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DIAMOND REPORTING (877) 624-3287 [email protected]
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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS------------------------------------------X A.H., as Infant and Natural Guardian, ZAHED HOSSAIN,
PLAINTIFF,
-against- Index No.: 510843/2015E
FERDOUSHI KAMAL, as Administrator of the Estate of MOHAMMAD M. KAMAL, M.D.,Deceased, MOHAMMAD KAMAL, PHYSICIAN, P.C., MARLA LEVINE, M.D., CARMEN CORTIS, D.O., and MAIMONIDES MEDICAL CENTER,
DEFENDANTS. ------------------------------------------X
DATE: August 2, 2019
TIME: 10:25 a.m.
VIDEOCONFERENCED DEPOSITION of a
non-party witness, SHAHAJADI BEGUM, taken
by the Defendants, pursuant to Notice Under
Article 31 of the Civil Practice Law and
Rules, held at the offices of Metschl &
Associates, 295 Main Street, Buffalo, New
York 14203, before Patricia A. Schreier, a
Notary Public of the State of New York.
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
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DIAMOND REPORTING (877) 624-3287 [email protected]
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A P P E A R A N C E S:
DUFFY & DUFFY, PLLC Attorneys for the Plaintiff 1370 RXR Plaza West Tower, 13th Floor Uniondale, New York 11556 BY: ROBERT J. CRISTIANO, ESQ.
CONNICK, MYERS, McNAMEE & FITZGERALD, PLLC Attorneys for the Defendants FERDOUSHI KAMAL, as Administrator of the Estate of MOHAMMAD M. KAMAL, M.D., and MOHAMMAD KAMAL, PHYSICIAN, P.C.114 Old Country Road, Suite 208 Mineola, New York 11501 BY: TARYN FITZGERALD, ESQ. (Via videoconference)
McALOON & FRIEDMAN, P.C. Attorneys for the Defendants MARLA LEVINE, M.D., CARMEN CORTIS, D.O., and MAIMONIDES MEDICAL CENTER123 William Street, 25th Floor New York, New York 10038 BY: PAUL PALEY, ESQ.(Via videoconference)
ALSO PRESENT:
TAHMINA SHOMPA, Bengali Interpreter
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
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DIAMOND REPORTING (877) 624-3287 [email protected]
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221. UNIFORM RULES FOR THE CONDUCT OF DEPOSITIONS221.1 Objections at Depositions
(a) Objections in general. No objections shall be made at a deposition except those which, pursuant to subdivision (b), (c) or (d) of Rule 3115 of the Civil Practice Law and Rules, would be waived if not interposed, and except in compliance with subdivision (e) of such rule. All objections made at a deposition shall be noted by the officer before whom the deposition is taken, and the answer shall be given and the deposition shall proceed subject to the objections and to the right of a person to apply for appropriate relief pursuant to Article 31 of the CPLR.
(b) Speaking objections restricted. Every objection raised during a deposition shall be stated succinctly and framed so as not to suggest an answer to the deponent and, at the request of the questioning attorney, shall include a clear statement as to any defect in form or other basis of error or irregularity. Except to the extent permitted by CPLR Rule 3115 or by this rule, during the course of the examination persons in attendance shall not make statements or comments that interfere with the questioning.221.2 Refusal to answer when objection is made A deponent shall answer all questions at a deposition, except (i) to preserve a privilege or right of confidentiality, (ii) to enforce a limitation set forth in an order of the court, or (iii) when the question is plainly improper and would, if answered, cause significant prejudice to any person. An attorney shall not direct a deponent not to answer except as provided in CPLR Rule 3115 or this subdivision. Any refusal to answer or direction not to answer shall be accompanied by a succinct and clear statement of the basis therefor. If the deponent does not answer a question, the examining party shall have the right to complete the remainder of the deposition.
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
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DIAMOND REPORTING (877) 624-3287 [email protected]
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221. UNIFORM RULES FOR THE CONDUCT OF DEPOSITIONS
221.3 Communication with the deponentAn attorney shall not interrupt the
deposition for the purpose of communicating with the deponent unless all parties consent or the communication is made for the purpose of determining whether the question should not be answered on the grounds set forth in section 221.2 of these rules and, in such event, the reason for the communication shall be stated for the record succinctly and clearly.
IT IS FURTHER STIPULATED AND AGREED that the transcript may be signed before any Notary Public with the same force and effect as if signed before a clerk or a Judge of the court.
IT IS FURTHER STIPULATED AND AGREED that the examination before trial may be utilized for all purposes as provided by the CPLR.
IT IS FURTHER STIPULATED AND AGREED that all rights provided to all parties by the CPLR cannot be deemed waived and the appropriate sections of the CPLR shall be controlling with respect hereto.
IT IS FURTHER STIPULATED AND AGREED by and between the attorneys for the respective parties hereto that a copy of this examination shall be furnished, without charge, to the attorneys representing the witness testifying herein.
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
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S. BEGUM
T A H M I N A S H O M P A, a Bengali
Interpreter, having first been duly sworn,
promised to interpret the proceedings to
the best of her ability.
S H A H A J A D I B E G U M, 548 Minnesota
Avenue, Buffalo, New York 14215, having
first been duly sworn, was examined and
testified as follows:
EXAMINATION BY
MR. PALEY:
Q. Good morning. My name is Paul
Paley and I represent Maimonides Medical
Center in this case.
I'm going to ask you some
questions this morning regarding your son.
If there are any questions you do not
understand or you would like me to repeat,
please tell me and I will do so.
A. Yes.
Q. The only instructions I will
give you is that you have to answer
verbally. You can't nod your head or shake
your head. And wait until I complete my
question until you start to answer because
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
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S. BEGUM
the reporter cannot take down both of us
talking at one time.
A. Yes.
Q. Everything I've said to you,
have you understood?
A. Yes.
Q. How long have you lived at 548
Minnesota Avenue?
A. I'm not able to recall exactly
how long.
Q. Is it more than --
A. It could be about five years.
Q. And is that a private house?
A. Yes.
Q. And what is your date of birth?
MR. CRISTIANO: Just put the
year.
A. X/X/1981.
Q. I'm going to ask you your
Social Security Number, but to protect your
privacy we will not put it on the record.
A. XXX-XX-XXXX.
Q. And who do you live with at the
present time?
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
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S. BEGUM
A. I didn't understand.
Q. In your house, who do you live
with now?
A. My family, my children and my
husband.
Q. And what is your husband's
name?
A. Zahed, Z-A-H-E-D H-O-S-S -- I'm
not able to recall his name, exactly.
Q. Is his last name H-O-S-S-A-I-N?
A. Yes, yes.
Q. And how many children do you
have?
A. Three.
Q. Do you have one boy and two
girls?
A. Yes.
Q. And what is your son's name?
A. A.H.
MR. CRISTIANO: Just the
initials please.
MR. PALEY: So, Rob, we'll
agree that every time I will use the
name, that the reporter will just put
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
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S. BEGUM
the initials?
MR. CRISTIANO: Correct, for
the subject and his siblings.
They're all minors. So we can just
use all of their initials on the
record. We can just write them down.
MR. PALEY: So whenever I say
A.H. she'll understand that that's
her son.
MR. CRISTIANO: Are you going
to say A.H.?
MR. PALEY: I will say A.H., if
you prefer, Rob. I thought I would
just say the name and the reporter
will put A.H.
MR. CRISTIANO: Whichever way,
I want just the initials on the
record.
MR. PALEY: All right. I guess
it's easier for me to say A.H.
Q. How old is A.H.?
A. Seventeen.
Q. Seventeen?
A. Yes.
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
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S. BEGUM
Q. And how old are your two
daughters?
A. I can tell you their date of
birth.
Q. Please tell me their dates of
birth.
A. The eldest daughter is March
24, 2007. The younger daughter is June 12,
2019.
Q. Your younger daughter was born
a month ago?
A. Yes, yes.
MR. CRISTIANO: There may be
something lost here.
A. X/X/2012.
MR. CRISTIANO: Just the year
please.
Q. All right. Were you married to
your husband in Bangladesh or in the United
States?
A. In Bangladesh.
Q. Did you come to the United
States with your husband?
A. No.
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
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S. BEGUM
Q. Were you married when you came
to the United States?
A. Yes.
Q. When did you come to the United
States, in what year?
A. Maybe, 2005. I'm not sure.
Q. Are you an American citizen?
A. Yes.
Q. In what year did you become a
citizen?
A. Maybe, 2012.
MR. CRISTIANO: Just note my
objection. Answered over objection.
Q. How far did you go in school?
A. I completed SSC degree in my
county. I have SSC degree and diploma in
Bangladesh.
Q. Do you work at the present
time?
A. No.
Q. Have you worked at all since
you came to the United States?
A. No.
Q. Did you work at all in
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
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Bangladesh?
A. No.
Q. Do you speak English?
A. A little bit, not much.
Q. Do you understand English?
A. A little bit, not much.
Q. And between you and your
husband, who speaks better English?
MR. CRISTIANO: Just note my
objection, but you can answer.
A. I don't know.
Q. Between you and your husband,
who understands more English?
MR. CRISTIANO: Just note my
objection.
A. Almost the same.
Q. I don't understand.
A. We're almost the same. I meant
by that, like almost the same.
Q. If you took your son to a
doctor who speaks English, would you be
able to tell the doctor your son's medical
complaints in English or not?
MR. CRISTIANO: That's today?
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
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S. BEGUM
Q. Today.
A. Now I'm -- now I go with my son
because he speaks better -- now I go with
my son since he speaks and understands
better English. That's why whatever he
needs, he tells the doctor. Before there
was a Bengali doctor.
Q. In 2013 could you go to a
doctor who only speaks English and tell the
doctor what your son's medical complaints
were in English, I'm talking about you?
A. Actually, I didn't understand.
Are you asking about my son?
Q. No. I'm asking if you took
your son to a doctor or hospital in 2013
and the doctor only spoke English, could
you tell the doctor in English what your
son's complaints were?
A. In 2013 I actually used to go
to Dr. Kamal. He's from Bangladesh and he
speaks Bengali.
MR. CRISTIANO: Do you want her
to read the question back?
MR. PALEY: Yes, please.
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
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S. BEGUM
(Record read back)
A. I never took him to the
hospital because he was okay. Maybe, once
or twice I took him to Dr. Kamal.
MR. CRISTIANO: All right.
Maybe, there is some confusion but
what he's asking about, he's asking a
pretty straightforward question,
which is could she speak English to
her son's doctors?
MR. PALEY: Right.
A. Before he got sick, I took him
once or twice to the doctor. I am not able
to recall properly.
Q. What grade in school is your
son going into in September?
A. In 12th grade.
Q. And is that in high school?
A. Are you speaking about next
year?
Q. Yes, after this summer.
A. Yes.
Q. And what school does he go to?
A. Currently, what school he's
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S. BEGUM
going -- same school.
Q. Which school is he going to
after the summer? What is the name of the
school?
A. Olmstead.
Q. The school is called Olmstead,
O-L-M-S-T-E-A-D?
A. Okay. Maybe. Could be. I
forgot. I'm not able to help you.
Q. Does your son intend to go to
college?
A. Yes.
Q. Has he taken any tests in order
to get into college?
A. Yes.
Q. Is there a particular college
that he wants to go to?
A. I don't know yet.
Q. Before your son got sick in
2013, are you aware of any medical
conditions that he had?
A. No.
Q. No, I'm not aware or no, he did
not have any?
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S. BEGUM
MR. CRISTIANO: Note my
objection.
A. He did not have any.
Q. Before your son got sick in
2013, was he taking any prescription
medications?
A. I'm not able to recall,
exactly.
Q. In 2013 did your son have a
pediatrician?
A. Yes.
Q. Was it Dr. Kamal?
A. Yes.
Q. Was Dr. Kamal in Brooklyn?
A. Yes.
Q. Do you remember what year your
son first started seeing Dr. Kamal?
A. No, I don't remember. When we
came, then we took him. Right now, I'm not
able to recall.
Q. And when your son went to see
Dr. Kamal over the years, did you take your
son, did your husband take your son or
would it be one or the other?
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S. BEGUM
A. My husband used to take him.
Q. Did you ever take your son to
see Dr. Kamal instead of your husband?
A. As I told you earlier, probably
I took him once or twice, I'm not able to
recall properly, when he was sick.
Q. Is there a reason that your
husband took your son to Dr. Kamal more
than you did?
A. Yes. I had a baby in 2012 and
that's why I was sick.
Q. How about before you had a
baby, is there a reason that your husband
took your son to Dr. Kamal as opposed to
you?
A. Can you say that again?
Q. Before you had a baby in 2012,
when your son went to see Dr. Kamal is
there a reason why your husband took your
son instead of you?
A. My husband used to do it.
Q. Why did your husband take him
instead of you?
A. I was staying home, since I'm
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remembering. I was not going. That's why
he was taking him.
Q. In what year did your son A.H.
get sick?
A. I'm not able to recall,
exactly.
MR. CRISTIANO: Objection.
Q. Was it in 2013?
A. Maybe. Since it's been six
years, I'm not able to recall that.
Q. When your son got sick, do you
remember the first complaints that he was
making?
A. Yes.
Q. And what complaints did he
make?
A. He used to have joint pain and
he used to complain about a fever and pain.
Q. When you say he complained
about a fever, did he complain about a
fever or was his temperature taken and it
showed a fever?
A. I'm not completely clear about
fever, but he used to complain about pain.
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S. BEGUM
Q. And to what part or parts of
his body did he complain of pain?
A. All the joints or fingers or
wrists, elbows, neck, legs, neck.
Q. Did he make these complaints
about joint pain to the fingers, wrists,
elbows and neck at the same time or were
these complaints made at different times?
A. He used to complain, but I'm
not able to recall.
Q. In other words, can you recall
if first he complained about pain in one
place and then another place the next day
or a few days later or were all the
complaints about his joints at the same
time?
MR. CRISTIANO: Or something
else.
Q. Or something else.
A. While he was writing, while he
was writing one day he was complaining
about his fingers and hand and then it
started with neck.
Q. How long after he complained
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about his fingers and hand did he complain
about the neck?
A. I did not understand.
Q. How long after he complained
about his fingers and hand did he complain
about the neck?
A. He complained about neck first.
Q. And then he complained about
the hand?
MR. CRISTIANO: Note my
objection.
A. Yes.
Q. How long after he complained
about the neck did he complain about the
hand?
A. I don't remember.
Q. And were there times when he
complained about pain in the fingers,
wrist, elbows and neck all at the same
time?
A. Yes and then his hands, legs
and neck were like bending.
Q. Did your -- was your son taken
to the doctor as a result of these
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complaints?
A. Yes. I told you before that I
took him once or twice to the doctor. It
was a bad time.
Q. So when he was complaining
about joint pain in various parts of his
body, that's when you took him to the
doctor?
MR. CRISTIANO: Note my
objection.
A. I'm not able to recall exactly
when I took him, before or after he started
to complain, but so far around that time I
took him.
Q. Is this Dr. Kamal?
A. Yes, yes.
Q. And how long after your son
starting making these complaints of joint
pain did you take your son to Dr. Kamal for
the first time?
A. I'm not able to recall exactly
when I took him, but so far I recall that,
after he started to complain but I'm not
sure exactly when.
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Q. And when you saw Dr. Kamal, did
you speak to him in Bengali?
A. Yes.
Q. And what did you tell Dr. Kamal
about your son's condition?
A. When I went I complained about
his joint pain and he was coughing and the
symptoms was not that good to me.
Q. And did Dr. Kamal examine your
son at that time?
A. Yes, he did. He checked his
heartbeat and others.
Q. Did he check his throat?
A. I don't remember that.
Q. Do you remember the month of
this visit?
A. No.
Q. Do you remember the year?
A. No. I'm not able to recall.
Q. And after examining your son,
what did Dr. Kamal say at the time of this
visit?
