Preview
iD: OUN NK 06 U4: DV INDEX NO. 512150/2020
NYSCEF BOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
EXHIBIT
INDEX NO. 512150/2020
NYSCEF BOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
In the Matter Of:
JACKSON vs VAN BLARCOM CLOSURES
512150/2020
CHRISTINE ABREU
March 20, 2023
INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2028
JACKSON vs VAN BLARCOM CLOSURES
2 SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
j---------------------------
RAY JACKSON,
Plaintiff(s),
-against- No. 512150/2020
AN BLARCOM CLOSURES, INC.,
Defendant(s).
j----------------------------
10
11
12 DEPOSITION OF CHRISTINE ABREU
13 New York, New York
14 Monday, March 20, 2023
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19 Reported by:
Yaffa Kaplan
20 JOB NO. 9455235
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2028
JACKSON vs VAN BLARCOM CLOSURES
March 20, 2023
10:32 a.m.
Deposition of CHRISTINE ABREU, held
at the offices of Weber Gallagher Simpson
Stapleton Fires & Newby, 1500 Broadway, New
ork, New York, pursuant to Subpoena,
before Yaffa Kaplan, a Notary Public of the
10 State of New York.
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2028
JACKSON vs VAN BLARCOM CLOSURES
1
2 APPEARANCES:
3
4 SUBIN ASSOCIATES LLP.
5 Attorneys for Plaintiff
6 150 Broadway
New York, New York 10038
BY: HOWARD ADELSBERG, ESQ
10 WEBER GALLAGHER SIMPSON STAPLETON FIRES &
11 NEWBY LLP
12 Attorneys for Defendant
13 1500 Broadway, Suite 2401
14 New York, New York 10036
15 BY: JERRY L. LYNCH, ESQ.
16
17 ALSO PRESENT:
18 EL] ESAKOFF
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2028
JACKSON vs VAN BLARCOM CLOSURES
IT IS HEREBY STIPULATED AND AGREED
by and between the attorneys for the
espective parties herein, that filing,
ealing and the same are hereby waived.
IT IS FURTHER STIPULATED AND AGREED
hat all objections, except as to the form
bf the question, shall be reserved to the
ime of the trial.
10 IT IS FURTHER STIPULATED AND AGREED
11 that the within deposition may be sworn to
12 land signed before any officer authorized to
13 administer an oath, with the same force
14 land effect as if signed and sworn to before
15 the Court.
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2028
JACKSON vs VAN BLARCOM CLOSURES
C. Abreu
CHRISTINE ABREU, calledasa
witness, having been duly sworn by a Notary Public,
was examined and testified as follows:
EXAMINATION BY
MR. LYNCH:
Q. What is your name and address?
A. Christine Abreu, 1158 Boynton Avenue,
B-H, Bronx, New York 10472.
10 Q._ Ms. Abreu, how are you doing today? My
11 Iname is Jerry Lynch. | am the attorney for Van
12 Blarcom Closures. We have been brought here today
13 because of a lawsuit filed by a gentlemen | believe
14 that you know, Mr. Ray Jackson, and he has brought
15 la lawsuit against my client, and | just brought you
16 here by subpoena to ask you a few questions. And
17 before | begin, | just wanted to go over some
18 ground rules for a deposition.
19 So if you need to take a break for any
20 reason, just let me know. You are perfectly able
21 to do that. This isn't an interrogation. It's
22 ust questions. | just ask before you take any
23 kind of break, if there is a question that | have
24 lasked that has not yet been answered that you
25 lanswer the question and then take a break. For any
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2028
JACKSON vs VAN BLARCOM CLOSURES
C. Abreu
eason whatsoever, by the way.
If there is anything that | ask that you
Won't understand the first time, | am glad to
ephrase it. Just let me know but | don't want you
lo guess. Though sometimes | may ask for you to
approximate so maybe you don't know exactly what
ime or exactly the weather or exactly the
measurement that | am asking for and | will just
10 lask for an approximation or you can say that you
11 lare approximating but no guessing. Does that make
12 sense?
13 A. Yes.
14 Q Because this is entirely recorded by the
15 reporter, | just ask for a clear record that only
16 lone of us speaks at a time. So you may anticipate
17 the answer to a question | am asking before |
18 finished asking it, but | will just ask that you
19 let me finish speaking before you answer, and |
20 will do the same for you.
21 If you do answer a question, | will
22 lassume that you understood it. And | also ask that
23 all your answers be verbal. Yes, no, | don't know,
24 lanything like that, because if you shake your head
25 lor you shrug, the court reporter won't be able to
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2028
JACKSON vs VAN BLARCOM CLOSURES
C. Abreu
lake it down, so then I will just follow up and say
was that a yes, ano, or something else. Does that
make sense?
A. Yes.
Q Lastly, | just ask that you keep your
oice up for the benefit of myself and the reporter
and the other attorneys.
MR. ADELSBERG: If! may, just before we
10 proceed, just so you know who | am in this
11 whole theme, | represent Mr. Jackson. | am an
12 attorney. As | said to you before, my name is
13 Howard Adelsberg, and | am with the law firm
14 Subin Associates. As Mr. Lynch pointed out to
15 you, since you are here by subpoena, | am
16 basically here along for the ride to hear what
17 you have to say this morning, and later there
18 may come a point in time | may have some
19 follow-up questions for you, but both of us
20 are here to hear what you have to say.
