Preview
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
EXHIBIT E
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
SUPREME COURT OF THE STATE OF N YÒRK
COUNTY OF SUFFOLK
ASHLEY BRACCO,
Plaintiff,
against- Index No:
600234/2023
SKYWAY TRUCK PARTS INC. and MARCUS O.
NIEVES,
Defendants.
EXAMINATION BEFORE TRIAL of the
Plaintiff, ASHLEY BRACCO, taken by the
Defendant, pursuant to Court Order, held
via Videoconference, on May 8th, 2022, at
2:07 p.m., before a Notary Public of the
State of New York.
QUICK REPORTING SERVICE, INC 516-488-8822
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
Page 2
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2 A P P E A R A N C E S:
3 SURIS & ASSOCIATES, PC
Attorneys for Plaintiff
4 395 North Service Road, Suite 302
Melville, New York 11747
5
BY: DANIEL OPISSO, ESQ.
6
FILE #: 4027520AH
7
8
9 SCAHILL LAW GROUP, PC
Attorneys for Defendants
10 1065 Stewart Avenue, Suite 210
Bethpage, New York 11714
11
BY: KEVIN PHILBIN, ESQ.
12 .
MATTER No.: PREF20113863
13
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QUICK REPORTING SERVICE, INC 516-488-8822
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
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2 S T I P U L A T I O N S;
3 IT IS STIPULATED AND AGREED by and between the
attorneys for the respective parties herein,
4 and in compliance with Rule 221 of the Uniform
Rules for the Trial Courts:
THAT the parties recognize the provision of
6 Rule 3115 subdivisions (b), (c) and/or (d).
All objections made at a deposition shall be
7 noted by the officer before whom the deposition
is taken, and the answer shall be given and the
8 deposition shall proceed subject to the
objections and to the right of a person to
9 apply for appropriate relief pursuant to
Article 31 of the CPLR;
10
THAT every objection raised during a deposition
11 shall be stated succinctly and framed so as not
to suggest an answer to the deponent and, at
12 the request of the guestioning attorney, shall
include a clear statement as to any defect in
13 form or other basis of error or irregularity.
Except to the extent permitted by CPLR Rule
14 3115 or by this rule, during the course of the
examination persons in attendance shall not
15 make statements or comments that interfere with
the guestioning.
16
THAT a deponent shall answer all guestions at a
17 deposition, except (i) to preserve a privilege
or right of confidentiality, (ii) to enforce a
18 limitation set forth in an order of a court, or
(iii) when the guestion is plainly improper and
19 would, if answered, cause significant prejudice
to any person. An attorney shall not direct a
20 deponent not to answer except as provided in
CPLR Rule 3115 or this subdivision. Any refusal
21 to answer or direction not to answer shall be
accompanied by a succinct and clear statement
22 on the basis therefore. If the deponent does
not answer a guestion, the examining party
23 shall have the right to complete the remainder
of the deposition.
24
THAT an attorney shall not interrupt the
25 deposition for the purpose of communicating
QUICK REPORTING SERVICE, INC 516-488-8822
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
Page 4
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2 with the deponent unless all parties consent or
the communication is made for the purpose of
3 determining whether the question should not be
answered on the grounds set forth in Section
4 221.2 of these rules, and, in such event, the
reason for the communication shall be stated
5 for the record succinctly and clearly.
6 THAT the failure to object to any question or
to move to strike any testimony at this
7 examination shall not be a bar or waiver to
make such objection or motion at the time of
8 the trial of this action, and is hereby
reserved; and
9
THAT this examination may be signed and sworn
10 to by the witness examined herein before any
Notary Public, but the failure to do so or to
11 return the original of the examination to the
attorney on whose behalf the examination is
12 taken, shall not be deemed a waiver of the
rights provided by Rule 3116 and 3117 of the
13 CPLR, and shall be controlled thereby; and
14 THAT the certification and filing of the
original of this examination are hereby waived;
15 and
16 THAT the questioning attorney shall provide
counsel for the witness examined herein with a
17 copy of this examination at no charge.
