Preview
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
1
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^_ -^ .l
;,;;GINAL May 29, 201_9
J SUPREME COURT OE THE
STATE OE NEW YORK
COUNTY OE NEW YORK
of
WANDA COLLADO, as Parent and Natural Guardian
A.P., an Infant
Plaintiff'
-against- Index No'
805008/2017
HOSPITAL'
THE NEW YORK & PRESBYTERIAN
De f endant '
--------x
538 Riverdale Avenue
Yonkers, New York
MaY 29, 2A19
U 10:18 a'm'
EXAMINATION BEFORE TRIAL of
Pfaintiff, WANDA
r
COLLADO, Pursuant to Orde '
h,efore Randi
and for the
Vecchione / a NotarY Public within
State ot New ror J'"
{. E\/ 1"[
t DEllZ -^,,rr ReDort-ing " ' A Lexiras
Company
800-678-0165
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
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FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
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May 29 | 2Al9
o 1
APPEARANCES
2
3
4 THE F]TZGERALD LAW FIRM, P.C
AttorneYS for Plaintiff
5 538 Riverdale Avenue
Yonkers, New York 10705
6
BY: ELIZABETH CORLEY, ESQ-, of Counsel
1
HEIDELL, PITTONl, MURPHY & BACH, LLP
9 Attorneys for De f endant
99 Par k Avenue' lrh Fl oor
10 New York, New York 10016-1501
o 11
L2
BY: MAURA KERNAN, ESQ.
t-3
l4
15
16
L1
LO
19
20
27
22
23
24
25
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DEITZ Court Reporting... A Lexitas Company
800-578-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
D=aa
!qYL ?J
May 29, 201"9
a I
2 ST I PULAT fON S
3
4 IT IS HEREBY ST]PULATED
5 AND AGREED by and between(among) counsef for the
6 respectlve parties hereto, that:
1
I A11 riqhts Pr:ovided bY
9 the C.P.L.R., lncluding the right to object to any
10 question, except as to form, or to move to strike
11 any testimony at thls (these) examination(s), are
t2 .reserved, and, in addition, the faifure to obj ect
to any question or to move to strike any testimony
o 13
L4 at this (these) examination(s) shall not be a bar
15 or waiver to make such motion at, and is reserved
l6 for the trial of this action;
!7
18 IT IS EURTHER STIPULATED
19 AND AGREED by and between (among) counsel for the
20 respective parties hereto, that this (these)
27 examlnation(s) may be sworn to by the witness(es)
22 being examined, before a Notary Public other than
?3 the Notary Public before whom this (these)
24 examination (s) was (were)
25
o
DElTZ Court Reporting... A Lexitas Company
800-618-01-66
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Page 4
tlay 29, 20L9
t 1
2 ST]PULATIONS
3
4 begun; but the failure to do so, or to
5 return the original of this (these) examination (s )
6 to counsef, shall not be deemed a waiver of rights
1 provided by Rules 3116 and 3117 of the C.P.L.R.,
I and shaf I be controlled thereby;
9
10 IT ]S EURTHER STIPULATED
11 AND AGREED by and between (among) counse.I for the
t2 respective parties hereto, that this (these)
a 13
L4
examination(s) may be utilized for all purposes as
provided by the C. P. L. R. ;
15
16 IT IS EURTHER STIPULATED
U AND AGREED hy and between (among) counsef for the
18 respective parties hereto, that the fil1ng and
19 sealing of the original of this (these)
20 examination(s) shalf be and the same hereby are
2I wa ived;
22
23 IT ]S EURTHER STlPULATED AND AGREED
1A by and between (among) counsef for the respective
25 parties hereto, that a copy of the
I
DEITZ Court Reporting... A Lexitas Company
800-678-0r66
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Page 5
t4ay 29, 20L9
t 2
1
STIPULAT]ONS
3
4 within examination (s ) shal I be furnished
5 to counsel representing the wilness(es)
6 testi fyinq, without charge.
7
I IT IS EURTHER ST]PULATED
9 AND AGREED by and between (among) counsef for the
10 respective parties hereto, that all r ight s
11 provided by the C.P.L.R., and ParL 221 of the
L2 Uni-f orm Rufes for the Conduct of Deposltions,
t 13
L4
including the right to obj ect to any question,
except as to form, or to move to strike any
15 testimony at thls examination is reserved; and in
L6 addition, the failure to obrject to any questions
T1 or to move to strike any testimony at this
18 examination shalL not be a bar or waiver to make
19 such motion at, and is reserved to, the trial of
20 thi s action.
27
22
23
25
t DEITZ Court Reporting... A Lexitas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Pagte 6
t{ay 29, 2Al9
o 1 W. COLLADO
2 W ANDA C O L L A D O, called as a witness,
3 having been first du.Iy sworn by a Notary Pub 1i c
4 within and for the State of New York, was examined
5 and testified as follows:
6
7
I EXAMINATION BY
9 MS. KERNAN:
10 O. What is your name, please?
11 A. Wanda Coffado.
L2 O. Good morning, Miss Collado. My name is
o 13
I4
Maura Kernan and frm from the faw firm of Heidefl
Pittoni Murphy and Bach. I represent New York
15 Presbyterlan Hospital in this f awsu.it.
16 Today I'm golng to be as klng you a series
L1 of questions about the fawsuit. I'm j ust going to
18 begin with a few instructions. P.Iease respond to
19 all of my questions verbally because the court
20 reporter can't take down any head nods or hand
2L gestures or anyth.ing Ilke that. PLease make sure
22 that you wait to begin speaking untiL I am finished
23 speaking because that wiff help the court repo rt e r
take down a clear record. There wiff be times
25 where you know where my question is going, just
o
DEITZ Court Reporting... A Lexitas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Page 7
t4ay ?9, 201.9
o 1 W. COLLADO
2 remember to wait, for the court reporter again.
