People v Curran, 2013 NY Slip Op 00613 (4th Dept. 2013)
“We note that the victim’s testimony about her own out-of-court statements did not constitute hearsay and, therefore, application of the “prompt outcry” exception was not necessary for the admission of that testimony.”
I am not sure I ever saw an appellate court definitively state that the deponent’s own prior statements were not hearsay. I always thought that was the case, and the Appellate Division agreed.