Preview
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
EXHIBIT F
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
AW OFFICES OF TINA NEWSOME-LEE Attorney: Shana A. Kleinman
Malling Address Only: Direct Dial: (631)577-7517
P.O. Box 2904 Facsimile: (855) 872-7924
Hartford, CT 06104-2904 EMail: SKLEINMA@travelers.com
March 14, 2023
Email: claims@kimlawpc.com
Law Offices Of Kim & Associates, Pc
164-01 Northern Blvd
Flushing, New York 11358
RE: Matter No.: 2022107113
Claim No.: IPG3941
Examination Under Oath of n S Park
Dear Counselor:
Enclosed please find one copy of your clienes Rami on Under Oath in the above-referenced matter.
Please have your client provide any information and/ r documents which may have been requested
and you agreed to provide during this EUO within 20 days of the date of this letter. After doing so, in
the presence of a Notary Public, please have the copy duly executed and return it to this office with
your clienes signature. Please note you may scan and email the signature page, with errata sheets if
applicable, back same to Cinde Kusher at ckusher@travelers.com with the above Matter Number in
the subject line.
Please be advised that the failure to do so may constitute a breach of the subject automobile policy of
insurance as well as noncompliance with the New York State No-Fault Regulations.
Thank you for your anticipated cooperation regarding these requests.
Very truly yours,
Law Offices of Tina Newsome-Lee
BY: Shana A. Kleinman, Esq.
Direct Dial: (631)577-7517
Not a Partnership or Professional Corporadon
AII attorneys are Employees of The Travelers Indemnity Company and its Property Casualty Affiliates
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page l]
December 2, 2022
1
_____________________________________Ç
In the Matter of the Claim of
YUN SOOK PARK
TRAVELERS INSURANCE COMPANY
Claim No: IPG3941
_________________________________________Ç
December 2, 2022
10:30 a.m.
Video conference
EXAMINATION UNDER OATH
OF
YUN SOOK PARK
Jessica Schmidt
Court Reporter
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 2]
December 2, 2022
(1)
(2) A P P E A R A N C E S:
(3) LAW OFFICES OF KIM & ASSOCIATES
Attorneys for Claimant
(4) 164-01 Northern Boulevard
Queens, New York 11358
(5)
BY: RICHARD PAK, ESQ.
(6)
(7)
LAW OFFICES OF TINA NEWSOME-LEE
(8) Attorneys for Travelers
P.O. Box 430
(9) Buffalo, New York 14240
(10) BY: MATTHEW GOUVEIA, INVESTIGATOR
(11)
(12) ALSO PRESENT:
(13) Sean Kim, Korean Interpreter
(14) Jae Kim, Korean Interpreter
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
(23)
(24)
(25)
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 3]
December 2, 2022
(1) VIDEO STIPULATIONS
(2)
(3) IT IS HEREBY STIPULATED AND AGREED by
(4) And between counsel for all parties present
(5) That this deposition is being conducted by
(6) Videoconference, that the Court Reporter,
(7) all counsel, and the witness are all in
(8) separate remote locations and participating
(9) via Videoconference (LegalView/Zoom/WebEx)
(10) meeting under the control of Lexitas Court
(11) Reporting Service, that the officer
(12) administering the oath to the witness shall
(13) be sworn in remotely by the Court Reporter
(14) after confirming the witness's identity, that
(15) this Videoconference will not be recorded in
(16) any manner, and that any recording without the
(17) express written consent of all parties shall be
(10) considered unauthorized, in violation of law,
(19) and shall not be used for any purpose in this
(2:0) litigation or otherwise.
(21)
(22)
(23)
(24)
(25)
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 4]
December 2, 2022
(1) IT IS FURTHER STIPULATED that exhibits may be
(2) marked by the attorney presenting the exhibit to
(3) the witness, and that a copy of any exhibit
(4) presented to a witness shall be emailed to or
(5) otherwise in possession of all counsel prior to
(6) any questioning of a witness regarding the exhibit
(7) in question. All parties shall bear their own costs
(8) in the conduct of this deposition by Videoconference.
