Preview
FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023
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FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023
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IN THE MATTER OF THE CLAIM OF:
ZSOLT MADARI
PEAK PROPERTY AND CASUALTY INSURANCE
CORPORATION
CLAIM NUMBER: 97A820969
DOL: JULY 17, 2021
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April 21, 2022
10:18 A.M.
EXAMINATION UNDER OATH of ZSOLT MADARI, the
witness herein, taken by the attorney for Peak
Property and Casualty Insurance, pursuant to the
terms and conditions of the insurance policy,
held via web conference, and held before
Diane Chen, a Notary Public and shorthand
reporter of the State of New York on the above
stated day and time.
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NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023
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1 A P P E A R A N C E S :
2
ALAHVERDIAN VAN LEUVAN, P.C.
3 Attorneys for Respondent
295 Broadway- 1st floor
4 Bethpage, New York 11714
5 BY: SHONT VOSKERIJIAN, ESQ
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516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
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NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023
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1 THE REPORTER: It is hereby stipulated
2 and agreed by and between counsel for all
3 parties present this or Examination Under
4 Oath is being conducted remotely by video
5 conference, and that the court reporter,
6 witness and all counsel are in separate
7 remote locations and participating via Zoom
8 or any web conference meeting platform under
9 the control of the court reporting agency.
10 It is further stipulated that this
11 videoconference will not be recorded in any
12 manner and that any recording, without the
13 express written consent of all parties,
14 shall be considered unauthorized.
15 Before I swear in the witness, I will ask
16 each counsel to stipulate on the record that
17 I, the court reporter, may swear in the
18 witness even though I am not physically in
19 the presence of the witness and that there
20 is no objection to that at this time, nor
21 will there be an objection at a future date.
22 MR. VOSKERIJIAN: No objection.
23 THE REPORTER: Before we begin, sir, do
24 you have a photo ID you can hold up to the
25 camera for us?
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1 (Whereupon, the witness held his ID up
2 to the camera.)
3 Z S O L T M A D A R I,
4 the witness herein, having first been duly
5 sworn by Diane Chen, a Notary Public in and for
6 the State of New York, was examined and
7 testified as follows:
8 EXAMINATION BY
9 SHONT VOSKERIJIAN, ESQ.:
10 Q State your name for the record, please.
11 A Zsolt Madari.
12 Q Please state your address.
13 A 80 South Avenue, Bridgeport,
14 Connecticut.
15 Q Good morning, sir. I just want to
16 confirm: Is Zsolt your first name or your
17 last name?
18 A Yes, my first name. In my country, we
19 change it. We have the last name after the first
20 name. But my name is Zsolt, my first name.
21 Q Got it. I just want to make sure I'm
22 calling you by your first name.
23 A Okay, thank you.
24 Q Good morning, Mr. Zsolt. My name is
25 Shont Voskerijian, and I was retained by Peak
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NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023
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1 Zsolt Madari
2 Property to conduct what's called an Examination
3 Under Oath today.
4 So the court reporter, the woman here,
5 she's going to be writing everything down so
6 there is a record of this conversation. But I
7 want you to know that before you answer any
8 question, I ask that you make sure you understood
9 it.
10 If you don't, just tell me that, and I
11 will either rephrase it or ask it in a different
12 way so you can understand it. I don't want you
13 to have to blindly answer things that you don't
14 understand because, today, it's very important.
15 I'm going to be asking you questions
16 regarding a motor vehicle accident that you were
17 involved in, among some other things.
18 Have you ever been part of an
19 Examination Under Oath before?
20 A Say again, please.
21 Q Have you ever been part of an
22 Examination Under Oath?
23 So today, what we're doing right now,
24 this is an Examination Under Oath. I want you to
25 know if you have ever been a part of something like
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
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NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023
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1 Zsolt Madari
2 this before?
3 A No.
4 Q So this is your first time?
5 A Yes, first time.
6 Q Have you ever been a plaintiff in a
7 lawsuit before?
8 A No.
9 Q Have you ever given any sworn testimony
10 related to an insurance claim?
11 A No.
12 Q Have you ever given any statements,
13 either verbal or written?
14 A No.
15 Q So some ground rules before we go any
16 further: Just wait until I finish the question
17 before you answer. If you can't hear, make sure
18 you let us know because we're doing this
19 virtually.
20 Like I said, we have a court reporter
21 present and she can't write down movement. So if
22 you wave your hand or point to a direction, she
23 can't write that down, so you have the give
24 verbal responses.
25 A Okay, I understand.
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1 Zsolt Madari
2 Q So you have just been sworn in;
3 therefore, your answers are considered sworn
4 testimony. This means that when you were sworn
5 in, you took the same oath, and it has the same
6 importance as it would carry the same penalties
7 as testimony in a courtroom. So we're simulating
8 that right now. Do you understand what I'm
9 saying?
10 A I try to understood, yeah.
11 Q If you don't, just make sure you let me
12 know.
13 A Yeah, okay. Thank you.
14 Q So you understood everything we have
15 said so far?
16 A Yes, I think -- yes.
17 Q If there's anything that you're
18 uncertain about, I would be happy to go over it
19 with you.
20 A Okay.
21 Q Is there anything that I said that
22 you're confused about?
23 A Yeah.
24 Q What?
25 A What do you mean?
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1 Zsolt Madari
2 Q I'm saying, is there anything that you
3 don't understand that I have said so far?
4 A I understand, yeah. If I don't
5 understand something, I tell you.
6 Q Okay good. Is English your primary
7 language?
8 A No, my language is Hungarian.
9 Q Were you involved in a motor vehicle
10 accident in New Jersey on July 17, 2021?