3 If at any time you need a brreak just let
4 me know and we'Il be happy to accommodate you. I
5 ask that you wait unti-1 there ' s no outstanding
6 question to do so.
'7 Have you understood all of my
I instructions?
9 A. YeS.
10 O. Do you understand that your answers are
11 being given under oath?
l2
o 13
l4
0. Have you reviewed any documents in
preparation for today' s deposltion?
15 A, No .
1-6 O. Have you spoken with anyone other than
l1 your attorney about today's deposition?
18 A. No.
19 o. Have you ta ken any medications within the
2A past 24 hours that might affect your memo ry ?
2L A. No.
22 O. Have you had any alcohof to drink in the
23 past hours ?
24 A No.
25 o. Have you consumed any drugs in the past
o
DEITZ Court Reporting... A Lexitas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Page I
May 29, 2019
I 1 W. COLLADO
2 24 hours ?
3 A. No.
4 O. Did you ever write a diary regarding Lhe
5 subject of this 1a wsuit?
6 A. No .
'7
O. Did you ever take any notes regardinq the
I subj ect of thls. fa wsu.it?
9 A. No.
10 O. Have you ever written on any Internet Web
11 sites about the sub j ect of this .Iawsuit?
t2 A. No.
o 13
74
u. ndve you ever written anyt hl ng that has
been published about the s ul:r j ect of this .Iawsuit?
15
16 0. In 2013 did you keep a cafendar of your
71 medicaf appo i ntment s ?
t-B A. No .
19 0. In 20L4 did you keep a calendar of your
20 medical appo intment s?
27 A. No .
22 a. In 2014 after your son, A., was born, did
23 you ever keep a calendar of his medical
.A appo intment s ?
25 A. No.
o
DEITZ Court Reporting... A Lexitas Company
800-678-01-66
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Dr^^ O
May 29, 201,9
t 1 W.
Since 2014 have you at any point kept
COLLADO
2 0. a
3 calendar of A.'s medical appointments?
4 A. NO .
5 O, Have you ever been known by any name
6 other than Wanda Coffado?
1 A. Yes.
8 O. Wha L other name?
9 A. So previously ma.r.ried name Perez. And
10 Ogando.
11 O. We.re those two different names?
72 A,
a 13
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o.
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What
558
is your current addre s s ?
West 164th Street, Apartment 3E, New
15 York, New York 10032.
16 0 What is your social security number?
71 A xxx-xx-2 812 .
18 o What is your date of birth?
19 A l.l'/ l.l'/ t d.
20 O Where were you born?
2L A QueensI New York.
22 o How fong have you fived at your current
23 address?
24 A Five years.
25 0 Where did you 1i ve before thls?
o
DEITZ Court Reporting... A Lexitas Company
800-578-0r66
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Page 10
May 29, 2019
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2 1 554 West
W.
6th Street.
17
COLLADO
3 o. How long were you at that address for?
4 A. Roughly about ten years.
5 o. Was that an apartment?
6 A. Yes.
1 Did anyone five with you there?
o.
I A. My husband and my three chi.Idren.
9 o. Have you lived anywhere e1se other than
10 the two addresses you just gave me dating back to
11 2008?
72 l No.
I 13
14
o.
A.
Is your current residence an apartment?
Yes.
15 O. How many bedrooms does it have?
76 A. .LIIICC.
I1 O. Is it in a building with an e.Ievator?
1B A. Yes.
19 O. Do you rent or own the apartment?
2A A. Rent.
2L O. How much is your rent each month?
22 A. 1,189.
23 O. Do you receive any subsidles for your
24 rent ?
25 A. Section 8
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DEITZ Court Reporting... A Lexltas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
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May 29, 20L9
I 1 W, COLLADO
2 o. How much does that cover?
3 A. 30 percent.
4 o. Does anyone five with you currentfy?
5 A. My three chlfdren and my mother.
6 o. What are the names and dates of birth of
1 the t hree children that 1i ve with you ?
I A. H. P. , she' s ten. G. P. , he' s six. And
9 A. P. who is f ive.
10 O. What is H.rs date of birth?
11 A. xx/xx/A9. G. is XX/xx/12. A. is
1-2 xx/xx/14.
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L4
0.
A
Has H. lived with you since she was born?
Yes.
15 o. Has G, lived with you since he uras born?
L6 A.
L'7 0. Has A. Iived with you since he was born?
18 I
19 O. Do you have any other chifdren who don't
currently live with you?
27 A
22 o. Ilow many other chifdren do you have?
23 A. Just one more.
24 O. What is the name and date of birth of
25 your other child?
I
DEITZ Court Reporting... A Lexitas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
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May 29, 2019
I 1
2 A. Her name
W
AS
COLLADO
Sharlene Ogando . Her date of
3 birth is xx/xx/ 95.
4 O. Does she have the same fast name that you
5 previously had?
6 A Di ^h+
7 O. [,ihere does Sharlene I ive?
B A. She fives in upstate with her boyfriend.
9 O. Where upstate ?
10 A She just moved up there. I don't
11 r ememb e r the name of the town -- Monroe.
L2 0. When did Sharfene fast five with you ?
o 13
74
A.
0.
We're in May, so about March of 2019.
Dld she five with you consistent.Iy from
15 May 2 014 through March 2019?
L6 A. Yes.
t1 o. Does Sharlene work?
