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DOCKET NO.: DBD CV 19 6031062S : SUPERIOR COURT
DIANE RALPH : J. D. OF DANBURY
V. : AT DANBURY
ROBIN SCHWARTZ-BRINDLEY : MAY 24, 2021
PLAINTIFF'S DISCLOSURE OF EXPERT WITNESSES
The Plaintiff, Diane Ralph, hereby gives notice of the disclosure of expert witnesses who may
testify at trial.
Names, Addresses and Employers
Martha J. Moulton, MD and
Western Connecticut Medical Group - Brookfield Family Medicine Personnel
60 Old New Milford Road, #2
Brookfield, CT 06804
Robert J. Daher, MD and Orthopaedic Specialists of Connecticut Personnel
60 Old New Milford Road, Suite 3E
Brookfield, CT 06804
Access Physical Therapy and Wellness Personnel
f/k/a Physical Therapy Arts
31 Old Route 7
Brookfield, CT 06804
In addition, the Plaintiff reserves the right to and may elicit opinions upon cross-examination
of any expert witnesses called by the Defendant at trial.
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
1
Subject Matter
The general subject matter upon which the medical experts will testify includes the medical
condition of the Plaintiff; examinations, findings and diagnosis; the nature and extent of the
Plaintiff’s injuries; the causation of those injuries; treatment; recommendations; the Plaintiff's
prognosis; future treatment and the cost of same; and any permanency.
Substance of the Facts and Opinions
Martha J. Moulton, MD and Western Connecticut Medical Group - Brookfield Family
Medicine Personnel
Martha J. Moulton, MD and Western Connecticut Medical Group - Brookfield Family
Medicine Personnel will testify regarding their examination and treatment of Plaintiff. It is expected
that they will testify in accordance with the treatment notes and evaluation and consultation reports
that have been provided through discovery. Evidence or testimony will include the nature and extent
of the Plaintiff’s injuries, causation, prognosis and permanency. They will testify that the injuries the
Plaintiff suffered were directly related to the accident on May 17, 2017 and are permanent. These
injuries include: left thumb pain and sprain, neck pain and sprain, and thoracic spine pain and sprain,
and pain and suffering, both mental and physical. They will testify that the treatment of the Plaintiff
for the injuries sustained in the May 17, 2017 accident, as more fully described in the medical reports
and records, was both reasonable and necessary. They are expected to testify regarding the future
treatment and cost of treatment, the Plaintiff may have to undergo as a result of the May 17, 2017
accident.
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
2
Robert J. Daher, MD and Orthopaedic Specialists of Connecticut Personnel
Robert J. Daher, MD and Orthopaedic Specialists of Connecticut Personnel will testify
regarding their examination and treatment of Plaintiff. It is expected that they will testify in
accordance with the treatment notes and evaluation and consultation reports that have been provided
through discovery. Evidence or testimony will include the nature and extent of the Plaintiff’s
injuries, causation, prognosis and permanency. They will testify that the injuries the Plaintiff
suffered were directly related to the accident on May 17, 2017 and are permanent. These injuries
include: left thumb pain and sprain, neck pain and sprain, and thoracic spine pain and sprain, and
pain and suffering, both mental and physical. They will testify that the treatment of the Plaintiff for the
injuries sustained in the May 17, 2017 accident, as more fully described in the medical reports and
records, was both reasonable and necessary. They are expected to testify regarding the future treatment
and cost of treatment, the Plaintiff may have to undergo as a result of the May 17, 2017 accident.
Access Physical Therapy and Wellness Personnel
Access Physical Therapy and Wellness Personnel will testify regarding their examination and
treatment of Plaintiff. It is expected that they will testify in accordance with the treatment notes and
evaluation and consultation reports that have been provided through discovery. Evidence or
testimony will include the nature and extent of the Plaintiff’s injuries, causation, prognosis and
permanency. They will testify that the injuries the Plaintiff suffered were directly related to the
accident on May 17, 2017 and are permanent. These injuries include: left thumb pain and sprain,
neck pain and sprain, and thoracic spine pain and sprain, and pain and suffering, both mental and
physical. They will testify that the treatment of the Plaintiff for the injuries sustained in the May 17,
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
3
2017 accident, as more fully described in the medical reports and records, was both reasonable and
necessary. They are expected to testify regarding the future treatment and cost of treatment, the Plaintiff
may have to undergo as a result of the May 17, 2017 accident.
Summary of the Grounds for Each Opinion
The medical witnesses' opinions will be based upon examination and treatment of the
Plaintiff; interviews with the Plaintiff; and review of medical records and reports and diagnostic test
results; and upon their knowledge, education, experience and training.
THE PLAINTIFF,
DIANE RALPH
By____418917_________________
Pamela L. Cameron, Esq.
MOORE, O'BRIEN & FOTI
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
4
CERTIFICATION
I certify that a copy of this document was or will immediately be mailed or delivered
electronically or non-electronically on May 24, 2021 to all attorneys and self-represented parties of
record and that written consent for electronic delivery was received from all attorneys and self-
represented parties of record who received or will immediately be receiving electronic delivery.
Michael O. Connelly, Esq.
