Preview
FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
"B"
EXHIBIT
FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
"as" 2
GERTIFIED TRANSCRIPT
1
2 - - - - - - - - - - - - - - - - - - - -x
3 In the Matter of the Claim of
4 HYACINTH REID,
5 Claimant,
6 -against-
7 COUNTY OF NASSAU and NEW YORK STATE
OFFICE OF COURT ADMINISTRATION,
8
Respondents.
9
- - - - - - - - - - - - - - - - - - - -x
10
1 West Street
11 Mineola, New York
12 November 14, 2018
2:00 p.m.
13
14 EXAMINATION of HYACINTH REID, the
15 Claimant in the above-entitled action,
16 held at the above time and place, taken
17 before Jacqueline Gandolfo, a Notary
18 Public of the State of New York, pursuant
19 to Section 50(h) of the General Municipal
20 Law.
21
22
23
24
25
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FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
Page 2
1
2 APPEARANCES:
3
MONTELEONE & SIEGEL, PLLC
4 Attorneys for Claimant
114 Old Country Road, Suite 216
5 Mineola, New York 11501
6 BY: JARAD L. SIEGEL, ESQ.
7
8
NASSAU COUNTY ATTORNEY OFFICE
9 Attorneys for Respondents
1 West Street
10 Mineola, New York 11501
11 BY: STEPHEN CARLIN, ESQ.
12
13
14
15
16
17
!
18
19
20
21
22
23
24
25
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NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
Page 3
1
2 H Y A C I N T H R E I D, the Witness
3 herein, having first been duly sworn by
4 the Notary Public, was examined and
5 testified as follows:
6 EXAMINATION BY
7 MR. CARLIN:
8 Q. State your name for the record?
9 A. My name is Hyacinth Reid.
10 Q. And your address?
11 A. 188-68 120th Road, St. Albans,
12 New York 11412.
13 MR. CARLIN: This will be
14 Respondents' Exhibit A.
15 [The documents were hereby
16 marked as Respondents' Exhibit A for
17 identification, as of this date.]
18 Q. Good afternoon, Ms. Reid. My
19 name is Stephen Carlin. I'm a deputy
20 county attorney with the Nassau County
21| Attorney's Office. I will be conducting
22 this hearing today pursuant to General
23 Municipal Law Section 50(h).
24 I'm going to be asking you a
25 series of questions today beginning with
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NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
Page 4
1 H. REID
2 your background and then the events of
3 your claim from February 18, 2018.
4 I just have a few instructions
5 before we begin. First, I ask that before
6 you answer you let me finish my question.
7 I don't find it rude. It's more for the
8 reporter who can't take down what we're
9 both saying at the same time.
10 Also, please keep your voice up
11 for the reporter.
12 Please keep all of your answers
13 verbal, meaning no hand gestures or nods
14 of the head. The reporter can't take down
15 either of those. She can only take down
16 , what you say.
17 If at any point you don't
18 understand what I'm asking, please let me
19 know and I'll be happy to rephrase it for
20 you.
21 If at any point you need to take
22 a break to use the bathroom or to speak
23 with your counsel, just let me know and we
24 can accommodate. I just ask that if
25 there's an open question -- which I
by
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NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
Page 5
1 H. REID
2 mean an unanswered question -- please
3 answer the question first before going on
4 the break.
5 Do you understand these
6 instructions?
7 A. Yes.
8 Q. Ms. Reid, how long have you
9 lived at the address you just gave in St.
10 Albans?
11 A. Eleven years.
12 Q. Do you live there with anyone?
13 A. My mom and my two kids.
14 Q. What's your mother's name?
15 A. Millicent Swearing.
16 Q. And you said that you have two
17 children?
18 A. Yes.
19 Q. How old are your children?
20 A. One is twenty-three and one is
21 eighteen.
22 Q. What are their namesS
23 A. Christine and Maitland.
24 Q. What is your date of birth?
25 A. XX/XX/1975.
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Page 6
1 H. REID
2 MR. SIEGEL: I just ask that we
3 only put the year on the record?
4 MR. CARLIN: That's fine.
5 Q. What is your social security
6 number? I'll ask the reporter to leave
7 off everything but the last four.