18
IT IS HEREBY STIPULATED AND AGREED by and
19 between counsel for all parties present that
Pursuant to CPLR Section 3113(d) this
20 deposition is being conducted by
videoconference, that the court reporter, all
21 counsel, and the witness are all in separate
remote locations and participating via
22 videoconference meeting under the control of
Quick Reporting Service, that the officer
23 administering the oath to the witness need not
be in the place of the deposition, and the
24 witness shall be sworn in remotely by the court
witness'
reporter after confirming the
25 identity, that this videoconference will not be
QUICK REPORTING SERVICE, INC 516-488-8822
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
Page 5
1
2 recorded in any manner, and that any recording
without the express written consent of all
3 parties shall be considered unauthorized, in
violation of law, and shall not be used for any
4 purpose in this litigation or otherwise.
5 IT IS FURTHER STIPULATED that exhibits may be
marked by the attorney presenting the exhibit
6 to the witness, and that a copy of any exhibit
presented to a witness shall be e-mailed to or
7 otherwise in possession of all counsel prior to
any questioning of a witness regarding the
8 exhibit in question. All parties shall bear
their own costs in the conduct of this
9 deposition by videoconference, not withstanding
the obligation by CPLR to supply a copy of the
10 transcript to the deposed party by the taking
party. in civil litigation matters.
11
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QUICK REPORTING SERVICE, INC 516-488-8822
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FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
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2 THE REPORTER: Before I swear in
3 the witness, I will ask counsel to
i 4 stipulate on the record, that the court
5 reporter may swear in the deponent even
6 though they are not in the physical
7 presence of the deponent, and that there
8 is no objection to that at this time,
9 nor will there be an objection to it at
10 a future date.
11 MR. PHILBIN: So stipulated.
12 MR. OPISSO: Agreed.
13 THE REPORTER: Counsel, can you
14 represent that to the best of your
15 knowledge and belief, the witness
16 appearing today via videoconference is
17 indeed Ashley Bracco?
18 MR. OPISSO: Yes, I can.
19 A S H L E Y B R A C C O, the witness herein,
20 having been first duly sworn by a Notary Public
21 of the State of New York, was examined and
22 testified as follows:
23 BY THE REPORTER:
24 Q. State your name for the record, please.
25 A. Ashley Bracco.
QUICK REPORTING SERVICE, INC 516-488-8822
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
Page 7
1 A. BRACCO
2 Q. State your address for the record,
3 please.
4 A. 2213 Southard Avenue, Seaford, New York
5 11783. It's a private home.
6 EXAMINATION BY
7 MR. PHILBIN:
8 Q. Good morning Ms. Bracco.
9 A. Good morning.
10 Q. My name is Kevin Philbin. I am an
11 attorney with the Scahill Law Group. We
12 represent the defendants Skyway Truck Parts
13 Incorporated and Marcus O. Nieves in this
14 lawsuit that you've brought. I am going to be
15 asking you some questions this afternoon about
16 the accident and the injuries that you are
17 claiming as a result.
18 If at any point during the course of
19 this deposition you don't understand a question
20 that I've asked you, please me know, and I will
21 be happy to rephrase it. All right?
22 A. Thank you.
23 Q. Please wait until I finish asking my
24 question before you begin your answer so that
25 the court reporter can create a clear record.
QUICK REPORTING SERVICE, INC 516-488-8822
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
Page 8
1 A. BRACCO
2 Okay?
3 A. Yes.
4 Q. When you answer the questions, please
5 give verbal responses. The court reporter
6 can't take down a hand gesture, or nod of the
7 head, shrugging of the shoulders, things like
8 that, so please make sure all your responses
9 are verbal.
