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Case 1:09-cr-00581-WHP Document 646-10 Filed 05/24/22 Page 47 of 67
A-5665

UNITED STATES OF AMERICA, v
PAUL M. DAUGERDAS, ET AL.,
February 15, 2012

[Page 221]
C2frdau7 Conrad - cross
1 MR. OKULA: Let me have one moment, your Honor.
2 Q. Ms. Conrad, a few more questions. I'm sorry. Are you
3 ready?
4 A. Yes.
5 Q. At the time that you were selected to serve as a juror in
6 this case, your status was a suspended New York attorney,
7 correct?
8 A. Yes.
9 Q. You were not working, correct?
10 A. Correct.
11 Q. Is it fair to say that even though the daily witness fee
12 that you received for your service was rather meager, it was
13 not irrelevant to you in your service as a juror?
14 A. Yes, that's correct.
15 Q. After all, you were basically out of work, correct?
16 A. Yes.
17 Q. You referred earlier during Mr. Gair's questioning to a
18 motivation that you had in the form of intellectual curiosity
19 with respect to tax shelters, is that correct?
20 MR. GAIR: Objection to the form of the question, your
21 Honor.
22 MR. OKULA: I'll rephrase it, your Honor.
23 THE COURT: All right.
24 Q. You remember in Judge Pauley's initial instructions he
25 described in general terms the subject matter of the case, in

[Page 222]
C2frdau7 Conrad - cross
1 particular tax charges, correct?
2 A. Yes.
3 Q. You heard certain things about tax shelters in the
4 introductory instructions, correct?
5 A. Vaguely.
6 Q. Is it correct that the subject matter of the case was of
7 some interest to you when you were answering questions during
8 voir dire and considering your motives for serving on the jury?
9 A. Yes, it piqued my curiosity. I had no experience ever with
10 tax work.
11 Q. Had you ever sat as a juror in a federal criminal case
12 before?
13 A. No.
14 Q. Was one of your motivations a desire to see a trial through
15 with this complexity from beginning to end?
16 A. Partially.
17 Q. One final question, Ms. Conrad. Is it correct that you
18 waited until Judge Pauley told you it was appropriate for you
19 to begin your deliberations and the consideration of the
20 evidence based on his instructions, and that's what guided your
21 verdict in this case?
22 A. Yes.
23 MR. OKULA: I have nothing further, Judge.
24 THE COURT: Redirect examination, Mr. Gair.
25 REDIRECT EXAMINATION

[Page 223]
C2frdau7 Conrad - redirect
1 BY MR. GAIR:
2 Q. Can you explain to us how it is you can remember the
3 substance of many specific jury instructions that you received
4 8 1/2 months ago when you cannot remember things that you said to
5 Judge Pauley on December 20th when you appeared in this court?
6 A. Because I'm familiar with the PJI and they are sort of
7 basically the same IN state court as in federal court.
8 Q. Did you have any trouble understanding my questions when I
9 was asking you questions earlier?
10 A. To which are you referring?
11 Q. Any of them.
12 A. I don't have the transcript written in my head.
13 Q. You certainly didn't have any trouble with Mr. Okula's
14 questions, correct?
15 A. He's pretty straightforward.
16 Q. You didn't find anything that Mr. Okula said that you
17 disagreed with, correct?
18 A. Correct.
19 Q. Did you know what Mr. Okula was going to ask you today?
20 A. No, I don't. This is the first time I've ever actually
21 spoken to Mr. Okula.
22 Q. Mr. Okula asked you about whether or not you wanted to see
23 through this trial as a juror. Do you remember that question?
24 A. Yes.
25 Q. You did, right?

[Page 224]
C2frdau7 Conrad - redirect
1 A. Yes.
2 Q. You did that in the context of just a day or two before the
3 trial having filed a petition for readmission or reinstatement
4 to the bar, is that correct?
5 A. That's the correct chronology, yes.
6 Q. You believed that by seeing through this trial, by serving
7 as a juror for a lengthy trial, you could help demonstrate your
8 stability to the bar authorities, correct?
9 A. No. It's apples and oranges. The two thoughts never
10 crossed.
11 Q. Never occurred to you once that seeing this through might
12 be something that would be helpful to you with the bar
13 authorities?
14 A. Not at all. It was my civic duty.
15 Q. Which part was your civic duty? The part where you lied?
16 A. No, of course not.
17 Q. Mr. Okula asked you some questions about the instructions
18 that Judge Pauley gave you. Do you remember those?
19 A. I remember both.
20 Q. You said that you had followed Judge Pauley's instructions,
21 correct?
22 A. Yes.
23 Q. But the truth is you only followed those of Judge Pauley's
24 instructions that you wanted to follow, correct?
25 A. I don't know what that question means, sir.

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