18 A. Not at the moment.
19 O. Does Sharlene have any medical training?
20 A. No.
2T o. Do you have any grandchildren?
22 A Going to be a grandmother,
23 0. Congra t uf ations.
24 A Thank you.
25 O. I assume this is Sharfene's?
a
DEITZ Court Reporting... A Lexitas Company
800-678-0165
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
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May 29, ?419
t l-
2 A Thatrs right.
W. COLLADO
3 O. Are you currentfy married?
4 A. No.
5 O. What is the name of A.'s fathe r ?
6 A. I'11 spell that for you. A-N-E-U-D-Y.
7 Perez,
8 0. Is he stilf afive?
9 A I don't know.
10 o. Do you know his date of birth?
11 A. xx/xx/18 .
L2 o. When did you last speak to him?
o 13
L4 year
A.
and
About a year ago or two years ago
a half ago.
a
15 o. When did you fast see him?
16 1 In court.
t1 o. Wa s that a year and a half ago?
Lo A. Ye s .
L9 0. Do you know where he was living at that
20 time?
2L A. In the Bronx.
22 0. Were you ever married to Mr. Perez?
23 A. Yes.
24 o. When were you married to Mr. Perez?
25 A. 2001 . June 14th of 2AA1 .
a
DEITZ Court Reporting... A Lexitas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Page 14
May 29, 2079
a 1 W. COLLADO
o. Are you separated or divorced now ?
3 A. Divorced.
4 O. did you d i vorce?
When
5 A. I didn't divorce. He did.
6 O. When was the divorce finalized?
1 A. I don't know because -- so in court he
8 presented d i vorce papers, but from Domi n i can
9 Republic.
10 O. So this was a year and a half ago?
11 A. That he presented the papers,
l2 o. How long ago was that ?
t 13
L4
A.
0.
Like more than two years ago.
When did you change your name back to
15 Collado?
16 A. I dldn't actuaffy physically change it.
l1 I just started using my maiden name. I didn't have
to present 1i ke divorce papers or anything. I just
19 started writing my own name, my maiden name on all
20 my credit cards, documents. Any court documents,
2t any medicaf documents f woufd just sign my name on
22 it. I wasn'1. signing Perez.
23 0. As in Wanda Coffado, which is your maiden
name ?
25 a Di ^hr
a
DEITZ Court Reporting... A Lexitas Company
800-578-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
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May 29, 2479
t I W. COLLADO
approximately was that?
2 O. When
3 A. Let's see. So A. was born in 2414,
4 O. Approx.imate.Iy?
5 A. So about 2015.
6 O. Where dld you and Mr. Perez get married?
1 A. In the Bronx.
I 0. Do you know if your divorce has been
9 finafi zed in a court 1n the U.S.?
10 A. No.
11 O. No, you don't know or no, 1t has not?
t2 A. No, I don't know.
o 13
74
A. So is it posslble you're sti11 legaIIy
married to h im?
15 A. Possible.
L6 O. Did you and Mr. Perez live together after
L1 you married?
18 A. No -- I'm sorry, yes.
19 O, How fong did you live together for?
20 A. So from 2007 up until 2014.
2L O. gefoie or after A. was born?
?2 A. Before. We were together for about a
23 year.
O. You just said that you lived together up
25 through 2014. Did you stop livlng together be fo re
o
DEITZ Court Reporting... A Lex.itas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Pagre 15
t4ay 29, 201,9
I 1 W. COLLADO
2 or af ter I:,orn?
3 A. After A u,: c harn
4 a. I s he the father of any of your other
5 chifdren?
6 A. Yes. H, and G.
1 O. Did you live together consistently flom
I when you were married up until- A. was born?
9 A.
10 o. Does Mr. Pere z work?
11 A. I donit know.
l2 o. When you were .Iast in contac]- with
I 13
L4
Mr:. Perez, did he work?
A re5.
15 o. Where was he wo r king ?
76 A. As a cab driver.
).1 0. For how long had he been workinq as a cab
driver?
19 A. I don't know.
2A O. Was he working before he was working as a
27 cab driver?
22 A. Subway Re s t aurant .
23 O. What was he doing at a Subv./ay Restaurant?
24 A. Preparing sandwiches.
25 O. Was he working when A. was born?
I
DEITZ Court Reporting... A Lexitas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
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May 29, 2al9
t 2
1
A. Yes.
W. COLLADO
3 O. What was he doing?
4 A. Cab driver.
5 O. Eor how long did he work as a cab driver,
6 approxlmat.ely?
7 A. f don't know. Guessing maybe three or
8 f our years,
9 O. Before that he was working at a Subway
10 Restaurant?
11 A D; ^}1+
L2 O. Eor how long had he worked at a Subway
I 13
1-4
Restaurant?
A. Those seven/eight years we were together.
O. Does he have any medical training?
16 A. No .
1.1 O. What is his highest level of education?
18 A. High school.
19 O. Has A. ever Iived wi th Mr. Perez?
2A A. No .
21" O. When did A. last see Mr. Perez?
22 A. He does not know A.
23 O. A. has never met Mr. Perez?
?4 A. No .
la O. Does Mr. Perez pay you child support?
t DEITZ Court Reporting... A Lexltas Company
800-678-0r66
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
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Itay 29, 20L9
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2 A \/6c
W. COLLADO
3 O. How much does he pay you each month?
4 A. 900.
5 O. Have you continued to receive payments in
6 the past year and a half?
1 A. On and off.
8 O. Is this court ordered?
9 l V6 c
10 O. Eor how long has he been paying you child
11 support?
