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Tort Law

Tort Law Appellate Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5917

AC46047 - Speer v. Skaats ("The plaintiff, Sheri Speer, appeals from the judgment of the trial court, Goodrow, J., dismissing the civil action brought by her against the defendant, Donna Skaats. The plaintiff claims that, in dismissing the action, the court erred in concluding that it lacked subject matter jurisdiction because she was not aggrieved and, thus, lacked standing to bring the action. The plaintiff also claims that the court, Spallone, J., erred in "denying [her motion for] summary judgment." We agree with the plaintiff's first claim and, therefore, reverse the judgment of the trial court.")


Tort Law Appellate Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5909

AC46061 - Wylie v. APT Foundation, Inc. ("The plaintiff, Nadine Wylie, acting in her capacity as the administratrix of the estate of Keith Wylie (decedent), appeals from the judgment rendered by the trial court in favor of the defendant, APT Foundation, Inc., following the granting of a motion to strike her amended substitute complaint dated July 21, 2021. On appeal, the plaintiff claims that the court improperly concluded that she failed to allege sufficient facts to support her public nuisance claim. We disagree and, accordingly, affirm the judgment of the trial court.")


Tort Law Appellate Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5893

AC44921 - GHP Media, Inc. v. Hughes ("The defendant and third-party plaintiff, Shafiis', Inc., doing business as TigerPress (TigerPress), appeals from the judgment of the trial court rendered in favor of the third-party defendants, John Robinson and Joseph LaValla, both officers of the plaintiff, GHP Media, Inc. (GHP), after it granted their motion to strike TigerPress' revised third-party complaint for indemnification. On appeal, TigerPress claims that the court, in granting the third-party defendants' motion to strike, improperly concluded that its revised third-party complaint failed to allege that TigerPress, Robinson, and LaValla owed an identical duty to GHP in the underlying action. We affirm the judgment of the trial court.")


Tort Law Appellate Court Opinions

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5882

AC45862 - DeCicco v. Dynata, LLC ("The plaintiffs, Attorney Joseph DeCicco, administrator of the estates of twenty-nine Philippine citizens, Jehmar Bongcayao, Mostes B. Castillo, Sylvester B. Celades, Guidhavio C. Garzon, Jexter D. Generales, and Cecilline Sismar, appeal from the judgment of the trial court granting the motion of the defendants, Dynata, LLC (Dynata), Christopher Mark Fanning, and David Ian Weatherseed, to dismiss the plaintiffs' complaint on the ground of forum non conveniens. On appeal, the plaintiffs claim that the court (1) applied the wrong test to determine whether the Philippines was an adequate alternative forum, and (2) improperly dismissed this case on the ground of forum non conveniens. We disagree and, accordingly, affirm the judgment of the court.")

AC46249 - Fountain of Youth Church, Inc. v. Fountain ("This appeal arises from an action commenced by Fountain of Youth Church, Inc. (Church), against the defendants, Franklin L. Fountain (Fountain) and Fountain of Youth Cathedral, Inc. (Cathedral), asserting claims of fraud, constructive trust, conversion, and statutory theft. The trial court granted the defendants' motion to dismiss, concluding that the Church lacked standing because it failed to demonstrate that it was acting pursuant to a valid authorization when it initiated the present action against the defendants. On appeal, the Church claims that the court improperly concluded that it was not authorized to initiate the present action. We disagree and affirm the judgment of the trial court.")


