RETURN DATE: MAY 5, 2015 : SUPERIOR COURT · PDF file1 return date: may 5, 2015 : superior court michael a. palmer, ii, : judicial district administrator of the estate of of fairfield

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RETURN DATE: MAY 5, 2015 : SUPERIOR COURT

MICHAEL A. PALMER, II, : JUDICIAL DISTRICT

ADMINISTRATOR OF THE ESTATE OF OF FAIRFIELD

MICHAEL A. PALMER, SR., DECEASED :

VS. : AT BRIDGEPORT

SCA, INC.; SURGICAL CARE

AFFILIATES, LLC; SURGERY CENTER :

OF FAIRFIELD COUNTY, LLC;

SANDRA JOYCE CONGDON, MD; :

FAIRFIELD ANESTHESIA ASSOCIATES, LLC;

GERARD J. GIRASOLE, MD; :

THE ORTHOPAEDIC & SPORTS MEDICINE

CENTER, P.C.; ABRAHAM MINTZ, MD;

ABRAHAM MINTZ, M.D., P.C. : MARCH 27, 2015

COMPLAINT

COUNT I: (MICHAEL A. PALMER, II, ADMINISTRATOR OF THE ESTATE OF

MICHAEL A. PALMER, SR., DECEASED VS. SCA, INC. AND SURGICAL CARE

AFFILIATES, LLC; SURGERY CENTER OF FAIRFIELD COUNTY, LLC)

1. On or about, June 24, 2013, the plaintiff, MICHAEL A. PALMER, II, was appointed

Administrator of the Estate of his father, MICHAEL A. PALMER, SR., by the Court of Probate,

District of Stratford, Connecticut. (A copy of said appointment is attached hereto as Exhibit A.)

2. This wrongful death claim is being brought pursuant to Connecticut General Statutes §52-555.

3. Prior to his death on or about May 6, 2013, at age 53, the plaintiff’s decedent, MICHAEL A.

PALMER, SR., had been a long-time resident of Connecticut, the father of eight children, and

was employed as a bus driver for Connecticut Transit Authority.

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4. At all times mentioned herein, the defendant, SCA, Inc., was a Delaware Corporation that, along

with SURGICAL CARE AFFILIATES, LLC, operated approximately 185 surgical facilities,

including outpatient surgery centers throughout the United States, one of which was the

SURGERY CENTER OF FAIRFIELD COUNTY, LLC, (collectively referred to hereinafter as

the SURGERY CENTER), and was licensed to do business in the State of Connecticut.

5. The SURGERY CENTER was established for the purpose of providing selected patients with a

safe venue for out-patient surgical procedures in which to perform specific low-risk procedures

that did not require in-patient or overnight stays.

6. In order to determine which procedures were safe to perform at the center, the Governing Body

of the SURGERY CENTER reviewed the proposed procedures and compiled a list of approved

procedures with protocols for performing those procedures.

7. In furtherance of its goals, the SURGERY CENTER employed and engaged the services of

nurses, physicians, anesthesia personnel, and others as their agents, apparent agents, servants and

employees, and provided facilities and equipment for the performance of out-patient surgery.

8. In furtherance of its goals, the SURGERY CENTER also entered into joint-ventures and/or co-

management agreements with the other individuals, partnerships, LLC’s, and corporate

defendants, herein.

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9. At all times mentioned herein the defendant, GERARD J. GIRASOLE, MD., a part owner of the

SURGICAL CENTER, was an orthopedic surgeon who was employed by the defendant, THE

ORTHOPAEDIC & SPORTS MEDICINE CENTER, P.C., and was agent, apparent agent,

servant and employee of the SURGERY CENTER, and together with THE ORTHOPAEDIC &

SPORTS MEDICINE CENTER, P.C., was engaged in a joint-venture or other co-management

agreement with the SURGERY CENTER.