I2 A. Eor about four years now.
a 13
L4
O. So some time after A. was born he
court ordered; is that correct ?
was
15 A. YeS.
16 0. Does Mr. Perez see H. Perez?
L1 A No.
18 (An off-the-record discussion was hefd. )
19 O Does Mr. Perez see \J. dL dLL'
20 A No.
21 o Were you married before Mr. Perez?
22 A Ye s .
23 o To whom were you married b,ef ore
24 Mr. Perez?
25 A Sharlene ' s father. Jose Ogando.
o
DEITZ Court Reporting... A Lexitas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
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l,lay 29, 2019
o 1 W. COLLADO
2 0. When did you and Jose get married?
3 A. Sharlene was born 1995, about '91 /'98.
4 o. Where did you get married?
5 A. Bronx, New Yor k.
6 o. How long were you married to Mr. Ogando
'7
for?
I A. About five years.
9 0. Dld you divorce Mr. ogando?
10 A. Yes.
11 O. Does Mr. Ogando have any medical
l2 training?
o 13
L4
A
o.
No.
When was the last time you saw Mr.
15 ogando ?
L6 A. About a year ago.
ll O. What is your mother's name?
18 l Elba Mef f a.
19 o. Can you spell her first name?
20 A. E-L-B-A. Last name is spelled M-E-L-L-4.
2t O. Do you know her date of h,irth?
22 A. xx/xx/ 51 .
23 o. How long has she I ived with you for?
24 A. Eour years -- five years now.
?5 o. Has she lived with you continuously since
I
DEITZ Court Reporting... A Lexitas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Page 20
May 29, 20L9
o 1 W. COLLADO
2 then?
3 A Yes.
4 o Was this right about when A. was born?
5 A Right.
6 o Has anyone else fived with you since
1 20L3?
I A. No.
9 O. Where was your mother living before she
10 moved in with you?
11 A. With her mother.
L2 O. Where was that?
o 13
L4
A. 115th and Lenox.
O. Does your mother work?
15 A. No .
16 O. Has she worked at afl since 2013?
L1 a v6c =. a home attendant.
1B O. When was that, approximately?
t9 A. I don't remembe r .
20 O. Eor how long did she work as a home
21 a L L enda nr , app rox ima ce 1y?
22 A. 15 years.
23 0. So was she continulng to work as a home
24 attendant when she moved?
25 A. Yes, she was still working when she moved
o
DEITZ Court Reporting... A Lexitas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Page 21
May 29, 2019
t 1
2 in with me.
W. COLLADO
3 O, About how many hours a week was she
4 working?
5 A. 12 hours.
O, A week.' correct?
1 A. No, she was a five-in home attendant.
8 She woufd work Monday through Eriday.
9 O. So she was a live-in home attenclant
10 Monday through Frlday for L2 hours --
11 A. She would stay with the patient --
L2 O, Eor 1-2 hours?
o 13
74
A. 12 hours straight Monday through Eriday
and then release Eriday morning, so around 7: OO in
15 the morning she would head to my p.Iace.
t6 O. Was she with the same patient?
t1 A. Yes.
18 O. How ofd was the patient, approximately?
t9 A. 8 0 something yea rs oId.
2A O. Does she have any medicaf training?
2L A. My mothe r ?
22 O. Yes .
23 A. As a home attendant.
1A
O. Has she worked since she stopped working
25 as a home attendant at aff?
t
DEITZ Court Reporting... A Lexitas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
acle 22
P
May 29, 2079
t I
2 A No.
W. COLLADO
3 O. after A. was born did she stop
How soon
4 working as a home attendant ?
5 A. About a year/six months after. Six
6 months to a year aftel:.
1 o. Is your father stifl a 11ve ?
B A. Yes.
9 o. What 1s your father's name?
10 A. Juan Antonio Collado.
11 o. How do you spe.Il the fast name?
l2 A. c-o-L-L-A-D-O.
o 13
l4
o.
A
About how old is Your father?
15 O. Where does he 11ve ?
L6 A. In can Republ.ic.
Domi n.i
T1 O. Does he have any medicaf training?
_LO A No.
19 O. Has he fived in the Dominican Republic
20 consistently since 2014?
2l A. No .
22 O. Where efse has he l-ived since 2014?
23 A. He travefs a lot.
24 O. Has he fived in the New York City area?
25
t
DEITZ Court Reporting... A Lex.itas Company
800-678-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
Page 23
May 29, 2019
t 1
2 o Since 20L4 ?
W. COLLADO
3 A
4 O. When did he last live in the New York
5 City area?
6 A. Last year.
1 O. For how .Iong was he living in the New
I York City area at that I]Lme1
9 A Six months,
10 o. Where does he Live when he comes to New
11 York City?
72 A. He just visits family everywhere and just
t 13
L4
stays wherever he wants.
O. Does he stay with you?
15 A. He doesnrt have a stable place.
t6 Sometimes he stays with me.
Ll 0. OE.her than rhe six monrhs that he was in
18 New York City fast year, has he been an the New
19 York City area for an extended period of time since
20 A. was born ?
27 A. NO .
22 O. How many times has he met A
23 approximately?
24 A. In those five years, about six,/seven
25 times.
t
DEITZ Court Reporting... A Lexltas Company
800-578-0166
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017
NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022
May 29, 2419
a 1 W. COLLADO
2 a Every t ime in New York?
3 A Yes.
4 0 Does your father work?
5 A No.
6 o Has he worked at afl since 2014?
1 A No,
I o Do you have any siblings?
9 A Vae
10 O. How many siblings do you have?
11 A. Eour -- five.
L2 O. What are their names, ages,
o 13
14
approximately?
