Preview
FILED: NEW YORK COUNTY CLERK 07/16/2021
08/06/2020 09:58
02:38 AM
PM INDEX NO. 805302/2015
NYSCEF DOC. NO. 164
121 RECEIVED NYSCEF: 07/16/2021
08/06/2020
October 18, 2017DOUGLAS & LONDON, P.C.
Attorneys At Law
6th
59 Maiden Lane, FlOOr
New York, N.Y. 10038
(212) 566-7500
FAX: (212) 566-7501
www.DOUGLASANDLONDON.com
Gary J. Douglas
MichaelA. London*
Stephanie O'Connor*
Virginia E. Anallo^
Randolph D. Janis
Rebecca G. Newman*
KrladnD. Padden'
Robin J. Bond"
I.ara J. Say*•
Michael D. SharpF
Alicia P. Ellsayed*
*Also admilted in NJ
AAlsoadmitted In LA
'Admitted In NJ only
•Also admitted in NC
5Of Counsel
Shellyann Hoffman
45 Jackson Street, Apt 2C
New York, NY 10002
Re: Hoffman, Shellyann v. New York Presbyterian
Dear Ms. Hoffman,
Enclosed please find the original transcript of your examination before trial. Please read the transcript
carefully and, if you wish, make any corrections on the enclosed separate correction sheet. Both the transcript and
any correction sheets must be signed by you before a notary public.
Kindly return the signed transcript and any corrections to this office at your earliest convenience.
Thank you for your cooperation. If youhave any questions or concerns, please do not hesitate to contact me.
Very truly yours,
nid O a
RDJ/eo
Enclosures [2]
FILED: NEW YORK COUNTY CLERK 07/16/2021
08/06/2020 09:58
02:38 AM
PM INDEX NO. 805302/2015
NYSCEF DOC. NO. 164
121 RECEIVED NYSCEF: 07/16/2021
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1
ORIGINAL
1
2 SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
3 ------------------------------------------X
SHELLYANN HOFFMAN and OLUJIMI JOLAOSHO,
4
PLAINTIFFS,
5
-against- Index No.:
6 805302/15
7 DEBRA TAUBEL, M. D. , TIRSIT ASFAW, M. D. ,
DMITRY YOUSHKD, M.D., MEGAN KNASNIAK, M.D.,
8 LARISSA STATHAKES, P.A., BROOKLYN HOSPITAL
and NEW YORK PRESBYTERIAN HOSPITAL,
9
DEFENDANTS.
10 ------------------------------------------X
11
12 DATE: August 25, 2017
13 TIME: 10:18 a.m.
14
15 EXAMINATION BEFORE TRIAL of the
16 Plaintiff SHELLYANN HOFFMAN, taken by the
17 Defendants, held at the offices of Douglas
18 & London, P.C., 59 Maiden Lane, New York,
19 New York 10038, before Linda Devecka, a
20 Notary Public of the State of New York.
21
22
23
24
25
DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com
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FILED: NEW YORK COUNTY CLERK 07/16/2021
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PM INDEX NO. 805302/2015
NYSCEF DOC. NO. 164
121 RECEIVED NYSCEF: 07/16/2021
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2
1
2 A P P E A R A N C E S:
3
4 DOUGLAS & LONDON, P.C.
Attorneys for the Plaintiffs
5 SHELLYANN HOFFMAN and OLUJIMI JOLAOSHO
59 Maiden Lane, 6th Floor
6 New York, New York 10038
BY: MICHAEL D. SHARP, ESQ.
7
8
AARONSON RAPPAPORT
9 FEINSTEIN & DEUTSCH, LLP
Attorneys for the Defendants
10 DEBRA TAUBEL, M.D., TIRSIT ASFAW, M.D.
and NEW YORK PRESBYTERIAN HOSPITAL
11 600 Third Avenue, 5th Floor
New York, New York 10016
12 BY: KEVIN J. DENARO, ESQ.
-and-
13 JACOB E. LEWIN, ESQ.
File #: 270.072
14
15
GARSON & JAKUB, LLP
16 Attorneys for the Defendant
DMITRY YOUSHKO, M.D.
