{
  "document_metadata": {
    "page_number": "53",
    "document_number": "A-5820",
    "date": "02/24/2022",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case 1:20-cv-03038-PAE Document 616-1 Filed 02/24/22 Page 53 of 117\nA-5820\n363\nC2grdau4 Schoeman - cross\n1 A. Yes.\n2 Q. That's what any good lawyer or investigator does when\n3 somebody tells them a broad fact; you ask what supports that,\n4 correct?\n5 A. It's the question I asked.\n6 Q. Do you disagree with my proposition that a good\n7 investigator or lawyer, when somebody gives them a broad\n8 proposition, asks the follow-up question, what is that based\n9 on?\n10 A. I don't disagree with it.\n11 Q. Did you ask Ms. Trzaskoma what had led her to conclude or\n12 what led to her belief that there was a possible connection\n13 between Juror No. 1 and the suspended attorney?\n14 A. I think she told me that there was someone with the same\n15 name as Juror No. 1. I don't recall whether we actually used\n16 the person's name. Then, as I described, I asked questions\n17 about why she had determined it was not the same person, and\n18 the answer was based on the voir dire responses.\n19 Q. Is it correct that you didn't ask any other follow-up\n20 questions that led to her initial belief that there was a\n21 connection between Juror No. 1 and the suspended attorney?\n22 A. I think all she told me was that they had the same name,\n23 and I inferred that was the basis of her considering it\n24 possible that they were the same person.\n25 Q. Did she tell you that they had the same middle initials?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00009424",
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      "content": "Case 1:20-cv-03038-PAE Document 616-1 Filed 02/24/22 Page 53 of 117",
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    {
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      "content": "A-5820",
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    {
      "type": "printed",
      "content": "363",
      "position": "header"
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    {
      "type": "printed",
      "content": "C2grdau4 Schoeman - cross",
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      "type": "printed",
      "content": "1 A. Yes.\n2 Q. That's what any good lawyer or investigator does when\n3 somebody tells them a broad fact; you ask what supports that,\n4 correct?\n5 A. It's the question I asked.\n6 Q. Do you disagree with my proposition that a good\n7 investigator or lawyer, when somebody gives them a broad\n8 proposition, asks the follow-up question, what is that based\n9 on?\n10 A. I don't disagree with it.\n11 Q. Did you ask Ms. Trzaskoma what had led her to conclude or\n12 what led to her belief that there was a possible connection\n13 between Juror No. 1 and the suspended attorney?\n14 A. I think she told me that there was someone with the same\n15 name as Juror No. 1. I don't recall whether we actually used\n16 the person's name. Then, as I described, I asked questions\n17 about why she had determined it was not the same person, and\n18 the answer was based on the voir dire responses.\n19 Q. Is it correct that you didn't ask any other follow-up\n20 questions that led to her initial belief that there was a\n21 connection between Juror No. 1 and the suspended attorney?\n22 A. I think all she told me was that they had the same name,\n23 and I inferred that was the basis of her considering it\n24 possible that they were the same person.\n25 Q. Did she tell you that they had the same middle initials?",
      "position": "middle"
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009424",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Schoeman",
      "Ms. Trzaskoma"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "02/24/22"
    ],
    "reference_numbers": [
      "1:20-cv-03038-PAE",
      "A-5820",
      "616-1",
      "DOJ-OGR-00009424"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}