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
(23)
(24)
(25)
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 5]
December 2, 2022
(1)
(2) S E A N K I M, called as the interpreter
(3) in this matter, was duly sworn by a Notary
(4) Public of the State of New York to accurately
(5) and faithfully translate the questions
(6) propounded to the witness from English into
(7) Korean and the answers given by the witness from
(8) Korean into English.
(9) -oOo-
(10) Y U N S O O K P A R K, the witness
(11) herein, having been first duly sworn by a Notary
(12) Public of the State of New York, was examined
(13) and testified through the interpreter as
(14) follows:
(15) EXAMINATION BY
(16) MR. GOUVEIA:
(17) Q State your name for the record,
(18) please.
(19) A Yun Sook Park.
(20) Q State your address for the record,
(21) please.
(22) A 16-51 Clintonville Street,
(23) Whitestone, New York 11357.
(24) Q My name is Matthew Gouveia. I'm
(25) an Investigator with Travelers Investigative
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 6]
December 2, 2022
(1) Y. Sook Park
(2) Services and represent Travelers Insurance
(3) Company. We are here 12to conduct the
(4) Examination Under Oath of Yun Sook Park, as
(5) stated in your insurance policy.
(6) Today's Examination is being
(7) conducted via Zoom web conference. It concerns
(8) Travelers claim number IPG3941, a motor vehicle
(9) accident that occurred in Queens, New York, near
(10) 160th Street and the Cross Island Parkway.
(11) Attending today's Examination with
(12) Ms. Yun Park is her selected counsel,
(13) Mr. Richard Pak, of the Law Offices of Kim &
(14) Associates. Providing Korean to English
(15) translation is Mr. Sean Kim.
(16) At the attorney's request, a copy
(17) of this transcript will be provided.
(18) Q Ms. Park, in a moment, I will
(19) provide some direction. Before doing so, I just
(20) want to verify two things: I want to make sure
(21) on the record that our connection is secure.
(22) A yes.
(23) Q And can you please identify if you
(24) can hear and understand your interpreter.
(25) A yes.
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 7]
December 2, 2022
(1) Y. Sook Park
(2) Q Before proceeding, this is nothing
(3) personal, I ask it of everybody: Are you under
(4) the influence of any medications, drugs or
(5) alcohol which would impair your ability to
(6) recall events or answer my questions today?
(7) A No.
(8) Q Ms. Park, please provide all of
(9) your responses in Korean today.
(10) A Got it.
(11) Q Please wait for the translator to
(12) translate the questions from English into
(13) Korean.
(14) A Yes.
(15) Q As you can see, there's a Court
(16) Reporter in the room present. The Reporter will
(17) be noting everything that is being said today on
(18) what is called a transcript. It 3 a important
(19) that we both do not speak at the same time, so
(20) that the Court Reporter can note what we are
(21) saying.
(22) A yes.
(23) Q Please verbalize all of your
(24) responses. Do not point. If you're trying to
(25) indicate an area, please be as specific as
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 8]
December 2, 2022
(1) Y. Sook Park
(2) possible. Okay?
(3) A I'm not understanding what you
(4) mean. What do you mean "area"?
(5) Q I don't understand.
(6) THE INTERPRETER: You said
(7) not to point to the area. Be
(8) specific.
(9) Q When we're talking about
(10) questions, such as injuries, for example, let's
(11) say that you indicate that you may have hurt
(12) your arm. Please indicate if it was your left
(13) or right arm, in that example.
(14) A Left arm.
(15) Q It was just an example, ma'am.
(16) A Okay.
