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Home My WebLink About00-07693 ,- "~i,.J l_.;...;;.......1 , ," F:\FILES\DA TAFILE\Prgdoc.arc\PrgdocOO\124-ans.lIajt Created: 09fI8/0002:31:53PM Revised; 011l0fOl02:04:15PM 7837.121 ARTHUR and BRENDA DAVISON Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 2000-7693 CIVIL ACTION-LAW THOMAS J. MICKEY d/b/a MICKEY'S TOWING Defendant JURY TRIAL OF TWELVE DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO: ARTHUR and BRENDA DAVISON, Plaintiffs and their attorney DAVID 1. LUTZ, ESQUIRE ,~ YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOu. (, AND NOW, comes Defendant, THOMAS J. MICKEY, d/b/a MICKEY' S TOWING, by and through its attorneys, MARTS ON DEARDORFF WILLIAMS & OTTO and hereby responds to Plaintiffs Complaint as follows: 1. After reasonable investigation the answering Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of the averments contained in this paragraph. 2. Admitted accept that Defendant's business is located in York County, Pennsylvania. 3. Admitted. 4. Admitted. 5. Admitted. 6, Denied to the contrary the bed was already lowered and Plaintiffhad wedged his foot under the bed to push the car off the rollback. Plaintiff apparently left his foot there and when the bed was being put back in the upright position the bed rolled over Defendant's foot. 7. Denied pursuant to Pa. R.c.P. l029(e), ~. ~LL J ,_......1.. ~ ;dll" ...."'" CLAIM I Arthur Davison v. Thomas Mickey d/b/a Mickev's Towin!!: 8. The averments of paragraphs 1 through 7 of this Answer are hereby incorporated by reference, 9-17. Denied pursuant to Pa. R.C.P. 1029(e). CLAIM II Brenda Davison v. Thomas Mickey d/b/a Mickev's Towin!!: 18. The averments of paragraphs of 1-17 of this Answer are hereby incorporated by reference. 19. Denied pursuant to Pa. R.C,P. 1029(e). WHEREFORE, Defendant, Thomas J. Mickey, d/b/a Mickey's Towing, demands judgment in his favor and dismissal of Plaintiffs Complaint of prejudice, NEW MATTER 20. The averments of paragraphs 1 through 19 of this Answer are incorporated herein by reference. 21. The Plaintiffs claims are barred by the applicable Statute of Limitations. 22. The Plaintiffs recovery is barred or reduced by the Pennsylvania Motor Vehicle Financial Responsibility Law as amended. 23, Plaintiffs or their representatives chose the limited tort option by signing a valid selection form. 24. Plaintiffs' injuries do not involve death, serious impairment of bodily function or permanent disfigurement. WHEREFORE, Defendant demands judgment in his favor and dismissal of Plaintiffs' Complaint with prejudice. By Ge ge . Faller, Jr., Esquire LD, No. 49813 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Thomas J, Mickey Dated: January 10,2001 " J ,U ....1& ...~"......"...,~~~ , VERIFICATION The foregoing Answer is based upon information which has been gathered by my cOlUlsel in the preparation of the lawsuit. The language of the document is that of cOlUlsel and not my own, I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correctto the best of my knowledge, information and belief. To the extent that the content of the document is that of cOUlLSel, I have relied upon cOUlLSel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to lUlswom falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. " ,II i --1____ ~ a'lill~ CERTIFICATE OF SERVICE I, Ami J. Thumma, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Answer was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: David L. Lutz, Esquire ANGINO & ROVNER, P.C. 4503 N. Front Street Harrisburg, P A 17110 MARTSON DEARDORFF WILLIAMS & OTTO B~X\/\QL1Id~ W \ill Melinda A. Hall Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: January 10, 2001 ~<'.,i."'~ ~'" "" L.:.-~" ;0,;,-__ . BJ I~ , "-;"";;'-'.-"', :'-"',,-,__,;,~ 'M;'''' ~""". ... ,,"". ~."" ~'''-- ~'" ~, -- -, .~. ~i\!ji<:l~W u'~ . . ~ , ~ 'R" ",." 0 C) P c cS: -p.-, ,"j" rTlfl' Z:J: ;;..:c- (:=0 Cn -< t-: ~ '.- ~D >;;: (- '~"? ~ '--', )> ',,-..' :.'-) ~ ~0 (,:, . " . ".~ . .,~#~ ~, ),"'i i:-:i 1'< I', , , i:,i !' I,,; i" h i I' II i':: j'!j Ii: [:-I , j!j ji I: ~-I ~.j II 1i 11 ],J Ii I I-I 'I I! ,I 'I i I I I I " .,.," ~, '--'", --'='~ '0_ ~ " , \' ;,J;;;'-'-'ii ~J r -'~-~-. " ,,"' o,,"~, ".,e_ " i-'",/;:.>ii"'"".;.c'..' , w. "r1 ARTHUR AND BRENDA DAVISON Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. CIVIL ACTION - LAW NO. 60- rr~9J Co'd~~ JURY TRIAL DEMANDED THOMAS J. MICKEY, d/b/a MICKEY'S TOWING, Defendant NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER'S REFERRAL SERVICE CotUt ~ 4:Ldi.l~.l~;:)tLator 4th fit, CUIlibc:dand Cuwuy CUWdlUU:SC: Cllli,lt, Fa. 17BlJ P17) 219 6290 C1..v,.."bEP /~.:YL GxM.->iy ]~ IIssOCJ::H, aJ ~ 1.., b~ IJcX,-,<' r-, ~o( rS [I:, fJA-- 170/~ 717- ';lJ!i"-31I.:.b OR\G\NAL 214675.1\DLLILC2 ~ , -- ~,,---- , H _'.",,",_,_<.% -^ ,- --~~-Ii1~ ARTHUR AND BRENDA DAVISON Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A CIVIL ACTION - LAW v. THOMAS 1. MICKEY, d/b/a MICKEY'S TOWING, Defendant NO. JURY TRIAL DEMANDED NOTICIA Le han demandado a usted en la corte, Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUlR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER'S REFERRAL SERVICE Court Administrator 4th Fl., Cumberland County Courthouse Carlisle, Pa. 17013 (717) 240-6200 214675.lIDLLILC2 II 1\ U ~ , _h '<'00'-1__;" ,_-~~_< - o"~ "'''''''-_''0' _,_~~,_' ARTHUR AND BRENDA DAVISON Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. CIVIL ACTION - LAW NO. /)1)- 'l{; 93 ~ '/~ THOMAS J. MICKEY, d/b/a MICKEY'S TOWING, Defendant JURY TRIAL DEMANDED COMPLAINT I. Plaintiffs Arthur and Brenda Davison, citizens of the Commonwealth of Pennsylvania, are husband and wife, who reside at 16 Paddock Lane, Camp Hill, Cumberland County, Pennsylvania. 2, Defendant Thomas J. Mickey, d/b/a Mickey's Towing (hereinafter Mickey) is an adult individual and citizen of the Commonwealth of Pennsylvania who does business in Cumberland County, Pennsylvania. Defendant Mickey's business is located at 10 Crescent Drive, New Cumberland, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about February 5, 1999, at Petroleum Tire and Automotive, 1599 Hummel Avenue, Camp Hill, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Arthur Davison was doing business as Petroleum Tire and Automotive. 5. During the morning of February 5, 1999, Defendant Mickey was operating a tow-truck and in the process of delivering an automobile to Mr. Davison's business. 6. Defendant Mickey lowered the flatbed of his tow-truck onto Plaintiff Arthur Davison's right foot. 214675,l1DLL\LC2 , II Ii a ~- '- ....,;...i;("'/,~ ~-- . 1"'- "&'.-~ - ,-- -~- '--'"- _~,_v _ fi-i.;! 7. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiffs Arthur and Brenda Davison are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Mickey operated his tow-truck as follows: a) failure to keep alert and maintain a proper watch for the presence of persons around his tow-truck; b) failure to keep proper and adequate control over his tow-truck; c) lowering his flat-bed onto Mr. Davison's foot; and d) operating his tow-truck in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others. CLAIM I ARTHUR DAVISON v. THOMAS J. MICKEY. d/b/a MICKEY'S TOWING 8. Paragraphs I through 7 of the Complaint are incorporated herein by reference. 9. Plaintiff Arthur Davison sustained painful and severe injuries which include but are not limited to multiple fractures in his right foot, including injury to the connective tissues of his foot. 10. By reason of the aforesaid injuries sustained by Plaintiff Arthur Davison, he was forced to incur liability for medical treatment, medications, and similar miscellaneous expenses in an effort to restore him to health, and claim is made therefor. II. Because of the nature of his injuries, Plaintiff Arthur Davison has been advised and, therefore, avers that he may be forced to incur similar expenses in the future, and claim is made therefor. 214675,lIDLLILC2 2 I I ~ ,L '-'" l' -~, " jioliiio"; .;,. 12. As a result of the aforementioned injuries, Plaintiff Arthur Davison has undergone and in the future may undergo physical and mental suffering, inconvenience in carrying out his daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 13. As a result of the aforesaid injuries, Plaintiff Arthur Davison has been and in the future may be subject to humiliation and embarrassment, and claim is made therefor. 14. As a result of the aforementioned injuries, Plaintiff Arthur Davison has sustained work loss, loss of opportunity and a permanent diminution of his earning power and capacity, and claim is made therefor. 15. As a result of the aforesaid injuries, Plaintiff Arthur Davison has sustained uncompensated work loss, and claim is made therefor. 16. Plaintiff Arthur Davison continues to be plagued by persistent pain and limitation and, therefore, avers that his injuries may be of a permanent nature, causing residual problems for the remainder of his lifetime, and claim is made therefor. 17. As a result of the aforesaid accident, Plaintiff Arthur Davison has sustained scars which will result in a permanent disfigurement, and claim is made therefor. CLAIM II BRENDA DAVISON v. THOMAS 1. MICKEY. d/b/a MICKEY'S TOWING Ii d 18. Paragraphs 1 through 17 of the Complaint are incorporated herein by reference. ii Ii Ii 19. As a result of the aforementioned injuries sustained by her husband, Plaintiff Arthur ii Iii,' , Davison, Plaintiff Brenda Davison has been and may in the future be deprived of the care, Iii companionship, consortium, and society of her husband, all of which will be to her great detriment, and claim is made therefor. 214675,IIDLLILC2 3 ~ , -'-1-' '.--- f!'__ -1'-',-1 -"," ". ,~~.,",:-""-. " ~~",~'~2~:i WHEREFORE, Plaintiffs Arthur and Brenda Davison demand judgment against Defendant Thomas 1. Mickey in an amount in excess of Twenty-Five Thousand ($25,000.00) Dollars exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ANGINa & ROVNER, P.C. Date: \ \] -d-- { ....tD M~ David 1. Lutz ' J.D. No, 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiffs 214675,l\DLLILC2 4 '0. .1' """.',1'-'''''-'''1---,- "'^,.', ,.', . ~,-.:,'; ,,~ C_'__ ." :"fii%j VERIFICATION We, Arthur and Brenda Davison, Plaintiffs, have read the foregoing COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of our knowledge, information and belief. We understand that this Verification is made subject to the penalties of 18 Pa.C,S,A. Section 4904, relating to unsworn falsification to authorities. WITNESS: /fJ- ( 1~ 06 ~.~()~ Arthur Davison / /) , /If -11J \f::,~~ A. ))A/~M'M./ renda Davison /' Dated: 214675.lIDLLILC2 II af"~-- "-ji.iii.tBI~~-' .~-" ' __-1_ --u.-.:~ -'~'~'E~'~l-..:.LLj ~! , ~ ~ ~ p "'l::, c~,"~," ill ~)'-'-;"'," ~ ~ ~ .~ ~ B~B , I ~~ 1- -'s" '_0' (') r; <- -Om mrl'! Z:-n ze ~:f;: ;<0 >0 Zo Pc Z =<! o c' a n "-I w Cl c) " -< ;"11 ;.g' -:-J;-n ~~ .-'""'.