UNITED STATES DISTRICT CORT oS : DISTRICT OF CONNECTICUT : ANTHONY MOXNIGHT SR_ 395CV00962 v CIVIL NO: _ NC DEPARTMENT OF CORRECTIONS (STATE GF CONNECTICUT) ee WAROEN GILLIS WARDEN WARREN HUCKABY CAPTAIN HALTER FORO LIEUTENANT CARL MOORE PERSONNEL OFFICER LINDA FOWLER PRINCIPAC PERSONNEL OFFICER MITOH DRABIK WORKERS! CENPENSATION COMMISSION (STATE OF CONNECTICUT) COMMISSIONER RHODA LOEB COMMISSIONER GEORGE WALDRON ALEXSIS INSURANCE. CORPORATION ATTORNEY MILLIAV, HYPOLITE ATTORNEY KENNEDY CLAIMS REPRESENTATIVE LISA CARNEY CLAIMS REPRESENTATIVE NANCY HUBMAN CLAIMS REPRESENTATIVE NANCY ROUCHETTE NEW HAVEN ORTHOPAEDICS SURGEONS INCORPORATED ALLAN GOODMAN, MD YALE NEW HAVEN ORTHOPAEDIC CLINIC / YALE NEW HAVEN HOSPITAL ROBERT MARGOLIS, MD ‘STATE GF COMNECTITICUT 1 of 42PARTIES 1, Plaintiff is a employee of the State of Conacticut Department of Corrections: PO BOK G47 NEW HAVEN, CONNECTICUT 06503 2. Defendant Departrent of Corrections is a State of Conrecticut agency; SHO CAPTTOL AVENUE HARTFORD, CONNECTICUT 06102. Defendant. Warden Gillis 1s an enployee of ‘the State of Connécticut Department of Corections: 340 CAPITOL AVENUE HARTFORD, CONNECTICUT 06102. Defendants Warden Warren Huckaby, Captain Walter Ford, Lieutenant. Carol Moore, Persomel Officer Linda Fowler and Principal Personnel Officer Mitch Drabik are employed by the State of Connecticut Departnent of Corrections; 340 CAPITOL AVENUE HARTFORD, CONNECTICUT 06102, The defendant, Deoartnent of Corrections and its’ defendant employees are being sued both individually and in their official capacities. 3. Plaintiff wishes to reserve the right to amend the list of defendants to include Department of Correction enployees Personnel Directors Laurie seble and Dianne Pierpont, Personnel Officer Becky Riordan and Payroll Officer Nery Raduski wham are mentioned in the complaint, to be sued in both their official and individual capacities 4, Defendant Workers! Canpensation Commission is a State of Connecticut agency: 746 GWPEL STREET NEM HAVEN, COWECTICUT 06510. Defendant's Commissioners Gaorge Waldren ard Rroda Loeh are employees of the State of Connecticut Wrkers! Compensation Comission at 746 CHAPEL STREET NEW HAVEN, CONNECTICUT 06610. 5. Defendant Alexsis Insurance Corporation is the insurance campany for the State of Comecticut: 333 EAST RIVER ORIVE CIMERCE CENTER ONE P 0 BOK S048 HARTFORD CONNECTICUT 06102-5048. Defendants Claim Representatives Lisa Carney, nancy Honan, and Nancy Rouchette are erployees of the Alexsis Insurance Corporation. Defendants Attorney Willian Hypolite and Attorney Kennedy are employees of the Alexsis Insurance Corporation: 333 EAST RIVER ORIVE COMERCE CENTER ONE PO BOK 5048 HERTFORD CONNECTICUT 06510-5048. 2of a2Gefendant. employees of the Alexsis Insurance Corporation mentioned in paragrachs 4 and 5 ‘to be sued in both their individual and official capacities. Plaintiff wishes to reserve the right to anend the list of defendents to include Alexsis Insurance Corporation erployees, Claims Review Officers Laura £. Camio and Tonya M. ota after further investigation , both to be sued individually and in their official capacities. 7. Osfendant Yale New Haven Hospital Orthopaedic Clinic is a healthcare facility; 800 HOWARD AVENUE NEW HAVEN, CONNECTICUT 06519. To be sued in its official capacity. 8. Gefendant Robert Margolis, MD is a physician at the Yale Orthopaedic Clinic; 600 HOWARD AVENUE NEW HAVEN, CONNECTICUT 06518, To be sued in both in his individual and official capacities. 9, Defendant New Haven Orthaepadic Surgeons Incorporated is a Health Maintenance Organization 60 TEPPLE STREET NEW HAVEN, CONNECTICUT 05510. To be sud in its official capacity. 10, Defendant Allan Goodran, MO is a physician at Naw Haven Orthopaedics Surgeons Inc. 60 TENPLE STREET NEW HAVEN, CONVECTECUT 06510. To be sued both in his individual and official capacities. ‘1, Plaintiff brings this action against individual employees, supervisors and The Comecticut State Cepartnent ‘oF Corrections, The Connecticut State Workers! Canpensation Comission, Yale New Haven Orthopaedic Clinic, New Haven Orthopaedic Surgeons Incorporated and Alexisis Insurance Corporation for damages arising out of unconstitutional policies and practices, which the plaintif® substained while under the supervision, authority and care of the defendants. 12, Plaintiff contends thet prior to the filing of this camplaint, nurerous attenpts through Certified Mail telephone conversations, scheduled and unscheduled meetings were made. To date ro reoly or compensation has been offered by defendant(s) or received by plaintiff. 12a. Plaintiff brings this action against the State of Comectiovt for damages arising out ‘of umconstitutional policies and practices, which the plaintiff substained while in the enploy of the state. 3of 42