A Welf , the two siblings from my mother are
15 4 9 and 48. Theil: names are Petel: Coffado and
L6 Ronnie Co 1f ado .
L1 o Is Ronnie a man or a woman?
18 A Male.
19 O. Do you
Preview
FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 1 rdqe ^_ -^ .l ;,;;GINAL May 29, 201_9 J SUPREME COURT OE THE STATE OE NEW YORK COUNTY OE NEW YORK of WANDA COLLADO, as Parent and Natural Guardian A.P., an Infant Plaintiff' -against- Index No' 805008/2017 HOSPITAL' THE NEW YORK & PRESBYTERIAN De f endant ' --------x 538 Riverdale Avenue Yonkers, New York MaY 29, 2A19 U 10:18 a'm' EXAMINATION BEFORE TRIAL of Pfaintiff, WANDA r COLLADO, Pursuant to Orde ' h,efore Randi and for the Vecchione / a NotarY Public within State ot New ror J'" {. E\/ 1"[ t DEllZ -^,,rr ReDort-ing " ' A Lexiras Company 800-678-0165 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 C o U FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 v)^a,! May 29 | 2Al9 o 1 APPEARANCES 2 3 4 THE F]TZGERALD LAW FIRM, P.C AttorneYS for Plaintiff 5 538 Riverdale Avenue Yonkers, New York 10705 6 BY: ELIZABETH CORLEY, ESQ-, of Counsel 1 HEIDELL, PITTONl, MURPHY & BACH, LLP 9 Attorneys for De f endant 99 Par k Avenue' lrh Fl oor 10 New York, New York 10016-1501 o 11 L2 BY: MAURA KERNAN, ESQ. t-3 l4 15 16 L1 LO 19 20 27 22 23 24 25 l DEITZ Court Reporting... A Lexitas Company 800-578-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 D=aa !qYL ?J May 29, 201"9 a I 2 ST I PULAT fON S 3 4 IT IS HEREBY ST]PULATED 5 AND AGREED by and between(among) counsef for the 6 respectlve parties hereto, that: 1 I A11 riqhts Pr:ovided bY 9 the C.P.L.R., lncluding the right to object to any 10 question, except as to form, or to move to strike 11 any testimony at thls (these) examination(s), are t2 .reserved, and, in addition, the faifure to obj ect to any question or to move to strike any testimony o 13 L4 at this (these) examination(s) shall not be a bar 15 or waiver to make such motion at, and is reserved l6 for the trial of this action; !7 18 IT IS EURTHER STIPULATED 19 AND AGREED by and between (among) counsel for the 20 respective parties hereto, that this (these) 27 examlnation(s) may be sworn to by the witness(es) 22 being examined, before a Notary Public other than ?3 the Notary Public before whom this (these) 24 examination (s) was (were) 25 o DElTZ Court Reporting... A Lexitas Company 800-618-01-66 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 4 tlay 29, 20L9 t 1 2 ST]PULATIONS 3 4 begun; but the failure to do so, or to 5 return the original of this (these) examination (s ) 6 to counsef, shall not be deemed a waiver of rights 1 provided by Rules 3116 and 3117 of the C.P.L.R., I and shaf I be controlled thereby; 9 10 IT ]S EURTHER STIPULATED 11 AND AGREED by and between (among) counse.I for the t2 respective parties hereto, that this (these) a 13 L4 examination(s) may be utilized for all purposes as provided by the C. P. L. R. ; 15 16 IT IS EURTHER STIPULATED U AND AGREED hy and between (among) counsef for the 18 respective parties hereto, that the fil1ng and 19 sealing of the original of this (these) 20 examination(s) shalf be and the same hereby are 2I wa ived; 22 23 IT ]S EURTHER STlPULATED AND AGREED 1A by and between (among) counsef for the respective 25 parties hereto, that a copy of the I DEITZ Court Reporting... A Lexitas Company 800-678-0r66 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 5 t4ay 29, 20L9 t 2 1 STIPULAT]ONS 3 4 within examination (s ) shal I be furnished 5 to counsel representing the wilness(es) 6 testi fyinq, without charge. 7 I IT IS EURTHER ST]PULATED 9 AND AGREED by and between (among) counsef for the 10 respective parties hereto, that all r ight s 11 provided by the C.P.L.R., and ParL 221 of the L2 Uni-f orm Rufes for the Conduct of Deposltions, t 13 L4 including the right to obj ect to any question, except as to form, or to move to strike any 15 testimony at thls examination is reserved; and in L6 addition, the failure to obrject to any questions T1 or to move to strike any testimony at this 18 examination shalL not be a bar or waiver to make 19 such motion at, and is reserved to, the trial of 20 thi s action. 27 22 23 25 t DEITZ Court Reporting... A Lexitas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Pagte 6 t{ay 29, 2Al9 o 1 W. COLLADO 2 W ANDA C O L L A D O, called as a witness, 3 having been first du.Iy sworn by a Notary Pub 1i c 4 within and for the State of New York, was examined 5 and testified as follows: 6 7 I EXAMINATION BY 9 MS. KERNAN: 10 O. What is your name, please? 11 A. Wanda Coffado. L2 O. Good morning, Miss Collado. My name is o 13 I4 Maura Kernan and frm from the faw firm of Heidefl Pittoni Murphy and Bach. I represent New York 15 Presbyterlan Hospital in this f awsu.it. 16 Today I'm golng to be as klng you a series L1 of questions about the fawsuit. I'm j ust going to 18 begin with a few instructions. P.Iease respond to 19 all of my questions verbally because the court 20 reporter can't take down any head nods or hand 2L gestures or anyth.ing Ilke that. PLease make sure 22 that you wait to begin speaking untiL I am finished 23 speaking because that wiff help the court repo rt e r take down a clear record. There wiff be times 25 where you know where my question is going, just o DEITZ Court Reporting... A Lexitas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 7 t4ay ?9, 201.9 o 1 W. COLLADO 2 remember to wait, for the court reporter again. 