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1
2 SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
3 _______________ ______
4 xxxxxx xxxxxxxx, on behalf of C
- S an infant under the ge o f 18
, a
5 years, and xxxxxx xxxxxxxx, individually,
6 Plaintiff,
7 -against-
8 RONALD J. TADDEO, MD, RICHARD PITCH, MD,
SCOTT BERLIN, MD SHORE PSYCHIATRIC
9 CENTER, FAMILY PSYCHOLOGY OF LONG ISLAND,
BERLIN OB/GYN ASSOCIATES, JANSSEN
10 PHARMACEUTICALS, INC., and EYDUS
PHARMACEUTICALS (USA), INC.,
11
Defendants.
12
Index No. 026910/12
14 June 13, 2014
10:35 a.m.
15
170 Old Country Road
16 Mineola, New York
17
18 CONTINUED EXAMINATION BEFORE TRIAL
19 of xxxxxx xxxxxxxx, the Plaintiff herein,
20 held at the above-noted time and place
21 before Josephine Winter, Certified
22 Shorthand Reporter and a Notary Public of
23 the State of New York.
24
. 25
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2 A P P 5 A R A N C E S:
3
NAPOLI BERN RIPKA SHKOLNIK, LLP
4 Attorneys for Plaintiff
350 Fifth Avenue
5 New York, New York 10118
BY: STAESHA O. RATH, ESQ.
6
7 BOWER LAW, PC
Attorneys for Defendants
. 8 RONALD J. TADDEO, MD, and
SHORE PSYCHIATRIC CENTER
Un ad e New York 11556
10 BY: ANINA H.. MONTE, ESQ.
amonte@blawpc.com
11
12 LAW OFFICES OF MITCHELL J. ANGEL, PLLC
Attorneys for Defendant
13 RICHARD PITCH, MD
170 Old Country Road
14- Mineola, New York 11501
BY: ANGELA FABIANO, ESQ.
15
16 BARTLETT, McDONOUGH & MONAGHAN, LLP
Attorneys for Defendants
17 SCOTT BERLIN, MD, and
BERLIN OB/GYN ASSOCIATES, PC
18 670 Main Street
Islip, New York 11751
19 BY: DOU-GLAS LANGHOLE, ESQ.
doug.1angholz@bamilp.com
2 0
21 KAUFMAN, BORGEEST & RYAN, LLP
Attorneys for Defendant
22 FAMILY PSYCHOLOGY OF LONG ISLAND
1205 Franklin Avenue
23 Garden City, New York 11530
BY: PATRICK A. DOLAN, ESQ.
24 pdolan@kbr1aw.com
25
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1
2 A P P E A R A N C E S: (cont.)
3
PATTERSON, BELENAP, WEBB & TYLER, LLP
4 Attorneys for Defendant
JANSSEN PHARMACEUTICALS, INC.
5 1133 Avenue of the Americas
New York, New York 10036
6 BY: MATTHEW W.J. WEBB, ESQ.
mwebb@pbwt..com
8 SILLS, CUMMIS & GROSS, PC
Attorneys for Defendant
9 EYDUS PHARMACEUTICALS (USA), INC.
One Riverfront Plaza
.
10 Newark, New Jersey 07102
BY: ANDREW W, SCHWARTE, ESQ.
11 aschwartz@ sillsoummis.com
12
* * *
13
14
15
16
17
18
19
20
21
22
23
24
25
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2 P A M E L A S C H A L L E R, having
3 been first duly sworn by a Notary Public
4 of the State of New York, upon being
5 examined, testified further as follows:
6 EXAMINATION BY
7 MR. SCHWARTE:
8 Q Good morning, Mrs. xxxxxxxx. My
9 name is Andrew Schwartz and I'm not sure
10 we met at the last day of your deposition.
11 I'm still fairly new to this case. My
12 colleague Katie started asking you some
13 questions at the end of the third day of
14 the deposition.
15 I'm going to pick up where she
16 left off. I promise I'll try not to
17 repeat myself with regard to questions
18 already asked, but there were some
19 follow-up questions I had based on that.
