FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 01/05/2020 02:85 P
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCI EF DOC. NO. 141
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`IND
`EX NO.
`518796/2018
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`
`
` EIVE :D
` EF’:
`01/05/2020
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
` NYSCI
`
`"H"
`EXHIBIT "H"
`EXHIBIT
`
`

`

`FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
`Page
`
`1
`
`SUPREME
`
`COURT
`
`OF
`
`THE
`
`STATE
`
`OF
`
`NEW YORK
`
`COUNTY
`
`OF
`
`KINGS
`
`-----------------------------------------------x
`
`JOHN
`
`ROMANO,
`
`Plaintiff,
`
`-against-
`
`Index
`
`No:
`
`518796/18
`
`ALLSTAR
`
`SECURITY
`
`& CONSULTING,
`
`INC.,
`
`AVANT
`
`GARDNER,
`
`LLC
`
`D/B/A
`
`THE
`
`BROOKLYN
`
`MIRAGE
`
`AND
`
`"JOHN
`
`DOE"
`
`(THE
`
`NAME
`
`BEING
`
`FICTITIOUS
`
`AND
`
`INTENDED
`
`TO DESIGNATED
`
`THE
`
`BOUNCER
`
`WHO ASSAULTED
`
`PLAINTIFF),
`
`Defendants.
`
`-----------------------------------------------x
`
`EXAMINATION
`
`TRIAL
`
`of
`
`1
`
`2
`
`3
`
`4 5
`
`6 7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`BEFORE
`
`the
`
`Plaintiff,
`
`JOHN
`
`ROMANO,
`
`taken
`
`by
`
`the
`
`Defendant,
`
`pursuant
`
`to
`
`Court
`
`Order,
`
`held
`
`at
`
`50
`
`Court
`
`Street,
`
`Suite
`
`502,
`
`Brooklyn,
`
`New
`
`York
`
`11201,
`
`on
`
`December
`
`17th,
`
`2019,
`
`at
`
`of
`
`10:15
`
`a.m.,
`
`before
`
`a Notary
`
`Public
`
`of
`
`the
`
`State
`
`New
`
`York.
`
`*************************************************
`
`Job
`
`No.
`
`CS3819697
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`800-567-8658
`
`973410-4098
`
`Veritext
`
`Legal
`
`Solutions
`
`

`

`FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
`1 A P P E A R A N C E S:
`2
`3 LOUIS C. FIABANE
`Attorneys for Plaintiff
`304 East 49th Street
`New York, New York 10017
`VINCENT LOIODICE, ESQ.
`
`5 BY:
`
`4
`
`INC.
`
`9
`
`8 AHMUTY, DEMERS & MCMANUS
`Attomeys for Defandr.t
`ALLSTAR SECURITY & CONSULTING,
`200 I.U Willets Road
`Albertson, New York 1I507
`DAVID S. CONKLIN, ESQ.
`FILE #: AILl51SDSC
`
`10
`11 BY:
`12
`13
`14 PlLLINGER MILLER TARALLO, LLP
`Attorneys for Defendant
`AVANT GARDNER LLC d/b/a
`THE BROOKLYN MIRAGE
`555 Taxter Road, 5th Floor
`Elmsford, New York 10523
`NEIL VEILLEUX, ESQ.
`
`15
`
`16
`
`17 BY:
`
`20
`
`21
`
`22
`
`23
`24 BY:
`25
`
`LAW OFFICE OF THOMAS TONA, P.C.
`Attomeys for Defendant
`STANTON P. INC., DAVID VENDERHOFF
`AND KEVIN MCLEAN
`152 Islip Avenue, Suite I 8
`Islip, New York I1751
`CHRISTOPHER M. BECKER, ESQ.
`
`1
`
`ST1PUL ATI ONS:
`
`3 rrissnPULATEDANDAOREEDbyandbetweenthe
`4 attomeysfortherespectivepartiesherein.andin
`compliancewithRule221oftheUniformRulesfor
`5 theTrialCourtr
`6 THATthepartiesrecognizetheprovisionofRule
`3115subdivisions(b),(c)and/or(d).All
`7 objectionsmadestadepositionshallbenotedby
`theomcerbeforewhomthedepositionistaken,and
`8 theanswershallbegivenandthedepositionshall
`proceedsubjecttotheobjectionsandlatheright
`r proprlatereliefpursuant
`9 ofape
`toop
`
`10
`THATeveryobjectionraisedduringadeposition
`11shallbestatedsuccinctlyandframedsoasnotto
`suggestananswertothedeponemand,atthe
`12requestorthequestioningattomey,shallincludea
`clearstatementestoanydefecthtformorother
`13basisoferrororirregularity.Exceptgotheextent
`permittedbyCPLRRule3115orbythisrule,during
`14thecourseoftheexaminationpersonsinsttendance
`shallnotmakestatementsorcommentsthatinterfere
`
`6
`
`A a e o etttshallansweraliquestionsata
`dePosition.except6) topreserveaprivilege"
`17rightofcoltfldemiality,(ii) toenforcea
`limiiaisonsetforthinanorderofacourt.ar
`1II(Si)whenthequestionisplainlyirnproperand
`wotdd.if answered,causesignincantprejudiceto
`19anyperson.Anattorneyshallnotdirectadeponent
`nottoanswerexceptasprovidedinCPLRRule3115
`20 orthissubdivision.Anyrefusaltoansweror
`directionnottoanswershallbeaccompaniedbya
`21 succinctandclearstaternentonthebasisthererore.
`
`n
`
`s aj‡a
`i ngp
`dar°f'h'd'P°5itic"
`
`h?righta
`
`pÎetethe
`
`THATanattorneyshallnotinterruptthedeposition
`24 forthepurposeofconununicating
`25 withthedeponentunlessallpartiesconsentorthe
`
`Page2
`
`Page4
`
`1 communiensinnis made for the purpose of determining
`2 whether the question should not be answeredon the
`3 grounds set forth in Section
`4
`5 221.2 of these rules, and, in such event, the reason
`6 for the communication shall be statedfor the record
`7 succinctly and clearly.
`8 THAT the failure to object to any question or to
`Inove to strike any testimony at this exarnination
`9 shall not be a bar or waiver to make such objection
`or motion at the tirne of the trial of this action,
`10 and is hereby reserved; and
`I 1 THAT this examination may be signed and swom to by
`the witness examined herein before any Notary
`12 Public, but the failure to do so or to return the
`original of the examination to the attorney on whose
`13 behalf the e--i=tien
`is taken, shall not be deemed
`a waiver of the rights provided by Rule 31I6 and
`14 3117 of the CPLR, and shall be controlled thereby;
`and
`
`15
`
`THAT the certification and filing of the original of
`16 this examination are hereby waived; and
`17 THAT the questioning attorney shall provide counsel
`for the witriess examined herein with a copy of this
`18 examination at no charge.
`
`20
`21
`22
`23
`24
`25
`
`Page3
`
`Page5
`
`2 J O H N R O M A N O, the witness herein, having
`3 been first duly sworn by a Notary Public of the
`4 State OfNew York, was examined and testified as
`5 fOll OWs'
`6 EXAMINATION
`7 MR. CONKLHt
`State your name for the record, please.
`John Romano.
`State your address for the record, please.
`
`8 Q.
`
`9 A.
`
`10 Q.
`
`BY
`
`11 A.
`
`12
`
`14 A.
`
`13 Q.
`
`Good morning, Mr. Romano.
`Good morning.
`My name is Dave Conklin. Um a lawyer with
`15 Q.
`16 Ahmuty, Demers, Mcmanus. Um going to be asking you
`17 questions this morning probably into the afternoon
`18 regarding your claim. There are some rules that go
`10 p War
`r de S
`Ï 9
`
`20 thern with you now.
`
`21 A.
`
`Okay.
`Really number one rule, make sure you
`22 Q.
`23 understand what Um asking you.
`24 A.
`Yes.
`If you don't understand me, or you don't
`
`25 Q.
`
`800-567-8658
`
`Veritext
`
`Legal
`
`SolutiOns
`
`2 (Pages
`
`2 -
`
`5)
`
`973-410-4098
`
`

