Preview
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
EXHIBIT "G
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
[Page 1]
SUPREME COURT OF THE STATE OF NEW YORK
QQpy
COUNTY OF SUFFOLK
xxxxxx xxxxxxxx on behalf of , an
infant under the age of 18, and xxxxxx xxxxxxxx,
Individually,
PLAINTIFFS,
- against - INDEX NO.: 026910/12
RONALD J. TADEO, M.D., RICHARD PITCH, M.D.,
SCOTT BERLIN, M.D., SHORE PSYCHIATRIC CENTER,
FAMILY PSYCHOLOGY OF LONG ISLAND, BERLIN OBGYN
ASSOCIATES, JANSSEN PHARMACEUTICALS, INC. k/n/a
ORTHO-MCNEIL-JANSSEN PHARMACEUTICALS, INC.. and
ZYDUS PHARMACEUTICALS USA, INC.,
DEFENDANTS.
DATE: June 26 , 2014
TIME: 10:18 A.M.
R5taMINATION BEFORE TRIAL of a
Defendant, RONALD J. TADDEO, M.D., s/h/a RONALD J.
TADEO, M.D., taken by the Plaintiff, pursuant to a
Court Order, held at the offices of BOWER LAW
P.C., 1220 RXR Plaza, Uniondale, New York 11556,
before a Notary Public of the State of New York.
877-479-2484 U.S.LEGALSUPPORT www.usieghaa-t.com
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
(Page 2]
1
2 A P P E A R A N C E S:
3
4 NAPOLI BERN RIPKA SHKOLNIK, LLP
Attorneys for Plaintiffs
5 Empire State Building
350 Fifth Avenue, Suite 7413
6 New York, New York 10118
BY: DANIELLE L. BRENNER, ESQ.
7
8
BOWER LAW P.C.
9 Attorneys for Defendants
RONALD J. TADDEO, M.D. s/h/a
10 RONALD J. TADEO, M.D. and
SHORE PSYCHIATRIC CENTER
11 1220 RXR Plaza
Uniondale, New York 11556
12 BY: ANINA H. MONTE, ESQ.
FILE #: 199.124
13
14
LAW OFFICES OF MITCHELL J. ANGEL, PLLC
15 Attorneys for Defendant
RICHARD PITCH, M.D.
16 170 Old Country Road, Suite 210
Mineola, New York 11501
17 BY: ANGELA FABIANO, ESQ.
FILE #: MLM 37682
18
19
BARTLETT, McDONOUGH & MONAGHAN, LLP
20 Attorneys for Defendants
SCOTT BERLIN, M.D. and
21 BERLIN OB/GYN ASSOCIATES
170 Old Country Road, 4th Floor
22 Mineola, New York 11501
BY: GLEN T. PEWARSKI, ESQ.
23 FILE #: PRI 2440555
24
25
877-479-2484 U.S.LEGAL SUPPORT www.uatepl .com
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
[Page 3]
1
2 A P P E A R A N C E S (Cont'd.):
3
4 KAUFMAN BORGEEST & RYAN LLP
Attorneys for Defendant
5 FAMILY PSYCHOLOGY OF LONG
ISLAND, P.C.
6 1205 Franklin Avenue, Suite 200
Garden City, New York 11530
7 BY: PATRICK A. DOLAN, ESQ.
FILE #: 508.166
8
9
PATTERSON BELKNAP WEBB & TYLER, LLP
10 Attorneys for Defendant
JANSSEN PHARMACEUTICALS, INC.
11 1133 Avenue of the Americas
New York, New York 10036
12 BY: JOHN WINTER, ESQ.
FILE #: J54102576
13
14
SILLS CUMMINS & GROSS, P.C.
15 Attorneys for Defendant
ZYDUS PHARMACEUTICALS USA, INC.