21 A. Okay.
22 Q. This should be quick too. Are you okay
23 to begin? Do you want to take a restroom break or
24 lanything like that?
25 A No.
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2028
JACKSON vs VAN BLARCOM CLOSURES
1 C. Abreu
2 Q Just making sure. Have you reviewed any
3 materials before today's deposition?
4 A Say that again.
5 Q Have you reviewed any materials before
6 loday's deposition?
A No.
Q. Any documents you have looked at?
A No.
10 Q._ Any photos?
11 A No.
12 Q Have you taken any drugs or medication
13 that might affect your ability to testify today?
14 A No.
15 Q In the last 24 hours, have you had any
16 lalcohol?
17 A No.
18 Q Is there any medication that you are
19 typically prescribed to take that you didn't take
20 today that might affect your ability to testify?
21 A No.
22 Q Have you ever been known by any other
23 Inames than the other one you gave to the court
24 reporter?
25 A No.
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2028
JACKSON vs VAN BLARCOM CLOSURES
C. Abreu
Q Do you have a middle name?
A No.
Q | am going to ask for the date of birth,
but there will only be Xs in the record so that way
here is no way to get the date of birth without
lalking to me.
A. XX/IXXIXXXX.
Q | am also going to ask for your Social
10 Security number, but again only Xs will be placed
11 lon the record.
12 A. XXX-XX-XXXX.
13 Q How long have you lived at the address
14 lon Boynton Avenue that you gave to the reporter?
15 A Forty years.
16 MR. ADELSBERG: I'm sorry?
17 THE WITNESS: Forty years.
18 Q Do you own or rent that apartment?
19 A. Rent.
20 Q Is this in a walk-up building, or does
21 it have an elevator?
22 A Has an elevator.
23 Q Are you on the sixth floor?
24 A Yes.
25 Have you spoken to anyone about this
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INDEX NO. 512150/2020
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NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 10
C. Abreu
lawsuit?
A No.
Q Not even Mr. Jackson?
A Oh, yes. | have spoken to him, yes.
Q Have you spoken to Mr. Jackson about
his lawsuit at all?
A. Yes.
Q. What did you talk about?
10 A. Wanted to know why was | being
11 subpoenaed if | have nothing to do with this.
12 Q. What did he say?
13 A He said he didn't know either.
14 Q Is there anything else in your
15 conversation that you spoke with him about
16 regarding the lawsuit?
17 A No.
18 Q. Was it ever mentioned that he brought
19 lyour name up at his deposition?
20 A No.
21 Q Okay. Are you presently employed?
22 A Yes.
23 What is your current role?
24 Security officer.
25 Where is that?
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 11
C. Abreu
A | work for a company Prosegur,
P-R-O-S-E-G-U-R.
Q How long have you worked there?
A | worked for that company for five
ears.
Q Are you married?
A No.
Q Are you divorced?
10 A No.
11 Q What is your highest level of education?
12 A Twelfth grade.
13 Q Do you have any certifications like?
14 A The security license.
15 Q That's what | was going to ask, any
16 icenses. Do you have any notes, calendars,
17 journals, or any other kind of written information
18 regarding this lawsuit that you have kept?
19 A No.
20 Q. To your knowledge, does anyone else have
21 lany type of documents or materials including Mr.
22 Vackson regarding this incident?
23 A No.
24 Q Have you ever filed for bankruptcy?
25 A No.
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 12
C. Abreu
Have you ever been deposed before?
Deposed? What is that word?
What we are doing right now.
No. This is the first time.
Q Do you maintain any social media pages
like Facebook or Instagram? Something else?
A. Yes.
Q. What do you have? Facebook?
10 A Facebook, Instagram, Tik Tok.
11 Q. What's your Facebook handle?
12 A. My name on Facebook? It would be my
13 Iname, Christina Abreu.
14 Q. What's your Instagram handle?
15 A. When you say "handle" --
16 Q. The little @ sign and next to it is
17 going to be whatever your title for your profile.
18 A. @yahoo.com.
19 Q. Oh, I'm sorry. Normally in Instagram it
20 Will say maybe @CAbreu.
21 A No. It's just my name.
22 Q What's your Tik Tok handle?
23 A | have to look at it.
24 Q No problem. | just ask that a blank be
25 eft in the record, and once you get a copy of this
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 13
C. Abreu
ranscript in like a month or so, | just ask that
ou write that in if that's okay.
fO BE FURNISHED:
MR. ADELSBERG: Can we go off the record
for one second?
(Discussion off the record.)
Q Do you know Mr. Ray Jackson?
10 A Yes.
11 Q How long have you known him?
12 A | have known him for 21 years.
13 Q And how did you first meet?
14 A We met in 2002 at Daytop Rehab.
15 Q | am going to ask questions about it.
16 But | am going to be delicate about this topic, so
17 if, at any point, you want to take a break again,
18 jplease let me know.
19 Why were you at Daytop Rehabilitation?
20 A. Oh, because | was smoking crack for 20
21 years.
22 Q. And do you know why Mr. Jackson was at
23 IDaytop?
24 A He came -- he told me he came straight
25 from Rikers Island, so | don't know why.
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 14
C. Abreu
Q Did he ever have any discussions with
ou regarding why he was in rehabilitation?
A No.
Q How long were you in the program
logether?
A. Thirty days at Far Rockaway until |
otated upstate to Swan Lake.
