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Case 1:20-cr-00330-PAE Document 616-20 Filed 02/24/22 Page 28 of 67
A-5666

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

[Page 225]
C2frdau7 Conrad - redirect Page 225
1 Q. Well, did you follow all of Judge Pauley's instructions or
2 only the ones that you wanted to follow?
3 A. That's the job of the trier of fact, which I was a trier of
4 fact.
5 Q. Did you follow all of Judge Pauley's instructions or only
6 those instructions that you wanted to follow?
7 A. Probably all of them.
8 Q. All of them, every single one, right?
9 A. I don't have the PJI in front of me.
10 Q. But as far as you know, of all the ones Mr. Okula
11 mentioned, you followed them, right?
12 A. More likely than not.
13 Q. And of all the other instructions he gave you, you followed
14 them, is that correct?
15 A. I can't answer that.
16 Q. You know for a fact you didn't follow all those
17 instructions, don't you?
18 A. No, I don't think that's correct.
19 Q. Didn't he tell you at the very start of the trial that you
20 had to speak the truth to tell about your background in order
21 to even be seated as a juror?
22 A. He also told us to render a fair verdict --
23 Q. No, no.
24 A. -- which we did.
25 Q. Do you see the difference between your answers to my

[Page 226]
C2frdau7 Conrad - redirect Page 226
1 questions and Mr. Okula's questions?
2 A. Sure: Splitting hairs and semantics.
3 Q. Exactly. You're splitting hairs and you're engaging in
4 semantics?
5 MR. OKULA: Objection, your Honor.
6 THE COURT: Overruled.
7 Q. Let me ask you this, Ms. Conrad. Did Judge Pauley give you
8 an instruction as a juror to tell the truth?
9 A. I'm sure he did, yes.
10 Q. Did you tell the truth?
11 A. By rendering an unbiased verdict.
12 Q. Did you tell the truth?
13 A. Yes.
14 Q. You told the truth, the whole truth, and nothing but the
15 truth?
16 A. You're asking me about the voir dire?
17 Q. Yes. That was an instruction he gave you, wasn't it?
18 A. That's correct.
19 Q. Did you tell the truth? Did you follow that instruction?
20 A. No.
21 Q. So, when you just said a couple of moments ago that you
22 followed those instructions, you were lying right then?
23 A. That's incorrect. I thought we were on the same page
24 talking about the PJI at the end of the trial.
25 Q. Did I ever mention the PJI?

[Page 227]
C2frdau7 Conrad - redirect Page 227
1 A. No, but I did.
2 Q. Do I look like I know what the PJI is?
3 A. Yes. You're a professor.
4 Q. Would you agree with me then that since you did for the
5 follow Judge Pauley's initial instruction at the start of the
6 trial, you did not in fact follow all of his instructions?
7 A. You're mischaracterizing it.
8 Q. It's a simple question, yes or no. Since you did not
9 follow the instruction to tell the truth, did you follow all of
10 his instructions?
11 A. Regarding the verdict, yes.
12 Q. Did you follow all of Judge Pauley's instructions?
13 A. Not with respect to the voir dire.
14 Q. Therefore, you did not follow all of his instructions, is
15 that correct?
16 A. If you need to connect the dots like that.
17 Q. Did you follow all of his corrections?
18 A. Yes. In rendering a correct verdict, yes.
19 Q. Now you're saying you did follow all of his instructions.
20 Let me try and get this very simply. Can you answer my
21 question? Taking into account the fact that you perjured
22 yourself repeatedly at voir dire, did you follow all of his
23 instructions?
24 A. I think you just answered the question.
25 Q. Why don't you answer it.

[Page 228]
C2frdau7 Conrad - redirect Page 228
1 A. Besides the voir dire, yes.
2 Q. Including the voir dire, did you follow all of Judge
3 Pauley's instructions?
4 A. Not with my omissions, no.
5 Q. Not with your lies, right?
6 A. However you want to characterize it.
7 Q. Therefore, you picked which of Judge Pauley's instructions
8 you were going to follow and which of those that you were not
9 going to follow, is that correct?
10 A. No.
11 Q. Was it random that you followed some of his instructions
12 and didn't follow others?
13 A. I didn't follow the instructions in voir dire.
14 Q. You chose, you picked that instruction not to follow,
15 correct?
16 A. Yes.
17 Q. You want us to take your assurance that you didn't pick any
18 other instructions not to follow, correct?
19 MR. OKULA: Objection.
20 THE COURT: Sustained.
21 Q. In your opinion, Ms. Conrad, did your perjury in voir dire
22 affect your ability to act as a fair and impartial juror?
23 A. No, not at all.
24 Q. Ms. Conrad, did I understand you to say that you thought
25 that it was basically no harm/no foul as far as the defense was

SOUTHERN DISTRICT REPORTERS (57) Page 225 - Page 228
DOJ-OGR-00009270