Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:01-cv-01979-WWE

Document 83

Filed 08/31/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT KARL HOGFELDT v. OLD SAYBROOK POLICE DEPARTMENT; ET AL : : : : : : NO.: 3:01 CV 1979 (WWE)

AUGUST 30, 2005

DEFENDANTS' MOTION TO AMEND DEFENDANTS' COMPLIANCE WITH PRETRIAL ORDER The Defendants in the above matter respectfully move this Court to amend their Compliance with Pretrial Order dated May 17, 2005, to include the Plaintiff's medical records, ambulance run sheet and police reports from incidents dated September 24, 1998, to May 9, 2003, as exhibits they intend to offer at trial for the following reasons: 1. Defendants obtained said documents by way of subpoena after plaintiff failed to respond to many requests to provide sufficient HIPAA compliant authorization to obtain such records. 2. Defendants only recently obtained said records. 3. Said records are relevant to the issues of liability and damages in this case. 4. Plaintiff suffered no prejudice from any alleged late disclosure as the records are Plaintiff's own medical records and documents related to incidents that Plaintiff was fully aware existed.

ORAL ARGUMENT IS REQUESTED

Case 3:01-cv-01979-WWE

Document 83

Filed 08/31/2005

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WHEREFORE, the Defendants request that an order be entered amending Defendants Compliance with Pretrial order to include Exhibit A. (Attached).

THE DEFENDANTS, OLD SAYBROOK POLICE DEPARTMENT, SERGEANT DONALD HULL, PATROLMAN DAVID PERRROTTI, PATROLMAN CHRIS DEMARCO, PATROLMAN JAY RANKIN and THE TOWN OF OLD SAYBROOK

By__/s/ Jeffrey E. Potter_________ Jeffrey E. Potter, ct 26356 HOWD & LUDORF, LLC 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (fax) [email protected]

Case 3:01-cv-01979-WWE

Document 83

Filed 08/31/2005

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via U.S. Mail to the following counsel of record this 30th day of August 2005. Bruce E. Newman, Esquire Newman, Creed & Associates 99 North Street, Route 6 P.O. Box 575 Bristol, CT 06011 A. Paul Spinella, Esquire Spinella & Associates One Lewis Street Hartford, CT 06103

By__/s/ Jeffrey E. Potter____ Jeffrey E. Potter