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DOCKET NO.: UWY-CV21-6060768-S : SUPERIOR COURT
CYNTHIA BROWN, CONSERVATOR : J.D. OF WATERBURY
OF THE PERSON AND ESTATE OF
ELIZABETH STEWART,
CYNTHIA BROWN, INDIVIDUALLY,
AND EDWARD STEWART
VS. : AT WATERBURY
SAINT MARY’S HOSPITAL, INC., ET AL : FEBRUARY 1, 2022
DEFENDANT ANGELA QUATROCELLI, M.D.’S OBJECTIONS TO PLAINTIFF’S
I&P DATED JULY 2, 2021
Pursuant to Practice Book §13-8, the undersigned, Defendant, Angela Quatrocelli,
M.D., hereby objects to the Plaintiff’s Interrogatories and Production dated July 2, 2021.
1. State the following:
b. your date of birth;
(b) OBJECTION This Interrogatory is objectionable insofar as it seeks personal
identifying information that is not relevant to the parties’ claims or defenses nor is
it reasonably calculated to lead to the discovery of admissible evidence and is not
proportional to the needs of the case.
Unless the information is provided in your CV, respond to questions 3 through 11.
2. State the name of each college and graduate school you attended, the date of
graduation, and each degree obtained, or provide your curriculum vitae including such
information.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
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The foregoing objection notwithstanding, see attached CV.
3. State the name and address of each medical institution where you underwent post-
graduate training (e.g., internship, residency, fellowship, or similar training), and the dates of
attendance, or provide your curriculum vitae including such information.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, see attached CV.
4. State whether you have had training in a medical or surgical specialty, identify the
specialty, state the dates you have practiced the specialty, and the name and address of each
institution where you were trained, or provide your curriculum vitae including such
information.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, see attached CV.
5. State whether you have ever specialized in or limited your practice to a particular
field or branch of medicine or surgery and, if so, for each specialized or limited practice,
state the field or branch of medicine or surgery, the inclusive dates you have so practiced,
and the location of each place where you so practiced in the past 10 years, or provide your
curriculum vitae including such information.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, see attached CV.
6. State whether you have ever been associated with or connected in a teaching capacity
with any medical institutions. If so, for each institution, state:
a. the name and address of the institution;
b. the inclusive dates of your association; and
c. the title held in each position, or provide your curriculum vitae including
such information.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, see attached CV.
7. State the name and location of any hospital or medical facility at which you have or
have had privileges and/or where you have worked in the past 10 years, and the dates thereof,
or provide your curriculum vitae including such information.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, see attached CV.
8. Identify each medical book, paper, article, or other document that you have published,
written, or to which you have contributed, and for each, state the title, whether you were an
author, co-author, or contributor, or provide your curriculum vitae including such
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information.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, see attached CV.
9. State the name of every jurisdiction in which you are or have been licensed as a
health care provider, or provide your curriculum vitae including such information.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, see attached CV.
10. State whether you are, or have ever been, a member of any medical or other health
care provider association, society or organization, and if so, as to each such membership,
state:
a. the name and address of the medical or other health care provider association,
society, or organization;
b. the inclusive dates of your membership;
c. whether you have ever held any office therein and, if so, the title of the office
and the inclusive dates you have held such office, or provide your curriculum
vitae including such information.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, see attached CV.
11. With respect to any medical specialty board or other specialty board, state for each
such board, whether you were refused or granted such certification, the reasons therefor, and,
if granted such certification, your title or rank (e.g., diplomate, fellow, member), and whether
you still hold such certification, title, or rank.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, No.
12. During the past 10 years have you ever had your privileges or application for
privileges or employment denied, revoked, restricted, suspended, or limited in any way at
any hospital or medical facility?
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, No.
13. State whether at the time of the negligence alleged in the Complaint you were an
officer, shareholder, employee, member, partner, or otherwise affiliated with any entity or
person involved in the care and treatment of the Plaintiff.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, No.
