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Home My WebLink About99-04775(9 ¦, ,S ?u?•lrtu>: CASE NO. mow r i.N 1 - C?4riS{nn?ier LC L.CnLAr 2.A ? 1ZLcflnLr Gc,.? ro z nuA k! 3.N 99 - 14), J)a le m tCAe lI J - ?. 3 4.1??T-- g S -r?C e? 6.0 JO S 4+1,)CNQ 3a Yn? _ - Q e iY1rZ p'L 94 -tra?-1?I,irdTr?-?-F'-'?rcfrcv, 3 12.0 IL LCIA__?Lt 6l ------- 1 4.0 16.0 - a? E, l21'l om'30td 17.0 ((2(o - .To yCe M- 140rmanJ 18.0 5--? - V , .. > C P OL_??jA /1 I , n) S 1 19.0 g 3 _ -id1-1 S _-mQ !' !-1 C n n) ------- ro.N.?L_ zz.0 z1.0 24.0 2i.0 26.0_ 21.0 i, f x ' ADDAMS & RUN DLE 3 r7 t Zlr;yt ATTOANEYSATLAIV? ybXl`'i?µ+?it i3nh ?, E„ .e i 2850=2!h!?ZSTREET CARUSLE, PENNSYLVANIA 17013 TELEPHONE (717) 2488900 1 Y: er SHARON HAWBAKER and IN THE COURT OF COMMON PLEAS OF WALTER HAWBAKER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 99-4775 CIVIL TERM V. CHARLES S. MURPHY, JR., Defendant JURY TRIAL DEMANDED DEFENDANT'S PRETRIAL MEMORANDUM 1. FACTS: This action arises out of an automobile accident that occurred on April 11, 1998. Mrs. Hawbaker was a passenger in an automobile which was traveling east on Wertzville Road and stopped to make a left turn for a yard sale. Mr. Murphy was also traveling east, but failed to see the automobile come to a stop due to blinding sunlight. The result was a rear-end collision. 2. DAMAGES: The Plaintiff sustained a flexion-extension injury of the cervical spine which has allegedly developed into fibromyalgia. 3. ISSUES: Liability is not contested. The principal issue is the extent of the injury. 4. EVIDENCE: No problems a anticipated. 5. WITNESSES: Cha les Murphy, Jr. and Terr .Leslie, vocational counselor. 6. EXHIBITS: None anticipated. 7. SETTLEMENT NEGOTIATIONS: Pending. ADDAMS & RUNDLE By: William A. Addams Supreme Court I.D. No. 06265 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Defendant A 0 C7 AUG 9 2000 SHARON HAWBAKER and WALTER IN T14E COURT OF COMMON PLEAS HAWBAKER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. CIVIL ACTION - LAW CHARLES S. MURPHY, JR., NO. 99-4775 Civil Defendant JURY TRIAL DEMANDED PLAINTIFFS' PRE-TRIAL MEMORANDUM • 1. Brief narrative statement of the case On April 11, 1998, Plaintiff Sharon Hawbaker was a front-seat passenger in a 1988 • • 0 0 0 Honda Accord driven by Renee Conrad, Mrs. Hawbaker's daughter. Mrs. Conrad was traveling eastbound on Wertzville Road and stopped her vehicle to turn north on Carol Lane. At the same time, Charles Murphy, operating a 1993 Chevrolet Blazer, was also traveling eastbound on Wertzville Road. Mr. Murphy permitted the front of his Blazer to collide into the rear of Mrs. Conrad's stationary 1988 Honda Accord. II. List all types and amounts of damages claimed A. Plaintiff Sharon Hawbaker: 1. Non-economic damages. Mrs. Hawbaker had mild pre-existing degenerative disc disease; however, she was asymptomatic before the subject motor vehicle accident. Mrs. Hawbaker sustained a hyperextension/flexion injury, an aggravation of her pre- existing asymptomatic degenerative disc disease at C5-6, chronic pain syndrome, depression and anxiety, adjustment disorder with mixed anxiety and depressed mood, chronic, low back pain with right lower extremity radiculopathy, and a cervical strain. Mrs. Hawbaker's condition developed into debilitating fibromyalgia. Additionally, Mrs. Hawbaker has a driving phobia as a result of the subject motor vehicle accident. 217434.I\n AAC2 W A 2. Economic damages. Mrs. Hawbaker has sustained work loss and a • I permanent diminution of her earning power and capacity. Mrs. Hawbaker was a beautician before the accident. As a result of result of her motor vehicle accident injuries, she remains 11 disabled. B. Plaintiff Walter Hawbaker • Loss of consortium. II III List of names and addresses of all Persons who may be called as witnesses classifi inc them as liability or damage witnesses • A. Liability Witnesses • Drive #10 urt;, PA 17055 2. wee Conrad 124 Woods Drive #29 Mechanicsburg, PA 17055 • 3. Frede i 9J a isle, PA 13 • 4. C S?Murphy, as if on cross-examination 9 Orchard Street Mechanicsburg, PA 17055 !1 B. DamXr esses • I. nald B ruaw - family physician - deposition 56 South Enola Drive Enola, PA 17025 2. Richard Hallock - orthopaedic surgeon - video deposition Orthopaedic Institute of Pennsylvania 3916 Trindle Road Camp Hill, PA 17011 217434.1 WHALC2 I V 0 O O O O O O 0 0 Cd V V175 Lancaster Boulevard e. Harrisburg, PA 17110 Harris burg, PA 17112 11. inda Deraela - former customer 45 Logan's Run Enola, PA 17025 3, r. Daniel DeFalcis - physiatrist - video deposition P.O. Box 2028 Mechanicsburg, PA 17055 4. D tuart Hartman -physiatrist -video deposition 645 North Third Street 5. Dr. Pauline Wallin -psychologist 201 South 32"`t Street Camp Hill, PA 17011 6. .Paul Anderson -vocational expert 2418 North Second Street Harrisburg, PA 17110 erapist 7. DebrKI McC240 p 8. nna Lorince -occupational therapi st Healthsouth Rehabilitation Center of Mechanicsburg P.O. Box 2016 Mechanicsburg, PA 17055 9. indy Heinl -employer 4933 Carlisle Pike Mechanicsburg, PA 17055 10. Fran Cunningham - former customer 7045 Pine Road 13. P ttffSharon Hawbaker 24 Woods Drive #10 Mechanicsburg, PA 17055 12. Sandy Box - former customer 2 ady Lane nola, PA 17025 217434.1\DLL\LC2 A Drive #10 • urg, PA 17055 15. nee Conrad - Plaintiffs' daughter 124 Woods Drive #29 Mechanicsburg, PA 17055 • II IV. List of all exhibits which a party intends to use at trial • A. Photographs of the accident scene B. Diagram of the accident scene C. Photographs of the property damage to the vehicles 0 11 D. Theracane E. 1994 through 1997 W-2 statements F. Vocational loss charts from Dr. Anderson's report O G. Medical Treatment Summary H. Mrs. Hawbaker's appointment book 0 1. Charts from Work Performance Center V. Cony of the written report or answer to written interrogatories consistent with Rule O 4003.5 containing opinion of expert witnesses A. Dr. Donald Bruaw's deposition is attached as Exhibit A. B. Dr. Richard Hallock's deposition is attached as Exhibit B. C. Dr. Daniel DeFalcis' deposition is attached as Exhibit C. D. Dr. Pauline Wallin's report and records are attached as Exhibit D. E. Dr. Hartman's report is attached as Exhibit E. G II F. Dr. Paul Anderson's vocational expert report is attached as Exhibit F. G. Debra Latsha's physical therapy reports and records are attached as Exhibit G. 217434.1\DLL\LC2 4 Iff Wa 14. PI ' Iter Hawbaker 4 Woods Mechanicsb N U n H. Donna Lorince's occupational therapy reports and records are attached as Exhibit H. ea A VI. Stinulationsoftheparties, if any None. VII. Estimated length of trial C 2 days. VIII. Any scheduling problems C None. II IX. Any special evidentiary issues O None anticipated. O X. A realist settlement offer or demand Attached as Exhibit I is Plaintiffs' counsel's June 23, 1999, correspondence to the Defendant's insurer demanding a tender of policy limits. The Defendant has made no offer. G U C; II Date: ANGINO & ROVNER, P.C David L. utz I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717)238-6791 Attorney for Plaintiffs II 217434.1\I)LI,\LC2 5 V • • • • • • 0 a 6 V A a C? Q O ?J v J V COPY SHARON HAWBAKER AND WALTER : IN THE COURT OF COMMON PLEAS HAWBAKER, : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS V : CIVIL ACTION - LAW : NO. 99-4775 CIVIL CHARLES S. MURPHY, JR., DEFENDANT JURY TRIAL DEMANDED DEPOSITION OF: DONALD A. BRUAW, D.O. TAKEN BY: PLAINTIFFS BEFORE: TAMMY J. BAKER, REPORTER NOTARY PUBLIC DATE: JUNE 12, 2000, 10:00 A.M. PLACE: ANGINO & ROVNER 4503 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA APPEARANCES: ANGINO & ROVNER BY: DAVID L. LUTZ, ESQUIRE FOR - PLAINTIFFS WILLIAM ADDAMS, ESQUIRE FOR - DEFENDANT ' Hu96ez ' Alb.ight Foltz ? ya' ) tl. NaWlp 2080 Linglestrnm Road • Suite 103 s Harrisburg, PA 17110 717.540.0220 • fax 717.540.0221 • Lancaster 717.393.5101 n n n O J I..; Multi-Pagcn' DONALD A. BRUAW, D.O. JUNE 12, 2000 Page 2 Page 4 1 WITNESS I A Four years. 2 NAME EXAMINATION 2 Q Once you graduated you received a -- 3 DONALD A. BRUAW, D.O. 3 A Do degree. 4 BY: MR. LUTZ 3 4 Q From that point what did you do? 5 BY: MR. ADDAMS 10 5 A I was in general practice in Enola. 