DOJ-OGR-00009263.jpg
1020 KB
Extraction Summary
8
People
2
Organizations
2
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Court transcript (exhibit)
File Size:
1020 KB
Summary
This document is a four-page transcript excerpt (pages 197-200) from the case United States v. Daugerdas (February 15, 2012), filed as Exhibit A-5659 in the Ghislaine Maxwell case (1:20-cr-00330-PAE). The transcript features the examination of a witness named Ms. Conrad regarding a letter she sent to a Mr. Okula (likely a fellow juror), in which she included her phone number and discussed her reasoning for convicting defendant David Parse. The questioning highlights contradictions between what Conrad wrote to Okula on May 25th (claiming she wanted to convict Parse 100%) and what she told Judge Pauley on December 20th (claiming Parse shouldn't have been convicted on count 1). This document was likely used in the Maxwell trial to argue legal precedents regarding juror misconduct.
People (8)
| Name | Role | Context |
|---|---|---|
| Conrad | Witness/Juror |
Being questioned about a letter she wrote to another juror and her conduct.
|
| Mr. Okula | Juror/Recipient |
Recipient of a letter from Conrad; attempts to object on 606 grounds.
|
| Mr. Gair | Attorney |
Asks to respond to objection; asks for witness instruction regarding jury deliberations.
|
| Judge Pauley | Judge |
Judge mentioned in relation to a statement made on December 20th.
|
| David Parse | Defendant (Daugerdas case) |
Mentioned as the person Conrad wanted to convict/held out on.
|
| Mr. Bharara | Official (Preet Bharara) |
Mentioned in the context of Mr. Okula potentially taking his job.
|
| Brubaker | Person of interest |
Mentioned as 'stupid Brubaker' in a quote read from Exhibit 3.
|
| Paul M. Daugerdas | Defendant |
Named in the case caption.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States of America |
Plaintiff in the case caption.
|
|
| Southern District Reporters |
Court reporting agency listed in footer.
|
Locations (2)
| Location | Context |
|---|---|
|
Address mentioned by questioning attorney.
|
|
|
Address mentioned by questioning attorney.
|
Relationships (2)
Conrad discusses her deliberations regarding Parse's conviction.
Key Quotes (4)
"I solely held out for two days on the conspiracy charge for him... I wanted to convict 100 percent not only on that charge."Source
DOJ-OGR-00009263.jpg
Quote #1
"in my mind Parse should not have been convicted of number 1"Source
DOJ-OGR-00009263.jpg
Quote #2
"I'll retain myself or my husband, the convicted felon."Source
DOJ-OGR-00009263.jpg
Quote #3
"I'm not playing into this fantasy stuff. No, not at all."Source
DOJ-OGR-00009263.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (4,883 characters)
Case 1:20-cr-00330-PAE Document 616-1 Filed 02/24/22 Page 241 of 67
A-5659
A-5659
February 15, 2012
UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL.,
UNITED STATES OF AMERICA, v PAUL M. DAUGERDAS, ET AL.,
[Page 197]
C2FFDAU6 Conrad - direct Page 197
1 you put your cell number on your letter to Mr. Okula?
2 A. Because that's how I'm most accessible, sir.
3 Q. Because you wanted him to call you, didn't you, ma'am?
4 A. No, not at all.
5 Q. Well, then why did you care if you were most accessible
6 that way or not?
7 A. Just a heading I use. That's all.
8 Q. No, you just told us that you put that on that letter
9 because that's where you're most accessible.
10 A. That's true. But not with any forethought to an
11 expectation of a call from Mr. Okula.
12 Q. Why did you care whether you were accessible or not? Why
13 did you put a phone number on there?
14 A. Because that's usually what a heading has.
15 Q. And you made a conscious decision to put your phone number
16 on there, right?
17 A. Sir, this is minutiae. I don't know. I can't answer that.
18 Q. You were hoping to be accessible for a phone call from
19 Mr. Okula, correct?
20 A. Absolutely not.
21 Q. And would you agree with me that at times the tone of your
22 letter was playful?
23 A. Oh, sure.
24 Q. Maybe even flirtatious, right?
25 A. That's -- please. Judge.
C2FFDAU6 Conrad - direct Page 197
1 you put your cell number on your letter to Mr. Okula?