20 First of all, since we were last
21 present for your deposition on May 29 have
22 any of your medications changed?
23 A No.
24 Q Have you had any doctor's
25 appointments aince May 29 for you
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2 personally?
3 A I don't believe so. I don't
4 think so, no.
5 Q Are you currently seeing any
6 psychiatrist?
7 A Yes .
8 Q Who is your ourrent treater?
9 A Dr . Greenberg .
10 Q Are you in any other treatment
11 groups for your mental health presently?
12 A Groups?
13 Q Groups, sessions, anyone else
14 you're seeing.
15 A Yes.
16 Q Who else are you seeing for your
17 mental health?
18 A Heidi Beisp.iel .
19 Q Could you spell that, please?
20 A I think it's B E I S P E L.
21 Q Where is she located?
22 A Same office.
23 Q Is she affiliated with Dr.
24 Greenberg?
. 25 A Yes.
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2 What type of treatment is -- is
Q
3 she a doctor?
4 A No.
..
5 Q What is her title?
6 A Her title -- I'm to think
trying
7 of the letters at the end of her name.
8 She is a psychologist. I think L -- not
9 an L C. L something.
10 Q And Dr. Greenberg is an MD?
11 A Yes.
12 Q How does the treatment of Dr.
13 Greenberg differ from the treatment Dr.
14 Beispiel provides you?
15 A He prescribes medication and
16 she -- we speak.
17 Q Do you speak with him at all or
18 does he only prescribe medication?
19 A No. We speak.
20 Q How often do you see Dr.
21 Beispiel?
22 A Once a week for now.
23 Q How often do you see Dr.
24 Greenberg?
25 A Once a month.
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2 Q For how long have you been
3 treating with Dr. Beispiel?
4 A A few months.
5 Q What medications have you taken
6 in the last 24 hours?
7 A Lamiotal.
8 24 hours?
9 Q 24 hours.
10 A Lamiotal in the morning.
11 Do you want me to tell you the
12 milligrams again?
13 Q No. I just need the names.
14 A Lamictal, Benicar and Latuda.
15 That's it,
16 Q Have you smoked any cigarettes
17 in the last 24 hours?
18 A No.
19 Q When was the last time you
20 smoked?
21 A January 21, 2013.
22 Q Unlike other dates that you've
23 been asked about in your deposition that
24 one seems to stand out. Why is that?
25 A Because I was so proud of myself
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2 to quit smoking. I'll never forget that
3 day.
4 Q Did you follow a particular
5 program or did you just stop cold turkey
6 on January 21, 2013?
7 A I used a couple of Nicotrol and
8 then I just stopped cold turkey. I used
9 like two days' worth.
10 Q And you've not smoked any
11 cigarettes since?
12 A No.
13 Q What about cigars?
14 A No.
15 Q Ever smoked cigars?
16 A Maybe once for my honeymoon.
17 Q Have you reviewed any documents
18 since May 29, the date of your last
19 deposition?
20 A No, not at all.
21 Q Did you do anything in
22 particular to prepare for today's
23 deposition?
24 A No.
25 Q Any further meetings with your
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2 counsel?
3 A No. Just this morning hi, how
4 are you.
5 Q Any phone calls with your
6 counsel regarding this deposition?
7 A Just to schedule it.
8 . Q When were you last employed?
9 A Wow. Out of the home?
10 Q At all. Paying job.
11 A I don't remember the date or the
12 year. Maybe 2009. 2009, 2010. I don't
13 remember.
14 Q Have you had any paid employment
15 since you gave birth to C
16 A No.
17 Q Are you still on complete
18 disability?
19 A Yes.
20 Q Ho W much do you receive per
21 month presently?
22 A Abou t 1,100 after taxes.
23 Q At any time since 2007, so going
24 back about seven years, have you kept a
25 diary or journal?
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2 A No.
3 Q Do you know if Tony has kept a
4 diary or journal since 2007?
5 A I doubt it highly. I've never
6 seen him write anything down.