A. He said he's fine, he has no
problem.
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Q. And did he say anything,
specifically, about the complaints of joint
pain?
A. No. He did not say anything.
Q. And after that visit to Dr.
Kamal when he said that everything was
fine, how was your son doing after that?
MR. CRISTIANO: Just a minute.
Immediately after?
MR. PALEY: Well, in the days
after that visit.
MR. CRISTIANO: All right.
A. I don't remember, exactly, how
long after but after a few days after I
took him to Dr. Kamal. He was getting
worse. His health was getting worse and
then my husband took him to Maimonides
Hospital.
Q. Was there one visit to Dr.
Kamal before your husband took your son to
Maimonides or more than one visit with the
complaints that you talked about, joint
pain?
MR. CRISTIANO: Note my
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objection. That she took him to?
Q. That either you or your husband
took him to Dr. Kamal before your husband
took your son to Maimonides with complaints
of joint pain.
A. I don't remember.
Q. After you took your son to Dr.
Kamal when your son had complaints of joint
pain, did your husband also take your son
to Dr. Kamal before he took your son to
Maimonides?
A. My husband and I, we both took
him that doctor but I'm not sure how many
times.
Q. Well, the visit you spoke about
when your son was complaining of joint pain
and coughing and his symptoms did not look
good to you, to Dr. Kamal, was that a visit
that you took your son or was your husband
with you?
A. I took him by myself.
Q. And is there a reason you took
your son on that visit and your husband
didn't take him?
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A. Maybe, my husband was busy that
day. That's why I took him. I don't
remember, exactly.
Q. When your husband took your son
to Maimonides Hospital, do you know what
date that was?
A. No.
Q. Did you go to the hospital with
your son and husband?
MR. CRISTIANO: Maimonides.
A. No.
Q. Did your son stay overnight at
Maimonides or did they treat him and
release him when your husband took him to
Maimonides?
MR. CRISTIANO: For the first
time?
Q. The first time.
A. I don't remember.
Q. How many times in all did your
son go to Maimonides?
A. I don't remember, exactly.
Q. After your son came back from
Maimonides the first time when your husband
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took him, did your husband tell you what
they said at Maimonides about your son's
condition?
MR. CRISTIANO: Just note an
objection.
A. Yes. So after he came back he
did say, but I'm not able to recall.
Q. On the day that your husband
took your son to Maimonides for the first
time, do you recall what your son's
complaints were on that day before your
husband took him?
A. Maybe he had all the symptoms
-- the same symptoms. Maybe he was
complaining about same symptoms. Maybe
that's why he took him.
MR. CRISTIANO: Maybe that's
why he took him?
A. Maybe that's why he took him.
MR. CRISTIANO: All right.
Q. And when you say the same
symptoms, what symptoms were those?
A. I'm not able to recall them
now.
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Q. After your son came back from
Maimonides with your husband for the first
time, did your son go back to Dr. Kamal?
A. Maybe. No. I don't remember.
Q. Did your son go to Maimonides
again a second time after your husband took
him the first time?
A. I didn't understand.
Q. Did your son go to Maimonides
again a second time after your husband took
him the first time?
A. Yes, he did because he got sick
again.
Q. And how long after your husband
took your son to Maimonides the first time
did he go the second time when he got sick
again?
A. I don't remember the exact day
and time.
Q. Do you know if it was a week
later or two weeks later or three weeks
later?
A. Could be. I'm not able to
recall the exact time or days.
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Q. Between the first visit to
Maimonides and the second visit when your
son got sick again, did your son go to see
Dr. Kamal at all?
A. I am not able to recall right
now.
Q. And between the first time your
husband took your son to Maimonides and the
second time he went to Maimonides when he
got sick again, what was your son's
condition like?
MR. CRISTIANO: Just note my
objection to condition.
A. His condition was not that
great.
Q. When you say it was not that
great, why was it not that great?
A. To me, he was not that great.
I felt like he was not doing okay.
Q. What complaints was he making
that made you feel that he was not doing
okay?
A. He was coughing, he was losing
weight and he was complaining so much that
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he felt like he was not doing okay.
Q. Was he making complaints about
joint pain?
A. Yes.
Q. And between the first and the
second time he went to Maimonides, where
was he complaining of joint pain, to what
part of his body?
A. I'm not able to recall the
exact body parts that he was complaining,
but he was complaining about pain.
Q. Between the first visit to
Maimonides when your husband took him and
the second time he went to Maimonides, did
he miss any time from school?
A. I'm not able to recall exactly,
but Dr. Kamal told him to send him to the
school.
Q. Do you recall taking your son
to Dr. Kamal a few days after your husband
first took your son to Maimonides?
A. No. I don't remember.
Q. Do you remember any
conversations that you had with Dr. Kamal
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about your son's medical condition?
MR. CRISTIANO: That's ever?
MR. PALEY: No. I'll be more
specific.
Q. Do you recall any conversations
that you had with Dr. Kamal after your son
first started complaining of joint pain?
MR. CRISTIANO: That's other
than what she already testified to?
MR. PALEY: Other than what she
testified to.
A. I complained about breathing.
Like he had to -- he used to breathe a lot
--
Q. You mean --
MR. CRISTIANO: Were you done?
A. No.
Q. I'm sorry, I thought you were.
Go ahead.
A. I'm not able to recall that, if
I mentioned it to him but he used to have
short of breath at nighttime.
Q. And when you say he had short
of breath at nighttime, was that in the
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same time that he was complaining of joint
pain?
A. I'm not able to recall exactly
when it was and he also mentioned about his
heart, like he used to have pain like in
his heart.
Q. When you say "he", you mean
your son?
A. Yes, yes.
Q. Was he complaining about pain
in his heart at the same time that he was
complaining of joint pain or at a different
time?
MR. CRISTIANO: Just note my
objection.
A. Maybe in different, but I'm not
sure. Maybe he said, but I'm not able to
recall when.
Q. Well, on the visit that you
took your son to see Dr. Kamal when he
complained about coughing and joint pain,
was he also complaining of shortness of
breath?
A. I don't remember if I said
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about his short of breath, but I mentioned
about other two.
Q. Other two meaning coughing and
joint pain?
A. Maybe.
Q. And how about heart pain, did
you mention anything about heart pain at
the time you complained -- you told Dr.
Kamal about the complaint of coughing and
joint pain?
A. I don't remember.
Q. Other than what you said Dr.
Kamal said after that visit you took your
son to, do you recall any other
conversations with Dr. Kamal about your
son's physical condition during the time
that he was complaining of joint pain?
A. I'm not able to recall right
now. Whatever so far I have remembered, I
already said to you.
Q. You don't remember any other
conversation?
MR. CRISTIANO: Just for
clarification, this is in person or
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on the phone?
Q. Either in person or on the
phone.
A. Even if I had more
conversation, I'm not able to recall now.
Q. All right. You said that your
son went back to Maimonides when he got
sick again. Who took your son to
Maimonides at that time, you, your husband
or both of you?
A. My husband.
Q. And do you know why your
husband took your son back to Maimonides
that day?
A. When?
Q. When your son got sick again
and your husband took your son to
Maimonides for the second time --
A. Because at nighttime his health
was going -- getting worse like and like he
was having short of breath and he was
vomiting. That's why.
Q. And for how long was he short
of breath and vomiting before your husband
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took him to Maimonides the second time?
A. Maybe, for a long time but I'm
not able to recall.
Q. And was your son admitted to
the hospital when your husband took him the
second time?
A. I'm not able to recall that
exactly, but at the last time he was
admitted.
Q. So the last time he was at
Maimonides he was admitted to the hospital?
A. Yes.
Q. For how long was he at the
hospital when he was admitted?
A. Maybe, once or twice. I don't
remember.
Q. What do you mean by once or
twice, one or two days or something else?
A. Maybe, one or two days but I
don't remember now.
Q. Did you visit your son in the
hospital when he was admitted for one to
two days?
MR. CRISTIANO: Just for
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clarification, we're talking about
Maimonides right now?
MR. PALEY: Maimonides.
A. Yes.
Q. And did anyone tell you what
was wrong with your son when he was at
Maimonides for one to two days?
A. No one told me anything. I
don't remember.
Q. And was your husband also there
when your son was admitted to Maimonides
for one to two days?
A. Yes.
Q. Did your husband speak to the
doctors at Maimonides when your son was
there for one to two days?
A. I don't know that now, whoever
he spoke with.
Q. Did your husband tell you what
was wrong with your son when your son was
at Maimonides for one to two days?
MR. CRISTIANO: Just over my
objection.
A. No. He didn't tell me
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anything. Probably, because I was really
tension (sic), that's why he didn't want to
tell me anything.
Q. After your son was at
Maimonides -- withdrawn. After your son
was at Maimonides for one to two days,
where did he go next?
MR. CRISTIANO: For care and
treatment?
Q. Care and treatment.
A. In Columbia Hospital.
Q. Is that Columbia Presbyterian
Hospital in Manhattan?
A. Maybe. I'm not able to recall
that now.
Q. Were you told why your son was
being -- withdrawn. Was your son
transferred from Maimonides hospital
directly to Columbia Presbyterian Hospital?
A. Maybe. I was not in there.
Maybe.
Q. How long was your son at
Columbia Hospital?
A. I'm not able to recall,
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exactly.
Q. Was it weeks, was it days? Do
you know?
A. Maybe, one month.
Q. And did you visit your son when
he was at Columbia Hospital for the month?
A. Yes.
Q. And how often did you visit
him?
A. I'm unable to recall that now.
Q. Did any doctor tell you about
what was wrong with your son when he was at
Columbia?
A. No.
Q. Did your husband tell you what
any doctor told him about what was wrong
with your son when he was at Columbia?
MR. CRISTIANO: Note my
objection.
A. He mentioned about pneumonia.
Q. Anything else?
A. He did not say anything else to
me.
Q. Did he ever say anything to you
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about a condition known as rheumatic fever?
A. He just told me that he also
had rheumatic fever.
Q. When your son was at Maimonides
when he was admitted for one to two days
and at Columbia, was your husband more
involved in speaking with the doctors than
you were?
MR. CRISTIANO: Just note my
objection.
A. I don't know if he spoke to
them directly. I don't know.
Q. But would he be more involved
in speaking with them than you were?
A. Yes.
Q. Do you know where in the
hospital your son was during the month he
was there, what unit or units?
A. No, I don't remember.
Q. Did you observe or did someone
tell you what they were doing for your son
while he was at Columbia?
A. No. I did not ask anybody and
nobody told me anything. I was really
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tense.
Q. During the month that you were
visiting your son at Columbia, did he make
any complaints to you about his physical
condition?
A. No. He did not tell me
anything.
Q. After your son was discharged
from Columbia, where did he go?
A. Then he came back home, my
home.
Q. And on the day he was
discharged, was he making any physical
complaints to you?
A. I don't remember that, if he
made any complaints.
Q. And did your son have any
further admissions to Columbia after that
one month?
A. Maybe, for a checkup, you know,
we took him back but I don't remember.
Q. But did he have any admissions
where he stayed for a few days at Columbia
after that one month admission?
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A. Maybe, no.
Q. When you say maybe no, is it no
or you're not sure?
MR. CRISTIANO: Note my
objection.
A. I don't remember. I'm not
sure.
Q. All right. Where was your son
seen for treatment after he was discharged
from Columbia, outpatient treatment?
MR. CRISTIANO: Just note my
objection.
A. I don't remember that, after
that, but we moved to Buffalo.
Q. While your son was at Columbia,
did you have any telephone conversations
with Dr. Kamal?
A. No.
Q. After your son was released
from Columbia, did either you or your
husband ever take your son back to Dr.
Kamal?
A. I don't remember about my
husband. Probably. I did not go.
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Q. You don't remember if your
husband ever went with your son back to Dr.
Kamal after Columbia, correct?
A. No.
Q. In what month and year did you
move to Buffalo?
A. I don't remember exactly, but
after he got released from there. I'm not
able to recall the month.
Q. Do you remember the year?
A. Yes. Maybe, in '13.
MR. CRISTIANO: That's 2013?
A. Yes.
Q. And when you moved to Buffalo,
did your son start treatment with a
pediatrician in Buffalo?
A. Yes.
Q. What was the name of the
pediatrician?
A. Dr. Holmes.
Q. Dr. David Holmes?
A. Holmes.
MR. CRISTIANO: H-O-L-M-E-S.
Q. H-O-L-M-E-S?
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2 A. Yes.
3 Q. And does he continue to be your
4 son's pediatrician today?
5 A. Yes.
6 Q. And did he treat your son at a
7 clinic or a medical center or by himself or
8 is he by himself?
9 A. It's in the family healthcare
10 center. I don't know if it is his own or
11 not.
12 Q. Is it called the ECMC Family
13 Health Center?
14 A. Yes.
15 Q. And when your son sees Dr.
16 Holmes, who takes your son, you or your
17 husband or do you alternate?
18 A. Mostly, my husband takes him.
19 I go sometimes.
20 Q. How often does your son see Dr.
21 Holmes?
22 A. He have to go every month for
23 his injection.
24 Q. Does Dr. Holmes give him the
25 injections?
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2 A. I'm not sure, but nurse.
3 Q. The nurse gives the injection?
4 A. Yes.
5 Q. And is this a penicillin
6 injection?
7 A. Maybe, penicillin.
8 Q. And have you spoken to Dr.
9 Holmes about these injections?
10 A. No.
11 Q. Did Dr. Holmes tell you for how
12 long your son will need to have these
13 injections?
14 A. No. Nobody told me anything
15 about.
16 Q. About what?
17 A. But I'm not sure -- I don't
18 remember how long.
19 Q. During the times that you've
20 taken your son to Dr. Holmes, has he said
21 anything to you about your son's medical
22 condition?
23 MR. CRISTIANO: Just note my
24 objection.
25 A. Maybe. No.
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2 Q. Other than Dr. Holmes, has your
3 son seen a cardiologist during the time
4 that he was in Buffalo since you've been in
5 Buffalo?
6 A. No.
7 Q. Has your son seen a
8 cardiologist named Dr. Glenn Leonard?
9 A. No, I did not.
10 MR. CRISTIANO: Did she see or
11 did her son see?
12 Q. The question is did your -- has
13 your son seen a cardiologist since you
14 moved to Buffalo?
15 A. I don't remember that.
16 Q. You said a little earlier that
17 the cardiologist said something about your
18 son's penicillin injections. So who are
19 you referring to?
20 A. I meant my son told me, that's
21 why.
22 Q. Are you aware of your son
23 seeing any doctor for your son's heart in
24 Buffalo?
25 A. For heart?
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1 S. BEGUM
2 Q. Yes.
3 A. I know that he just goes to
4 cardiology.
5 Q. Have you ever gone with your
6 son to the cardiologist?
7 A. No.
8 Q. Is the cardiologist in the same
9 family health center as Dr. Holmes or at a
10 different place?
11 MR. CRISTIANO: If you know.
12 A. I don't know.
13 Q. Other than the penicillin
14 injections, does your son take any
15 prescription medication at home at the
16 present time?
17 A. Yes.
18 Q. What does he take?
19 A. He takes blood pressure
20 medication.
21 Q. Do you know the name of the
22 medication?
23 A. Lisinopril.
24 Q. Lisinopril?
25 A. Yes.
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1 S. BEGUM
2 Q. Did he take blood pressure
3 medication before he was taking Lisinopril?
4 A. Maybe. He used to. Actually,
5 he started it after he got sick.
6 Q. Did your son ever have a
7 problem with his blood pressure before he
8 got sick?
9 MR. CRISTIANO: Just note my
10 objection. She testified he took
11 what she understood to be a blood
12 pressure pill.
13 Q. Did your son, did any doctor
14 tell you that your son has a blood pressure
15 problem now?
