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DOCKET NO: X06-UWY-CV19-6053479-S SUPERIOR COURT
JANELLE POMPEA COMPLEX LITIGATION DOCKET
VS. AT WATERBURY
RYAN CAPOZZIELLO, ET AL. April 24, 2020
SURE
DOCKET NO: X06-UWY-CV19-6053483-S SUPERIOR COURT
JANELLE POMPEA COMPLEX LITIGATION DOCKET
VS. AT WATERBURY
LUKE CICCARELLO and April 24, 2020
GRANT CICCARELLO
eC
DOCKET NO: X06-UWY-CV19-6053485-S SUPERIOR COURT
JANELLE POMPEA COMPLEX LITIGATION DOCKET
VS. AT WATERBURY
SEASIDE WINE AND LIQUOR, LLC, ET AL April 24, 2020
ee
DOCKET NO: X06-UWY-CV19-6053486-S SUPERIOR COURT
JANELLE POMPEA COMPLEX LITIGATION DOCKET
VS. AT WATERBURY
VICTOR SAVERINO April 24, 2020
EXPERT DISCLOSURE
The Plaintiff, Janelle Pompea, hereby discloses, pursuant Practice Book § 13-4, the
following expert witness which may testify at the trial of her case:
A Name: Joseph Carfi, M.D.
B. Address of Expert: 2001 Marcus Ave., Suite N-219
Lake Success, NY 11042
1
Cc Employer: Physiatry Associates P.C.
D. Field of Expertise: Physical Medicine & Rehabilitation
Electrodiagnosis (Life Care Expert)
Subject Matter on Which the Witness is Expected to Offer Expert Testimony:
Dr. Carfi is expected to testify, or his records /records will contain information, regarding
his qualifications as a board certified physiatrist, his physical exam of Miss Pompea on February 26,
2020, the Plaintiff's history, examinations, including diagnostic studies, surgeries, diagnosis,
causation of injuries (that the incident(s) described in the Complaint(s) caused Miss Pompea’s
injuries), mechanism of injury, treatment (past and future), prognosis, medical terminology and
anatomy of the human body, hypotheticals, permanency of injuries and past and future medical
expenses. The subject matter on which he will testify, the substance of the grounds for his opinions
to which he will testify, and his opinions are set forth more particularly in his report(s), which
includes a Life Care Plan and Summary, dated April 13, 2020 and, which has/have been
contemporaneously supplied to all counsel of record in all consolidated actions.
Dr. Carfi may address opinions offered by defense experts as well.
Expert Opinions to Which the Witness is Expected to Testify:
It is anticipated that Dr. Carfi will testify that he examined the Plaintiff on February 26,
2020 and its relationship to the injuries she sustained on April 14, 2017. During the course of the
exam, Miss Pompea reported constant nerve pain throughout both arms. She further reported pain
4/10 on a consistent basis, which can be 10/10 at times. Miss Pompea reported pain with her
exercises, as well as piercing-type pain with sleep. Miss Pompea also reported tightness in the left
side of her chest, and decreased range of motion of the left shoulder. Miss Pompea further reported
various sensory, functional, and strength issues with respect to her left arm and right arm as set forth
in Dr. Carfi’s report.
It is expected, based upon Miss Pompea’s medical records, history, and physical
examination, that Dr. Carfi will testify that Miss Pompea suffered catastrophic injuries as a result of
the April 14, 2017 motor vehicle collision. He is further expected to testify that Miss Pompea has
sustained, amongst other things, severe head trauma, complete paralysis of the left arm,
significantly reduced strength in the right arm, and sensory loss in her upper limbs. He is further
expected to testify that, due to these and other injuries, that Miss Pompea has a loss of function,
requires the assistance of another person in many areas of her life, that her career opportunities will
be restricted, and that her conditions are permanent.