`

`FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
`Page6
`
`Page8
`
`by the quaden,
`re ask
`and I'll
`know,
`
`let
`
`J. ROMANO
`1
`2 hear me or you're just confused
`3 me know or let your attorney
`4 the question?
`Yes, sir.
`So speak up.
`Yes, sir.
`If you answer
`
`5 A.
`
`6 Q.
`
`7 A.
`
`8 Q.
`
`I'm going to
`the question,
`it and I'm going to move
`9 assume that you understood
`10 on.
`
`11 A.
`
`Okay.
`
`12 Q.
`
`Okay.
`
`Also,
`not a conversation.
`13 session;
`let me get me questien
`14 is,
`15 A.
`
`this is kind of a question
`and answer
`I mean by that
`out before you answer.
`
`What
`
`16 Q.
`
`17 figure
`
`18 me get
`
`About
`
`half way through,
`you're going to
`to get
`from you, but
`out what
`I'm trying
`it all on the record and then you answer.
`
`let
`
`19 A.
`
`20 Q.
`
`Okay.
`
`The court
`
`reporter
`
`cannot
`
`take us down at
`
`21 the same time.
`
`22 A.
`
`I feel you.
`I'm going to let you finish your answer
`23 Q.
`24 before I ask you a new one.
`
`Okay.
`
`1
`
`J. ROMANO
`2 and be can used as trial
`
`tcstimony?
`
`3 A.
`
`Yes.
`
`MR. CONKLIN:
`
`Counsel
`
`for Stanton
`
`Inc. want
`
`P.I.,
`before we begin.
`
`to place a quick
`statement
`You don't have to worry
`stuff.
`It's lawyer
`
`about
`
`that.
`
`you. Stanton
`
`and Kevin Mclean
`
`MR. BECKER:
`Thank
`INC, David Venderhoff
`P.I.,
`to today's
`object
`deposition
`going
`the medical
`as we only received
`at approximately
`1:30 p.m. We
`yesterday
`reserve our
`to any further
`right
`if we are not provided
`the medicals
`all
`
`forward
`
`records
`
`depositions
`
`or
`
`further
`
`review of
`
`need for
`
`further
`
`issues.
`
`the records presents the
`on any other
`
`questioning
`
`MR. CONKLIN:
`
`Allstar
`
`and I will
`
`join,
`made a demand for prior
`
`Dave Conklin
`
`for
`just note that we
`
`treatment
`
`because I
`
`think
`
`there is some prior
`
`treatment
`
`that we
`
`wanted to take a look at before the
`
`reserve
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`25 A.
`
`but we haven't. We'll
`deposition,
`and we can work
`our
`right accordingly,
`through
`that.
`
`Page7
`
`Page9
`
`1
`
`J. ROMANO
`If
`I cut you off,
`let me know.
`2 Q.
`just
`Say,
`3 "Mr. Conklin,
`or counsel,
`f'mished with my
`4 answer,"
`and give me your complete
`answer.
`Okay.
`5 A.
`
`I wasn't
`
`6 Q.
`
`I don't want you to guess to anything.
`to a question,
`7 you don't know the answer
`and I'll move on.
`8 me you don't know,
`Okay.
`9 A.
`
`just
`
`If
`
`tell
`
`10 Q.
`
`it
`
`if you're not a hundred
`However,
`11 but have you an idea of what
`is, just
`or géñcrdizing,
`
`12 you're
`
`-wthg
`
`percent,
`tell me
`
`but you're not
`
`appr
`13 being specific.
`14 A.
`Okay,
`kind of
`You're
`in charge here.
`15 Q.
`16 to take a break at any time,
`Okay.
`17 A.
`walk around,
`To use the bathroom,
`The only time we don't do that
`19 me know.
`just answer
`20 have a questioning
`the
`pending,
`21 question.
`
`1
`
`2
`
`J. ROMANO
`MR. VEILLEUX:
`
`On behalf of Avant
`
`3
`
`4
`
`I join in that
`
`request
`
`for
`
`the
`
`Gardner,
`LLC,
`authorizations
`the prior medical.
`for
`I'm going to start with some background
`5 Q.
`6 questions. We ask these of everyone,
`so don't
`7 offense.
`
`take
`
`8 A.
`
`9 Q.
`
`10
`
`I1 A.
`
`12 Q.
`
`13
`
`14 A.
`
`15 Q.
`
`Okay.
`
`What
`
`is your date of birth?
`
`MR, LOIODICE:
`
`Just
`
`the year.
`
`XX-XX-199L
`Can I ask your Social Security
`MR. CONKLIN:
`
`Nothing
`
`number?
`
`on the record.
`
`XXX-XX-XXXX.
`
`You gave us an of
`
`16 have you lived there?
`
`Two years.
`
`Who do you live there with?
`
`Myself.
`
`Where
`
`did you live before that?
`
`17 A.
`
`18 Q.
`
`19 A.
`
`20 Q.
`
`21 A.
`
`22 Q.
`
`23 A.
`
`24 Q.
`
`25 A.
`
`that's fair.
`
`If you want
`
`just
`
`let me know.
`
`just
`
`is if
`
`let
`
`I
`
`18 Q.
`
`22 A.
`
`23 Q.
`
`24 A.
`
`25 Q.
`
`Okay.
`With that, we're going to begin.
`Let's start.
`
`You understand
`
`your
`
`testimony
`
`is under oath
`
`Where?
`
`In an apartment
`
`b
`
`ng.
`
`What apartment?
`
`6F.
`
`800-567-8658
`
`Veritext
`
`Legal
`
`Solutions
`
`..
`
`3 (Pages
`
`6 -
`
`9)
`
`973-410-4098
`
`

