NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019 1 2 …

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DIAMOND REPORTING (877) 624-3287 [email protected]

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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS------------------------------------------X A.H., as Infant and Natural Guardian, ZAHED HOSSAIN,

PLAINTIFF,

-against- Index No.: 510843/2015E

FERDOUSHI KAMAL, as Administrator of the Estate of MOHAMMAD M. KAMAL, M.D.,Deceased, MOHAMMAD KAMAL, PHYSICIAN, P.C., MARLA LEVINE, M.D., CARMEN CORTIS, D.O., and MAIMONIDES MEDICAL CENTER,

DEFENDANTS. ------------------------------------------X

DATE: August 2, 2019

TIME: 10:25 a.m.

VIDEOCONFERENCED DEPOSITION of a

non-party witness, SHAHAJADI BEGUM, taken

by the Defendants, pursuant to Notice Under

Article 31 of the Civil Practice Law and

Rules, held at the offices of Metschl &

Associates, 295 Main Street, Buffalo, New

York 14203, before Patricia A. Schreier, a

Notary Public of the State of New York.

FILED: KINGS COUNTY CLERK 10/01/2019 04:59 PM INDEX NO. 510843/2015

NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019

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A P P E A R A N C E S:

DUFFY & DUFFY, PLLC Attorneys for the Plaintiff 1370 RXR Plaza West Tower, 13th Floor Uniondale, New York 11556 BY: ROBERT J. CRISTIANO, ESQ.

CONNICK, MYERS, McNAMEE & FITZGERALD, PLLC Attorneys for the Defendants FERDOUSHI KAMAL, as Administrator of the Estate of MOHAMMAD M. KAMAL, M.D., and MOHAMMAD KAMAL, PHYSICIAN, P.C.114 Old Country Road, Suite 208 Mineola, New York 11501 BY: TARYN FITZGERALD, ESQ. (Via videoconference)

McALOON & FRIEDMAN, P.C. Attorneys for the Defendants MARLA LEVINE, M.D., CARMEN CORTIS, D.O., and MAIMONIDES MEDICAL CENTER123 William Street, 25th Floor New York, New York 10038 BY: PAUL PALEY, ESQ.(Via videoconference)

ALSO PRESENT:

TAHMINA SHOMPA, Bengali Interpreter



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221. UNIFORM RULES FOR THE CONDUCT OF DEPOSITIONS221.1 Objections at Depositions

(a) Objections in general. No objections shall be made at a deposition except those which, pursuant to subdivision (b), (c) or (d) of Rule 3115 of the Civil Practice Law and Rules, would be waived if not interposed, and except in compliance with subdivision (e) of such rule. All objections made at a deposition shall be noted by the officer before whom the deposition is taken, and the answer shall be given and the deposition shall proceed subject to the objections and to the right of a person to apply for appropriate relief pursuant to Article 31 of the CPLR.

(b) Speaking objections restricted. Every objection raised during a deposition shall be stated succinctly and framed so as not to suggest an answer to the deponent and, at the request of the questioning attorney, shall include a clear statement as to any defect in form or other basis of error or irregularity. Except to the extent permitted by CPLR Rule 3115 or by this rule, during the course of the examination persons in attendance shall not make statements or comments that interfere with the questioning.221.2 Refusal to answer when objection is made A deponent shall answer all questions at a deposition, except (i) to preserve a privilege or right of confidentiality, (ii) to enforce a limitation set forth in an order of the court, or (iii) when the question is plainly improper and would, if answered, cause significant prejudice to any person. An attorney shall not direct a deponent not to answer except as provided in CPLR Rule 3115 or this subdivision. Any refusal to answer or direction not to answer shall be accompanied by a succinct and clear statement of the basis therefor. If the deponent does not answer a question, the examining party shall have the right to complete the remainder of the deposition.



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221. UNIFORM RULES FOR THE CONDUCT OF DEPOSITIONS

221.3 Communication with the deponentAn attorney shall not interrupt the

deposition for the purpose of communicating with the deponent unless all parties consent or the communication is made for the purpose of determining whether the question should not be answered on the grounds set forth in section 221.2 of these rules and, in such event, the reason for the communication shall be stated for the record succinctly and clearly.

IT IS FURTHER STIPULATED AND AGREED that the transcript may be signed before any Notary Public with the same force and effect as if signed before a clerk or a Judge of the court.

IT IS FURTHER STIPULATED AND AGREED that the examination before trial may be utilized for all purposes as provided by the CPLR.

IT IS FURTHER STIPULATED AND AGREED that all rights provided to all parties by the CPLR cannot be deemed waived and the appropriate sections of the CPLR shall be controlling with respect hereto.

IT IS FURTHER STIPULATED AND AGREED by and between the attorneys for the respective parties hereto that a copy of this examination shall be furnished, without charge, to the attorneys representing the witness testifying herein.



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S. BEGUM

T A H M I N A S H O M P A, a Bengali

Interpreter, having first been duly sworn,

promised to interpret the proceedings to

the best of her ability.

S H A H A J A D I B E G U M, 548 Minnesota

Avenue, Buffalo, New York 14215, having

first been duly sworn, was examined and

testified as follows:

EXAMINATION BY

MR. PALEY:

Q. Good morning. My name is Paul

Paley and I represent Maimonides Medical

Center in this case.

I'm going to ask you some

questions this morning regarding your son.

If there are any questions you do not

understand or you would like me to repeat,

please tell me and I will do so.

A. Yes.

Q. The only instructions I will

give you is that you have to answer

verbally. You can't nod your head or shake

your head. And wait until I complete my

question until you start to answer because



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S. BEGUM

the reporter cannot take down both of us

talking at one time.

A. Yes.

Q. Everything I've said to you,

have you understood?

A. Yes.

Q. How long have you lived at 548

Minnesota Avenue?

A. I'm not able to recall exactly

how long.

Q. Is it more than --

A. It could be about five years.

Q. And is that a private house?

A. Yes.

Q. And what is your date of birth?

MR. CRISTIANO: Just put the

year.

A. X/X/1981.

Q. I'm going to ask you your

Social Security Number, but to protect your

privacy we will not put it on the record.

A. XXX-XX-XXXX.

Q. And who do you live with at the

present time?



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S. BEGUM

A. I didn't understand.

Q. In your house, who do you live

with now?

A. My family, my children and my

husband.

Q. And what is your husband's

name?

A. Zahed, Z-A-H-E-D H-O-S-S -- I'm

not able to recall his name, exactly.

Q. Is his last name H-O-S-S-A-I-N?

A. Yes, yes.

Q. And how many children do you

have?

A. Three.

Q. Do you have one boy and two

girls?

A. Yes.

Q. And what is your son's name?

A. A.H.

MR. CRISTIANO: Just the

initials please.

MR. PALEY: So, Rob, we'll

agree that every time I will use the

name, that the reporter will just put



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S. BEGUM

the initials?

MR. CRISTIANO: Correct, for

the subject and his siblings.

They're all minors. So we can just

use all of their initials on the

record. We can just write them down.

MR. PALEY: So whenever I say

A.H. she'll understand that that's

her son.

MR. CRISTIANO: Are you going

to say A.H.?

MR. PALEY: I will say A.H., if

you prefer, Rob. I thought I would

just say the name and the reporter

will put A.H.

MR. CRISTIANO: Whichever way,

I want just the initials on the

record.

MR. PALEY: All right. I guess

it's easier for me to say A.H.

Q. How old is A.H.?

A. Seventeen.

Q. Seventeen?

A. Yes.



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S. BEGUM

Q. And how old are your two

daughters?

A. I can tell you their date of

birth.

Q. Please tell me their dates of

birth.

A. The eldest daughter is March

24, 2007. The younger daughter is June 12,

2019.

Q. Your younger daughter was born

a month ago?

A. Yes, yes.

MR. CRISTIANO: There may be

something lost here.

A. X/X/2012.

MR. CRISTIANO: Just the year

please.

Q. All right. Were you married to

your husband in Bangladesh or in the United

States?

A. In Bangladesh.

Q. Did you come to the United

States with your husband?

A. No.



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S. BEGUM

Q. Were you married when you came

to the United States?

A. Yes.

Q. When did you come to the United

States, in what year?

A. Maybe, 2005. I'm not sure.

Q. Are you an American citizen?

A. Yes.

Q. In what year did you become a

citizen?

A. Maybe, 2012.

MR. CRISTIANO: Just note my

objection. Answered over objection.

Q. How far did you go in school?

A. I completed SSC degree in my

county. I have SSC degree and diploma in

Bangladesh.

Q. Do you work at the present

time?

A. No.

Q. Have you worked at all since

you came to the United States?

A. No.

Q. Did you work at all in



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S. BEGUM

Bangladesh?

A. No.

Q. Do you speak English?

A. A little bit, not much.

Q. Do you understand English?

A. A little bit, not much.

Q. And between you and your

husband, who speaks better English?


objection, but you can answer.

A. I don't know.

Q. Between you and your husband,

who understands more English?


objection.

A. Almost the same.

Q. I don't understand.

A. We're almost the same. I meant

by that, like almost the same.

Q. If you took your son to a

doctor who speaks English, would you be

able to tell the doctor your son's medical

complaints in English or not?

MR. CRISTIANO: That's today?



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S. BEGUM

Q. Today.

A. Now I'm -- now I go with my son

because he speaks better -- now I go with

my son since he speaks and understands

better English. That's why whatever he

needs, he tells the doctor. Before there

was a Bengali doctor.

Q. In 2013 could you go to a

doctor who only speaks English and tell the

doctor what your son's medical complaints

were in English, I'm talking about you?

A. Actually, I didn't understand.

Are you asking about my son?

Q. No. I'm asking if you took

your son to a doctor or hospital in 2013

and the doctor only spoke English, could

you tell the doctor in English what your

son's complaints were?

A. In 2013 I actually used to go

to Dr. Kamal. He's from Bangladesh and he

speaks Bengali.

MR. CRISTIANO: Do you want her

to read the question back?

MR. PALEY: Yes, please.



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S. BEGUM

(Record read back)

A. I never took him to the

hospital because he was okay. Maybe, once

or twice I took him to Dr. Kamal.

MR. CRISTIANO: All right.

Maybe, there is some confusion but

what he's asking about, he's asking a

pretty straightforward question,

which is could she speak English to

her son's doctors?

MR. PALEY: Right.

A. Before he got sick, I took him

once or twice to the doctor. I am not able

to recall properly.

Q. What grade in school is your

son going into in September?

A. In 12th grade.

Q. And is that in high school?

A. Are you speaking about next

year?

Q. Yes, after this summer.

A. Yes.

Q. And what school does he go to?

A. Currently, what school he's



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S. BEGUM

going -- same school.

Q. Which school is he going to

after the summer? What is the name of the

school?

A. Olmstead.

Q. The school is called Olmstead,

O-L-M-S-T-E-A-D?

A. Okay. Maybe. Could be. I

forgot. I'm not able to help you.

Q. Does your son intend to go to

college?

A. Yes.

Q. Has he taken any tests in order

to get into college?

A. Yes.

Q. Is there a particular college

that he wants to go to?

A. I don't know yet.

Q. Before your son got sick in

2013, are you aware of any medical

conditions that he had?

A. No.

Q. No, I'm not aware or no, he did

not have any?



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S. BEGUM

MR. CRISTIANO: Note my

objection.

A. He did not have any.

Q. Before your son got sick in

2013, was he taking any prescription

medications?

A. I'm not able to recall,

exactly.

Q. In 2013 did your son have a

pediatrician?

A. Yes.

Q. Was it Dr. Kamal?

A. Yes.

Q. Was Dr. Kamal in Brooklyn?

A. Yes.

Q. Do you remember what year your

son first started seeing Dr. Kamal?

A. No, I don't remember. When we

came, then we took him. Right now, I'm not

able to recall.

Q. And when your son went to see

Dr. Kamal over the years, did you take your

son, did your husband take your son or

would it be one or the other?



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S. BEGUM

A. My husband used to take him.

Q. Did you ever take your son to

see Dr. Kamal instead of your husband?

A. As I told you earlier, probably

I took him once or twice, I'm not able to

recall properly, when he was sick.

Q. Is there a reason that your

husband took your son to Dr. Kamal more

than you did?

A. Yes. I had a baby in 2012 and

that's why I was sick.

Q. How about before you had a

baby, is there a reason that your husband

took your son to Dr. Kamal as opposed to

you?

A. Can you say that again?

Q. Before you had a baby in 2012,

when your son went to see Dr. Kamal is

there a reason why your husband took your

son instead of you?

A. My husband used to do it.

Q. Why did your husband take him

instead of you?

A. I was staying home, since I'm



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S. BEGUM

remembering. I was not going. That's why

he was taking him.

Q. In what year did your son A.H.

get sick?


exactly.

MR. CRISTIANO: Objection.

Q. Was it in 2013?

A. Maybe. Since it's been six

years, I'm not able to recall that.

Q. When your son got sick, do you

remember the first complaints that he was

making?

A. Yes.

Q. And what complaints did he

make?

A. He used to have joint pain and

he used to complain about a fever and pain.

Q. When you say he complained

about a fever, did he complain about a

fever or was his temperature taken and it

showed a fever?

A. I'm not completely clear about

fever, but he used to complain about pain.



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S. BEGUM

Q. And to what part or parts of

his body did he complain of pain?

A. All the joints or fingers or

wrists, elbows, neck, legs, neck.

Q. Did he make these complaints

about joint pain to the fingers, wrists,

elbows and neck at the same time or were

these complaints made at different times?

A. He used to complain, but I'm

not able to recall.

Q. In other words, can you recall

if first he complained about pain in one

place and then another place the next day

or a few days later or were all the

complaints about his joints at the same

time?

MR. CRISTIANO: Or something

else.

Q. Or something else.

A. While he was writing, while he

was writing one day he was complaining

about his fingers and hand and then it

started with neck.

Q. How long after he complained



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S. BEGUM

about his fingers and hand did he complain

about the neck?

A. I did not understand.


about his fingers and hand did he complain

about the neck?

A. He complained about neck first.

Q. And then he complained about

the hand?


objection.

A. Yes.


about the neck did he complain about the

hand?

A. I don't remember.

Q. And were there times when he

complained about pain in the fingers,

wrist, elbows and neck all at the same

time?

A. Yes and then his hands, legs

and neck were like bending.

Q. Did your -- was your son taken

to the doctor as a result of these



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S. BEGUM

complaints?

A. Yes. I told you before that I

took him once or twice to the doctor. It

was a bad time.

Q. So when he was complaining

about joint pain in various parts of his

body, that's when you took him to the

doctor?


objection.


when I took him, before or after he started

to complain, but so far around that time I

took him.

Q. Is this Dr. Kamal?

A. Yes, yes.

Q. And how long after your son

starting making these complaints of joint

pain did you take your son to Dr. Kamal for

the first time?


when I took him, but so far I recall that,

after he started to complain but I'm not

sure exactly when.



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S. BEGUM

Q. And when you saw Dr. Kamal, did

you speak to him in Bengali?

A. Yes.

Q. And what did you tell Dr. Kamal

about your son's condition?

A. When I went I complained about

his joint pain and he was coughing and the

symptoms was not that good to me.

Q. And did Dr. Kamal examine your

son at that time?

A. Yes, he did. He checked his

heartbeat and others.

Q. Did he check his throat?

A. I don't remember that.

Q. Do you remember the month of

this visit?

A. No.

Q. Do you remember the year?

A. No. I'm not able to recall.

Q. And after examining your son,

what did Dr. Kamal say at the time of this

visit?

A. He said he's fine, he has no

problem.



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S. BEGUM

Q. And did he say anything,

specifically, about the complaints of joint

pain?

