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ALIA HABIB and her husband : IN THE COURT OF COMMON PLEAS
KHALIL HABIB, Plaintiffs I CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
. NO. 96- ~'/c "CIVIL TERM
ve. I
.
.
TRAVELERS INSURANCE I CIVIL ACTION - LAW
COMPANY, .
.
Defendant . JURY TRIAL DEMANDED
.
AND NOW COMES this
COKPtIIIT
/2 '" day of September, 1996, ALIA
I
HABIB and her husband KHALIL HABIB, Plaintiffs above-named by and
through their attorney JOHN M. GLACE, Esquire and presents this
Civil Complaint aqainst TRAVELERS INSURANCE COMPANY and, in support
hereof, presents the following:
1. Plaintiffs ALIA and KHALIL HABIB are adult individuals
and husband and wife, who reside and resided for all ti:lles relevant
to this Complaint at 1428 Bradley Drive, Apartment J312, Carlisle,
CUlIIberland County, Pennsylvania.
2. Defendant TRAVELERS INSURANCE COMPANY b an insurance
company licensed to transact business in the C~nwealth of
Pennsylvania with offices situate; inter alia at 1105 Berkshire
Boulevard, Nyo.bainq, PA
3. On or about February 3, 1996, Plaintiffs _ra involved in
a actor vehicle accident wherein ALIA HAllI. as _11 .s ItUALIL HAllIB
I
and their minor children sustained personal injuries.
4. Prior thereto Defendant TRAVELERS INSURANCE COMPANY
issued automobile insurance to the Plaintiffs ALIA and KHALIL
HABIB. Defendant, through its authorized agent, employee andlor
servant, Andrea D. Griffith confirmed coverage to Plaintiffs'
counsel by her letter of February 9, 1996. Said letter is attached
hereto and made part hereof as Exhibit A.
5. Pursuant to the terms and conditions of the aforesaid
policy, both Plaintiffs are the named insureds. Additionally, said
automobile insurance policy provided coverage as described in
Exhibit A in first party medical loss benefits in accordance with
the Pennsylvania Motor Vehicle Responsibility Law, 7S Pa. C.S.A.
1701, et seq, as llII8nded. A copy of this policy ia in the
possession of Defendant.
6. As a result of the aforede.cribed IIOtor vehicle accident,
ALIA HABIB suffered severe and debilitating injuries, s~ of which
may be permanent, including, but not lialted, to cervical disc
herniation at C4-C5 and CS-C6.
7. As a further result of the aforede.cribed IIOtor vehicle
accident, Plaintiff ALIA HABIB was obligated to receive and undergo
medical attention and care and to expend various suas of IIOney or
to incur various expen.es for which -.dical benefits are payable.
Further, Plaintiff ALIA HABIB will be obligated to continue to
incur .uch obligation. for indefinite period of ti_ in future for
trea~nt of her accident-related injurie..
2
COURT I
BREACH OP' COHTRACT
B. Paragraphs one (1) through seven (7) ara incorporated
herein as if set forth in full.
9. Acting pursuant to the terms and conditions of their
automobile insurance contract, Plaintiff ALIA HABIB, after initial
emergency medical treatment, presented on February 6, 1996 at
Mas land Associates, Inc. of 220 Willow Street, Suite 109, Carlisle,
Cumberland County, Pennsylvania for treatment of her accident
related injuries.
10. At various times thereafter Plaintiff ALIA HABIB incurred
medical billing obligations for reasonable and necessary treatment
of various health care providers as follows:
Masland Assoc., Inc.
Alexander Spring. Physical Therapy
Carlisle Imagining Assocs.
prescriptions (paid by Plaintiffs)
11. At various time., Plaintiffs ALIA and KHALIL HABIB have
submitted or the provider has directly subaitted -.dical billings
generated by the trea~nt of ALIA HABIB for her eccident related
injurie. to Defendant insurer.