17 14 Wall Street
New York, New York 10005
18 BY: MARIA S. HRISTOVA, ESQ.
19
20 KAUFMAN BORGEEST & RYAN LLP
Attorneys for the Defendants
21 LARISSA STATHAKES, P.A. and BROOKLYN
HOSPITAL
22 200 Summit Lake Drive
Valhalla, New York 10595
23 BY: KENNETH BEAUZILE, ESQ.
File #: 766.098
24
* * *
25
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2
FILED: NEW YORK COUNTY CLERK 07/16/2021
08/06/2020 09:58
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PM INDEX NO. 805302/2015
NYSCEF DOC. NO. 164
121 RECEIVED NYSCEF: 07/16/2021
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3
1
2 221. UNIFORM RULES FOR THE
CONDUCT OF DEPOSITIONS
3 221.1 Objections at Depositions
(a) Objections in general. No objections
4 shall be made at a deposition except those
which, pursuant to subdivision (b), (c) or
5 (d) of Rule 3115 of the Civil Practice Law
and Rules, would be waived if not
6 interposed, and except in compliance with
subdivision (e) of such rule. All
7 objections made at a deposition shall be
noted by the officer before whom the
8 deposition is taken, and the answer shall
be given and the deposition shall proceed
9 subject to the objections and to the right
of a person to apply for appropriate relief
10 pursuant to Article 31 of the CPLR.
(b) Speaking objections restricted. Every
11 objection raised during a deposition shall
be stated succinctly and framed so as not
12 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
15 rule, during the course of the examination
persons in attendance shall not make
16 statements or comments that interfere with
the questioning.
17 221.2 Refusal to answer when objection is
made. A deponent shall answer all questions
18 at a deposition, except (i) to preserve a
privilege or right of confidentiality, (ii)
19 to enforce a limitation set forth in an
order of the court, or (iii) when the
20 question is plainly improper and would, if
answered, cause significant prejudice to
21 any person. An attorney shall not direct
a deponent not to answer except as provided
22 in CPLR Rule 3115 or this subdivision.
Any refusal to answer or direction not to
23 answer shall be accompanied by a succinct
and clear statement of the basis therefor.
24 If the deponent does not answer a question,
the examining party shall have the right to
25 complete the remainder of the deposition.
DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com
3
FILED: NEW YORK COUNTY CLERK 07/16/2021
08/06/2020 09:58
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PM INDEX NO. 805302/2015
NYSCEF DOC. NO. 164
121 RECEIVED NYSCEF: 07/16/2021
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4
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
6 the purpose of determining whether the
question should not be answered on the
7 grounds set forth in section 221.2 of these
rules and, in such event, the reason for
8 the communication shall be stated for the
record succinctly and clearly.
9
10 IT IS FURTHER STIPULATED AND AGREED
that the transcript may be signed before
11 any Notary Public with the same force and
effect as if signed before a clerk or a
12 Judge of the court.
13
IT IS FURTHER STIPULATED AND AGREED
14 that the examination before trial may be
utilized for all purposes as provided by
15 the CPLR.
16
IT IS FURTHER STIPULATED AND AGREED
17 that all rights provided to all parties by
the CPLR cannot be deemed waived and the
18 appropriate sections of the CPLR shall be
controlling with respect hereto.
19
20 IS IT FURTHER STIPULATED AND AGREED
by and between the attorneys for the
21 respective parties hereto that a copy of
this examination shall be furnished,
22 without charge, to the attorneys
representing the witness testifying herein.
23
24
25
DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com
4
FILED: NEW YORK COUNTY CLERK 07/16/2021
08/06/2020 09:58
02:38 AM
PM INDEX NO. 805302/2015
NYSCEF DOC. NO. 164
121 RECEIVED NYSCEF: 07/16/2021
08/06/2020
5
1 S. HOFFMAN
2 S H E L L Y A N N H O F F M A N, called
3 as a witness, having been first duly sworn
4 by a Notary Public of the State of New
5 York, was examined and testified as
6 follows:
7 EXAMINATION BY
8 MR. DENARO:
9 Q. Please state your name for the
10 record.
11 A. Shellyann Hoffman.
12 Q. What is your address?
13 A. 45 Jackson Street, Apartment
14 2-C, New York, New York 10002.
15 Q. Good morning, Ms. Hoffman. My
16 name is Kevin Denaro. I'm with the law
17 firm Aaronson Rappaport Feinstein &
18 Deutsch. My firm represents Dr. Taubel,
19 Dr. Asfaw and New York Presbyterian
20 Hospital in this case today.
21 Today I am going to ask you a
22 series of questions regarding your medical
23 history and your medical treatment as it
24 relates to this case. If at any time you
25 don't understand one of my questions,
DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com
5
FILED: NEW YORK COUNTY CLERK 07/16/2021
08/06/2020 09:58
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PM INDEX NO. 805302/2015
NYSCEF DOC. NO. 164
121 RECEIVED NYSCEF: 07/16/2021
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6
1 S. HOFFMAN
2 please let me know and I will do my best to
3 rephrase it. If you do answer the
4 question, I am going to assume that you
5 understood it.
