Preview
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
Ex. D
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 36
2 Q Were you referred to physical therapy by
3 Dr. Greisberg?
4 A Yes.
5 Q Who did he refer you to?
!
6 A He referred me to a physical therapy in
7 Canarsie. 1
8 Q When did you start going to physical
9 therapy, was that November around or after?
10 A Around November.
11 Q How many times a week did you go to
12 physical therapy?
14 Q For how long did you attend physical
15 therapy?
16 A About four months.
17 Q Four months consecutively, right, every
18 month?
19 A Yes.
20 Q Three times a week?
21 A Yes.
22 Q During this time, did you see
23 Dr. Greisberg during the four months?
24 A Yes.
25 Q How often?
5162485-2222 BEE REPORTING AGENCY, INC, 212-327-350C
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 37
2 A like -- it was about
Probably every every
3 two weeks.
4 Q That's with your physical therapy you
5 would see Dr. --
6 A Yes.
7 Q Why did you stop physical therapy after
8 four months, was that your choice or was that the
9 doctor's assessment, that you no longer needed it?
10 AwarøEngagW W@Weigage
11 Q Why, why did you stop?
12 A I seen it wasn't really doing nothing for
13 me and I was learning to do better on my own, in my
14 own house.
15 Q Once you stopped the physical therapy,
16 what type of treatment were you getting after that?
17 I'm assuming you were still following up with
18 Dr. Greisberg, right?
19 A Yes.
20 Q Still every two weeks or did it extend
21 out? .
22 A It extend out a little bit. I was still
23 in a boot. I had a boot on after that.
24 Q You wore the boot after the physical
25 therapy was over, right?
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-350t
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 38
2 A Uh-uh. I wore the boot during and
3 after.
4 Q We're going to go after the physical
5 therapy. After you stopped receiving physical
6 therapy, were you referred to any other doctors, an
7 orthopedist or any other doctors? Did Dr. Greisberg
8 refer you to any other type of physician?
9 A No.
z
10 Q How frequently were you seeing j
11 206WetWB as it still every two weeks or did
12 it become once a month?
13 tn©5M &MlMVP
14 Q Just monthly?
15 A Yes.
.
16 Q What did he say about your progress at
17 that point, when you were seeing him monthly only?
18 How did he assess your progress?
19 f 5 Ef&RatWeimpsemesis
20 Q Were you still wearing the walking boot
21 at the time you were seeing him on a monthly
22 basis?
23 A Yes.
24 . Q When was the boot removed?
25 A Probably like maybe B@]ammaya
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 39
2 Q So that would be February 2018?
3 A Uh-hub. Yes, but I was still on
4 crutches.
5 Q At this point in January and February of
6 2018 when you were still on crutches, were you
7 able to leave the house to go out, do grocery
.
8 shopping, do normal activities of daily living?
9 Ameersma@41spazingneeslrareEeardeeB&P'aF"Ef5Yf&ffiY¶@Tft.
10 Q That would be the only time you would
11 leave the house at that point, right?
12 A Yes. !
13 Q So you weren't able to do anything
14 outside of doctor's appointments, in terms of like
15 the things you did prior to your incident, shopping,
16 going out to take care of any errands or anything
17 like that?
18 A No.
19 Q I asked you. I'm going to ask this one
20 more time.
21 Dr. Greisberg, at this point, February
22 2018, when the boot was removed and you were still
23 on crutches, he's the only doctor that you're
24 seeing, right?
25 A Yes. 1
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-350(
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAIAH STEVENS 40
2 Q Treating with, okay.
3 At what point were you able to walk
4 without the crutches? Give me a time frame.
5 A Probably like the middle of March, the
6 end of March.
7 Q By the end of March, you didn't need the
were you able to leave the house at --
8 crutches,
9 when you didn't have the crutches, you didn't have
10 to rely on the crutches, were you able to leave the
11 house at that point to do activities, normal daily
12 activities?