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14. During the 10 years prior to the negligence alleged in the Complaint, have you ever
had your license or application for a license denied, revoked, restricted, suspended, or limited
in any way in any jurisdiction?
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that
is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
16. With respect to the negligence alleged in the Complaint, did you ever consult with
any physician or other health care provider regarding your diagnosis, care, or treatment that
is not documented in the medical record? If so, identify the person consulted and their
specialty as well as the reason for said consult.
OBJECTION: This Interrogatory is objectionable insofar as it is overbroad and unduly
burdensome. Furthermore, it seeks information that is not reasonably calculated to lead
to the discovery of admissible evidence and is not proportional to the needs of the case.
This Interrogatory is further objectionable in that it seeks information protected by the
peer review privilege, pursuant to Connecticut General Statutes § 19a-17b.
The foregoing objection notwithstanding, No. See St. Mary’s Hospital Chart of
June 28, 2020 for all care and treatment.
18. If you are covered by an insurance policy under which an insurer may be liable to
satisfy part or all of a judgment or reimburse you for payments to satisfy part or all of a
judgment relating to the negligence alleged in the Complaint, state the following:
a. the name(s) and address(es) of the insured(s);
b. the amount of coverage under each insurance policy;
c. the name(s) and address(es) of said insurer(s).
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is
not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, see attached Declaration Page.
19. If you are covered by excess or umbrella insurance, or any other insurance relating to
the negligence alleged in the Complaint, state:
a. the name(s) and address(es) of the named insured;
b. the amount of coverage effective at this time;
c. the name(s) and address(es) of said insurer(s).
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is
not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, None.
20. As to each policy identified in response to the preceding two interrogatories, state
whether:
a. any disclaimer or reservation of rights letter has been issued; and
b. it is an eroding policy.
OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is
not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to
the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing notwithstanding, No.
21. Pursuant to Conn. Gen. Stat. § 19a-17b, were your staff privileges terminated or
restricted by a medical review committee conducting a peer review with respect to the
negligence alleged in the Complaint? If so, please disclose the specific restriction imposed,
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if any.
OBJECTION: This Interrogatory is objectionable insofar as it is overbroad and unduly
burdensome. Furthermore, it seeks information that is not reasonably calculated to lead
to the discovery of admissible evidence and is not proportional to the needs of the case.
This Interrogatory is further objectionable in that it seeks information protected by the
peer review privilege, pursuant to Connecticut General Statutes § 19a-17b.
The foregoing objection notwithstanding, N/A.
22. Have you been sued for medical negligence arising out of your conduct as a
healthcare provider? If so, state the caption, venue and docket number of any such suit.
OBJECTION: This Interrogatory is objectionable insofar as it is overbroad and unduly
burdensome. Furthermore, it seeks information that is not reasonably calculated to lead
to the discovery of admissible evidence and is not proportional to the needs of the case.
The foregoing objection notwithstanding, No.
23. Have you made any statements, as defined in Practice Book Section 13-1, to any
person regarding any of the allegations in the Complaint?
COMMENT: This interrogatory is intended to include party statements made to a
representative of an insurance company prior to involvement of defense counsel.
OBJECTION: This Interrogatory is objectionable in that it seeks information protected
by the peer review privilege, pursuant to Connecticut General Statutes § 19a-17b.
The foregoing objection notwithstanding, No.
24. If the answer to the previous interrogatory is affirmative, state:
a. the name and address of the person or persons to whom such statements were
made;
b. the date on which such statements were made;
c. the form of the statement (i.e., whether written, made by recording device or
recorded by a stenographer, etc.);
d. the name and address of each person having custody, or a copy or copies of
each statement.
OBJECTION: This Interrogatory is objectionable in that it seeks information protected
by the peer review privilege, pursuant to Connecticut General Statutes § 19a-17b.
The foregoing objection notwithstanding, N/A.
25. Other than those individuals referenced in the medical record, state the names and
addresses of all persons known to you who were present at the time of the negligence alleged
in the Complaint or who observed or witnessed all or part of the negligence alleged in the
Complaint.