(17) Q For another example, when we're
(18) discussing the motor vehicle accident, please
(19) don't indicate and say things such as "something
(20) happened right there" or "over because
there",
(21) if someone was to read our transcript, it won't
(22) be very clear for them to understand. It's just
(23) important to provide detail.
(24) A yes.
(25) Q Thank you. If at any time you
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 9]
December 2, 2022
(1) Y. Sook Park
(2) don't understand a question that I ask, ask me
(3) to repeat or rephrase the question.
(4) A Yes.
(5) Q If you need to speak to your
(6) attorney, please let me know. We may take a
(7) short break. If you need to use the restroom or
(8) a break for any reason, please let me know.
(9) A Yes.
(10) Q Can you please state your full
(11) name and your date of birth?
(12) A Yun Sook Park, Y-U-N S-O-O-K
(13) P-A-R-K. KK/KK/1961.
(14) MR. PAK: Can we put the
(15) year on the record for security
(16) purposes?
(17) MR. GOUVEIA: I'm okay with
(18) that.
(19) MR. PAK: You can write
(20) down the whole thing, but on the
(21) record, just the year.
(22) MR. GOUVEIA: Sure.
(23) Q Ms. Park, do you go by any other
(24) name?
(25) A I use Rosa as my English name.
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 10]
December 2, 2022
(1) Y. Sook Park
(2) Q What are the last four digits of
(3) your Social Security number?
(4) A .
(5) Q What is your present address?
(6) A 16-51 Clintonville Street,
(7) Whitestone, New York 11357.
(8) Q Is that a single-family home?
(9) A Yes.
(10) Q Do you rent or own the home?
(11) A Rental,
(12) Q How long have you resided at that
(13) address for?
(14) A Under five years.
(15) Q Who do you reside at that address
(16) with?
(17) A Husband and my son.
(18) Q And what is your husband's name?
(19) A Byung Jeu Kim.
(20) Q Can you spell that?
(21) A B-Y-U-N-G J-E-U K-I-M.
(22) Q And what is Mr. Kim's date of
(23) birth?
(24) A XX/XX/1956.
(25) MR, PAK: Again, I ask just
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 11]
December 2, 2022
(1) Y. Sook Park
(2) the year on the record.
(3) MR. GOUVEIA: That's fine.
(4) Q Byung Jeu Kim, is that the correct
(5) name?
(6) A Yes.
(7) Q Is Mr. Kim licensed to drive
(8) vehicles?
(9) A No.
(10) Q He does not have a driver's
(11) license?
(12) A He doesn't.
(13) Q Okay. And your son's name?
(14) A Brian Gimm, G-I-M-M.
(15) Q What is Brian's date of birth?
(16) A KX/XX/1991.
(17) MR. PAK: Again, just put
(18) the year on the record.
(19) MR. GOUVEIA: I'm
(20) agreeable. That's fine.
(21) Q Now, do you have any other
(22) children?
(23) A My daughter is married. She's
(24) married.
(25) Q She does not reside in your
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 12]
December 2, 2022
(1) Y. Sook Park
(2) household?
(3) A Correct.
(4) Q Okay. Do you reside with anyone
(5) else other than your son and your husband?
(6) A No.
(7) Q How long have you been married
(8) for?
(9) A With who?
(10) Q Byung Jeu Kim?
(11) A 1984.
(12) Q Okay. Do you have any other
(13) address or home, other than the Clintonville
(14) street address in Whitestone?
(15) A My previous address was 32nd
(16) Avenue in Bayside.
(17) Q You no longer reside there,
(18) correct?
(19) A Correct.
(2:0) Q Okay. Do you have any other
(21) residences though, is my question?
(22) A No.
(2:3) Q Okay. What is your highest level
(24) of education?
(25) A High school.
Lexitas Court Reporting
800-678-0166
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023
[Page 13]
December 2, 2022
(1) Y. Sook Park
(2) Q Where did you go to high school?
(3) A South Korea.
(4) Q Ms. Park, do you presently have
(5) health insurance?