6 6 Q How long were you in genet al practice? 7 7 A 36 years. 8 8 Q During those years did you have occasion to see 9 9 patients involved in motor vehicle accidents? 10 10 A Yes. 11 11 Q During those years at times would you treat these 12 12 patients? 13 13 A Yes. 14 14 Q And at times would you also refer those patients 15 15 to other specialists? 16 16 A Yes. 17 17 MR. LUTZ: I'm going to move to admit Dr. Brnaw 18 18 as an expert in family medicine and ask if them are any 19 19 questions on qualifications. 20 20 MR. ADDAMS: 1 have no questions. 21 21 BY MR. LUTZ; 22 22 Q Doctor, in answering any of my questions or 23 23 attorney Addams' questions you may certainly look at your 24 24 medical records. When was Sharon Hawbaker lust seen after 25 25 an accident of April 11th, 1998? Page 3 Page 5 1 STIPULATION I A She was seen April the 14th of 1998. You said 2 It is hereby stipulated by and between counsel 2 after the accident? 3 for the respective parties that reading, signing, sealing, 3 Q Yes, sir? 4 certification and filing are hereby waived; and that all 4 A The 14th. 5 objections, except as to the form of the question, are 5 Q Now, was she scheduled to come in and see you 6 reserved to the time of trial. 6 anyway on April 14th, 1998? 7 7 A I believe she was scheduled for routine blood 8 DONALD A. BRUAW, DO, called as a witness, being 8 pressure check, maybe some blood work to be taken. 9 duly swom, testified as follows: 9 Q Before Mrs. Hawbaker's accident of April 11th, 10 EXAMINATION 1o 1998, what was the problem with her blood pressure? 11 BY MR. I=: I1 A She had hypertension. 12 Q Will you please state your full name? 12 Q All right. For the jury would you please explain 13 A Donald A. Bmaw, B-R-U-A-W. 13 hypertension in layman's terms? 14 Q Your professional? 14 A High blood pressure. 15 A Osteopathic physician, retired. 15 Q Was she on medication for that? 16 Q Dr. Bruaw, when did you retire? 16 A Yes. 17 A October 1, '98. 17 Q Do you know if she had any chronic 18 Q When did you start practicing medicine? 18 musculoskeletal problems before this accident? 19 A October 1, '62. 19 A Not to my knowledge. 20 Q Will you please give the jury a summary of your 20 Q Doctor, we'll go to the April 14th, 1998, office 21 educational background and training starting with college? 2 1 visit. Can you tell us whether there was a history 22 A I graduate from F and M in 1957, PcO in 1961. 2 2 recorded? 23 Q What is Pco? 2 3 A For her for the accident? 24 A Philadelphia College of Osteopathy. 2 4 Q Yes. 25 Q How many years program was this? 2 5 A Yes, there was, yes. HUGHES, ALBRIGHT, FOLTZ & NATALE Page 2 - Page 5 n DONALD A. BRUAW, D.O. Multi-Page' JUNE 12, 2000 Page 6 1 Q Will you please tell us about that? n 2 A Evidently she --1 believe her daughter was 3 driving, they were coming down 944, the Wertzville Road 4 toward Enola and someone stopped on the Wertzville Road to 5 tum into -- they were making a left-hand turn onto Carol 6 Lane, which is a nasty intersection. ^ 7 The daughter stopped and someone behind her did 8 not, plowed into her from behind. 9 Q Did you examine Sharon Hawbaker that day? 10 A Yes. 11 Q And essentially could you tell the jury in 12 layman's terns what you found? 125 13 A She was complaining of a lot of problems with her 14 neck. She also complained of pain in the low back. She had 15 a lot of muscle spasm in the cervical spine. She had 6 decreased motion in the cervical spine. The lumbar spine 7 evidently had some muscle spasm and decreased motion there. 8 Q What is a spasm, Doctor? 9 A Spasm is when a muscle tightens up, shortens 1 0 because it's been injured. ; 1 Q Is this something you can actually feel? 2 2 A Yes. 2 3 Q Doctor, given the history and,your physical 2 4 examination, what was your diagnosis? 2 A We thought she had a flexion/extension injury or 2. Page 7 1 a whiplash of the cervical spine. 2 Q What about the lumbar spine? 3 A Well, the lumbar spine was probably from being '` 4 thrown forward, too. 5 Q What was your treatment plan relevant to the 6 injury to the neck and low back? 7 A We tried muscle relaxants in the form -- do you 8 want me to name the medications? J Q Sure. 10 A Flexeril, which is a potent muscle relaxant and 11 Vicoden for the pain, to try to break up the pain cycle. 12 We told her to do some physical therapy at home, 13 hot compresses, that sort of thing. 14 Q Did that pretty much complete your April 14, 1998 5 visit? 1 6 A Yes. 7 Q When did you next see her, Doctor? 8 A April 21 st, a week later. 9 Q How was she doing? V A No better. Worse. I Q At that point what was your treatment plan? 2 A The same. We continued with the therapy as i 3 outlined and told her to stay on the medicine for another j I week until we rechecked her. Actually it was two weeks. Q You mentioned therapy. Did you prescribe a more Page 8 I formal physical therapy program? 2 A No, not at that time. I don't think so. 3 Q Actually, Doctor, I'll show you a document from 4 perhaps a couple days later. 5 A Yeah, we did. Several days later we sent her to 6 physical therapy with McCuen. 7 Q Why did you feel physical therapy was warranted? 8 A She seemed to think that she was much worse. 9 Q Okay. Did she indicate to you when you met her 10 on April 21st, 1998, anything about her job? 11 A Yeah, she was a hair dresser and it required 12 standing, it required working with her arms over her head 13 and she didn't feel she could do the job. 14 Q When did you next see her for these problems? 15 A The next time was the 5th of May. 16 Q Any improvement? 7 A No. 8 Q All right. When was the next time you saw her? 9 A The 19th of May. 0 Q And would you tell us about that visit, please? I A Sharon needed a lot of reassurance. She was a 2 very emotional girl and she said the physical therapy wasn't I doing much. t She hadn't been able to work and the physical i therapist, he recommended that she discontinue the therapy Page 9 I and that we refer her to an orthopedist. 2 I talked to her about it and I felt that since 3 she wasn't much better and since the pain was now in the 4 anus and somewhat in the fingers, that we should refer her 5 to an orthopedist and she requested Dr. Hallock. 6 Q Did you send her to Dr. Hallock? 7 A Yes. 8 Q Once you sent her to Dr. Hallock, was it your 9 understanding that he was going to take care of the neck and 10 low back problem? II A Yes. 12 Q Doctor, you mentioned problems with the hands and 13 arms? 14 A Yes. 15 Q Anatomically speaking, what causes that? 16 A Probably the muscle spasm, the plexus of nerves 17 in the upper extremity originating in the neck, that is what 18 I thought it was. 19 Q Doctor, based on the history of the motor vehicle 20 accident, the fact that she was your patient beforehand, 21 your physical exam, do you have an opinion with a reasonable 22 degree of medical certainty that Mrs. Hawbaker's injury to 23 her neck and low back was causally related to the April 24 11 th, 1998, motor vehicle accident? 25 A 1 believe it was yes. ige 6 - Page 9 HUGHES, ALBRIGHT, FOLTZ & NATALE n R9 (n) C,: V W(_ E U MWh-Page' DONALD A. BRUAW, D.O. JUNE 12, 2000 Page 1 1 MR. LUTL: Thank, Doctor, Mc Addams probably has 0 Page 12 I COUNTY OF DAUPHIN 2 some questions. 2 : SS 1 3 BY MR. ADDAMS: 3 COMMONWEALTH OP PENNSYLVANIA : 4 Q How long has she been your patient? 4 I, Tammy J. Baker, a Notary Public authorized t 5 A I started seeing her in 1989, so that would be , o 5 administer oaths within and for the Commonwealth of 6 nine years, ten years. 6 Pennsylvania, do hereby certify that the foregoing is the 7 Q During those nine or ten years, I understand 7 testimony Of DONALD A. BRUAW DO 8 you'd been treating her for hypertension? , . 8 1 further certify that before the taking of said 9 A Yes. 10 Q Were you giving her any treatment for any 9 deposition, the witness was duly swom; that thu questions 10 I I emotional problems? and answers were taken down stenographically by the said 1 11 Reporter-Notary Public, and afterwards reduced to 12 A Yes. 12 typewriting under the direction of the said Reporter 13 Q What was the nature of that? . 