16 30 Rockefeller Plaza
New York, New York 10112
17 BY: ANDREW W. SCHWARTZ, ESQ.
FILE #: 02520075-000001
18
19
20
21
22
23
24
25
877-479-2484 U.S,LEGALSUPPORT www.¤slagâ!:::pport.com
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
[Page 4]
1
2 221. UNIFORM RULES FOR THE
CONDUCT OF DEPOSITIONS
3
221.1 Objections at Depositions
4 (a) Objections in general. No objections
shall be made at a deposition except those
5 which, pursuant to subdivision (b), (c) or (d)
of Rule 3115 of the Civil Practice Law and
6 Rules, would be waived if not interposed, and
except in compliance with subdivision (e) of
7 such rule. All objections made at a
deposition shall be noted by the officer
8 before whom the deposition is taken, and the
answer shall be given and the deposition shall
9 proceed subject to the objections and to the
right of a person to apply for appropriate
10 relief pursuant to Article 31 of the CPLR.
(b) Speaking objections restricted.
11 Every objection raised during a deposition
shall be stated succinctly and framed so as
12 not to suggest an answer to the deponent and,
at the request of the questioning attorney,
13 shall include a clear statement as to any
defect in form or other basis of error or
14 irregularity. Except to the extent permitted
by CPLR Rule 3115 or by this rule, during the
15 course of the examination persons in
attendance shall not make statements or
16 comments that interfere with the questioning.
17 221.2 Refusal to answer when objection is made.
A deponent shall answer all questions at
18 a deposition, except (i) to preserve a
privilege or right of confidentiality, (ii) to
19 enforce a limitation set forth in an order of
the court, or (iii) when the question is
20 plainly improper and would, if answered, cause
significant prejudice to any person. An
21 attorney shall not direct a deponent not to
answer except as provided in CPLR Rule 3115 or
22 this subdivision. Any refusal to answer or
direction not to answer shall be accompanied
23 by a succinct and clear statement of the basis
therefor. If the deponent does not answer a
24 question, the examining party shall have the
right to complete the remainder of the
25 deposition.
177-479-2484 U.S.LEGALSUPPORT www.uslegalsupportcom
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
(Page 5]
1
2 221. UNIFORM RULES FOR THE
CONDUCT OF DEPOSITIONS
3
221.3 Communication with the deponent.
4 An attorney shall not interrupt the
deposition for the purpose of communicating
5 with the deponent unless all parties consent
or the communication is made for the purpose
.
6 of determining whether the question should not .
be answered on the grounds set forth in
7 section 221.2 of these rules and, in such
event, the reason for the communication shall
8 be stated for the record succinctly and
clearly.
9
10
11 IT IS FURTHER STIPULATED AND AGREED that
the transcript may be signed before any Notary
12 Public with the same force and effect as if
signed before a clerk or a Judge of the court.
13
14 IT IS FURTHER STIPULATED AND AGREED that
the examination before trial may be utilized
15 for all purposes as provided by the CPLR.
16
IT IS FURTHER STIPULATED AND AGREED that
17 all rights provided to all parties by the CPLR
cannot be deemed waived and the appropriate
18 sections of the CPLR shall be controlling with
respect hereto.
19
20 IT IS FURTHER STIPULATED AND AGREED by
and between the attorneys for the respective
21 parties hereto that a copy of this examination
shall be furnished, without charge, to the
22 attorneys representing the witness testifying
herein.
23
24
25
177-479-2484 U.S.LEGALSUPPORT www.=!:p!:;;:pport.com
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
[Page 6]
1
2 R O N A L D J. T A D D E O, M.D. called as a
3 witness, having been first duly sworn by a Notary
4 Public of the State of New York, was examined and
5 testified as follows:
6 MS. MONTE: Just so you know, this
7 is his original record, the Doctor's
8 original. If you want to mark it, I don't
9 know.
10 MS. BRENNER: Okay. We can mark it
11 at the beginning. Could you put it as
12 Plaintiff's Exhibit 1 for today. Thank
13 you.
14 (Whereupon, the aforementioned chart
15 was marked as Plaintiff's Exhibit No. 1 for
16 identification as of this date by the
17 Reporter.)
18 MS. BRENNER: Plaintiff's 1 is the
19 Doctor's original chart.
20 EXAMINATION BY
21 MS. BRENNER:
22 Q. Please state your full name for the
23 record.
