Quiroz v Zottola, 2015 NY Slip Op 04627 (2d Dept. 2015)
“Moreover, the trial court did not improvidently exercise its discretion in limiting the cross-examination of Zottola. The court properly limited the plaintiffs’ cross-examination of Zottola regarding his prior employment and negative credit history, due to the collateral nature of these issues (see Badr v Hogan, 75 NY2d 629, 635; Parsons v 218 E. Main St. Corp., 1 AD3d 420). We also note that, with respect to Zottola’s credit history, “civil judgments cannot be characterized as bad or immoral . . . acts involving moral turpitude that would allow them to be used to question the defendant’s credibility” (People v Heiss, 221 AD2d 562, 563).”
