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Case 1:20-cr-00330-AJN Document 646-10 Filed 08/11/22 Page 30 of 67
A-5648

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

[Page 153]
C2frdau5 Conrad - direct Page 153
1 I'm from there. I live there sometimes. I live at my Bronx
2 address also.
3 Q. Ma'am, my question is, did you say that you lived in
4 Bronxville in order to portray yourself as living in a more
5 affluent community than you actually live in?
6 A. No, not specifically, no.
7 Q. When you said a few minutes ago that the reason that you
8 gave the Bronxville address was because it was a little bit
9 more of an affluent community, that wasn't true?
10 A. My statement was true, but you're twisting it, obviously.
11 Q. Why don't you tell me why, having sworn to the bar
12 authorities on February 26th that you lived in the Bronx, you
13 swore to Judge Pauley on March 2nd that you lived in
14 Bronxville. Tell us why.
15 A. I consider myself living in both places.
16 Q. Why didn't you tell the Court that you lived both places?
17 A. Probably so I would be more marketable as a juror.
18 Q. Have you done any jury trials as a lawyer?
19 A. Nonjury. No. One a few years ago.
20 Q. Why did you want to be more marketable as a juror?
21 A. Because I knew I could be fair and unbiased. As I did
22 mention a few minutes ago, I've been a plaintiff and a
23 defendant on both the civil and the criminal sides, and I have
24 also represented plaintiffs and defendants on both sides, and
25 been unemployed, out of the courtroom. And I had never had a

[Page 155]
C2frdau5 Conrad - direct Page 155
1 A. I did not wake up in Bronxville that day, probably not.
2 Q. So you told a deliberate lie that day, correct?
3 A. No.
4 Q. Was it an accidental misstatement?
5 A. No.
6 Q. Was it an oversight?
7 MR. OKULA: Judge, we have been through this several
8 times.
9 THE COURT: Overruled.
10 A. No. I consider myself having two residences.
11 Q. Then why didn't you tell the truth when you were asked that
12 question?
13 A. I did.
14 Q. Did you say, I have two residences and, by the way, I've
15 been on both sides of criminal cases? Did you say that?
16 A. I wasn't asked that, sir.
17 Q. We'll come to that. Did you say that you had two
18 residences?
19 A. No.
20 Q. Did you tell the disciplinary authorities that you had two
21 residences?
22 A. They know.
23 Q. Did you tell the disciplinary authorities in your affidavit
24 that you resided in Bronxville?
25 A. Not in this one.

[Page 154]
C2frdau5 Conrad - direct Page 154
1 tax shelter case or experience with tax law, and I knew I could
2 be an unbiased juror.
3 Q. Because you knew that you could be an unbiased juror, you
4 decided to lie to get on a jury, is that right?
5 A. Probably subconsciously.
6 Q. Subconsciously, Ms. Conrad, you wanted to do something
7 worthwhile, is that right?
8 MR. OKULA: Objection to the form, your Honor.
9 THE COURT: Overruled.
10 A. I don't know how you can characterize "worthwhile." If
11 it's sending a -- rendering a verdict which I felt was just,
12 then I can agree with you. But if there's something ulterior
13 to your question, I don't know how to answer that.
14 Q. When you started just then to say "sending a" and then you
15 stopped, were you going to say sending a criminal to jail? Is
16 that what you were about to say?
17 A. No.
18 Q. You wanted to be part of the process, didn't you, ma'am?
19 A. Sure.
20 Q. You wanted to be part of this process so badly that you
21 made yourself look like a different juror than you were,
22 different person than you were?
23 A. That's not for me to judge.
24 Q. Can we agree that you lied about where you resided on March
25 2nd?

[Page 156]
C2frdau5 Conrad - direct Page 156
1 Q. Not in this one. Do you remember that a couple of years
2 before this you were sworn to give a deposition under oath?
3 A. March 24, 2009.
4 Q. You do remember, don't you.
5 A. Yes, I do.
6 Q. You were asked where you lived, weren't you?
7 A. Probably.
8 Q. You said, truthfully, that you lived on Barker Avenue in
9 the Bronx, didn't you?
10 A. I don't recall specifically.
11 Q. Ma'am, you've lived on Barker Avenue in the Bronx for many
12 years, isn't that true?
13 A. Sure.
14 Q. And every one of your neighbors on the third floor knows
15 who you are, don't they?
16 A. Probably.
17 Q. Because you and your husband are constantly, every day and
18 night, engaged in screaming and fights and insults and threats,
19 right?
20 MR. OKULA: Objection, your Honor. Relevance.
21 THE COURT: Overruled.
22 A. Probably.
23 Q. Yeah, probably. The police are there all the time, aren't
24 they?
25 A. No.

SOUTHERN DISTRICT REPORTERS (39) Page 153 - Page 156
DOJ-OGR-00009931