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FBT-CY-14-6043491
DAVID CONFEITEIRO : SUPERIOR COURT
vs. : JUDICIAL DISTRICT OF
: BRIDGEPORT, AT BRIDGEPORT
TATIANA MEZARINA-ROJAS, ET AL : SEPTEMBER 8, 2016
DISCLOSURE OF EXPERT WITNESSES AND DOCUMENTS/RECORDS
PURSUANT TO PRACTICE BOOK SECTION 13-4, AS AMENDED
EXPERT WITNESSES EXPECTED TO TESTIFY AT TRIAL
TREATING HEALTHCARE PROVIDERS:
The plaintiff, David Confeiteiro, currently intends to call as witnesses the following
healthcare providers who have examined and treated him for the injuries he has suffered as a
result of the subject accident, which occurred on June 4, 2012:
Kenneth Lipow, MD
CT Neurosurgical Specialists, P.C.
6 Greenwich Office Park
Greenwich, CT 06831
Francis P, Alcedo, MD
PriMED Silver Nichols Medical
3 Enterprise Drive, Ste. 404
Shelton, CT 06484
Kanaga Sena, MD
Formerly of:
Neurological Specialists
2590 Main Street
Stratford, CT 06615-5838
Presently of:
Bridgeport Hospital Clinic226 Mill Hill Avenue
Bridgeport, CT 06610
Dario M. Zagar, M.D.
Assoc. Neurologists of Southern CT
75 Kings Hwy Cut Off, 5"" FL
Fairfield, CT 06824
The above-named healthcare providers are expected to testify, where relevant and
necessary, based upon a reasonable degree of medical probability, as to causation, damages,
diagnosis, nature and extent of injuries, treatment, prognosis, permanent disability, and the
overall physical condition of the plaintiff, as well as his ability to function in society and carry
out and participate in the duties and responsibilities of everyday life, including his work
capacity, in accordance with their reports and notes, which have been provided to opposing
counsel, and in accordance with any opinion disclosed in deposition. They will also give their
opinion as to the probable extent of future treatment the plaintiff will likely be required to
undergo. They are expected to testify as to the cost of such treatment based on the plaintiff's
course of treatment to date and the cost of the same.
The above-named healthcare providers are expected to base their opinions upon their
education in their respective fields, clinical experience, training, examination of the plaintiff,
testing procedures performed on the plaintiff, diagnostic studies, and upon their review of the
plaintiff's applicable records, reports, and history, and certain texts, treatises, journals, written
materials, and other materials that are particular or peculiar to this case.
1
VOCATIONAL EXPERT:
The plaintiff currently intends to call as a witness the following vocational expert:
2 iAlbert Sabella, M.S., Q.R.C., L.R.C.
Vocational Rehabilitation Counselor
115 Cedar Street
Providence, RI 02903
Mr, Sabella is expected to testify regarding the vocational capacity of the plaintiff
resulting from the subject accident and his related physical injuries and impairments in
accordance with his 8/29/16 report and attachments, which have been provided to opposing
counsel, and in accordance with any opinion disclosed in deposition. Mr. Sabella is expected to
testify based on his 8/15/16 assessment interview, testing of the plaintiff, and his review of all
available medical records. Mr, Sabella is expected to testify based on his education, training,
and professional experience, all within the bounds of reasonable vocational probability.
Mr. Sabella is expected to testify that the plaintiff has incurred significant employment
barriers as a result of his injuries and subsequent concomitants as a consequence of the subject
accident and is unemployable for any practical vocational purpose.
ECONOMIC EXPERT:
The plaintiff currently intends to call as a witness the following economics expert:
Gary Crakes, PhD
Maher Crakes & Associates
860 Ward Lane
Cheshire, CT 06410
Dr. Crakes is expected to testify regarding the lost earning capacity of the plaintiff in
terms of net discounted economic losses resulting from the subject accident and his related
physical injuries and impairments in accordance with his 9/7/16 report and attachments, which
have been provided to opposing counsel, and in accordance with any opinion disclosed in
deposition. Dr. Crakes is expected to testify based on his review and analysis of the plaintiff's
3earnings records, relevant portions of the Union handbook and summary plan description, the
plaintiffs tax returns, and the 8/29/16 report of Mr. Sabella.
