DOJ-OGR-00009476.jpg

Case E20 OSE PANES BOC ENN ER) LOU ORIRA Rag eaue!S ol 117 Case 1:09-cr-00581-WHP Document 544 _ Filed 08/07/12 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, § § ECF CASE Vv. § § Case No. 83 09 Cr. 581 (WHP) PAUL M. DAUGERDAS, § DONNA GUERIN, § AFFIDAVIT OF DAVID PARSE DENIS FIELD, and § DAVID PARSE, § § Defendants, § STATE OF NEW YORK _) S833 COUNTY OF NEW YORK ) DAVID PARSE, being duly sworn, deposes and says: L. My name is David Parse, and I am a defendant in the above-captioned case. 2 During jury selection (or shortly thereafter), I heard one of the lawyers at the Brune firm (I believe it was Theresa Trzaskoma) say that there was a prospective juror (or a juror) who had the same name as a suspended attorney but that it was not the same person. I cannot recall if the lawyer was speaking to me or if ] overheard her speaking to someone else. a A week after the verdict, I met with the Brune lawyers to discuss possible post- trial motions and appellate issues. The possibility of a juror misconduct issue was not raised. 4, It was not until after the Brune firm filed its motion for a new trial that I learned that prior to jury deliberations the issue of Conrad being a suspended lawyer had resurfaced, More precisely, to the best of my memory, it was after the July 15, 2011 conference call that I learned (i) that on May 12, 2011, Ms. Trzaskoma had considered the possibility that Juror No. 1 368933 | DOJ-OGR-00009476