Murphy Karpie Connelly & Sickinger LLC
350 Fairfield Avenue, Suite 408
Bridgeport, CT 06604
Via Email To connelly@murphykarpie.com
Via Email to v.lisi@murphykarpie.com
And Via U.S. Mail
By: /s/418917 ______
Pamela L. Cameron
Commissioner of the Superior Court
MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW
891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519
5
Preview
DOCKET NO.: DBD CV 19 6031062S : SUPERIOR COURT DIANE RALPH : J. D. OF DANBURY V. : AT DANBURY ROBIN SCHWARTZ-BRINDLEY : MAY 24, 2021 PLAINTIFF'S DISCLOSURE OF EXPERT WITNESSES The Plaintiff, Diane Ralph, hereby gives notice of the disclosure of expert witnesses who may testify at trial. Names, Addresses and Employers Martha J. Moulton, MD and Western Connecticut Medical Group - Brookfield Family Medicine Personnel 60 Old New Milford Road, #2 Brookfield, CT 06804 Robert J. Daher, MD and Orthopaedic Specialists of Connecticut Personnel 60 Old New Milford Road, Suite 3E Brookfield, CT 06804 Access Physical Therapy and Wellness Personnel f/k/a Physical Therapy Arts 31 Old Route 7 Brookfield, CT 06804 In addition, the Plaintiff reserves the right to and may elicit opinions upon cross-examination of any expert witnesses called by the Defendant at trial. MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 1 Subject Matter The general subject matter upon which the medical experts will testify includes the medical condition of the Plaintiff; examinations, findings and diagnosis; the nature and extent of the Plaintiff’s injuries; the causation of those injuries; treatment; recommendations; the Plaintiff's prognosis; future treatment and the cost of same; and any permanency. Substance of the Facts and Opinions Martha J. Moulton, MD and Western Connecticut Medical Group - Brookfield Family Medicine Personnel Martha J. Moulton, MD and Western Connecticut Medical Group - Brookfield Family Medicine Personnel will testify regarding their examination and treatment of Plaintiff. It is expected that they will testify in accordance with the treatment notes and evaluation and consultation reports that have been provided through discovery. Evidence or testimony will include the nature and extent of the Plaintiff’s injuries, causation, prognosis and permanency. They will testify that the injuries the Plaintiff suffered were directly related to the accident on May 17, 2017 and are permanent. These injuries include: left thumb pain and sprain, neck pain and sprain, and thoracic spine pain and sprain, and pain and suffering, both mental and physical. They will testify that the treatment of the Plaintiff for the injuries sustained in the May 17, 2017 accident, as more fully described in the medical reports and records, was both reasonable and necessary. They are expected to testify regarding the future treatment and cost of treatment, the Plaintiff may have to undergo as a result of the May 17, 2017 accident. MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 2 Robert J. Daher, MD and Orthopaedic Specialists of Connecticut Personnel Robert J. Daher, MD and Orthopaedic Specialists of Connecticut Personnel will testify regarding their examination and treatment of Plaintiff. It is expected that they will testify in accordance with the treatment notes and evaluation and consultation reports that have been provided through discovery. Evidence or testimony will include the nature and extent of the Plaintiff’s injuries, causation, prognosis and permanency. They will testify that the injuries the Plaintiff suffered were directly related to the accident on May 17, 2017 and are permanent. These injuries include: left thumb pain and sprain, neck pain and sprain, and thoracic spine pain and sprain, and pain and suffering, both mental and physical. They will testify that the treatment of the Plaintiff for the injuries sustained in the May 17, 2017 accident, as more fully described in the medical reports and records, was both reasonable and necessary. They are expected to testify regarding the future treatment and cost of treatment, the Plaintiff may have to undergo as a result of the May 17, 2017 accident. Access Physical Therapy and Wellness Personnel Access Physical Therapy and Wellness Personnel will testify regarding their examination and treatment of Plaintiff. It is expected that they will testify in accordance with the treatment notes and evaluation and consultation reports that have been provided through discovery. Evidence or testimony will include the nature and extent of the Plaintiff’s injuries, causation, prognosis and permanency. They will testify that the injuries the Plaintiff suffered were directly related to the accident on May 17, 2017 and are permanent. These injuries include: left thumb pain and sprain, neck pain and sprain, and thoracic spine pain and sprain, and pain and suffering, both mental and physical. They will testify that the treatment of the Plaintiff for the injuries sustained in the May 17, MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 3 2017 accident, as more fully described in the medical reports and records, was both reasonable and necessary. They are expected to testify regarding the future treatment and cost of treatment, the Plaintiff may have to undergo as a result of the May 17, 2017 accident. Summary of the Grounds for Each Opinion The medical witnesses' opinions will be based upon examination and treatment of the Plaintiff; interviews with the Plaintiff; and review of medical records and reports and diagnostic test results; and upon their knowledge, education, experience and training. THE PLAINTIFF, DIANE RALPH By____418917_________________ Pamela L. Cameron, Esq. MOORE, O'BRIEN & FOTI MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 4 CERTIFICATION I certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on May 24, 2021 to all attorneys and self-represented parties of record and that written consent for electronic delivery was received from all attorneys and self- represented parties of record who received or will immediately be receiving electronic delivery. Michael O. Connelly, Esq. Murphy Karpie Connelly & Sickinger LLC 350 Fairfield Avenue, Suite 408 Bridgeport, CT 06604 Via Email To connelly@murphykarpie.com Via Email to v.lisi@murphykarpie.com And Via U.S. Mail By: /s/418917 ______ Pamela L. Cameron Commissioner of the Superior Court MOORE, O’BRIEN & FOTI ● ATTORNEYS AT LAW 891 STRAITS TURNPIKE ● MIDDLEBURY, CT 06762 ● TEL. (203) 272-5881 ● JURIS NO. 408519 5