis of Juror No. 50's intent requires consideration of the totality of the circumstances. And if only because Juror No. 50 has a pattern and practice of giving false answers to the Court, Ms. Maxwell is not required to accept any post-hoc assertion by him that he did not act deliberately. Cf. United States v. James, 609 F.2d 36, 46 (2d Cir. 1979) ("[W]hen attempting to show bias or interest, as opposed to bad reputation, the examiner is not bound to accept the witness' answer, but is free to call additional witnesses for impeachment.").
+
+The government disingenuously suggests that the Court "need not inquire about the details of the victim's sexual abuse, just as the Court did not probe such details with respect to other jurors who answered Question 48 affirmatively." Resp. at 34 n.16. Apparently the government has forgotten that Question 48a itself (approved of by the government) asked for details of any affirmative answer to Question 48, and each of the other jurors who answered 48 in the affirmative provided those details in written form when they answered Question 48a. There was thus no need for the Court to inquire the details during the live voir dire. For example, the government points to Juror 189 and notes the Court only followed up with the question whether a question concerning ability to be fair and impartial. Resp. at 36. Yet Juror 189's answer to 48a contained the details of her alleged abuse
+
+. The same with Juror 239:
+
+[REDACTED].10 The government therefore wants Juror No. 50 to only now correctly answer Question 48 but not give the details as he would have had to do in Question 48a in the event he had correctly answered Question 48 at the time of *voir dire*. The government also misses the significant point that none of these other jurors disclosed childhood sexual abuse, the facts underlying the charges in this case.
+
+The government also mischaracterizes the record regarding questions to – and potential for cause challenges against –any juror who may have been incapable of accepting the testimony of Ms. Maxwell’s expert, Dr. Loftus. *See* Resp. at 35-36. The government first only points to the fact that none of the jurors who answered yes to Question 48 were asked about the expert testimony. That is because none of the others – like Juror No. 50 – claimed to have been the victim of *childhood sexual abuse*, i.e., the charges in *this* case. Why would anyone have asked whether a groping on the subway as an adult would be replayed like a videotape? Second, this Court inquired of many other potential jurors, including at the request of the government, whether they could put aside their outside knowledge and consider the expert testimony presented at trial. *See, e.g.*, Tr. 489-90, 527-28, 534-39, 666-67, 709-10. There is nothing to suggest that, had Juror No. 50 disclosed his beliefs about the science of memory as he publicly aired post-verdict in the media (that his own memory is like a video-tape), that the Court would not have followed up to inquire whether he could fairly evaluate expert testimony on that topic.
+
+[REDACTED]
+[REDACTED]
+[REDACTED]
+[REDACTED]
+[REDACTED]
+
+---
+
+10 The other jurors who also answered affirmatively to question 48 provided the details, as required by the questionnaire, to 48a. *See generally* Resp. at 4-5; [REDACTED]
+
+For all the reasons given in the motion, Rule of Evidence 606(b) poses no bar to the inquiry this Court should conduct on Ms. Maxwell's motion, primarily because Ms. Maxwell possesses evidence from external to the deliberations to substantiate Juror No. 50's bias. To the extent the Rule might apply as a bar to limit certain questions, it violates Ms. Maxwell's constitutional rights to due process and to confrontation as applied to her. U.S. Const. amends. V, VI; cf. Pena-Rodriguez v. Colorado, 137 S. Ct. 855 (2017) (finding the no-impeachment rule of 606(b) unconstitutional as applied to juror statements indicating racial bias). The Rules of Evidence cannot constitutionally prevent Ms. Maxwell from proving juror misconduct and vindicating her right to a fair and impartial jury."
+
+## 3. The Additional Biased Juror Should Be Questioned
+
+As detailed in the motion at 21, a second juror has alerted the New York Times that they too had deliberated on the case and were the victim of childhood sexual abuse. That juror whose identity is currently unknown also failed to disclose their victimhood in response to Question 48.12 The government would like to bury its head in the sand and deprive Ms. Maxwell of the
+
+■
+
+" See also Warger v. Shauers, 574 U.S. 40, 49 & n.3 (holding, before Pena-Rodriguez was decided, that Rule 606(b) bars inquiry to "deliberations evidence" when seeking a new trial based on juror false statements during voir dire but recognizing that "[t]here may be cases of juror bias so extreme that, almost by definition, the jury trial right has been abridged. If and when such a case arises, the Court can consider whether the usual safeguards are or are not sufficient to protect the integrity of the process. We need not consider the question, however, for those facts are not presented here.").
+
+Warger doesn't control here, though, if only because it was a civil and not a criminal case. Moreover, in this case, Juror No. 50's statements admitting to having provided false answers during voir dire are statements he personally made to the media and on social media. Those statements are not "deliberations evidence" and not subject to Rule 606(b) in any case, even under Warger.
+
+ability to establish that yet a second juror was biased by having been a victim of the very type of crime at issue in this trial. The cases relied on by the government are inapposite as none reach the issue of whether a juror was dishonest in response to voir dire questions regarding whether they had been the victim of the same type of crime at issue. See Resp. at 38-39. Importantly, the government cites only to cases where the only evidence that a juror had engaged in misconduct was a news article to that effect. Here, there are two pieces of evidence: one, the New York Times article, and two, Juror No. 50's media statement that a second juror disclosed that they were also a victim of childhood sexual abuse. Where there is "clear, strong, substantial and incontrovertible evidence" of juror misconduct, a hearing on that issue is required. United States v. Stewart, 433 F.3d 273, 302-03 (2d Cir. 2006).
+
+The government paints a parade of horrors to try to dissuade the Court from pursuing this second clear instance of a juror's inaccurate voir dire statement on a critical issue in this case. Resp. at 37. Yet simply asking the other 11 jurors one question, whether they were the victim of childhood sexual abuse is not the intrusion the government suggests; the juror apparently felt comfortable sharing that information both during deliberations and also to the New York Times.
+
+## 4. Ms. Maxwell is entitled to Discovery
+
+The government cites no authority for its request to foreclose discovery in advance of the hearing, nor could they given that such discovery is often necessary to establish the very misconduct at issue. The government's complaints center on their view that the requested discovery is either overbroad or violative of Rule 606(b). The government intentionally misreads the defendant's request. Obviously, Ms. Maxwell would be requesting communications that occurred outside of deliberations. It is also surprising that the government thinks that there will be a "high volume" of social media material during the "relevant time frame," i.e., between when Juror No. 50 stated he had closed all of his accounts (a week before trial) and his
+
+communications on Twitter and Instagram shortly after trial. Juror No. 50 deliberately misstated the date of his closing of his Twitter account and therefore Ms. Maxwell is entitled to discovery in order to prove that deliberate falsehood.
+
+### 5. Juror No. 50 is not entitled to discovery in advance of the hearing.
+
+Finally, for all the reasons given in the new trial motion and the letters about sealing, Ms. Maxwell maintains that Juror No. 50 should not be provided a copy of the questionnaire, which is currently under seal in this Court. Providing that questionnaire will only distort the search for the truth by allowing Juror No. 50 to further refine his story and excuses. Of course, if this Court orders a hearing, Juror No. 50 will receive his questionnaire at that time. But balanced against Ms. Maxwell's constitutional right to a fair and impartial jury and this Court's unflagging duty to investigate Ms. Maxwell's claim, Juror No. 50's request for the questionnaire now pales in comparison.
+
+## Conclusion
+
+Let there be no doubt. The prosecution's response is not credible because the government has the luxury of a double standard. If a juror had falsely answered material voir dire questions to favor Ms. Maxwell, the government would not hesitate to prosecute the juror for contempt or perjury. But when, as here, a juror falsely answers voir dire questions to favor the prosecution, the government invokes words like "finality" and "disfavor" and sighs, "well, no trial is perfect."
+
+But all trials, perfect or not, require a fair and impartial jury. That is non-negotiable. That is the premise and fundamental guarantee of the criminal justice system, a system that was undermined by Juror No. 50's misconduct.
+
+Juror No. 50 was not fair and impartial. His presence on the jury violated Ms. Maxwell's Sixth Amendment rights and constituted structural, reversible error. This Court should vacate the jury's verdict and order a new trial. In the alternative, this Court should hold an evidentiary hearing and examine all twelve jurors.
+
+Dated: February 9, 2022
+
+Respectfully submitted,
+
+s/ Jeffrey S. Pagliuca
+
+Jeffrey S. Pagliuca
+
+Laura A. Mennin er
+
+HADDON, & P.C.
+
+950 17th Street, Suite 1000
+
+Denver, CO 80202
+
+Phone: 303-831-7364
+
+Christian R. Everdell
+
+& GRESSER LLP
+
+800 Third Avenue
+
+New York, NY 10022
+
+Phone: 212-957-7600
+
+Bobbi C. Sternheim
+
+Law Offices of Bobbi C. Sternheim
+
+225 Broadway, Suite 715
+
+New York, NY 10007
+
+Phone: 212-243-1100
+
+Attorneys for Ghislaine Maxwell
+
+#### Certificate of Service
+
+I hereby certify that on February 9, 2022, I electronically filed the foregoing Ghislaine Maxwell's Reply in Support of Her Motion for a New Trial, with the Court and counsel for the government:
+
+Alison Moe Maurene Comey Andrew Rohrbach Lam Pomerantz U.S. Attorney's Office SDNY One Saint Andrew's Plaza New York, NY 10007 Alison.moe@usdoj.gov Maurene.comey@usdoj.gov Andrew.Rohrbach@usdoj.gov Lara.Pomerantz@usdoj.gov
+
+s/ Nicole
+
+
\ No newline at end of file
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+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x
+
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+UNITED STATES OF AMERICA,
+
+v.
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+Before:
+
+x
+
+20 CR 330 (AJN)
+
+New York, N.Y. March 8, 2022 10:15 a.m.
+
+HON. ALISON J. NATHAN,
+
+District Judge
+
+## APPEARANCES
+
+DAMIAN United States Attorney for the Southern District of New York ALISON MOE MAURENE COMEY ANDREW ROHRBACH LARA POMERANTZ Assistant United States Attorneys
+
+& GRESSER Attorneys for Defendant CHRISTIAN EVERDELL
+
+BOBBI C. STERNHEIM Attorney for Defendant
+
+SPODEK LAW GROUP Attorneys for Juror 50 TODD A. SPODEK
+
+4 5 6 MS. MOE: Good morning, your Honor, Alison Moe, Lara Pomerantz, Andrew Rohrbach and Maurene Comey for the government.
+
+7 THE COURT: Good morning, counsel.
+
+8 9 10 MS. STERNHEIM: Bobbi C. Sternheim and Christian Everdell for Ghislaine Maxwell, who is present at defense table.
+
+11 THE COURT: Good morning.
+
+12 13 And Mr. Spodek on behalf of Juror 50, please state your appearance.
+
+14 15 MR. SPODEK: Good morning, your Honor, Todd Spodek on behalf of Juror 50, who is present.
+
+16 17 18 THE COURT: Thank you. We're here today for a hearing on the defendant's motion for a new trial. The government has consented and to indeed requested this hearing as to Juror 50.
+
+19 20 21 22 My opinion and order dated February 24, 2022 ordered this hearing into Juror 50's responses to questions on the jury selection questionnaire. That opinion lays out the scope and nature of today's hearing.
+
+23 24 25 In addition to the motion for new trial briefing that I received from of the parties, I also received proposed questions from both sides which I have carefully considered in
+
+(Case called)
+
+DEPUTY CLERK: Counsel, please state your name for the record, starting with the government.
+
+4 5 preparing for today's hearing. In the submitted questions, the defense renewed the request that counsel be permitted to conduct the questioning. I am denying that renewed request. I will conduct this proceeding in accord with my February 24 opinion.
+
+6 7 8 Following my questioning, I will hear from counsel for the parties at sidebar as to any proposed follow-up questions that they wish be asked and I will consider those requests.
+
+9 In a moment, I will address counsel for Juror 50.
+
+10 11 Let me ask counsel for the parties if there are any preliminary matters.
+
+12 13 MS. MOE: Not from the government, your Honor, thank you.
+
+14 MS. STERNHEIM: No, thank you.
+
+15 16 THE COURT: All right. Juror 50 is present and represented by retained counsel, Mr. Spodek.
+
+17 18 19 Mr. Spodek, just as a preliminary matter, does your client wish that he be referred to here as Juror 50 rather than using his full name?
+
+20 MR. SPODEK: Yes, your Honor.
+
+21 22 23 THE COURT: And I understand, but again confirm for me that in post-verdict press interviews he did not reveal his last name, is that correct?
+
+24 MR. SPODEK: That's correct.
