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DOCKET #: UWY-CV-23-6068559S : SUPERIOR COURT
BARBARA EASTWOOD : J.D. OF WATERBURY
v : AT WATERBURY
TYRONE PETERS : March 16, 2023
PLAINTIFF'S DISCLOSURE OF EXPERT WITNESSES
The Plaintiff, Barbara Eastwood, hereby gives notice of the disclosure of expert witnesses
who may testify at trial.
Names, Addresses and Employers
American Medical Response Personnel
8 City Blvd, Suite 400
Nashville, TN 37209
St. Mary’s Hospital Personnel
56 Franklin Street
Waterbury, CT 06706
Pond Place Medical Center
Sudha Thiruvengadam MD
166 Waterbury Rd, Suite 300
Prospect, CT 06712
Active Orthopaedics
Erik Carlson MD
1579 Straits Turnpike
Middlebury, CT 06762
Waterbury Neurology
Xiao Weng MD
1625 Straits Turnpike, Suite 307
Middlebury, CT 06762
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
1
Access Rehab Physical Therapy Personnel
134 Grandview Ave
Waterbury, CT 06706
Investigating Charles Bliss
Badge # 861
Waterbury Police Department
In addition, the Plaintiff reserves the right to and may elicit opinions upon cross-
examination of any expert witnesses called by the Defendant at trial.
Subject Matter
The general subject matter upon which the medical experts will testify includes the medical
condition of the Plaintiff; examinations, findings and diagnosis; the nature and extent of the
plaintiff’s injuries; the causation of those injuries; treatment; recommendations; the Plaintiff's
prognosis; future treatment and the cost of same; and any permanency.
Substance of the Facts and Opinions
American Medical Response Ambulance Personnel
Evidence is expected to relate to plaintiff’s physical condition when presented for treatment.
Evidence or testimony will include the nature of plaintiff’s injuries and the treatment given,
including the nature and results of objective and diagnostic tests conducted. The personnel will
testify substantially in accordance with the medical records/reports that have been supplied to the
defense through discovery.
St. Mary’s Hospital Personnel
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
2
Evidence is expected to relate to plaintiff’s physical condition when presented in the hospital on
August 25, 2022. Evidence or testimony will include the nature of plaintiff’s injuries and the
treatment given, including the nature and results of objective and diagnostic tests conducted. The
personnel will testify substantially in accordance with the medical records/reports that have been
supplied to the defense through discovery.
Sudha Thiruvengadam MD
Dr. Sudha Thiruvengadam will testify regarding the examination and treatment of Plaintiff. It is
expected that Dr. Sudha Thiruvengadam will testify in accordance with the treatment notes and
evaluation and consultation reports that have been provided through discovery. Evidence or
testimony will include the nature and extent of the plaintiff's injuries, causation, prognosis and
permanency. Dr. Sudha Thiruvengadam will testify that the injuries the Plaintiff suffered were
directly related to the accident of August 25, 2022 and are permanent. These injuries include: left
shoulder pain, right knee pain and headaches. Dr. Sudha Thiruvengadam is expected to testify that
the treatment of the plaintiff for injuries sustained in the August 25, 2022 accident, as more fully
described in the medical reports and records, was both reasonable and necessary. Dr. Sudha
Thiruvengadam is expected to testify regarding the future treatment and cost of treatment, the
plaintiff may have to undergo as a result of the August 25, 2022 accident.
Erik Carlson MD
Dr. Erik Carlson will testify regarding the examination and treatment of Plaintiff. It is expected
that Dr. Erik Carlson will testify in accordance with the treatment notes and evaluation and
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
3
consultation reports that have been provided through discovery. Evidence or testimony will include
the nature and extent of the plaintiff's injuries, causation, prognosis and permanency. Dr. Erik
Carlson will testify that the injuries the Plaintiff suffered were directly related to the accident of
August 25, 2022 and are permanent. These injuries include: left shoulder pain. Dr. Erik Carlson
is expected to testify that the treatment of the plaintiff for injuries sustained in the August 25, 2022
accident, as more fully described in the medical reports and records, was both reasonable and
necessary. Dr. Erik Carlson is expected to testify regarding the future treatment and cost of
treatment, the plaintiff may have to undergo as a result of the August 25, 2022 accident.