2 A. Because that's how I'm most accessible, sir.
3 Q. Because you wanted him to call you, didn't you, ma'am?
4 A. No, not at all.
5 Q. Well, then why did you care if you were most accessible
6 that way or not?
7 A. Just a heading I use. That's all.
8 Q. No, you just told us that you put that on that letter
9 because that's where you're most accessible.
10 A. That's true. But not with any forethought to an
11 expectation of a call from Mr. Okula.
12 Q. Why did you care whether you were accessible or not? Why
13 did you put a phone number on there?
14 A. Because that's usually what a heading has.
15 Q. And you made a conscious decision to put your phone number
16 on there, right?
17 A. Sir, this is minutiae. I don't know. I can't answer that.
18 Q. You were hoping to be accessible for a phone call from
19 Mr. Okula, correct?
20 A. Absolutely not.
21 Q. And would you agree with me that at times the tone of your
22 letter was playful?
23 A. Oh, sure.
24 Q. Maybe even flirtatious, right?
25 A. That's -- please. Judge.
[Page 198]
C2FFDAU6 Conrad - direct Page 198
1 THE COURT: You can answer the question.
2 A. Absolutely not.
3 Q. Did you tell Mr. Okula that something, words to the effect
4 that maybe he was on track to take Mr. Bharara's job from him?
5 A. Oh, yes.
6 Q. Now, did you hope that he would call you back, ma'am?
7 A. I'm not playing into this fantasy stuff. No, not at all.
8 Please.
9 Q. Did you feel, did you think about putting the phone number
10 that went with this address 16 Parkview Drive, did you think
11 about putting that phone number on the letterhead?
12 A. No.
13 Q. Did you think about putting your real address on the
14 letterhead?
15 A. That is my real address as well.
16 Q. Did you think about putting your Barker Avenue address on
17 the letterhead?
18 A. Sir, it was probably just cut and pasted from another
19 letter I had done. It wasn't conscious.
20 Q. Did you just make that up, just this moment, it was
21 probably cut and pasted from another letter? Did you just make
22 that up?
23 A. I'm answering your question, sir.
24 Q. No, I want to know if you just made that up or if you had
25 any reason to believe that you cut and pasted this from another
C2FFDAU6 Conrad - direct Page 198
1 THE COURT: You can answer the question.
2 A. Absolutely not.
3 Q. Did you tell Mr. Okula that something, words to the effect
4 that maybe he was on track to take Mr. Bharara's job from him?
5 A. Oh, yes.
6 Q. Now, did you hope that he would call you back, ma'am?
7 A. I'm not playing into this fantasy stuff. No, not at all.
8 Please.
9 Q. Did you feel, did you think about putting the phone number
10 that went with this address 16 Parkview Drive, did you think
11 about putting that phone number on the letterhead?
12 A. No.
13 Q. Did you think about putting your real address on the
14 letterhead?
15 A. That is my real address as well.
16 Q. Did you think about putting your Barker Avenue address on
17 the letterhead?
18 A. Sir, it was probably just cut and pasted from another
19 letter I had done. It wasn't conscious.
20 Q. Did you just make that up, just this moment, it was
21 probably cut and pasted from another letter? Did you just make
22 that up?
23 A. I'm answering your question, sir.
24 Q. No, I want to know if you just made that up or if you had
25 any reason to believe that you cut and pasted this from another
[Page 199]
C2FFDAU6 Conrad - direct Page 199
1 letter.
2 A. Yes, I probably did cut and paste it.
3 Q. What other letter?
4 A. I have no idea.
5 Q. Okay. Now, in this letter you told Mr. Okula, and I quote,
6 "I solely held out for two days on the conspiracy charge for
7 him," referring to David Parse. "I wanted to convict
8 100 percent not only on that charge." Do you remember that?
9 A. Yes.
10 Q. And you're sure about that, right? You wouldn't lie to
11 Mr. Okula, would you?
12 MR. OKULA: Judge, object on 606 grounds.
13 MR. GAIR: May I respond, your Honor?
14 THE COURT: No. Overruled.
15 Q. Did you tell Mr. Okula, "I solely held out for two days on
16 the conspiracy charge for Parse. I wanted to convict
17 100 percent not only on that charge." Did you tell him that?