+
+25 THE COURT: I do intend to continue to refer to him as
+
+4 5 6 7 8 9 10 I received a letter dated March 1st, 2022 from Mr. Spodek. In that letter, Mr. Spodek, you informed me that Juror 50 would invoke his Fifth Amendment privilege against self-incrimination at this hearing. As you see from my February 24 opinion, Mr. Spodek, I am going to ask Juror 50 questions today about responses that he gave during the jury selection process in the case of United States v. Maxwell.
+
+11 12 Does it remain your client's intention to assert his Fifth Amendment privilege in response to those questions?
+
+13 MR. SPODEK: Yes, your Honor.
+
+14 15 THE COURT: I'm going to confirm on the record with your client, Mr. Spodek:
+
+16 17 18 Juror 50, is it your intention to assert your Fifth Amendment privilege in response to the questions I'm going to ask you today?
+
+19 JUROR 50: Yes, your Honor.
+
+20 21 THE COURT: All right. I received a written application from the government last night.
+
+22 23 Ms. Moe, could you confirm that the government is making the application?
+
+24 MS. MOE: Yes, your Honor.
+
+25 THE COURT: In accord with the application, I have
+
+Juror 50. In post-verdict press interviews he did not reveal his last name. Consistent with that and my juror anonymity order during trial, I will permit that to continue.
+
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+signed the proposed immunity order which will be docketed with Juror 50's name redacted.
+
+Juror 50, in view of your assertion of the Fifth Amendment privilege, I have signed an order granting you immunity. It is use immunity with respect to your testimony in this proceeding. That means that no testimony given by you or any information, directly or indirectly, derived from your testimony may be used against you in a federal criminal case, except if you testify falsely today you could be prosecuted for perjury. In light of this immunity, you will be required to answer questions today.
+
+So in other words, you need to answer my questions today. You need to answer truthfully. If you don't answer truthfully, you could be prosecuted for perjury. But you will not be prosecuted in federal court based on any truthful testimony that you give here today, even if that testimony indicated that you committed a crime.
+
+Juror 50, do you understand that?
+
+JUROR 50: Yes, your Honor.
+
+THE COURT: All right. I am going to have Juror 50 come forward to the witness stand, please.
+
+(Continued on next page)
+
+4 BY THE COURT:
+
+5 6 7 8 THE COURT: I'm going to approach with the court reporter and ask Juror 50 at the sidebar to state and spell his name for the record. His name will be redacted from the public transcript.
+
+9 (At sidebar)
+
+10 THE COURT: Please state your name for the record.
+
+11 THE WITNESS:
+
+12 (In open court)
+
+13 BY THE COURT:
+
+14 Q. With that, Juror 50, you are under oath.
+
+15 16 17 18 I will begin with some general instructions to you If at any point you don't understand something that I'm asking, please ask for clarification. Don't speculate as to the meaning of my question, ask for clarification.
+
+19 20 21 22 23 24 25 In responding to questions, I do instruct you not to tell me about the jury deliberations or your thought process during deliberations. I'm not asking questions about those and you should not provide that information in response to my questions. So listen to my specific questions, let me know if there's something you don't understand, do not respond with information about the jury's deliberations, and tell the truth.
+
+having been duly sworn, testified as follows:
+
+EXAMINATION
+
+If there is a response that is too difficult or embarrassing for you to share in open court, you may request to 4 5 speak at sidebar with me and counsel. However, if you have already shared the information publicly, including in media interviews, then I will not allow the sidebar.
+
+6 7 8 9 There's a binder in front of you. I have marked the document in there as Court Exhibit 1, so it's Court Exhibit 1 to the record for this hearing proceeding and you may open that.
+
+10 11 12 That is a copy of the questionnaire that you filled out on November 4, 2021. Please take a moment and look through it so that you're familiar with it and can identify it.
+
+13 A. Yes.
+
+14 15 16 Q. Do you recognize that as the questionnaire that you filled out on November 4, 2021, as part of the jury selection process in this case?
+
+17 A. Yes, your Honor.
+
+18 Q. I will ask you to turn to page 24 and look at question 48.
+
+19 20 21 22 23 24 That question reads: Have you or a friend or family member ever been the victim of sexual harassment, sexual abuse or sexual assault, and then in parenthesis, this includes actual or attempted assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher or family member. Do you see that question 48?
+
+25 A. Yes, your Honor.
+
+4 A. No, it is not.
+
+5 Q. What is an accurate answer to that question?
+
+6 A. Yes for self.
+
+7 8 Q. Okay. If you look at question 48A, that question says: If yes, without listing names, please explain.
+
+9 10 11 And when you filled out the questionnaire on November 4, 2021, you left that blank. What is an accurate answer to question 48A?
+
+12 A. I would have put I was abused as a child.
+
+13 Q. Without listing names, what happened?
+
+14 15 16 A. It was a family member, who is no longer a part of the family, and one of their friends when I was nine and ten years old.
+
+17 Q. Did this happen on one occasion or multiple occasions?
+
+18 A. Multiple occasions.
+
+19 Q. And did you tell anyone?
+
+20 A. I did not for several years until I was in high school.
+
+21 22 Q. And when you told someone in high school, did you tell authorities or adults or friends?
+
+23 Who did you tell?
+
+24 25 A. I told my mom and she called the police station and gave a report of the account and but never received any paperwork. So
+
+Q. On your questionnaire you indicated no as your answer. You checked the box for no. Is no an accurate answer to that question?
+
+I don't know if anything was actually filed or anything done.
+
+4 5 Again, without listing names, what was the nature of the familial relationship?
+
+6 A. A stepbrother.
+
+7 Q. You said stepbrother?
+
+8 A. Yes.
+
+9 10 11 12 Q. I'm going to ask you to look at question 48B. Question 48B reads: If your answer to 48 was yes, do you believe this would affect your ability to serve fairly and impartially as a juror in this case?
+
+13 14 When you filled this out on November 4, you left that blank. What is an accurate answer to 48B?
+
+15 16 A. It would have been no, because it did not affect my ability to be fair and impartial at all.
+
+17 18 19 Q. I'm going to ask you to turn to page 13 of the questionnaire. Question 25 reads: Have you or any of your relatives or close friends ever been a victim of a crime?
+
+20 21 And you checked no when you filled this out on November 4. Is no an accurate answer?
+
+22 A. Looking back at it now, no, it's an incorrect answer.
+
+23 Q. Who would have an accurate answer have been?
+
+24 A. It would have been yes.
+
+25 Q. Yes self, yes friend or family?
+
+There were no charges brought.
+
+Q. You said a family member, no longer a family member.
+
+A. Yes self.
+
+4 5 6 7 8 9 What I was thinking when I was completing that questionnaire was like if I was robbed or mugged or some sort of crime like that. I wasn't thinking of my sexual abuse as being a victim of a crime because I no longer associate being a victim. It's part of my healing process and it's how I dealt with the abuse.
+
+10 Q. Have you ever been robbed?
+
+11 A. Never.
+
+12 Q. Ever been mugged?
+
+13 A. Never.
+
+14 Q. Family or friends ever been robbed?
+
+15 A. No.
+
+16 Q. Or mugged?
+
+17 A. I don't know anybody that has ever been robbed or mugged.
+
+18 19 20 Q. Question 25A, asked: If yes, is there anything about the experience that would prevent you from acting as a fair and impartial juror in this case?
+
+21 You left that blank when you filled it out on
+
+22 November 4. What is an accurate answer to 25A?
+
+23 24 A. It would have been no. I was definitely able to set aside everything and be fair and impartial.
+
+25 Q. Okay. In light of the answer that you gave to 48A, I am
+
+Q. And when you say "yes self," what are you referring to?
+
+A. I'm referring to the sexual abuse.
+
+going to ask you to turn to question 49. It's on page 25.
+
+4 5 6 7 8 Question 49 reads: Have you or a friend or family member ever been accused of sexual harassment, sexual abuse or sexual assault, and then in parenthesis: This includes both formal accusations in a court or law or informal accusations in a social or work setting of actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher or family member.
+
+9 10 When you filled this out on November 4, you checked no. Is that an accurate answer?
+
+11 A. Yes, your Honor.
+
+12 13 14 15 Q. So the incident that you described in response to 48 in which, as I understand it, you informed your mother when you were in high school that when you were nine or ten a family member had engaged in sexual abuse with you, is that correct?
+
+16 A. Yes.
+
+17 Q. So why is that not responsive to question 49?
+
+18 19 20 A. Because I don't consider them part of my family. I never considered them part of my family even when they lived with us for a few years.
+
+21 22 23 24 Q. And when you filled out the questionnaire, when you got to this question were you thinking about what happened to you but you didn't respond yes because you didn't consider them a family member, or you didn't consider it?
+
+25 A. I didn't even consider it at all.
+
+4 5 6 A. I flew through this questionnaire. I never thought that I -- I honestly never thought I would be chosen to sit on this jury. We had to be at the courthouse super early, and I got here early and it took 45 minutes just to get through the security line. And we get ushered into a room --
+
+7 8 Q. I will come back and ask you some questions about the process for filling it out.
+
+9 A. Got it.
+
+10 11 Q. Just for the moment, just with respect to this question, tell me your thought process.
+
+12 13 14 15 16 17 18 19 20 A. At this point I was super distracted because I was sat right in front of the table, literally within four feet of that table where everybody was dropping off their questionnaires. People were asking questions, there was papers being ripped off the questionnaire packets, and there's a lot of talking going on, and it's super distracting. I'm like: I want to finish. So I just start going through and marking the questions as I'm like: Okay, okay. I didn't spend a whole lot of time thinking about it.
+
+21 Q. As you sit here now, what's the answer to question 49?
+
+22 23 24 A. It would have been -- it would have been yes, that a stepbrother was accused -- a stepbrother and his friend was accused of sexual abuse.
+
+25 Q. Okay. So a moment ago you said the answer would have been
+
+Q. Why is that?
+
+4 Q. But now you say yes because it would have been a stepbrother. Explain.
+
+5 6 7 8 A. Because by law, by marriage, that person was my stepbrother. So when you read the question that way and it says has a friend or family member ever been accused, then the correct answer would have been yes, a friend or family member.
+
+9 10 Q. Okay. And so the same response then for 48A is what you would have given for 49B?
+
+11 A. Yes, your Honor.
+
+12 13 14 Q. And 49B, if your answer to 49 was yes, do you believe this would affect your ability to serve fairly and impartially as a juror in this case?
+
+15 A. In no case. It would not affect me.
+
+16 17 Q. In responding a moment ago you said you never thought you would be chosen as a juror in this case. Why is that?
+
+18 19 20 21 22 23 24 25 A. Only because the sheer volume of people that were there. It was insane, the amount of people. So I just never thought -- number one, I didn't know what it was when I went into it, and then when they played the video of you, I just thought that the likelihood of being chosen, surely they will be interviewing thousands of people. And they ultimately choose twelve people to sit on a jury, and I never thought I would be one of those twelve.
+
+no because you didn't consider them family.
+
+A. Family, yeah.
+
+4 5 A. I did not hope to be on this jury. But again, like if you're going to serve jury duty, it might as well as be something that's interesting, but I did not set out in order to get on this jury.
+
+6 7 8 9 Q. Let me ask you to return to question 48A, page 24. You spoke to this a little bit but I want to make sure I understand the answer. You indicated that when you checked no, that was an inaccurate answer. Why did you check no?
+
+10 11 12 13 14 15 16 17 18 19 A. I didn't see the part where it says self, I just -- I completely skimmed way too fast. I was distracted by all the noise going on around me. And again, like I said, I just wanted to get done with this. It had been a long process, I had been sitting for hours, there were audiovisual problems getting your video to play, so we literally sat there for three hours. I didn't have a phone, I didn't have a book, I was sitting there twiddling my thumbs thinking about the break up that just happened a few weeks prior and sitting in my feelings and not very focused.
+
+20 Q. So tell me what you understood the question to be asking.
+
+21 A. I thought it was asking about family or a friend.
+
+22 Q. And the box that says yes for self?
+
+23 24 25 A. Right, I just missed it. Inadvertent mistake. This was one of the biggest mistakes I have ever made in my life, and if I could go back and change everything and have slowed down and
+
+Q. Did you hope that you would be?
+
+actually taken the time to read this appropriately, I would in a heartbeat.
+
+4 5 Q. There are other questions on the questionnaire that are structured with similar yes self, yes friend or family, or no. Do you recall seeing those questions?
+
+6 A. Only after I have reread this do I recall that.
+
+7 8 Q. So on none of the questions that included yes, parenthesis self, yes friend or family member, or no
+
+9 A. I did not pick up on that when I was filling this out.
