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DOCKET NO. FBT CV23 6129500S : SUPERIOR COURT
PHABIO BASQUIAT : J.D. OF FAIRFIELD
V. : AT BRIDGEPORT
GARCIA BIEN AIME A/K/A AIME : JANUARY 16, 2024
GARCIA BIEN AND STATE FARM
MUTUAL AUTOMOBILE
INSURANCE COMPANY
NOTICE OF SERVICE OF STANDARD INTERROGATORIES
AND REQUEST FOR PRODUCTION
Pursuant to Practice Book §§13-6(c) and 13-9(b), the Defendant in the above action hereby
gives notice that they are directing to the Co-Defendant, STATE FARM MUTUAL
AUTOMOBILE INSURANCE COMPANY, Practice Book Interrogatories and Requests for
Production:
XXXXX Forms 201 and 204 (Directed to Co-Defendant)
To be answered under oath within sixty (60) days hereof.
PLEASE NOTE: The included authorization must be completed in full including the treating
doctor/providers full name, business address and treating office address.
THE DEFENDANT,
GARCIA BIEN AIME A/K/A AIME
GARCIA BIEN
By: /s/433656
Denise Penn
Law Offices Of Meehan, Di Palma, Roberts
& Turret
Tel. # 203-294-7800
Juris # 408308
LAW OFFICES OF MEEHAN, DI PALMA, ROBERTS & TURRET
108 LEIGUS ROAD, 1ST FLOOR, WALLINGFORD, CT 06492  (203) 294-7800  Juris No. «JurisNumber»
CERTIFICATION
This is to certify that all personal identifying information was redacted pursuant to Practice
Book Section 4-7. This will further certify the foregoing was mailed via U.S. Mail, postage pre-paid or
electronically delivered pursuant to Practice Book Section 10-14 on this 16th day of January, 2024.
Attorney for Plaintiff
Michael R. Denkovich, Esq.
Karayiannis & Denkovich, PC
P.O. Box 229
Bridgeport, CT 06601
mrd@esqmail.com
Attorney for Co-Defendant
Jonathan Warren Kelly, Esq.
Halloran & Sage, LLP.
One Goodwin Square
225 Asylum Street
Hartford , CT 06103
kelly@halloransage.com
/s/433656____________
Denise Penn
Commissioner of the Superior Court
LAW OFFICES OF MEEHAN, DI PALMA, ROBERTS & TURRET
108 LEIGUS ROAD, 1ST FLOOR, WALLINGFORD, CT 06492  (203) 294-7800  Juris No. «JurisNumber»
DEFENDANT’S CERTIFICATION
I, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, hereby
certify that I have reviewed the above Interrogatories and Requests for Production and responses
thereto and that they are true and accurate to the best of my knowledge and belief.
State Farm Mutual Automobile
Insurance Company
Subscribed and sworn to before me this , day of , 2024.
Commissioner of the Superior Court/
Notary Public
LAW OFFICES OF MEEHAN, DI PALMA, ROBERTS & TURRET
108 LEIGUS ROAD, 1ST FLOOR, WALLINGFORD, CT 06492  (203) 294-7800  Juris No. «JurisNumber»
AUTHORIZATION FOR THE RELEASE AND
TRANSFER OF EMPLOYMENT INFORMATION
TO:
I, the undersigned, hereby consent and authorize you to disclose and release to agents,
servants, and employees of the Law Offices Of Meehan, Di Palma, Roberts & Turret, 108 Leigus
Road, 1st Floor, Wallingford, CT 06492(including any physician(s), nurse(s), and expert witness(es)
retained or consulted by the Law Offices Of Meehan, Di Palma, Roberts & Turret, and the liability
insurer of the Law Offices Of Meehan, Di Palma, Roberts & Turret client in connection with my
claim), and any arbitrator(s), appointed to hear my claim, the following confidential information, to
order, inspect, copy and/or reproduce any and all records arising from my hire/enlistment with you,
including but not limited to wage information, pre-employment/pre-enlistment physicals, physicals
thereafter, attendance, personnel, clinic and/or hospital records.
I authorize the transfer of said information by and between the aforesaid persons.
