On December 23, 2014 a
Trial Materials
was filed
involving a dispute between
Bogumila Tabaka,
and
Ean Holdings Llc,
Gene Dickinson,
Safeco Insurance Company Of Illinois,
for V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
in the District Court of New Haven County.
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DN AAN CV15-6017543 S : SUPERIOR COURT
BOGUMILA TABAKA : J. D. OF ANSONIA/MILFORD
VS. : AT MILFORD
GENE DICKINSON; SAFECO INS.
COMPANY OF ILLINOIS and
EAN HOLDINGS, LLC : JULY 29, 2015
DISCLOSURE OF EXPERT WITNESS
Pursuant to Practice Book Section 13-4(4), the plaintiff, BOGUMILA TABAKA,
discloses JONATHAN P. KONECNY, D.C., of Konecny Chiropractic Centers, LLC -
2140 Park Avenue, Bridgeport, CT 06604, as an expert witness. Dr. Konecny will
testify that as a result of the motor vehicle accident of April 17, 2014, the plaintiff,
BOGUMILA TABAKA, suffered: neck pain, back pain, stiffness and headaches;
restricted range of motion of the neck; restricted range of motion of the back; loss
(straightening) of the lordotic curve in the cervical spine; change in ligamentous
strucures; cervical acceleration/deceleration injury; decrease in normal disc height
evident in C5-C6 and C6-C7 levels; L2-3 diffuse disc bulging; disc herniation; L3-4
mild diffuse disc bulging; L4-5 diffuse disc bulging; L5-S1 diffuse disc bulging, which
resulted in a 5% permanent physical impairment of the cervical spine and a 13%
permanent physical impairment of the lumbar spine according to the AMA Guides 5th
Edition and are directly related to the motor vehicle accident of April 17, 2014.
Dr. Konecny's opinion will be based upon his treatment and observations of
plaintiff and his review of the plaintiff's medical records, in conjunction with his
training, education, and experience as a chiropractic physician. Dr. Konecny's Final
Narrative Report dated October 7, 2014, is annexed hereto.
Dr. Konecny further opines that the plaintiff may require additional office
treatment for exacerbations that can not be handled through her home exercise
program and anticipates the need for symptomatic treatment at an annual cost of
$1,500.00 to $2,000.00.
' These opinions may be introduced by way of written records and reports
previously disclosed with plaintiff's compliance and/or through court testimony.
THE PLAINTIFF,
BY:______________________________
Bruce J. Corrigan, Jr.
Law Offices of Bruce J. Corrigan, Jr.
1853 Post Road East, Westport, CT 06880
(203) 255-1950/Juris #: 429597
CERTIFICATION
This is to certify that a copy of the foregoing has been sent, via first class mail,
postage prepaid, on this 11th day of June 2008 to:
Denise Lynn Drews, Esquire
Meehan, Turret & Rosenbaum
101 Barnes Road – 3rd Floor
Wallingford, CT 06492
________________________________
Bruce J. Corrigan, Jr.
Document Filed Date
July 29, 2015
Case Filing Date
December 23, 2014
Category
V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
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DN AAN CV15-6017543 S : SUPERIOR COURT BOGUMILA TABAKA : J. D. OF ANSONIA/MILFORD VS. : AT MILFORD GENE DICKINSON; SAFECO INS. COMPANY OF ILLINOIS and EAN HOLDINGS, LLC : JULY 29, 2015 DISCLOSURE OF EXPERT WITNESS Pursuant to Practice Book Section 13-4(4), the plaintiff, BOGUMILA TABAKA, discloses JONATHAN P. KONECNY, D.C., of Konecny Chiropractic Centers, LLC - 2140 Park Avenue, Bridgeport, CT 06604, as an expert witness. Dr. Konecny will testify that as a result of the motor vehicle accident of April 17, 2014, the plaintiff, BOGUMILA TABAKA, suffered: neck pain, back pain, stiffness and headaches; restricted range of motion of the neck; restricted range of motion of the back; loss (straightening) of the lordotic curve in the cervical spine; change in ligamentous strucures; cervical acceleration/deceleration injury; decrease in normal disc height evident in C5-C6 and C6-C7 levels; L2-3 diffuse disc bulging; disc herniation; L3-4 mild diffuse disc bulging; L4-5 diffuse disc bulging; L5-S1 diffuse disc bulging, which resulted in a 5% permanent physical impairment of the cervical spine and a 13% permanent physical impairment of the lumbar spine according to the AMA Guides 5th Edition and are directly related to the motor vehicle accident of April 17, 2014. Dr. Konecny's opinion will be based upon his treatment and observations of plaintiff and his review of the plaintiff's medical records, in conjunction with his training, education, and experience as a chiropractic physician. Dr. Konecny's Final Narrative Report dated October 7, 2014, is annexed hereto. Dr. Konecny further opines that the plaintiff may require additional office treatment for exacerbations that can not be handled through her home exercise program and anticipates the need for symptomatic treatment at an annual cost of $1,500.00 to $2,000.00. ' These opinions may be introduced by way of written records and reports previously disclosed with plaintiff's compliance and/or through court testimony. THE PLAINTIFF, BY:______________________________ Bruce J. Corrigan, Jr. Law Offices of Bruce J. Corrigan, Jr. 1853 Post Road East, Westport, CT 06880 (203) 255-1950/Juris #: 429597 CERTIFICATION This is to certify that a copy of the foregoing has been sent, via first class mail, postage prepaid, on this 11th day of June 2008 to: Denise Lynn Drews, Esquire Meehan, Turret & Rosenbaum 101 Barnes Road – 3rd Floor Wallingford, CT 06492 ________________________________ Bruce J. Corrigan, Jr.