(6) A Medicaid.
(7) Q How long have you been a Medicaid
(8) recipient?
(9) A six years, five years,
(10) approximately.
(11) Q Okay. And do you have a primary
(12) care phys ician?
(13) A Yes.
(14) Q Who would that be?
(15) A
Preview
FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 EXHIBIT F FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 AW OFFICES OF TINA NEWSOME-LEE Attorney: Shana A. Kleinman Malling Address Only: Direct Dial: (631)577-7517 P.O. Box 2904 Facsimile: (855) 872-7924 Hartford, CT 06104-2904 EMail: SKLEINMA@travelers.com March 14, 2023 Email: claims@kimlawpc.com Law Offices Of Kim & Associates, Pc 164-01 Northern Blvd Flushing, New York 11358 RE: Matter No.: 2022107113 Claim No.: IPG3941 Examination Under Oath of n S Park Dear Counselor: Enclosed please find one copy of your clienes Rami on Under Oath in the above-referenced matter. Please have your client provide any information and/ r documents which may have been requested and you agreed to provide during this EUO within 20 days of the date of this letter. After doing so, in the presence of a Notary Public, please have the copy duly executed and return it to this office with your clienes signature. Please note you may scan and email the signature page, with errata sheets if applicable, back same to Cinde Kusher at ckusher@travelers.com with the above Matter Number in the subject line. Please be advised that the failure to do so may constitute a breach of the subject automobile policy of insurance as well as noncompliance with the New York State No-Fault Regulations. Thank you for your anticipated cooperation regarding these requests. Very truly yours, Law Offices of Tina Newsome-Lee BY: Shana A. Kleinman, Esq. Direct Dial: (631)577-7517 Not a Partnership or Professional Corporadon AII attorneys are Employees of The Travelers Indemnity Company and its Property Casualty Affiliates FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page l] December 2, 2022 1 _____________________________________Ç In the Matter of the Claim of YUN SOOK PARK TRAVELERS INSURANCE COMPANY Claim No: IPG3941 _________________________________________Ç December 2, 2022 10:30 a.m. Video conference EXAMINATION UNDER OATH OF YUN SOOK PARK Jessica Schmidt Court Reporter Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 2] December 2, 2022 (1) (2) A P P E A R A N C E S: (3) LAW OFFICES OF KIM & ASSOCIATES Attorneys for Claimant (4) 164-01 Northern Boulevard Queens, New York 11358 (5) BY: RICHARD PAK, ESQ. (6) (7) LAW OFFICES OF TINA NEWSOME-LEE (8) Attorneys for Travelers P.O. Box 430 (9) Buffalo, New York 14240 (10) BY: MATTHEW GOUVEIA, INVESTIGATOR (11) (12) ALSO PRESENT: (13) Sean Kim, Korean Interpreter (14) Jae Kim, Korean Interpreter (15) (16) (17) (18) (19) (20) (21) (22) (23) (24) (25) Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 3] December 2, 2022 (1) VIDEO STIPULATIONS (2) (3) IT IS HEREBY STIPULATED AND AGREED by (4) And between counsel for all parties present (5) That this deposition is being conducted by (6) Videoconference, that the Court Reporter, (7) all counsel, and the witness are all in (8) separate remote locations and participating (9) via Videoconference (LegalView/Zoom/WebEx) (10) meeting under the control of Lexitas Court (11) Reporting Service, that the officer (12) administering the oath to the witness shall (13) be sworn in remotely by the Court Reporter (14) after confirming the witness's identity, that (15) this Videoconference will not be recorded in (16) any manner, and that any recording without the (17) express written consent of all parties shall be (10) considered unauthorized, in violation of law, (19) and shall not be used for any purpose in this (2:0) litigation or otherwise. (21) (22) (23) (24) (25) Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 4] December 2, 2022 (1) IT IS FURTHER STIPULATED that exhibits may be (2) marked by the attorney presenting the exhibit to (3) the witness, and