On August 26, 2021 a
EXHIBIT(S) - J (Motion #003) - DIRECT-DEFENSE AIDBE CASTHELIOLA
was filed
involving a dispute between
Silas Ajawuihe,
and
Carmen Mathe,
Jane Mathe
The First Name Being Fictitious,
Lawrence Mathe,
for Torts - Other (Dog Attack)
in the District Court of Richmond County.
Preview
FILED: RICHMOND COUNTY CLERK 04/05/2023 10:03 AM INDEX NO. 151617/2021
NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 04/05/2023
"J"
EXHIBIT
FILED: RICHMOND COUNTY CLERK 04/05/2023 10:03 AM INDEX NO. 151617/2021
NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 04/05/2023
Direct-Defense-Aidbe Castheliola
1 answer, three, one voice at a time. If the attorney's
2 talking wait for that voice to be completed before you
3 answer and, fourth, if you hear the word objection, stop
4 so I can rule on that objection.
5 Can you all do that?
6 THE WITNESS: Yes, your Honor.
7 THE COURT: Mr. Riso, you may inquire.
8 MR. RISO: Thank you.
9 DIRECT EXAMINATION BY MR. RISO:
10 Q. Good afternoon, Mrs. Castheliola. Have we ever met?
11 A. No.
12 Q. Are you employed?
13 A. Yes, sir.
14 Q. By whom?
15 A. United States Postal Service, I'm a letter carrier.
16 THE COURT: Thank you for your service.
17 THE WITNESS: Thank you.
18 THE COURT: I know that you all worked very hard
19 during Covid too.
20 THE WITNESS: And I was pregnant at the time, I
21 worked all through Covid.
22 THE COURT: That's a blessing, I hope the baby
23 is okay.
24 THE WITNESS: Yes, she is, thank you.
25 Q. How long have you been a letter carrier?
- DR -
FILED: RICHMOND COUNTY CLERK 04/05/2023 10:03 AM INDEX NO. 151617/2021
NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 04/05/2023
Direct-Defense-Aidbe Castheliola
1 A. Eighteen years.
2 Q. Does one of your routes contain an address of 405
3 Greeley Avenue?
4 A. Yes, sir.
5 Q. How long have you delivered to 405 Greeley Avenue?
6 A. I have been delivering there for the past 7 years.
7 Q. So you would have been delivering there in May of
8 2021?
9 A. Yes.
10 Q. And as a postal carrier do you generally know what
11 homes have all the dogs on your routes?
12 A. Yes, sir, I know the dogs by names, I carry dog
13 treats with me.
14 Q. Why do you need to know that?
15 A. It's important.
16 Q. Why?
17 A. Just in case we get attacked, dog bites.
18 Q. Did you ever get attacked?
19 A. Yes, I did.
20 Q. And do you --
so, actually carry any
21 A. Yes, we carry mail.
22 Q. Did you ever see a dog while delivering a letter in
23 those seven years at 405 Greeley Avenue?
24 A. Never.
25 Q. Is there a cage or enclosure at 405 Greeley Avenue?
- DR -
Document Filed Date
April 05, 2023
Case Filing Date
August 26, 2021
Category
Torts - Other (Dog Attack)
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Preview
FILED: RICHMOND COUNTY CLERK 04/05/2023 10:03 AM INDEX NO. 151617/2021 NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 04/05/2023 "J" EXHIBIT FILED: RICHMOND COUNTY CLERK 04/05/2023 10:03 AM INDEX NO. 151617/2021 NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 04/05/2023 Direct-Defense-Aidbe Castheliola 1 answer, three, one voice at a time. If the attorney's 2 talking wait for that voice to be completed before you 3 answer and, fourth, if you hear the word objection, stop 4 so I can rule on that objection. 5 Can you all do that? 6 THE WITNESS: Yes, your Honor. 7 THE COURT: Mr. Riso, you may inquire. 8 MR. RISO: Thank you. 9 DIRECT EXAMINATION BY MR. RISO: 10 Q. Good afternoon, Mrs. Castheliola. Have we ever met? 11 A. No. 12 Q. Are you employed? 13 A. Yes, sir. 14 Q. By whom? 15 A. United States Postal Service, I'm a letter carrier. 16 THE COURT: Thank you for your service. 17 THE WITNESS: Thank you. 18 THE COURT: I know that you all worked very hard 19 during Covid too. 20 THE WITNESS: And I was pregnant at the time, I 21 worked all through Covid. 22 THE COURT: That's a blessing, I hope the baby 23 is okay. 24 THE WITNESS: Yes, she is, thank you. 25 Q. How long have you been a letter carrier? - DR - FILED: RICHMOND COUNTY CLERK 04/05/2023 10:03 AM INDEX NO. 151617/2021 NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 04/05/2023 Direct-Defense-Aidbe Castheliola 1 A. Eighteen years. 2 Q. Does one of your routes contain an address of 405 3 Greeley Avenue? 4 A. Yes, sir. 5 Q. How long have you delivered to 405 Greeley Avenue? 6 A. I have been delivering there for the past 7 years. 7 Q. So you would have been delivering there in May of 8 2021? 9 A. Yes. 10 Q. And as a postal carrier do you generally know what 11 homes have all the dogs on your routes? 12 A. Yes, sir, I know the dogs by names, I carry dog 13 treats with me. 14 Q. Why do you need to know that? 15 A. It's important. 16 Q. Why? 17 A. Just in case we get attacked, dog bites. 18 Q. Did you ever get attacked? 19 A. Yes, I did. 20 Q. And do you -- so, actually carry any 21 A. Yes, we carry mail. 22 Q. Did you ever see a dog while delivering a letter in 23 those seven years at 405 Greeley Avenue? 24 A. Never. 25 Q. Is there a cage or enclosure at 405 Greeley Avenue? - DR -