24 A. Ronald J. Taddeo, M.D.
25 Q. Where do you reside?
377-479-2484 U.S.LEGALSUPPORT www.micg±=pport.com
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
[Page 7]
1 R. TADDEO, M.D.
2 A. 12 Buckingham Lane, Bohemia, New
3 York 11716.
4 Q. Good morning, Doctor. My name is
5 Danielle Brenner. I'm an attorney with the law
6 firm of Napoli Bern Ripka Shkolnik, and today I'm
7 going to be asking you some questions about some
8 care and treatment that you rendered to my client,
9 xxxxxx xxxxxxxx.
10 Before I get started with the
11 questions, I'm going to go over some instructions
12 for today's deposition. The first instruction
13 that I have is to please make sure to keep all of
14 your responses verbal.
15 We have a Court Reporter here today
16 and she needs to be able to hear your responses,
17 in order to take it down onto the record; is that
18 understood?
19 A, Yes.
20 Q. The second instruction that I have
21 is, please wait for me to finish asking my
22 question, before you start giving me your
23 , response. You may be able to anticipate some of
24 the questions that I'm asking, but it will be a
25 little difficult for the Court Reporter to take
177-479-2484 U.S.LEGALSUPPORT www.u±p:epp:-n.com
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
[Page 8]
1 R. TADDEO, M.D.
2 down both of our voices at the same time;
3 understood?
4 A. Understood.
5 Q. The third instruction is, if do you
6 not understand the question that I'm asking,
7 please let me know, I will gladly rephrase it for
8 you; but if you give me a response to my question,
9 I'm going to assume that you understood it; okay?
10 A. Yes.
11 Q. And then lastly, any time during the
12 deposition that you would like to take a break, I
13 have no problem with that. The only thing I
14 request is if I've asked you a question, you give
15 me a response to my question before we take that
16 break; understood?
17 A. Yes.
18 Q. Thank you very much. Do you have
19 any questions about the instructions that I gave
20 you?
21 A. No.
22 Q. Doctor, do you keep a CV?
23 A. Yes.
24 Q. And when was the last time that your
25 CV was updated?
877-479-2484 U.S.LEGALSUPPORT www.iis:sg. pp d.com
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
[Page 9]
1 R. TADDEO, M.D.
2 A. In the Spring of 2013.
3 Q. And why was it updated in the Spring
4 of 2013?
5 A. The application fo,r this job with
6 BayCare in Florida.
7 Q. You said VA Care?
8 A, No, BayCare, B-A-Y, C-A-R-E.
9 Q. Right now I'm going to ask you some
10 questions about your education and work history.
11 Doctor, did you attend medical school?
12 A. Yes.
13 Q. And where did you attend medical
14 school?
15 A. Bologna Medical School, Bologna,
16 Italy.
17 Q. And did you graduate from Bologna
18 Medical School?
19 A. Yes.
20 Q. And when did you graduate?
21 A. 1971.
22 Q. And what degree did you graduate
23 with in 1971?
24 A, Medical doctor.
25 Q. Upon your graduation in 1971, did
77-479-2484 U.S.LEGALSUPPORT www.us4:-wportcom
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
[Page 10]
1 R. TADDEO, M.D.
2 you thereafter pursue a residency?
3 A, Yes.
4 Q. And where did you pursue that
5 residency?
6 A. At Long Island Jewish Hospital in
7 Queens.
8 MS. NONTE: Do you need water? Do
9 you need any water?
10 THE WITNESS: Yeah, it might be good
11 to have a glass.
12 MS. MONTE: One second.
13 (Whereupon, a short break was
14 taken.)
15 MS. NONTE: Okay, continue,
16 Q. What year did you begin your
17 residency at Long Island Jewish Medical Center in
18 Queens?
19 A. 1972.
20 Q. And did you complete that residency?
21 A. Yes.
22 Q. When did you complete it?
23 A. 1975.
24 Q. Was there a particular focus to that
25 residency?