10 A. Okay.
11 Q. All right. If you need to take break
12 for any reason, please let us know; we will be
13 happy to accommodate you. However, if there is
14 a question pending that you have not answered,
15 I ask that you please answer that question
16 before we take a break. Fair enough?
17 A. Okay.
18 Q. Any problems with these instructions?
19 A. No.
20 Q. Prior to testifying today, have you
21 taken any medications or drugs of any kind that
22 might impair your ability to understand my
23 questions and answer them truthfully?
24 A. No.
25 Q. How long have you resided at the Seaford
QUICK REPORTING SERVICE, INC 516-488-8822
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
Page 9
1 A. BRACCO
2 address that you just gave us?
3 A. About a year, a little over a year.
4 Q. Do you reside there with anyone?
5 A. My husband and my daughter.
6 Q. What is your husband's name?
7 A. Anthony.
8 Q. Anthony Bracco?
9 A. Yes.
10 Q. How old is your daughter?
11 A. One.
12 Q. What is your date of birth?
13 A. 3/12/1993.
14 Q. What is your Social Security number?
15 A.
16 Q. Have you ever been known by any other
17 names besides Ashley Bracco?
18 A. Yes, my maiden name is Zerafa.
19 Q. Can you spell that?
20 A. Z-E-R-A-F-A.
21 Q. Thank you. Any other names besides
22 that?
23 A. No.
24 Q. Are you known by any nicknames?
25 A. No.
QUICK REPORTING SERVICE, INC 516-488-8822
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
Page 10
1 A. BRACCO
2 Q. Where were you born?
3 A. Bay Shore, New York.
4 Q. What is your current height and weight?
5 A. 5'3", 200.
6 Q. 200 you said?
7 A. Yes.
8 Q. What was your weight on the day of the
9 accident?
10 A. I don't know.
11 Q. Can you estimate for us?
12 A. 190.
13 Q. Are you right-handed or left-handed?
14 A. Right.
15 Q. You are wearing glasses now. What are
16 those glasses for?
17 A. The computer.
18 Q. Do you wear glasses for distance?
19 A. No.
20 Q. Were you wearing glasses on the date of
21 the accident?
22 A. No.
23 Q. Were you wearing sunglasses on the date
24 of the accident?
25 A. No.
QUICK REPORTING SERVICE, INC 516-488-882
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
Page 11
1 A. BRACCO
2 Q. Are you currently or have you ever been
3 a member of the armed services?
4 A. No.
5 Q. Are you currently or have you ever been
6 a member of law enforcement?
7 A. No.
8 Q. You mentioned that you rent a house in
9 Seaford, correct?
10 A. Correct.
11 Q. Have you been there for about a year?
12 A. Yes.
13 Q. What was the date of the accident that
14 we are here talking about?
15 A. August 14th, 2020.
16 Q. Do you know approximately what time of
17 the day it was?
18 A. Around 4:45 p.m.
19 Q. Where were you living on the day of the
20 accident?
21 A. 82 12th Avenue Holtsville, New York
22 11742.
23 Q. Did you reside there with anyone at that
24 time?
A. was with --
25 Yes, I my that is my
QUICK REPORTING SERVICE, INC S16-488-8822
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024
Page 12
1 A. BRACCO
parents'
2 home.
parents'
3 Q. What are your name?
4 A. Debra Zerafa and Alfred Zerafa.
5 Q. Back in August of 2020, besides yourself
6 and your parents, did anybody else reside that
7 the address in Holtsville?
8 A. My husband Anthony was living there was
9 well.
10 Q. Were you married at that time?
11 A. Recently married, yes.
12 Q. Recently married before the accident?
13 A. Yes.
14 Q. What was the date of your marriage?
15 A. January 18th, 2020.
16 Q. The rental house that you are living in
17 now, is that one two or two floors?
18 A. Two.
19 Q. Are there stairs in the house or
20 elevator or both?