Xiao Weng MD
Dr. Xiao Weng will testify regarding the examination and treatment of Plaintiff. It is expected
that Dr. Xiao Weng will testify in accordance with the treatment notes and evaluation and
consultation reports that have been provided through discovery. Evidence or testimony will include
the nature and extent of the plaintiff's injuries, causation, prognosis and permanency. Dr. Xiao
Weng will testify that the injuries the Plaintiff suffered were directly related to the accident of
August 25, 2022 and are permanent. These injuries include: headaches, TBI and concussion. Dr.
Xiao Weng is expected to testify that the treatment of the plaintiff for injuries sustained in the
August 25, 2022 accident, as more fully described in the medical reports and records, was both
reasonable and necessary. Dr. Xiao Weng is expected to testify regarding the future treatment and
cost of treatment, the plaintiff may have to undergo as a result of the August 25, 2022 accident.
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
4
Access Rehab Physical Therapy Personnel
Evidence is expected to relate to the nature and extent of plaintiff’s injuries and the course of
treatment rendered in physical therapy. The personnel are expected to testify that their treatment
of the plaintiff for injuries sustained in the August 25, 2022 accident, was both reasonable and
necessary. The personnel will testify substantially in accordance with the medical records/reports
that have been supplied to the defense through discovery.
Investigating Charles Bliss
The investigating officer will testify regarding the scene of the accident and evidence found there
as well as the investigation of the accident. The details of the facts and opinions to which this
officer will testify are contained in the police report for the incident.
Summary of the Grounds for Each Opinion
The medical witnesses' opinions will be based upon examination and treatment of the
plaintiff; interviews with the plaintiff; and review of medical records and reports and diagnostic
test results; and upon their knowledge, education, experience and training.
THE PLAINTIFF,
By /s/ 433509
Garrett M. Moore Jr., Esq.
MOORE, O'BRIEN & FOTI
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
5
CERTIFICATION
I certify that a copy of this document was or will immediately be mailed or delivered
electronically or non-electronically on March 16, 2023, to all attorneys and self-represented parties
of record and that written consent for electronic delivery was received from all attorneys and self-
represented parties of record who received or will immediately be receiving electronic delivery.
Kelly Byron, Esq.,
Hanks Olsen & Sheehan
538 Preston Avenue, Suite 305
Meriden, CT 06450
connecticutHC@progressive.com
/s/ 433509
Garrett M. Moore Jr., Esq.
Commissioner of the Superior Court
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
6
Preview
DOCKET #: UWY-CV-23-6068559S : SUPERIOR COURT BARBARA EASTWOOD : J.D. OF WATERBURY v : AT WATERBURY TYRONE PETERS : March 16, 2023 PLAINTIFF'S DISCLOSURE OF EXPERT WITNESSES The Plaintiff, Barbara Eastwood, hereby gives notice of the disclosure of expert witnesses who may testify at trial. Names, Addresses and Employers American Medical Response Personnel 8 City Blvd, Suite 400 Nashville, TN 37209 St. Mary’s Hospital Personnel 56 Franklin Street Waterbury, CT 06706 Pond Place Medical Center Sudha Thiruvengadam MD 166 Waterbury Rd, Suite 300 Prospect, CT 06712 Active Orthopaedics Erik Carlson MD 1579 Straits Turnpike Middlebury, CT 06762 Waterbury Neurology Xiao Weng MD 1625 Straits Turnpike, Suite 307 Middlebury, CT 06762 MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 1 Access Rehab Physical Therapy Personnel 134 Grandview Ave Waterbury, CT 06706 Investigating Charles Bliss Badge # 861 Waterbury Police Department In addition, the Plaintiff reserves the right to and may elicit opinions upon cross- examination of any expert witnesses called by the Defendant at trial. Subject Matter The general subject matter upon which the medical experts will testify includes the medical condition of the Plaintiff; examinations, findings and diagnosis; the nature and extent of the plaintiff’s injuries; the causation of those injuries; treatment; recommendations; the Plaintiff's prognosis; future treatment and the cost of same; and any permanency. Substance of the Facts and Opinions American Medical Response Ambulance Personnel Evidence is expected to relate to plaintiff’s physical condition when presented for treatment. Evidence or testimony will include the nature of plaintiff’s injuries and the treatment given, including the nature and results of objective and diagnostic tests conducted. The personnel will testify substantially in accordance with the medical records/reports that have been supplied to the defense through discovery. St. Mary’s Hospital Personnel MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 2 Evidence is expected to relate to plaintiff’s physical condition when presented in the hospital on August 25, 2022. Evidence or testimony will include the nature of plaintiff’s injuries and the treatment