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Case TAECIOOS8E- PEUTIC NE O63 Filed@W2z/e4/22gePaged 45 of 67 February 15, 2012 C2FFDAU6 Conrad - cross Page 213 1 before you started hearing any evidence, is that correct? In | 1 2 other words, you hadn't prejudged the case after you were | 2 3 selected that you were going to find the defendants guilty or | 3 4 rule in favor of the government, is that correct? 4 5 A. That's correct, yes. 5 6 Q. And is it also true that you didn't make up your mind with | 6 7 respect to the guilt or innocence of any of the defendants | 7 8 until you heard all the evidence in the case and listenedto | 8 9 the judge's instructions, is that fair? 9 10 A, Absolutely. 10 11 Q. Let me pick up ona section where Mr. Gair was asking you | 11 12 about things you said with respect to David Parse. Do you |12 13 remember those questions? 13 ia A. Yes. 14 15 Q. And Mr. Gair referenced the letter that you sent to me [15 16 after the return of the verdict, do you remember that? |16 17 A. Yes. 17 18 Q. And you were also asked questions about the fact that you |16 19 referred to fighting the good fight. Do you recall that? |19 20 A. Yes. 20 21 Q. Without getting into your deliberations with the other | 21 '22 23 we Ww jurors, is it correct that as you said in the letter that you viewed initially during your, when you began deliberating, that Ww oe] 1 Q. And you also note in your letter, though, that you | 1 2 ultimately relented after hearing a jury charge from Judge 3 Pauley about the definition of knowingly and willfully, 4 correct? 2 3 4 5 A. Yes. 5 6 Q. Sois it fair to say that when you personally deliberated | 6 7 with respect to Mr. Parse, you reached your conclusion based on | 7 8 the legal instruction that Judge Pauley gave you and without | 8 9 bias to any side. Fair? 9 zo A. 100 percent. Correct, 10 11 Q. Now, when you were selected to serve on the jury, did you | 11 12 have any personal knowledge with respect to any of the | 12 13 defendants in this case? 13 14 A, No, none, 14 15 Q. And is it also fair that you didn't have any personal | 15 C2FFDAU6 24 Mr. Parse should have been found guilty? 24 a5 A. Yes, 25 C2FFDAU6 Conrad - cross Page 214 | C2FFDAUS UNITED STATES OF AMERICA, y PAUL M, DAUGERDAS, ET AL., Conrad - cross Page 215 A. No. Q. Now, Mr, Gair went through and Mr. Schectman did also to some extent some of your criminal] cases with you. Do you remember that? A. Yes. Q. For instance, you went through your driving under the influence offenses and your harassment offense, the contempt offense and the shoplifting offenses. Do you remember that? A. Yes. Q. And were you also asked about the disorderly conduct offense that you were arrested for that you didn't appear on in Winslow, Arizona. Do you recall that? A. Yes, sir, Q. Now, none of those cases, Ms. Conrad, had anything to do with the subject matter involved in this trial, correct’? | A. That's correct. Q. In other words, these offenses, those local offenses that | you were arrested for, none of them had anything to do with taxes or tax evasion Or tax shelters, is that fair? A. That's correct. Q. And is it also fair, Ms. Conrad, that your involvement in those criminal cases did not cause you to be biased in one matter or another against any party or any attorney in this case? A. That's correct. Conrad - cross Page 216 Q. Now, let me ask you this, Ms, Conrad. Did the fact that you were a criminal defendant in a prior case affect you from fairly and impartially judging the evidence in this case and weighing and applying Judge Pauley's legal instruction? A. Absolutely not. Q. Did the fact that you were arrested by a police officer on a number of occasions in your criminal cases in any way affect your ability to be fair and impartial? A. No. Q. Did your involvement in the disciplinary proceedings where lawyers made complaints about you and you were asked questions by disciplinary counsel, did that affect your ability to carefully and appropriately and fairly weigh the evidence and the legal instructions in this case? A. No, not at all. Q. Did the fact that you were a suspended attorney affect your impartiality in this case? Q. Now, do you remember you received legal instructions from Judge Pauley on a number of occasions during the case, both during voir dire at the beginning of the trial and at the end Q. And in particular, do you remember a jury instruction that went somewhat, | know it's a long time ago and you may not 16 knowledge of any of the defense lawyers, correct? | 16 17 A. Correct. 17 18 Q. You didn't know any of the prosecutors in the case orany |18 A. No. 19 of the IRS agents, correct? 19 20 A. No. That's correct. 20 21 Q. And you weren't factually involved in any of the underlying | 21 22 events at trial, correct? 22. of the trial? 23 A. Never. 23 A. Yes. 24 Q. And did you have any financial mative inthe outcome of the | 24 25 case? | 25 Page 213 - Page 216 (54) SOUTHERN DISTRICT REPORTERS iy DOJ-OGR-00009267