`

`FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
`Page 10
`
`Page 12
`
`1
`
`2 Q.
`
`3 A.
`
`4 Q.
`
`5 A.
`
`6 Q.
`
`7 A.
`
`J. ROMANO
`
`Is that Brooklyn?
`
`Yés.
`
`What was the zip?
`
`I think.
`11002,
`How long did you live there?
`For a year.
`
`How about before that?
`Long Island.
`Where about?
`66 Route 106, Jericho, New York
`Who did you live with there?
`My family.
`How long did you live there?
`Ten years.
`When you say your
`17 consist of?
`My mom, my dad, my two sisters and my
`19 grandma.
`
`I1753.
`
`family, who does that
`
`8 Q.
`
`9 A.
`
`10 Q.
`
`11 A.
`
`12 Q.
`
`13 A.
`
`14 Q.
`
`15 A.
`
`16 Q.
`
`18 A.
`
`20 Q.
`
`21 A.
`
`22 Q.
`
`23 A.
`24 Q.
`
`25 A.
`
`1
`
`2 Q.
`
`3 A.
`
`4 Q.
`
`1
`
`2 Q.
`
`3 A.
`
`J. ROMANO
`
`So a couple months ago?
`
`Yes.
`
`4 Q.
`
`What were you on prchatica for?
`For -- I had a drug charge, someone set me
`5 A.
`6 up with something.
`It was a CI.
`What do you mean CI?
`7 Q.
`
`8 A.
`
`Informant.
`
`9 Q.
`
`10 A.
`
`Did you plead guilty, or were you convicted?
`it was a misdemeanor.
`I pled guilty, but
`11 Q.
`Right, so what misdessmor
`drug charge did
`12 you plead guilty to?
`the exact charge was.
`13 A.
`I'm not sure what
`What county was it in?
`Brooklyn.
`
`14 Q.
`
`15 A.
`
`16 Q.
`
`17 A.
`
`When was it that you pled guilty?
`
`February.
`
`18 Q.
`
`19 A.
`
`20 Q.
`
`2019?
`Yes, sir.
`What was the violation of the prob::ticn?
`I wound up getting a DV for being at my
`21 A.
`22 son's baseball game because my ex-wife chased me and
`23 said she had to get a shovel.
`24 Q.
`DV, what does that mean?
`Domestic violence.
`It wasn't DV;
`
`25 A.
`
`it was a
`
`What's
`
`your mom's name?
`
`Roxanne.
`
`Your dad?
`
`Paul.
`
`Just gcacrally,
`Yes.
`
`do your mom and dad work?
`
`J. ROMANO
`What does your mom do?
`
`She's a financial
`
`advisor.
`
`business.
`
`Page 11
`
`I
`
`2 violation
`
`of
`
`J. ROMANO
`the order of pretcctién.
`
`l'm sorry
`
`Page13
`
`3 about
`
`4 Q.
`
`that.
`So you were previously
`Yes.
`
`married?
`
`How about your dad?
`He owns a plumbing
`the name?
`What's
`Ro-Sal Plumbing
`How tall are you?
`
`and Heating.
`
`6-4.
`
`How much do you weigh?
`
`184.
`
`Right-handed
`
`or left?
`
`Right-handed.
`
`Do you wear glasses or contacts?
`
`No.
`
`5 A.
`
`6 Q.
`
`7 A.
`
`8 Q.
`
`9 A.
`
`10 Q.
`
`11 A.
`
`12 Q.
`
`13 A.
`
`14 Q.
`
`15 A.
`
`5 A.
`
`6 Q.
`
`7 A.
`
`8 Q.
`
`9 A.
`
`10 Q.
`
`11 Nicole?
`
`12 A.
`
`13 Q.
`
`14 A.
`
`15 Q.
`
`When were you married?
`
`I was married
`
`in 2014.
`
`Who were you married
`Nicole Silverstein.
`During what years were you married
`
`to?
`
`to
`
`Eight months.
`Are you currently
`Yes.
`
`divorced
`
`formally?
`
`You mennoñéd
`
`a son;
`
`is that your only
`
`Have you ever been convicted
`16 Q.
`17 to a felony
`18 A.
`Misdemeanor,
`What was the misdemeanor?
`
`or misdemeanor?
`
`yes.
`
`or pled guilty
`
`16 child?
`
`17 A.
`
`18 Q.
`
`Yes.
`I'm not going to ask his name, but how old
`
`19 Q.
`
`20 A.
`
`21 Q.
`
`22 A.
`
`23 Q.
`
`24 A.
`
`What's
`
`called violation
`
`of probation.
`
`When was that?
`
`September.
`
`This year?
`Yeah - September
`
`of
`
`-- this - when the
`
`25 football
`
`season started.
`
`19 is he?
`
`20 A.
`
`21 Q.
`
`22 A.
`
`5.
`Are you presently
`Yes.
`
`23 Q.
`
`About whom?
`24 A.
`Ro-Sal Plumbing
`independent
`25 record label,
`
`800-567-8658
`
`Veritext
`
`Legal
`
`Solutions
`
`employed?
`
`and Heating,
`and Roman 23
`Roman
`
`and I have a
`
`4 (Pages
`
`10 -
`
`13)
`
`973-410-4098
`
`

