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Home My WebLink About01-7115 FX ~" CO~l\i.ONJtALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. 0l-7/1...S Co~l'--r~ NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on ,the date and in the case mentioned below. NAME OF APPEllANT Clifford A. Rieders, Esquire, MAG. D15T. NO. OR NAME OF D.J. 09-1-01 ADDRESS OF APPELlANT 161 West Third Street CITY Williamspart STATE FA ZIP CODE 17703 DATE OF JUDGMENT IIN THE CASE OF (Plaintiff) (Defendant) 11/28/01 Alternatives in Health Care Mgmt. V \'S. Clifford A. Rieders, Esquire ClAIM NO. SIGNATURE OF APPELLANT OR HIS ATTORNEY OR AGENT -= . CY 11' 0000594-01 ..,. LT 19 --- ~ This block will be signed ONLY when this notation is required under;a. il;c.PJP. No. If appellant was CLAIMANT (see Pa. R.GP.JP. No. 1008B. This. Notice 01 Appeal, when received by the District Justice, will operdte as a 1001 (6) in action before District Justice, he MUST SUPERSEDEAS 10 the judgment for possession in this case. FILE A COMPLAINT within twenty (20) days after Signature of Profhonotary or Deputy filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of fann to be used ONLY when appeffant was DEFENDANT (see Pa. HC.P.J.P. No. 1001 (7) in action before District Justice. fF NOT USED, detach from copy of notice of appeaf to be served upon appeffee). PRAECIPE: To Prothonotary Alternatives in Health Care Mgmt. Enter rule upon , appellee(s), ta file a complaint in this appeal Name of appe/lee{s) C:IUi! '7riA.^i within twenty (20) days after service of rule or suffer ent 1 judgment of non pro~ Signature of appellant or his attorney or agent (Comman Pleas No. t':::> 1- 7/ IS RULE: Alternatives in Health Care Mgmt. To Name of appelfee(S) , appellee(s). (1) You are notified that a rule is hereby entered upon you 10 file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by,}:ertifiep 0;. regi~~~d ~~I. -. .'. . . ..,' (2) If you do not file a complaint within this tim., a JUDGMENi.OF'NON PROS WILL BE ENTERED AGAINST YOu. (3) The date of service of this rule if service wqs bynlaiiis the dpte af-mailing. Date:])..C' 19 ,'W~I ~' Ao,,"p j ,P ~A___. ~ SIgnature of ProthOnotar or ~ 312-84 COURT FILE TO BE FILED WITH PROTHONOTARY ";~<~'''I''-':f,C!I?'~~,'''''ffi""",-y;:o::t-'''''''f'i','1&'Jirn'E,,7\'1i''I'i-1'';'''''-'=-~;C~~~:illllilf'll_'i\1IImr~~mJ~[J,li\j.1 ,..__ .~~~"f'!:""""~""~"''''~~''''''''''''''''''<'''''~''''''''''''-,"""",~,~=.,,.,.~"~=~="-~&__,~.,. II' It!! PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUSTBEFfLED WITHIN TEN (10) DA YS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT: I hereby swear or affirm that I served o a copy of the Notice of Appeal, Common Pleas No, , upon the District Justice designated therein on (date of service) , 19_, 0 by personai service 0 by (certified) (registered) mail, sender's receipt attached hereto. and upon the appellee, (name) . on ,19 n bypersonai service 0 by (certified) (registered) mail, sender's receipt attached hereto. o and further that I served theRule t.oFile a Complaint accompanying the above Notice of Appeal upon the appej,Jee(s) to whom the Rule was addressed on , 19_ 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF ,19_ Signature of .affiant Signature of official before whom affidavit was made Title of official My commission expires on .19_. ~ {0 -(,., ~ f; iQ. ..t ~ ~ .~ 9 "- ..c: g~ "'- () f --0.. ~ I \ ' ,. '~ "{l ~ G' ~'i- '-l, r ~ r f fi IJi---" l-nr ,Jii;fii r.;;:;'"'_'- .' ?r._ t.e ._<~ :.-:) ",.; ,','_',k",_",""""""" ,,_, -'~',-"'_"~ C.K~';;">,f"""'1fi;~Tu::".,>I~<'.'!"'<1,~1o,1I'I.~1.""''';j;f!iM<''''.,",'4'''',', ,y,:~gW''RH:''-Yi',~",,_,,0'f.0n1!~~'w~CBi!i;~WJ';:;~,I-~~:~<,;8';;''_' ' ,'~; '. I>' ' tic .. ~OMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dis\. No.: 09-1-01 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'ALTERNATIVES IN HEALTH CARE MGMT I 301 MARKET STREET REBECCA J. CHICK ~ CUMBERLAND, PA 17070 -.J VS. . OJ Name: Hen. CHARLES A. CLEMENT, JR. Add..,,, 1106 CARLISLE ROAD CAMP HILL, PA T",ph"" (717) 761-4940 17011 DEFENDANT: NAME and ADDRESS 'RIEDERS, ESQ, CLIFFORD 161 WEST THIRD ST RIEDERS AND ASSOCIATES i!iILLIAMSPORT, PA 17703 Docket No.: CV- 0000594 - 01 Date Filed: 10/05/01 I ATTORNEY DEF PRIVATE : RODNEY LEE KNIER, ESQ 161 W. THIRD ST P.O.BOX 215 WILLIAMSPORT, PA 17703-0215 -.J THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT .TIJDa.MmIl'r PLTF [!] Judgment was entered for: (Name) U""R1UillI'I'TVRll TN RRU.'I'H r'IIRR M~ [!] Judgment was entered against: (Name) RTlm"RRll, "RllQ, cr.TFFORn in the amount of $ 4,2RR 00 on: (Date of Judgment) 11/2R/01 D D D D Defendants are jointly and severally liable. (Date & Time) Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Amount of Judgment $ 4.187.00 Judgment Costs $ 101. 00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 4,288.00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ Damages will be assessed on: This case dismissed without prejudice. D Levy is stayed for days or D generally stayed. D Objection to levy has been filed and hearing will be held: I:: r- I ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDG~E~T1TR~T FORM WITH YOUR NOTICE OF APPEAL. ~Date ~ . ~" ,DistrictJustice 1 certify that this is a true and correct copy of the record of the proceedings containing the judgment. Date , District Justice My commission expires first Monday of January, Aope 315-99 2002 SEAL ~~" r ~ , . . .,~~ ~ - ~. "~ ~~."' ,-~-~~ ~ ~ - " _"''''''A,'_'''''''''~~ - - ~ COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL p .' ~ FROM JUDICIAL DISTRICT Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on'.the date and in the case mentioned belmv. NAME OF APPELLANT C1:I.fford. A. Rieders. Esquire MAG. 0151. NQ OR NAME OF D.J. 09-1...01 ADDRESS OF APPEllANT 161 West. Third, Street '~, r. ,.... DATE OF JUDGMENT IN THE CASE OF (Plaintiff) my Wllliamsport STATE PA ZIP CODE 17703 11/28/01 CLAIM NQ Alternatives in Health CY 1\1 0000594-01 LT 19 This block..willbesigned p"'L)'. ~eh this notation is. requi",d under 10088. This Notice of Appeal. when received by the District Justice..will operate as a SUPERSEI)EAS:tothe judgmenHor possession in this case. It appellant was CLAIMAN,T tSlJfJ p? R.CP.J.P. No. tOO t (6) in aciion before DiiitridtJustice, he MUST FILE AGOMPLA/NT witniht.;y~niyf26)days after filing his Nor!i::;Eof APi?~il.i'; l: i ~. ~. ~.. Signature at Prothonotary or Deputy , f f. i PIlAECIPE TO ENTEIlRULE TO FILECOMP~AIN"'.ANDRULE TO FILE. (This section at tonn to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.JP No. 1001(7) in actiph betore District Justice iF NOT USED, detach trom copy at notice at appeal to be served upon appellee). PRAECIPE: To Prothonotary Alternatives in Health Care Mgmt. Enter rule upon . appellee(s). to file a complaint in this appeal Name of appelfee(sJ Ct0ll/~ within twenty (20) days afte, ,service of rule o~sufferent f judgment of non pras --- ---=::::. (Common Pleas No. (.) I - 7//..$ RULE: Altehladves in Hea1th CareMpt. To ' Name of appellee{ s) ::Signature. of appellant. or.his:.attomey ,or agent. ,a~p~lee(s). . (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after,the dale of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. Dale:]).. C 19 ,w..2t:x>/ '-- Ao/}'>.f!... p r ~ 'P /7 /'Y~ ~gnature of Prothrinotary.. ty " - AOPC 312-84 COURT FILE I ~"i:"'.'-'-'''';';_''-*Nn.d,~~.&Wil;t!g;:;..~",,~,.,m..-_ ~_ ~.",_.,......-"" _ """'_""'-""~"""'~""~""-"_"""'~" '"'~=~~._ ~_ ~"""_.. . 0 ,,:Jl.M n r --'-'~" ._, .- e.'H'INf1 ." ''" ., PROOF O.F SERVICE OF NOTICE OF APPEAL.AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DA YS AFTER (iling the notice at appeal. Check applicable'l5oxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF / -,/ Co --n I,., &. / / AFFIDAVIT: I hereby swear or affirm that I served _ ;ss li1 a copy of the Notice of Appeal, Common Pleas No. (!I/ ~ 7/1 :; . (date of service) f'Z / 2.' . }fI~, 0 bY personal service receipt'attached hereto; and upon the appellee, (name) ~r,,-t- ,.,.... . ' on h / '2 7 ,)42<>9" n by personal service O<r!