- :to om ~ :Q -0 ::~ w .. "'" """ " ~ , 'l Ii I') ! ~ j H 'i i ~-1 lj c, ,. Ii Ii '1 Ii i' II II 1;1 i,1 ~i n !j ri ~ l I I g =~ -~~~ ~ "_ '^ j __tl ...- . SHERIFF'S RETURN - OUT OF COUNTY , CASE NO: 2000-07693 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DAVISON ARTHUR ET AL VS MICKEY THOMAS J ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MICKEY THOMAS J D/B/A MICKEY'S TOWING but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On November 28th, 2000 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge Dep. York Co 18.00 9.00 10,00 32,35 .00 69.35 11/28/2000 ANGINO & ROVNER ~c>> ~ Thomas KIln Sheriff of Cumberland County Sworn and subscribed to before me ~~ L,A . this .3D '- day of !~.ILn_../ d.o-o-o A.D. C)-y,,-,,-,o. )u,.iI/2'c 40t'~ Prothono ary ~ COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST" YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN ':' , " ::,:,lfiI~Buc.nOfil$ , :'. ' ',::.,. " :el.,~$J: TYPJ:QfilLY I.INE1'TO 12 '" ' "'bONOT DE1'4CH ANYCOPIE$ 1. PLAINTIFF/SI 2. COURT NUMBER Arthur & Brenda Da,-ison 7(\ _7"0., (';vi], 4. TYPE Of WRIT OR COMPLAINT 3. DEFENDANTISI Thomas J. Mickev, d/b/a Mi~key's Towtng Notice & Complaint SERVE { 5. NAME OF IND,IVIOUA, L COMPAN, Y; CORPORATION, ET~. TO SERV,E OR DESCRJ:TION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. ....... Thomas ,:T. Mickey, d/b/a M],r.key s TowTng ..,.. 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO., CITY, BORO. TWR, STATE AND ZIP CODE AT 10 Crescent Dct-'e, New Cumberland, FA 17070 7,INDICATESERVICE: 0 PERSONAL 0 PERSON IN CHARGE ttEPUTIZE ('1IrrAJ,~~ \If\J\.rl 0 1ST CLASS MAIL 0 POSTED o OTHER NOW 1. 1 I ~ 100 , 20 I, SHERIFF OFlMOflf< COUN P 0 here~y d g , the sheriff of York COUNTY to exec et " .[lCcording to law, This deputation being made at the request and risk of the plaintiff, SHERIFF OF UNlY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE; C urn be r 1 and ADVANCE FEE PAID BY ATTY OUT OF CQUNTY CUMBERLAND NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAJVER OF WATCHMAN - Any deputy sherjff levyjng upon or attaching any property under within writ may leave same without a watchman, in custody of whomever IS found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9, TY~~6"D&-'m~TT~tP~~IN1:mz'i" ~~URE 4503 N. FRONT ST., HAR.'USBURG,PA 17110 12. SEND NOTICE OF SERVICE COPY NAME AND ADDRESS BELOW: (This area must be completed jf notice is to be mailed). 10. TELEPHONE NUMBEA 11. DATE FILED (717) 238-6791 10/30/00 CUMBERLAND COUNTY SHERIFF SPACE BELOW FOR OSE OF THE SHERIFF. DO NOT WRITE BEI.OWTHIS LINE 13. I acknowledge receipt of the writ 14. DATE RECEIVED 15. ExpirationlHearing Date or complain1 as Indicated above, J. LUDWIG 11/08/00 11/29/00 16, HOW SERVED: PERSONAL ( ) RESIDENC POSTED ( ) POE( ) SHERIFF'S OFF ( ) OTHER ( SEE REMARKS 17.01 hereby certify and return a NOT FOUND because I am unable to locate the individual. company, etc. named above. (See remarks beiow.) 22. REMARKS 42. day of 44. Signature of Dep. Sheriff 45. Signature of York County Sheriff WILLIAM M. HOSE 46. Signature of Foreign County Sheriff NATURE ~~ 11/21/00 49. DATE 50. I A NO EDGE RECEIPT OF THE SHERJFPS R OF AUTH A/ZED ISSUING AUTHORITY AND TITL 1. WHITE K Issuing A~orlty 2. ~JNK - Attorney 3. CANARY - Sheriff's Office 4. BLUE. Sheriff's Office 51. DATE RECEIVED :':j~~' '-\ ,- ~ 1'.~7 ~~}, < .:",,:;' .1;~"~\U'; 'r:;\ ~ '-' ;,.'~ .' . -'-....-, <... "f") rd~CEIVE0" OFF/GEOF SHERiff YORK. PA '00 NDU 8 '~, "j1~MilTm _J"i'tiii~g.~~Y1K~_1~ti~M'~jii!M!."Ift~~iI\!ffl~f~@!W~~-~M!\"t~;h1W!i~l<};~'ifitv..~'il;1;e'" P[1Jl 23 ,-","' ,<l" 1 ",-,'_c_;.- ',<,__,;,,_,l -.,"--,.,~,.,-,_.,"- ";'" , ;:J!i . ~ COUNTY OF YORK OFFclCE OF THE SHERIFF SERVICE CALL (717) 771-9601 28EASTMARKETST.. YORK, PA 17401 . INSTRUCTIONS PLEASE TYPE ONLY LINE 1 TO 12 DO NOT DET~CH ANY COPIES 2. COURT NUMBER SHERIFF SERVI(:E PROCESS RECEIPT, and AFFIDAVIT OF RETURN 1. PLAINTIFF/S1 ~ i ",- ( ry, ....,_.] ., ;"';;'-!~.'1 R~""" . -4. iYPE OF WRIT OR COMPLAINT -- ..- 3. DEFENDANT1SI SERVE .. AT . - _'_:,~_ . . ,','rpr ii!b/;'~ ~''[i''''k0yrS'-" lrr;;.~1;)-g-- , - 5. NAME OF INDIVIDUAL COMPANY, C.PRf:lORATIOl\l. ETC. TO SERVE OB DESCBIPTION OF PROPERTY TO 8.E L~IED. ATTACH.EO-> oR SOLD, ,. 4 -', '.~~ C ",1- .,....,.;~; D,^ 1 7 (\ '7 n ._ o PERSON,iN_GHAR(3.!; , __~'Rff1irgg,c",.,,9.9'f1T,f!!!Nb, ._~IQ~"-~_ _~'-eQS,m) __OOTHEB ,go_j,SHJ:81FFQFYOR~CO_UNTY, PI', do hereby deputize the sheriff of '.' n~' k ~ i- - m~--CQ1JN.1YiQ~execiufettiis WCiland 'rn:aker~turnthereof according to law, This deputation being made at the re.quesl <md.risJLQf.1ile_ plaliii1fCm------- --'--~- -,,- m' -- ------.---- V ~- . ___' ~$HEA[FF QF'i'Ol~KCOUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL A~S-IST IN'~){PEDIilNU SERVICE:-w { .- ~ roo ,_, -.~;>" j c: "r-',1~1-i ")(1 6. ADDRESS (STREET_OR RFO WITH BOX N_UMBER. Apt.: NO,,-C1TY. 130110->. fflP... S1'.ATt=~N-D-?if' t::ODE: 7. INDICATE SERVICE: o PERSONAL NOW '" ": ..--:-..--_;.nl'iH~ ; Otrlll)JP C.)~}~.'1_y CUMBEHI1'J<D 1', [";V '\N:''::: t~~ :<' li!\:...J 1::.1. A:rTY NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.6, WAiVER OF WATCHMAN - Any.deputy sherJff levying upon or attachjng any p"r.,gperty under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attac~ment, without liability on the part ~f such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. - " 9. TY~~"'~~~f~N~",ADt?tw.'~}kA;r~~ol~ {P'~~I~~~~'S~~UR'E 10. j~LEF'-'40NE NUMBER '::.1>-;:: N. F'Hcin ST~~ HARRfSBURGrPA 171,lQ ~ j7_~T /"i.::_.:.,~ 12, SEND NOTICE OF SERVICE COPY NAME AND ADDRE:SS -SELdW: (1'hi_$__aie~ m.ll_5t Ol;!j~QrQRI~t~a:TfD-Qtig_els tb'b~ m~n~.al: 11. DATE FILED :'J,"2E.Hl..J\t-ill o..JiJl.,-rl'Y SHERIFF _ "_ ,,- ,,~ ,. SPACE BElOW FOB U$11: OF THE SHERIFF. DO NOT WRITE BELOW THIS [rIlE ,h 13. I acknowledge receipt of the writ 14. DATE RECEIVED 15. ExpirationlHearing Date or complaint. as indicated above. v.. Wr:.~'~ l.G 1.J../0,$90:.; 16, HOW SERVED: PERSONAL ( ) RESIDENCE (,f' POSTED ( ) _ POE ( SHERIFF'S OFF ( ) OTHER ( ) SEE REMARKS 17. 0 I hereby c,ertity and return a NOT FOUND because I am unaQ1E! t'o lOG-ate tbJ!, lIJ9iyid!Jg.1, pgmRal1Y~ et9._ named .a_b9ve._f$_e:e rem8!!5~_ qe~.) 18. NAMEAN~lJTLE_OF.l~~lVIDU~L SERVED I LIST A~D~~SS.H!;8E ~E~OT_~'RkjYJtiA~9~1i=~{B:1tl.~Q6~liif~t9'oe.f~n~_~tltl~' .-f" ._._,_',.. J.~,-P'!te_ of ~elVice . 'J-.:.__ ,. I, ,. ,; ... ,. t.; .! '_ :'t' f). ~ /, /-, :.' , ' -' i /' f \.. l\ n- 21.ATTEMPTS Date Tirne Miles lot lnf Date Time Int. In!. Date rime Miles Int. Int. 22. REMARKS___ , 23. Advance C_osts Check No. ~JQ.OO 40. Cost Due or Refund 41. AFFIRMED and subscribed to before _me this ?i_3t_ 44. Signature of Dep. Sheriff 45. _Signature of York County Sheriff 47. DATE 42. day of ,-~.~~, . F>FtOTHO fNOiARY 48. DATE ! " 46. Signature of Foreign .'.i ... ,/ ~.' Coun Sheriff 50. 1 ACKNOwt:ElJGE RECEIPT OF THE SHERIFF'S RETU~N SlGNAiUBE_ OF AUTHOF{]ZED ISSUING AUTHORITY AND TITLE . 1. WHITE ~ Issuing Authority 2. PINK. Attorney 3. CANARY - Sheriff's Office 4. BLl;'~E . Sheriff's Office 49. DATE 51. DATE RECEIVED '--~-- 0' 'n' ;-'-~. i, Arthur and Brenda Davison Plaintiffs IN THE COURT OF CO~~ON PL&AS OF CL~mERLAND COUNTY, PENNSYLVANIA NO. 00-7693 CIVIL 19 vs. Thanas J. Mickey, d/b/a Mickey's Towing, Defendant RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form; P~TIT.!ON FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: David L. Lutz. Esq. . counsel for the plaintiff~ in the above l. 2. action (or actions), respectfully represents that: The above-captioned,action (or actions) is (arei at issue. The claim of the plaintiff in the action is $ b~...Q 0..b;;7 The counterclaim of the defendant in the action is The following attorneys are interested in wise disqualified to sit as arbitrators: the case(s) as David Lutz. counselor are other- Esquire and GAnrgp. FA 1 ] @ox _ Esauire WHEREFORE. your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. 1-16-01 Esquire R ORDER OF COURT AND NOW, , iE;!od ~ in consideration of the foregoing Esq., nted arbitrators in the Esq., and ,Esq., are above-captioned action (or actions) as prayed for. P. J. f" i II Ii ~ II i' Ii i, " II II b " " " I.J Ii i< I; L I:; 1;1 " ! 1'-1 :-',""""","" ~, ,- ,.".,.~ " ~ >- 0:: ~;:~ co c-,: >- l'- Z ;:<~ "--)--;;7 "~:')~~ ::;)~ :~-~. (I) :)2 ~-S:Z -.+LU ~D- b rr- ,-. <:) 1:11 r'D-l'C""'q: "..C_", .r,"f"lv.... OF THr:' PP'Iru'iNO' T.'Any """ , ,,"~ r-K) ""11 01 .IAN 19 PM 3: 32 CUMBERLAND COutfIY PSNNSvlVAN/A ')- a ~~~ E 1; -b; d c2 - , , ~~,~>- _U'1!:,,~_~' > ~f':', 1""" ,~'''' ~~ '......,..~~~-~ - '~""'"-' " T_~~'" , _ ~ -""- ~ " , =b. HI "~ ...;; , , , Arthur and Brenda Davison Plaintiffs IN THE COURT OF COtMON PL~AS OF CL~IBERLAND COUNTY, PENNSYLV~,IA vs. NO. 00-7693 CIVIL 19 Thanas J. Mickey, d/b/a Mickey's TC\d.I1g, Defendant RULE 1312-1. The Pecicion for Appoincmenc of Arbicracors shall be subscanc~ally in che following form; PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: David L. Lutz, Esq. , counsel for the plaintiff~ in the above 1. 2. action (or actions), respectfully represents that: The above-captioned action (or actions) is (arej at issue. The claim of the plaintiff in che action is S U\~~AL{~ The counterclaim of the defendant in the action is The following attorneys are interesced in wise disqualified to sit as arbitrators: the case(s) as counselor are ocher- David Lutz, Esquire and ~()rQ:p. Fa] 1 p.r. Esauire WHEREFORE, your pecicioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. 1-16-01 Esquire ORDER OF COURT AND NOW, j, , :t9,;:LaJ ~ in consideration of che C1/Wbll 1: . Esq., tf_-~-~/(~ ,Esq., are appointed arbitrators in ,the foregoing Esq., and above-captioned action (or actions) as prayed for. P. J. I I -!" c' ._~" ^ v.".,' ,--,--'--'~ '_"_~'I """'~:'.",~" ;"'.' "". ;"""~ "_",_"_"c'_i "_";"_-'__;-'~'_-,,-. f-'i ARTHUR AND BRENDA DAVISON, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-7693 CIVIL TERM Plaintiffs vs. . . THOMAS J. MICKEY, d/b/a : MICKEY'S TOWING, Defendant CIVIL ACTION - LAW NOTICE OF HEARING BY BOARD OF ARBITRATORS You are hereby notified that the Board of Arbitrators appointed by the Court in the above captioned case will sit for the purpose of their appointment at the offices of James D. Bogar, Esquire, One West Main Street, Shiremanstown, Pennsylvania 17011 on Friday, March 30, 2001 at 8:30 a.m. Any party requesting a continuance will assume tqe responsibility of contact and notification of all parties to re-schedule this hearing. James D. Bogar, Esquire James D. Cameron, Esquire Gregory L. Cutler, Esquire Date: February 27, 2001 TO: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 George B. Faller, Jr., Esquire Martson Deardorff Williams & otto Ten East High Street Carlisle, PA 17013 Court Administrator - ...L~~.