I am informed that the above information requested is needed and is to be used for pursuing
the disposition of my claim arising out of an alleged accident on _________. This consent for the
release and transfer of said information may be withdrawn at any future time and is subject to
revocation by me when transmitted in writing, except when signed in connection with a claim for
benefits under any insurance policy in which case it shall be valid during the pendency of that claim.
I agree that a photocopy of this Authorization be accepted with the same authority as the
original.
Signed: Date:
SS#: Date of Birth:
LAW OFFICES OF MEEHAN, DI PALMA, ROBERTS & TURRET
108 LEIGUS ROAD, 1ST FLOOR, WALLINGFORD, CT 06492  (203) 294-7800  Juris No. «JurisNumber»
AUTHORIZATION FOR THE RELEASE OF PROTECTED HEALTH INFORMATION
I, hereby voluntarily consent and authorize you, in accordance with 45 C.F.R. Sec. 164.508, to use or disclose health information including, if
applicable, information relating to the diagnosis or treatment of mental illness, drug and/or alcohol abuse and confidential HIV/AIDS related
information, only for the purposes and parties described below. This authorization permits you to disclose all medical, psychiatric, drug and/or
alcohol abuse, HIV information, records, x-rays, films, bills, reports, or copies thereof relating to my examination, consultation, confinement, or
treatment by you. This release also authorizes the disclosure of any and all payment records, billing records and insurance related information.
Purpose for Disclosure:
Civil Litigation: Personal Injury Lawsuit
Workers’ Compensation Claim
Name of Health Care Provider to make Disclosure: Records to be disclosed to:
_____________________________________ Law Offices Of Meehan, Di Palma, Roberts
& Turret
_____________________________________
Wallingford, CT 06492
_____________________________________
Liberty Mutual Group, and its affiliates
175 Berkeley Street
Boston, MA 02116
ABI Document Support Services
1122 Franklin Avenue, Suite 300
Garden City, NY 11530
Description of Records to be Disclosed: My full and complete medical file and billing records including but not limited to: office notes,
doctor’s notes, nurse’s notes, billing records, treatment plans, laboratory results, diagnostic test results, records of other physicians in your chart,
radiological results, history, physical exam, discharge summaries, operative records, consultations, same day surgery records, emergency room records,
ambulatory care records, rehabilitation records, therapeutic records, psychiatric records, psychological records, counseling records, pathology records,
cytology records, cardiology records, neurology records, orthopedic records, physiology records, hematology records, oncology records, chiropractic
records, CT scan reports and films, MRI reports and films, X-ray reports and films, imaging reports and films, ultrasound records, immunization
records, medication records, etc.
Patient Name and Address: Patient Date of Birth:
_______________________________ _____________________
_______________________________ Dates of Treatment:
_______________________________ _____________________
This Authorization shall remain in Effect for one year from date below.
I understand that I may cancel this authorization at any time by notifying you in writing, but if I do it will not have any affect on actions that the
provider took before it received the cancellation. Furthermore, the information disclosed under this authorization may be subject to further disclosure
by the recipient and thus, no longer protected by state or federal privacy regulations.
I understand that my treatment or continued treatment by you is in no way conditioned on whether or not I sign this authorization and that I may
refuse to sign it.
I am entitled to a copy of this authorization, and acknowledge receipt of a copy. I understand that I may inspect or copy the information disclosed
under federal regulations.
The patient’s parent or legal guardian must sign this authorization if the patient is a minor (under age 18) or has a legal guardian. Minors may sign their
own authorizations for records relating to drug/alcohol abuse treatment, sexually transmitted diseases or HIV/AIDS related diagnosis, and in certain
circumstances, Mental Health treatment records.
I understand that you may receive compensation as set by law for copying and processing fees related to the use/disclosure of my health information
under this authorization.
I agree that a photocopy of this Authorization has the same authority as the original.
________________________________________________________________ ____________________________
Signature of Patient or Authorized Representative Date
If patient has not signed this form, please indicate the relationship of the signatory to the patient.