377479-2484 U.S. LEGALSUPPORT www.usiega!±eppertcom
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019
[Page 11]
1 R. TADDEO, M.D..
2 A. It was in general psychiatry, I had
3 training
Preview
FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 EXHIBIT "G FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 [Page 1] SUPREME COURT OF THE STATE OF NEW YORK QQpy COUNTY OF SUFFOLK xxxxxx xxxxxxxx on behalf of , an infant under the age of 18, and xxxxxx xxxxxxxx, Individually, PLAINTIFFS, - against - INDEX NO.: 026910/12 RONALD J. TADEO, M.D., RICHARD PITCH, M.D., SCOTT BERLIN, M.D., SHORE PSYCHIATRIC CENTER, FAMILY PSYCHOLOGY OF LONG ISLAND, BERLIN OBGYN ASSOCIATES, JANSSEN PHARMACEUTICALS, INC. k/n/a ORTHO-MCNEIL-JANSSEN PHARMACEUTICALS, INC.. and ZYDUS PHARMACEUTICALS USA, INC., DEFENDANTS. DATE: June 26 , 2014 TIME: 10:18 A.M. R5taMINATION BEFORE TRIAL of a Defendant, RONALD J. TADDEO, M.D., s/h/a RONALD J. TADEO, M.D., taken by the Plaintiff, pursuant to a Court Order, held at the offices of BOWER LAW P.C., 1220 RXR Plaza, Uniondale, New York 11556, before a Notary Public of the State of New York. 877-479-2484 U.S.LEGALSUPPORT www.usieghaa-t.com FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 (Page 2] 1 2 A P P E A R A N C E S: 3 4 NAPOLI BERN RIPKA SHKOLNIK, LLP Attorneys for Plaintiffs 5 Empire State Building 350 Fifth Avenue, Suite 7413 6 New York, New York 10118 BY: DANIELLE L. BRENNER, ESQ. 7 8 BOWER LAW P.C. 9 Attorneys for Defendants RONALD J. TADDEO, M.D. s/h/a 10 RONALD J. TADEO, M.D. and SHORE PSYCHIATRIC CENTER 11 1220 RXR Plaza Uniondale, New York 11556 12 BY: ANINA H. MONTE, ESQ. FILE #: 199.124 13 14 LAW OFFICES OF MITCHELL J. ANGEL, PLLC 15 Attorneys for Defendant RICHARD PITCH, M.D. 16 170 Old Country Road, Suite 210 Mineola, New York 11501 17 BY: ANGELA FABIANO, ESQ. FILE #: MLM 37682 18 19 BARTLETT, McDONOUGH & MONAGHAN, LLP 20 Attorneys for Defendants SCOTT BERLIN, M.D. and 21 BERLIN OB/GYN ASSOCIATES 170 Old Country Road, 4th Floor 22 Mineola, New York 11501 BY: GLEN T. PEWARSKI, ESQ. 23 FILE #: PRI 2440555 24 25 877-479-2484 U.S.LEGAL SUPPORT www.uatepl .com FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 [Page 3] 1 2 A P P E A R A N C E S (Cont'd.): 3 4 KAUFMAN BORGEEST & RYAN LLP Attorneys for Defendant 5 FAMILY PSYCHOLOGY OF LONG ISLAND, P.C. 6 1205 Franklin Avenue, Suite 200 Garden City, New York 11530 7 BY: PATRICK A. DOLAN, ESQ. FILE #: 508.166 8 9 PATTERSON BELKNAP WEBB & TYLER, LLP 10 Attorneys for Defendant JANSSEN PHARMACEUTICALS, INC. 11 1133 Avenue of the Americas New York, New York 10036 12 BY: JOHN WINTER, ESQ. FILE #: J54102576 13 14 SILLS CUMMINS & GROSS, P.C. 15 Attorneys for Defendant ZYDUS PHARMACEUTICALS USA, INC. 16 30 Rockefeller Plaza New York, New York 10112 17 BY: ANDREW W. SCHWARTZ, ESQ. FILE #: 02520075-000001 18 19 20 21 22 23 24 25 877-479-2484 U.S,LEGALSUPPORT www.¤slagâ!:::pport.com FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 [Page 4] 1 2 221. UNIFORM RULES FOR THE CONDUCT OF DEPOSITIONS 3 221.1 Objections at Depositions 4 (a) Objections in general. No objections shall be made at a deposition except those 5 which, pursuant to subdivision (b), (c) or (d) of Rule 3115 of the Civil Practice Law and 6 Rules, would be waived if not interposed, and except in compliance with subdivision (e) of 7 such rule. All objections made at a deposition shall be noted by the officer 8 before whom the deposition is taken, and the answer shall be given and the deposition shall 9 proceed subject to the objections and to the right of a person to apply for appropriate 10 relief pursuant to Article 31 of the CPLR. (b) Speaking objections restricted. 