13 I further certify that the said deposition was taken 14 A Reassurance. Occasionally we would give her 14 at the time and place specified in the caption sheet hereof 15 something for headache, dizziness, that sort of thing. . 15 I further certify that I am not a relative or employee 16 Q When did that first begin? 16 or attorney or counsel to any of the parties or a relative 17 A That began in 1997, January -- wail a minute. ' , 17 or employee of such attorney or counsel, or financially 18 No. I don t know if we have that. What do you want to 18 interested directly or indirectly in this action 19 know, when did her emotional problems begin? . 19 I further certify that the said deposition 10 Q Yes, sir. 20 constitutes a true record of the testimony given by the said 21 A Probably 1994. 21 witness. 22 Q Did you prescribe any medications for that? ' 22 IN WITNESS WHEREOF, I have hereunto set my hand 23 A I don t have -- I don't think she wanted to take 23 this 14th day of June, 2000. 24 any medication for her nerves. 24 25 Q So your treatment was generally in the form of _r rr1 25 Notary Public Page 1 I eassurance? A Reassurance and ant7 when [ T e time came. 4 Q She's expressed somor em ck of a better tern -- whean a n j 6 automobile since the accident. 7 In your opinion is that a continuation or does it 8 have anything to do with her situation before? 9 A I don't see how it affects her situation before. 10 Q Did the situation before affect this is what the 11 question is? 12 A I don't think so. She's gone through a nasty 13 divorce. She had an alcoholic husband, two daughters who 14 were in bad marriages, moved down to an area she didn't 15 know, they were from Scranton. I believe they were from 16 Scranton, somewhere up there. 17 MR. ADDAMS: Okay. Thank you, Doctor, that's all 18 1 have. 19 MR. LM: You're finished. 20 (Whereupon, the deposition was concluded at 10:10 21 a.m.) 22 23 24 25 HUGHES, ALBRIGHT, FOLTZ & NATALE Page 10 - Page 12 717-540-0220\717-393-5101 0 7 0 0 0 0 0 U G n n e1 CA 0 0 0 Iii u v V COPY SHARON HAWBECKER AND IN THE COURT OF COMMON PLEAS WALTER HAWBECKER, CUMBERLAND COUNTY, PLAINTIFFS PENNSYLVANIA CIVIL ACTION - LAW V NO. 99-4775 CIVIL CHARLES S. MURPHY, JR., DEFENDANT VIDEOTAPED DEPOSITION OF: RICHARD HALLOCK, M.D. TAKEN BY: PLAINTIFFS BEFORE: MARIA N. O'DONNELL, RPR NOTARY PUBLIC DATE: MARCH 23, 2000, 4:13 P.M. PLACE: 450 POWERS AVENUE HARRISBURG, PENNSYLVANIA APPEARANCES: ANGINO & ROVNER, PC BY: DAVID L. LUTZ, ESQUIRE FOR - PLAINTIFFS WILLIAM ADDAMS, ESQUIRE FOR - DEFENDANT HugM1es Albright F.I. 44 rlamlc 2080 Linglesrown Road • Suite 103 • Harrisburg, PA 17110 717.540.0220 0 fax 717540.0221 • Lancaster 717.393.5101 2 n C) O 0 O O U ® V wi ? 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 WITNESSES NAME EXAMINATION RICHARD HALLOCK, M.D. DIRECT CROSS BY: MR. LUTZ 3 -- BY: MR. ADDAMS -- 12 ¦I v r. I WITNESSES 2 NAME EXAMINATION 3 RICHARD HALLOCK, M.D. 4 DIRECT CROSS 5 BY: MR. LUTZ 3 6 BY: MR. ADDAMS •• 12 7 n 8 9 10 11 12 13 IS 16 1 18 19 C) I RICHARD HALLOCK. M.D., called as a witness, 2 being duly sworn, testified as follows: 3 DIRECT EXAMINATION 4 BY MR. LUTZ: 5 Q Doctor, would you please state your full name? 6 A Full name is Richard Henry Hallock. 7 Q Your profession? 8 A I am an orthopedic surgeon.. 9 Q Could you tell the jury what you do on a daily 10 basis as an orthopedic surgeon? 11 A I take care of patients who have surgical and 12 nonsurgical problems related to their bones and joints. 13 Q Would you please summarize your educational 14 background and training to become an orthopedic surgery. 15 A I initially went to four years of undergraduate 16 school followed by four years of medical school, graduating 17 from the University of Maryland, then I finished five years 18 of orthopedic training at the Hershey Medical Center. 19 Q Are you board certified, doctor? 20 A Yes, I am. 11 Q Doctor, over the years have you received 22 referrals from other physicians? 23 A Yes, I have. 4 Q Over the years, have you treated people that have '.5 been involved in motor vehicle accident trauma? HUGHES, ALBRIGHT, FOLTZ & NATALE 717-540-0220\717-393-5101 Multi-Page, Page 2 RICHARD HALLOCK, M.D. MARCH 23, 2000 Page 4 I A Yes, I have. 2 MR. Lf71Z: At this point I am going to move to 3 have Dr. Ilallock admitted as an expert in orthopedic surgery 4 and ask if there are any questions on qualifications? 5 MR. ADDAMS: No, I have no questions on 6 qualifications. 7 BY MR. LUTZ: 8 Q Doctor, we're going to be asking you questions 9 concerning your care and treatment of Mrs. Hawbecker. And 10 if in answering my questions or Attorney Addams' questions I 1 you need to look at your notes, please feel free to dose. 12 When did you first meet this lady? 13 A I first met Mrs. Hawbecker on June 3, 1998. 14 Q Do you know how it was that she came to be seen 15 by you? 16 A She was referred by Dr. Bruaw. 17 Q What was her chief problem at that time, doctor? 18 A Neck pain. 19 Q Did you obtain a history from her as to what had 20 happened? 21 A Yes, I did. 22 Q Could you summarize the history, please? 23 A At the time she came in she was a 46 year old 24 woman who had been involved in an automobile accident on 25 April 11th, 1998. Page ' Page 5 I She was the passenger in a car that was stopped 2 turning left and was eventually rear ended. 3 Several days after her accident, she developed 4 neck, midback and low back pain. Gradually the low back 5 pain got better. 6 Dr. Bmaw started her on physical therapy prior 7 to my initial consultation, which had improved her low back 8 pain. Unfortunately the pain in her cervical spine and 9 upper thoracic spine had not improved and actually had been 10 aggravated by the physical therapy. I I Q Doctor, where is the thoracic spine and where is 12 the cervical spine? 13 A Actually here is a model of the spine. And the 14 low back area, the lumbar area is the brown region. The 15 thoracic spine which is the area where the ribs come off 16 where your chest is is the lighter brown vertebrae. And the 17 upper spine which is your neck or cervical spine is the 18 yellow. 19 Q All right. And doctor, did you examine her that 20 day? 21 A Yes, I did. 22 Q Could you give us the highlights of that exam? 23 A At that point she had normally a full range of 24 motion of her neck. Extension of her spine definitely 25 reproduced pain in bctwam her shoulder blades. Page 2 - Page 5 n RICHARD HALLOCK, M.D. Multi-Page "' MARCH 23, 2000 Page 6 I She had tenderness along the borders of her Page 8 1 Q In layman's terms, can you tell us what an MRI 2 scapula which are the shoulder blades. 2 scan is? 3 Her neurological exam which included strength and 3 A An Mat scan is a special type of an -- I wouldn't 4 reflexes were fully intact. 4 say x-ray because it's not really -- doesn't involve 5 She had no pain with rotational movements or her 5 radiation, but it's a type of picture that's produced by 6 shoulder, indicating her shoulder joints were unaffected. 6 going into a tube that has a magnetic field. And as a 7 She had normal strength and reflexes in her lower 7 result of that it creates pictures of not just the bone A 8 extremities and she walked with a normal gait pattern. , 8 like a plane x-ray does, but also of the soft tissues which 9 Q Doctor, did you review any diagnostic studies? 9 in the circumstance of the neck includes all of the nerves 10 A She had x-rays taken prior to my visit which 10 and the disks. I I showed some mild degenerative disk disease at -- in her 1 11 Q Did the radiologist that took the Mtti scan report 12 cervical spine in the neck between the fifth and sixth 12 back to you his findings? 13 vertebrae. 13 A Yes, he did. 14 Q Now, is that anything unusual for somebody that 14 Q And again, doctor, in layman's terms, can you 15 is 46 years old? 15 tell us what the MRI scan showed? 16 A No, it's not unusual. It's part of the natural 16 A Basically it confirmed what had already been 17 aging process and it wouldn't be unusual to have it at the 17 previously seen on the x-ray. There was some mild 18 age of 46 in a mild form. 18 degenerative disk disease. There did not appear to be G 19 Q Would that have existed before the accident? 