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Case 1:20-cr-00330-PAE Document 616-20 Filed 02/24/22 Page 22 of 67
A-5640

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

[Page 121]
C2FFDAU4 Conrad - direct

1 Q. Do you regard water as a medication?
2 A. It calms me down. Sure.
3 Q. Besides water, what other medications do you take?
4 A. Tylenol for PMS.
5 Q. Do you take any prescription medication?
6 A. Not at all.
7 Q. At any time in the last, say, two years have you taken any
8 prescription medication?
9 A. No, sir.
10 Q. Now, did you tell the judge that, after he reminded you
11 that a subpoena had just been served on you on December 20, did
12 you tell the judge, "I reject the subpoena. I reject it and
13 you're going to have to arrest me because nothing is going to
14 change."
15 A. I don't specifically remember that, but I'm sure I told him
16 that if it's in your record.
17 Q. Would you agree with me that that is uncommon conduct for
18 an officer of the Court?
19 A. I'm not a psychologist. I don't know what common conduct
20 quote-unquote, what your terms mean.
21 Q. So you're not really in a position to judge whether
22 something is common or uncommon, correct?
23 A. I'm not a judge, like you just said.
24 Q. And you're not in a position to judge whether something is
25 rational or irrational, right?

[Page 122]
C2FFDAU4 Conrad - direct

1 A. Common knowledge is common knowledge, sir.
2 Q. Are you in a position to judge whether something is
3 rational or irrational?
4 MR. OKULA: Objection, Judge. We're getting into this
5 rational/irrational. Different people have different ideas
6 about it.
7 THE COURT: And he's exploring the witness' view of
8 that. Overruled.
9 A. Can you please say that again, sir?
10 MR. GAIR: Your Honor, can I ask that the court
11 reporter read back the question?
12 THE COURT: Madam court reporter, would you kindly
13 read back the question for Ms. Conrad?
14 (Record read)
15 A. In what context, sir?
16 Q. In the context of conduct of a lawyer appearing before a
17 federal judge, do you know what kind of conduct is rational and
18 what kind of conduct is irrational?
19 A. Probably, sir.
20 Q. Was your conduct irrational when you said, "I reject the
21 subpoena. I reject it and you're going to have to arrest me
22 because nothing is going to change"?
23 A. I consider it irrelevant.
24 Q. I beg your pardon?
25 A. Irrelevant, not irrational.

[Page 123]
C2FFDAU4 Conrad - direct

1 Q. Would your conduct be sane if irrational?
2 A. I'm not going to answer that. Of course not. Insanely?
3 Is that what you said, sir?
4 THE COURT: Why don't you put another question?
5 Q. Was your conduct in rejecting the subpoena that the judge
6 ordered served on you and saying that you were not going to
7 appear and the judge would have to have you arrested, was that
8 conduct irrational?
9 A. Absolutely not. Nobody wants a subpoena served on them.
10 Q. Now, have you ever witnessed an officer of the court in
11 your career as a lawyer, have you ever witnessed an officer of
12 the court telling a judge that the judge would have to have
13 them arrested because they weren't going to appear as ordered?
14 A. I don't know how to answer that. I don't know.
15 Q. Do you know what your own experiences are?
16 A. If you're asking if I did it? You just told me I did it.
17 Q. I'm asking you -- are you able to understand my question?
18 A. Yes, but these questions are ridiculous.
19 Q. Why are they ridiculous?
20 A. Pose it again, please.
21 Q. Can you answer me why -- you just said my questions are
22 ridiculous. What did you mean when you said they were
23 ridiculous?
24 A. How would I know whether an attorney, what another attorney
25 said to another judge? I don't understand your questions.

[Page 124]
C2FFDAU4 Conrad - direct

1 Q. Okay. Now, would you agree with me that a good part of
2 that hearing on December 20th was about Judge Pauley advising
3 you that you should get a lawyer.
4 A. Yes, sir. I understand the underlying reason why we're
5 here is not lawyer or lawyer up, whether I did or didn't, it's
6 whether the underlying fact of the verdict.
7 Q. Did you understand that the hearing on December 20th was to
8 give you instructions which included instructing you about your
9 right to a lawyer?
10 A. I guess partly, sir.
11 Q. Okay. And Judge Pauley told you that he would appoint a
12 lawyer for you if you qualified financially, correct?
13 A. I don't recall specifically. I don't recall.
14 Q. Well, didn't you -- you don't recall whether the judge told
15 you that you would have to -- that he could only appoint a
16 lawyer if you couldn't afford to hire one yourself?
17 A. Sir, I don't specifically remember that.
18 Q. Did you say that you didn't have the money to pay for
19 counsel?
20 A. Oh, I don't recall.
21 Q. Did you have the money to pay for counsel?
22 A. No.
23 Q. Well, let me just ask you to look, there's a big black
24 binder in front of you, and I'm going to ask you about a
25 document in that binder, Exhibit 3.

SOUTHERN DISTRICT REPORTERS (31) Page 121 - Page 124
DOJ-OGR-00009244