DOJ-OGR-00010081.pdf

C2GFDAU3 Edelstein 341 1 Q. You knew from the voir dire, didn't you, that the Catherine 2 Conrad who sat as Juror No. 1 referred to being involved in a 3 personal injury lawsuit, correct? 4 A. Yes. 5 Q. Did Theresa Trzaskoma tell you that document she had seen 6 in the form of the Westlaw report had indicated Catherine M. 7 Conrad as a party to a lawsuit? 8 A. No. 9 Q. Would you agree with me that you had the resources 10 available to you, that all you had to do was pick up the phone 11 and call Nardello or anyone else and ask them to go to a 12 courthouse or do investigating for you to try to establish a 13 link, or the link that Theresa Trzaskoma had suggested? Would 14 you agree that you had those resources? 15 A. We could have done that, but we didn't believe they were 16 the same person. We thought -- 17 Q. So the answer is yes. You had those resources, right? 18 It's a simple question. 19 A. Yes, we could have called someone to investigate if we 20 thought that there was a reason to investigate. 21 Q. Now, after you received the juror letter that was sent to 22 you, you did call Nardello in to assist you in gathering 23 information, correct? 24 A. Yes. 25 Q. And that led to the preparation of your brief, correct? 1 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010081