Q Did there come a point in time when you
10 finished rehabilitation?
11 A | was discharged from that program, and
12 l continued my rehabilitation in outpatient.
13 MR. ADELSBERG: Was that at Swan Lake.
14 A | left Swan Lake. | was discharged,
15 then | went to a rehab center in the Bronx
16 outpatient.
17 MR. ADELSBERG: Sorry to interrupt.
18 MR. LYNCH: No, you are fine.
19 Q Did there come a time where, to your
20 knowledge, Mr. Jackson was finished with
21 rehabilitation?
22 A No, he wasn't finished.
23 Q. To your knowledge, is Mr. Jackson still
24 n rehab?
25 A No, | don't think so. | don't believe
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 15
C. Abreu
0
Q Did there come a time where you
completed the rehabilitation and you no longer were
yoing?
A. Yes, | completed.
Q. When you completed, did you continue to
peak to or have a friendly relationship with Mr.
ackson?
10 A. Yes.
11 Q How would you describe the nature of
12 your relationship with Mr. Jackson?
13 A. Well, we were a couple for a while. But
14 Wwe are now just very good friends. | care for him
15 ery much. He is not doing well.
16 Q. When were you a couple?
17 A From '03 until 2000 -- 2021 or '22. So
18 from 2003 to 2022, to '22. We were together.
19 Q. Was there any particular reason why you
20 stopped seeing each other?
21 A | no longer cared to be ina
22 relationship with him.
23 Q. Why was that?
24 A | just had moved on. | don't care to be
25 nvolved with him.
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 16
1 C. Abreu
2 Q Did there ever come a time where you two
3 were living together?
4 A. There was a time, yes.
Q. What time period were you living there?
A. That's been off and on, so it wasn't
nothing straight. So | can't remember all the
Hifferent years. It's been off and on.
Q. Can you approximate a time period of
10 lbeing off and on living together from, you know, a
11 certain year to another year?
12 A From like 2010 to most recently, which
13 would have been August of 2022 off and on.
14 Q. When you say "off and on", can you
15 describe that in terms of time by saying a week at
16 la time? A day at a time?
17 A. Months at a time.
18 Q. At the time when Mr. Jackson wasn't
19 iving with you, do you know where he would live?
20 A No.
21 Q Did you ever inquire as to where he
22 would go when he wasn't living with you?
23 A No.
24 Q. What would be the circumstances by which
25 lhe would no longer be living with you for a period
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 17
C. Abreu
bf time?
A Because if you are not going to come
nome for periods of days, then you stay whenever
ou have been staying at.
Q. So there would be periods of days where
ne would not come home?
A. Weeks, yes.
Q. When Mr. Jackson was living with you,
10 did he provide you any rent?
11 A No, not -- not monetary. You know, like
12 through public assistance from living there.
13 Q Oh, sure.
14 A Rent check.
15 Q Okay. How much was that for?
16 A 215 amonth. 107.50 every two weeks.
17 Q These would be issued from some kind of
18 lagency but not through him directly?
19 A HR.
20 Q. To your knowledge, did Mr. Jackson ever
21 luse methadone in your presence?
22 A Never.
23 Q Do you know what methadone is?
24 A Yes.
25 Q It's for the treatment of heroin?
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 18
1 C. Abreu
2 A. Yes, right.
3 Q Did Mr. Jackson during the time period
4 pf the last three years, four years ever use heroin
5 in your presence?
6 A No.
7 MR. ADELSBERG: If you can just clarify
8 the three or four years, when was the last
9 time you saw Mr. Jackson?
10 THE WITNESS: The last time | saw
11 Jackson was two or three days ago.
12 MR. ADELSBERG: Okay.
13 Q._ And the entire time that Mr. Jackson was
14 iving with you from 2003 to until 2022 off and on,
15 did you ever see Mr. Jackson use methadone in your
16 lpresence?
17 A No.
18 Q._ Are you familiar with an accident that
19 loccurred in July 30th of 2019 involving Mr.
20 Vackson?
21 A Where he fell?
22 Q Where he fell.
23 A Yes. He told me about that.
24 Q Did he ever speak to you about how he
25 fell, about the accident?
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INDEX NO. 512150/2020
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NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 19
1 C. Abreu
2 A No. He just stated that he fell in
3 ront of some storefront in Brooklyn. Pavement was
4 messed up and there were no lights there. That was
5 at a time where he wasn't staying with me.
6 Q Did there come a time to your knowledge
7 when Mr. Jackson underwent a serious back surgery
8 in connection with this accident?
A. Yes.
10 Q Do you remember around what time that
11 was or what day?
12 A No. No.
13 Q. After he had that surgery, did there
14 come a time where he was living with you?
15 A. Yes. Off and -- yes, he was doing very
16 lad.
17 Q Do you recall whether or not he lived
18 with you almost immediately following the surgery?
19 A No. No.
20 Q. Was it weeks after the surgery that
21 lhe --
22 A It had to be weeks after because |
23 didn't realize he had the surgery when | first saw
24 him.
25 Q. When you first saw him weeks after the
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INDEX NO. 512150/2020
FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM
NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 20
C. Abreu
urgery, what was his condition based on what
Ou --
A. Dead man walking. He was terrible.
lerrible.
Q In your opinion, did his condition
ignificantly change from the way that he was
bodily? And by your observations, was there a
ignificant change from before the accident to
10 lafter the accident?
