Preview
FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
EXHIBIT "K"
FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
ORIGINAL
. 50-H HEARING
- - - - - - - - - - - - - - - x
In the Matter of the Claim of
ALICIA M. ARUNDEL,
Claimant,
-against-
THE COUNTY OF SUFFOLK and THE TOWN OF
SOUTHOLD, . .
Respondents.
- - - - - - - - - - - - - - x
100 Veterans Memorial Highway
Hauppauge, New York
December 18, 2015
10:14 a.m.
50-H HEARING of ALICIA M. ARUNDEL, the
Claimant in the above-entitled action, held at
the above time and place, pursuant to Notice,
taken before KATHY J. DROSSEL, a shorthand
reporter and Notary Public within and for the
State of New York.
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
2
1
2 A p p e a r a n c e s:
...
3 THE BONGIORNO LAW FIRM, PLLC
ATTORNEYS for Claimant
4 250 Mineola Boulevard
Mineola, New York 11501
5 BY: BRANDON KRUZ, ESQ.
FILE #: NONE
6
7
SUFFOLK COUNTY ATTORNEY'S OFFICE
8 ATTORNEYS for Respondent
THE COUNTY OF SUFFOLK
9 100 Veterans Memorial Highway
Sixth Floor
10 Hauppauge, New York 11788
BY: CHRISTOPHER A. JEFFREYS, ESQ.
11 FILE #: NONE
12
13
14
15
16
17
18
19
20
21
22
23
24
25
FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
3
1 Alicia M. Arundel
2 A L I C I A M. A R U N D E L, the witness
3 herein, having been first duly sworn by a
4 Notary Public of the State of New York, was
5 examined and testified as follows:
6 EXAMINATION BY
7 MR. JEFFREYS:
. 8 Q. State your name for the record,
9 please.
10 A. Alicia Arundel.
11 Q. State your address for the record,
12 please.
13 A. 248 Erin Lane, Setauket, New York
14 11733.
15 MR. JEFFREYS: Please mark the
16 Notice of Claim as Respondent's
17 Exhibit A for identification.
18 (Whereupon, a 10-page Notice of
19 Clam was marked as Respondent's
20 Exhibit A, for identification, as of
21 this date.)
22 MR. JEFFREYS: On the record.
23 Q. Good morning, Ms. Arundel. My name
24 is Christopher Jeffreys. I'm an Assistant
25 County Attorney for the County of Suffolk.
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
4
1 Alicia M. Arundel
2 I'm going to be asking you some questions
3 concerning a claim that's been filed on your
4 behalf. If, at any time, you don't
5 understand any of my questions please let me
6 know, and I'll repeat it or rephrase them.
7 It's my obligation to make myself clear to
8 you, so don't answer any of my questions if
9 you don't understand them. If, at any time,
10 during my questioning you want to speak with
11 your attorney please feel free to do so, and
12 if you want me to leave the room, and Kathy,
13 our court reporter, to leave the room, all
14 you have to do is ask.
15 This is not by any means an
16 endurance contest, so if, at any point, you
17 want to take a break, for any reason, all you
18 have to do is ask, and we'll take whatever
19 break you need.
20 The one thing that I do ask is, if
21 there is an open question answer the
22 question, and then we'll take the break,
23 okay?
24 On behalf of our court reporter
25 there are certain things that she simply
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
5
1 Alicia M. Arundel
2 can't do. She is taking down words as we say
3 them. She can't take down nods of the head
4 or a hand gesture. She can't take down
5 things that we take to mean yes or no, like
6 un ha or un un. She can't take down those,
7 because they come out looking like the exact
8 same thing.
9 So, in the event that you do, and we
10 all do it, if you say un ha or un un I'll ask
11 you to say, please, say yes or no, so that
12 Eathy can take that down, okay?
13 A. Okay.
14 Q. Do you understand the brief
15 instructions that I have given to you?
16 A. Yes.
17 Q. Are you taking any medications that
18 would effect your ability to testify?
19 A. No.
20 Q. You feel ùp to giving a little
21 testimony this morning?