OBJECTION: This request is objectionable insofar as it is overbroad and unduly
burdensome. Furthermore, the documentation sought may be obtained with
substantially greater facility by the Plaintiff than it may by the Defendant.
The foregoing objection notwithstanding, please refer to the 6.28.20 St. Mary’s Hospital
Chart.
27. State whether the Plaintiff was referred to you, if so, state the person or entity that
made the referral and the date thereof.
OBJECTION: This request is objectionable insofar as it is overbroad and unduly
burdensome. Furthermore, the information sought may be obtained with substantially
greater facility by the Plaintiff than it may by the Defendant.
The foregoing objection notwithstanding, No.
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28. Did you create, use, or maintain any "electronic protected health information"
[hereinafter "health information"], as defined in 45 C.F.R. § 160.103, during your treatment
of Plaintiff?
OBJECTION: This request is objectionable insofar as it is overbroad and unduly
burdensome. Furthermore, the information sought may be obtained with substantially
greater facility by the Plaintiff than it may by the Defendant.
The foregoing objection notwithstanding, yes, entries were made using St. Mary’s
Hospital EMR.
29. If the answer to the previous interrogatory is in the affirmative, list the names of any
and all electronic "information system(s)" [hereinafter "EMR system(s)"], as defined in 45
C.F.R. § 164.304, that contain or previously contained the health information of the Plaintiff.
OBJECTION: This request is objectionable insofar as it is overbroad and unduly
burdensome. Furthermore, the information sought may be obtained with substantially
greater facility by the Plaintiff than it may by the Defendant.
The foregoing objection notwithstanding, upon information and belief, EPIC.
30. Identify the medical provider(s), database manager(s), or other administrator(s)
whose job responsibilities include performing queries of Defendant's audit database of EMR
system(s) at the time the interrogatory is answered.
ANSWER: OBJECTION: This request is objectionable insofar as it is overbroad and
unduly burdensome. Furthermore, the information sought may be obtained with
substantially greater facility by the Plaintiff than it may by the Defendant.
The foregoing objection notwithstanding, unknown to this Defendant.
OBJECTIONS TO REQUESTS FOR PRODUCTION
The Defendant hereby objects to the Plaintiff’s requests for production as follow:
1. Provide your current curriculum vitae.
OBJECTION: This Request is objectionable insofar as it seeks information that is not
reasonably calculated to lead to the discovery of admissible evidence and is not
proportional to the needs of the case.
The foregoing objection notwithstanding, see attached CV.
2. All non-privileged documents that you know of, possess, or have power to
obtain, not subject to attorney-client or statutory privilege, concerning the
Plaintiff’s care, scheduling, appointments, treatment, evaluation, diagnosis,
consultation or referral to others, including but not limited to:
a. All documents normally maintained as part of a patient's chart;
b. Office management records including jackets, file covers, face sheets,
transmittal documents for any requests for studies or consultations,
transportation records;
c. Nursing notes;
d. Hospital records;
e. Laboratory records;
f. Testing records;
g. Radiology requisitions, reports, and images/studies (lossless images), an
audio recordings of radiology reviews;
h. Notes, post-its, or written markings;
i. Pharmacy medication records;
j. Automated medication dispensing system records;
k. Any images/photographs taken during treatment or pathological
examination;
l. Pathology reports;
m. Drafts and/or audio recordings of pathology reports;
n. Quality improvement documents related to root cause analysis not part of
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the peer review process;
o. Documents provided in connection with a peer review, other than those
prepared as part of the peer review process;
p. Intra-department transportation records;
q. Laboratory test results;
r. Documents and communications concerning the Plaintiff and the allegations
in the complaint; and
s. Investigations or reports concerning the incident that is the subject of this
lawsuit.
OBJECTION: This Request is objectionable insofar as it is overbroad and unduly
burdensome. Furthermore, the documentation sought may be obtained with
substantially greater facility by the Plaintiff than it may by the Defendant.