11 Every objection raised during a deposition shall be stated succinctly and framed so as 12 not to suggest an answer to the deponent and, at the request of the questioning attorney, 13 shall include a clear statement as to any defect in form or other basis of error or 14 irregularity. Except to the extent permitted by CPLR Rule 3115 or by this rule, during the 15 course of the examination persons in attendance shall not make statements or 16 comments that interfere with the questioning. 17 221.2 Refusal to answer when objection is made. A deponent shall answer all questions at 18 a deposition, except (i) to preserve a privilege or right of confidentiality, (ii) to 19 enforce a limitation set forth in an order of the court, or (iii) when the question is 20 plainly improper and would, if answered, cause significant prejudice to any person. An 21 attorney shall not direct a deponent not to answer except as provided in CPLR Rule 3115 or 22 this subdivision. Any refusal to answer or direction not to answer shall be accompanied 23 by a succinct and clear statement of the basis therefor. If the deponent does not answer a 24 question, the examining party shall have the right to complete the remainder of the 25 deposition. 177-479-2484 U.S.LEGALSUPPORT www.uslegalsupportcom FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 (Page 5] 1 2 221. UNIFORM RULES FOR THE CONDUCT OF DEPOSITIONS 3 221.3 Communication with the deponent. 4 An attorney shall not interrupt the deposition for the purpose of communicating 5 with the deponent unless all parties consent or the communication is made for the purpose . 6 of determining whether the question should not . be answered on the grounds set forth in 7 section 221.2 of these rules and, in such event, the reason for the communication shall 8 be stated for the record succinctly and clearly. 9 10 11 IT IS FURTHER STIPULATED AND AGREED that the transcript may be signed before any Notary 12 Public with the same force and effect as if signed before a clerk or a Judge of the court. 13 14 IT IS FURTHER STIPULATED AND AGREED that the examination before trial may be utilized 15 for all purposes as provided by the CPLR. 16 IT IS FURTHER STIPULATED AND AGREED that 17 all rights provided to all parties by the CPLR cannot be deemed waived and the appropriate 18 sections of the CPLR shall be controlling with respect hereto. 19 20 IT IS FURTHER STIPULATED AND AGREED by and between the attorneys for the respective 21 parties hereto that a copy of this examination shall be furnished, without charge, to the 22 attorneys representing the witness testifying herein. 23 24 25 177-479-2484 U.S.LEGALSUPPORT www.=!:p!:;;:pport.com FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 [Page 6] 1 2 R O N A L D J. T A D D E O, M.D. called as a 3 witness, having been first duly sworn by a Notary 4 Public of the State of New York, was examined and 5 testified as follows: 6 MS. MONTE: Just so you know, this 7 is his original record, the Doctor's 8 original. If you want to mark it, I don't 9 know. 10 MS. BRENNER: Okay. We can mark it 11 at the beginning. Could you put it as 12 Plaintiff's Exhibit 1 for today. Thank 13 you. 14 (Whereupon, the aforementioned chart 15 was marked as Plaintiff's Exhibit No. 1 for 16 identification as of this date by the 17 Reporter.) 18 MS. BRENNER: Plaintiff's 1 is the 19 Doctor's original chart. 20 EXAMINATION BY 21 MS. BRENNER: 22 Q. Please state your full name for the 23 record. 24 A. Ronald J. Taddeo, M.D. 25 Q. Where do you reside? 377-479-2484 U.S.LEGALSUPPORT www.micg±=pport.com FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 [Page 7] 1 R. TADDEO, M.D. 2 A. 12 Buckingham Lane, Bohemia, New 3 York 11716. 