11 A. Yes. There was a big change.
12 Q. What were some of the changes that you
13 Inoticed?
14 A. Changes of depression. And because |
15 feel the surgery was botched.
16 Q. Why do you feel that?
17 A Because he would very -- every so often
18 lhe would like paralyze on one side. He had no
19 feelings, and he would at any time anywhere he
20 would just pass out.
21 Q Did you feel that that was the changes
22 you noticed in him after the surgery?
23 A. Yes.
24 Q. What about after the accident but before
25 the surgery? What was his condition?
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CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 21
C. Abreu
A He wasn't -- he wasn't with me. |
Hidn't see him physically.
MR. ADELSBERG: I'm sorry. Could you
repeat that?
THE WITNESS: | didn't see him after the
accident. | guess where he was staying, he
couldn't move. He said he couldn't really
move around.
10 Q Following the surgery, the weeks
11 following where you said that he came to stay with
12 lyou, how long did he stay with you do you remember
13 for that time period after that surgery?
14 A. Well, it was months after the surgery
15 that he came to me. By that time, you know, he had
16 told me about how he passes out from time to time
17 land how he had to look into finding out what's
18 wrong with him because the surgery didn't seem to
19 go the way it was planned.
20 Q Following the surgery, when he came to
21 stay with you the months after, was he able to
22 provide you any assistance with chores around the
23 house?
24 A No.
25 Q. Were you taking care of him during that
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CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 22
C. Abreu
ime?
A Sure. Yes, | was.
Q. What sort of tasks were you doing at
hat time?
A Just make sure he eats because very --
Q. Anything else besides cooking for him?
A. Making sure his clothes were washed and
make sure, you know, he had his toiletries and his
10 ittle things that he needed.
11 Q Did there ever come a time following the
12 surgery where you saw Mr. Jackson's condition
13 mprove?
14 A No.
15 Q. When you saw Mr. Jackson two to three
16 days ago, how would you describe his condition now
17 n relation to how you saw him following the
18 surgery back in, you know, 2021 or so?
19 A He still is very depressed because he is
20 homeless. He has been put up in a hotel. He was
21 lon Wards Island until that was closed down, and he
22 Was put up in a hotel room in Woodside, Queens in
23 (Comfort Inn, which he does not like.
24 Q. When was the last time Mr. Jackson
25 stayed with you?
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JACKSON vs VAN BLARCOM CLOSURES 23
1 C. Abreu
2 A Before last -- the summer before. About
3 Aa year now.
4 Q. Was --
MR. ADELSBERG: I'm sorry. Was that
about a year now?
THE WITNESS: Yes. He left in September
of 20 --'22.
Q Even though he does not live with you
10 lanymore on an off-and-on basis, do you still see
11 Mr. Jackson?
12 A. Yes. | saw him two or three days ago
13 lbecause he receives -- | allow him to use my
14 address to receive mail. He has his mail address,
15 so he picks us his car fare check from the program
16 that he goes to.
17 Q. What's the program he goes to?
18 A. Oh, | don't know.
19 Q Do you understand the kind of program it
20 is?
21 A | believe it's a methadone program.
22 Q Do you know Mr. Jackson to use methadone
23 regularly?
24 A No.
25 Q. What makes you think it's a methadone
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CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 24
C. Abreu
program?
A Because right before | asked him to
leave, | -- | saw some bottles in his backpack from
a methadone program. | don't know if it's pills or
liquid. | don't know.
Q. Was you seeing those methadone bottles
in his backpack the catalyst for asking him to
leave?
10 A No.
11 Q. On the day of Mr. Jackson's accident,
12 which was in July of 2019, do you recall speaking
13 With him on that day?
14 A No.
15 Q Did you ever take Mr. Jackson to any
16 medical appointments in relation to this incident?
17 A No.
18 Q. To your knowledge, does Mr. Jackson
19 receive a source of income from anything other than
20 those checks that you receive?
21 A Nothing.
22 MR. ADELSBERG: That's what your
23 knowledge is, right?
24 THE WITNESS: That's from my knowledge,
25 yes.
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INDEX NO. 512150/2020
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NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023
CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 25
1 C. Abreu
2 Q. To your knowledge, has Mr. Jackson
3 worked since 2015?
4 A Since meeting Mr. Jackson, | have never
5 known him to work.
6 Q. Since 2003?
7 A. Yes. When | met him at Daytop.
8 Q. Was there a time where when Mr. Jackson
9 was living with you that he was able to help you
10 with chores around the house?
11 A. Yes. There were times when | first
12 started living there.
13 Q. Would that be just for -- maybe could
14 lyou quantify that time period where he was helping
15 lyou with chores from 2003 to 2010 or maybe more,
16 Imaybe less?
17 A Listen, he barely did anything. |
18 lalways had to ask him to help me do something so |
19 don't --
20 MR. ADELSBERG: Typical man.
21 THE WITNESS: Right.
22 MR. ADELSBERG: In most situations.
23 Q Do you have any children?
24 A. Yes.
25 Q. Are any of those children with Mr.
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CHRISTINE ABREU March 20, 2023
JACKSON vs VAN BLARCOM CLOSURES 26
C. Abreu
ackson?
A No. | have one son.
Q lam pretty much done. | am going to
5 Nave just a couple of more questions here. | am
6 just reviewing my notes. Did Mr. Jackson ever show
7 ou any of the medical records or anything like
8 hat that he may have received regarding this
9 incident?