Dr. Crakes is expected to testify based on his education, training, and professional
experience, all within the bounds of reasonable economic probability. Dr. Crakes is expected to
testify that the plaintiff's net reduction in earning capacity resulting from the subject accident
and the associated injuries and impairments ranges from $2,671,000 to $2,753,000 (stated in
terms of present value).
DOCUMENTS/ RECORDS EXPECTED TO BE SUBMITTED INTO EVIDENCE
The plaintiff hereby discloses the following list of documents and/or records that he
expects to submit in evidence in addition to, or in lieu of, the testimony of expert witnesses:
Healthcare Provider
Bridgeport Hospital
& Bridgeport Hospital Radiology
267 Grant St.
Bridgeport, CT 06610
Bridgeport Radiological Assoc.
PO Box 3187
Lewiston, ME 04243
Reports
6/5/12 ER (reports & films)
11/14/12 MRI c-spine (reports & films)
11/15/13 fluoroscopy (reports & films)
12/11/13 c-spine surgery/x-ray
(reports & films)
1/14/14 X-ray, c-spine (reports & films)
3/4/14 X-ray, jaw (reports & films)
3/18/14 CT c-spine (reports & films)
5/13/14 MRI c-spine (reports & films)
6/5/12 X-rays, c-spine; CT brain
(reports & films)
11/14/12 X-ray, face; MRI c-spine
(reports & films)
12/11/13 X-ray, spine (reports & films)
1/14/14 X-rays, c-spine (reports & films)
‘3/18/14 CT e-spine (reports & films)
5/13/14 MRI c-spine (reports & films)
3/4/14 X-ray, jaw (reports & films)
Bills
$5,380.00
$4,556.00
$5,332.39
$32,140.80
$825.00
$1,184.00
$3,269.00
$5,537.08
$335.00
$370.00
$68.00
$49.00
$278.00
$630.00
$50.00Dr. Kristen A. Kaczanowski, LLC
49 Cannon Street
Bridgeport, CT 06604
Drs. Sena, Barasch, Beck, Zhang
Neurological Specialists
2590 Main Street
Stratford, CT 06615-5838
Quest Diagnostics
PO Box 71310
Philadelphia, PA 19176
Francis P, Alcedo, MD
PriMED Silver Nichols Medical
3 Enterprise Drive, Ste. 404
Shelton, CT 06484
Advanced Radiology
2876 Main Street
Stratford, CT 06614
William H. Backus Hospital
326 Washington St.
Norwich, CT 06360
Eric Katz, MD
3180 Main Street, Suite 107
Bridgeport, CT 06606
Kenneth Lipow, MD
Chris Dall, PA-C
CT Neurosurgical Specialists, P.C.