Parent/Guardian Administrator/Executor of Estate Power of Attorney/Conservator Other-specify
LAW OFFICES OF MEEHAN, DI PALMA, ROBERTS & TURRET
108 LEIGUS ROAD, 1ST FLOOR, WALLINGFORD, CT 06492  (203) 294-7800  Juris No. «JurisNumber»
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DOCKET NO. FBT CV23 6129500S : SUPERIOR COURT PHABIO BASQUIAT : J.D. OF FAIRFIELD V. : AT BRIDGEPORT GARCIA BIEN AIME A/K/A AIME : JANUARY 16, 2024 GARCIA BIEN AND STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY NOTICE OF SERVICE OF STANDARD INTERROGATORIES AND REQUEST FOR PRODUCTION Pursuant to Practice Book §§13-6(c) and 13-9(b), the Defendant in the above action hereby gives notice that they are directing to the Co-Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Practice Book Interrogatories and Requests for Production: XXXXX Forms 201 and 204 (Directed to Co-Defendant) To be answered under oath within sixty (60) days hereof. PLEASE NOTE: The included authorization must be completed in full including the treating doctor/providers full name, business address and treating office address. THE DEFENDANT, GARCIA BIEN AIME A/K/A AIME GARCIA BIEN By: /s/433656 Denise Penn Law Offices Of Meehan, Di Palma, Roberts & Turret Tel. # 203-294-7800 Juris # 408308 LAW OFFICES OF MEEHAN, DI PALMA, ROBERTS & TURRET 108 LEIGUS ROAD, 1ST FLOOR, WALLINGFORD, CT 06492  (203) 294-7800  Juris No. «JurisNumber» CERTIFICATION This is to certify that all personal identifying information was redacted pursuant to Practice Book Section 4-7. This will further certify the foregoing was mailed via U.S. Mail, postage pre-paid or electronically delivered pursuant to Practice Book Section 10-14 on this 16th day of January, 2024. Attorney for Plaintiff Michael R. Denkovich, Esq. Karayiannis & Denkovich, PC P.O. Box 229 Bridgeport, CT 06601 mrd@esqmail.com Attorney for Co-Defendant Jonathan Warren Kelly, Esq. Halloran & Sage, LLP. One Goodwin Square 225 Asylum Street Hartford , CT 06103 kelly@halloransage.com /s/433656____________ Denise Penn Commissioner of the Superior Court LAW OFFICES OF MEEHAN, DI PALMA, ROBERTS & TURRET 108 LEIGUS ROAD, 1ST FLOOR, WALLINGFORD, CT 06492  (203) 294-7800  Juris No. «JurisNumber» DEFENDANT’S CERTIFICATION I, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, hereby certify that I have reviewed the above Interrogatories and Requests for Production and responses thereto and that they are true and accurate to the best of my knowledge and belief. State Farm Mutual Automobile Insurance Company Subscribed and sworn to before me this , day of , 2024. Commissioner of the Superior Court/ Notary Public LAW OFFICES OF MEEHAN, DI PALMA, ROBERTS & TURRET 108 LEIGUS ROAD, 1ST FLOOR, WALLINGFORD, CT 06492  (203) 294-7800  Juris No. «JurisNumber» AUTHORIZATION FOR THE RELEASE AND TRANSFER OF EMPLOYMENT INFORMATION TO: I, the undersigned, hereby consent and authorize you to disclose and release to agents, servants, and employees of the Law Offices Of Meehan, Di Palma, Roberts & Turret, 108 Leigus Road, 1st Floor, Wallingford, CT 06492(including any physician(s), nurse(s), and expert witness(es) retained or consulted by the Law Offices Of Meehan, Di Palma, Roberts & Turret, and the liability insurer of the Law Offices Of Meehan, Di Palma, Roberts & Turret client in connection with my claim), and any arbitrator(s), appointed to hear my claim, the following confidential information, to order, inspect, copy and/or reproduce any and all records arising from my hire/enlistment with you, including but not limited to wage information, pre-employment/pre-enlistment physicals, physicals thereafter, attendance, personnel, clinic and/or hospital records. I authorize the transfer of said information by and between the aforesaid persons. I am informed that the above information requested is needed and is to be used for pursuing the disposition of my claim arising out of an alleged accident on _________. This consent for the release and transfer of said information may be withdrawn at any future time and is subject to revocation by me when transmitted in writing, except when signed in connection with a claim for benefits under any insurance policy in which case it shall be valid during the pendency of that claim. I agree that a photocopy of this Authorization be accepted with the same authority as the original. Signed: Date: SS#: Date of Birth: LAW OFFICES OF MEEHAN, DI PALMA, ROBERTS & TURRET 108 LEIGUS ROAD, 1ST FLOOR, WALLINGFORD, CT 06492  (203) 294-7800  Juris No. «JurisNumber» AUTHORIZATION FOR THE RELEASE OF PROTECTED HEALTH INFORMATION I, hereby voluntarily consent and authorize you, in accordance with 45 C.F.R. Sec. 164.508, to use or disclose health information including, if applicable, information relating to the diagnosis or treatment of mental illness, drug and/or alcohol abuse and confidential HIV/AIDS related information, only for the purposes and parties described below. This authorization permits you to disclose all medical, psychiatric, drug and/or alcohol abuse, HIV information, records, x-rays, films, bills, reports, or copies thereof relating to my examination, consultation, confinement, or treatment by you. This release also authorizes the disclosure of any and all payment records, billing records and insurance related information. Purpose for Disclosure: Civil Litigation: Personal Injury Lawsuit Workers’ Compensation Claim Name of Health Care Provider to make Disclosure: Records to be disclosed to: _____________________________________ Law Offices Of Meehan, Di Palma, Roberts & Turret _____________________________________ Wallingford, CT 06492 _____________________________________ Liberty Mutual Group, and its affiliates 175 Berkeley Street Boston, MA 02116 ABI Document Support Services 1122 Franklin Avenue, Suite 300 Garden City, NY 11530 Description of Records to be Disclosed: My full and complete medical file and billing records including but not limited to: office notes, doctor’s notes, nurse’s notes, billing records, treatment plans, laboratory results, diagnostic test results, records of other physicians in your chart, radiological results, history, physical exam, discharge summaries, operative records, consultations, same day surgery records, emergency room records, ambulatory care records, rehabilitation records, therapeutic records, psychiatric records, psychological records, counseling records, pathology records, cytology records, cardiology records, neurology records, orthopedic records, physiology records, hematology records, oncology records, chiropractic records, CT scan reports and films, MRI reports and films, X-ray reports and films, imaging reports and films, ultrasound records, immunization records, medication records, etc. Patient Name and Address: Patient Date of Birth: _______________________________ _____________________ _______________________________ Dates of Treatment: _______________________________ _____________________ This Authorization shall remain in Effect for one year from date below. I understand that I may cancel this authorization at any time by notifying you in writing, but if I do it will not have any affect on actions that the provider took before it received the cancellation. Furthermore, the information disclosed under this authorization may be subject to further disclosure by the recipient and thus, no longer protected by state or federal privacy regulations. I understand that my treatment or continued treatment by you is in no way conditioned on whether or not I sign this authorization and that I may refuse to sign it. I am entitled to a copy of this authorization, and acknowledge receipt of a copy. I understand that I may inspect or copy the information disclosed under federal regulations. The patient’s parent or legal guardian must sign this authorization if the patient is a minor (under age 18) or has a legal guardian. Minors may sign their own authorizations for records relating to drug/alcohol abuse treatment, sexually transmitted diseases or HIV/AIDS related diagnosis, and in certain circumstances, Mental Health treatment records. I understand that you may receive compensation as set by law for copying and processing fees related to the use/disclosure of my health information under this authorization. I agree that a photocopy of this Authorization has the same authority as the original. ________________________________________________________________ ____________________________ Signature of Patient or Authorized Representative Date If patient has not signed this form, please indicate the relationship of the signatory to the patient. Parent/Guardian Administrator/Executor of Estate Power of Attorney/Conservator Other-specify LAW OFFICES OF MEEHAN, DI PALMA, ROBERTS & TURRET 108 LEIGUS ROAD, 1ST FLOOR, WALLINGFORD, CT 06492  (203) 294-7800  Juris No. «JurisNumber»