12. On or about May 8, 1996, Defendant insurer, by and
througb it. authorhed agent, ellployee and/or servant Andrea
Griffith, info~ Dr. Debra Taylor, an ...ociate of Haaland
A.aceiate., Inc., that an April 23, 1996 bill wa. questioned a. to
it. relation to ALIA HABIB'. accident related injurie.. Said
letter 1. attached hereto a. Exhibit 8 and ..de ~rt hereof.
3
13. On Hay 15, 1996, Dr. Douglas Bower also of Has land
Associates, Inc. wrote to Andrea Griffith requesting
reconsideration of Defendant's denial and reiterating Plaintiff
ALIA HABIB's recurrent accident-related symptomology of headache
and neck discomfort. Said letter is attached hereto as Exhibit C
and made part hereof.
14. On July 3, 1996, Defendant's authorized agent, employee
or servant notified Dr. Bower that his billings would be submitted
to Peer Review pursuant to the "amended Pennsylvania Financial
Responsibility Law" at section 1797B. Said notification is
attached hereto as Exhibit 0 and made part hereof.
15. The aforedescribed July 3, 1996 notification was
addressed to Douglas J. Bower, M.D. at Alexander Spring Rehab, 27
Boulevard Avenue, Carlisle, PA. Upon knowledge and belief, Dr.
Bower is not associated with that rehabilitation service nor does
he receive mail at that address.
16. Defendant insurer knew or should have known the address
of Doctors Taylor and Bower and Hasland Associates, Inc. by prior
correspondence and by their purported review of billings generated
on or after April 23, 1996 prior to Peer Review subaittal.
17. Defendant insurer contracted with Consolidated
Rehabilitation Co.pany, 2616 North Broad Street, P.O. Box 1719,
Lansdale, PA 19446-0127 to initiate a Peer Review.
18. By notice of the dored.scribed Peer Review Organization,
all Dr. &aw.r's progre.s and clinical note. and diagnoetic .tudy
report. frOll April 23, 1996 _re requested. This notice is dated
4
both July 11, 1996 and July 16, 1996 and is attached hereto as
Exhibit E and made part hereof.
19. Peer Review referral is permitted by regulation only when
a prudent person believes a PRO is necessary to determine the
reasonableness and necessity of care 31 Pa. Code S63.S2(a) and
Defendant insurer at or after April 23, 1996 had no such basis to
request PRO for the treatment of Plaintiff's headaches and neck
pain and his continuing diagnostic process.
20. Plaintiff ALIA HABIB continued to be treated by various
health care providers and by medication after April 23, 1996 and,
as a continuing step in her diagnostic process was administered a
MRI along with radiologic tests on August 8, 1996. Those tests
disclosed cervical disc herniations at C4-C5 and CS-C6. Said
results are attached hereto as Exhibit F and made part hereof.
21. By letter of August 14, 1996, Defendant's authorized
agent employee and/or servant sent Dr. Bower a copy of Peer Review
Report of R. Nathan Link, H.D. purportedly dated July 31, 1996.
This letter was again sent to an address than Defendant insurer
knew or should have know was not that of Dr. Bower or Mas land
ABBociate., Ine.. Said letter is attached as Exhibit G and the PRO
report a. Exhibit H and they are made part of.
22. The PRO report of Dr. Link which is attached hereto as
Exhibit H is baaed on Dr. Bower.s diagnostic !.pression of
orthopedic injury. That impreBBion was fo~d February 6, 1996 and
included only the radiologic tests performed at the ...rveney care
provider February ., 1996. Dr. Bower, ALIA HABIB's priaary care
5
provider, and Dr. Link are internists and neither is an
orthopedist.
23. Dr. Link's PRO report, based solely on the records
provided including a February 6, 1996 diagnostic impression,
determined that all passive treatment modalities after April 4,
1996 were unnecessary and Defendant insurer through Andrea Griffith
its authorized agent, employee andlor servant, by its August 14,
1996 letter (Exhibit G) demanded Dr. Bower return reimbursement of
all payments since April 29, 1996.