6 Greenwich Office Park
Greenwich, CT 06831
Rahul S, Anand, MD
CT Pain and Wellness Center, LLC
52 Beach Road, Suite 204
Fairfield, CT 06824-6016
6/13-8/28/12; 10/11-LE/7/12
6/19, 6/26/12, 12/19/12: 5/15, 7/25/13
6/19/12
6/21/12; 10/29, 12/6/13, 3/7, 6/13,
10/13/14; 3/16/15; 2/12/16
6/21/12 MRI brain / CT brain
(reports & films)
12/5/12 MRI c-spine (reports & films)
3/26/13 MRI brain (reports & films)
7/8/13 MRI c-spine (reports & films)
7/28/12 ER
9/6, 11/5/12; 5/6, 10/3/13; 2/6/14
(incl. injections)
14/14, 11/27/12; 3/12, 4/16, 6/27,
TAA, 11/21, 12/19/13; 2/20, 3/18,
5/13/14; 4/21, 6/14/15
12/11/13 c-spine surgery (Lipow)
12/11/13 (Dall)
6/4/13
6/12/13 epidural steroid injection
7/29/13 epidural steroid injection
8/19/13 epidural steroid injection
11/15/13 discography c-spine
5
$4,470.00
$1,715.00
$687.85
$438.00
$2,148.00
$1,180.00
$1,270.00
$1,180.00
$569.84
$1,685.00
$1,643.12
$22,197.00
$5,449.50
$550.00
$2,775.00
$5,750.00
$5,750.00
$2,470.00Bridgeport Anesthesia
PO Box 4640
Rutherford, NJ 07070
Michael Waltzman, MD, PhD
PriMed ENT
965 White Plains Rd #3
Trumbull, CT 06611
Patricia A. Richard, MD, DMD
PO Box 702-1735 Post Road
Fairfield, CT 06824-0702
PriMed Physical Therapy
112 Quarry Rd #120
Trumbull, CT 06611
Dr. Franco Menta
Menta Chiropractic, LLC
9 Research Drive
Milford, CT 06460
Town of Stratford (EMT)
2712 Main St.
Stratford, CT 06615
St. Vincent’s Hospital
2800 Main St.
Bridgeport, CT 06606
John Kveton, MD
6/24/14
1/7, 1/22, 2/4, 2/14/14
2/17, 3/3, 3/10, 3/17, 3/24/14
2/27, 3/20/14
5/28/14-8/5/14 (22 visits)
720/14
7/20/14 (ER)
8/19/14
Ear, Note & Throat Med. & Surg. Grp.
31 Broadway
North Haven, CT 06473
Dario M. Zagar, M.D.
Assoc. Neurologists of Southern CT
75 Kings Hwy Cutt Off, 5" Fl
Fairfield, CT 06824
12/4/14; 10/29/15; 1/28/16
$255.00
$910.00
$1,025.00
$4,545.00
$478.00
$1,103.50
$1,040.84
$4,772.30
$2,680.00
$580.00Pharmacy $1,300.74
Other Documents/Records
Report of Economics Expert, Gary Crakes, PhD, dated 9/7/16
Report of Vocational Expert, Albert Sabella, M.S., Q.R.C., L.R.C., dated 8/29/16
Life Table
Connecticut Uniform Police Accident Report, dated 6/4/12
Police Case No.: 1200320782
Property Damage Estimate as to plaintiff's vehicle, prepared by Allstate Insurance Company and
dated 6/7/12
Property Damage Estimate as to vehicle driven by defendant, prepared by Family Auto Body,
Inc. and dated 6/6/12
This disclosure is in no way intended to limit the plaintiff's right to call any healthcare
provider and/or representative of a treatment facility, economies or vocational expert, police
officer, or any other expert witness, to testify at trial and/or at a deposition to be submitted at
trial, or to submit additional reports, notes, documents, or records, including photographs.
The plaintiff reserves the right to amend this disclosure.
THE PLAINTIFF
i g
By:__Ldvtie 2
Chelsea E. Krombel
LAW OFFICES OF PAUL E. FARREN, JR., P.C.
129 Whitney Avenue
New Haven, CT 06510
Phone: (203) 784-0326
Fax: (203) 624-5321
Juris No, 421215CERTIFICATION
I certify that a copy of this document was or will immediately by mailed or
delivered electronically or non-electronically this date to all attorneys and self-
represented parties of record and to all parties who have not appeared in this matter and
that written consent for electronic delivery was received from all attorneys and self-
represented parties receiving electronic delivery.
Name and address of each party and attorney that copy was or wili immediately be
mailed or delivered to:
Alan S. Tobin, Esq.
Law Offices of Meehan, Roberts, Turret & Rosenbaum
108 Leigus Road, 1st Floor
Wallingford, CT 06492
Joseph S. Dobrowolski, Esq.
