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Case A eR PN BOC EN ESQ mba @ageall of 67 UNITED STATES OF AMERICA, y February 15, 2012 PAUL M. DAUGERDAS, ET AL., C2FFDAU6 Conrad -direct Pagai97|C2FFDAU6 —Conrad-direct =—St—<“‘(ét*«éRQ UE DY 1 you put your cell number on your letter to Mr. Okula? | 1 letter. 2 A. Because that's how I'm most accessible, sir. 2 A. Yes, ] probably did cut and paste it. 3 Q. Because you wanted him to call you, didn't you, ma'am? | 3 Q. What other letter? 4 A. No, not at all. a A, Thave no idea. 5 Q. Well, then why did you care if you were most accessible | 5 Q. Okay. Now, in this letter you told Mr. Okula, and I quote, 6 that way or not? 6 "I solely held out for two days on the conspiracy charge for 7 A. Just a heading ] use. That's all. 7 him,” referring to David Parse. "I wanted to convict a Q. No, you just told us that you put that on that letter | 8 100 percent not only on that charge.” Do you remember that? g because that's where you're most accessible. 9 A. Yes. 10 A. That's true. But not with any forethought to an 10 Q. And you're sure about that, right? You wouldn't lie to 11 expectation of a call from Mr. Okula. 11 Mr. Okula, would you? 12 Q. Why did you care whether you were accessible or not? Why |12 MR. OKULA: Judge, object on 606 grounds. 13 did you put a phone number on there? 13 MR. GAIR: May I respond, your Honor? 14 A. Because that's usually what a heading has. 14 THE COURT: No. Overruled. 15 Q. And you made a conscious decision to put your phone number |15 Q. Did you tell Mr. Okula, "I solely held out for two days on 16 onthere, right? 16 the conspiracy charge for Parse. I wanted to convict 17 A. Sir, this is minutiae. [don't know. [can't answer that. |17 100 percent not only on that charge." Did you tell him that? 18 Q. You were hoping to be accessible for a phone callfrom |18 A. You're reading it correctly. 19 Mr. Okula, correct? 18 Q. Did you tell Judge Pauley on December 20th that "in my mind 20 A. Absolutely not. 20 Parse should not have been convicted of number 1"? 21 Q. And would you agree with me that at times the tone of your |21 A. Oh, I don't recall, sir. ‘22 letter was playful? /22 Q. Well, let's look at Exhibit 3, page 16. Beginning at line 23 A. Oh, sure. 23 3, "For what? For what? I'll retain myself or my husband, 24 Q, Maybe even flirtatious, right? 24 the convicted felon. For what? For what, sir? To say that I '25 A. That's -- please, Judge, 125 convicted everybody except the stupid Brubaker? Parse was an C2FFDAU6 Conrad - direct Page 198 | C2FFDAU6 Conrad - direct Page 200 1 THE COURT: You can answer the question. 1 idiot but we let him go because I had evidence enough that he 2 A. Absolutely not. 2 really, he didn't really, in my mind he shouldn't have been 3 Q. Did you tell Mr. Okula that something, words to the effect | 3 convicted of number 1," 4 that maybe he was on track to take Mr. Bharara's job from him? | 4 Did you say that to Judge Pauley on December 20th? 5 A. Oh, yes. 5 A. Yes, you're reading correctly, 6 Q. Now, did you hope that he would call you back, ma'am? | 6 Q. And that's a contradiction of what you said to Mr. Okula 7 A, I'm not playing into this fantasy stuff. No, not at all. | 7 the day after the trial, correct? 8 Please. s A. I wasn't the only holdout. 9 Q. Did you feel, did you think about putting the phone number | 9 MR. GAJIR: Your Honor, I'm going to ask that this 10 that went with this address 16 Parkview Drive, did you think |10 witness be instructed not to discuss the jury deliberations. I 11 about putting that phone number on the letterhead? {11 didn't ask about them. 12 A. No. 12 THE COURT: Please -- 13 Q. Did you think about putting your real address on the |13 A. But in essence -- 14 letterhead? 14 THE COURT: Don't discuss the deliberations or the 15 A. That is my real address as well. 15 split of the vote among the jury. Respect the sanctity of jury 126 Q. Did you think about putting your Barker Avenue address on |16 deliberations, Ms. Conrad. 17 the letterhead? a7 THE WITNESS: Yes. 1s A. Sir, it was probably just cut and pasted from another |18 THE COURT: And respond directly to counsel's 19 letter [ had done. It wasn't consciaus. 19 questions, 20 Q. Did you just make that up, just this moment, it was |20 Q. Ma'am, isn't it true that the statement you made to Judge 21. probably cut and pasted from another letter? Did you just make |21 Pauley on December 20th was directly contradictory to the | 22 that up? 22 statement you made to Mr. Okula in his letter, in your letter 23 A. I'm answering your question, sir. 23. of May 25th? 24 Q. No, I want to know if you just made that up or if you had (24 A, I don't know. | 25 any reason to believe that you cut and pasted this from another 25 Q. Well, is it contradictory to say that a person should have | Page 197 - Page 200 (50) SOUTHERN DISTRICT REPORTERS Ny DOJ-OGR-00009263