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1010 KB

Extraction Summary

6
People
3
Organizations
1
Locations
5
Events
3
Relationships
5
Quotes

Document Information

Type: Legal document
File Size: 1010 KB
Summary

This document is a court transcript from February 15, 2012, containing the cross-examination of a juror named Conrad regarding her service in the trial of U.S. v. Daugerdas, et al. The questioning attorney probes Conrad's impartiality by referencing her past criminal record, her status as a suspended attorney, and a letter she wrote after the verdict. Conrad affirms that while she initially believed defendant David Parse was guilty, her final decision was based solely on Judge Pauley's legal instructions and was free from any bias.

People (6)

Name Role Context
Conrad Witness / Juror
The individual being cross-examined about her role as a juror, her past criminal record, and her impartiality.
PAUL M. DAUGERDAS Defendant
Named in the case title, UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL.
Mr. Gair Attorney
Mentioned as the attorney who was asking questions of the witness, Conrad, and referenced a letter she sent.
David Parse Defendant
A defendant in the case whom the juror, Conrad, initially believed should have been found guilty.
Judge Pauley Judge
The judge who provided legal instructions and a jury charge to the jury, which influenced Conrad's final decision.
Mr. Schectman Attorney
Mentioned as an attorney who also questioned Conrad about her past criminal cases.

Organizations (3)

Name Type Context
UNITED STATES OF AMERICA government agency
The plaintiff in the case against Paul M. Daugerdas, et al.
IRS government agency
Mentioned in the context of IRS agents, whom the juror Conrad did not know.
SOUTHERN DISTRICT REPORTERS company
Appears in the footer of the document, likely the court reporting service that transcribed the proceedings.

Timeline (5 events)

2012-02-15
Cross-examination of witness/juror Conrad.
Courtroom
The underlying trial in the case of UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL.
Courtroom
Jury deliberation where Conrad initially believed Mr. Parse was guilty but changed her mind after hearing the judge's instructions.
Jury room
Conrad other jurors
Conrad was arrested for several offenses including driving under the influence, harassment, contempt, shoplifting, and disorderly conduct.
Winslow, Arizona (for disorderly conduct)
Disciplinary proceedings against Conrad where lawyers made complaints about her.
Conrad disciplinary counsel lawyers

Locations (1)

Location Context
The location where Ms. Conrad was arrested for a disorderly conduct offense.

Relationships (3)

Conrad Juror-Defendant David Parse
Conrad served as a juror in a trial where David Parse was a defendant. She initially believed he was guilty but changed her mind after reviewing the judge's instructions.
Conrad Juror-Judge Judge Pauley
Conrad received and followed legal instructions from Judge Pauley during the trial, which she states formed the basis of her final conclusion in the case.
Mr. Gair Professional Conrad
Mr. Gair is an attorney who cross-examined Conrad about her conduct and impartiality as a juror. Conrad had also sent a letter to him after the verdict.

Key Quotes (5)

"Without getting into your deliberations with the other jurors, is it correct that as you said in the letter that you viewed initially during your, when you began deliberating, that Mr. Parse should have been found guilty?"
Source
— Questioning Attorney (The attorney is questioning Conrad about a letter she wrote, confirming her initial belief about a defendant's guilt during deliberations.)
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Quote #1
"So is it fair to say that when you personally deliberated with respect to Mr. Parse, you reached your conclusion based on the legal instruction that Judge Pauley gave you and without bias to any side. Fair?"
Source
— Questioning Attorney (The attorney is establishing that Conrad's final decision was based on the judge's instructions and not personal bias.)
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Quote #2
"100 percent. Correct."
Source
— Conrad (Conrad's response confirming that her verdict regarding Mr. Parse was based entirely on Judge Pauley's legal instructions and was without bias.)
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Quote #3
"Did the fact that you were a criminal defendant in a prior case affect you from fairly and impartially judging the evidence in this case and weighing and applying Judge Pauley's legal instruction?"
Source
— Questioning Attorney (The attorney is probing whether Conrad's own history as a criminal defendant created any bias in her role as a juror.)
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Quote #4
"Absolutely not."
Source
— Conrad (Conrad's firm denial that her past as a criminal defendant affected her ability to be an impartial juror.)
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Quote #5

Full Extracted Text

Complete text extracted from the document (4,894 characters)