The foregoing objection notwithstanding, none other than the St. Mary’s Hospital
charts which are maintained by St. Mary’s Hospital
4. A copy of the declaration page(s) of each insurance policy identified in response to
Interrogatories #18 and 19.
OBJECTION: See objection to Interrogatory Nos. 18 and 19.
The foregoing objection notwithstanding, see attached Declaration Page
5. If the answer to Interrogatory # 20 is in the affirmative, a copy of the complete policy
contents of each insurance policy identified in response to Interrogatory #19 and 20.
OBJECTION: See objection to Interrogatory Nos. 19 and 20.
The foregoing objection notwithstanding, see attached Declaration Page.
6. Each non-privileged statement identified in response to Interrogatories #24 and 26.
OBJECTION: See objection to Interrogatory Nos. 24 and 26.
THE DEFENDANTS,
MIDDLE CT EMERGENCY
PHYSICIANS, LLC, SARAH
GARCEAU, PA-C, DYLAN STEMPEL,
PA-C, ANGELA QUATROCELLI, M.D.
By /s/306542
Frederick J. Trotta, Sr., Esq.
HALLORAN & SAGE LLP
One Century Tower
265 Church Street, Suite 802
New Haven, CT 06510
Tel: 203-672-5432
Fax: 203-672-5480
Email: trotta@halloransage.com
Their Attorney- Juris No. 432591
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CERTIFICATION
I hereby certify that a copy of the above was mailed or electronically delivered on this
date to all counsel and pro se parties of record and that written consent for electronic delivery
was received from all counsel and pro se parties of record who were electronically served.
Thomas P. Cella, Esq.
Howard, Kohn, Sprague & Fitzgerald, LLP
237 Buckingham Street
Hartford, CT 06126
Tel: 860-525-3101
Fax: 860-247-4201
Email: tpc@hksflaw.com
For the Plaintiffs
Michael D. Neubert, Esq.
Neubert Pepe & Monteith, P.C.
195 Church Street, 13th Floor
New Haven, CT 06510
Tel: 203-821-2000
Fax: 203-821-2009
Email: mneubert@npmlaw.com
For the Defendants: St. Mary’s Hospital, Inc., Trinity Health of New England
Corporation, Inc., and Mark Stevens, PA
/s/306542
FREDERICK J. TROTTA, SR., ESQ.
Commissioner of the Superior Court
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DOCKET NO.: UWY-CV21-6060768-S : SUPERIOR COURT CYNTHIA BROWN, CONSERVATOR : J.D. OF WATERBURY OF THE PERSON AND ESTATE OF ELIZABETH STEWART, CYNTHIA BROWN, INDIVIDUALLY, AND EDWARD STEWART VS. : AT WATERBURY SAINT MARY’S HOSPITAL, INC., ET AL : FEBRUARY 1, 2022 DEFENDANT ANGELA QUATROCELLI, M.D.’S OBJECTIONS TO PLAINTIFF’S I&P DATED JULY 2, 2021 Pursuant to Practice Book §13-8, the undersigned, Defendant, Angela Quatrocelli, M.D., hereby objects to the Plaintiff’s Interrogatories and Production dated July 2, 2021. 1. State the following: b. your date of birth; (b) OBJECTION This Interrogatory is objectionable insofar as it seeks personal identifying information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. Unless the information is provided in your CV, respond to questions 3 through 11. 2. State the name of each college and graduate school you attended, the date of graduation, and each degree obtained, or provide your curriculum vitae including such information. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. 1 The foregoing objection notwithstanding, see attached CV. 3. State the name and address of each medical institution where you underwent post- graduate training (e.g., internship, residency, fellowship, or similar training), and the dates of attendance, or provide your curriculum vitae including such information. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, see attached CV. 4. State whether you have had training in a medical or surgical specialty, identify the specialty, state the dates you have practiced the specialty, and the name and address of each institution where you were trained, or provide your curriculum vitae including such information. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, see attached CV. 5. State whether you have ever specialized in or limited your practice to a particular field or branch of medicine or surgery and, if so, for each specialized or limited practice, state the field or branch of medicine or surgery, the inclusive dates you have so practiced, and the location of each place where you so practiced in the past 10 years, or provide your curriculum vitae including such information. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, see attached CV. 6. State whether you have ever been associated with or connected in a teaching capacity with any medical institutions. If so, for each institution, state: a. the name and address of the institution; b. the inclusive dates of your association; and c. the title held in each position, or provide your curriculum vitae including such information. