On June 07, 2021 a
OBJECTION RE DISCOVERY OR DISCLOSURE as to Plaintiff's Supplemental Interrogatories and Requests for Production
was filed
involving a dispute between
Cynthia Brown Conservator Of The Person And Estate Of Elizabeth Stewart,
Cynthia Brown Individually,
Edward Stewart,
and
Angela Quatrocelli Md,
Dylan Stempel Pa,
Mark Stevens Pa,
Middle Ct Emergency Physicians, Llc,
Saint Mary'S Hospital, Inc.,
Sarah Garceau Pa,
Trinity Health Of New England Corporation, Inc.,
for T28 - Torts - Malpractice - Medical
in the District Court of New Haven County.
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DOCKET NO.: UWY-CV21-6060768-S : SUPERIOR COURT
CYNTHIA BROWN, CONSERVATOR : J.D. OF WATERBURY
OF THE PERSON AND ESTATE OF
ELIZABETH STEWART,
CYNTHIA BROWN, INDIVIDUALLY,
AND EDWARD STEWART
VS. : AT WATERBURY
SAINT MARY’S HOSPITAL, INC., ET AL : DECEMBER 11 2023
DEFENDANTS’ OBJECTIONS TO
PLAINTIFFS' SUPPLEMENTAL INTERROGATORIES
AND REQUESTS FOR PRODUCTION DATED OCTOBER 12, 2023
Pursuant to Practice Book § §§ 13-8 and 13-10 Defendants, Saint Mary's Hospital
and Trinity Health of New England hereby submit the objections to Plaintiff’s
Supplemental Interrogatories and Requests for Production dated October 12, 2023.
Interrogatories
6. How many patients were seen in the emergency department on June 28, 2020,
June 30, 2020 and July 1, 2020.
OBJECTION: Defendants object to this interrogatory insofar as it seeks irrelevant and
immaterial information and is not reasonably calculated to lead to the discovery of
admissible evidence.
PRODUCTION
6. A copy of the emergency department patient census for June 28, 2020, June 30,
2020 and July 1, 2020, not including patient identifying information.
OBJECTION: Defendants object to this request insofar as it seeks irrelevant and
immaterial materials and is not reasonably calculated to lead to the discovery of
admissible evidence.
7. A copy of the patient census for Saint Mary's Hospital Urgent Care, West Main
Street, Waterbury, CT for June 27, 2020 and June 28, 2020, not including patient identifying
information.
OBJECTION: Defendants object to this request insofar as it seeks irrelevant and
immaterial materials and is not reasonably calculated to lead to the discovery of
admissible evidence.
1
DEFENDANTS,
SAINT MARY’S HOSPITAL, INC.
TRINITY HEALTH OF NEW ENGLAND
CORPORATION, INC.
BY: /s/ Gretchen G. Randall
Michael D. Neubert
Gretchen G. Randall
Janine Hodgson
NEUBERT, PEPE & MONTEITH, P.C.
195 Church Street, 13th Floor
New Haven, CT 06510
Tel. (203) 821-2000
Juris No. 407996
mneubert@npmlaw.com
grandall@npmlaw.com
jhodgson@npmlaw.com
2
CERTIFICATION
I hereby certify that the foregoing was mailed or delivered electronically on this 11th day
of December, 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 receiving
electronic delivery.
Thomas P. Cella, Esq.
Howard, Kohn, Sprague & FitzGerald, LLP
237 Buckingham Street
Hartford, CT 06126
tpc@hksflaw.com
Frederick J. Trotta, Sr., Esq.
Halloran & Sage, LLP
One Century Tower
265 Church Street, Suite 802
New Haven, CT 06510
trotta@halloransage.com
/s/ Gretchen G. Randall
Gretchen G. Randall
NEUBERT, PEPE & MONTEITH, P.C.
Document Filed Date
December 11, 2023
Case Filing Date
June 07, 2021
Category
T28 - Torts - Malpractice - Medical
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DOCKET NO.: UWY-CV21-6060768-S : SUPERIOR COURT CYNTHIA BROWN, CONSERVATOR : J.D. OF WATERBURY OF THE PERSON AND ESTATE OF ELIZABETH STEWART, CYNTHIA BROWN, INDIVIDUALLY, AND EDWARD STEWART VS. : AT WATERBURY SAINT MARY’S HOSPITAL, INC., ET AL : DECEMBER 11 2023 DEFENDANTS’ OBJECTIONS TO PLAINTIFFS' SUPPLEMENTAL INTERROGATORIES AND REQUESTS FOR PRODUCTION DATED OCTOBER 12, 2023 Pursuant to Practice Book § §§ 13-8 and 13-10 Defendants, Saint Mary's Hospital and Trinity Health of New England hereby submit the objections to Plaintiff’s Supplemental Interrogatories and Requests for Production dated October 12, 2023. Interrogatories 6. How many patients were seen in the emergency department on June 28, 2020, June 30, 2020 and July 1, 2020. OBJECTION: Defendants object to this interrogatory insofar as it seeks irrelevant and immaterial information and is not reasonably calculated to lead to the discovery of admissible evidence. PRODUCTION 6. A copy of the emergency department patient census for June 28, 2020, June 30, 2020 and July 1, 2020, not including patient identifying information. OBJECTION: Defendants object to this request insofar as it seeks irrelevant and immaterial materials and is not reasonably calculated to lead to the discovery of admissible evidence. 7. A copy of the patient census for Saint Mary's Hospital Urgent Care, West Main Street, Waterbury, CT for June 27, 2020 and June 28, 2020, not including patient identifying information. OBJECTION: Defendants object to this request insofar as it seeks irrelevant and immaterial materials and is not reasonably calculated to lead to the discovery of admissible evidence. 1 DEFENDANTS, SAINT MARY’S HOSPITAL, INC. TRINITY HEALTH OF NEW ENGLAND CORPORATION, INC. BY: /s/ Gretchen G. Randall Michael D. Neubert Gretchen G. Randall Janine Hodgson NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, CT 06510 Tel. (203) 821-2000 Juris No. 407996 mneubert@npmlaw.com grandall@npmlaw.com jhodgson@npmlaw.com 2 CERTIFICATION I hereby certify that the foregoing was mailed or delivered electronically on this 11th day of December, 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 receiving electronic delivery. Thomas P. Cella, Esq. Howard, Kohn, Sprague & FitzGerald, LLP 237 Buckingham Street Hartford, CT 06126 tpc@hksflaw.com Frederick J. Trotta, Sr., Esq. Halloran & Sage, LLP One Century Tower 265 Church Street, Suite 802 New Haven, CT 06510 trotta@halloransage.com /s/ Gretchen G. Randall Gretchen G. Randall NEUBERT, PEPE & MONTEITH, P.C.