~ J '~~'m.:' F:\FILES\DATAFILE\Prgdoc.cur\124,pra,1\ajt Created: 12f04l0008:32:1:5AM Revised: I2I04/0011:30:12AM " ARTHUR and BRENDA DAVISON Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ':\1oq3 NO. OO~ CIVIL ACTION-LAW THOMAS J. MICKEY d/b/a MICKEY'S TOWING Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant in the above matter. Defendant hereby demands a twelve juror jury trial in the above captioned action. MARTSON DEARDORFF WILLIAMS & OTTO Attorneys for Defendant Dated: December 1, 2000 ""~ ~-~- ..L.~I - ".,. " CERTIFICATE OF SERVICE I, Ami J. Thumma, an authorized agent for Martson Deardorff Williams & Otto, hereby certifY that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: David L. Lutz, Esquire ANGINO & ROVNER 4503 N. Front Street Harrisburg, P A 17110 MARTSON DEARDORFF WILLIAMS & OTTO BY~~~ Arlli J. Thu a Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: December 1, 2000 li~rt:uJ '~L~!W__.:ti'l:.d:--I.L'I~~!..~~~-J.'lr1i' ~, ,< ^ -'.. .' '. ~"' "" ,< ", . -"11 , . (') c::;; 1~... c::: 0 -n g: CJ >1'- "'Oro r'1 ,..---r'l ~rn ,""> : ~"1;.' -, X t '1~S9 tJj5:= Ul -=<2 ~~~ kU -0 ~O :Jl; >2 r:- '=-1 ,. ~ >;:> ?6 -< '.' n~ ._,~o, , - __ l~~ "-I';',,': .'C~ ,_~~,_--::.. <-:~'"'-:d:::-; tj-jftj'~:\1 ",- ARTHUKAJND BRENDADA VISON Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. CIVIL ACTION - LAW THOMAS J. MICKEY, d/b/a MICKEY'S TOWING, Defendant NO. 00-7693 Civil Term JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER 21. through 24. The allegations contained in the Defendant's New Matter, paragraphs 21 through 24, are all conclusions oflaw to which no response is necessary. The factual allegations contained in the Plaintiffs' Complaint are incorporated herein by reference. WHEREFORE, the Plaintiffs respectfully request that the Defendant's New Matter be dismissed. ANGINO & ROVNER, P.C. Date: (/\C\' 0\ ~utz LD. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiffs :1 II ""jL_'__, :, b~4'~- "~" - ""^.~"-~-- '^ '," ,,' -;.-;"- '"'-- ""' . J "i~1 ~ "" ~-.....",. CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER upon all counsel of record via postage prepaid first class United States mail addressed as follows: George Faller, Esquire Ten East High Street Carlisle, P A 17013 Attorney for Defendant Dated: \ - \ C\ - CJ \ 225734.1\DLL\MTG II Ii \';,:,""'" , d "'---"""' ~ . '':''''''''1 -ume , - - ,:""- ,-"~- -.." -':.<. J.:hi;;-';'- ,'- ,~,- I ~ ii~_lJ~j.oli;llll_!l]i!Jir'r_.w~IlIll_ ,= .'-' """ '.,II I ! 'ii :'i "I , ,.I ,'! ',I 'Ii I (i U 11 II H 1:1 I;i _'C ~ 0 0 -n '- ,-~ -~ -00:> ="" f'1'i# mm % ZXi N c.,~)rn ZIj; -'0 (J).::'; N ~~ 1 ~0 <._" ( , -0 :ij--f:' ~. :x {-Sill ZO ~o Lrn :<>2 ~ Q ~ w ~ N -< , " - j..-. , " ---. '~b.-";' ,I '-;.-o-:--,""'I':.c1 /\, .,,~"-c,^ -",.~ :-.~",,,\ '-'-- ',.;c_" L's..! ANGINa & ROVNER, P.C. 4503 NORTH FRom S'TREET !1ARRISBURG, PA 17110-1708 RICHARD C. ANGINO NEILJ. ROVNER JOSEPH M. MELillO TERRY 8. HYMAN DAVIDL. LUTZ MICHAEL E. Kosu< RICHARD A. SADLOCK JOSEPH >L DORIA JAMES DECINTI 717/238-6791 FAX 717/238-5610 WWW.ANGINOROVNER.COM E-MAIL: DLUTZ@ANGINOROVNER.COM March 21,2001 James Bogar, Esquire One West Main Street Shiremanstown, P A 17011 James D. Cameron, Esquire 1325 N. Front Street Harrisburg, P A 171 02 Gregory Cutler, Esquire 50 East High Street Carlisle, PA 17013 Re: Davison v. Mickey Gentlemen: Enclosed is Plaintiffs' Arbitration Memorandum. The above-captioned action IS scheduled for arbitration on March 30, 2001, at 8:30 a.m. at Attorney James Bogar's office. Very truly yours, ct\~ DLL:mtg Enclosure cc George Faller, Jr., Esquire (w/enc.) 22B607.1\DLLIMTG . ARTHUR AND BRENDA DAVISON, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA . v. CIVIL ACTION - LAW . THOMAS J. MICKEY, d/b/a MICKEY'S TOWING, Defendant NO. 00-7693 JURY TRIAL DEMANDED PLAINTIFFS' ARBITRATION MEMORANDUM . I. Facts Plaintiff Arthur Davison is the owner/operator of Petroleum Tire and Automotive, a garage located at 1599 Hummel Avenue, Camp Hill. On February 5, 1999, at approximately . 9:30 a.m., Defendant Thomas J. Mickey, while in the process of delivering an automobile to Mr. Davison's garage, negligently lowered the flatbed of his tow-truck onto Mr. Davison's right foot. Mr. Davison sustained a crushing injury to his right foot; he experienced immediate and . excruciating pain and was unable to bear weight on his right foot. The garage employees heard Mr. Davison scream in pain. Mr. Mickey apologized. John Fisher, one of Mr. Davison's . employees, drove him to the Emergency Room at Harrisburg Hospital. II. Damages A. Medical Treatment 1. Harrisburg Hospital's Emergencv Department Mr. Davison was evaluated at Harrisburg Hospital. X-rays of his right foot revealed . fractures of the distal shafts of the second, third, and fourth metatarsals. Secondly, a laceration on the dorsum of Mr. Davison's right foot was cleaned and dressed. His right foot was splinted . and he was given crutches. Mr. Davison was given prescriptions for Vicodin, a pain medication 216519.1IDLLILC2 . ",--- . , ~;""."l ,,-, ,- ;- "-,f '0,-" 'F~;'-'-" ",~,_,_ -,,"~"_'-- -';0:.: "., "0' ,'- -.',,, ,,,,~_~,,",'.'i"C-,,,",O~" -, ,. -~ . . and Keflex, an antibiotic. Mr. Davison was discharged with instructions to keep his right foot elevated and to apply ice to decrease the swelling. Mr. Davison was also instructed to follow,up with an orthopedic surgeon. Attached as Exhibit A are Harrisburg Hospital's Emergency Department records. . 2. Dr. Jason Litton A. Treatment for foot iniury . . On February 8, 1999, Mr. Davison presented to Dr. Jason Litton, an orthopedic surgeon. Dr. Litton examined Mr. Davison's foot and found extensive swelling and "mottling" on the dorsum of the right foot. Attached as Exhibit B are colorcopies of three photographs of Mr. Davison's foot. Dr. Litton prescribed a DonJoy walker and instructed him to return in two weeks for x-rays. On February 22, 1999, Mr. Davison returned to Dr. Litton's office. Mr. Davison's right foot had given out and he fell against his left hip. Dr. Litton's examination ofMr. Davison's left hip was essentially normal and diagnosed him with a contusion of the left buttock. X-rays of Mr. Davison's right foot revealed that the fractures were starting to heal. Dr. Litton recommended that Mr. Davison increase his weight bearing on his right foot and return for x-rays in one month. On March 22, 1999, Mr. Davison returned to Dr. Litton's office. He was still wearing a DonJoy walker. X-rays were performed of his right foot revealing that the fractures were begiIming to heal. Mr. Davison continued to experience right foot pain and coldness. Dr. Litton noted that Mr. Davison's right foot was cold compared to his left foot, and he was concerned that Mr. Davison's symptoms might be causalgic, related to nerve damage. Dr. Litton instructed Mr. Davison to return in three weeks for more x-rays. . . . . 216519,1\DLL\LC2 2 -----'_^.-,-'I'-'.-- "-",,- ,,-'" .~.,''''-'- ,>(:--- '--"-' . ],-,:0 --,-'~I':;: ~-" "-',-", ,i;-;", -' ,." '.;""~',, .'",,,'",~_ ),,,'~/",'~- ,.~ ;,-, 'j,:." '",,"" , ~~~..1L: . . On April 13, 1999, Mr. Davison returned to Dr Litton's office. He continued to experience pain and swelling in his right foot.. X-rays of Mr. Davison's right foot revealed that the fractures appeared to be healed. However, his foot pain had not resolved. B. Treatment for left shoulder iniurv Mr. Davison did not see Dr. Litton again until December 7, 1999. He presented to Dr. Litton and related that he was experiencing severe left shoulder and elbow pain that resulted from slipping and falling in the bathroom in October. X-rays performed of Mr. Davison's left shoulder revealed that there was no evidence of fracture or dislocation. Dr. Litton diagnosed Mr. Davison with traumatic bursitis of his left shoulder and trawnatic lateral humeral epicondylitis. Dr. Litton injected Mr. Davison's left shoulder with Xylocaine and Celestone for pain, prescribed a forearm cuff, and instructed Mr. Davison to perform passive range of motion exercises of his left shoulder daily. On December 30, 1999, Mr. Davison returned to Dr. Litton's office for follow up. His elbow pain had resolved; however, he continued to experience left shoulder pain. Dr. Litton repeated the injection of Xylocaine and Celestone in Mr. Davison's left shoulder and recommended an arthrogram of his left shoulder to rule out a rotator cuff tear. On January 26, 2000, Mr. Davison returned to Dr. Litton's office. An MRI performed on Mr. Davison's left shoulder revealed a rotator cuff tear. At this time, Mr. Davison was also experiencing left buttock and left lower extremity pain and nwnbness. X-rays performed of Mr. Davison's lwnbosacral spine revealed narrowing of the L4-5 and L5-S1 disc spaces and some bone spurs through out the lwnbar spine. Dr. Litton diagnosed Mr. Davison with sciatica. On February 3, 2000, Dr. Litton performed a Neer acromionectomy to Mr. Davison's left shoulder. Mr. Davison tolerated the procedure well and healed well thereafter. Mr. Davison was . . . . . . . . 216519.1IDLLILC2 3 . ~ n, , . _ _ '~~'.' .,-' ""'-. he-.'" ''',,- __ <>_;,,_ J - -l'^ ;,.o-c->_:' ::s..l!,"~ ,"'c_,.,;'.',., ."'"_,.~,, ",;,.,-"";,"J.:<.,,,,'-j;';',," ,-,' 'llI1~_~ . instructed to perform passive range of motion exercises. He followed up with Dr. Litton twice . after the surgery and was discharged from his care on March 2, 2000. Attached as Exhibit Care Dr. Litton's records. . 3. Dr. Craig Fultz Given Mr. Davison's persistent right foot pain, he sought a second opinion. On June 1, . 2000, he was evaluated by Dr. Craig Fultz, also an orthopedic surgeon. Mr. Davison reported that he had ongoing pain in his right foot for over a year and it was worse with weight-bearing activities. At times he would walk with a limp and the pain was worse when standing on hard . surfaces and changes with adverse weather. Upon physical examination, Dr. Fultz noted an obvious antalgic gait and noted "coolness to palpation distal to the crush injury area. There is minimal swelling about his foot. He has . palpable pulse which is slightly decreased in quality." Dr. Fultz obtained new x-rays and noted a moderate amount of callous formation. His . diagnosis was as follows: 1. SIP crush injury to the right foot with residual pain. 2. SIP closed right second, third and fourth metatarsal fractures - healed. . Attached as Exhibit D is Dr. Fultz's June 1,2000, office note. . . Z16519.1IDLLILCZ 4 . ^. 'H " ",","- _ __ ~d ~I",,__ -"''''- 'ok-~'M_ ,.iC'A_C - ,"-_~;\.!";,,,_--, -, . III. Conclusion . Based on the documentary evidence attached hereto and the evidence to be provided, the Plaintiffs would respectfully request that this Arbitration Board enter an award in their favor. . ANGINa & ROVNER, P.C. D~ I.D. No. 35956 4503 N. Front Street Harrisburg, P A 17110 (717) 238-6791 Attorney for Plaintiffs . Date: 3 ~ II - tJ/ . . . . . . 216519.1\DLLILC2 5 . ~"~'" ~"I<-~~=-,,"~"',-<' , ~ !,"- ~" ~, ' . " ~I-I ~~~ . 