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, see attached CV. 7. State the name and location of any hospital or medical facility at which you have or have had privileges and/or where you have worked in the past 10 years, and the dates thereof, or provide your curriculum vitae including such information. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, see attached CV. 8. Identify each medical book, paper, article, or other document that you have published, written, or to which you have contributed, and for each, state the title, whether you were an author, co-author, or contributor, or provide your curriculum vitae including such 3 information. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, see attached CV. 9. State the name of every jurisdiction in which you are or have been licensed as a health care provider, or provide your curriculum vitae including such information. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, see attached CV. 10. State whether you are, or have ever been, a member of any medical or other health care provider association, society or organization, and if so, as to each such membership, state: a. the name and address of the medical or other health care provider association, society, or organization; b. the inclusive dates of your membership; c. whether you have ever held any office therein and, if so, the title of the office and the inclusive dates you have held such office, or provide your curriculum vitae including such information. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, see attached CV. 11. With respect to any medical specialty board or other specialty board, state for each such board, whether you were refused or granted such certification, the reasons therefor, and, if granted such certification, your title or rank (e.g., diplomate, fellow, member), and whether you still hold such certification, title, or rank. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, No. 12. During the past 10 years have you ever had your privileges or application for privileges or employment denied, revoked, restricted, suspended, or limited in any way at any hospital or medical facility? OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, No. 13. State whether at the time of the negligence alleged in the Complaint you were an officer, shareholder, employee, member, partner, or otherwise affiliated with any entity or person involved in the care and treatment of the Plaintiff. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, No. 5 14. During the 10 years prior to the negligence alleged in the Complaint, have you ever had your license or application for a license denied, revoked, restricted, suspended, or limited in any way in any jurisdiction? OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. 16. With respect to the negligence alleged in the Complaint, did you ever consult with any physician or other health care provider regarding your diagnosis, care, or treatment that is not documented in the medical record? If so, identify the person consulted and their specialty as well as the reason for said consult. OBJECTION: This Interrogatory is objectionable insofar as it is overbroad and unduly burdensome. Furthermore, it seeks information that is not reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. This Interrogatory is further objectionable in that it seeks information protected by the peer review privilege, pursuant to Connecticut General Statutes § 19a-17b. The foregoing objection notwithstanding, No. See St. Mary’s Hospital Chart of June 28, 2020 for all care and treatment. 18. If you are covered by an insurance policy under which an insurer may be liable to satisfy part or all of a judgment or reimburse you for payments to satisfy part or all of a judgment relating to the negligence alleged in the Complaint, state the following: a. the name(s) and address(es) of the insured(s); b. the amount of coverage under each insurance policy; c. the name(s) and address(es) of said insurer(s). OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, see attached Declaration Page. 19. If you are covered by excess or umbrella insurance, or any other insurance relating to the negligence alleged in the Complaint, state: a. the name(s) and address(es) of the named insured; b. the amount of coverage effective at this time; c. the name(s) and address(es) of said insurer(s). OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, None. 20. As to each policy identified in response to the preceding two interrogatories, state whether: a. any disclaimer