10 A No. No.
11 Q Did he ever tell you what happened in
12 regards to this incident and how the accident
13 loccurred?
14 A He said he was walk
Preview
iD: OUN NK 06 U4: DV INDEX NO. 512150/2020 NYSCEF BOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 EXHIBIT INDEX NO. 512150/2020 NYSCEF BOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 In the Matter Of: JACKSON vs VAN BLARCOM CLOSURES 512150/2020 CHRISTINE ABREU March 20, 2023 INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2028 JACKSON vs VAN BLARCOM CLOSURES 2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS j--------------------------- RAY JACKSON, Plaintiff(s), -against- No. 512150/2020 AN BLARCOM CLOSURES, INC., Defendant(s). j---------------------------- 10 11 12 DEPOSITION OF CHRISTINE ABREU 13 New York, New York 14 Monday, March 20, 2023 15 16 17 18 19 Reported by: Yaffa Kaplan 20 JOB NO. 9455235 21 22 23 24 25 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2028 JACKSON vs VAN BLARCOM CLOSURES March 20, 2023 10:32 a.m. Deposition of CHRISTINE ABREU, held at the offices of Weber Gallagher Simpson Stapleton Fires & Newby, 1500 Broadway, New ork, New York, pursuant to Subpoena, before Yaffa Kaplan, a Notary Public of the 10 State of New York. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2028 JACKSON vs VAN BLARCOM CLOSURES 1 2 APPEARANCES: 3 4 SUBIN ASSOCIATES LLP. 5 Attorneys for Plaintiff 6 150 Broadway New York, New York 10038 BY: HOWARD ADELSBERG, ESQ 10 WEBER GALLAGHER SIMPSON STAPLETON FIRES & 11 NEWBY LLP 12 Attorneys for Defendant 13 1500 Broadway, Suite 2401 14 New York, New York 10036 15 BY: JERRY L. LYNCH, ESQ. 16 17 ALSO PRESENT: 18 EL] ESAKOFF 19 20 21 22 23 24 25 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2028 JACKSON vs VAN BLARCOM CLOSURES IT IS HEREBY STIPULATED AND AGREED by and between the attorneys for the espective parties herein, that filing, ealing and the same are hereby waived. IT IS FURTHER STIPULATED AND AGREED hat all objections, except as to the form bf the question, shall be reserved to the ime of the trial. 10 IT IS FURTHER STIPULATED AND AGREED 11 that the within deposition may be sworn to 12 land signed before any officer authorized to 13 administer an oath, with the same force 14 land effect as if signed and sworn to before 15 the Court. 16 17 18 19 20 21 22 23 24 25 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2028 JACKSON vs VAN BLARCOM CLOSURES C. Abreu CHRISTINE ABREU, calledasa witness, having been duly sworn by a Notary Public, was examined and testified as follows: EXAMINATION BY MR. LYNCH: Q. What is your name and address? A. Christine Abreu, 1158 Boynton Avenue, B-H, Bronx, New York 10472. 10 Q._ Ms. Abreu, how are you doing today? My 11 Iname is Jerry Lynch. | am the attorney for Van 12 Blarcom Closures. We have been brought here today 13 because of a lawsuit filed by a gentlemen | believe 14 that you know, Mr. Ray Jackson, and he has brought 15 la lawsuit against my client, and | just brought you 16 here by subpoena to ask you a few questions. And 17 before | begin, | just wanted to go over some 18 ground rules for a deposition. 19 So if you need to take a break for any 20 reason, just let me know. You are perfectly able 21 to do that. This isn't an interrogation. It's 22 ust questions. | just ask before you take any 23 kind of break, if there is a question that | have 24 lasked that has not yet been answered that you 25 lanswer the question and then take a break. For any 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2028 JACKSON vs VAN BLARCOM CLOSURES C. Abreu eason whatsoever, by the way. If there is anything that | ask that you Won't understand the first time, | am glad to ephrase it. Just let me know but | don't want you lo guess. Though sometimes | may ask for you to approximate so maybe you don't know exactly what ime or exactly the weather or exactly the measurement that | am asking for and | will just 10 lask for an approximation or you can say that you 11 lare approximating but no guessing. Does that make 12 sense? 13 A. Yes. 14 Q Because this is entirely recorded by the 15 reporter, | just ask for a clear record that only 16 lone of us speaks at a time. So you may anticipate 17 the answer to a question | am asking before | 18 finished asking it, but | will just ask that you 19 let me finish speaking before you answer, and | 20 will do the same for you. 21 If you do answer a question, | will 22 lassume that you understood it. And | also ask that 23 all your answers be verbal. Yes, no, | don't know, 24 lanything like that, because if you shake your head 25 lor you shrug, the court reporter won't be able to 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2028 JACKSON vs VAN BLARCOM CLOSURES C. Abreu lake it down, so then I will just follow up and say was that a yes, ano, or something else. Does that make sense? A. Yes. Q Lastly, | just ask that you keep your oice up for the benefit of myself and the reporter and the other attorneys. MR. ADELSBERG: If! may, just before we 10 proceed, just so you know who | am in this 11 whole theme, | represent Mr. Jackson. | am an 12 attorney. As | said to you before, my name is 13 Howard Adelsberg, and | am with the law firm 14 Subin Associates. As Mr. Lynch pointed out to 15 you, since you are here by subpoena, | am 16 basically here along for the ride to hear what 17 you have to say this morning, and later there 18 may come a point in time | may have some 19 follow-up questions for you, but both of us 20 are here to hear what you have to say. 21 A. Okay. 22 Q. This should be quick too. Are you okay 23 to begin? Do you want to take a restroom break or 24 lanything like that? 25 A No. 