Case 1:20-cv-03038-PAE Document 616-1 Filed 02/24/22 Page 53 of 117
A-5820
363
C2grdau4 Schoeman - cross
1 A. Yes.
2 Q. That's what any good lawyer or investigator does when
3 somebody tells them a broad fact; you ask what supports that,
4 correct?
5 A. It's the question I asked.
6 Q. Do you disagree with my proposition that a good
7 investigator or lawyer, when somebody gives them a broad
8 proposition, asks the follow-up question, what is that based
9 on?
10 A. I don't disagree with it.
11 Q. Did you ask Ms. Trzaskoma what had led her to conclude or
12 what led to her belief that there was a possible connection
13 between Juror No. 1 and the suspended attorney?
14 A. I think she told me that there was someone with the same
15 name as Juror No. 1. I don't recall whether we actually used
16 the person's name. Then, as I described, I asked questions
17 about why she had determined it was not the same person, and
18 the answer was based on the voir dire responses.
19 Q. Is it correct that you didn't ask any other follow-up
20 questions that led to her initial belief that there was a
21 connection between Juror No. 1 and the suspended attorney?
22 A. I think all she told me was that they had the same name,
23 and I inferred that was the basis of her considering it
24 possible that they were the same person.
25 Q. Did she tell you that they had the same middle initials?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009424
@epsteinpedia
CA:
AEb4NmMJF2x5kcp19M13RiXZuAGyajWSKLaioqBrpump
Document A-5820
AI Analysis
Summary: The document is a transcript of Schoeman's cross-examination, where they discuss their investigation techniques and their conversation with Trzaskoma about a potential connection between Juror No. 1 and a suspended attorney. Schoeman confirms that they didn't ask follow-up questions about Trzaskoma's initial belief. The testimony highlights the limited basis of Trzaskoma's concern, which was a shared name.
Significance: This deposition transcript reveals the investigative techniques used by Schoeman and the basis of Trzaskoma's belief about a potential connection between Juror No. 1 and a suspended attorney.
Key Topics:
Investigation techniques
Juror No. 1 and suspended attorney connection
Witness testimony
Key People:
- Schoeman - Witness being cross-examined
- Trzaskoma - Person interviewed by Schoeman
Full Text
Case 1:20-cv-03038-PAE Document 616-1 Filed 02/24/22 Page 53 of 117
A-5820
363
C2grdau4 Schoeman - cross
1 A. Yes.
2 Q. That's what any good lawyer or investigator does when
3 somebody tells them a broad fact; you ask what supports that,
4 correct?
5 A. It's the question I asked.
6 Q. Do you disagree with my proposition that a good
7 investigator or lawyer, when somebody gives them a broad
8 proposition, asks the follow-up question, what is that based
9 on?
10 A. I don't disagree with it.
11 Q. Did you ask Ms. Trzaskoma what had led her to conclude or
12 what led to her belief that there was a possible connection
13 between Juror No. 1 and the suspended attorney?
14 A. I think she told me that there was someone with the same
15 name as Juror No. 1. I don't recall whether we actually used
16 the person's name. Then, as I described, I asked questions
17 about why she had determined it was not the same person, and
18 the answer was based on the voir dire responses.
19 Q. Is it correct that you didn't ask any other follow-up
20 questions that led to her initial belief that there was a
21 connection between Juror No. 1 and the suspended attorney?
22 A. I think all she told me was that they had the same name,
23 and I inferred that was the basis of her considering it
24 possible that they were the same person.
25 Q. Did she tell you that they had the same middle initials?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009424
--- PAGE BREAK ---
C2grdau4 Schoeman - cross 363
1 A. Yes.
2 Q. That's what any good lawyer or investigator does when
3 somebody tells them a broad fact; you ask what supports that,
4 correct?
5 A. It's the question I asked.
6 Q. Do you disagree with my proposition that a good
7 investigator or lawyer, when somebody gives them a broad
8 proposition, asks the follow-up question, what is that based
9 on?
10 A. I don't disagree with it.
11 Q. Did you ask Ms. Trzaskoma what had led her to conclude or
12 what led to her belief that there was a possible connection
13 between Juror No. 1 and the suspended attorney?
14 A. I think she told me that there was someone with the same
15 name as Juror No. 1. I don't recall whether we actually used
16 the person's name. Then, as I described, I asked questions
17 about why she had determined it was not the same person, and
18 the answer was based on the voir dire responses.
19 Q. Is it correct that you didn't ask any other follow-up
20 questions that led to her initial belief that there was a
21 connection between Juror No. 1 and the suspended attorney?
22 A. I think all she told me was that they had the same name,
23 and I inferred that was the basis of her considering it
24 possible that they were the same person.
25 Q. Did she tell you that they had the same middle initials?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010103
Individual Pages
Page 53 - DOJ-OGR-00009424
Page 363 - DOJ-OGR-00010103
C2grdau4 Schoeman - cross 363
1 A. Yes.
2 Q. That's what any good lawyer or investigator does when
3 somebody tells them a broad fact; you ask what supports that,
4 correct?
5 A. It's the question I asked.
6 Q. Do you disagree with my proposition that a good
7 investigator or lawyer, when somebody gives them a broad
8 proposition, asks the follow-up question, what is that based
9 on?
10 A. I don't disagree with it.
11 Q. Did you ask Ms. Trzaskoma what had led her to conclude or
12 what led to her belief that there was a possible connection
13 between Juror No. 1 and the suspended attorney?
14 A. I think she told me that there was someone with the same
15 name as Juror No. 1. I don't recall whether we actually used
16 the person's name. Then, as I described, I asked questions
17 about why she had determined it was not the same person, and
18 the answer was based on the voir dire responses.
19 Q. Is it correct that you didn't ask any other follow-up
20 questions that led to her initial belief that there was a
21 connection between Juror No. 1 and the suspended attorney?
22 A. I think all she told me was that they had the same name,
23 and I inferred that was the basis of her considering it
24 possible that they were the same person.
25 Q. Did she tell you that they had the same middle initials?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010103