10. At all times mentioned herein the defendant, SANDRA JOYCE CONGDON, MD, was an

employee of the defendant, FAIRFIELD ANESTHESIA ASSOCIATES, LLC, and was agent,

apparent agent, servant and employee of the SURGERY CENTER, and, together with the

defendant, FAIRFIELD ANESTHESIA ASSOCIATES, LLC, was engaged in a joint-venture or

other co-management agreement with the SURGERY CENTER, and was part owner of the

SURGERY CENTER.

11. At all times mentioned herein the defendant, ABRAHAM MINTZ, MD, was an employee of

ABRAHAM MINTZ, M.D., P.C., and was agent, apparent agent, servant and employee of the

SURGERY CENTER and, together with ABRAHAM MINTZ, M.D., P.C., was engaged in a

joint venture and/or other co-management agreement with the SURGERY CENTER and was

part owner of the SURGERY CENTER,

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12. On or about April 13, 2013, and prior thereto, the plaintiff’s decedent, MICHAEL A. PALMER,

SR., was under the care and treatment of the defendant, GERARD J. GIRASOLE, MD, for a

problem involving pain in the cervical spinal.

13. The defendant, GERARD J. GIRASOLE, MD, prescribed a surgical procedure called an

“anterior discectomy and fusion” (ACDF) of the cervical spine at levels 3-4 and 4-5.

14. The plaintiff’s decedent, MICHAEL A. PALMER, SR., requested that the procedure be done at

St. Vincent’s Hospital; however, the defendant, GERARD J. GIRASOLE, M.D., advised him

that his insurance would not cover the procedure at St. Vincent’s Hospital and it needed to be

done in an outpatient facility, specifically the SURGERY CENTER.

15. On or about April 26, 2013 and for some time prior thereto, the plaintiff ‘s decedent, Michael A.

Palmer, was under the care of ABRAHAM MINTZ, MD., who was retained for the purpose of

performing the neurosurgical portion of the operation.

16. On May 6, 2013, the plaintiff’s decedent, MICHAEL A. PALMER, SR., arrived at the

SURGERY CENTER as directed. The SURGERY CENTER assigned the defendant, SANDRA

JOYCE CONGDON, MD, to serve as anesthesiologist for the plaintiff’s decedent, MICHAEL A.

PALMER, SR.

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17. The plaintiff’s decedent, MICHAEL A. PALMER, SR., was offered no choice regarding the

anesthesiologist who would perform the anesthesia at his surgery, had never before met the

defendant, SANDRA JOYCE CONGDON, MD., and reasonably assumed that SANDRA

JOYCE CONGDON, MD, was an employee of the SURGERY CENTER and/or was under the

control and supervision of the SURGERY CENTER.

18. During the course of the surgical procedure, while under general anesthesia, a surgical assistant

pressed against the blood pressure cuff causing the reading to drop on the blood pressure

monitor, whereupon the defendant, SANDRA JOYCE CONGDON, MD, negligently

administered a bolus of 4% Lidocaine, a toxic agent, mistaking it for the agent, Hespan.

19. When the plaintiff’s decedent began to react to the toxic agent the defendant, SARAH JOYCE

CONGDON, MD., called a “code blue,” administered emergency treatment to the plaintiff’s

decedent and ultimately called an ambulance to take plaintiff’s decedent, to St. Vincent’s

Hospital for emergency care.

20. After arriving at St. Vincent’s Hospital the plaintiff’s decedent expired.

21. The death of the plaintiff’s decedent, MICHAEL A. PALMER, SR., was caused by the

negligence, corporate negligence and malpractice of the defendants, SCA, INC and SURGICAL

CARE AFFILIATES, LLC, and the SURGERY CENTER, and its nurses, agents, servants,

apparent agents, joint venturers and employees in that they:

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a. failed to adequately and properly care for, treat, monitor, and supervise the

plaintiff’s decedent, MICHAEL A. PALMER, SR., before, during, and after the

procedure in which general anesthesia was administered;

b. violated Section 18-13-D56(c) of the Public Health Regulations of the State of