>y certified registered)maii. sender's re,ceiptattachedhereto. %land further that I served the Rule to File a Complaint accompanying the above Notice of Appealuponthea Ilee(s) ,towhom the Rule was addressed on I L /2;> ~"i... 0 by personal service [;;Kb (certifie (registered) mail, sefider's receipt attached hereto. THIS '"'"::::::::::::::::::;:~- - "'" _____--- $ignature of affiant Notarial Seal Arne L. Sbuman:. Notary .Public City cfWilliromport; I;YCO)I!l\~g9CW8sty My ComOUSSton Expires u Y . Member, PannsvlvaniaAssoclalionof I\ICI8rles 0 c:> r' ,d C '--'-1 ;;;::: r::::J ~C0 rCl 1.: ~~n n w (,-.~ Z'::- , y w-~ -<;~ :-:::C) ~Cj ""TI -!~r, ~C) ::1:';: C; ~t.} ,t:- ;-< " >c ,-,J ~ ~j ~O Xl .< ", ~ - W4 ..D .-'l o o Postage $ ru fT1 fT1 ~ ..D ru ru r'- Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) o Total Postage & Fees CJ ~ _~:;tC";:j~(!/~=(;,r~t~~r;1l:~b'd~1.Clel!l~1 ~ ]i!:~:r;~pl~._m~7?-b;~.--_.___.mn._mn..n CJ CJ ~ fT1 Postage ",....,--., /,}' "~:,~ ,._" 'Ut;..~;eal~l. : ,u2r-1 \ , 20t: ..D U1 fT1 ~ ..D ru ru r'- Certified Fee ..D .-'l CJ CJ Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Pos~ge & Fees $ ....5')5'f.' Ir Ir CJ r'- '-;"'1'i1,:,~1.' l!~,_ . ~ I".) """~ f. ""C ~->-, . ".'-' I,W .-: Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW 0 0 0 c: " ~ <::l -om f'll NO. 01-7115 CIVIL TERM m'm c-> ?:l Z:r zc w ~;~: j~=; ~z g~~ JUDGE: ::;::CJ -u ~8 :x ~C5 JURY TRIAL DEMANDED )>r"- :- (5 '" ...... s;! Z ~ \0 :0 -< ALTERNATIVES IN HEALTH CARE MGMT, P1aintiff(s) v. RIEDERS, CLIFFORD, CERTIFICATE OF SERVICE AND NOW comes Rodney Lee Knier, Esq., Attorney for Plaintiff, and certifies that a copy of the foregoing Notice of Appeal and Praecipe for Rule to File Complaint has, this ;< 7..fL day of -{)C<' "A'k iJ€A--. , 2001, been served by Certified Mail, postage pre-paid, upon: District Court 09-1-01 Honorable Charles A. Clement, Jr., 1106 Carlisle Road Camp Hill, PA 17011 Alternatives in Health Care Mgmt. 301 Market Street New Cumberland, P A 17070 RIEDERS, TRAVIS, HUMPHREY, HARRIS, WATERS & WAFFENSCHMIDT ~~~' ~ LD. No. 84497 161 West Third Street Williamsport, P A 17703 (570) 323-8711 ~ <'~"'.:~'--,,->-" -~. --~,"'-,--~"" -~-. ~, . ., ""'-' "-"" ~T ...,.,.,..... '~" - AL TERNA TIVES IN HEALTH CARE MANAGEMENT, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS OF THE CUMBERLAND COUNTY, PENNSYLVANIA v. -- NO: J cO I _.i- ( (S CLIFFORD RIEDERS, Esq., DEFENDANT CIVIL ACTION-LAW NOTICE 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 defense 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 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 717/249-3166 800/990-9108 t'!",~"!IW~,.,.~~. " F-- ~ . " ,. ~ ~, _.~.""~ f _ AL TERNA TIVES IN HEALTH CARE MANAGEMENT, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS OF THE CUMBERLAND COUNTY, PENNSYLVANIA v. NO: CLIFFORD RlEDERS, Esq., DEFENDANT CIVIL ACTION-LAW COMPLAINT TO THE HONORABLE, THE JUDGES OF THE SAID COURT: AND NOW COMES, Alternatives in Health Care Management, Inc., Plaintiff, by and through its attorney, Gregory Barton Abeln, Esquire, who avers as follows: 1. Plaintiff is Alternatives in Health Care Management, Inc. ("Alternatives"), Rebecca J. Chick, R.N., President, PO Box 397, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is Clifford Rieders, Esquire ("Rieders"), ofRieders, Travis, Humphrey, Harris, Watters & Waffenschmidt, 161 W. Third Street, Williamsport, Pennsylvania 17701. 3. On May 28, 1999, Clifford Rieders, Esquire, signed a fee agreement with Alternatives to have them perform professional services, provide expert reports and submit a Life Care Plan relative to Rieders' client, Ms. Ellen Thurston. Attachment A. 4. Between May 27,1999 and June 15, 1999, said professional services were provided by Alternatives. 5. Despite numerous attempts to collect fees for Alternatives' professional services, Defendant Rieders has failed to pay the June 15, 1999 invoice amount of$4,187.00. Attachment B. 6. On November 28,2001, District Justice Charles Clement awarded a default judgment to <.~"""~~ r,'V;".o,....... ...C .~~, "." <0, _..~_," ?'.F , , ',," , , ,- - ~""" y :T[f ~. -~" ~"'" the Plaintiff in the amount of $4,288.00, including costs. 7. On December 15, 2001, Defendant filed a Notice of Appeal and Praecipe for Rule to File Complaint. WHEREFORE, Plaintiff demands judgment against the Defendant for damages in the amount of $4, 288.00, together with costs of suit, interest and all such additional relief as the Court may deem appropriate. Respectfully submitted, ABELN LAW OFFICES ~~oil~ Gregory Barton Abeln, Esquire Attorney for Plaintiff 37 E. Pomfret Street Carlisle, P A 17013 717/245-2851 -^'>'~'_f.M,?>"'"", ,__, _.~ po"~ .'." -- - , ,. - "'-"..,.!!! "rJClilr.!!iililf "iJIj[. j. . - IN HEALTH CABE MANACE.'w1ENT. me. lltblCGlJ I. Oi<t. RN. MP..... CCIII. a.'IC P.O. Box 9. C1mp Hill. rA 1700t~ Telephone: (717) 901.036ft . Fla (717)901-9304 http://www.a1than.ccm !o'EE AGREEMENT Referra.l Source Information: Rc: C. WalcmOll1 "Thur~ Allomey'~ Nl1me; .... Clifrnrd Rillders. E.~q. . Firm: 'RI"'.{"~"> Trn\J'~ I-I"mph~"''l Nnf'r,~ Addr~~: 1,~~I,,',:~:2~.:t'~1{~~, Busineu Phone: ~'O :~;:;l",,>~<j7lll Businc:"s F:1X: (570) 323-4\92 I- In f..o ..-. 'Y LVlLfif(n.:;.cJ-,M',.J+ Tyre ofBusine$s: Parmer.llup wdividual, PrOpriCtllrsrJp Corporation TEa.\lS AND CONDITIONS: A retainer in rbe 3lIlounr of $400.00 will he t'orwurckd tu Altematives in Iicallh C= Management. Jnc., and llI:(;omp:my tbe: medieal record.~ ur arrive prior III rhe client evl1lllac;un. Professional time will be billed at arate of $ 125.00 per hour:llld $.36 pcrmile. Jo'ioal ioyoie:e will iIl;l:Ompany the repoll and is payable within 15 business days. lfhalancc is unpaid;l19O days fwm dlltc ofinvQice. a $15Iarc! fee permonrh will be inC\UTlld. After 180 days, the a.c:eount will go intO default (See below). 1=iJe will he updatcc1 by telephone inlerView ju:;t prior to [c.~timony if it 11:L~ been more [,'1:111 six months sinc:e e:ompletion or the report. Expert Witness Protocols an: uutlincd ...' attached and will be strictly adhered to. Rdcn-..1 Source agrees [0 pay aud a..sumes full responsibilit)' ior payment of all hilling rclllLCd to rhe above c:rpLioned fill!. If refcrr.J source defaultS in payment of any amount due under this agrcemem. A!termui ves in &allh Care Management. Tne:. shall be entitled to recover l:Oun costs, reasonable attorney's fees and COllIt cost. and auomey's rees on appeal, if any. In any action to eol\cct the amount due from referral source, Rererral 501.1= agrcc.~ that venue would be proper and appropriate in Cumberland COUnty. Pennsyl\llll1ia. -A- """""'."'~,' -~. , , - -- ;:<;,;!',,-~,y- - . ,.' ". -- -, -"-1 ..,..".~ C._ 1/'*" 'Ii ",~'lr~"~' ""'" .- , ' 2 ReCerr:l..l Suurce Acceptance: The undersigned ackno\llledge~ lh;u hcl~he I13s read the forgoing m Agreem~nl :\lId hereby agrees to be bound by iL~ terms. ihc unllersigncdrulihcr Teprcso:nL~ that he/she i~ duly auumriud to c:x~\ItC th;~ agreement on behalf of the RciClT..\ Soun:e. Name of AUllmey!RcfelTal SO\m:e: l1~~~"~~t\ll:IClfft.s.~~&\~~ Slgnarure:_ _~ _'-_ . (j..;&J ri?c:dC"Yl.f: ~. . Date: & 0><8 -qg Ple;lSC siGn and retllrTllO: R,llbe= J. Chick. RN. MPA. CCM, CLNC Altematives in HC01lth Care Manag;mcnl. Inc. P.O. Box 9 Camp Hill. PA 1700HXJ09 ''0'-'''''-.--...- _ __,,,,,_"~__, __.,. _ 8--',7'_.' _~><P'_'''~_'' I,hl '" ',7 . ,- ,~r"'':'''''' - '~,"' ~,_",,,W~~, '~,'~~'~ ... ,~ Dec-26-01 12:17P Alternatives - PLEASE REMIT TO: - ALTERNATIVES IN HEALTH CARE MANAGEMENT, INC. P.O. Box 9 C;jmp Hill. PA 17001.0009 (717) 901.0366 TAX 10# 25.1676933 Clifford Rieders, Esquire Rieders, Travis, Humphery, Harris, Waters & Waffenschmidt 161 West Third Street WnUamsport, PA 17703 5/27/99 5/28/99 5/28/99 5/28/99 5/28/99 5/28/99 6/2/99 6/2/99 6/3/99 6/3/99 6/4/99 6/6/99 6/6/99 6/7/99 6/7/99 6/7/99 6/1/99 6/7/99 6/7/99 6/8/99 6/8/99 6/9/99 6/9/99 6/10/99 6/10/99 6/10/99 6/11/99 6/12/99 6112199 6/13/99 6/14199 6/14/99 <.",,*,,;,'I"Mi'~.