16 A. Yes.
17 Q. Who told you that your son has
18 a blood pressure problem?
19 A. Whenever I take him to the
20 doctor and then a nurse takes his blood
21 pressure, then they tell me.
22 Q. What do they tell you?
23 A. They said high. That's why he
24 needs medication.
25 Q. High blood pressure?
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1 S. BEGUM
2 A. Yes.
3 Q. Did your son have high blood
4 pressure before he got sick?
5 A. No.
6 Q. Other than the Lisinopril and
7 the penicillin injections, does your son
8 take any medications at the present time?
9 A. No.
10 Q. What is the name of the
11 pharmacy where the Lisinopril medication
12 prescription is filled?
13 A. Previously, he used to take it
14 from Buffalo and probably he's taking from
15 Rite Aid. Probably, he's taking now from
16 Rite Aid.
17 Q. Other than the cardiologist and
18 Dr. Holmes, does your son see any other
19 doctors at the present time?
20 MR. CRISTIANO: Just note she
21 also said ECMC.
22 Q. Well, you said that your son
23 sees Dr. Holmes at ECMC. Does he see any
24 other doctors at ECMC?
25 A. He used to see him before.
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47
1 S. BEGUM
2 Q. So now another doctor besides
3 Dr. Holmes sees your son at ECMC?
4 A. Yes. I don't go there all the
5 time. There is a nurse and then -- I don't
6 know much about it.
7 Q. Well, do you know the names of
8 any of the doctors at ECMC Family Health
9 Center that your son sees aside from Dr.
10 Holmes?
11 A. There is a nurse for him.
12 Q. Since you've lived in Buffalo,
13 has your son been hospitalized?
14 A. No.
15 Q. Has your son gone to the
16 emergency room since you moved to Buffalo?
17 MR. CRISTIANO: Just for
18 clarification, when you say
19 hospitalized, do you mean admitted?
20 Q. Well, hospitalized is admitted
21 and now the second question is not
22 admitted, just going to the ER.
23 A. I'm not able to recall.
24 Q. Does your -- is your son
25 covered by health insurance at the present
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1 S. BEGUM
2 time?
3 A. Yes.
4 Q. What is the name of the health
5 insurance?
6 A. Your Care.
7 Q. Y-O-U-R Care?
8 A. Yes.
9 Q. Are there any out-of-pocket
10 expenses for either Dr. Holmes or the
11 cardiologist or any medications that you
12 and your husband have had or is everything
13 covered by insurance?
14 MR. CRISTIANO: Just note my
15 objection. There is no independent
16 cause of action, but you can answer.
17 A. I don't know that. My husband
18 knows about it.
19 MR. PALEY: There is no
20 independent cause of action?
21 MR. CRISTIANO: I don't see it.
22 MR. PALEY: All right.
23 Q. At the present time, does your
24 son have any physical complaints that
25 you're aware of?
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1 S. BEGUM
2 A. Now he doesn't complain
3 anything about it to me.
4 Q. Are there any limitations on
5 his physical activities? Is there anything
6 that he can't do, physically?
7 A. Yes.
8 Q. What is that?
9 A. He plays soccer and doing it in
10 the summer, soccer.
11 Q. Is he on the soccer team at
12 school?
13 A. No. He plays with his friends.
14 Q. Does he participate in gym at
15 school?
16 MR. CRISTIANO: Currently?
17 Q. Currently.
18 A. Maybe. I don't know.
19 Actually, I don't know.
20 Q. Are you aware of any physical
21 activities that he's not allowed to do at
22 the present time?
23 A. I did not understand the
24 question. If my son said to me or what?
25 Q. Has any doctor told you or has
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50
1 S. BEGUM
2 your husband told you that any doctor has
3 said that there are physical activities
4 your son cannot do because of his physical
5 condition?
6 MR. CRISTIANO: Note my
7 objection.
8 A. No. No doctor has told to me,
9 but I'm not sure if anybody talked to my
10 husband.
11 Q. What is your son doing this
12 summer?
13 MR. CRISTIANO: Note my
14 objection.
15 A. He plays soccer with his
16 friends.
17 Q. Is this at a camp or is he just
18 playing with his friends in the street?
19 A. I don't know. He goes with his
20 friends.
21 MR. PALEY: I have no further
22 questions. Thank you very much.
23 MS. FITZGERALD: I don't have
24 any questions.
25 MR. PALEY: Thank you.
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51
1 S. BEGUM
2 MR. CRISTIANO: Thank you for
3 coming in.
4 THE REPORTER: Since this is a
5 nonparty deposition, are you all
6 agreeing to purchase your own
7 transcripts?
8 MR. CRISTIANO: Well, put on
9 the record that for purposes of
10 today's deposition, I'm representing
11 the deponent.
12 THE REPORTER: Then Mr. Paley
13 and Ms. Fitzgerald, are you both
14 agreeing to provide Mr. Cristiano
15 with this transcript?
16 MR. PALEY: So I guess the
17 question is, and I'm not sure of the
18 answer, it has to do with whether you
19 get a free copy, Rob.
20 MR. CRISTIANO: Okay.
21 MS. FITZGERALD: I don't know.
22 MR. PALEY: Well, if that's how
23 it goes in Buffalo, sure. That's
24 okay then.
25 THE REPORTER: Ms. Fitzgerald,
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1 S. BEGUM
2 are you also agreeing then to supply
3 Mr. Cristiano?
4 MS. FITZGERALD: Okay, yes.
5 Sure.
6 THE REPORTER: And would
7 everyone prefer digital or paper
8 transcripts?
9 MR. PALEY: Paper please.
10 MS. FITZGERALD: A paper copy
11 also.
12 MR. CRISTIANO: And paper for
13 me. Thank you.
14 (Whereupon, at 12:05 P.M., the
15 Examination of this witness was
16 concluded.)
17
18° ° ° °
19
20
21
22
23
24
25
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53
1 S. BEGUM
2 D E C L A R A T I O N
3
4 I hereby certify that having been
5 first duly sworn to testify to the truth, I
6 gave the above testimony.
7
8 I FURTHER CERTIFY that the foregoing
9 transcript is a true and correct transcript
10 of the testimony given by me at the time
11 and place specified hereinbefore.
12
13
14
15 SHAHAJADI BEGUM
16
17
18 Subscribed and sworn to before me
19 this day of 20 .
20
21
22 NOTARY PUBLIC
23
24
25
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54
1 S. BEGUM
2 E X H I B I T S
3
4 EXHIBIT EXHIBIT PAGE
5 NUMBER DESCRIPTION
6 (None)
7
8
9 I N D E X
10
11 EXAMINATION BY PAGE
12 MR. PALEY 5
13
14
15 INFORMATION AND/OR DOCUMENTS REQUESTED
16 INFORMATION AND/OR DOCUMENTS PAGE
17 (None)
18
19
20 QUESTIONS MARKED FOR RULINGS
21 PAGE LINE QUESTION
22 (None)
23
24
25
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55
1 S. BEGUM
2 C E R T I F I C A T E
3
4 STATE OF NEW YORK ): SS.:
5 COUNTY OF ERIE )
6
7 I, PATRICIA A. SCHREIER, a Notary
8 Public for and within the State of New
9 York, do hereby certify:
10 That the witness whose examination is
11 hereinbefore set forth was duly sworn and
12 that such examination is a true record of
13 the testimony given by that witness.
14 I further certify that I am not
15 related to any of the parties to this
16 action by blood or by marriage and that I
17 am in no way interested in the outcome of
18 this matter.
19 IN WITNESS WHEREOF, I have hereunto
20 set my hand this 19th day of August 2019.
21
23PATRICIA A. SCHREIER
24
25
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NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
56S. BEGUM
25:24, 26:24, 27:6, 28:10, 18:15, 19:20, 24:21, 25:14, asking [4] - 12:14, 12:15,28:17, 29:21, 30:4, 30:18, 27:5, 47:4, 51:5 13:8
'13 [1] - 40:12 31:19, 32:6, 33:4, 33:8, AII [10]- 3:6, 8:20, 9:19, 13:6, Associates [1] - 1:2135:15, 35:25, 40:10, 47:23 18:4, 22:13, 25:21, 32:7, At [1] - 48:23
1 About [1] - 42:16 39:9, 48:22 at [63]- 1:20, 3:3, 3:4, 3:7,
10038 [1] - 2:16 about [59]- 6:13, 12:12, allowed [1] - 49:21 3:12, 3:18, 6:3, 6:8, 6:24,
10:25 [1] - 1:14 12:14, 13:8, 13:20, 16:13, Almost [1] - 11:17 10:19, 10:22, 10:25, 18:8,
114 [1] - 2:10 17:19, 17:21, 17:24, 17:25, almost [2] - 11:19, 11:20 18:9, 18:16, 19:20, 21:11,
11501 [1] - 2:11 18:7, 18:13, 18:16, 18:23, already [2] - 29:10, 31:21 21:22, 24:13, 25:3, 27:5,
11556 [1] - 2:5 19:2, 19:3, 19:6, 19:7, also [81- 23:10, 30:5, 30:23, 29:23, 29:25, 30:12, 30:13,19:8, 19:9, 19:15, 19:19, 34:11, 37:3, 46:21, 52:2, 31:8, 32:10, 32:20, 33:9,12 [1] - 9:920:7, 21:6, 21:7, 22:3, 52:11 33:11, 33:14, 34:7, 34:16,123 [1] - 2:1622:23, 23:16, 25:3, 25:16, ALSO [1] - 2:19 34:22, 35:5, 35:7, 35:23,12:05 [1] - 52:1428:3, 28:12, 29:2, 29:13, alternate [1] - 41:17 36:7, 36:13, 36:18, 37:5,
12th [1] - 13:1830:5, 30:11, 30:22, 31:2, am [4] - 13:14, 27:6, 55:14, 37:7, 37:23, 38:4, 38:24,
1370 [1] - 2:4 31:3, 31:7, 31:8, 31:10, 55:17 39:16, 41:6, 44:9, 44:15,13th [1] - 2:5 31:16, 34:2, 36:12, 36:17, American [1] - 10:8 46:8, 46:19, 46:23, 46:24,14203 [1] - 1:22 36:21, 37:2, 38:5, 39:24, AND [4] - 4:10 4:13 4:16, 47:3, 47:8, 47:25, 49:11,14215 [1] - 5:7 42:9, 42:15, 42:21, 43:17, 4:20 49:14, 49:21, 50:17, 52:14,19th [1] - 55:20 47:6, 48:18, 49:3 AND/OR [2] - 54:15, 54:16 53:10
above [1] - 53:6 another [2] - 18:14, 47:2 attendance [1] - 3:152 accompanied [1] - 3:23 answer [13]- 3:8, 3:12, 3:17, attorney [3] - 3:13, 3:21, 4:4
2 [1] - 1:13 action [3] - 48:16, 48:20, 3:17, 3:21, 3:22, 3:23, attorneys [3] - 2:14, 4:20,
2005 [1] - 10:7 55:16 3:24, 5:22, 5:25, 11:11, 4:22
2007 [1] - 9:9 activities [3] - 49:5, 49:21, 48:16, 51:18 Attorneys [2] - 2:4, 2:8
2012 [3] - 10:12, 16:11, 16:18 50:3 answered [2] - 3:20, 4:6 August [2] - 1:13, 55:20
2013 [81- 12:9, 12:16, 12:20, ActuaHy [3] - 12:13, 45:4, Answered [1] - 10:14 Avenue [2] - 5:7, 6:9
14:21, 15:6, 15:10, 17:9,49:19 Any [1] - 3:22 aware [51- 14:21, 14:24,
40:13 actuaHy [1] - 12:20 any [38]- 3:13, 3:21, 4:11, 43:22, 48:25, 49:20
2019 [3] - 1:13, 9:10, 55:20 Administrator [2] - 1:7, 2:9 5:17, 14:14, 14:21, 14:25,208 [1] - 2:10 admission [1] - 38:25 15:4, 15:6, 28:16, 28:24, B