24. Premised on Dr. Link's PRO report which relies on a
diagnostic impression of an orthopediclneurologic injury by an
internist two (2) days after the traumatic event, Defender insurer
has refused payment of medical treatment for ALIA HABIB including
future treatment.
25. Defendant insurer has confused ALIA HABIB's medical care
provider. by addressing the August 14, 1996 reimbursement demand to
Dr. Bower to Alexander Springs Rehab and demanding reimbursement of
funds never paid to either Dr. Bower or Hasland Assocs., Inc.
26. Defendant insurer's PRO review request is overtly
premature, premised on a primary care providers first diagnostic
impres.ion, and clearly .pecious in light of the MRI re.ults. It
i. averred that all aedical billings of Plaintiff ALIA HABIB before
and after the Peer Review are fair and reasonable and that her
continuinq treatment by the aforede.cribed provider. was and i.
aedically nee....ry and related to the accident.
6
27. Defendant insurer has refused to pay the balance due of
ALIA HABIB's medical billings and, further, demanded reimbursement
by her health care provider(s). As a direct result the above
Plaintiffs have had to retain an attorney to collect the medical
dues and, therefore, pursuant to Section 1716 of the Pennsylvania
Hotor Vehicle Financial Responsibility Law said Plaintiffs are
entitled to attorney fees and twelve (12\) interest.
28. Plaintiffs are further entitled to attorney's fees
because Defendant insurer has acted with no reasonable foundation
and in violation of Section 1798 of the Pennsylvania Hotor Vehicle
Financial Responsibility Law.
29. Defendant insurer's course of action was unilateral,
arbitrarily premature, without notice or consultation with
Plaintiff's counsel, without justification, and wanton and its
refusal of the Plaintiffs' first party claims with its demand for
reimbursement has made Plaintiffs personally responsible for
medical bills arisinq out of the maintenance and use of their
insured motor vehicle and is in breach of the terms of the
insurance contract, the Pennsylvania Motor Vehicle Financial
Responsibility Law and the cas. law of the Co.-onwealth of
Pennsylvania.
WHEREFORE, Plaintiff ALIA and KHALIL HABIB demand paywent in
full of all ALIA RABIB's medical bills related to her trea~nt of
her accident related injurie., additional cOllp8nsatory andlor
consequential daaages allowed by law, her reasonable attorney'.
fees, costs of this suit, and interest on all overdue benefits.
1
COURT II
BAD FAITH
30. Paragraphs one (1) through twenty-nine (29) are
incorporated herein as if set forth in full.
31. Effective July 1, 1990, Pennsylvania law at 42 Pa. C.S.A.
58371 provides a private cause of action for bad faith against
insurance companies as follows:
"In an action arising under an insurance
policy, if the court finds that the insurer
has acted in bad faith toward the insured, the
court may take all of the following actions'
(1) Award interest on the amount of the claim
from the date the claim was made by the
insured in an aIIOunt equal to the prime rate
of interest plus 3'.
(2) Award punitive damages against the
insurer.
(3) Assess court costs and attorney fees
against the insurer."
32. All treatment was provided to Plaintiff ALIA HABIB after
the effective date of the above statute and the alleged bad faith
occurred after the effective date of the statute.
33. It is believed and, therefore, averred that the
Defendant, insurer, ha. eaployed the aforedescribed Peer Review
Organization in bad faith in that said peer review organization
does . 8ubstantial .-aunt of peer review work for Defendant and,
therefore, has a financial intereat in providing to Defendant a
biased peer review report.
8
34. Additionally, it is alleged that Defendant insurer had
knowledge that Plaintiffs were naturalized American citizens with
limited financial wherewithal and its Peer Review request was over-
reaching, prejudicial, and pre-conceived to take advantage of
Plaintiffs' limited understanding of their statutory rights and
lack of resource.
35. Additionally, it is alleged that the July 31, 1996 PRO
report of Dr. Link is overtly flawed and premised on an initial
diagnostic impression of a non-specialist and Defendant insurer, by
and through its agents, employees andlor servants, knew said report
was not current, inaccurate, andlor nonreliable at the date of its
issuance and that the August 14, 1996 reimbursement demand letter
to Dr. Bower was not based on Plaintiff ALIA HABIB's current
condition.
