DOJ-OGR-00009264.jpg
951 KB
Extraction Summary
13
People
2
Organizations
2
Locations
3
Events
5
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
951 KB
Summary
This document is a court transcript from February 15, 2012, in the case of U.S. v. Paul M. Daugerdas. It captures the direct examination of a witness, Conrad, by attorneys Mr. Gair and Mr. Schectman. The questioning focuses intensely on a letter Conrad wrote to attorney Mr. Okula, specifically her choice of postage stamp and her decision to capitalize the words "our government," probing her motivations and opinions about other individuals involved in the case.
People (13)
| Name | Role | Context |
|---|---|---|
| PAUL M. DAUGERDAS | Defendant |
Named in the case title, UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL.
|
| Conrad | Witness |
The person being questioned throughout the transcript (also referred to as Ms. Conrad).
|
| MR. OKULA | Attorney |
An attorney present in court, making objections and being addressed by the court and other counsel. He is also the re...
|
| Judge | Judge |
Presiding over the court proceedings, referred to as 'THE COURT' and 'Judge'.
|
| Mr. Gair | Attorney |
An attorney questioning the witness, Conrad.
|
| Miss Davis |
Mentioned in a letter written by the witness: "I thought that you, Miss Davis and Mr. Hernandez did an outstanding jo...
|
|
| Mr. Hernandez |
Mentioned in a letter written by the witness: "I thought that you, Miss Davis and Mr. Hernandez did an outstanding jo...
|
|
| Mr. Brubaker |
Mentioned in a question to the witness: "Did you believe that Mr. Brubaker was an idiot?"
|
|
| Mr. Parse |
Mentioned in a question to the witness: "Did you believe Mr. Parse was just stupid?"
|
|
| MR. ROTERT | Defense Counsel |
Identified as a defense counsel who declines to question the witness.
|
| Ms. Guerin |
Mentioned by Mr. Rotert, who states he has "no inquiry for Ms. Guerin."
|
|
| MR. SCHECTMAN | Attorney |
An attorney who conducts a brief direct examination of the witness, Ms. Conrad.
|
| Ms. Conrad | Witness |
The witness being questioned, identified by Mr. Schectman.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| UNITED STATES OF AMERICA | government agency |
The plaintiff in the case title.
|
| SOUTHERN DISTRICT REPORTERS | company |
Listed at the bottom of page 204, likely the court reporting service.
|
Timeline (3 events)
Locations (2)
| Location | Context |
|---|---|
|
Mentioned as the location where the witness was suspended and previously testified at voir dire.
|
|
|
Mentioned in the context of the Southern District of New York.
|
Relationships (5)
Conrad is a witness being questioned by multiple attorneys, including Mr. Okula's colleague Mr. Schectman. Conrad also wrote a letter to Mr. Okula, which is a key piece of evidence being discussed.
Mr. Gair is an attorney conducting a cross-examination of the witness, Conrad, questioning her motives and credibility.
Mr. Schectman is an attorney conducting a direct examination of the witness, Conrad.
Mr. Okula
→
professional
→
Mr. Rotert
Both are identified as defense lawyers in the same proceeding.
Mr. Okula
→
professional
→
Mr. Schectman
Both are defense lawyers in the same proceeding.
Key Quotes (2)
"Sorry. You're going a little too far here, Mr. Gair."Source
— Conrad
(The witness's response when being questioned by Mr. Gair about the specific stamp she used on a letter.)
DOJ-OGR-00009264.jpg
Quote #1
"I thought that you, Miss Davis and Mr. Hernandez did an outstanding job on behalf of our government."Source
— Conrad
(A quote from a letter written by the witness, which is being read back to her during questioning.)
DOJ-OGR-00009264.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (4,259 characters)
Case 1:20-cr-00330-PAE Document 1616-1 Filed 02/24/22 Page 242 of 67
A-5660
UNITED STATES OF AMERICA, v
PAUL M. DAUGERDAS, ET AL.,
A-5660
UNITED STATES OF AMERICA, v
PAUL M. DAUGERDAS, ET AL.,
C2FFDAU6 Conrad - direct Page 201
1 been convicted of Count One and that a person should not have
2 been convicted of Count One? Do you see the contradiction
3 there?
4 MR. OKULA: Objection, Judge. Those are not the
5 facts.
6 THE COURT: Yes, sustained.
7 Q. Now, in the letter, in the letter you say -- by the way,
8 did you choose the stamp specially for this letter that you put
9 on?
