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1020 KB
Extraction Summary
8
People
2
Organizations
2
Locations
3
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
1020 KB
Summary
This document is a court transcript from February 15, 2012, detailing the cross-examination of a witness named Conrad, who was a juror in a previous trial. The questioning focuses on a letter Conrad wrote to another individual, Mr. Okula, in which she claimed she held out for two days to convict a defendant, David Parse. This is contrasted with a later statement she made to Judge Pauley, where she stated that Parse should not have been convicted on a particular charge, highlighting a significant contradiction in her accounts of the jury deliberations.
People (8)
| Name | Role | Context |
|---|---|---|
| Conrad | Witness |
The person being questioned throughout the transcript, referred to as Ms. Conrad by the court.
|
| Mr. Okula | Recipient of a letter / Attorney |
Person to whom the witness, Conrad, wrote a letter. Also appears to be an attorney making an objection.
|
| David Parse | Defendant |
A person mentioned in a letter written by Conrad, who was a juror in his trial. She wrote that she "solely held out f...
|
| Judge Pauley | Judge |
A judge to whom Conrad made a statement on December 20th, contradicting what she wrote in her letter about David Parse.
|
| Mr. Bharara |
Mentioned in a question to Conrad about whether she told Mr. Okula he was "on track to take Mr. Bharara's job from him."
|
|
| MR. GAIR | Attorney |
An attorney present in the courtroom who asks to respond to an objection and later asks the court to instruct the wit...
|
| Brubaker |
Mentioned in a quote from Conrad where she says she "convicted everybody except the stupid Brubaker."
|
|
| PAUL M. DAUGERDAS | Defendant |
Named in the case title, indicating he is a defendant in the case United States of America v. Paul M. Daugerdas, et al.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| UNITED STATES OF AMERICA | government agency |
The plaintiff in the case, listed in the document header.
|
| SOUTHERN DISTRICT REPORTERS | company |
The court reporting service that transcribed the proceedings, listed at the bottom of the page.
|
Timeline (3 events)
Locations (2)
| Location | Context |
|---|---|
|
An address mentioned in questioning about the letterhead Conrad used.
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|
|
An address mentioned in questioning about the letterhead Conrad used.
|
Relationships (3)
They likely served on the same jury. Conrad wrote a letter to Mr. Okula after the trial discussing the deliberations. The questioning suggests the tone of the letter may have been overly familiar or 'flirtatious'.
Conrad was a juror in David Parse's trial. She made contradictory statements about her desire to convict him, claiming in a letter she held out to convict him, but telling a judge he shouldn't have been convicted on one charge.
Conrad, a juror, spoke with Judge Pauley on December 20th after the trial to discuss the verdict concerning David Parse.
Key Quotes (3)
"I solely held out for two days on the conspiracy charge for him," referring to David Parse. "I wanted to convict 100 percent not only on that charge."Source
— Conrad
(A quote from a letter Conrad wrote to Mr. Okula, being read to her by the questioner during her testimony.)
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Quote #1
"in my mind Parse should not have been convicted of number 1"Source
— Conrad
(A statement Conrad made to Judge Pauley on December 20th, which contradicts what she wrote in her letter to Mr. Okula.)
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Quote #2
"For what? For what? I'll retain myself or my husband, the convicted felon. For what? For what, sir? To say that I convicted everybody except the stupid Brubaker? Parse was an idiot but we let him go because I had evidence enough that he really, he didn't really, in my mind he shouldn't have been convicted of number 1."Source
— Conrad
(A quote from Exhibit 3, page 16, which is a transcript of what Conrad said to Judge Pauley on December 20th.)
DOJ-OGR-00009942.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (4,843 characters)
Case 2:20-cr-00338-PAE-N Document 646-20 Filed 03/24/22 Page 140 of 767
A-5659
A-5659
February 15, 2012
UNITED STATES OF AMERICA, v
PAUL M. DAUGERDAS, ET AL.,
UNITED STATES OF AMERICA, v
PAUL M. DAUGERDAS, ET AL.,
C2FFDAU6 Conrad - direct Page 197
1 you put your cell number on your letter to Mr. Okula?
2 A. Because that's how I'm most accessible, sir.
3 Q. Because you wanted him to call you, didn't you, ma'am?
4 A. No, not at all.
5 Q. Well, then why did you care if you were most accessible
6 that way or not?