19 anything such as a soft disk herniation which would indicate 20 A Absolutely. 20 acute trauma to the disk in the neck, and to me as a surgeon 21 Q Doctor, what was your diagnosis? 21 there was no evidence there was a surgical problem in her 22 A My diagnosis was degenerative disk disease which 22 neck. 23 had been aggravated by cervical strain injury. 23 Q Was this particular problem at C-5,6 that you 24 Q And could you tell thejury what is a cervical t.; 24 mentioned? 25 strain, what is the mechanism of such an injury? 25 A Yes, it was. Page I A Mechanism of the injury is at the point of impact 7 Page 9 1 Q And could you again show us on a model where that 2 when one car hits another or one train car hits another or 2 is? 3 whatever circumstance that you are involved in. There is a 3 A Again, this is the cervical spine here in yellow. 4 hyperextension and hyperflexion of the neck which is really 4 The vertebrae are numbered from the top down. This being 5 produced by movement of the head pulling the neck back and 5 one, this being seven. The disk, the C-5 disk is actually 6 forth. The head being the anchor, so to speak. 6 the one disk, but it's between the fifth vertebrae and the 7 Q What was your treatment plan on this particular 7 sixth vertebrae, so the C-5 disk is the small darker 8 day? 8 material between the two adjacent bony vertebrae. 9 A Well, she had already been tried on physical 9 Q Doctor, did you have her come back to see you 10 therapy. And it had aggravated her symptoms in the neck. 10 after the MRI scan? 1 For that reason we just kept heron Voltaren, started her on 1 1 I A Yes, I did. 2 home exercise program, and agreed to see her back several -- 12 Q Can you tell us how she was doing? 3 a month later. 13 A Actually I saw her back on July 9th, 1998. At 1 4 Q Did you order any more diagnostic studies? 14 that point she stated that her neck was gradually getting 5 A Yes. 15 better. Again, she was taking Voltaren which is an 16 Q What did you order doctor? 16 anti-inflammatory medication and continuing with the home I7 A Mgt scan. 17 exercise program. 18 Q Why did you feel that was necessary? 18 Based on the fact that she was gradually getting 19 A Basically because she had a fair amount of 19 better with what she was doing, we had kind of decided that 0 symptoms that had already been treated fairly aggressively 20 1 wouldn't need to see her again and that she would return 21 with medication and physical therapy and didn't respond I 21 to work after she had completed another four weeks of 22 would say in the normal fashion to what 90 to 95 percent of 22 exercise. 23 people respond to in the shape that she was in. 1 23 Q Doctor, before we go on to passed July 9th, did 24 Q Did she undergo the MRI scan? 24 you see her on June Ilth? A Yes, she did. 1 ,15 25 A Yes, 1 did. Page 6 - Page 9 HUGHES, ALBRIGHT, FOLTZ & NATALE 717-540-0220\717-393-5101 /1 n n n ' .' _J .l I 1.10 Multi-Pagc'M RICHARD HALLOCK, M.B. MARCH 23, 2000 Pagc 10 Page 12 I Q On June 1 1, what was your treatment plan? 1 Q And did you more or loss tom her ova to Dr 2 A My treatment plan was pretty much the same as 1 . 2 Lupanacci? 3 just mentioned. We had decided to keep her on the Voltaren 3 A Yes. Obviously she was -- there is always that 4 and to continue her on home exercise program. 4 interim period of time when we make the appointment and when 5 Q At that point, did you release her to relum to 5 she would sac Dr, Lupanacci that if she had problems she 6 work on June Ilth, 1998? 6 could certainly always call our office for help. 7 A No. She was unable to work at that point. 7 Q All right. But August 6, 1998 would be the last 8 Q But then when you saw her on July 91h, 1998, you 8 time that you saw her? 9 did discuss return to work? 9 A Yes 10 A Yes. 10 Q Doctor, based on the history of the motor vehicle 11 Q What specifically did you tell her? 11 accident of April 11, 1998 your physical exams, your review 12 A I told her that we would give her another four 12 of the diagnostic studies, do you have an opinion with a 13 weeks to continue to exercise her neck at home. And 13 reasonable degree of medical certainty, that Mrs. 14 assuming that the trend continues as it had been, that she 14 Hawbecker's degenerative joint disease of her cervical spine 15 would be allowed to return to work on August 6, 1998. 15 and the cervical strain was causally related to the April 16 Q All right. When was the next contact that you 16 11, 1998 accident? 17 had with Mrs. Hawbecker? 17 A I do. And it was related to the accident. 18 A The next contact we had was actually a phone 18 MR. LVIZ: Thank you. Doctor. 19 message that my secretary took. Stating that she had tried 19 Cross-examination. 20 to do some housework over the previous weekend and that her 20 CROSS EXAMINATION 21 neck was aggravated and she really didn't feel like she 21 BY MR, ADDAMS: 22 could probably return to work when she was given the release 22 Q Doctor, as I understood your plan was that sbe 23 to. 23 would return to work on August 6, 19987 24 Q When did you next see her? 24 A Yes 25 A I actually saw her on August 6, 1998. 25 Q What happened? Page 13 I Q And did you again examine her doctor? I A Well, about a week after we had had that office 2 A Yes, I did. 2 visit she called and said that she had been doing some 7 3 Q And can you tell us what the res 3 housework at home, and with -- felt that based on her -- the 4 were? 4 response that she had from that increase in activity, that 5 A Well, that she was complaining o 5 she didn't feel she could probably return to work. This was 6 pain but also low back pain. She also c 6 still several weeks away from the date that we had given 7 sciatica in her right lower extremity. 7 her, so we just said why don't you wait and see how you 8 The neck symptoms had -- really were unchanged 8 feel, you know, if things -- if time passes and you are 9 from her previous examination. Physical examination 9 still feeling the same way, just come back and see us. 10 revealed a woman who was somewhat upset about the fact that 10 Q Then you did see her on August 8th? 11 she wasn't getting better. She had a decreased range of 11 A Yes. 12 motion in her neck and low back. 12 Q And she wasn't any better? 13 The neurological examination was totally normal, 13 A Correct. 14 and she had no limitation of movements in her shoulder and 14 Q But really what's her problem? Why doesn't she 15 hips which would indicate that there was some component of 15 get better? 16 joint disease involved in her injury. I6 A Well, I can't comment on that at this point since 17 Q What was your plan at this point? 17 1 haven't seen her since August 6th, so I don't know whether 18 A At that point, I really didn't feel like i had a 18 there has been further diagnostic work since that time. 19 lot else to offer her as an orthopedic surgeon. So I 19 Q You sent her over to the rehab specialist for I 20 referred her to Dr. Luppanaci who is a physiatrisl, a 20 believe what you characterized as a chronic pain management 21 rehabilitation specialist who is trained in the management 21 situation? 22 of that type of problem. 22 A Yes. 23 Q So at this point, you felt certain there was not 23 Q Did you make a diagnosis of chronic pain syndrome 24 a surgical problem? 24 with her? 25 A Yes. 25 A No. My diagnosis was as previously stated HUGHES, ALBRIGHT, FOLTZ & NATALE Page 10 - Page 13 717-540-0220\717-393-5101 n RICHARD HALLOCK, M.D. Multi-Pagcr" MARCH 23.2000 Page 14 1 degenerative disk disease which was pre-existing in her neck 2 which had been aggravated by a cervical strain, but neither 3 of those two particular problems unless they would be in -- 4 unless -- especially the cervical strain, unless it changes 5 is a surgical issue. And obviously that's what I do for a 6 living. 