10 A. What?
11 Q. Did you choose the stamp that you put on the letter
12 specially?
13 A. I don't know what you're talking about.
14 Q. Well, do you see the copy of the envelope?
15 A. That was, that was the eternity stamps or something like
16 that.
17 Q. Do you see --
18 A. Oh.
19 Q. Do you see what the stamp says?
20 A. Sorry. You're going a little too far here, Mr. Gair.
21 Q. I'm just asking you if you chose that stamp specially.
22 A. I'm sure I didn't.
23 Q. So you didn't have any other stamps, this was just one that
24 was laying around?
25 A. A book of stamps is a book of stamps, sir.
1 been convicted of Count One and that a person should not have
2 been convicted of Count One? Do you see the contradiction
3 there?
4 MR. OKULA: Objection, Judge. Those are not the
5 facts.
6 THE COURT: Yes, sustained.
7 Q. Now, in the letter, in the letter you say -- by the way,
8 did you choose the stamp specially for this letter that you put
9 on?
10 A. What?
11 Q. Did you choose the stamp that you put on the letter
12 specially?
13 A. I don't know what you're talking about.
14 Q. Well, do you see the copy of the envelope?
15 A. That was, that was the eternity stamps or something like
16 that.
17 Q. Do you see --
18 A. Oh.
19 Q. Do you see what the stamp says?
20 A. Sorry. You're going a little too far here, Mr. Gair.
21 Q. I'm just asking you if you chose that stamp specially.
22 A. I'm sure I didn't.
23 Q. So you didn't have any other stamps, this was just one that
24 was laying around?
25 A. A book of stamps is a book of stamps, sir.
C2FFDAU6 Conrad - direct Page 202
1 Q. Now, in the letter in the second paragraph, you say, "I
2 thought that you, Miss Davis and Mr. Hernandez did an
3 outstanding job on behalf of our government." Do you see that?
4 A. Yes, sir.
5 Q. Is there anything unusual that you see with your knowledge
6 of English literature in that sentence?
7 MR. OKULA: Objection to the form, your Honor.
8 A. I don't know what that means.
9 THE COURT: Overruled.
10 Q. Okay. Did you capitalize the word "our"?
11 A. Oh, yes.
12 Q. And did you capitalize the word "government"?
13 A. Yes.
14 Q. Is it your opinion that in that sentence "our government"
15 is a proper noun?
16 A. Government is.
17 Q. Is "our government" a proper known?
18 A. I don't know.
19 Q. You capitalized it not because you believed it was a proper
20 noun, but because you wanted to emphasize that you were talking
21 about his government and your government, correct?
22 A. You're slanting that. No.
23 Q. Well, I didn't use the word "our government" and I didn't
24 capitalize it. Why did you do it?
25 A. I don't know.
1 Q. Now, in the letter in the second paragraph, you say, "I
2 thought that you, Miss Davis and Mr. Hernandez did an
3 outstanding job on behalf of our government." Do you see that?
4 A. Yes, sir.
5 Q. Is there anything unusual that you see with your knowledge
6 of English literature in that sentence?
7 MR. OKULA: Objection to the form, your Honor.
8 A. I don't know what that means.
9 THE COURT: Overruled.
10 Q. Okay. Did you capitalize the word "our"?
11 A. Oh, yes.
12 Q. And did you capitalize the word "government"?
13 A. Yes.
14 Q. Is it your opinion that in that sentence "our government"
15 is a proper noun?
16 A. Government is.
17 Q. Is "our government" a proper known?
18 A. I don't know.
19 Q. You capitalized it not because you believed it was a proper
20 noun, but because you wanted to emphasize that you were talking
21 about his government and your government, correct?
22 A. You're slanting that. No.
23 Q. Well, I didn't use the word "our government" and I didn't
24 capitalize it. Why did you do it?
25 A. I don't know.
C2FFDAU6 Conrad - direct February 15, 2012 Page 203
1 Q. Did you believe that Mr. Brubaker was an idiot?
2 A. Yes.
3 Q. Did you believe Mr. Parse was just stupid?
4 A. For the backdating, yes.
5 Q. And do you believe that there's really no reason for this
6 hearing to be undertaken at all because these people are just
7 fricken crooks and it doesn't matter?