----..;v,,, . '),''P'.".h_ 7179019304. p.02 #8116 Date: June 15, 1999 Client: ~l1en Thurston Re: C. Waltman Thurston Our File No. : 1077 Coordinator: Rebecca Chick Invoice and ltemiqttion of Services Ren.lkrm -File review and set up -Telephone call to Attorney Riedel'S -Telephone call to Attorney Riedel'S -Telephone call to Attorney Rieders -Fax to Attorney Riedel'S -Flle review -Telephone call to Attorney Riedel'S -File review -Telephone call to Attorney Rieders -File collation and write reports -Teleconference -Fax to Attorney Rieders -Report dictation -Telephone call to Dr. Voogt -Telephone call to Dr. Voogt -Telephone call to cUent -Fax to Dr. Voaght -Fax to Attorney Rieders -Proof prior to fax -Vistt client's home -Travel -Telephone call to Attorney Riedel'S -Telephone call to Dr. Voagt -Telephone call to Dr. Burke -Telephone call to Dr. Burke -Telephone call to Dr. Dahl -Telephone call to Attorney Rieders -Write report - Review add expert reports -Write report -Telephone call to Attorney Riedel'S -Fax report draft to Attorney Rieders -B- ~-'; ',! . - I' ~ ." Hours 6.00 0.10 0.10 0.30 0.10 1.00 0.30 1.00 0.30 5.00 0.60 0.10 1.60 0.20 0.20 0.30 0.10 0.10 0.50 1.50 7.50 0.30 0.50 0.10 0.40 0.40 0.30 5.00 1.00 3.30 0.30 0.60 -,'0" Amount 750.00 12.50 12.50 37.50 12.50 125.00 37.50 125.00 37.50 625.00 75.00 12.50 187.50 25.00 25.00 37.50 12.50 12.50 62.50 187.50 487.50 37.50 62.50 12.50 50.00 50.00 37.50 625.00 125.00 412.50 37.50 75.00 - ':1 Oec-26-01 12:1BP Alternatives 7179019304 - PLEASE REMIT TO: - ALTERNATIVES IN HIlAtTH CARE MANAGEMENT, INC. P.O. Box 9 Camp HiD, PA 17001-0009 (717) 901-()366 TAX 10# 25-1676933 Ellen Thurston June 15. 1999 p.03 ""- ;~ ~ Page 2 Invoice and Itemization of Services Iiendere~ For profeSSional servtces rendered Additional charges 6/8/99 -Mileage (450) Total additional charges Total tltne and expense charges 6/15/99 -Retainer received - thank you Balance due Payment Due Upon Receipt ..... 'J1'l''!!'11V>~"",,,,, ,_,~_ ,~ 'roc .,-." "'f.''''. '"_~ '''-~ Hours 39.00 Amount $4,425.00 162.00 $162.00 $4,587.00 ($400.00) $4,187.00 I" - "'~,~= "fl!li1f111I'Y'" 'a""'<~' 12/28/20el 12:a~ 7!.72d59622 ABELN LAW OFFICES PAGE 09 VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, infonnation and belief. I understand that false statements are made subject to the penalties of 18 Pa.C.S.A. 94904, relating to Unsworn Falsifications to Authorities. /~/3IJ OJ Date I I ;Mf~.l~a._, ._, "__eO . .=".' ." , . ? - ~ -- ,- - ,--' -'~"""".- ~, . ~, , . -- -"I . ALTERNATIVES IN HEALTH CARE MANAGEMENT, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS OF THE CUMBERLAND COUNTY, PENNSYLVANIA v. NO: CLIFFORD RIEDERS, Esq., DEFENDANT CIVIL ACTION-LAW CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing COMPLAINT by mailing a true and exact copy addressed to the following: Rodney Lee Knier, Esquire PO Box 215 Williamsport, P A 17703-0215 Respectfully submitted, Date / ..,) - () I ABELN LAW OFFICES -Lf adttu-.. 1 {~ Darlene F. Cramer Legal Assistant 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 0!>'0'-%o~ ,- - ,.< ",=,. - ,----=~" , ~ - .,. ~. "" T -~'~"'" ~~'''-,."- - ,." ~ -- -" _,_ "","J;:\~..,_-ry _M_!i!J'I!T':~l!lIl!J =---".~. ~"~ -~-'---'r'-"-'"- >--""~-" ' .~ .- . (') C = "'Oe: fTlr--;-j --:7.' ~fi;~: GCJ "- :;::;,-,......., 21..,.0::" c.Lc .PC Z ~ 'j" rlilTlrL1!ltiUi_"I~,F':M C) f0 ~ :~:;oo 2: 1~;:g- , <"" ....", .~ ~~:} )::..;" :_n: .'n n- .",,;0 ,-J,-'! .~ -1 ~. ""'-~ :< -:...) .t:" ,I~ BI-I ,~!!!!!I'" ; !"1"i1:1i'l$~~!--~~<<;'~!\"i<<';PF;"'-~-!"{-<,t~'-'Pc:-'''F:'-q.,-",~,,,,;",'--I~j;;"'''O'~!''''~'''';~'"I'_*4!-''~'1~~:)''';''lj '{ir:~k'~~"''!1-,ji}~!iiilWj~;;'' , ALTERNATIVES IN HEALTH CARE MGMT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY P1aintiff(s) CIVIL ACTION - LAW v. NO.2001-71l5 RIEDERS, CLIFFORD, Defendant(s) NOTICE TO PLEAD YOU ARE HEREBY NOTIFIED to file a written response to the enclosed New Matter within twenty (20) days or a judgment may be entered against you. RIEDERS, TRAVIS, HUMPHREY, HARRIS, WATERS & WAFFENSCHMIDT ~ Attorney for Defendant I.D.# 84497 161 West Third Street Williamsport, PA 17701 (570) 323-8711 - ;;'li~M111~_Jr,,,__,,_,,_" '0' .," -"'''' -~ ,,' , ,1 ALTERNATIVES IN HEALTH CARE MANAGEMENT, INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW v. NO. 2001 - 7115 CLIFFORD RIEDERS, ESQ. Defendant ANSWER / NEW MATTER / COUNTERCLAIM COMES NOW, Clifford A. Rieders, Esquire (hereinafter Rieders), by and through his attorney, Rodney Lee Knier, Esquire, ofRieders, Travis, Humphrey, Harris, Waters & Waffenschmidt, and answers the Complaint of Plaintiff Alternatives in Health Care Management, Inc. (hereinafter Alternatives) as follows: 1. Admitted that Alternatives is the listed Plaintiff. 2. Admitted that Rieders is the listed Defendant. 3. Admitted. 4. After reasonable investigation Plaintiff is without knowledge sufficient to form an opinion as to the truth of the averment that Alternatives actually performed any services in regard to this matter on any specific dates and accordingly the averment is denied. 5. Admitted that there has been communication regarding this disputed debt, specifically denied that said communication/s constitute numerous attempts. 6. Admitted that Defendant chose not to litigate this matter before the Magistrates Court and permitted the entry of a Default Judgment in that Court. 7. Admitted that pursuant to the Pennsylvania Rules Defendant appeals de-novo to the Court of Common Pleas of Cumberland County. -~l1f'?"?i~j .r,~ ,,~_, "~_ ,'," , . <'- , r- , . NEW MATTER 8. At that time of contracting for services Alternatives, through their agent Rebecca Chick, was advised that the matter was pending in Federal Court and that the report was due to the Court on June 15, 1999, which would require its being shipped from Rieders' office on, or before June 14, 1999. Copies of two letters from Rieders' office to Ms. Chick attached as Exhibit "A." 9. At that time of contracting for services Alternatives, through their agent Rebecca Chick, was advised that time was of the essence. See Exhibit "A." 10. At that time of contracting for services Alternatives, through their agent Rebecca Chick, was advised of the requirement that Rieders had to have the Report and Life Care Plan sufficiently prior to the due date to permit Rieders and his staff to fully check and proofread the Report and Life Care Plan for errors, omissions and improper materials; to discuss any needed changes to the report with Ms. Chick and to permit Ms. Chick time to make any needed corrections and/or changes and then to prepare and provide a final Report and Life Care Plan. See Exhibit "A." 11. At the time of contracting with Alternatives for the preparation of a Report and Life Care Plan Rieders paid Alternatives a retainer of $400.00. See Agreement and invoice, both attached to Plaintiffs Complaint. 12. A faxed draft copy of Ms. Chick's Report and Life Care Plan was not received in Rieder's office until approximately 3:00 p.m. on June 14, 1999. Draft copy of Report and Life Care Plan attached as Exhibit "B." 13. The Report and Life Care Plan faxed at 3:00 p.m. June 14, 1999, contained significant and material errors. 2 ---.:~-~-~ "',"." ~ -' '^' ~-- "" F - - - ;p--- .~I '"N 14. The Report and Life Care Plan faxed at 3:00 p.m. June 14, 1999, contained information and materials that were inappropriate and/or immaterial and/or irrelevant and which had to be removed from the Report and Life Care Plan before it could be filed with the Court. 15. The Report and Life Care Plan as provided on the afternoon of June 14, 1999, was unusable to Rieders due to its significant and material errors and the inclusion of inappropriate and/or improper materials. 16. Rieders and his staff proofed and reviewed the faxed Report and Life Care Plan and, at approximately 3:45 p.m., Rieders attempted to contact Ms. Chick with the required corrections and changes to the Report and Life Care Plan. 17. Ms. Chick was not in her office at the time and Rieders discussed the needed changes with Ms. Chick's secretary. 