A. No. He did not say anything.

Q. And after that visit to Dr.

Kamal when he said that everything was

fine, how was your son doing after that?

MR. CRISTIANO: Just a minute.

Immediately after?

MR. PALEY: Well, in the days

after that visit.


A. I don't remember, exactly, how

long after but after a few days after I

took him to Dr. Kamal. He was getting

worse. His health was getting worse and

then my husband took him to Maimonides

Hospital.

Q. Was there one visit to Dr.

Kamal before your husband took your son to

Maimonides or more than one visit with the

complaints that you talked about, joint

pain?




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S. BEGUM

objection. That she took him to?

Q. That either you or your husband

took him to Dr. Kamal before your husband

took your son to Maimonides with complaints

of joint pain.


Q. After you took your son to Dr.

Kamal when your son had complaints of joint

pain, did your husband also take your son

to Dr. Kamal before he took your son to

Maimonides?

A. My husband and I, we both took

him that doctor but I'm not sure how many

times.

Q. Well, the visit you spoke about

when your son was complaining of joint pain

and coughing and his symptoms did not look

good to you, to Dr. Kamal, was that a visit

that you took your son or was your husband

with you?

A. I took him by myself.

Q. And is there a reason you took

your son on that visit and your husband

didn't take him?



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S. BEGUM

A. Maybe, my husband was busy that

day. That's why I took him. I don't

remember, exactly.

Q. When your husband took your son

to Maimonides Hospital, do you know what

date that was?

A. No.

Q. Did you go to the hospital with

your son and husband?

MR. CRISTIANO: Maimonides.

A. No.

Q. Did your son stay overnight at

Maimonides or did they treat him and

release him when your husband took him to

Maimonides?

MR. CRISTIANO: For the first

time?

Q. The first time.


Q. How many times in all did your

son go to Maimonides?

A. I don't remember, exactly.

Q. After your son came back from

Maimonides the first time when your husband



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S. BEGUM

took him, did your husband tell you what

they said at Maimonides about your son's

condition?

MR. CRISTIANO: Just note an

objection.

A. Yes. So after he came back he

did say, but I'm not able to recall.

Q. On the day that your husband

took your son to Maimonides for the first

time, do you recall what your son's

complaints were on that day before your

husband took him?

A. Maybe he had all the symptoms

-- the same symptoms. Maybe he was

complaining about same symptoms. Maybe

that's why he took him.

MR. CRISTIANO: Maybe that's

why he took him?

A. Maybe that's why he took him.


Q. And when you say the same

symptoms, what symptoms were those?

A. I'm not able to recall them

now.



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Q. After your son came back from

Maimonides with your husband for the first

time, did your son go back to Dr. Kamal?

A. Maybe. No. I don't remember.

Q. Did your son go to Maimonides

again a second time after your husband took

him the first time?

A. I didn't understand.

Q. Did your son go to Maimonides

again a second time after your husband took

him the first time?

A. Yes, he did because he got sick

again.

Q. And how long after your husband

took your son to Maimonides the first time

did he go the second time when he got sick

again?

A. I don't remember the exact day

and time.

Q. Do you know if it was a week

later or two weeks later or three weeks

later?

A. Could be. I'm not able to

recall the exact time or days.



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Q. Between the first visit to

Maimonides and the second visit when your

son got sick again, did your son go to see

Dr. Kamal at all?

A. I am not able to recall right

now.

Q. And between the first time your

husband took your son to Maimonides and the

second time he went to Maimonides when he

got sick again, what was your son's

condition like?


objection to condition.

A. His condition was not that

great.

Q. When you say it was not that

great, why was it not that great?

A. To me, he was not that great.

I felt like he was not doing okay.

Q. What complaints was he making

that made you feel that he was not doing

okay?

A. He was coughing, he was losing

weight and he was complaining so much that



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he felt like he was not doing okay.

Q. Was he making complaints about

joint pain?

A. Yes.

Q. And between the first and the

second time he went to Maimonides, where

was he complaining of joint pain, to what

part of his body?

A. I'm not able to recall the

exact body parts that he was complaining,

but he was complaining about pain.

Q. Between the first visit to

Maimonides when your husband took him and

the second time he went to Maimonides, did

he miss any time from school?

A. I'm not able to recall exactly,

but Dr. Kamal told him to send him to the

school.

Q. Do you recall taking your son

to Dr. Kamal a few days after your husband

first took your son to Maimonides?

A. No. I don't remember.

Q. Do you remember any

conversations that you had with Dr. Kamal



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about your son's medical condition?

MR. CRISTIANO: That's ever?

MR. PALEY: No. I'll be more

specific.

Q. Do you recall any conversations

that you had with Dr. Kamal after your son

first started complaining of joint pain?

MR. CRISTIANO: That's other

than what she already testified to?

MR. PALEY: Other than what she

testified to.

A. I complained about breathing.

Like he had to -- he used to breathe a lot

--

Q. You mean --

MR. CRISTIANO: Were you done?

A. No.

Q. I'm sorry, I thought you were.

Go ahead.

A. I'm not able to recall that, if

I mentioned it to him but he used to have

short of breath at nighttime.

Q. And when you say he had short

of breath at nighttime, was that in the



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S. BEGUM

same time that he was complaining of joint

pain?


when it was and he also mentioned about his

heart, like he used to have pain like in

his heart.

Q. When you say "he", you mean

your son?

A. Yes, yes.

Q. Was he complaining about pain

in his heart at the same time that he was

complaining of joint pain or at a different

time?


objection.

A. Maybe in different, but I'm not

sure. Maybe he said, but I'm not able to

recall when.

Q. Well, on the visit that you

took your son to see Dr. Kamal when he

complained about coughing and joint pain,

was he also complaining of shortness of

breath?

A. I don't remember if I said



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S. BEGUM

about his short of breath, but I mentioned

about other two.

Q. Other two meaning coughing and

joint pain?

A. Maybe.

Q. And how about heart pain, did

you mention anything about heart pain at

the time you complained -- you told Dr.

Kamal about the complaint of coughing and

joint pain?


Q. Other than what you said Dr.

Kamal said after that visit you took your

son to, do you recall any other

conversations with Dr. Kamal about your

son's physical condition during the time

that he was complaining of joint pain?

A. I'm not able to recall right

now. Whatever so far I have remembered, I

already said to you.

Q. You don't remember any other

conversation?

MR. CRISTIANO: Just for

clarification, this is in person or



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on the phone?

Q. Either in person or on the

phone.

A. Even if I had more

conversation, I'm not able to recall now.

Q. All right. You said that your

son went back to Maimonides when he got

sick again. Who took your son to

Maimonides at that time, you, your husband

or both of you?

A. My husband.

Q. And do you know why your

husband took your son back to Maimonides

that day?

A. When?

Q. When your son got sick again

and your husband took your son to

Maimonides for the second time --

A. Because at nighttime his health

was going -- getting worse like and like he

was having short of breath and he was

vomiting. That's why.

Q. And for how long was he short

of breath and vomiting before your husband



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took him to Maimonides the second time?

A. Maybe, for a long time but I'm

not able to recall.

Q. And was your son admitted to

the hospital when your husband took him the

second time?

A. I'm not able to recall that

exactly, but at the last time he was

admitted.

Q. So the last time he was at

Maimonides he was admitted to the hospital?

A. Yes.

Q. For how long was he at the

hospital when he was admitted?

A. Maybe, once or twice. I don't

remember.

Q. What do you mean by once or

twice, one or two days or something else?

A. Maybe, one or two days but I

don't remember now.

Q. Did you visit your son in the

hospital when he was admitted for one to

two days?

MR. CRISTIANO: Just for



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S. BEGUM

clarification, we're talking about

Maimonides right now?

MR. PALEY: Maimonides.

A. Yes.

Q. And did anyone tell you what

was wrong with your son when he was at

Maimonides for one to two days?

A. No one told me anything. I

don't remember.

Q. And was your husband also there

when your son was admitted to Maimonides

for one to two days?

A. Yes.

Q. Did your husband speak to the

doctors at Maimonides when your son was

there for one to two days?

A. I don't know that now, whoever

he spoke with.

Q. Did your husband tell you what

was wrong with your son when your son was

at Maimonides for one to two days?

MR. CRISTIANO: Just over my

objection.

A. No. He didn't tell me



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S. BEGUM

anything. Probably, because I was really

tension (sic), that's why he didn't want to

tell me anything.

Q. After your son was at

Maimonides -- withdrawn. After your son

was at Maimonides for one to two days,

where did he go next?

MR. CRISTIANO: For care and

treatment?

Q. Care and treatment.

A. In Columbia Hospital.

Q. Is that Columbia Presbyterian

Hospital in Manhattan?

A. Maybe. I'm not able to recall

that now.

Q. Were you told why your son was

being -- withdrawn. Was your son

transferred from Maimonides hospital

directly to Columbia Presbyterian Hospital?

A. Maybe. I was not in there.

Maybe.

Q. How long was your son at

Columbia Hospital?




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S. BEGUM

exactly.

Q. Was it weeks, was it days? Do

you know?

A. Maybe, one month.

Q. And did you visit your son when

he was at Columbia Hospital for the month?

A. Yes.

Q. And how often did you visit

him?

A. I'm unable to recall that now.

Q. Did any doctor tell you about

what was wrong with your son when he was at

Columbia?

A. No.

Q. Did your husband tell you what

any doctor told him about what was wrong

with your son when he was at Columbia?


objection.

A. He mentioned about pneumonia.

Q. Anything else?

A. He did not say anything else to

me.

Q. Did he ever say anything to you



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S. BEGUM

about a condition known as rheumatic fever?

A. He just told me that he also

had rheumatic fever.

Q. When your son was at Maimonides

when he was admitted for one to two days

and at Columbia, was your husband more

involved in speaking with the doctors than

you were?


objection.

A. I don't know if he spoke to

them directly. I don't know.

Q. But would he be more involved

in speaking with them than you were?

A. Yes.

Q. Do you know where in the

hospital your son was during the month he

was there, what unit or units?

A. No, I don't remember.

Q. Did you observe or did someone

tell you what they were doing for your son

while he was at Columbia?

A. No. I did not ask anybody and

nobody told me anything. I was really



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S. BEGUM

tense.

Q. During the month that you were

visiting your son at Columbia, did he make

any complaints to you about his physical

condition?

A. No. He did not tell me

anything.

Q. After your son was discharged

from Columbia, where did he go?

A. Then he came back home, my

home.

Q. And on the day he was

discharged, was he making any physical

complaints to you?

A. I don't remember that, if he

made any complaints.

Q. And did your son have any

further admissions to Columbia after that

one month?

A. Maybe, for a checkup, you know,

we took him back but I don't remember.

Q. But did he have any admissions

where he stayed for a few days at Columbia

after that one month admission?



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S. BEGUM

A. Maybe, no.

Q. When you say maybe no, is it no

or you're not sure?


objection.

A. I don't remember. I'm not

sure.

Q. All right. Where was your son

seen for treatment after he was discharged

from Columbia, outpatient treatment?


objection.

A. I don't remember that, after

that, but we moved to Buffalo.

Q. While your son was at Columbia,

did you have any telephone conversations

with Dr. Kamal?

A. No.

Q. After your son was released

from Columbia, did either you or your

husband ever take your son back to Dr.

Kamal?

A. I don't remember about my

husband. Probably. I did not go.



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Q. You don't remember if your

husband ever went with your son back to Dr.

Kamal after Columbia, correct?

A. No.

Q. In what month and year did you

move to Buffalo?

A. I don't remember exactly, but

after he got released from there. I'm not

able to recall the month.

Q. Do you remember the year?

A. Yes. Maybe, in '13.

MR. CRISTIANO: That's 2013?

A. Yes.

Q. And when you moved to Buffalo,

did your son start treatment with a

pediatrician in Buffalo?

A. Yes.

Q. What was the name of the

pediatrician?

A. Dr. Holmes.

Q. Dr. David Holmes?

A. Holmes.

MR. CRISTIANO: H-O-L-M-E-S.

Q. H-O-L-M-E-S?



41

1 S. BEGUM

2 A. Yes.

3 Q. And does he continue to be your

4 son's pediatrician today?

5 A. Yes.

6 Q. And did he treat your son at a

7 clinic or a medical center or by himself or

8 is he by himself?

9 A. It's in the family healthcare

10 center. I don't know if it is his own or

11 not.

12 Q. Is it called the ECMC Family

13 Health Center?

14 A. Yes.

15 Q. And when your son sees Dr.

16 Holmes, who takes your son, you or your

17 husband or do you alternate?

18 A. Mostly, my husband takes him.

19 I go sometimes.

20 Q. How often does your son see Dr.

21 Holmes?

22 A. He have to go every month for

23 his injection.

24 Q. Does Dr. Holmes give him the

25 injections?


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1 S. BEGUM

2 A. I'm not sure, but nurse.

3 Q. The nurse gives the injection?

4 A. Yes.

5 Q. And is this a penicillin

6 injection?

7 A. Maybe, penicillin.

8 Q. And have you spoken to Dr.

9 Holmes about these injections?

10 A. No.

11 Q. Did Dr. Holmes tell you for how

12 long your son will need to have these

13 injections?

14 A. No. Nobody told me anything

15 about.

16 Q. About what?

17 A. But I'm not sure -- I don't

18 remember how long.

19 Q. During the times that you've

20 taken your son to Dr. Holmes, has he said

21 anything to you about your son's medical

22 condition?

23 MR. CRISTIANO: Just note my

24 objection.

25 A. Maybe. No.


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1 S. BEGUM

2 Q. Other than Dr. Holmes, has your

3 son seen a cardiologist during the time

4 that he was in Buffalo since you've been in

5 Buffalo?

6 A. No.

7 Q. Has your son seen a

8 cardiologist named Dr. Glenn Leonard?

9 A. No, I did not.

10 MR. CRISTIANO: Did she see or

11 did her son see?

12 Q. The question is did your -- has

13 your son seen a cardiologist since you

14 moved to Buffalo?

15 A. I don't remember that.

16 Q. You said a little earlier that

17 the cardiologist said something about your

18 son's penicillin injections. So who are

19 you referring to?

20 A. I meant my son told me, that's

21 why.

22 Q. Are you aware of your son

23 seeing any doctor for your son's heart in

24 Buffalo?

25 A. For heart?


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1 S. BEGUM

2 Q. Yes.

3 A. I know that he just goes to

4 cardiology.

5 Q. Have you ever gone with your

6 son to the cardiologist?

7 A. No.

8 Q. Is the cardiologist in the same

9 family health center as Dr. Holmes or at a

10 different place?

11 MR. CRISTIANO: If you know.

12 A. I don't know.

13 Q. Other than the penicillin

14 injections, does your son take any

15 prescription medication at home at the

16 present time?

17 A. Yes.

18 Q. What does he take?

19 A. He takes blood pressure

20 medication.

21 Q. Do you know the name of the

22 medication?

23 A. Lisinopril.

24 Q. Lisinopril?

25 A. Yes.


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1 S. BEGUM

2 Q. Did he take blood pressure

3 medication before he was taking Lisinopril?

4 A. Maybe. He used to. Actually,

5 he started it after he got sick.

6 Q. Did your son ever have a

7 problem with his blood pressure before he

8 got sick?


10 objection. She testified he took

11 what she understood to be a blood

12 pressure pill.

13 Q. Did your son, did any doctor

14 tell you that your son has a blood pressure

15 problem now?

16 A. Yes.

17 Q. Who told you that your son has

18 a blood pressure problem?

19 A. Whenever I take him to the

20 doctor and then a nurse takes his blood

21 pressure, then they tell me.

22 Q. What do they tell you?

23 A. They said high. That's why he

24 needs medication.

