Corcoran et al v. CVS Health Corporation

Northern District of California, cand-4:2015-cv-03504

Exhibit 36

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0 Exhibit 36 0 Page 1 1 2 UNITED STATES DISTRICT COURT 3 NORTHERN DISTRICT OF CALIFORNIA 4 OAKLAND DIVISION 5 - - - - - - - - - - - - - - - -x 6 CHRISTOPHER CORCORAN, et.al, 7 Plaintiffs, 8 -against- No.: 15-CV-03504 9 CVS PHARMACY, INC., 10 Defendant. 11 - - - - - - - - - - - - - - - -x 12 598 Broad Hollow Road Melville, New York 11747 13 14 October 14, 2019 9:08 a.m. 15 16 17 EXAMINATION BEFORE TRIAL of 18 STEPHEN SULLIVAN, the Plaintiff in the 19 above-entitled action, held at the above 20 time and place, taken before Angela M. 21 Spinelli, CSR, RPR and a Notary Public of 22 the State of New York. 23 24 * * * 25 Veritext Legal Solutions 215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830 0 Page 34 Page 36 1 Stephen Sullivan 1 Stephen Sullivan 2 Q. Prior to 2 weeks ago? 2 in this lawsuit, right? 3 A. Yes. 3 A. Right. 4 Q. How many times did you talk on 4 Q. All right. So the phone calls 5 the phone before 2 weeks ago about this 5 on September 13th, this second phone 6 lawsuit? 6 call -- 7 A. About 2 times. 7 A. Okay. 8 Q. 2 times. You recall when those 8 Q. -- was there anybody else on the 9 phone conversations were? 9 phone then? 10 A. October, beginning of October, 10 A. No, nobody else. 11 first week, and then the second week was 11 Q. How long was that phone call? 12 October 13th on the phone. 12 A. I would say about a half an 13 Q. Sorry? 13 hour. 14 A. We spoke on the phone on October 14 Q. Half an hour? 15 4th and October 13th. 15 A. Yeah. 16 Q. So yesterday? 16 Q. All right. And then were there 17 A. Oh, no, not yesterday. It would 17 any other contacts between you and any 18 be -- yesterday I saw -- 18 counsel in this litigation or otherwise 19 Q. -- do you mean September 4th and 19 between that September 13th phone call and 20 September 13th? 20 your first in-person meeting with Mr. 21 A. Yes, sorry. 21 Lewis 2 weeks ago? 22 Q. No problem. 22 A. No, no other contact. 23 A. I get myself confused. 23 Q. All right. The second in-person 24 Q. All right. So let's start with 24 meeting, when was that meeting? 25 the September 4th phone call. Was there 25 A. The second one was -- the second Page 35 Page 37 1 Stephen Sullivan 1 Stephen Sullivan 2 anybody else on the phone? 2 one was this week. I think it was this 3 A. No, just me and Richard. 3 week. 4 Richard and I. 4 Q. So yesterday, 2 days ago? 5 Q. How long did the call last? 5 A. The second was 2 days ago, I 6 A. About an hour. 6 would say, the second one. Actually, 7 Q. Is that when you learned of this 7 again, confusing the dates. 8 lawsuit? 8 Q. It's okay if you give me a 9 A. Yes, it actually was I learned 9 ballpark. Do you think it was in the past 10 it, yeah, then, yes. 10 few days? 11 Q. Is that when you were first 11 A. Yes. 12 asked to participate in this lawsuit? 12 Q. And where was that meeting? 13 MR. LEWIS: Objection. Calls 13 A. That was at my house. 14 for the witness to disclose 14 Q. And who was present at that 15 attorney/client communication. 15 meeting? 16 Please answer to the best of 16 A. My wife, myself and Richard. 17 your ability without saying what you 17 Q. And I just want to clarify again 18 said to me, or what I said to you. 18 your wife Linda is not a plaintiff in this 19 A. I don't know. 19 lawsuit, right? 20 Q. So prior to your first phone 20 A. Correct. 21 call with Mr. Lewis on September 4th, did 21 Q. How long did that second 22 you know about this lawsuit? 