Tort Law Supreme Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5877

SC20777 - Deutsche Bank AG v. Vik ("The plaintiff, Deutsche Bank AG, has spent the last decade attempting to collect from a nonparty, Sebastian Holdings, Inc. (SHI), an approximately $243 million foreign judgment (English judgment) resulting from an unpaid margin call in 2008. In Deutsche Bank AG v. Sebastian Holdings, Inc., 346 Conn. 564, 294 A.3d 1 (2023), the plaintiff unsuccessfully sought to pierce SHI's corporate veil and to hold the defendant Alexander Vik (Alexander) jointly and severally liable with SHI for the English judgment. Id., 568–69. While that case was pending in the trial court, the plaintiff commenced the present action against Alexander and his daughter, the defendant Caroline Vik (Caroline), alleging tortious interference with business expectancy and violation of the Connecticut Unfair Trade Practices Act (CUTPA), General Statutes § 42-110a et seq., on the basis of the defendants' alleged efforts to interfere with the order of a Norwegian courtrequiring the sale of SHI's shares in a Norwegian software company in partial satisfaction of SHI's debt to the plaintiff. The defendants moved to dismiss the action, arguing that it was barred by the litigation privilege. The trial court denied the motion, and the defendants appealed to the Appellate Court, which reversed the trial court's decision and directed the trial court to dismiss the plaintiff's complaint in its entirety. See Deutsche Bank AG v. Vik, 214 Conn. App. 487, 511, 281 A.3d 12 (2022). We granted the plaintiff's petition for certification to appeal, limited to the issue of whether the Appellate Court correctly determined that the plaintiff's complaint was barred by the litigation privilege. See Deutsche Bank AG v. Vik, 345 Conn. 964, 964–65, 285 A.3d 388 (2022). During oral argument before this court, the defendants argued that this case was rendered moot by our decision in Deutsche Bank AG v. Sebastian Holdings, Inc., supra, 346 Conn. 564, which we issued after the parties had filed their briefs in this case. We conclude that the case is not moot and that the plaintiff's complaint is not barred by the litigation privilege. Accordingly, we reverse the judgment of the Appellate Court.")


Tort Law Appellate Court Opinions

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5869

AC46231 - Cockerham v. Westphalen ("The defendant Jennifer Westphalen appeals from the judgment of the trial court rendered against her and in favor of the plaintiff, Kenneth Cockerham, on counts nine, ten, and eleven of the plaintiff's complaint, asserting claims of fraudulent transfer against the defendant and her husband, Adam Westphalen (Westphalen), pursuant to the Connecticut Uniform Fraudulent Transfer Act (CUFTA), General Statutes § 52-552a et seq. On appeal, the defendant claims that the court erred in finding that Westphalen fraudulently transferred money to the defendant under the common law and pursuant to General Statutes § 52-552e.Specifically, the defendant argues that the court erred in finding that Westphalen possessed actual fraudulent intent, that the defendant shared in that intent, and that the transfers were made without consideration, leaving Westphalen unable to meet his financial obligations. We disagree with the arguments advanced by the defendant and, accordingly, affirm the judgment of the trial court.")

AC46193 - Tran v. Woodworth ("The plaintiff, Cuong Kim Tran, appeals from the summary judgment rendered by the trial court in favor of the defendants, Mark Allen Woodworth and Jennifer Woodworth Sulc, coadministrators of the estate of the decedent, Nancy S. Woodworth. On appeal, the plaintiff claims that the trial court improperly granted the defendants' motion for summary judgment and determined that the defendants were entitled to judgment as a matter of law as to the plaintiff's complaint alleging negligence because (1) the documents on which the defendants relied in support of their motion did not demonstrate the absence of any genuine issue of material fact as to the allegations of negligence in the complaint and (2) the plaintiff submitted countervailing evidence demonstrating the existence of a genuine issue of material fact that precluded summary judgment. We agree with the plaintiff and, therefore, reverse the summary judgment rendered in favor of the defendants and remand the case for further proceedings.")


Tort Law Appellate Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5864

AC45745 - Marafi v. El Achchabi ("The defendant Hind El Achchabi appeals from the summary judgment rendered by the trial court in favor of the plaintiff, Sadiq Marafi. On appeal, the defendant claims that the court (1) improperly determined that no genuine issue of material fact existed with respect to the plaintiff's actions for fraudulent misrepresentation, statutory theft, and unjust enrichment, and (2) committed plain error in granting the plaintiff's motion for summary judgment because those actions were predicated on adultery in contravention of General Statutes § 52-572f.We affirm the judgment of the trial court.")