22 A. Yes.
23 Q. How long have you resided at 248
24 Erin Lane?
25 A. A little over two years.
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
6
1 Alicia M. Arundel
2 Q. Who do you presently live there
3 with?
4 A. My mother.
5 Q. What's your Mom's name?
6 A. Susan Arundel.
7 Q. Back in July of 2015 was that your
8 address also?
9 A. Yes.
10 Q. Did anybody else live with you back
11 on date of loss?
12 A. No.
13 Q. What is your date of birth?
14 A. May 19th, 1991.
15 Q. I'm going to ask you to provide your
16 Social Security number, but you're going to
17 see it in the transcript. It's going to show
18 up as all "X's". It's going to be nine
19 "X's". Don't write in your Social Security
20 number. Leave it as all nine "X's".
21 A. Okay.
22 Q. What is your Social Security number?
23 A. X-X-X-X-X-X-X-X-X.
24 Q. Are you married?
25 A. No.
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
7 .
1 Alicia M. Arundel
2 Q. Do you have any children?
3 A. No.
4 Q. Have you ever been married?
5 A. Nope.
6 Q. Are you employed outside the house?
7 A. No.
8 Q. Are you a student?
9 A. Yes.
10 Q. Where are you a student?
11 A. CUNY Lehman College.
12 Q. What are you studying there?
13 A. My masters in speech language
14 pathology.
15 Q. When did you start your studies at
16. Lehman College?
17 A. Fall of 2014.
18 Q. If everything goes according to
19 schedule when are you to complete your
20 master's degree?
21 . A. Summer of 2016.
22 Q. Do you have a bachelor's degree?
23 A. I do.
24 Q. Where was that conferred on you?
25 A. SUNY Albany.
FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
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1 Alicia M. Arundel
2 Q. What was your major?
3 A. Sociology.
4 Q. When was that conferred on you?
5 A. May 2013.
6 Q. When did you start at SUNY Albany?
7 A. Fall of 2009.
8 Q. Were you a continuous full-time
9 student from fall of 2009 through May of
10 2013?
11 A. Yes.
12 Q. When you graduated do you remember
13 what your cumulative grade point average was?
14 A. I believe it was a 3.5.
15 Q. How are you doing now in your
16 master's program concerning your cumulative
17 grades?
18 A. I'm at a 3.9.
19 Q. Since your attendance at SUNY Albany
20 have you worked at any location, even
21 part-time?
22 A. Yes.
23 Q. Where have you worked?
24 A. I have worked at a bagel store. I
25 have babysat. I have worked at a handicap
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
9
1 Alicia M. Arundel
2 camp. I worked at a grocery store. That's
3 about it.
4 Q. Are you working at any of those
5 locations now while you're pursuing your
6 master's degree?
7 A. Not now.
8 Q. When did you work at the bagel store
9 if you remember the year?
10 A. I have worked there since I was 16,
11 on and off, until about two years ago.
12 Q. What about babysitting, do you work
13 for particular families, or is it from
14 referrals from friends and families who call?
15 A. Different families. I've done that
16 throughout college and throughout this past
17 year, previously.
18 Q. Do you still do that when the
19 opportunity arises?
20 A. Not anymore.
21 Q. -When is the last time that you
22 babysat?
23 A. Up until the accident a couple of
24 days before that.
25 Q. So, that would be somewhere around
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
10
1 Alicia M. Arundel
2 July of 2015 is the last time that you
3 babysat?
4 A. Yes.
5 Q. .When you worked for the handicapped
6 camp were you a camp counselor or something
7 else?
8 A. A camp counselor.
9 Q. When did you do that?
10 A. I did it in the summer, I'll say
11 2014 to the summer of, I'm sorry, I think I
12 was there from 2013 up until the 2014 summer.
13 Q. Which camp did you work at?
14 A. It's a Town of Oyster Bay Group
15 Activities Program Handicap Camp.
16 Q. Is that a private organization, or
17 is that town run?