11 A Yes.
12 Q What state were you in?
13 A Now? Or --
14 Q No, the accident. Was it in New Jersey?
15 A The accident was in New York, in the
16 Bronx. Yes, some parkway because -- it's some
17 parkway.
18 Q Is it the Hutchison River Parkway?
19 A Yeah, I think so. Yeah, if I remember
20 good, yeah.
21 Q Do you remember the make and model of
22 your vehicle?
23 A Say that again? I don't understand.
24 Q Do you remember what kind of car you
25 were driving?
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1 Zsolt Madari
2 A My car, 2004 Ford Expedition.
3 Q Who is your insurance carrier?
4 A My insurance was Drildyland,
5 D-R-I-L-D-Y-L-A-N-D, I think. But I think this
6 company from Florida.
7 Q Do you remember when you took out your
8 policy?
9 A When I started the insurance?
10 Q Yes.
11 A That was long time. I think -- I think
12 before accident is the six months ago, I think
13 so. Six, seven months ago I started insurance.
14 MR. VOSKERIJIAN: Diane, I'm going to
15 send you something right now. Can you pull
16 this up from the e-mail I'm sending you and
17 share it.
18 (Whereupon, the requested exhibit was
19 displayed on the screen.)
20 A Yes. This is my insurance.
21 (Whereupon, a copy of insurance was
22 marked as Exhibit A for identification, as
23 of this date.)
24 Q And this is when you took out your
25 policy, April 5, 2021?
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1 Zsolt Madari
2 A Yes.
3 Q And can you read that address for me?
4 A Wait a second, I read for you?
5 Q Not out loud, just for yourself.
6 A Okay, I see that.
7 Q And were you ever living at that
8 address?
9 A No.
10 Q Where were you living when you took out
11 this policy?
12 A Before, I living in the New York State --
13 Upstate, Catskill, 117 Gypsy Point Road.
14 Q My firm sent EUO letters to you; did you
15 ever receive anything in the mail notifying you
16 about today's examination?
17 A So where is the accident, I got the
18 mail. So everything mail, is here, every paper,
19 here. Yeah.
20 Q I'm just going to ask again to post
21 something up so you can take a look.
22 MR. VOSKERIJIAN: Diane, can you pull up
23 the one where it says -- same thing, Zsolt
24 2nd EUO Scheduling Letter to Insured
25 New York.
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1 Zsolt Madari
2 (Whereupon, the requested exhibit was
3 displayed on the screen.)
4 (Whereupon, an EUO scheduling letter was
5 marked as Exhibit B for identification, as
6 of this date.)
7 Q Is this this one you received in the
8 mail?
9 A Yeah.
10 Q That address at the top, can you read
11 that one, please?
12 A Me?
13 Q Yeah.
14 A 117 Gypsy Point Road, Catskill, New York
15 State 12414.
16 Q That's the address you were living at
17 when you first got the insurance policy?
18 A Yes, yes.
19 Q And you do understand what I'm asking
20 you, right?
21 A Yes, yes, exactly. I understand.
22 MR. VOSKERIJIAN: Now, can you Zoom
23 out for me, please.
24 Q Can you see the screen?
25 A Yeah, I have it here in front of me,
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1 Zsolt Madari
2 yes.
3 Q You have that right now?
4 A Yes, here. (indicating)
5 Q Can you hold it up to the camera? I
6 just want to make sure it's the same.
7 (Whereupon, the witness held a piece of
8 paper up to the camera.)
9 Q Do you have any of that stuff with you
10 right now, like a driver's license?
11 A Problem is -- I want tell you when was
12 the accident. Before, was the -- not big problem,
13 the policy stopping me, because company car is
14 not the issue here. It is my boss problem.
15 Then the police tell me, can I make the
16 New York State driver's license, the New York
17 State ID. After I start the driving school --
18 but right now, I have the New York State driver's
19 license, but when was the accident I was just
20 from Hungary. This before, it was international.
21 Before I coming to United States, I was
22 international driver.
23 Q Okay. I just want to make sure you have
24 a photo ID that I can see?
25 A Okay. Do you want a picture?
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1 Zsolt Madari
2 Q Well, if you can pull it out of your
3 pocket or wherever you can --
4 A Yes, one second. Do you see it?
5 (Whereupon, the witness held his ID up
6 to the camera.)
7 I bring here when was the accident.
8 This was my international driver's license,
9 you see?
10 Q Yes.
11 A This was when was the accident, and
12 here's the permit, New York State driver's
13 license. But last week, I was the road test, so
14 I got the driver's license.
15 Q So you just had your road test last
16 week?
17 A Yeah, one week ago.
18 Q In New York?
19 A Yes, in New York.
20 Q So when did you first move from Hungary
21 to the United States?
22 A First time was 2018, and after, I go
23 back home to Hungary. Then later, five months
24 later, I come back for United States. This was
25 2019. Exactly, is the -- 2019, February 22, I
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
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1 Zsolt Madari
2 think so.
3 Q So in 2018, you moved from Hungary to the
4 United States; where did you move to?
5 A First time, I moving upstate to Catskill
6 because I was going over there -- some Jewish
7 camp in Catskill. You need this company name?
8 Q Yes, please.
9 A Camp Achim.
10 Q This was in 2019 or 2018?
11 A 2019. First time I come to USA was
12 2018, but after -- later three months, I go back
13 home. And after the last year, 2019, February
14 22, I come back to United States.
15 Q Then you worked at the Jewish camp?
16 A Yes, exactly.
17 Q When you moved here in 2019, you moved
18 to upstate New York?
19 A Yeah.
20 Q And you stayed in upstate since you
21 moved?