13 A No. It was still very hard for me to
14 carry bags, all of that, to carry bags, to walk far
15 blocks. It's a lot of pain on the ankle.
16 Q At that point you still were pretty much
17 homebound?
18 A Yes.
19 Q At what point did your healing progress
20 to the point where you could leave the house and 1
21 resume some normal activities, regular activities,
22 that you used to do before the incident?
23 MR. JANOWITZ: Objection to the
form of the question because when you --
24
25 you're talking about normal activities.
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 41
2 There's some things she still can't do,
3 some things she can, some she can't. So
4 you're generalizing everything all in
5 one.
6 MR. CARR: All right.
7 MR. JANOWITZ: So if she gives an
8 answer it's a misleading question and
9 answer.
10 MR. CARR: I'll strike that.
11 Q Tell me what you were able to do, the
12 things you were able to do.
13 MR. JANOWITZ: When, today or back
14 in February?
15 Q After you no longer needed the crutches
16 we're talking the end of March of 2018, your
17 condition had improved some. Now what were some of
18 the things that you were now able to do that you
19 weren't able to do before?
20 A I can kinda bathe myself. I can cook for
21 myself. I could try to cleanup, but I get tired, a
22 lot of pain on my ankle. That's about it.
23 Q Did you still have a home health aide at
24 this time?
25 A No. â
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 42
2 Q When did you no longer need her? When
3 did she leave?
4 A Probably like the ending of March.
5 MR. JANOWITZ: The what?
6 THE WITNESS: March.
--
7 Q The same March
8 MR. JANOWITZ: What did you just
9 say?
10 THE WITNESS: March. He said when
11 did the home attendant leave.
12 MR. CARR: Right.
13 A When I stopped getting a home attendant?
14 Q Right, have her services.
15 A Right.
16 So like probably the end of March. No.
17 No. No. Let me see. April. Yeah.
18 MR. JANOWITZ: Off the record.
19 (Whereupon, a discussion was held
20 off the record.) j
21 Q When you no longer needed the crutches,
22 did you --
23 A No.
24 Q You didn't? She was no longer there?
25 A No.
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 43
2 Q So approximately how long before then was
3 she released or no longer needed at the home?
4 A Say about the beginning of February.
5 Q You mentioned that your daughter lived
6 with you. Was she still there at that time?
7 A Yes.
8 Q Did your daughter at that time assist you
9 with your --
10 A Yes. She helped do everything.
11 Q You said helped with everything?
12 A Yes. As in helping me cook, as in
13 washing, as in going to the grocery store, as in
14 cleanup the house.
15 Q Okay.
16 A The things that the home attendant was
17 doing.
18 Q Does she still assist now? At this
19 point, does your daughter still assist or are you
20 able to do most of the things?
21 A She still help me with grocery shopping.
22 Like cleanup the house 'cause my leg still hurts she
23 still helps me. Cooking.
24 Q Let's come into the present. Let's say
25 2019, how often do you see Dr. Greisberg now?
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 44
2 A I don't see him.
3 Q When did you stop?
4 A Like in March.
5 Q Of?
6 A 2018.
7 MR. JANOWITZ: This last March?
8 We're in 2019.
9 A Excuse me. I stopped him -- let
seeing
10 me see. I stopped seeing him, yeah, like after the
11 surgeries and stuff. I can't exactly remember
12 Q Let's see if I can help.
13 When you were able to walk without the
14 crutches, you said that was around the end of March
15 of 2018, right?
16 A Yes.
17 Q Were you still seeing him then?
18 A I seen him one time.
19 Q After?
20 A Yes.
21 And then that was --
Q
22 A I seen him no more.
23 Q Okay.
24 A But...
25 Q But?
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 45
2 A The last time I was with him, I still had
3 a lot of pain with the screws. I have six big
4 screws, seven little screws and a plate. He told me
5 I have so much pain that the plate could be removed
6 but not the screws, but I decided not to go back
7 through it because it was so much on my heart to g.et
8 the plate removed. Yeah, that's what he said could
9 be removed, the plate but not the screws. So I
10 decided I don't think that I am because it's so much
11 on my heart.