18. The requirement to proofread and fully review the Report and Life Care Plan is exactly the reason Ms. Chick was notified that time was of the essence and that the Report and Life Care Plan had to be provided to Rieders early enough before the due date to permit the proof reading and full review of the Report and Life Care Plan and to permit Ms. Chick to make any needed corrections, additions and/or deletions to the Report and Life Care Plan. 19. A corrected Report and Life Care Plan, with a significant amount of material that Rieders had required to be removed still in the report and containing material errors in the Life Care Plan computations, was not faxed to Rieders until approximately 5:30 p.m. on June 14,1997. 20. The necessities of filing had required that all expert reports be sent out by Federal Express overnight delivery at 5:00 p.m. 3 ~-~oc "-~-," - - - :r- :":n '" :':-~fJnr m_ll 21. The corrected Report and Life Care Plan was not received until approximately 30 minutes after it had to be shipped to the Court. 22. The corrected Report and Life Care Plan was received far too late on the afternoon of June 14, 1999 to permit Rieders and his staff to proofread, copy and prepare the Report and Life Care Plan for filing. 23. The corrected Report and Life Care Plan was unusable to Rieders as it was provided too late to permit its filing with the court prior to the due date. 24. The Report and Life Care Plan was not used at the trial of this matter. 25. Defendant Rieders asserts that the failure of Alternatives to provide a usable Report and Life Care Plan within the Court mandated time1ines constitutes a significant and material breach of the agreement by Alternatives. 26. Defendant Rieders asserts that Plaintiff is not entitled to any recovery or payment under the contract as the contracted for Report and Life Care Plan was not provided in a usable format until after the passing of the Federal Court mandated deadline. 27. Rieders further asserts that Plaintiff s breach mandates their return to him of the four hundred dollar ($400.00) retainer he has paid to Alternatives. COUNTERCLAIM 28. At the time of contracting for the preparation ofthe Expert Report and Life Care Plan Rieders paid Alternatives a retainer in the amount of four hundred dollars ($400.00). See agreement and invoice attached to Plaintiffs Complaint. 29. Alternatives failed to provide Rieders with a usable Report and Life Care Plan within the mandated time frame. 4 ;*!(;e,. e _ - _ ~~ ..' , .,., . 'T . ~~ -~ , 30. Alternatives knew of the strict time limitations at the time of contracting to perform these services and that time was of the essence. 31. The failure of Alternatives to provide the Report and Life Care Plan in a usable form within the mandated time frame constitutes a significant and material breach of the contract. WHEREFORE, Rieders demands judgment against Alternatives in the amount of four hundred dollars ($400.00) together with costs of suit, interest and all such additional relief as the Court may deem appropriate. RIEDERS, TRAVIS, HUMPHREY, HARRIS, WATERS & WAFFENSCHMIDT ~.::::-~ Rodney Lee Knier, Esquire Attorney for Defendant LD. No. 84497 161 West Third Street Williamsport, P A 17701 (570) 323-8711 5 ,i'~_~___~ V'''~'<." .__ - < , ,., .. ~ ~. FAlL (570) 323-4192 A PARTNERSHIP ~,QT~,~, ~, G'ff/~ gG'ff/~ 161 WEST THIRD STREET P.O. Box 215 WILLIAMS PORT, PENNSYLVANIA 17703-0215 (570) 323-8711 E-MAIL, rlmlJ,@mail.mlink.net JEFFREY C. DOHRMANN GARY T. HARRIs JOHN M. HUMPHREY CLIFFORD A. RIEDERS Also Memher N.Y. & D.C. Ba.rs RONALD C. TRAVIS THOMAS WAFFENSCHMIDT C. SCorrWATERs ROBERT H. VESELY Also Mem1er Maine & Mass. Bars VALERIE G. ZlM Aleo MemLer CaliEomia B.., KIMBERLY A. P AULHAMUS Finn MilIl<Iger May 21,1999 Rebecca J. Chick, MPA, RN, CCM, CLNC 301 Market Street New Cumberland, PA 17070 Re: Ellen Thurston Dear Rebecca: It was a pleasure speaking with you on the above date. We certainly appreciate you making yourself available on such short notice to review this matter and prepare a life care plan on behalf of Ellen Thurston. As discussed, I am enclosing a retainer in the amount of $400.00 along with the below listed items for your review. 1. A summary of medical events; 2. Medical records from Robert Packer Hospital for the date August 26, 1996 to December 11, 1996; 3. Medical records from Cortland Hospital; 4. Medical records of Dr. Burke, Ellen's current treating physician; 5. Medical records from Dr. Lee; 6. Medical records from Dr. Gauss; 7. Notes/Diary prepared by Ellen Thurston; 8. Video tape depicting a day in the life of Ellen Thurston; 9. Video taped interview of Ellen and Bud Fleming (Ellen's fiance'); 10. Deposition transcript of Ellen Thurston; 11. Medical Bill summary as provided through the insurance company; 12. Medial receipts for supplies; As indicated, all expert reports are due by June 15, 1999_ Upon reviewing this file, I would ask that you contact either Mr. Rieders or myself to arrange a convenient time for you to meet with Ms. Thurston. In the interim, should you have any questions or concerns, please do not hesitate to call. 'ld~~l] "_ M_ ,_ ~,..., -"'F~' ". - I ,- f~ " Rebecca J. Chick May 21,1999 Page 2 Again, thank you for your time in this matter. CARlplh PENDING: June 10, 1999 ,'~~" .~, . ~'I" - 'C.. ..,~ ~. , _ '''''"', ., Very truly yours, RIEDERS, TRAVIS, HUMPHREY HARRIS, (!\.AATTEERR~S & WAFFENSCHMIDT l-&n ~ Pamela L. Hiqks, Paralegal to Clifford A. Rieders, Esquire ,- , ~~, I~ ~ .~" FAX, (570) 323-4192 A PARTNERSHIP ~,QT~,~, ~, Off/~ fJ'Off/~ 161 WEST THIRD STREET P.O. Box 215 WILLIAMSPORT. PENNSYLVANIA 17703-0215 (570) 323-8711 E-MAiL, rlmhh@mail.csrlin1.net " JEFFREY C. DOHRMANN GARY T. HARRis JOHN M. HUMPHREY CUFFORD A. RiEDERS Also MemLer N.Y. &D.C. Bars RoNAlD C. TRAVIS THOMAS WAFFENSCHMIDT C. ScorrWATERS ROBERT H. VESELY Also Memher Maine & Mass. Bars VALERIE G. ZIM Aleo Memlter c.lifomia Bar KIMBERLY A. P AUllIAMUS Firm Manager June 3, 1999 VIA FAX (717) 901-9304 and FIRST CLASS MAIL Rebecca Chick, MPA, RN, CCM, CLNC 301 Market Street New Cumberland, PA 17070 Re: Thurston Dear Rebecca: We have been trying to reach you, because our expert report is due no later than June 15, 1999. Since we are in federal court, judges do not easily grant extensions and there will not be an extension. granted here. Obviously, we would want to be able to review whatever you put in writing, or ideally, speak to you ahead of time. When you call the office, have me interrupted. If you would rather use the 800 number, it is 1-800-326-9259. You may feel free to call me at home. My home phone number is (570) 326-7180. CARljss "~"~ - ~- - ,~ "'-~r,"" ' _ f'- , C-'_' "~" ~ 0_., '- \. 717 901 9304 1".01 .',- -. J'un-14-99 Alternatives in .....c. '_.'''.'_.'~. ._t.IDc:. P.Q. kQU.~'RiII:'PA l '. I, " 717.gQl.0366 flu 717-901-9304 bap:I/www.llllbc:m.com R. ; p d--4S R.. ; f rl~.r, 1'>>.",/".; "i /t1vs~~ FAX r.OV'1R SRRRT DAm TO: COMPANY: PAX NUMBER: RlOM: COMPANY: 1o-1~-99 ~ 5?-o - 3':l ~.- 1/9~ t( 1wA'~,^ r'A.11 c....K.. . Atr8l'lariws in Health Carl! MAnA~r PHONE: 17m 901-0366 PAX NUMBER: t7171 9Ot.9'J04 TOTAL NUMBER. OPPAaES INa.UDING COVER SHE'ET: :Jt/ RE; t//'HI 7h v is -kn -;. ;. 11llI iDfonIIlIIion ia Ibis fa is of a corl;d_,,1II .-. ud oa1y iJa&endccl for Ibo UIC of Ibo perIOa lI1IIIIor COIlIp8Il)' JIlIIIUId allo..... If 1IIa readar of &bill --.~lle is naI: tha iawlcled rec:ipiellt, you DIe _ boiag IIOlificd dIIII. dlucmiaadon. clIaaiburioa. or copy ol &bill ~""'''''-;''''d'IIJI is Slric:dy plObibifCd. If you have zecavecl &bill flllt ia -. pleIso COIIWllIllll n.........;~rly by telepbcmc 8l1lla sbIwe allDlber 1IIIIl_ 1IIa ...n....;.el~ to me. U.s. PosuI1 Service.. 'I1uIIIkyou. _ . --""""'" -- ,.> n '("'__ r - - ~ I'~ IT Jun-14-99 02:54P Alternatives 717 901 9304 <>.02 ALTERNATIVES IN HEALTIi CARE MANAGEMENT. INC. Rebecca 1. Chick. RN. MPA. CCM, CLNC p.o. Box 9, Camp Hill, PA 17001..()()()9 Telephone (717) 90Hl366 . Fall (717) 901-9304 hltp:/lwww.althcm.com LIFE CARE PLAN FOR ELLEN THURSTON Prepared by Rebecca J. Chick, CLNC June 14, 1999 -)~lMl!!I!Y.