Connecticut by permitting the co–defendants to perform a double level ACDF on

the plaintiff’s decedent, MICHAEL A. PALMER, SR., even though ACDF’S had

not been approved or authorized by the Governing Body of the SURGERY

CENTER;

c. permitted the performance of the procedure even though the facility was not

properly equipped or prepared for said procedure;

d. failed to perform the surgery in a hospital as requested by the plaintiff’s decedent,

MICHAEL A. PALMER, SR.;

e. permitted the defendants to perform a double level ACDF even though it is a

procedure that carries considerable risk and often requires overnight stays in a

hospital;

f. permitted the defendants to perform the ACDF on the plaintiff’s decedent even

though he was not a fit candidate to have it performed in an outpatient setting;

g. failed to provide a properly set up operating room with necessary anesthetic

agents properly labeled, organized and readily available;

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h. failed to provide proper nursing, pharmacy, and anesthesia support staff to assist

the defendant, SANDRA JOYCE CONGDON, MD, in organizing the anesthetic

agents and in the performance of the anesthesia;

i. permitted 4% Lidocaine infusion bags to be in close proximity to drugs and

agents used for resuscitation, specifically Hespan;

j. provided and administered 4% Lidocaine to the plaintiff intravenously even

though it was toxic and inappropriate for use in this surgery;

k. failed to warn the anesthesiologist that 4% Lidocaine was being administered;

l. failed to inspect the operating suite to determine that the pharmaceutical agents to

be used and available for emergencies were the appropriate and necessary ones

for the surgery;

m. failed to adequately and properly assess, determine the cause of and treat the

decline in blood pressure that was shown on the blood pressure monitor;

n. failed to have in place and implement an adequate and proper plan to treat

medical, surgical and/or anesthesia complications and emergencies if they

occurred;

o. failed to have adequate and proper personnel and equipment to handle a medical,

surgical and/or anesthesia emergencies, including a well-trained code team and a

properly equipped code cart to handle medical emergencies ;

p. failed to have and enforce adequate rules, regulations and protocols to provide for

timely transfer in the event of medical emergencies;

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q. failed to timely call for an ambulance to transport the patient to the hospital

following the medical emergency;

r. failed to communicate to the ambulance personnel and St. Vincent’s Hospital the

cause of the plaintiffs emergent condition;

s. negligently misdiagnosed the cause of the reduced blood pressure shown on the

monitor;

t. negligently treated the plaintiff for hypovolemia that did not exist;

u. failed to administer intralipid to the plaintiff’s decedent, MICHAEL A. PALMER,

SR., following the administration of the 4% Lidocaine;

v. allowed surgeons with ownership interests in the SURGERY CENTER to

perform surgery without rules, regulations, protocols or supervision to prevent

conflicts of interest;

w. failed to have a functioning pharmacy, and/or anesthesia techs to provide for the

correct medications to be on hand and properly organized and to supervise the

administration of medications in the operating room;

x. failed to have properly trained nurses of other personnel to warn the defendant,

SANDRA JOYCE CONGDON, MD, that she was administering the wrong

medication;

y. failed to stock intralipid and have it on hand to reverse the effects of the 4%

Lidocaine infusion;

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z. failed adopt policies and practices insuring checks and balances, and redundancy

to prevent medication errors;

aa. failed to promulgate and/or enforce rules, regulations, standards and protocols for

the treatment of patients such as MICHAEL A. PALMER, SR.

22. As a result of the carelessness and negligence of the defendant, SCA, Inc. and SURGICAL

CARE AFFILIATES, LLC, and the defendant, SURGERY CENTER, and its servants, agents,

apparent agents, joint venturers and/or employees, the plaintiff’s decedent, MICHAEL A.

PALMER, SR., suffered the following severe, serious, painful and permanent injuries:

a. respiratory depression and failure;

b. severe hypotension;

c. pulmonary edema;

d. cerebral edema;

e. hypoxia;

f. respiratory and cardiac arrest;

g. death.

