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Case 1:20-cr-00330-PAE Document 616-1 Filed 02/04/22 Page 27 of 67
A-5645

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

[Page 141]
C2FFDAU4 Conrad - direct
1 A. Exactly. Yes. And that's what we did.
2 Q. So you knew from the outset of this trial that there was a
3 connection between speaking the truth on voir dire and
4 ferreting out jurors who might have biases, didn't you, then?
5 MR. OKULA: Objection, your Honor.
6 THE COURT: Overruled.
7 A. Can you please repeat that?
8 Q. You understood based on what Judge Pauley told you in voir
9 dire that there was a connection between speaking the truth in
10 answer to what you were being asked and the ability of the
11 Court to ferret out biases or other things that might make a
12 juror unsuitable?
13 A. Yes, there is a nexus.
14 Q. There is a nexus?
15 A. Mm-hmm.
16 Q. And yet you deliberately decided to defy the Court, isn't
17 that correct?
18 A. If you want to mischaracterize it like that.
19 Q. I don't want to mischaracterize anything. I want you to
20 tell me whether you deliberately decided to mislead the Court
21 here.
22 A. I did not reveal that I was an attorney.
23 Q. That was not my question, ma'am.
24 A. Then please rephrase it.
25 Q. Did you make a deliberate decision to lie to this Court?

[Page 142]
C2FFDAU4 Conrad - direct
1 A. I did omit the fact that I had a JD.
2 Q. Was that the only fact you omitted?
3 A. No.
4 Q. We're going to come back to that, but right now I'd like to
5 try to get an answer to my question. Did you make the
6 deliberate decision I'm going to lie to the Court?
7 A. Not at first.
8 Q. Not at first.
9 A. I --
10 Q. When did you make the deliberate decision that you were
11 going to lie to the Court?
12 A. It was omission.
13 Q. So you did not tell any active lie to the Court, is that
14 correct?
15 A. I'm not really sure.
16 Q. Is that because you don't remember what you said or because
17 you don't know the difference between truth and lie?
18 A. Of course I know the difference, and the character
19 assassination is, you know, well done, but the fact of the
20 matter is that you're here to discredit me and to discredit the
21 fact that myself and eleven other jurors convicted your client
22 across the board.
23 Q. Ms. Conrad, when did you make the deliberate decision to
24 lie to the Court?
25 A. I don't recall.

[Page 143]
C2FFDAU4 Conrad - direct
1 Q. Was it during the voir dire?
2 A. I don't recall.
3 Q. Was it before you showed up for court the first day?
4 A. No, I don't think so.
5 Q. Was it after Judge Pauley told you that you had to speak
6 the truth?
7 A. I don't recall, sir.
8 Q. In response to what question did you make the decision to
9 lie to the Court?
10 A. I didn't lie.
11 Q. You did not lie?
12 A. I omitted the fact that I was an attorney.
13 Q. I just want to make sure I heard you right. You did not
14 lie under oath, is that correct?
15 A. In my mind I didn't. I omitted the fact that I had a JD.
16 Q. And that was not a lie in your mind?
17 A. It was an omission.
18 Q. Is it a lie?
19 A. You're the evidence professor.
20 Q. Did you lie to the Court --
21 A. I omitted.
22 Q. Okay. So there's a distinction in your mind between
23 omitting a truth and lying, is that correct?
24 A. I'm not sure.
25 Q. Well, is the lie that you, or the omission that you

[Page 144]
C2FFDAU4 Conrad - direct
1 remember an omission about being a lawyer?
2 A. I don't know what that question means, sir.
3 Q. Well, let me try another question. Do you remember that
4 the very first question that Judge Pauley asked you was where
5 do you live.
6 A. Yes. And we had to, I believe, state the county.
7 Q. Okay, and in answer to the very first question that Judge
8 Pauley asked you, you told a deliberate lie to Judge Pauley,
9 isn't that true, ma'am?
10 A. No. I don't know what you're talking about.
11 Q. Well, didn't you tell Judge Pauley that you lived in Bronx
12 Village in Westchester?
13 A. There is no such thing as Bronx Village.
14 Q. Well, that's what the transcript says. Did you tell Judge
15 Pauley that you lived in Bronxville in Westchester?
16 A. Yes.
17 Q. And that's a lie, wasn't it?
18 A. No, it's my official address.
19 Q. Ma'am, Judge Pauley didn't ask you what your official
20 address is, he asked you where you live, right?
21 A. Anyone can have more than one residence.
22 Q. Did he ask you where you lived?
23 A. I don't remember the exact question. It might have been --
24 no, it was, you had to give your county. No, he didn't ask.
25 No, I remember that.

Page 141 - Page 144 (36) SOUTHERN DISTRICT REPORTERS DOJ-OGR-00009249