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Senator Edward Kennedy — Part 21
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October 8th,1982, up to December Sth, 1982. PLaintiff£ charges
that on advice of attending physician, he did return tO work
in a "Guarded Condition", on December 6th,1982, working the
7th,8th, and 9th, however unable to work on the 10th,1982 as
the condition of his lower back injury, had gradually diminished
his capability of normal activities, job related and other.
Plaintiff charges that the pain and inability to turn,benc,
stand on his left leg, drive, (normal activities) had returned/worsened
to same condition, and solely due to this injury on the job,
sustained on October 8th,1982, he was unable to perform his
job related duties,work. Plaintiff Charges that the employer
Defendant John Tomlinson, was fully aware that the Plaintiff
was still incapacitated/attemptingotsese? gigsheceould stilkoperfora
same work related duties, and did switch the plaintiff to easier
work loads. All verifyable recorded events. Plaintiff further
charges that he did see attending Chiropractor, Dr.Carnevale,
on December 11th,1982, and that he did again agtempt-tocpeffonm
his normal job related duties, Monday December”~ 13th,1982,being
switched again to lighter tasks. However, Plaintiff states that
the condition had returned, in his lower back, due to the
October 8th,1982 injury that he was advised on December 14th,
1982, by attending Dr. Carnevale, not to return to work again
until further notice. Plaintiff charges that the Carrier of the
Workers Compensation Insurance, Reliance Insurance Co'S, did use
this pre-text to deny any further payments on this Injury, and
did not has not paid, since this last payment for period uo to
and including December Sth,1982-1 Inviolation RIGE!S) .
Plaintiff Charges that he was unable to return to this normal
job, Plaintiff had been a Tractor Trailer/Truck Driver since
1963, until May of 1985, and then did so under limited conditions
with this back injury still semi-incapacitating him. Plainti£é
charges that this condition still exists, lower back pain,and
limitations, on normal activities, and has limited/is limiting
his life. Plaintiff Charges that prior to October 8th,1982, he
had never had any problems with his back, and that he had never
been attended to by any physician or other for any back problems
whatso-ever, and had just passed an ICC, physical, and that all
this evidence was readilly available to be submitted into this
Workers Compensation Case, but was not, on conspiracy by the
Commissioner Rotondi, Lawyers, Raul L.Lovett, John Harnett,
Jeff perlow, and that he was criminally deprived of his Civil ~
Righss to a fair and impartial hearing, in this matter, by this
conspiracy, to Deprive.
Plaintiff charges that he did inform John Tomlinson/Tomlinson
Transportation,and Reliance Ins, Co.s, and that they were also
advised by attending Dr.Carnevale, of the continuing nature of
a@isability, up to and including, the continued inability of the
Plaintiff to perform his job related tasks, December 14th,i982,
and thereafter in Certified mail, celepnone calls and bills io
medical service rendered on a continuing basis bv the plaincitt
and attending physicians, chiropractors, hospitals, Etc.
And that the Defendant Reliance Ins. Co.5, was fully aware of
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