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Hamden, Connecticut 06518
Tel. (203) 248-5678
ESTY & BUCKMIR, LLC
2285 Whitney Avenue
Juris No. 415435
Fax 203-288-9974
DOCKET NO. FBT-CV19-6084679-S : SUPERIOR COURT
DIANE SARACINO > J.D. OF FAIRFIELD
VS. : AT BRIDGEPORT
MUTUAL HOUSING ASSOCIATION OF : OCTOBER 8, 2021
SOUTHWESTERN CT, INC., ET AL
DISCLOSURE OF EXPERTS
Pursuant to Practice Book §13-4, the defendants hereby disclose the
following expert witnesses who may testify at the time of trial.
1. NAME AND ADDRESS OF EXPERT
Connecticut ENT Medical and Surgical Specialists
(Dr. Tom Coffey and Dr. Adam Pear!)
15 Corporate Drive, Trumbull, CT 06611
NATURE AND SUBJECT MATTER
Dr. Coffey and/or Dr. Pear! will testify or their records will be introduced
regarding the treatment they provided to the plaintiff from July 13, 2011 through
June 7, 2017 regarding plaintiffs symptoms, diagnosis, treatment and prognosis
for decreased balance, vertigo, lower extremity weakness and gait problems.
FINDINGS AND OPINIONS
Dr. Coffey and/or Dr. Pearl will testify or their records will be introduced
that reflect from 2011 through 2017 plaintiff treated consistently for dizziness,
spinning, being off balance, decreased balance, gait problems and lowerHamden, Connecticut 06518
Tel. (203) 248-5678
ESTY & BUCKMIR, LLC
2285 Whitney Avenue
Juris No. 415435.
Fax 203-288-9974
extremity weakness. They will testify consistent with the medical reports that
were obtained by an authorization provided by plaintiffs’ counsel and which such
records were previously produced to plaintiffs’ counsel. Those records are
incorporated by reference as if fully set forth herein. Such testimony will include
that plaintiff suffered from positional vertigo for years prior to 2017. Such
testimony will include that she was prescribed Meclizine and other medications
for her dizziness which did not help. Such testimony will include that due to
dizziness Ms. Saracino sustained multiple falls over the years resulting in
fractures, head injuries, neck injuries and other injuries. Such testimony will
include that due to her medical problems including disequilibrium, vertigo,
weakness and gait issues, plaintiff's ability to engage in activities were greatly
reduced during the timeframe of the treatment.
BASIS OF FINDINGS AND OPINIONS
Dr. Coffey and Dr. Pearl's opinions will be based on their examination and
treatment of the plaintiff as reflected in the medical records that were obtained
pursuant to an authorization produced by the plaintiff. Further, such testimony will
be based on their education, training and experience and a review of plaintiff's
medical records.ESTY & BUCKMIR, LLC
2285 Whitney Avenue
Hamden, Connecticut 06518
Tel. (203) 248-5678
Juris No. 415435
Fax 203-288-9974
2. NAME AND ADDRESS OF EXPERT
Neurological Specialists
(Dr. Barash, Dr. Butler, Dr. Beck)
99 Hawley Lane, Stratford, CT 06614
NATURE AND SUBJECT MATTER
Representatives of Neurological Specialists will testify or their records will
be introduced regarding plaintiff's treatment with Neurological Specialists from
December 29, 2011 through June 2017.
FINDINGS AND OPINIONS
Such testimony will include the symptoms, complaints, examination,
testing and treatment of Ms. Saracino for vertigo and dizziness during this
timeframe. Such testimony will include that Ms. Saracino has had a number of
falls associated with her dizziness and/or vertigo. Further, the testimony will
include that as of July 2016 she had a chronic sense of feeling off balance.
Further, because of her condition she was prescribed different medications over
this timeframe. Further, she was referred to a rehabilitation center for the new
vestibular program to address her dizziness and vertigo.
For a full and complete detailing of their expected testimony please see
the medical records that were obtained by defense counsel through an
authorization provided by plaintiff and which records were previously provided toESTY & BUCKMIR, LLC
2285 Whitney Avenue
Hamden, Connecticut 06518
Fax 203-288-9974 Juris No. 415435.