22 A Yeah, but I -- after the accident, I
23 lose my job, so I lost everything. Then because
24 my friend help me find job on the other end,
25 right now, I live in Bridgeport, Connecticut.
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1 Zsolt Madari
2 Q Just to make it clear, you moved here in
3 2019, and you lived in upstate New York, you
4 worked at Camp Achim from 2019 up until your
5 accident?
6 A Yes. When moved here to Bridgeport,
7 last year, 2021, September 26 -- so right now, I
8 living here.
9 Q And what address is on your New York
10 driver's license?
11 A My New York State driver's license, same
12 thing: 117 Gypsy Point Road, Catskill. When I
13 start this class, I go over there.
14 Q How old are you, Mr. Zsolt?
15 A Thirty-three.
16 Q What's your date of birth?
17 A September 3, 1988.
18 Q Do you have a Social Security number?
19 A Yes. Tax ID, but I don't have number.
20 Q Prior to your July motor vehicle
21 accident, were you involved in any other prior
22 ones?
23 A Say that again, please.
24 Q Sure. So before your July 21st
25 accident, were you ever involved in any other
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1 Zsolt Madari
2 accident prior to that?
3 A No.
4 Q What about afterwards?
5 A Before, nothing. That was no, nothing.
6 The Ford Expedition was the first car.
7 Q And I know you've said this already. So
8 you first moved here, came here 2019, lived in
9 upstate New York up until the time of your
10 accident, and then you moved to Connecticut; can
11 you just provide for me your Connecticut address?
12 A 80 Taft Avenue, Bridgeport.
13 Q Now, is that an apartment complex or,
14 like, a house?
15 A Apartment. So we have the 18 apartment,
16 I think so.
17 Q Is there an apartment number?
18 A My apartment was first -- not the first
19 floor. This is the first apartment, studio
20 apartment.
21 Q Does your studio apartment -- I know you
22 call them flats --
23 A Yes.
24 Q -- does your flat have a number, like 1A
25 or 1F?
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1 Zsolt Madari
2 A I think it's 18, Apartment 18.
3 Q Whenever you get mail, it says 80 Taft
4 Avenue, Apartment 18; that's what it says?
5 A Yeah, but the problem is I can't get
6 mail, so I always use my friend post mail. I
7 mean, I don't have the mailbox, because this
8 place is not so good.
9 Other people mail, other people package
10 -- so everything -- other people package -- so my
11 friend told me, can I use his mailbox. So it's
12 his address.
13 Q So you're saying, because the apartment
14 complex you live in you feel is not safe
15 because people steal other people's mail?
16 A Yeah, this is problem.
17 Q So you use your friend's address for
18 mail; what address is that?
19 A 78 Booth Hill Road, Trumbull,
20 Connecticut.
21 Q And you pay rent for the apartment you
22 live in?
23 A Yes.
24 Q How much is rent?
25 A One thousand per month.
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2 Q Where are you working now?
3 A With my -- I working with my friend. He
4 has apartments and I am superintendent. I fix
5 everything. So, yeah, handyman, but I work few
6 places. It's Bridgeport, Shreveport, New Haven.
7 So his apartments.
8 Q So your friend has several apartment
9 complexes and you help him with maintenance or
10 whatever problems he has with them?
11 A Yes, exactly.
12 Q How long have you been working with your
13 friend doing this; once you got let go from Camp
14 Achim?
15 A Yes.
16 Q Is this the same friend that you just
17 provided on Booth Hill Road?
18 A Yeah, he's the -- it's his address,
19 yeah.
20 Q But it's the same friend, the friend
21 that you --
22 A Yes, yes. Same friend, yeah.
23 Q Now, earlier, we established that you
24 took out your insurance policy on April 5th; right,
25 and I showed you your insurance page?
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2 A Yes.
3 Q April 5, 2021, were you living at that
4 Catskill address?
5 A Yes.
6 Q Have you ever lived in Florida?
7 A No, never in Florida.
8 Q But you put a Florida address for your
9 car insurance, right?
10 A Yeah. Sometimes -- I don't understand,
11 but someone make for me the place and the
12 insurance. So I don't understand why not put my
13 real address.
14 Q How did you hear about Dairyland
15 Insurance?
16 A So someone make for me the license
17 plate, so I don't know who here, because he
18 living in Florida, and I pay for him, and he make
19 for me everything: Insurance, license plate,
20 registration, everything, but I don't know who is
21 the name. I just find website and that's it, and
22 something for him. Everything -- that's it. So
23 yeah.
24 Q Did you take out the -- you took out the
25 insurance policy online yourself?
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2 A Yes.
3 Q And did you sign it online?
4 A No. I find this insurance online. I am
5 going to the website and order. I made the
6 insurance.
7 Q But you said someone made a license
8 plate and registration for you?
9 A Yeah, yes. I send for him everything.
10 Q What did you send him; what information?
11 A I don't know. I have a new phone, and
12 this is a long time ago, so I don't know.
13 Q And you don't remember what you provided
14 for him?
15 A I don't remember. No, because I think I
16 lost this mail and this address because I have a
17 new phone, so -- but this what I want to tell
18 you. I don't know who is -- just someone who
19 give me the address and send me over there and my
20 passport, driver's license, and that's it.
21 And after this, I waiting almost two
22 months. I waiting, and he sent for me back the
23 new license plate, and the new title, and that's
24 it. Sorry, I don't remember who was this or
25 which job this was.
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1 Zsolt Madari
2 Q The Florida address on your insurance
3 policy that you said you didn't live at, how did
4 you get that address?
5 A I don't know. I didn't find this
6 address.
7 Q Did the guy prepare for you that
8 address?