3 If at any time you need a brreak just let 4 me know and we'Il be happy to accommodate you. I 5 ask that you wait unti-1 there ' s no outstanding 6 question to do so. '7 Have you understood all of my I instructions? 9 A. YeS. 10 O. Do you understand that your answers are 11 being given under oath? l2 o 13 l4 0. Have you reviewed any documents in preparation for today' s deposltion? 15 A, No . 1-6 O. Have you spoken with anyone other than l1 your attorney about today's deposition? 18 A. No. 19 o. Have you ta ken any medications within the 2A past 24 hours that might affect your memo ry ? 2L A. No. 22 O. Have you had any alcohof to drink in the 23 past hours ? 24 A No. 25 o. Have you consumed any drugs in the past o DEITZ Court Reporting... A Lexitas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page I May 29, 2019 I 1 W. COLLADO 2 24 hours ? 3 A. No. 4 O. Did you ever write a diary regarding Lhe 5 subject of this 1a wsuit? 6 A. No . '7 O. Did you ever take any notes regardinq the I subj ect of thls. fa wsu.it? 9 A. No. 10 O. Have you ever written on any Internet Web 11 sites about the sub j ect of this .Iawsuit? t2 A. No. o 13 74 u. ndve you ever written anyt hl ng that has been published about the s ul:r j ect of this .Iawsuit? 15 16 0. In 2013 did you keep a cafendar of your 71 medicaf appo i ntment s ? t-B A. No . 19 0. In 20L4 did you keep a calendar of your 20 medical appo intment s? 27 A. No . 22 a. In 2014 after your son, A., was born, did 23 you ever keep a calendar of his medical .A appo intment s ? 25 A. No. o DEITZ Court Reporting... A Lexitas Company 800-678-01-66 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Dr^^ O May 29, 201,9 t 1 W. Since 2014 have you at any point kept COLLADO 2 0. a 3 calendar of A.'s medical appointments? 4 A. NO . 5 O, Have you ever been known by any name 6 other than Wanda Coffado? 1 A. Yes. 8 O. Wha L other name? 9 A. So previously ma.r.ried name Perez. And 10 Ogando. 11 O. We.re those two different names? 72 A, a 13 L4 o. l What 558 is your current addre s s ? West 164th Street, Apartment 3E, New 15 York, New York 10032. 16 0 What is your social security number? 71 A xxx-xx-2 812 . 18 o What is your date of birth? 19 A l.l'/ l.l'/ t d. 20 O Where were you born? 2L A QueensI New York. 22 o How fong have you fived at your current 23 address? 24 A Five years. 25 0 Where did you 1i ve before thls? o DEITZ Court Reporting... A Lexitas Company 800-578-0r66 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 10 May 29, 2019 t t 2 1 554 West W. 6th Street. 17 COLLADO 3 o. How long were you at that address for? 4 A. Roughly about ten years. 5 o. Was that an apartment? 6 A. Yes. 1 Did anyone five with you there? o. I A. My husband and my three chi.Idren. 9 o. Have you lived anywhere e1se other than 10 the two addresses you just gave me dating back to 11 2008? 72 l No. I 13 14 o. A. Is your current residence an apartment? Yes. 15 O. How many bedrooms does it have? 76 A. .LIIICC. I1 O. Is it in a building with an e.Ievator? 1B A. Yes. 19 O. Do you rent or own the apartment? 2A A. Rent. 2L O. How much is your rent each month? 22 A. 1,189. 23 O. Do you receive any subsidles for your 24 rent ? 25 A. Section 8 t DEITZ Court Reporting... A Lexltas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 11 May 29, 20L9 I 1 W, COLLADO 2 o. How much does that cover? 3 A. 30 percent. 4 o. Does anyone five with you currentfy? 5 A. My three chlfdren and my mother. 6 o. What are the names and dates of birth of 1 the t hree children that 1i ve with you ? I A. H. P. , she' s ten. G. P. , he' s six. And 9 A. P. who is f ive. 10 O. What is H.rs date of birth? 11 A. xx/xx/A9. G. is XX/xx/12. A. is 1-2 xx/xx/14. t 13 L4 0. A Has H. lived with you since she was born? Yes. 15 o. Has G, lived with you since he uras born? L6 A. L'7 0. Has A. Iived with you since he was born? 18 I 19 O. Do you have any other chifdren who don't currently live with you? 27 A 22 o. Ilow many other chifdren do you have? 23 A. Just one more. 24 O. What is the name and date of birth of 25 your other child? I DEITZ Court Reporting... A Lexitas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 12 May 29, 2019 I 1 2 A. Her name W AS COLLADO Sharlene Ogando . Her date of 3 birth is xx/xx/ 95. 4 O. Does she have the same fast name that you 5 previously had? 6 A Di ^h+ 7 O. [,ihere does Sharlene I ive? B A. She fives in upstate with her boyfriend. 9 O. Where upstate ? 10 A She just moved up there. I don't 11 r ememb e r the name of the town -- Monroe. L2 0. When did Sharfene fast five with you ? o 13 74 A. 0. We're in May, so about March of 2019. Dld she five with you consistent.Iy from 15 May 2 014 through March 2019? L6 A. Yes. t1 o. Does Sharlene work? 18 A. Not at the moment. 