23. As a result of the aforementioned injuries and death, the plaintiff’s decedent, MICHAEL A.

PALMER, SR., has been permanently deprived of his ability to carry on and enjoy life’s

activities and his earning capacity has been forever destroyed.

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24. As a further result of the aforesaid injuries and death of the plaintiff’s decedent, MICHAEL A.

PALMER, SR., his Estate has incurred expenses for medical care and hospital treatment and for

funeral expenses, all to its financial loss.

COUNT II: (MICHAEL A. PALMER, II, ADMINISTRATOR OF THE ESTATE OF

MICHAEL A. PALMER, SR., DECEASED VS. SANDRA JOYCE CONGDON,

MD; FAIRFIELD ANESTHESIA ASSOCIATES, LLC)

1-20. Paragraphs 1-20 of Count I are hereby made Counts 1-20 of Count II.


negligence, and malpractice of the defendants, SANDRA JOYCE CONGDON, MD, and

FAIRFIELD ANESTHESIA ASSOCIATES, LLC, and their agents, servants, apparent agents,

joint venturers and employees in that they:




b. participated in the performance of a double level ACDF on the plaintiff’s

decedent, MICHAEL A. PALMER, SR., even though ACDF’S had not been

approved or authorized by the Governing Body of the SURGERY CENTER;

c. participated in the performance of the procedure even though the facility was not


d. failed to perform the surgery in a hospital as requested by the plaintiff’s decedent,

MICHAEL A. PALMER, SR.;

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e. participated in the performance of a double level ACDF even though it is a

procedure that carries considerable risk and often requires overnight stays in a

hospital;

f. participated in the performance of the ACDF on the plaintiff’s decedent even

though he was not a fit candidate to have it performed in an outpatient setting;

g. failed to provide a properly set up operating room with necessary anesthetic

agents properly labeled, organized and readily available;

h. failed to provide an appropriately equipped and designed operating table for a

man of the weight and size of the plaintiff’s decedent;

i. failed to arrange for proper nursing, pharmacy, and anesthesia support staff to

assist the defendant, SANDRA JOYCE CONGDON, MD, in organizing the

anesthetic agents and in the performance of the anesthesia;

j. permitted 4% Lidocaine infusion bags to be in close proximity to drugs and

agents used for resuscitation, specifically Hespan;

k. provided and administered 4% Lidocaine to the plaintiff intravenously even

though it was toxic and inappropriate for use in this surgery;

l. failed to inspect the agent she was administering to determine that it was 4%

Lidocaine and not Hespan;

m. failed to inspect the operating suite prior to surgery to determine that the

pharmaceutical agents to be used and available for emergencies were the

appropriate, necessary and properly organized for the surgery;

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n. failed to adequately and properly assess, determine the cause of, and treat the

decline in blood pressure that was shown on the blood pressure monitor;

o. failed to have in place and implement an adequate and proper plan to treat

anesthesia complications and emergencies if they occurred;

p. failed to have a properly equipped code cart to handle medical emergencies ;

q. failed to timely call for an ambulance to transport the patient to the hospital


r. failed to communicate to the ambulance personnel and St. Vincent’s Hospital the

cause of the plaintiffs emergent condition;

s. negligently misdiagnosed the cause of the reduced blood pressure shown on the

monitor;

t. negligently treated the plaintiff for hypovolemia that did not exist;

u. failed to administer intralipid to the plaintiff’s decedent, MICHAEL A.

PALMER, SR., following the administration of the 4% Lidocaine;

v. failed to have intralipid on hand to reverse the effects of the 4% Lidocaine

infusion;

w. failed adopt policies and practices insuring checks and balances, and redundancy

to prevent medication errors.