9 A Yeah, I think. Because I just --
10 passport, driver's license, that's it. So I
11 don't make everything.
12 Q But you took out the policy yourself?
13 A The policy, yeah.
14 Q Okay. I just want to pull up another
15 document.
16 How did you meet this guy?
17 A We never meet. Now, I try to thinking,
18 because I find it, this guy, from the Facebook.
19 We together text me, and he's living in the city,
20 in Brooklyn or the Bronx, I don't know.
21 He tell everything, the document and
22 everything. So I think he's a dealer, maybe, so
23 because he been working, he have a mechanic shop
24 and the cars. So I think he's a dealer.
25 Q Where on Facebook did you meet him?
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1 Zsolt Madari
2 A Like --
3 Q I will make that easier for you: Where
4 you met him, was that on Facebook marketplace?
5 A Yes.
6 Q Do you remember the name of the auto
7 body or the mechanic shop he has?
8 A I think his name is -- because I save
9 his number, just -- not the name, but the license
10 plate. But I think Antala, A-N-T-A-L-A.
11 Q Do you still have his phone number?
12 A Wait a second.
13 Yep, I have it.
14 Q Can you provide it for me, please; what
15 is it?
16 A So you need the phone number?
17 Q Yes, please.
18 A 347-247-9994.
19 Q And did he give you the Florida address
20 to use, or did you get that address somewhere
21 else?
22 A I think he's given the address when I
23 send him the title and everything.
24 Q So he got you the license plate and
25 title, and he provided you an address to use that
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1 Zsolt Madari
2 you used to take out your policy?
3 A Yes.
4
5 MR. VOSKERIJIAN: Diane, I just sent you
6 one more exhibit. So this last e-mail, can
7 you just pull up -- it's the signed
8 insurance application.
9 (Whereupon, the requested exhibit was
10 displayed on the screen.)
11 (Whereupon, insurance application was
12 marked as Exhibit C for identification, as
13 of this date.)
14 A Can I have a question?
15 Q Sure.
16 A Because now I have the New York State
17 driver's license, so now, can I make the New York
18 State license plate, right?
19 Q I can't really provide you any
20 information on how to go about your things. I
21 can only answer questions in relation to this.
22 A Okay, sorry about that.
23 Q Don't apologize.
24 So we have here -- this is, again, your
25 coverage information. Now, if we scroll down a
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1 Zsolt Madari
2 bit, there are some signatures or initials.
3 Right here. So now, did you sign that?
4 A Signature?
5 Q Yes. That's where you're supposed to
6 initial, understanding -- saying you understood
7 and agree to the terms of policy.
8 A Yes.
9 Q Are those your signatures; did you put
10 that?
11 A That's not my signature.
12 Q Then who signed that?
13 A I don't know. I made the signatures
14 online, it's the --
15 Q That's digital, yes.
16 See, at the top of the page, that's your
17 name and that's your insurance policy --
18 A Yes.
19 Q -- and that's the Florida address,
20 again, that you said you never lived at, correct?
21 A No -- yes, correct. I never lived
22 there.
23 MR. VOSKERIJIAN: Scroll down, please.
24 So this is where you're supposed to be
25 initialing; did you take out the policy -- did
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023
25
1 Zsolt Madari
2 you initial over there?
3 A Yes.
4 Q So these are your initials, correct?
5 A Yes.
6 Q Then on the bottom, it says, name,
7 insured signature, and we just established that
8 you are that named insured; did you sign there;
9 is that you?
10 A Yes.
11 Q And then on the date over there, it
12 says, April 5th; this is where you took out your
13 policy?
14 A Yes.
15 Q And earlier you said, at this time, you
16 weren't living in Florida; you were living at the
17 Catskill address, right?
18 A Yes.
19 Q Now, for your accident information,
20 where were you coming from?
21 A So this day, accident day?
22 Q Yes. Let me just shift your attention
23 now to the time -- to the date of the accident,
24 which is July 17th; what did you do that day?
25 Let's go through that day.
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
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NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023
26
1 Zsolt Madari
2 A This was -- I think is it Saturday, so
3 because upstate, I live together, working
4 together, two friends. We -- this day, the
5 morning, went into the city, first, Queens meeting
6 with friends.
7 Then after, we go to Brooklyn. We
8 meeting with other friend, but after, I see --
9 before we go home, after I see some regular
10 problems with my car -- the generator was the
11 problem. After we go home, we try to go home, but
12 the car was done.
13 Q Where is home?
14 A Catskill.
15 Q You and your friend from Queens and
16 Brooklyn were traveling together to go to your
17 place in upstate?
18 A No. Maybe I say wrong. This day,
19 morning, is it two friends. The morning, we go
20 into the city meeting with two friends. First,
21 we stopped at Queens in the morning. Morning
22 after, we go to Tomas, but they living in
23 Brooklyn.
24 We meeting after, we both go home in the
25 Catskill with me. Zsolt, Rita, see everything,
516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500
FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023
27
1 Zsolt Madari
2 what was the problem. We see everything when was
3 the accident yeah.
4 Q So what happened, you guys -- you and
5 then your friend, Zsolt, and you said his wife,
6 Rita --
7 A Yes.
8 Q You were all in your car together
9 heading back upstate, and that's when the
10 accident occurred, you said?