that a copy of any exhibit (4) presented to a witness shall be emailed to or (5) otherwise in possession of all counsel prior to (6) any questioning of a witness regarding the exhibit (7) in question. All parties shall bear their own costs (8) in the conduct of this deposition by Videoconference. (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) (22) (23) (24) (25) Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 5] December 2, 2022 (1) (2) S E A N K I M, called as the interpreter (3) in this matter, was duly sworn by a Notary (4) Public of the State of New York to accurately (5) and faithfully translate the questions (6) propounded to the witness from English into (7) Korean and the answers given by the witness from (8) Korean into English. (9) -oOo- (10) Y U N S O O K P A R K, the witness (11) herein, having been first duly sworn by a Notary (12) Public of the State of New York, was examined (13) and testified through the interpreter as (14) follows: (15) EXAMINATION BY (16) MR. GOUVEIA: (17) Q State your name for the record, (18) please. (19) A Yun Sook Park. (20) Q State your address for the record, (21) please. (22) A 16-51 Clintonville Street, (23) Whitestone, New York 11357. (24) Q My name is Matthew Gouveia. I'm (25) an Investigator with Travelers Investigative Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 6] December 2, 2022 (1) Y. Sook Park (2) Services and represent Travelers Insurance (3) Company. We are here 12to conduct the (4) Examination Under Oath of Yun Sook Park, as (5) stated in your insurance policy. (6) Today's Examination is being (7) conducted via Zoom web conference. It concerns (8) Travelers claim number IPG3941, a motor vehicle (9) accident that occurred in Queens, New York, near (10) 160th Street and the Cross Island Parkway. (11) Attending today's Examination with (12) Ms. Yun Park is her selected counsel, (13) Mr. Richard Pak, of the Law Offices of Kim & (14) Associates. Providing Korean to English (15) translation is Mr. Sean Kim. (16) At the attorney's request, a copy (17) of this transcript will be provided. (18) Q Ms. Park, in a moment, I will (19) provide some direction. Before doing so, I just (20) want to verify two things: I want to make sure (21) on the record that our connection is secure. (22) A yes. (23) Q And can you please identify if you (24) can hear and understand your interpreter. (25) A yes. Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 7] December 2, 2022 (1) Y. Sook Park (2) Q Before proceeding, this is nothing (3) personal, I ask it of everybody: Are you under (4) the influence of any medications, drugs or (5) alcohol which would impair your ability to (6) recall events or answer my questions today? (7) A No. (8) Q Ms. Park, please provide all of (9) your responses in Korean today. (10) A Got it. (11) Q Please wait for the translator to (12) translate the questions from English into (13) Korean. (14) A Yes. (15) Q As you can see, there's a Court (16) Reporter in the room present. The Reporter will (17) be noting everything that is being said today on (18) what is called a transcript. It 3 a important (19) that we both do not speak at the same time, so (20) that the Court Reporter can note what we are (21) saying. (22) A yes. (23) Q Please verbalize all of your (24) responses. Do not point. If you're trying to (25) indicate an area, please be as specific as Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 8] December 2, 2022 (1) Y. Sook Park (2) possible. Okay? (3) A I'm not understanding what you (4) mean. What do you mean "area"? (5) Q I don't understand. (6) THE INTERPRETER: You said (7) not to point to the area. Be (8) specific. (9) Q When we're talking about (10) questions, such as injuries, for example, let's (11) say that you indicate that you may have hurt (12) your arm. Please indicate if it was your left (13) or right arm, in that example. (14) A Left arm. (15) Q It was just an example, ma'am. (16) A