Tel. (203) 248-5678
the plaintiff. The contents of such records are incorporated by reference as if fully
set forth herein.
BASIS OF FINDINGS AND OPINIONS
The opinions of the representatives of Neurological Specialists will be
based on their examination and treatment of the plaintiff as reflected in the
medical records that were obtained pursuant to an authorization produced by the
plaintiff. Further, such testimony will be based on their education, training and
experience and a review of plaintiff's medical records.
3. NAME AND ADDRESS OF EXPERT
Dr. Michele Ranno
401 Monroe Turnpike #15, Monroe, CT 06468
NATURE AND SUBJECT MATTER
Dr. Ranno will testify and/or her records will be introduced regarding her
treatment of the plaintiff from February 24, 2017 through May 1, 2018.
FINDINGS AND OPINIONS
Dr. Ranno’s testimony will include that when she first presented for
treatment on February 24, 2017 she was unable to walk four blocks or two flights
of stairs without having any symptoms. She has difficulty walking. She had more
than 20 separate and distinct medical issues, various orthopedic issues, vertigo,ESTY & BUCKMIR, LLC
2285 Whitney Avenue
Hamden, Connecticut 06518
Fax 203-288-9974 Juris No. 415435,
Tel. (203) 248-5678
gait issues, unsteady gait, using a walker and abnormal gait, prior fractures and
numerous prior falls.
Dr. Ranno will testify and/or her records will be introduced referencing
Prior falls as well as her difficulty in ambulating prior to the subject incident. Dr.
Ranno’s testimony will include that by 2015 plaintiff stated she was “unable to
function". For a full detailing of her problems and Dr. Ranno’s testimony, please
see Dr. Ranno’s medical records which were obtained by a medical authorization
provided by plaintiff's counsel and which records were provided to the plaintiff.
BASIS OF FINDINGS AND OPINIONS
The opinions of Dr. Ranno will be based on her examination and treatment
of the plaintiff as reflected in the medical records that were obtained pursuant to
an authorization produced by the plaintiff. Further, such testimony will be based
on her education, training and experience and a review of pertinent medical
records.
4. NAME AND ADDRESS OF EXPERT
Connecticut Orthopedic Specialists
330 Orchard St, New Haven, CT 06511
NATURE AND SUBJECT MATTER
Representatives of Connecticut Orthopedic Specialists will testify
regarding plaintiff's treatment from July 17, 2014 through the present. SuchU
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Fax 203-288-9974 Juris No. 415435
Tel. (203) 248-5678
testimony will be consistent with the medical records that were obtained by
defense counsel through an authorization provided by plaintiff. All such records
were previously produced to plaintiff.
FINDINGS AND OPINIONS
Such testimony will include that from 2014 up through the date of the
subject incident on October 17, 2017 plaintiff suffered from numerous falls and
was suffering from significant problems and injuries including injuries to her
shoulders and both knees prior to the incident. Such testimony will include that
she underwent viscosupplementation in an effort to delay total knee
replacements prior to the incident. In 2015 plaintiff was seen in follow-up for total
knee replacement. She complained of bilateral knee pain and indicated that she
had previously fallen in November 2014 and fell and broke her left shoulder.
Such testimony will include the symptoms that plaintiff complained of, her
examination and treatment following the fall in November 2014. Such testimony
will include plaintiffs symptoms, complaints and limitations regarding her prior
injuries and conditions.
BASIS OF FINDINGS AND OPINIONS
The opinions of representatives of Connecticut Orthopedic Specialists will
be based on their examination and treatment of the plaintiff as reflected in the
medical records that were obtained pursuant to an authorization produced by theESTY & BUCKMIR, LLC
2285 Whitney Avenue
Hamden, Connecticut 06518
Fax 203-288-9974 Juris No. 415435
Tel. (203) 248-5678
plaintiff. Further, such testimony will be based on their education, training and
experience.