25 Q. High blood pressure?


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1 S. BEGUM

2 A. Yes.

3 Q. Did your son have high blood

4 pressure before he got sick?

5 A. No.

6 Q. Other than the Lisinopril and

7 the penicillin injections, does your son

8 take any medications at the present time?

9 A. No.

10 Q. What is the name of the

11 pharmacy where the Lisinopril medication

12 prescription is filled?

13 A. Previously, he used to take it

14 from Buffalo and probably he's taking from

15 Rite Aid. Probably, he's taking now from

16 Rite Aid.

17 Q. Other than the cardiologist and

18 Dr. Holmes, does your son see any other

19 doctors at the present time?

20 MR. CRISTIANO: Just note she

21 also said ECMC.

22 Q. Well, you said that your son

23 sees Dr. Holmes at ECMC. Does he see any

24 other doctors at ECMC?

25 A. He used to see him before.


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1 S. BEGUM

2 Q. So now another doctor besides

3 Dr. Holmes sees your son at ECMC?

4 A. Yes. I don't go there all the

5 time. There is a nurse and then -- I don't

6 know much about it.

7 Q. Well, do you know the names of

8 any of the doctors at ECMC Family Health

9 Center that your son sees aside from Dr.

10 Holmes?

11 A. There is a nurse for him.

12 Q. Since you've lived in Buffalo,

13 has your son been hospitalized?

14 A. No.

15 Q. Has your son gone to the

16 emergency room since you moved to Buffalo?

17 MR. CRISTIANO: Just for

18 clarification, when you say

19 hospitalized, do you mean admitted?

20 Q. Well, hospitalized is admitted

21 and now the second question is not

22 admitted, just going to the ER.

23 A. I'm not able to recall.

24 Q. Does your -- is your son

25 covered by health insurance at the present


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1 S. BEGUM

2 time?

3 A. Yes.

4 Q. What is the name of the health

5 insurance?

6 A. Your Care.

7 Q. Y-O-U-R Care?

8 A. Yes.

9 Q. Are there any out-of-pocket

10 expenses for either Dr. Holmes or the

11 cardiologist or any medications that you

12 and your husband have had or is everything

13 covered by insurance?


15 objection. There is no independent

16 cause of action, but you can answer.

17 A. I don't know that. My husband

18 knows about it.

19 MR. PALEY: There is no

20 independent cause of action?

21 MR. CRISTIANO: I don't see it.

22 MR. PALEY: All right.

23 Q. At the present time, does your

24 son have any physical complaints that

25 you're aware of?


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1 S. BEGUM

2 A. Now he doesn't complain

3 anything about it to me.

4 Q. Are there any limitations on

5 his physical activities? Is there anything

6 that he can't do, physically?

7 A. Yes.

8 Q. What is that?

9 A. He plays soccer and doing it in

10 the summer, soccer.

11 Q. Is he on the soccer team at

12 school?

13 A. No. He plays with his friends.

14 Q. Does he participate in gym at

15 school?

16 MR. CRISTIANO: Currently?

17 Q. Currently.

18 A. Maybe. I don't know.

19 Actually, I don't know.

20 Q. Are you aware of any physical

21 activities that he's not allowed to do at

22 the present time?

23 A. I did not understand the

24 question. If my son said to me or what?

25 Q. Has any doctor told you or has


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1 S. BEGUM

2 your husband told you that any doctor has

3 said that there are physical activities

4 your son cannot do because of his physical

5 condition?

6 MR. CRISTIANO: Note my

7 objection.

8 A. No. No doctor has told to me,

9 but I'm not sure if anybody talked to my

10 husband.

11 Q. What is your son doing this

12 summer?

13 MR. CRISTIANO: Note my

14 objection.

15 A. He plays soccer with his

16 friends.

17 Q. Is this at a camp or is he just

18 playing with his friends in the street?

19 A. I don't know. He goes with his

20 friends.

21 MR. PALEY: I have no further

22 questions. Thank you very much.

23 MS. FITZGERALD: I don't have

24 any questions.

25 MR. PALEY: Thank you.


50



51

1 S. BEGUM

2 MR. CRISTIANO: Thank you for

3 coming in.

4 THE REPORTER: Since this is a

5 nonparty deposition, are you all

6 agreeing to purchase your own

7 transcripts?

8 MR. CRISTIANO: Well, put on

9 the record that for purposes of

10 today's deposition, I'm representing

11 the deponent.

12 THE REPORTER: Then Mr. Paley

13 and Ms. Fitzgerald, are you both

14 agreeing to provide Mr. Cristiano

15 with this transcript?

16 MR. PALEY: So I guess the

17 question is, and I'm not sure of the

18 answer, it has to do with whether you

19 get a free copy, Rob.

20 MR. CRISTIANO: Okay.

21 MS. FITZGERALD: I don't know.

22 MR. PALEY: Well, if that's how

23 it goes in Buffalo, sure. That's

24 okay then.

25 THE REPORTER: Ms. Fitzgerald,


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1 S. BEGUM

2 are you also agreeing then to supply

3 Mr. Cristiano?

4 MS. FITZGERALD: Okay, yes.

5 Sure.

6 THE REPORTER: And would

7 everyone prefer digital or paper

8 transcripts?

9 MR. PALEY: Paper please.

10 MS. FITZGERALD: A paper copy

11 also.

12 MR. CRISTIANO: And paper for

13 me. Thank you.

14 (Whereupon, at 12:05 P.M., the

15 Examination of this witness was

16 concluded.)

17

18° ° ° °

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53

1 S. BEGUM

2 D E C L A R A T I O N

3

4 I hereby certify that having been

5 first duly sworn to testify to the truth, I

6 gave the above testimony.

7

8 I FURTHER CERTIFY that the foregoing

9 transcript is a true and correct transcript

10 of the testimony given by me at the time

11 and place specified hereinbefore.

12

13

14

15 SHAHAJADI BEGUM

16

17

18 Subscribed and sworn to before me

19 this day of 20 .

20

21

22 NOTARY PUBLIC

23

24

25


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54

1 S. BEGUM

2 E X H I B I T S

3

4 EXHIBIT EXHIBIT PAGE

5 NUMBER DESCRIPTION

6 (None)

7

8

9 I N D E X

10

11 EXAMINATION BY PAGE

12 MR. PALEY 5

13

14

15 INFORMATION AND/OR DOCUMENTS REQUESTED

16 INFORMATION AND/OR DOCUMENTS PAGE

17 (None)

18

19

20 QUESTIONS MARKED FOR RULINGS

21 PAGE LINE QUESTION

22 (None)

23

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25


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55

1 S. BEGUM

2 C E R T I F I C A T E

3

4 STATE OF NEW YORK ): SS.:

5 COUNTY OF ERIE )

6

7 I, PATRICIA A. SCHREIER, a Notary

8 Public for and within the State of New

9 York, do hereby certify:

10 That the witness whose examination is

11 hereinbefore set forth was duly sworn and

12 that such examination is a true record of

13 the testimony given by that witness.

14 I further certify that I am not

15 related to any of the parties to this

16 action by blood or by marriage and that I

17 am in no way interested in the outcome of

18 this matter.

19 IN WITNESS WHEREOF, I have hereunto

20 set my hand this 19th day of August 2019.

21

23PATRICIA A. SCHREIER

24

25


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56S. BEGUM

25:24, 26:24, 27:6, 28:10, 18:15, 19:20, 24:21, 25:14, asking [4] - 12:14, 12:15,28:17, 29:21, 30:4, 30:18, 27:5, 47:4, 51:5 13:8

'13 [1] - 40:12 31:19, 32:6, 33:4, 33:8, AII [10]- 3:6, 8:20, 9:19, 13:6, Associates [1] - 1:2135:15, 35:25, 40:10, 47:23 18:4, 22:13, 25:21, 32:7, At [1] - 48:23

1 About [1] - 42:16 39:9, 48:22 at [63]- 1:20, 3:3, 3:4, 3:7,

10038 [1] - 2:16 about [59]- 6:13, 12:12, allowed [1] - 49:21 3:12, 3:18, 6:3, 6:8, 6:24,

10:25 [1] - 1:14 12:14, 13:8, 13:20, 16:13, Almost [1] - 11:17 10:19, 10:22, 10:25, 18:8,

114 [1] - 2:10 17:19, 17:21, 17:24, 17:25, almost [2] - 11:19, 11:20 18:9, 18:16, 19:20, 21:11,

11501 [1] - 2:11 18:7, 18:13, 18:16, 18:23, already [2] - 29:10, 31:21 21:22, 24:13, 25:3, 27:5,

11556 [1] - 2:5 19:2, 19:3, 19:6, 19:7, also [81- 23:10, 30:5, 30:23, 29:23, 29:25, 30:12, 30:13,19:8, 19:9, 19:15, 19:19, 34:11, 37:3, 46:21, 52:2, 31:8, 32:10, 32:20, 33:9,12 [1] - 9:920:7, 21:6, 21:7, 22:3, 52:11 33:11, 33:14, 34:7, 34:16,123 [1] - 2:1622:23, 23:16, 25:3, 25:16, ALSO [1] - 2:19 34:22, 35:5, 35:7, 35:23,12:05 [1] - 52:1428:3, 28:12, 29:2, 29:13, alternate [1] - 41:17 36:7, 36:13, 36:18, 37:5,

12th [1] - 13:1830:5, 30:11, 30:22, 31:2, am [4] - 13:14, 27:6, 55:14, 37:7, 37:23, 38:4, 38:24,

1370 [1] - 2:4 31:3, 31:7, 31:8, 31:10, 55:17 39:16, 41:6, 44:9, 44:15,13th [1] - 2:5 31:16, 34:2, 36:12, 36:17, American [1] - 10:8 46:8, 46:19, 46:23, 46:24,14203 [1] - 1:22 36:21, 37:2, 38:5, 39:24, AND [4] - 4:10 4:13 4:16, 47:3, 47:8, 47:25, 49:11,14215 [1] - 5:7 42:9, 42:15, 42:21, 43:17, 4:20 49:14, 49:21, 50:17, 52:14,19th [1] - 55:20 47:6, 48:18, 49:3 AND/OR [2] - 54:15, 54:16 53:10

above [1] - 53:6 another [2] - 18:14, 47:2 attendance [1] - 3:152 accompanied [1] - 3:23 answer [13]- 3:8, 3:12, 3:17, attorney [3] - 3:13, 3:21, 4:4

2 [1] - 1:13 action [3] - 48:16, 48:20, 3:17, 3:21, 3:22, 3:23, attorneys [3] - 2:14, 4:20,

2005 [1] - 10:7 55:16 3:24, 5:22, 5:25, 11:11, 4:22

2007 [1] - 9:9 activities [3] - 49:5, 49:21, 48:16, 51:18 Attorneys [2] - 2:4, 2:8

2012 [3] - 10:12, 16:11, 16:18 50:3 answered [2] - 3:20, 4:6 August [2] - 1:13, 55:20

2013 [81- 12:9, 12:16, 12:20, ActuaHy [3] - 12:13, 45:4, Answered [1] - 10:14 Avenue [2] - 5:7, 6:9

14:21, 15:6, 15:10, 17:9,49:19 Any [1] - 3:22 aware [51- 14:21, 14:24,

40:13 actuaHy [1] - 12:20 any [38]- 3:13, 3:21, 4:11, 43:22, 48:25, 49:20

2019 [3] - 1:13, 9:10, 55:20 Administrator [2] - 1:7, 2:9 5:17, 14:14, 14:21, 14:25,208 [1] - 2:10 admission [1] - 38:25 15:4, 15:6, 28:16, 28:24, B

20 [1] - 53:19 admissions [2] - 38:19, 29:6, 31:15, 31:22, 36:12, B [2] - 5:6 54:2221 [Ï - 3:2, 4:2 38:23 36:17, 38:5, 38:14, 38:17, b - 3:5 3:10221 1 - 3:3 admitted [10]- 33:5, 33:10, 38:18, 38:23, 39:17, 43:23,

221.2 [ ] - 3:17, 4:7 33:12, 33:15, 33:23, 34:12, 44:14, 45:13, 46:8, 46:18,37:6, 47:19, 47:20, 47:22 46:23, 47:8, 48:9, 48:11221.3 [1] - 4:3

after [30]- 13:22, 14:4, 48:24, 49:4 49:20, 49:25 bacM12] - 12:24, 13:2,24 [1] - 9:9

18:25, 19:5, 19:14, 20:13, 50:2, 50:24 55:15 2424, 2U, 2&2, 2M,25th [1] - 2:16

20:18, 20:24, 21:21, 22:6, anybody [2] - 37:24, 50:9 322, 32M, 3W , 3&22,295 [1] - 1:21

22:8, 22:10, 22:12, 22:15, anyone [1] - 34:6 39:22, 40:3

25:7, 26:7, 26:11, 26:15, Anything [1] - 36:22bad [1] - 20:5

3 28:21, 29:7, 31:14, 38:19, anything [14]- 22:2, 22:5,angladesM - 120, 122,

31 [2] - 1:19, 3:10 38:25, 39:10, 39:14, 40:4, 31:8, 34:9, 35:2, 35:4,10:18, 11:2, 12:21

3115 [3] - 3:5, 3:14, 3:22 40:9, 45:5 36:23, 36:25, 37:25, 38:8,basis [2] - 3M, 123

After [71- 23:8, 24:24, 26:2, 42:14, 42:21, 49:3, 49:5be [23]- 3¼, 32, 37, 32,

5 35 5· 35 6· 38% 39 20 apply [1] - 3:9 3:11, 3:23, 4:6, 4:8, 4:10,

again [9] - 16:17, 26:7, appropriate [2] - 3:9, 4:185 [1] - 54:12 26:11, 26:14, 26:18, 27:4, are [71- 5:17 9:2, 14:21 , , 22, W,510843/2015E [1] - 1:6 27:11, 32:9, 32:17 50:3, 51:5, 51:13, 52:2548 [2] - 5:6, 6:8 against [1] - 1:6 Are [6] - 8:11, 10:8, 12:14,

41:3, 45:11

ago [1] - 9:12 13:20, 43:22, 49:20A agree 1] - 7:24 Are there [2] - 48:9, 49:4

A.H [9] - 1:3, 7:20, 8:9, 8:12,AGREED [41- 4:10, 4:13, around [1] - 20:14

8:13, 8:16, 8:21, 8:22, 17:4 4:16, 4:20 Article [2] - 1:19, 3:10been [6] - 5:3, 5:8, 17:10

a.m [1] - 1:14 agreeing [3] - 51:6, 51:14, as [13]- 1:3, 1:7, 2:9, 3:11, 43:4, 47:13, 53:4ability [1] - 5:5 52:2 3:13, 3:21, 4:11, 4:14, 5:9, Before [51- 12:7, 13:13,able [31]- 6:10, 7:10, 11:23,

ahead [1] - 29:20 16:15, 19:25, 37:2, 44:914:20, 15:5, 16:18

13:14, 14:10, 15:8, 15:21,Aid [2] - 46:15, 46:16 As [1] - 16:5

before [18]- 1:22, 3:7, 4:1016:6, 17:6, 17:11, 18:11,

all [16]- 3:17, 4:5, 4:14, 4:17, aside [1] - 47:94:11, 4:14, 16:13, 20:3

20:12, 20:22, 21:20, 25:8, 8:5, 8:6, 10:22, 10:25, ask [3] - 5:15, 6:20, 37:24

DIAMOND REPORT NG (877) 624-3287 [email protected]