51 Elm St., 2nd Floor
New Haven, CT 06510
Dated: September 8, 2016 C fohe é
Chelsea E. Krombel
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FBT-CY-14-6043491 DAVID CONFEITEIRO : SUPERIOR COURT vs. : JUDICIAL DISTRICT OF : BRIDGEPORT, AT BRIDGEPORT TATIANA MEZARINA-ROJAS, ET AL : SEPTEMBER 8, 2016 DISCLOSURE OF EXPERT WITNESSES AND DOCUMENTS/RECORDS PURSUANT TO PRACTICE BOOK SECTION 13-4, AS AMENDED EXPERT WITNESSES EXPECTED TO TESTIFY AT TRIAL TREATING HEALTHCARE PROVIDERS: The plaintiff, David Confeiteiro, currently intends to call as witnesses the following healthcare providers who have examined and treated him for the injuries he has suffered as a result of the subject accident, which occurred on June 4, 2012: Kenneth Lipow, MD CT Neurosurgical Specialists, P.C. 6 Greenwich Office Park Greenwich, CT 06831 Francis P, Alcedo, MD PriMED Silver Nichols Medical 3 Enterprise Drive, Ste. 404 Shelton, CT 06484 Kanaga Sena, MD Formerly of: Neurological Specialists 2590 Main Street Stratford, CT 06615-5838 Presently of: Bridgeport Hospital Clinic226 Mill Hill Avenue Bridgeport, CT 06610 Dario M. Zagar, M.D. Assoc. Neurologists of Southern CT 75 Kings Hwy Cut Off, 5"" FL Fairfield, CT 06824 The above-named healthcare providers are expected to testify, where relevant and necessary, based upon a reasonable degree of medical probability, as to causation, damages, diagnosis, nature and extent of injuries, treatment, prognosis, permanent disability, and the overall physical condition of the plaintiff, as well as his ability to function in society and carry out and participate in the duties and responsibilities of everyday life, including his work capacity, in accordance with their reports and notes, which have been provided to opposing counsel, and in accordance with any opinion disclosed in deposition. They will also give their opinion as to the probable extent of future treatment the plaintiff will likely be required to undergo. They are expected to testify as to the cost of such treatment based on the plaintiff's course of treatment to date and the cost of the same. The above-named healthcare providers are expected to base their opinions upon their education in their respective fields, clinical experience, training, examination of the plaintiff, testing procedures performed on the plaintiff, diagnostic studies, and upon their review of the plaintiff's applicable records, reports, and history, and certain texts, treatises, journals, written materials, and other materials that are particular or peculiar to this case. 1 VOCATIONAL EXPERT: The plaintiff currently intends to call as a witness the following vocational expert: 2 iAlbert Sabella, M.S., Q.R.C., L.R.C. Vocational Rehabilitation Counselor 115 Cedar Street Providence, RI 02903 Mr, Sabella is expected to testify regarding the vocational capacity of the plaintiff resulting from the subject accident and his related physical injuries and impairments in accordance with his 8/29/16 report and attachments, which have been provided to opposing counsel, and in accordance with any opinion disclosed in deposition. Mr. Sabella is expected to testify based on his 8/15/16 assessment interview, testing of the plaintiff, and his review of all available medical records. Mr, Sabella is expected to testify based on his education, training, and professional experience, all within the bounds of reasonable vocational probability. Mr. Sabella is expected to