{ "document_metadata": { "page_number": "1", "document_number": "544", "date": "08/07/12", "document_type": "Affidavit", "has_handwriting": false, "has_stamps": false }, "full_text": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. PAUL M. DAUGERDAS, DONNA GUERIN, DENIS FIELD, and DAVID PARSE, Defendants. STATE OF NEW YORK ) COUNTY OF NEW YORK ) ss.: DAVID PARSE, being duly sworn, deposes and says: 1. My name is David Parse, and I am a defendant in the above-captioned case. 2. During jury selection (or shortly thereafter), I heard one of the lawyers at the Brune firm (I believe it was Theresa Trzaskoma) say that there was a prospective juror (or a juror) who had the same name as a suspended attorney but that it was not the same person. I cannot recall if the lawyer was speaking to me or if I overheard her speaking to someone else. 3. A week after the verdict, I met with the Brune lawyers to discuss possible post-trial motions and appellate issues. The possibility of a juror misconduct issue was not raised. 4. It was not until after the Brune firm filed its motion for a new trial that I learned that prior to jury deliberations the issue of Conrad being a suspended lawyer had resurfaced. More precisely, to the best of my memory, it was after the July 15, 2011 conference call that I learned (i) that on May 12, 2011, Ms. Trzaskoma had considered the possibility that Juror No. 1", "text_blocks": [ { "type": "printed", "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK", "position": "header" }, { "type": "printed", "content": "UNITED STATES OF AMERICA, v. PAUL M. DAUGERDAS, DONNA GUERIN, DENIS FIELD, and DAVID PARSE, Defendants.", "position": "header" }, { "type": "printed", "content": "STATE OF NEW YORK ) COUNTY OF NEW YORK ) ss.:", "position": "middle" }, { "type": "printed", "content": "DAVID PARSE, being duly sworn, deposes and says:", "position": "middle" }, { "type": "printed", "content": "1. My name is David Parse, and I am a defendant in the above-captioned case.", "position": "middle" }, { "type": "printed", "content": "2. During jury selection (or shortly thereafter), I heard one of the lawyers at the Brune firm (I believe it was Theresa Trzaskoma) say that there was a prospective juror (or a juror) who had the same name as a suspended attorney but that it was not the same person. I cannot recall if the lawyer was speaking to me or if I overheard her speaking to someone else.", "position": "middle" }, { "type": "printed", "content": "3. A week after the verdict, I met with the Brune lawyers to discuss possible post-trial motions and appellate issues. The possibility of a juror misconduct issue was not raised.", "position": "middle" }, { "type": "printed", "content": "4. It was not until after the Brune firm filed its motion for a new trial that I learned that prior to jury deliberations the issue of Conrad being a suspended lawyer had resurfaced.", "position": "middle" }, { "type": "printed", "content": "More precisely, to the best of my memory, it was after the July 15, 2011 conference call that I learned (i) that on May 12, 2011, Ms. Trzaskoma had considered the possibility that Juror No. 1", "position": "middle" } ], "entities": { "people": [ "David Parse", "Theresa Trzaskoma", "Conrad" ], "organizations": [ "Brune firm", "UNITED STATES DISTRICT COURT", "UNITED STATES OF AMERICA" ], "locations": [ "New York" ], "dates": [ "July 15, 2011", "May 12, 2011", "08/07/12" ], "reference_numbers": [ "1:09-cr-00581-WHP", "544", "S3 09 Cr. 581 (WHP)" ] }, "additional_notes": "The document appears to be a court filing, specifically an affidavit from David Parse. The text is clear and legible, with no visible redactions or damage." }