6 Okay?
7 A. Okay.
8 Q. Also, sometimes it will seem
9 like we are having a conversation and you
10 can anticipate what I am going to ask you,
11 but it's important for the court reporter
12 and for us that you let me complete my
13 question first and then give your response.
14 Okay?
15 A. Okay.
16 Q. Also, you can take a break at
17 any time. That's not a problem. I just
18 ask that if there's a question pending,
19 that you answer the question first and then
20 you can take a break.
21 Okay?
22 A. Okay.
23 Q. Have you ever been to a
24 deposition before?
25 A. No.
DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com
6
FILED: NEW YORK COUNTY CLERK 07/16/2021
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PM INDEX NO. 805302/2015
NYSCEF DOC. NO. 164
121 RECEIVED NYSCEF: 07/16/2021
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7
1 S. HOFFMAN
2 Q. Have you ever been a party to
3 any other lawsuit?
4 A. No.
5 Q. Did you review any materials
6 today for this deposition, any medical
7 records, anything like that?
8 A. No.
9 Q. Have you taken any medications
10 today that would in any way affect your
11 ability to testify truthfully?
12 A. No.
13 Q. Have you taken any medications
14 today?
15 A. No.
16 Q. What is your date of birth?
17 A. December 20th, 1976.
18 Q. Where were you born?
19 A. Jamaica, West Indies.
20 Q. What year did you come to the
21 United States?
22 A. 1987.
23 Q. Are you currently a United
24 States citizen?
25 A. Yes, I am.
DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com
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FILED: NEW YORK COUNTY CLERK 07/16/2021
08/06/2020 09:58
02:38 AM
PM INDEX NO. 805302/2015
NYSCEF DOC. NO. 164
121 RECEIVED NYSCEF: 07/16/2021
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8
1 S. HOFFMAN
2 Q. What year did you become a
3 citizen?
4 A. 2002.
5 Q. How long have you resided at
6 the 45 Jackson Street address?
7 A. About three years.
8 Q. Were you living there in 2014?
9 A. Yes.
10 Q. Prior to the 45 Jackson Street
11 address, where did you live?
12 A. 32 Jackson Street.
13 Q. Apartment number?
14 A. Apartment 2-E.
15 Q. How long did you reside there?
16 A. Around two years.
17 Q. In 2014, who lived with you at
18 the 45 Jackson Street address?
19 A. My husband and my two boys,
20 Q. The Jackson Street address, is
21 it an apartment building?
22 A. Yes, it is.
23 Q. Is there an elevator in the
24 building?
25 A. Yes, there is.
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FILED: NEW YORK COUNTY CLERK 07/16/2021
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NYSCEF DOC. NO. 164
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1 S. HOFFMAN
2 Q. Are there any steps leading
3 into the apartment building?
4 A. Yes.
5 Q. How many steps?
6 A. I don't know.
7 Q. More than five?
8 A. Yes.
9 Q. What is your husband's name?
10 A. Olujimi Jolaosho.
11 Q. Can you spell that?
12 A. O-1-u-j-i-m-i.
13 MR. SHARP: I need to take this
14 call. I am sorry. It will just take
15 a second.
16 (Whereupon, a short recess was
17 taken.)
18 BY MR. DENARO:
19 Q. And his last name?
20 A. Is Jolaosho, J-o-1-a-o-s-h-o.
21 Q. When were you and your husband
22 married?
23 A. In 2013. December 14, 2013.
24 Q. Do you have any prior
25 marriages?
DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com
9
FILED: NEW YORK COUNTY CLERK 07/16/2021
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NYSCEF DOC. NO. 164
121 RECEIVED NYSCEF: 07/16/2021
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10
1 S. HOFFMAN
2 A. No.
3 Q. You mentioned you have two
4 sons.
5 How many children in total do
6 you have?
7 A. I have three.
8 Q. What are their names?
9 A. The first one, her name is
10 Shaquaia DeRiggs.
11 Q. How do you spell that?
12 A. S-h-a-q-u-a-i-a.
13 Q. Her last name?
14 A. DeRiggs, D-e-R-i-g-g-s.
15 Q. How old is your daughter?
16 A. She is 23.
17 Q. Where does she live?
18 A. She lives in Long Island right
19 now.