Dr. Carfi is expected to testify that there are various extraordinary expenses related to Miss
Pompea’s injuries which has/have been contemporaneously supplied to all counsel of record in all
consolidated actions. Said Life Care Plan, with attached Summary, includes expenses related to
Medical Care, Medical Supply & Equipment, Home Equipment Adaptations, Therapies, and
Home/Facility Care. Dr. Carfi’s Plan identifies an Annual Total Cost of $251,567.64 for Miss
Pompea between the ages of 19 to 21, and an Annual Total Cost of $173,068.44 from age 21 to the
remainder of Miss Pompea’s life.
Dr. Carfi will testify in accordance with his Narrative Report, Life Care Plan, and Summary
dated April 13, 2020, which has/have been contemporaneously supplied to all counsel of record in
all consolidated actions. Dr. Carfi may amend and/or supplement his opinions in the future as
additional information becomes available. Dr. Carfi may also provide opinions based on
hypothetical questions at the time of trial based on the evidence.
The plaintiff reserves the right to supplement, amend or modify the above anticipated
testimony upon the availability of new or additional information or to rebut any expert testimony
from defense experts.
Substance of the grounds for each expert opinion:
Dr. Carfi’s opinions are based upon his training, education, resources, experience and
qualifications as a board-certified physiatrist in the areas of physical medicine and rehabilitation,
and upon his clinical examination, review of Miss Pompea’s medical records, physical therapy
records, and the results of any radiological studies.
Dr. Carfi’s Report(s), Life Care Plan, and Summary are based upon his many years of
experience in organizing and projecting medically necessary patient needs of medical care,
medications, diagnostic testing, equipment, aids for independent function, home furnishings and
accessories, home care or facility-based care needs, orthopedic care needs, and projected physical
therapy for patients who have been seriously and catastrophically injured.
THE PLAINTIFF,
By /s/
Etan Hirsch, Esq.
Adelman Hirsch & Connors, LLP
1000 Lafayette Boulevard
Bridgeport, CT 06604
(203)331-8888 Juris: 416503
CERTIFICATE OF SERVICE
I certify that a copy of the above was or will immediately be mailed or delivered
electronically or non-electronically on the date hereof, to all attorneys and self-represented parties of
record of all consolidated actions and to all parties who have not appeared in this matter and that
written consent for electronic delivery was received from all counsel and self-represented parties
receiving electronic delivery.
Paula S. Bennett, Esq. Joseph Mascaro, Esq.
Gordon Muir and Foley LLP Morrison Mahoney LLP
1344 Silas Dean Highway, Suite 501 One Constitution Plaza
Rocky Hill, CT 06067 10" Floor
pbennett@gmflaw.com Hartford, CT 06103
jmascaro@morrisonmahoney.com
Defendant Attorney for Matthew Bull
Defendant Attorney for Thomas Bull
Robert G. Fashjian
Fashjian & Falco, P.C.
66 Huntington Street
Shelton, CT 06484
Regf.law@snet.ne
Plaintiff Attorney for Thomas Bull
James E. Butler, Esq.
Miller Rosnick D’Amico August & Butler
1087 Broad Street
Bridgeport, CT 06604
jim@millerandrosnick.com
Plaintiff Attorney for Thomas Bull
Thomas P. Cella, Esq. Roy W. Moss, Esq.
Deborah Jekot, Esq. 143 Rowayton Avenue
Howard Kohn Sprague & Fitzgerald Norwalk, CT 06853
PO Box 261798 ‘oywmoss@optimum.net
Hartford, CT 06124 Defendant Attorney for Jon Pompea &
tpc@hksflaw.com ShirleyAnn Pompea
dva@hksflaw.com
Defendant’s Attorney for Ryan Capozziello Michael O. Connelly, Esq.
Murphy Karpie Connelly & Sickinger LLC
Jonathan Perkins 350 Fairfield Ave, Ste. 408
Perkins & Associates Bridgeport, CT 06604
30 Lucy Street Attorney for ShirleyAnn Pompea
Woodbridge, CT 06525
Plaintiff’s Attorney for Ryan Capozziello
Page 1 of 3
Chrysten Dufour Paul Ganim, Esq.