7 A. Just a heading I use. That's all.
8 Q. No, you just told us that you put that on that letter
9 because that's where you're most accessible.
10 A. That's true. But not with any forethought to an
11 expectation of a call from Mr. Okula.
12 Q. Why did you care whether you were accessible or not? Why
13 did you put a phone number on there?
14 A. Because that's usually what a heading has.
15 Q. And you made a conscious decision to put your phone number
16 on there, right?
17 A. Sir, this is minutiae. I don't know. I can't answer that.
18 Q. You were hoping to be accessible for a phone call from
19 Mr. Okula, correct?
20 A. Absolutely not.
21 Q. And would you agree with me that at times the tone of your
22 letter was playful?
23 A. Oh, sure.
24 Q. Maybe even flirtatious, right?
25 A. That's -- please. Judge.
1 you put your cell number on your letter to Mr. Okula?
2 A. Because that's how I'm most accessible, sir.
3 Q. Because you wanted him to call you, didn't you, ma'am?
4 A. No, not at all.
5 Q. Well, then why did you care if you were most accessible
6 that way or not?
7 A. Just a heading I use. That's all.
8 Q. No, you just told us that you put that on that letter
9 because that's where you're most accessible.
10 A. That's true. But not with any forethought to an
11 expectation of a call from Mr. Okula.
12 Q. Why did you care whether you were accessible or not? Why
13 did you put a phone number on there?
14 A. Because that's usually what a heading has.
15 Q. And you made a conscious decision to put your phone number
16 on there, right?
17 A. Sir, this is minutiae. I don't know. I can't answer that.
18 Q. You were hoping to be accessible for a phone call from
19 Mr. Okula, correct?
20 A. Absolutely not.
21 Q. And would you agree with me that at times the tone of your
22 letter was playful?
23 A. Oh, sure.
24 Q. Maybe even flirtatious, right?
25 A. That's -- please. Judge.
C2FFDAU6 Conrad - direct Page 198
1 THE COURT: You can answer the question.
2 A. Absolutely not.
3 Q. Did you tell Mr. Okula that something, words to the effect
4 that maybe he was on track to take Mr. Bharara's job from him?
5 A. Oh, yes.
6 Q. Now, did you hope that he would call you back, ma'am?
7 A. I'm not playing into this fantasy stuff. No, not at all.
8 Please.
9 Q. Did you feel, did you think about putting the phone number
10 that went with this address 16 Parkview Drive, did you think
11 about putting that phone number on the letterhead?
12 A. No.
13 Q. Did you think about putting your real address on the
14 letterhead?
15 A. That is my real address as well.
16 Q. Did you think about putting your Barker Avenue address on
17 the letterhead?
18 A. Sir, it was probably just cut and pasted from another
19 letter I had done. It wasn't conscious.
20 Q. Did you just make that up, just this moment, it was
21 probably cut and pasted from another letter? Did you just make
22 that up?
23 A. I'm answering your question, sir.
24 Q. No, I want to know if you just made that up or if you had
25 any reason to believe that you cut and pasted this from another
1 THE COURT: You can answer the question.
2 A. Absolutely not.
3 Q. Did you tell Mr. Okula that something, words to the effect
4 that maybe he was on track to take Mr. Bharara's job from him?
5 A. Oh, yes.
6 Q. Now, did you hope that he would call you back, ma'am?
7 A. I'm not playing into this fantasy stuff. No, not at all.
8 Please.
9 Q. Did you feel, did you think about putting the phone number
10 that went with this address 16 Parkview Drive, did you think
11 about putting that phone number on the letterhead?
12 A. No.
13 Q. Did you think about putting your real address on the
14 letterhead?
15 A. That is my real address as well.
16 Q. Did you think about putting your Barker Avenue address on
17 the letterhead?
18 A. Sir, it was probably just cut and pasted from another
19 letter I had done. It wasn't conscious.
20 Q. Did you just make that up, just this moment, it was
21 probably cut and pasted from another letter? Did you just make
22 that up?
23 A. I'm answering your question, sir.
24 Q. No, I want to know if you just made that up or if you had
25 any reason to believe that you cut and pasted this from another
C2FFDAU6 Conrad - direct Page 199
1 letter.
