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DOCKET NO. CV 14 6043491 S
DAVID CONFEITEIRO : SUPERIOR COURT
VS. : JUDICIAL DISTRICT OF FAIRFIELD,
: AT BRIDGEPORT ‘
TATIANA MEZARINA-ROJAS, ETAL: OCTOBER 13, 2016
JOINT TRIAL MANAGEMENT REPORT
1. Abrief, non-argumentative factual description of the case.
On June 4, 2012, defendant Tatiana Mezarina-Rojas, operating a vehicle leased by
defendant The Nielson Company (US) LLC, rear-ended the plaintiff, David Confeiteiro,
on Interstate 95 in Bridgeport, CT. The plaintiff claims personal injuries.
2. A list of the legal and factual issues in dispute.
a) Liability; (fault for the accident not in dispute)
b) Causation; and
b) Damages.
3. A witness list with an identifier for each witness (party, expert, fact witness, document
custodian) including any anticipated scheduling problems.
Plaintiff's Witnesses (subject to change):
a) Plaintiff David Confeiteiro, who will testify as to liability and damages.
b) Kenneth Lipow, M.D., expert witness/treating healthcare provider for the
plaintiff. Dr. Lipow’s availability to testify is limited to the morning of November
4 ,
c) Dario M. Zagar, M.D., expert witness/treating healthcare provider for the
plaintiff. Dr. Zagar’s availability to testify is limited to the afternoon of November
etd) Kanaga Sena, M.D., expert witness/treating healthcare provider for the
plaintiff. Dr. Sena’s availability to testify is limited to November.
e) Francis P. Alcedo, M.D., expert witness/treating healthcare provider for the
plaintiff.
f) Albert Sabella, expert witness/vocational expert.
g) Gary Crakes, PhD, expert witness/economics expert.
h) Esleiden Confeiteiro, the Plaintiff's wife, who will testify as to damages.
i) Arcenio DeSilva, the Plaintiff's friend and former coworker, who will testify as
to damages.
j) John Paul Broccoli, the Plaintiff's friend, who will testify as to damages.
(N.B. Order of witnesses also subject to change depending on their availability.)
The Plaintiff reserves the right to call any additional witnesses, throughout trial,
that may be required for impeachment, rebuttal or for any other relevant
purposes.
Defendants’ Witnesses:
a) Tatiana Mezarina-Rojas- via video (for 10/2016 Trial) re: impact and
causation
b) Richard Delaney, PhD. Expert witness-Damages
c) Phillip Dickey, MD—Expert (IME 10/13/16) -Damages
d) Kanaga Sena, MD-Plaintiff Expert
The Defendant reserves the right to call any additional witnesses, throughout
trial, that may be required for impeachment, rebuttal or for any other relevant
purposes.4. A list of all pending motions that must be decided before the start of trial including motions
in limine or to preclude evidence. If any party anticipates filing such a motion before the start
of evidence, that party should identify the anticipated motion(s).
The Plaintiff reserves the right to file any motions necessary to address specific issues
that may arise at or before trial.
The Defendant has/will file:
a. Motion to Reconsider Continuance-filed 10/12/16
b. Motion to Preclude Plaintiff Expert-Crakes- filed 10/12/16
c. Motion to Preclude lost wage/future capacity claim
d. Motion to Preclude evidence/claim of SSI Determination
The Defendant reserves the right to call any additional witnesses, throughout
trial, that may be required for impeachment, rebuttal or for any other relevant
purposes.
5. A list identifying the operative pleadings (complaint, answer, counterclaim, etc.) and any
Practice Book § 13-4 expert disclosures by name and docket entry number.
Complaint
Answer 102.00
Certificate of Closed Pleadings 108.00
Defendant Gelco Corporation’s Motion for Summary Judgment 119.00
Plaintiff's Withdrawal of Action Against Gelco Corporation 121.00
Defendants’ Disclosure of Expert Witness 127.00
Plaintiff's Disclosure of Expert Witness 128.00
Plaintiff's First Amended Disclosure of Expert Witness 131.00
Defendant’s Disclosure of Expert Witness-Pending
6. An estimate as to the amount of time required for jury selection.
2-3 days
7. An estimate of the amount of time necessary to try the case.4-5 days
8. Astatement as to any anticipated scheduling problems other than those involving
witnesses, which must be set forth as required in paragraph 3.
The Defendant Mezarina-Rojas will be out of the country in November. While video
testimony is scheduled for 10/25/16, the Defendant would prefer to be directly involved in the
case brought against her.
THE PLAINTIFF, DAVID CONFEITEIRO
BY: 435293
Chelsea E. Krombel
Law Offices of Paul E. Farren, Jr., P.C.
129 Whitney Avenue
New Haven, CT 06510
Phone: (203) 784-0326
Fax: (203) 624-5321
Juris No.: 421215
THE DEFENDANTS, TATIANA MEZARINA-ROJAS
and THE NIELSEN COMPANY (US) LLC
BY:___ 408236
Alan S. Tobin, Esq.