21 A. Stairs.
22 Q. Besides your husband and
Preview
FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 EXHIBIT E FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 SUPREME COURT OF THE STATE OF N YÒRK COUNTY OF SUFFOLK ASHLEY BRACCO, Plaintiff, against- Index No: 600234/2023 SKYWAY TRUCK PARTS INC. and MARCUS O. NIEVES, Defendants. EXAMINATION BEFORE TRIAL of the Plaintiff, ASHLEY BRACCO, taken by the Defendant, pursuant to Court Order, held via Videoconference, on May 8th, 2022, at 2:07 p.m., before a Notary Public of the State of New York. QUICK REPORTING SERVICE, INC 516-488-8822 FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 2 1 2 A P P E A R A N C E S: 3 SURIS & ASSOCIATES, PC Attorneys for Plaintiff 4 395 North Service Road, Suite 302 Melville, New York 11747 5 BY: DANIEL OPISSO, ESQ. 6 FILE #: 4027520AH 7 8 9 SCAHILL LAW GROUP, PC Attorneys for Defendants 10 1065 Stewart Avenue, Suite 210 Bethpage, New York 11714 11 BY: KEVIN PHILBIN, ESQ. 12 . MATTER No.: PREF20113863 13 14 15 16 17 18 19 20 21 22 23 24 25 QUICK REPORTING SERVICE, INC 516-488-8822 FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 3 . 1 2 S T I P U L A T I O N S; 3 IT IS STIPULATED AND AGREED by and between the attorneys for the respective parties herein, 4 and in compliance with Rule 221 of the Uniform Rules for the Trial Courts: THAT the parties recognize the provision of 6 Rule 3115 subdivisions (b), (c) and/or (d). All objections made at a deposition shall be 7 noted by the officer before whom the deposition is taken, and the answer shall be given and the 8 deposition shall proceed subject to the objections and to the right of a person to 9 apply for appropriate relief pursuant to Article 31 of the CPLR; 10 THAT every objection raised during a deposition 11 shall be stated succinctly and framed so as not to suggest an answer to the deponent and, at 12 the request of the guestioning attorney, shall include a clear statement as to any defect in 13 form or other basis of error or irregularity. Except to the extent permitted by CPLR Rule 14 3115 or by this rule, during the course of the examination persons in attendance shall not 15 make statements or comments that interfere with the guestioning. 16 THAT a deponent shall answer all guestions at a 17 deposition, except (i) to preserve a privilege or right of confidentiality, (ii) to enforce a 18 limitation set forth in an order of a court, or (iii) when the guestion is plainly improper and 19 would, if answered, cause significant prejudice to any person. An attorney shall not direct a 20 deponent not to answer except as provided in CPLR Rule 3115 or this subdivision. Any refusal 21 to answer or direction not to answer shall be accompanied by a succinct and clear statement 22 on the basis therefore. If the deponent does not answer a guestion, the examining party 23 shall have the right to complete the remainder of the deposition. 24 THAT an attorney shall not interrupt the 25 deposition for the purpose of communicating QUICK REPORTING SERVICE, INC 516-488-8822 FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 4 1 2 with the deponent unless all parties consent or the communication is made for the purpose of 3 determining whether the question should not be answered on the grounds set forth in Section 4 221.2 of these rules, and, in such event, the reason for the communication shall be stated 5 for the record succinctly and clearly. 6 THAT the failure to object to any question or to move to strike any testimony at this 7 examination shall not be a bar or waiver to make such objection or motion at the time of 8 the trial of this action, and is hereby reserved; and 9 THAT this examination may be signed and sworn 10 to by the witness examined herein before any Notary Public, but the failure to do so or to 11 return the original of the examination to the attorney on whose behalf the examination is 12 taken, shall not be deemed a waiver of the rights provided by Rule 3116 and 3117 of the 13 CPLR, and shall be controlled thereby; and 14 THAT the certification and filing of the original of this examination are hereby waived; 15 and 16 THAT the questioning attorney shall provide counsel for the witness examined herein with a 17 copy of this examination at no charge. 