2 A. Yes, I probably did cut and paste it.
3 Q. What other letter?
4 A. I have no idea.
5 Q. Okay. Now, in this letter you told Mr. Okula, and I quote,
6 "I solely held out for two days on the conspiracy charge for
7 him," referring to David Parse. "I wanted to convict
8 100 percent not only on that charge." Do you remember that?
9 A. Yes.
10 Q. And you're sure about that, right? You wouldn't lie to
11 Mr. Okula, would you?
12 MR. OKULA: Judge, object on 606 grounds.
13 MR. GAIR: May I respond, your Honor?
14 THE COURT: No. Overruled.
15 Q. Did you tell Mr. Okula, "I solely held out for two days on
16 the conspiracy charge for Parse. I wanted to convict
17 100 percent not only on that charge." Did you tell him that?
18 A. You're reading it correctly.
19 Q. Did you tell Judge Pauley on December 20th that "in my mind
20 Parse should not have been convicted of number 1"?
21 A. Oh, I don't recall, sir.
22 Q. Well, let's look at Exhibit 3, page 16. Beginning at line
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
1 letter.
2 A. Yes, I probably did cut and paste it.
3 Q. What other letter?
4 A. I have no idea.
5 Q. Okay. Now, in this letter you told Mr. Okula, and I quote,
6 "I solely held out for two days on the conspiracy charge for
7 him," referring to David Parse. "I wanted to convict
8 100 percent not only on that charge." Do you remember that?
9 A. Yes.
10 Q. And you're sure about that, right? You wouldn't lie to
11 Mr. Okula, would you?
12 MR. OKULA: Judge, object on 606 grounds.
13 MR. GAIR: May I respond, your Honor?
14 THE COURT: No. Overruled.
15 Q. Did you tell Mr. Okula, "I solely held out for two days on
16 the conspiracy charge for Parse. I wanted to convict
17 100 percent not only on that charge." Did you tell him that?
18 A. You're reading it correctly.
19 Q. Did you tell Judge Pauley on December 20th that "in my mind
20 Parse should not have been convicted of number 1"?
21 A. Oh, I don't recall, sir.
22 Q. Well, let's look at Exhibit 3, page 16. Beginning at line
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 evidence enough that he
2 really, he didn't really, in my mind he shouldn't have been
3 convicted of number 1."
4 Did you say that to Judge Pauley on December 20th?
5 A. Yes, you're reading correctly.
6 Q. And that's a contradiction of what you said to Mr. Okula
7 the day after the trial, correct?
8 A. I wasn't the only holdout.
9 MR. GAIR: Your Honor, I'm going to ask that this
10 witness be instructed not to discuss the jury deliberations. I
11 didn't ask about them.
12 THE COURT: Please --
13 A. But in essence --
14 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.
18 THE COURT: And respond directly to counsel's
19 questions.
20 Q. Ma'am, isn't it true that the statement you made to Judge
21 Pauley on December 20th was directly contradictory to the
22 statement you made to Mr. Okula in his letter, in your letter
23 of May 25th?
24 A. I don't know.
25 Q. Well, is it contradictory to say that a person should have
1 idiot but we let him go because I had evidence enough that he
2 really, he didn't really, in my mind he shouldn't have been
3 convicted of number 1."
4 Did you say that to Judge Pauley on December 20th?
5 A. Yes, you're reading correctly.
6 Q. And that's a contradiction of what you said to Mr. Okula
7 the day after the trial, correct?
8 A. I wasn't the only holdout.
9 MR. GAIR: Your Honor, I'm going to ask that this
10 witness be instructed not to discuss the jury deliberations. I
11 didn't ask about them.
12 THE COURT: Please --
13 A. But in essence --
14 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.
18 THE COURT: And respond directly to counsel's
19 questions.
20 Q. Ma'am, isn't it true that the statement you made to Judge
21 Pauley on December 20th was directly contradictory to the
22 statement you made to Mr. Okula in his letter, in your letter
23 of May 25th?
24 A. I don't know.
25 Q. Well, is it contradictory to say that a person should have
Page 197 - Page 200 (50)
SOUTHERN DISTRICT REPORTERS
DOJ-OGR-00009942
SOUTHERN DISTRICT REPORTERS
DOJ-OGR-00009942
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