7 Q I saw reference in your
0 treatment records with doctor -- and I'm
9 going to alobber this name. Is it Cavuto?
10 A Yes.
11 Q Look at that.
12, I saw references in your
. 13 treatment records with Dr. Cavuto to your
14 completing diary cards for him.
15 Could you explain what those
16 are?
17 A I remember that. I would write
18 down -- I don't think were actual
they
19 cards. I think things that happened
20 during the week that we needed to discuss
21 or I needed help with DBT regarding it.
22 Q So you would make notes on
23 events that happened during the week?
24 A I believe so. I wasn't too --
25 what's the word I'm looking for? It
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2 wasn't something I often did. A lot of
3 times I forgot or I was busy, so it was
4 sporadio.
5 Q But it wasn't an actual card?
..
6 A No. It was paper.
7 Sorry.
8 Q That's okay. We'll get into a
9 flow at some point.
10 Was it a pad of paper or
11 individual sheets of paper?
12 A I believe it was individual
13 sheets.
14 Q When you completed those, you
15 would bring those with you to your
16 sessions with Dr. Cavuto?
17 A Yes.
18 Q What would happen to those
19 papers after those sessions? Would he
[
20 keep them or would he return them to you?
21 A My god, it was so long ago. I
22 don't remember if I discarded it or he
23 kept it. I don't remember.
24 Q There was a lot of discussion at
25 the last couple days of your deposition
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2 about several gentlemen that you had
3 relationships with at or about the time
4 you conceived C .
5 A Yes..
6 Q One was originally referred to
7 as being from Colombia but we now believe
8 is from India; is that correct?
9 A I believe.
10 Q Since May 29 have you recalled
11 his name?
12 A I was thinking about it. I
13 think it started with an S, but I can't
14 remember. It wasn't something that was
15 something I wanted to remember.
16 Q Do you have any documents where
17 you would have written down his name?
18 A No. No.
19 Q Not in a day planner, an e-mail
20 or anything like that?
21 A No. No.
22 Q Was he in your contacts on your
23 phone or in your computer?
24 A No.
25 Q Did you ever discuss him with
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2 any of your friends?
3 A I don't remember. I had
w
4 different friends back then that I don't
5 speak to anymore.
. 6 Q Back in September of 2009 who
7 were your closest friends?
8 A 2009 -- it's so hard to remember
9 2009. It's five years later. I think
10 Alison was one, but I don't know what you
11 mean by close friends.
12 Q All right. Let's try it this
13 way:
14 Di.d you have any friends with
15 whom you discussed your relationship with
16 this Indian man at any time?
17 A Honestly,. I don't remember if I
18 did or didn't. I kept a lot of my life
19 private.
20 Q Did you have any friends that
21 you discussed your extramarital affairs
22 with at any time?
23 A I think it was -- I mean pretty
24 much my psychologist.
25 Q So just professionals, not
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2 friends?
3 A I kept it private.
4 Q Alison, what is her last name?
5 A Sebor, S E B O R.
6 Q Where does she reside?
7 A Islip,
8 Q Do you know the street?
9 A No.
10 Q What was your relationship with
11 her?
12 A We were just friends.
13 Q How did you meet?
14 A We met through a moms' group.
15 Q That was the one you ran?
16 A Yes. .
17 Q What about Tom? Do you recall
18 Tom's last name?
19 A No.
20 Q Was there anyone other than your
21 treating physicians that you discussed Tom
22 with at any time?
23 A No.
24 Q How did you first come in
25 contact with this gentleman from India?
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2 A I believe it was the internet.
3 Q What specific site?
4 A It might have been a chat room
5 in AOL. I don't remember.
6 Q What specific chat room?
7 A I don't know.
8 Q What was his user name?
9
A· I don't know that. I donT
10 remember that.
11 Q What was your user name?
12 A I don't want to lie. I believe
1 3 a t that time it was .
14 Q What is zero five two three?
15 A My birthday.
16 Q Other than AOL were there any
17 other chat rooms you would frequent back
18 in the period say from 2008 to 2009?