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2028 JACKSON vs VAN BLARCOM CLOSURES 1 C. Abreu 2 Q Just making sure. Have you reviewed any 3 materials before today's deposition? 4 A Say that again. 5 Q Have you reviewed any materials before 6 loday's deposition? A No. Q. Any documents you have looked at? A No. 10 Q._ Any photos? 11 A No. 12 Q Have you taken any drugs or medication 13 that might affect your ability to testify today? 14 A No. 15 Q In the last 24 hours, have you had any 16 lalcohol? 17 A No. 18 Q Is there any medication that you are 19 typically prescribed to take that you didn't take 20 today that might affect your ability to testify? 21 A No. 22 Q Have you ever been known by any other 23 Inames than the other one you gave to the court 24 reporter? 25 A No. 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2028 JACKSON vs VAN BLARCOM CLOSURES C. Abreu Q Do you have a middle name? A No. Q | am going to ask for the date of birth, but there will only be Xs in the record so that way here is no way to get the date of birth without lalking to me. A. XX/IXXIXXXX. Q | am also going to ask for your Social 10 Security number, but again only Xs will be placed 11 lon the record. 12 A. XXX-XX-XXXX. 13 Q How long have you lived at the address 14 lon Boynton Avenue that you gave to the reporter? 15 A Forty years. 16 MR. ADELSBERG: I'm sorry? 17 THE WITNESS: Forty years. 18 Q Do you own or rent that apartment? 19 A. Rent. 20 Q Is this in a walk-up building, or does 21 it have an elevator? 22 A Has an elevator. 23 Q Are you on the sixth floor? 24 A Yes. 25 Have you spoken to anyone about this 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 10 C. Abreu lawsuit? A No. Q Not even Mr. Jackson? A Oh, yes. | have spoken to him, yes. Q Have you spoken to Mr. Jackson about his lawsuit at all? A. Yes. Q. What did you talk about? 10 A. Wanted to know why was | being 11 subpoenaed if | have nothing to do with this. 12 Q. What did he say? 13 A He said he didn't know either. 14 Q Is there anything else in your 15 conversation that you spoke with him about 16 regarding the lawsuit? 17 A No. 18 Q. Was it ever mentioned that he brought 19 lyour name up at his deposition? 20 A No. 21 Q Okay. Are you presently employed? 22 A Yes. 23 What is your current role? 24 Security officer. 25 Where is that? 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 11 C. Abreu A | work for a company Prosegur, P-R-O-S-E-G-U-R. Q How long have you worked there? A | worked for that company for five ears. Q Are you married? A No. Q Are you divorced? 10 A No. 11 Q What is your highest level of education? 12 A Twelfth grade. 13 Q Do you have any certifications like? 14 A The security license. 15 Q That's what | was going to ask, any 16 icenses. Do you have any notes, calendars, 17 journals, or any other kind of written information 18 regarding this lawsuit that you have kept? 19 A No. 20 Q. To your knowledge, does anyone else have 21 lany type of documents or materials including Mr. 22 Vackson regarding this incident? 23 A No. 24 Q Have you ever filed for bankruptcy? 25 A No. 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 12 C. Abreu Have you ever been deposed before? Deposed? What is that word? What we are doing right now. No. This is the first time. Q Do you maintain any social media pages like Facebook or Instagram? Something else? A. Yes. Q. What do you have? Facebook? 10 A Facebook, Instagram, Tik Tok. 11 Q. What's your Facebook handle? 12 A. My name on Facebook? It would be my 13 Iname, Christina Abreu. 14 Q. What's your Instagram handle? 15 A. When you say "handle" -- 16 Q. The little @ sign and next to it is 17 going to be whatever your title for your profile. 18 A. @yahoo.com. 19 Q. Oh, I'm sorry. Normally in Instagram it 20 Will say maybe @CAbreu. 21 A No. It's just my name. 22 Q What's your Tik Tok handle? 23 A | have to look at it. 24 Q No problem. | just ask that a blank be 25 eft in the record, and once you get a copy of this 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 13 C. Abreu ranscript in like a month or so, | just ask that ou write that in if that's okay. fO BE FURNISHED: MR. ADELSBERG: Can we go off the record for one second? (Discussion off the record.) Q Do you know Mr. Ray Jackson? 10 A Yes. 11 Q How long have you known him? 12 A | have known him for 21 years. 13 Q And how did you first meet? 14 A We met in 2002 at Daytop Rehab. 15 Q | am going to ask questions about it. 16 But | am going to be delicate about this topic, so 17 if, at any point, you want to take a break again, 18 jplease let me know. 19 Why were you at Daytop Rehabilitation? 20 A. Oh, because | was smoking crack for 20 21 years. 22 Q. And do you know why Mr. Jackson was at 23 IDaytop? 24 A He came -- he told me he came straight 25 from Rikers Island, so | don't know why. 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 14 C. Abreu Q Did he ever have any discussions with ou regarding why he was in rehabilitation? A No. Q How long were you in the program logether? A. Thirty days at Far Rockaway until | otated upstate to Swan Lake. Q Did there come a point in time when you 10 finished rehabilitation? 11 A | was discharged from that program, and 12 l continued my rehabilitation in outpatient. 