20 [1] - 53:19 admissions [2] - 38:19, 29:6, 31:15, 31:22, 36:12, B [2] - 5:6 54:2221 [Ï - 3:2, 4:2 38:23 36:17, 38:5, 38:14, 38:17, b - 3:5 3:10221 1 - 3:3 admitted [10]- 33:5, 33:10, 38:18, 38:23, 39:17, 43:23,
221.2 [ ] - 3:17, 4:7 33:12, 33:15, 33:23, 34:12, 44:14, 45:13, 46:8, 46:18,37:6, 47:19, 47:20, 47:22 46:23, 47:8, 48:9, 48:11221.3 [1] - 4:3
after [30]- 13:22, 14:4, 48:24, 49:4 49:20, 49:25 bacM12] - 12:24, 13:2,24 [1] - 9:9
18:25, 19:5, 19:14, 20:13, 50:2, 50:24 55:15 2424, 2U, 2&2, 2M,25th [1] - 2:16
20:18, 20:24, 21:21, 22:6, anybody [2] - 37:24, 50:9 322, 32M, 3W , 3&22,295 [1] - 1:21
22:8, 22:10, 22:12, 22:15, anyone [1] - 34:6 39:22, 40:3
25:7, 26:7, 26:11, 26:15, Anything [1] - 36:22bad [1] - 20:5
3 28:21, 29:7, 31:14, 38:19, anything [14]- 22:2, 22:5,angladesM - 120, 122,
31 [2] - 1:19, 3:10 38:25, 39:10, 39:14, 40:4, 31:8, 34:9, 35:2, 35:4,10:18, 11:2, 12:21
3115 [3] - 3:5, 3:14, 3:22 40:9, 45:5 36:23, 36:25, 37:25, 38:8,basis [2] - 3M, 123
After [71- 23:8, 24:24, 26:2, 42:14, 42:21, 49:3, 49:5be [23]- 3¼, 32, 37, 32,
5 35 5· 35 6· 38% 39 20 apply [1] - 3:9 3:11, 3:23, 4:6, 4:8, 4:10,
again [9] - 16:17, 26:7, appropriate [2] - 3:9, 4:185 [1] - 54:12 26:11, 26:14, 26:18, 27:4, are [71- 5:17 9:2, 14:21 , , 22, W,510843/2015E [1] - 1:6 27:11, 32:9, 32:17 50:3, 51:5, 51:13, 52:2548 [2] - 5:6, 6:8 against [1] - 1:6 Are [6] - 8:11, 10:8, 12:14,
41:3, 45:11
ago [1] - 9:12 13:20, 43:22, 49:20A agree 1] - 7:24 Are there [2] - 48:9, 49:4
A.H [9] - 1:3, 7:20, 8:9, 8:12,AGREED [41- 4:10, 4:13, around [1] - 20:14
8:13, 8:16, 8:21, 8:22, 17:4 4:16, 4:20 Article [2] - 1:19, 3:10been [6] - 5:3, 5:8, 17:10
a.m [1] - 1:14 agreeing [3] - 51:6, 51:14, as [13]- 1:3, 1:7, 2:9, 3:11, 43:4, 47:13, 53:4ability [1] - 5:5 52:2 3:13, 3:21, 4:11, 4:14, 5:9, Before [51- 12:7, 13:13,able [31]- 6:10, 7:10, 11:23,
ahead [1] - 29:20 16:15, 19:25, 37:2, 44:914:20, 15:5, 16:18
13:14, 14:10, 15:8, 15:21,Aid [2] - 46:15, 46:16 As [1] - 16:5
before [18]- 1:22, 3:7, 4:1016:6, 17:6, 17:11, 18:11,
all [16]- 3:17, 4:5, 4:14, 4:17, aside [1] - 47:94:11, 4:14, 16:13, 20:3
20:12, 20:22, 21:20, 25:8, 8:5, 8:6, 10:22, 10:25, ask [3] - 5:15, 6:20, 37:24
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56
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NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
57S. BEGUM
20:13, 22:21, 23:4, 23:11, camp[1]-50:17 complaint[1]-31:10 50:6, 50:13, 51:2, 51:8,25:12, 32:25, 45:3, 45:7, can[5]-8:5, 8:7, 9:4, 11:11, complaints[21]-11:24, 51:20, 52:1246:4, 46:25, 53:18 48:16 12:11, 12:19, 17:13, 17:16, Currently [3] -13:25, 49:16,
BEGUM[2]-1:17, 53:15 Can you[2]-16:17, 18:12 18:6, 18:9, 18:16, 20:2, 49:17being[1]-35:18 can't[2]-5:23, 49:6 20:19, 22:3, 22:23, 23:5,bending[1]-19:23 cannot [3] -4:17, 6:2, 50:4 23:9, 25:12, 27:21, 28:3, DBengali[5]-2:20, 5:2, 12:8, cardiologist[8]-43:3, 43:8, 38:5, 38:15, 38:17, 48:24
12:22, 21:3 43:13, 43:17, 44:6, 44:8, complete[2]-3:25, 5:24 D [3] -5:6, 53:2, 54:9
besides[1]-47:2 46:17, 48:11 completed[1]-10:16 d[1]-3:5
best[1]-5:5 cardiology[1]-44:4 completely[1]-17:24 D.0[2]-1:9, 2:15
better [3] -11:9, 12:4, 12:6 care[1]-35:9 compliance[1]-3:6 date [3] -6:16, 9:4, 24:7
between[4]-4:20, 11:8, Care [3] -35:11, 48:6, 48:7 concluded[1]-52:16 DATE[1]-1:13
27:8, 28:6 CARMEN[2]-1:9, 2:15 condition[11]-21:6, 25:4,dates[1]-9:6
Between [3] -11:13, 27:2, case[1]-5:14 27:12, 27:14, 27:15, 29:2,daughter [3] -9:8, 9:9, 9:11
28:13 cause [3] -3:20, 48:16, 31:17, 37:2, 38:6, 42:22,daughters[1]-9:3
birth [3]-6:16, 9:5, 9:7 48:20 50:5 David[1]-40:22
bit[2]-11:5, 11:7 Center [3] -5:14, 41:13, 47:9 conditions[1]-14:22 day[1o]-18:14, 18:22, 24:3,
blood[10]-44:19, 45:2, center [3] -41:7, 41:10, 44:9 CONDUCT[2]-3:2, 4:2 25:9, 25:12, 26:19, 32:15,
45:7, 45:11, 45:14, 45:18, CENTER[2]-1:9, 2:15 confidentiality[1]-3:18 38:13, 53:19, 55:20
45:20, 45:25, 46:3, 55:16 certify [3] -53:4, 55:9, 55:14 confusion[1]-13:7 days[16]-18:15, 22:11,
body[41-18:3, 20:8, 28:9, CERTIFY[1]-53:8 CONNICK[1]-2:8 22:15, 26:25, 28:21, 33:19,
28:11 charge[1]-4:22 consent[1]-4:5 33:20, 33:24, 34:8, 34:13,
born[1]-9:11 check[1]-21:14 continue[1]-41:3 34:17, 34:22, 35:7, 36:3,
both[4]-6:2, 23:13, 32:11, checked[1]-21:12 controlling[1]-4:18 37:6, 38:24
51:13 checkup[1]-38:21 conversation[2]-31:23,Deceased[1]-1:8
boy[1]-7:16 children[2]-7:5, 7:13 32:6deemed[1]-4:17
breath[6]-29:23, 29:25, citizen[2]-10:8, 10:11 conversations[41-28:25,defect[1]-3:13
30:24, 31:2, 32:22, 32:25 Civil[2]-1:19, 3:5 29:6, 31:16, 39:17 DEFENDANTS[1]-1:10
breathe[1]-29:14 clarification [3] -31:25, copy [3] -4:21, 51:19, 52:10 Defendants [3] -1:18, 2:8,
breathing[1]-29:13 34:2, 47:18 Correct[1]-8:32:14
Brooklyn[1]-15:15 clear [3] -3:13, 3:23, 17:24 correct[2]-40:4, 53:9 degree[2]-10:16, 10:17
Buffalo[14]-1:21, 5:7, clearly[1]-4:8 CORTIS[2]-1:9, 2:15 deponent[71-3:12, 3:17,
39:15, 40:7, 40:15, 40:17, clerk[1]-4:11 coughing[6]-21:8, 23:18,3:21, 3:24, 43, 45, 51:11
43:4, 43:5, 43:14, 43:24, clinic[1]-41:7 27:24, 30:22, 31:4, 31:10 deposition[10]-3:4, 3:7,
46:14, 47:12, 47:16, 51:23 college [3] -14:12, 14:15 could[4]-6:13, 12:9, 12:17,3:8, 3:8, 3m, 3d8, 3:25,
busy[1]-24:2 14:17 13:10 4:4, 51:5, 51:10
but[26]-6:21, 11:11, 13:7, Columbia[171-35:12, 35:13 Could[2]-14:9, 26:24DENSmœ[1]-1:16
17:25, 18:10, 20:14, 20:23, 35:20, 35:24, 36:7, 36:14, Country[1]-2:10 DEPOS>ITIONS[2]-3:2, 4:2
20:24, 22:15, 23:14, 25:8, 36:18, 37:7, 37:23, 38:4 county[1]-10:17Depositions[1]-3:3
28:12, 28:18, 29:22, 30:17, 38:10, 38:19, 38:24, 39:11 COUNTY[2]-1:2, 55:5SCMM[1]-¾5
30:18, 31:2, 33:3, 33:9, 39:16, 39:21, 40:4 course[1]-3:15determining[1]-4:6
33:20, 38:22, 39:15, 40:8, come[2]-9:23, 10:5 COURT[1]-1:2did [33]-14:24, 15:4, 15:10,
42:2, 48:16, 50:9 coming[1]-51:3 court[2]-3:19, 4:12 15:24, 16:10, 16:23, 17:4,
But [3] -37:14, 38:23, 42:17 comments[1]-3:16 covered[2]-47:25, 48:13 , 2 , 2 2, 225,
BY[5 -2:6, 2:11, 2:17, 5:10, communicating[1]-4:4 CPLR[6]-3:10, 3:14, 3:22,2,
Communication[1]-4:3 4:15, 4:17, 4:18by [19]- 18, 7, 3:14, 3:23, communication[2]-4:5, 4:8 Cristiano[2]-51:14, 52:3
23:22 33:18 41:7 41:8, , CRISUANO[571-2:6, 6:17, 40:16, 43:9, 43:11, 43:12,
17:25, 18:3, 18:10, 19:2, 7:21, 8:3, 8:11, 8:17, 9:14,4 , 48:13, 53:10, 55:13, 19:6, 19:15, 20:14, 20:24, 9:17, 10:13, 11:10, 11:15, D -1 24, 24:13, 26:6,
49:2 11:25, 12:23, 13:6, 15:2, 26:10, 34:15, 34:20, 36:12complained[12]-17:20, 17:8, 18:18, 19:11, 20:10, 36:16, 42:11, 45:6, 45:13,
18:13, 18:25, 19:5, 19:8, 22:9, 22:13, 22:25, 24:11, 46:3c[1]-3:5 19:9, 19:14, 19:19, 21:7, 24:17, 25:5, 25:18, 25:21, did he[18]-17:16, 17:21C[41-2:2, 53:2, 55:2 29:13, 30:22, 31:9 27:13, 29:3, 29:9, 29:17, 18:3, 18:6, 19:2, 19:6called[2]-14:7, 41:12 complaining[14]-18:22, 30:15, 31:24, 33:25, 34:23, 19:15, 21:14, 22:2, 26:17
came[7]-10:2, 10:23, 20:6, 23:17, 25:16, 27:25, 35:9, 36:19, 37:10, 39:5, 28:15, 35:8, 36:25, 38:4
15:20, 24:24, 25:7, 26:2, 28:8, 28:11, 28:12, 29:8, 39d2, 40d3, 40:24, 42:23, 38:10, 38:23, 41:6, 45:238:11 30:2, 30:11, 30:13, 30:23, 43:10, 44:11, 45:9, 46:20, Did she[1]-43:10
31:18 47:17, 48:14, 48:21, 49:16,
DIAMOND REPORT NG (877) 624-3287 [email protected]
57
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
58S. BEGUM
did they[1]-24:14 48:21, 49:18, 49:19, 50:19, Everything[1]-6:5 32:24, 33:3, 33:23, 33:25,Did you[161-9:23, 10:10, 50:23, 51:21 everything[2]-22:7, 48:12 34:8, 34:13, 34:17, 34:22,
10:15, 10:25, 15:23, 16:3, done[1]-29:17 exact [3] -26:19, 26:25, 35:7, 36:7, 37:6, 37:22,20:20, 21:2, 24:9, 31:7, down[2]-6:2, 8:7 28:11 38:21, 38:24, 39:10, 41:22,33:22, 36:6, 36:9, 37:21, Dr[52]-12:21, 13:5, 15:13, exactly[15]-6:10, 7:10, 42:11, 43:23, 47:11, 47:17,39:17, 40:6 15:15, 15:18, 15:23, 16:4, 15:9, 17:7, 20:12, 20:22, 48:10, 51:2, 51:9, 52:12,
didn't[6]-7:2, 12:13, 23:25, 16:9, 16:15, 16:19, 20:16, 20:25, 22:14, 24:4, 24:23, 55:8
26:9, 34:25, 35:3 20:20, 21:2, 21:5, 21:10, 28:17, 30:4, 33:9, 36:2, For[4]-24:17, 33:14, 35:9,different[4]-18:9, 30:13, 21:22, 22:6, 22:16, 22:20, 40:8 43:25
30:17, 44:10 23:4, 23:8, 23:11, 23:19, examination[5]-3:15, 4:14, force[1]-4:11digital[1]-52:7 26:4, 27:5, 28:18, 28:21, 4:21, 55:10, 55:12 foregoing[1]-53:8diploma[1]-10:17 28:25, 29:7, 30:21, 31:9, Examination[1]-52:15 forgot[1]-14:10direct[1]-3:21 31:13, 31:16, 39:18, 39:22, EXAMINATION[2]-5:10, form[1]-3:13direction[1]-3:22 40:3, 40:21, 40:22, 41:15, 54:11 forth [3] -3:19, 4:7, 55:11
directly[2]-35:20, 37:13 41:20, 41:24, 42:8, 42:11, examine[1]-21:10 framed[1]-3:11discharged [3] -38:9, 38:14, 42:20, 43:2, 43:8, 44:9, examined[1]-5:8 free[1]-51:19
39:10 46:18, 46:23, 47:3, 47:9, examining[2]-3:24, 21:21 FRIEDMAN[1]-2:14
do[8]-5:17, 5:19, 16:22, 48:10 except[4]-3:4, 3:6, 3:18, friends[4]-49:13, 50:16,49:6, 49:21, 50:4, 51:18, DUFFY[2]-2:3 3:21 50:18, 50:2055:9 duly[41-5:3, 5:8, 53:5, Except[1]-3:14 from [13]-12:21, 24:24,
dothey[1]-45:22 55:11 EXHIBIT[2]-54:4 26:2, 28:16, 35:19, 38:10,doyou[28]-6:24, 7:3, 7:13, During[2]-38:3, 42:19 expenses[1]-48:10 39:11, 39:21, 40:9, 46:14,
7:16, 10:19, 11:4, 11:6, during[51-3:11, 3:15, extent[1]-3:14 46:15, 47:9
12:23, 15:17, 17:12, 21:16, 31:17, 37:18, 43:3 furnished[1]-4:21
21:19, 24:6, 25:11, 26:21, F further [3] -38:19, 50:21,28:20, 28:24, 29:6, 31:15, E 55:1432:13, 33:18, 36:3, 37:17, F[1]-55:2 FURTHER[5]-4:10, 4:1340:11, 41:17, 44:21, 47:7,
]-2:2, ½, 24, 53:2, Family[2]-41:12, 47:8 4:16, 4:20 53:847:19 542, 549, 55:2 family [3]-7:5, 41:9, 44:9
doctor [23]-11:22, 11:23,e[1]-3:6 far[4]-10:15, 20:14, 20:23,
12:7, 12:8, 12:10, 12:11,earHeq2]-16:5, 43:16 31:20
12:16, 12:17, 12:18, 13:14,easier[1]-8:21 feel[1]-27:22 G[1]-5:6