+
+10 11 Q. Okay. When did you first learn that an answer to the questionnaire was inaccurate?
+
+12 13 A. When an article had come out about the article that I had given to Lucia through The Independent.
+
+14 15 Q. So you learned of an inaccurate answer in an article about an interview?
+
+16 A. Yes.
+
+17 Q. And what about during the interview?
+
+18 A. During the interview, no.
+
+19 20 Q. When did you first learn that the questionnaire may contain a question that asked about sexual abuse history?
+
+21 22 A. That was during my Daily Mail interview with the reporter Laura
+
+23 24 25 Q. So we're talking about your response to 48 which you have indicated was inaccurate. Did you in any way intentionally provide an inaccurate answer to this question?
+
+4 A. Absolutely not, your Honor.
+
+5 6 7 Q. Did your history of sexual abuse motivate you in any way to try to tailor your answers to make it more likely that you would be selected for this jury?
+
+8 A. Not at all, your Honor.
+
+9 10 11 Q. At the time you filled out the questionnaire on November 4, did it occur to you that you might personally benefit in any way from being on the jury in this case?
+
+12 A. Not at all, your Honor.
+
+13 14 15 16 Q. I'm going to return to question 25 again, which you have indicated was inaccurately responded to, and again you've discussed this, but I want to just hear directly in response to this question, why did you check no?
+
+17 18 19 20 21 22 23 24 25 A. Well, again, I wasn't thinking about abuse. I don't really think about my abuse really much anymore because it doesn't define me, it doesn't make me who I am today. It's something that happened, it's an experience that I lived through, and I have become the person I am today because of my goals and ambitions. And I do not feel that I am a victim of a crime, even though looking back on this abuse, that does make me a victim of a crime, which is why I should have marked yes for self.
+
+A. Absolutely not.
+
+Q. In responding to this question, did you answer no so as to make it more likely that you would be selected for the jury?
+
+4 5 Q. In responding to the question, did you answer no so as to make it more likely that you would be selected for the jury?
+
+6 A. No, your Honor.
+
+7 8 9 Q. Did your history of sexual abuse motivate you, again, to try to tailor this answer to make it more likely that you would be selected for the jury?
+
+10 A. No, your Honor, I wasn't even thinking about that.
+
+11 12 13 14 15 Q. I am going to return to the topic of the process for filling out the questionnaire, and you have spoken to that some and I will give you as much space as you want to respond. Just by background, you were summoned to appear for jury duty on the morning of November 4, is that correct?
+
+16 A. Yes, your Honor.
+
+17 18 Q. And when did you learn you would be filling out a questionnaire?
+
+19 A. When we got to the courtroom.
+
+20 21 Q. When did you learn the case for which you were being considered as a juror?
+
+22 A. Three hours after sitting in that chair.
+
+23 Q. And how long did it take you to fill out the questionnaire?
+
+24 25 A. It's a great question. I don't recall how long it took, but I want to say we were done by around noon or a little after
+
+Q. In any way did you intentionally provide an inaccurate answer to this question?
+
+A. Absolutely not, your Honor.
+
+noon.
+
+4 A. I felt rushed only because of all the commotion going on in front of me and everybody else just going by on both sides.
+
+5 Q. And how did that make you feel rushed?
+
+6 7 8 9 10 11 A. It made me -- growing up in school I never wanted to be the last one finished. You want to finish your test and go hang out with your friends. So it's kinds of that same policy, I just wanted -- everyone else is finishing and I'm like: Why am I still reading this? I'm like: I'm never going to get chosen, let's get this done with.
+
+12 13 Q. Would you say you approached the filling out of the questionnaire with diligence?
+
+14 A. Looking back on it now, no, your Honor.
+
+15 Q. Were you concerned with following my instructions?
+
+16 A. Absolutely not.
+
+17 Q. You were not concerned with following my instructions?
+
+18 19 A. No, I really -- this is a terrible excuse, but I didn't really think I would be chosen.
+
+20 21 Q. Some of the questions required follow up depending on whether a yes or no answer was provided. Do you recall that?
+
+22 A. Yes, your Honor.
+
+23 24 Q. And we'll take a quick look at two examples, question 9 on page 8, question 9 and 9A and question 10 and 10A.
+
+25 Question 9 asked whether your beliefs would make you
+
+Q. Were you rushed in any way?
+
+4 unable to render a verdict. You checked no. 9A said: If yes, please explain. You left that blank. So that question, if a yes response called for explanation, you didn't provide an explanation because you checked no.
+
+5 6 7 8 9 The next question 10 asked about principles of law and whether you would accept them if selected to serve on the jury, and you said yes. 10A said: If no, please explain. And you followed that instruction and didn't provide an explanation because you had said yes.
+
+10 11 You recall there were a number of questions that sometimes called for explanation and sometimes didn't?
+
+12 A. Yes, your Honor.
+
+13 Q. So how did you know whether to include follow-up answers?
+
+14 15 16 17 18 19 20 A. So these questions are in the beginning where I had more focus than I did at the end and less distractions, so it was easier to follow along, like these are the first few questions. It is a pretty thick packet, there's a binder of questions, so at this point I was still, I guess, in focus and in the zone and knew how to respond to these questions I guess accurately at this part.
+
+21 22 Q. Actually throughout the questionnaire you appeared to have followed the instructions with respect to follow-up questions.
+
+23 A. Right.
+
+24 25 Q. I reviewed a lot of questionnaires. Some people would provide follow-up when it wasn't called for or not provide 4 5 So how do you reconcile that with what you just testified to that you were distracted, raced through?
+
+6 7 8 9 10 11 A. Pretty simply, because you see your answer, you mark a no, then the next question says "if yes." Well, I marked no, so skip, go to the next question. So that's what I'm talking about when I flew through, I skimmed, I didn't read everything. So if I had just marked no and it says "if yes," immediately move on.
+
+12 13 14 15 16 Q. Just to return to 48 now, sorry to go back, first you told me it was a good question, how long it took you to fill it out, and then you said you couldn't remember. I want to go back. I think you said you were finished by noon. Do you remember what time you started the questionnaire?
+
+17 18 A. It had to be around 11-something. Again, I don't know, I --
+
+19 Q. I'm not sure that clock works.
+
+20 21 22 23 24 25 A. Yeah, I don't remember seeing -- obviously that clock is in the back and I was facing the front of the courtroom that we were in, so I wouldn't have even seen that clock. But I feel like the room we were in was much larger than this one, and I don't know what time I started. It definitely felt like we were there for hours before even seeing your video and then
+
+follow-up when it was called for. Your questionnaire seems to follow the instructions throughout. It appears generally that you read and followed the instructions within each question.
+
+4 A. Maybe. I think that would be accurate.
+
+5 6 7 8 Q. And to return to 48, so you just said it was pretty easy to, if yes, explain, if no, explain, so you skimmed through that. Looking again at 48, which has sort of a lot of space for the answer there, do you see that?
+
+9 A. Yes, your Honor.
+
+10 11 Q. And again, this is how many of the questions were structured: Check box yes self, yes friend or family, or no.
+
+12 13 Tell me again your thought process and how you understood the yes self, and yes friend or family.
+
+14 15 16 A. I just read the friend or family, again, like distracted, so I missed that "have you," and then "yes self" while reading this question.
+
+17 18 19 Q. At the time you were filling this out, were you surprised the questionnaire asked about friend and family but not about you?
+
+20 A. I didn't honestly think about it.
+
+21 22 23 24 Q. At the time you filled out the questionnaire, did you think that your history of sexual abuse would be something that the parties and I would want to know in order to determine if you could be fair and impartial?
+
+25 A. Looking back thinking now, yes, that's a question that
+
+given the questionnaire.
+
+Q. You say, if you had to estimate, an hour to fill out the questionnaire?
+
+would have been asked, but I honestly didn't think about it. I really don't think about my sexual abuse, period. I don't tell very many people.
+
+4 5 Q. After the trial you gave interviews in which you did tell people about your history of sexual abuse.
+
+6 A. Yes.
+
+7 Q. How do you reconcile what you just said with that?
+
+8 9 A. So I didn't -- this is going back to a deliberation thing, so I have to think about how to say this.
+
+10 Q. Well, I don't want you to talk about deliberations.
+
+11 A. Right.
+
+12 Q. If you can, you just said you don't talk about it, but
+
+13 14 15 16 17 A. I didn't talk about my abuse, I only said that -- I only used it in order to talk to a reporter about jury deliberations, I didn't use it in order to insert anything. I just gave that as to why I believe a certain way based on all the evidence that was provided during the trial.
+
+18 19 20 21 22 Q. I suppose that the question is: You were prepared for the public and you knew the public paid a lot of attention to this case, you were giving national and international media interviews, you were prepared for your history of sexual abuse to be widely known.
+
+23 24 25 A. Right, but not something -- I didn't think this would happen, like I didn't lie in order to get on this jury and then go to the press and tell them about my abuse. It just -- it's
+
+4 5 6 7 8 a little illogical thinking about it, like if I lied deliberately I wouldn't have told a soul. I certainly wouldn't have put myself in a position to where I could -- this position that I'm in now, potentially any sort of criminal charges, I just wouldn't have done it. It was an honest mistake and one of the biggest mistakes, and again, I apologize for wasting a lot of people's time and money, and this is never anything that I intended or did on purpose.
+
+9 10 11 12 13 14 Q. I understand your point, I still want to just make sure I understand as someone who is filling out the questionnaire and sort of walking through life and doesn't think about the history of sexual abuse and talk about it, at the same time you were prepared for the world to know about it. Tell me how to make sense of that.
+
+15 16 17 18 A. It was only how I view things and how I can recall memories, that's it. I didn't talk about my abuse, I just said I can remember things and recall things, like the color of the wall or --
+
+19 20 Q. Did you think about the fact that many people would learn from your interview that you had this history of sexual abuse?
+
+21 A. No, I did not.
+
+22 Q. You didn't think about that?
+
+23 24 A. No, I did not think that anybody -- certainly my family or friends would find this out.
+
+25 Q. Friends weren't following the news of the case after you
+
+4 5 6 7 A. I don't know if they were following the news of the case, but I have had some conversations about it with my friends afterward, but most people don't even know. It's not like -- I didn't know much about it either. Sexual abuse isn't a topic that I really want to research or learn about or watch about frequently.
+
+8 9 Q. You did understand from your interviews that the fact that you were abused would be a known fact in the world.
+
+10 A. Yes, your Honor.
+
+11 12 Q. And did you make a conscious decision that you were okay with that?
+
+13 14 15 16 17 A. Yes, your Honor. After sitting on this trial for several weeks and seeing the victims be brave enough to give their story, I felt like if they can do it, then so can I. I didn't have to divulge any of the details that happened to me, I focused on the memory aspect.
+
+18 19 20 21 22 Q. Okay. What I'm going to do now is I'm going to take us back in time to not November 4 but November 16, 2021. That's when I questioned you individually in that process that I suspect now you know is called voir dire. You recall that process?
+
+23 A. Yes, your Honor.
+
+24 25 Q. At that time I asked you some follow-up questions based on your responses to the questionnaire and some additional
+
+indicated you had been a juror on it?
+
+4 5 6 Q. So if you had filled out your questionnaire accurately as to 48 and 25 and 49, I would have asked additional questions that day. So what I'm going to do is ask you those questions now.
+
+7 A. Okay.
+
+8 9 10 Q. And I need you to answer honestly as to how you would have answered on November 16 if you had answered the questions 25, 48 and 49 accurately. Do you understand that?
+
+11 A. Yes, your Honor.
+
+12 13 14 15 16 Q. And again, I'm not asking for your thought process during deliberations or anything about jury deliberations, I'm asking you to go back to that time and if you had answered these questions accurately, how would you have responded to my follow ups. Okay?
+
+17 18 19 20 21 So at the time I asked you questions on November 16, and if you had answered the questions accurately, did you believe there was anything about your prior experience with sexual abuse that would affect your ability to be a fair and impartial juror?
+
+22 A. No, it would not affect me in any way.
+
+23 24 25 Q. At the time I asked you the questions, if you had answered the questions accurately, did you believe there was anything about your experience with sexual abuse that would have
+
+questions. Do you recall that?
+
+A. Yes, your Honor.
+
+4 A. Yeah. No, your Honor, I would be able to review the evidence based solely on the evidence.
+
+5 6 7 8 9 Q. Okay. At the time I asked you questions, and if you answered accurately, did you believe there's anything about your experience with prior sexual abuse that would interfere with your ability to assess the credibility of witnesses alleging sexual abuse?
+
+10 A. Absolutely in no way.