8 A. XXX-XX-3350.
9 Q. Are you currently married?
10 A. Yes, I do.
11 Q. When were you married?
12 A. Four years.
13 Q. What is your spouse's name?
14 A. Excuse me?
15 Q. What is your spouse's name?
16 A. My husband is not here.
17 MR. SIEGEL: Off the record.
18 (A discussion was held off the
19 record.)
20 A. My husband's name is Roy Clarke.
21 Q. Can you spell that for me?
22 A. R-O-Y, C-L-A-R-K-E.
23 Q. Are you currently employed?
24 A. Pardon me?
25 Q. Are you currently employed? Are
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NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
Page 7
1 H. REID
2 you working for anyone?
3 A. No.
4 MR. SIEGEL: Do you understand
5 the question?
6 THE WITNESS: No, can he explain
7 it? He asked me if I'm currently
8 working?
9 MR. SIEGEL: Yes.
10 A. I work for Corporate Source.
11 Q. Where is Corporate Source
12 located?
13 A. 1225 -- it's in this area. I
14 don't remember the address.
15 MR. SIEGEL: By Counsel,
16 Franklin Avenue?
17 THE WITNESS: Yes.
18 Q. Here in Mineola?
19 A. Yes.
20 Q. How long have you worked there?
21 A. Five years.
22 Q. What is your position?
23 A. Janitor.
24 Q. What are your normal work hours?
25 A. Five days a week.
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NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
Page 8
1 H. REID
2 Q. Is that 9:00 to 5:00, or
3 overnight, or something else?
4 A. just from 8 to -- I start to
No,
5 work at 12 to 8:30.
6 Q. Is it 12:00 a.m. or 12:00 p.m.?
7 A. 12:00 a.m.
8 MR. SIEGEL: Off the record.
9 (A discussion was held off the
10 record.)
11 Q. Just so that the record is
12 clear, you work from 12:00 p.m. to 8:00
13 p.m.?
14 A. Yes.
15 Q. And that's five days a week?
16 A. Yes.
17 Q. Do you work Monday through
18 Friday?
19 A. Yes.
20 Q. Are you salaried or do you get
21 paid hourly?
22 A. I do not remember.
23 MR. SIEGEL: Off the record.
24 (A discussion was held off the
25 record.)
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Page 9
1 H. REID
2 Q. How much do you get paid a week?
3 A. Five fifty.
4 Q. Is that five hundred and fifty
5 dollars?
6 A. Yes.
7 Q. You said you've been there for
8 five years, correct?
9 A. Yes.
10 Q. Do you hold any other jobs
11 outside of that janitor position? .
12 A. No.
13 Q. Ms. Reid, I just want to direct
14 your attention to the events of February
15 18, 2018 at about 1:00 p.m. Do you
16 remember where you were that afternoon?
17 A. If I remember where I was? Yes,
18 I was at the pharmacist downstairs in the
19 basement.
20 Q. What were you doing there that
21 day?
22 A. Doing my job.
23 Q. 1:00 p.m. on that day were you
24 at 99 Main Street in Hempstead?
25 A. Yes, sir.
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Page 10
1 H. REID
2 Q. Around that time you were just
3 cleaning that area?
4 A. Yes.
5 Q. And by that area I mean in the
6 basement?
7 A. Yes.
8 Q. That day did you start work
9 around 12:00 p.m.?
10 A. Yes -- no.
11 Q. Did you start at a different
12 time?
13 A. I started working at 10:00 a.m.
14 in the morning.
15 Q. Were you working with anyone?
16 A. No.
17 Q. Do you normally work by
18 yourself?
19 A. Yes.
20 Q. Had you worked in that basement
21 prior to that day? In other words, you
22 cleaned that basement before?
23 A. Yes.
24 Q. While you were oleaning anything
25 in that basement, did you sustain any
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NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
Page 11
1 H. REID
2 injury?
3 MR. SIEGEL: Objection to the
4 form. You can answer his question if
5 you understand it.
6 A. Repeat the question please?
7 Q. Were you injured at all while
8 working that afternoon?
9 A. Yes.
10 Q. How were you injured?
11 A. I went to the room to do the
12 cleaning. I went in there and I turned on
!
13 the switch. When I turned it on with my
14 two fingers -- I just hold it like this --
15 when I hold it there I did not see
16 anything cause the room was dark. I hold
17 on the switch like this and I was
18 electrocuted.
19 Q. When you say a switch, was it a
20 light switch?