19:25, 20:4, 20:9, 23:14, ECMC[6]-41:12, 46:21, felt[2]-27:20, 28:2 gave[1]-53:6
36:12, 36:17, 43:23, 45:13, 46:23, 46:24, 47:3, 47:8 FERDOUSHI[2]-1:7, 2:9 general[1]-3:3
45:20, 47:2, 49:25, 50:2,effect[1]-4:11 fever[71-17:19, 17:21, get [3] -14:15, 17:5, 51:19
50:8 either [3]-23:3, 39:21, 48:10 17:22, 17:23, 17:25, 37:2, getting [3] -22:16, 22:17,
doctors[6]-13:11, 34:16,Either[1]-32:3 37:4 32:21
37:8, 46:19, 46:24, 47:8 elbows [3] -18:5, 18:8, few[4]-18:15, 22:15, 28:21, girls[1]-7:17
DOCUMENTS[2]-54:15,19:20 38:24 give[2]-5:22, 41:24
54:16 eldest[1]-9:8 filled[1]-46:12 given [3] -3:8, 53:10, 55:13
does[6]-3:24, 41:20, 44:14, else[51-18:19, 18:20, 33:19, fine[2]-21:24, 22:8 gives[1]-42:3
46:7, 46:18, 48:23 36:22, 36:23 fingers[6]-18:4, 18:7, Glenn[1]-43:8
Does [3] -14:11, 41:24, emergency[1]-47:16 18:23, 19:2, 19:6, 19:19 Go[1]-29:20
47:24 enforce[1]-3:19 first[22]-5:3, 5:8, 15:18, go[21]-10:15, 12:3, 12:4,does he[5]-13:24, 41:3, English[12]-11:4, 11:6, 17:13, 18:13, 19:8, 20:21, 12:9, 12:20, 13:24, 14:11,
44:18, 46:23, 49:14 11:9, 11:14, 11:22, 11:24, 24:17, 24:19, 24:25, 25:10, 14:18, 24:9, 24:22, 26:4,doesn't[1]-49:2 12:6, 12:10, 12:12, 12:17, 26:3, 26:8, 26:12, 26:16, 26:6, 26:10, 26:17, 27:4,
doing[7]-22:8, 27:20, 12:18, 13:10 27:2, 27:8, 28:6, 28:13, 35:8, 38:10, 39:25, 41:19,
27:22, 28:2, 37:22, 49:9,ER[1]-47:22 28:22, 29:8, 53:5 41:22, 47:4
50:11 ERIE[1]-55:5 Fitzgerald[2]-51:13, 51:25 goes [3] -44:3, 50:19, 51:23
don't[44]-11:12, 11:18, error[1]-3:14 FITZGERALD[6]-2:8, 2:11, going [9] -5:15, 6:20, 8:11,
14:19, 15:19, 19:17, 21:15, ESQ [3] -2:6, 2:11, 2:17 50:23, 51:21, 52:4, 52:10 13:17, 14:2, 14:3, 17:2,
22:14, 23:7, 24:3, 24:20, Estate[2]-1:8, 2:9 five[1]-6:13 32:21, 47:22
24:23, 26:5, 26:19, 28:23, Even[1]-32:5 Floor[2]-2:5, 2:16 gone[2]-44:5, 47:15
30:25, 31:12, 31:22, 33:16, event[1]-4:7 follows[1]-5:9 Good[1]-5:12
33:21, 34:10, 34:18, 37:12, ever[71-16:3, 29:3, 36:25, FOR [3] -3:2, 4:2, 54:20 good[2]-21:9, 23:19
37:13, 37:20, 38:16, 38:22, 39:22, 40:3, 44:5, 45:6 for[421-2:4, 2:8, 2:14, 3:9, got[14]-13:13, 14:20, 15:5,39:7, 39:14, 39:24, 40:2, every[2]-7:24, 41:22 4:4, 4:5, 4:7, 4:8, 4:14, 17:12, 26:13, 26:17, 27:4,40:8, 41:10, 42:17, 43:15, Every[1]-3:11 4:20, 8:3, 8:21, 20:20, 27:11, 32:8, 32:17, 40:9,44:12, 47:4, 47:5, 48:17, everyone[1]-52:7 25:10, 26:3, 31:24, 32:19, 45:5, 45:8, 46:4
DIAMOND REPORT NG (877) 624-3287 [email protected]
58
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
59S. BEGUM
grade [2] - 13:16, 13:18 35:3, 36:7, 36:13, 36:18, HOLMES [1] - 40:25 37:20, 37:24, 37:25, 38:16,great [4] - 27:16, 27:18, 37:3, 37:6, 37:12, 37:14, home [4] - 16:25, 38:11, 38:22, 39:7, 39:14, 39:24,
27:19 37:18, 37:23, 38:11, 38:13, 38:12, 44:15 39:25, 40:8, 41:10, 41:19,grounds [1] - 4:7 38:16, 38:24, 39:10, 40:9, hospital [9] - 12:16, 13:4, 42:17, 43:9, 43:15, 43:20,Guardian [1] - 1:3 41:8, 42:20, 43:4, 44:3, 24:9, 33:6, 33:12, 33:15, 44:3, 44:12, 45:19, 47:4,guess [2] - 8:20, 51:16 45:3, 45:5, 45:7, 45:10, 33:23, 35:19, 37:18 47:5, 48:17, 48:21, 49:18,gym [1] - 49:14 45:23, 46:4, 46:13, 49:2, Hospital [71- 22:19, 24:6, 49:19, 49:23, 50:19, 50:21,
49:6, 49:11, 50:17 35:12, 35:14, 35:20, 35:24, 50:23, 51:16, 51:21, 53:2,
H He's [1] - 12:21 36:7 53:4, 53:5, 53:8, 54:2,he's [7] - 13:8, 13:25, 21:24, hospitalized [3] - 47:13, 54:9, 55:2, 55:7, 55:14,
H [61- 5:2, 5:6, 40:24, 54:2 46:14, 46:15, 49:21 47:19, 47:20 55:16, 55:19H-O-L-M-E-S [1] - 40:24 head [2] - 5:23, 5:24 HOSS [1] - 7:9 i [1] - 3:18had [13]- 14:22, 16:11, health [5] - 22:17, 32:20, HOSSAIN [2] - 1:4, 7:11 I'll [1] - 29:4
16:13, 16:18, 23:9, 25:14, 44:9, 47:25, 48:4 house [2] - 6:14, 7:3 I'm [481- 5:15, 6:10, 6:20,28:25, 29:7, 29:14, 29:24, Health [2] - 41:13, 47:8 How [8] - 6:8, 8:22, 10:15, 7:9, 10:7, 12:3, 12:12,32:5, 37:4, 48:12 healthcare [1] - 41:9 16:13, 18:25, 19:5, 19:14, 12:15, 14:10, 14:24, 15:8,
hand [6] - 18:23, 19:2, 19:6, heart [71- 30:6, 30:7, 30:12, 35:23 15:20, 16:6, 16:25, 17:6,19:10, 19:16, 55:20 31:7, 31:8, 43:23, 43:25 how [12]- 6:11, 9:2, 20:18, 17:11, 17:24, 18:10, 20:12,
hands [1] - 19:22 heartbeat [1] - 21:13 22:8, 22:14, 26:15, 31:7, 20:22, 20:24, 21:20, 23:14,Has [4] - 14:14, 43:7, 47:15, held [1] - 1:20 32:24, 33:14, 42:11, 42:18, 25:8, 25:24, 26:24, 28:10,
49:25 help [1] - 14:10 51:22 28:17, 29:19, 29:21, 30:4,has [11]- 21:24, 42:20, 43:2, her [51- 5:5, 8:10, 12:23, how many [3] - 7:13, 23:14, 30:17, 30:18, 31:19, 32:6,
43:12, 45:14, 45:17, 47:13, 13:11, 43:11 24:21 33:3, 33:8, 35:15, 35:25,49:25, 50:2, 50:8, 51:18 here [1] - 9:15 how often [2] - 36:9, 41:20 36:11, 39:7, 40:9, 42:2,
have [24]- 3:24, 5:22, 7:14, hereby [2] - 53:4, 55:9 husband [56]- 7:6, 9:20, 42:17, 47:23, 50:9, 51:10,7:16, 10:17, 14:25, 15:4, herein [1] - 4:22 9:24, 11:9, 11:13, 15:24, 51:1715:10, 17:18, 29:22, 30:6, hereinbefore [2] - 53:11, 16:2, 16:4, 16:9, 16:14, I've [1] - 6:531:20, 38:18, 38:23, 39:17, 55:11 16:20, 16:22, 16:23, 22:18, f [16]- 3:5, 3:20, 4:11, 8:13,41:22, 42:12, 45:6, 46:3, hereto [2] - 4:18, 4:21 22:21, 23:3, 23:4, 23:10, 12:15, 18:13, 26:21, 29:21,48:12, 48:24, 50:21, 50:23, hereunto [1] - 55:19 23:13, 23:20, 23:24, 24:2, 30:25, 32:5, 37:12, 38:16,5M9
high [3] - 13:19, 45:23, 46:3 24:5, 24:10, 24:15, 24:25, 40:2, 41:10, 50:9, 51:22have you [5] - 6:6, 6:8, High [1] - 45:25 25:2, 25:9, 25:13, 26:3, If [51- 3:24, 5:17, 11:21,
10:22, 42:8, 44:5him [46]- 13:3, 13:5, 13:13, 26:7, 26:11, 26:15, 27:9, 44:11, 49:24
having [4] - 5:3, 5:7, 32:22,15:20, 16:2, 16:6, 16:23, 28:14, 28:21, 32:10, 32:12, ii [1] - 3:18
5N17:3, 20:4, 20:8, 20:13 32:14, 32:18, 32:25, 33:6, iii [1] - 3:19
He [22]- 15:4, 17:18, 18:10,20:15, 20:23, 21:3, 22:16 34:11, 34:15, 34:20, 36:16, Immediately [1] - 22:10
19:8, 21:12, 21:24, 22:5,22:18, 23:2, 23:4, 23:14 37:7, 39:22, 39:25, 40:3, improper [1] - 3:20
22:16, 27:24, 34:25, 36:21,23:22, 23:25, 24:3, 24:14 41:17, 41:18, 48:12, 48:17, IN [1] - 55:19
36:23, 37:3, 38:7, 41:22,24:15, 25:2, 25:13, 25:17 50:2, 50:10 In [11]- 7:3, 9:22, 10:10,
44:19, 45:4, 46:25, 49:9,25:19, 25:20, 26:8, 26:12 husband's [1] - 7:7 12:9, 12:20, 13:18, 15:10,
49:13, 50:15, 50:1928:14, 28:18, 29:22, 33:2 17:4, 18:12, 35:12, 40:6
he [113]- 12:4, 12:5, 12:6,33:6, 36:10, 36:17, 38:22 in [63]- 3:3, 3:6, 3:13, 3:15,
12:7, 12:21, 13:4, 13:13, 41:18, 41:24, 45:19, 46:25 3:19, 3:22, 4:7, 4:7, 5:14,14:3, 14:14, 14:18, 14:22, 47:11
' I [126]- 5:2, 5:6, 5:13, 5:19, 9:20, 10:6, 10:15, 10:16,14:24, 16:7, 17:3, 17:13, himself [2] - 41:7, 41:8 , , 2, , 8, 10:17, 10:25, 11:24, 12:12,17:19, 17:20, 17:25, 18:13, His [2] - 22:17 27:15
8:13, 8:14, 8:18, 8:20, 9:4, 12:16, 12:18, 13:16, 13:17,18:21, 18:22, 18:25, 19:5, his [32]- 7:10 7:11 8:4 13:19, 14:14, 14:20, 15:5,19:9, 19:14, 19:18, 20:6, 17:22 18:3 18:16 18:23 15:15, 16:11, 16:18, 17:9,20:13, 20:24, 21:8, 21:12, 19:2 19:6 19:22 20:7 18:13, 19:19, 20:7, 21:3,21:24, 22:7, 23:11, 25:7, 13:14, 14:9, 14:19, 15:19, 22:11, 24:21, 29:25, 30:6,25:14, 25:15, 25:17, 25:19, 28:9 30:5 30:7 30:12 30:12, 30:17, 31:25, 32:3,25:20, 26:13, 26:17, 27:10, 32:20 38:5 41:10 33:22, 35:14, 35:21, 37:8,27:19, 27:20, 27:22, 27:24, 41:23 45:7 45:20 49:5 37:15, 37:17, 40:12, 40:17,27:25, 28:2, 28:7, 28:8, 49:13 50:4 50:15 50:18 41:9, 43:4, 43:23, 44:8,28:11, 28:12, 28:15, 29:14, 50:19 47:12, 49:9, 49:14, 50:18,29:22, 29:24, 30:2, 30:5, 24:20, 24:23, 26:5, 26:9, 51:3 51:23 55:1730:6, 30:8, 30:12, 30:18,
H4 3 1 16 :21 24 include [1] - 3:1330:21, 31:18, 32:8, 32:21,
42:9 42:11 42:20 43:2 independent [2] - 48:15,32:22, 33:9, 33:11, 33:12 ' ' ' ' 31:2, 31:12, 31:20, 32:5,33:15, 33:23, 34:7, 34:19, 4t9, 46d 8, 4&23, R3, 33:16, 33:20, 34:9, 34:18,
47:10, 48:1035:2, 35:21, 37:12, 37:13,
DIAMOND REPORT NG (877) 624-3287 [email protected]
59
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
60S. BEGUM
Infant [1] - 1:3 joints [2] - 18:4, 18:16 26:15, 32:24, 33:3, 33:14, MEDICAL [2] - 1:9, 2:15INFORMATION [2] - 54:15, Judge [1] - 4:12 35:23, 42:12, 42:18 Medical [1] - 5:13
54:16 June [1] - 9:9 look [1] - 23:18 medical [6] - 11:23, 12:11,initials [4] - 7:22, 8:2, 8:6, Just [20]- 6:17, 7:21, 9:17, losing [1] - 27:24 14:21, 29:2, 41:7, 42:21
8:18 10:13, 11:10, 11:15, 22:9, lost [1] - 9:15 medication [61- 44:15,injection [3] - 41:23, 42:3, 25:5, 27:13, 30:15, 31:24, lot [1] - 29:14 44:20, 44:22, 45:3, 45:24,
42:6 33:25, 34:23, 37:10, 39:12, 46:11injections [6] - 41:25, 42:9, 42:23, 45:9, 46:20, 47:17, M medicationS [3] - 15:7, 46:8,
42:13, 43:18, 44:14, 46:7 48:14 48:11instead [3] - 16:4, 16:21, just [9] - 7:25, 8:5, 8:7, 8:15,
M [61- t8, 2:9, 5:2, 5:6, mention [1] - 31:816:24 8:18, 37:3, 44:3, 47:22,
40:24 mentioned [4] - 29:22, 30:5,instructions [1] - 5:21 50:17 M.D [4] - t8, t9, 2:9, 2d5
31:2, 36:21insurance [3] - 47:25, 48:5,
made [7] - 3:4, 3:7, 3:17, 4:5, Metschl [1] - 1:2048:13 K 18:9, 27:22, 38:17 Mineola [1] - 2:11
intend [1] - 14:11 Maimonides [40]- 5:13, Minnesota [2] - 5:6, 6:9. Kamal [36]- 12:21, 13:5, 22:18, 22:22, 23:5, 23:12,mterested [1] - 55:17
15:13, 15:15, 15:18, 15:23, 24:6, 24:11, 24:14, 24:16interfere [1] - 3:16
16:4, 16:9, 16:15, 16:19, 24:22, 24:25, 25:3, 25:10,interposed [1] - 3:620:16, 20:20, 21:2, 21:5, 26:3, 26:6, 26:10, 26:16,interpret [1] - 5:421:10, 21:22, 22:7, 22:16, 27:3, 27:9, 27:10, 28:7,Interpreter [2] - 2:20, 5:322:21, 23:4, 23:9, 23:11, 28:14, 28:15, 28:22, 32:8,
2 , 2d0interrupt [1] - 4:4
23:19, 26:4, 27:5, 28:18, 32:10, 32:14, 32:19, 33:2,month p1] - 9:12, 21:16,
into [2] - 13:17, 14:1528:21, 28:25, 29:7, 30:21, 33:12, 34:3, 34:4, 34:8, 36:5, 36:7, 37:18, 38:3,
involved [2] - 37:8, 37:14 31:10, 31:14, 31:16, 39:18, 34:12, 34:16, 34:22, 35:6, 38:20, 38:25, M, C O,irregularity [1] - 3:14 39:23, 40:4 35:7, 35:19, 37:5 41:22IS [41- 4:10, 4:13, 4:16, 4:20 KAMAL [6] - 1:7, 1:8, 1:8, MAIMONIDES [2] - 1:9, 2:15 more [81- 612, 11M, 169,Is [5] - 6:12, 7:11, 41:12, 2:9, 2:9, 2:10 Main [1] - 1:21 22:22, 29:4, 32:5, 37:7,
