DOJ-OGR-00009943.jpg

955 KB

Extraction Summary

11
People
3
Organizations
1
Locations
2
Events
2
Relationships
5
Quotes

Document Information

Type: Court transcript
File Size: 955 KB
Summary

This document is a transcript excerpt from the trial 'United States v. Paul M. Daugerdas' dated February 15, 2012. It features the testimony of a witness named Conrad, who is questioned about a letter she wrote to Mr. Okula, her use of specific stamps, and her negative opinions of individuals named Brubaker and Parse (referring to them as 'idiot', 'stupid', and 'fricken crooks'). The witness also admits to having been suspended in the Southern District of New York. This document appears to have been filed as an exhibit in a later 2022 case (1:20-cv-00813), likely the US Virgin Islands v. JPMorgan Chase litigation regarding Jeffrey Epstein.

People (11)

Name Role Context
Conrad Witness
Undergoing direct and cross-examination regarding a letter, stamps, and opinions on other individuals.
Paul M. Daugerdas Defendant
Named in the case caption.
Mr. Okula Attorney
Raises objections; recipient of a letter discussed in testimony.
Mr. Gair Attorney
Questioning the witness (Conrad) about stamps and opinions.
Mr. Schectman Attorney
Begins Direct Examination of Ms. Conrad on page 204.
Mr. Rotert Attorney
Declines to inquire on behalf of Ms. Guerin.
Ms. Guerin Person of Interest/Client
Represented by Mr. Rotert.
Mr. Brubaker Subject of Inquiry
Witness questioned if she believed he was an 'idiot'.
Mr. Parse Subject of Inquiry
Witness questioned if she believed he was 'just stupid'.
Miss Davis Mentioned in Letter
Mentioned in a letter as doing an outstanding job.
Mr. Hernandez Mentioned in Letter
Mentioned in a letter as doing an outstanding job.

Organizations (3)

Name Type Context
Southern District of New York
Jurisdiction where the witness was suspended.
Southern District Reporters
Reporting agency listed in the footer.
DOJ
Department of Justice (referenced in bates stamp DOJ-OGR).

Timeline (2 events)

December 20th
Past event where witness allegedly called people 'fricken crooks'.
Unknown
February 15, 2012
Court proceedings in United States v. Paul M. Daugerdas.
Courtroom

Locations (1)

Location Context
Jurisdiction mentioned regarding witness suspension.

Relationships (2)

Conrad Professional/Adversarial Mr. Okula
Conrad wrote a letter to Okula; Okula is an attorney in the case.
Conrad Negative Opinion Mr. Parse
Conrad agreed she believed Parse was 'stupid' regarding backdating.

Key Quotes (5)

"Did you believe that Mr. Brubaker was an idiot? A. Yes."
Source
DOJ-OGR-00009943.jpg
Quote #1
"Did you believe Mr. Parse was just stupid? A. For the backdating, yes."
Source
DOJ-OGR-00009943.jpg
Quote #2
"because these people are fricken crooks and it doesn't matter?"
Source
DOJ-OGR-00009943.jpg
Quote #3
"I thought that you, Miss Davis and Mr. Hernandez did an outstanding job on behalf of our government."
Source
DOJ-OGR-00009943.jpg
Quote #4
"Were you suspended in the Southern District of New York? A. Sure. I must have been. Yes."
Source
DOJ-OGR-00009943.jpg
Quote #5

Full Extracted Text

Complete text extracted from the document (4,274 characters)

Case 1:20-cv-00813-DAB Document 146-20 Filed 03/21/22 Page 24 of 67
A-5660
UNITED STATES OF AMERICA, v
PAUL M. DAUGERDAS, ET AL.,
February 15, 2012
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.
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.
C2FFDAU6 Conrad - direct 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
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.
Mini-Script® SOUTHERN DISTRICT REPORTERS (51) Page 201 - Page 204
DOJ-OGR-00009943

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