56



57S. BEGUM

20:13, 22:21, 23:4, 23:11, camp[1]-50:17 complaint[1]-31:10 50:6, 50:13, 51:2, 51:8,25:12, 32:25, 45:3, 45:7, can[5]-8:5, 8:7, 9:4, 11:11, complaints[21]-11:24, 51:20, 52:1246:4, 46:25, 53:18 48:16 12:11, 12:19, 17:13, 17:16, Currently [3] -13:25, 49:16,

BEGUM[2]-1:17, 53:15 Can you[2]-16:17, 18:12 18:6, 18:9, 18:16, 20:2, 49:17being[1]-35:18 can't[2]-5:23, 49:6 20:19, 22:3, 22:23, 23:5,bending[1]-19:23 cannot [3] -4:17, 6:2, 50:4 23:9, 25:12, 27:21, 28:3, DBengali[5]-2:20, 5:2, 12:8, cardiologist[8]-43:3, 43:8, 38:5, 38:15, 38:17, 48:24

12:22, 21:3 43:13, 43:17, 44:6, 44:8, complete[2]-3:25, 5:24 D [3] -5:6, 53:2, 54:9

besides[1]-47:2 46:17, 48:11 completed[1]-10:16 d[1]-3:5

best[1]-5:5 cardiology[1]-44:4 completely[1]-17:24 D.0[2]-1:9, 2:15

better [3] -11:9, 12:4, 12:6 care[1]-35:9 compliance[1]-3:6 date [3] -6:16, 9:4, 24:7

between[4]-4:20, 11:8, Care [3] -35:11, 48:6, 48:7 concluded[1]-52:16 DATE[1]-1:13

27:8, 28:6 CARMEN[2]-1:9, 2:15 condition[11]-21:6, 25:4,dates[1]-9:6

Between [3] -11:13, 27:2, case[1]-5:14 27:12, 27:14, 27:15, 29:2,daughter [3] -9:8, 9:9, 9:11

28:13 cause [3] -3:20, 48:16, 31:17, 37:2, 38:6, 42:22,daughters[1]-9:3

birth [3]-6:16, 9:5, 9:7 48:20 50:5 David[1]-40:22

bit[2]-11:5, 11:7 Center [3] -5:14, 41:13, 47:9 conditions[1]-14:22 day[1o]-18:14, 18:22, 24:3,

blood[10]-44:19, 45:2, center [3] -41:7, 41:10, 44:9 CONDUCT[2]-3:2, 4:2 25:9, 25:12, 26:19, 32:15,

45:7, 45:11, 45:14, 45:18, CENTER[2]-1:9, 2:15 confidentiality[1]-3:18 38:13, 53:19, 55:20

45:20, 45:25, 46:3, 55:16 certify [3] -53:4, 55:9, 55:14 confusion[1]-13:7 days[16]-18:15, 22:11,

body[41-18:3, 20:8, 28:9, CERTIFY[1]-53:8 CONNICK[1]-2:8 22:15, 26:25, 28:21, 33:19,

28:11 charge[1]-4:22 consent[1]-4:5 33:20, 33:24, 34:8, 34:13,

born[1]-9:11 check[1]-21:14 continue[1]-41:3 34:17, 34:22, 35:7, 36:3,

both[4]-6:2, 23:13, 32:11, checked[1]-21:12 controlling[1]-4:18 37:6, 38:24

51:13 checkup[1]-38:21 conversation[2]-31:23,Deceased[1]-1:8

boy[1]-7:16 children[2]-7:5, 7:13 32:6deemed[1]-4:17

breath[6]-29:23, 29:25, citizen[2]-10:8, 10:11 conversations[41-28:25,defect[1]-3:13

30:24, 31:2, 32:22, 32:25 Civil[2]-1:19, 3:5 29:6, 31:16, 39:17 DEFENDANTS[1]-1:10

breathe[1]-29:14 clarification [3] -31:25, copy [3] -4:21, 51:19, 52:10 Defendants [3] -1:18, 2:8,

breathing[1]-29:13 34:2, 47:18 Correct[1]-8:32:14

Brooklyn[1]-15:15 clear [3] -3:13, 3:23, 17:24 correct[2]-40:4, 53:9 degree[2]-10:16, 10:17

Buffalo[14]-1:21, 5:7, clearly[1]-4:8 CORTIS[2]-1:9, 2:15 deponent[71-3:12, 3:17,

39:15, 40:7, 40:15, 40:17, clerk[1]-4:11 coughing[6]-21:8, 23:18,3:21, 3:24, 43, 45, 51:11

43:4, 43:5, 43:14, 43:24, clinic[1]-41:7 27:24, 30:22, 31:4, 31:10 deposition[10]-3:4, 3:7,

46:14, 47:12, 47:16, 51:23 college [3] -14:12, 14:15 could[4]-6:13, 12:9, 12:17,3:8, 3:8, 3m, 3d8, 3:25,

busy[1]-24:2 14:17 13:10 4:4, 51:5, 51:10

but[26]-6:21, 11:11, 13:7, Columbia[171-35:12, 35:13 Could[2]-14:9, 26:24DENSmœ[1]-1:16

17:25, 18:10, 20:14, 20:23, 35:20, 35:24, 36:7, 36:14, Country[1]-2:10 DEPOS>ITIONS[2]-3:2, 4:2

20:24, 22:15, 23:14, 25:8, 36:18, 37:7, 37:23, 38:4 county[1]-10:17Depositions[1]-3:3

28:12, 28:18, 29:22, 30:17, 38:10, 38:19, 38:24, 39:11 COUNTY[2]-1:2, 55:5SCMM[1]-¾5

30:18, 31:2, 33:3, 33:9, 39:16, 39:21, 40:4 course[1]-3:15determining[1]-4:6

33:20, 38:22, 39:15, 40:8, come[2]-9:23, 10:5 COURT[1]-1:2did [33]-14:24, 15:4, 15:10,

42:2, 48:16, 50:9 coming[1]-51:3 court[2]-3:19, 4:12 15:24, 16:10, 16:23, 17:4,

But [3] -37:14, 38:23, 42:17 comments[1]-3:16 covered[2]-47:25, 48:13 , 2 , 2 2, 225,

BY[5 -2:6, 2:11, 2:17, 5:10, communicating[1]-4:4 CPLR[6]-3:10, 3:14, 3:22,2,

Communication[1]-4:3 4:15, 4:17, 4:18by [19]- 18, 7, 3:14, 3:23, communication[2]-4:5, 4:8 Cristiano[2]-51:14, 52:3

23:22 33:18 41:7 41:8, , CRISUANO[571-2:6, 6:17, 40:16, 43:9, 43:11, 43:12,

17:25, 18:3, 18:10, 19:2, 7:21, 8:3, 8:11, 8:17, 9:14,4 , 48:13, 53:10, 55:13, 19:6, 19:15, 20:14, 20:24, 9:17, 10:13, 11:10, 11:15, D -1 24, 24:13, 26:6,

49:2 11:25, 12:23, 13:6, 15:2, 26:10, 34:15, 34:20, 36:12complained[12]-17:20, 17:8, 18:18, 19:11, 20:10, 36:16, 42:11, 45:6, 45:13,

18:13, 18:25, 19:5, 19:8, 22:9, 22:13, 22:25, 24:11, 46:3c[1]-3:5 19:9, 19:14, 19:19, 21:7, 24:17, 25:5, 25:18, 25:21, did he[18]-17:16, 17:21C[41-2:2, 53:2, 55:2 29:13, 30:22, 31:9 27:13, 29:3, 29:9, 29:17, 18:3, 18:6, 19:2, 19:6called[2]-14:7, 41:12 complaining[14]-18:22, 30:15, 31:24, 33:25, 34:23, 19:15, 21:14, 22:2, 26:17

came[7]-10:2, 10:23, 20:6, 23:17, 25:16, 27:25, 35:9, 36:19, 37:10, 39:5, 28:15, 35:8, 36:25, 38:4

15:20, 24:24, 25:7, 26:2, 28:8, 28:11, 28:12, 29:8, 39d2, 40d3, 40:24, 42:23, 38:10, 38:23, 41:6, 45:238:11 30:2, 30:11, 30:13, 30:23, 43:10, 44:11, 45:9, 46:20, Did she[1]-43:10

31:18 47:17, 48:14, 48:21, 49:16,


57



58S. BEGUM

did they[1]-24:14 48:21, 49:18, 49:19, 50:19, Everything[1]-6:5 32:24, 33:3, 33:23, 33:25,Did you[161-9:23, 10:10, 50:23, 51:21 everything[2]-22:7, 48:12 34:8, 34:13, 34:17, 34:22,

10:15, 10:25, 15:23, 16:3, done[1]-29:17 exact [3] -26:19, 26:25, 35:7, 36:7, 37:6, 37:22,20:20, 21:2, 24:9, 31:7, down[2]-6:2, 8:7 28:11 38:21, 38:24, 39:10, 41:22,33:22, 36:6, 36:9, 37:21, Dr[52]-12:21, 13:5, 15:13, exactly[15]-6:10, 7:10, 42:11, 43:23, 47:11, 47:17,39:17, 40:6 15:15, 15:18, 15:23, 16:4, 15:9, 17:7, 20:12, 20:22, 48:10, 51:2, 51:9, 52:12,

didn't[6]-7:2, 12:13, 23:25, 16:9, 16:15, 16:19, 20:16, 20:25, 22:14, 24:4, 24:23, 55:8

26:9, 34:25, 35:3 20:20, 21:2, 21:5, 21:10, 28:17, 30:4, 33:9, 36:2, For[4]-24:17, 33:14, 35:9,different[4]-18:9, 30:13, 21:22, 22:6, 22:16, 22:20, 40:8 43:25

30:17, 44:10 23:4, 23:8, 23:11, 23:19, examination[5]-3:15, 4:14, force[1]-4:11digital[1]-52:7 26:4, 27:5, 28:18, 28:21, 4:21, 55:10, 55:12 foregoing[1]-53:8diploma[1]-10:17 28:25, 29:7, 30:21, 31:9, Examination[1]-52:15 forgot[1]-14:10direct[1]-3:21 31:13, 31:16, 39:18, 39:22, EXAMINATION[2]-5:10, form[1]-3:13direction[1]-3:22 40:3, 40:21, 40:22, 41:15, 54:11 forth [3] -3:19, 4:7, 55:11

directly[2]-35:20, 37:13 41:20, 41:24, 42:8, 42:11, examine[1]-21:10 framed[1]-3:11discharged [3] -38:9, 38:14, 42:20, 43:2, 43:8, 44:9, examined[1]-5:8 free[1]-51:19

39:10 46:18, 46:23, 47:3, 47:9, examining[2]-3:24, 21:21 FRIEDMAN[1]-2:14

do[8]-5:17, 5:19, 16:22, 48:10 except[4]-3:4, 3:6, 3:18, friends[4]-49:13, 50:16,49:6, 49:21, 50:4, 51:18, DUFFY[2]-2:3 3:21 50:18, 50:2055:9 duly[41-5:3, 5:8, 53:5, Except[1]-3:14 from [13]-12:21, 24:24,

dothey[1]-45:22 55:11 EXHIBIT[2]-54:4 26:2, 28:16, 35:19, 38:10,doyou[28]-6:24, 7:3, 7:13, During[2]-38:3, 42:19 expenses[1]-48:10 39:11, 39:21, 40:9, 46:14,

7:16, 10:19, 11:4, 11:6, during[51-3:11, 3:15, extent[1]-3:14 46:15, 47:9

12:23, 15:17, 17:12, 21:16, 31:17, 37:18, 43:3 furnished[1]-4:21

21:19, 24:6, 25:11, 26:21, F further [3] -38:19, 50:21,28:20, 28:24, 29:6, 31:15, E 55:1432:13, 33:18, 36:3, 37:17, F[1]-55:2 FURTHER[5]-4:10, 4:1340:11, 41:17, 44:21, 47:7,

]-2:2, ½, 24, 53:2, Family[2]-41:12, 47:8 4:16, 4:20 53:847:19 542, 549, 55:2 family [3]-7:5, 41:9, 44:9

doctor [23]-11:22, 11:23,e[1]-3:6 far[4]-10:15, 20:14, 20:23,

12:7, 12:8, 12:10, 12:11,earHeq2]-16:5, 43:16 31:20

12:16, 12:17, 12:18, 13:14,easier[1]-8:21 feel[1]-27:22 G[1]-5:6

19:25, 20:4, 20:9, 23:14, ECMC[6]-41:12, 46:21, felt[2]-27:20, 28:2 gave[1]-53:6

36:12, 36:17, 43:23, 45:13, 46:23, 46:24, 47:3, 47:8 FERDOUSHI[2]-1:7, 2:9 general[1]-3:3

45:20, 47:2, 49:25, 50:2,effect[1]-4:11 fever[71-17:19, 17:21, get [3] -14:15, 17:5, 51:19

50:8 either [3]-23:3, 39:21, 48:10 17:22, 17:23, 17:25, 37:2, getting [3] -22:16, 22:17,

doctors[6]-13:11, 34:16,Either[1]-32:3 37:4 32:21

37:8, 46:19, 46:24, 47:8 elbows [3] -18:5, 18:8, few[4]-18:15, 22:15, 28:21, girls[1]-7:17

DOCUMENTS[2]-54:15,19:20 38:24 give[2]-5:22, 41:24

54:16 eldest[1]-9:8 filled[1]-46:12 given [3] -3:8, 53:10, 55:13

does[6]-3:24, 41:20, 44:14, else[51-18:19, 18:20, 33:19, fine[2]-21:24, 22:8 gives[1]-42:3

46:7, 46:18, 48:23 36:22, 36:23 fingers[6]-18:4, 18:7, Glenn[1]-43:8

Does [3] -14:11, 41:24, emergency[1]-47:16 18:23, 19:2, 19:6, 19:19 Go[1]-29:20

47:24 enforce[1]-3:19 first[22]-5:3, 5:8, 15:18, go[21]-10:15, 12:3, 12:4,does he[5]-13:24, 41:3, English[12]-11:4, 11:6, 17:13, 18:13, 19:8, 20:21, 12:9, 12:20, 13:24, 14:11,

44:18, 46:23, 49:14 11:9, 11:14, 11:22, 11:24, 24:17, 24:19, 24:25, 25:10, 14:18, 24:9, 24:22, 26:4,doesn't[1]-49:2 12:6, 12:10, 12:12, 12:17, 26:3, 26:8, 26:12, 26:16, 26:6, 26:10, 26:17, 27:4,

doing[7]-22:8, 27:20, 12:18, 13:10 27:2, 27:8, 28:6, 28:13, 35:8, 38:10, 39:25, 41:19,

27:22, 28:2, 37:22, 49:9,ER[1]-47:22 28:22, 29:8, 53:5 41:22, 47:4

50:11 ERIE[1]-55:5 Fitzgerald[2]-51:13, 51:25 goes [3] -44:3, 50:19, 51:23

don't[44]-11:12, 11:18, error[1]-3:14 FITZGERALD[6]-2:8, 2:11, going [9] -5:15, 6:20, 8:11,

14:19, 15:19, 19:17, 21:15, ESQ [3] -2:6, 2:11, 2:17 50:23, 51:21, 52:4, 52:10 13:17, 14:2, 14:3, 17:2,

22:14, 23:7, 24:3, 24:20, Estate[2]-1:8, 2:9 five[1]-6:13 32:21, 47:22

24:23, 26:5, 26:19, 28:23, Even[1]-32:5 Floor[2]-2:5, 2:16 gone[2]-44:5, 47:15

30:25, 31:12, 31:22, 33:16, event[1]-4:7 follows[1]-5:9 Good[1]-5:12

33:21, 34:10, 34:18, 37:12, ever[71-16:3, 29:3, 36:25, FOR [3] -3:2, 4:2, 54:20 good[2]-21:9, 23:19