7 Q You made some comment before that she didn't C? 8 respond the way 90 to 95 percent of other patients do? 9 A Yes. 10 Q Does the cervical strain normally heal? 11 A Well, I don't think we see 90 to 95 percent of 12 people who are in small bump accidents in our office. They 13 never get to the level of treatment that we're talking about 14 here. And that's kind of what I meant by that. I am not 15 talking -- didn't really mean to say that she didn't respond 16 like 90 to 95 percent of the patients that we see in the 17 office. But probably 90 to 95 percent of the people that 18 actually have an accident, but that was an educated guess. t-. 19 Q There is no doubt in your mind that she does have 20 a legitimate injury or she did have in 1998? 21 A She did in '98, yes. 22 Q And you expected her to make a full recovery? 23 A At that point, I did. Yes. 24 MR. ADDAMS: Thank you, sir, that's all I have. t 25 MR. LUTZ: Thank you, doctor. Page 15 1 (Whereupon, the deposition was concluded at 2 4:20 p.m.) 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Page 16 1 COUNTY OI' DAUPHIN 2 : sS 3 COMMONWEACITI OF PENNSYLVANIA: 4 I, Maria N. O'Donnell, a Notary Public, authorized to 5 administer oaths within and for the Commonwealth of 6 Pennsylvania, do hereby certify that the foregoing is the 7 testimony of RICHARD HALLOCK. M.D. 8 I further certify that before the taking of said 9 deposition, the witness was duly swom; that the questions 10 and answers were taken down stenographically by the said I 1 Reporter-Notary Public, and afterwards reduced to 12 typewriting under the direction of the said Reporter. 13 1 further certify the said deposition was taken at 14 the time and place specified in the caption sheet hereof. 15 I further certify that 1 am not a relative or 16 employee or attorney or counsel to any of the parties, or a 17 relative or employee of such attorney or counsel, or 18 financially interested directly or indirectly in this 19 action. 20 1 further certify the said deposition constitutes 21 a true record of the testimony given by the said witness. 22 IN WITNESS WHEREOF, I have hereunto set my hand 23 this 28th day of March, 2000. 24 - , ., , NPR 25 Notary Public 24 Page 14 - Page 16 HUGHES, ALBRIGHT, FOLTZ & NATALE 717-540-0220\717-393-5101 0 0 0 0 0 0 0 V r% M Cl 0 0 V u V V 'opST SHARON HAWBAKER AND WALTER HAWBAKER, PLAINTIFFS V CHARLES S. MURPHY, JUNIOR, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4775 JURY TRIAL DEMANDED VIDEO DEPOSITION OF: DANIEL C. DE FALCIS, M.D. TAKEN BY: PLAINTIFFS BEFORE: DEIRDRE J. MEYER, REPORTER NOTARY PUBLIC DATE: JUNE 14, 2000, 2:32 P.M. PLACE: PRISM 175 LANCASTER BOULEVARD MECHANICSBURG, PENNSYLVANIA APPEARANCES: ANGINO & ROVNER, P.C. BY: DAVID L. LUTZ, ESQUIRE FOR - PLAINTIFFS ADDAMS & RUNDLE BY: WILLIAM ADDAMS, ESQUIRE FOR - DEFENDANT eporti er?4iree n `• 2000 Linglescown Road • Suite 302 • Harrisburg, PA 17110 717.540.0220 • Fax 717.540.0221 0 Lancaster 717.3935101 n n n n :D V V v V Multi-Page" DANIEL C. DE FALCIS, M.D. JUNE 14, 2000 Page 2 Page 4 1 WITNESS I A Daniel De Falcis. 2 NAME EXAMINATION 2 Q You're a doctor? 3 DANIEL C. DE FALCIS, M.D. 3 A That is correct, 4 BY: MR, LLJTZ 3, 5, 23 4 Q What type of doctor? 5 BY: MR. ADDAMS 20 5 A A medical -- M.D. specializing in physical medicine 6 6 and rehabilitation. 7 7 Q Is that called a physiatrist? 8 8 A That is correct. 9 9 Q How long have you been a physiotrist? 10 10 A I've been a physiatrist since 1998. 11 11 Q Would you tell the ladies and gentlemen of the jury 12 12 what you do on a daily basis as a physiatrist? 13 13 A A physiatrist treats all sorts of chronic illnesses 14 EXHIBITS 14 as far as musculoskeletal, stroke, amputees, spinal cord 15 Da FALCO DEPOSITION EXHIBIT NO. PRODUCED &MARKED 15 injuries, traumatic brain injury, and dealing with the acute 16 1. DISABILm' CIADAREPORT 19 16 rehabilitation and chronic rehabilitation to improve patients' 17 17 overall function and independence with their living. 18 18 Q Doctor, what I'd like for you to do is summarize 19 19 your educational background and training starting with 20 20 graduation from college. 21 21 A Okay. Graduated from Villanova University 1989 22 22 with a ns in biology. Then I worked for a pharmaceutical 23 23 company for approximately two years, Merck, Sharp, and Dohme, 24 24 in West Point, Pennsylvania. Following that, I enrolled in 25 25 medical school at Penn State University in Hershey, Page 3 Page 5 1 THE VIDEOGRAPHFR: My name is Arki Simmers, a 1 Pennsylvania, where I graduated with an M.D. in 1994. 2 paralegal with Angino & Rovner. Our offices arc located at 2 Following that, I did my internship at Penn State 3 4503 North Front Street, Harrisbwg; and I'm operating the 3 in Hershey and affiliated hospitals from '94 to '95. 4 video and audio equipment for today's deposition. The date is 4 Following that, I did my residency in physical medicine and 5 June 14th, 2000; and it is 2:32 p.m. 5 rehabilitation down in Baylor, Houston, Texas, and completed 6 We'= here on behalf of the Plaintiffs to take 6 that in 1998. 7 the deposition of Daniel De Falcis at 175 Lancaster Boulevard 7 Q Do you have any board certifications in your field 8 in Mechanicsburg, PA. Dr. De Falcis will be testifying in 8 of expertise? 9 this case: Sharon Hawbaker and Walter Hawbaker versus Charl es 9 A I do. 10 S. Murphy, Junior, in the Court of Common Pleas, Cumberland 10 Q And what is that, Doctor? I I County, Pennsylvania, No. 99, dash, 4775 Civil. Will the I I A Board certified in physical medicine and 12 attorneys please introduce themselves and who they represent? 12 rehabilitation as well as certified Independent Medical 13 MR. LUfZ: My name is David Lutz. I'm the attorney 13 Evaluation. 14 that represents Mrs. Hawbaker. 14 Q And, Doctor, have you treated people that have been 15 MR. ADDAMS: And I'm Bill Addams, anomey for 15 involved in motorcycle accident trauma? 16 Charles Murphy. 16 A I have. 17 THE VIDEOGRAPIIFR: Will the court reporter please 17 Q Given your background, do you receive referrals 18 swear in the witness? 1 8 from other doctors? 19 1 9 A I have. 20 DANIEL C DE FALCIS, M.D., called as a witness. 2 0 MR. I.Lr¢: At this point I'm going to move to have 21 being duly swom, testified as follows: 2 1 the Doctor admitted as an expert in physical medicine and 22 DIRECr ON QUALIFICATIONS 2 2 physiatry and ask if there's any questions on qualifications? 23 BY MR. LUT7: 2 3 MR. ADDAMS: I have no questions. 24 Q Would you please state your full name for the 2 4 DIRECT EXAMINATION 25 record? 2 5 BY MR. LUIL: HUGHES, ALBIUGHT, FOLTZ & NATALE Page 2 - Page 5 717-540-0220\717-393-5101 n DANIEL C. DE FALCIS, M.D. Multi-Page" JUNE 14, 2000 Page 1 Q Doctor, we're going to ask you questions concerning 6 Page 8 I therapy as well as a medication called amitri t line and 2 your care and treatment of Sharon Hawbaker. And if there's p y 2 continuing with her nonsteroidal medication, Voltaren and 3 any need to look at your medical records, certainly fail free , 3 discontinuing her muscle relaxant. 4 to do so. When did you first meet this lady'? 4 Q What kind of medication is Voltaren? 5 A I first met Mrs. Hawbaker on 8/19/98. 5 A Voltaren is a nonsteroidal medication similar to 6 Q Do you know how it was that she carne to be seen by 6 Ibuprofen, Advil, Motrin. 7 you? 7 Q How about amitriptyline, what is that? n 8 A She was referred by an orthopedic surgeon, 8 A amitriptyline is a tricyclic antidepressant 9 Dr. Hallick. 9 medication which has been around for quite some time It has 10 Q When you first met her, did you obtain a history? . 10 been used historically for depression at higher doses 11 A I did. , 11 however, has been found to have good properties with 12 Q Can you summarize the history that you obtained, 12 controlling pain as well as promoting sleep. 13 Doctor? n 13 Q Now, Doctor, this was the summer of 1998. Did you 14 A She was a 46-year-old, white female involved in a 14 continue to see her throughout 1998? 15 motorcycle accident on 4/11/98 where she was a restrained 15 A That is correct. 