1 ",....., . ^ . ) PINNACLEHEALTH DAVISON, ARTHUR R RM# HER MRN 176-34-8680 CASE: 00990219361 ADM' 02/05/99 I \ I I I I i . HARRlSPU~G HOSPITAL 111 South Fl'Ont Street Hamsburg, PA 17101 EMERGENCYOEPARTMENT . HISTORY Patient seen with a complamt of a foot InJul)'. ThIs IS a 55-year-old male who presents complaints of pain In the right foot from a rollback from the truck that was aCCIdentally dropped on hiS n t foot He has been unable to weight bear Since He has a lot of swelling and bruiSing, s~vere pain a d throbbIng In the nght foot He also has a small cut on the foot dorsum He IS presently on no medlcln . and he IS allergiC to IVP DYE He is not allergiC to any oral meds . 11 , I PHYSICAL EXAMINATION The patient IS alert and oriented In general he IS undlSlres~..ed while he~ seated and hiS foot IS elevated Temp 36 2, pulse 75, respIrations 16, blood pressure 161/93 The ng t foot has a small 1 em laceration on the dorsum over the first metatarsal head He has ecchymOSIS all ov the dorsum, a lot of soft tissue swelling He does, however, have good capillary refill H~ can flex a extend the toes Just slightly He has no ankle tenderness He does have a good dorsaIJs.p.edls pulse q TREATMENT Supervising phYSICian IS Dr Taylor, With whom case was discussed X-ray of the foot I Significant for nondlsplaced fractures of the second. third, and fourth metatarsals No flrst or fifth metalarsa fractures were noted Sue Miller was contacted and came to see the patient The foot was dressed Wit antibiotic ointment and stenle gauze on the laceration. AJones dreSSing was applied. as w"!!' as a posteno sphnt He was given crutches i DISCHARGE INSTRUCTIONS/FOLLOW UP Discharged With Instructions to 9.0 home an~ Ice It, elevatJ rt Take V,codln one every 4-6 hours as needed for severe pam He IS not 10 dnve, and he cannOllak~ any alcohol while he IS on the Vicodin He IS also to take Kef/ex 500 bId for 5 days he should follow u, WIth Dr DeMult1, calling today to make an appointment Return here ,f wors~ For now,., the pallent IS unable to return to work ; \ I I I \ I \ I , DIAGNOSTIC IMPRESSION Right foot fracture it it it c . 00: Of: 0#: 02/05/99 02105/99 /kad 42:3544 ~~ CARRASCO, .9 ~ . ., ER REPORT ER REPORT CHART COPY ER REPORT I '!D c.~_~~_",-~kn=_~~""""'~j~1I111 . ~) PfNNAClEHEAl H ~ HOIpIta - ..ill...... ...~~~ --~ ' ~- =-iMiIilIiMi -dliliiiIV:!l:;",11.~~"t', MEDICAL R~CO~S TIME aim , \', 3C 2 . DVJ51T ~li a CP CENTER HAS o CAmCALCAREHoLD ~ o TRNJh'lA. ALERTfCASE 1_ D e"'oo TUBE o CARDIAC MONITOR DEKG o IVAClMINI PUMPS o lVCA.THETERlPRN ADAPTER D SUCTION Do,_lPM o PlILSE OX D PEAK FlOW o At:ROSQL TREAT . PHYSICIAN LE\IEL OF CARE o I MED SMER On Dv o III s!!y OIV ~A Ov o Gn1QI CiIIv . STAB LYMPH MONO ,OS . MIIIl2l~ ~)Hlll S:J'\J ,~] 1 rHLJf< 17b .,:1,_ aL~ FIRST PLACE " ~ n_1T D....a 0,""" D au.\llTA~" PAEG DACETONE . I o OLUCOSE DIlllAIITflVEPAEG DAM'ItJoSE o HEPAltc ClMPEAT~P,IS '" DCARCIAC ISO PANa. OAHFAtroIl OCARDIAC PANEL DHaH OAPA -.""" \1-...... \..4-h Ocec OH" o EIASlCMETPANEL ~~ OCOWME'r o UPASE o TICROSS PANEL o PT/PlT DT$C'EEtI OCSF DWA o E!.ECTROlYrES CULTURES o HeRPES o BlOOD x_ o SPUTUM DURiNE O~Oil\i DWOUND STREP ROU'lINE RAPID DRUO DACETAM D"",,^,,' DNOO-MDA SO....N DASA o DlGOXIN 0_ DDll.ANTIH O_EN 0,... D"'" OlHEQ '''" Du~", ST. o GI:,ICI-IUJ.f'to'OL.\ GENE.wp (J Be CULTURE DCIlAM\'D~CUlTllR' '<<l1l>Ell ACT BLOOO_ wee ,... CAST' BACT N",..T'" EJ(G '! 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INSURANCE CO NAME fI;-,4/r-l' < HI" I r GROUP NO POUCY NUMBER r:",'1(11/I1 III (.'BDllL;:,,,[lL \71 . r L j C r- PATIENT NAME . ~)liVJS(lN 'I n~~n.l~r j e, PRDDOCf~ U~N 111\ l ~ '/11 1 HOMlf . f_ t- Fol'm H02SO ~ 4/96) , ' TIME AGE DATE OF BIRTH S M R SOCIAl SECURITY # PIT FIC MEDI '>, D ADDRESS R CAMf' ,!ILL " I' 'I' ~ I 1 dl ~"''''''''i~""..~U_l~~ll"'-~~~'~~ '---.~""I""""""""""'" ^ ~~~~"'~OI!!~iJl~~.I~11IIiiIIMiI ~t~~~""""'~'!fI'"]i\!;irj[1.t)ltd;t_",~;~\'<'L\ . DATE . - 9 TIllE ~ (j TRIAGEHOTE: FI,R'1' P~d...CE NAAtE ..J Jh '-' ~.1?t. TII8QO€latuo: tu~ . CUflRMMEDICA110NS HPI _W1III~ ;";1,3 o Spouse 0 F_ I o P..... 0 FamIy , o PoIc:o 0 o SpoaknoEnghoh- -: ',II .-., ff , '. ?Z cfl"LtL RESP Z'llogular o IIoundJ1q .Id'Onlabo1ld o ~rod Olleep PRUIAlI\' ASSESSIIENT IJ~ DOlIler 0_ o Regular D~ o Shallow cY if- . PUlSl: o AudibleWlleeze DR<l~_ 0_, '1 i~(\ t:----, I'J...-. >' . ~""" 0 FkIshed 0 Dusk\' OPaIe 0__ OC\lOllOllC S~N....----- j.i'WB/Ill 0 Cool D E<</Ijm_ ..-Billy Olliophorotlo DOIlIer o Hot D Raah 0 OIlIer IIEIlTALASSUSIIElI'tl 0 lImoIponsiVe D In1onVCIII\lI l'reabI$ItPnorIoAnlYal ~~pnaIo ~ ~~~/S~ NwsIl9Ac11on1CommonlL L 1 ' o 1lGnted/F1al -0 Impahd D 811011I 0 l'egue/lltlCOlll1OC TETAllUSSTATU8: 0 Wlllml0V.... M...Than 10,\1011 o lleleosNa 0 - 0 T1III_ 0 SIowIa_ D ru...a-:: /. !::l:l7P'" _____ D Appehe_ Cl D_ PO$I 0 RepelJm 0 Dlsonenled CI\ILIllIllOD -,WIlAllONS: 0 0 _ 111L o ReslIes8/C<Imbellve 0 Mumblmg 0 Polson '4 o AvOIdo. _ 0 SIumld 0 Place 01lme 'I1I1of,GE HUllSESlGIlAT\lRE L ~ TREATMENT IN PROGRESS ON ARRIVAL: 0 NlA 0 N/A 0 NlA PIlSlO8PITAL MEOlCATIOIl ~ Cl Cl'll _d Down 11m. 0 MonllOr RhyIlm RIIIO " o hrWfI( 0 0ltI 0 N01lOI 0 ET 0 HI SIze 0 Oxygen 0 MaaI< 0 NC - UM,n o v._"._ 0 c-coIIar 0 ClD 0 l""9- o III SoIubon $Il8 SIZ8 0 PuIBe OJ. CI\em_ o III SoIubon $Il8 SIze 0 Other o SwoIing o PMH .:;J~~u ) / o~ . . o iliA LlIItll SOUNDS: 0 iliA -- GLASCOW COIIASCAI.Il -J . 1 3 6 lift: RIIlht A_ 2 4 5 11ME o Cloer D_ D Cloer , i D WhH.. ",IS ll) 10 .,...... SCORE O~ 0_ o ClacIcloai'OIllm_ ~ ""'" ""'" - """".... DilIll'IlbIee 0_ o Rumblea i! 0_1 "'"""- .... _.- .... SCORE ,~ 'II$UA\. At\llt'f: -...... ..... ...... Pupls. 0 iliA 4.0 NA .....""~ ....... ..... I.d o _-SIze ,. """" .... ... ..::.0 SCORE 11Im D Col>et:IlId --...... .... OS~ ONR 5.0 tIni:GINcIId 2. . TOTAL Right 0 _-SIze lllm 8.: o Sluggoh D NR 3. I GOIlIIeII ~ - NURSE'S SIGNATURE PLAN OF CARE, D _ PaIenl MWIJII D lI<mIID<CanliDVaSllllIer_ o IV 0 8PMonilllr D EKG D CenllOCMomIN o SaIoly_... D_ O FallsPro_ Cl &de~...Up D OomlortM_ ' Cl PGl G<lnIIoI D P_"""COmlorl DPnlplllefolElcam Cl E>plalll Proced.... Cl Emobonel Support o _Tnchmg Cl Drsdlarg.lnsnu_ Cl 1.1001.. diagnoabc_ Cl MDI'IIl<Ir 'IiaI "9M o t.IoMor '" oIIlIulI o lIondorllO o 0Iher o 0Ih0r D 0lIler '"""I . NURSING OIAGIIDSIS, , _yCleonlnce, ,_ =AnJCl8Iy _ Bodylollip,M.m Bowel PaIlIm, AI In =llrJa1I1ongPallerne,ln~ _ CordI"" 0u\j\uI, Der.IoMed _ConIfoIt,AIl... Comm_, Impend - - - ~~,At.m - Gat ElIchange, Impelled = _,PoIenflal InjUry,_ = Knowledge DetiaI _ MoWy,AIl... -=:= = SIun IntegrIy,lmpand _ llIougIltP--.At.I. _ TI&sue PeriuoIon, At. m _ Unnaly Pdem, AI.. OUTCOMeIGOAL " . j'=-","",,~ ~ !'ll]!;f'w= Jilloli Ii.. ".",........_.~"~ -''ill. " 1 ~111 '~".J-~ ...l;_1 -it~'IWr" il.hU': ,Iihiifrh'l'iio",,*,,'-", r- 3'\\J 'T2fH~ I I ' I III \J . '!Mil' .' . . ,=~ IV FLUID: SITE 'SIZE . TIME INllIAl D05E ROlITE SITE TIME 1NFT1Jl I V. ... i r... I "."" W I' - - - TREA1IIENrlFllOCEDlIIEll' - INTAKE' OUTPUT o lABS o UA 0 IV PO Unno E-.. 0Ih o XRAY 0 0 Typo AmI Tl'PO Am! o El(G 0 0 o RESP TREATMENT TIME MED TIME MED TIME MED TOTAl TOTAl. o PlJl.5EOx. J I TOTAl. TOTAl. TIME + RESULT J I NOT1FICATION OF: o PEN< FLOW I I p _....w_ 0__ TIME + RESULT I I p_ o ...... o ABG'S TIME SITE 0_ 0_ [JCtR~ 0_ ALLEN TEST + - 0......_ 0_ TIME T P R 8/P NARRATiVE' I ~ J''''~ ,f .. .~... 01. -\., . ~. ~,,,. I ',~""'^>t-......,.I...~... ." , .. ..I'J.-<- , ~. /.,., I. ....\l".r-f~..........~l(..~ ' J,- a- Ii," ..-- ~I\L - - .. ,~ 1d".......~" ., , .u.....'...... ",t-J. ... ~tCl "'..........\0 ~t..-\--L i.. ~.. -""~ 1--, , - " ' r ", <::1"1 ~ILYVERB !ZED UNDERSTANDING OF DISCHARGE INSTIlUCI1ONS..I.....l' l<" --- I IlISPOSlI1DN: llodt of DIe: ~ lNI1W. - SlllHAlIIRli TJ< (;l"""'AnOuIoIoy ~ b....J I a_........ CJ AniluIatDtycAasiltmll a_"""'b a_ a_ ao_ a_ a - a_~ 0_ l - . .. a__ a llaIaBuo_ o CIneol....... - 4) PINNAel PATIENT IDEN11FlCATION lEHEALTH IWIIIIllIIURGIIOIlFII'AL 1'n S. "*..... , Hospitals _....1'11....... DAVISON lRHUR II I r EMERGE Ney NURSING gQ021Q3bl' 176-3'-1 &S 1?/1~/ "'43 ", '\ K c FLOW S ~EET II, p ~ r" . V , ,~t 170 I C A ~: , . - p 717-737-90 t R "'f. ., '~f p ~ EHtRGtNC eH/~C CAP \ 1 " ~ 3& I ! Fll"" 5401" ~ r,M " "( Q 07/05/99 P.1oft I 4 . . r- . . . . r- . I""' . . I""' II rll II -~~"",,,,,,",~~_~; ~~~L,~. .'JIil. . . . . . . II r' . . r' . . , l, I ~...o.1 -~" .",=~~,~ "~' ~ ~~j!g',~',!\,0clWjL<1"" r' .' , . I . t 'I ~ AUTHORIZAT FOR TREATM&:; rlconoemIO\herOl'$n. ng oIm-edlCal care, wh1ch~~.dlagnCl$hOprooed"'"andsUchm.dl _II as my aIlenrling.r 0 nsulllng pIlyslOl!ll\ or!. lrs to be necessary I el$o uncIerst!ll\rl't IS custol1l&<y' lent emergency or extr""'dm8Jy Cl ., substantial proced will be performed upon meunl..e oruntlll ha.... hlld!ll\ opportunrtyto disCUS. them wltIlmy phYSJol!ll\orother he&'tIt care sahsfacllon If I am a ompetent adult, I have thenghttoCOO$ElntorrefOSElto consenttoanyproposed procaduretotherapeutlC treatment I WIll not bel research or expen tat prooedure WIthout my1ul1 knowledge ana consl!int 1 understand thetthe practu~eofm~!dJolt1e and surgery J&not an exactscr dlagOOS18 and trea t may Involv&nsks of injury or even death and act<nowIedgethatno guwanteehu been madeto-me astothe'etiUlbl of any e)( treatment In this hos ,tal 5: , RELEASE OF DICAL INFORMATION -I hereby author"e Plnnao,eHaaIth System, my attending phYSlolan and for llther phYSla WIlhhlrnlherorwhom e/lIhemayde5tgnBleto ,eleasellll orpertofmymedlcalrecordfromthlS Inpa~ent adm..s1onloanyother heaJl/1 o....proVlder., con1Inulng care end ell1ment, to IT'If Insuranee compeny end.18 contraotual vendor., So....1 Security AdlYllnlStrlll1on, Health Carl> """'n.,ng Adml.. third-party earners then contraotueJ ven.dors, Qrthelr rept'8Sent8tIve$. forthe purpose of cotleetmg InSUrance t1eneftts so long .,tam listed CO the havtng coverage such carner j: , , I PRE-CERTIFl :T10N REQUIREMENTS -limy Insuranceoompeny o'thlrd-party reqUIres pre-cetll~C8tJon, then I understand thaI It .. ' bll1ly to contact them 0 obtam such ce_en EXCEPTION Medicare " ASSIGNMENT 0 INSURANCE BENEFITS -I herebyauthcnze my MedICare enO/or medlcoJ InsurancebenefllspayalllelOme underthel IrlSuranc:e pOliCies to e paid dlrec;UytQ PlnnacJeHeaJlh System 11 my attending physICIan and/or o'her phYSICian assoaated wrth hlmor whom he mil accepts Insurance as Ignment, then I hereby euthonze my Medicare and/or medlcallnsuranca benefrts to be pBld directly to those phymaanB I unde am hnanclally respo b1e for non-lXlVered servrcss, as well as any d:eductrbles, COinsurance or amounts In exceu of,nsurance benefrts I permit a authonzabon to -be In place of the ongmal il r'" INPATIENTS AND O"SJ:RVATlON BED PATII:NTS ONLY PATIENT SELF- EttRMINATION ACT OF 1990 (AClvilnee Directives) -I acknowledge that PlnnacleHealll1 Syftern has prlMd wntIen mformaliOl'l on n....1s to make health carelreatment de<:lSI... In compliOllCe Wl1tI the Plll1ent Self-Det.....lnalicn Poet of 1890 ~. . tl I PERSONAL V. ABLES -I understOJld th81PlnneoleHeelth System proVldes """lrtJeoforlhe 'atekeepmgofany valuable ancI ony valuablee~, pabent.... kept allhe ~ent's nS!