19 A I don't remember the time
20 period. I'm sorry. It's so difficult to
21 remember dates.
22 Q How long had you been chatting
23 with the gentleman from India before you
24 first met him?
25 A Weeks or months. I don't know.
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2 Q At ·some point I believe you
3 testified that you communicated with him
4 by phone?
5 A Yes.
6 Q Is that right?
7 A Yes. Sometimes.
8 Q And who would call whom?
9 A He would call me. I would call
10 him. There wasn't a specific routine.
11 Q So at some point you had his
12 phone number?
- 13 A Ye s .
14 Q Do you recall what hotels you
15 met him at?
16 A I don't.
17 Q You don't recall any of the .
18 hotels you met him at?
19 A The name s, no.
20 Q Locations?
21 A I don't remember names.
22 Q Do you remember dates on which
23 you met him?
2 4 A No , def ini te ly .not .
25 g When you met this gentleman from
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2 India at a hotel room, who would pay for
3 the room?
4 A He would pay for it.
5 Q Would he use cash or a credit
6 card?
7 A I have no idea.
8 Q You weren't present when he
9 paid?
10 A No.
11 Q Do you have any pictures of him?
12
Preview
FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 630 SERTIFIED TRANSCRIPT 1 2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK 3 _______________ ______ 4 xxxxxx xxxxxxxx, on behalf of C - S an infant under the ge o f 18 , a 5 years, and xxxxxx xxxxxxxx, individually, 6 Plaintiff, 7 -against- 8 RONALD J. TADDEO, MD, RICHARD PITCH, MD, SCOTT BERLIN, MD SHORE PSYCHIATRIC 9 CENTER, FAMILY PSYCHOLOGY OF LONG ISLAND, BERLIN OB/GYN ASSOCIATES, JANSSEN 10 PHARMACEUTICALS, INC., and EYDUS PHARMACEUTICALS (USA), INC., 11 Defendants. 12 Index No. 026910/12 14 June 13, 2014 10:35 a.m. 15 170 Old Country Road 16 Mineola, New York 17 18 CONTINUED EXAMINATION BEFORE TRIAL 19 of xxxxxx xxxxxxxx, the Plaintiff herein, 20 held at the above-noted time and place 21 before Josephine Winter, Certified 22 Shorthand Reporter and a Notary Public of 23 the State of New York. 24 . 25 VERITBXTREPORTINGCOMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 631 1 2 A P P 5 A R A N C E S: 3 NAPOLI BERN RIPKA SHKOLNIK, LLP 4 Attorneys for Plaintiff 350 Fifth Avenue 5 New York, New York 10118 BY: STAESHA O. RATH, ESQ. 6 7 BOWER LAW, PC Attorneys for Defendants . 8 RONALD J. TADDEO, MD, and SHORE PSYCHIATRIC CENTER Un ad e New York 11556 10 BY: ANINA H.. MONTE, ESQ. amonte@blawpc.com 11 12 LAW OFFICES OF MITCHELL J. ANGEL, PLLC Attorneys for Defendant 13 RICHARD PITCH, MD 170 Old Country Road 14- Mineola, New York 11501 BY: ANGELA FABIANO, ESQ. 15 16 BARTLETT, McDONOUGH & MONAGHAN, LLP Attorneys for Defendants 17 SCOTT BERLIN, MD, and BERLIN OB/GYN ASSOCIATES, PC 18 670 Main Street Islip, New York 11751 19 BY: DOU-GLAS LANGHOLE, ESQ. doug.1angholz@bamilp.com 2 0 21 KAUFMAN, BORGEEST & RYAN, LLP Attorneys for Defendant 22 FAMILY PSYCHOLOGY OF LONG ISLAND 1205 Franklin Avenue 23 Garden City, New York 11530 BY: PATRICK A. DOLAN, ESQ. 24 pdolan@kbr1aw.com 25 VERITEXT REPORTING COMPANY 212-279-9424 www.veritext.com 212··490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 632 .. 1 2 A P P E A R A N C E S: (cont.) 3 PATTERSON, BELENAP, WEBB & TYLER, LLP 4 Attorneys for Defendant JANSSEN PHARMACEUTICALS, INC. 5 1133 Avenue of the Americas New York, New York 10036 6 BY: MATTHEW W.J. WEBB, ESQ. mwebb@pbwt..com 8 SILLS, CUMMIS & GROSS, PC Attorneys for Defendant 9 EYDUS PHARMACEUTICALS (USA), INC. One Riverfront Plaza . 