11 A Yes.
12 Q So what was wrong with your car again?
13 A My car was the problem. Generator make
14 power, so the electric -- so I hope generator, in
15 English -- what is the generator?
16 Q Yeah, roughly.
17 A So this is the problem. The generator
Preview
FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 G FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 1 - - - - - - - - - - - - x IN THE MATTER OF THE CLAIM OF: ZSOLT MADARI PEAK PROPERTY AND CASUALTY INSURANCE CORPORATION CLAIM NUMBER: 97A820969 DOL: JULY 17, 2021 - - - - - - - - - - - - - x April 21, 2022 10:18 A.M. EXAMINATION UNDER OATH of ZSOLT MADARI, the witness herein, taken by the attorney for Peak Property and Casualty Insurance, pursuant to the terms and conditions of the insurance policy, held via web conference, and held before Diane Chen, a Notary Public and shorthand reporter of the State of New York on the above stated day and time. 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 2 1 A P P E A R A N C E S : 2 ALAHVERDIAN VAN LEUVAN, P.C. 3 Attorneys for Respondent 295 Broadway- 1st floor 4 Bethpage, New York 11714 5 BY: SHONT VOSKERIJIAN, ESQ 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 3 1 THE REPORTER: It is hereby stipulated 2 and agreed by and between counsel for all 3 parties present this or Examination Under 4 Oath is being conducted remotely by video 5 conference, and that the court reporter, 6 witness and all counsel are in separate 7 remote locations and participating via Zoom 8 or any web conference meeting platform under 9 the control of the court reporting agency. 10 It is further stipulated that this 11 videoconference will not be recorded in any 12 manner and that any recording, without the 13 express written consent of all parties, 14 shall be considered unauthorized. 15 Before I swear in the witness, I will ask 16 each counsel to stipulate on the record that 17 I, the court reporter, may swear in the 18 witness even though I am not physically in 19 the presence of the witness and that there 20 is no objection to that at this time, nor 21 will there be an objection at a future date. 22 MR. VOSKERIJIAN: No objection. 23 THE REPORTER: Before we begin, sir, do 24 you have a photo ID you can hold up to the 25 camera for us? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 4 1 (Whereupon, the witness held his ID up 2 to the camera.) 3 Z S O L T M A D A R I, 4 the witness herein, having first been duly 5 sworn by Diane Chen, a Notary Public in and for 6 the State of New York, was examined and 7 testified as follows: 8 EXAMINATION BY 9 SHONT VOSKERIJIAN, ESQ.: 10 Q State your name for the record, please. 11 A Zsolt Madari. 12 Q Please state your address. 13 A 80 South Avenue, Bridgeport, 14 Connecticut. 15 Q Good morning, sir. I just want to 16 confirm: Is Zsolt your first name or your 17 last name? 18 A Yes, my first name. In my country, we 19 change it. We have the last name after the first 20 name. But my name is Zsolt, my first name. 21 Q Got it. I just want to make sure I'm 22 calling you by your first name. 23 A Okay, thank you. 24 Q Good morning, Mr. Zsolt. My name is 25 Shont Voskerijian, and I was retained by Peak 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 5 1 Zsolt Madari 2 Property to conduct what's called an Examination 3 Under Oath today. 4 So the court reporter, the woman here, 5 she's going to be writing everything down so 6 there is a record of this conversation. But I 7 want you to know that before you answer any 8 question, I ask that you make sure you understood 9 it. 10 If you don't, just tell me that, and I 11 will either rephrase it or ask it in a different 12 way so you can understand it. I don't want you 13 to have to blindly answer things that you don't 14 understand because, today, it's very important. 15 I'm going to be asking you questions 16 regarding a motor vehicle accident that you were 17 involved in, among some other things. 18 Have you ever been part of an 19 Examination Under Oath before? 20 A Say again, please. 21 Q Have you ever been part of an 22 Examination Under Oath? 23 So today, what we're doing right now, 24 this is an Examination Under Oath. I want you to 25 know if you have ever been a part of something like 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 6 1 Zsolt Madari 2 this before? 3 A No. 4 Q So this is your first time? 5 A Yes, first time. 6 Q Have you ever been a plaintiff in a 7 lawsuit before? 8 A No. 9 Q Have you ever given any sworn testimony 10 related to an insurance claim? 11 A No. 12 Q Have you ever given any statements, 13 either verbal or written? 14 A No. 15 Q So some ground rules before we go any 16 further: Just wait until I finish the question 17 before you answer. If you can't hear, make sure 18 you let us know because we're doing this 19 virtually. 20 Like I said, we have a court reporter 21 present and she can't write down movement. So if 22 you wave your hand or point to a direction, she 23 can't write that down, so you have the give 24 verbal responses. 25 A Okay, I understand. 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 7 1 Zsolt Madari 2 Q So you have just been sworn in; 3 therefore, your answers are considered sworn 4 testimony. This means that when you were sworn 5 in, you took the same oath, and it has the same 6 importance as it would carry the same penalties 7 as testimony in a courtroom. So we're simulating 8 that right now. Do you understand what I'm 9 saying? 10 A I try to understood, yeah. 11 Q If you don't, just make sure you let me 12 know. 13 A Yeah, okay. Thank you. 14 Q So you understood everything we have 15 said so far? 16 A Yes, I think -- yes. 17 Q If there's anything that you're 18 uncertain about, I would be happy to go over it 19 with you. 20 A Okay. 21 Q Is there anything that I said that 22 you're confused about? 23 A Yeah. 24 Q What? 25 A What do you mean? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 8 1 Zsolt Madari 2 Q I'm saying, is there anything that you 3 don't understand that I have said so far? 4 A I understand, yeah. If I don't 5 understand something, I tell you. 6 Q Okay good. Is English your primary 7 language? 8 A No, my language is Hungarian. 9 Q Were you involved in a motor vehicle 10 accident in New Jersey on July 17, 2021? 11 A Yes. 12 Q What state were you in? 13 A Now? Or -- 14 Q No, the accident. Was it in New Jersey? 15 A The accident was in New York, in the 16 Bronx. Yes, some parkway because -- it's some 17 parkway. 18 Q Is it the Hutchison River Parkway? 19 A Yeah, I think so. Yeah, if I remember 20 good, yeah. 21 Q Do you remember the make and model of 22 your vehicle? 23 A Say that again? I don't understand. 24 Q Do you remember what kind of car you 25 were driving? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 9 1 Zsolt Madari 2 A My car, 2004 Ford Expedition. 3 Q Who is your insurance carrier? 4 A My insurance was Drildyland, 5 D-R-I-L-D-Y-L-A-N-D, I think. But I think this 6 company from Florida. 7 Q Do you remember when you took out your 8 policy? 9 A When I started the insurance? 10 Q Yes. 11 A That was long time. I think -- I think 12 before accident is the six months ago, I think 13 so. Six, seven months ago I started insurance. 14 MR. VOSKERIJIAN: Diane, I'm going to 15 send you something right now. Can you pull 16 this up from the e-mail I'm sending you and 17 share it. 18 (Whereupon, the requested exhibit was 19 displayed on the screen.) 20 A Yes. This is my insurance. 21 (Whereupon, a copy of insurance was 22 marked as Exhibit A for identification, as 23 of this date.) 24 Q And this is when you took out your 25 policy, April 5, 2021? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 10 1 Zsolt Madari 2 A Yes. 3 Q And can you read that address for me? 4 A Wait a second, I read for you? 5 Q Not out loud, just for yourself. 6 A Okay, I see that. 7 Q And were you ever living at that 8 address? 9 A No. 10 Q Where were you living when you took out 11 this policy? 12 A Before, I living in the New York State -- 13 Upstate, Catskill, 117 Gypsy Point Road. 14 Q My firm sent EUO letters to you; did you 15 ever receive anything in the mail notifying you 16 about today's examination? 17 A So where is the accident, I got the 18 mail. So everything mail, is here, every paper, 19 here. Yeah. 20 Q I'm just going to ask again to post 21 something up so you can take a look. 22 MR. VOSKERIJIAN: Diane, can you pull up 23 the one where it says -- same thing, Zsolt 24 2nd EUO Scheduling Letter to Insured 25 New York. 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 11 1 Zsolt Madari 2 (Whereupon, the requested exhibit was 3 displayed on the screen.) 4 (Whereupon, an EUO scheduling letter was 5 marked as Exhibit B for identification, as 6 of this date.) 7 Q Is this this one you received in the 8 mail? 9 A Yeah. 10 Q That address at the top, can you read 11 that one, please? 12 A Me? 13 Q Yeah. 14 A 117 Gypsy Point Road, Catskill, New York 15 State 12414. 16 Q That's the address you were living at 17 when you first got the insurance policy? 18 A Yes, yes. 19 Q And you do understand what I'm asking 20 you, right? 21 A Yes, yes, exactly. I understand. 22 MR. VOSKERIJIAN: Now, can you Zoom 23 out for me, please. 24 Q Can you see the screen? 25 A Yeah, I have it here in front of me, 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 12 1 Zsolt Madari 2 yes. 3 Q You have that right now? 4 A Yes, here. (indicating) 5 Q Can you hold it up to the camera? I 6 just want to make sure it's the same. 7 (Whereupon, the witness held a piece of 8 paper up to the camera.) 9 Q Do you have any of that stuff with you 10 right now, like a driver's license? 11 A Problem is -- I want tell you when was 12 the accident. Before, was the -- not big problem, 13 the policy stopping me, because company car is 14 not the issue here. It is my boss problem. 15 Then the police tell me, can I make the 16 New York State driver's license, the New York 17 State ID. After I start the driving school -- 18 but right now, I have the New York State driver's 19 license, but when was the accident I was just 20 from Hungary. This before, it was international. 21 Before I coming to United States, I was 22 international driver. 23 Q Okay. I just want to make sure you have 24 a photo ID that I can see? 25 A Okay. Do you want a picture? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 13 1 Zsolt Madari 2 Q Well, if you can pull it out of your 3 pocket or wherever you can -- 4 A Yes, one second. Do you see it? 5 (Whereupon, the witness held his ID up 6 to the camera.) 7 I bring here when was the accident. 8 This was my international driver's license, 9 you see? 10 Q Yes. 11 A This was when was the accident, and 12 here's the permit, New York State driver's 13 license. But last week, I was the road test, so 14 I got the driver's license. 15 Q So you just had your road test last 16 week? 17 A Yeah, one week ago. 18 Q In New York? 19 A Yes, in New York. 20 Q So when did you first move from Hungary 21 to the United States? 22 A First time was 2018, and after, I go 23 back home to Hungary. Then later, five months 24 later, I come back for United States. This was 25 2019. Exactly, is the -- 2019, February 22, I 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 14 1 Zsolt Madari 2 think so. 3 Q So in 2018, you moved from Hungary to the 4 United States; where did you move to? 5 A First time, I moving upstate to Catskill 6 because I was going over there -- some Jewish 7 camp in Catskill. You need this company name? 8 Q Yes, please. 9 A Camp Achim. 10 Q This was in 2019 or 2018? 11 A 2019. First time I come to USA was 12 2018, but after -- later three months, I go back 13 home. And after the last year, 2019, February 14 22, I come back to United States. 15 Q Then you worked at the Jewish camp? 16 A Yes, exactly. 17 Q When you moved here in 2019, you moved 18 to upstate New York? 19 A Yeah. 20 Q And you stayed in upstate since you 21 moved? 