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Senator Edward Kennedy — Part 21

41 pages · May 11, 2026 · Broad topic: Politics & Activism · Topic: Senator Edward Kennedy · 41 pages OCR'd
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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 e u ce) € 27 r ao: . a (42)
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