+
+11 12 13 Q. So at the time did you believe that you would be able to conclude that a witness alleging sexual abuse was not testifying truthfully if that was what the evidence suggested?
+
+14 A. Correct, your Honor, yes, I did.
+
+15 16 Q. At the time I asked you questions on November 16, did you harbor any bias against Ms. Maxwell?
+
+17 A. Not at all.
+
+18 19 Q. At the time I asked you questions on November 16, were with you biased in favor of the government or the prosecution?
+
+20 A. Not at all, your Honor.
+
+21 22 Q. Did you want to put your thumb on the scale in any direction?
+
+23 A. No.
+
+24 25 Q. At the time I asked you questions, and in light of your experience with sexual abuse, did you believe that the subject
+
+affected your ability to render a verdict based solely on the evidence presented at trial and my instructions as to the law? 4 5 Q. Would you be thinking about your own experience in a way that would prevent you from being fair or impartial?
+
+6 A. No, your Honor.
+
+7 8 9 10 11 Q. At the time I asked you questions on November 16, and in light of your experience with sexual abuse, did you believe that issues of reporting or not reporting sexual abuse that might be discussed at trial would interfere with your ability to be fair or impartial as a juror in the case?
+
+12 A. No, your Honor.
+
+13 14 15 16 Q. At the time I asked you questions on November 16, and if you had answered accurately and based on your experience with sexual abuse, did you have any doubt as to your ability to be fair to both sides?
+
+17 A. No, your Honor, no doubt.
+
+18 19 THE COURT: All right. I will meet with counsel at sidebar.
+
+20 (At sidebar)
+
+21 22 23 THE COURT: I will give you an opportunity to propose follow-up questions in light of his responses to questions of counsel.
+
+24 25 MS. MOE: Yes, your Honor, just one proposal. I believe the Court asked Juror 50 about the way in which he
+
+matter of the case would upset you in such a way that would distract you from your duty as a juror?
+
+A. No, your Honor.
+
+4
+
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+
+6
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+
+approached the questionnaire process, whether he took the Court's instructions seriously. We would just propose asking parallel questions about the questions he was asked in person, in particular because the juror was asked during voir dire similar questions about questions of bias for or against the government, impartiality. And so to clarify the record, whether he took answering those questions in person seriously and answered truthfully.
+
+MS. STERNHEIM: Could we have a moment?
+
+THE COURT: You may.
+
+(Pause)
+
+MR. EVERDELL: Your Honor, I think there was several areas of follow-up here that are warranted.
+
+First, the juror made some reference to his healing process. I couldn't quite understand what he said at the time, something about how he views himself as a victim or not as a victim of a crime. I think we need to understand his healing process and what he has gone through, because that affects his ability to be an impartial juror in a case involving sexual abuse. Is this something that he still is seeking treatment for? Is this something he is still thinking? How he deals with the healing process and how he thinks about himself as a victim affects how he views the victim witnesses in this case, and I think there ought to be more questions about that.
+
+THE COURT: What's the proposed question?
+
+4 5 6 7 8 MR. EVERDELL: What was -- we gave a number of those in our submissions, but: You talked publicly about the fact that you were in therapy, what was the nature of the therapy? Does it deal with your experiences as victim of sexual abuse? What was the healing process that you talked about? Describe this healing process for me. Does it involve addressing this issue of prior child sexual abuse? Were you in therapy during the trial? Is this an issue that you are still dealing with?
+
+9 10 11 12 13 THE COURT: I did review those questions proposed and I considered them. The defense did not propose any comparable questions for jurors during the voir dire process who indicated yes to this question and indicated a history of sexual abuse, so those requests are denied.
+
+14 Any other follow-up requests?
+
+15 16 17 18 19 20 21 22 23 MR. EVERDELL: Your Honor, I think we need to talk further about the nature of abuse. We talked about the fact this was repeated, happened multiple times. This happened with more than one person, a stepbrother and a friend. I think we need to understand because -- I'm not trying to pry, your Honor, I'm not trying to get into these gory details, but it is relevant, the extent of the similarities of this juror's abuse and whether that lines up with the testimony we heard from the victims is relevant in an inquiry to bias.
+
+24 25 And I think we need to understand a little more about similar questions that we asked -- we proposed to the Court in
+
+4 our follow up: How long did this go on? When did it stop? Were you home when this happened? What was the interaction between you and the abusers and family members? These are all things that go to the similarity.
+
+5 6 7 8 9 10 11 12 13 14 15 16 17 THE COURT: I have the same response. I considered those questions. We had, I think it was Juror 21 who had talked about familial abuse. The defense didn't propose any comparable follow-up questions. The questions went to the core questions of impartiality and fairness. The defense didn't request those questions and they didn't move to strike for cause. Here, there's dissimilarity of age; for example, younger than some of the proposed jurors, some of the inquired-into jurors who indicated yes, the defense didn't request follow up as to the specific similarities and the like, and I don't think I would have asked them because the bottom line questions are what is in issue. So that request is denied.
+
+18 Any other proposed follow up?
+
+19 MR. EVERDELL: Yes, I have a few more.
+
+20 21 22 23 24 MS. STERNHEIM: Judge, you have asked certain things about the questionnaire, but I do not believe that you asked about the summary of the case which specifically says what this case is about, it is about sexual abuse of a minor, and did he just fly through that as well?
+
+25 It is clear that this juror has supplemented --
+
+4 5 MS. STERNHEIM: I know your Honor did not want to get into what happened in the jury room, but a couple of --
+
+6 THE COURT: I'm not permitted to get into that.
+
+7 8 MS. STERNHEIM: You are permitted to discuss what he stated publicly, and publicly he said that he
+
+9 10 11 12 13 14 15 THE COURT: You misunderstand the law, or I do, but I have written an analysis of that issue in my opinion. That he revealed what happened in jury deliberations does not allow me to accept, as part of this hearing, evidence of what he said in jury deliberations. You may disagree with that legal analysis. I have written extensively about it in my February 24 opinion. I won't relitigate that now.
+
+16 17 MS. STERNHEIM: He did not tell very many people about it, then he told the world.
+
+18 19 20 THE COURT: Right. I pressed repeatedly on that issue. If you have a specific follow up that you would like me to ask --
+
+21 22 23 24 25 MR. EVERDELL: I do have some follow up. He said he didn't tell many people, but he also said he didn't think people would learn about his history of sexual abuse, despite the fact that he was telling reporters about that. We need to ask him, I think, about his post to where he says:
+
+THE COURT: Make your arguments in briefing afterwards, if you're doing that. I want specific proposed questions in light of responses.
+
+4 5 6 7 Thanks for telling my story. So if he says: I didn't expect the world to hear about my sexual abuse, yet at the same time he's telling , one of the victims in this case, post-trial, "Thanks for telling my story," that suggests to me that he wanted to be known as the victim of sexual abuse, he wanted to be seen as a champion of sexual abuse, and that this explanation that he is giving is simply false.
+
+8 9 There's also the Facebook post that he made after the fact --
+
+10 11 12 13 14 THE COURT: Just a moment. I will ask him to explain, to reconcile that if he can, that he said he didn't think people would know about it with the fact that he went on social media and thanked one of the witnesses in the case. I will ask about that.
+
+15 16 17 18 19 20 21 MR. EVERDELL: Your Honor, he said this is a verdict for all of the victims, which I think includes himself. How does he reconcile that comment with the fact that he didn't want to share with the world that he himself was a victim of sexual abuse, meaning: I'm doing this for the victims of sexual abuse. That's clear import of that comment. I think that's a conflict.
+
+22 23 24 25 There's also his Facebook posts after the fact where he says: I can now tell everybody that I was a juror on the Ghislaine Maxwell trial. What an incredible, surreal experience. Again, telling the world that I'm out here.
+
+4 5 6 7 MR. EVERDELL: I think we also need some follow-up questions that we proposed in our letter about his belief about victim memory, because I think that goes to his ability to evaluate the evidence fairly and impartially.
+
+8 THE COURT: I will deny that.
+
+9 10 11 12 13 14 15 16 17 MR. EVERDELL: I believe also he said in his answers that he didn't hope to be on the jury but if he is going to be on a jury, it might as well be something interesting. I'm paraphrasing, but that's the import of his comment. I think we need some follow up about what he meant by that comment. Why was it that he found this interesting? Was it some reflection of the fact that it involved victims of sexual abuse, and because he was the victim of sexual abuse himself that made it interesting for him?
+
+18 THE COURT: I will ask him what he meant.
+
+19 20 21 22 MS. STERNHEIM: Judge, I may have an issue. I thought the last question about following your instructions, I think he said no. And insofar as saying no, how did he not follow your instructions after he filled out the questionnaire?
+
+23 24 25 THE COURT: Okay. I will ask that question and then I will ask the government's question about whether he followed my instructions during voir dire.
+
+THE COURT: I will ask the question how does he reconcile the statement that he didn't think anyone would know with the fact that he was posting on social media.
+
+4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 MR. EVERDELL: Your Honor, I believe he mentioned something about his interview with the journalist Lucia, first name Lucia, and I was trying to follow his response, but he said something about: I didn't understand that this was an issue in the questionnaire. But I believe the reporting is that they discussed this at length, the consequences of him going public and the consequences of the fact that there was a jury questionnaire at issue here and there were answers to those questions that he would be talking about. I can't remember exactly what it is, but there was some discussion about the consequences of him going forward. And I believe what he said was: I didn't have any discussions or any lengthy discussions with the journalists about me coming forward and just answered their questions. But I believe there was a discussion with Lucia about the consequences, about whether he wants to do this, about -- I don't remember now --
+
+19 20 THE COURT: I don't understand what you're referring
+
+21 22 23 24 25 MR. EVERDELL: I think the issue is he was saying how he didn't expect to be public, he didn't expect to be known worldwide as a victim of sexual abuse, he didn't expect this come out, even though he's talking to journalists. My understanding is he had a discussion with Lucia, the journalist
+
+MS. MOE: Thank you, your Honor.
+
+THE COURT: And then I will --
+
+from The Independent, about the consequences of him coming forward, which is: This is a momentous decision you're making.
+
+4 5 6 So I don't see how he squares his comments about I never thought by talking to the press that I would come forward and be known this way, when in fact I think there was a lengthy discussion he had with a journalist about this very fact.
+
+7 8 THE COURT: He said that he recognized by talking to the press about it that it would be known publicly.
+
+9 10 11 12 13 14 15 16 17 18 19 MR. EVERDELL: I think he may have said that, but I think at the same time he's saying I didn't think this would be known by my parents and my friends. I don't know how you square those responses. To me -- and I know this was the subject of argument that you don't want to hear at this point, but his responses are simply not credible on this point because he's talking out of both sides of his mouth: I didn't think I would be known, but yet I did know I would be known. It makes no sense to me. I'm curious to hear more about what I perceive as blatant conflict in answers about a discussion with a journalist about the consequences of going forward.
+
+20 21 THE COURT: You want me to ask about what he discussed with which journalist?
+
+22 23 24 25 MR. EVERDELL: Lucia, who I believe is The Independent journalist. So I would -- I'm sorry it's not coming out very focused, I apologize, but: You had discussed before in responses to my questions about the fact that you didn't think
+
+4 5 6 7 8 9 10 11 12 that talking to a reporter would necessarily make you known to the world about -- your sexual abuse known to the world. If that wasn't something that truly entered your head, isn't it a fact that you spoke to Lucia, the reporter from The Independent that you spoke to, about the consequences that you might face in revealing all this stuff -- we won't get into jury deliberations -- about what you said to her about your sexual abuse and other things, there would be well-known consequences to what you were doing. How do you square those two thoughts in your head, which you didn't think it would be public, didn't think you would be known for this, and the journalist is telling you that very fact?
+
+13 14 15 16 17 18 19 20 21 22 MS. MOE: Your Honor, the government has no objection to limited follow-up questions about his understanding about whether it would become public. I do have concerns about the proposed question because it's confusing and a little cryptic. I don't know what the word "consequences" might mean in response to the question or what that's in particular driving at. I think, as the Court noted, he has already sort of explained his understanding about speaking publicly to a reporter and whether it would be publicly known that he was the victim of sexual abuse.
+
+23 24 25 There's also, I think, some tension between the Court's focused question about whether he understood it would become public that he was the victim of sexual abuse and
+
+4 5 6 7 8 THE COURT: I think what I will do is go back and ask: Did you understand at the time you talked to the press in the way that you did, did you understand that it would be publicly known that you were a victim of sexual abuse? We'll see what he says.
+
+9 10 11 Did you think about the consequences of talking to the press about that? Did you talk to the press, the press reporter about the consequences?