36. Its is averred that Defendant insurer's request for Peer
Review was arbitrary, without articulatable prellise, and requested
in reliance that the PRO aforementioned would provide justification
to refuse to provide Plaintiffs' contractual benefits.
37. Defendant insurer knew or recklessly disregarded its lack
of reasonable basis in denying Plaintiffs first party benefits and
subllitting the -.dical billings of Plaintiff ALIA HABIB to Peer
Review.
38. The 8ubaittal to Plaintiff ALIA HABIB's -.dical billings
as described herein to Peer Review were for purpose. not
statutorily envisioned and Defendant insurer used the Peer Review
process illproperly and in deviation of SI197(b).
9
08/22/1996 08:58
7172499332
MASLANDASSO
PAGE 01
-
. Medical Case Ma"".emenl
. Peer Review OraamUltlon
. Hospital RelmbuBcmcnt Services
Michael A. Momme. M. Ed . Independent Mecllc:al Eaam
Director . \\x:a1lonaJ RehabllltatlOll
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HOSPITAL I'In'SIClAN OR HEALmCAKE PltOFESS10NAL
Coalplete Hospital 0\U1 .lC Oonot'$ f'rog.eu/Clinial Nota
CIxharp Summary J< I>>&nostic Study RepoI1s
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Consolidated Rehabilitation Company
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88/22/1996 e8:S8
7172499332
HASLANDASSO
.
A\ Carlisle Hospital
~, and Health Services
2046 PaftetStreet. P.O,1Ioa 310. Carllale, PennsylYaniClI7013-o310. (717) 2<19.1212
DEPARTMENT OF RADIOLOGY
CARLISLB IMAGIftG ASSOCIATlS, P.C.
HABIB. ALIA
1428 BRADLEY
CARLISl.E, PA
5lY
DRIVE APT. .1312
17013
08/08/1996
X-RAY .121:261
HED. RBC. .7S1297
DR. BOWBR
CIRVICAL SPI" - PIVK VISWS
Blight diffuse demineralization is noted. Degenerative change.
involve the mid and lower cervical vertebral bodies. "arrowing with
associated degenerative change. involve C5-C6 interspace. On each
oblique projection, po.terior osteophytes project into the
intervertebral foramina bilaterally at the fifth cervical l.vel.
Several .mall calcifications ar. noted in the right .ide neck which
may be vaacular. Small bil.teral cervical ribs ar. noted.
IHPRBsstOIf:
De.ineralization and degener.tive change. of the
cervical .pine.
Degen.rative di.c di..... of C5-C6 int.rspac..
S~ll bilateral cervical ribs.
MItt or ".. czavICAL aPIn
Multipl. .ag1ttal and axial i.aq.. v.r. made of the cerVIcal .pine in
routine pulse .equence.. Th. .tudy is evaluated in conjunction with
x-ra, .xamination of the cervical .pine done on the ...e date.
The ..rrow signal inten.ity 1. normal. "arrowing with a..oclated
degenerative change a involve C5-C6 inter.pace.
At the C'-C5 inter.pace, centrallY and so.ewhat right 1at.rally lying
protruded diac herniation 1. noted without causing any significant
spinal steno.i..
At the C5 C6 inter.pace, diffuae cantrally and bath laterally lYln9
protrudad disc harniation 1. noted. No .ignificant apinal stano... 1.
seen. The rematning intarspaca. are nor.a1 and the po.terior ele..nta
show no abnormality.
The appeeranca of ~he poeterior foa.a
nor.al.
and cervlcal .'i~;~~d [.
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RdwblliwlitJlI SI','ciali.1/.I
CONFIDENTIAL REPORT
A comprehcnsivc
Peer Rcvicw Organizalll1fl
cenificd by lhc
Commonwcalth of Penns~" Jr.IJ
Name:
File:
Date:
Alia Habib
2i8 PP GUN 4639
July 31, 1996
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Submitted for my review are medical records. of Alia Habib as they I'elate to injuries
sustained in a motor vehicle accident on February 4. 19%. I received these records for
review on June 26, 1996.