22 in-person meeting at home last? 23 A. No. 23 A. I'd say about an hour. 24 Q. So if you didn't know about it, 24 Q. Did you guys review documents 25 you hadn't thought about being a plaintiff 25 during that meeting? 10 (Pages 34 - 37) Veritext Legal Solutions 215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830 0 Page 110 Page 112 1 Stephen Sullivan 1 Stephen Sullivan 2 Q. So sort of in laymen's terms, if 2 I use that till now. 3 you fill prescriptions in mail instead of 3 Q. Well, you put dates for CVS? 4 retail you could save $75? 4 A. For Rite Aid because CVS don't 5 MR. LEWIS: Same objection. 5 cover certain medications, you have to go 6 Calls for technical knowledge. Please 6 where they have it on the shelf. 7 answer to the best of your ability. 7 Q. Sorry, that is not the question. 8 A. Yes, I see it. But it's a 8 Is there a reason you didn't put 9 tricky thing now. 9 a date for Rite Aid? 10 Q. Even though you could save $75 10 A. No. 11 per year per person by filling 11 Q. Now, the third pharmacy Stop and 12 prescriptions in the mail, you didn't use 12 Shop Pharmacy -- 13 the mail service, did you? 13 A. Yes. 14 MR. LEWIS: Same objection. 14 Q. -- there's no address or town 15 Please answer. 15 for that. Do you know where that Stop and 16 A. To the best of my ability, no, I 16 Shop Pharmacy is? 17 did not use a mail service. 17 A. Yes. 18 Q. All right. Let's go back to 18 Q. Where is it? 19 Defendant's Exhibit 337, it's your 19 A. West Islip. 20 responses to our interrogatories. And if 20 Q. Are there any dates for that 21 you will go to page 4? 21 pharmacy? 22 A. Yes, sir. 22 A. No. 23 Q. Do you see at the top between 23 Q. Do you know what dates you 24 lines one and 2 interrogatory number 3? 24 shopped there roughly, ballpark? 25 A. Yes. 25 A. Dates I shopped there? Page 111 Page 113 1 Stephen Sullivan 1 Stephen Sullivan 2 Q. And do you see it asks you to 2 Q. Yeah, so you provide a range of 3 identify every pharmacy or other retailer 3 2006 through 2015, is it the same for Stop 4 where you had filled prescription 4 and Shop? 5 medication since November 1, 2006 5 A. Yeah, for the Stop and Shop, and 6 including the pharmacy or other retailers 6 same thing for Rite Aid. 7 name and address and the dates you filled 7 Q. Okay. Okay. Now, is the 8 prescriptions there. Did I read that 8 information here in your response to 9 correctly? 9 interrogatory number 3, is that accurate? 10 A. Yes. 10 A. Over here? 11 Q. You respond with 3 pharmacies? 11 Q. Sorry, it's the same thing we're 12 A. Correct. 12 looking at now, the 3 pharmacies you 13 Q. The first is a CVS in Montauk 13 identify. Is that accurate? 14 Highway, West Islip, New York? 14 A. Correct. Up to my knowledge, 15 A. Yes. 15 yes. 16 Q. The dates that you shopped there 16 Q. Okay. I'm going to show you 17 are 2006 through 2015? 17 what's being marked as Defendant's Exhibit 18 A. Yes. 18 338. Okay? 19 Q. And the second pharmacy you 19 [The document was hereby marked 20 identify there is Rite Aid at Union 20 as Defendant's Exhibit 341 for 21 Boulevard in West Islip? 21 identification, as of this date.] 22 A. Yes. 22 MR. BELDEN: Defendant's Exhibit 23 Q. You don't provide dates for 23 341, sorry. 24 that? 24 Q. And I'm just going to identify 25 A. No, I didn't provide any dates. 25 for the record Defendant's Exhibit 341 is 29 (Pages 110 - 113) Veritext Legal Solutions 215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830 0 Page 118 Page 120 1 Stephen Sullivan 1 Stephen Sullivan 2 Q. What about 2013? 