+
+12 13 14 15 16 17 18 19 20 21 22 23 It's difficult for me to see what it's going at, but I will seek clarification on his answers, as I did multiple times, on the reconciling and understanding his thinking about coming out publicly as a victim of sexual abuse. He has explained some of the transformation process and the like. You can make your arguments about credibility. But I will go back and see if there's something to ask regarding talking to the reporter about the consequences. Which also there's a temporal issue here, he didn't think about it until he talked to the press, and in the course of that the press talked to him about the consequences and that changed his understanding potentially.
+
+24 25 MS. MOE: Yes, your Honor. And I think yet a third point, talking about consequences today, I think Juror 50
+
+further questions about his understanding about sort of the magnitude of press coverage arising from the issue that gives rise to this hearing, which I believe he touched on as well.
+
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+rightly understands that question to be referring to whether he would understand he would be sitting in a courtroom like this.
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+THE COURT: I will go back and try to get an understanding of what he thought would happen when talking to the press regarding his own sexual history regarding it being publicly known that he was someone who suffered from sexual abuse.
+
+MS. STERNHEIM: During the interview he mentioned question 48, and he said: I recall being asking about friend and family, and she said "it also asked about you," he turned beet red, and she said: You're turning beet red. He said: The blood is rushing to my head.
+
+THE COURT: She actually said: You're not on the stand. You misquoted it in the papers.
+
+MR. EVERDELL: Not in the sun.
+
+THE COURT: You're not in the sun, she said, you're not on the stand, don't worry, but yes.
+
+MS. STERNHEIM: What was going through his mind when she mentioned that the question included you?
+
+THE COURT: I will ask that. He talked about the first time he learned that the questionnaire had the question.
+
+MS. STERNHEIM: And last thing is: What was his motivation in speaking to the press and being interviewed?
+
+THE COURT: Those questions, what motivated him after trial, is not relevant to what was going on during the filling a
+
+out of the questionnaire and responding to the voir dire. I would ask questions about that, and I have, but what motivated him to talk to the press is not relevant to the inquiry.
+
+All right. Anything else?
+
+MS. MOE: Not from the government, your Honor, thank you.
+
+(Continued on next page)
+
+4 BY THE COURT:
+
+5 6 Q. I asked you whether you approached filling out the questionnaire with diligence.
+
+7 Can you recall that?
+
+8 A. Yes, your Honor.
+
+9 10 11 Q. And you indicated no and you wish you had and that sort of thing. And I asked you whether you took my instructions carefully in the questionnaire.
+
+12 Do you remember that?
+
+13 A. Yes, your Honor.
+
+14 Q. And your answer is no? Is that accurate?
+
+15 A. Yes, your Honor.
+
+16 17 Q. And to make sure I understand, why is that? Why didn't you take my instructions carefully?
+
+18 19 20 21 A. It was definitely inadvertent. Again, like I said, I began to float, fly through it, in order to get done. I was super distracted, and it just -- I don't know what happened. I just wanted to get done with it.
+
+22 23 Q. When you came back on November 16 for the follow-up questions, there was another instruction video.
+
+24 Do you recall that?
+
+25 A. Yes, your Honor.
+
+(In open court)
+
+THE COURT: All right. I do have some additional questions, Juror 50.
+
+4 Q. Did you listen carefully to my questions?
+
+5 A. Yes, your Honor.
+
+6 7 Q. Do you have any doubt that you answered those questions accurately?
+
+8 A. I answered every single one of those questions accurately.
+
+9 10 Q. Might you have failed to pay attention to the specifics of the questions in any way?
+
+11 A. Not at all, your Honor.
+
+12 13 Q. And how do you know that, given how you approached the questionnaire?
+
+14 15 16 17 A. Because it was a different situation. I wasn't distracted. There weren't things going on. I wasn't sitting there for hours. It was multiple weeks later. So, again, I wasn't at that point, I wasn't thinking about my ex.
+
+18 Q. Would you say that you're distracted easily?
+
+19 20 21 A. I think I can become distracted, but it had no effect me serving in the jury, on the jury, and listening to all the evidence given during the trial.
+
+22 23 Q. And what was your approach to my instructions at various points?
+
+24 A. It was to follow them.
+
+25 Q. When you were testifying earlier -- and I asked you some
+
+Q. And when I asked you questions, those one-on-one questions, did you pay attention to the instructions at that time?
+
+A. Yes, your Honor.
+
+4 Do I have that right?
+
+5 A. Yes, your Honor.
+
+6 Q. And why didn't you think that?
+
+7 8 9 10 A. Well, I wasn't using my full name. I'm also not ashamed about it. It's something that happened, and it's something that is relatively common that happened to multiple people throughout the world.
+
+11 12 Q. And we talked about this, but you understood that there was a high level of press and public attention to the case.
+
+13 Correct?
+
+14 A. Yes, your Honor.
+
+15 16 17 Q. Help me reconcile that you didn't think friends and family would learn about your sexual abuse with the fact that you were speaking publicly about it.
+
+18 19 20 21 22 23 A. The one thing that I can point to is that when my friends commented, texted me -- commented on my post, texted me about it, they didn't even know that this trial was even happening. So I figured a little article about a juror giving their experience wouldn't be record-breaking or really in the news at all.
+
+24 Q. So you couldn't see how they would find out about it?
+
+25 A. Yes, your Honor. That wasn't something that I was
+
+questions about this -- you said that you didn't think that your family or friends would learn that you were a victim of sexual abuse, despite the press interviews.
+
+4 Q. And otherwise -- well, let me ask you: You were posting on social media about your role as a juror.
+
+5 A. After the trial, yes.
+
+6 7 Q. So wouldn't your friends and family find out in that regard?
+
+8 9 A. It just -- I just said that I had served on the jury. I didn't say anything about it in it.
+
+10 11 Q. There was a communication with one of the witnesses in the case, on social media?
+
+12 A. That's right.
+
+13 Q. And you thanked her for sharing your story.
+
+14 A. Yes.
+
+15 Q. What did you mean by that?
+
+16 17 18 19 A. She just shared the article, and then I commented on it; that thank you for sharing my story because she said that I was brave enough to come forward, and so I thanked her for sharing hers as well.
+
+20 Q. So your friends who followed you there would see that.
+
+21 22 23 24 A. I don't have any followers. I think I had like two followers, and they were random things. Twitter is not something I normally use. So I had just randomly seen that she'd shared that. So I felt like I wanted to comment.
+
+25 Q. You testified, when I asked whether you hoped you'd be on
+
+intentionally planning to hide; right? So if somebody were to ask me if I was abused, I would say yes.
+
+4 If you were going to serve jury duty, this would be --
+
+5 What did you mean you thought it would be interesting?
+
+6 7 8 A. So not everybody gets called for jury duty. Some people never get called in their entire lifetime. I figured if - what I mean by that is this is something interesting. It's not
+
+9 like -- I don't know. Maybe a fraud case might be boring. I
+
+10 11 don't know. I just felt like this might be something interesting that keeps my attention.
+
+12 13 Q. I asked you when you first learned that the questionnaire included a history-of-sexual-abuse question.
+
+14 Do you remember that?
+
+15 A. Yes, your Honor.
+
+16 Q. And you told me during a videoed interview.
+
+17 A. Yes, your Honor.
+
+18 Q. Correct.
+
+19 20 What was your reaction when you learned that the questionnaire contained that question?
+
+21 22 23 24 A. Well, she asked me. And I was, like, they don't ask about your own personal abuse because it's what I believed. It's what I thought. It's what I read. I didn't know I had made a huge mistake like that, and that's why I responded that way.
+
+25 Q. And how did you feel?
+
+the jury, and you had said that you didn't think you would.
+
+And I asked you why, and I asked you if you hoped you would.
+
+And you said, well, I thought it would be interesting.
+
+4 5 6 Q. I think at one point you said that you sort of didn't realize the extent to which your interviewing would kind of reverberate. I don't mean this process.
+
+7 8 9 But in terms of the public knowing that you had a history of sexual abuse, with any of the reporters you spoke to, did you talk through the consequences?
+
+10 A. No, your Honor.
+
+11 12 Q. And, again, I don't mean about this kind of process. But I just mean to speak about your history of sexual abuse.
+
+13 A. Correct. No, your Honor.
+
+14 THE COURT: I'll briefly meet with counsel.
+
+15 (At the sidebar)
+
+16 17 18 19 THE COURT: I want to make sure that I've accurately captured the follow-up questions that were requested and give you a final opportunity if you have any additional questions for followup.
+
+20 21 MS. POMERANTZ: Nothing further, your Honor. Thank you.
+
+22 23 24 25 MS. STERNHEIM: Judge, I had asked before if the Court could inquire about the summary of the case. He said he paid attention early on. He specifically said that the case was about sexual abuse.
+
+A. Well, number one, I was, like, did I just mess something up entirely? And I was embarrassed and sort of like shocked and didn't know that that was the full question.
+
+4 MS. STERNHEIM: Well, you had read that. So you knew what this case about, and that was in your mind when you were answering the questionnaire. For him to say that
+
+5 THE COURT: I don't want argument.
+
+6 What question do you want me to ask?
+
+7 8 MS. STERNHEIM: Did you read the summary of the case and understand that the subject matter of this case --
+
+9 10 11 THE COURT: Well, I won't summarize it. I'll read the whole thing and ask: "Did you understand that that was the subject matter of the case?"
+
+12 MS. STERNHEIM: Yes.
+
+13 14 MS. POMERANTZ: No objection, your Honor. Thank you. (In open court)
+
+15 BY THE COURT:
+
+16 17 18 Q. Returning to the questionnaire, it says, page 4. It's actually the second page of the questionnaire. There were documents that you took off when you filled it out.
+
+19 I provided a summary of the case.
+
+20 Do you recall that?
+
+21 A. Yes, your Honor.
+
+22 23 24 25 Q. The third paragraph down in that summary reads: "The charges of the indictment stem from allegations that from at least 1994 through 2004, the defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to
+
+THE COURT: I don't understand what the question is.
+
+4 5 And then the next paragraph lays out of the specific counts.
+
+6 Do you recall if you read that summary of the case?
+
+7 A. Yes, your Honor. I did.
+
+8 Q• So what did you understand the case to be about?
+
+9 A. Just that, just what was written there.
+
+10 11 Q. And in reading that, did that cause you to think about your history of sexual abuse?
+
+12 13 14 A. It did not. Again, it's something that I don't think about. It happened so long ago. Again, it's not part of who I am.
+
+15 THE COURT: All right. You may step down.
+
+16 (Witness excused)
+
+17 18 THE COURT: Counsel, let me ask your proposals as to some briefing, if necessary, post-trial briefing.
+
+19 Government?
+
+20 21 22 MS. MOE: Your Honor, the government would respectfully propose that the parties submit letter briefing promptly following the hearing within the next few days.
+
+23 24 25 If I could just have a moment to confer with my colleagues about a specific date. Our general proposal would be to have a short and tight briefing schedule to resolve the
+
+engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor."
+
+4 (Government counsel confer off the record)
+
+5 6 MS. MOE: Your Honor, the government would propose that we submit our letter briefing by Friday.
+
+7 I, Judge?
+
+8 9 THE COURT: Yes. I think your response on the other briefing is due on Friday.
+
+10 11 12 MS. STERNHEIM: And I am starting a trial, not that that is going to necessarily prolong our request. But I would ask for two weeks for us to submit our written submission.
+
+13 14 15 16 17 18 MS. MOE: Your Honor, the government respectfully submits that this issue has been prolonged in litigation. It has been briefed exhaustively. The only remaining issues are about Juror 50's testimony today and the inferences to be drawn, which is a very narrow and confined issue which can be resolved quickly and briefed quickly.
+
+19 20 MS. STERNHEIM: Your Honor, this is an incredibly important issue. We are not asking for --
+
+21 22 23 THE COURT: I know it's incredibly important, Ms. Sternheim. That doesn't alter the fact of what there is to do. But let me look at the calendar.
+
+24 What date does your trial start, Ms. Sternheim?
+
+25 MS. STERNHEIM: The 16th.
+
+issues from the hearing, but if I could just have one moment about a specific date.
+
+THE COURT: Okay.
+
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+THE COURT: is appropriate. For legal issues, and so All right. I think simultaneous briefing one, I have responsive briefing on the really what we're talking about is argument following based on today's record.
+
+One week from today, the 15th. Simultaneous briefing, I don't care if you call it letter briefing or otherwise. As you know, all I care is that it's double-spaced so I can read it on my iPad. Fifteen pages max per side.
+
+Anything else from the government?
+
+MS. POMERANTZ: No, your Honor. Thank you.
+
+MS. STERNHEIM: Your Honor, I would just request that our submission of questions which was sent to be made a part of this record.