18 A. It's town run.
19 Q. So, when you were working for the
20 handicapped camp you were a Town of Oyster
21 Bay employee?
22 A. Yes.
23 Q. What did you do at the grocery
24 store?
25 A. I was a cashier.
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
11
1 Alicia M. Arundel
2 Q. When did you do that?
3 A. I did it for about two months. The
4 spring semester, this past spring semester.
5 Q. Spring _of 2015?
6 A. Yes.
7 Q. Is that full time or part-time?
8 A. Part-time.
9 Q. Do you remember what your rate of
10 pay was?
11 A. I don't remember.
12 Q. Did you leave because of the
13 accident or something else?
7
14 A. For something else.
15 Q. What was the reason that you left?
16 A. I got busy with school.
17 Q. Now, as you're attending Lehman
18 College do you live at 248 Erin Lane, or do
19 you live somewhere else?
20 A. 248 Erin Lane.
21 Q. So, you're a commuter. student?
22 A. Yes.
23 Q. And to go back and forth to school
24 do you drive, take the train, or something
25 else?
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
12
1 Alicia M. Arundel
2 A. I drive.
3 Q. How often are your classes?
4 A. Four classes.
5 Q. What is your schedule?
6 A. The fall semester was Monday through
7 Thursday.
8 Q. How many classes do you take in the
9 master's program for the fall semester?
10 A. Four or five classes.
11 Q. Have you gotten your grades back
12 yet?
13 A. Not yet.
14 Q. Do you think you did okay?
15 A. I think so.
16 Q. Now, back in July of 2015 were you
17 enrolled as a full-time student in the CUNY
18 program?
19 A. I was a student taking one class
20 over the summer.
21 Q. So, it was a summer semester?.
22 A. Yes.
23 Q. Were you enrolled in the spring of
24 the 2015 semester?
25 A. Yes.
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
13
1 Alicia M. Arundel
2 Q. Did you complete all of those
3 classes?
4 A. Yes.
5 Q^. Did you get grades in all of the
6 classes without having to withdraw from any
7 of them?
8 A. Yes.
9 Q. The summer class that you took what
10 class was that?
11 A. I took one each summer session,
12 there were two summer sessions.
13 Q. How did the summer session work at
14 Lehman College?
15 A. The first summer session was the
16 month of June, and the second summer sessi.on
17 was the month of July into a little bit of
18 August.
19 Q. What did you take in June; do you
20 remember?
21 A. It was called Voice Disorders.
22 Q. Did you pass that class?
23 A. Yes.
24 Q. What did you take for the second
. .
25 section?
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
14
1 Alicia M. Arundel
2 A. AAC.
3 Q. What's that?
4 A. Assistive Augmentative
5 Communication.
6 Q. I don't know what that is. What is
7 AAC?
8 A. It's like Steven Hawkins uses an ACC
9 device to let him speak, or there are many
10 varieties with that.
11 Q. Did you complete the second summer
12 session class?
13 A. I did.
14 Q. Did you get a grade in that?
15 A. I did.
16 Q. Did the accident happen before or
17 after you finished your second summer class?
18 A. Before.
19 Q. Did you miss any time from the
20 second summer session class from the
21 accident?
22 A. Yes, I missed a-lot of time.
23 Q. How many days did you miss,
24 approximately?
25 A. I missed at least half the class.. I
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
15
1 Alicia M. Arundel
2 only went the first half.
3 Q. If you know, was any part of your
4 grade in your second summer session class
5 based on your classroom attendance?
6 A. No.
7 Q. What was your grade in that class;
8 if you can remember?
9 A. I believe I got an A minus.
10 Q. After the accident occurred --
11 withdrawn.
12 Were you involved in an accident on
13 July 18th, 2015?
14 A. Yes.
15 Q. After that accident occurred did you
16 attend any of the classes that you had at
17 Lehman College in the summer session?.
18 A. No.
19 Q. So, in order to finish your class
20 schedule for your second summer session
21 class, what activities or reports did you
22 have to do to finish your class schedule?
23 A. They allotted me extra time ,t
24 complete a final project and final exam.