`

`FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
`I
`
`J. ROMANO
`
`2 ind-p:ndont
`
`labels.
`
`3 Q.
`
`4 A.
`
`5 Q.
`
`that's your dad's business?
`
`Ro-Sal,
`Yes.
`
`Who do you do for
`
`them?
`
`I was a head foreman
`them, but after
`for
`6 A.
`I wasn't able to carry or lift
`and so
`7 this,
`things,
`let me do it, so I'm
`8 and my doctor wouldn't
`supervising.
`9 basically
`10
`
`Move to strike as
`
`MR. BECKER:
`
`nonresponsive.
`
`currently
`
`employed
`
`by Ro-Sal?
`
`You're
`
`Yes.
`
`What
`
`is your
`
`current
`
`title?
`
`11
`
`12 Q.
`
`13 A.
`
`14 Q.
`15 A.
`
`Page 4
`
`I
`
`Page 16
`
`J. ROMANO
`that, but did you go to the
`I understand
`where the main high school building was or
`building?
`
`2 Q.
`3 ini!ding
`4 a different
`
`5 A.
`
`At
`
`first,
`6 and then a different
`
`I went
`
`to the high school building
`called EAC.
`building
`
`7 Q.
`
`8 A.
`
`What
`is that?
`Just EAC,
`9 of
`like special ed type.
`to do that.
`so it was easier
`10 concan.trati=g
`Did you have any vocational
`I1 Q.
`classes?
`12 or just normal
`
`just
`
`like an easier
`
`-- like a kind
`I had problems
`
`training
`
`there
`
`13 A.
`
`14 Q.
`
`15 A.
`
`16 Q.
`
`Normal
`
`classes.
`
`What year did you attended the EAC program?
`
`From 2006 to 2008.
`
`and senior?
`
`assistant.
`Supei-visor/fereman's
`How long have you held that
`Since I came back three months after
`
`job title?
`
`the
`
`16 Q.
`
`17 A.
`
`I8
`
`incident.
`
`19 Q.
`
`Is Ro-Sal
`
`a commercial
`
`plumbing
`
`company,
`
`20 residential
`
`or both?
`
`Commercial.
`
`Is it a union shop?
`
`17 A.
`
`18 Q.
`
`19 A.
`
`20 Q.
`
`21 A.
`
`22 Q.
`
`As a junior
`
`Yes.
`
`Did you graduate
`
`from Jericho High School?
`
`Yes.
`
`What year did you graduate?
`
`2008.
`
`Thank
`
`you. After
`
`Jericho High School, where
`
`21 A.
`
`22 Q.
`
`23 A.
`
`24 Q.
`
`25 work
`
`1
`
`2 A.
`
`3 Q.
`
`Nonunion.
`
`Currently,
`there?
`
`Forty.
`
`Monday
`Yes.
`
`how many hours per week do you
`
`I went
`
`23 did you go next?
`- well,
`24 A.
`to Boston College
`it was
`and I just--
`to Boston College,
`
`25 Anna Marie
`
`next
`
`J. ROMANO
`
`through
`
`Friday?
`
`Page 15
`
`1
`
`J. ROMANO
`it wasn't
`and if
`something
`-- so I started
`
`I
`
`I
`
`Page 17
`
`7:00
`
`to 3:00?
`
`Yes.
`
`2 had problems
`focusing,
`didn't
`I really
`3 wanted to do,
`for my dad instead.
`4 working
`MR. LOIODICE:
`5
`
`6
`
`question
`
`he asks.
`
`Only answer
`
`the
`
`Where
`
`does
`
`that
`
`job
`
`take you primarily?
`
`7 Q.
`
`Did you go to a school
`
`known
`
`as Dimend
`
`4 A.
`
`5 Q.
`
`6 A.
`
`7 Q.
`
`8 A.
`
`9 Q.
`
`10 A.
`
`11 Q.
`
`12 A.
`
`13 Q.
`
`14 A.
`
`15 Q.
`
`Take me?
`
`Do you go to the job
`
`sites?
`
`Yes.
`
`Where
`
`All
`
`are they
`over.
`Coney
`the five
`
`generally?
`
`Island
`
`to the Bronx.
`
`boroughs?
`
`Mainly
`Just
`five
`
`boroughs.
`
`What
`
`is your
`
`highest
`
`level
`
`of education?
`
`bit of
`
`8 Ranch?
`
`9 A.
`
`Yes.
`
`10 Q.
`
`When did you go there?
`-
`That was actually
`that was my last year,
`11 A.
`about
`forgot
`12 my senior year.
`that. My
`I ccmp'ctc|y
`13 parents sent me there when I was a kid.
`last year of high school?
`That was your
`there, but
`
`14 Q.
`
`15 A.
`
`I gradnited
`
`it was a Jericho
`
`16 A.
`17 college,
`18 Q.
`
`19 A.
`20 Q.
`
`I completed
`
`high
`
`school
`
`I never
`
`finished
`
`year.
`
`and little
`my first
`did you go to high
`school?
`
`but
`
`Where
`
`Jericho
`
`High
`
`School.
`
`Were
`
`at Jericho
`four
`years
`all
`High
`or did you go to any other
`I went
`to Jericho.
`
`16 Diploma.
`
`17 Q.
`
`Between
`
`like 17 and 18 you went
`
`to Diamond
`
`18 Ranch?
`
`19 A.
`
`Yes.
`
`Schoo
`
`20 Q.
`
`Where was that
`
`located?
`
`21 A.
`
`22 Q.
`
`Utah.
`Why did they send you there?
`help me because -
`it would
`23 A.
`They thought
`I
`in Long Island.
`24 don't know I was upset about
`living
`
`21
`
`on 106-107
`
`22 A.
`
`23 Q.
`
`No,
`Did you
`
`locations
`
`ever go to an out of district
`
`24
`
`placement
`
`while
`
`25 A.
`
`Yeah,
`
`but
`
`attending
`still
`it was
`
`Jericho?
`
`Jericho
`
`High
`
`School.
`
`25 I don't know.
`
`800-567-8658
`
`Veritext
`
`Legal
`
`Solutions
`
`5 (Pages
`
`14 -
`
`17)
`
`973-410-4098
`
`