20 Q. Do you know her address?
21 A. No.
22 Q. Do you know what town on Long
23 Island?
24 A. Baldwin.
25 Q. Is she married?
DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com
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FILED: NEW YORK COUNTY CLERK 07/16/2021
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NYSCEF DOC. NO. 164
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1 S. HOFFMAN
2 A. No.
3 Q. Who is your next child?
4 A. Elijah Austin.
5 Q. How old is Elijah?
6 A. He is 17.
7 Q. He currently lives with you?
8 A. Yes.
9 Q. Your other son's name?
10 A. Marsul.
11 Q. How do you spell that?
12 A. M-a-r-s-u-1.
13 Q. Same last name?
14 A. H-o-y-t-e.
15 Q. How old is Marsul?
16 A. He is 10.
17 Q. He also lives with you?
18 A. Yes.
19 Q. Do you have any other children?
20 A. No.
21 Q. Do you have any children with
22 your husband?
23 A. No.
24 Q. What is your highest level of
25 education?
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11
FILED: NEW YOR
Preview
FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 October 18, 2017DOUGLAS & LONDON, P.C. Attorneys At Law 6th 59 Maiden Lane, FlOOr New York, N.Y. 10038 (212) 566-7500 FAX: (212) 566-7501 www.DOUGLASANDLONDON.com Gary J. Douglas MichaelA. London* Stephanie O'Connor* Virginia E. Anallo^ Randolph D. Janis Rebecca G. Newman* KrladnD. Padden' Robin J. Bond" I.ara J. Say*• Michael D. SharpF Alicia P. Ellsayed* *Also admilted in NJ AAlsoadmitted In LA 'Admitted In NJ only •Also admitted in NC 5Of Counsel Shellyann Hoffman 45 Jackson Street, Apt 2C New York, NY 10002 Re: Hoffman, Shellyann v. New York Presbyterian Dear Ms. Hoffman, Enclosed please find the original transcript of your examination before trial. Please read the transcript carefully and, if you wish, make any corrections on the enclosed separate correction sheet. Both the transcript and any correction sheets must be signed by you before a notary public. Kindly return the signed transcript and any corrections to this office at your earliest convenience. Thank you for your cooperation. If youhave any questions or concerns, please do not hesitate to contact me. Very truly yours, nid O a RDJ/eo Enclosures [2] FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 1 ORIGINAL 1 2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK 3 ------------------------------------------X SHELLYANN HOFFMAN and OLUJIMI JOLAOSHO, 4 PLAINTIFFS, 5 -against- Index No.: 6 805302/15 7 DEBRA TAUBEL, M. D. , TIRSIT ASFAW, M. D. , DMITRY YOUSHKD, M.D., MEGAN KNASNIAK, M.D., 8 LARISSA STATHAKES, P.A., BROOKLYN HOSPITAL and NEW YORK PRESBYTERIAN HOSPITAL, 9 DEFENDANTS. 10 ------------------------------------------X 11 12 DATE: August 25, 2017 13 TIME: 10:18 a.m. 14 15 EXAMINATION BEFORE TRIAL of the 16 Plaintiff SHELLYANN HOFFMAN, taken by the 17 Defendants, held at the offices of Douglas 18 & London, P.C., 59 Maiden Lane, New York, 19 New York 10038, before Linda Devecka, a 20 Notary Public of the State of New York. 21 22 23 24 25 DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 1 FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 2 1 2 A P P E A R A N C E S: 3 4 DOUGLAS & LONDON, P.C. Attorneys for the Plaintiffs 5 SHELLYANN HOFFMAN and OLUJIMI JOLAOSHO 59 Maiden Lane, 6th Floor 6 New York, New York 10038 BY: MICHAEL D. SHARP, ESQ. 7 8 AARONSON RAPPAPORT 9 FEINSTEIN & DEUTSCH, LLP Attorneys for the Defendants 10 DEBRA TAUBEL, M.D., TIRSIT ASFAW, M.D. and NEW YORK PRESBYTERIAN HOSPITAL 11 600 Third Avenue, 5th Floor New York, New York 10016 12 BY: KEVIN J. DENARO, ESQ. -and- 13 JACOB E. LEWIN, ESQ. File #: 270.072 14 15 GARSON & JAKUB, LLP 16 Attorneys for the Defendant DMITRY YOUSHKO, M.D. 17 14 Wall Street New York, New York 10005 18 BY: MARIA S. HRISTOVA, ESQ. 19 20 KAUFMAN BORGEEST & RYAN LLP Attorneys for the Defendants 21 LARISSA STATHAKES, P.A. and BROOKLYN HOSPITAL 22 200 Summit Lake Drive Valhalla, New York 10595 23 BY: KENNETH BEAUZILE, ESQ. File #: 766.098 24 * * * 25 DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 2 FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 3 1 2 221. UNIFORM RULES FOR THE CONDUCT OF DEPOSITIONS 3 221.1 Objections at