13 MR. ADELSBERG: Was that at Swan Lake. 14 A | left Swan Lake. | was discharged, 15 then | went to a rehab center in the Bronx 16 outpatient. 17 MR. ADELSBERG: Sorry to interrupt. 18 MR. LYNCH: No, you are fine. 19 Q Did there come a time where, to your 20 knowledge, Mr. Jackson was finished with 21 rehabilitation? 22 A No, he wasn't finished. 23 Q. To your knowledge, is Mr. Jackson still 24 n rehab? 25 A No, | don't think so. | don't believe 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 15 C. Abreu 0 Q Did there come a time where you completed the rehabilitation and you no longer were yoing? A. Yes, | completed. Q. When you completed, did you continue to peak to or have a friendly relationship with Mr. ackson? 10 A. Yes. 11 Q How would you describe the nature of 12 your relationship with Mr. Jackson? 13 A. Well, we were a couple for a while. But 14 Wwe are now just very good friends. | care for him 15 ery much. He is not doing well. 16 Q. When were you a couple? 17 A From '03 until 2000 -- 2021 or '22. So 18 from 2003 to 2022, to '22. We were together. 19 Q. Was there any particular reason why you 20 stopped seeing each other? 21 A | no longer cared to be ina 22 relationship with him. 23 Q. Why was that? 24 A | just had moved on. | don't care to be 25 nvolved with him. 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 16 1 C. Abreu 2 Q Did there ever come a time where you two 3 were living together? 4 A. There was a time, yes. Q. What time period were you living there? A. That's been off and on, so it wasn't nothing straight. So | can't remember all the Hifferent years. It's been off and on. Q. Can you approximate a time period of 10 lbeing off and on living together from, you know, a 11 certain year to another year? 12 A From like 2010 to most recently, which 13 would have been August of 2022 off and on. 14 Q. When you say "off and on", can you 15 describe that in terms of time by saying a week at 16 la time? A day at a time? 17 A. Months at a time. 18 Q. At the time when Mr. Jackson wasn't 19 iving with you, do you know where he would live? 20 A No. 21 Q Did you ever inquire as to where he 22 would go when he wasn't living with you? 23 A No. 24 Q. What would be the circumstances by which 25 lhe would no longer be living with you for a period 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 17 C. Abreu bf time? A Because if you are not going to come nome for periods of days, then you stay whenever ou have been staying at. Q. So there would be periods of days where ne would not come home? A. Weeks, yes. Q. When Mr. Jackson was living with you, 10 did he provide you any rent? 11 A No, not -- not monetary. You know, like 12 through public assistance from living there. 13 Q Oh, sure. 14 A Rent check. 15 Q Okay. How much was that for? 16 A 215 amonth. 107.50 every two weeks. 17 Q These would be issued from some kind of 18 lagency but not through him directly? 19 A HR. 20 Q. To your knowledge, did Mr. Jackson ever 21 luse methadone in your presence? 22 A Never. 23 Q Do you know what methadone is? 24 A Yes. 25 Q It's for the treatment of heroin? 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 18 1 C. Abreu 2 A. Yes, right. 3 Q Did Mr. Jackson during the time period 4 pf the last three years, four years ever use heroin 5 in your presence? 6 A No. 7 MR. ADELSBERG: If you can just clarify 8 the three or four years, when was the last 9 time you saw Mr. Jackson? 10 THE WITNESS: The last time | saw 11 Jackson was two or three days ago. 12 MR. ADELSBERG: Okay. 13 Q._ And the entire time that Mr. Jackson was 14 iving with you from 2003 to until 2022 off and on, 15 did you ever see Mr. Jackson use methadone in your 16 lpresence? 17 A No. 18 Q._ Are you familiar with an accident that 19 loccurred in July 30th of 2019 involving Mr. 20 Vackson? 21 A Where he fell? 22 Q Where he fell. 23 A Yes. He told me about that. 24 Q Did he ever speak to you about how he 25 fell, about the accident? 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 19 1 C. Abreu 2 A No. He just stated that he fell in 3 ront of some storefront in Brooklyn. Pavement was 4 messed up and there were no lights there. That was 5 at a time where he wasn't staying with me. 6 Q Did there come a time to your knowledge 7 when Mr. Jackson underwent a serious back surgery 8 in connection with this accident? A. Yes. 10 Q Do you remember around what time that 11 was or what day? 12 A No. No. 13 Q. After he had that surgery, did there 14 come a time where he was living with you? 15 A. Yes. Off and -- yes, he was doing very 16 lad. 17 Q Do you recall whether or not he lived 18 with you almost immediately following the surgery? 19 A No. No. 20 Q. Was it weeks after the surgery that 21 lhe -- 22 A It had to be weeks after because | 23 didn't realize he had the surgery when | first saw 24 him. 25 Q. When you first saw him weeks after the 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 20 C. Abreu urgery, what was his condition based on what Ou -- A. Dead man walking. He was terrible. lerrible. Q In your opinion, did his condition ignificantly change from the way that he was bodily? And by your observations, was there a ignificant change from before the accident to 10 lafter the accident? 11 A. Yes. There was a big change. 12 Q. What were some of the changes that you 13 Inoticed? 14 A. Changes of depression. And because | 15 feel the surgery was botched. 