On June 05, 2014 a
Order
was filed
involving a dispute between
David Confeiteiro,
and
Gelco Corporation,
Tatiana Mezarina-Rojas,
The Nielsen Company,
for V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
in the District Court of Fairfield County.
Preview
DOCKET NO. FBT-CV14-6043491-S : SUPERIOR COURT
DAVID CONFEITEIRO : J.D. OF FAIRFIELD
V : AT BRIDGEPORT
TATIANA MEZARINA-ROJAS ET AL : APRIL 28, 2015
MOTION TO COMPEL FULL DISCLOSURE
The undersigned Defendants move the Court for an order compelling the Plaintiff to fully
comply with the Defendant’s Interrogatories and Requests for Production dated 7/3/14.
Specifically, defendants seek full responses on following issues via full disclosure or providing fully
executed authorizations::
1. any and all employment records and tax returns for the 3 years prior to the subject
accident to the present,
2. any and all prior records relating to neck or back complaints. While Plaintiff denied
any prior similar conditions in his interrogatory responses, a review of his records
makes clear he had neck pain at least sometime in 2011 and underwent a cervical
MRI on 7/5/11. Additionally, Dr. Lipow’s note of 3/12/13 references neck pains in
2001 that resolved with Neurontin; whether this is actually 2001 or simply a typo
referring to 2011,
3. pre- and post-accident records relating to treatment for anxiety and depression
(particularly where he is also claiming post-traumatic stress from the subject accident
as well.)
4. Any and all records from Dr. Patricia Richards; these were claimed in his
interrogatories but none were provided
5. Any and all records from Dr. Menta/Menta Chiropractic; these were claimed in his
interrogatories but none were provided
LAW OFFICES OF MEEHAN, TURRET & ROSENBAUM
101 BARNES ROAD, 3RD FLOOR, WALLINGFORD, CT 06492 (203) 294-7800 JURIS NO. 408308
6. Treatment record from St. Vincent’s Hospital 7/20/14; these were claimed in his
interrogatories but none were provided
7. records from the diskogram performed antecedent to Plaintiff’s surgery; unclear from
records where this was performed but no records were provided
8. ANY AND ALL radiodiagnostic films of Plaintiff’s cervical and lumbar spine,
including but not limited to CT Scan of cervical spine 6/5/12; MRI’s of cervical spine
7/5/11, 11/14/12, 12/5/12, 7/8/13; as well as any and all electrodiagnostic studies
relating to Plaintiff’s neck and/or upper extremity radiculopathy.
9. -disability application 4/29/14, and supporting documentation regarding his lost wage
claim.
WHEREFORE, the Defendant requests this Court to rule the following relief:
1. Enter an order requiring the Plaintiff to adequately respond to said requests;
2. Enter Nonsuit against the Plaintiff for failure to comply or to adequately respond;
3. Award the Defendant the costs of pursuing this motion, including reasonable Attorney’s
fees; and
4. Order any and all further relief that the court may deem necessary.
LAW OFFICES OF MEEHAN, TURRET & ROSENBAUM
101 BARNES ROAD, 3RD FLOOR, WALLINGFORD, CT 06492 (203) 294-7800 JURIS NO. 408308
THE DEFENDANTS,
BY ______408236__
Alan S. Tobin
Law Offices of Meehan, Turret &
Rosenbaum
101 Barnes Road, 3rd Floor
Wallingford, CT 06492
Tel. # 203-294-7800
Juris # 408308
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 28th day of
April, 2015.
Attorney forPltf
Joseph S. Dobrowolski, Esq.
51 Elm Street
New Haven, CT 06510
408236__
Alan S. Tobin
Commissioner of the Superior Court
LAW OFFICES OF MEEHAN, TURRET & ROSENBAUM
101 BARNES ROAD, 3RD FLOOR, WALLINGFORD, CT 06492 (203) 294-7800 JURIS NO. 408308
Document Filed Date
April 28, 2015
Case Filing Date
June 05, 2014
Category
V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
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DOCKET NO. FBT-CV14-6043491-S : SUPERIOR COURT DAVID CONFEITEIRO : J.D. OF FAIRFIELD V : AT BRIDGEPORT TATIANA MEZARINA-ROJAS ET AL : APRIL 28, 2015 MOTION TO COMPEL FULL DISCLOSURE The undersigned Defendants move the Court for an order compelling the Plaintiff to fully comply with the Defendant’s Interrogatories and Requests for Production dated 7/3/14. Specifically, defendants seek full responses on following issues via full disclosure or providing fully executed authorizations:: 1. any and all employment records and tax returns for the 3 years prior to the subject accident to the present, 2. any and all prior records relating to neck or back complaints. While Plaintiff denied any prior similar conditions in his interrogatory responses, a review of his records makes clear he had neck pain at least sometime in 2011 and underwent a cervical MRI on 7/5/11. Additionally, Dr. Lipow’s note of 3/12/13 references neck pains in 2001 that resolved with Neurontin; whether this is actually 2001 or simply a typo referring to 2011, 3. pre- and post-accident records relating to treatment for anxiety and depression (particularly where he is also claiming post-traumatic stress from the subject accident as well.) 4. Any and all records from Dr. Patricia Richards; these were claimed in his interrogatories but none were provided 5. Any and all records from Dr. Menta/Menta Chiropractic; these were claimed in his interrogatories but none were provided LAW OFFICES OF MEEHAN, TURRET & ROSENBAUM 101 BARNES ROAD, 3RD FLOOR, WALLINGFORD, CT 06492 (203) 294-7800 JURIS NO. 408308 6. Treatment record from St. Vincent’s Hospital 7/20/14; these were claimed in his interrogatories but none were provided 7. records from the diskogram performed antecedent to Plaintiff’s surgery; unclear from records where this was performed but no records were provided 8. ANY AND ALL radiodiagnostic films of Plaintiff’s cervical and lumbar spine, including but not limited to CT Scan of cervical spine 6/5/12; MRI’s of cervical spine 7/5/11, 11/14/12, 12/5/12, 7/8/13; as well as any and all electrodiagnostic studies relating to Plaintiff’s neck and/or upper extremity radiculopathy. 9. -disability application 4/29/14, and supporting documentation regarding his lost wage claim. WHEREFORE, the Defendant requests this Court to rule the following relief: 1. Enter an order requiring the Plaintiff to adequately respond to said requests; 2. Enter Nonsuit against the Plaintiff for failure to comply or to adequately respond; 3. Award the Defendant the costs of pursuing this motion, including reasonable Attorney’s fees; and 4. Order any and all further relief that the court may deem necessary. LAW OFFICES OF MEEHAN, TURRET & ROSENBAUM 101 BARNES ROAD, 3RD FLOOR, WALLINGFORD, CT 06492 (203) 294-7800 JURIS NO. 408308 THE DEFENDANTS, BY ______408236__ Alan S. Tobin Law Offices of Meehan, Turret & Rosenbaum 101 Barnes Road, 3rd Floor Wallingford, CT 06492 Tel. # 203-294-7800 Juris # 408308 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 28th day of April, 2015. Attorney forPltf Joseph S. Dobrowolski, Esq. 51 Elm Street New Haven, CT 06510 408236__ Alan S. Tobin Commissioner of the Superior Court LAW OFFICES OF MEEHAN, TURRET & ROSENBAUM 101 BARNES ROAD, 3RD FLOOR, WALLINGFORD, CT 06492 (203) 294-7800 JURIS NO. 408308