10 Newark, New Jersey 07102 BY: ANDREW W, SCHWARTE, ESQ. 11 aschwartz@ sillsoummis.com 12 * * * 13 14 15 16 17 18 19 20 21 22 23 24 25 VERITEXT REPORTING COMPANY 212-279-9424 www.veritextcom 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 633 1 2 P A M E L A S C H A L L E R, having 3 been first duly sworn by a Notary Public 4 of the State of New York, upon being 5 examined, testified further as follows: 6 EXAMINATION BY 7 MR. SCHWARTE: 8 Q Good morning, Mrs. xxxxxxxx. My 9 name is Andrew Schwartz and I'm not sure 10 we met at the last day of your deposition. 11 I'm still fairly new to this case. My 12 colleague Katie started asking you some 13 questions at the end of the third day of 14 the deposition. 15 I'm going to pick up where she 16 left off. I promise I'll try not to 17 repeat myself with regard to questions 18 already asked, but there were some 19 follow-up questions I had based on that. 20 First of all, since we were last 21 present for your deposition on May 29 have 22 any of your medications changed? 23 A No. 24 Q Have you had any doctor's 25 appointments aince May 29 for you VERITEXTREPORTINGCOMPANY 212-279-9424 www.veritextcom 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 634 1 P. xxxxxxxx 2 personally? 3 A I don't believe so. I don't 4 think so, no. 5 Q Are you currently seeing any 6 psychiatrist? 7 A Yes . 8 Q Who is your ourrent treater? 9 A Dr . Greenberg . 10 Q Are you in any other treatment 11 groups for your mental health presently? 12 A Groups? 13 Q Groups, sessions, anyone else 14 you're seeing. 15 A Yes. 16 Q Who else are you seeing for your 17 mental health? 18 A Heidi Beisp.iel . 19 Q Could you spell that, please? 20 A I think it's B E I S P E L. 21 Q Where is she located? 22 A Same office. 23 Q Is she affiliated with Dr. 24 Greenberg? . 25 A Yes. VERITEXTREPORTINGCOMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 635 1 P. xxxxxxxx 2 What type of treatment is -- is Q 3 she a doctor? 4 A No. .. 5 Q What is her title? 6 A Her title -- I'm to think trying 7 of the letters at the end of her name. 8 She is a psychologist. I think L -- not 9 an L C. L something. 10 Q And Dr. Greenberg is an MD? 11 A Yes. 12 Q How does the treatment of Dr. 13 Greenberg differ from the treatment Dr. 14 Beispiel provides you? 15 A He prescribes medication and 16 she -- we speak. 17 Q Do you speak with him at all or 18 does he only prescribe medication? 19 A No. We speak. 20 Q How often do you see Dr. 21 Beispiel? 22 A Once a week for now. 23 Q How often do you see Dr. 24 Greenberg? 25 A Once a month. VERITEXT REPORTING COMPANY 212-279-9424 www.veritextcom 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 636 1 P. xxxxxxxx 2 Q For how long have you been 3 treating with Dr. Beispiel? 4 A A few months. 5 Q What medications have you taken 6 in the last 24 hours? 7 A Lamiotal. 8 24 hours? 9 Q 24 hours. 10 A Lamiotal in the morning. 11 Do you want me to tell you the 12 milligrams again? 13 Q No. I just need the names. 14 A Lamictal, Benicar and Latuda. 15 That's it, 16 Q Have you smoked any cigarettes 17 in the last 24 hours? 18 A No. 19 Q When was the last time you 20 smoked? 21 A January 21, 2013. 22 Q Unlike other dates that you've 23 been asked about in your deposition that 24 one seems to stand out. Why is that? 25 A Because I was so proud of myself VERITEXTREPORTINGCOMPANY 212-279-9424 www.veritext.com 212.490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 637 1 P. xxxxxxxx 2 to quit smoking. I'll never forget that 3 day. 4 Q Did you follow a particular 5 program or did you just stop cold turkey 6 on January 21, 2013? 7 A I used a couple of Nicotrol and 8 then I just stopped cold turkey. I used 9 like two days' worth. 