Moore O’Brien & Foti 2370 Park Avenue
891 Straits Turnpike Bridgeport, CT 06604
Middlebury, CT 06762 Attorney for Ryan Gombos PPA Jeffrey
cdufour@mojylaw.com Gombos & Jeffrey Gombos
Attorney for Grant Ciccarello PPA Kim
Ciccarello
Nicholas J. Taylor, Esq.
Marshall Dennehey
287 Bowman Avenue, Suite 404
Purchase, NY 10577
njtaylor@mdweg.com
Attorney for Grant Ciccarello PPA Kim
Ciccarello & Luke Ciccarello
James Noonan, Esq.
Ryan Ryan Deluca
1000 Lafayette Blvd, Ste. 800
Bridgeport, CT 06604
jjnoonan@ryandelucalaw.com
Attorney for Grant and Luke Ciccarello
Richard A. Lord, Jr. Esq. Sergio C. Deganis, Esq.
Litchfield Cavo Ouellette Deganis Gallagher & Grippe LLC
82 Hopmeadow Street, Suite 210 143 Main Street
Simsbury, CT 06089 Cheshire, CT 06410
lord@litchfieldcavo.com info@odglaw.com
Attorney for Pompea Metals Group LLC Attorney for Seaside Liquors LLC & Robert
Pambianchi
Page 2 of 3
William Bloss, Esq. Richard A. Roberts, Esq.
Koskoff, Koskoff & Bieder Nuzzo & Roberts LLC
350 Fairfield Avenue One Town Center
Bridgeport, CT 06604 PO Box 747
bbloss@koskoff.com Cheshire, CT 06410
recep@nuzzo-roberts.com
Attorney for Seaside Wine and Liquor LLC
Maureen E. Burns, Esq. & Yesika Saverino
Mulvey Oliver Gould & Crotta
2911 Dixwell Avenue, 4"" Floor
Hamden, CT 06518
burns@moglaw.com
Adam J. Tusia, Esq.
Milano & Wanat
471 East Main Street
Branford, CT 06405
atusia@mwIlc.u:
Attorneys for Allison Loder
Joseph J. Blyskal III
Gordon & Rees, LLP
95 Glastonbury Blvd, Ste. 206
Glastonbury, CT 06033
jblyskal@grsm.com
Attorney for Guiseppe Saverino
/s/
Etan Hirsch, Esq.
Page 3 of3
Preview
DOCKET NO: X06-UWY-CV19-6053479-S SUPERIOR COURT JANELLE POMPEA COMPLEX LITIGATION DOCKET VS. AT WATERBURY RYAN CAPOZZIELLO, ET AL. April 24, 2020 SURE DOCKET NO: X06-UWY-CV19-6053483-S SUPERIOR COURT JANELLE POMPEA COMPLEX LITIGATION DOCKET VS. AT WATERBURY LUKE CICCARELLO and April 24, 2020 GRANT CICCARELLO eC DOCKET NO: X06-UWY-CV19-6053485-S SUPERIOR COURT JANELLE POMPEA COMPLEX LITIGATION DOCKET VS. AT WATERBURY SEASIDE WINE AND LIQUOR, LLC, ET AL April 24, 2020 ee DOCKET NO: X06-UWY-CV19-6053486-S SUPERIOR COURT JANELLE POMPEA COMPLEX LITIGATION DOCKET VS. AT WATERBURY VICTOR SAVERINO April 24, 2020 EXPERT DISCLOSURE The Plaintiff, Janelle Pompea, hereby discloses, pursuant Practice Book § 13-4, the following expert witness which may testify at the trial of her case: A Name: Joseph Carfi, M.D. B. Address of Expert: 2001 Marcus Ave., Suite N-219 Lake Success, NY 11042 1 Cc Employer: Physiatry Associates P.C. D. Field of Expertise: Physical Medicine & Rehabilitation Electrodiagnosis (Life Care Expert) Subject Matter on Which the Witness is Expected to Offer Expert Testimony: Dr. Carfi is expected to testify, or his records /records will contain information, regarding his qualifications as a board certified physiatrist, his physical exam of Miss Pompea on February 26, 2020, the Plaintiff's history, examinations, including diagnostic studies, surgeries, diagnosis, causation of injuries (that the incident(s) described in the Complaint(s) caused Miss Pompea’s injuries), mechanism of injury, treatment (past and future), prognosis, medical terminology and anatomy of the human body, hypotheticals, permanency of injuries and past and future medical expenses. The subject matter on which he will testify, the substance of the grounds for his opinions to which he will testify, and his opinions are set forth more particularly in his report(s), which includes a Life Care Plan and Summary, dated April 13, 2020 and, which has/have been