44:8, 49:11 KINGS [1] - 1:2 make [4] - 3:16, 17:17, 18:6,3W
is [33]- 3:8, 3:17, 3:20, 4:5, know [23]- 11:12, 14:19, 38:4 morning [2] - 5:12, 5:16
5:12, 8:22, 9:8, 9:9, 13:7, 24:6, 26:21, 32:13, 34:18, making [51- 17:14, 20:19, MosW p] - C 8
13:10, 13:16, 14:3, 14:7, 36:4, 37:12, 37:13, 37:17, 27:21, 28:3, 38:14 move [1] - 40:7
31:25, 39:3, 41:8, 41:10, 38:21, 41:10, 44:3, 44:11, Manhattan [1] - 35:14 moved [4] - 39:15, 40:15,43:12, 46:12, 47:5, 47:11, 44:12, 44:21, 47:6, 47:7, March [1] - 9:8 43:14, 47:16
47:20, 47:21, 47:24, 48:12, 48:17, 49:18, 49:19, 50:19, MARKED [1] - 54:20Mr [3] - 51:12, 51:14, 52:3
48:15, 48:19, 50:17, 51:4, 51:21 MARLA [2] - 1:9, 2:15 W5] - 5m , W, m ,51:17, 53:9, 55:10, 55:12 known [1] - 37:2 marriage [1] - 55:16 7:23, 8:3, 8:8, 8:11, 8:13,
is that [4] - 5:22, 6:14, 13:19, knows [1] - 48:18 married [2] - 9:19, 10:2 , 20, W, W,35:13 10:13, 11:10, 11:15, 11:25,
Is there [6] - 14:17, 16:8, 12:23, 12:25, 13:6, 13:12,16:14, 16:19, 23:23, 49:5
L may [3] - 4:10, 4:14, 9:1415:2, 17:8, 18:18, 19:11,
Is this [3] - 20:16, 42:5, L [2] - 40:24, 53:2 maybe [1] - 39:320:10, 22:9, 22:11, 22:13,
50:17 last [3] - 7:11, 33:9, 33:11 Maybe [30]- 10:7, 10:12, 22:25, 24:11, 24:17, 25:5,IT [4] - 4:10, 4:13, 4:16, 4:20 later [41- 18:15, 26:22, 26:23 13:4, 13:7, 14:9, 17:10, 25:18, 25:21, 27:13, 29:3,it [22]- 6:12, 6:22, 15:25 Law [2] - 1:19, 3:5 24:2, 25:14, 25:15, 25:16, 29:4, 29:9, 29:11, 29:17,
16:22, 17:22, 18:23, 26:21, legs [2] - 18:5, 19:22 25:18, 25:20, 26:5, 30:17, 30:15, 31:24, 33:25, 34:4,27:17, 29:22, 30:5, 39:3 Leonard [1] - 43:8 30:18, 31:6, 33:3, 33:16, 34:23, 35:9, 36:19, 37:10,41:10, 41:12, 45:5, 46:13, LEVINE [2] - 1:9, 2:15 3&20, 35:15, 35:21, 35:22, 39:5, 39:12, 40:13, 40:24,47:6, 48:18, 48:21, 49:3, Like [1] - 29:14 36:5, 38:21, 39:2, 40:12, 42:23, 43:10, 44:11, 45:9,49:9, 51:18, 51:23 like [1o]- 5:18, 11:20, 19:23
, , 45:4, 49:1846:20, 47:17, 48:14, 48:19,
It [2] - 6:13, 20:4 27:12, 27:20, 28:2, 30:6,' McALOON [1] - 2:14
48:21, 48:22, 49:16, 50:6,it's [2] - 8:21, 17:10 32:21
McNAMEE [1] - 2:8 50:13, 50:21, 50:25, 51:2,It's [1] - 41:9 limitation [1] - 3:19
me [22]- 5:18, 5:19, 8:21, 51:8, 51:16, 51:20, 51:22,
limitations [1] - 49:4 9:6, 21:9, 27:19, 34:9, 52:9, 52:12, 54:12
LINE [1] - 54:21 34:25, 35:4, 36:24, 37:3, MS [41- 50:23, 51:21, 52:4,37:25, 38:7, 42:14, 43:20, 52:10
J [2] - 2:6, 5:64r 5 23, M24, 45:21, 49:3, 49:24, 50:8, Ms [2] - 51:13, 51:25
joint [19]- 17:18, 18:7, 20:7, little [3] - 11:5, 11:7, 43:16 much [5] - 11:5, 11:7, 27:25,20:19, 21:8, 22:3, 22:23, mean [4] - 29:16, 30:8, 47:6, 50:2223:6, 23:9, 23:17, 28:4,
e 2] 2 , 33:18, 47:19My [7] - 5:12, 7:5, 16:2,
28:8, 29:8, 30:2, 30:13, meaning [1] - 31:416:22, 23:13, 32:12, 48:17
30:22, 31:5, 31:11, 31:182
meant [2] - 11:19, 43:20my [35]- 5:24, 7:5, 10:13,
DIAMOND REPORT NG (877) 624-3287 [email protected]
60
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
10:16, 11:10, 11:15, 12:3, 12:5, 12:14, 15:2, 19:11, 20:10, 22:18, 22:25, 24:2, 27:13, 30:15, 34:23, 36:19, 37:10, 38:11, 39:5, 39:12, 39:24, 41:18, 42:23, 43:20, 45:9, 48:14, 49:24, 50:6, 50:9, 50:13, 55:20
MYERS [1] - 2:8myself [1] - 23:22
NN [4] - 2:2, 5:2, 53:2, 54:9name [12] - 5:12, 7:8, 7:10,
7:11, 7:19, 7:25, 8:15, 14:4, 40:19, 44:21, 46:10, 48:4
named [1] - 43:8names [1] - 47:7Natural [1] - 1:3neck [10] - 18:5, 18:8, 18:24,
19:3, 19:7, 19:8, 19:15, 19:20, 19:23
need [1] - 42:12needs [2] - 12:7, 45:24never [1] - 13:3NEW [2] - 1:2, 55:4New [8] - 1:21, 1:23, 2:5,
2:11, 2:16, 5:7, 55:8next [3] - 13:20, 18:14, 35:8nighttime [3] - 29:23, 29:25,
32:20no [9] - 14:24, 21:24, 39:2,
39:3, 48:15, 48:19, 50:21, 55:17
No [39] - 1:6, 3:3, 9:25, 10:21, 10:24, 11:3, 12:15, 14:23, 14:24, 15:19, 21:18, 21:20, 22:5, 24:8, 24:12, 26:5, 28:23, 29:4, 29:18, 34:9, 34:25, 36:15, 37:20, 37:24, 38:7, 39:19, 40:5, 42:10, 42:14, 42:25, 43:6, 43:9, 44:7, 46:5, 46:9, 47:14, 49:13, 50:8
nobody [1] - 37:25Nobody [1] - 42:14nod [1] - 5:23non [1] - 1:17non-party [1] - 1:17none [1] - 54:6None [2] - 54:17, 54:22nonparty [1] - 51:5not [81] - 3:6, 3:12, 3:15,
3:21, 3:21, 3:22, 3:24, 4:4, 4:6, 5:17, 6:10, 6:22, 7:10, 10:7, 11:5, 11:7, 11:24, 13:14, 14:10, 14:24, 14:25, 15:4, 15:8, 15:20, 16:6,
17:2, 17:6, 17:11, 17:24, 18:11, 19:4, 20:12, 20:22, 20:24, 21:9, 21:20, 22:5, 23:14, 23:18, 25:8, 25:24, 26:24, 27:6, 27:15, 27:17, 27:18, 27:19, 27:20, 27:22, 28:2, 28:10, 28:17, 29:21, 30:4, 30:17, 30:18, 31:19, 32:6, 33:4, 33:8, 35:15, 35:21, 35:25, 36:23, 37:24, 38:7, 39:4, 39:7, 39:25, 40:9, 41:11, 42:2, 42:17, 43:9, 47:21, 47:23, 49:21, 49:23, 50:9, 51:17, 55:14
Notary [3] - 1:23, 4:11, 55:7NOTARY [1] - 53:22note [12] - 10:13, 11:10,
11:15, 25:5, 27:13, 30:15, 37:10, 39:12, 42:23, 45:9, 46:20, 48:14
Note [8] - 15:2, 19:11, 20:10, 22:25, 36:19, 39:5, 50:6, 50:13
noted [1] - 3:7Notice [1] - 1:18Now [2] - 12:3, 49:2now [17] - 7:4, 12:3, 12:4,
15:20, 25:25, 27:7, 31:20, 32:6, 33:21, 34:3, 34:18, 35:16, 36:11, 45:15, 46:15, 47:2, 47:21
Number [1] - 6:21NUMBER [1] - 54:5nurse [5] - 42:2, 42:3, 45:20,
47:5, 47:11
OO [3] - 5:2, 40:24, 53:2Objection [1] - 17:8objection [23] - 3:11, 3:17,
10:14, 11:11, 11:16, 15:3, 19:12, 20:11, 23:2, 25:6, 27:14, 30:16, 34:24, 36:20, 37:11, 39:6, 39:13, 42:24, 45:10, 48:15, 50:7, 50:14
Objections [2] - 3:3, 3:3objections [4] - 3:4, 3:7, 3:9,
3:10observe [1] - 37:21OF [7] - 1:2, 1:2, 3:2, 4:2,
55:4, 55:5of [87] - 1:7, 1:8, 1:16, 1:19,
1:20, 1:23, 2:9, 2:9, 3:5, 3:6, 3:9, 3:10, 3:12, 3:13, 3:15, 3:18, 3:19, 3:23, 3:25, 4:4, 4:6, 4:7, 4:12, 4:18, 4:21, 5:5, 6:2, 6:16, 8:6, 9:4, 9:6, 14:4, 14:21, 16:4, 16:21, 16:24, 18:2,
18:3, 19:25, 20:7, 20:19, 21:16, 21:22, 22:3, 23:6, 23:9, 23:17, 28:8, 28:9, 29:8, 29:23, 29:25, 30:2, 30:13, 30:23, 31:2, 31:10, 31:18, 32:11, 32:22, 32:25, 40:19, 43:22, 44:21, 46:10, 47:7, 47:8, 48:4, 48:9, 48:16, 48:20, 48:25, 49:20, 50:4, 51:9, 51:17, 52:15, 53:10, 53:19, 55:8, 55:12, 55:15, 55:17, 55:20
officer [1] - 3:7offices [1] - 1:20okay [5] - 13:4, 27:20, 27:23,
28:2, 51:24Okay [3] - 14:9, 51:20, 52:4old [2] - 8:22, 9:2Old [1] - 2:10Olmstead [2] - 14:6, 14:7OLMSTEAD [1] - 14:8on [13] - 4:6, 6:22, 8:6, 8:18,
23:24, 25:12, 30:20, 32:2, 32:3, 38:13, 49:4, 49:11, 51:8
On [1] - 25:9once [6] - 13:4, 13:14, 16:6,
20:4, 33:16, 33:18one [20] - 6:3, 7:16, 15:25,
18:13, 18:22, 22:20, 22:22, 33:19, 33:20, 33:23, 34:8, 34:9, 34:13, 34:17, 34:22, 35:7, 36:5, 37:6, 38:20, 38:25
only [3] - 5:21, 12:10, 12:17opposed [1] - 16:15or [67] - 3:5, 3:13, 3:14, 3:14,
3:16, 3:18, 3:19, 3:22, 3:22, 4:5, 4:11, 5:18, 5:23, 9:20, 11:24, 12:16, 13:5, 13:14, 14:24, 15:24, 15:25, 16:6, 17:22, 18:2, 18:4, 18:8, 18:15, 20:4, 20:13, 22:22, 23:3, 23:20, 24:14, 26:22, 26:25, 30:13, 31:25, 32:3, 32:11, 33:16, 33:18, 33:19, 33:20, 37:19, 37:21, 39:4, 39:21, 41:7, 41:10, 41:16, 41:17, 43:10, 44:9, 48:10, 48:11, 48:12, 49:24, 49:25, 50:17, 52:7, 55:16
Or [2] - 18:18, 18:20order [2] - 3:19, 14:14Other [7] - 29:11, 31:4,
31:13, 43:2, 44:13, 46:6, 46:17
other [9] - 3:13, 15:25, 18:12, 29:9, 31:3, 31:15, 31:22, 46:18, 46:24
others [1] - 21:13
S. BEGUM
DIAMOND REPORTING (877) 624-3287 [email protected]
61
out [1] - 48:9out-of-pocket [1] - 48:9outcome [1] - 55:17outpatient [1] - 39:11over [3] - 10:14, 15:23, 34:23overnight [1] - 24:13own [2] - 41:10, 51:6
PP [3] - 2:2, 5:2P.C [3] - 1:8, 2:10, 2:14P.M [1] - 52:14PAGE [4] - 54:4, 54:11,
54:16, 54:21pain [29] - 17:18, 17:19,
17:25, 18:3, 18:7, 18:13, 19:19, 20:7, 20:20, 21:8, 22:4, 22:24, 23:6, 23:10, 23:17, 28:4, 28:8, 28:12, 29:8, 30:3, 30:6, 30:11, 30:13, 30:22, 31:5, 31:7, 31:8, 31:11, 31:18
Paley [2] - 5:13, 51:12PALEY [20] - 2:17, 5:11,
7:23, 8:8, 8:13, 8:20, 12:25, 13:12, 22:11, 29:4, 29:11, 34:4, 48:19, 48:22, 50:21, 50:25, 51:16, 51:22, 52:9, 54:12
paper [3] - 52:7, 52:10, 52:12Paper [1] - 52:9part [2] - 18:2, 28:9participate [1] - 49:14particular [1] - 14:17parties [4] - 4:5, 4:17, 4:21,
55:15parts [3] - 18:2, 20:7, 28:11party [2] - 1:17, 3:24PATRICIA [2] - 55:7, 55:23Patricia [1] - 1:22PAUL [1] - 2:17Paul [1] - 5:12pediatrician [4] - 15:11,
40:17, 40:20, 41:4penicillin [5] - 42:5, 42:7,
43:18, 44:13, 46:7permitted [1] - 3:14person [4] - 3:9, 3:21, 31:25,
32:3persons [1] - 3:15pharmacy [1] - 46:11phone [2] - 32:2, 32:4physical [8] - 31:17, 38:5,
38:14, 48:24, 49:5, 49:20, 50:3, 50:4
physically [1] - 49:6PHYSICIAN [2] - 1:8, 2:10pill [1] - 45:12place [4] - 18:14, 44:10,
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
53:11plainly [1] - 3:20PLAINTIFF [1] - 1:5Plaintiff [1] - 2:4playing [1] - 50:18plays [3] - 49:9, 49:13, 50:15Plaza [1] - 2:4please [5] - 5:19, 7:22, 9:18,
12:25, 52:9Please [1] - 9:6PLLC [2] - 2:3, 2:8pneumonia [1] - 36:21pocket [1] - 48:9Practice [2] - 1:19, 3:5prefer [2] - 8:14, 52:7prejudice [1] - 3:20Presbyterian [2] - 35:13,
35:20prescription [3] - 15:6,
44:15, 46:12PRESENT [1] - 2:19present [8] - 6:25, 10:19,
44:16, 46:8, 46:19, 47:25, 48:23, 49:22
preserve [1] - 3:18pressure [9] - 44:19, 45:2,
45:7, 45:12, 45:14, 45:18, 45:21, 45:25, 46:4
pretty [1] - 13:9Previously [1] - 46:13privacy [1] - 6:22private [1] - 6:14privilege [1] - 3:18Probably [3] - 35:2, 39:25,
46:15probably [2] - 16:5, 46:14problem [4] - 21:25, 45:7,
45:15, 45:18proceed [1] - 3:8proceedings [1] - 5:4promised [1] - 5:4properly [2] - 13:15, 16:7protect [1] - 6:21provide [1] - 51:14provided [3] - 3:21, 4:14,
4:17Public [3] - 1:23, 4:11, 55:8PUBLIC [1] - 53:22purchase [1] - 51:6purpose [2] - 4:4, 4:6purposes [2] - 4:14, 51:9pursuant [3] - 1:18, 3:4, 3:10put [5] - 6:17, 6:22, 7:25,
8:16, 51:8
Qquestion [10] - 3:20, 3:24,