37:13, 37:20, 38:16, 38:22, 39:22, 40:3, 44:5, 45:6 for[421-2:4, 2:8, 2:14, 3:9, got[14]-13:13, 14:20, 15:5,39:7, 39:14, 39:24, 40:2, every[2]-7:24, 41:22 4:4, 4:5, 4:7, 4:8, 4:14, 17:12, 26:13, 26:17, 27:4,40:8, 41:10, 42:17, 43:15, Every[1]-3:11 4:20, 8:3, 8:21, 20:20, 27:11, 32:8, 32:17, 40:9,44:12, 47:4, 47:5, 48:17, everyone[1]-52:7 25:10, 26:3, 31:24, 32:19, 45:5, 45:8, 46:4


58



59S. BEGUM

grade [2] - 13:16, 13:18 35:3, 36:7, 36:13, 36:18, HOLMES [1] - 40:25 37:20, 37:24, 37:25, 38:16,great [4] - 27:16, 27:18, 37:3, 37:6, 37:12, 37:14, home [4] - 16:25, 38:11, 38:22, 39:7, 39:14, 39:24,

27:19 37:18, 37:23, 38:11, 38:13, 38:12, 44:15 39:25, 40:8, 41:10, 41:19,grounds [1] - 4:7 38:16, 38:24, 39:10, 40:9, hospital [9] - 12:16, 13:4, 42:17, 43:9, 43:15, 43:20,Guardian [1] - 1:3 41:8, 42:20, 43:4, 44:3, 24:9, 33:6, 33:12, 33:15, 44:3, 44:12, 45:19, 47:4,guess [2] - 8:20, 51:16 45:3, 45:5, 45:7, 45:10, 33:23, 35:19, 37:18 47:5, 48:17, 48:21, 49:18,gym [1] - 49:14 45:23, 46:4, 46:13, 49:2, Hospital [71- 22:19, 24:6, 49:19, 49:23, 50:19, 50:21,

49:6, 49:11, 50:17 35:12, 35:14, 35:20, 35:24, 50:23, 51:16, 51:21, 53:2,

H He's [1] - 12:21 36:7 53:4, 53:5, 53:8, 54:2,he's [7] - 13:8, 13:25, 21:24, hospitalized [3] - 47:13, 54:9, 55:2, 55:7, 55:14,

H [61- 5:2, 5:6, 40:24, 54:2 46:14, 46:15, 49:21 47:19, 47:20 55:16, 55:19H-O-L-M-E-S [1] - 40:24 head [2] - 5:23, 5:24 HOSS [1] - 7:9 i [1] - 3:18had [13]- 14:22, 16:11, health [5] - 22:17, 32:20, HOSSAIN [2] - 1:4, 7:11 I'll [1] - 29:4

16:13, 16:18, 23:9, 25:14, 44:9, 47:25, 48:4 house [2] - 6:14, 7:3 I'm [481- 5:15, 6:10, 6:20,28:25, 29:7, 29:14, 29:24, Health [2] - 41:13, 47:8 How [8] - 6:8, 8:22, 10:15, 7:9, 10:7, 12:3, 12:12,32:5, 37:4, 48:12 healthcare [1] - 41:9 16:13, 18:25, 19:5, 19:14, 12:15, 14:10, 14:24, 15:8,

hand [6] - 18:23, 19:2, 19:6, heart [71- 30:6, 30:7, 30:12, 35:23 15:20, 16:6, 16:25, 17:6,19:10, 19:16, 55:20 31:7, 31:8, 43:23, 43:25 how [12]- 6:11, 9:2, 20:18, 17:11, 17:24, 18:10, 20:12,

hands [1] - 19:22 heartbeat [1] - 21:13 22:8, 22:14, 26:15, 31:7, 20:22, 20:24, 21:20, 23:14,Has [4] - 14:14, 43:7, 47:15, held [1] - 1:20 32:24, 33:14, 42:11, 42:18, 25:8, 25:24, 26:24, 28:10,

49:25 help [1] - 14:10 51:22 28:17, 29:19, 29:21, 30:4,has [11]- 21:24, 42:20, 43:2, her [51- 5:5, 8:10, 12:23, how many [3] - 7:13, 23:14, 30:17, 30:18, 31:19, 32:6,

43:12, 45:14, 45:17, 47:13, 13:11, 43:11 24:21 33:3, 33:8, 35:15, 35:25,49:25, 50:2, 50:8, 51:18 here [1] - 9:15 how often [2] - 36:9, 41:20 36:11, 39:7, 40:9, 42:2,

have [24]- 3:24, 5:22, 7:14, hereby [2] - 53:4, 55:9 husband [56]- 7:6, 9:20, 42:17, 47:23, 50:9, 51:10,7:16, 10:17, 14:25, 15:4, herein [1] - 4:22 9:24, 11:9, 11:13, 15:24, 51:1715:10, 17:18, 29:22, 30:6, hereinbefore [2] - 53:11, 16:2, 16:4, 16:9, 16:14, I've [1] - 6:531:20, 38:18, 38:23, 39:17, 55:11 16:20, 16:22, 16:23, 22:18, f [16]- 3:5, 3:20, 4:11, 8:13,41:22, 42:12, 45:6, 46:3, hereto [2] - 4:18, 4:21 22:21, 23:3, 23:4, 23:10, 12:15, 18:13, 26:21, 29:21,48:12, 48:24, 50:21, 50:23, hereunto [1] - 55:19 23:13, 23:20, 23:24, 24:2, 30:25, 32:5, 37:12, 38:16,5M9

high [3] - 13:19, 45:23, 46:3 24:5, 24:10, 24:15, 24:25, 40:2, 41:10, 50:9, 51:22have you [5] - 6:6, 6:8, High [1] - 45:25 25:2, 25:9, 25:13, 26:3, If [51- 3:24, 5:17, 11:21,

10:22, 42:8, 44:5him [46]- 13:3, 13:5, 13:13, 26:7, 26:11, 26:15, 27:9, 44:11, 49:24

having [4] - 5:3, 5:7, 32:22,15:20, 16:2, 16:6, 16:23, 28:14, 28:21, 32:10, 32:12, ii [1] - 3:18

5N17:3, 20:4, 20:8, 20:13 32:14, 32:18, 32:25, 33:6, iii [1] - 3:19

He [22]- 15:4, 17:18, 18:10,20:15, 20:23, 21:3, 22:16 34:11, 34:15, 34:20, 36:16, Immediately [1] - 22:10

19:8, 21:12, 21:24, 22:5,22:18, 23:2, 23:4, 23:14 37:7, 39:22, 39:25, 40:3, improper [1] - 3:20

22:16, 27:24, 34:25, 36:21,23:22, 23:25, 24:3, 24:14 41:17, 41:18, 48:12, 48:17, IN [1] - 55:19

36:23, 37:3, 38:7, 41:22,24:15, 25:2, 25:13, 25:17 50:2, 50:10 In [11]- 7:3, 9:22, 10:10,

44:19, 45:4, 46:25, 49:9,25:19, 25:20, 26:8, 26:12 husband's [1] - 7:7 12:9, 12:20, 13:18, 15:10,

49:13, 50:15, 50:1928:14, 28:18, 29:22, 33:2 17:4, 18:12, 35:12, 40:6

he [113]- 12:4, 12:5, 12:6,33:6, 36:10, 36:17, 38:22 in [63]- 3:3, 3:6, 3:13, 3:15,

12:7, 12:21, 13:4, 13:13, 41:18, 41:24, 45:19, 46:25 3:19, 3:22, 4:7, 4:7, 5:14,14:3, 14:14, 14:18, 14:22, 47:11

' I [126]- 5:2, 5:6, 5:13, 5:19, 9:20, 10:6, 10:15, 10:16,14:24, 16:7, 17:3, 17:13, himself [2] - 41:7, 41:8 , , 2, , 8, 10:17, 10:25, 11:24, 12:12,17:19, 17:20, 17:25, 18:13, His [2] - 22:17 27:15

8:13, 8:14, 8:18, 8:20, 9:4, 12:16, 12:18, 13:16, 13:17,18:21, 18:22, 18:25, 19:5, his [32]- 7:10 7:11 8:4 13:19, 14:14, 14:20, 15:5,19:9, 19:14, 19:18, 20:6, 17:22 18:3 18:16 18:23 15:15, 16:11, 16:18, 17:9,20:13, 20:24, 21:8, 21:12, 19:2 19:6 19:22 20:7 18:13, 19:19, 20:7, 21:3,21:24, 22:7, 23:11, 25:7, 13:14, 14:9, 14:19, 15:19, 22:11, 24:21, 29:25, 30:6,25:14, 25:15, 25:17, 25:19, 28:9 30:5 30:7 30:12 30:12, 30:17, 31:25, 32:3,25:20, 26:13, 26:17, 27:10, 32:20 38:5 41:10 33:22, 35:14, 35:21, 37:8,27:19, 27:20, 27:22, 27:24, 41:23 45:7 45:20 49:5 37:15, 37:17, 40:12, 40:17,27:25, 28:2, 28:7, 28:8, 49:13 50:4 50:15 50:18 41:9, 43:4, 43:23, 44:8,28:11, 28:12, 28:15, 29:14, 50:19 47:12, 49:9, 49:14, 50:18,29:22, 29:24, 30:2, 30:5, 24:20, 24:23, 26:5, 26:9, 51:3 51:23 55:1730:6, 30:8, 30:12, 30:18,

H4 3 1 16 :21 24 include [1] - 3:1330:21, 31:18, 32:8, 32:21,

42:9 42:11 42:20 43:2 independent [2] - 48:15,32:22, 33:9, 33:11, 33:12 ' ' ' ' 31:2, 31:12, 31:20, 32:5,33:15, 33:23, 34:7, 34:19, 4t9, 46d 8, 4&23, R3, 33:16, 33:20, 34:9, 34:18,

47:10, 48:1035:2, 35:21, 37:12, 37:13,


59



60S. BEGUM

Infant [1] - 1:3 joints [2] - 18:4, 18:16 26:15, 32:24, 33:3, 33:14, MEDICAL [2] - 1:9, 2:15INFORMATION [2] - 54:15, Judge [1] - 4:12 35:23, 42:12, 42:18 Medical [1] - 5:13

54:16 June [1] - 9:9 look [1] - 23:18 medical [6] - 11:23, 12:11,initials [4] - 7:22, 8:2, 8:6, Just [20]- 6:17, 7:21, 9:17, losing [1] - 27:24 14:21, 29:2, 41:7, 42:21

8:18 10:13, 11:10, 11:15, 22:9, lost [1] - 9:15 medication [61- 44:15,injection [3] - 41:23, 42:3, 25:5, 27:13, 30:15, 31:24, lot [1] - 29:14 44:20, 44:22, 45:3, 45:24,

42:6 33:25, 34:23, 37:10, 39:12, 46:11injections [6] - 41:25, 42:9, 42:23, 45:9, 46:20, 47:17, M medicationS [3] - 15:7, 46:8,

42:13, 43:18, 44:14, 46:7 48:14 48:11instead [3] - 16:4, 16:21, just [9] - 7:25, 8:5, 8:7, 8:15,

M [61- t8, 2:9, 5:2, 5:6, mention [1] - 31:816:24 8:18, 37:3, 44:3, 47:22,

40:24 mentioned [4] - 29:22, 30:5,instructions [1] - 5:21 50:17 M.D [4] - t8, t9, 2:9, 2d5

31:2, 36:21insurance [3] - 47:25, 48:5,

made [7] - 3:4, 3:7, 3:17, 4:5, Metschl [1] - 1:2048:13 K 18:9, 27:22, 38:17 Mineola [1] - 2:11

intend [1] - 14:11 Maimonides [40]- 5:13, Minnesota [2] - 5:6, 6:9. Kamal [36]- 12:21, 13:5, 22:18, 22:22, 23:5, 23:12,mterested [1] - 55:17

15:13, 15:15, 15:18, 15:23, 24:6, 24:11, 24:14, 24:16interfere [1] - 3:16

16:4, 16:9, 16:15, 16:19, 24:22, 24:25, 25:3, 25:10,interposed [1] - 3:620:16, 20:20, 21:2, 21:5, 26:3, 26:6, 26:10, 26:16,interpret [1] - 5:421:10, 21:22, 22:7, 22:16, 27:3, 27:9, 27:10, 28:7,Interpreter [2] - 2:20, 5:322:21, 23:4, 23:9, 23:11, 28:14, 28:15, 28:22, 32:8,

2 , 2d0interrupt [1] - 4:4

23:19, 26:4, 27:5, 28:18, 32:10, 32:14, 32:19, 33:2,month p1] - 9:12, 21:16,

into [2] - 13:17, 14:1528:21, 28:25, 29:7, 30:21, 33:12, 34:3, 34:4, 34:8, 36:5, 36:7, 37:18, 38:3,

involved [2] - 37:8, 37:14 31:10, 31:14, 31:16, 39:18, 34:12, 34:16, 34:22, 35:6, 38:20, 38:25, M, C O,irregularity [1] - 3:14 39:23, 40:4 35:7, 35:19, 37:5 41:22IS [41- 4:10, 4:13, 4:16, 4:20 KAMAL [6] - 1:7, 1:8, 1:8, MAIMONIDES [2] - 1:9, 2:15 more [81- 612, 11M, 169,Is [5] - 6:12, 7:11, 41:12, 2:9, 2:9, 2:10 Main [1] - 1:21 22:22, 29:4, 32:5, 37:7,

44:8, 49:11 KINGS [1] - 1:2 make [4] - 3:16, 17:17, 18:6,3W

is [33]- 3:8, 3:17, 3:20, 4:5, know [23]- 11:12, 14:19, 38:4 morning [2] - 5:12, 5:16

5:12, 8:22, 9:8, 9:9, 13:7, 24:6, 26:21, 32:13, 34:18, making [51- 17:14, 20:19, MosW p] - C 8

13:10, 13:16, 14:3, 14:7, 36:4, 37:12, 37:13, 37:17, 27:21, 28:3, 38:14 move [1] - 40:7

31:25, 39:3, 41:8, 41:10, 38:21, 41:10, 44:3, 44:11, Manhattan [1] - 35:14 moved [4] - 39:15, 40:15,43:12, 46:12, 47:5, 47:11, 44:12, 44:21, 47:6, 47:7, March [1] - 9:8 43:14, 47:16

47:20, 47:21, 47:24, 48:12, 48:17, 49:18, 49:19, 50:19, MARKED [1] - 54:20Mr [3] - 51:12, 51:14, 52:3

48:15, 48:19, 50:17, 51:4, 51:21 MARLA [2] - 1:9, 2:15 W5] - 5m , W, m ,51:17, 53:9, 55:10, 55:12 known [1] - 37:2 marriage [1] - 55:16 7:23, 8:3, 8:8, 8:11, 8:13,

is that [4] - 5:22, 6:14, 13:19, knows [1] - 48:18 married [2] - 9:19, 10:2 , 20, W, W,35:13 10:13, 11:10, 11:15, 11:25,

Is there [6] - 14:17, 16:8, 12:23, 12:25, 13:6, 13:12,16:14, 16:19, 23:23, 49:5

L may [3] - 4:10, 4:14, 9:1415:2, 17:8, 18:18, 19:11,

Is this [3] - 20:16, 42:5, L [2] - 40:24, 53:2 maybe [1] - 39:320:10, 22:9, 22:11, 22:13,

50:17 last [3] - 7:11, 33:9, 33:11 Maybe [30]- 10:7, 10:12, 22:25, 24:11, 24:17, 25:5,IT [4] - 4:10, 4:13, 4:16, 4:20 later [41- 18:15, 26:22, 26:23 13:4, 13:7, 14:9, 17:10, 25:18, 25:21, 27:13, 29:3,it [22]- 6:12, 6:22, 15:25 Law [2] - 1:19, 3:5 24:2, 25:14, 25:15, 25:16, 29:4, 29:9, 29:11, 29:17,