or reservation of rights letter has been issued; and b. it is an eroding policy. OBJECTION: This Interrogatory is objectionable insofar as it seeks information that is not relevant to the parties’ claims or defenses nor is it reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing notwithstanding, No. 21. Pursuant to Conn. Gen. Stat. § 19a-17b, were your staff privileges terminated or restricted by a medical review committee conducting a peer review with respect to the negligence alleged in the Complaint? If so, please disclose the specific restriction imposed, 7 if any. OBJECTION: This Interrogatory is objectionable insofar as it is overbroad and unduly burdensome. Furthermore, it seeks information that is not reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. This Interrogatory is further objectionable in that it seeks information protected by the peer review privilege, pursuant to Connecticut General Statutes § 19a-17b. The foregoing objection notwithstanding, N/A. 22. Have you been sued for medical negligence arising out of your conduct as a healthcare provider? If so, state the caption, venue and docket number of any such suit. OBJECTION: This Interrogatory is objectionable insofar as it is overbroad and unduly burdensome. Furthermore, it seeks information that is not reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, No. 23. Have you made any statements, as defined in Practice Book Section 13-1, to any person regarding any of the allegations in the Complaint? COMMENT: This interrogatory is intended to include party statements made to a representative of an insurance company prior to involvement of defense counsel. OBJECTION: This Interrogatory is objectionable in that it seeks information protected by the peer review privilege, pursuant to Connecticut General Statutes § 19a-17b. The foregoing objection notwithstanding, No. 24. If the answer to the previous interrogatory is affirmative, state: a. the name and address of the person or persons to whom such statements were made; b. the date on which such statements were made; c. the form of the statement (i.e., whether written, made by recording device or recorded by a stenographer, etc.); d. the name and address of each person having custody, or a copy or copies of each statement. OBJECTION: This Interrogatory is objectionable in that it seeks information protected by the peer review privilege, pursuant to Connecticut General Statutes § 19a-17b. The foregoing objection notwithstanding, N/A. 25. Other than those individuals referenced in the medical record, state the names and addresses of all persons known to you who were present at the time of the negligence alleged in the Complaint or who observed or witnessed all or part of the negligence alleged in the Complaint. OBJECTION: This request is objectionable insofar as it is overbroad and unduly burdensome. Furthermore, the documentation sought may be obtained with substantially greater facility by the Plaintiff than it may by the Defendant. The foregoing objection notwithstanding, please refer to the 6.28.20 St. Mary’s Hospital Chart. 27. State whether the Plaintiff was referred to you, if so, state the person or entity that made the referral and the date thereof. OBJECTION: This request is objectionable insofar as it is overbroad and unduly burdensome. Furthermore, the information sought may be obtained with substantially greater facility by the Plaintiff than it may by the Defendant. The foregoing objection notwithstanding, No. 9 28. Did you create, use, or maintain any "electronic protected health information" [hereinafter "health information"], as defined in 45 C.F.R. § 160.103, during your treatment of Plaintiff? OBJECTION: This request is objectionable insofar as it is overbroad and unduly burdensome. Furthermore, the information sought may be obtained with substantially greater facility by the Plaintiff than it may by the Defendant. The foregoing objection notwithstanding, yes, entries were made using St. Mary’s Hospital EMR. 29. If the answer to the previous interrogatory is in the affirmative, list the names of any and all electronic "information system(s)" [hereinafter "EMR system(s)"], as defined in 45 C.F.R. § 164.304, that contain or previously contained the health information of the Plaintiff. OBJECTION: This request is objectionable insofar as it is overbroad and unduly burdensome. Furthermore, the information sought may be obtained with substantially greater facility by the Plaintiff than it may by the Defendant. The foregoing objection notwithstanding, upon information and belief, EPIC. 30. Identify the medical provider(s), database