< I hereby accepllUll responsibility for eny persona effects talcen to the hoaptlel room, Including el"'" things as de, g)assss, contact lanse . hearing 81ds end radIOS ~ ) f"" MEDICARE INPA: IENTS ONLY -I certlty !h81llulIntormal1on gt...... by meln applYing for paymentunderT1tte XVIII of the Saoiel Secunly Poet acknowledge thai I ......\iOQ a copy of "An Important Mess~gefrom Medicare My signature only acknowladges my receipt ofll"8 messagefrom Healthanclrkles not we eny 01 my rlghtsto request alll1llOWOI' mMemellobleforeny payment I realize that hfe1Jme reserveday''''!8 oncelllebrne 60 days If I should us all my full days and r;o-Jnsurance days, I agree 10 use my hfebme reselVe days for any remllnrng Oays! I ' d ' NTS ONLY -I eck~e that I have......ved acopyof AnlmportantMa....g.tmm CHAMPUS 'MYltgn_eonlYElOkn1 from P,nnacleHealth System !lI\d does not Wlllllll any of my nghts to requeat a _e'! or make me 1~8 fo, any payme i AU HORIZATION MUST BE SIGNED BY tHE PATIENT'S LEGAL REPRESENTATIVE IN llIE CASE OF A MINOR. OR WHEN THE PATIEN:r IS PHYSICALLY OR MENTA!-lY INCAP~ITATED. pate Signed Palient IS unable 10 ..g. t>eoause l.egal Rep,ese"ull1velR alienstup Hosptlel Repreeent8lNe , Hoopilal Representat,ve " AAfIENT IQEN.TlFtCA.TIOtt ..,j) PINNAe EHEALTH ~ Hospitals AUTHO IZATION FOR TREATM NT Form 09t!lO (RClIl2/9Sl {FQrmDrl~ 8241-39) DA'ISON .ART~UR. QQ021. g3bl. 17f>-H-8 12/1 ~ I "43 ') 5 ~,C 1101 I' 1I.,,-'-ex,'~E '.!/ Ch " r, 7 p.117-Q06l lR " "BIP .(MERaE~CY ~,,! ,'., ,f'_ 36. ~- I OJ , " " o - .~ .. .. . , d . r\'/(I~/ClQ ,_~J . . . 1ft :it :it It lit '~ 1>> . :it ~-~,",,- ~"- - .-.-- '~<:~ .'- --r -__ __. -' .. c~ ';1 I , , , i PLEASE N011E THAT THE INSTRUCTIONS CIRCLED OR-CHECKED BELOW PERTAIN TO y~u. The examination and treatment you have receIVed In the Emergenoy Department has been rendered on an emergen basis only, and '1l not intended to be a substitute for, or an effort to provtde complete medical care. If you develop new problems or complications, contact your phYSICIan or thIS Emergency Department ' . i I I Laoeratrons. Abr~lons. Bums 1 Wash dally with soap and water 2 Keep area olE/an, dry, covered/uncovered 3 If area becomes red, swollen hot or IT drainage occurs, return to farmly doctor or Emergency Department 4 Sutures out 111 days Sorams. Strams of Extremet,as 1 Apply ,ce, '/1, I : Ii on I off for 24 hours. :i1. Keep elevated and rest 3 Ace wrap to r$duDe swelling 4 Crutches for ncn-w!!I9.t1I bearing comfort 5 .."" - Head Iniury 1 Given SPfJClal InstructJon Sheet Cast and Splint Care 1 GIVen Spec,al /{lsfructJon Sheet Care of Fever 1. GIVen SPfJCJaI ,"structJon Sheet Eye Care 1 Do not remove /lye patch for days 2 Eye patch to be removed by Eye Dootor In days 3 Cool compress '10 eye 4 Use the follOWing eye medication it ~ 1 .l.llIIiibliil~ 'O'iIIllllli!Ia;~(lilli-'I.;II!!....,;,+.~,,,; . ~. ,.<- 6 Genera/Instructions 1 But for off work/school from return to work on ught duty for Regular duty 2 .Diel force flUids clear liqUids 3 Medlc,.Il'1?" ! , , I ') ,~ , ,C , , /" ! 4, Miscellaneous to solt diet as tolerated " :'J :i '.j d " ,: ; , I) -' , , ~I ( d ", '( ~ j ,/' '/~ I E I I I ! , cL '. ,:'1 l,j / ,\ 5. Follow up MedIcal Services Cemer - 782-3660. cliniC Within ' 'j day,Wweek I Family PractJce Center- 231-8660:1 Emergency Department follow up " F " artl1ly Doctor I', SpeClal~ ,'I ,'. ,j; L. o The Interpretatlon of your x-ray IS only a preliminary report The radiologist Will review the films If there IS a change in the diagnOSIS, we'Wllllnform you or your family doctor 1 hereby acknowl$dge receipt of these InstructJons and understand them I understand that I have had emergency lreatment only, anP that I may be released before all of rrry medical problems are known or treated I ~II arrange for folio:"" up, care es I have ~ Instructe~ (' . '; ^ \, ~,~ t/lM/L. .( ~, I, t-c.k"lr ~)....) Dille I PEIlIeni or Responsible Party Nurse ~'> PINNACLEHEALTH ~ Hospttals EMERGEFtJCY DEPARTMENT PATIENT INSTRUCTION SHEET FormIS4(l.1.22.{Re-l7/gel ORIGINAl.. - MTlefT DAVISON ARTHUR R 17<-'4-8&~O gg021'13bl' u" ~ 12l1~!iH3 SSMe I h PAC C ( :: K LA ,1 E I 70 I I I CAMP ,'_ r, 717-737-~Ob5 I r. 7f, PI 0' EMERGEtlC1 YSU,ow-MeOlCA1."9"'\"1"I:: - ~ T' I J":. 3&, .- 1"" -'l\ " ) (" ~ I ~ () -- - ,t', -~- "~*~~ . 17 DAVIsoN, ARTHUR ~ 176348680 PAGE 1 ~ . l'INNACLBHEALTH at HARRISBURG I Rl\DIOLOGY IIIPOR'1' . MR.. SSlh ADM' . DOBI BBD. LOC. EMR OIlD 01... OIlDI" M~T DR. ~1634a6ao 176348680 990219361 ~2/~5/~943 NAIIJ!:, DAVISON. AR'l'HUR. II 16 PADDOCK LANE CAMP gILL, PA ~70ll BMBRGlIlK:Y 1l00K. ASSOC 90001 EMERGENCY ROOM, ASSOCIATES, RllASON. INJURY . S EXAM, 9000~-FOOT COMP- RIGBT-DIA-359 DATH. 02/05/~999 ~o 50 " RESULT. RIGHT FOOT (Three V~ews) 55-year-old w~th trauma t! . Nond~splaced fractures are seen ~n ehe distal shafts of the second, third, and fourth m~tatarsals. Alignment is anatom~c and there are no o~her abno~lit~ea. 'j '-j CONCLUSIoa, Nondisplaced fractures of the d~stal second, th~rd, and fourth ,~ ~ metatars~ls in anatom~c posit1on~n9 ~ 1 . o EC/rep 2/5/99 T 02/0611999 10 l?AMI li DICTATED BY ERNEST J CAMPONOVO, MD ELECTRONICALLY REVIEWED OZ/06/~999 ~~'33AM i f: " ,St ;\ ',' i '" ~ II FOOT COMP- RIGH~/02/05/1999 'fll .Page 1 ot 1 2? . . . . . . . . . . file:!! A:\MVC-002S.JPG 10/19/2000 . Page 1 ot 1 q . . . . . . . . . . file://A:\MVC-OOlS.JPG 10/19/2000 . Page 1 of! 10 . . . . . . . . . . file:// A:\MVC-003S.JPG 10/19/2000 . "'oj! lllJi Ii"" '10:'~--' r - \, J.......J. - " -~~ e' ORTHOf'_~IC INSTITUTE OF PENNSYLVM- i 1 1 (717) 761-5530 Patient: Arthur R. Davison Chart #: 15302906 e~~~~_____::~:=~~:_______~~~~_:~~_:~_~~~~_______________~:~:_~_~_______________ 2/10/2000 J~SON J. LITTON, M.D. GLOBAL SERVICE VISIT -CONTINUED- e PLAN: He was carefully instructed to be on active and passive range of motion exercises. He is to return in three weeks. JJL/mee e 3/02/2000 JASON J. LITTON, M.D. GLOBAL SERVICE VISIT Poplar Church Road Office CHIEF COMPLAINT: Mr. Davison is now one month post Neer acromionectomy of his left shoulder and he is doing extremely well. . PHYSICAL EXAM: He has far less pain than he had preoperatively and nearly full range of motion. ~ PLAN: I don't believe that further treatment is needed for his shoulder except continued use and progression towards full range. . JJL/mee cc: West Shore Family Practice via fax . . . It . -,Willl3M, U. - t, ..J..-I. - ~~-~''i$$t-~, . ORTHO~_~IC INSTITUTE OF PENNSYLVAl,A 1 2 (717) 761-5530 Patient: Arthur R. Davison DOB: 12/15/43 SSN: 176 34 8680 . -------------------------------------------- Chart #: 15302906 Page # 8 ----------------------- 1/26/2000 JASON J. LITTON, M.D. LEVEL THREE office today and showed some narrowing of the L4-5 and L5-S1 disc spaces and some small spurs are present throughout the lumbar spine_ -CONTINUED- . DIAGNOSIS' I feel that Mr_ Davison is exhibiting sciatica without any localizing findings_ PLAN, He plans to undergo his shoulder surgery in early February_ After his shoulder surgery he should begin taking ibuprofen 800 mg twice daily with food as long as it doesnrt upset his stomach as a treatment for his low back and left lower extremCy symptoms_ .. JJL/clv RADIOLOGY RESULTS . ,'- LUMBOSACRAL SPINE (5 VIEWS), Radiographs of his lumbosacral spine were taken in our office today and showed some narrowing of the L4-5 and L5-S1 disc spaces and some small spurs are present throughout the lumbar spine. . IMPRESSION' See discussion above JJL/clv 2/03/2000 JASON J. LITTON, M.D. = GRANDVIEW SURGICAL CENTER February 3, 2000 GRANDVIEW SURGERY CENTER DIAGNOSIS, Impingement syndrome left shoulder PROCEDURE, Neer acromionectomy left shoulder . He is to come to the office in one week's time to have clipping of the ends . of the sutures_ JJL/clv ," LTR-MISC LTR RE PATIENT (Msc) IMAGING CENTER, MAGNETIC 2/10/2000 JASON J. LITTON, M.D. GLOBAL SERVICE VISIT Poplar Church Road Office It CHIEF COMPLAINT, He is one week post Neer acromionectomy_ His wound is healing nicely_ . -I ~-~ ~ _ L_ " L~liIlI "~ !iilIJ1~\ .. ORTHOP~0IC INSTITUTE OF PENNSYLV~~A 1 3 (717) 761-5530 Patient: Arthur R. Davison .DOB: 12/15/43 SSN: 176 34 8680 Chart #: 15302906 Page # 7 ---------------------------------------- 12/30/1999 LEVEL TWO JASON J. LITTON, M.D. -CONTI NUED- . TEL/MESG-DOC TEL CALL I just called Mr. Davison and told him that his MRI done today at Magnetic Imaging Center shows a rotator cuff tear of the left shoulder. I explained the operative procedure and the post-operative manangement to him. He wants to go ahead with the surgery. . JJL!clv 1/26/2000 JASON J. LITTON, M.D. LEVEL TllREE Poplar Church Road Office CHIEF COMPLAINT, Mr. Davison came in today to discuss the pros and cons of rotator cuff repair, and because he lS having left hip pain. . HISTORY OF COMPLAINT, His shoulder is a bit better than it was at the time he c- had his MRI that shows a rotator cuff tear but he is not comfortable and wishes to go ahead with rotator cuff repair surgery. He understands Chat his cuff tear will be irreparable, in which case he will have an acromionectorny and begin immediate active range of motion exercises. If a rotator cuff repair is successful, he will have to wear the immobilizer at nighttime for a month and avoid full active abduction and forward flexion for four weeks and it will be three months before he can resume vigorous use of his left arm. ,. For seve~al months Mr. Davison has had left buctock and left lower extremity pain and paresthesias. They seem uncomfortable, but not unbearable. He has no bowel or urinary symptoms. :~ REVIEW OF SYSTEMS, The patient's review of systems, past medical history, family history and social history have been re-evaluated and reviewed. It PHYSICAL EXAM, Examination today shows that Mr. Davison is most pleasant. He ambulates normally. The skin of his left upper extremity is intact. He has full but painful range of motion in his left shoulder and resisted abduction is weak ond painful for him. . Examination of the spine reveals normal posture with no scoliosis, lordosis or kyphosis. There is no tenderness upon palpation of the lumbar spine or the posterior superior iliac spines. No masses are palpable. Range of motion of the lumbar spine reveals normal flexion and extension, normal rotation, and normal lateral bending. Motor examination reveals normal extension of great toe and knee, and normal active hip flexion. Patellar tendon and ankle reflexes are normal with no sensory deficits noted. There are normal distal pulses. There is pain with straight leg raising in the left side causing left buttock and left thigh pain. His hip range of motion is normal and painless. . DIAGNOSTIC TESTS, Radiographs of his lumbosacral spine were taken in our . - - ~ - ~ " "' I.. J -~*' . ORTHOf'~.JIC INSTITUTE OF PENNSYLVAh~., 1 4 (717) 761-5530 Patient: Arthur R. Davison .DOB: 12/15/43 SSN: 176 34 8680 Chart #: 15302906 Page # 6 12/07/1999 LEVEL THREE JASON J. LITTON, M.D. -CONTINUED- cc: West Shore Family Practice via fax . RADIOLOGY RESULTS LEFT SHOULDER X-RAYS: Radiographs of his left shoulder taken in our office today show no abnormalities. . IMPRESSION: SEE ABOVE STUDY. JJL/mee . LEFT ELBOW X-RAYS: Radiographs of his left elbow taken in our office today show the bony architecture is intact without evidence of fracture or dislocation. No significant soft tissue abnormality is seen. (.:..", IMPRESSION: SEE ABOVE STUDY. JJL/mee . 