contemporaneously supplied to all counsel of record in all consolidated actions. Dr. Carfi may address opinions offered by defense experts as well. Expert Opinions to Which the Witness is Expected to Testify: It is anticipated that Dr. Carfi will testify that he examined the Plaintiff on February 26, 2020 and its relationship to the injuries she sustained on April 14, 2017. During the course of the exam, Miss Pompea reported constant nerve pain throughout both arms. She further reported pain 4/10 on a consistent basis, which can be 10/10 at times. Miss Pompea reported pain with her exercises, as well as piercing-type pain with sleep. Miss Pompea also reported tightness in the left side of her chest, and decreased range of motion of the left shoulder. Miss Pompea further reported various sensory, functional, and strength issues with respect to her left arm and right arm as set forth in Dr. Carfi’s report. It is expected, based upon Miss Pompea’s medical records, history, and physical examination, that Dr. Carfi will testify that Miss Pompea suffered catastrophic injuries as a result of the April 14, 2017 motor vehicle collision. He is further expected to testify that Miss Pompea has sustained, amongst other things, severe head trauma, complete paralysis of the left arm, significantly reduced strength in the right arm, and sensory loss in her upper limbs. He is further expected to testify that, due to these and other injuries, that Miss Pompea has a loss of function, requires the assistance of another person in many areas of her life, that her career opportunities will be restricted, and that her conditions are permanent. Dr. Carfi is expected to testify that there are various extraordinary expenses related to Miss Pompea’s injuries which has/have been contemporaneously supplied to all counsel of record in all consolidated actions. Said Life Care Plan, with attached Summary, includes expenses related to Medical Care, Medical Supply & Equipment, Home Equipment Adaptations, Therapies, and Home/Facility Care. Dr. Carfi’s Plan identifies an Annual Total Cost of $251,567.64 for Miss Pompea between the ages of 19 to 21, and an Annual Total Cost of $173,068.44 from age 21 to the remainder of Miss Pompea’s life. Dr. Carfi will testify in accordance with his Narrative Report, Life Care Plan, and Summary dated April 13, 2020, which has/have been contemporaneously supplied to all counsel of record in all consolidated actions. Dr. Carfi may amend and/or supplement his opinions in the future as additional information becomes available. Dr. Carfi may also provide opinions based on hypothetical questions at the time of trial based on the evidence. The plaintiff reserves the right to supplement, amend or modify the above anticipated testimony upon the availability of new or additional information or to rebut any expert testimony from defense experts. Substance of the grounds for each expert opinion: Dr. Carfi’s opinions are based upon his training, education, resources, experience and qualifications as a board-certified physiatrist in the areas of physical medicine and rehabilitation, and upon his clinical examination, review of Miss Pompea’s medical records, physical therapy records, and the results of any radiological studies. Dr. Carfi’s Report(s), Life Care Plan, and Summary are based upon his many years of experience in organizing and projecting medically necessary patient needs of medical care, medications, diagnostic testing, equipment, aids for independent function, home furnishings and accessories, home