16:22, 17:22, 18:23, 26:21, legs [2] - 18:5, 19:22 25:18, 25:20, 26:5, 30:17, 30:15, 31:24, 33:25, 34:4,27:17, 29:22, 30:5, 39:3 Leonard [1] - 43:8 30:18, 31:6, 33:3, 33:16, 34:23, 35:9, 36:19, 37:10,41:10, 41:12, 45:5, 46:13, LEVINE [2] - 1:9, 2:15 3&20, 35:15, 35:21, 35:22, 39:5, 39:12, 40:13, 40:24,47:6, 48:18, 48:21, 49:3, Like [1] - 29:14 36:5, 38:21, 39:2, 40:12, 42:23, 43:10, 44:11, 45:9,49:9, 51:18, 51:23 like [1o]- 5:18, 11:20, 19:23

, , 45:4, 49:1846:20, 47:17, 48:14, 48:19,

It [2] - 6:13, 20:4 27:12, 27:20, 28:2, 30:6,' McALOON [1] - 2:14

48:21, 48:22, 49:16, 50:6,it's [2] - 8:21, 17:10 32:21

McNAMEE [1] - 2:8 50:13, 50:21, 50:25, 51:2,It's [1] - 41:9 limitation [1] - 3:19

me [22]- 5:18, 5:19, 8:21, 51:8, 51:16, 51:20, 51:22,

limitations [1] - 49:4 9:6, 21:9, 27:19, 34:9, 52:9, 52:12, 54:12

LINE [1] - 54:21 34:25, 35:4, 36:24, 37:3, MS [41- 50:23, 51:21, 52:4,37:25, 38:7, 42:14, 43:20, 52:10

J [2] - 2:6, 5:64r 5 23, M24, 45:21, 49:3, 49:24, 50:8, Ms [2] - 51:13, 51:25

joint [19]- 17:18, 18:7, 20:7, little [3] - 11:5, 11:7, 43:16 much [5] - 11:5, 11:7, 27:25,20:19, 21:8, 22:3, 22:23, mean [4] - 29:16, 30:8, 47:6, 50:2223:6, 23:9, 23:17, 28:4,

e 2] 2 , 33:18, 47:19My [7] - 5:12, 7:5, 16:2,

28:8, 29:8, 30:2, 30:13, meaning [1] - 31:416:22, 23:13, 32:12, 48:17

30:22, 31:5, 31:11, 31:182

meant [2] - 11:19, 43:20my [35]- 5:24, 7:5, 10:13,


60



10:16, 11:10, 11:15, 12:3, 12:5, 12:14, 15:2, 19:11, 20:10, 22:18, 22:25, 24:2, 27:13, 30:15, 34:23, 36:19, 37:10, 38:11, 39:5, 39:12, 39:24, 41:18, 42:23, 43:20, 45:9, 48:14, 49:24, 50:6, 50:9, 50:13, 55:20

MYERS [1] - 2:8myself [1] - 23:22

NN [4] - 2:2, 5:2, 53:2, 54:9name [12] - 5:12, 7:8, 7:10,

7:11, 7:19, 7:25, 8:15, 14:4, 40:19, 44:21, 46:10, 48:4

named [1] - 43:8names [1] - 47:7Natural [1] - 1:3neck [10] - 18:5, 18:8, 18:24,

19:3, 19:7, 19:8, 19:15, 19:20, 19:23

need [1] - 42:12needs [2] - 12:7, 45:24never [1] - 13:3NEW [2] - 1:2, 55:4New [8] - 1:21, 1:23, 2:5,

2:11, 2:16, 5:7, 55:8next [3] - 13:20, 18:14, 35:8nighttime [3] - 29:23, 29:25,

32:20no [9] - 14:24, 21:24, 39:2,

39:3, 48:15, 48:19, 50:21, 55:17

No [39] - 1:6, 3:3, 9:25, 10:21, 10:24, 11:3, 12:15, 14:23, 14:24, 15:19, 21:18, 21:20, 22:5, 24:8, 24:12, 26:5, 28:23, 29:4, 29:18, 34:9, 34:25, 36:15, 37:20, 37:24, 38:7, 39:19, 40:5, 42:10, 42:14, 42:25, 43:6, 43:9, 44:7, 46:5, 46:9, 47:14, 49:13, 50:8

nobody [1] - 37:25Nobody [1] - 42:14nod [1] - 5:23non [1] - 1:17non-party [1] - 1:17none [1] - 54:6None [2] - 54:17, 54:22nonparty [1] - 51:5not [81] - 3:6, 3:12, 3:15,

3:21, 3:21, 3:22, 3:24, 4:4, 4:6, 5:17, 6:10, 6:22, 7:10, 10:7, 11:5, 11:7, 11:24, 13:14, 14:10, 14:24, 14:25, 15:4, 15:8, 15:20, 16:6,

17:2, 17:6, 17:11, 17:24, 18:11, 19:4, 20:12, 20:22, 20:24, 21:9, 21:20, 22:5, 23:14, 23:18, 25:8, 25:24, 26:24, 27:6, 27:15, 27:17, 27:18, 27:19, 27:20, 27:22, 28:2, 28:10, 28:17, 29:21, 30:4, 30:17, 30:18, 31:19, 32:6, 33:4, 33:8, 35:15, 35:21, 35:25, 36:23, 37:24, 38:7, 39:4, 39:7, 39:25, 40:9, 41:11, 42:2, 42:17, 43:9, 47:21, 47:23, 49:21, 49:23, 50:9, 51:17, 55:14

Notary [3] - 1:23, 4:11, 55:7NOTARY [1] - 53:22note [12] - 10:13, 11:10,

11:15, 25:5, 27:13, 30:15, 37:10, 39:12, 42:23, 45:9, 46:20, 48:14

Note [8] - 15:2, 19:11, 20:10, 22:25, 36:19, 39:5, 50:6, 50:13

noted [1] - 3:7Notice [1] - 1:18Now [2] - 12:3, 49:2now [17] - 7:4, 12:3, 12:4,

15:20, 25:25, 27:7, 31:20, 32:6, 33:21, 34:3, 34:18, 35:16, 36:11, 45:15, 46:15, 47:2, 47:21

Number [1] - 6:21NUMBER [1] - 54:5nurse [5] - 42:2, 42:3, 45:20,

47:5, 47:11

OO [3] - 5:2, 40:24, 53:2Objection [1] - 17:8objection [23] - 3:11, 3:17,

10:14, 11:11, 11:16, 15:3, 19:12, 20:11, 23:2, 25:6, 27:14, 30:16, 34:24, 36:20, 37:11, 39:6, 39:13, 42:24, 45:10, 48:15, 50:7, 50:14

Objections [2] - 3:3, 3:3objections [4] - 3:4, 3:7, 3:9,

3:10observe [1] - 37:21OF [7] - 1:2, 1:2, 3:2, 4:2,

55:4, 55:5of [87] - 1:7, 1:8, 1:16, 1:19,

1:20, 1:23, 2:9, 2:9, 3:5, 3:6, 3:9, 3:10, 3:12, 3:13, 3:15, 3:18, 3:19, 3:23, 3:25, 4:4, 4:6, 4:7, 4:12, 4:18, 4:21, 5:5, 6:2, 6:16, 8:6, 9:4, 9:6, 14:4, 14:21, 16:4, 16:21, 16:24, 18:2,

18:3, 19:25, 20:7, 20:19, 21:16, 21:22, 22:3, 23:6, 23:9, 23:17, 28:8, 28:9, 29:8, 29:23, 29:25, 30:2, 30:13, 30:23, 31:2, 31:10, 31:18, 32:11, 32:22, 32:25, 40:19, 43:22, 44:21, 46:10, 47:7, 47:8, 48:4, 48:9, 48:16, 48:20, 48:25, 49:20, 50:4, 51:9, 51:17, 52:15, 53:10, 53:19, 55:8, 55:12, 55:15, 55:17, 55:20

officer [1] - 3:7offices [1] - 1:20okay [5] - 13:4, 27:20, 27:23,

28:2, 51:24Okay [3] - 14:9, 51:20, 52:4old [2] - 8:22, 9:2Old [1] - 2:10Olmstead [2] - 14:6, 14:7OLMSTEAD [1] - 14:8on [13] - 4:6, 6:22, 8:6, 8:18,

23:24, 25:12, 30:20, 32:2, 32:3, 38:13, 49:4, 49:11, 51:8

On [1] - 25:9once [6] - 13:4, 13:14, 16:6,

20:4, 33:16, 33:18one [20] - 6:3, 7:16, 15:25,

18:13, 18:22, 22:20, 22:22, 33:19, 33:20, 33:23, 34:8, 34:9, 34:13, 34:17, 34:22, 35:7, 36:5, 37:6, 38:20, 38:25

only [3] - 5:21, 12:10, 12:17opposed [1] - 16:15or [67] - 3:5, 3:13, 3:14, 3:14,

3:16, 3:18, 3:19, 3:22, 3:22, 4:5, 4:11, 5:18, 5:23, 9:20, 11:24, 12:16, 13:5, 13:14, 14:24, 15:24, 15:25, 16:6, 17:22, 18:2, 18:4, 18:8, 18:15, 20:4, 20:13, 22:22, 23:3, 23:20, 24:14, 26:22, 26:25, 30:13, 31:25, 32:3, 32:11, 33:16, 33:18, 33:19, 33:20, 37:19, 37:21, 39:4, 39:21, 41:7, 41:10, 41:16, 41:17, 43:10, 44:9, 48:10, 48:11, 48:12, 49:24, 49:25, 50:17, 52:7, 55:16

Or [2] - 18:18, 18:20order [2] - 3:19, 14:14Other [7] - 29:11, 31:4,

31:13, 43:2, 44:13, 46:6, 46:17

other [9] - 3:13, 15:25, 18:12, 29:9, 31:3, 31:15, 31:22, 46:18, 46:24

others [1] - 21:13

S. BEGUM


61

out [1] - 48:9out-of-pocket [1] - 48:9outcome [1] - 55:17outpatient [1] - 39:11over [3] - 10:14, 15:23, 34:23overnight [1] - 24:13own [2] - 41:10, 51:6

PP [3] - 2:2, 5:2P.C [3] - 1:8, 2:10, 2:14P.M [1] - 52:14PAGE [4] - 54:4, 54:11,

54:16, 54:21pain [29] - 17:18, 17:19,

17:25, 18:3, 18:7, 18:13, 19:19, 20:7, 20:20, 21:8, 22:4, 22:24, 23:6, 23:10, 23:17, 28:4, 28:8, 28:12, 29:8, 30:3, 30:6, 30:11, 30:13, 30:22, 31:5, 31:7, 31:8, 31:11, 31:18

Paley [2] - 5:13, 51:12PALEY [20] - 2:17, 5:11,

7:23, 8:8, 8:13, 8:20, 12:25, 13:12, 22:11, 29:4, 29:11, 34:4, 48:19, 48:22, 50:21, 50:25, 51:16, 51:22, 52:9, 54:12

paper [3] - 52:7, 52:10, 52:12Paper [1] - 52:9part [2] - 18:2, 28:9participate [1] - 49:14particular [1] - 14:17parties [4] - 4:5, 4:17, 4:21,

55:15parts [3] - 18:2, 20:7, 28:11party [2] - 1:17, 3:24PATRICIA [2] - 55:7, 55:23Patricia [1] - 1:22PAUL [1] - 2:17Paul [1] - 5:12pediatrician [4] - 15:11,

40:17, 40:20, 41:4penicillin [5] - 42:5, 42:7,

43:18, 44:13, 46:7permitted [1] - 3:14person [4] - 3:9, 3:21, 31:25,

32:3persons [1] - 3:15pharmacy [1] - 46:11phone [2] - 32:2, 32:4physical [8] - 31:17, 38:5,

38:14, 48:24, 49:5, 49:20, 50:3, 50:4

physically [1] - 49:6PHYSICIAN [2] - 1:8, 2:10pill [1] - 45:12place [4] - 18:14, 44:10,



53:11plainly [1] - 3:20PLAINTIFF [1] - 1:5Plaintiff [1] - 2:4playing [1] - 50:18plays [3] - 49:9, 49:13, 50:15Plaza [1] - 2:4please [5] - 5:19, 7:22, 9:18,

12:25, 52:9Please [1] - 9:6PLLC [2] - 2:3, 2:8pneumonia [1] - 36:21pocket [1] - 48:9Practice [2] - 1:19, 3:5prefer [2] - 8:14, 52:7prejudice [1] - 3:20Presbyterian [2] - 35:13,

35:20prescription [3] - 15:6,

44:15, 46:12PRESENT [1] - 2:19present [8] - 6:25, 10:19,

44:16, 46:8, 46:19, 47:25, 48:23, 49:22

preserve [1] - 3:18pressure [9] - 44:19, 45:2,

45:7, 45:12, 45:14, 45:18, 45:21, 45:25, 46:4

pretty [1] - 13:9Previously [1] - 46:13privacy [1] - 6:22private [1] - 6:14privilege [1] - 3:18Probably [3] - 35:2, 39:25,

46:15probably [2] - 16:5, 46:14problem [4] - 21:25, 45:7,

45:15, 45:18proceed [1] - 3:8proceedings [1] - 5:4promised [1] - 5:4properly [2] - 13:15, 16:7protect [1] - 6:21provide [1] - 51:14provided [3] - 3:21, 4:14,

4:17Public [3] - 1:23, 4:11, 55:8PUBLIC [1] - 53:22purchase [1] - 51:6purpose [2] - 4:4, 4:6purposes [2] - 4:14, 51:9pursuant [3] - 1:18, 3:4, 3:10put [5] - 6:17, 6:22, 7:25,

8:16, 51:8

Qquestion [10] - 3:20, 3:24,

4:6, 5:25, 12:24, 13:9, 43:12, 47:21, 49:24, 51:17

QUESTION [1] - 54:21questioning [2] - 3:12, 3:16QUESTIONS [1] - 54:20questions [5] - 3:17, 5:16,

5:17, 50:22, 50:24

RR [3] - 2:2, 53:2, 55:2raised [1] - 3:11read [2] - 12:24, 13:2really [2] - 35:2, 37:25reason [5] - 4:7, 16:8, 16:14,

16:20, 23:23recall [36] - 6:10, 7:10, 13:15,

15:8, 15:21, 16:7, 17:6, 17:11, 18:11, 18:12, 20:12, 20:22, 20:23, 21:20, 25:8, 25:11, 25:24, 26:25, 27:6, 28:10, 28:17, 28:20, 29:6, 29:21, 30:4, 30:19, 31:15, 31:19, 32:6, 33:4, 33:8, 35:15, 35:25, 36:11, 40:10, 47:23

record [7] - 4:8, 6:22, 8:7, 8:19, 13:2, 51:9, 55:12

referring [1] - 43:19Refusal [1] - 3:17refusal [1] - 3:22regarding [1] - 5:16related [1] - 55:15release [1] - 24:15released [2] - 39:20, 40:9relief [1] - 3:9remainder [1] - 3:25remember [33] - 15:17,

15:19, 17:13, 19:17, 21:15, 21:16, 21:19, 22:14, 23:7, 24:4, 24:20, 24:23, 26:5, 26:19, 28:23, 28:24, 30:25, 31:12, 31:22, 33:17, 33:21, 34:10, 37:20, 38:16, 38:22, 39:7, 39:14, 39:24, 40:2, 40:8, 40:11, 42:18, 43:15

remembered [1] - 31:20remembering [1] - 17:2repeat [1] - 5:18REPORTER [4] - 51:4, 51:12,