`

`FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
`Page 18
`
`Page20
`
`1
`
`2 Q.
`
`3 classified
`
`J. ROMANO
`to high school, were you
`When you went
`disability?
`a learning
`as having
`
`4 A.
`
`Yes.
`
`When were you classified
`5 Q.
`6 learning
`When I was nine.
`7 A.
`
`disability?
`
`as having
`
`a
`
`8 Q.
`
`9 A.
`
`Where were you goingtoschoolatthe
`
`time?
`
`Saint Helens.
`
`10 Q.
`
`Where
`
`is that?
`
`1
`
`2 Q.
`
`3 A.
`
`4 Q.
`
`5 A.
`
`6 Q.
`
`J. ROMANO
`How do you spell
`
`that?
`
`S-A-U-L.
`
`Is that his first name or last name?
`Last name.
`
`it's Lawrence
`
`I think
`
`Saul.
`
`What
`
`type of doctor was he?
`
`7 A.
`
`8 Q.
`
`A specialist with brain injuries.
`Do you recall any other doctors?
`I've seen so many - no, you're talking
`10 about when I was nine?
`
`9 A.
`
`11 A.
`
`12 Q.
`
`Howard
`Beach.
`Is that where the family
`13 to Brookville?
`
`lived before moving
`
`Yes.
`
`11 Q.
`
`12 A.
`
`13 Q.
`
`about when you lived in
`
`14 A.
`
`15 Q.
`
`16 wait
`
`Yes.
`
`Just
`
`remember,
`it out on the record.
`for me to get
`
`question
`
`and answer.
`
`17 A.
`
`Okay.
`
`18 Q.
`
`19 A.
`
`20 Q.
`
`What years did you live in Howard
`From '91 to 2004.
`The family moved
`21 Brookville?
`
`I don't
`remember.
`No,
`We're talking
`14 Bayridge.
`
`Just
`
`15 A.
`
`Okay.
`
`Before
`16 Q.
`you told me
`you moved to Brookville,
`17 that you saw Dr. Saul who was the brain injury
`18 specialist?
`
`Beach?
`
`from Howard Beach to
`
`there.
`
`22 A.
`
`Yeah, directly
`you told us about when you
`23 Q.
`Saint Helens,
`24 were nine; you were climailiod with a learning
`Was that a catholic
`25 disability.
`school?
`
`1
`
`2 A.
`
`3 Q.
`
`4 A.
`
`J. ROMANO
`
`school?
`
`Page 19
`
`19 A.
`
`Yes.
`Did you sustain a brain injury
`21 were in the 9th grade?
`
`20 Q.
`
`before you
`
`When I was nine years old.
`
`What happened?
`I was hit by a car
`In Bayridge?
`
`in front of my house.
`
`J. ROMANO
`Beach.
`
`In Howard
`
`I never
`
`lived
`
`in the
`
`Page21
`
`22 A.
`
`23 Q.
`
`24 A.
`
`25 Q.
`
`1
`
`2 A.
`
`4 Q.
`
`Yes.
`That was elementary
`Yes.
`
`Were you in Saint Helens
`
`immediate
`
`before
`
`to Brookville?
`
`8 Bayridge
`
`No.
`
`I had to go to another
`school
`in
`because I couldn't
`keep up with the class.
`
`9 Q.
`
`10 A.
`
`What
`
`school was that?
`
`Bayridge
`
`Prep.
`
`5 Q.
`6 moving
`7 A.
`
`What years did you go to Bayridge
`2003 to 2006 -- no,
`12 A.
`13 to eighth grade so -
`When you were -
`14 Q.
`2002 to 2004.
`
`11 Q.
`
`15 A.
`
`Prep?
`
`it was from sixth grade
`
`16 Q.
`
`When you were still
`
`do
`
`3 Bayridge.
`I'm sorry. What
`That was my mistake.
`you got hit by the car?
`when
`5 happened
`feet
`in the air and landed
`thirty
`
`on
`
`6 A.
`I went
`7 my head.
`I take it an ambulance
`8 Q.
`
`came?
`
`9 A.
`
`10 Q.
`
`11 A.
`
`12 Q.
`
`13 A.
`
`14 Q.
`
`Yes.
`
`And
`
`Yes.
`
`they
`
`took
`
`you to a hospital?
`
`What
`
`hospital
`
`were
`
`you taken
`
`too?
`
`Jamaica
`
`first.
`
`How long
`I don't
`recall,
`Institute.
`to Rusk
`
`but
`
`there?
`did you spend
`they had to move me
`
`You
`
`there?
`
`living
`17 you recall who your pediatrician
`
`in Bayridge,
`was?
`
`18 A.
`
`No.
`
`do
`in Bayridge,
`When you were still
`19 Q.
`living
`that you may have
`20 you recall any of
`the doctors
`21 treated with when you lived there?
`I was going to doctors
`the names of
`23 Q.
`Do you recall
`24 were seeing in the City?
`25 A.
`Dr. Saul was his name.
`
`22 A.
`
`in the City.
`
`the doctor
`
`you
`
`15 A.
`16 quickly
`17 Q.
`
`18 A.
`
`19 Q.
`
`20 A.
`
`did rehabilitation
`
`I was there.
`Yes,
`How long were
`I don't
`know.
`really
`
`I was a couple
`
`of places.
`
`you at Rusk?
`
`I was out
`
`for
`
`like
`
`21 three months.
`
`22
`
`23
`
`MR.
`
`LOIODICE:
`
`Only
`
`answer
`
`the
`
`question
`
`he asks.
`
`24 Q.
`
`Was there
`
`a period
`
`of
`
`time
`
`you lost
`
`25
`
`consciousness
`
`as a result
`
`of
`
`the accident?
`
`800-567-8658
`
`Veritext
`
`Legal
`
`Solutions
`
`6 (Pages
`
`18 -
`
`21)
`
`973-410-4098
`
`