25 Q. What was your final project?
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
16
1 Alicia M. Arundel
2 A. We had to design an AAC device.
3 Q. What type of device did you make?
4 A. It was a type of Ap for an iPad.
5 Q. Did you have to do that from scratch
6 all on your or did they- have certain
own,
7 computer folks who worked with you on that?
8 A. It was a group project, and my
9 classmates took the brunt of doing the work.
10 Q. You also had to take a final exam?
11 A. Yes.
12 Q. Did you do that at the school online
13 at home or somewhere else?
14 A. At home online.
15 Q. Is that how all the tests were
16 given, or was a special exception made for
17 you in that class?
18 A. It was a special exception.
19 Q. How did you do on the final exam; if
20 you remember?
21 A. I believe I did pretty well, maybe
22 an A minus.
23 Q. Was that examination multiple
24 choice, essay, or something else?
25 A. Essay.
FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022
17
1 Alicia M. Arundel
2 Q. So, in order to do that test did you
3 have to type your essay responses into a
4 computer and send them through the Internet
5 somewhere?
6 A. I had to type it up, but I
Preview
FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 EXHIBIT "K" FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 ORIGINAL . 50-H HEARING - - - - - - - - - - - - - - - x In the Matter of the Claim of ALICIA M. ARUNDEL, Claimant, -against- THE COUNTY OF SUFFOLK and THE TOWN OF SOUTHOLD, . . Respondents. - - - - - - - - - - - - - - x 100 Veterans Memorial Highway Hauppauge, New York December 18, 2015 10:14 a.m. 50-H HEARING of ALICIA M. ARUNDEL, the Claimant in the above-entitled action, held at the above time and place, pursuant to Notice, taken before KATHY J. DROSSEL, a shorthand reporter and Notary Public within and for the State of New York. ¬" m" n ----H-- T-n __ 2..i,- e4-.. es .,, , MowYnrk. NY 1onRS PhonG:631.224,5054 Fax 631.224.3926 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 2 1 2 A p p e a r a n c e s: ... 3 THE BONGIORNO LAW FIRM, PLLC ATTORNEYS for Claimant 4 250 Mineola Boulevard Mineola, New York 11501 5 BY: BRANDON KRUZ, ESQ. FILE #: NONE 6 7 SUFFOLK COUNTY ATTORNEY'S OFFICE 8 ATTORNEYS for Respondent THE COUNTY OF SUFFOLK 9 100 Veterans Memorial Highway Sixth Floor 10 Hauppauge, New York 11788 BY: CHRISTOPHER A. JEFFREYS, ESQ. 11 FILE #: NONE 12 13 14 15 16 17 18 19 20 21 22 23 24 25 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 3 1 Alicia M. Arundel 2 A L I C I A M. A R U N D E L, the witness 3 herein, having been first duly sworn by a 4 Notary Public of the State of New York, was 5 examined and testified as follows: 6 EXAMINATION BY 7 MR. JEFFREYS: . 8 Q. State your name for the record, 9 please. 10 A. Alicia Arundel. 11 Q. State your address for the record, 12 please. 13 A. 248 Erin Lane, Setauket, New York 14 11733. 15 MR. JEFFREYS: Please mark the 16 Notice of Claim as Respondent's 17 Exhibit A for identification. 18 (Whereupon, a 10-page Notice of 19 Clam was marked as Respondent's 20 Exhibit A, for identification, as of 21 this date.) 22 MR. JEFFREYS: On the record. 23 Q. Good morning, Ms. Arundel. My name 24 is Christopher Jeffreys. I'm an Assistant 25 County Attorney for the County of Suffolk. "' * - - -- n T ,,,. , . g,, ,,,, ,,, Nav York. NY scoa8 Fax631.224.3926 Phone:63).224.5054 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 4 1 Alicia M. Arundel 2 I'm going to be asking you some questions 3 concerning a claim that's been filed on your 4 behalf. If, at any time, you don't 5 understand any of my questions please let me 6 know, and I'll repeat it or rephrase them. 7 It's my obligation to make myself clear to 8 you, so don't answer any of my questions if 9 you don't understand them. If, at any time, 10 during my