2 MR. LEWIS: Same objection. 3 A. Same places. 3 Please answer. 4 Q. So you never went anywhere other 4 A. I have no answer for it. I 5 than these 3 pharmacies? 5 cannot answer that. 6 A. Correct. 6 Q. All right. Let's go back to DX 7 Q. And on page 2 -- 7 337 your responses to our interrogatories. 8 A. Of the document? 8 CVS. We're looking at being at page 4 of 9 Q. -- of that document, yes. You 9 that document? 10 see row 4? 10 A. Okay. 11 A. Yes. 11 Q. And around line 19 of that page, 12 Q. Purchase, a Rite Aid Pharmacy, 12 you see interrogatory number 4? 13 10665, on July 28, 2012; you see that? 13 A. Yes. 14 A. Yes, sir. 14 Q. And interrogatory number 4 asks 15 Q. And then row 5 is a purchase at 15 "identify each and every generic drug 16 Stop and Shop Pharmacy on the same day 16 discount program, e.g., CVS Health Savings 17 July 28, 2012, right? 17 Pass, Wal-Mart's $4 program of which you 18 A. Correct. 18 have been aware at any time since November 19 Q. Do you have any idea why you 19 1, 2006 including identifying in which 20 went to 2 different pharmacies on one day? 20 such programs you have participated or 21 A. I rather not answer that. 21 enrolled, if any." Did I read that 22 Q. I'm sorry that's -- 22 correctly? 23 MR. LEWIS: Please answer to the 23 A. Yes, you did. 24 best of your ability. 24 Q. Then your response is "subject 25 A. The best of my ability on this 25 to the general objections plaintiff states Page 119 Page 121 1 Stephen Sullivan 1 Stephen Sullivan 2 one I don't know what happened that day. 2 he has not participated and has not 3 Why did I go to 2 pharmacies, I don't 3 enrolled in any generic drug discount 4 know. 4 programs, he was not aware of any such 5 Q. Is that something you normally 5 programs until this litigation." Did I 6 do? 6 read that correctly? 7 A. No, that's not something we 7 A. Yes, you did. 8 normally do. We try to make it convenient 8 Q. And is your answer to this 9 for us to CVS. Rite Aid is somewhat 9 interrogatory true and accurate as you see 10 convenient. Stop and Shop. But not like 10 it today? 11 the CVS. Rite Aid had certain medication 11 A. It's true. 12 that I could get right there comes in. 12 Q. Have you heard of something 13 CVS I have to order certain things. 13 called the Paramount Rx discount card? 14 Q. Can you think of any other 14 A. No. 15 reason you might have gone to both a Rite 15 Q. Have you ever heard of a 16 Aid and a Stop and Shop on one day? 16 discount card generally? 17 A. No other reasons. 17 A. Like I said earlier in my 18 Q. So is this Stop and Shop the 18 testimony, when I go to the doctors 19 Amoxicillin you got there on July 28, 19 sometimes they have cards laying on the 20 2012, is that something you couldn't get 20 desk. 21 at Rite Aid? 21 Q. Did you ever sign up for one of 22 MR. LEWIS: Objection. 22 those? 23 A. I don't know. 23 A. No, I never did sign up for one 24 Q. Is it something you couldn't get 24 of them. Because I already have 25 at CVS? 25 insurance, I don't need the card. 31 (Pages 118 - 121) Veritext Legal Solutions 215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830 0 Page 150 Page 152 1 Stephen Sullivan 1 Stephen Sullivan 2 involves a program called the Health 2 don't know if you're suing because you 3 Savings Pass? 3 think you paid more then a price that was 4 A. I don't know. 4 available in the HP program, you don't 5 Q. Do you know who operated Health 5 know that? 6 Savings Pass? 6 A. The lawyer and the experts 7 A. I don't know. 7 figured it out. 8 Q. Do you know whether customers 8 Q. Have you done any independent 9 had to enroll in the Health Savings Pass? 9 investigation of the Health Savings Pass 10 A. I have no idea. 10 Program since you joined this lawsuit? 