Tort Law Appellate Court Opinions

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5851

AC45775 - C. W. v. Warzecha ("The defendant, Keith J. Warzecha, appeals from the judgment of the trial court in favor of the plaintiff, C. W., on her claim for negligent infliction of emotional distress. On appeal, the defendant claims that (1) the trial court abused its discretion by asking him questions during the trial, sua sponte, that went beyond the scope of what was permissible, (2) the evidence presented at trial did not support a finding of negligent infliction of emotional distress, and (3) 'this court [should] grant [his] motion to dismiss when the trial court did not act on it.' We affirm the judgment of the trial court.")

AC46339 - Harvin v. Yale New Haven Health Services Corp. ("In this civil action, the plaintiff, Marcus T. Harvin, a former inmate, asserts claims of, inter alia, negligence per se and negligent infliction of emotional distress against the defendant Lawrence + Memorial Hospital on the basis of its allegedly unlawful disclosure of his confidential health information during his criminal prosecution. The plaintiff alleges that the defendant unlawfully disclosed his confidential health information in two ways. First, he alleges that the defendant unlawfully provided certain unspecified confidential health records, including a psychiatric evaluation, to members of the Office of the Chief State's Attorney. Second, he alleges that two of the defendant's agents disclosed confidential health information during their testimony at his criminal trial. The defendant appeals from the judgment of the trial court denying its motion to dismiss the action for lack of subject matter jurisdiction on the theory that the defendant is entitled to absolute immunity from suit under the litigation privilege because any and all disclosures of the plaintiff's confidential health information, whether by itself or its agents, occurred in the course of the criminal litigation and in response to a valid subpoena and court order. The defendant specifically claims that the court improperly determined that it lacked a sufficient evidentiary basis on which to determine if the litigation privilege applied under the circumstances of this case.

At oral argument before this court, the plaintiff's attorney conceded, and we agree, that the litigation privilege does bar those portions of the underlying action premised on the testimony provided by the defendant's agents at the plaintiff's criminal trial. We disagree, however, that the defendant demonstrated on this record that it is entitled to litigation privilege with respect to the allegations of unlawful disclosure of confidential health information to members of the Office of the Chief State's Attorney. Accordingly, for the reasons that follow, we reverse in part and affirm in part the judgment of the trial court and remand the case with direction to grant the motion to dismiss to the extent that the remaining counts are premised on the testimony given by the defendant's agents at the plaintiff's criminal trial.")

AC46348 - Rubin v. Brodie ("The issues before this court are whether an application to confirm an arbitration award filed in a pending civil action survives the dismissal of the civil action and, if so, whether an appeal from the judgment dismissing the civil action operates to automatically stay proceedings on the application to confirm the arbitration award. We reject the argument that the application to confirm did not survive the dismissal of the complaint and conclude that this appeal does not automatically stay proceedings before the Superior Court on the pending application to confirm an arbitration award filed by the named defendant, Barnett Brodie. Accordingly, we grant the motion for review filed by Brodie and other defendants and grant the relief requested in accordance with this court's February 14, 2024 order.")


Business Law Appellate Court Opinion

   by Oumano, Emily

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5829

AC45631, AC45632 - Lyons v. Birmingham Law Office, LLC (“The plaintiff, Justine Lyons, appeals from the judgment of the trial court dismissing the underlying action against the defendants Birmingham Law Office, LLC, and Attorney Matthew Birmingham (Birmingham defendants); and Marylou Scofield, PC, and Attorney Marylou Scofield (Scofield defendants), for lack of personal jurisdiction. The plaintiff claims that the court improperly concluded that (1) personal jurisdiction over the defendants was not conferred under our state’s long arm statute, General Statutes § 52-59b, and (2) exercising jurisdiction over the defendants would violate the due process requirements of the United States constitution because they have insufficient ‘‘minimum contacts’’ with the state. We disagree and, accordingly, affirm the judgment of the trial court.”)