given, including the nature and results of objective and diagnostic tests conducted. The personnel will testify substantially in accordance with the medical records/reports that have been supplied to the defense through discovery. Sudha Thiruvengadam MD Dr. Sudha Thiruvengadam will testify regarding the examination and treatment of Plaintiff. It is expected that Dr. Sudha Thiruvengadam will testify in accordance with the treatment notes and evaluation and consultation reports that have been provided through discovery. Evidence or testimony will include the nature and extent of the plaintiff's injuries, causation, prognosis and permanency. Dr. Sudha Thiruvengadam will testify that the injuries the Plaintiff suffered were directly related to the accident of August 25, 2022 and are permanent. These injuries include: left shoulder pain, right knee pain and headaches. Dr. Sudha Thiruvengadam is expected to testify that the treatment of the plaintiff for injuries sustained in the August 25, 2022 accident, as more fully described in the medical reports and records, was both reasonable and necessary. Dr. Sudha Thiruvengadam is expected to testify regarding the future treatment and cost of treatment, the plaintiff may have to undergo as a result of the August 25, 2022 accident. Erik Carlson MD Dr. Erik Carlson will testify regarding the examination and treatment of Plaintiff. It is expected that Dr. Erik Carlson will testify in accordance with the treatment notes and evaluation and MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 3 consultation reports that have been provided through discovery. Evidence or testimony will include the nature and extent of the plaintiff's injuries, causation, prognosis and permanency. Dr. Erik Carlson will testify that the injuries the Plaintiff suffered were directly related to the accident of August 25, 2022 and are permanent. These injuries include: left shoulder pain. Dr. Erik Carlson is expected to testify that the treatment of the plaintiff for injuries sustained in the August 25, 2022 accident, as more fully described in the medical reports and records, was both reasonable and necessary. Dr. Erik Carlson is expected to testify regarding the future treatment and cost of treatment, the plaintiff may have to undergo as a result of the August 25, 2022 accident. Xiao Weng MD Dr. Xiao Weng will testify regarding the examination and treatment of Plaintiff. It is expected that Dr. Xiao Weng will testify in accordance with the treatment notes and evaluation and consultation reports that have been provided through discovery. Evidence or testimony will include the nature and extent of the plaintiff's injuries, causation, prognosis and permanency. Dr. Xiao Weng will testify that the injuries the Plaintiff suffered were directly related to the accident of August 25, 2022 and are permanent. These injuries include: headaches, TBI and concussion. Dr. Xiao Weng is expected to testify that the treatment of the plaintiff for injuries sustained in the August 25, 2022 accident, as more fully described in the medical reports and records, was both reasonable and necessary. Dr. Xiao Weng is expected to testify regarding the future treatment and cost of treatment, the plaintiff may have to undergo as a result of the August 25, 2022 accident. MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 4 Access Rehab Physical Therapy Personnel Evidence is expected to relate to the nature and extent of plaintiff’s injuries and the course of treatment rendered in physical therapy. The personnel are expected to testify that their treatment of the plaintiff for injuries sustained in the August 25, 2022 accident, was both reasonable and necessary. The personnel will testify substantially in accordance with the medical records/reports that have been supplied to the defense through discovery. Investigating Charles Bliss The investigating officer will testify regarding the scene of the accident and evidence found there as well as the investigation of the accident. The details of the facts and opinions to which this officer will testify are contained in the police report for the incident. Summary of the Grounds for Each Opinion The medical witnesses' opinions will be based upon examination and treatment of the plaintiff; interviews with the plaintiff; and review of medical records and reports and diagnostic test results; and upon their knowledge, education, experience and training. THE PLAINTIFF, By /s/ 433509 Garrett M. Moore Jr., Esq. MOORE, O'BRIEN & FOTI MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 5 CERTIFICATION I certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on March 16, 2023, to all attorneys and self-represented parties of record and that written consent for electronic delivery was received from all attorneys and self- represented parties of record who received or will immediately be receiving electronic delivery. Kelly Byron, Esq., Hanks Olsen & Sheehan 538 Preston Avenue, Suite 305 Meriden, CT 06450 connecticutHC@progressive.com /s/ 433509 Garrett M. Moore Jr., Esq. Commissioner of the Superior Court MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 6