12 Q This was at your last visit with him?
13 A Yes.
14 Q I'm going to put that at the end of March
15 2018.
16 MR. JANOWITZ: We have that as a
17 couple of months ago. I think it's March
18 of 2019.
19 THE WITNESS: Right.
20 Q So it's March 2019?
21 A Yes.
22 Q He told you that the plate could be
23 removed, the screws had to remain in place?
24 A Yes.
25 Q To this date, is the plate still in your
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 46
2 ankle?
3 A Yes.
4 Q And the screws as well?
5 A Yes.
6 Q At the present time, since you last saw
Dr. -- I alluded to this question. I'm
7 Greisberg
to again just to confirm -- have you
8 going ask it
9 seen any other doctors?
10 A No.
11 MR. JANOWITZ: Off the record.
12 (Whereupon, a discussion was held
13 off the record.)
14 Q Have you received any additional medical
15 treatment or other medical treatment since
16 Dr. Greisberg?
17 A No.
18 Q Physical therapy, that's a little
19 different than medical treatment.
20 Have you gone back to any physical
21 therapy?
22 A No.
23 Q We already spoke about some of the
24 activities that you're able to do with some
25 difficulty, such as cleaning you say is difficult
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023
1 NAJAH STEVENS 47
2 but you're able to bathe and do some cooking.
3 Has that gotten better for you? Are you
4 able to do those things longer now or with less pain
5 now?
6 A It's still a lot of pain.
7 Q For what, bathing, cooking and
8 cleaning?
9 A Right.
10 Q All of them?
11 A Yeah. It's hard for me to ride a bike,
12 to roller skate, to exercise.
13 Q Did you exercise prior to?
14 A Yes.
15 Q You said roller skate, bike ride.
16 A Ice skating.
17
Preview
FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 Ex. D FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 36 2 Q Were you referred to physical therapy by 3 Dr. Greisberg? 4 A Yes. 5 Q Who did he refer you to? ! 6 A He referred me to a physical therapy in 7 Canarsie. 1 8 Q When did you start going to physical 9 therapy, was that November around or after? 10 A Around November. 11 Q How many times a week did you go to 12 physical therapy? 14 Q For how long did you attend physical 15 therapy? 16 A About four months. 17 Q Four months consecutively, right, every 18 month? 19 A Yes. 20 Q Three times a week? 21 A Yes. 22 Q During this time, did you see 23 Dr. Greisberg during the four months? 24 A Yes. 25 Q How often? 5162485-2222 BEE REPORTING AGENCY, INC, 212-327-350C FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 37 2 A like -- it was about Probably every every 3 two weeks. 4 Q That's with your physical therapy you 5 would see Dr. -- 6 A Yes. 7 Q Why did you stop physical therapy after 8 four months, was that your choice or was that the 9 doctor's assessment, that you no longer needed it? 10 AwarøEngagW W@Weigage 11 Q Why, why did you stop? 12 A I seen it wasn't really doing nothing for 13 me and I was learning to do better on my own, in my 14 own house. 15 Q Once you stopped the physical therapy, 16 what type of treatment were you getting after that? 17 I'm assuming you were still following up with 18 Dr. Greisberg, right? 19 A Yes. 20 Q Still every two weeks or did it extend 21 out? . 22 A It extend out a little bit. I was still 23 in a boot. I had a boot on after that. 24 Q You wore the boot after the physical 25 therapy was over, right? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-350t FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 38 2 A Uh-uh. I wore the boot during and 3 after. 4 Q We're going to go after the physical 5 therapy. After you stopped receiving physical 6 therapy, were you referred to any other doctors, an 7 orthopedist or any other doctors? Did Dr. Greisberg 8 refer you to any other type of physician? 9 A No. z 10 Q How frequently were you seeing j 11 206WetWB as it still every two weeks or did 12 it become once a month? 13 tn©5M &MlMVP 14 Q Just monthly? 15 A Yes. . 