11 Q. Do you know if there's a fee to 11 A. No. 12 enroll in the Health Savings Pass? 12 Q. Did you ever contact CVS about 13 A. I don't know. 13 the Health Savings Pass? 14 Q. Do you know what kind of drugs a 14 A. No, I have not. 15 person could get in the Health Savings 15 Q. Did CVS ever make any statement 16 Pass program? 16 to you about the Health Savings Pass? 17 A. I don't know. 17 A. I don't know. 18 Q. Do you know one way or the other 18 Q. You don't know? 19 whether the program included any drugs 19 A. I don't remember. If there was, 20 that you've taken? 20 I don't know. 21 A. No, I don't know. 21 Q. You would remember? 22 Q. Do you know what prices were 22 A. I don't remember, I don't know. 23 available in the HSP program? 23 Q. Did CVS make any statement about 24 A. I don't know the program. 24 HSP to your wife? 25 Q. Do you know whether they were 25 A. I don't know. Page 151 Page 153 1 Stephen Sullivan 1 Stephen Sullivan 2 higher or lower than your retail co-pays? 2 Q. Do you have any reason to 3 A. I have no idea. 3 believe that they did? 4 Q. Do you know whether they were 4 A. I don't know, I can't answer 5 higher or lower than your mail order 5 that, I don't know. 6 co-pays? 6 Q. Did Caremark ever say anything 7 A. I don't know. 7 about HSPD to you? 8 Q. Do you know what quantities of 8 A. I don't know. 9 drugs were available in the Health Savings 9 Q. Did Caremark ever say anything 10 Pass program? 10 about HSP to your wife? 11 A. I don't know. 11 A. I don't know. 12 Q. Have you reviewed any documents 12 Q. Did Cigna ever say anything 13 related to the Health Savings Pass program 13 about Health Savings Pass to you? 14 at any time? 14 A. No, I don't know. 15 A. No, I haven't. 15 Q. Did Cigna ever say anything 16 Q. And so, do you have any 16 about Health Savings Pass to your wife? 17 understanding of how your claims in this 17 A. I don't know that answer. 18 lawsuit relate to the HSP program, if at 18 Q. Did anybody else at any time say 19 all? 19 anything about Health Savings Pass to you? 20 MR. LEWIS: Objection. Requires 20 A. No, I don't know. At any time. 21 expert knowledge. Please answer to 21 Q. Did anybody else ever at any 22 the best of your ability. 22 time say anything to your wife about 23 A. I don't know, experts handle 23 Health Savings Pass? 24 that. 24 A. I don't know. 25 Q. So you don't know if your -- you 25 Q. So you never received any oral 39 (Pages 150 - 153) Veritext Legal Solutions 215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830 0 Page 162 Page 164 1 Stephen Sullivan 1 Stephen Sullivan 2 foundation. Please answer. 2 questions here for you, Mr. Sullivan. 3 A. Going forward. 3 I'm going to show you to the 4 Q. Going forward? 4 best I can we will -- we've only got one 5 A. What I know now it's a different 5 copy f this document being marked as DX 6 outlook about CVS. Going forward the way 6 344. It is an annotated version of the 7 you're saying it to me, no, but how you 7 third amended complaint that's been filed 8 said it in my mind, I didn't know about 8 in this litigations? 9 it, why didn't they tell me about it. 9 [The document was hereby marked 10 Q. I'm asking a different question. 