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22. The death of the plaintiff’s decedent, MICHAEL A. PALMER, SR., was due to the failure of the

defendant, SANDRA JOYCE CONGDON, MD, to obtain proper informed consent from

MICHAEL A. PALMER, SR., by failing to properly advise of the risks and alternatives to

having his surgery performed at the SURGERY CENTER as opposed to a hospital including, but

not limited to, his increased risk of injury due to his history of sleep apnea, size and weight; the

risk that medication errors were more likely because the SURGICAL CENTER did not have

inspection protocols and redundancy procedures in place to prevent medication errors; the risk

attendant to the fact that the Surgery Center had no emergency staff or code team readily

available in the event of an emergency; the risk of needing to be transported to a hospital in

event of an emergency; the risk of having no inspection of the operating suite prior to surgery;

and the risk of not having available a full range of pharmaceutical products and personnel to

handle emergencies should they occur; and the benefit of performing the procedure in a hospital

with experience, well-established procedures, protocols, and personnel for anesthesia, surgical

and emergency care.

23. As a result of the carelessness and negligence of the defendants, SANDRA JOYCE CONGDON,

MD, and FAIRFIELD ANESTHESIA ASSOCIATES, LLC, and their servants, agents, apparent

agents, joint venturers and/or employees, the plaintiff’s decedent, MICHAEL A. PALMER, SR.,

suffered the following severe, serious, painful and permanent injuries:



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c. pulmonary edema;

d. cerebral edema;

e. hypoxia;


g. death.





PALMER, SR., his estate has incurred expenses for medical care and hospital treatment, and for


COUNT III: (MICHAEL A. PALMER, II, ADMINISTRATOR OF THE ESTATE OF

MICHAEL A. PALMER, SR., DECEASED VS. GERARD J. GIRASOLE, MD; THE

ORTHOPAEDIC & SPORTS MEDICINE CENTER, P.C.)

1.-20. Paragraphs 1-20 of Count I are hereby made Counts 1-20 of Count III.


negligence, and malpractice of the defendants, GERARD J. GIRASOLE, MD; THE

ORTHOPAEDIC & SPORTS MEDICINE CENTER, P.C., and their agents, servants, apparent

agents, joint venturers and employees in that they:

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b. ordered the double-level ACDF to be performed at the SURGERY CENTER even

though the procedure was not on the list of procedures approved and authorized

by the Governing Body of the SURGERY CENTER;

c. proceeded to perform the unauthorized surgery even though the facility was not


d. arranged for the double-level ACDF at the SURGERY CENTER even though it is

a procedure that carries considerable risk and often requires over-night stays in a

hospital;

e. arranged for the double-level ACDF at the SURGERY CENTER even though the

plaintiff’s decedent was not a fit candidate to have the procedure performed at

THE SURGERY CENTER;

f. failed to perform the surgery at St. Vincent’s Hospital as requested by the

plaintiff’s decedent, MICHAEL A. PALMER, SR.;

g. miss-advised the plaintiff’s decedent, MICHAEL A. PALMER, SR., that the cost

of the surgery would not be covered by medical insurance if performed at St.

Vincent’s Hospital;

h. failed to have in place an adequate and proper plan to treat medical, surgical,

and/or anesthesia complications if they occurred;

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i. failed to timely call for an ambulance to transport the patient to the hospital


j. failed to render proper emergency treatment to the plaintiff’s decedent,

MICHAEL A. PALMER, SR., following the administration of the 4% Lidocaine;


defendant, GERARD J. GIRASOLE, MD, to obtain proper informed consent from MICHAEL

A. PALMER, SR., by failing to advise him of the risks and alternatives to having his surgery

performed at the SURGERY CENTER as opposed to a hospital including, but not limited to: his

increased risk of injury due to his history of sleep apnea, size and weight; the risk that

medication errors were more likely because the SURGICAL CENTER did not have inspection

protocols and redundancy procedures in place to prevent medication errors; the risk attendant to

the fact that the SURGERY CENTER had no emergency staff or code team readily available in

the event of an emergency; the risk of needing to be transported to a hospital in event of an

emergency; the risk of having no inspection of the operating suite prior to surgery; the risk that

the SURGERY CENTER lacked experience and expertise in preparing for and conducting

surgery of this type; the risk of not having available a full range of pharmaceutical products and

personnel to handle emergencies should they occur; the risk of performing unauthorized surgery;

the risk of performing a double-level ACDF when the SURGERY CENTER had not established

safety rules and protocols for its performance; the benefit of performing the procedure in a

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hospital with experience, well-established procedures, protocols, and personnel for anesthesia,

surgical and emergency care.