16 Q. Why do you feel that? 17 A Because he would very -- every so often 18 lhe would like paralyze on one side. He had no 19 feelings, and he would at any time anywhere he 20 would just pass out. 21 Q Did you feel that that was the changes 22 you noticed in him after the surgery? 23 A. Yes. 24 Q. What about after the accident but before 25 the surgery? What was his condition? 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 21 C. Abreu A He wasn't -- he wasn't with me. | Hidn't see him physically. MR. ADELSBERG: I'm sorry. Could you repeat that? THE WITNESS: | didn't see him after the accident. | guess where he was staying, he couldn't move. He said he couldn't really move around. 10 Q Following the surgery, the weeks 11 following where you said that he came to stay with 12 lyou, how long did he stay with you do you remember 13 for that time period after that surgery? 14 A. Well, it was months after the surgery 15 that he came to me. By that time, you know, he had 16 told me about how he passes out from time to time 17 land how he had to look into finding out what's 18 wrong with him because the surgery didn't seem to 19 go the way it was planned. 20 Q Following the surgery, when he came to 21 stay with you the months after, was he able to 22 provide you any assistance with chores around the 23 house? 24 A No. 25 Q. Were you taking care of him during that 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 22 C. Abreu ime? A Sure. Yes, | was. Q. What sort of tasks were you doing at hat time? A Just make sure he eats because very -- Q. Anything else besides cooking for him? A. Making sure his clothes were washed and make sure, you know, he had his toiletries and his 10 ittle things that he needed. 11 Q Did there ever come a time following the 12 surgery where you saw Mr. Jackson's condition 13 mprove? 14 A No. 15 Q. When you saw Mr. Jackson two to three 16 days ago, how would you describe his condition now 17 n relation to how you saw him following the 18 surgery back in, you know, 2021 or so? 19 A He still is very depressed because he is 20 homeless. He has been put up in a hotel. He was 21 lon Wards Island until that was closed down, and he 22 Was put up in a hotel room in Woodside, Queens in 23 (Comfort Inn, which he does not like. 24 Q. When was the last time Mr. Jackson 25 stayed with you? 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 23 1 C. Abreu 2 A Before last -- the summer before. About 3 Aa year now. 4 Q. Was -- MR. ADELSBERG: I'm sorry. Was that about a year now? THE WITNESS: Yes. He left in September of 20 --'22. Q Even though he does not live with you 10 lanymore on an off-and-on basis, do you still see 11 Mr. Jackson? 12 A. Yes. | saw him two or three days ago 13 lbecause he receives -- | allow him to use my 14 address to receive mail. He has his mail address, 15 so he picks us his car fare check from the program 16 that he goes to. 17 Q. What's the program he goes to? 18 A. Oh, | don't know. 19 Q Do you understand the kind of program it 20 is? 21 A | believe it's a methadone program. 22 Q Do you know Mr. Jackson to use methadone 23 regularly? 24 A No. 25 Q. What makes you think it's a methadone 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 24 C. Abreu program? A Because right before | asked him to leave, | -- | saw some bottles in his backpack from a methadone program. | don't know if it's pills or liquid. | don't know. Q. Was you seeing those methadone bottles in his backpack the catalyst for asking him to leave? 10 A No. 11 Q. On the day of Mr. Jackson's accident, 12 which was in July of 2019, do you recall speaking 13 With him on that day? 14 A No. 15 Q Did you ever take Mr. Jackson to any 16 medical appointments in relation to this incident? 17 A No. 18 Q. To your knowledge, does Mr. Jackson 19 receive a source of income from anything other than 20 those checks that you receive? 21 A Nothing. 22 MR. ADELSBERG: That's what your 23 knowledge is, right? 24 THE WITNESS: That's from my knowledge, 25 yes. 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 25 1 C. Abreu 2 Q. To your knowledge, has Mr. Jackson 3 worked since 2015? 4 A Since meeting Mr. Jackson, | have never 5 known him to work. 6 Q. Since 2003? 7 A. Yes. When | met him at Daytop. 8 Q. Was there a time where when Mr. Jackson 9 was living with you that he was able to help you 10 with chores around the house? 11 A. Yes. There were times when | first 12 started living there. 13 Q. Would that be just for -- maybe could 14 lyou quantify that time period where he was helping 15 lyou with chores from 2003 to 2010 or maybe more, 16 Imaybe less? 17 A Listen, he barely did anything. | 18 lalways had to ask him to help me do something so | 19 don't -- 20 MR. ADELSBERG: Typical man. 21 THE WITNESS: Right. 22 MR. ADELSBERG: In most situations. 23 Q Do you have any children? 24 A. Yes. 25 Q. Are any of those children with Mr. 800.211.DEPO (3376) EsquireSolutions.com INDEX NO. 512150/2020 FILED: KINGS COUNTY CLERK 06/15/2023 04:59 PM NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 06/15/2023 CHRISTINE ABREU March 20, 2023 JACKSON vs VAN BLARCOM CLOSURES 26 C. Abreu ackson? A No. | have one son. Q lam pretty much done. | am going to 5 Nave just a couple of more questions here. | am 6 just reviewing my notes. Did Mr. Jackson ever show 7 ou any of the medical records or anything like 8 hat that he may have received regarding this 9 incident? 10 A No. No. 11 Q Did he ever tell you what happened in 12 regards to this incident and how the accident 13 loccurred? 14 A He said he was walk