questioning you want to speak with 11 your attorney please feel free to do so, and 12 if you want me to leave the room, and Kathy, 13 our court reporter, to leave the room, all 14 you have to do is ask. 15 This is not by any means an 16 endurance contest, so if, at any point, you 17 want to take a break, for any reason, all you 18 have to do is ask, and we'll take whatever 19 break you need. 20 The one thing that I do ask is, if 21 there is an open question answer the 22 question, and then we'll take the break, 23 okay? 24 On behalf of our court reporter 25 there are certain things that she simply ¬" ---n- A. m ...K,,e,,..,, _e,,, ,,,, *w vark. NY 10028 Fax 63t224.3926 Phone: 633.224.5°54 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 5 1 Alicia M. Arundel 2 can't do. She is taking down words as we say 3 them. She can't take down nods of the head 4 or a hand gesture. She can't take down 5 things that we take to mean yes or no, like 6 un ha or un un. She can't take down those, 7 because they come out looking like the exact 8 same thing. 9 So, in the event that you do, and we 10 all do it, if you say un ha or un un I'll ask 11 you to say, please, say yes or no, so that 12 Eathy can take that down, okay? 13 A. Okay. 14 Q. Do you understand the brief 15 instructions that I have given to you? 16 A. Yes. 17 Q. Are you taking any medications that 18 would effect your ability to testify? 19 A. No. 20 Q. You feel ùp to giving a little 21 testimony this morning? 22 A. Yes. 23 Q. How long have you resided at 248 24 Erin Lane? 25 A. A little over two years. ¬" m . .- n -- -2.-- T-.. __ ,-n ,,,,_, _ n,,, ,,,,w vmt NY 1an28 Phone: 631.m.so54Fax 631.224.3926 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 6 1 Alicia M. Arundel 2 Q. Who do you presently live there 3 with? 4 A. My mother. 5 Q. What's your Mom's name? 6 A. Susan Arundel. 7 Q. Back in July of 2015 was that your 8 address also? 9 A. Yes. 10 Q. Did anybody else live with you back 11 on date of loss? 12 A. No. 13 Q. What is your date of birth? 14 A. May 19th, 1991. 15 Q. I'm going to ask you to provide your 16 Social Security number, but you're going to 17 see it in the transcript. It's going to show 18 up as all "X's". It's going to be nine 19 "X's". Don't write in your Social Security 20 number. Leave it as all nine "X's". 21 A. Okay. 22 Q. What is your Social Security number? 23 A. X-X-X-X-X-X-X-X-X. 24 Q. Are you married? 25 A. No. "^ C+ar DemarHn rr Tne an.1nJn RIract - Ste. 42: New York, NY 19038 Fax 633.224.3926 Phone: 631.224·5054 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 7 . 1 Alicia M. Arundel 2 Q. Do you have any children? 3 A. No. 4 Q. Have you ever been married? 5 A. Nope. 6 Q. Are you employed outside the house? 7 A. No. 8 Q. Are you a student? 9 A. Yes. 10 Q. Where are you a student? 11 A. CUNY Lehman College. 12 Q. What are you studying there? 13 A. My masters in speech language 14 pathology. 15 Q. When did you start your studies at 16. Lehman College? 17 A. Fall of 2014. 18 Q. If everything goes according to 19 schedule when are you to complete your 20 master's degree? 21 . A. Summer of 2016. 22 Q. Do you have a bachelor's degree? 23 A. I do. 24 Q. Where was that conferred on you? 25 A. SUNY Albany. FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 8 1 Alicia M. Arundel 2 Q. What was your major? 3 A. Sociology. 4 Q. When was that conferred on you? 5 A. May 2013. 6 Q. When did you start at SUNY Albany? 7 A. Fall of 2009. 8 Q. Were you a continuous full-time 9 student from fall of 2009 through May of 10 2013? 11 A. Yes. 12 Q. When you graduated do you remember 13 what your cumulative grade point average was? 14 A. I believe it was a 3.5. 15 Q. How are you doing now in your 16 master's program concerning your cumulative 17 grades? 18 A. I'm at a 3.9. 