Order: SANSONE, DOMINIC v. LENNON, RALSTON G Et Al

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                                DOCKET NO. HHD-CV-20-6127575-S : SUPERIOR COURT

DOMINIC SANSONE z J.D. OF HARTFORD

vs. 3 AT HARTFORD

RALSTON G. LENNON and
J.B. HUNT TRANSPORT, INC. : JULY 12, 2022

MOTION FOR ORDER OF COMPLIANCE

Pursuant to Practice Book Section 13-7, the undersigned
defendants respectfully request that this Court compel the
plaintiff to produce the following medical and billing records
ordered by the Court to be produced by April 15, 2022.

BACKGROUND: On July 13, 2021, the defendants wrote the
plaintiff in regards to outstanding medical and billing records,
employment records and tax returns, on December 10, 2021, after
no response, the defendant filed a Motion for Order of Compliance
(#129) which the Court granted on February 14, 2022 (#129.86
citing “Supplemental compliance ordered on or before 4/15/22. If
the moving party does not receive compliance by that date,

sanctions may be ordered”.On March 4, 2022 and March 7, 2022 the defendants received
partial compliance electronically. On March 24, 2022 plaintiff
wrote the defendant addressing the records listed in the Motion
for Order of Compliance dated December 10, 2021. Within this
letter the plaintiff stated they are working on obtaining records
and will disclose upon receipt the following records, which to

date have not been provided:

1. VA records in CT from 1/1/21 to the present;

2. Prescription records

3. Catholic Family Counseling

4, Vocational Rehab records

5. Dr. Jeffrey Schaberg/ Signature Orthopedics

6. Bradley Morris Agency records

7. Tax returns from 2015, 2016, 2017, 2018 and 2021

8.U.S. Army medical records between 2012 through 2016

In addition to those records referenced above, after review
of the records provided in March 2022, the following records

remain outstanding. As to prior treatment in Missouri:1. VA in Missouri - All prior and current records,
including but not limited to, Hospital, psychiatrist,
counseling, orthopedic and any other records which
relate in part to his alleged claims in this matter;

2. Dr. Gheith - Plaintiff was referred to this provider
for disability purposes;

3. Select Physical Therapy - A Compete copy of all
records from this provider. Records received from
plaintiff reflect 4 visits out of 11.

As to treatment in Connecticut, the following records are

also outstanding:

1.

J. Mark Hall, PhD. - We are missing medical records
dated 1/21/21 and 2/2/21 and all medical and billing
records from 4/13/22 to the present;

- VA in Connecticut - The records for this provider start

at 10/11/18 and then the plaintiff does not return until
8/12/20 for an MRI. The last date of treatment we have
for this provider is in February of 2022. It appears
that there is over a year gap in treatment and records
indicated the plaintiff received Vocational Rehab and
Acupuncture from the VA, yet those records were not
provided. It does not appear that the plaintiff’s entire
VA record from the time he moved to Connecticut to the
present has been provided;

May Chiropractic - All intake and questionnaire forms
which were referenced and filled out on 10/22/18;

. Hartford Hospital Pain Center - We are missing medical

records dated 8/16/19, 10/24/19, and 11/22/19. We also
missing intake and questionnaire forms, as well as a
readable billing statement;5. Anna L. Perrone, MD - This provider was referenced in
the Hartford Hospital Pain Center’s record as a treater;

6. West Hartford Acupuncture - Missing billing record for
3/12/21;

7. Manchester Memorial Hospital - All records from March
2019 admission;

8. All medical records for the provider who prescribed

medical marijuana.

To date the plaintiff has not provided any of the documents
requested above. In fact, plaintiff’s counsel has sent subpoena’s
to out of state providers without a proper Commission for out of
state subpoena and deposition to make it appear to the Court that
they were attempting to comply with the Courts orders.

The defendants have given the plaintiff more than adequate
time to comply and therefore seek a Court order compelling
response within two weeks of the date of this motion or dismissal

will be entered.

THE DEFENDANTS,

BY Meal ‘ Cote

ELLEN M. COSTELLO

DEL SOLE & DEL SOLE, LLP
JURIS NO. 101674
ELLENC@DELSOLEDELSOLE .COMCERTIFICATION

I hereby certify that a copy of the foregoing has been mailed
postage prepaid and/or sent via electronic mail and/or via
facsimile on this date to the following:

Tiffany Lynn Sabato, Esquire
Goff Law Group LLC

75 Brace Road

West Hartford, CT 06107

Month

Ellen M. Costéllo