8 A. Is that a question?
9 Q. Yes, it is.
10 A. Well, the answer is no.
11 Q. Did you tell the Court that you thought this was all
12 ridiculous on December 20th because these people are fricken
13 crooks?
14 A. I'm not sure.
15 MR. GAIR: May I have a moment, your Honor?
16 THE COURT: Yes. Take your time.
17 Q. Were you suspended in the Southern District of New York?
18 A. Sure. I must have been. Yes.
19 Q. Did you know you were suspended in the Southern District of
20 New York when you testified at voir dire?
21 A. Yes. Yes.
22 MR. GAIR: Your Honor, I would move the admission of
23 several exhibits. PMD 1, 24, 25, 26 and 45.
24 MR. OKULA: No objection, your Honor.
25 THE COURT: All right. PMD Exhibits 1, 24, 25, 26 and
1 Q. Did you believe that Mr. Brubaker was an idiot?
2 A. Yes.
3 Q. Did you believe Mr. Parse was just stupid?
4 A. For the backdating, yes.
5 Q. And do you believe that there's really no reason for this
6 hearing to be undertaken at all because these people are just
7 fricken crooks and it doesn't matter?
8 A. Is that a question?
9 Q. Yes, it is.
10 A. Well, the answer is no.
11 Q. Did you tell the Court that you thought this was all
12 ridiculous on December 20th because these people are fricken
13 crooks?
14 A. I'm not sure.
15 MR. GAIR: May I have a moment, your Honor?
16 THE COURT: Yes. Take your time.
17 Q. Were you suspended in the Southern District of New York?
18 A. Sure. I must have been. Yes.
19 Q. Did you know you were suspended in the Southern District of
20 New York when you testified at voir dire?
21 A. Yes. Yes.
22 MR. GAIR: Your Honor, I would move the admission of
23 several exhibits. PMD 1, 24, 25, 26 and 45.
24 MR. OKULA: No objection, your Honor.
25 THE COURT: All right. PMD Exhibits 1, 24, 25, 26 and
C2FFDAU6 Conrad - direct Page 204
1 45 are received in evidence.
2 (Exhibits PMD 1, 24, 25, 26 and 45 received in
3 evidence)
4 MR. GAIR: Nothing further, your Honor. Thank you.
5 THE COURT: Mr. Okula.
6 MR. OKULA: I didn't know if there were any other
7 defense lawyers who intend to question.
8 THE COURT: Any other defense counsel wish to inquire?
9 MR. ROTERT: Thank you, your Honor, no inquiry for
10 Ms. Guerin.
11 THE COURT: Mr. Schectman?
12 MR. SCHECTMAN: Briefly, Judge.
13 THE COURT: Go ahead.
14 DIRECT EXAMINATION
15 BY MR. SCHECTMAN:
16 Q. Ms. Conrad, could you look at your letter to Mr. Okula
17 again, Government Exhibit 1, I believe.
18 A. Number 7, correct?
19 THE COURT: PMD 7.
20 Q. PMD 7. Do you have that?
21 A. Yes, sir.
22 Q. And I think your testimony was that as you sit here today
23 you don't recall why you capitalized "our government," is that
24 correct?
25 A. Yes.
1 45 are received in evidence.
2 (Exhibits PMD 1, 24, 25, 26 and 45 received in
3 evidence)
4 MR. GAIR: Nothing further, your Honor. Thank you.
5 THE COURT: Mr. Okula.
6 MR. OKULA: I didn't know if there were any other
7 defense lawyers who intend to question.
8 THE COURT: Any other defense counsel wish to inquire?
9 MR. ROTERT: Thank you, your Honor, no inquiry for
10 Ms. Guerin.
11 THE COURT: Mr. Schectman?
12 MR. SCHECTMAN: Briefly, Judge.
13 THE COURT: Go ahead.
14 DIRECT EXAMINATION
15 BY MR. SCHECTMAN:
16 Q. Ms. Conrad, could you look at your letter to Mr. Okula
17 again, Government Exhibit 1, I believe.
18 A. Number 7, correct?
19 THE COURT: PMD 7.
20 Q. PMD 7. Do you have that?
21 A. Yes, sir.
22 Q. And I think your testimony was that as you sit here today
23 you don't recall why you capitalized "our government," is that
24 correct?
25 A. Yes.
(51) Page 201 - Page 204
SOUTHERN DISTRICT REPORTERS
DOJ-OGR-00009264
SOUTHERN DISTRICT REPORTERS
DOJ-OGR-00009264
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