5. NAME AND ADDRESS OF EXPERT
St. Vincent’s Hospital/Bridgeport Hospital
2800 Main Street, Bridgeport, CT 06606
267 Grant Street, Bridgeport, CT 06610
NATURE AND SUBJECT MATTER
Representatives of St. Vincent's Hospital/Bridgeport Hospital will testify or
their records will be introduced regarding plaintiff's prior injuries, medical
conditions and treatment including a fall and hospitalization in April of 2016, a fall
and hospitalization in May of 2016, a hospitalization in April of 2017 during which
multiple falls were reported and a hospitalization in September of 2017.
FINDINGS AND OPINIONS
Representatives will testify or records will be introduced that reflect that
plaintiff suffered from a variety of illnesses, conditions and falls prior to October
of 2017. Such illnesses, conditions and falls include (but are not limited to) the
dates referenced above. For a full detailing, please see the actual records which
are incorporated by reference as if fully set forth herein. Such records were
obtained through an authorization provided by plaintiffs counsel and such
records were previously provided to plaintiff.Hamden, Connecticut 06518
Tel. (203) 248-5678
ESTY & BUCKMIR, LLC
2285 Whitney Avenue
Juris No. 415435
Fax 203-288-9974
BASIS OF FINDINGS AND OPINIONS
The opinions of representatives of St. Vincent's Hospital/Bridgeport
Hospital will be based on their examination and treatment of the plaintiff as
reflected in the medical records that were obtained pursuant to an authorization
produced by the plaintiff. Further, such testimony will be based on their
education, training and experience and a review of plaintiff's medical records.
THE DEFENDANTS,
/s/400462
MILES N. ESTY, ESQ.
Esty & Buckmir, LLC
2285 Whitney Avenue
Hamden, CT 06518
(203) 248-5678
Juris No.: 415435
CERTIFICATE OF SERVICE
| certify that a copy of the above was or will immediately be mailed or
delivered electronically or non-electronically on this date to all counsel and self-
represented parties of record and that written consent for electronic delivery was
received from all counsel and self-represented parties of record who were or will
immediately be electronically served:
Kennedy Johnson Schwab & Roberge, LLC
555 Long Wharf Drive
13th Floor
New Haven, CT 06511
/s/400462
Miles N. Esty, Esq.
Commissioner of the Superior Court
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Hamden, Connecticut 06518 Tel. (203) 248-5678 ESTY & BUCKMIR, LLC 2285 Whitney Avenue Juris No. 415435 Fax 203-288-9974 DOCKET NO. FBT-CV19-6084679-S : SUPERIOR COURT DIANE SARACINO > J.D. OF FAIRFIELD VS. : AT BRIDGEPORT MUTUAL HOUSING ASSOCIATION OF : OCTOBER 8, 2021 SOUTHWESTERN CT, INC., ET AL DISCLOSURE OF EXPERTS Pursuant to Practice Book §13-4, the defendants hereby disclose the following expert witnesses who may testify at the time of trial. 1. NAME AND ADDRESS OF EXPERT Connecticut ENT Medical and Surgical Specialists (Dr. Tom Coffey and Dr. Adam Pear!) 15 Corporate Drive, Trumbull, CT 06611 NATURE AND SUBJECT MATTER Dr. Coffey and/or Dr. Pear! will testify or their records will be introduced regarding the treatment they provided to the plaintiff from July 13, 2011 through June 7, 2017 regarding plaintiffs symptoms, diagnosis, treatment and prognosis for decreased balance, vertigo, lower extremity weakness and gait problems. FINDINGS AND OPINIONS Dr. Coffey and/or Dr. Pearl will testify or their records will be introduced that reflect from 2011 through 2017 plaintiff treated consistently for dizziness, spinning, being off balance, decreased balance, gait problems and lowerHamden, Connecticut 06518 Tel. (203) 248-5678 ESTY & BUCKMIR, LLC 2285 Whitney Avenue Juris No. 415435. Fax 203-288-9974 extremity weakness. They will testify consistent with the medical reports that were obtained by an authorization provided by plaintiffs’ counsel and which such records were previously produced to plaintiffs’ counsel. Those records are incorporated by reference as if fully set forth herein. Such testimony will include that plaintiff suffered from positional vertigo for years prior to 2017. Such testimony will include that she was prescribed Meclizine and other medications for her dizziness which did not help. Such testimony will include that due to dizziness Ms. Saracino