Contract Law Supreme and Appellate Court Opinions

   by Oumano, Emily

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5828

SC20754 - Mercedes-Benz Financial v. 1188 Stratford Avenue, LLC ("In this certified appeal, the defendants, Aniello Dizenzo and his company, 1188 Stratford Avenue, LLC (company), appeal from the Appellate Court's judgment affirming the trial court's denial of their motion to open the judgment rendered in favor of the plaintiff, Mercedes-Benz Financial. On appeal, the defendants claim that the Appellate Court incorrectly concluded that the trial court had not abused its discretion by denying their motion to open as untimely and with no basis, even though the defendants timely filed their motion. We agree and, therefore, reverse the Appellate Court's judgment.")

AC45867 - Burr v. Grossman Chevrolet-Nissan, Inc. (“The plaintiffs, Mathew Burr, Elmer Blackwell, and MPK Property Maintenance, LLC (MPK), appeal from the judgment of the trial court, rendered in favor of the defendant, Grossman Chevrolet-Nissan, Inc. On appeal, the plaintiffs claim that the court erred in (1) misinterpreting their legal claims, (2) relying on the testimony of the defendant’s representative to reach its conclusion, and (3) finding certain facts in support of its judgment for the defendant. We affirm the judgment of the trial court.”)

AC45620 - Jefferson Solar, LLC v. FuelCell Energy, Inc. (“The plaintiff, Jefferson Solar, LLC, appeals from the judgment of the trial court dismissing the action as to the defendants FuelCell Energy, Inc., and SCEF1 Fuel Cell, LLC (collectively, FuelCell), and the United Illuminating Company (United Illuminating). On appeal, the plaintiff claims that the court improperly concluded that the plaintiff lacked standing to assert its claims. We disagree and, accordingly, affirm the judgment of the trial court.”

AC45222 - Travinski v. General Ins. Co. of America (“The plaintiffs, Christoper S. Travinski and Lena L. Travinski, appeal from the summary judgment rendered by the trial court in favor of the defendants, General Insurance Company of America, Safeco Corporation, Liberty Mutual Insurance Company, and Liberty Mutual Holding Company, Inc., on the plaintiffs’ complaint. The plaintiffs claim that the court improperly (1) granted the defendants’ motion for summary judgment as to the counts of their complaint alleging breach of contract and a violation of the Connecticut Unauthorized Insurers Act (CUIA), General Statutes § 38a-271 et seq., and (2) permitted the defendants Safeco Corporation, Liberty Mutual Insurance Company, and Liberty Mutual Holding Company, Inc., to file a motion for summary judgment without posting a bond pursuant to General Statutes § 38a-27. We disagree and, accordingly, affirm the judgment of the trial court.)


Tort Law Appellate Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5826

AC46460 - Cardoza v. Waterbury ("The plaintiff, Paula M. Cardoza, appeals from the judgment of the trial court granting the motion to dismiss filed by the defendant, the city of Waterbury, for lack of subject matter jurisdiction over the plaintiff's complaint on the basis that she failed to comply with the requirements of the notice provision of the municipal defective highway statute, General Statutes § 13a-149. On appeal, the plaintiff claims that the court erred in granting the defendant's motion to dismiss because the written notice that she submitted to the defendant contained sufficient information in compliance with the notice requirements of § 13a-149, or, in the alternative, the savings clause of § 13a-149 grants her relief under the statute. We disagree and, accordingly, affirm the judgment of the court.")