+
+THE COURT: Yes. As I've said, I will docket everything. There's identifying information of Juror 50 in your submitted questions. So that needs to be redacted.
+
+But other than Juror 50 identifying information, the redactions for all materials, I believe, for all materials based on the post-trial briefing and the submitted questions can be publicly docketed.
+
+Is that correct? As well as my opinion had two lines of redactions. So I'll docket my opinion without redactions. I'll ask the parties to -- actually, I think we can handle the submitted questions, the redactions for identifying information.
+
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+The parties' briefing, I'll ask you to submit the briefs with redactions only for protecting juror privacy and juror identity.
+
+Any reason not to do that by tomorrow?
+
+MS. MOE: Yes, your Honor.
+
+THE COURT: By tomorrow?
+
+MS. STERNHEIM: Yes.
+
+THE COURT: Thank you.
+
+So that will put everything on the record. As for today's hearing, the only thing that's redacted is Juror 50's name. And that's redacted on the immunity materials, as well as Mr. Spodek's letter just indicated "Juror 50."
+
+Anything further, Ms. Sternheim?
+
+MS. STERNHEIM: Not at this time.
+
+THE COURT: Ms. Moe?
+
+MS. MOE: No, your Honor. Thank you.
+
+THE COURT: All right. We're adjourned.
+
+(Adjourned)
\ No newline at end of file
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AM
+
+USA / Plaintiff(s)
+
+case No.: 20 CR 330
+
+GHISLAINE MAXWELL,
+
+Defendant(s)
+
+## NOTICE OF FILING OF OFFICIAL TRANSCRIPT
+
+Notice is hereby given that an official transcript of a )NFERENCheld on has been filed by the court reporter/transcriber in the above-captioned matter.
+
+3/8/22
+
+Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media.
+
+The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days.
+
+This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion.
+
+I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter.
+
+Court Reporter/Transcriber Date
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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x
+
+S2 20 Cr. 330 (AJN)
+
+## REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER POST-TRIAL MOTIONS
+
+Christian R. Evade11 & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600
+
+Jeffrey S. Pagliuca Laura A. Mennin er HADDON, 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 P.C.
+
+Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100
+
+Attorneys for Ghislaine Maxwell
+
+#### TABLE OF CONTENTS
+
+| | Page |
+|--------------------------------------------------------------------------------|----------------------------------------------------------------------------|
+| I. The Court's Response to the Jury Note (Court Exhibit #I5) Was Erroneous and | |
+| Resulted in a Constructive Amendment/Variance. | 1 |
+| A. | The Jury Note Indicated that the Jury Misunderstood the Intent Requirement |
+| for Count Four | 3 |
+| B. The Court Erred When It Declined to Give the Jury a Supplemental | |
+| Instruction Clarifying the Intent Requirement for Count Four | 7 |
+| II. All Three Conspiracy Counts Are Multiplicitous Because They Are Based on a | |
+| Single Underlying Criminal Scheme. | 10 |
+| A. The Criminal Offenses Charged | 12 |
+| B. Overlap in Participants, Time, and Geographic Scope | 14 |
+| C. Common Overt Acts | 16 |
+| D. Similarity of Operation, Common Objectives, and Degree of | |
+| Interdependence | 17 |
+| III. The Court Should Grant Ms. Maxwell's Other Motions. | 18 |
+| CONCLUSION | 18 |
+
+## TABLE OF AUTHORITIES
+
+| | Page(s) |
+|--------------------------------------------------------------------------------------------------------|------------|
+| Cases | |
+| Bollenbach v. United States ,
326 U.S. 607 (1946)..... | 2 |
+| United States v. Broce ,
488 U.S. 563 (1989)..... | 11 |
+| United States v. Calderone ,
982 F.2d 42 (2d Cir. 1992)..... | 16, 17 |
+| United States v. Gross ,
No. 15-cr-769 (AJN), 2017 WL 4685111 (S.D.N.Y. Oct. 18, 2017) ..... | 2, 7, 8 |
+| United States v. [REDACTED],
7 F. App'x 45 (2d Cir. 2001) ..... | 12 |
+| United States v. Korfant ,
771 F.2d 660 (2d Cir. 1985) ( per curiam ) ..... | 11, 12, 13 |
+| United States v. Millstein ,
401 F.3d 53 (2d Cir. 2005)..... | 3, 8 |
+| United States v. [REDACTED],
903 F.2d 91 (2d Cir. 1990)..... | 2, 7 |
+| United States v. Reid ,
475 F. App'x 385 (2d Cir. 2012) ..... | 15 |
+| United States v. Sattar ,
314 F. Supp. 2d 279 (S.D.N.Y. 2004)..... | 11, 13 |
+| United States v. Villa ,
No. 12 Cr. 40 (JBA), 2014 WL 252013 (D. Conn. Jan. 22, 2014) ..... | 13 |
+| Statutes | |
+| 18 U.S.C. § 2422..... | 12 |
+| 18 U.S.C. § 2423(a) ..... | 12 |
+| New York Penal Law, Section 130.55..... | 8, 9 |
+
+## Other Authorities
+
+Ghislaine Maxwell respectfully submits this Reply Memorandum in Support of her Post-Trial Motions ("Motion" or "Mot.").
+
+#### I. The Court's Response to the Jury Note (Court Exhibit #15) Was Erroneous and Resulted in a Constructive AmendmentNariance.
+
+As the government states in its Opposition to Ms. Maxwell's Motion ("Opp."), the parties agree that the Act offenses for which Ms. Maxwell was convicted required the following proof of intent: that Ms. Maxwell "knowingly transported Jane with the intent that Jane engage in criminal sexual activity in New York" (Count Four) and that she "conspir[ed] to entice and transport minors in interstate commerce with the intent that they engage in criminal sexual activity in New York" (Counts One and Three). (Opp. at 6 (emphasis added)). Stated differently, the government agrees that if the jury found that Ms. Maxwell intended for Jane or the other victims of the Act conspiracies to engage in sexual activity in some place other than New York, such as New Mexico, that would not be sufficient, by itself, to convict Ms. Maxwell of the Act counts. (Opp. at 6-7 ("As the defendant correctly states ... `it was necessary to prove that [the defendant] enticed or caused underaged girls to travel to New York, or conspired to do the same, with the intent that they would engage in illegal sexual activity that violated New York law.'" (quoting Mot. at I ) (emphasis in original)).
+
+Similarly, the government does not dispute that, for purposes of a constructive amendment analysis, Ms. Maxwell's intent to have Jane or the other victims of the Act conspiracies engage in sexual activity within the state of New York that violated New York law was an "essential element" of Counts One, Three, and Four, and part of the "core of criminality" for those charges. (Opp. at 6 ("That is the core of criminality charged in the S2 Indictment, and it is what the Government proved at trial and the Court captured in its jury instructions.")). The only dispute is whether "the evidence or jury instructions at trial created a substantial likelihood
+
+that [Ms. Maxwell] was not convicted of the crime described in that core, but of a crime `distinctly different' from the one alleged." United States v. Gross, No. 15-cr-769 (AJN), 2017 WL 4685111, at \*21 (S.D.N.Y. Oct. 18, 2017). In other words, the dispute is whether there is a substantial likelihood that the jury convicted Ms. Maxwell on Counts One, Three, and Four without finding that she intended Jane and the other victims to engage in sexual activity in New York in violation of New York law, and instead convicted her of a "distinctly different" crime based on a finding that she intended the illegal sexual activity to occur in New Mexico.
+
+Based on a plain reading of the Jury Note (Court Exhibit #15), it is substantially likely that this is exactly what happened in this case. The government once again confidently states that there is "no likelihood" that this could have occurred because the government never argued this as a theory of guilt and the jury instructions required the jury to find that Ms. Maxwell intended to violate New York law. (Opp. at 10). But that argument misses the mark entirely. Regardless of what the government did or did not argue in its summation, or what the jury instructions did or did not say about the intent requirement for Count Four, the Jury Note laid bare that the jury was confused about that element and had the mistaken belief that if it found that Ms. Maxwell intended for Jane to engage in sexual activity in New Mexico, and the other elements of Count Four were satisfied, it could convict Ms. Maxwell on Count Four without finding that she intended Jane to engage in sexual activity in New York.
+
+At that point, it was incumbent on the Court to correct the jury's misunderstanding of an essential element of the offense with a supplemental instruction, as the defense requested. See Bollenbach v. United States, 326 U.S. 607, 612-13 (1946) (When "a jury makes explicit its difficulties [through a written inquiry,] a trial judge should clear them away with concrete accuracy"); United States v.=, 903 F.2d 91, 101 (2d Cir. 1990) (when a jury sends a note
+
+indicating that it is confused, lilt is the responsibility of the trial judge to provide the jury with sufficient instruction to enable it to assess the evidence within the proper legal framework and to reach a rational verdict"). The Court's decision not to do so and to refer the jurors to the existing jury instructions, which had caused the confusion in the first place, was erroneous and resulted in a constructive amendment and/or variance by permitting the jury to convict Ms. Maxwell on the
+
+Act counts based on an alternative theory of guilt not charged in the Indictment. See United States v. Millstein, 401 F.3d 53, 65 (2d Cir. 2005) ("When the trial evidence or the jury charge operates to broaden the possible bases for conviction from that which appeared in the indictment, the indictment has been constructively amended." (cleaned up)). Accordingly, the Court should vacate her convictions on Counts One, Three, and Four and grant a new trial.'
+
+#### A. The Jury Note Indicated that the Jury Misunderstood the Intent Requirement for Count Four.
+
+The Court erred when it concluded that that the Jury Note was "too difficult to parse" and declined to give the jury a supplemental instruction. (Tr. 3126-40). In fact, the text of the Jury Note is straightforward and indicates on its face that the jurors had an incorrect understanding of the intent requirement for Count Four that needed to be clarified with a supplemental instruction. The Note reads:
+
+Under Count Four (4), if the defendant aided in the transportation of Jane's return flight, but not the flight to New Mexico where/if the intent was for Jane to engage in sexual activity, can she be found guilty under the second element?
+
+(Court Exhibit #I5). Stated slightly differently, but using the same words that the jurors themselves used, the question posed by the Jury Note was the following:
+
+' The government contends that this argument is "better framed as a challenge to the Court's response to the jury note or a challenge to the jury instructions in the form of a constructive amendment argument." (Opp. at 20). It is not clear to the defense how these arguments differ in any material respect from the one we are advancing. For the sake of clarity, we are claiming that the Court's response to the Jury Note was erroneous and resulted in a constructive amendment/variance.
+
+Under the second element of Count Four, can the defendant be found guilty if the defendant's intent was for Jane to engage in sexual activity in New Mexico and if the defendant aided in the transportation of Jane's return flight from New Mexico, but not the flight to New Mexico?
+
+Hence, the question posed by the Jury Note contained two parts. The jury wanted to know if it was sufficient to satisfy the second element of Count Four if it found (I) that Ms. Maxwell's intent was for Jane to engage in sexual activity in New Mexico, and (2) that Ms. Maxwell assisted with Jane's return flight from New Mexico, but not her flight to New Mexico. That is the straightforward, common sense reading of the Jury Note.
+
+The answer to the first part of the jury's question is an unequivocal no. The jury instruction for the second element of Count Four charged that the government had to prove beyond a reasonable doubt that Ms. Maxwell "knowingly transported Jane in interstate commerce with an intent that Jane engage in sexual activity for which any person can be charged with a criminal offense in violation of New York law." (Instr. No. 21 (emphasis added)). It was therefore not sufficient to satisfy this element if the jury found that Ms. Maxwell intended for Jane to engage in sexual activity in New Mexico. Any sexual activity that occurred in New Mexico could not, by definition, be a violation of New York law.
+
+Accordingly, the Jury Note revealed that the jury had a fundamental misunderstanding of the intent requirement under Count Four. The jury needed to be given a supplemental instruction clarifying that to convict under Count Four, they needed to find that Ms. Maxwell intended for Jane to engage in sexual activity in New York and that any sexual activity that occurred in New Mexico, while it was potentially relevant evidence, could not have violated New York law. The Court's decision to simply refer the jury to the existing jury instruction for the second element of Count Four did nothing to cure the misunderstanding because the jury already had those instructions and was still evidently confused about the proof necessary to satisfy Count Four. As
+
+a result, there is a substantial likelihood that the jury convicted Ms. Maxwell on Count Four based on a constructive amendment of the crime charged in the Indictment.
+
+The government goes to great lengths to muddy the common sense reading of the Jury Note by focusing on peripheral or irrelevant issues, or by mischamcterizing the text of the Note, or even by inserting words, phrases, and punctuation that are not contained in the Note, in an effort to confuse and complicate the analysis. (Opp. at 15-17). This is nothing more than misdirection and should be rejected.