Depositions (a) Objections in general. No objections 4 shall be made at a deposition except those which, pursuant to subdivision (b), (c) or 5 (d) of Rule 3115 of the Civil Practice Law and Rules, would be waived if not 6 interposed, and except in compliance with subdivision (e) of such rule. All 7 objections made at a deposition shall be noted by the officer before whom the 8 deposition is taken, and the answer shall be given and the deposition shall proceed 9 subject to the objections and to the right of a person to apply for appropriate relief 10 pursuant to Article 31 of the CPLR. (b) Speaking objections restricted. Every 11 objection raised during a deposition shall be stated succinctly and framed so as not 12 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 15 rule, during the course of the examination persons in attendance shall not make 16 statements or comments that interfere with the questioning. 17 221.2 Refusal to answer when objection is made. A deponent shall answer all questions 18 at a deposition, except (i) to preserve a privilege or right of confidentiality, (ii) 19 to enforce a limitation set forth in an order of the court, or (iii) when the 20 question is plainly improper and would, if answered, cause significant prejudice to 21 any person. An attorney shall not direct a deponent not to answer except as provided 22 in CPLR Rule 3115 or this subdivision. Any refusal to answer or direction not to 23 answer shall be accompanied by a succinct and clear statement of the basis therefor. 24 If the deponent does not answer a question, the examining party shall have the right to 25 complete the remainder of the deposition. DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 3 FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 4 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 6 the purpose of determining whether the question should not be answered on the 7 grounds set forth in section 221.2 of these rules and, in such event, the reason for 8 the communication shall be stated for the record succinctly and clearly. 9 10 IT IS FURTHER STIPULATED AND AGREED that the transcript may be signed before 11 any Notary Public with the same force and effect as if signed before a clerk or a 12 Judge of the court. 13 IT IS FURTHER STIPULATED AND AGREED 14 that the examination before trial may be utilized for all purposes as provided by 15 the CPLR. 16 IT IS FURTHER STIPULATED AND AGREED 17 that all rights provided to all parties by the CPLR cannot be deemed waived and the 18 appropriate sections of the CPLR shall be controlling with respect hereto. 19 20 IS IT FURTHER STIPULATED AND AGREED by and between the attorneys for the 21 respective parties hereto that a copy of this examination shall be furnished, 22 without charge, to the attorneys representing the witness testifying herein. 23 24 25 DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 4 FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 5 1 S. HOFFMAN 2 S H E L L Y A N N H O F F M A N, called 3 as a witness, having been first duly sworn 4 by a Notary Public of the State of New 5 York, was examined and testified as 6 follows: 7 EXAMINATION BY 8 MR. DENARO: 9 Q. Please state your name for the 10 record. 11 A. Shellyann Hoffman. 12 Q. What is your address? 13 A. 45 Jackson Street, Apartment 14 2-C, New York, New York 10002. 15 Q. Good morning, Ms. Hoffman. My 16 name is Kevin Denaro. I'm with the law 17 firm Aaronson Rappaport Feinstein & 18 Deutsch. My firm represents Dr. Taubel, 19 Dr. Asfaw and New York Presbyterian 20 Hospital in this case today. 21 Today I am going to ask you a 22 series of questions regarding your medical 23 history and your medical treatment as it 24 relates to this case. If at any time you 25 don't understand one of my questions, DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 5 FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 6 1 S. HOFFMAN 2 please let me know and I will do my best to 3 rephrase it. If you do answer the 4 question, I am going to assume that you 5 understood it. 6 Okay? 7 A. Okay. 8 Q. Also, sometimes it will seem 9 like we are having a conversation and you 10 can anticipate what I am going to ask you, 11 but it's important for the court reporter 12 and for us that you let me complete my 13 question first and then give your response. 