51:25, 52:6reporter [3] - 6:2, 7:25, 8:15represent [1] - 5:13representing [2] - 4:22,

51:10request [1] - 3:12REQUESTED [1] - 54:15respect [1] - 4:18respective [1] - 4:21restricted [1] - 3:10result [1] - 19:25rheumatic [2] - 37:2, 37:4

right [14] - 3:9, 3:18, 3:24, 8:20, 9:19, 13:6, 22:13, 25:21, 27:6, 31:19, 32:7, 34:3, 39:9, 48:22

Right [2] - 13:12, 15:20rights [1] - 4:17Rite [2] - 46:15, 46:16Road [1] - 2:10Rob [3] - 7:23, 8:14, 51:19ROBERT [1] - 2:6room [1] - 47:16Rule [3] - 3:5, 3:14, 3:22rule [2] - 3:6, 3:15rules [1] - 4:7Rules [2] - 1:20, 3:5RULES [2] - 3:2, 4:2RULINGS [1] - 54:20RXR [1] - 2:4

SS [5] - 2:2, 5:2, 5:6, 40:24,

54:2said [18] - 6:5, 21:24, 22:7,

25:3, 30:18, 30:25, 31:13, 31:14, 31:21, 32:7, 42:20, 43:16, 43:17, 45:23, 46:21, 46:22, 49:24, 50:3

same [14] - 4:11, 11:17, 11:19, 11:20, 14:2, 18:8, 18:16, 19:20, 25:15, 25:16, 25:22, 30:2, 30:12, 44:8

saw [1] - 21:2say [19] - 8:8, 8:12, 8:13,

8:15, 8:21, 16:17, 17:20, 21:22, 22:2, 22:5, 25:8, 25:22, 27:17, 29:24, 30:8, 36:23, 36:25, 39:3, 47:18

school [13] - 10:15, 13:16, 13:19, 13:24, 13:25, 14:2, 14:3, 14:5, 14:7, 28:16, 28:19, 49:12, 49:15

SCHREIER [2] - 55:7, 55:23Schreier [1] - 1:22second [11] - 26:7, 26:11,

26:17, 27:3, 27:10, 28:7, 28:15, 32:19, 33:2, 33:7, 47:21

section [1] - 4:7sections [1] - 4:18Security [1] - 6:21see [12] - 15:22, 16:4, 16:19,

27:4, 30:21, 41:20, 43:10, 43:11, 46:18, 46:23, 46:25, 48:21

seeing [2] - 15:18, 43:23seen [4] - 39:10, 43:3, 43:7,

43:13sees [4] - 41:15, 46:23, 47:3,

47:9

S. BEGUM


62

send [1] - 28:18September [1] - 13:17set [4] - 3:19, 4:7, 55:11,

55:20Seventeen [2] - 8:23, 8:24SHAHAJADI [2] - 1:17, 53:15shake [1] - 5:23shall [15] - 3:4, 3:7, 3:8, 3:8,

3:11, 3:13, 3:15, 3:17, 3:21, 3:23, 3:24, 4:4, 4:8, 4:18, 4:21

She [1] - 45:10she [6] - 13:10, 23:2, 29:10,

29:11, 45:11, 46:20she'll [1] - 8:9SHOMPA [1] - 2:20short [5] - 29:23, 29:24, 31:2,

32:22, 32:24shortness [1] - 30:23should [1] - 4:6showed [1] - 17:23siblings [1] - 8:4sic [1] - 35:3sick [16] - 13:13, 14:20, 15:5,

16:7, 16:12, 17:5, 17:12, 26:13, 26:17, 27:4, 27:11, 32:9, 32:17, 45:5, 45:8, 46:4

signed [2] - 4:10, 4:11significant [1] - 3:20since [6] - 10:22, 12:5,

16:25, 43:4, 43:13, 47:16Since [3] - 17:10, 47:12, 51:4six [1] - 17:10So [9] - 7:23, 8:5, 8:8, 20:6,

25:7, 33:11, 43:18, 47:2, 51:16

so [6] - 3:11, 5:19, 20:14, 20:23, 27:25, 31:20

soccer [4] - 49:9, 49:10, 49:11, 50:15

Social [1] - 6:21some [2] - 5:15, 13:7someone [1] - 37:21something [5] - 9:15, 18:18,

18:20, 33:19, 43:17sometimes [1] - 41:19son [121] - 5:16, 8:10, 11:21,

12:3, 12:5, 12:14, 12:16, 13:17, 14:11, 14:20, 15:5, 15:10, 15:18, 15:22, 15:24, 16:3, 16:9, 16:15, 16:19, 16:21, 17:4, 17:12, 19:24, 20:18, 20:20, 21:11, 21:21, 22:8, 22:21, 23:5, 23:8, 23:9, 23:10, 23:11, 23:17, 23:20, 23:24, 24:5, 24:10, 24:13, 24:22, 24:24, 25:10, 26:2, 26:4, 26:6, 26:10, 26:16, 27:4, 27:9, 28:20,



28:22, 29:7, 30:9, 30:21, 31:15, 32:8, 32:9, 32:14, 32:17, 32:18, 33:5, 33:22, 34:7, 34:12, 34:16, 34:21, 35:5, 35:6, 35:17, 35:18, 35:23, 36:6, 36:13, 36:18, 37:5, 37:18, 37:22, 38:4, 38:9, 38:18, 39:9, 39:16, 39:20, 39:22, 40:3, 40:16, 41:6, 41:15, 41:16, 41:20, 42:12, 42:20, 43:3, 43:7, 43:11, 43:13, 43:20, 43:22, 44:6, 44:14, 45:6, 45:13, 45:14, 45:17, 46:3, 46:7, 46:18, 46:22, 47:3, 47:9, 47:13, 47:15, 47:24, 48:24, 49:24, 50:4, 50:11

son's [15] - 7:19, 11:23, 12:11, 12:19, 13:11, 21:6, 25:3, 25:11, 27:11, 29:2, 31:17, 41:4, 42:21, 43:18, 43:23

sorry [1] - 29:19speak [4] - 11:4, 13:10, 21:3,

34:15speaking [3] - 13:20, 37:8,

37:15Speaking [1] - 3:10speaks [6] - 11:9, 11:22,

12:4, 12:5, 12:10, 12:22specific [1] - 29:5specifically [1] - 22:3specified [1] - 53:11spoke [4] - 12:17, 23:16,

34:19, 37:12spoken [1] - 42:8SS [1] - 55:4SSC [2] - 10:16, 10:17start [2] - 5:25, 40:16started [6] - 15:18, 18:24,

20:13, 20:24, 29:8, 45:5starting [1] - 20:19STATE [2] - 1:2, 55:4State [2] - 1:23, 55:8stated [2] - 3:11, 4:8statement [2] - 3:13, 3:23statements [1] - 3:16States [5] - 9:21, 9:24, 10:3,

10:6, 10:23stay [1] - 24:13stayed [1] - 38:24staying [1] - 16:25STIPULATED [4] - 4:10,

4:13, 4:16, 4:20straightforward [1] - 13:9Street [2] - 1:21, 2:16street [1] - 50:18subdivision [3] - 3:4, 3:6,

3:22subject [2] - 3:9, 8:4

Subscribed [1] - 53:18succinct [1] - 3:23succinctly [2] - 3:11, 4:8such [3] - 3:6, 4:7, 55:12suggest [1] - 3:12Suite [1] - 2:10summer [4] - 13:22, 14:4,

49:10, 50:12supply [1] - 52:2SUPREME [1] - 1:2sure [11] - 10:7, 20:25, 23:14,

30:18, 39:4, 39:8, 42:2, 42:17, 50:9, 51:17, 51:23

Sure [1] - 52:5sworn [5] - 5:3, 5:8, 53:5,

53:18, 55:11symptoms [7] - 21:9, 23:18,

25:14, 25:15, 25:16, 25:23

TT [5] - 5:2, 53:2, 54:2, 55:2TAHMINA [1] - 2:20take [16] - 6:2, 15:23, 15:24,

16:2, 16:3, 16:23, 20:20, 23:10, 23:25, 39:22, 44:14, 44:18, 45:2, 45:19, 46:8, 46:13

taken [6] - 1:17, 3:8, 14:14, 17:22, 19:24, 42:20

takes [4] - 41:16, 41:18, 44:19, 45:20

taking [6] - 15:6, 17:3, 28:20, 45:3, 46:14, 46:15

talked [2] - 22:23, 50:9talking [3] - 6:3, 12:12, 34:2TARYN [1] - 2:11team [1] - 49:11telephone [1] - 39:17tell [20] - 5:19, 9:4, 9:6,

11:23, 12:10, 12:18, 21:5, 25:2, 34:6, 34:20, 34:25, 35:4, 36:12, 36:16, 37:22, 38:7, 42:11, 45:14, 45:21, 45:22

tells [1] - 12:7temperature [1] - 17:22tense [1] - 38:2tension [1] - 35:3testified [4] - 5:9, 29:10,

29:12, 45:10testify [1] - 53:5testifying [1] - 4:22testimony [3] - 53:6, 53:10,

55:13tests [1] - 14:14than [12] - 6:12, 16:10, 22:22,

29:10, 29:11, 31:13, 37:8, 37:15, 43:2, 44:13, 46:6, 46:17

Thank [4] - 50:22, 50:25, 51:2, 52:13

That [3] - 23:2, 23:3, 55:10that [88] - 3:16, 4:10, 4:14,

4:17, 4:21, 7:24, 7:25, 8:9, 11:20, 14:18, 14:22, 16:8, 16:14, 16:17, 17:11, 17:13, 20:3, 20:14, 20:23, 21:9, 21:11, 21:15, 22:6, 22:7, 22:8, 22:12, 22:23, 23:14, 23:20, 23:24, 24:2, 24:7, 25:9, 25:12, 27:15, 27:17, 27:18, 27:19, 27:22, 27:25, 28:11, 28:25, 29:7, 29:21, 30:2, 30:12, 30:20, 31:14, 31:18, 32:7, 32:10, 32:15, 33:8, 34:18, 35:16, 36:11, 37:3, 38:3, 38:16, 38:19, 38:25, 39:14, 39:15, 42:19, 43:4, 43:15, 43:16, 44:3, 45:14, 45:17, 46:22, 47:9, 48:11, 48:17, 48:24, 49:6, 49:8, 49:21, 50:2, 50:3, 51:9, 53:4, 53:8, 55:12, 55:13, 55:14, 55:16

that's [9] - 8:9, 16:12, 20:8, 25:17, 25:18, 25:20, 35:3, 43:20, 51:22

That's [10] - 11:25, 12:6, 17:2, 24:3, 29:3, 29:9, 32:23, 40:13, 45:23, 51:23

THE [7] - 1:2, 3:2, 4:2, 51:4, 51:12, 51:25, 52:6

The [7] - 5:21, 9:8, 9:9, 14:7, 24:19, 42:3, 43:12

the [227] - 1:7, 1:18, 1:19, 1:20, 1:23, 2:4, 2:8, 2:9, 2:14, 3:5, 3:7, 3:8, 3:8, 3:9, 3:10, 3:12, 3:12, 3:14, 3:15, 3:16, 3:19, 3:23, 3:24, 3:24, 3:25, 4:3, 4:4, 4:4, 4:5, 4:5, 4:6, 4:6, 4:7, 4:8, 4:10, 4:11, 4:12, 4:14, 4:15, 4:17, 4:18, 4:20, 4:22, 4:22, 5:4, 5:5, 6:2, 6:17, 6:22, 6:24, 7:21, 7:24, 7:25, 8:2, 8:4, 8:6, 8:15, 8:18, 9:17, 9:20, 9:23, 10:3, 10:5, 10:19, 10:23, 11:17, 11:19, 11:20, 11:23, 12:7, 12:10, 12:17, 12:18, 12:24, 13:3, 13:14, 14:4, 15:23, 15:25, 17:13, 18:4, 18:7, 18:8, 18:14, 18:15, 18:16, 19:3, 19:7, 19:10, 19:15, 19:19, 19:20, 19:25, 20:4, 20:8, 20:21, 21:8, 21:16, 21:19, 21:22, 22:3, 22:11, 22:22, 23:16, 24:9, 24:17, 24:25, 25:9,

S. BEGUM


63

25:10, 25:14, 25:15, 25:22, 26:3, 26:8, 26:12, 26:16, 26:17, 26:19, 26:25, 27:2, 27:3, 27:8, 27:9, 28:6, 28:10, 28:13, 28:15, 28:18, 29:25, 30:12, 30:20, 31:9, 31:10, 31:17, 32:2, 32:3, 32:19, 33:2, 33:6, 33:9, 33:11, 33:12, 33:14, 33:22, 34:15, 36:7, 37:8, 37:17, 37:18, 38:3, 38:13, 40:10, 40:11, 40:19, 41:9, 41:12, 41:24, 42:3, 42:19, 43:3, 43:17, 44:6, 44:8, 44:13, 44:15, 44:21, 45:19, 46:6, 46:7, 46:8, 46:10, 46:11, 46:17, 46:19, 47:4, 47:7, 47:8, 47:15, 47:21, 47:22, 47:25, 48:4, 48:10, 48:23, 49:10, 49:11, 49:22, 49:23, 50:18, 51:9, 51:11, 51:16, 51:17, 52:14, 53:5, 53:6, 53:8, 53:10, 55:8, 55:10, 55:13, 55:15, 55:17

their [3] - 8:6, 9:4, 9:6them [4] - 8:7, 25:24, 37:13,

37:15then [11] - 15:20, 18:14,

18:23, 19:9, 19:22, 22:18, 45:20, 45:21, 47:5, 51:24, 52:2

Then [2] - 38:11, 51:12there [9] - 5:17, 12:7, 13:7,

19:18, 34:11, 35:21, 40:9, 47:4, 50:3

There [5] - 9:14, 47:5, 47:11, 48:15, 48:19

therefor [1] - 3:23these [7] - 4:7, 18:6, 18:9,

19:25, 20:19, 42:9, 42:12they [3] - 25:3, 37:22, 45:21They [1] - 45:23They're [1] - 8:5this [17] - 3:15, 3:22, 4:21,

5:14, 5:16, 13:22, 21:17, 21:22, 31:25, 50:11, 51:4, 51:15, 52:15, 53:19, 55:15, 55:18, 55:20

those [2] - 3:4, 25:23thought [2] - 8:14, 29:19three [1] - 26:22Three [1] - 7:15throat [1] - 21:14TIME [1] - 1:14time [51] - 6:3, 6:25, 7:24,

10:20, 18:8, 18:17, 19:21, 20:5, 20:14, 20:21, 21:11, 21:22, 24:18, 24:19, 24:25, 25:11, 26:4, 26:7, 26:8, 26:11, 26:12, 26:16, 26:17,