16 passenger in a car that was rear-ended. She developed neck 16 Q Doctor, what I'd like for you to do is tell us the 17 and back pain and low back pain. Two to three days later was 17 dates you saw her, how she was doing generally speaking, and IS seen by her primary care physician. Diagnosed her with a 18 then what you did for her on the dates you saw her? ltrain. She also had cervical X-rays which revealed no 19 A She wasreevaluated on 9/8/98. She had complaints but some mild degenerative disc disease in C5.6 20 of burning discomfort radiating down both arms, right side on. 21 worse than the left, worse with prolonged activity of holding an you show us on your own body the approximate L 22 her arms fully extended. She did have some benefit from the of where C5/C6 is? 23 therapy but did not take the amitriptyline. at would be approximately in this area right here 24 Q Doctor -- g). (indicating). 25 A She was -- Page 7 I Q And what does C51C6 stand for? 2 A C stands for cervical, which means the fifth and 3 sixth cervical vertebrae coming down from your neck. <- 4 Q And these degenerative changes you mentioned, is 5 drat anything unusual for somebody who's 46 years old? 6 A May not be unusual. 7 Q Okay. And, Doctor, after you obtained the history, 8 thm what did you do? 9 A I also obtained a past medical history as well as !0 comprehensive, you know, looking at the social history, I 1 allergies, and her medications. I did a physical examination. 12 Q And after doing the examination, did you reach a 13 diagnosis? 14 A I did. 5 Q And what was that, Doctor? 16 A Stams.posI motorcycle accident with degenerative 17 disc disease at 516 and cervical facet dysfunction. Also 18 chronic pain syndrome -- or chronic pain secondary to above. 19 Q Can you put that in layman's terms for us? e0 A The patient was involved in a motorcycle accident, [24 she had some degenerative changes, and she had an aggravation of pain as well as prolongation of her pain. Q All right. What did you do for her that day? What wen; your recommendations? A Recommendations were for a course of physical 6 - Page 9 Page 9 I Q Go ahead. I'm sorry. 2 A She was noted to have some trigger points and 3 underwent a trigger point injection. 4 Q Is that something you did? 5 A That is correct. 6 Q What exactly did you do? 7 A As far as a trigger point injection, 1 injected a 8 steroid medication as well as a numbing medication called 9 Marcaine, similar to what you get at the dentist's office. 10 Identified certain trigger points in the muscle; injected 11 those areas to break up the pain generators and spasms of the 12 muscle. 13 Q Where did you insert the injections? 14 A She had the injections in the right levator 15 scapula, which is a muscle on the top border of the scapula, 16 or the wing bone. 17 Q Show us on your own body, Doctor. 18 A That would be right there (indicating). 19 Q All right. 20 A As well as the rhomboids, which are the muscles in 21 between your shoulder blades; as well as the right trapezius, 22 which is this upper trapezius muscle up in here (indicating). 23 Q Now, Doctor, at this point in time was she working 24 or not? 25 A She was not employed as to my knowledge. HUGHES, ALBRIGHT, FOLTZ & NATALE 717-540-0220\717-393-5101 r-1 n 1 .J v Multi-Pagc'' DANIEL C. DE FALCIS, M.D. NNE 14, 2000 Pagc 10 Page 12 I Q All right. I take it you continued to se: her? 1 Q And can you tell its when you saw her during the 2 A That is correct. 2 renmainder of 1998? 3 Q And what happened next medically speaking from your 3 A 1 sow her in 11/98, at which time she underwent 4 perspective? 4 another trigger point injection. 5 A She continued -- I saw her again on 9/22/98. She 5 Q Then that takes us up to 19997 6 continued to have complaints of -- she first -- she did have 6 A And again in 12/16/98. 7 some relief with the injections. She continued to have 7 Q Doctor, 12116198 would have been roughly four 8 overall complaints although appeared to be improved. She was 8 months after you first saw her. How was she doing emotionally 9 tried again on the Amitriptyline, which she did not previously 9 from what you can tell? 10 take, to help improve her sleep. And there was concern about 10 A Emotionally, she had complained of some anxiety as 11 a possible irritation of the nerve called a radiculopathy 11 well as depression. She was very tearful. She also states 12 causing her persistent complaints going down her right upper 12 that she was having some nightmares about being unable to 13 extremity. 13 return to work. 14 Q So what did you do with regard to the radiculopothy 14 Q So what did you do from your perspective in that 15 concern? 15 regard? 16 A I ordered an onto nerve conduction study. 16 A We bad increased her amitriptyline, or Elavil to 17 Q Okay. What's that? , 17 50 milligrams to help with sleep. And that may also help with 18 A It's a diagnostic test which evaluates the 18 depression. And I recommended a persistent pain program as 19 physiology of the nerve by assessing both its sensory and 19 well as a psychology evaluation for bar anxiety and her 20 motor studies as well as the interaction between the nerve and 20 depression and dealing with coping. 21 the muscle. 21 Q What is a persistent pain program? 22 Q And did you perform that test? 22 A A persistent pain program is a program 23 A I did. 23 multidiscipline that uses both psychology intervention, 24 Q And again in layman's terms, Doctor, can you just 24 biofeedback, therapy in helping patients make their pain 25 tell us what the results were? 25 perhaps an aspect of their life but not the main purpose of Page 1 1 Page 13 1 A It was a normal study. There was no evidence of I their life. 2 any pinched nerve or hemiuted -- or radiculopathy. 2 Q Did she undergo this program? 3 Q All right. Then after the EMo was done, did you 3 A She underwent an evaluation by the program by 4 have her come back and see you? 4 Dr. Hills on 1/20/99; however, the program itself was still in 5 A I did. 5 its beginning and never took off -- 6 Q And again, Doctor, was she improving with time and 6 Q Okay. 7 what did you do for her? 7 A -- so she was not enrolled in it. 8 A Um, her pain complaints seemed to range between a 4 8 Q I take it she was evaluated by Dr. Hills? 9 to 7 out of 10; 10 being the most severe pain. She did seem 9 A Correct. 10 to be having some improvement with therapy, improved range of 10 Q By the way, is he one of your partners? II motion. 11 A Yes. 12 Q Was there a discussion about doing something to 12 Q Did he find anything different or new that you saw 13 return her to employment? 13 in his records? 14 A There was. We -- I initiated her in a 14 A No, he did not. 15 work-hardening program to increase -- or to test out her 15 Q All right. Did you continue to see her after 16 capacity to return back to work. 16 Dr. Hills saw her? 17 Q What is work hardening? What does that mean? 17 A I had. 18 A it's where a physical therapist takes a patient 18 Q And when was that, Doctor? 19 through a series of tests trying to simulate theirjob, trying 19 A 1/20/99. 20 to increase their tolerance for work making sure that patients 20 Q All right. Could you tell us what was going on by 21 tend to bend, lift, and twist in a manner that is conducive to 21 January of 1999? 22 appropriate body mechanics. 22 A I'm sorry. That was -- that was Dr. Hills' note 23 Q And. Doctor, while she was undergoing the 23 there. 24 work-hardening program, did you continue to see her? 24 Q Okay. 25 A I did. 25 A I did se: her on 1/13/99 prior to his evaluation. HUGHES, ALBRIGHT, FOLTZ & NATALE Page 10 - Page 13 717-540-0220\717-393-5101 DANIEL C. DE FALCIS, M.D. JUNE 14, 2000 Multi-Page" P.- 14 I Q So you saw her the week before Dr. Hills? 2 A That is correct. 3 Q Anything different in terms of your evaluation? 4 A She did have some concerns and anxiety regarding a 5 medical workup for a questionable cyst on the pancreas in 6 which her primary care physician, Dr. Groff, was working up 7 Q That would have nothing to do with this accident? 8 A That would be correct. 9 Q All right. Now, Doctor, after Dr. Mills saw her, 10 when did you next see her? 11 A That would be on 3/15/99. 12 Q Can you summarize your findings on that day? 13 A Yes. She was evaluated by the psychologist, O 14 Dr. Higgins. She stated that her chronic pain had worsened 15 approximately to 8 to 9 out of 10; 10 being the worst. She 16 also reported taking Vicodin to help, but she was using an 17 effective home exercise program of stretching as well as heat 18 and the use of a Theracane. r125 19 We continued -- I continued with the home exercise 20 program, the Theracane, as well as her medications and 21. scheduled a appointment with a psychologist, Dr. Wallin. 