19 Q. Since your attendance at SUNY Albany 20 have you worked at any location, even 21 part-time? 22 A. Yes. 23 Q. Where have you worked? 24 A. I have worked at a bagel store. I 25 have babysat. I have worked at a handicap T-- - - -t- ----'h-- m hia= vark NY inn28 Phone: 631.224.5054 Fax 631.224.3926 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 9 1 Alicia M. Arundel 2 camp. I worked at a grocery store. That's 3 about it. 4 Q. Are you working at any of those 5 locations now while you're pursuing your 6 master's degree? 7 A. Not now. 8 Q. When did you work at the bagel store 9 if you remember the year? 10 A. I have worked there since I was 16, 11 on and off, until about two years ago. 12 Q. What about babysitting, do you work 13 for particular families, or is it from 14 referrals from friends and families who call? 15 A. Different families. I've done that 16 throughout college and throughout this past 17 year, previously. 18 Q. Do you still do that when the 19 opportunity arises? 20 A. Not anymore. 21 Q. -When is the last time that you 22 babysat? 23 A. Up until the accident a couple of 24 days before that. 25 Q. So, that would be somewhere around m-.-- n n -w- un - ia""" C'-' - at'" d'"Naw Varki'Y inom8 Fox 631.224.3926 Pholic: 63i.224.5o54 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 10 1 Alicia M. Arundel 2 July of 2015 is the last time that you 3 babysat? 4 A. Yes. 5 Q. .When you worked for the handicapped 6 camp were you a camp counselor or something 7 else? 8 A. A camp counselor. 9 Q. When did you do that? 10 A. I did it in the summer, I'll say 11 2014 to the summer of, I'm sorry, I think I 12 was there from 2013 up until the 2014 summer. 13 Q. Which camp did you work at? 14 A. It's a Town of Oyster Bay Group 15 Activities Program Handicap Camp. 16 Q. Is that a private organization, or 17 is that town run? 18 A. It's town run. 19 Q. So, when you were working for the 20 handicapped camp you were a Town of Oyster 21 Bay employee? 22 A. Yes. 23 Q. What did you do at the grocery 24 store? 25 A. I was a cashier. -- =" * ..u-tru - - -.,o himu m./ n, ae4 anca F.u 6ua24.2026 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 11 1 Alicia M. Arundel 2 Q. When did you do that? 3 A. I did it for about two months. The 4 spring semester, this past spring semester. 5 Q. Spring _of 2015? 6 A. Yes. 7 Q. Is that full time or part-time? 8 A. Part-time. 9 Q. Do you remember what your rate of 10 pay was? 11 A. I don't remember. 12 Q. Did you leave because of the 13 accident or something else? 7 14 A. For something else. 15 Q. What was the reason that you left? 16 A. I got busy with school. 17 Q. Now, as you're attending Lehman 18 College do you live at 248 Erin Lane, or do 19 you live somewhere else? 20 A. 248 Erin Lane. 21 Q. So, you're a commuter. student? 22 A. Yes. 23 Q. And to go back and forth to school 24 do you drive, take the train, or something 25 else? "' T-. - . -..-. n......u-.,v..,L axy,an,a Phmm:6ttasa aos4 Fax 63 2.224.3926 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 12 1 Alicia M. Arundel 2 A. I drive. 3 Q. How often are your classes? 4 A. Four classes. 5 Q. What is your schedule? 6 A. The fall semester was Monday through 7 Thursday. 8 Q. How many classes do you take in the 9 master's program for the fall semester? 10 A. Four or five classes. 11 Q. Have you gotten your grades back 12 yet? 13 A. Not yet. 14 Q. Do you think you did okay? 15 A. I think so. 16 Q. Now, back in July of 2015 were you 17 enrolled as a full-time student in the CUNY 18 program? 19 A. I was a student taking one class 20 over the summer. 21 Q. So, it was a summer semester?. 22 A. Yes. 23 Q. Were you enrolled in the spring of 24 the 2015 semester? 25 A. Yes. h 0v D cmenene Tn t' no John Sircet - Ste. 41s New York, NY noo38 Phone: 63L1sq.5054Fax 632.224.3926 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 13 1 Alicia M. Arundel 2 Q. Did you complete all of those 3 classes? 