On September 29, 2015 a
Party Statement
was filed
involving a dispute between
Duda, M.D., Francis J.,
and
Baystate Medical Practices, Inc.,
for Torts
in the District Court of Hampden County.
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COMMONWEALTH OF MASSACHUSETTS
Hampden, ss. Superior Court Department
Of the Trial Court
Civil Action No.: 15-679
FRANCIS J. DUDA, M.D.,
Plaintiff
AFFIDAVIT OF KELLY L. CONNORS ON
v. BEHALF OF FEDERAL INSURANCE
COMPANY
BAYSTATE MEDICAL PRACTICES, DEN_ COUNTY
INC., f/k/a BAYSTATE MEDICAL URE gs
EDUCATION AND RESEARCH
FOUNDATION, INC., . pce 42 2018
Defendant La oo
‘OLERK OF OBURTS:
I, Kelly L. Connors, depose and say:
1, I am Kelly L: Connors, Vice President, EPLI Claim Leader, for Federal Insurance
Company.
2. Federal Insurance Company (“Federal”) issued a Health Care Portfolio Policy,
policy number 6802-6523 (“Federal Policy”), to Baystate Health, Inc. Federal has determined
that the above referenced action is covered as an Employment Claim under the Executive
Liability, Entity Liability and Employment Practices Liability Coverage Section (“Coverage
Section”). The Coverage Section provides a limit of liability of $25,000,000.
3. Federal has determined that the judgment entered against Baystate Medical
Practices, Inc. in the above captioned action, including the awards of compensatory damages,
punitive damages, and attorneys’ fees, as well as pre-judgment and post-judgment interest, is
covered under the Coverage Section of the Federal Policy. To the extent any employer wage
taxes are owed as a result of the judgment in the above captioned action, those wage taxes are
not covered under the Federal Policy.4. Federal has advised Baystate Medical Practices, Inc. that the judgment in the
above captioned action, including awards of compensatory damages, punitive damages, and
attorneys’ fees; as well as pre-judgment and post-judgment interest, is covered under the
Coverage Section of the Federal Policy. To the extent any employer wage taxes are owed as a
result of the judgment in the above captioned action, those wage taxes are not covered under the
Federal Policy.
\
Signed under the penalties of perjury this 11th day of December, 2018.
elly L. Cgnnors
Vice President, EPLI Claim Leader
North American Financial Lines Claims
3038970vi
DEC 12 2018
C obs OF CBURTS
Document Filed Date
December 12, 2018
Case Filing Date
September 29, 2015
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COMMONWEALTH OF MASSACHUSETTS Hampden, ss. Superior Court Department Of the Trial Court Civil Action No.: 15-679 FRANCIS J. DUDA, M.D., Plaintiff AFFIDAVIT OF KELLY L. CONNORS ON v. BEHALF OF FEDERAL INSURANCE COMPANY BAYSTATE MEDICAL PRACTICES, DEN_ COUNTY INC., f/k/a BAYSTATE MEDICAL URE gs EDUCATION AND RESEARCH FOUNDATION, INC., . pce 42 2018 Defendant La oo ‘OLERK OF OBURTS: I, Kelly L. Connors, depose and say: 1, I am Kelly L: Connors, Vice President, EPLI Claim Leader, for Federal Insurance Company. 2. Federal Insurance Company (“Federal”) issued a Health Care Portfolio Policy, policy number 6802-6523 (“Federal Policy”), to Baystate Health, Inc. Federal has determined that the above referenced action is covered as an Employment Claim under the Executive Liability, Entity Liability and Employment Practices Liability Coverage Section (“Coverage Section”). The Coverage Section provides a limit of liability of $25,000,000. 3. Federal has determined that the judgment entered against Baystate Medical Practices, Inc. in the above captioned action, including the awards of compensatory damages, punitive damages, and attorneys’ fees, as well as pre-judgment and post-judgment interest, is covered under the Coverage Section of the Federal Policy. To the extent any employer wage taxes are owed as a result of the judgment in the above captioned action, those wage taxes are not covered under the Federal Policy.4. Federal has advised Baystate Medical Practices, Inc. that the judgment in the above captioned action, including awards of compensatory damages, punitive damages, and attorneys’ fees; as well as pre-judgment and post-judgment interest, is covered under the Coverage Section of the Federal Policy. To the extent any employer wage taxes are owed as a result of the judgment in the above captioned action, those wage taxes are not covered under the Federal Policy. \ Signed under the penalties of perjury this 11th day of December, 2018. elly L. Cgnnors Vice President, EPLI Claim Leader North American Financial Lines Claims 3038970vi DEC 12 2018 C obs OF CBURTS