Property Law Supreme Court Opinion

   by Oumano, Emily

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5814

SC20759 - Canner v. Governors Ridge Assn., Inc. (“The plaintiffs, Glen A. Canner, the executor of the estate of Charles A. Canner, and Louis D. Puteri, brought separate actions against a condominium association, the named defendant in each case, Governors Ridge Association, Inc., alleging that the foundations supporting their respective units were sinking as a result of improper design. In this consolidated appeal, the plaintiffs contend that the Appellate Court improperly affirmed the trial court’s judgments in favor of the defendant on the ground that the three year tort statute of limitations; see General Statutes § 52-577; barred pursuit of an alleged cause of action under the Common Interest Ownership Act (CIOA), General Statutes § 47-200 et seq. We conclude that some, but not all, of the plaintiffs’ claims against the defendant are time barred and, accordingly, we affirm in part and reverse in part the judgment of the Appellate Court.”)


Tort Law Appellate Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5800

AC45807 - Rodriguez v. Hartford ("The plaintiff, Carmen Rodriguez, as parent and next friend of her minor son, Christopher Rodriguez (Christopher), appeals from the summary judgment rendered in favor of the defendants, the city of Hartford (city) and Heather Dionne, the city forester, in this action to recover damages for injuries sustained by Christopher when a tree fell on him while he was playing at a basketball court located in a city park. On appeal, the plaintiff claims that the court erred by (1) denying her requests to amend her complaint and (2) concluding that her complaint did not set forth a claim of public nuisance and that no genuine issue of material fact existed as to whether her claims against the defendants were barred by governmental immunity. We conclude that the court properly rendered summary judgment as to the plaintiff's negligence claims but that the court erred in denying one of the plaintiff's requests to amend her complaint. We therefore affirm in part and reverse in part the judgment of the trial court.")


Tort Law Supreme Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5792

SC20722 - O'Sullivan v. Haught ("In this certified appeal, we consider the scope of an appellate court’s jurisdiction over an interlocutory appeal from the denial of a motion for summary judgment on the ground of collateral estoppel that is based on the preclusive effect of a Probate Court decree. The defendant, Alan F. Haught, appeals, upon our grant of his petition for certification, from the Appellate Court’s dismissal of his appeal from the trial court’s denial of his motion for summary judgment with respect to the claim of tortious interference with an expected inheritance brought in a tort action by the plaintiff, David O’Sullivan. Specifically, the defendant claims that the Appellate Court improperly granted the motion to dismiss his appeal because a trial court’s denial of a summary judgment motion based on a colorable claim of collateral estoppel is an immediately appealable final judgment. We agree with the defendant and conclude that the Appellate Court improperly dismissed the defendant’s appeal from the decision of the trial court.")


Civil Procedure Law Supreme Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5791

SC20699 - Benvenuto v. Brookman ("This is an appeal from an order granting a bill of discovery and requiring the defendant, Kevin Brookman, who publishes an Internet blog known as ‘‘We The People–Hartford,’’ to submit his laptop and cell phone for a forensic analysis that will enable the plaintiff, Vincent G. Benvenuto, to ascertain the identities of persons who posted blog comments containing allegedly defamatory statements about him. ‘‘[T]o safeguard the defendant’s privacy interest,’’ the trial court’s discovery order mandates that the parties attempt to reach an agreement on the terms of a protective order and search protocols that together will govern the scope and procedures to be used in the forensic analysis, or, in the absence of an agreement, submit proposed orders so that the trial court can resolve any disputes regarding the terms of the protective order and search protocols. The court expressly retained jurisdiction until such time as the parties have filed an agreement or the court has resolved any impasse. Following oral argument, we ordered the parties to file supplemental briefs addressing whether the trial court’s order is a final judgment for purposes of appellate review. We conclude that the order is not final and dismiss the appeal.")


Tort Law Appellate Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5786

AC45845 - Northeast Building Supply, LLC v. Morrill ("The plaintiff, Northeast Building Supply, LLC, appeals from the judgment of the trial court denying the application for a prejudgment remedy that it filed in accordance with General Statutes § 52-278a et seq. against the defendants, Maureen Morrill, Clifford Jones, Pullman & Comley, LLC, Attorney Irve Goldman, Attorney Bruce Diamond, and the Law Office of Bruce W. Diamond, LLC. On appeal, the plaintiff claims that the trial court erred in denying its application for a prejudgment remedy when it concluded that (1) collateral estoppel barred the vexatious litigation claims it sought to bring against the defendants and (2) the attorney and law firm defendants—Pullman & Comley, LLC, Goldman, Diamond, and the Law Office of Bruce W. Diamond, LLC—had adequate insurance to secure any judgment that might be rendered against them.