14 Okay? 15 A. Okay. 16 Q. Also, you can take a break at 17 any time. That's not a problem. I just 18 ask that if there's a question pending, 19 that you answer the question first and then 20 you can take a break. 21 Okay? 22 A. Okay. 23 Q. Have you ever been to a 24 deposition before? 25 A. No. DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 6 FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 7 1 S. HOFFMAN 2 Q. Have you ever been a party to 3 any other lawsuit? 4 A. No. 5 Q. Did you review any materials 6 today for this deposition, any medical 7 records, anything like that? 8 A. No. 9 Q. Have you taken any medications 10 today that would in any way affect your 11 ability to testify truthfully? 12 A. No. 13 Q. Have you taken any medications 14 today? 15 A. No. 16 Q. What is your date of birth? 17 A. December 20th, 1976. 18 Q. Where were you born? 19 A. Jamaica, West Indies. 20 Q. What year did you come to the 21 United States? 22 A. 1987. 23 Q. Are you currently a United 24 States citizen? 25 A. Yes, I am. DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 7 FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 8 1 S. HOFFMAN 2 Q. What year did you become a 3 citizen? 4 A. 2002. 5 Q. How long have you resided at 6 the 45 Jackson Street address? 7 A. About three years. 8 Q. Were you living there in 2014? 9 A. Yes. 10 Q. Prior to the 45 Jackson Street 11 address, where did you live? 12 A. 32 Jackson Street. 13 Q. Apartment number? 14 A. Apartment 2-E. 15 Q. How long did you reside there? 16 A. Around two years. 17 Q. In 2014, who lived with you at 18 the 45 Jackson Street address? 19 A. My husband and my two boys, 20 Q. The Jackson Street address, is 21 it an apartment building? 22 A. Yes, it is. 23 Q. Is there an elevator in the 24 building? 25 A. Yes, there is. DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 8 FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 9 1 S. HOFFMAN 2 Q. Are there any steps leading 3 into the apartment building? 4 A. Yes. 5 Q. How many steps? 6 A. I don't know. 7 Q. More than five? 8 A. Yes. 9 Q. What is your husband's name? 10 A. Olujimi Jolaosho. 11 Q. Can you spell that? 12 A. O-1-u-j-i-m-i. 13 MR. SHARP: I need to take this 14 call. I am sorry. It will just take 15 a second. 16 (Whereupon, a short recess was 17 taken.) 18 BY MR. DENARO: 19 Q. And his last name? 20 A. Is Jolaosho, J-o-1-a-o-s-h-o. 21 Q. When were you and your husband 22 married? 23 A. In 2013. December 14, 2013. 24 Q. Do you have any prior 25 marriages? DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 9 FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 10 1 S. HOFFMAN 2 A. No. 3 Q. You mentioned you have two 4 sons. 5 How many children in total do 6 you have? 7 A. I have three. 8 Q. What are their names? 9 A. The first one, her name is 10 Shaquaia DeRiggs. 11 Q. How do you spell that? 12 A. S-h-a-q-u-a-i-a. 13 Q. Her last name? 14 A. DeRiggs, D-e-R-i-g-g-s. 15 Q. How old is your daughter? 16 A. She is 23. 17 Q. Where does she live? 18 A. She lives in Long Island right 19 now. 20 Q. Do you know her address? 21 A. No. 22 Q. Do you know what town on Long 23 Island? 24 A. Baldwin. 25 Q. Is she married? DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 10 FILED: NEW YORK COUNTY CLERK 07/16/2021 08/06/2020 09:58 02:38 AM PM INDEX NO. 805302/2015 NYSCEF DOC. NO. 164 121 RECEIVED NYSCEF: 07/16/2021 08/06/2020 11 1 S. HOFFMAN 2 A. No. 3 Q. Who is your next child? 4 A. Elijah Austin. 5 Q. How old is Elijah? 6 A. He is 17. 7 Q. He currently lives with you? 8 A. Yes. 9 Q. Your other son's name? 10 A. Marsul. 11 Q. How do you spell that? 12 A. M-a-r-s-u-1. 13 Q. Same last name? 14 A. H-o-y-t-e. 15 Q. How old is Marsul? 16 A. He is 10. 17 Q. He also lives with you? 18 A. Yes. 19 Q. Do you have any other children? 20 A. No. 21 Q. Do you have any children with 22 your husband? 23 A. No. 24 Q. What is your highest level of 25 education? DIAMOND REPORTING (877) 624-3287 info@diamondreporting.com 11 FILED: NEW YOR