4 Q. Good morning, Doctor. My name is 5 Danielle Brenner. I'm an attorney with the law 6 firm of Napoli Bern Ripka Shkolnik, and today I'm 7 going to be asking you some questions about some 8 care and treatment that you rendered to my client, 9 xxxxxx xxxxxxxx. 10 Before I get started with the 11 questions, I'm going to go over some instructions 12 for today's deposition. The first instruction 13 that I have is to please make sure to keep all of 14 your responses verbal. 15 We have a Court Reporter here today 16 and she needs to be able to hear your responses, 17 in order to take it down onto the record; is that 18 understood? 19 A, Yes. 20 Q. The second instruction that I have 21 is, please wait for me to finish asking my 22 question, before you start giving me your 23 , response. You may be able to anticipate some of 24 the questions that I'm asking, but it will be a 25 little difficult for the Court Reporter to take 177-479-2484 U.S.LEGALSUPPORT www.u±p:epp:-n.com FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 [Page 8] 1 R. TADDEO, M.D. 2 down both of our voices at the same time; 3 understood? 4 A. Understood. 5 Q. The third instruction is, if do you 6 not understand the question that I'm asking, 7 please let me know, I will gladly rephrase it for 8 you; but if you give me a response to my question, 9 I'm going to assume that you understood it; okay? 10 A. Yes. 11 Q. And then lastly, any time during the 12 deposition that you would like to take a break, I 13 have no problem with that. The only thing I 14 request is if I've asked you a question, you give 15 me a response to my question before we take that 16 break; understood? 17 A. Yes. 18 Q. Thank you very much. Do you have 19 any questions about the instructions that I gave 20 you? 21 A. No. 22 Q. Doctor, do you keep a CV? 23 A. Yes. 24 Q. And when was the last time that your 25 CV was updated? 877-479-2484 U.S.LEGALSUPPORT www.iis:sg. pp d.com FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 [Page 9] 1 R. TADDEO, M.D. 2 A. In the Spring of 2013. 3 Q. And why was it updated in the Spring 4 of 2013? 5 A. The application fo,r this job with 6 BayCare in Florida. 7 Q. You said VA Care? 8 A, No, BayCare, B-A-Y, C-A-R-E. 9 Q. Right now I'm going to ask you some 10 questions about your education and work history. 11 Doctor, did you attend medical school? 12 A. Yes. 13 Q. And where did you attend medical 14 school? 15 A. Bologna Medical School, Bologna, 16 Italy. 17 Q. And did you graduate from Bologna 18 Medical School? 19 A. Yes. 20 Q. And when did you graduate? 21 A. 1971. 22 Q. And what degree did you graduate 23 with in 1971? 24 A, Medical doctor. 25 Q. Upon your graduation in 1971, did 77-479-2484 U.S.LEGALSUPPORT www.us4:-wportcom FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 [Page 10] 1 R. TADDEO, M.D. 2 you thereafter pursue a residency? 3 A, Yes. 4 Q. And where did you pursue that 5 residency? 6 A. At Long Island Jewish Hospital in 7 Queens. 8 MS. NONTE: Do you need water? Do 9 you need any water? 10 THE WITNESS: Yeah, it might be good 11 to have a glass. 12 MS. MONTE: One second. 13 (Whereupon, a short break was 14 taken.) 15 MS. NONTE: Okay, continue, 16 Q. What year did you begin your 17 residency at Long Island Jewish Medical Center in 18 Queens? 19 A. 1972. 20 Q. And did you complete that residency? 21 A. Yes. 22 Q. When did you complete it? 23 A. 1975. 24 Q. Was there a particular focus to that 25 residency? 377479-2484 U.S. LEGALSUPPORT www.usiega!±eppertcom FILED: SUFFOLK COUNTY CLERK 01/09/2019 10:58 AM INDEX NO. 026910/2012 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 01/09/2019 [Page 11] 1 R. TADDEO, M.D.. 2 A. It was in general psychiatry, I had 3 training