18 A. You're reading it correctly.
19 Q. Did you tell Judge Pauley on December 20th that "in my mind
20 Parse should not have been convicted of number 1"?
21 A. Oh, I don't recall, sir.
22 Q. Well, let's look at Exhibit 3, page 16. Beginning at line
23 3. "For what? For what? I'll retain myself or my husband,
24 the convicted felon. For what? For what, sir? To say that I
25 convicted everybody except the stupid Brubaker? Parse was an
C2FFDAU6 Conrad - direct Page 199
1 letter.
2 A. Yes, I probably did cut and paste it.
3 Q. What other letter?
4 A. I have no idea.
5 Q. Okay. Now, in this letter you told Mr. Okula, and I quote,
6 "I solely held out for two days on the conspiracy charge for
7 him," referring to David Parse. "I wanted to convict
8 100 percent not only on that charge." Do you remember that?
9 A. Yes.
10 Q. And you're sure about that, right? You wouldn't lie to
11 Mr. Okula, would you?
12 MR. OKULA: Judge, object on 606 grounds.
13 MR. GAIR: May I respond, your Honor?
14 THE COURT: No. Overruled.
15 Q. Did you tell Mr. Okula, "I solely held out for two days on
16 the conspiracy charge for Parse. I wanted to convict
17 100 percent not only on that charge." Did you tell him that?
18 A. You're reading it correctly.
19 Q. Did you tell Judge Pauley on December 20th that "in my mind
20 Parse should not have been convicted of number 1"?
21 A. Oh, I don't recall, sir.
22 Q. Well, let's look at Exhibit 3, page 16. Beginning at line
23 3. "For what? For what? I'll retain myself or my husband,
24 the convicted felon. For what? For what, sir? To say that I
25 convicted everybody except the stupid Brubaker? Parse was an
[Page 200]
C2FFDAU6 Conrad - direct Page 200
1 idiot but we let him go because I had evidence enough that he
2 really, he didn't really, in my mind he shouldn't have been
3 convicted of number 1."
4 Did you say that to Judge Pauley on December 20th?
5 A. Yes, you're reading correctly.
6 Q. And that's a contradiction of what you said to Mr. Okula
7 the day after the trial, correct?
8 A. I wasn't the only holdout.
9 MR. GAIR: Your Honor, I'm going to ask that this
10 witness be instructed not to discuss the jury deliberations. I
11 didn't ask about them.
12 THE COURT: Please --
13 A. But in essence --
14 THE COURT: Don't discuss the deliberations or the
15 split of the vote among the jury. Respect the sanctity of jury
16 deliberations, Ms. Conrad.
17 THE WITNESS: Yes.
18 THE COURT: And respond directly to counsel's
19 questions.
20 Q. Ma'am, isn't it true that the statement you made to Judge
21 Pauley on December 20th was directly contradictory to the
22 statement you made to Mr. Okula in his letter, in your letter
23 of May 25th?
24 A. I don't know.
25 Q. Well, is it contradictory to say that a person should have
C2FFDAU6 Conrad - direct Page 200
1 idiot but we let him go because I had evidence enough that he
2 really, he didn't really, in my mind he shouldn't have been
3 convicted of number 1."
4 Did you say that to Judge Pauley on December 20th?
5 A. Yes, you're reading correctly.
6 Q. And that's a contradiction of what you said to Mr. Okula
7 the day after the trial, correct?
8 A. I wasn't the only holdout.
9 MR. GAIR: Your Honor, I'm going to ask that this
10 witness be instructed not to discuss the jury deliberations. I
11 didn't ask about them.
12 THE COURT: Please --
13 A. But in essence --
14 THE COURT: Don't discuss the deliberations or the
15 split of the vote among the jury. Respect the sanctity of jury
16 deliberations, Ms. Conrad.
17 THE WITNESS: Yes.
18 THE COURT: And respond directly to counsel's
19 questions.
20 Q. Ma'am, isn't it true that the statement you made to Judge
21 Pauley on December 20th was directly contradictory to the
22 statement you made to Mr. Okula in his letter, in your letter
23 of May 25th?
24 A. I don't know.
25 Q. Well, is it contradictory to say that a person should have
Page 197 - Page 200 (50) SOUTHERN DISTRICT REPORTERS DOJ-OGR-00009263
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