16 Q What did he say about your progress at 17 that point, when you were seeing him monthly only? 18 How did he assess your progress? 19 f 5 Ef&RatWeimpsemesis 20 Q Were you still wearing the walking boot 21 at the time you were seeing him on a monthly 22 basis? 23 A Yes. 24 . Q When was the boot removed? 25 A Probably like maybe B@]ammaya 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 39 2 Q So that would be February 2018? 3 A Uh-hub. Yes, but I was still on 4 crutches. 5 Q At this point in January and February of 6 2018 when you were still on crutches, were you 7 able to leave the house to go out, do grocery . 8 shopping, do normal activities of daily living? 9 Ameersma@41spazingneeslrareEeardeeB&P'aF"Ef5Yf&ffiY¶@Tft. 10 Q That would be the only time you would 11 leave the house at that point, right? 12 A Yes. ! 13 Q So you weren't able to do anything 14 outside of doctor's appointments, in terms of like 15 the things you did prior to your incident, shopping, 16 going out to take care of any errands or anything 17 like that? 18 A No. 19 Q I asked you. I'm going to ask this one 20 more time. 21 Dr. Greisberg, at this point, February 22 2018, when the boot was removed and you were still 23 on crutches, he's the only doctor that you're 24 seeing, right? 25 A Yes. 1 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-350( FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAIAH STEVENS 40 2 Q Treating with, okay. 3 At what point were you able to walk 4 without the crutches? Give me a time frame. 5 A Probably like the middle of March, the 6 end of March. 7 Q By the end of March, you didn't need the were you able to leave the house at -- 8 crutches, 9 when you didn't have the crutches, you didn't have 10 to rely on the crutches, were you able to leave the 11 house at that point to do activities, normal daily 12 activities? 13 A No. It was still very hard for me to 14 carry bags, all of that, to carry bags, to walk far 15 blocks. It's a lot of pain on the ankle. 16 Q At that point you still were pretty much 17 homebound? 18 A Yes. 19 Q At what point did your healing progress 20 to the point where you could leave the house and 1 21 resume some normal activities, regular activities, 22 that you used to do before the incident? 23 MR. JANOWITZ: Objection to the form of the question because when you -- 24 25 you're talking about normal activities. 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 41 2 There's some things she still can't do, 3 some things she can, some she can't. So 4 you're generalizing everything all in 5 one. 6 MR. CARR: All right. 7 MR. JANOWITZ: So if she gives an 8 answer it's a misleading question and 9 answer. 10 MR. CARR: I'll strike that. 11 Q Tell me what you were able to do, the 12 things you were able to do. 13 MR. JANOWITZ: When, today or back 14 in February? 15 Q After you no longer needed the crutches 16 we're talking the end of March of 2018, your 17 condition had improved some. Now what were some of 18 the things that you were now able to do that you 19 weren't able to do before? 20 A I can kinda bathe myself. I can cook for 21 myself. I could try to cleanup, but I get tired, a 22 lot of pain on my ankle. That's about it. 23 Q Did you still have a home health aide at 24 this time? 25 A No. â 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 42 2 Q When did you no longer need her? When 3 did she leave? 4 A Probably like the ending of March. 5 MR. JANOWITZ: The what? 6 THE WITNESS: March. -- 7 Q The same March 8 MR. JANOWITZ: What did you just 9 say? 10 THE WITNESS: March. He said when 11 did the home attendant leave. 12 MR. CARR: Right. 13 A When I stopped getting a home attendant? 14 Q Right, have her services. 15 A Right. 16 So like probably the end of March. No. 17 No. No. Let me see. April. Yeah. 18 MR. JANOWITZ: Off the record. 19 (Whereupon, a discussion was held 20 off the record.) j 21 Q When you no longer needed the crutches, 22 did you -- 23 A No. 24 Q You didn't? She was no longer there? 