The defendants argue that the court properly denied the plaintiff's application for a prejudgment remedy. They also, for the first time on appeal, raise a jurisdictional claim. They claim that the plaintiff lacked standing to assert the vexatious litigation claims against the defendants because those claims were assigned to the plaintiff from a different entity, Northeast Builders Supply & Home Centers, LLC (Home Centers).The defendants argue that the plaintiff's vexatious litigation claims constitute tort claims that involve alleged personal injuries unique to Home Centers. They further contend that Connecticut law makes clear that such tort claims may not be assigned. Consequently, the defendants maintain that the plaintiff lacks standing to pursue its application for a prejudgment remedy.

For the reasons that follow, we agree with the defendants that the plaintiff lacks standing to pursue the application for a prejudgment remedy and, consequently, that the trial court was without subject matter jurisdiction. Accordingly, we reverse the judgment of the trial court and remand the case to that court with direction to render judgment dismissing the plaintiff's application.")


Tort Law Appellate Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5773

AC46440 - Cameron v. Santiago ("The self-represented plaintiff, Catherina Cameron, appeals from the judgment of the trial court dismissing, sua sponte, her action against the defendant, Javier Santiago. On appeal, she claims that the court deprived her of procedural due process by sua sponte dismissing her action, with prejudice, without giving her notice and an opportunity to be heard with respect to the grounds on which the court based its dismissal. We agree with the plaintiff and reverse the judgment of the trial court.")


Tort Law Appellate Court Opinion

   by Agati, Taryn

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5768

AC45538 - Silano v. Cooney ("The self-represented plaintiff, Virginia Silano, appeals from the summary judgment rendered by the trial court in favor of the defendant Kevin Hammel on count two of the plaintiff's complaint alleging malicious prosecution. On appeal, the plaintiff claims that the court improperly (1) rendered summary judgment in favor of the defendant on her malicious prosecution claim, (2) rejected her arguments with respect to intentional spoliation, and (3) admitted into evidence the defendant's contemporaneous notes regarding his viewing of a surveillance video that the plaintiff contends the defendant failed to preserve. We affirm the judgment of the court.")


Tort Law Appellate Court Opinion

   by Oumano, Emily

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5712

AC45491, AC45492 - Ciara v. Atlantic Motors, LLC (“These two appeals arise from consolidated cases. The plaintiffs in the respective actions, Nancy Ciara and Jeryd Griffin, appeal from the judgments of the trial court in favor of the defendants New England Property, LLC (New England Property), Edmond Ferati, Balkiz Ferati, and Rini Ferati. On appeal, the plaintiffs claim that the court erred in (1) declining to enforce subpoenas to compel the attendance of the defendants at trial and (2) failing to admit Carfax reports into evidence at trial. We affirm the judgments of the trial court.”)


Tort Law Appellate Court Opinion

   by Oumano, Emily

 https://jud.ct.gov/lawlib/LawLibNews/Posts/Post.aspx?Id=5699

AC45401 - Lafferty v. Jones (“The defendant Alex Jones appeals from the judgments of the trial court, Bellis, J., granting the joint motion for contempt filed by the plaintiffs for the defendant’s violation of the court’s orders to attend a deposition scheduled on March 23 and 24, 2022. On appeal, the defendant claims that the court (1) abused its discretion by holding him in contempt of court for failing to appear at his deposition after the court was provided an affidavit and two letters from his physicians attesting that he was too ill to attend the deposition, and (2) violated his due process rights by not requesting additional information from his physicians regarding his medical condition prior to holding him in contempt. We affirm the judgments of the trial court.”)