~ I'M ~ ~ . ,'P - .. ~_, ,-~,~ T-. '_p~~!E' "~r- Jun-14-99 02:54P Alternatives , ' Table of Contents Introduction Medical Records Reviewed Medical Summary Past Medical History Social History Chief Complaints Activities Current Medical Care Medication and Supplies Recommendations Medical Care Home Management Dur.mle Medical Equipmcnt Medications Wound Management Home Care Diagnostic Studies C.ase Management Multiple Hospitalizations Personal Care and Companion Care Comments Regarding the Interview Conclusion Bibliograpby Summary of Costs Life Care Plan ,t:~'i'~lQl, , . " 7~7 90~ 9304 Appendix Appendix P.03 2 4 5 5 6 7 8 8 8 l\ 8 9 9 9 9 9 9 9 10 10 Il ~~ ~ . "T'''''~ ''''~, ~ --"~ <.< - III Jun-14-99 02:54P Alternatives 717 901 9304 P_04 . ' NAME: DATE OF BIRTH: DATE OF EVENT: DATE OF EVALUATION: DATE OF REPORT: Ellen Thurston 4-24-46 8-26-96 6-8-99 6-14-99 INTRODUCTION Ellen Thurston is a 53-year-old woman rcferred by Attorney Clifford Riedel's for a rehabilitation evaluation. The purpose of this referral is to assess the extent to whieh Ms. Thurston has incurred handicapping conditions secondary to an August 26.1996, incidcnt and onset of disability. We will explore the specific manner in which this situation evolved and to what cxtent the sequelae of the incident impedes her ability to demonstrate indcpendent living skills, Tn addition to an intcrview in the home of Ms. Thurston on June 8, 1999, cxtcnsive medical records have been reviewed, Thc purpose of the evaluation is to dctcrmine Ms. Thurston's lifclong needs as they relate to hcr injuries and secondary disability. This repOlt will outline her history, her current status. and proposc her lifetime necds and their associated cOSts in thc ~ltlached Lifc Carc Plan. The basis for recommendations outlined in this report are the pertinent medical records, thc interview with the patielll, research into the current medical care, and the education and cxperience of this medical consultant. Ms. Thurston was born April 24, 1946, She has just turned 53 YC3rS of age. She is a white femalc. Based on the 1990 Lifc Tables she has a life expectancy of 29 years, or until age 82 years. The Vital Statistics of the United States. J 990 Life T able;-, is a governmcnt document dcsigned to provide life expectancy information. It is based on avcrages (i.e. dcaths by all causes), and addresses life expectancies based on gcndcr, age, and racc. MEDICAL RECORDS REVIEWED Robert Packer Hospital Courtland Care Cenrer 8-26-96 to 12-2-96 12-2-96 to 12-4-96 12-14-96 to 12-17-96 12-14-96 to 12-17-96 3-17-97 4-6-97 to 4-1 1-97 4-12-97 to 5-2-97 Coullland Memorial Hospital Robert Packer Hospital Michael J, Georgetson, admission for PEG tube insertion, Guthrie Clinic Courtland Memorial Hospital Robert Packer Hospital Coultlalld Mcmorial Hospital Crnu~e Hospital 5-2-97 to 5-6-97 6-30-97 to 7-4-97 6-13-98 to 6- I 6-98 , ~"~~lW~.~ ,0" ._".,,_," r "- ".-- ,,' -~~f -- ~T "" '11'" , -- Jun-14-99 02:54P Alternatives 717 901 9304 P.D5 . . Thurston. Ellcn 2 P. Gauss. M.D., report Letter from H. Woon Lec Letter from Lawrence H. Repsher, M.D. Report from Jamcs Bass, Jr., M.D. Depositions Ellen Thurston 6-16-97 to 9-15-98 ~ 2-17-94LO 1-20-98 ~ 8-8-96 5-6-99 William A. Burke, M.D., office notes William A. Burke, M.D., report P. Gauss, M.D., office notes Robert J. Lennox 2-25-99 2-25-99 1-19-99 Paul Flemming Michael W. Chisdak 1-26-99 Tammy S. Schrick Lisa C. Jordan 4-28-99 12-21-98 MEDICAL SUMMARY On August 20, 1996, Ms. Thurston presented to Pulmonary Medicine Clinic becausc of an abnormal chcst x-ray. She was seen by Robert J. Lennox, M.D.. who rccommended a surgical approach to the small nodule in the left lowcr lobe of her lung. He also recommendcd pulmonary function studies and blood work. Ms. Thurston was seen by Dr. Robert Quigley that same day. He recommcnded and scheduled admission for a bronchoscopy and left lower lobcctomy. Ms. Thurston was admittcd to the Robert Packer Hospital on August 26,1996, by Robert Quiglcy, M.D. On August 27,1996, Dr. Quigley performed a bronChoscopy and left lower lobectomy under general anesthesia. The specimen (nodule) was removed and sent to the lab. Dr. Quigley's operative notes indicate hc dissected multiple adhesions of the left lowcr chest area and wall and noted several air leaks in the upper lobe. which wcre oversewn. The lower lobc was removed, a chest tube was inserted. thc ribs were closcd, lung reinflation wa~ accomplished.. and thc skin was closed. " Post-operatively. Ms. Thurston began complaining of sevcre abdominal pain. A CT scan on August 31. 1996, showed plcural effusion and atelectasis pOst reinsertion of the chest tube. lIer chest tube was draining large amounts of dark coffee-ground-colored drainage. She was returned to lCU on Septcmber 1, 1996, and hyperalimentation was started and a centrallinc was surgically placed by Dr. Quigley. On September 4, 1996, another CT scan showed collection of ga~ and/or fluid in the left chest area. A portable chest X-roIY on Septembcr 5. 1996, showed continued large pleural effusion on the left. !-~~ ,- ". ,. I- ,<- .",.. - - ,~,~ I' "~= ~'" . .". , "- -~ Jun-14-99 02:S4P Alternat;ves 7l.7 90l. 9304 P.OG . . Thurston, Ellen 3 Finally on Septembcr 6, 1?96, Felice ~citknecht, ~.D., p~rformed an exploratory thorac~~tomy with dcbridement of the left plcural cavity and rcpalf of a dIaphragmatic hemla. She callcd In Dr. Carlton to pedorm an exploratory laparotomy with dcbridement and repair of stomach, which had necrosed and pcrfon'led into the pleural cavity. The wound was thoroughly irrigated and debrided. Because of the massive infection, Ihe wound was left open and packed with Kerlix dipped in normal saline. The endotracheal tuhe was rcplaced with a tracheal tube and Dr. Carlton. Gencral Surgeon, inserted a ga~trostomy tube prior to completion of his surgery. Tube feedings werc started. Ms. Thurston was transferrcd to the recovery room and placed on a vcntilator because of breathing difficulties. On September 9, 1996, Ms. Thurston was extubatcd but, due to difficulty, shc was reintubaled on September 10, 1996, post pneumonia. Ms. Thurston bcgan having problcms with atrial fibrillation and was trcated with digitalis and magnesium sulfate; howevcr, her temperature continued to remain elevated. Infectious Disease was consultcd for assistance. Blood transfusions werc given and regular drcssing changes continued. A mucous plug was discovered by Pulmonary on September 19, 1996. This again compromised her brcathing, leading to hypoxia. and the plug was removed. Multiple attempts were made to wean Ms. Thurston from the ventilator; however, there was difficulty in doing so partly due to a pneumothorax on the left. A tracheotomy was inserted on September25, 1996, and the thoracotomy wound was examined undcr anesthesia. Air leaks were sutured and stapled onthc left upper lobc. On Septcmber 27, 1996, an angiogram was performed to assess the blood supply to her chest in anticipation of a flap to aid in closure of the chest wound. By September 30,1996, Ms. Thurston was again taken to surgery for cvaluation of her left chest under anesthesia. Two air leaks were found, and a purulent exudate found on the rcmaining portion of her lung. A pneumonectomy was then pcrfonned with a pectoralis nap for coverage of thc Icft hilum. Ms. Thurston progressed with treatment and on Octobcr 5, 1996, hcr tracheotomy was capped. She was also initiated on a regular diet plus tube fccdings, and on Octobcr 11, 1996, she was returned to ICU with a diagnosis of aspiration pneumonia. This causcd her to require intubation for breathing difficulties. She again progressed and was ultimately wcaned from thc tracheotomy, which was removed on October 28, 1996. Again on October 31, 1996, Ms. Thurston was felt to have aspirated, which again led to pneumonia. She returned to leU and required mechanical ventilation for hypoxia. She gradually stabilizcd and started to improve, and she was wcaned from the ventilator. Ms. Thurston cOlllinued to have periodic problems with aspiration. Howevcr, with the aid of numerous broad- spcctrum antibiotics she stabilized, and on Novcmber 5, 1996, her antibiotics were stopped and her by-mouth diet was advanccd. Occupational therapy and physical therapy were aggressively pursued and a swallowing evaluation was performed. Dressing changes continued regularly with wound packing into the open cavity. Occupational thcrapy worked on her left shoulder with attcmpL~ to increase the range of mOlion due to loss of function. Ms. Thurston was discharged from the Robert Packer Hospital on Decembcr 2, 1996. with an open cavity requiring skilled nursing care. She was transferred to the Courtland Care ('..enter and from then discharged to home on December 4, 1996. She was then admitted to the Courtland Memorial Hospital on Deccmber 14, 1996, with a diagnosis of bronchitis or pncumonia. Shc was treated there and immediately transferred to the Robert Packer Hospital for follow-up care. At lj'~"'o,ff.i^,,,"_,,,,,___ ___.c,., - " -~.