12130/1999 JASON J. LITTON, M.D. LEVEL TWO Poplar Church Road Office CHIEF COMPLAINT: Mr. Davison's left elbow is completely better but his left shoulder still hurts. It hurts him considerably. He is very uncomfortable ~ at night and even with routine sitting. REVIEW OF SYSTEMS: The patient's review of systems, past medical history, family history and social history have been re-evaluated and reviewed. PHYSICAL EXAM: When I examined Mr. Davison today I found that he no longer '411 has tenderness over the lateral humeral epicondyle of his left elbow. He is most pleasant. He ambulates normally. The skin of his left upper extremity is intact. He has full range of motion in his left shoulder but abduction is painful for him, especially resisted abduction. He has no deformity or tenderness of his acromioclavicular joint. It PLAN: I feel that Mr. Davison should have an arthrogram of his left shoulder to rule out a rotator cuff tear and should be given an excuse from jury duty because of his pain and the need for treatment of his left shoulder. Mr. Davison asked today if I would reinject his left shoulder with Xylocaine and 1 cc. of Celestone and I did. do that. 411 JJL/mee cc: West Shore Family Practice via fax . ., ::;\jl"-~ ~"~ .-- ~ ~ ,~ tl , ~ -I I. rl't~~ . ORTHOl JIC INSTITUTE OF PENNSYLV~. A 1 5 (717) 761-5530 Patient: Arthur R. Davison DOB: 12/15/43 SSN: . 176 34 8680 Chart #: 15302906 page # 5 -------------~--------------------------- -----------------~---- 12107/1999 JASON J. LITTON, M.D. LEVEL THREE Poplar Church Road Office . CHIEF COMPLAINT, Mr. Davidson is a 55-year old right handed man who has left shoulder and left elbow pain. . HISTORY OF COMPLAINT, He was at home on the 2nd of October and slipped in the bathroom, fell and landed on his left elbow and noted the immediate onset of left shoulder pain and then left elbow pain. The main pain is his left shoulder pain wh~ch makes it very uncomfortable for him to put on a shirt, especially an unbuttoned shirt or reach overhead. He also has considerable pain in his left shoulder at night time. He notes that his left elbow hurts when he tries to do appreciable lifting. . REVIEW OF SYSTEMS, The patient's review of systems, past medical history, family nistory and social history have been re-evaluated and reviewed. r-- PHYSICA~ EXAM, When I examined Mr. Davison today I found that he was most pleasant. The skin of his left upper extremity is intact. He ambulates normally. He has full range of motion of his left shoulder but abduction is quite painful for him. He has pain with resisted abduction. He does not appear to have weakness. He has no tenderness or deformity of his left acromioclavicular joint. . Examination of his left elbow shows that he has full range of motion in his left elbow and no ligamentous instability. No loose bodies are felt. He has marked tenderness over his lateral humeral epicondyle and resisted extension of his wrist causes lateral epicondylar pain. . DIAGNOSTIC TESTS, Radiographs of his left shoulder taken in our office today show no abnormalities. Radiographs of his left elbow taken in our office today show the bony architecture is intact without evidence of fracture or dislocation. No .. significant soft tissue abnormality is seen. DIAGNOSIS, I feel that Mr. Davison has traumatic bursitis of his left shoulder and traumatic lateral humeral epicondylitis. PLAN, I injected his left shoulder with Xylocaine and I cc. of Celestone and . made sure that he'understood that he is to be on at least passive range of motion exercises for his shoulder on a daily basis. I provided him with a prescription for a forearm cuff for his left elbow and he is to wear it when he is using his left arm vigorously. I will see him in follow-up examination. If his symptoms do not respond to the injection of steroid, he may require an arthrogram to see if he tore his rotator cuff when he slipped . and fell in the shower. JJL/mee . <_ -~~~~ _ ~!..o.. .- , 1 ~I- "" ~, 'li~~.-- e' ORTHOf_~IC INSTITUTE OF PENNSYLV~..i (717) 761-5530 1 6 Patient: Arthur R. Davison Chart #: 15302906 .~~~~-----=~~=~~~~-------~~~~-==~-~~-~~~~---------------~~~:_~-~--------------- 3/22/1999 JASON J. LITTON, M.D. RADIOLOGY RESULTS show excellent position of his fractures and they appear to be just about healed. -CONTINUED- . IMPRESSION: SEE ABOVE STUDY. JJL/mee . 4/13/1999 JASON J. LITTON, M.D. GLOBAL SERVICE VISIT Poplar Church Road Office CHIEF COMPLA!NT: He is doing extremely well. It has now been 2-1/2 months since he fractured the metatarsals in his right foot. . DIAGNOSTIC TESTS: Radiographs of his right foot show that the fractures of the second, third and apparently healed. I can still see the fracture second metatarsal. taken in our office today fourth metatarsals have ,"- line clearly through the . PHYSICAL EXAM: Clinically, Mr. Davison has full range of motion in his foot and minimal discoloration. He has no tenderness in any of the fracture sites an says he has occasional pain and swelling in his foot. PLAN: I expect that with a few more months time, he will have no remaining symptoms and have discharged him at this time.. ,. JJL/mee cc: Jeffrey Potter, M.D. via fax RADIOLOGY RESULTS RIGHT FOOT X-RAYS: Radiographs of his right foot taken in our office today . show that the fractures of the second, third and fourth metatarsals have apparently healed. I can still see the fracture line clearly through the second metatarsal. IMPRESSION: SEE ABOVE STUDY. . JJL/mee 5/03/1999 JASON J. LITTON, M.D. REQUEST FOR RECORDS Office notes copied, billed by Quadramed and mailed to PROGRESSIVE. elb . . ,t_~b.O'"_ ~<'" "~~~ ~ It ~, " r ""<Ii~I~:j!o .' ORTHO~_~IC INSTITUTE OF PENNSYLVlU._A 1 7 (717) 761-5530 Patient: Arthur R. Davison . ~~~~-----=:~=:~~=-------~~~~-=~~-=~-~~~~------------ 2/22/1999 JASON J. LITTON, M.D. RADIOLOGY RESULTS Chart #: 15302928 Page # 3 . RIGHT FOOT (2 VIEWS), Radiographs of his right foot taken in our office today show excellent position, in fact, anatomic position of the fractures of his second, third and fourth metatarsals. IMPRESSION, Healing fractures right foot it JJL/clv . 3/12/1999 DISABILITY FORM Erie Insurance disability copy made for chart. JASON J. LITTON, M.D. form completed and mailed in envelope provided. r-, clv . 3/22/1999 JASON J. LITTON, M.D. GLOBAL SERVICE VISIT Poplar Church Road Office . CHIEF COMPLAINT, He is still wearing his DonJoy walker. He is still having pain in his left foot at night and it makes me begin to worry that he is getting a causalgic type picture. PHYSICAL EXAM, Examination shows that he feels his foot is cold and it is a bit cold. It is tender. . DIAGNOSTIC TESTS, Radiographs of his right foot taken in our office today show excellent position of his fractures and they appear to be just about healed. PLAN; Mr. Davison owns his own shop but he says he can't work out in the shop. He is going Co get rid of the DonJoy walker and walk. I am going to see him in three weeks and obtain follow-up radiographs. I asked him to really walk. .. JJL/mee cc, Jeffrey Potter, M.D. via fax . RADIOLOGY RESULTS RIGHT FOOT X-RAYS, Radiographs of his right foot taken in our office today .. __ _I -~_..... ."~ J ---J~~I j'~8:': . ORTHO~~DIC INSTITUTE OF PENNSYLVM,~A 1 8 (717) 761-5530 Patient: Arthur R. Davison . DOB: 12/15/43 SSN: 176 34 8680 Chart #: 15302928 Page # 2 --------------~--------------------------------~------------ 2122/1999 LEVEL THRl>E JASON J. LITTON, M.D. -CONTINUED- . REVIEW OF SYSTEMS: The patient's review of systems, past medical history, family history and social history have been re-evaluated and reviewed. . PHYSICAL EXAM: I did a low back examination today and found that the skin of Mr. Davison's left lower extremity is intact as is his buttock. He is very pleasant. Inspection of the spine reveals normal posture with no scoliosis, lordosis o~ kyphosis. There is no tenderness upon palpation of the lumbar spine or the posterior superior iliac spines. No masses are palpable. Range of motion of the lumbar spine reveals normal flexion and extension, normal rotation, and normal lateral bending. Motor examination reveals normal extension of great toe and knee, and normal active hip flexion. Patellar tendon and ankle reflexes are normal with no sensory deficits noted. There are normal distal pulses. There is no pain with straight leg raising in either lower extremity. . ,---.. DIAGNOSIS: I explained to Mr. Davison that he contused his left buttock. PLAN: I feel that Mr. Davison's symptoms will resolve spontaneously_ . JJL/clv cc: Jeffrey Potter, M.D. GLOBAL SERVICE VISIT Poplar Church Road Office . Mr. Davison continues to have pain in his right foot and he has been walking with crutches even though he has the DonJoy walker, which is a miscommunication. He is to be walking without crutches with the DonJoy walker or remove the walker if he wants to. The walker is there just for his convenience. He is to increase his weightbearing. . Examination shows that he still has swelling of his right foot and says that when he is up for any period of time his right foot swells and hurts. Radiographs of his right foot taken in our office today show excellent position, in fact, anatomic position of the fractures of his second, third and fourth metatarsals. . He is to be full weightbearing as tolerated and return in one month for follow-up films of his right foot. '. JJL/clv II c~li_ ":: -~ u ........L , <^ - -. ~~~~~!! . 