23. As a result of the carelessness and negligence of the defendants, GERARD J. GIRASOLE, MD;

THE ORTHOPAEDIC & SPORTS MEDICINE CENTER, P.C., and their servants, agents,

apparent agents, joint venturers and/or employees, the plaintiff’s decedent, MICHAEL A.

PALMER, SR., suffered the following severe, serious, painful and permanent injuries:



c. pulmonary edema;

d. cerebral edema;

e. hypoxia;


g. death.







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COUNT IV: (MICHAEL A. PALMER, II, ADMINISTRATOR OF THE ESTATE OF

MICHAEL A. PALMER, SR., DECEASED VS. ABRAHAM MINTZ, MD;

ABRAHAM MINTZ, M.D., P.C.)

1.-20. Paragraphs 1-20 of Count I are hereby made Counts 1-20 of Count IV.


negligence, and malpractice of the defendants, ABRAHAM MINTZ, MD; ABRAHAM MINTZ,

M.D., P.C., and their agents, servants, apparent agents, joint venturers and employees in that

they:




b. ordered the double-level ACDF to be performed at the SURGERY CENTER even

though the procedure was not on the list of procedures approved by the Governing

Body of the SURGERY CENTER;

c. proceeded to perform the unauthorized surgery even though the facility was not

properly equipped or ready for said procedure;

d. arranged for the double-level ACDF at the SURGERY CENTER even though it is

a procedure that caries considerable risk and often requires over-night stays in a

hospital;

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e. arranged for the double-level ACDF at the SURGERY CENTER even though the

plaintiff’s decedent was not a fit candidate to have the procedure performed at

THE SURGERY CENTER;

f. failed to perform the surgery at St. Vincent’s Hospital as requested by the

plaintiff’s decedent, MICHAEL A. PALMER, SR.;

g. miss-advised the plaintiff’s decedent, MICHAEL A. PALMER, SR., that the cost

of the surgery would not be covered if performed at St. Vincent’s Hospital;

h. failed to have in place an adequate and proper plan to treat medical, surgical,

and/or anesthesia complications if they occurred;

i. failed to timely call for an ambulance to transport the patient to the hospital


j. failed to render proper emergency treatment to the plaintiff’s decedent,

MICHAEL A. PALMER, SR., following the administration of the 4% Lidocaine;


defendant, ABRAHAM MINTZ, MD, to obtain proper informed consent from MICHAEL A.

PALMER, SR., by failing to advise him of the risks of having his surgery performed at the

SURGERY CENTER as opposed to a hospital including, but not limited to: his increased risk of

injury due to his history of sleep apnea, size and weight; the risk that medication errors were

more likely because the SURGICAL CENTER did not have inspection protocols and redundancy

procedures in place to prevent medication errors; the risk attendant to the fact that the

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SURGERY CENTER had no emergency staff or code team readily available in the event of an

emergency; the risk of needing to be transported to a hospital in event of an emergency; the risk

of having no inspection of the operating suite prior to surgery; the risk that the SURGERY

CENTER lacked experience and expertise in preparing for and conducting surgery of this type;

the risk of not having available a full range of pharmaceutical products and personnel to handle

emergencies should they occur; the risk of performing unauthorized surgery; the risk of

performing a double-level ACDF when the SURGERY CENTER had not established safety

rules and protocols for its performance; the benefit of performing the procedure in a hospital

with experience, well-established procedures, protocols, and personnel for anesthesia, surgical

and emergency care.

