Document for LAURIDSEN, PETER v. TUROVETS D.C., ARTHUR Et Al

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                                DOCKET #: FST-CV-21-6050815 S                             :   SUPERIOR COURT

PETER LAURIDSEN                                           :   J.D. OF STAMFORD/NORWALK

v                                                         :   AT STAMFORD

ARTHUR TUROVETS, D.C., ET AL.                             :   NOVEMBER 27, 2023

    PLAINTIFF'S DISCLOSURE OF DOCUMENTS/RECORDS EXPECTED TO BE
                       SUBMITTED INTO EVIDENCE

       Pursuant to Connecticut Practice Book Section 13-4(d) (1), the Plaintiff Peter

Lauridsen, hereby discloses a list of all documents or records that the plaintiff expects to

submit into evidence pursuant to Connecticut General Statute or Connecticut Rules of Practice

permitting the admissibility of the documentary evidence in lieu of the live testimony of an

expert witness.

    1. Records of Arthur Turovets, MD for treatment on 04/29/2019, 05/22/2019 &
       06/05/2019 plus one-time flat-fee bill;
    2. Records and bills of John Shajan, MD & Frank Walsh, MD of Greenwich Primary
       Care for treatment from 06/24/2019 thru 07/10/2019;
    3. Records and bills of Greenwich Hospital for treatment from 06/24/2019 thru
       10/05/2023;
    4. Records and bills of Yale New Haven Hospital for treatment from 09/04/2019 thru
       02/17/2023;
    5. Records and bills of Yale Medicine Providers for treatment from 07/19/2019 thru
       08/17/2023;
    6. Records and bills of Connecticut GI for treatment from 06/25/2019 thru 07/01/2019
       (06/25/2019, 06/26/2019 & 06/27/2019 records can be found in Greenwich Hospital
       records);
    7. Bills for treatment with Northeast Medical Group providers on 09/04/2019 &
       10/29/2019 (records can be found in hospital records);
    8. Records from Quest for treatment from 07/25/2019 thru 12/09/2019 (bills are
       pending);




                              MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
           891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519

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   9. Pharmacy billing records from Yale Outpatient Pharmacy Service(s) for
       12/10/2019 thru 08/16/2023; and
   10. Record and bill from RVNA – Home Health for 09/21/2019;
   11. Prior Labs – Taken for Insurance Physical 10/06/2016;
   12. Summary of Medicals;
   13. CMS letter dated 11/16/2023.


       The plaintiff reserves the right pursuant to Practice Book section 13-4, to amend this

disclosure should the plaintiff seek additional treatment, new information be discovered or

disclosed, or for good cause shown.

                                              THE PLAINTIFF,



                                              By     /s/ 303657
                                              Joseph D. Foti, Esq.
                                              MOORE, O'BRIEN & FOTI
                                              891 Straits Turnpike
                                              Middlebury, CT 06762
                                              (203) 272-5881
                                              Juris No. 408519
                                              His Attorneys




                             MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
          891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519

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                                        CERTIFICATION

        I certify that a copy of this document was or will immediately be mailed or delivered
electronically or non-electronically on November 27, 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.

Megan Bryson, Esq.
Kaufman Borgeest & Ryan LLP
1010 Washington Boulevard
Stamford, CT 06901
Via Email To mbryson@kbrlaw.com
Via Email To skruczkiewicz@kbrlaw.com


                                                  /s/ 303657
                                               Joseph D. Foti, 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

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