DOJ-OGR-00018791.pdf

Case 1:20-cr-00330-PAE Document 753 Filed 08/10/22 Page 193 of 264 1634 LC7Cmax6 Carolyn - cross 1 THE WITNESS: I am confused. 2 MR. PAGLIUCA: It is. 3 THE WITNESS: Very confused right now. 4 BY MR. PAGLIUCA: 5 Q. Well, reviewing those questions and answers, does that refresh your recollection -- 6 A. You want me to read from 8 and 9 to 20 and 20-what? 7 Q. Deposition page 12, on that page. 8 A. Okay. 9 Q. Lines 18 through 25. 10 A. 18 through 25. Like I said, I'm so confused. 11 Okay. I read it. 12 Q. Does that refresh your recollection that you were shown your answers to interrogatories, Mr. Scarola directed you to them, and that you said to Mr. Scarola, this is what me and you did, right, then it should be correct, unless somebody messed with it? 13 MS. COMEY: Objection, your Honor. I didn't think that was what -- the witness said she didn't recall. 14 THE COURT: Sustained. 15 Q. Isn't it true that's what you said under oath in 2009? 16 MS. COMEY: A same objection. 17 THE COURT: Sustained. 18 Q. I'd like to show you, Carolyn, the answers to 19 interrogatories that you authored and swore to under oath in 20 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018791