`

`FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
`L ROMANO
`from when it happened
`
`Yes,
`
`I
`
`2 A.
`
`3 later.
`
`Page22
`
`Page24
`
`1
`
`J. ROMANO
`
`to about
`
`ten days
`
`2 you recall who else treated you as a result of
`
`the
`
`3 that accident when you were nine?
`
`4 A.
`
`5 Q.
`
`6 you're
`
`Not
`really.
`Then the family moves to Brookville
`in 9th grade?
`
`when
`
`7 A.
`
`Yes.
`
`11 Q.
`
`8 Q.
`Did you continue
`treating with the doctors
`9 you had been treating with in the City?
`10 A.
`I did, yes.
`than Dr. Saul, do you recall any of
`Other
`you cañtiñüéd
`12 the doctors
`treating with?
`I started meeting with this guy Dr. Karceski
`13 A.
`seizures.
`14 because I was having
`15 Q.
`Do you how to spell
`that?
`K-A-R -- I'm not sure -- S-E-S-K-I.
`located?
`Where is Dr. Karceski
`
`16 A.
`
`17 Q.
`
`18 A.
`
`19 Q.
`
`20 A.
`
`Comell.
`What age did you start developing
`Since I was nine.
`
`seizures?
`
`21 Q.
`
`Since the car accident?
`22 A.
`saw it while
`I was in the coma. They
`They
`23 saw seizure activity when I just came out of
`it
`24 because the EG.
`
`4 Q.
`
`Do you recall how long you did inpatient
`5 rehabilitation?
`
`and I believe
`
`at the time it
`
`6 A.
`
`8 Q.
`
`Three months,
`7 was New York Presbyterian
`I think.
`Okay. Did you have a surgery
`9 the accident?
`
`as a result of
`
`10 A.
`
`12 Q.
`
`leg. They to inflate
`I had a broken
`11 drain blood
`out of my brain.
`Do you know if
`they referred
`
`--
`
`to it as a
`
`13 craniotomy?
`
`14 A.
`
`What
`is that?
`Where they basically
`16 to relieve pressure.
`
`15 Q.
`
`17 A.
`
`I don't know.
`
`have to open the skull
`
`Do you have a scar
`from that?
`In the back of my head. Over here -- my
`19 A.
`20 neck, and I have scars here because they had to put
`21 metal
`rods in my leg.
`MR. LOIODICE:
`
`18 Q.
`
`22
`
`Indicating
`
`his left
`
`23
`
`24 A.
`
`25 Q.
`
`leg.
`
`Broke my femur.
`Was there a lawsuit
`
`1
`
`J. ROMANO
`
`2 accident?
`
`3 A.
`
`Yes.
`
`as a result of
`
`this
`
`25 Q.
`
`Did you have seizures before the car
`
`Page23
`
`Page25
`
`J. ROMANO
`
`1
`
`2 accident?
`
`3 A.
`
`No.
`
`Was the lawsuit
`
`in Brooklyn?
`
`Queens.
`
`That case settled?
`Settled a long time ago.
`Did you give testimony
`
`No.
`
`like you did here
`
`No, you don't scmcmber,
`remember.
`I don't
`
`or no, you did not?
`
`Do you recall
`
`the name of
`
`that
`
`lawsuit?
`
`No.
`
`Do you recall who the defendant was?
`parents'
`I believe my
`insurance.
`The car that hit you, did it
`It stopped.
`
`take off?
`
`the car was sued?
`
`Do you know if
`They weren't
`Do you know why?
`
`sued.
`
`I don't know.
`
`I wasn't
`
`in charge at this
`
`4 Q.
`
`5 A.
`
`6 Q.
`
`7 A.
`
`8 Q.
`
`9 today?
`
`I0 A.
`
`11 Q.
`12 A.
`
`13 Q.
`
`14 A.
`
`15 Q.
`
`16 A.
`
`17 Q.
`
`18 A.
`
`19 Q.
`
`20 A.
`
`21 Q.
`
`22 A.
`
`23 time.
`
`24 Q.
`
`25 hospital
`
`I understand.
`than Dr. Saul,
`the
`that you told me about, Rusk Institute,
`
`Other
`
`do
`
`4 Q.
`
`Dr. Karceski,
`5 seizures?
`
`he treated you for
`
`the
`
`6 A.
`
`7 Q.
`
`8 A.
`
`9 Q.
`
`Yes.
`
`Did he put you on medication?
`
`Yes.
`
`What medication?
`
`There is a huge list.
`I've prebpbly
`10 A.
`you can think of.
`11 almost every concoction
`12 until 2016 for him to actually
`13 was seizure-less
`two years.
`for
`Meaning where the medic::tions
`15 seizures?
`
`been on
`
`It
`
`took
`
`get
`
`to work where I
`
`14 Q.
`
`controlled
`
`the
`
`16 A.
`
`17 Q.
`
`I didn't have any at all.
`Yes,
`Can you tell me what
`time period you were
`
`18 seizure free?
`
`19 A.
`
`seizure in 2016 that
`I had a nine-hour
`they
`20 couldn't
`stop. They had to put me in a coma, and
`21 11 days later,
`I woke up.
`I had to learn how to
`that stuff again, and I didn't have any
`do all
`22 walk,
`I was great. Nothing.
`23 seizures
`two years.
`It
`for
`and then after
`24 was amazing,
`that night,
`25 September
`I started having
`them, and I've had
`
`9th,
`
`800-567-8658
`
`Veritext
`
`Legal
`
`Solutions
`
`7 (Pages
`
`22 -
`
`25)
`
`973-410-4098
`
`