19 O. Does Sharlene have any medical training? 20 A. No. 2T o. Do you have any grandchildren? 22 A Going to be a grandmother, 23 0. Congra t uf ations. 24 A Thank you. 25 O. I assume this is Sharfene's? a DEITZ Court Reporting... A Lexitas Company 800-678-0165 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 13 May 29, ?419 t l- 2 A Thatrs right. W. COLLADO 3 O. Are you currentfy married? 4 A. No. 5 O. What is the name of A.'s fathe r ? 6 A. I'11 spell that for you. A-N-E-U-D-Y. 7 Perez, 8 0. Is he stilf afive? 9 A I don't know. 10 o. Do you know his date of birth? 11 A. xx/xx/18 . L2 o. When did you last speak to him? o 13 L4 year A. and About a year ago or two years ago a half ago. a 15 o. When did you fast see him? 16 1 In court. t1 o. Wa s that a year and a half ago? Lo A. Ye s . L9 0. Do you know where he was living at that 20 time? 2L A. In the Bronx. 22 0. Were you ever married to Mr. Perez? 23 A. Yes. 24 o. When were you married to Mr. Perez? 25 A. 2001 . June 14th of 2AA1 . a DEITZ Court Reporting... A Lexitas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 14 May 29, 2079 a 1 W. COLLADO o. Are you separated or divorced now ? 3 A. Divorced. 4 O. did you d i vorce? When 5 A. I didn't divorce. He did. 6 O. When was the divorce finalized? 1 A. I don't know because -- so in court he 8 presented d i vorce papers, but from Domi n i can 9 Republic. 10 O. So this was a year and a half ago? 11 A. That he presented the papers, l2 o. How long ago was that ? t 13 L4 A. 0. Like more than two years ago. When did you change your name back to 15 Collado? 16 A. I dldn't actuaffy physically change it. l1 I just started using my maiden name. I didn't have to present 1i ke divorce papers or anything. I just 19 started writing my own name, my maiden name on all 20 my credit cards, documents. Any court documents, 2t any medicaf documents f woufd just sign my name on 22 it. I wasn'1. signing Perez. 23 0. As in Wanda Coffado, which is your maiden name ? 25 a Di ^hr a DEITZ Court Reporting... A Lexitas Company 800-578-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 15 May 29, 2479 t I W. COLLADO approximately was that? 2 O. When 3 A. Let's see. So A. was born in 2414, 4 O. Approx.imate.Iy? 5 A. So about 2015. 6 O. Where dld you and Mr. Perez get married? 1 A. In the Bronx. I 0. Do you know if your divorce has been 9 finafi zed in a court 1n the U.S.? 10 A. No. 11 O. No, you don't know or no, 1t has not? t2 A. No, I don't know. o 13 74 A. So is it posslble you're sti11 legaIIy married to h im? 15 A. Possible. L6 O. Did you and Mr. Perez live together after L1 you married? 18 A. No -- I'm sorry, yes. 19 O, How fong did you live together for? 20 A. So from 2007 up until 2014. 2L O. gefoie or after A. was born? ?2 A. Before. We were together for about a 23 year. O. You just said that you lived together up 25 through 2014. Did you stop livlng together be fo re o DEITZ Court Reporting... A Lex.itas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Pagre 15 t4ay 29, 201,9 I 1 W. COLLADO 2 or af ter I:,orn? 3 A. After A u,: c harn 4 a. I s he the father of any of your other 5 chifdren? 6 A. Yes. H, and G. 1 O. Did you live together consistently flom I when you were married up until- A. was born? 9 A. 10 o. Does Mr. Pere z work? 11 A. I donit know. l2 o. When you were .Iast in contac]- with I 13 L4 Mr:. Perez, did he work? A re5. 15 o. Where was he wo r king ? 76 A. As a cab driver. ).1 0. For how long had he been workinq as a cab driver? 19 A. I don't know. 2A O. Was he working before he was working as a 27 cab driver? 22 A. Subway Re s t aurant . 23 O. What was he doing at a Subv./ay Restaurant? 24 A. Preparing sandwiches. 25 O. Was he working when A. was born? I DEITZ Court Reporting... A Lexitas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 17 May 29, 2al9 t 2 1 A. Yes. W. COLLADO 3 O. What was he doing? 4 A. Cab driver. 5 O. Eor how long did he work as a cab driver, 6 approxlmat.ely? 7 A. f don't know. Guessing maybe three or 8 f our years, 9 O. Before that he was working at a Subway 10 Restaurant? 11 A D; ^}1+ L2 O. Eor how long had he worked at a Subway I 13 1-4 Restaurant? A. Those seven/eight years we were together. O. Does he have any medical training? 16 A. No . 1.1 O. What is his highest level of education? 18 A. High school. 19 O. Has A. ever Iived wi th Mr. Perez? 2A A. No . 21" O. When did A. last see Mr. Perez? 22 A. He does not know A. 23 O. A. has never met Mr. Perez? ?4 A. No . la O. Does Mr. Perez pay you child support? t DEITZ Court Reporting... A Lexltas Company 800-678-0r66 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 18 Itay 29, 20L9 t 1 2 A \/6c W. COLLADO 3 O. How much does he pay you each month? 4 A. 900. 5 O. Have you continued to receive payments in 6 the past year and a half? 1 A. On and off. 8 O. Is this court ordered? 9 l V6 c 10 O. Eor how long has he been paying you child 11 support? I2 A. Eor about four years now. a 13 L4 O. So some time after A. was born he court ordered; is that correct ? was 15 A. YeS. 16 0. Does Mr. Perez see H. Perez? L1 A No. 18 (An off-the-record discussion was hefd. ) 19 O Does Mr. Perez see \J. dL dLL' 20 A No. 21 o Were you married before Mr. Perez? 