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`: SUPERIOR COURT
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`: J.D. OF STAMFORD/NORWALK
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`: AT STAMFORD
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`FST CV 20 6047763 S
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`EVA A. PASQUINO
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`V.
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`KRAMONT OPERATING
`PARTNERSHIP, LP, ET AL
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`: DECEMBER 28, 2021
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`DISCLOSURE OF EXPERT WITNESSES
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`The Plaintiff, Eva A. Pasquino, in accordance with the provisions of Connecticut Practice
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`Book §13-4(b)(2), discloses that she expects the following expert witnesses to testify at the trial of
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`this case, if necessary, either in person or through written documents
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`1. Sonny Ruskin, EMT, American Medical Response, 335 Connecticut Avenue,
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`Bridgeport, CT 06607;
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`2. Timothy Crouch, EMT, American Medical Response, 335 Connecticut Avenue,
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`Bridgeport, CT 06607;
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`3. Richard Katz, M.D., Stamford Hospital, 1 Hospital Plaza, Stamford, Connecticut
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`06902;
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`4. Jeffrey Kleinman, M.D., (Radiologist), Stamford Hospital, 1 Hospital Plaza,
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`Tel: (203) 333-3339 | Fax: (203) 324-1407 | Juris No. 106151
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`80 Fourth Street, Stamford, CT 06905
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`Wocl Leydon LLC
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`Stamford, Connecticut 06902;
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`5. Elizabeth Gaary, M.D., (Radiologist), Stamford Hospital, 1 Hospital Plaza, Stamford,
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`Connecticut 06902;
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`6. Lori Lambrinakos, P.T., Tully Health Center, 32 Strawberry Hill Court, Stamford,
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`Connecticut 06902;
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`7. Nina Inamadar, M.D., Northwell Health, 945 Summer Street, 3rd Floor, Stamford,
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`Connecticut 06905;
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`8. Christopher J. Palkimas, RPA-C, Northwell Health, 945 Summer Street, 3rd Floor,
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`Stamford, Connecticut 06905;
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`9. Moira McCarthy, M.D., Hospital for Special Surgery, 535 E. 70th Street, New York,
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`New York 10021;
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`10. Agnes Herceg, DDS, Advanced Endodontics & Microsurgery of Stamford, P.C., 44
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`Strawberry Hill Avenue, Suite 5, Stamford, Connecticut 06902;
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`11. Francesco Maratta, DMD, FACP, Stamford Dental Group, 47 Oak Street, Suite 220,
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`Stamford, Connecticut 06905;
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`12. Karen S. Nipper, M.D., Stamford Eye Associates, 999 Summer Street, Suite 105,
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`Stamford, Connecticut 06905.
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`It is expected that the disclosed healthcare providers enumerated within these records may
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`testify at trial and offer expert witness testimony at trial as to any opinions that they may have
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`arrived as set forth in the disclosed records.
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`It is expected that the experts will testify based upon their education, knowledge, training
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`and experience and based upon the history, examinations and treatment of the Plaintiff and a
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`review of the medical, radiological, hospital and diagnostic records of the Plaintiff. The experts
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`may utilize medical charts, diagrams, models and/or illustrations as demonstrative evidence during
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`the trial.
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`In addition these providers may testify as to the nature, extent, duration, permanency,
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`expense, cause, disability, treatment, effect upon lifestyle, limitation of activities, pain and
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`explanation of injuries and effected body parts of the Plaintiff's injuries. The providers will explain
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`the nature, mechanism, etiology and/or pathology of the Plaintiff’s injuries and the dynamics of
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`how the injuries occurred. The providers will discuss the anatomy of the Plaintiff and his injured
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`2
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`Tel: (203) 333-3339 | Fax: (203) 324-1407 | Juris No. 106151
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`80 Fourth Street, Stamford, CT 06905
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`Wocl Leydon LLC
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`body parts. The medical providers will discuss the reasonableness of the treatment the Plaintiff
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`received to date. Additionally, the experts may testify as to the probable cost of future treatment,
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`its expected duration and why future treatment is necessary. The experts may opine as to the
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`permanent partial disability ratings and/or loss of function assigned to the Plaintiff’s injuries
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`caused by this incident. If the Plaintiff has pre-existing conditions, the expert will testify how
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`those conditions may have been affected by this incident. The substance of the facts and opinions
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`they will testify to are set forth in the records and reports previously disclosed or to be disclosed as
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`well as the allegations in the Plaintiff's complaint and/or Amended Complaint, including, but not
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`limited to that the Plaintiff has suffered significant, painful, and/or permanent injuries attributable
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`to the incident complained of. The Plaintiff anticipates introducing their office notes, reports,
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`records, and bills regarding any treatment of the Plaintiff.
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`In addition to the above mentioned, any other provider of medical services who has been or
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`may be disclosed to the Defendant may testify as to the nature, extent, duration, permanency,
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`expense, cause, disability, treatment, effect upon lifestyle, limitation of activities, pain and
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`explanation of injuries and effected body parts of the Plaintiff's injuries. The providers will explain
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`the nature, mechanism, etiology and/or pathology of the Plaintiff’s injuries and the dynamics of
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`how the injuries occurred. The providers will discuss the anatomy of the Plaintiff and his injured
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`body parts. The medical providers will discuss the reasonableness of the treatment the Plaintiff
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`received to date. Additionally, the experts may testify as to the probable cost of future treatment,
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`its expected duration and why future treatment is necessary. The experts may opine as to the
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`permanent partial disability ratings and/or loss of function assigned to the Plaintiff’s injuries
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`caused by this incident. If the Plaintiff has pre-existing conditions, the expert will testify how
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`those conditions may have been affected by this incident. The substance of the facts and opinions
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`3
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`Tel: (203) 333-3339 | Fax: (203) 324-1407 | Juris No. 106151
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`80 Fourth Street, Stamford, CT 06905
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`Wocl Leydon LLC
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`they will testify to are set forth in the records and reports previously disclosed or to be disclosed as
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`well as the allegations in the Plaintiff's complaint and/or Amended Complaint, including, but not
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`limited to that the Plaintiff has suffered significant, painful, and/or permanent injuries attributable
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`to the incident complained of. The Plaintiff anticipates introducing their office notes, reports,
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`records, and bills regarding any treatment of the Plaintiff.
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`THE PLAINTIFF,
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` BY /s/ Anastasios T. Savvaides
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`Anastasios T. Savvaides, Esq.
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`Wocl Leydon, LLC
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`80 Fourth Street
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`Stamford, CT 06905
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`203.333.3339
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`Juris No.: 106151
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`CERTIFICATION
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`This is to certify that a copy of the foregoing was mailed and/or emailed on this date to:
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`Tel: (203) 333-3339 | Fax: (203) 324-1407 | Juris No. 106151
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`80 Fourth Street, Stamford, CT 06905
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`Wocl Leydon LLC
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`Timothy R. Scannell, Esq.
`Boyle Shaughnessy
`280 Trumbull Street, 23rd Floor
`Hartford, CT 06103
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`Joseph M. Musco, Esq.
`Musco & Iassogna
`555 Long Wharf Drive, 10th Floor
`New Haven, CT 06511
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`Gina M. Galullo, Esq.
`Law Offices of Jeffrey Apuzzo
`10 Waterside Drive, Suite 102
`Farmington, CT 06032
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`/s/ Anastasios T. Savvaides
`Anastasios T. Savvaides, Esq.
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`4
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