`

`FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
`Page26
`
`Page28
`
`1
`
`J. ROMANO
`
`2 them since.
`
`3 Q.
`
`4 nine-hour
`
`So you told me about 2016 you had a
`seizure, where were you treated then in
`
`5 20167
`
`6 A.
`
`7 Q.
`
`I woke up in Cornell.
`In the City?
`
`8 A.
`
`Yes,
`9 had the seizure.
`
`I went
`
`through
`
`sheetrock wall when I
`
`10
`
`11
`
`12 Q.
`
`13 A.
`
`14 Q.
`
`Only answer
`MR. LOIODICE:
`question
`he asks you, John.
`Were you working
`at the time?
`Yes.
`
`the
`
`Was that
`
`for Ro-Sal
`
`you were working?
`
`15 A.
`
`Yes.
`As a result of having
`16 Q.
`17 file a workers'
`comp claim?
`Yes.
`18 A.
`
`that seizure, did you
`
`precipitate
`
`that seizure in
`19 Q.
`Did something
`20 2016 or did it come on spontaneously?
`They said it could have always happened
`22 the car accident.
`What
`I'm trying
`of steps or -
`No, no.
`I was actually
`
`21 A.
`
`23 Q.
`
`24 a flight
`
`25 A.
`
`from
`
`to ask is, did you fall down
`
`getting my car.
`
`1
`2 Picking
`3 Q.
`
`4 A.
`
`J. ROMANO
`it up and the lady said I went
`correct?
`convulsing,
`Indicating
`Yeah.
`
`-
`
`Page27
`
`I
`
`2
`
`3
`
`J. ROMANO
`
`MR. LOIODICE:
`
`You can't go off
`
`the
`
`record.
`
`4 A.
`
`I was on tons of=dication.
`
`Thars why I
`5 had to change schools. The walls were moving.
`I
`6 was -- they had me drugged out when I was nine-years
`7 old like on crazy stuff, so I was like I can't do
`8 this.
`I can't think, so I stopped and that's when
`9 the seizum happened, but everything was beautiful
`10 after that when I staned the Keppra.
`So between 2013 and 2016, you felt better
`11 Q.
`the medication?
`12 being off
`13 A.
`Yes.
`
`I would classify as a
`seizure in 2016?
`
`14 Q.
`Then you had what
`15 pretty significant
`16 A.
`Yes.
`Then you wind up in the hospital?
`Yes.
`That's when you really you needed to go back
`20 on med
`tion, so that doesn't happen again?
`21 A.
`22 Q.
`
`17 Q.
`
`18 A.
`
`19 Q.
`
`23 A.
`
`24 Q.
`
`25 A.
`
`1
`
`2 Q.
`
`3 A.
`
`4 Q.
`
`Yes.
`They put you on Keppra?
`Yes.
`
`Who prescribed that?
`Dr. Karceski, and 2,000 minigrams a day.
`
`Page29
`
`J. ROMANO
`
`Had you ever been on that before?
`
`No.
`
`I believe
`
`you said that when you were in the
`
`Did an arabülance
`
`take you to Cornell?
`
`5 hospital
`
`in 2016 you were in a coma for a period of
`
`Yes.
`
`5 Q.
`
`6 A.
`
`7 Q.
`
`6 time?
`
`7 A.
`
`8 Q.
`
`9 A.
`
`10 Q.
`
`11 A.
`
`Yes.
`
`How long?
`
`11 days.
`
`Was that an induced
`
`coma?
`
`Yes.
`
`12 Q.
`
`they took you out of
`the 11 days,
`13 coma to see how you were doing?
`
`After
`
`the
`
`14 A.
`
`15 Q.
`
`16 that?
`
`Yes.
`How long did you stay in the hospital
`
`for
`
`17 A.
`
`About
`
`two weeks.
`18 Q.
`you were released from the hospital,
`After
`19 they sent you to the rehab facility?
`Yes.
`20 A.
`
`21 Q.
`
`22 A.
`
`23 Q.
`24 A.
`
`25 Q.
`
`What
`
`rehab facility?
`
`recall.
`I don't
`How long were you there?
`Two weeks.
`They had to teach you how to walk?
`
`When you went
`to Cornell New York
`you were already on the antiseizure
`correct?
`taking them at the time.
`I wasn't
`I stopped seeing all
`this point,
`I would
`go, but
`take the
`I wouldn't
`and then this is when Keppra
`
`8 Presbyterian,
`9 medication,
`10 A.
`
`No,
`11 stopped.
`
`At
`
`12 doctors.
`
`13 medication
`
`I
`
`the
`
`came and
`
`14 saved me.
`
`15 Q.
`
`Dr. Karceski,
`
`you were seeing him prior
`
`to
`
`16 2016?
`
`17 A.
`
`Yes.
`
`When was the last
`18 Q.
`time,
`19 that you saw him before 2016?
`20 A.
`2013 maybe.
`
`if you remember,
`
`21 Q.
`
`If
`
`22 prescribed
`
`23 not
`
`24 A.
`
`25 feeling.
`
`you correctly,
`he had
`I understand
`but you were
`you antiseizure medicaticñs,
`them?
`taking
`I was taking
`Honestly,
`
`them.
`
`I didn't
`
`if we can go off
`
`like how I was
`the record -
`
`800-567-8658
`
`Veritext
`
`Legal
`
`Solutions
`
`8 (Pages
`
`26 -
`
`29)
`
`973-410-4098
`
`