10 as Defendant's Exhibit 344 for 11 You still fill prescriptions or your 11 identification, as of this date.] 12 wife -- 12 Q. You see at the top in red ink 13 A. -- my wife does it over there. 13 the file date is circled, April 4, 2016, 14 Now it's done differently, they were 14 Mr. Lewis's name is circled in red, third 15 called until now. 15 amended complaint title of the document is 16 Q. Do you know why you still fill 16 circled in red ink as well in red ink, 17 prescriptions at CVS? 17 written legal doc, what that case is. Is 18 A. Because it's convenient for us. 18 that your handwriting? 19 Q. Do you have any other complaints 19 A. Yes. 20 about CVS or does your wife? 20 Q. When did you write this? 21 A. Me, I'm fine. 21 A. Yesterday. 22 MR. LEWIS: Mr. Sullivan, wait 22 Q. Yesterday? 23 for the attorney to finish his 23 A. Yes. 24 question, and then answer it, please. 24 Q. And did you review this document 25 Your question is? 25 in connection with meeting with Mr. Lewis? Page 163 Page 165 1 Stephen Sullivan 1 Stephen Sullivan 2 Q. Do you have any other complaints 2 A. I didn't go page by page, but I 3 about the service you receive at CVS? 3 looked at it. 4 A. No. 4 Q. Was your wife was present at 5 Q. Have you heard from your wife 5 that meeting as well? 6 any complaints about the service at CVS? 6 A. Yes. 7 A. I have not heard. 7 Q. So who told you what to circle 8 Q. What about Caremark, do you have 8 in this document? 9 any other complaints about Caremark? 9 A. I circled -- oh, the lawyer. 10 A. I have no complaints about 10 Q. Mr. Lewis told you? 11 Caremark. 11 A. Yeah, this is part of the things 12 Q. Have you heard any complaints 12 that you got, I had to read it, I'm not a 13 about Caremark or their services? 13 lawyer, so seeing a form like that is -- 14 A. No. 14 Q. So do you have personal 15 Q. Okay. 15 knowledge of the facts alleged in this 16 MR. BELDEN: Can we go off the 16 complaint? 17 record for just a second. 17 MR. LEWIS: Object to 18 THE VIDEOGRAPHER: The time is 18 foundation. Please answer. 19 1:03 p.m., we're off the record. 19 A. I don't know. 20 [Discussion held off the 20 Q. You don't know? 21 record.] 21 A. What? 22 THE VIDEOGRAPHER: Standby. The 22 Q. You don't know if you have 23 time is 1:08 p.m., we're on the 23 personal knowledge of the facts alleged in 24 record. 24 this complaint? 25 Q. All right. Just a few more 25 A. I would have to review it. 42 (Pages 162 - 165) Veritext Legal Solutions 215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830 0 Page 178 Page 180 1 Stephen Sullivan 1 Stephen Sullivan 2 Q. On the right hand side in red 2 A. I don't know. 3 ink? 3 Q. You don't know. You don't know 4 A. That's me. 4 who wrote this? Was this annotated in the 5 Q. You wrote that? 5 meeting where the 3 of you were present? 6 A. Yes. 6 A. Yes. 7 Q. It says CVS Ensure overcharge? 7 Q. You didn't write it? 8 A. Correct. 8 A. Correct. 9 Q. Do you know why you wrote that? 9 Q. You don't know if Richard wrote 10 A. Because that's what the 10 it, but you knew he wrote some other 11 paragraphs -- condensing the paragraph 11 things, right? 12 down what's there put on the side. 12 A. Could be possibly. 13 Q. That was just notes you were 13 Q. Do you think possibly that your 14 taking during the meeting? 14 wife wrote on this document that you 15 A. Yes. 15 brought to your deposition today? 16 Q. Did you read this motion? 16 A. Could possibly, yes. 17 A. I didn't read the whole thing, 17 Q. And she wrote "most important" 18 no. 18 with an asterisk? 19 Q. All right. This is DX 347? 