DOJ-OGR-00009421.pdf

Case 1:20-cv-03038-PAE Document 616-1 Filed 02/24/22 Page 23 of 117 A-5817 C2grdau4 Schoeman - direct 360 1 which we concluded the summations in the case, yes. 2 Q. Do you recall the subject matter of that note? 3 A. I recall in general that there was a question regarding respondeat superior. 4 Q. Again just to be clear, what stage was the trial at? 5 A. I believe that that was after all of the summations had 6 been concluded, I think including the rebuttal summation. 7 8 Q. Do you know a lawyer named Theresa Trzaskoma? 9 A. I do. 10 Q. How do you know her? 11 A. I think I first met Ms. Trzaskoma in approximately 2,000. 12 My babysitter and her babysitter became friends. Being a 13 first- time parent, I did a little diligence on the parents of 14 my 3 month old's playmate and learned that it was Ms. Trzaskoma 15 and her husband. We became family friends at that point. 16 Q. I'm loathe to ask this question, but you Googled her? 17 A. Actually, I think I knew her husband, who had been an 18 associate with me at Paul Weiss and had clerked in the Eastern 19 District at the same time that my wife had clerked. So I think 20 I knew them in advance. 21 Q. Was Ms. Trzaskoma also a lawyer during the course of the 22 trial in this courtroom, the David Parse trial? 23 A. She was. 24 Q. Who did she and her firm represent? 25 A. She and her firm represented David Parse. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009421