22 A Ye s . 23 o To whom were you married b,ef ore 24 Mr. Perez? 25 A Sharlene ' s father. Jose Ogando. o DEITZ Court Reporting... A Lexitas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 19 l,lay 29, 2019 o 1 W. COLLADO 2 0. When did you and Jose get married? 3 A. Sharlene was born 1995, about '91 /'98. 4 o. Where did you get married? 5 A. Bronx, New Yor k. 6 o. How long were you married to Mr. Ogando '7 for? I A. About five years. 9 0. Dld you divorce Mr. ogando? 10 A. Yes. 11 O. Does Mr. Ogando have any medical l2 training? o 13 L4 A o. No. When was the last time you saw Mr. 15 ogando ? L6 A. About a year ago. ll O. What is your mother's name? 18 l Elba Mef f a. 19 o. Can you spell her first name? 20 A. E-L-B-A. Last name is spelled M-E-L-L-4. 2t O. Do you know her date of h,irth? 22 A. xx/xx/ 51 . 23 o. How long has she I ived with you for? 24 A. Eour years -- five years now. ?5 o. Has she lived with you continuously since I DEITZ Court Reporting... A Lexitas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 20 May 29, 20L9 o 1 W. COLLADO 2 then? 3 A Yes. 4 o Was this right about when A. was born? 5 A Right. 6 o Has anyone else fived with you since 1 20L3? I A. No. 9 O. Where was your mother living before she 10 moved in with you? 11 A. With her mother. L2 O. Where was that? o 13 L4 A. 115th and Lenox. O. Does your mother work? 15 A. No . 16 O. Has she worked at afl since 2013? L1 a v6c =. a home attendant. 1B O. When was that, approximately? t9 A. I don't remembe r . 20 O. Eor how long did she work as a home 21 a L L enda nr , app rox ima ce 1y? 22 A. 15 years. 23 0. So was she continulng to work as a home 24 attendant when she moved? 25 A. Yes, she was still working when she moved o DEITZ Court Reporting... A Lexitas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 21 May 29, 2019 t 1 2 in with me. W. COLLADO 3 O, About how many hours a week was she 4 working? 5 A. 12 hours. O, A week.' correct? 1 A. No, she was a five-in home attendant. 8 She woufd work Monday through Eriday. 9 O. So she was a live-in home attenclant 10 Monday through Frlday for L2 hours -- 11 A. She would stay with the patient -- L2 O, Eor 1-2 hours? o 13 74 A. 12 hours straight Monday through Eriday and then release Eriday morning, so around 7: OO in 15 the morning she would head to my p.Iace. t6 O. Was she with the same patient? t1 A. Yes. 18 O. How ofd was the patient, approximately? t9 A. 8 0 something yea rs oId. 2A O. Does she have any medicaf training? 2L A. My mothe r ? 22 O. Yes . 23 A. As a home attendant. 1A O. Has she worked since she stopped working 25 as a home attendant at aff? t DEITZ Court Reporting... A Lexitas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 acle 22 P May 29, 2079 t I 2 A No. W. COLLADO 3 O. after A. was born did she stop How soon 4 working as a home attendant ? 5 A. About a year/six months after. Six 6 months to a year aftel:. 1 o. Is your father stifl a 11ve ? B A. Yes. 9 o. What 1s your father's name? 10 A. Juan Antonio Collado. 11 o. How do you spe.Il the fast name? l2 A. c-o-L-L-A-D-O. o 13 l4 o. A About how old is Your father? 15 O. Where does he 11ve ? L6 A. In can Republ.ic. Domi n.i T1 O. Does he have any medicaf training? _LO A No. 19 O. Has he fived in the Dominican Republic 20 consistently since 2014? 2l A. No . 22 O. Where efse has he l-ived since 2014? 23 A. He travefs a lot. 24 O. Has he fived in the New York City area? 25 t DEITZ Court Reporting... A Lex.itas Company 800-678-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 Page 23 May 29, 2019 t 1 2 o Since 20L4 ? W. COLLADO 3 A 4 O. When did he last live in the New York 5 City area? 6 A. Last year. 1 O. For how .Iong was he living in the New I York City area at that I]Lme1 9 A Six months, 10 o. Where does he Live when he comes to New 11 York City? 72 A. He just visits family everywhere and just t 13 L4 stays wherever he wants. O. Does he stay with you? 15 A. He doesnrt have a stable place. t6 Sometimes he stays with me. Ll 0. OE.her than rhe six monrhs that he was in 18 New York City fast year, has he been an the New 19 York City area for an extended period of time since 20 A. was born ? 27 A. NO . 22 O. How many times has he met A 23 approximately? 24 A. In those five years, about six,/seven 25 times. t DEITZ Court Reporting... A Lexltas Company 800-578-0166 FILED: NEW YORK COUNTY CLERK 01/12/2022 12:19 PM INDEX NO. 805008/2017 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 01/12/2022 May 29, 2419 a 1 W. COLLADO 2 a Every t ime in New York? 3 A Yes. 4 0 Does your father work? 5 A No. 6 o Has he worked at afl since 2014? 1 A No, I o Do you have any siblings? 9 A Vae 10 O. How many siblings do you have? 11 A. Eour -- five. L2 O. What are their names, ages, o 13 14 approximately? A Welf , the two siblings from my mother are 15 4 9 and 48. Theil: names are Petel: Coffado and L6 Ronnie Co 1f ado . L1 o Is Ronnie a man or a woman? 18 A Male. 19 O. Do you