22 Q All right. Now, Doctor, a couple of times you've 23 used a pain scale. Is that subjective in that she tells you 24 her ratings and you write it down? A That is correct. Page I S 1 Q All right. But that's something you use in your 2 daily practice? 3 A I do. 4 Q All right. Now, Doctor, moving on, you continued 5 to see her through 1999? 6 A That is correct. 7 Q Can you -- go ahead. 8 A In May of '99, she did not fecl that she was s 9 getting any benefit with Dr. Wallin's treatments; however, she 10 continued to complain of fear of bring in the car, overwhelmed 11 with fear. Her pain complaints varial from a 2 out of 10 to 12 an 8 out of 10, but she was independent with her home exercise 13 program and was working on a treadmill and aerobic exercise 14 activity. 45 Q How about did she ever get back to hairdressing by 16 this point? 17 A She did not. 18 Q Okay. Did you see her in the summer of 1999? 19 A The next time was in August 11, '99. 10 Q Was she getting better, Doctor, or pretty much 21 staying the same? ?2 A Still about the same, the average of 4 out of 10. !3 She had been taking -- has taken herself off at this point the A amitriptyline; still taking the Voliaren as well as Advil. !5 She was noted that she's able to drive locally without 14 - Page 17 Page 16 1 increased anxiety. Again she was continued on her (tome 2 exercise program for managing her pain. 3 Q Did you see her towards the end of the year, 4 Doctor? 5 A On 1 1/2/99 she had complained of increasing pain 6 averaging of a 5 -- excuse me -- at its best at a 5; at its 7 worst a 10. Complained of a pulling sensation. She was 8 working on a home exercise program, but she was no longer 9 using the treadmill. She did report some decreased sleep and 10 had restarting seeing -- reinitiated seeing her psychologist, I I Dr. Wallin. 12 Q And, Doctor, moving onto the year 2000, did you 13 see her this year? 14 A She was seen in January of 2000. 15 Q Was that your last visit with her? 16 A I believe so. 17 Q All right. Why don't you tell us about that visit, 18 Doctor? 19 A She had reported some increased pain in the center 20 of her back prior to the Christmas holidays. She felt that it 21 was, quote, tom; although, with her techniques she was able 22 to improve her pain. And that's her home exercise techniques 23 I'm referring to. 24 She had still difficulty with sleeping and was 25 placed on some Serzone by her primary care physician. Her Page 17 1 pain was radiating into the low back and the hips, a 6 to a 10 2 out of 10. She was also taking larger doses of Ibuprofen, or 3 Advil, as well as the Voltaren; and I cautioned her on 4 potential side effects and problems. 5 She was continuing to see the psychologist, 6 Dr. Wallin, who had evaluated her vocational rehab, which 7 according to the patient was minimal given her difficulty, wwith 8 reading, spelling, and a 9th grade education; although, she 9 has had her GED. 10 Q How about your diagnostic impressions as of January 11 2000? 12 A Given her new complaints of the back discomfort and 13 the physical exam findings where she had tender points in the 14 upper tmpezius, the levator scapulae, the low back, the PSIS, 15 the hips as well as the medial knee, it was felt that she may 16 have met the criteria for fibromyalgia. 17 Q What is that, Doctor? 18 A Fibromyalgia is a chronic muscle illness which has 19 diffuse pain. 20 Q What's the treatment for fibromyalgia and the 21 treatment for chronic pain syndrome? 22 A At this point, it would probably be the same: 23 Improving sleep, aerobic exercise activity, as well as 24 continuing a home exercise program for stretching, 25 HUGHES, ALBRIGHT, FOLTZ & NATALE 717-540-0220\717-393-5101 A A n 0 U W V M Multi-Pagc' DANIEL C. DE FALCIS, M.D. JUNE. 14, 2000 Page 20 Page 18 1 Q What's the cur: for fibromyalgia? 2 A This is no cure for fibromyalgia. 3 Q Doctor, you mentioned a term, Psls. What is that? 4 A Pm sorry. The posterior superior iliac spine. 5 Q Okay. What does that mean in layman's terns? 6 A I'll have to point to where it is here on the side, 7 back here (indicating). 8 Q All right. And, Doctor, when you last saw her in 9 January this year, what were your recommendations for her? 10 A I recommended that she only use the Voltaren and Ill not -- and stop the Advil and she may use Tylenol in between 12 because they are similar drugs, the Voltaren and the Advil. 13 That can cause some potential problems with ulcers. She's to 14 continue with her Serzone for sleep, continue with her (tome is exercise program, may use heat, and to follow up as needed. 16 Q All right. Now, Doctor, at that point had you 17 released her to return to work as a hairdresser? 18 A Actually, prior to that I had stated to her that 19 she should be able to return to a light-duty capacity with 20 limited use of the upper extremities from an outreached 21 position. 22 Q So are you saying that she can return to employment 23 but not hairdresser? 24 A Because of her difficulties that she has in cutting 25 hair with an outreached position, she will not be able to Page 19 1 return to that. 2 Q In fact, Doctor, I'm going to show you an exhibit. 3 We'll mark it is Dr. De Falcis Exhibit 1. 4 (Disability form, one page, produced and marked De 5 Falcis Deposition Exhibit No. 1.) 6 BY MR. Lurz: 7 Q Is that your disability form that you signed? 8 A That is correct. 9 Q Okay. Now, Doctor, thank you. I'm going to ask 10 you a legal type question. Based on the history of the April 11 11th, 1998, accident, your physical examinations, your 12 diagnostic studies, do you have an opinion with a reasonable 13 degree of medical certainty whether Mrs. Hawbaker's chronic 14 pain syndrome and the criteria for fibromyalgia and the 15 problems you've been discussing are causally related to the 16 April I Ith, 1998, motorcycle accident? 17 A I do. is Q And your opinion is it's related? 19 A That it is related. 20 Q Doctor, you last saw her January of 2000. What 21 would your prognosis be for Mrs. Iiawbaker to have a full, 22 hundred percent recovery? 23 A Given her persistent pain complaints, I feet that 24 she will most likely always have some degree of pain. She 25 should be able to manage her pain, and she has shown to do HUGHES, ALBRIGHT, FOLTZ & NATALE 717-540-02201717-393-5101 I that effectively and still continue to pursue her life. 2 Q Okay. Now, Doctor, what would be the mechanism of 3 the injury? Ilow does this happen in a rear-end accident? 4 A Rwr-end accident would be a whiplash injury of 5 forward and backward thrusting. 6 Q Thank you, Doctor. Mr. Addams may have some 7 questions. 8 MR. ADDAMS: I just have a few for you, Doctor. 9 CROSS EXAMINATION 10 BY MR. ADDAMS: 1 I Q 1 noticed repeatedly in your reports as we were 12 going through these dates that you noted that she has a full 13 range of motion in her cervical spine. That first notation I 14 believe was December 6th, 1998, and continues up until the 15 present. Her EMG studies were normal. 16 I understood you to say earlier that she has 17 degenerative disc disease but not an unusual amount or degree 18 for a 46- to 48-year-old lady. Why doesn't she get better? 19 A I don't know. 20 Q You noted several times in your reports that she's 21 able to return to work to light duty if she's willing to do 22 so. Is she afraid to go to work? 23 A I feel that she does have a fear of returning back 24 to work as well as a fear of driving, and hence I sent her to 25 Dr. Wallin to address those issues. Page 21 1 Q She reported to us 1 believe earlier that the fear 2 with regard to the driving is when she's riding as a passenger 3 and she's okay with driving herself. Did she tell you that? 4 A I believe she did make some notation that she feels 5 more secure when x` 'a behind the wheel. 6 Q You would agree she's reluctant to return to work? 7 A I'd agree that she has anxiety about returning to 8 work. 9 Q What could be done about that? 10 A About the anxiety? 