19 A. Yes, could be. 20 [The document was hereby marked 20 Q. What do you understand that to 21 as Defendant's Exhibit 347 for 21 mean most important with an asterisk? 22 identification, as of this date.] 22 A. Well, just says what the front 23 A. Okay. 23 -- what the words that are there, and the 24 Q. And this is an annotated copy of 24 lawsuit covering different areas, and 25 your plaintiff Steven Sullivan's responses 25 who's representing those areas. Page 179 Page 181 1 Stephen Sullivan 1 Stephen Sullivan 2 and objections to defendant's 2 Q. Do you remember the document 3 interrogatories? 3 that you signed, verified as true and 4 A. Okay. 4 accurate and correct? 5 Q. We looked at a clean copy, DX 5 A. Correct. 6 337? 6 Q. Is that maybe this was marked as 7 A. Yes. 7 the most important thing for you to 8 Q. Do you see in the top right 8 review? 9 asterisk and the words most important? 9 A. Yes. 10 A. That's me. 10 MR. LEWIS: Objection to 11 Q. You wrote that? 11 foundation. You can answer. 12 A. Yeah. 12 Q. On the back handwriting? 13 Q. Are you sure you wrote this? 13 A. That's me. 14 A. Well, because I'd be happy to 14 Q. It says "CVS Ensure runs 15 compare it to the handwriting you said was 15 overcharge, Dr. Hays, expert All Stock"? 16 yours, and they don't look the same. I 16 A. All Stock is a company. 17 don't know. 17 Q. Why did you write CVS insurance 18 THE WITNESS: Is that your 18 overcharge? 19 handwriting? 19 A. That was my footnote. I knew 20 MR. LEWIS: You can't ask Linda 20 what I was doing. 21 questions, unless counsel wants to. 21 Q. What do you mean, you said you 22 It's just you -- you have to answer. 22 knew what you were doing? 23 Q. You're the plaintiff? 23 A. I don't get lost in what you're 24 A. I didn't write it. 24 asking. If you ask me how did I get the 25 Q. Did Richard write it? 25 papers, I know it was All Stock 46 (Pages 178 - 181) Veritext Legal Solutions 215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830 0 Page 182 Page 184 1 Stephen Sullivan 1 Stephen Sullivan 2 represented me before. 2 Q. Did your wife highlight these? 3 Q. That's how the lawyers found you 3 A. No, she didn't. 4 in this case? 4 Q. So here on page 8, chart listing 5 A. Yes. 5 prescription drugs and medical conditions? 6 Q. Who at All Stock represented 6 A. I know about the drugs, yes. 7 you? 7 Q. You know about the drugs? 8 A. I don't remember his name. 8 A. Yes. 9 Q. You don't remember his name? 9 Q. These are your prescription 10 A. No. No, I just know the firm. 10 drugs that you were taking? 11 Q. Is All Stock based here in West 11 A. Correct. 12 Islip? 12 Q. The medical conditions that they 13 A. No, in Florida. 13 relate to? 14 Q. Florida? 14 A. Yes. 15 A. Yeah. 15 Q. Did you highlight this? 16 Q. Why do you have Dr. Hay's expert 16 A. No, I did not. 17 written on the back? 17 Q. Do you know why they're 18 A. I remember the name, he is the 18 highlighted? 19 expert of coming up with the -- identified 19 A. I don't know. 20 the overcharges. 20 Q. Do you know why anything in this 21 Q. He came up with the identified 21 document is highlighted? 22 overcharges? 22 A. No. 23 A. Correct. 23 Q. When did you first see this 24 Q. Did you write these notes during 24 highlighted version of this document? 25 the meeting between you and Mr. Lewis and 25 A. Yesterday. Page 183 Page 185 1 Stephen Sullivan 1 Stephen Sullivan 2 your wife? 2 Q. You have any idea why it was 3 A. Yes. 3 highlighted yesterday? 