4:6, 5:25, 12:24, 13:9, 43:12, 47:21, 49:24, 51:17
QUESTION [1] - 54:21questioning [2] - 3:12, 3:16QUESTIONS [1] - 54:20questions [5] - 3:17, 5:16,
5:17, 50:22, 50:24
RR [3] - 2:2, 53:2, 55:2raised [1] - 3:11read [2] - 12:24, 13:2really [2] - 35:2, 37:25reason [5] - 4:7, 16:8, 16:14,
16:20, 23:23recall [36] - 6:10, 7:10, 13:15,
15:8, 15:21, 16:7, 17:6, 17:11, 18:11, 18:12, 20:12, 20:22, 20:23, 21:20, 25:8, 25:11, 25:24, 26:25, 27:6, 28:10, 28:17, 28:20, 29:6, 29:21, 30:4, 30:19, 31:15, 31:19, 32:6, 33:4, 33:8, 35:15, 35:25, 36:11, 40:10, 47:23
record [7] - 4:8, 6:22, 8:7, 8:19, 13:2, 51:9, 55:12
referring [1] - 43:19Refusal [1] - 3:17refusal [1] - 3:22regarding [1] - 5:16related [1] - 55:15release [1] - 24:15released [2] - 39:20, 40:9relief [1] - 3:9remainder [1] - 3:25remember [33] - 15:17,
15:19, 17:13, 19:17, 21:15, 21:16, 21:19, 22:14, 23:7, 24:4, 24:20, 24:23, 26:5, 26:19, 28:23, 28:24, 30:25, 31:12, 31:22, 33:17, 33:21, 34:10, 37:20, 38:16, 38:22, 39:7, 39:14, 39:24, 40:2, 40:8, 40:11, 42:18, 43:15
remembered [1] - 31:20remembering [1] - 17:2repeat [1] - 5:18REPORTER [4] - 51:4, 51:12,
51:25, 52:6reporter [3] - 6:2, 7:25, 8:15represent [1] - 5:13representing [2] - 4:22,
51:10request [1] - 3:12REQUESTED [1] - 54:15respect [1] - 4:18respective [1] - 4:21restricted [1] - 3:10result [1] - 19:25rheumatic [2] - 37:2, 37:4
right [14] - 3:9, 3:18, 3:24, 8:20, 9:19, 13:6, 22:13, 25:21, 27:6, 31:19, 32:7, 34:3, 39:9, 48:22
Right [2] - 13:12, 15:20rights [1] - 4:17Rite [2] - 46:15, 46:16Road [1] - 2:10Rob [3] - 7:23, 8:14, 51:19ROBERT [1] - 2:6room [1] - 47:16Rule [3] - 3:5, 3:14, 3:22rule [2] - 3:6, 3:15rules [1] - 4:7Rules [2] - 1:20, 3:5RULES [2] - 3:2, 4:2RULINGS [1] - 54:20RXR [1] - 2:4
SS [5] - 2:2, 5:2, 5:6, 40:24,
54:2said [18] - 6:5, 21:24, 22:7,
25:3, 30:18, 30:25, 31:13, 31:14, 31:21, 32:7, 42:20, 43:16, 43:17, 45:23, 46:21, 46:22, 49:24, 50:3
same [14] - 4:11, 11:17, 11:19, 11:20, 14:2, 18:8, 18:16, 19:20, 25:15, 25:16, 25:22, 30:2, 30:12, 44:8
saw [1] - 21:2say [19] - 8:8, 8:12, 8:13,
8:15, 8:21, 16:17, 17:20, 21:22, 22:2, 22:5, 25:8, 25:22, 27:17, 29:24, 30:8, 36:23, 36:25, 39:3, 47:18
school [13] - 10:15, 13:16, 13:19, 13:24, 13:25, 14:2, 14:3, 14:5, 14:7, 28:16, 28:19, 49:12, 49:15
SCHREIER [2] - 55:7, 55:23Schreier [1] - 1:22second [11] - 26:7, 26:11,
26:17, 27:3, 27:10, 28:7, 28:15, 32:19, 33:2, 33:7, 47:21
section [1] - 4:7sections [1] - 4:18Security [1] - 6:21see [12] - 15:22, 16:4, 16:19,
27:4, 30:21, 41:20, 43:10, 43:11, 46:18, 46:23, 46:25, 48:21
seeing [2] - 15:18, 43:23seen [4] - 39:10, 43:3, 43:7,
43:13sees [4] - 41:15, 46:23, 47:3,
47:9
S. BEGUM
DIAMOND REPORTING (877) 624-3287 [email protected]
62
send [1] - 28:18September [1] - 13:17set [4] - 3:19, 4:7, 55:11,
55:20Seventeen [2] - 8:23, 8:24SHAHAJADI [2] - 1:17, 53:15shake [1] - 5:23shall [15] - 3:4, 3:7, 3:8, 3:8,
3:11, 3:13, 3:15, 3:17, 3:21, 3:23, 3:24, 4:4, 4:8, 4:18, 4:21
She [1] - 45:10she [6] - 13:10, 23:2, 29:10,
29:11, 45:11, 46:20she'll [1] - 8:9SHOMPA [1] - 2:20short [5] - 29:23, 29:24, 31:2,
32:22, 32:24shortness [1] - 30:23should [1] - 4:6showed [1] - 17:23siblings [1] - 8:4sic [1] - 35:3sick [16] - 13:13, 14:20, 15:5,
16:7, 16:12, 17:5, 17:12, 26:13, 26:17, 27:4, 27:11, 32:9, 32:17, 45:5, 45:8, 46:4
signed [2] - 4:10, 4:11significant [1] - 3:20since [6] - 10:22, 12:5,
16:25, 43:4, 43:13, 47:16Since [3] - 17:10, 47:12, 51:4six [1] - 17:10So [9] - 7:23, 8:5, 8:8, 20:6,
25:7, 33:11, 43:18, 47:2, 51:16
so [6] - 3:11, 5:19, 20:14, 20:23, 27:25, 31:20
soccer [4] - 49:9, 49:10, 49:11, 50:15
Social [1] - 6:21some [2] - 5:15, 13:7someone [1] - 37:21something [5] - 9:15, 18:18,
18:20, 33:19, 43:17sometimes [1] - 41:19son [121] - 5:16, 8:10, 11:21,
12:3, 12:5, 12:14, 12:16, 13:17, 14:11, 14:20, 15:5, 15:10, 15:18, 15:22, 15:24, 16:3, 16:9, 16:15, 16:19, 16:21, 17:4, 17:12, 19:24, 20:18, 20:20, 21:11, 21:21, 22:8, 22:21, 23:5, 23:8, 23:9, 23:10, 23:11, 23:17, 23:20, 23:24, 24:5, 24:10, 24:13, 24:22, 24:24, 25:10, 26:2, 26:4, 26:6, 26:10, 26:16, 27:4, 27:9, 28:20,
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
28:22, 29:7, 30:9, 30:21, 31:15, 32:8, 32:9, 32:14, 32:17, 32:18, 33:5, 33:22, 34:7, 34:12, 34:16, 34:21, 35:5, 35:6, 35:17, 35:18, 35:23, 36:6, 36:13, 36:18, 37:5, 37:18, 37:22, 38:4, 38:9, 38:18, 39:9, 39:16, 39:20, 39:22, 40:3, 40:16, 41:6, 41:15, 41:16, 41:20, 42:12, 42:20, 43:3, 43:7, 43:11, 43:13, 43:20, 43:22, 44:6, 44:14, 45:6, 45:13, 45:14, 45:17, 46:3, 46:7, 46:18, 46:22, 47:3, 47:9, 47:13, 47:15, 47:24, 48:24, 49:24, 50:4, 50:11
son's [15] - 7:19, 11:23, 12:11, 12:19, 13:11, 21:6, 25:3, 25:11, 27:11, 29:2, 31:17, 41:4, 42:21, 43:18, 43:23
sorry [1] - 29:19speak [4] - 11:4, 13:10, 21:3,
34:15speaking [3] - 13:20, 37:8,
37:15Speaking [1] - 3:10speaks [6] - 11:9, 11:22,
12:4, 12:5, 12:10, 12:22specific [1] - 29:5specifically [1] - 22:3specified [1] - 53:11spoke [4] - 12:17, 23:16,
34:19, 37:12spoken [1] - 42:8SS [1] - 55:4SSC [2] - 10:16, 10:17start [2] - 5:25, 40:16started [6] - 15:18, 18:24,
20:13, 20:24, 29:8, 45:5starting [1] - 20:19STATE [2] - 1:2, 55:4State [2] - 1:23, 55:8stated [2] - 3:11, 4:8statement [2] - 3:13, 3:23statements [1] - 3:16States [5] - 9:21, 9:24, 10:3,
10:6, 10:23stay [1] - 24:13stayed [1] - 38:24staying [1] - 16:25STIPULATED [4] - 4:10,
4:13, 4:16, 4:20straightforward [1] - 13:9Street [2] - 1:21, 2:16street [1] - 50:18subdivision [3] - 3:4, 3:6,
3:22subject [2] - 3:9, 8:4
Subscribed [1] - 53:18succinct [1] - 3:23succinctly [2] - 3:11, 4:8such [3] - 3:6, 4:7, 55:12suggest [1] - 3:12Suite [1] - 2:10summer [4] - 13:22, 14:4,
49:10, 50:12supply [1] - 52:2SUPREME [1] - 1:2sure [11] - 10:7, 20:25, 23:14,
30:18, 39:4, 39:8, 42:2, 42:17, 50:9, 51:17, 51:23
Sure [1] - 52:5sworn [5] - 5:3, 5:8, 53:5,
53:18, 55:11symptoms [7] - 21:9, 23:18,
25:14, 25:15, 25:16, 25:23
TT [5] - 5:2, 53:2, 54:2, 55:2TAHMINA [1] - 2:20take [16] - 6:2, 15:23, 15:24,
16:2, 16:3, 16:23, 20:20, 23:10, 23:25, 39:22, 44:14, 44:18, 45:2, 45:19, 46:8, 46:13
taken [6] - 1:17, 3:8, 14:14, 17:22, 19:24, 42:20
takes [4] - 41:16, 41:18, 44:19, 45:20
taking [6] - 15:6, 17:3, 28:20, 45:3, 46:14, 46:15
talked [2] - 22:23, 50:9talking [3] - 6:3, 12:12, 34:2TARYN [1] - 2:11team [1] - 49:11telephone [1] - 39:17tell [20] - 5:19, 9:4, 9:6,
11:23, 12:10, 12:18, 21:5, 25:2, 34:6, 34:20, 34:25, 35:4, 36:12, 36:16, 37:22, 38:7, 42:11, 45:14, 45:21, 45:22
tells [1] - 12:7temperature [1] - 17:22tense [1] - 38:2tension [1] - 35:3testified [4] - 5:9, 29:10,
29:12, 45:10testify [1] - 53:5testifying [1] - 4:22testimony [3] - 53:6, 53:10,
55:13tests [1] - 14:14than [12] - 6:12, 16:10, 22:22,
29:10, 29:11, 31:13, 37:8, 37:15, 43:2, 44:13, 46:6, 46:17
Thank [4] - 50:22, 50:25, 51:2, 52:13
That [3] - 23:2, 23:3, 55:10that [88] - 3:16, 4:10, 4:14,
4:17, 4:21, 7:24, 7:25, 8:9, 11:20, 14:18, 14:22, 16:8, 16:14, 16:17, 17:11, 17:13, 20:3, 20:14, 20:23, 21:9, 21:11, 21:15, 22:6, 22:7, 22:8, 22:12, 22:23, 23:14, 23:20, 23:24, 24:2, 24:7, 25:9, 25:12, 27:15, 27:17, 27:18, 27:19, 27:22, 27:25, 28:11, 28:25, 29:7, 29:21, 30:2, 30:12, 30:20, 31:14, 31:18, 32:7, 32:10, 32:15, 33:8, 34:18, 35:16, 36:11, 37:3, 38:3, 38:16, 38:19, 38:25, 39:14, 39:15, 42:19, 43:4, 43:15, 43:16, 44:3, 45:14, 45:17, 46:22, 47:9, 48:11, 48:17, 48:24, 49:6, 49:8, 49:21, 50:2, 50:3, 51:9, 53:4, 53:8, 55:12, 55:13, 55:14, 55:16
that's [9] - 8:9, 16:12, 20:8, 25:17, 25:18, 25:20, 35:3, 43:20, 51:22
That's [10] - 11:25, 12:6, 17:2, 24:3, 29:3, 29:9, 32:23, 40:13, 45:23, 51:23
THE [7] - 1:2, 3:2, 4:2, 51:4, 51:12, 51:25, 52:6
The [7] - 5:21, 9:8, 9:9, 14:7, 24:19, 42:3, 43:12
the [227] - 1:7, 1:18, 1:19, 1:20, 1:23, 2:4, 2:8, 2:9, 2:14, 3:5, 3:7, 3:8, 3:8, 3:9, 3:10, 3:12, 3:12, 3:14, 3:15, 3:16, 3:19, 3:23, 3:24, 3:24, 3:25, 4:3, 4:4, 4:4, 4:5, 4:5, 4:6, 4:6, 4:7, 4:8, 4:10, 4:11, 4:12, 4:14, 4:15, 4:17, 4:18, 4:20, 4:22, 4:22, 5:4, 5:5, 6:2, 6:17, 6:22, 6:24, 7:21, 7:24, 7:25, 8:2, 8:4, 8:6, 8:15, 8:18, 9:17, 9:20, 9:23, 10:3, 10:5, 10:19, 10:23, 11:17, 11:19, 11:20, 11:23, 12:7, 12:10, 12:17, 12:18, 12:24, 13:3, 13:14, 14:4, 15:23, 15:25, 17:13, 18:4, 18:7, 18:8, 18:14, 18:15, 18:16, 19:3, 19:7, 19:10, 19:15, 19:19, 19:20, 19:25, 20:4, 20:8, 20:21, 21:8, 21:16, 21:19, 21:22, 22:3, 22:11, 22:22, 23:16, 24:9, 24:17, 24:25, 25:9,
S. BEGUM
DIAMOND REPORTING (877) 624-3287 [email protected]
63
25:10, 25:14, 25:15, 25:22, 26:3, 26:8, 26:12, 26:16, 26:17, 26:19, 26:25, 27:2, 27:3, 27:8, 27:9, 28:6, 28:10, 28:13, 28:15, 28:18, 29:25, 30:12, 30:20, 31:9, 31:10, 31:17, 32:2, 32:3, 32:19, 33:2, 33:6, 33:9, 33:11, 33:12, 33:14, 33:22, 34:15, 36:7, 37:8, 37:17, 37:18, 38:3, 38:13, 40:10, 40:11, 40:19, 41:9, 41:12, 41:24, 42:3, 42:19, 43:3, 43:17, 44:6, 44:8, 44:13, 44:15, 44:21, 45:19, 46:6, 46:7, 46:8, 46:10, 46:11, 46:17, 46:19, 47:4, 47:7, 47:8, 47:15, 47:21, 47:22, 47:25, 48:4, 48:10, 48:23, 49:10, 49:11, 49:22, 49:23, 50:18, 51:9, 51:11, 51:16, 51:17, 52:14, 53:5, 53:6, 53:8, 53:10, 55:8, 55:10, 55:13, 55:15, 55:17
their [3] - 8:6, 9:4, 9:6them [4] - 8:7, 25:24, 37:13,
37:15then [11] - 15:20, 18:14,
18:23, 19:9, 19:22, 22:18, 45:20, 45:21, 47:5, 51:24, 52:2
Then [2] - 38:11, 51:12there [9] - 5:17, 12:7, 13:7,
19:18, 34:11, 35:21, 40:9, 47:4, 50:3
There [5] - 9:14, 47:5, 47:11, 48:15, 48:19
therefor [1] - 3:23these [7] - 4:7, 18:6, 18:9,
19:25, 20:19, 42:9, 42:12they [3] - 25:3, 37:22, 45:21They [1] - 45:23They're [1] - 8:5this [17] - 3:15, 3:22, 4:21,
5:14, 5:16, 13:22, 21:17, 21:22, 31:25, 50:11, 51:4, 51:15, 52:15, 53:19, 55:15, 55:18, 55:20
those [2] - 3:4, 25:23thought [2] - 8:14, 29:19three [1] - 26:22Three [1] - 7:15throat [1] - 21:14TIME [1] - 1:14time [51] - 6:3, 6:25, 7:24,
10:20, 18:8, 18:17, 19:21, 20:5, 20:14, 20:21, 21:11, 21:22, 24:18, 24:19, 24:25, 25:11, 26:4, 26:7, 26:8, 26:11, 26:12, 26:16, 26:17,
