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FBT-CV-14-6043491
DAVID CONFEITEIRO : SUPERIOR COURT
VS. : JUDICIAL DISTRICT OF
: BRIDGEPORT, AT BRIDGEPORT
TATIANA MEZARINA-ROJAS, ET AL : OCTOBER 7, 2016
FIRST AMENDED 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 06484Kanaga Sena, MD
Formerly of?
Neurological Specialists
2590 Main Street
Stratford, CT 06615-5838
Presently of:
Bridgeport Hospital Clinic
226 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 theplaintiff's applicable records, reports, and history, and certain texts, treatises, journals, written
materials, and other materials that are particular or peculiar to this case.
VOCATIONAL EXPERT:
The plaintiff currently intends to call as a witness the following vocational expert:
Albert Sabeila, M.S., Q.R.C., L.R.C.
Vocational Rehabilitation Counselor
115 Cedar Street
Providence, R1 02903
Mr. Sabeila 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 06410Dr. 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 plaintiffs
earnings records, relevant portions of the Union handbook and summary plan description, the
plaintiff's 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 Reports Bills
Bridgeport Hospital 6/5/12 ER (reports & films) $5,380.00
& Bridgeport Hospital Radiology —_ 11/14/12 MRI c-spine (reports & films) $4,556.00
267 Grant St. 11/15/13 fluoroscopy (reports & films) $5,332.39
Bridgeport, CT 06610 12/11/13 c-spine surgery/x-ray $32,140.80
(reports & films)
1/14/14 X-ray, c-spine (reports & films) $825.00
3/4/14 X-ray, jaw (reports & films) $1,184.00
3/18/14 CT c-spine (reports & films) $3,269.00
5/13/14 MRI c-spine (reports & films) $5,537.08Bridgeport Radiological Assoc.
PO Box 3187
Lewiston, ME 04243
Dr. 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
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 c-spine (reports & films)
5/13/14 MRI c-spine (reports & films)
3/4/14 X-ray, jaw (reports & films)
6/13-8/28/12; LO/LI-LI/A7/12
6/19, 6/26/12, 12/19/12; S/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)
11/14, 11/27/12; 3/12, 4/16, 6/27,
5
$335.00
$370.00
$68.00
$49.00
$278.00
$630.00
$50.00
$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
$1,643.12Chris 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
Hanger Clinic
1985 Barnum Avenue
Stratford, CT 06615
Med Now
1040 Barnum Avenue
Stratford, CT 06614
Bridgeport 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)
7/11, 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
6/24/14
TALIA
10/30, 11/1/13
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)
1/20/14
$22,197.00
$5,449.50
$550.00
$2,775.00
$5,750.00
$5,750.00
$2,470.00
$255.00
$447.00
$516.00
$910.00
$1,025.00
$4,545.00
$478.00
$1,103.50
$1,040.842712 Main St.
Stratford, CT 06615
St. Vincent’s Hospital 7/20/14 (ER) $4,772.30
2800 Main St.
Bridgeport, CT 06606
John Kveton, MD 8/19/14 $2,680.00
Ear, Note & Throat Med. & Surg. Grp.
31 Broadway
North Haven, CT 06473
Dario M. Zagar, M.D. 12/4/14, 10/29/15; 1/28/16 $580.00
Assoc. Neurologists of Southern CT
75 Kings Hwy Cutt Off, 5"" Fi
Fairfield, CT 06824
Pharmacy $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, economics 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,
7The plaintiff reserves the right to amend further this disclosure.
THE PLAINTIFF
By: 0 ML. é EL Le
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 will immediately be
mailed or delivered to:
Alan 8. 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: October 7, 2016 Cure. é, LGC
Chelsea E. Krombel