+
+For example, the government asserts that Jane's testimony concerning the New Mexico conduct was proper and relevant to the jury's consideration of the Act counts, and that the jury "could have convicted even if no sexual abuse occurred in New York, so long as it concluded that the defendant intended for abuse to occur in New York." (Opp. at 11-12 (emphasis in original)). The Court itself raised this same point in declining to give the jury the requested supplemental instruction. (Tr. 3149-50). Ms. Maxwell does not dispute either assertion. But that is not the issue raised by the Jury Note. In fact, the Jury Note makes clear that the jury was considering convicting Ms. Maxwell on Count Four without concluding that she intended for Jane to be abused in New York. The question posed in the Jury Note was whether Ms. Maxwell could "be found guilty" under the second element of Count Four (to use the jury's own words) if the jury found that Ms. Maxwell's intent was for Jane to engage in sexual activity in New Mexico. (Court Exhibit #15). In other words, the jury was asking whether they could convict Ms. Maxwell on Count Four based on that intent, and that intent alone. The answer to that question is no, and the jury should have been so instructed to prevent a constructive amendment.
+
+The government further argues that the Jury Note is ambiguous because it is not clear which flights it refers to or where the jury believed the sexual activity occurred. (Opp. at 15-16). The first point is irrelevant and the second is based on a disingenuous reading of the Jury Note. As to the flights, it is true that one of the jury's questions was whether it was sufficient to convict under Count Four if the jury found that Ms. Maxwell assisted with Jane's return trip from New Mexico, but not her flight to New Mexico. But the problem raised by the Jury Note had nothing to do with the specific flights the jury may have been referring to, or whether Jane was on those flights, or whether those flights may have gone to New York. The problem raised by the Jury Note related to the jury's other question about Ms. Maxwell's intent. The jury was asking whether they could convict on Count Four if they found that Ms. Maxwell's intent was for Jane to engage in sexual activity in New Mexico. That was the question that raised the potential for a constructive amendment. And contrary to the government's assertion, the Jury Note was crystal clear about where the jury believed the sexual activity occurred: New Mexico. See Court Exhibit #15 ("... the flight to New Mexico where/if the intent was for Jane to engage in sexual activity ..." (emphasis added)).2
+
+Finally, the government attempts to cast further doubt on the clear meaning of the Jury Note by altering its text. The government posits that the jury was asking whether Ms. Maxwell could be found guilty based "in pan" on sexual activity occurring in New Mexico. (Opp. at 16). That is simply not what the Jury Note says. The jury could have easily asked that very question: "Can Ms. Maxwell be found guilty on Count Four based in part on Jane's testimony about sexual abuse in New Mexico?" In fact, as the government points out, the jury had previously sent a
+
+2 We note that the government inserted a comma between "New Mexico" and "where/if," which does not exist in the Jury Note. Compare Opp. at 13 ("... New Mexico, where/if ...") with Court Exhibit #15 ("... New Mexico where/if ..."). The absence of a comma is significant to the analysis because it clarifies that the jury was focused on New Mexico as the place where Ms. Maxwell intended Jane to engage in sexual activity.
+
+note asking a similar question about testimony. See Court Exhibit # 9 ("Can we consider Annie's testimony as conspiracy to commit a crime in Counts One and Three?"). But the Jury Note did not say that, nor did it contain the phrase "in part." Instead, the Jury Note asked a much more specific question about whether the jury could convict Ms. Maxwell on Count Four if it found that she (I) intended for Jane to engage in sexual activity in New Mexico and (2) aided with Jane's return flight from New Mexico, but not her flight to New Mexico. The government's speculation about what the jury may have meant cannot alter the clear text and meaning of the Jury Note, which revealed that the jury fundamentally misunderstood the intent requirement necessary for Count Four and needed to be given a supplemental instruction to remedy the confusion.'
+
+## B. The Court Erred When It Declined to Give the Jury a Supplemental Instruction Clarifying the Intent Requirement for Count Four.
+
+The Court further erred when it declined to give the jury a supplemental instruction, as requested by the defense, clarifying the intent requirement for Count Four — namely, that the government had to prove that Ms. Maxwell intended for Jane to engage in sexual activity in New York. The Jury Note showed not only that the jury had a mistaken understanding of the law concerning intent, but also indicated that the jury might convict Ms. Maxwell on Count Four based an alternative theory of guilt not charged in the Indictment. At that point, it was the responsibility of the Court to give the jury a supplemental instruction "to enable it to assess the evidence within the proper legal framework and to reach a rational verdict" and to avoid a constructive amendment of the charges. , 903 F.2d at 101; see also Gross, 2017 WL
+
+I The government chides the defense for engaging in speculation about what the jury may have been thinking before sending the Jury Note. (Opp. 17-19). The defense engaged in that discussion to explain why the proof at trial may have led the jury to focus on Jane's testimony about the conduct in New Mexico with respect to Count Four. But the Court need not rely on that analysis. The Jury Note speaks for itself. The jury was focused on Jane's abuse in New Mexico and misunderstood the intent requirement necessary to convict under Count Four.
+
+4685111, at \*23 ("[T]he Second Circuit has emphasized the power of limiting instructions to prevent constructive amendment[.]" (emphasis in original)). By declining to provide a supplemental instruction, the Court created "a substantial likelihood" that Ms. Maxwell was convicted of crimes "distinctly different" from the ones alleged. Gross, 2017 WL 4685111, at \*21; see also Millstein, 401 F.3d at 65 ("When the trial evidence or the jury charge operates to broaden the possible bases for conviction from that which appeared in the indictment, the indictment has been constructively amended." (cleaned up)).
+
+The government argues that any confusion the jury may have had on the issue of intent was ameliorated by the Court's decision to refer the jury to the existing instruction on the second element of Count Four. (Opp. at 19). According to that instruction, the government had to prove that Ms. Maxwell intended "that Jane engage in sexual activity for which any person can be charged with a criminal offense in violation of New York law" and further specified that the relevant criminal offense was a violation of New York Penal Law, Section 130.55. (Instr. No. 21). The government contends that the jury could not have misunderstood the instruction because it did not mention New Mexico at all and only mentioned an intent to engage in sexual activity that violated New York law. (Opp. at 19-20).
+
+The government's confidence, however, is belied by the Jury Note, which indicates that the jury thought it could potentially convict Ms. Maxwell on Count Four if it found that she intended for Jane to engage in sexual activity in New Mexico. And it is not hard to see where this confusion came from. Although the jury instructions state that the jury needed to find that Ms. Maxwell intended "that Jane engage in sexual activity for which any person can be charged with a criminal offense in violation of New York law," nowhere in the jury instructions does it state that a violation of New York law, or specifically a violation of Section 130.55, must occur
+
+within the state of New York. (See Instr. No. 17, 19, 21). To lawyers, that may seem obvious because we are familiar with the concept of jurisdiction and understand the limited territorial reach of state criminal statutes. But to a juror who does not have legal training, it is not so obvious. Based on the jury instructions they had been given, the jury could have easily (but mistakenly) determined that the sexual abuse Jane described in New Mexico was "sexual activity for which any person can be charged with a criminal offense in violation of New York law," as long as it met all the elements of Section 130.55, even though all of the conduct took place in New Mexico. It follows, then, that the jury could have mistakenly believed that if they found that Ms. Maxwell intended for Jane to engage in sexual activity in New Mexico, as opposed to New York, that was sufficient to satisfy the second element of Count Four.
+
+Ultimately, it is not necessary to determine why the jury was confused on this point. The confusion was clear on the face of the Jury Note and needed to be corrected. The defense's proposed supplemental instruction would have clarified this very issue. It stated in relevant part:
+
+As to the second element of Count Four, you must determine whether the Government has proven beyond a reasonable doubt that the Defendant transported Jane with the intent that Jane would engage in sexual activity within the state of New York in violation of New York Penal Law 130.55.
+
+Dkt. 566 (emphasis added). The defense further explained that the instruction needed to be given because, according to the Jury Note, the jury did not understand that Count Four "requires an intent to violate New York law, and you can't violate this section of New York law in New Mexico." (Tr. 3154) (emphasis added). But the Court declined to give this instruction, even though neither the Court nor the government questioned its accuracy. (Tr. 3148-54).4 The
+
+' The Court disagreed with the appropriateness of the first paragraph of the defense's proposed instruction and questioned the accuracy of the third paragraph. But neither the Court nor the government challenged the accuracy of the second paragraph, which is quoted above. (Tr. 3148-54). Moreover, even if the Court disagreed with the entire text of the defense's proposed instruction, it was the Court's responsibility to give the jury an appropriate instruction that clarified the intent requirement and prevented a constructive amendment.Court's error was compounded by its earlier refusal to instruct the jury that Jane's sexual abuse in New Mexico could not be considered "illegal sexual activity" as charged in the Indictment because it was not a violation of New York law, as it had instructed with regard to Kate and testimony. (Tr. 2775-77). As a result, the jury instructions were insufficient to properly instruct the jury on the law and created a substantial likelihood that Ms. Maxwell was convicted of a crime other than the one alleged in the Indictment. Moreover, because the Act conspiracy counts (Counts One and Three) required an identical finding of intent, there is a substantial likelihood that the jury improperly convicted Ms. Maxwell on those counts based on the same conduct. Accordingly, the Court should vacate Ms. Maxwell's convictions on Counts One, Three, and Four, and grant a new trial on these counts.
II. All Three Conspiracy Counts Are Multiplicitous Because They Are Based on a Sinele Underlyine Criminal Scheme.
The government concedes in its Opposition that the Act conspiracies charged in Counts One and Three are so similar that they are multiplicitous, and that the Court should only enter judgment as to one of those two counts. (Opp. at 24) ("[T]he Government agrees that the Court should enter judgment on only one of the Act conspiracy counts, given the similarities between those counts."). The government maintains, however, that the sex trafficking conspiracy charged in Count Five is not multiplicitous and that the Court should enter judgment on Counts Three and Five because they "arose from different criminal schemes, involving different criminal conduct, different statutory predicates, and a different modus operandi." (Opp. at 24).
The government's attempt to separate and distinguish the conspiracies charged in Counts Three and Five is directly contrary to its theory of prosecution and the proof at trial, and flies in the face of the arguments the government made to the jury. The government never framed these
counts in the Indictment or in its arguments to the jury as two separate criminal agreements between Epstein and Ms. Maxwell to commit two separate crimes. To the contrary, the government's theory throughout the case was that Ms. Maxwell participated in a single criminal conspiracy with Epstein, which may have evolved slightly over time, but always maintained the same overarching objective, the same core participants, and the same method of operation throughout the entire time period alleged in the Indictment.
The government's arguments to the jury were consistent with the proof at trial, which established, at most, a single decade-long conspiracy between Epstein and Ms. Maxwell, not multiple independent conspiracies. See United States v. Sattar, 314 F. Supp. 2d 279, 307 (S.D.N.Y. 2004) ("A single agreement to commit several crimes constitutes one conspiracy," but "multiple agreements to commit separate crimes constitute multiple conspiracies" (quoting United States v. Brace, 488 U.S. 563, 570-71(1989)). Indeed, the government repeatedly emphasized to the jury the similarities of what occurred to the four accusers and the "common playbook" that Epstein and Ms. Maxwell used with each of them. (Tr. 2848) ("[Maxwell] ran the same playbook over and over and over again as she exploited young girls. The similarities between what happened to Jane and Annie and Carolyn and Kate are incredibly powerful evidence of the defendant's guilt").
The government's current position is a 180-degree about-face and is nothing more than an after-the-fact attempt to preserve as many counts of conviction as possible and avoid the consequences of its own charging theory. As we explained in our Motion and as discussed further below, under the governing multi-factor test established in United States v. Korfant, 771
F.2d 660, 662 (2d Cir. 1985) (per curiam), Count Three and Count Five are multiplicitous. The Court should therefore enter judgment only on Count Three.5
A. The Criminal Offenses Charged
The government argues that the differences between the offenses charged in Count Three and Count Five are fatal to the defense's multiplicity argument. Not so.6 Count Five is not a distinct conspiracy simply because it alleged a different statutory object than Count Three, as the government claims. (Opp. at 27). If that were the case, the government would never have conceded that Counts One and Three were multiplicitous because they, too, alleged different statutory objects. Count One alleged a conspiracy to violate the enticement statute (18 U.S.C. § 2422), while Count Three alleged a conspiracy to violate the transportation statute (18 U.S.C. § 2423(a)). (Ind. ¶¶ 11-12, 17-18). Moreover, each of these statutory objects has different elements. For example, enticement does not require actual travel in interstate commerce, whereas transportation does. (Compare Instr. 14 with Instr. 19). Enticement requires persuasion or inducement to travel, whereas transportation does not. (Id.) Transportation (in this case) requires that the defendant know that the individual transported was under the age of seventeen, whereas enticement does not. (Id.). These legal distinctions are no less significant than the distinctions between Count Three and Count Five that were highlighted by the government e.g., the age of consent was seventeen for Count Three and eighteen for Count Five, and Count
5 As discussed further below, the conspiracy charged in Count Five is a smaller subset of the larger conspiracy charged in Count Three. The Court should therefore enter judgment on Count Three.