sustained multiple falls over the years resulting in fractures, head injuries, neck injuries and other injuries. Such testimony will include that due to her medical problems including disequilibrium, vertigo, weakness and gait issues, plaintiff's ability to engage in activities were greatly reduced during the timeframe of the treatment. BASIS OF FINDINGS AND OPINIONS Dr. Coffey and Dr. Pearl's opinions will be based on their examination and treatment of the plaintiff as reflected in the medical records that were obtained pursuant to an authorization produced by the plaintiff. Further, such testimony will be based on their education, training and experience and a review of plaintiff's medical records.ESTY & BUCKMIR, LLC 2285 Whitney Avenue Hamden, Connecticut 06518 Tel. (203) 248-5678 Juris No. 415435 Fax 203-288-9974 2. NAME AND ADDRESS OF EXPERT Neurological Specialists (Dr. Barash, Dr. Butler, Dr. Beck) 99 Hawley Lane, Stratford, CT 06614 NATURE AND SUBJECT MATTER Representatives of Neurological Specialists will testify or their records will be introduced regarding plaintiff's treatment with Neurological Specialists from December 29, 2011 through June 2017. FINDINGS AND OPINIONS Such testimony will include the symptoms, complaints, examination, testing and treatment of Ms. Saracino for vertigo and dizziness during this timeframe. Such testimony will include that Ms. Saracino has had a number of falls associated with her dizziness and/or vertigo. Further, the testimony will include that as of July 2016 she had a chronic sense of feeling off balance. Further, because of her condition she was prescribed different medications over this timeframe. Further, she was referred to a rehabilitation center for the new vestibular program to address her dizziness and vertigo. For a full and complete detailing of their expected testimony please see the medical records that were obtained by defense counsel through an authorization provided by plaintiff and which records were previously provided toESTY & BUCKMIR, LLC 2285 Whitney Avenue Hamden, Connecticut 06518 Fax 203-288-9974 Juris No. 415435. Tel. (203) 248-5678 the plaintiff. The contents of such records are incorporated by reference as if fully set forth herein. BASIS OF FINDINGS AND OPINIONS The opinions of the representatives of Neurological Specialists will be based on their examination and treatment of the plaintiff as reflected in the medical records that were obtained pursuant to an authorization produced by the plaintiff. Further, such testimony will be based on their education, training and experience and a review of plaintiff's medical records. 3. NAME AND ADDRESS OF EXPERT Dr. Michele Ranno 401 Monroe Turnpike #15, Monroe, CT 06468 NATURE AND SUBJECT MATTER Dr. Ranno will testify and/or her records will be introduced regarding her treatment of the plaintiff from February 24, 2017 through May 1, 2018. FINDINGS AND OPINIONS Dr. Ranno’s testimony will include that when she first presented for treatment on February 24, 2017 she was unable to walk four blocks or two flights of stairs without having any symptoms. She has difficulty walking. She had more than 20 separate and distinct medical issues, various orthopedic issues, vertigo,ESTY & BUCKMIR, LLC 2285 Whitney Avenue Hamden, Connecticut 06518 Fax 203-288-9974 Juris No. 415435, Tel. (203) 248-5678 gait issues, unsteady gait, using a walker and abnormal gait, prior fractures and numerous prior falls. Dr. Ranno will testify and/or her records will be introduced referencing Prior falls as well as her difficulty in ambulating prior to the subject incident. Dr. Ranno’s testimony will include that by 2015 plaintiff stated she was “unable to function". For a full detailing of her problems and Dr. Ranno’s testimony, please see Dr. Ranno’s medical records which were obtained by a medical authorization provided by plaintiff's counsel and which records were provided to the plaintiff. BASIS OF FINDINGS AND OPINIONS The opinions of Dr. Ranno will be based on her examination and treatment of the plaintiff as reflected in the medical records that were obtained pursuant to an authorization produced by the plaintiff. Further, such testimony will be based on her education, training and experience and a review of pertinent medical records. 