- ." ~ -- ~~~ t- ~, Jll! 1'1 _u,,__'c' -" . Jun-14-99 02:55P Alternatives 7~7 90~ 9304 P_07 Thurston. Ellen 4 Robert Packer she was found to have an infcction (If her internal jugular vein catheter, which was changed and she was discharged on the foll(lwing medications: 2% 650 mg. 15 mg. daily daily daily by mouth daily as needed local application by mouth every four hours as needed by mouth every four hours as nceded Atarax Reglan EstraCe Provera Ducolax Mycostatin Tylenol Restoril 25 mg. 10 mg. 0.5 mg. 2.5 mg. She was discharged from the Robert Packer Hospital on December 17, 1996, and remained at home until March 17, 1997, when she was seen at the Robert Packer Hospital Guthrie Clinic for PEG tube insertion due to weight loss and anorexia. She was dischargcd from there on March 18, 1997, in satisfactory condition. She was again admitted to Courtland Memorial Hospital on April 6, 1997, discharged on April 11, 1997, and transferred LO Robert Packer Hospital for a continued elevated temperature of 100 degrees. By April 21, 1997. Ms. Thurston had dcveloped pncumonia again requiring care. A thorocentesis compl~ted on ~pril 29. 1997, was performed due to continucd elevated temperature. A llepann dnp was 1ll1Llated for fcar of pulmonary embohsm. The right pleural effusion and atelectasis were treated with Rocephin and Gelltomycin. Her wound was clean and she wa~ ultimatcly transferred to Robert Packer Hospital On May 2, 1997. undcr the care of Dr. Reitknecht. She stopped antihiotics and cultured the wounds, and the cultures wcre negative. The x-rays were clear, So she was discharged home in stable condition on May 6,1997. According to the records from Mr- Reiders' office, Ms. Thurston was readmitted to Courtland on June 30, 1997, to July 4. 1997; however, I do not have benefit of those records. iple errors occu ed in 1C treatment of Ms. PAST MEDICAL HISTORY Ms. Thurston was a customer service manager for Wal Mart in her town in New York. She had history of a cough, which started approximately one month prior to her seeking medical carc. She noted productive purulent sputum associated with some blood-strcaked sputum. She went to see hcr doctor, who lrCated her with antibiotics and ordered a chest x-ray. The chest x-ray showed a nodule in the left lower lobe. She saw Dr. Quigley for a second opinion about the removal of the lesion. She was suffering from some dyspnca upon climbing sleps. She wa~ sleeping on two pillows; however, there wa~ no ankle edema. Ms. Thurston suffered from chrunic urticaria and was taking the following medicalions prior to her admission to the hospital on August 26, 1996: -'_"'>.l'1'iW"'~~ ,_~ ~ - ,~, > I ~ . ~ I ~, , ~'--'- ," ~. -~-~ I" ",_",~1lt!~ '"m~--'Irl -M__ -... - - .- -- Jun-14-99 02:55P Alternat;ves 717 90l. 9304 P.OB Thurston, Ellen 5 Claritin 30 mg. pcr day Cyrin 2.5 mg. daily Estrace 0.5 mg_ daily Hydroxyzinc 25 mg. tWO tablets three times a day She claimcd to be allergic to Cecll)T. which had caused welts, and aspirin, which has caused hives. She alS() has food allergies and avoids products such as seafood, acidic foods, spices, nuts, and potatoes. II.. "D~~fA[9R'r t'aw;Jr ht;:o~^"r r'rij'..~f Ll....r....~th~rl1....A ......f']nng .....n1~ir it~" 1\3 ooallOJI ,uvti.Of ditKl at Agt.. 71 Elf ll. !1lill~'l.Rflll'l". T~ere were six children in all, five of whom are living and well. One sister died at age 5 of rheumatic fever. SOCIAL mSTORY Ms. Thurston is the mother of one 30-year-old son, who lives in the Courtland, NY, area. She also has several nieccs and nephews with wham she enjoys spending time. llil>. Tl.u..,t.,... is div......;.._J. fri;l~ ..... ...).,..~ri".l ille~l~li\,; husbanQ. Wllu 1.....1\ 1", ~ ~I' rh'i':" -ri.. ...1.1...'\ du~t; J....~.~ l1f "'g,e. Paul Flemming is Ellen Thurslon's fiance. They met over 25 years ago and have maintained a relationship cver since. They reside together in a medium-si7.ed. well-kept homc where Ellcn used to enjoy doing all the yard work, housekeeping, and cooking. Prcsently Ms. Thurslon. because of her disabilily, can barely complcte the laundry. do light housekeeping, and minimal meal preparation. She is totally unable to do any yard work and must rely upon hired help or Mr. Flemming to complete these chores. Ms. Thurston is mostly confined to the house becausc she must rely upon visiting nurses to pack her chest wound and apply her dressings on a daily basis. She is at the beck and call of their schedule. Ms. Thurston is unable Lo eat prior to the nurses' visit, because when they remove the packing from and repack the chest cavity it causes her to gag and cough, sometimes causing her to vomit. This reaction to the dressing change prevents her from taking breakfast until afLer the nurses' visits. Food preparation is an activity she used to enjoy that is now limited nOl only due to her lack of endunmce and the left shoulder stiffness, bUlbecause of the difficulty with her short-term memory. Safety is an issue when it comes to operating the stove, because many timcs the stove is forgotten due lo the short-term memory loss. CHIEF COMPI.AINl'S In view of Ms. Thurston's serious and debilitating post-operative problems, il is only because of her delennination and persistence lhat she is living independently at all. Shc is feartill of being alone when Mr. Flemming is out of town, and in lieu of hiring a companion, she stays with her sister, who lives in the Courtland area. Lifting is a major problem for Ms. Thurston, because it pulls against the opening in her chest cavity and hurts Iter shoulder. She accomplishes small ta.~ks such as bringing the laundry basket out of the basemellt hy resting at frequent intervals until she regains her strength and breath and is able to continue. As you can imagine, stairs arc very difficult to negotiate due to hcr shortness of breath. r~~",~... " -^o,c . ~. "'".1"'" . ~ ~~ ~-~. , ". -'~ "'''" , ,"" ,.' Jun-14-99 02:55P Alt2rnatives 717 901 9304 P.09 Thurston, Ellen 6 Memory problems have plagucd Ms. Thurston since her discharge from the hospitaL Following discharge she began keeping a written log of events in an effort to keep track of health-related and other issues. Bathing presents a problcm because of the need to keep water out of the chest cavity. Thus, bathing must be limited to the tub with assistancc and very careful management of the open wound area. She is unable to lift the left arm high enough to use both hands for hair washing and Care. Sleeping for Ms. ThurslOn is literally' a nightmare. She must always be watchful not to sleep on her right side, as fluid from the affccled left side can drain through the opcning in the Slump of hcr left lung into the right (good) lung and cause a.~piration pneumonia. This has happened on numerous occasions and is one of Ms. Thurston' s greate.~t fears. She then is required to sleep on her painful open wound by lying on her left side. or must sleep with her head elevated at a 30- degree angle on her back 10 prevent a~pira1ion. When Ms. Thurston is walking outside the home she uses a cane due lu her feeling of imbalance. especially on uneven ground. This imbalance is auribulable to the brain damage caused by the hypoxia. as is hcr memury loss and inability to orchcstrate her daily aspects of living. ~IJI ...~ .,ip;^n ;r;. "'T,,", nn.r r,..._ tft.... d....l~{jafl sf ReI Hill i ~lnrl "1, 'YY""&t of 1..... f4u,~1]~ ~1s-. ~lIMtSfl .../..,~ &.0, .... (l~~r l!pn~ir1~rr- f^r ~TnTnpAi~~~ pl.".lHllJl"i :.. _ ,BRiSn J I __ 8i.l.d.1.