care or facility-based care needs, orthopedic care needs, and projected physical therapy for patients who have been seriously and catastrophically injured. THE PLAINTIFF, By /s/ Etan Hirsch, Esq. Adelman Hirsch & Connors, LLP 1000 Lafayette Boulevard Bridgeport, CT 06604 (203)331-8888 Juris: 416503 CERTIFICATE OF SERVICE I certify that a copy of the above was or will immediately be mailed or delivered electronically or non-electronically on the date hereof, to all attorneys and self-represented parties of record of all consolidated actions and to all parties who have not appeared in this matter and that written consent for electronic delivery was received from all counsel and self-represented parties receiving electronic delivery. Paula S. Bennett, Esq. Joseph Mascaro, Esq. Gordon Muir and Foley LLP Morrison Mahoney LLP 1344 Silas Dean Highway, Suite 501 One Constitution Plaza Rocky Hill, CT 06067 10" Floor pbennett@gmflaw.com Hartford, CT 06103 jmascaro@morrisonmahoney.com Defendant Attorney for Matthew Bull Defendant Attorney for Thomas Bull Robert G. Fashjian Fashjian & Falco, P.C. 66 Huntington Street Shelton, CT 06484 Regf.law@snet.ne Plaintiff Attorney for Thomas Bull James E. Butler, Esq. Miller Rosnick D’Amico August & Butler 1087 Broad Street Bridgeport, CT 06604 jim@millerandrosnick.com Plaintiff Attorney for Thomas Bull Thomas P. Cella, Esq. Roy W. Moss, Esq. Deborah Jekot, Esq. 143 Rowayton Avenue Howard Kohn Sprague & Fitzgerald Norwalk, CT 06853 PO Box 261798 ‘oywmoss@optimum.net Hartford, CT 06124 Defendant Attorney for Jon Pompea & tpc@hksflaw.com ShirleyAnn Pompea dva@hksflaw.com Defendant’s Attorney for Ryan Capozziello Michael O. Connelly, Esq. Murphy Karpie Connelly & Sickinger LLC Jonathan Perkins 350 Fairfield Ave, Ste. 408 Perkins & Associates Bridgeport, CT 06604 30 Lucy Street Attorney for ShirleyAnn Pompea Woodbridge, CT 06525 Plaintiff’s Attorney for Ryan Capozziello Page 1 of 3 Chrysten Dufour Paul Ganim, Esq. Moore O’Brien & Foti 2370 Park Avenue 891 Straits Turnpike Bridgeport, CT 06604 Middlebury, CT 06762 Attorney for Ryan Gombos PPA Jeffrey cdufour@mojylaw.com Gombos & Jeffrey Gombos Attorney for Grant Ciccarello PPA Kim Ciccarello Nicholas J. Taylor, Esq. Marshall Dennehey 287 Bowman Avenue, Suite 404 Purchase, NY 10577 njtaylor@mdweg.com Attorney for Grant Ciccarello PPA Kim Ciccarello & Luke Ciccarello James Noonan, Esq. Ryan Ryan Deluca 1000 Lafayette Blvd, Ste. 800 Bridgeport, CT 06604 jjnoonan@ryandelucalaw.com Attorney for Grant and Luke Ciccarello Richard A. Lord, Jr. Esq. Sergio C. Deganis, Esq. Litchfield Cavo Ouellette Deganis Gallagher & Grippe LLC 82 Hopmeadow Street, Suite 210 143 Main Street Simsbury, CT 06089 Cheshire, CT 06410 lord@litchfieldcavo.com info@odglaw.com Attorney for Pompea Metals Group LLC Attorney for Seaside Liquors LLC & Robert Pambianchi Page 2 of 3 William Bloss, Esq. Richard A. Roberts, Esq. Koskoff, Koskoff & Bieder Nuzzo & Roberts LLC 350 Fairfield Avenue One Town Center Bridgeport, CT 06604 PO Box 747 bbloss@koskoff.com Cheshire, CT 06410 recep@nuzzo-roberts.com Attorney for Seaside Wine and Liquor LLC Maureen E. Burns, Esq. & Yesika Saverino Mulvey Oliver Gould & Crotta 2911 Dixwell Avenue, 4"" Floor Hamden, CT 06518 burns@moglaw.com Adam J. Tusia, Esq. Milano & Wanat 471 East Main Street Branford, CT 06405 atusia@mwIlc.u: Attorneys for Allison Loder Joseph J. Blyskal III Gordon & Rees, LLP 95 Glastonbury Blvd, Ste. 206 Glastonbury, CT 06033 jblyskal@grsm.com Attorney for Guiseppe Saverino /s/ Etan Hirsch, Esq. Page 3 of3