26:20, 26:25, 27:8, 27:10, 28:7, 28:15, 28:16, 30:2, 30:12, 30:14, 31:9, 31:17, 32:10, 32:19, 33:2, 33:3, 33:7, 33:9, 33:11, 43:3, 44:16, 46:8, 46:19, 47:5, 48:2, 48:23, 49:22, 53:10

times [5] - 18:9, 19:18, 23:15, 24:21, 42:19

To [1] - 27:19to [213] - 1:18, 3:4, 3:9, 3:9,

3:10, 3:12, 3:13, 3:14, 3:17, 3:18, 3:19, 3:20, 3:21, 3:22, 3:24, 4:17, 4:22, 5:4, 5:15, 5:18, 5:22, 5:25, 6:5, 6:10, 6:20, 6:21, 7:10, 8:12, 8:21, 9:19, 9:23, 10:3, 10:5, 10:23, 11:21, 11:23, 12:9, 12:16, 12:20, 12:21, 12:24, 13:3, 13:5, 13:10, 13:14, 13:15, 13:24, 14:3, 14:10, 14:11, 14:15, 14:18, 15:8, 15:21, 15:22, 16:2, 16:3, 16:6, 16:9, 16:15, 16:19, 16:22, 17:6, 17:11, 17:18, 17:19, 17:25, 18:2, 18:7, 18:10, 18:11, 19:25, 20:4, 20:8, 20:12, 20:14, 20:20, 20:22, 20:24, 21:3, 21:9, 21:20, 22:6, 22:16, 22:18, 22:20, 22:21, 23:2, 23:4, 23:5, 23:8, 23:11, 23:19, 24:6, 24:9, 24:15, 24:22, 25:8, 25:10, 25:24, 26:4, 26:6, 26:10, 26:16, 26:24, 27:2, 27:4, 27:6, 27:9, 27:10, 27:14, 28:7, 28:8, 28:10, 28:13, 28:15, 28:17, 28:18, 28:21, 28:22, 29:10, 29:12, 29:14, 29:21, 29:22, 30:4, 30:6, 30:18, 30:21, 31:15, 31:19, 31:21, 32:6, 32:8, 32:9, 32:14, 32:18, 33:2, 33:4, 33:5, 33:8, 33:12, 33:23, 34:8, 34:12, 34:13, 34:15, 34:17, 34:22, 35:3, 35:7, 35:15, 35:20, 35:25, 36:11, 36:23, 36:25, 37:6, 37:12, 38:5, 38:15, 38:19, 39:15, 39:22, 40:3, 40:7, 40:10, 40:15, 41:3, 41:22, 42:8, 42:12, 42:20, 42:21, 43:14, 43:19, 44:3, 44:6, 45:4, 45:11, 45:19, 46:13, 46:25, 47:15, 47:16, 47:22, 47:23, 49:3, 49:21, 49:24, 50:8, 50:9, 51:6, 51:14, 51:18, 52:2, 53:5, 53:18, 55:15

Today [1] - 12:2

today [2] - 11:25, 41:4today's [1] - 51:10told [14] - 16:5, 20:3, 28:18,

31:9, 34:9, 35:17, 36:17, 37:3, 37:25, 42:14, 43:20, 49:25, 50:2, 50:8

took [51] - 11:21, 12:15, 13:3, 13:5, 13:13, 15:20, 16:6, 16:9, 16:15, 16:20, 20:4, 20:8, 20:13, 20:15, 20:23, 22:16, 22:18, 22:21, 23:2, 23:4, 23:5, 23:8, 23:11, 23:13, 23:20, 23:22, 23:23, 24:3, 24:5, 24:15, 25:2, 25:10, 25:13, 25:17, 25:19, 25:20, 26:7, 26:11, 26:16, 27:9, 28:14, 28:22, 30:21, 31:14, 32:9, 32:14, 32:18, 33:2, 33:6, 38:22, 45:10

Tower [1] - 2:5transcript [4] - 4:10, 51:15,

53:9transcripts [2] - 51:7, 52:8transferred [1] - 35:19treat [2] - 24:14, 41:6treatment [5] - 35:10, 35:11,

39:10, 39:11, 40:16trial [1] - 4:14true [2] - 53:9, 55:12truth [1] - 53:5twice [6] - 13:5, 13:14, 16:6,

20:4, 33:16, 33:19two [14] - 7:16, 9:2, 26:22,

31:3, 31:4, 33:19, 33:20, 33:24, 34:8, 34:13, 34:17, 34:22, 35:7, 37:6

UU [1] - 5:6unable [1] - 36:11Under [1] - 1:18understand [9] - 5:18, 7:2,

8:9, 11:6, 11:18, 12:13, 19:4, 26:9, 49:23

understands [2] - 11:14, 12:5

understood [2] - 6:6, 45:11UNIFORM [2] - 3:2, 4:2Uniondale [1] - 2:5unit [1] - 37:19United [5] - 9:20, 9:23, 10:3,

10:5, 10:23units [1] - 37:19unless [1] - 4:5until [2] - 5:24, 5:25us [1] - 6:2use [2] - 7:24, 8:6used [13] - 12:20, 16:2,

16:22, 17:18, 17:19, 17:25,

18:10, 29:14, 29:22, 30:6, 45:4, 46:13, 46:25

utilized [1] - 4:14

Vvarious [1] - 20:7verbally [1] - 5:23very [1] - 50:22via [2] - 2:12, 2:17videoconference [2] - 2:12,

2:17VIDEOCONFERENCED [1] -

1:16visit [17] - 21:17, 21:23, 22:6,

22:12, 22:20, 22:22, 23:16, 23:19, 23:24, 27:2, 27:3, 28:13, 30:20, 31:14, 33:22, 36:6, 36:9

visiting [1] - 38:4vomiting [2] - 32:23, 32:25

Wwait [1] - 5:24waived [2] - 3:5, 4:17want [3] - 8:18, 12:23, 35:3wants [1] - 14:18was [81] - 5:8, 9:11, 12:8,

13:4, 16:7, 16:12, 16:25, 17:2, 17:3, 17:13, 17:22, 18:21, 18:22, 19:24, 20:5, 20:6, 21:8, 21:9, 22:7, 22:8, 22:16, 22:17, 23:17, 23:20, 24:2, 24:7, 25:15, 26:21, 27:15, 27:17, 27:19, 27:20, 27:22, 27:24, 27:25, 28:2, 28:11, 28:12, 30:2, 30:5, 30:12, 31:18, 32:21, 32:22, 33:5, 33:9, 33:11, 33:12, 33:15, 33:23, 34:7, 34:11, 34:12, 34:21, 35:2, 35:5, 35:7, 35:17, 35:21, 35:23, 36:7, 36:13, 36:18, 37:5, 37:6, 37:7, 37:18, 37:23, 37:25, 38:9, 38:13, 39:10, 39:16, 39:20, 43:4, 45:3, 52:15, 55:11

Was [2] - 15:15, 35:18was he [8] - 15:6, 27:21,

28:3, 30:11, 30:23, 32:24, 33:14, 38:14

Was it [5] - 15:13, 17:9, 27:18, 36:3

was that [2] - 23:19, 29:25Was there [3] - 22:20, 34:16,

37:19way [2] - 8:17, 55:17we [7] - 6:22, 8:5, 15:19,

15:20, 23:13, 38:22, 39:15We [1] - 8:7

S. BEGUM


64

we'll [1] - 7:23We're [1] - 11:19we're [1] - 34:2week [1] - 26:21weeks [3] - 26:22, 36:3weight [1] - 27:25Well [8] - 22:11, 23:16,

30:20, 46:22, 47:7, 47:20, 51:8, 51:22

went [8] - 15:22, 16:19, 21:7, 27:10, 28:7, 28:15, 32:8, 40:3

were [13] - 12:12, 12:19, 18:8, 18:15, 19:18, 19:23, 25:12, 25:23, 29:19, 37:9, 37:15, 37:22, 38:3

Were you [4] - 9:19, 10:2, 29:17, 35:17

West [1] - 2:5What [5] - 13:16, 27:21,

33:18, 44:18, 45:22what [26] - 10:6, 10:10,

12:11, 12:18, 13:8, 13:24, 13:25, 15:17, 17:4, 17:16, 18:2, 24:6, 25:2, 25:11, 25:23, 28:8, 29:10, 29:11, 31:13, 36:16, 37:19, 37:22, 40:6, 42:16, 45:11, 49:24

what did [2] - 21:5, 21:22what is [8] - 6:16, 7:7, 7:19,

14:4, 46:10, 48:4, 49:8, 50:11

what was [6] - 27:11, 34:6, 34:20, 36:13, 36:17, 40:19

whatever [1] - 12:6Whatever [1] - 31:20when [35] - 3:17, 3:19, 15:22,

16:7, 16:19, 19:18, 20:6, 20:13, 20:23, 20:25, 22:7, 23:9, 23:17, 24:15, 24:25, 26:17, 27:3, 27:10, 28:14, 30:5, 30:19, 30:21, 32:8, 33:6, 33:15, 33:23, 34:7, 34:12, 34:16, 34:21, 36:6, 36:13, 36:18, 37:6, 41:15

When [7] - 15:19, 17:12, 21:7, 24:5, 32:16, 32:17, 37:5

When did [1] - 10:5when you [11] - 10:2, 17:20,

20:8, 21:2, 25:22, 27:17, 29:24, 30:8, 39:3, 40:15, 47:18

Whenever [1] - 45:19whenever [1] - 8:8where [5] - 35:8, 37:17,

38:10, 38:24, 46:11where was [2] - 28:7, 39:9WHEREOF [1] - 55:19Whereupon [1] - 52:14



whether [2] - 4:6, 51:18which [2] - 3:4, 13:10Which [1] - 14:3Whichever [1] - 8:17While [2] - 18:21, 39:16while [2] - 18:21, 37:23who [7] - 6:24, 7:3, 11:9,

11:14, 11:22, 12:10, 41:16Who [1] - 32:9who are [1] - 43:18Who told [1] - 45:17whoever [1] - 34:18whom [1] - 3:7whose [1] - 55:10Why [1] - 16:23why [15] - 12:6, 16:12, 16:20,

17:2, 24:3, 25:17, 25:19, 25:20, 27:18, 32:13, 32:23, 35:3, 35:17, 43:21, 45:23

will [8] - 5:19, 5:21, 6:22, 7:24, 7:25, 8:13, 8:16, 42:12

William [1] - 2:16with [38] - 3:6, 3:16, 4:3, 4:5,

4:11, 4:18, 6:24, 7:4, 9:24, 12:3, 12:4, 18:24, 22:22, 23:5, 23:21, 24:9, 26:3, 28:25, 29:7, 31:16, 34:7, 34:19, 34:21, 36:13, 36:18, 37:8, 37:15, 39:18, 40:3, 40:16, 44:5, 45:7, 49:13, 50:15, 50:18, 50:19, 51:15, 51:18

withdrawn [2] - 35:6, 35:18within [1] - 55:8without [1] - 4:22witness [5] - 1:17, 4:22,

52:15, 55:10, 55:13WITNESS [1] - 55:19words [1] - 18:12work [2] - 10:19, 10:25worked [1] - 10:22worse [3] - 22:17, 32:21would [8] - 3:5, 3:20, 5:18,

8:14, 11:22, 15:25, 37:14, 52:6

wrist [1] - 19:20wrists [2] - 18:5, 18:7write [1] - 8:7writing [2] - 18:21, 18:22wrong [4] - 34:7, 34:21,

36:13, 36:17

XX [4] - 1:3, 1:11, 54:2, 54:9X/X/1981 [1] - 6:19X/X/2012 [1] - 9:16XX [1] - 6:23XXX [1] - 6:23

XXX-XX-XXXX [1] - 6:23XXXX [1] - 6:23

Yyear [10] - 6:18, 9:17, 10:6,

10:10, 13:21, 15:17, 17:4, 21:19, 40:6, 40:11

years [3] - 6:13, 15:23, 17:11Yes [51] - 5:20, 6:4, 6:7, 6:15,

7:12, 7:18, 8:25, 9:13, 10:4, 10:9, 12:25, 13:22, 13:23, 14:13, 14:16, 15:12, 15:14, 15:16, 16:11, 17:15, 19:13, 19:22, 20:3, 20:17, 21:4, 21:12, 25:7, 26:13, 28:5, 30:10, 33:13, 34:5, 34:14, 36:8, 37:16, 40:12, 40:14, 40:18, 41:2, 41:5, 41:14, 42:4, 44:2, 44:17, 44:25, 45:16, 46:2, 47:4, 48:3, 48:8, 49:7

yes [5] - 7:12, 9:13, 20:17, 30:10, 52:4

yet [1] - 14:19YORK [2] - 1:2, 55:4York [8] - 1:22, 1:23, 2:5,

2:11, 2:16, 5:7, 55:9You [6] - 5:23, 29:16, 31:22,

32:7, 40:2, 43:16you [96] - 5:15, 5:17, 5:18,

5:22, 5:25, 6:5, 6:20, 8:11, 8:14, 9:4, 10:5, 10:8, 10:23, 11:8, 11:11, 11:13, 11:21, 11:22, 12:9, 12:12, 12:14, 12:15, 12:18, 13:20, 14:10, 14:21, 16:5, 16:10, 16:13, 16:16, 16:18, 16:21, 16:24, 20:3, 21:5, 22:23, 23:3, 23:8, 23:16, 23:19, 23:20, 23:21, 23:23, 25:2, 27:22, 28:25, 29:7, 29:19, 30:8, 30:20, 31:9, 31:13, 31:14, 31:21, 32:10, 32:11, 34:6, 34:20, 36:12, 36:16, 36:25, 37:9, 37:15, 37:22, 38:3, 38:5, 38:15, 38:21, 39:21, 41:16, 42:11, 42:21, 43:13, 43:19, 43:22, 44:11, 45:14, 45:17, 45:22, 46:22, 47:16, 48:11, 48:16, 49:20, 49:25, 50:2, 50:22, 50:25, 51:2, 51:5, 51:13, 51:18, 52:2, 52:13

you're [2] - 39:4, 48:25you've [3] - 42:19, 43:4,

47:12younger [2] - 9:9, 9:11your [184] - 5:16, 5:23, 5:24,

6:16, 6:20, 6:21, 7:3, 7:7, 7:19, 9:2, 9:20, 9:24, 11:8,

S. BEGUM


65

11:13, 11:21, 11:23, 12:11, 12:16, 12:18, 13:16, 14:11, 14:20, 15:5, 15:10, 15:17, 15:22, 15:23, 15:24, 16:3, 16:4, 16:8, 16:9, 16:14, 16:15, 16:19, 16:20, 16:23, 17:4, 17:12, 19:24, 20:18, 20:20, 21:6, 21:10, 21:21, 22:8, 22:21, 23:3, 23:4, 23:5, 23:8, 23:9, 23:10, 23:11, 23:17, 23:20, 23:24, 24:5, 24:10, 24:13, 24:15, 24:21, 24:24, 24:25, 25:2, 25:3, 25:9, 25:10, 25:11, 25:12, 26:2, 26:3, 26:4, 26:6, 26:7, 26:10, 26:11, 26:15, 26:16, 27:3, 27:4, 27:8, 27:9, 27:11, 28:14, 28:20, 28:21, 28:22, 29:2, 29:7, 30:9, 30:21, 31:14, 31:16, 32:7, 32:9, 32:10, 32:13, 32:14, 32:17, 32:18, 32:25, 33:5, 33:6, 33:22, 34:7, 34:11, 34:12, 34:15, 34:16, 34:20, 34:21, 35:5, 35:6, 35:17, 35:18, 35:23, 36:6, 36:13, 36:16, 36:18, 37:5, 37:7, 37:18, 37:22, 38:4, 38:9, 38:18, 39:9, 39:16, 39:20, 39:21, 39:22, 40:2, 40:3, 40:16, 41:3, 41:6, 41:15, 41:16, 41:20, 42:12, 42:20, 42:21, 43:2, 43:7, 43:12, 43:13, 43:17, 43:22, 43:23, 44:5, 44:14, 45:6, 45:13, 45:14, 45:17, 46:3, 46:7, 46:18, 46:22, 47:3, 47:9, 47:13, 47:15, 47:24, 48:12, 48:23, 50:2, 50:4, 50:11, 51:6

Your [2] - 9:11, 48:6YOUR [1] - 48:7

ZZahed [1] - 7:9ZAHED [2] - 1:3, 7:9

°° [4] - 52:18



NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 10/01/2019 1 2 …

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