testify that the plaintiff has incurred significant employment barriers as a result of his injuries and subsequent concomitants as a consequence of the subject accident and is unemployable for any practical vocational purpose. ECONOMIC EXPERT: The plaintiff currently intends to call as a witness the following economics expert: Gary Crakes, PhD Maher Crakes & Associates 860 Ward Lane Cheshire, CT 06410 Dr. Crakes is expected to testify regarding the lost earning capacity of the plaintiff in terms of net discounted economic losses resulting from the subject accident and his related physical injuries and impairments in accordance with his 9/7/16 report and attachments, which have been provided to opposing counsel, and in accordance with any opinion disclosed in deposition. Dr. Crakes is expected to testify based on his review and analysis of the plaintiff's 3earnings records, relevant portions of the Union handbook and summary plan description, the plaintiffs tax returns, and the 8/29/16 report of Mr. Sabella. Dr. Crakes is expected to testify based on his education, training, and professional experience, all within the bounds of reasonable economic probability. Dr. Crakes is expected to testify that the plaintiff's net reduction in earning capacity resulting from the subject accident and the associated injuries and impairments ranges from $2,671,000 to $2,753,000 (stated in terms of present value). DOCUMENTS/ RECORDS EXPECTED TO BE SUBMITTED INTO EVIDENCE The plaintiff hereby discloses the following list of documents and/or records that he expects to submit in evidence in addition to, or in lieu of, the testimony of expert witnesses: Healthcare Provider Bridgeport Hospital & Bridgeport Hospital Radiology 267 Grant St. Bridgeport, CT 06610 Bridgeport Radiological Assoc. PO Box 3187 Lewiston, ME 04243 Reports 6/5/12 ER (reports & films) 11/14/12 MRI c-spine (reports & films) 11/15/13 fluoroscopy (reports & films) 12/11/13 c-spine surgery/x-ray (reports & films) 1/14/14 X-ray, c-spine (reports & films) 3/4/14 X-ray, jaw (reports & films) 3/18/14 CT c-spine (reports & films) 5/13/14 MRI c-spine (reports & films) 6/5/12 X-rays, c-spine; CT brain (reports & films) 11/14/12 X-ray, face; MRI c-spine (reports & films) 12/11/13 X-ray, spine (reports & films) 1/14/14 X-rays, c-spine (reports & films) ‘3/18/14 CT e-spine (reports & films) 5/13/14 MRI c-spine (reports & films) 3/4/14 X-ray, jaw (reports & films) Bills $5,380.00 $4,556.00 $5,332.39 $32,140.80 $825.00 $1,184.00 $3,269.00 $5,537.08 $335.00 $370.00 $68.00 $49.00 $278.00 $630.00 $50.00Dr. Kristen A. Kaczanowski, LLC 49 Cannon Street Bridgeport, CT 06604 Drs. Sena, Barasch, Beck, Zhang Neurological Specialists 2590 Main Street Stratford, CT 06615-5838 Quest Diagnostics PO Box 71310 Philadelphia, PA 19176 Francis P, Alcedo, MD PriMED Silver Nichols Medical 3 Enterprise Drive, Ste. 404 Shelton, CT 06484 Advanced Radiology 2876 Main Street Stratford, CT 06614 William H. Backus Hospital 326 Washington St. Norwich, CT 06360 Eric Katz, MD 3180 Main Street, Suite 107 Bridgeport, CT 06606 Kenneth Lipow, MD Chris Dall, PA-C CT Neurosurgical Specialists, P.C. 6 Greenwich Office Park Greenwich, CT 06831 Rahul S, Anand, MD CT Pain and Wellness Center, LLC 52 Beach Road, Suite 204 Fairfield, CT 06824-6016 6/13-8/28/12; 10/11-LE/7/12 6/19, 6/26/12, 12/19/12: 5/15, 7/25/13 6/19/12 6/21/12; 10/29, 12/6/13, 3/7, 6/13, 10/13/14; 3/16/15; 2/12/16 6/21/12 MRI