Case 6:20-cr-00383-PGB-EJK Document 646-10 Filed 08/22/22 Page 454 of 767
A-5663
UNITED STATES OF AMERICA, v
PAUL M. DAUGERDAS, ET AL.,
February 15, 2012
C2FFDAU6 Conrad - cross Page 213
1 Q. before you started hearing any evidence, is that correct? In
2 other words, you hadn't prejudged the case after you were
3 selected that you were going to find the defendants guilty or
4 rule in favor of the government, is that correct?
5 A. That's correct, yes.
6 Q. And is it also true that you didn't make up your mind with
7 respect to the guilt or innocence of any of the defendants
8 until you heard all the evidence in the case and listened to
9 the judge's instructions, is that fair?
10 A. Absolutely.
11 Q. Let me pick up on a section where Mr. Gair was asking you
12 about things you said with respect to David Parse. Do you
13 remember those questions?
14 A. Yes.
15 Q. And Mr. Gair referenced the letter that you sent to me
16 after the return of the verdict, do you remember that?
17 A. Yes.
18 Q. And you were also asked questions about the fact that you
19 referred to fighting the good fight. Do you recall that?
20 A. Yes.
21 Q. Without getting into your deliberations with the other
22 jurors, is it correct that as you said in the letter that you
23 viewed initially during your, when you began deliberating, that
24 Mr. Parse should have been found guilty?
25 A. Yes.
C2FFDAU6 Conrad - cross Page 214
1 Q. And you also note in your letter, though, that you
2 ultimately relented after hearing a jury charge from Judge
3 Pauley about the definition of knowingly and willfully,
4 correct?
5 A. Yes.
6 Q. So is it fair to say that when you personally deliberated
7 with respect to Mr. Parse, you reached your conclusion based on
8 the legal instruction that Judge Pauley gave you and without
9 bias to any side. Fair?
10 A. 100 percent. Correct.
11 Q. Now, when you were selected to serve on the jury, did you
12 have any personal knowledge with respect to any of the
13 defendants in this case?
14 A. No, none.
15 Q. And is it also fair that you didn't have any personal
16 knowledge of any of the defense lawyers, correct?
17 A. Correct.
18 Q. You didn't know any of the prosecutors in the case or any
19 of the IRS agents, correct?
20 A. No. That's correct.
21 Q. And you weren't factually involved in any of the underlying
22 events at trial, correct?
23 A. Never.
24 Q. And did you have any financial motive in the outcome of the
25 case?
Conrad - cross Page 215
1 A. No.
2 Q. Now, Mr. Gair went through and Mr. Schectman did also to
3 some extent some of your criminal cases with you. Do you
4 remember that?
5 A. Yes.
6 Q. For instance, you went through your driving under the
7 influence offenses and your harassment offense, the contempt
8 offense and the shoplifting offenses. Do you remember that?
9 A. Yes.
10 Q. And were you also asked about the disorderly conduct
11 offense that you were arrested for that you didn't appear on in
12 Winslow, Arizona. Do you recall that?
13 A. Yes, sir.
14 Q. Now, none of those cases, Ms. Conrad, had anything to do
15 with the subject matter involved in this trial, correct?
16 A. That's correct.
17 Q. In other words, these offenses, those local offenses that
18 you were arrested for, none of them had anything to do with
19 taxes or tax evasion or tax shelters, is that fair?
20 A. That's correct.
21 Q. And is it also fair, Ms. Conrad, that your involvement in
22 those criminal cases did not cause you to be biased in one
23 matter or another against any party or any attorney in this
24 case?
25 A. That's correct.
Conrad - cross Page 216
1 Q. Now, let me ask you this, Ms. Conrad. Did the fact that
2 you were a criminal defendant in a prior case affect you from
3 fairly and impartially judging the evidence in this case and
4 weighing and applying Judge Pauley's legal instruction?
5 A. Absolutely not.
6 Q. Did the fact that you were arrested by a police officer on
7 a number of occasions in your criminal cases in any way affect
8 your ability to be fair and impartial?
9 A. No.
10 Q. Did your involvement in the disciplinary proceedings where
11 lawyers made complaints about you and you were asked questions
12 by disciplinary counsel, did that affect your ability to
13 fairly and appropriately and fairly weigh the evidence and
14 the legal instructions in this case?
15 A. No, not at all.
16 Q. Did the fact that you were a suspended attorney affect your
17 impartiality in this case?
18 A. No.
19 Q. Now, do you remember you received legal instructions from
20 Judge Pauley on a number of occasions during the case, both
21 during voir dire at the beginning of the trial and at the end
22 of the trial?
23 A. Yes.
24 Q. And in particular, do you remember a jury instruction that
25 went somewhat, I know it's a long time ago and you may not
Page 213 - Page 216 (54) SOUTHERN DISTRICT REPORTERS
DOJ-OGR-00009946

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