<<1.~...~. She is not safc to function independently, nor is she any longer capable of managing her own affairs. These are presently being managed by hcr fiance, Mr. Flemming. ACTIVITIES Lifting: Obviously the client's strcnglh in her upper body is compromised primarily on the left side. Restricted due to imbalancc and shortness of breath. Walking: Standing: Silling: Restricted due to endurance and shortness of breath. No major restrictions. Climbing: Balancing: Stooping: Totally restricted due tn shortnc.~s of breath. Difficulty with balance because of the tro:lumatic brain injury. Reslricted duc lO balance problems and shortness of breath. Restricted, again due to balance problems. Able to crawl for short distances. Kneeling: Crawling: Crouching: SiL~ in a crouch position due to poor posture associated with her ehest wound. Reaching: The client's right arm is unrestricted; however, thc left arm is restricted due to the shoulder immobili7.ation. Handling: She enjuys crafts and crocheting. -_~~~JJ:~-,.,..~~~_, "_~__. ,", "l\ "," '-" -"~",.,.._~ till Jun-14-99 02:55P Alternat;ves 7J"7 901 9304 P. J.O , I ;,] i 'i ;:! f:l I:.; :i l-! "!i " 1,1 , ii 1'1'1 i-; " !.J ill \.iI !';! i;1 ,i! I': ~, Ii ii' J I'll Ii' ,'I i' '..'1 ,! Hi Iii 1'1 ::1 iii' ii, HI Iii HI 1-'1 1 II !-il "I i'i II 'I :'1 ,I ..',1 i', II i'~1 'i~",,~~-<<J;,'w<;?'JI!'hii!im~ -'Cc- Thurston, Ellen 7 Fingering: Feeling/Sensation: She enjoys crafts and crocheting. Upper eXlremity scems unaffected. Difficulty due to shortncss of breath. Within nonnallimits. Talking: Hearing: Smclvra.~relVision: Within normal limits. Exposure to hcat, cold, and weather: Restrictions due to potential for frcquent upper rcspiratory infections, which are a major threat to her life. Noise intensity: Startles casi 1 y. Vibration: No limitation noticed. Atmospheric Conditions: Ms. Thurston ha~ reduced lung capacity and should not he in areas that may contribute to funher dysfunction. This client slatcs she is fearful of a~piralion should she roll on thc right side while sleeping. She is confined \0 30-degree elevation on her back or sleeping on hcr left side. Slceping: Stamina: Ms. Thurston's stamina b low due to prolonged confinemcnt to bed and inactivity, plus the dramatically dcerea~ed lung capacity. She would like to drive but is fearful of endangering other people because of shon attention span and inability to problem solvc. Driving: CURRENT MEDICAl. CARE Ms. Thurston is being followed by her family doctor, Paula Gauss, M.D., who monitors her lung infection and offers prompt care for early treatment of sinus and lung infections. She has educated Ms. Thurston in self-monitoring of her care tlu'ough daily body temperature monitoring, self- physical therapy and wound care management. ! . i "".,~~-' r 1 - ",. -. .": > '" Jun-14-99 02:56P AltQrnat;vQs 717 901 9304. P.IJ. - Thurston. Ellen 8 4. ThoTlL{; , w vC rihs and close eam .. ft chest wall. ement 0 The greatcst decision faced ~y. Ms. Thurston is whethcr she wants to undcrgo closure procedur&i or remain in her prescnt condition. , MEDICATION AND SUPPUES Ms. Thurston takes Tylenol III with Codcine, 300 mg., for pain as needed. She also uscs Atarax, 25 mg., to be taken as needed for urticaria. Antibiotics, which she has available to take at thc first sign of infection, are Augmentin. 500 mg., for sinus infection and Cipro, 500 mg.. to self-start for temperatures above 100 dcgrees. RECOMMENDATIONS Medical Care: . Continuc with her family doctor, Paula Gauss, M.D., to care for her ongoing medical concems if needed, at least every three months. . Quarterly visits to Dr. Burke, Thoracic Surgeon, for regular monitoring of thc chest wound and bronchop1eural fistula (open chest wound). . Annual visits to an orthopedic surgeon after an initial evaluation for treatment of the painful frozen left shoulder. . A neurop.ychological cvaluation. An initial cvaluation with regular subsequent evaluations starting annually, thcn tapering to every tivc yean;. . Speech therapy is a service that can he utiliLed to hclp Ms. Thurston with cognitive cueing and assist with increasing the ratc of her cognitive, auditory, and motor processing. I would recommend speech therapy with an initial evaluation and monthly visits for six months, then annually for eight years. . Due to lifestyle changcs being experienced by Ms. Thurston and her tlance, I recommend a scries of counseling sessions especially aimed at helping Ms. Thurston and Mr. Flemming regain a palt of their intimale relationship. It is my opinion that they would bcnefit from some help regarding positioning and new techniqucs for lovcmaking in view of Ms. Thurston's chest wound limitations. I noticed Mr. Flemming treats Ms. Thurston in a child-like fashion. They would benefit from help with communication and self-esteem building. . Ms. Thurston would bcnefit from physical therapy to correct her froLen right shoulder pending the visit to bel' orthopedic surgcon. H,)me Management: . Lifc Skills Coach-Request an evaluation be performcd by Community Skills, an agency offering a plethora of services pending the needs of the client. This would be requested in an effort to provide Ms. Thurston with techniqucs for making her everyday living safer and less stressful. . Biweekly house cleaning to help with heavier chores and regular lawn maintenancc, including lawn carc, snow removal services, and biannual cleanup. Durdble Medical Equipment: . Ms. Thurslon will require a hand-held shower replacemcnt every five years with grab bars for the tub replaced every ten years. . A cane will be required and need to be replaced every three years, depending upon use. . A raised wilet seat to be replaced every five years. ;,m.~,(,\Y-l~\"""'" -,~ -, IJ ~ < - , - ,~ ---"-- "; " ~" , , f~ -- Jun-14-99 02:56P Alternat;ves 717 901. 9304 I , '_n:-~.{".7,",-'",,,,,"1"_" Thurston, ElIcll Medications: Tylenollll with Codeine, 300 mg., pm Atarax, 25 mg" pm, for urtic:u-ia .. . . . Antibiotics include Augmentm, 500 mg., for smus mfcctlons and Clpro. 500 mg., for temperature over 100 dcgrees. Wound Mana2cmcnt: . Daily visil~ from the VNA w~Il be req~i~ for her lifc~ime, pending her decisi?n regardi!1g t~e drjlStic and risky surgery optIOns. This wIIl also require purchase of appropnate supplies for wound care. . Surgical intcrvention to dosc the chest cavity: . The one with thc most likelihood of success is the resection of the left main bronchus via a midline sternotomy at Massachusetts Gener-II in Boston, MA. . The mll.scle flap placement over thc bronchopleural cavity. . The thoracopl:l.~ty with massivc rearrangemcnt of the left chest wall, again at Mass General in Boston. Homc Carc: Regardless of the surgical decision made by Ms. Thurston about her bronchopleural ristula, she does now and will continue throughout her life to requirc some type of supervised care. Duc to the hypoxic damage caused to her frontal lobe, documcnted hy neuropsychological testing, which is responsible for orchcstrating her thoughts, she will require somc type of companion or supervised pcrsonal care throughout her life. DialP'ostic Studies: Multiple diagnostic studies will be requircd to sustain Ms. Thurston's health managemcnt. This will require multiple and regular x-rays of her shoulder and chcst, MRl studies of the shoulder, and lab studies for pulmonary function and oxygen saturation. Case Manm~ernent: This service will assist Ms. Thurston in obtaining appropriatc Care throughout thc remainder of her life. Should somcthing happen to Me. rlemming, her tlancc, Ms. Thurslon would be at a loss for management of hcr affairs. A case managcr would obtain the serviccs of a companion. assist in transfer to a pcrsonal care boarding home, and assist hcr in obtaining a bank offering fiduciary services to safeguard her resources. A case managcr would be available to guide Ms. Thurston with dccisions and carc throughout thc remainder of her life. Multiple Hospitali7.ations: Considering the prescnt status of Ms. Thurston. 