4. NAME AND ADDRESS OF EXPERT Connecticut Orthopedic Specialists 330 Orchard St, New Haven, CT 06511 NATURE AND SUBJECT MATTER Representatives of Connecticut Orthopedic Specialists will testify regarding plaintiff's treatment from July 17, 2014 through the present. SuchU Ae BS i oF oa nS Fax 203-288-9974 Juris No. 415435 Tel. (203) 248-5678 testimony will be consistent with the medical records that were obtained by defense counsel through an authorization provided by plaintiff. All such records were previously produced to plaintiff. FINDINGS AND OPINIONS Such testimony will include that from 2014 up through the date of the subject incident on October 17, 2017 plaintiff suffered from numerous falls and was suffering from significant problems and injuries including injuries to her shoulders and both knees prior to the incident. Such testimony will include that she underwent viscosupplementation in an effort to delay total knee replacements prior to the incident. In 2015 plaintiff was seen in follow-up for total knee replacement. She complained of bilateral knee pain and indicated that she had previously fallen in November 2014 and fell and broke her left shoulder. Such testimony will include the symptoms that plaintiff complained of, her examination and treatment following the fall in November 2014. Such testimony will include plaintiffs symptoms, complaints and limitations regarding her prior injuries and conditions. BASIS OF FINDINGS AND OPINIONS The opinions of representatives of Connecticut Orthopedic Specialists will be based on their examination and treatment of the plaintiff as reflected in the medical records that were obtained pursuant to an authorization produced by theESTY & BUCKMIR, LLC 2285 Whitney Avenue Hamden, Connecticut 06518 Fax 203-288-9974 Juris No. 415435 Tel. (203) 248-5678 plaintiff. Further, such testimony will be based on their education, training and experience. 5. NAME AND ADDRESS OF EXPERT St. Vincent’s Hospital/Bridgeport Hospital 2800 Main Street, Bridgeport, CT 06606 267 Grant Street, Bridgeport, CT 06610 NATURE AND SUBJECT MATTER Representatives of St. Vincent's Hospital/Bridgeport Hospital will testify or their records will be introduced regarding plaintiff's prior injuries, medical conditions and treatment including a fall and hospitalization in April of 2016, a fall and hospitalization in May of 2016, a hospitalization in April of 2017 during which multiple falls were reported and a hospitalization in September of 2017. FINDINGS AND OPINIONS Representatives will testify or records will be introduced that reflect that plaintiff suffered from a variety of illnesses, conditions and falls prior to October of 2017. Such illnesses, conditions and falls include (but are not limited to) the dates referenced above. For a full detailing, please see the actual records which are incorporated by reference as if fully set forth herein. Such records were obtained through an authorization provided by plaintiffs counsel and such records were previously provided to plaintiff.Hamden, Connecticut 06518 Tel. (203) 248-5678 ESTY & BUCKMIR, LLC 2285 Whitney Avenue Juris No. 415435 Fax 203-288-9974 BASIS OF FINDINGS AND OPINIONS The opinions of representatives of St. Vincent's Hospital/Bridgeport Hospital will be based on their examination and treatment of the plaintiff as reflected in the medical records that were obtained pursuant to an authorization produced by the plaintiff. Further, such testimony will be based on their education, training and experience and a review of plaintiff's medical records. THE DEFENDANTS, /s/400462 MILES N. ESTY, ESQ. Esty & Buckmir, LLC 2285 Whitney Avenue Hamden, CT 06518 (203) 248-5678 Juris No.: 415435 CERTIFICATE OF SERVICE | certify that a copy of the above was or will immediately be mailed or delivered electronically or non-electronically on this date to all counsel and self- represented parties of record and that written consent for electronic delivery was received from all counsel and self-represented parties of record who were or will immediately be electronically served: Kennedy Johnson Schwab & Roberge, LLC 555 Long Wharf Drive 13th Floor New Haven, CT 06511 /s/400462 Miles N. Esty, Esq. Commissioner of the Superior Court