{ "document_metadata": { "page_number": "143", "document_number": "1:20-cv-03339", "date": "02/24/22", "document_type": "court document", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cv-03339-PAE Document 612-2 Filed 02/24/22 Page 143 of 130\nA-5798\n341\nC2GFDAU3 Edelstein\n1 Q. You knew from the voir dire, didn't you, that the Catherine\n2 Conrad who sat as Juror No. 1 referred to being involved in a\n3 personal injury lawsuit, correct?\n4 A. Yes.\n5 Q. Did Theresa Trzaskoma tell you that document she had seen\n6 in the form of the Westlaw report had indicated Catherine M.\n7 Conrad as a party to a lawsuit?\n8 A. No.\n9 Q. Would you agree with me that you had the resources\n10 available to you, that all you had to do was pick up the phone\n11 and call Nardello or anyone else and ask them to go to a\n12 courthouse or do investigating for you to try to establish a\n13 link, or the link that Theresa Trzaskoma had suggested? Would\n14 you agree that you had those resources?\n15 A. We could have done that, but we didn't believe they were\n16 the same person. We thought --\n17 Q. So the answer is yes. You had those resources, right?\n18 It's a simple question.\n19 A. Yes, we could have called someone to investigate if we\n20 thought that there was a reason to investigate.\n21 Q. Now, after you received the juror letter that was sent to\n22 you, you did call Nardello in to assist you in gathering\n23 information, correct?\n24 A. Yes.\n25 Q. And that led to the preparation of your brief, correct?\n1 SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00009402", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cv-03339-PAE Document 612-2 Filed 02/24/22 Page 143 of 130", "position": "header" }, { "type": "printed", "content": "A-5798", "position": "header" }, { "type": "printed", "content": "341\nC2GFDAU3 Edelstein", "position": "header" }, { "type": "printed", "content": "1 Q. You knew from the voir dire, didn't you, that the Catherine\n2 Conrad who sat as Juror No. 1 referred to being involved in a\n3 personal injury lawsuit, correct?\n4 A. Yes.\n5 Q. Did Theresa Trzaskoma tell you that document she had seen\n6 in the form of the Westlaw report had indicated Catherine M.\n7 Conrad as a party to a lawsuit?\n8 A. No.\n9 Q. Would you agree with me that you had the resources\n10 available to you, that all you had to do was pick up the phone\n11 and call Nardello or anyone else and ask them to go to a\n12 courthouse or do investigating for you to try to establish a\n13 link, or the link that Theresa Trzaskoma had suggested? Would\n14 you agree that you had those resources?\n15 A. We could have done that, but we didn't believe they were\n16 the same person. We thought --\n17 Q. So the answer is yes. You had those resources, right?\n18 It's a simple question.\n19 A. Yes, we could have called someone to investigate if we\n20 thought that there was a reason to investigate.\n21 Q. Now, after you received the juror letter that was sent to\n22 you, you did call Nardello in to assist you in gathering\n23 information, correct?\n24 A. Yes.\n25 Q. And that led to the preparation of your brief, correct?", "position": "main" }, { "type": "printed", "content": "1 SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00009402", "position": "footer" } ], "entities": { "people": [ "Catherine Conrad", "Theresa Trzaskoma", "Nardello", "Edelstein" ], "organizations": [ "SOUTHERN DISTRICT REPORTERS, P.C." ], "locations": [], "dates": [ "02/24/22" ], "reference_numbers": [ "1:20-cv-03339", "A-5798", "C2GFDAU3", "DOJ-OGR-00009402" ] }, "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage." }