1 9 ORTHO~~~IC INSTITUTE OF PENNSYLVM,~A (717) 761-5530 Patient: Arthur R. Davison . DOB: 12/15/43 SSN: 176 34 8680 Chart #: 15302928 Page # 1 2/08/1999 JASON J. LITTON, M.D. INITIAL FRACTURE Poplar Church Road Office . CHIEF COMPLAINT, Right foot injury while at work HISTORY OF COMPLAINT, Mr. Davison is a 55-year-old right-handed man, who is self-employed as an auto mechanic. On February 5, 1999 he was at his office and another person dropped a rollbed on the dorsum of his right foot. He was seen at Pinnacle Health at Harrisburg Hospital on February 5, 1999 where radiographs of his right foot were taken and a padded splint applied. He was referred to me today for definitive care. . REVIEW OF SYSTEMS, Review of systems, past medical history. family history and social history have been recorded and reviewed. I. PHYSICAL EXAM, When I examined Mr. Davison today I found that he had intact neurovascular function in his right foot but considerable mottling ~d swelling on the dorsum of his foot. The skin is not broken. DIAGNOSTIC TESTS, Radiographs of his right foot which accompanied him to the appointment today from Harrisburg Hospital shows that he has undisplaced fractures through the neck of his second, third and fourth metatarsals. . DIAGNOSIS, Undisplaced fractures through the neck of the right second, third and fourth metatarsals I PLAN: The alternatives of treatment were discussed with Mr. Davison and I am going to have him placed in a DonJoy walker. I am going to see him in two weeks and obtain follow-up radiographs of his right foot. He was told today that it will be several weeks before his foot feels normal and that the soft tissue swelling from injury is an important part of his problem. JJL/clv . LTR-NEW PATIENT LETTER (Ref) POTTER, M.D., JEFFREY N. 2/22/1999 JASON J. LITTON, M.D. LEVEL THREE . NON-AUTO RELATED PROBLEM Poplar Church Road Office CHIEF COMPLAINT, Low back pain . HISTORY OF COMPLAINT, The same day that he lnjured his right foot he also fell and landed on his left buttock on the edge of the commode and has had some left buttock pain since then. ---------------------------------------------- . _~~~!!lil~. . -]1 *1YiIIliI1... ~,;- . 20 PATIENT INFORMATION SHEET ESTABLISHED PATIENT/NEW PROBLEM . Chart Number: 1630d-,c; Date: JAN 2 6 2000 Patient Name: V O-lJj~D{) ('~ R. Last First M.1. . Birth Date: I d-' I 5. 4 3 Age: 5LP Problem: L ~'I- Is the condition that you are being seen for the result of an injury? Date of Injury: Other it Type of injury: Work Auto If the condition is not the result of an injury, date symptoms first appeared: M.b(\.~ . Description of accident: n If Workers' Comp: Employer: Occupation: . Address: . Insurance: If Auto: . Insurance: State: If Other: . Insurance: Be-8S :t ~ Family Physician: ~l) t-.t t-JD<..c ,.N ~ Send letter to: Family Physician: N ~ RevisE<! 9/1/00 mee Referring Physician: tJ 0 4 Referring Physician: tJ6 Neither: ;j~~liil"~K"~-" -"_.'-=M"'i!jj~. -- ,jt -""'.l.r.,~liii - _H-'-"-" '.'"l!ilI@~" .' ,;;> ,..iTlENT INFORMATION SHEET ESTABLISHED PATIENT/NEW PROBLEM 2 1 . Chart Number: \(')~~ 9 Patient Name:~1 'l\ ~O;"--\ Last A~,-)<L- First Date: I'd. Wi!' R M.1. . Birth Date: \ri \ \1) \L.j,,"-\ Age: ~ Problem: L.O- \ ' Is the condition that you are being seen for the result of an injury? + Date of Injury: ~ . ~ . U\-l.~\...;Aj"'N Type of injury: Work Auto Other . If the condition is not the result of an injury, date symptoms first appeared: DescriPtionOfaccident:~ ~=~ \r\'f'. ~\...~ I'\.....\ ~~ 0+-. Y"'\Qvv-.U . If Workers' Comp: ~ Employer: Occupation: . Address: Insurance: !It If Auto: . Insurance: State: If Other: . Insurance: ~~ l QLD YC1,IOOO n~fJt'p~l{~lo~O . Family Physician: Send letter to: Family Physici aReferring Physician: ,,-\n\-...f Referring Physician: Neither: Revised 9/1/99 mOO . ~~ : .1'< " ...........1 ~. ,-"" ~~ .' ,.. '.." - .' ,- Chart Number . Patient Name: Birth Date: . Problem: 2L I S5o~ q PATIENT INFORMATION SHEET ~ Date ;)'dd.99 ()a 1/; StJ>L Last First Ar+lrur R. M.I. /Q./s .l/-3 Age: S~ ~&uc Is the condition that you are being seen for the result of an injury? - Date of Injury: If the condition is not the result of an injury, date symptoms first appeared: . Description of accident: . ~ If Workers' Compo Occup:>.tion: . Insurance: ~~ . Employer: ~oJf I ~Jt:; P~-ltE~-~l)- , _.,".,.,~, ,.~.., ,.~,~, . Family Physician: Referring physician: - Send letter to: J Family Physician: j Referring Physician: - Neither. ,. ~. ~, '. . ., -,,'............,~"".'" ~'"'''''',,~'''~...... -~.. [" 'j ''"~~",- ,. Address l' "J.".,.-.-I- '-~.~ "-LL.LIi>..;l'l-JlliilI1WMi1!t1i!*~;:'~" Time ICy.G) j/fk3 Chart/S'<3 t7.0 9 ~. Patient Name Phone 1)~'1 Q,OloS p\ 'S ri0l/ 1, ~l-9 . I ..... I}s l'llo13 Age b~ Sex ri\ ')011 Zlp ss# IILP- 5l/-~ln ~ Mar~al Status ~ DOB . Employer Occupation .,. Crty 5100> .. Mother DOB W# ,. EmploY9'= Father DOB W# '. -,~ Spouse , , ~ alCL EmploY9'= DOB}- \!:\. - L./3 W # ,.,.., , ChUd (School) Responsible Party if Child 72 (jl ~ Ii -- X . AnematelOther Contact Injury ~ (') " 001 ,~ -5-<19- Sports .' " . Auto ' Work Related AcciA~D,es__cr ~ ~ ~J-- L4 ~ ~ ~2Dl ~ _'_ ((}_~-rr $ . Group #_1~ lR 4.9 'l \ OOf) PoIicy# D?,O \'l\u 3'-\ ~'i$() Subscriber's Name ~ Group # ~ ,. Date 01 Symptoms first appeared if not injury INSURANCE Primary Address Secondary Address . Policy # Subscriber's Name Address Address . Famio/D$~~:~~~ . Address J-e~~ p()H-tv Referring Dr. Address Send letter 10: Family Dr.~ Referring Dr. Neither ;1 ~ ~~ ~ - ~-. ~.~~~~ :ii .~~::- . 24 Item: CM30 User: clv001 Ortho Institute of PA Dictation Worklist Chart # : 15302906 Jan 28 2000 {16,12} Page No: . Patient Address DAVISON, Al~THUR R. 16 PADDOCK LANE CAMP HILL PA 17011 Social Securlty#: Date of Birth Home Telephone #~ Work Telephone #: 176-34-8680 12/15/43 717-737-9065 717-737-1673 (I - - - - - - - - - - ~ - - - - - - - - - - - ALL ERG I E S (Needs to be address~d) Date Drug Name Strengtp Form Dispensed Pharmacy Remarks Refills Sig Stop Date Provider Status II 01/26/2000 IBUPROFEN OR TABS 800 MG 60 3 1 b.i.d. with foo ACTIVE MEDICATI LITTON, M.D., J, script given in office to be started after surgery . 08/02/1999 DARVOCET-N 100 OR TABS cvs JJL/clv 40 o 1 or 2 po q4h pm ACTIVE MEDlCATI LITTON, M.D., J, ,.'-.. II ,. ,. II . '. :"';;;>-',"(.:,- ;,-- ' . The following is very importanttousiii ",gccare:ofy6;;ihealth, Please take time to completely and accurately fill out all of this informatioo. Please also make sure you update tW:S information as changes occur. Patient's Name ~ "Gd~ Past Medical History Rave you or members of your family ever beeu told that you have:. You Family [] [] [ ] [ ] [] [] [] [] ,Ll," M-- it '~ B'Jg~?lIser 1, [ ] Eczema! Psoriasis I r tJ _ , ' --~ -;:;: :':", ' - ,.' , 'Epjl.,p,;yIseizures '[ r [] ~~~F<>I1dition:JJ ..' '[ 1 Are you takingdietmedfCation?N~yes' 'hgf!lh?iio:"'bloodpressure. ~ ; .ut ~. . .'if~~i~~~~i~[~;:!I&,!:?:~i.i~11:ii::::'; ,;~~~~~,;:~..#;~:~=L"~~i~Af;'~ , , Thbercu!OSISJd;j.;':L] 3-';)-bo ' Ulcer in stomachJ:~~'r\;F!; duodenum Osteoporosis Arthritis :,~-J,,"~h ~ '_~'> Iim"~~"! " ~-. ,-, ~ """'~. .~",-....'" ~ ....,-~'IHiiiIWI-~~.. ,; <-:--. It Chart Number 16502 q Medications You Are Taking Il~L()j,b,j",~, ' ' V . '~'dd-'~ " ' ,.,5.. ,.', . _~:-AmOilnt Frequency l15> , ,-' +. , Anemia " '-'-"-'-"0'\'" ASthma .. AbllonruUl3leeding Blood clots I phlebitis "--"-,,\.,-',->-,,- , . " ,CancerJ: tumor '~.," i; 'Diabetes . . [) ,;i;L] e'l "';"'('] ":,::,;:;;y, ; t1,:r'[ ] [], [] [ ] T] " Hospitalizations (List serious-illn~~ arid InjurIe~ or operations and approximate year.) mr ~eriOu.~ illness injuTV or SlIY'Q"et:j' . q :;./.3 00 Other bone / joint disease , Any nervous system disease Social History '"'I!I!I!;,"jj~I)j'J",~~I#'$:' ")-.25 0-/3 //~ Your UPDATE d' J' '991~ cfl,,p,tl-P9 cr 3 -dCr 9ffJJ.aI Lf-13-'tc(:fc- Describe /.)~ 7~! jM.r . '/;;J.,-3(}-r~k I-X-dbbr- ;;.j]ojOO ~- 38~ -"-,-'--F__,1-;,~.-;;'> . Do youSmoke? Do yoU: drink alcoho12 Do you use street dmgs? No_ Y~~ tli.m~int'frlif7-;: 'No_ Yes V Amoimt,;;'''.it;~i;..' Nod=Yes_Amount''''< :. ,-:, ,::~ ?[~~;ti,~{~~~; ~ ': ,--';" .- >t-' :.It Continued onback~~r\:;~'~~J~~~~~~t~\tt~ ,__,'~ ~--dli/o1~-~' ...,.~..,." ~'-m"ofL _ o"~ .. ~Js.<.....-.I"" - _~' -,0. - ~. '-1-' "wtlillll_.JI,M), J tmlI!Loiir"A''''~':j~:fi',' ."' During the past year, have you had: . I 2 3 4 heartburn or indigestion?..... ........ ................... ............. ............. ........ bowel movements that were bloody or tarry?..................................... any recent change in your bowel habits?............................................ frequent urination during the day or night?.......................................... . 5 6 7 ""..8 any recent loss of control of your bladder?......................................... b' .th..? ulrnngWl urmatlOn. ............................n......................................., d.ffi'u1.".".., ". . ?. . ' 1 ,Cty. starting your unnation. ........................................................ ',excessi:irid;urination'ho...;.o;...;:;;....;...."",';c;... ;........ ..........:....... ....... ... .," ,.. '", ~ - '-, ' . -, . , ~ " : - : --: -- '. - ':, - - ' .vilt.~.iEf-J4.ri.~.~:;f;.~.~.:.J.:...... .....:..........;....:..:..~.. eathorrh~ezmg. .....:.:..........;..;.....................:........;.. ,,,"":'.. --- ""/'> "" :'" ,,~.f~f~:~~~:i~;.~~~2.;~;- . ,,- "y-,< ;'.~, ' , ,-~, ""'.- - .,--~ - ,- ~',_:1'"--:::~y;,~-~:~{fSit't~~~':;~._,- r" ',.. ~ '" . ,. ....-- . ,". . ~~ :::~~!~;.~:~:S~~{;...;:.~~~:.:~;:;..~~.;~~.:...~X.....~::;~~..:~.~~.:....:..:..;~::..:....:..:.. 23 cold banda / feet?..........:..n.............................................................. 24 gangrene?..:....... ...... .................. ..................................................... .. 25 loss of consciousness? ............. .....n.........................................;........ 26 recent numbness in arms or legs? ..........................~........................... 27 chronic fatigue? ............ .........n...............................:.............n........n 28 uncontrolled bleeding?............ .............. ...... .............. ........................ . 29 weight loss? ......... ........................................................................:... 30 weight gain?.... .................... .......... .....:......... ..:.......... .........,.. .......... 31 heat / cold intolerance?........:..........,...".....:..,..........:.....:.................. "~:".~ ~':.'-; ,;:, 1{,'~_ ~~, '.'_':. - :. . The above information is true anw,correcttothebest army belief. Patient signature .- _.J'--' ~~~i~;,:~,c.-:;;;,;)~~h.~- .c" - c..- '~;.-; :: ,.,'_.._r_,:':_" ;, :;~,~~~:::i7:~t'f;~;: . '\'~""-<-'Y'---- - '-"--:''''''' ~, ",' "_M"... -:-~;'f" ,: No ./ N~ o~ NoV No / No r./ No v No~ No -; No----=::::" No v No V' Nor,.-/ No yr. No 7"":" No--;:/' No No t/ No' ..', '." ....{;4--: No-.4- No ----L- No~ No ,/ No /' No~ No / No) Nor No J No ,/ No~ No-+- Yes Yes Yes Yes Yes Yes_ Yes Yes Yes Yes_ Yes Yes Yes Yes_ Yes. YeS' V , Yes Yes .. YeS'_ Yes_ 'Yes~ Yes Yes_ Yes Yes Yes Yes Yes_ Yes Yes Yes_ Date 1-- 2r CY <J "- -'<!!1l1i' ,l' _ .......... ......,..'~'~~~' -~fi't'--""""""""jj;",\,~>~*" . December 30, 1999 RE: DAVISON, ARTHUR 16 Paddock Lane Camp Hill PA 17011 AGE: 56 SS#: 176 34 8680 STUDY: MRI of the left shoulder j55odCj27 5d- . . REFERRING PHYSICIAN: Jason Litton, M.D. CLINICAL HISTORY: Shoulder pain. Evaluate for rotator cuff tear. . MRI PULSE SEQUENCES: 1) 3DGRE axial 2) Tl/T2 with fat sat IR coronal 3) PO and T2 sagittal '. COMMENTS: Comparison is made to outside plain films dated 12/7/99. Focal signal abnormality is identified within the supraspinatus tendon at its insertion. This signal gets significantly brighter on the T2 weighted images and is consistent with a focal full thickness rotator cuff tear. The remaining rotator cuff tendons are normal in appearance. No joint effusion is present. There is a tiny degenerative subchondral cyst within the humeral head. No other bone marrow signal abnormality is noted. The biceps tendon is normally located. The glenoid labrum appears intact. No significant degenerative change of the acromioclavicular joint is present. .. .1fI Findings compatible with a focal full thickness tear of the supraspinatus tendon. Thank you for referring this patient to us. CONCLUSION: ~ Sincerely, .", ,7) '/ p/'S- L. Michele OPlin~r, M.D. MO/jp . . . 