manager(s), or other administrator(s) whose job responsibilities include performing queries of Defendant's audit database of EMR system(s) at the time the interrogatory is answered. ANSWER: OBJECTION: This request is objectionable insofar as it is overbroad and unduly burdensome. Furthermore, the information sought may be obtained with substantially greater facility by the Plaintiff than it may by the Defendant. The foregoing objection notwithstanding, unknown to this Defendant. OBJECTIONS TO REQUESTS FOR PRODUCTION The Defendant hereby objects to the Plaintiff’s requests for production as follow: 1. Provide your current curriculum vitae. OBJECTION: This Request is objectionable insofar as it seeks information that is not reasonably calculated to lead to the discovery of admissible evidence and is not proportional to the needs of the case. The foregoing objection notwithstanding, see attached CV. 2. All non-privileged documents that you know of, possess, or have power to obtain, not subject to attorney-client or statutory privilege, concerning the Plaintiff’s care, scheduling, appointments, treatment, evaluation, diagnosis, consultation or referral to others, including but not limited to: a. All documents normally maintained as part of a patient's chart; b. Office management records including jackets, file covers, face sheets, transmittal documents for any requests for studies or consultations, transportation records; c. Nursing notes; d. Hospital records; e. Laboratory records; f. Testing records; g. Radiology requisitions, reports, and images/studies (lossless images), an audio recordings of radiology reviews; h. Notes, post-its, or written markings; i. Pharmacy medication records; j. Automated medication dispensing system records; k. Any images/photographs taken during treatment or pathological examination; l. Pathology reports; m. Drafts and/or audio recordings of pathology reports; n. Quality improvement documents related to root cause analysis not part of 11 the peer review process; o. Documents provided in connection with a peer review, other than those prepared as part of the peer review process; p. Intra-department transportation records; q. Laboratory test results; r. Documents and communications concerning the Plaintiff and the allegations in the complaint; and s. Investigations or reports concerning the incident that is the subject of this lawsuit. OBJECTION: This Request is objectionable insofar as it is overbroad and unduly burdensome. Furthermore, the documentation sought may be obtained with substantially greater facility by the Plaintiff than it may by the Defendant. The foregoing objection notwithstanding, none other than the St. Mary’s Hospital charts which are maintained by St. Mary’s Hospital 4. A copy of the declaration page(s) of each insurance policy identified in response to Interrogatories #18 and 19. OBJECTION: See objection to Interrogatory Nos. 18 and 19. The foregoing objection notwithstanding, see attached Declaration Page 5. If the answer to Interrogatory # 20 is in the affirmative, a copy of the complete policy contents of each insurance policy identified in response to Interrogatory #19 and 20. OBJECTION: See objection to Interrogatory Nos. 19 and 20. The foregoing objection notwithstanding, see attached Declaration Page. 6. Each non-privileged statement identified in response to Interrogatories #24 and 26. OBJECTION: See objection to Interrogatory Nos. 24 and 26. THE DEFENDANTS, MIDDLE CT EMERGENCY PHYSICIANS, LLC, SARAH GARCEAU, PA-C, DYLAN STEMPEL, PA-C, ANGELA QUATROCELLI, M.D. By /s/306542 Frederick J. Trotta, Sr., Esq. HALLORAN & SAGE LLP One Century Tower 265 Church Street, Suite 802 New Haven, CT 06510 Tel: 203-672-5432 Fax: 203-672-5480 Email: trotta@halloransage.com Their Attorney- Juris No. 432591 13 CERTIFICATION I hereby certify that a copy of the above was mailed or electronically delivered on this date to all counsel and pro se parties of record and that written consent for electronic delivery was received from all counsel and pro se parties of record who were electronically served. Thomas P. Cella, Esq. Howard, Kohn, Sprague & Fitzgerald, LLP 237 Buckingham Street Hartford, CT 06126 Tel: 860-525-3101 Fax: 860-247-4201 Email: tpc@hksflaw.com For the Plaintiffs Michael D. Neubert, Esq. Neubert Pepe & Monteith, P.C. 195 Church Street, 13th Floor New Haven, CT 06510 Tel: 203-821-2000 Fax: 203-821-2009 Email: mneubert@npmlaw.com For the Defendants: St. Mary’s Hospital, Inc., Trinity Health of New England Corporation, Inc., and Mark Stevens, PA /s/306542 FREDERICK J. TROTTA, SR., ESQ. Commissioner of the Superior Court