Ms. Habib was the front seat passenger in a vehicle that was struck fron behind by
another vehicle on February 4. 1996. She was taken to the emergency room at Chester
County Hospital where she was treated and released but I did not receive a copy of the
physician's note from that visit.
On February 6. 1996. Ms. Habib presented to the office of Douglas Bower. MD, with
complaints of pain in her head. neck. shoulders, and chest. Her exam was notable for
tenderness over her neck. upper shoulder girdle. and anterior chest. Dr. Bower's
impression was minor contusion to the head. whiplash injury to the neck, and scathelt
area discomfon across the chest and upper abdomen. His plan was for analgesia and
physical therapy.
.
Beginning February 14, 1996. Ms. Habib underwent physical therapy treatments by
passive modalities such as hot packs. electrical stimulation. and massage. Treatments
were provided up to three times per week at least through May 20. 1996. On February
12, 1996 a CT scan of the head was performed to evaluate persistent headaches. It was
reponedl)' negative. On April 23, 1996. Ms. Habib continued to complain of head and
neck pain. On May 29, 1996. her only complaint was left sidCl.! neck pain 'becoming
worse since Friday.. I was also provided copies of prescriptions for cyclobenzaprine.
ibuprofen, and Roxicet on February 6, 1996 and February 12. 1996 only.
According to the records submitted for my review, the initial evaluation and treatment of
Ms. Habib by Dr. Bower were appropriate for the sotl-tlssue injuries she sustained;
however, passive modalities were cmployCl.! for an unusually long period of time
following the onset of injury. In general, inuooblliution and passive modalities of
treatment are most appropriate in the early period fOllOWing soli-tissue injury (n. Mild
isometric uercises 1t1.1)' be staned cautiously shonl)' after injury. followed by Iflltlt
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~lia ~abib and Khalil Habib
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IN TIlE COURT OF COMMON P1.EAS OF
CUMBER1.AND COUNTY. PENNSY1.V ANIA
ALIA HABIB and her husband KHALIL
BABIB.
CIVI1. DIVISION
Plaintiffs.
No. 96.5105
\'.
TRA VEI.ERS INSURANCE COMI)ANY.
Defendant.
PRAECIPE FOR APPEARANCE
TO: 1.a\\Tenee E. Welk~'I". ProthoDOlar)"
You are hertby directed to enter the appearance of BROWN &. I.EVICOFF on
behalf of Trnelers Insurance Company in the aoo\c-captioned case.
JURY TRIAl. DEMANDED
BY:
--Bryan J.' . Esquirt
BRO I.EVICOFF
Fi .0. #245
600 (julf Tower
Pittsbult\h. PA 1~219
Attorneys for IlI:fendant
.,
..
~
STEFANON & GlACE
A1TORNF.YS AT LAW
407 NO",":..50Jl(f STREI,T
POST OI'I'ICF. BOX 12027
HARRISBURG, PENNSYLVANIA 17108-2027
.....~
.....
ALIA HABIB and her husband : IN THE COURT OF COMMON PLEAS
KHALIL HABIB, Plaintiffs I CUMBERLAND COUNTY, PBNNSYLVANIA
.
.
.
.
vs. : NO. 96-5105 CIVIL TERM
.
.
TRAVELERS INSUR.2.':::::E : CIVIL ACTION - LAW
COMPANY, .
.
Defendant : JURY TRIAL DEMANDED
PRAECIPE OF SITTLIMIHT AIID DISCOHTIIlUAlfCE
ro 'rBI PROTBOIIOTARl' I
Please discontinue the above-captioned case as settled.
RIS'I!CTFULLY )r'....
lace, Esqu re
, GLACE
h Front Street
x 12027
Ha isburg, PA 17108-2027
(717) 232-0S11
1.0. 123933
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