't'''''~' ~.,,"'""""=.~' ~ ~~ , 1M ~ . ~_"",_I__. ~~ -' -~~ , . 28 PINNACLEHEALTH at HARRISBURG I RADIOLOGY lU!lPOM . MR.: SSN: 1IIlM: DOll: m:D: LOC: 1'16348680 116348680 990219361 12/15/1943 NllMIl : DAV::ISON 1 AllIlJ!lBO'R. R 16 PADDOCK LANE CAMl? HILL, PA 1 '1011 Ii:MIllllGlllNCY ROCM, ASSOC 90001 EMERGENCY ROOM, ASSOCIATES EMR ORD DR: ORD#: MT DR: . RF.ASON: INJURY S ~: 90001-FOOT COMP- RIGHT-DIA-359 DATE: 02/05/1999 10:50 . BESULT~ RIGHT FOOT (Three Views): 55-year-old with trauma. Nondlsplaced fractures are seen in the distal shafts of the second, third, and fourth metatarsals. Alignment is anato~c and there are no other abnor.rnalities. ,. CONCLOSION: Nondisplaced fractures of the distal second, third{ and fourth metatarsals in anatomic positioning. r':"-" D: EC/rep 2/5/99 T: 02/06/1999 10:17AM/ . DICTATED BY: ERNEST J CAMPONOVO, MD ELECTRONICALLY REVIEWED: 02/06/1999 11:33AM ,>> ,. . . FOOT COMP- RIGHT/02/05/1999 ril Last page, 1 page in total - . J&J'~~ - , .11 1..- "liJ.iJd 1il!l1Illi.,~~; " 29 ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. " " DAVISON, ARTHUR R 16 PADDOCK LANE CAMP HILL, PA 17011 ACCOUNT # CHART # SS # 95726 000827 176348680 June 1, 2000 CAMP HILL OFFICE - SECOND OPINION r. XR: RIGHT FOOT (3V) :it Mr. Davison is a 56-year-old white male who presents to our office for a second opinion regarding his right foot. He claims that on 02/05/99 a roll bed dropped on the dorsum of his right foot. He sustained a crushing injury to his right foot and was subsequently seen at Harrisburg Hospital Emergency Room. X-rays at that time demonstrated fractures. He was placed in a padded splint and referred to Dr. Litton. He was seen on 02/08/99 and diagnosed with undisplaced fractures of the right second, third and fourth metatarsals in the neck region. He was placed in a Don-Joy walker. He was seen in a serial fashion by Dr. Litton. His last office visit was on 04/13/99. According to Dr. Litton's notes, he was doing very well and had no tenderness over the fracture sit~s. The patient was complaining of occasional pain and swelling in his foot. He was discharged at that point. X-rays were performed of his foot at that time which demonstrated healing of the fractures. . .. fill On presentation today, Mr. Davison notes he has continued to have ongoing pain in that foot now for over a year. It is worse with weightbearing activity. He notes he walks with a limp because of this. The pain is worse with standing on hard surfaces as well as with weather changes. He has not been treated with any physical therapy. He has had no injections in his foot. He has had no recent x-rays. He is not taking any medications on a regular basis. The patient claims he is here for a second opinion and that he is dissatisfied with the ongoing symptoms in his right foot. ,. I reviewed with the patient his past medical history as outlined on his PMH sheet. This is significant for shoulder surgery on the left side in February 2000. He is not taking any medications on a regular basis. His only allergy is to contrast dye. He has no major medical problems for which he routinely sees a physician. He smokes a half pack of cigarettes per day. He denies any significant ethanol consumption. Family history is outlined on the chart. . '. PE: Physical examination today demonstrates his height to be 5 feet 9 inches, weight 198 pounds, blood pressure 107/76, pulse 104. He is awake, alert and oriented x 3. He does not appear to be in any acute distress in a sitting position. He has an obvious antalgic gait when he tries to walk in th~~~~qo~~.Q7 _ CONTINUED _ II' ~ ii I': ') \;'/ \ \'-.,. ,-""- \~"-- - ,:, \ i ~ , ~> '-----'.'.....: U / )- :J '\ ~ .~ ~~ - _J 'II _~"~' L", ~- I, - . ~~.h'_^ ~lLl' ir~~J!'tdll'jO;,'1;;;!dfi?'," . ORTHOP___ ~ SURGEONS OF CENTRAL Ph,. D. . 3C DAVISON,ARTHUR R 16 PADDOCK LANE CAMP HILL, PA 17011 ACCOUNT # CHART # SS # 95726 000827 176348680- .. June 1, 2000 Page 2 CAMP HILL OFFICE .. tries to protect his forefoot area. He localized the pain in his foot over the mid foot area and radiating along the lateral aspect of his foot proximally. He has grossly normal sensation in his foot. He does have coolness to palpation distal to the crush injury area. There is minimal swelling about his foot. He has palpable pulse which is slightly decreased in quality. He has grossly normal sensation. He has some mild tightness in his toes but he has no fixed deformities or clawing of his toes. He has no discrete tenderness over the fracture sites of his foot. He has reasonably good range of motion in his subtalar joint as well as his ankle joint. There is no tenderness in these areas. Weightbearing on the foot in the standing position does not demonstrate any dynamic deformities to his lesser toes and no abnormal positioning of his foot. '. ,. ,. XR: Three views of his right foot were obtained today and demonstrate osseous union of the fractures involving the second, third and fourth metatarsals in the neck region. There is a moderate amount of callous formation but not an exuberant amount that I would anticipate would cause any soft tissue problems. There does not appear to be any angulation of the fractures in the AP or lateral views. I do not see any evidence of any new fractures or bony destruction. .,. DX: 1) 2) sip crush injury of the right foot with residual pain sip closed right second, third and fourth metatarsal fractures - healed ." PL: I had a lengthy discussion with Mr. Davison regarding his foot pain and his ongoing symptoms. The patient gives a history of having a significant amount of swelling in that foot at the time of the crush injury. This obviously supports significant soft tissue injury in addition to the fractures he sustained. It is not unusual that people have some chronic discomfort after having an injury like that. I believe he may benefit with an anti-inflammatory medication and a course of physical therapy to try to improve his motion and function in the foot. I have recommended bringing his work shoes along next time to see if perhaps orthotic modifications may be helpful for him. We will re-evaluate him in approximately one month to see how he has responded to this therapy. It . Craig W. Fultz, M.D. - CONTINUED - (f: ~ ,-..~ C-V l.."",.... ," "'0 17 U (} i ;- ~,' \'./! . ~JU U . .";'0_ " "'~~ 1lllll.'-~ . . . '. . . '. .. .. . . - ,~,I _.Ll " I. - ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. DAVISON,ARTHUR R 16 PADDOCK LANE CAMP HILL, PA 17011 ACCOUNT # CHART # SS # June 1, 2000 Page 3 CAMP HILL OFFICE CWF/rjg RTO: one month -~-'~='rIT"r~-"" ~ . 1!l'rtl'.m2<l~il.W~~IJ.!i.f' 31 ~ 95726 000827 176348680 PATIENT UNDERSTANDS INSTRUCTIONS ;"',:,,';'\1 ,,', u:"\~ ''''ffl___~' ~.,_" _~.I~ ,_ .11 ..1........1......-_ . .~ m~~~&__'B<f.M'~'*'_4~,;, Brand or Drug . D- . Order Generic Refills 32 .. Date '. Drug Notes Treatment . Lab Order B G R - lwt l \ \) \J 1-+ : (, >Q ICy f ~ ~ '1 W' In),\.. t))' / G " e; 7C, .. 1 JUN 2000 o if @*"'Gt ~d.."-\1(l') '~(a'l..lq1 <1-\\ ~\9'i', ~':- ,\h- ... ",Q.'c';:' {J l:L.h\'i~ > ~ pr- . ) I; roo.K-" - HR MIN AMD PMD L-S ?in"- Ibi(:; \00 ,,\1 @5 Z {, --/- '" \ "'I,y... \- I'll rl.h'-r, '. (r;- ) - '0 Rfeot- 3v . c. o L! 00 V/0\'<,< z.~ T 1" k\) Y" i ,.. ;. i. (. 'I. .' '., ". "o,\,r; ;' ' >\'( ,"' ) , > I U '~--,' <~--"'" 'u 11 PT. Name: Chart #: Form 5 _'~..1.; , .-- --1- ,- 1'< ,,:._," ~-=,- '1'- :,--",' (', -- ' "',"-, i' ,"-,"~,"3 ,",-;--" --,", <-~', "0._ '.icl -.*jii,'-~,: It It CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.c., do hereby certify that I am this day serving a true and correct copy of PLAINTIFFS' ARBITRATION It MEMORANDUM upon all counsel of record via postage prepaid first class United States mail addressed as follows: It . George Faller, Esquire Ten East High Street Carlisle, P A 17013 Attorney for Defendant . Dated: 3 /d-I~D) . . . . 222379JIDLL\MTG . c~~ ,;" ~~. ..;'~~ ARTHUR AND BRENDA DAVISON, In The Court of Co~on Pleas of Plaintiffs ) ) 2 ) ) ) ) Cumberland County, Pennsylvania CI ~o. 00-7,693 CIVIL TF.RM 2000 THOMAS J. MICKEY, d/b/a MTrKF:VI~ tylnWTNf: J Defendant OATIl We do solemnly svear (or affirm) that we will su~port, obey and defend ~~e Constitution of the anited States and the Consti~~tio~ or this Common- ~ealth and that we will discharge che duties of our office w-jLt~ Eideli:y. We, the undersigned ar~itrators, having been duly appointed and svo~ (or affir.ned), make the follo~~ng award: (Note: !f damages for delay are awarded, they shall be separately stated.) ~M~~ H","I~~ ~ara....wf-~~ ~ike ~e{. ~ ~(\\)l7,~,=\~ . A=~~:=acor, dissenc5. (!~ser~ name applicable. ) Jaca of Hea:i=g~ 3l10{DI 3L10!PI Jate or Aware.: NOT!CZ OF ~IT~! OF AWARD New, the3{)~day of ~ aw-ard ".Jas ente=ea upon the dcckac and ?ar~ies or t~ei= atto~eys. , 20.01 , ac:l :/'1 , P. ./MI., the abc'7e ~Oc"_.~=_ ~e~~oJ:- a~ :oV-na~' :~ :~e - - ....~ -- ~- -. -- S ,2 9b.utJ 3y: qur/v< /)) .j) . It:. '^~) ?=~~.. n C3.r'7 O. IuA iilt- " ~ :e?u =-::" Arbitrators' compensation to be ?aid u~on appeal; '~ '. I,. . 1':;,.. ..A' '~I!LiIi\l'iii~~l!i!li~!I$!i!!il!!W~ii!!:lllW'~!i~~~~il!i '--'" -j,:..: '~';"",:~llo,~~ ~/~ 9;;;S'~.u.J.J.t."r:2 /710'- ~~~, ~ Ca.. ~' 'f'-lp'cI ----~_._-- ~ ~ ,3030,6( 'fr>' u~~ IiIifilRlillllil:'.JiJ (") C <'" -055 ~ill ...::;....,L' LC. r^..l--' ~...."'. :6~ Z-_.J >~ Z :;! .. ..> 0""".'='" "<,j o o '"f! 3: "';"~... So C) C) -T~ p:= '-;-j['":i _ . r-' __.J-'../ '~~~~: 7_--=--n "::-do Om :;;! ::n -< "'1.7 ::t: r:-? ...- W;) n - ~- - ." ," ='" ,-. ,,-""--'- '-' "___"V'_ .~-. _'..I __ ~.",-_,'" -.0" -."; "', ii:",,;j';~: ARTHUR AND BRENDA DAVISON Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW THOMAS J. MICKEY, d/b/a MICKEY'S TOWING, Defendant NO. 00-7693 Civil Term JURY TRIAL DEMANDED PRAECIPE To the Prothonotary of Cumberland County: Please mark the above-captioned action satisfied by the Arbitration Award entered on March 30, 2001. Date: le"'d- "'to\ ANGINO & ROVNER, P.C. ~utt J.D. No. 3.5956 4503 N. Front Street Harrisburg, P A 1711 0 (717) 238-6791 Attorney for Plaintiffs cc George Faller, Esquire Q,,\G\~t>l. Iirt' ,~' " tJ ,< ~"','--.~',,~ ~ " .'" -~'-Il.:;r'-' "''''''-''1 ""-it:L"~lfsLl I J , I "''''1 ~' ~ ,'^' C",N '/Ra -,""!"O_ -".,-, ''''''- -" - ~'-", ,-"~"",-,--" " , (" "",.,~ - "," , o ~ l~' ~~c. ~2 ~ ""H' '-~' ':-:.:::: :....,~) co c51 \0 ~ :':q -, IfF