`

`FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
`Page30
`
`Page32
`
`1
`
`2 A.
`
`3 Q.
`
`J. ROMANO
`I had to walk
`before I left of
`
`The rehabilitation
`
`facility,
`
`they
`
`the hospital.
`ma+ina-1
`
`4 to work on that
`
`I take it?
`
`5 A.
`
`Yes.
`
`6 Q.
`
`7 A.
`
`I believe
`
`Did you recall where it was?
`it was in Long Island like
`I don't know where or when.
`but
`8 Westbury,
`the treatment
`Just so I'm clear, all
`from
`9 Q.
`the hospital,
`the rehabilitation,
`10 the 2016 episode,
`workers'
`or your
`11 was that paid for by
`compensation
`12 private medical?
`My medical
`Who was your private medical
`
`13 A.
`
`14 Q.
`
`insurance.
`
`insurance
`
`back
`
`15 then?
`
`16 A.
`
`I don't know.
`
`The private medical
`
`17 Q.
`18 mom's or dad's?
`I don't know.
`
`19 A.
`
`insurance was that your
`
`20 Q.
`
`So 2016 after you get out of
`
`the rehab
`
`21 facility,
`22 A.
`
`to treat with Dr. Karceski?
`you continue
`I've seen him every month now.
`From the time you got out of rehab facility
`23 Q.
`for which
`the incident
`here we're today,
`24 up until
`25 were you seeing him every month?
`
`Adderall
`
`J. ROMANO
`is for attending
`for
`focus.
`Yes,
`Yes. How long have you been on the Adderall
`
`issues, correct?
`
`My entire life, since I was nine pretty
`
`1
`
`2 Q.
`
`3 A.
`
`4 Q.
`
`5 for?
`
`6 A.
`
`7 much.
`
`8 Q.
`
`the beginning
`of
`From 2016 up until
`9 September
`of 2018, what was the milligram
`
`of
`
`10 Adderall?
`
`11 A.
`
`12 Q.
`
`Thirty.
`of 2018
`the beginning
`From 2016 up until
`than seeing Dr. Karceski
`about once a month,
`13 other
`14 believe you said --
`15 A.
`Yes.
`-- were you seeing any other doctor on any
`regular
`basis?
`17 type of
`
`16 Q.
`
`I
`
`18 A.
`
`19 but
`
`I don't
`
`I was seeing,
`that
`There was another doctor
`his name -- Dr. Berlin.
`remember
`He was
`too because one of my lungs c0llapsed
`20 in Cornell
`but
`I saw him a couple times.
`21 when I aspirat-J,
`He was a pulmonologist?
`22 Q.
`
`23 A.
`24 Q.
`
`I don't know what
`is, but yeah.
`that
`He wasn't dealing with your seizure issues
`25 or your cognitive
`issues, he was dealing more with
`
`1
`
`2 A.
`
`3 Q.
`
`4 A.
`
`J. ROMANO
`
`Yes, sir.
`And you're
`
`Yes.
`
`Where would
`
`on 200 milligrams
`
`of Keppra?
`
`3 A.
`
`4 Q.
`
`Page31
`
`Page33
`
`1
`
`2 an internal
`
`J. ROMANO
`injury?
`
`Yes.
`Were you seeing any other doctors
`for
`5 cognitive
`issues or
`issue meaning
`-tteeng
`than Dr. Karceski
`from 2016 up
`
`other
`6 concentration
`the beginning
`of 2018?
`Not more head people,
`What did you see the therapist
`--
`For trying
`That was for emotional
`
`to talk out
`
`but
`
`I saw therapists.
`
`for?
`
`issues, not physical
`
`7 until
`
`8 A.
`
`9 Q.
`
`10 A.
`
`I 1 Q.
`
`5 Q.
`
`6 filled?
`
`7 A.
`
`8 Q.
`
`9 A.
`
`10 North
`
`11 Q.
`12 taking
`13 A.
`
`14 Q.
`
`15 A.
`
`16 Q.
`
`17 A.
`
`you have the prescription
`
`CVS.
`
`Beach to now CVS on
`
`Where
`from?
`Long Island to Howard
`6th and Kent Avenue.
`2018, were you
`From 2016 up until September
`other
`than Keppra?
`any other medication
`Klonopin.
`You take that every day?
`Yes.
`
`Was that
`
`for seizure?
`
`That was prescribed
`
`after
`
`the accident.
`
`18 Repeat
`
`the question
`
`again.
`
`I want
`to know from the 2016 seizure
`2018 before this
`up until September
`do you understand what
`
`19 Q.
`
`20 incident
`
`21 incident,
`22 A.
`I got you.
`
`I'm saying?
`
`23 Q.
`
`So in that
`we know you're
`timeframe,
`are you on any other medications?
`24 Keppra;
`Keppra
`25 A.
`and Adderall.
`
`on the
`
`12 issues?
`
`13 A.
`
`14 Q.
`
`15 A.
`
`16 Q.
`
`17 A.
`
`18 Q.
`
`Correct.
`
`Do you recall
`
`the therapists
`
`that you saw?
`
`Elizabeth
`
`Boris.
`
`Let's start with her. Where is she located?
`In Long Island.
`town?
`What
`
`19 A.
`
`I believe Westbury.
`Is she a psychiatrist,
`21 worker?
`
`20 Q.
`
`psy chologist,
`
`social
`
`22 A.
`
`23 Q.
`
`24 A.
`
`25 Q.
`
`She's a psychiatrist.
`
`So she's a medical
`
`doctor?
`
`Yes.
`
`Did she prescribe
`
`you any medications?
`
`800-567-8658
`
`Veritext
`
`Legal
`
`Solutions
`
`9 (Pages
`
`30 -
`
`33)
`
`973-410-4098
`
`

`

`FILED: KINGS COUNTY CLERK 01/05/2021 07:00 PM
`FILED: KINGS COUNTY CLERK 11/05/2020 12:25 PM
`NYSCEF DOC. NO. 121
`NYSCEF DOC. NO. 76
`
`INDEX NO. 518796/2018
`INDEX NO. 518796/2018
`
`RECEIVED NYSCEF: 01/05/2021
`RECEIVED NYSCEF: 11/05/2020
`
`1
`
`2 A.
`
`No.
`
`J. ROMANO
`
`Page34
`
`3 Q.
`
`that same time, 2016 up until
`right
`Again,
`for which we're here today
`4 before the incident
`you see Dr. Boris?
`2018, how long would
`Once a week.
`
`5 September
`
`6 A.
`
`7 Q.
`
`8 A.
`
`9 Q.
`
`10 A.
`
`11 Q.
`
`12 A.
`
`That was for counselling?
`
`Yes.
`Were you seeing any or doctors?
`Debra Mac.
`
`Where
`
`Right
`
`is she located?
`by my parent's house, but
`
`I would
`
`go
`
`1
`
`J. ROMANO
`When you were in high school,
`3 the SAT exam!netion?
`
`2 Q.
`
`Page36
`
`did you take
`
`4 A.
`