4 Q. You did? 4 A. I think -- I don't want to say I 5 A. Yes. 5 think. I know that the medications that 6 Q. Do you see that some of these 6 you have on line 26 to 27 and turn the 7 portions are highlighted like on page 2 7 page it's all comprised, compacted into 8 here we have general objections 8 that. 9 highlighted? 9 Q. We'll get to this. 10 A. Okay, all right. 10 A. That goes to there. 11 Q. Do you know who added the 11 Q. Starting on page 8, 12 highlighting to this document? 12 interrogatory number 11 asks you 13 A. No, I don't. 13 highlighted in this version each and every 14 Q. Was it you? 14 prescription you filled since November 9, 15 A. No. No, sir. 15 2008? 16 Q. You see on page 3 the 16 A. Correct. 17 interrogatory numbers and the response are 17 Q. Your response starts on page 8 18 highlighted? 18 and moves on to page 9, but this is 19 A. Okay. It wasn't me. 19 different from the version we looked at 20 Q. You didn't highlight those? 20 earlier, because 1, 2, 3, 4, 5, 6, 8, 9, 21 A. No. 21 10, 11 of your proposed transactions 22 Q. Same thing on page 4, there is 22 identified here are marked out in red pen; 23 highlighting on interrogatory and 23 is that right? 24 response. Did you highlight those? 24 A. They're marked out, yes, they 25 A. No, sir. 25 are marked out. 47 (Pages 182 - 185) Veritext Legal Solutions 215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830 0 Page 202 1 Stephen Sullivan 2 CERTIFICATION 3 4 5 I, Angela M. Spinelli, a Notary Public 6 for and within the State of New York, do 7 hereby certify: 8 That the witness whose testimony as 9 herein set forth, was duly sworn by me; 10 and that the within transcript is a true 11 record of the testimony given by said 12 witness. 13 I further certify that I am not related 14 to any of the parties to this action by 15 blood or marriage, and that I am in no way 16 interested in the outcome of this matter. 17 IN WITNESS WHEREOF, I have hereunto set 18 my hand this 14th day of October, 2019. 19 20 <%16976,Signature%> 21 ANGELA M. SPINELLI, CSR, RPR 22 23 24 * * * 25 Page 203 1 Stephen Sullivan 2 ERRATA SHEET VERITEXT LEGAL SOLUTIONS 3 CASE NAME: Corcoran v. CVS 4 DATE OF DEPOSITION: October 14, 2019 WITNESS' NAME: Stephen Sullivan 5 PAGE/LINE(S)/ CHANGE REASON 6 ____/_______/_________________/________ ____/_______/_________________/________ 7 ____/_______/_________________/________ ____/_______/_________________/________ 8 ____/_______/_________________/________ ____/_______/_________________/________ 9 ____/_______/_________________/________ ____/_______/_________________/________ 10 ____/_______/_________________/________ ____/_______/_________________/________ 11 ____/_______/_________________/________ ____/_______/_________________/________ 12 ____/_______/_________________/________ ____/_______/_________________/________ 13 ____/_______/_________________/________ ____/_______/_________________/________ 14 ____/_______/_________________/________ ____/_______/_________________/________ 15 ____/_______/_________________/________ ____/_______/_________________/________ 16 ____/_______/_________________/________ ____/_______/_________________/________ 17 ____/_______/_________________/________ ____/_______/_________________/________ 18 ____/_______/_________________/________ 19 20 _______________________ STEPHEN SULLIVAN 21 SUBSCRIBED AND SWORN TO 22 BEFORE ME THIS______DAY OF_______________, 20. 23 _______________________ 24 NOTARY PUBLIC 25 MY COMMISSION EXPIRES__________________ 52 (Pages 202 - 203) Veritext Legal Solutions 215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830