23. As a result of the carelessness and negligence of the defendants, ABRAHAM MINTZ, MD and

ABRAHAM MINTZ, M.D., P.C., and their servants, agents, apparent agents, joint venturers

and/or employees, the plaintiff’s decedent, MICHAEL A. PALMER, SR., suffered the following

severe, serious, painful and permanent injuries:



c. pulmonary edema;

d. cerebral edema;

e. hypoxia;

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g. death.







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WHEREFORE, THE PLAINTIFF, MICHAEL A. PALMER, II, ADMINISTRATOR OF THE

ESTATE OF MICHAEL A. PALMER, SR., CLAIMS DAMAGES IN EXCESS OF FIFTEEN

THOUSAND ($15,000.00) DOLLARS.

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Of this writ, with your doings thereon, make due service and return.

Dated at Bridgeport, Connecticut, this 27th day of March, 2015.

JOEL H. LICHTENSTEIN

Commissioner of the Superior Court

For Fairfield County

KINDLY ENTER THE APPEARANCE OF:

KOSKOFF, KOSKOFF & BIEDER, P.C.

350 Fairfield Avenue

Bridgeport, Connecticut 06604

203-336-4421 phone

203-368-3244 fax

32250 Juris Number

FOR THE PLAINTIFF

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RETURN DATE: MAY 5, 2015 : SUPERIOR COURT

MICHAEL A. PALMER, II, : JUDICIAL DISTRICT

ADMINISTRATOR OF THE ESTATE OF : OF FAIRFIELD

MICHAEL A. PALMER, SR., DECEASED :

VS. : AT BRIDGEPORT

SCA, INC.; SURGICAL CARE

AFFILIATES, LLC; SURGERY CENTER :

OF FAIRFIELD COUNTY, LLC;

SANDRA JOYCE CONGDON, MD; :

FAIRFIELD ANESTHESIA ASSOCIATES, LLC;

GERARD J. GIRASOLE, MD; :

THE ORTHOPAEDIC & SPORTS MEDICINE

CENTER, P.C.; ABRAHAM MINTZ, MD;

ABRAHAM MINTZ, M.D., P.C. : MARCH 27, 2015

CERTIFICATION

I, JOEL H. LICHTENSTIEN, hereby certify that I have made reasonable inquiry, as permitted

by the circumstances, to determine whether there are grounds for a good faith belief that there has been

negligence in the care and treatment of the plaintiff’s decedent, MICHAEL A. PALMER, SR. This

inquiry has given rise to a good faith belief on my part that grounds exist for an action against the

defendants, SCA, INC. and its servants, agents, apparent agents and/or employees; SURGICAL CARE

AFFILIATES, LLC, and its servants, agents, apparent agents and/or employees; SURGERY

CENTER OF FAIRFIELD COUNTY, LLC, and its servants, agents, apparent agents and/or

employees; SANDRA JOYCE CONGDON, MD and her servants, agents, apparent agents and/or

employees; FAIRFIELD ANESTHESIA ASSOCIATES, LLC, and its servants, agents, apparent

agents and/or employees; GERARD J. GIRASOLE, MD and his servants, agents, apparent agents

and/or employees; THE ORTHOPAEDIC & SPORTS MEDICINE CENTER, P.C., and its servants,

agents, apparent agents and/or employees; ABRAHAM MINTZ, MD and his servants, agents, apparent

agents and/or employees; ABRAHAM MINTZ, M.D., P.C., and its servants, agents, apparent agents

and/or employees.

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THE PLAINTIFF,

BY:

JOEL H. LICHTENSTEIN

Koskoff, Koskoff & Bieder, PC

350 Fairfield Aveue

Bridgeport, CT 06604

Phone: 203-336-4421

Fax: 203-368-3244

Juris Number: 032250

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Documents

RETURN DATE: MAY 5, 2015 : SUPERIOR COURT · PDF file1 return date: may 5, 2015 : superior court michael a. palmer, ii, : judicial district administrator of the estate of of fairfield