10 Q And you've not smoked any 11 cigarettes since? 12 A No. 13 Q What about cigars? 14 A No. 15 Q Ever smoked cigars? 16 A Maybe once for my honeymoon. 17 Q Have you reviewed any documents 18 since May 29, the date of your last 19 deposition? 20 A No, not at all. 21 Q Did you do anything in 22 particular to prepare for today's 23 deposition? 24 A No. 25 Q Any further meetings with your VERITEXTREPORTINGCOMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 638 1 P. xxxxxxxx 2 counsel? 3 A No. Just this morning hi, how 4 are you. 5 Q Any phone calls with your 6 counsel regarding this deposition? 7 A Just to schedule it. 8 . Q When were you last employed? 9 A Wow. Out of the home? 10 Q At all. Paying job. 11 A I don't remember the date or the 12 year. Maybe 2009. 2009, 2010. I don't 13 remember. 14 Q Have you had any paid employment 15 since you gave birth to C 16 A No. 17 Q Are you still on complete 18 disability? 19 A Yes. 20 Q Ho W much do you receive per 21 month presently? 22 A Abou t 1,100 after taxes. 23 Q At any time since 2007, so going 24 back about seven years, have you kept a 25 diary or journal? VERITEXTREPORTINGCOMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 639 1 P. xxxxxxxx 2 A No. 3 Q Do you know if Tony has kept a 4 diary or journal since 2007? 5 A I doubt it highly. I've never 6 seen him write anything down. 7 Q I saw reference in your 0 treatment records with doctor -- and I'm 9 going to alobber this name. Is it Cavuto? 10 A Yes. 11 Q Look at that. 12, I saw references in your . 13 treatment records with Dr. Cavuto to your 14 completing diary cards for him. 15 Could you explain what those 16 are? 17 A I remember that. I would write 18 down -- I don't think were actual they 19 cards. I think things that happened 20 during the week that we needed to discuss 21 or I needed help with DBT regarding it. 22 Q So you would make notes on 23 events that happened during the week? 24 A I believe so. I wasn't too -- 25 what's the word I'm looking for? It VERITEXT REPORTING COMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 640 1 P. xxxxxxxx 2 wasn't something I often did. A lot of 3 times I forgot or I was busy, so it was 4 sporadio. 5 Q But it wasn't an actual card? .. 6 A No. It was paper. 7 Sorry. 8 Q That's okay. We'll get into a 9 flow at some point. 10 Was it a pad of paper or 11 individual sheets of paper? 12 A I believe it was individual 13 sheets. 14 Q When you completed those, you 15 would bring those with you to your 16 sessions with Dr. Cavuto? 17 A Yes. 18 Q What would happen to those 19 papers after those sessions? Would he [ 20 keep them or would he return them to you? 21 A My god, it was so long ago. I 22 don't remember if I discarded it or he 23 kept it. I don't remember. 24 Q There was a lot of discussion at 25 the last couple days of your deposition VERITEXT REPORTING COMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 641 1 P. xxxxxxxx 2 about several gentlemen that you had 3 relationships with at or about the time 4 you conceived C . 5 A Yes.. 6 Q One was originally referred to 7 as being from Colombia but we now believe 8 is from India; is that correct? 9 A I believe. 10 Q Since May 29 have you recalled 11 his name? 12 A I was thinking about it. I 13 think it started with an S, but I can't 14 remember. It wasn't something that was 15 something I wanted to remember. 16 Q Do you have any documents where 17 you would have written down his name? 18 A No. No. 19 Q Not in a day planner, an e-mail 20 or anything like that? 21 A No. No. 22 Q Was he in your contacts on your 23 phone or in your computer? 