21 A. Yes.
22 MR. SIEGEL: Just note for the
23 record that the claimant is indicating
24 that she was using her left thumb and
25 her left index finger.
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NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
Page 12
1 H. REID
2 Q. When you were electrocuted, did
3 it happen as soon as you touched the
4 switch, or did some time pass between
5 touching the switch and getting
6 electrocuted?
7 A. When I touched the switch.
8 Q. Immediately?
9 A. Yes.
10 Q. Ms. Reid, I'm showing you what's
11 been marked as Respondents' Exhibit A. On
12 page five, please look at this photograph
13 and let me know when you're ready.
14 A. I'm ready.
15 Q. Do you recognize this
16 photograph?
17 A. Yes.
18 Q. What is this a photograph of?
19 A. It's a photograph of the switch.
20 Q. Did you take this photograph?
21 A. Yes.
22 Q. Did you take this photograph on
23 the day that you were electrocuted?
24 A. No, after everything happened to
25 me, then I take the photo.
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NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
Page 13
1 H. REID
2 MR. SIEGEL: Do you understand
3 the question? He's asking whether you
4 took this picture on the date of the
5 accident.
6 THE WITNESS: The same day.
7 Q. Did you take it right after you
8 were electrocuted, or did you take it a
9 couple of hours after?
10 A. A couple of hours.
11 Q. So there are two switches on
12 this photograph?
13 A. Yes.
14 Q. Can you point out or circle
15 which switch you touched when you were
16 electrocuted?
17 MR. SIEGEL: I'm going to object
18 to the form in that you're calling it
19 a switch. It calls for an expert
20 opinion. You can answer the question
21 and you can circle where it is.
22 A. This is the switch that I turned
23 on, the main one that I turned on. I hold
24 onto this thing right here. When I hold
25 onto it just a wire that was there.
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NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022
Page 14
1 H. REID
2 Q. You want to call it a switch; is
3 that okay with you?
4 A. Yes.
5 Q. There are two switches indicated
6 here. One is on the right and one is on
7 the left. You're indicating that you
8 touched the one on the
Preview
FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 "B" EXHIBIT FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 "as" 2 GERTIFIED TRANSCRIPT 1 2 - - - - - - - - - - - - - - - - - - - -x 3 In the Matter of the Claim of 4 HYACINTH REID, 5 Claimant, 6 -against- 7 COUNTY OF NASSAU and NEW YORK STATE OFFICE OF COURT ADMINISTRATION, 8 Respondents. 9 - - - - - - - - - - - - - - - - - - - -x 10 1 West Street 11 Mineola, New York 12 November 14, 2018 2:00 p.m. 13 14 EXAMINATION of HYACINTH REID, the 15 Claimant in the above-entitled action, 16 held at the above time and place, taken 17 before Jacqueline Gandolfo, a Notary 18 Public of the State of New York, pursuant 19 to Section 50(h) of the General Municipal 20 Law. 21 22 23 24 25 Veritext Legal Solutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 2 1 2 APPEARANCES: 3 MONTELEONE & SIEGEL, PLLC 4 Attorneys for Claimant 114 Old Country Road, Suite 216 5 Mineola, New York 11501 6 BY: JARAD L. SIEGEL, ESQ. 7 8 NASSAU COUNTY ATTORNEY OFFICE 9 Attorneys for Respondents 1 West Street 10 Mineola, New York 11501 11 BY: STEPHEN CARLIN, ESQ. 12 13 14 15 16 17 ! 18 19 20 21 22 23 24 25 Veritext Legal Solutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 3 1 2 H Y A C I N T H R E I D, the Witness 3 herein, having first been duly sworn by 4 the Notary Public, was examined and 5 testified as follows: 6 EXAMINATION BY 7 MR. CARLIN: 8 Q. State your name for the record? 9 A. My name is Hyacinth Reid. 10 Q. And your address? 11 A. 188-68 120th Road, St. Albans, 12 New York 11412. 13 MR. CARLIN: This will be 14 Respondents' Exhibit A. 15 [The documents were hereby 16 marked as Respondents' Exhibit A for 17 identification, as of this date.] 18 Q. Good afternoon, Ms. Reid. My 19 name is Stephen Carlin. I'm a deputy 20 county attorney with the Nassau County 21| Attorney's Office. I will be conducting 22 this hearing today pursuant to General 23 Municipal Law Section 50(h). 