6 The government suggests that the defense deliberately asked the Court to ignore this factor to avoid the Court's consideration of it. That is absolutely incorrect. The first Korfant factor, as set forth in the Korfant case itself, is "the criminal offenses charged in successive indictments." Korfant, 771 F.2d at 662 (emphasis added). Hence, it was not evident that this factor applied in cases where the multiplicitous counts were in the same indictment. The defense accepts that the Second Circuit has applied this factor in such cases and the Court may consider it here. See United States v. M, 7 F. App'x 45, 54-55 (2d Cir. 2001). But this factor is by no means fatal to the defense's multiplicity argument.
three required travel to New York whereas Count Five did not require interstate travel. (Opp. at 28). Yet the government still readily concedes that Counts One and Three are multiplicitous because the conduct underlying these counts is so similar. Count Five is no different.'
Indeed, it is evident from the way the government charged the S2 Indictment that the conduct charged in Count Five is part of the same conspiratorial agreement as the conduct charged in Counts One and Three. The Court will recall that Counts Five and Six, the sex trafficking counts, were added to the Indictment after the government located Carolyn and secured her as a witness. These counts are based primarily on her allegations of sexual abuse and are therefore limited to the time period from 2001-2004. But in superseding the Indictment, the government did not treat Carolyn's allegations as a separate conspiracy. Instead, the government recognized that the abuse she described was a continuation of the same conspiracy and fully incorporated her allegations into the existing Act conspiracies. For example, the govemment expanded the date range of Counts One and Three from 1994-1997 to 1994-2004 to include Carolyn's abuse and added an overt act to both counts alleging that Ms. Maxwell "invited [Carolyn] to travel from Florida to a place outside of Florida with Epstein." (Ind. ¶¶ I3e, I 9e). Consistent with this charging theory, the government argued to the jury that it could consider all of the evidence related to Carolyn as evidence of the Act conspiracies. (Tr. 2895) ("The first two conspiracy counts are from 1994 to 2004. Those counts are about Jane, Carolyn, and Annie." (emphasis added)).
The cases cited by the government arc not to the contrary. In United States v. Villa, No. 12 Cr. 40 (OSA), 2014 WL 252013 (D. Conn. Jan. 22, 2014), the District Court considered the nature of the offenses in holding that the relevant conspiracies were different but did not rely exclusively on that factor and instead based its decision on a thorough analysis of all of the Koorant factors. United States v. Satter, 314 F. Supp. 2d 279 (S.D.N.Y. 2004) is inapposite on this point because the relevant conspiracies were charged under two separate clauses of the general conspiracy statue and were therefore distinct conspiracies on their face, whereas the conspiracies in the Indictment in this case were all charged under the same clause.
The government's decision to add Counts Five and Six, which are based on the same conduct, did not suddenly convert Carolyn's abuse and the conduct she described in the Palm Beach residence from 2001-2004 into a separate, distinct conspiracy. In fact, the conduct in the 2000s that Carolyn described was no different than the conduct in the 1990s that Jane described. Like Carolyn, Jane testified that Epstein gave her money after almost every sexual encounter with him at this Palm Beach residence, which would support a sex trafficking charge. (Tr. 301- 02). Indeed, the government concedes that the only reason it did not expand Count Five to include Jane and abuse (as it had expanded Counts One and Three to include Carolyn's abuse) was that the sex trafficking statute was not enacted until after their abuse had occurred. (Opp. at 28). Had that legal impediment not existed, the government could have, and no doubt would have, broadened the date range of Count Five to 1994-2004, as it had done with Counts One and Three, and included overt acts related to Jane. Instead, the government included a more narrow sex trafficking count based primarily on Carolyn's allegations from 2001-2004, but still framed all of the charges in the Indictment as the product of a single, decade-long scheme between Epstein and Ms. Maxwell to "groom" and recruit minor girls to be sexually abused at Epstein's various residences from 1994 to 2004. (See Ind. ¶111-2, Overview Section). Accordingly, the offenses charged in the Indictment support a finding of multiplicity.
B. Overlap in Participants, lime, and Geographic Scope
The government makes a half-hearted attempt to deny the obvious overlap between Counts Three and Five in participants, time period, and geographic scope. (Opp. at 30-32). For example, the government argues that some "but importantly, not all" of the participants in the two conspiracies overlapped, and notes that who scheduled massage appointments for Epstein in Palm Beach, only appeared in the 2000s during the time period of the sex trafficking conspiracy. (Opp. at 30-31). But in the end, the government concedes, as it must,
that the core participants of the conspiracies—Epstein and Ms. Maxwell—were consistent throughout and that Carolyn was a victim of the conspiracies charged in both Count Three and Count Five. (Id.) The addition of as a co-conspirator towards the end of the conspiracy does not create multiple conspiracies. See United States v. Reid, 475 F. App'x 385, 387 (2d Cir. 2012) ("[C]hanges in membership do not necessarily convert a single conspiracy into multiple conspiracies, and there is no requirement that the same people be involved throughout the duration of the conspiracy." (cleaned up)).
The government also argues that although the time period of Count Five (2001-2004) was entirely contained within the time period of Count Three (1994-2004), there was no significant temporal overlap because "the gravamen of the offense conduct for Count Three occurred in the 1990s, while the offense conduct charged in Count Five took place in the 2000s." (Opp. at 31). That is non-sensical. Count Three charges a conspiracy lasting continuously from 1994-2004. Just because three of the witnesses testified about conduct in the 1990s and one of the witnesses testified about conduct in the 2000s, that does not mean that the 1990s conduct was somehow more important or more relevant to Count Three than the 2000s conduct. As charged, the conspiracy spanned the entire time period. Hence, the temporal overlap between Count Three and Count Five was not "minimal," as the government contends. (Opp. at 31). It was complete. The time period of Count Five was entirely contained within, and overlapped with, the time period of Count Three.
Finally, the government disingenuously argues that the geographic scope of the two conspiracies did not overlap because Count Three "was focused on travel to New York," whereas Count Five "largely concerned conduct that took place in Florida." (Opp. at 31-32). Here, the government is talking out of both sides of its mouth. The government argued
repeatedly, and the Court agreed, that evidence of travel to locations other than New York, and sexual abuse that occurred in those locations, was relevant to the Act conspiracies. As a result, the jury heard a great deal of testimony from Jane, Kate, and as well as other evidence, about conduct that took place in Epstein's residences in New Mexico, London, the U.S. Virgin Islands, and, of course, Florida. Indeed, a large portion of Jane's testimony, which was relevant to the Act conspiracies, described incidents of sexual abuse in Epstein's residence in Palm Beach that involved no interstate travel. (Tr. 298-315). Accordingly, the geographic scope of Count Five (Florida) was included within the geographic scope of Count Three.
Count Five did not describe a separate, independent conspiracy. Rather, it was a smaller subset of the broader overarching conspiracy charged in Count Three. Counts Three and Five are therefore multiplicitous. See United States v. Calderone, 982 F.2d 42, 47-48 (2d Cir. 1992) (finding two conspiracies were multiplicitous where, among other things, the time frame and geographic scope of one conspiracy was entirely contained within the other conspiracy and the core participants were the same); see also id. at 48 ("The Government cannot be permitted to retry defendants on smaller and smaller conspiracies, wholly contained within the scope of a large conspiracy, until it finds one small enough to be proved to the satisfaction of a jury.").
C. Common Overt Acts
The government argues that the lack of common overt acts between Count Three and Count Five indicates that they were different conspiracies. (Opp. at 30). As we explained in our initial Motion, because Count Five was based on Carolyn's allegations and did not involve Jane, Kate, or that count alleged overt acts specific to Carolyn that were not alleged in Count Three. (Mot. at 24; Ind. ¶¶ 25a-d, 19a-e). Nevertheless, because the conspiracy charged in Count Five was a subset of the conspiracy charged in Count Three, as discussed above, the
overt acts alleged in Count Five could easily have been alleged in Count Three because they were in furtherance of the same conspiracy. Hence, the differing overt acts do not indicate different conspiracies. See Calderone, 982 F.2d at 48 (finding two conspiracies were multiplicitous even though twenty-one overt acts listed in the second conspiracy were not listed in the first, because they were "all in furtherance of the broader conspiracy alleged in the first").
D. Similarity of Operation, Common Objectives, and Degree of Interdependence
Finally, the government argues that Counts Three and Five were different conspiracies because they were "fundamentally independent schemes, with different objectives and modes of operation." (Opp. at 32). In doing so, the government conveniently ignores the argument it made to the jury at trial — namely, that Jane, Kate, Carolyn, and were all victims of the same criminal plan to sexually exploit underaged girls, which Epstein and Ms. Maxwell carried out using the same methods throughout the entire course of the conspiracy. (Tr. 2848) ("[Maxwell] ran the same playbook over and over and over again as she exploited young girls. The similarities between what happened to Jane and Annie and Carolyn and Kate are incredibly powerful evidence of the defendant's guilt.").
The government attempts to side-step this obvious inconsistency by arguing that the conspiracy charged in Count Three involved "groom[ing] [victims] to travel to Epstein's properties for sexual abuse," whereas Count Five involved "paying victims for so-called 'massage appointments,' where they were sexually exploited." (Opp. at 32). But "grooming" and travel were not exclusive to Count Three. Carolyn testified about being progressively introduced to more serious sexual situations, which was a form of "grooming. (Tr. 1521-23, 1537). She also testified that Epstein and Ms. Maxwell asked her to travel to his island. (Tr. 1534-35). Similarly, payment and massages were not exclusive to Count Five. Jane testified
that Epstein gave her money after "almost every visit" to his home in Palm Beach. (Tr. 302).
And both Jane and testified about massages. (Tr. 308-11; 2083-86).
The government's attempt to characterize Count Three as an "earlier scheme" and Count Five as a "later pyramid scheme" with different objects and methods is unavailing. (Opp. at 32). The government's theory, as presented to the jury, was that Epstein and Ms. Maxwell engaged in a single conspiracy with a common method of operation and objective: to recruit and "groom" underage girls to sexually abuse them. That theory was entirely consistent with the evidence at trial. For these reasons, Counts Three and Five describe a single conspiracy, not multiple conspiracies, and are therefore multiplicitous. Accordingly, the Court should enter judgment only on Count Three.
III. The Court Should Grant Ms. Maxwell's Other Motions.
For the reasons already set forth in her initial Motion, the Court should vacate Ms. Maxwell's convictions as to all counts and dismiss the Indictment due to prejudicial preindictment delay. Further, the Court should enter a judgment of acquittal as to all counts under Rule 29 of the Federal Rules of Criminal Procedure because the government failed to prove each element of the charges beyond a reasonable doubt.
CONCLUSION
For the foregoing reasons, Ms. Maxwell respectfully requests that the Court, in the alternative, (1) vacate Ms. Maxwell's convictions on the Act counts (Counts One, Three, and Four) and grant a new trial under Rule 33 because the convictions were based on a constructive amendment and/or variance from the allegations in the Indictment, (2) enter judgment on only one of the three multiplicitous conspiracy counts — specifically, Count Three,
(3) vacate Ms. Maxwell's conviction on all counts and dismiss the S2 Indictment for preindictment delay, and (4) enter a judgment of acquittal as to all counts under Rule 29.
Dated: March 11, 2022 New York, New York
Respectfully submitted,
Is/ Christian R. Everdell
Christian R. Everdell & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600
Jeffrey S. Pagliuca Laura A. Mennin er HADDON, & 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 P.C.
Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
CERTIFICATE OF SERVICE
I hereby certify that on March 11, 2022, I served by ECF the within memorandum upon the following:
Maurene Comey, Esq. Maurene.Comey@usdoj.gov
Alison Moe, Esq. Alison.Moe@usdoj.gov
Lara Pomerantz, Esq. Lara.Pomerantz@usdoj.gov
Andrew Rohrbach, Esq. Andrew.Rohrbach@usdoj.gov
Is/ Christian R. Everdell
Christian R. Everdell
+