22 A Yeah, but I -- after the accident, I 23 lose my job, so I lost everything. Then because 24 my friend help me find job on the other end, 25 right now, I live in Bridgeport, Connecticut. 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 15 1 Zsolt Madari 2 Q Just to make it clear, you moved here in 3 2019, and you lived in upstate New York, you 4 worked at Camp Achim from 2019 up until your 5 accident? 6 A Yes. When moved here to Bridgeport, 7 last year, 2021, September 26 -- so right now, I 8 living here. 9 Q And what address is on your New York 10 driver's license? 11 A My New York State driver's license, same 12 thing: 117 Gypsy Point Road, Catskill. When I 13 start this class, I go over there. 14 Q How old are you, Mr. Zsolt? 15 A Thirty-three. 16 Q What's your date of birth? 17 A September 3, 1988. 18 Q Do you have a Social Security number? 19 A Yes. Tax ID, but I don't have number. 20 Q Prior to your July motor vehicle 21 accident, were you involved in any other prior 22 ones? 23 A Say that again, please. 24 Q Sure. So before your July 21st 25 accident, were you ever involved in any other 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 16 1 Zsolt Madari 2 accident prior to that? 3 A No. 4 Q What about afterwards? 5 A Before, nothing. That was no, nothing. 6 The Ford Expedition was the first car. 7 Q And I know you've said this already. So 8 you first moved here, came here 2019, lived in 9 upstate New York up until the time of your 10 accident, and then you moved to Connecticut; can 11 you just provide for me your Connecticut address? 12 A 80 Taft Avenue, Bridgeport. 13 Q Now, is that an apartment complex or, 14 like, a house? 15 A Apartment. So we have the 18 apartment, 16 I think so. 17 Q Is there an apartment number? 18 A My apartment was first -- not the first 19 floor. This is the first apartment, studio 20 apartment. 21 Q Does your studio apartment -- I know you 22 call them flats -- 23 A Yes. 24 Q -- does your flat have a number, like 1A 25 or 1F? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 17 1 Zsolt Madari 2 A I think it's 18, Apartment 18. 3 Q Whenever you get mail, it says 80 Taft 4 Avenue, Apartment 18; that's what it says? 5 A Yeah, but the problem is I can't get 6 mail, so I always use my friend post mail. I 7 mean, I don't have the mailbox, because this 8 place is not so good. 9 Other people mail, other people package 10 -- so everything -- other people package -- so my 11 friend told me, can I use his mailbox. So it's 12 his address. 13 Q So you're saying, because the apartment 14 complex you live in you feel is not safe 15 because people steal other people's mail? 16 A Yeah, this is problem. 17 Q So you use your friend's address for 18 mail; what address is that? 19 A 78 Booth Hill Road, Trumbull, 20 Connecticut. 21 Q And you pay rent for the apartment you 22 live in? 23 A Yes. 24 Q How much is rent? 25 A One thousand per month. 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 18 1 Zsolt Madari 2 Q Where are you working now? 3 A With my -- I working with my friend. He 4 has apartments and I am superintendent. I fix 5 everything. So, yeah, handyman, but I work few 6 places. It's Bridgeport, Shreveport, New Haven. 7 So his apartments. 8 Q So your friend has several apartment 9 complexes and you help him with maintenance or 10 whatever problems he has with them? 11 A Yes, exactly. 12 Q How long have you been working with your 13 friend doing this; once you got let go from Camp 14 Achim? 15 A Yes. 16 Q Is this the same friend that you just 17 provided on Booth Hill Road? 18 A Yeah, he's the -- it's his address, 19 yeah. 20 Q But it's the same friend, the friend 21 that you -- 22 A Yes, yes. Same friend, yeah. 23 Q Now, earlier, we established that you 24 took out your insurance policy on April 5th; right, 25 and I showed you your insurance page? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 19 1 Zsolt Madari 2 A Yes. 3 Q April 5, 2021, were you living at that 4 Catskill address? 5 A Yes. 6 Q Have you ever lived in Florida? 7 A No, never in Florida. 8 Q But you put a Florida address for your 9 car insurance, right? 10 A Yeah. Sometimes -- I don't understand, 11 but someone make for me the place and the 12 insurance. So I don't understand why not put my 13 real address. 14 Q How did you hear about Dairyland 15 Insurance? 16 A So someone make for me the license 17 plate, so I don't know who here, because he 18 living in Florida, and I pay for him, and he make 19 for me everything: Insurance, license plate, 20 registration, everything, but I don't know who is 21 the name. I just find website and that's it, and 22 something for him. Everything -- that's it. So 23 yeah. 24 Q Did you take out the -- you took out the 25 insurance policy online yourself? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 20 1 Zsolt Madari 2 A Yes. 3 Q And did you sign it online? 4 A No. I find this insurance online. I am 5 going to the website and order. I made the 6 insurance. 7 Q But you said someone made a license 8 plate and registration for you? 9 A Yeah, yes. I send for him everything. 10 Q What did you send him; what information? 11 A I don't know. I have a new phone, and 12 this is a long time ago, so I don't know. 13 Q And you don't remember what you provided 14 for him? 15 A I don't remember. No, because I think I 16 lost this mail and this address because I have a 17 new phone, so -- but this what I want to tell 18 you. I don't know who is -- just someone who 19 give me the address and send me over there and my 20 passport, driver's license, and that's it. 21 And after this, I waiting almost two 22 months. I waiting, and he sent for me back the 23 new license plate, and the new title, and that's 24 it. Sorry, I don't remember who was this or 25 which job this was. 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 21 1 Zsolt Madari 2 Q The Florida address on your insurance 3 policy that you said you didn't live at, how did 4 you get that address? 5 A I don't know. I didn't find this 6 address. 