18 IT IS HEREBY STIPULATED AND AGREED by and 19 between counsel for all parties present that Pursuant to CPLR Section 3113(d) this 20 deposition is being conducted by videoconference, that the court reporter, all 21 counsel, and the witness are all in separate remote locations and participating via 22 videoconference meeting under the control of Quick Reporting Service, that the officer 23 administering the oath to the witness need not be in the place of the deposition, and the 24 witness shall be sworn in remotely by the court witness' reporter after confirming the 25 identity, that this videoconference will not be QUICK REPORTING SERVICE, INC 516-488-8822 FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 5 1 2 recorded in any manner, and that any recording without the express written consent of all 3 parties shall be considered unauthorized, in violation of law, and shall not be used for any 4 purpose in this litigation or otherwise. 5 IT IS FURTHER STIPULATED that exhibits may be marked by the attorney presenting the exhibit 6 to the witness, and that a copy of any exhibit presented to a witness shall be e-mailed to or 7 otherwise in possession of all counsel prior to any questioning of a witness regarding the 8 exhibit in question. All parties shall bear their own costs in the conduct of this 9 deposition by videoconference, not withstanding the obligation by CPLR to supply a copy of the 10 transcript to the deposed party by the taking party. in civil litigation matters. 11 12 13 14 15 16 17 . . 18 19 20 21 22 23 24 25 QUICK REPORTING SERVICE, INC 516-488-8822 . . FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 6 1 2 THE REPORTER: Before I swear in 3 the witness, I will ask counsel to i 4 stipulate on the record, that the court 5 reporter may swear in the deponent even 6 though they are not in the physical 7 presence of the deponent, and that there 8 is no objection to that at this time, 9 nor will there be an objection to it at 10 a future date. 11 MR. PHILBIN: So stipulated. 12 MR. OPISSO: Agreed. 13 THE REPORTER: Counsel, can you 14 represent that to the best of your 15 knowledge and belief, the witness 16 appearing today via videoconference is 17 indeed Ashley Bracco? 18 MR. OPISSO: Yes, I can. 19 A S H L E Y B R A C C O, the witness herein, 20 having been first duly sworn by a Notary Public 21 of the State of New York, was examined and 22 testified as follows: 23 BY THE REPORTER: 24 Q. State your name for the record, please. 25 A. Ashley Bracco. QUICK REPORTING SERVICE, INC 516-488-8822 FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 7 1 A. BRACCO 2 Q. State your address for the record, 3 please. 4 A. 2213 Southard Avenue, Seaford, New York 5 11783. It's a private home. 6 EXAMINATION BY 7 MR. PHILBIN: 8 Q. Good morning Ms. Bracco. 9 A. Good morning. 10 Q. My name is Kevin Philbin. I am an 11 attorney with the Scahill Law Group. We 12 represent the defendants Skyway Truck Parts 13 Incorporated and Marcus O. Nieves in this 14 lawsuit that you've brought. I am going to be 15 asking you some questions this afternoon about 16 the accident and the injuries that you are 17 claiming as a result. 18 If at any point during the course of 19 this deposition you don't understand a question 20 that I've asked you, please me know, and I will 21 be happy to rephrase it. All right? 22 A. Thank you. 23 Q. Please wait until I finish asking my 24 question before you begin your answer so that 25 the court reporter can create a clear record. QUICK REPORTING SERVICE, INC 516-488-8822 FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 8 1 A. BRACCO 2 Okay? 3 A. Yes. 4 Q. When you answer the questions, please 5 give verbal responses. The court reporter 6 can't take down a hand gesture, or nod of the 7 head, shrugging of the shoulders, things like 8 that, so please make sure all your responses 9 are verbal. 