1 expcct she will requirc at least one hospitalization, perhaps two, per year for thc remaindcr of her life. Because of the susccptibility for her to acquire aspiration pneumonia and develop infections in her pleural cavity,l will huild in at least one to two hospitali7.ations per year for Ms. Thurston for the remainder of hcr life. Personal Care and Comoanion Care: For approximately thc next ten years, Ms. Thurston should bc ahle to function aidcd hy her fiance with approxim~tcly 48, hours per ~eek of companion care, as her fiance is out of town frequently. Ms. Thurston IS fearful of staymg alone. and should not bc left alone due to safcty factors uncovcred by her ncuropsychological testing. However, her fiance cannot beconsidercd immortal, as he comes with his own set ofhcalth problems that will tend to escalatc over the ncxt ten years. Therefore. I am placing Ms. Thurston under the 24-hour care of a companion or into u personal care boarding home ~y ~ ycar 2009, as I do not feel Mr. F1cmming will be capahle, nor should he be expected to contmue III her care beyond that date. I have offered Option I and Option 11 as two viable alternatives for Ms. Thurston's care into the future. . ,-. 1-- P. ],2 9 ~_ 7_ Jun-14-99 02:S6P Alternat;ves 7], 7 901, 930"1. P.13 Thurston. Ellen 10 COMMENTS REGARDING THE INTERVIEW The interview was held at Ms. Thurston's apartment, which she shares with her landlord and fiance, Paul Flemming. The apartment was neat, clean, and orderly and had two bedrooms. one of which was obviously exclusively Ms. Thurston's. There was a living room, dining room, kitchen. and bath, which shc shares with her fiance. The kitchen was recently rcmodeled by Mr. Flemming in an cffon to make it more accessible for Ms. Thurston. The bathroom seemed adequate but would be more convenient with a raised pony seat and grab bars; a hand-hcld showcr and grab bars would be beneticial. The intelvicw was attended by BIlen Thurston, her fiance Mr. Flemming, and initially by Brenda Twomey. RN. the visiting nurse who changed thc packing and dressing during my visit. All persons were friendly and helpful. CONCLUSION Careful consideration has been given to all medical, psychological, and rehabilitation data contained within the file and provided in my report. There is no qucstion Ms. Thurston is experiencing adjus\ment issues and also physical and cognitive conditions secondary to her August 27.1996. surgery. These conditions havc impaired her present and future life, all due to hlatant systemic neglect. The impact of the damage caused by the surgery ha~ altered her physical. psychological, economic, and cognitive capabilitics severely enough to warrant the necd for my recommendations. Ms. Thurston will ncvcr regain the ability to function independently. Rcalistically. there is going to come a timc for Ms. Thurston when her fiance can no longer be at her side. She will require outside, round-the-clock hclp in the form of a companion or a personal care home. It is my opinion Ms. Thurston will require help through counscling and must soon face a major, potcntially life-threatening decision about hcr options for surgical treatmcnt of her bronchopleural fistula. All of the needs dictated by the onset of this disability through life expectancy are outlined in the attached Life Care Plan. Respectfully submitted, Rebecca J. Chick, RN, MPA, CCM, CLNC Rehabilitation Consultant RIClnjd :3'!m1Wii'<"~,",' _ -~, ~ ''; . . ,''", 1< -'-' ,-, ,~ ~-" Jun-14-99 02:S7P A'ternat;ves 7].7 901 9304. Po ].4 Thurston, Ellen II BIBLIOGRAPHY Dorland's pocket Medical Dictionarv. 24th Edition. W.E. Saunders Co. Philadelphia. PA. 1982. "Hiring Personal AttendamS: Reducing the Risk." New Mobility. November 1996, page 45. Inside Life Care Plannin!!: A Bimonthly Newsletter for Life Care Planners and Case Managers. Volume 1, Numbed. Liooencott Manual of NUTsin!!: Practice. 6th edition. Lippeneott Raven Publishers. Philadelphia, PA. 1996. Neurorehabilitation Life Care Plannin~. October 1996. St. Thomas Guidc. Ameri.can Nurses Association. Rcprinted with Permission from Code For Nurses WIth Intewretlve Statements. American Nurses Association. Washington, D.C. 1995. II ;'1 I' " " I'-! -~,~\,SM't'-"~'a,"~ _, ',_" ,. - 'n ~~,. '. ~, ~~~ - "9~_ ". 717 90l. 9304 P. l.5 Jun-14-99 02:57P Alternat;ves NAME: LIFE EXPECTANCY: DA TF. OF BIRTH: DATE OF EVENT: DATE PREPARED: PREPARED BY: Life Care Plan Summary of Costs Ellen Thurston 29 years (to age 82) 4-24-46 8-26-96 June IS, 1999 Rebecca J. Chick, RN, MPA, CCM, CLNC Rehabilitalion Consultant Description Total Cost Medical Care $78,340.00 Home Management Option I Option II Durable Medical Equipment Option I Option II Medications Wound Management Diagnostics Case Mana2ement Hospitalizations Therapy $87,413.20 $32,963.00 $907.65 $325.85 $24,053.76 $342,220.30 S20,860.00 $22,742.50 $432,912.00 $5,000.00 $1,000,800.00 $517,920.00 Option I: In-Home Companion Care Option 11: Personal Care Home Total, Option I Life with companion care for 24 hours starting in )() years Total, Option 11 10 years with a move to a Personal Care Home in 2009 -:~"W"'l!'l"_""'" >, ~ - ,oo ',' " - _~~_""""~-, ','=>t.-. $2,015,249.41 $1,477,377.41 ~.,~ .." . '~,~ Jun-14-99 02:57P Alternatives 717 90J_ 9304 P. J"6 ~ ~ u :i u u <. 0.. ~c: . " ~ ~"%j N . C go ~8 ., ~ '" O.~ 0- , 0 0\ ~ -;t; , ~ ':'1 '" ea .'";: ~ '" ()::: ., ., ~~ ;.., c J:J.r. 0- :> ., ., N - ..:..: ;;.; Z u ~ -< ~ ;;.; ~ ..;l a:l c.. 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OJ ~~ u::C -~ "'c =-- 0"'8 c'" cfci5 7].7 901 9304 P_24 .."" .,=~~ i. ,. '" AL TERNA TIVES IN HEALTH CARE MANAGEMENT, INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW v, NO, 2001 - 7115 CLIFFORD RIEDERS, ESQ, Defendant CERTIFICATE OF SERVICE AND NOW comes Rodney Lee Knier, Esq., Attorney for Defendant, and certifies that a copy of the foregoing Answer I New matter I Counterclaim has been served upon Gregory B, Ablen, Esq" 37 East Pomfret St.; Carlisle, PA 17013-3313, thUitl4 day January, 2002, by first- class mail, postage pre-paid, RIEDERS, TRAVIS, HUMPHREY, HARRIS, WATERS & WAFFENSCHMIDT --- ~er,ESqui: Attorney for Defendant J.D. No. 84497 161 West Third Street WiIliamsport, P A 17701 (570) 323-8711 ~ 6 ~""'_W"fi1~",~< -- , I"" ',- - " '"~.;, ,,__, _, __""",5~' ill ,. ~-, ^~, .. r WiWIH!!W~~ ;~-~ ~.~ I""""" ~-~~,~o ,-, ,,' '-' ;.,-,-"'~'i;"i',"',,, -'~"X "'l '''''''' .' -'~.~lll]fjljWi\"Ut"~>~ijj]ir"iI o c: -.04 ..-,-~ 1'1\<"'- ~~;\~ f'.:"() ~'- ~~, -7 ::'1 -<. ., ~;_" ~!IIi.l!l ~ ., ~ r ,---. "-",' -,~; i',j (-.- "i",," " -~n ,n '_OJ ........1 C', (,,! "-'''J ~-.<~ ~fl '( , .::::; ~ '< ~.;,.. c- oO "" C:> E'S BI/ ~1"lI;ll~il;'!,r!j,j!~!i'j')#~~~~Jj:Wl"~N"l""f'."'!""'?";Y ';''0'.''''ZW!'':'~'''''0''","8''''F''\w?'*,~~~j0HI~~l~~",?~!,,,,,,,,_,~':Jl~_,_,~~: AL TERNA TNES IN HEALTH CARE MANAGEMENT, INC" PLAINTIFF v, CLIFFORD REIDERS, ESQ" DEFENDANT .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA CIVIL ACTION - LAW NO. 2001-7115 PRAECIPE TO WITHDRAW TO: PROTHONOTARY Please mark the above captioned matter as settled and withdrawn with prejudice, ~(c~~~ Date ;'f~i. " . "." "'~_'~_"~"~' _, _, ,'W ~ _>" . ." .~ - Respectfully submitted, ABELN LAW OFFICES egory Barton Abeln, Esquire Attorney for the Plaintiff 37 E, Pomfret Street Carlisle, PA 17013 717/245-2851 ", "~ .. .., .-- ALTERNATIVES IN HEAL TH CARE MANAGEMENT, INC" PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA v. CIVIL ACTION - LAW CLIFFORD REIDERS, ESQ., DEFENDANT NO. 2001-7115 CERTIFICATE OF SERVICE I hereby certifY that I have this day served the foregoing PRAECIPE TO WITHDRAW by mailing a true and exact copy addressed to the following: Rodney Lee Knier, Esquire PO Box 215 Williamsport, PA 17703-0215 Respectfully submitted, ABELN LAW OFFICES DateS- JJ -oJ Darlene F, Mellinger Legal Assistant 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 <'~l! ,- " , ~ ", --- ". - - , , ~" .""""". ~~ - ^. !!I .."00 .0"" "". ., ~-'o. "':'&. ';I'-O"?~~"'&- "~'.,-\O-, ~"~"""'}-"~;:'1;;';" ~~~~'.~t~p",~.;,},,'ti~~'I~~";lii)f~ ")~~~W"i/~~;;;(,'? ;:<":3:. ~'-. 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