brain / CT brain (reports & films) 12/5/12 MRI c-spine (reports & films) 3/26/13 MRI brain (reports & films) 7/8/13 MRI c-spine (reports & films) 7/28/12 ER 9/6, 11/5/12; 5/6, 10/3/13; 2/6/14 (incl. injections) 14/14, 11/27/12; 3/12, 4/16, 6/27, TAA, 11/21, 12/19/13; 2/20, 3/18, 5/13/14; 4/21, 6/14/15 12/11/13 c-spine surgery (Lipow) 12/11/13 (Dall) 6/4/13 6/12/13 epidural steroid injection 7/29/13 epidural steroid injection 8/19/13 epidural steroid injection 11/15/13 discography c-spine 5 $4,470.00 $1,715.00 $687.85 $438.00 $2,148.00 $1,180.00 $1,270.00 $1,180.00 $569.84 $1,685.00 $1,643.12 $22,197.00 $5,449.50 $550.00 $2,775.00 $5,750.00 $5,750.00 $2,470.00Bridgeport Anesthesia PO Box 4640 Rutherford, NJ 07070 Michael Waltzman, MD, PhD PriMed ENT 965 White Plains Rd #3 Trumbull, CT 06611 Patricia A. Richard, MD, DMD PO Box 702-1735 Post Road Fairfield, CT 06824-0702 PriMed Physical Therapy 112 Quarry Rd #120 Trumbull, CT 06611 Dr. Franco Menta Menta Chiropractic, LLC 9 Research Drive Milford, CT 06460 Town of Stratford (EMT) 2712 Main St. Stratford, CT 06615 St. Vincent’s Hospital 2800 Main St. Bridgeport, CT 06606 John Kveton, MD 6/24/14 1/7, 1/22, 2/4, 2/14/14 2/17, 3/3, 3/10, 3/17, 3/24/14 2/27, 3/20/14 5/28/14-8/5/14 (22 visits) 720/14 7/20/14 (ER) 8/19/14 Ear, Note & Throat Med. & Surg. Grp. 31 Broadway North Haven, CT 06473 Dario M. Zagar, M.D. Assoc. Neurologists of Southern CT 75 Kings Hwy Cutt Off, 5" Fl Fairfield, CT 06824 12/4/14; 10/29/15; 1/28/16 $255.00 $910.00 $1,025.00 $4,545.00 $478.00 $1,103.50 $1,040.84 $4,772.30 $2,680.00 $580.00Pharmacy $1,300.74 Other Documents/Records Report of Economics Expert, Gary Crakes, PhD, dated 9/7/16 Report of Vocational Expert, Albert Sabella, M.S., Q.R.C., L.R.C., dated 8/29/16 Life Table Connecticut Uniform Police Accident Report, dated 6/4/12 Police Case No.: 1200320782 Property Damage Estimate as to plaintiff's vehicle, prepared by Allstate Insurance Company and dated 6/7/12 Property Damage Estimate as to vehicle driven by defendant, prepared by Family Auto Body, Inc. and dated 6/6/12 This disclosure is in no way intended to limit the plaintiff's right to call any healthcare provider and/or representative of a treatment facility, economies or vocational expert, police officer, or any other expert witness, to testify at trial and/or at a deposition to be submitted at trial, or to submit additional reports, notes, documents, or records, including photographs. The plaintiff reserves the right to amend this disclosure. THE PLAINTIFF i g By:__Ldvtie 2 Chelsea E. Krombel LAW OFFICES OF PAUL E. FARREN, JR., P.C. 129 Whitney Avenue New Haven, CT 06510 Phone: (203) 784-0326 Fax: (203) 624-5321 Juris No, 421215CERTIFICATION I certify that a copy of this document was or will immediately by mailed or delivered electronically or non-electronically this date to all attorneys and self- represented parties of record and to all parties who have not appeared in this matter and that written consent for electronic delivery was received from all attorneys and self- represented parties receiving electronic delivery. Name and address of each party and attorney that copy was or wili immediately be mailed or delivered to: Alan S. Tobin, Esq. Law Offices of Meehan, Roberts, Turret & Rosenbaum 108 Leigus Road, 1st Floor Wallingford, CT 06492 Joseph S. Dobrowolski, Esq. 51 Elm St., 2nd Floor New Haven, CT 06510 Dated: September 8, 2016 C fohe é Chelsea E. Krombel