10 A. Okay. 11 Q. All right. If you need to take break 12 for any reason, please let us know; we will be 13 happy to accommodate you. However, if there is 14 a question pending that you have not answered, 15 I ask that you please answer that question 16 before we take a break. Fair enough? 17 A. Okay. 18 Q. Any problems with these instructions? 19 A. No. 20 Q. Prior to testifying today, have you 21 taken any medications or drugs of any kind that 22 might impair your ability to understand my 23 questions and answer them truthfully? 24 A. No. 25 Q. How long have you resided at the Seaford QUICK REPORTING SERVICE, INC 516-488-8822 FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 9 1 A. BRACCO 2 address that you just gave us? 3 A. About a year, a little over a year. 4 Q. Do you reside there with anyone? 5 A. My husband and my daughter. 6 Q. What is your husband's name? 7 A. Anthony. 8 Q. Anthony Bracco? 9 A. Yes. 10 Q. How old is your daughter? 11 A. One. 12 Q. What is your date of birth? 13 A. 3/12/1993. 14 Q. What is your Social Security number? 15 A. 16 Q. Have you ever been known by any other 17 names besides Ashley Bracco? 18 A. Yes, my maiden name is Zerafa. 19 Q. Can you spell that? 20 A. Z-E-R-A-F-A. 21 Q. Thank you. Any other names besides 22 that? 23 A. No. 24 Q. Are you known by any nicknames? 25 A. No. QUICK REPORTING SERVICE, INC 516-488-8822 FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 10 1 A. BRACCO 2 Q. Where were you born? 3 A. Bay Shore, New York. 4 Q. What is your current height and weight? 5 A. 5'3", 200. 6 Q. 200 you said? 7 A. Yes. 8 Q. What was your weight on the day of the 9 accident? 10 A. I don't know. 11 Q. Can you estimate for us? 12 A. 190. 13 Q. Are you right-handed or left-handed? 14 A. Right. 15 Q. You are wearing glasses now. What are 16 those glasses for? 17 A. The computer. 18 Q. Do you wear glasses for distance? 19 A. No. 20 Q. Were you wearing glasses on the date of 21 the accident? 22 A. No. 23 Q. Were you wearing sunglasses on the date 24 of the accident? 25 A. No. QUICK REPORTING SERVICE, INC 516-488-882 FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 11 1 A. BRACCO 2 Q. Are you currently or have you ever been 3 a member of the armed services? 4 A. No. 5 Q. Are you currently or have you ever been 6 a member of law enforcement? 7 A. No. 8 Q. You mentioned that you rent a house in 9 Seaford, correct? 10 A. Correct. 11 Q. Have you been there for about a year? 12 A. Yes. 13 Q. What was the date of the accident that 14 we are here talking about? 15 A. August 14th, 2020. 16 Q. Do you know approximately what time of 17 the day it was? 18 A. Around 4:45 p.m. 19 Q. Where were you living on the day of the 20 accident? 21 A. 82 12th Avenue Holtsville, New York 22 11742. 23 Q. Did you reside there with anyone at that 24 time? A. was with -- 25 Yes, I my that is my QUICK REPORTING SERVICE, INC S16-488-8822 FILED: SUFFOLK COUNTY CLERK 02/23/2024 02:41 PM INDEX NO. 600234/2023 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/23/2024 Page 12 1 A. BRACCO parents' 2 home. parents' 3 Q. What are your name? 4 A. Debra Zerafa and Alfred Zerafa. 5 Q. Back in August of 2020, besides yourself 6 and your parents, did anybody else reside that 7 the address in Holtsville? 8 A. My husband Anthony was living there was 9 well. 10 Q. Were you married at that time? 11 A. Recently married, yes. 12 Q. Recently married before the accident? 13 A. Yes. 14 Q. What was the date of your marriage? 15 A. January 18th, 2020. 16 Q. The rental house that you are living in 17 now, is that one two or two floors? 18 A. Two. 19 Q. Are there stairs in the house or 20 elevator or both? 21 A. Stairs. 22 Q. Besides your husband and