Okay. (17) Q For another example, when we're (18) discussing the motor vehicle accident, please (19) don't indicate and say things such as "something (20) happened right there" or "over because there", (21) if someone was to read our transcript, it won't (22) be very clear for them to understand. It's just (23) important to provide detail. (24) A yes. (25) Q Thank you. If at any time you Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 9] December 2, 2022 (1) Y. Sook Park (2) don't understand a question that I ask, ask me (3) to repeat or rephrase the question. (4) A Yes. (5) Q If you need to speak to your (6) attorney, please let me know. We may take a (7) short break. If you need to use the restroom or (8) a break for any reason, please let me know. (9) A Yes. (10) Q Can you please state your full (11) name and your date of birth? (12) A Yun Sook Park, Y-U-N S-O-O-K (13) P-A-R-K. KK/KK/1961. (14) MR. PAK: Can we put the (15) year on the record for security (16) purposes? (17) MR. GOUVEIA: I'm okay with (18) that. (19) MR. PAK: You can write (20) down the whole thing, but on the (21) record, just the year. (22) MR. GOUVEIA: Sure. (23) Q Ms. Park, do you go by any other (24) name? (25) A I use Rosa as my English name. Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 10] December 2, 2022 (1) Y. Sook Park (2) Q What are the last four digits of (3) your Social Security number? (4) A . (5) Q What is your present address? (6) A 16-51 Clintonville Street, (7) Whitestone, New York 11357. (8) Q Is that a single-family home? (9) A Yes. (10) Q Do you rent or own the home? (11) A Rental, (12) Q How long have you resided at that (13) address for? (14) A Under five years. (15) Q Who do you reside at that address (16) with? (17) A Husband and my son. (18) Q And what is your husband's name? (19) A Byung Jeu Kim. (20) Q Can you spell that? (21) A B-Y-U-N-G J-E-U K-I-M. (22) Q And what is Mr. Kim's date of (23) birth? (24) A XX/XX/1956. (25) MR, PAK: Again, I ask just Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 11] December 2, 2022 (1) Y. Sook Park (2) the year on the record. (3) MR. GOUVEIA: That's fine. (4) Q Byung Jeu Kim, is that the correct (5) name? (6) A Yes. (7) Q Is Mr. Kim licensed to drive (8) vehicles? (9) A No. (10) Q He does not have a driver's (11) license? (12) A He doesn't. (13) Q Okay. And your son's name? (14) A Brian Gimm, G-I-M-M. (15) Q What is Brian's date of birth? (16) A KX/XX/1991. (17) MR. PAK: Again, just put (18) the year on the record. (19) MR. GOUVEIA: I'm (20) agreeable. That's fine. (21) Q Now, do you have any other (22) children? (23) A My daughter is married. She's (24) married. (25) Q She does not reside in your Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 12] December 2, 2022 (1) Y. Sook Park (2) household? (3) A Correct. (4) Q Okay. Do you reside with anyone (5) else other than your son and your husband? (6) A No. (7) Q How long have you been married (8) for? (9) A With who? (10) Q Byung Jeu Kim? (11) A 1984. (12) Q Okay. Do you have any other (13) address or home, other than the Clintonville (14) street address in Whitestone? (15) A My previous address was 32nd (16) Avenue in Bayside. (17) Q You no longer reside there, (18) correct? (19) A Correct. (2:0) Q Okay. Do you have any other (21) residences though, is my question? (22) A No. (2:3) Q Okay. What is your highest level (24) of education? (25) A High school. Lexitas Court Reporting 800-678-0166 FILED: NEW YORK COUNTY CLERK 12/11/2023 05:04 PM INDEX NO. 161606/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/11/2023 [Page 13] December 2, 2022 (1) Y. Sook Park (2) Q Where did you go to high school? (3) A South Korea. (4) Q Ms. Park, do you presently have (5) health insurance? (6) A Medicaid. (7) Q How long have you been a Medicaid (8) recipient? (9) A six years, five years, (10) approximately. (11) Q Okay. And do you have a primary (12) care phys ician? (13) A Yes. (14) Q Who would that be? (15) A