24 I'm going to be asking you a 25 series of questions today beginning with Veritext Legal Solutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 4 1 H. REID 2 your background and then the events of 3 your claim from February 18, 2018. 4 I just have a few instructions 5 before we begin. First, I ask that before 6 you answer you let me finish my question. 7 I don't find it rude. It's more for the 8 reporter who can't take down what we're 9 both saying at the same time. 10 Also, please keep your voice up 11 for the reporter. 12 Please keep all of your answers 13 verbal, meaning no hand gestures or nods 14 of the head. The reporter can't take down 15 either of those. She can only take down 16 , what you say. 17 If at any point you don't 18 understand what I'm asking, please let me 19 know and I'll be happy to rephrase it for 20 you. 21 If at any point you need to take 22 a break to use the bathroom or to speak 23 with your counsel, just let me know and we 24 can accommodate. I just ask that if 25 there's an open question -- which I by VeritextLegal Solutions 212-267-6868 www.veritext.com 5I6-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 5 1 H. REID 2 mean an unanswered question -- please 3 answer the question first before going on 4 the break. 5 Do you understand these 6 instructions? 7 A. Yes. 8 Q. Ms. Reid, how long have you 9 lived at the address you just gave in St. 10 Albans? 11 A. Eleven years. 12 Q. Do you live there with anyone? 13 A. My mom and my two kids. 14 Q. What's your mother's name? 15 A. Millicent Swearing. 16 Q. And you said that you have two 17 children? 18 A. Yes. 19 Q. How old are your children? 20 A. One is twenty-three and one is 21 eighteen. 22 Q. What are their namesS 23 A. Christine and Maitland. 24 Q. What is your date of birth? 25 A. XX/XX/1975. Veritext Legal Solutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 6 1 H. REID 2 MR. SIEGEL: I just ask that we 3 only put the year on the record? 4 MR. CARLIN: That's fine. 5 Q. What is your social security 6 number? I'll ask the reporter to leave 7 off everything but the last four. 8 A. XXX-XX-3350. 9 Q. Are you currently married? 10 A. Yes, I do. 11 Q. When were you married? 12 A. Four years. 13 Q. What is your spouse's name? 14 A. Excuse me? 15 Q. What is your spouse's name? 16 A. My husband is not here. 17 MR. SIEGEL: Off the record. 18 (A discussion was held off the 19 record.) 20 A. My husband's name is Roy Clarke. 21 Q. Can you spell that for me? 22 A. R-O-Y, C-L-A-R-K-E. 23 Q. Are you currently employed? 24 A. Pardon me? 25 Q. Are you currently employed? Are VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 7 1 H. REID 2 you working for anyone? 3 A. No. 4 MR. SIEGEL: Do you understand 5 the question? 6 THE WITNESS: No, can he explain 7 it? He asked me if I'm currently 8 working? 9 MR. SIEGEL: Yes. 10 A. I work for Corporate Source. 11 Q. Where is Corporate Source 12 located? 13 A. 1225 -- it's in this area. I 14 don't remember the address. 15 MR. SIEGEL: By Counsel, 16 Franklin Avenue? 17 THE WITNESS: Yes. 18 Q. Here in Mineola? 19 A. Yes. 20 Q. How long have you worked there? 21 A. Five years. 22 Q. What is your position? 23 A. Janitor. 24 Q. What are your normal work hours? 25 A. Five days a week. Veritext Legal Solutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 8 1 H. REID 2 Q. Is that 9:00 to 5:00, or 3 overnight, or something else? 4 A. just from 8 to -- I start to No, 5 work at 12 to 8:30. 6 Q. Is it 12:00 a.m. or 12:00 p.m.? 7 A. 12:00 a.m. 8 MR. SIEGEL: Off the record. 9 (A discussion was held off the 10 record.) 11 Q. Just so that the record is 12 clear, you work from 12:00 p.m. to 8:00 13 p.m.? 14 A. Yes. 15 Q. And that's five days a week? 16 A. Yes. 17 Q. Do you work Monday through 18 Friday? 19 A. Yes. 20 Q. Are you salaried or do you get 21 paid hourly? 22 A. I do not remember. 23 MR. SIEGEL: Off the record. 24 (A discussion was held off the 25 record.) Veritext Legal Solutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 9 1 H. REID 2 Q. How much do you get paid a week? 3 A. Five fifty. 4 Q. Is that five hundred and fifty 5 dollars? 