25 A No. 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 43 2 Q So approximately how long before then was 3 she released or no longer needed at the home? 4 A Say about the beginning of February. 5 Q You mentioned that your daughter lived 6 with you. Was she still there at that time? 7 A Yes. 8 Q Did your daughter at that time assist you 9 with your -- 10 A Yes. She helped do everything. 11 Q You said helped with everything? 12 A Yes. As in helping me cook, as in 13 washing, as in going to the grocery store, as in 14 cleanup the house. 15 Q Okay. 16 A The things that the home attendant was 17 doing. 18 Q Does she still assist now? At this 19 point, does your daughter still assist or are you 20 able to do most of the things? 21 A She still help me with grocery shopping. 22 Like cleanup the house 'cause my leg still hurts she 23 still helps me. Cooking. 24 Q Let's come into the present. Let's say 25 2019, how often do you see Dr. Greisberg now? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 44 2 A I don't see him. 3 Q When did you stop? 4 A Like in March. 5 Q Of? 6 A 2018. 7 MR. JANOWITZ: This last March? 8 We're in 2019. 9 A Excuse me. I stopped him -- let seeing 10 me see. I stopped seeing him, yeah, like after the 11 surgeries and stuff. I can't exactly remember 12 Q Let's see if I can help. 13 When you were able to walk without the 14 crutches, you said that was around the end of March 15 of 2018, right? 16 A Yes. 17 Q Were you still seeing him then? 18 A I seen him one time. 19 Q After? 20 A Yes. 21 And then that was -- Q 22 A I seen him no more. 23 Q Okay. 24 A But... 25 Q But? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 45 2 A The last time I was with him, I still had 3 a lot of pain with the screws. I have six big 4 screws, seven little screws and a plate. He told me 5 I have so much pain that the plate could be removed 6 but not the screws, but I decided not to go back 7 through it because it was so much on my heart to g.et 8 the plate removed. Yeah, that's what he said could 9 be removed, the plate but not the screws. So I 10 decided I don't think that I am because it's so much 11 on my heart. 12 Q This was at your last visit with him? 13 A Yes. 14 Q I'm going to put that at the end of March 15 2018. 16 MR. JANOWITZ: We have that as a 17 couple of months ago. I think it's March 18 of 2019. 19 THE WITNESS: Right. 20 Q So it's March 2019? 21 A Yes. 22 Q He told you that the plate could be 23 removed, the screws had to remain in place? 24 A Yes. 25 Q To this date, is the plate still in your 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 46 2 ankle? 3 A Yes. 4 Q And the screws as well? 5 A Yes. 6 Q At the present time, since you last saw Dr. -- I alluded to this question. I'm 7 Greisberg to again just to confirm -- have you 8 going ask it 9 seen any other doctors? 10 A No. 11 MR. JANOWITZ: Off the record. 12 (Whereupon, a discussion was held 13 off the record.) 14 Q Have you received any additional medical 15 treatment or other medical treatment since 16 Dr. Greisberg? 17 A No. 18 Q Physical therapy, that's a little 19 different than medical treatment. 20 Have you gone back to any physical 21 therapy? 22 A No. 23 Q We already spoke about some of the 24 activities that you're able to do with some 25 difficulty, such as cleaning you say is difficult 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: KINGS COUNTY CLERK 11/07/2023 09:44 AM INDEX NO. 521039/2017 NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 11/07/2023 1 NAJAH STEVENS 47 2 but you're able to bathe and do some cooking. 3 Has that gotten better for you? Are you 4 able to do those things longer now or with less pain 5 now? 6 A It's still a lot of pain. 7 Q For what, bathing, cooking and 8 cleaning? 9 A Right. 10 Q All of them? 11 A Yeah. It's hard for me to ride a bike, 12 to roller skate, to exercise. 13 Q Did you exercise prior to? 14 A Yes. 15 Q You said roller skate, bike ride. 16 A Ice skating. 17