24 A No. 25 Q Did you ever discuss him with VERITEXTREPORTINGCOMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 642 1 P. xxxxxxxx 2 any of your friends? 3 A I don't remember. I had w 4 different friends back then that I don't 5 speak to anymore. . 6 Q Back in September of 2009 who 7 were your closest friends? 8 A 2009 -- it's so hard to remember 9 2009. It's five years later. I think 10 Alison was one, but I don't know what you 11 mean by close friends. 12 Q All right. Let's try it this 13 way: 14 Di.d you have any friends with 15 whom you discussed your relationship with 16 this Indian man at any time? 17 A Honestly,. I don't remember if I 18 did or didn't. I kept a lot of my life 19 private. 20 Q Did you have any friends that 21 you discussed your extramarital affairs 22 with at any time? 23 A I think it was -- I mean pretty 24 much my psychologist. 25 Q So just professionals, not VERITEXT REPORTING COMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 643 1 P. xxxxxxxx 2 friends? 3 A I kept it private. 4 Q Alison, what is her last name? 5 A Sebor, S E B O R. 6 Q Where does she reside? 7 A Islip, 8 Q Do you know the street? 9 A No. 10 Q What was your relationship with 11 her? 12 A We were just friends. 13 Q How did you meet? 14 A We met through a moms' group. 15 Q That was the one you ran? 16 A Yes. . 17 Q What about Tom? Do you recall 18 Tom's last name? 19 A No. 20 Q Was there anyone other than your 21 treating physicians that you discussed Tom 22 with at any time? 23 A No. 24 Q How did you first come in 25 contact with this gentleman from India? VERITEXT REPORTING COMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 644 1 P. xxxxxxxx 2 A I believe it was the internet. 3 Q What specific site? 4 A It might have been a chat room 5 in AOL. I don't remember. 6 Q What specific chat room? 7 A I don't know. 8 Q What was his user name? 9 A· I don't know that. I donT 10 remember that. 11 Q What was your user name? 12 A I don't want to lie. I believe 1 3 a t that time it was . 14 Q What is zero five two three? 15 A My birthday. 16 Q Other than AOL were there any 17 other chat rooms you would frequent back 18 in the period say from 2008 to 2009? 19 A I don't remember the time 20 period. I'm sorry. It's so difficult to 21 remember dates. 22 Q How long had you been chatting 23 with the gentleman from India before you 24 first met him? 25 A Weeks or months. I don't know. VERITEXT REPORTING COMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 645 1 P. xxxxxxxx 2 Q At ·some point I believe you 3 testified that you communicated with him 4 by phone? 5 A Yes. 6 Q Is that right? 7 A Yes. Sometimes. 8 Q And who would call whom? 9 A He would call me. I would call 10 him. There wasn't a specific routine. 11 Q So at some point you had his 12 phone number? - 13 A Ye s . 14 Q Do you recall what hotels you 15 met him at? 16 A I don't. 17 Q You don't recall any of the . 18 hotels you met him at? 19 A The name s, no. 20 Q Locations? 21 A I don't remember names. 22 Q Do you remember dates on which 23 you met him? 2 4 A No , def ini te ly .not . 25 g When you met this gentleman from VERITEXTREPORTINGCOMPANY 212-279-9424 www.veritext.com 212-490-3430 FILED: SUFFOLK COUNTY CLERK 01/10/2019 10:08 PM INDEX NO. 026910/2012 NYSCEF DOC. NO. 93 RECEIVED NYSCEF: 01/10/2019 Page 646 1 P. xxxxxxxx 2 India at a hotel room, who would pay for 3 the room? 4 A He would pay for it. 5 Q Would he use cash or a credit 6 card? 7 A I have no idea. 8 Q You weren't present when he 9 paid? 10 A No. 11 Q Do you have any pictures of him? 12