DOJ-OGR-00010115.pdf

--- Page 1 --- The extracted text from the document image is as follows: **Header:** * **Case Number:** C2grdau4 * **Date:** 2004 * **Document Type:** Cross Examination * **Page Number:** 375 * **A-5832** **Transcript:** * **CZgrdau4:** suspended attorney named Catherine Conrad, the same name as Juror No. 17 * **A:** I was never in a position where I needed to or had to make decisions about the investigation. I don't understand that I'm here as an expert witness. I can tell you as a matter of fact what I knew, what I was told, the conversations I had, but I really can't go beyond that, Mr. Okula. * **Q:** You're not going to answer my question? You've hired private investigators many times as a lawyer, right? * **A:** I have. * **Q:** Are you unwilling to answer the question that I just asked about what steps you would take if you learned that Catherine Conrad, a suspended attorney, was in existence and you knew you had Catherine Conrad sitting in seat number 17? Are you not going to answer that question? * **A:** What you are ignoring is it's such a far-fetched idea that any citizen would come in here and lie to be a juror. I have never experienced it as a practicing lawyer. It never occurred to me it happened in this trial, and it's not something I have ever thought about it. When I've used investigators it's because I'm defending someone in a criminal case or civil case and I want to look at facts. You're asking me to speculate and give opinions about an experience I've never had. * **MR. OKULA:** Judge, I have no further questions for Mr. Berke. * **Berke:** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 **Footer:** * **DOJ-OGR-00010115**