6 A. Yes. 7 Q. You said you've been there for 8 five years, correct? 9 A. Yes. 10 Q. Do you hold any other jobs 11 outside of that janitor position? . 12 A. No. 13 Q. Ms. Reid, I just want to direct 14 your attention to the events of February 15 18, 2018 at about 1:00 p.m. Do you 16 remember where you were that afternoon? 17 A. If I remember where I was? Yes, 18 I was at the pharmacist downstairs in the 19 basement. 20 Q. What were you doing there that 21 day? 22 A. Doing my job. 23 Q. 1:00 p.m. on that day were you 24 at 99 Main Street in Hempstead? 25 A. Yes, sir. Veritext Legal Solutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 10 1 H. REID 2 Q. Around that time you were just 3 cleaning that area? 4 A. Yes. 5 Q. And by that area I mean in the 6 basement? 7 A. Yes. 8 Q. That day did you start work 9 around 12:00 p.m.? 10 A. Yes -- no. 11 Q. Did you start at a different 12 time? 13 A. I started working at 10:00 a.m. 14 in the morning. 15 Q. Were you working with anyone? 16 A. No. 17 Q. Do you normally work by 18 yourself? 19 A. Yes. 20 Q. Had you worked in that basement 21 prior to that day? In other words, you 22 cleaned that basement before? 23 A. Yes. 24 Q. While you were oleaning anything 25 in that basement, did you sustain any Veritext Legal Solutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 11 1 H. REID 2 injury? 3 MR. SIEGEL: Objection to the 4 form. You can answer his question if 5 you understand it. 6 A. Repeat the question please? 7 Q. Were you injured at all while 8 working that afternoon? 9 A. Yes. 10 Q. How were you injured? 11 A. I went to the room to do the 12 cleaning. I went in there and I turned on ! 13 the switch. When I turned it on with my 14 two fingers -- I just hold it like this -- 15 when I hold it there I did not see 16 anything cause the room was dark. I hold 17 on the switch like this and I was 18 electrocuted. 19 Q. When you say a switch, was it a 20 light switch? 21 A. Yes. 22 MR. SIEGEL: Just note for the 23 record that the claimant is indicating 24 that she was using her left thumb and 25 her left index finger. VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 12 1 H. REID 2 Q. When you were electrocuted, did 3 it happen as soon as you touched the 4 switch, or did some time pass between 5 touching the switch and getting 6 electrocuted? 7 A. When I touched the switch. 8 Q. Immediately? 9 A. Yes. 10 Q. Ms. Reid, I'm showing you what's 11 been marked as Respondents' Exhibit A. On 12 page five, please look at this photograph 13 and let me know when you're ready. 14 A. I'm ready. 15 Q. Do you recognize this 16 photograph? 17 A. Yes. 18 Q. What is this a photograph of? 19 A. It's a photograph of the switch. 20 Q. Did you take this photograph? 21 A. Yes. 22 Q. Did you take this photograph on 23 the day that you were electrocuted? 24 A. No, after everything happened to 25 me, then I take the photo. Veritext Legal Solutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 13 1 H. REID 2 MR. SIEGEL: Do you understand 3 the question? He's asking whether you 4 took this picture on the date of the 5 accident. 6 THE WITNESS: The same day. 7 Q. Did you take it right after you 8 were electrocuted, or did you take it a 9 couple of hours after? 10 A. A couple of hours. 11 Q. So there are two switches on 12 this photograph? 13 A. Yes. 14 Q. Can you point out or circle 15 which switch you touched when you were 16 electrocuted? 17 MR. SIEGEL: I'm going to object 18 to the form in that you're calling it 19 a switch. It calls for an expert 20 opinion. You can answer the question 21 and you can circle where it is. 22 A. This is the switch that I turned 23 on, the main one that I turned on. I hold 24 onto this thing right here. When I hold 25 onto it just a wire that was there. Veritext Legal Solutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 05/10/2022 06:05 PM INDEX NO. 600978/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 05/10/2022 Page 14 1 H. REID 2 Q. You want to call it a switch; is 3 that okay with you? 4 A. Yes. 5 Q. There are two switches indicated 6 here. One is on the right and one is on 7 the left. You're indicating that you 8 touched the one on the