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
26:20, 26:25, 27:8, 27:10, 28:7, 28:15, 28:16, 30:2, 30:12, 30:14, 31:9, 31:17, 32:10, 32:19, 33:2, 33:3, 33:7, 33:9, 33:11, 43:3, 44:16, 46:8, 46:19, 47:5, 48:2, 48:23, 49:22, 53:10
times [5] - 18:9, 19:18, 23:15, 24:21, 42:19
To [1] - 27:19to [213] - 1:18, 3:4, 3:9, 3:9,
3:10, 3:12, 3:13, 3:14, 3:17, 3:18, 3:19, 3:20, 3:21, 3:22, 3:24, 4:17, 4:22, 5:4, 5:15, 5:18, 5:22, 5:25, 6:5, 6:10, 6:20, 6:21, 7:10, 8:12, 8:21, 9:19, 9:23, 10:3, 10:5, 10:23, 11:21, 11:23, 12:9, 12:16, 12:20, 12:21, 12:24, 13:3, 13:5, 13:10, 13:14, 13:15, 13:24, 14:3, 14:10, 14:11, 14:15, 14:18, 15:8, 15:21, 15:22, 16:2, 16:3, 16:6, 16:9, 16:15, 16:19, 16:22, 17:6, 17:11, 17:18, 17:19, 17:25, 18:2, 18:7, 18:10, 18:11, 19:25, 20:4, 20:8, 20:12, 20:14, 20:20, 20:22, 20:24, 21:3, 21:9, 21:20, 22:6, 22:16, 22:18, 22:20, 22:21, 23:2, 23:4, 23:5, 23:8, 23:11, 23:19, 24:6, 24:9, 24:15, 24:22, 25:8, 25:10, 25:24, 26:4, 26:6, 26:10, 26:16, 26:24, 27:2, 27:4, 27:6, 27:9, 27:10, 27:14, 28:7, 28:8, 28:10, 28:13, 28:15, 28:17, 28:18, 28:21, 28:22, 29:10, 29:12, 29:14, 29:21, 29:22, 30:4, 30:6, 30:18, 30:21, 31:15, 31:19, 31:21, 32:6, 32:8, 32:9, 32:14, 32:18, 33:2, 33:4, 33:5, 33:8, 33:12, 33:23, 34:8, 34:12, 34:13, 34:15, 34:17, 34:22, 35:3, 35:7, 35:15, 35:20, 35:25, 36:11, 36:23, 36:25, 37:6, 37:12, 38:5, 38:15, 38:19, 39:15, 39:22, 40:3, 40:7, 40:10, 40:15, 41:3, 41:22, 42:8, 42:12, 42:20, 42:21, 43:14, 43:19, 44:3, 44:6, 45:4, 45:11, 45:19, 46:13, 46:25, 47:15, 47:16, 47:22, 47:23, 49:3, 49:21, 49:24, 50:8, 50:9, 51:6, 51:14, 51:18, 52:2, 53:5, 53:18, 55:15
Today [1] - 12:2
today [2] - 11:25, 41:4today's [1] - 51:10told [14] - 16:5, 20:3, 28:18,
31:9, 34:9, 35:17, 36:17, 37:3, 37:25, 42:14, 43:20, 49:25, 50:2, 50:8
took [51] - 11:21, 12:15, 13:3, 13:5, 13:13, 15:20, 16:6, 16:9, 16:15, 16:20, 20:4, 20:8, 20:13, 20:15, 20:23, 22:16, 22:18, 22:21, 23:2, 23:4, 23:5, 23:8, 23:11, 23:13, 23:20, 23:22, 23:23, 24:3, 24:5, 24:15, 25:2, 25:10, 25:13, 25:17, 25:19, 25:20, 26:7, 26:11, 26:16, 27:9, 28:14, 28:22, 30:21, 31:14, 32:9, 32:14, 32:18, 33:2, 33:6, 38:22, 45:10
Tower [1] - 2:5transcript [4] - 4:10, 51:15,
53:9transcripts [2] - 51:7, 52:8transferred [1] - 35:19treat [2] - 24:14, 41:6treatment [5] - 35:10, 35:11,
39:10, 39:11, 40:16trial [1] - 4:14true [2] - 53:9, 55:12truth [1] - 53:5twice [6] - 13:5, 13:14, 16:6,
20:4, 33:16, 33:19two [14] - 7:16, 9:2, 26:22,
31:3, 31:4, 33:19, 33:20, 33:24, 34:8, 34:13, 34:17, 34:22, 35:7, 37:6
UU [1] - 5:6unable [1] - 36:11Under [1] - 1:18understand [9] - 5:18, 7:2,
8:9, 11:6, 11:18, 12:13, 19:4, 26:9, 49:23
understands [2] - 11:14, 12:5
understood [2] - 6:6, 45:11UNIFORM [2] - 3:2, 4:2Uniondale [1] - 2:5unit [1] - 37:19United [5] - 9:20, 9:23, 10:3,
10:5, 10:23units [1] - 37:19unless [1] - 4:5until [2] - 5:24, 5:25us [1] - 6:2use [2] - 7:24, 8:6used [13] - 12:20, 16:2,
16:22, 17:18, 17:19, 17:25,
18:10, 29:14, 29:22, 30:6, 45:4, 46:13, 46:25
utilized [1] - 4:14
Vvarious [1] - 20:7verbally [1] - 5:23very [1] - 50:22via [2] - 2:12, 2:17videoconference [2] - 2:12,
2:17VIDEOCONFERENCED [1] -
1:16visit [17] - 21:17, 21:23, 22:6,
22:12, 22:20, 22:22, 23:16, 23:19, 23:24, 27:2, 27:3, 28:13, 30:20, 31:14, 33:22, 36:6, 36:9
visiting [1] - 38:4vomiting [2] - 32:23, 32:25
Wwait [1] - 5:24waived [2] - 3:5, 4:17want [3] - 8:18, 12:23, 35:3wants [1] - 14:18was [81] - 5:8, 9:11, 12:8,
13:4, 16:7, 16:12, 16:25, 17:2, 17:3, 17:13, 17:22, 18:21, 18:22, 19:24, 20:5, 20:6, 21:8, 21:9, 22:7, 22:8, 22:16, 22:17, 23:17, 23:20, 24:2, 24:7, 25:15, 26:21, 27:15, 27:17, 27:19, 27:20, 27:22, 27:24, 27:25, 28:2, 28:11, 28:12, 30:2, 30:5, 30:12, 31:18, 32:21, 32:22, 33:5, 33:9, 33:11, 33:12, 33:15, 33:23, 34:7, 34:11, 34:12, 34:21, 35:2, 35:5, 35:7, 35:17, 35:21, 35:23, 36:7, 36:13, 36:18, 37:5, 37:6, 37:7, 37:18, 37:23, 37:25, 38:9, 38:13, 39:10, 39:16, 39:20, 43:4, 45:3, 52:15, 55:11
Was [2] - 15:15, 35:18was he [8] - 15:6, 27:21,
28:3, 30:11, 30:23, 32:24, 33:14, 38:14
Was it [5] - 15:13, 17:9, 27:18, 36:3
was that [2] - 23:19, 29:25Was there [3] - 22:20, 34:16,
37:19way [2] - 8:17, 55:17we [7] - 6:22, 8:5, 15:19,
15:20, 23:13, 38:22, 39:15We [1] - 8:7
S. BEGUM
DIAMOND REPORTING (877) 624-3287 [email protected]
64
we'll [1] - 7:23We're [1] - 11:19we're [1] - 34:2week [1] - 26:21weeks [3] - 26:22, 36:3weight [1] - 27:25Well [8] - 22:11, 23:16,
30:20, 46:22, 47:7, 47:20, 51:8, 51:22
went [8] - 15:22, 16:19, 21:7, 27:10, 28:7, 28:15, 32:8, 40:3
were [13] - 12:12, 12:19, 18:8, 18:15, 19:18, 19:23, 25:12, 25:23, 29:19, 37:9, 37:15, 37:22, 38:3
Were you [4] - 9:19, 10:2, 29:17, 35:17
West [1] - 2:5What [5] - 13:16, 27:21,
33:18, 44:18, 45:22what [26] - 10:6, 10:10,
12:11, 12:18, 13:8, 13:24, 13:25, 15:17, 17:4, 17:16, 18:2, 24:6, 25:2, 25:11, 25:23, 28:8, 29:10, 29:11, 31:13, 36:16, 37:19, 37:22, 40:6, 42:16, 45:11, 49:24
what did [2] - 21:5, 21:22what is [8] - 6:16, 7:7, 7:19,
14:4, 46:10, 48:4, 49:8, 50:11
what was [6] - 27:11, 34:6, 34:20, 36:13, 36:17, 40:19
whatever [1] - 12:6Whatever [1] - 31:20when [35] - 3:17, 3:19, 15:22,
16:7, 16:19, 19:18, 20:6, 20:13, 20:23, 20:25, 22:7, 23:9, 23:17, 24:15, 24:25, 26:17, 27:3, 27:10, 28:14, 30:5, 30:19, 30:21, 32:8, 33:6, 33:15, 33:23, 34:7, 34:12, 34:16, 34:21, 36:6, 36:13, 36:18, 37:6, 41:15
When [7] - 15:19, 17:12, 21:7, 24:5, 32:16, 32:17, 37:5
When did [1] - 10:5when you [11] - 10:2, 17:20,
20:8, 21:2, 25:22, 27:17, 29:24, 30:8, 39:3, 40:15, 47:18
Whenever [1] - 45:19whenever [1] - 8:8where [5] - 35:8, 37:17,
38:10, 38:24, 46:11where was [2] - 28:7, 39:9WHEREOF [1] - 55:19Whereupon [1] - 52:14
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019
whether [2] - 4:6, 51:18which [2] - 3:4, 13:10Which [1] - 14:3Whichever [1] - 8:17While [2] - 18:21, 39:16while [2] - 18:21, 37:23who [7] - 6:24, 7:3, 11:9,
11:14, 11:22, 12:10, 41:16Who [1] - 32:9who are [1] - 43:18Who told [1] - 45:17whoever [1] - 34:18whom [1] - 3:7whose [1] - 55:10Why [1] - 16:23why [15] - 12:6, 16:12, 16:20,
17:2, 24:3, 25:17, 25:19, 25:20, 27:18, 32:13, 32:23, 35:3, 35:17, 43:21, 45:23
will [8] - 5:19, 5:21, 6:22, 7:24, 7:25, 8:13, 8:16, 42:12
William [1] - 2:16with [38] - 3:6, 3:16, 4:3, 4:5,
4:11, 4:18, 6:24, 7:4, 9:24, 12:3, 12:4, 18:24, 22:22, 23:5, 23:21, 24:9, 26:3, 28:25, 29:7, 31:16, 34:7, 34:19, 34:21, 36:13, 36:18, 37:8, 37:15, 39:18, 40:3, 40:16, 44:5, 45:7, 49:13, 50:15, 50:18, 50:19, 51:15, 51:18
withdrawn [2] - 35:6, 35:18within [1] - 55:8without [1] - 4:22witness [5] - 1:17, 4:22,
52:15, 55:10, 55:13WITNESS [1] - 55:19words [1] - 18:12work [2] - 10:19, 10:25worked [1] - 10:22worse [3] - 22:17, 32:21would [8] - 3:5, 3:20, 5:18,
8:14, 11:22, 15:25, 37:14, 52:6
wrist [1] - 19:20wrists [2] - 18:5, 18:7write [1] - 8:7writing [2] - 18:21, 18:22wrong [4] - 34:7, 34:21,
36:13, 36:17
XX [4] - 1:3, 1:11, 54:2, 54:9X/X/1981 [1] - 6:19X/X/2012 [1] - 9:16XX [1] - 6:23XXX [1] - 6:23
XXX-XX-XXXX [1] - 6:23XXXX [1] - 6:23
Yyear [10] - 6:18, 9:17, 10:6,
10:10, 13:21, 15:17, 17:4, 21:19, 40:6, 40:11
years [3] - 6:13, 15:23, 17:11Yes [51] - 5:20, 6:4, 6:7, 6:15,
7:12, 7:18, 8:25, 9:13, 10:4, 10:9, 12:25, 13:22, 13:23, 14:13, 14:16, 15:12, 15:14, 15:16, 16:11, 17:15, 19:13, 19:22, 20:3, 20:17, 21:4, 21:12, 25:7, 26:13, 28:5, 30:10, 33:13, 34:5, 34:14, 36:8, 37:16, 40:12, 40:14, 40:18, 41:2, 41:5, 41:14, 42:4, 44:2, 44:17, 44:25, 45:16, 46:2, 47:4, 48:3, 48:8, 49:7
yes [5] - 7:12, 9:13, 20:17, 30:10, 52:4
yet [1] - 14:19YORK [2] - 1:2, 55:4York [8] - 1:22, 1:23, 2:5,
2:11, 2:16, 5:7, 55:9You [6] - 5:23, 29:16, 31:22,
32:7, 40:2, 43:16you [96] - 5:15, 5:17, 5:18,
5:22, 5:25, 6:5, 6:20, 8:11, 8:14, 9:4, 10:5, 10:8, 10:23, 11:8, 11:11, 11:13, 11:21, 11:22, 12:9, 12:12, 12:14, 12:15, 12:18, 13:20, 14:10, 14:21, 16:5, 16:10, 16:13, 16:16, 16:18, 16:21, 16:24, 20:3, 21:5, 22:23, 23:3, 23:8, 23:16, 23:19, 23:20, 23:21, 23:23, 25:2, 27:22, 28:25, 29:7, 29:19, 30:8, 30:20, 31:9, 31:13, 31:14, 31:21, 32:10, 32:11, 34:6, 34:20, 36:12, 36:16, 36:25, 37:9, 37:15, 37:22, 38:3, 38:5, 38:15, 38:21, 39:21, 41:16, 42:11, 42:21, 43:13, 43:19, 43:22, 44:11, 45:14, 45:17, 45:22, 46:22, 47:16, 48:11, 48:16, 49:20, 49:25, 50:2, 50:22, 50:25, 51:2, 51:5, 51:13, 51:18, 52:2, 52:13
you're [2] - 39:4, 48:25you've [3] - 42:19, 43:4,
47:12younger [2] - 9:9, 9:11your [184] - 5:16, 5:23, 5:24,
6:16, 6:20, 6:21, 7:3, 7:7, 7:19, 9:2, 9:20, 9:24, 11:8,
S. BEGUM
DIAMOND REPORTING (877) 624-3287 [email protected]
65
11:13, 11:21, 11:23, 12:11, 12:16, 12:18, 13:16, 14:11, 14:20, 15:5, 15:10, 15:17, 15:22, 15:23, 15:24, 16:3, 16:4, 16:8, 16:9, 16:14, 16:15, 16:19, 16:20, 16:23, 17:4, 17:12, 19:24, 20:18, 20:20, 21:6, 21:10, 21:21, 22:8, 22:21, 23:3, 23:4, 23:5, 23:8, 23:9, 23:10, 23:11, 23:17, 23:20, 23:24, 24:5, 24:10, 24:13, 24:15, 24:21, 24:24, 24:25, 25:2, 25:3, 25:9, 25:10, 25:11, 25:12, 26:2, 26:3, 26:4, 26:6, 26:7, 26:10, 26:11, 26:15, 26:16, 27:3, 27:4, 27:8, 27:9, 27:11, 28:14, 28:20, 28:21, 28:22, 29:2, 29:7, 30:9, 30:21, 31:14, 31:16, 32:7, 32:9, 32:10, 32:13, 32:14, 32:17, 32:18, 32:25, 33:5, 33:6, 33:22, 34:7, 34:11, 34:12, 34:15, 34:16, 34:20, 34:21, 35:5, 35:6, 35:17, 35:18, 35:23, 36:6, 36:13, 36:16, 36:18, 37:5, 37:7, 37:18, 37:22, 38:4, 38:9, 38:18, 39:9, 39:16, 39:20, 39:21, 39:22, 40:2, 40:3, 40:16, 41:3, 41:6, 41:15, 41:16, 41:20, 42:12, 42:20, 42:21, 43:2, 43:7, 43:12, 43:13, 43:17, 43:22, 43:23, 44:5, 44:14, 45:6, 45:13, 45:14, 45:17, 46:3, 46:7, 46:18, 46:22, 47:3, 47:9, 47:13, 47:15, 47:24, 48:12, 48:23, 50:2, 50:4, 50:11, 51:6
Your [2] - 9:11, 48:6YOUR [1] - 48:7
ZZahed [1] - 7:9ZAHED [2] - 1:3, 7:9
°° [4] - 52:18
FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019