7 Q Did the guy prepare for you that 8 address? 9 A Yeah, I think. Because I just -- 10 passport, driver's license, that's it. So I 11 don't make everything. 12 Q But you took out the policy yourself? 13 A The policy, yeah. 14 Q Okay. I just want to pull up another 15 document. 16 How did you meet this guy? 17 A We never meet. Now, I try to thinking, 18 because I find it, this guy, from the Facebook. 19 We together text me, and he's living in the city, 20 in Brooklyn or the Bronx, I don't know. 21 He tell everything, the document and 22 everything. So I think he's a dealer, maybe, so 23 because he been working, he have a mechanic shop 24 and the cars. So I think he's a dealer. 25 Q Where on Facebook did you meet him? 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 22 1 Zsolt Madari 2 A Like -- 3 Q I will make that easier for you: Where 4 you met him, was that on Facebook marketplace? 5 A Yes. 6 Q Do you remember the name of the auto 7 body or the mechanic shop he has? 8 A I think his name is -- because I save 9 his number, just -- not the name, but the license 10 plate. But I think Antala, A-N-T-A-L-A. 11 Q Do you still have his phone number? 12 A Wait a second. 13 Yep, I have it. 14 Q Can you provide it for me, please; what 15 is it? 16 A So you need the phone number? 17 Q Yes, please. 18 A 347-247-9994. 19 Q And did he give you the Florida address 20 to use, or did you get that address somewhere 21 else? 22 A I think he's given the address when I 23 send him the title and everything. 24 Q So he got you the license plate and 25 title, and he provided you an address to use that 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 23 1 Zsolt Madari 2 you used to take out your policy? 3 A Yes. 4 5 MR. VOSKERIJIAN: Diane, I just sent you 6 one more exhibit. So this last e-mail, can 7 you just pull up -- it's the signed 8 insurance application. 9 (Whereupon, the requested exhibit was 10 displayed on the screen.) 11 (Whereupon, insurance application was 12 marked as Exhibit C for identification, as 13 of this date.) 14 A Can I have a question? 15 Q Sure. 16 A Because now I have the New York State 17 driver's license, so now, can I make the New York 18 State license plate, right? 19 Q I can't really provide you any 20 information on how to go about your things. I 21 can only answer questions in relation to this. 22 A Okay, sorry about that. 23 Q Don't apologize. 24 So we have here -- this is, again, your 25 coverage information. Now, if we scroll down a 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 24 1 Zsolt Madari 2 bit, there are some signatures or initials. 3 Right here. So now, did you sign that? 4 A Signature? 5 Q Yes. That's where you're supposed to 6 initial, understanding -- saying you understood 7 and agree to the terms of policy. 8 A Yes. 9 Q Are those your signatures; did you put 10 that? 11 A That's not my signature. 12 Q Then who signed that? 13 A I don't know. I made the signatures 14 online, it's the -- 15 Q That's digital, yes. 16 See, at the top of the page, that's your 17 name and that's your insurance policy -- 18 A Yes. 19 Q -- and that's the Florida address, 20 again, that you said you never lived at, correct? 21 A No -- yes, correct. I never lived 22 there. 23 MR. VOSKERIJIAN: Scroll down, please. 24 So this is where you're supposed to be 25 initialing; did you take out the policy -- did 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 25 1 Zsolt Madari 2 you initial over there? 3 A Yes. 4 Q So these are your initials, correct? 5 A Yes. 6 Q Then on the bottom, it says, name, 7 insured signature, and we just established that 8 you are that named insured; did you sign there; 9 is that you? 10 A Yes. 11 Q And then on the date over there, it 12 says, April 5th; this is where you took out your 13 policy? 14 A Yes. 15 Q And earlier you said, at this time, you 16 weren't living in Florida; you were living at the 17 Catskill address, right? 18 A Yes. 19 Q Now, for your accident information, 20 where were you coming from? 21 A So this day, accident day? 22 Q Yes. Let me just shift your attention 23 now to the time -- to the date of the accident, 24 which is July 17th; what did you do that day? 25 Let's go through that day. 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 26 1 Zsolt Madari 2 A This was -- I think is it Saturday, so 3 because upstate, I live together, working 4 together, two friends. We -- this day, the 5 morning, went into the city, first, Queens meeting 6 with friends. 7 Then after, we go to Brooklyn. We 8 meeting with other friend, but after, I see -- 9 before we go home, after I see some regular 10 problems with my car -- the generator was the 11 problem. After we go home, we try to go home, but 12 the car was done. 13 Q Where is home? 14 A Catskill. 15 Q You and your friend from Queens and 16 Brooklyn were traveling together to go to your 17 place in upstate? 18 A No. Maybe I say wrong. This day, 19 morning, is it two friends. The morning, we go 20 into the city meeting with two friends. First, 21 we stopped at Queens in the morning. Morning 22 after, we go to Tomas, but they living in 23 Brooklyn. 24 We meeting after, we both go home in the 25 Catskill with me. Zsolt, Rita, see everything, 516-485-2222 BEE REPORTING AGENCY, INC. 212-327-3500 FILED: GREENE COUNTY CLERK 07/19/2023 05:33 PM INDEX NO. EF2022-290 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 07/19/2023 27 1 Zsolt Madari 2 what was the problem. We see everything when was 3 the accident yeah. 4 Q So what happened, you guys -- you and 5 then your friend, Zsolt, and you said his wife, 6 Rita -- 7 A Yes. 8 Q You were all in your car together 9 heading back upstate, and that's when the 10 accident occurred, you said? 11 A Yes. 12 Q So what was wrong with your car again? 13 A My car was the problem. Generator make 14 power, so the electric -- so I hope generator, in 15 English -- what is the generator? 16 Q Yeah, roughly. 17 A So this is the problem. The generator