Law Offices of Meehan, Roberts, Turret &
Rosenbaum
108 Leigus Road, 1st Floor
Wallingford, CT 06492
Tel. # 203-294-7800
Juris # 408308
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DOCKET NO. CV 14 6043491 S DAVID CONFEITEIRO : SUPERIOR COURT VS. : JUDICIAL DISTRICT OF FAIRFIELD, : AT BRIDGEPORT ‘ TATIANA MEZARINA-ROJAS, ETAL: OCTOBER 13, 2016 JOINT TRIAL MANAGEMENT REPORT 1. Abrief, non-argumentative factual description of the case. On June 4, 2012, defendant Tatiana Mezarina-Rojas, operating a vehicle leased by defendant The Nielson Company (US) LLC, rear-ended the plaintiff, David Confeiteiro, on Interstate 95 in Bridgeport, CT. The plaintiff claims personal injuries. 2. A list of the legal and factual issues in dispute. a) Liability; (fault for the accident not in dispute) b) Causation; and b) Damages. 3. A witness list with an identifier for each witness (party, expert, fact witness, document custodian) including any anticipated scheduling problems. Plaintiff's Witnesses (subject to change): a) Plaintiff David Confeiteiro, who will testify as to liability and damages. b) Kenneth Lipow, M.D., expert witness/treating healthcare provider for the plaintiff. Dr. Lipow’s availability to testify is limited to the morning of November 4 , c) Dario M. Zagar, M.D., expert witness/treating healthcare provider for the plaintiff. Dr. Zagar’s availability to testify is limited to the afternoon of November etd) Kanaga Sena, M.D., expert witness/treating healthcare provider for the plaintiff. Dr. Sena’s availability to testify is limited to November. e) Francis P. Alcedo, M.D., expert witness/treating healthcare provider for the plaintiff. f) Albert Sabella, expert witness/vocational expert. g) Gary Crakes, PhD, expert witness/economics expert. h) Esleiden Confeiteiro, the Plaintiff's wife, who will testify as to damages. i) Arcenio DeSilva, the Plaintiff's friend and former coworker, who will testify as to damages. j) John Paul Broccoli, the Plaintiff's friend, who will testify as to damages. (N.B. Order of witnesses also subject to change depending on their availability.) The Plaintiff reserves the right to call any additional witnesses, throughout trial, that may be required for impeachment, rebuttal or for any other relevant purposes. Defendants’ Witnesses: a) Tatiana Mezarina-Rojas- via video (for 10/2016 Trial) re: impact and causation b) Richard Delaney, PhD. Expert witness-Damages c) Phillip Dickey, MD—Expert (IME 10/13/16) -Damages d) Kanaga Sena, MD-Plaintiff Expert The Defendant reserves the right to call any additional witnesses, throughout trial, that may be required for impeachment, rebuttal or for any other relevant purposes.4. A list of all pending motions that must be decided before the start of trial including motions in limine or to preclude evidence. If any party anticipates filing such a motion before the start of evidence, that party should identify the anticipated motion(s). The Plaintiff reserves the right to file any motions necessary to address specific issues that may arise at or before trial. The Defendant has/will file: a. Motion to Reconsider Continuance-filed 10/12/16 b. Motion to Preclude Plaintiff Expert-Crakes- filed 10/12/16 c. Motion to Preclude lost wage/future capacity claim d. Motion to Preclude evidence/claim of SSI Determination The Defendant reserves the right to call any additional witnesses, throughout trial, that may be required for impeachment, rebuttal or for any other relevant purposes. 5. A list identifying the operative pleadings (complaint, answer, counterclaim, etc.) and any Practice Book § 13-4 expert disclosures by name and docket entry number. Complaint Answer 102.00 Certificate of Closed Pleadings 108.00 Defendant Gelco Corporation’s Motion for Summary Judgment 119.00 Plaintiff's Withdrawal of Action Against Gelco Corporation 121.00 Defendants’ Disclosure of Expert Witness 127.00 Plaintiff's Disclosure of Expert Witness 128.00 Plaintiff's First Amended Disclosure of Expert Witness 131.00 Defendant’s Disclosure of Expert Witness-Pending 6. An estimate as to the amount of time required for jury selection. 2-3 days 7. An estimate of the amount of time necessary to try the case.4-5 days 8. Astatement as to any anticipated scheduling problems other than those involving witnesses, which must be set forth as required in paragraph 3. The Defendant Mezarina-Rojas will be out of the country in November. While video testimony is scheduled for 10/25/16, the Defendant would prefer to be directly involved in the case brought against her. THE PLAINTIFF, DAVID CONFEITEIRO BY: 435293 Chelsea E. Krombel Law Offices of Paul E. Farren, Jr., P.C. 129 Whitney Avenue New Haven, CT 06510 Phone: (203) 784-0326 Fax: (203) 624-5321 Juris No.: 421215 THE DEFENDANTS, TATIANA MEZARINA-ROJAS and THE NIELSEN COMPANY (US) LLC BY:___ 408236 Alan S. Tobin, Esq. Law Offices of Meehan, Roberts, Turret & Rosenbaum 108 Leigus Road, 1st Floor Wallingford, CT 06492 Tel. # 203-294-7800 Juris # 408308