4 A. Yes. 5 Q^. Did you get grades in all of the 6 classes without having to withdraw from any 7 of them? 8 A. Yes. 9 Q. The summer class that you took what 10 class was that? 11 A. I took one each summer session, 12 there were two summer sessions. 13 Q. How did the summer session work at 14 Lehman College? 15 A. The first summer session was the 16 month of June, and the second summer sessi.on 17 was the month of July into a little bit of 18 August. 19 Q. What did you take in June; do you 20 remember? 21 A. It was called Voice Disorders. 22 Q. Did you pass that class? 23 A. Yes. 24 Q. What did you take for the second . . 25 section? . Abh simM - ste. asi MewYork. NY too38Phone: 631.224-5054 Fax 631.224-3926 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 14 1 Alicia M. Arundel 2 A. AAC. 3 Q. What's that? 4 A. Assistive Augmentative 5 Communication. 6 Q. I don't know what that is. What is 7 AAC? 8 A. It's like Steven Hawkins uses an ACC 9 device to let him speak, or there are many 10 varieties with that. 11 Q. Did you complete the second summer 12 session class? 13 A. I did. 14 Q. Did you get a grade in that? 15 A. I did. 16 Q. Did the accident happen before or 17 after you finished your second summer class? 18 A. Before. 19 Q. Did you miss any time from the 20 second summer session class from the 21 accident? 22 A. Yes, I missed a-lot of time. 23 Q. How many days did you miss, 24 approximately? 25 A. I missed at least half the class.. I ..... n - -.a. . Twn -- :-sin unt_sm. an New York, NY 10038Phalte: 631.224.5054 Far 633.224.3926 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 15 1 Alicia M. Arundel 2 only went the first half. 3 Q. If you know, was any part of your 4 grade in your second summer session class 5 based on your classroom attendance? 6 A. No. 7 Q. What was your grade in that class; 8 if you can remember? 9 A. I believe I got an A minus. 10 Q. After the accident occurred -- 11 withdrawn. 12 Were you involved in an accident on 13 July 18th, 2015? 14 A. Yes. 15 Q. After that accident occurred did you 16 attend any of the classes that you had at 17 Lehman College in the summer session?. 18 A. No. 19 Q. So, in order to finish your class 20 schedule for your second summer session 21 class, what activities or reports did you 22 have to do to finish your class schedule? 23 A. They allotted me extra time ,t 24 complete a final project and final exam. 25 Q. What was your final project? --T-5-- ===&- Qin at a $pwYork. NY I0038 Fax 631.224.3926 Phone: 63t-224-5054 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 16 1 Alicia M. Arundel 2 A. We had to design an AAC device. 3 Q. What type of device did you make? 4 A. It was a type of Ap for an iPad. 5 Q. Did you have to do that from scratch 6 all on your or did they- have certain own, 7 computer folks who worked with you on that? 8 A. It was a group project, and my 9 classmates took the brunt of doing the work. 10 Q. You also had to take a final exam? 11 A. Yes. 12 Q. Did you do that at the school online 13 at home or somewhere else? 14 A. At home online. 15 Q. Is that how all the tests were 16 given, or was a special exception made for 17 you in that class? 18 A. It was a special exception. 19 Q. How did you do on the final exam; if 20 you remember? 21 A. I believe I did pretty well, maybe 22 an A minus. 23 Q. Was that examination multiple 24 choice, essay, or something else? 25 A. Essay. FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 962 RECEIVED NYSCEF: 09/02/2022 17 1 Alicia M. Arundel 2 Q. So, in order to do that test did you 3 have to type your essay responses into a 4 computer and send them through the Internet 5 somewhere? 6 A. I had to type it up, but I