11 Q From a medical standpoint. 12 A There arc medications that may be of benefit. 13 Continued psychological therapy may be of benefit. 14 Q And with that treatment would you expect that the 15 condition would become manageable or livable or she could deal 16 with it? 17 A I would probably defer that to Dr. Wallin. 18 Q You said she now meets the criteria for 19 fibromyalgia. What is fibromyalgia? 20 A Fibromyalgia is a muscldtendon pain syndrome which 21 is characterized by having at least 1 I of the 18 tender points 22 as defined by the Rheumatalogic Society, also felt to be 23 partially a sleep disorder. 24 Q Is it thought to be a rheumatalogical disease? 25 A The word rheumatism has been used as much as --as Page 18 - Page 21 DANIEL C. DE FALCIS, M.D. JUNE 14.2000 Multi-page" Page 22 1 well as fibrositis has been used; but then: am no laboratory 2 findings shot etc positive for fihromyalgia. 3 Q It's just that people have sore points, right? 4 A That is correct. 5 Q Is the cause of fibromyalgia known? 6 A It is unknown. 7 Q You said earlier and in answer to Mr. Lutz's 8 question that in your opinion her chronic pain and 9 fibromyalgia was caused by the automobile accident? 10 A 1 said that her chronic pain and her chronic pain 11 syndrome was directly related to her automobile accident. The 12 fibromyalgia, in order to fully mat the criteria, blood work 13 would have to be performed in order to rule out any other type 14 of illness or disease. 15 Q But the cause of fibromyalgia is unknown? 16 A There have been causes linked to such as emotional 17 stress, physical stress, as wall as even trauma to 18 fibromyalgia; but basically unknown. 19 Q Now, with regard to her physical activities with a 20 view toward her getting back to work, what can she do? 21 A Can you be a little bit more specific? 22 Q What physical -- well, let's put it the odic way 23 then if you're mare comfortable with that: What can't she do 24 from a physical standpoint? 25 A What can't she do? I placed her under restrictions n n 0 1 of light duty, which is 10 to 20 pounds: 20 pounds 2 occasionally; 10 pounds move frequently. 3 Q Is that lifting? Q 4 A That's lifting. Okay. And limit activity from an 5 outreached position greater than 90 degrees or overhead 6 lifting orjust not even lifting but just bringing her arms 7 over on a repetitive use not more than -- according to the 8 Functional Capacity Evaluation, she had difficulty in 9 tolerating two m 11, inutes. I fat that he should probably be 0 able to tolerate a little bit mote than that. I would say l l ten to fifteen minutes. 2 Q Is she faithful doing her aerobic exercises? 3 A According to the notes, she has had some periods 4 4 where she has and some periods where she has not. 5 Q Does she have any restrictions on her ability to 16 stand and sit and walk? 17 A Just change positions as necessary. 18 Q Okay. Thank you, Doctor. 19 REDIRECT EXAMINATION Page 23 )0 BY MR. LUIZ: 21 Q Doctor, I will be very, very brief with regard to 22 the fibromyalgia you mentioned and you said if the blood work 23 was done. If the blood work was done and it ruled out whatever 24 the blood work would show if there was a problem; so if the 15 blood work was normal, would that reaffirm the criteria for Page 22 - Page 25 Page 25 I COUNTY OF CUMBERLAND 2 ss 3 COMMONWEALTH OF PENNSYLVANIA 4 1, Deirdre J. Meyer, a Notary Public, authorized 5 to administer oaths within and for the Commonwealth of 6 Pennsylvania, do hereby certify that the foregoing is the 7 testimony of Daniel C. De Falcis, M.D. 8 I further certify that before the taking of said 9 deposition, the witness was duly sworn; that the questions and 10 answers were taken down stenographically by the said 11 Reporter-Notary Public, and afterwards reduced to typewriting 12 under the direction of the said Reporter. 13 1 further certify that the said deposition was 14 taken at the time and place specified in the caption shat 15 hereof. 16 I further certify that I am not a relative or 17 employes or attorney or counsel to any of the parties, or 18 a relative or employee of such attorney or counsel, or 19 financially interested directly or indirectly in this action. 20 1 further certify that the said deposition constitutes a true 21 record of the testimony given by the said witness. 22 IN WITNESS WHEREOF, I have hereunto set my hand 23 this 14th day of June, 2000. 24 Ik?f. eyer, R4inter-- 25 Notary Public HUGHES, ALBRIGHT, FOLTZ & NATALE 717-540-0220\717-393-5101 Page 24 I fibromyalgia? 2 A It would -- my understanding of your question is if 3 the blood work is normal, does that state that she does have 4 fibromyalgia? 5 Q Or does that reaffirm the criteria for it? 6 A It does help in reaffirming the criteria. 7 Q But the impression is it's not the end-all-be-all 8 in terns of making that diagnosis? 9 A That is correct. 10 Q Okay. Thank you, Doctor. I I THE VIDEOGRAPIIFR: This concludes the deposition. 12 The time is 3:05 p.m. 13 (The deposition was concluded at 3:05 p.m.) 14 15 16 17 18 19 23 24 n HAWBAKER, SHARON 124 WOOD ? ? 124 WOODS DRIVE LOT 10 MECHANICSBURG,PA 17055 PDOB: 03/15/52 SSN: 187-42-8381 Acct. #: 014740 Physicians e/ Rehabilitation, Industrial t, Spine Medicine, P., DISABILITY CLAIM REPORT This form is to be completed and attached to any and all disability forms for patients of Physicians of Rehabilitation, Industrial and Spine Medicine, PC(P.R.I.S.M.) (Formerly "Physicians of Rehabilitation Medicine") A 5pnrvn of Mrdlnf Srmrn The insured is being asked to complete the PATIENT section °R'"° k4a.k'7/Ll' of the ORIGINAL form'. This attachment will replace the "mka!axmrar PHYSICIAN portion of their forms. No charge for this form. b Diagnosis Codes: 7231 7248 Initial Visit: 'F Date of last MD visit: Opt g,? Next office visit: O Michael F. Lupinacci, MD CURRENT DISABILITY STATUS: Si Van Do, MD William A. Rolli, Jr., MD Totally disabled (since date of Initial Visit unless ' Mark P. Lttness, MD Daniel C. DeFalcis is h noted in "Comment" section) Everett C. Hills, MS MD. u _/,-Partially disabled Disability ended: Disability status will be re-evaluated at next office visit. V CCMIdEbrl: ??/GCX ?tc%rr? ( J? ezC? tc*--cis Tj- n U Date 01/11/00 Physician. Signature 175 Lancaster Boulevards, ?A?rCL ?. DC ?/F(CCS , v PO. Box 2028 M h i b P (A copy of this page will be kept on file in our office chart.) ec an cs urg. A 17 If there are questions, please call 717-691-3755. Phone 717 691-37 ID# 7 Fax 717691-3834 p,y V . ?r D2Fu,lrrts ,J ???N ?J 450 Powers Avenue ED Rear Entrance Harrisburg, PA 17109 Phone 717 561-4242 Fax 717 561.4903 OP4 A A 0 0 0 0 O u A Pauline Wallin, Ph.D. Licensed Psvcholoeist A & Associates A A Re: Sharon Hawbaker Dear Mr. Lutz: Mrs. Hawbaker resumed psychotherapy with me on 9/24/99, after her previous session of 5/5/99. At that time she had suffered some physical and emotional setbacks, but said she was determined to get over her fear of riding in a car. Within a few sessions she was tolerating the anxiety while riding. She never became completely comfortable, but at the same time has not engaged in the avoidant behavior that she had a year,ago. 0 Mrs. Hawbaker continues to see me for psychotherapy. Although riding in the car still creates anxiety, this is not her most problematic issue at this time. Recently she was diagnosed with Fibromyalgia, a chronic, debilitating condition that is usually triggered by physical trauma, and has no known cure. Now Mrs. Hawbaker is trying to accept that she will not be returning to the occupation of cutting hair, which had given her not only pleasure, but also self-esteem. As with anyone confronting major loss, Mrs. Hawbaker is going through a period of mourning, replete with anger and depression. She does not know what else she can do to earn a living. Her reading and writing skills are so poor that she has trouble filling out a job application. Furthermore, her limited physical capabilities narrow her options considerably. I will continue to see her in psychotherapy to help her deal with these issues. It will probably take several months, though not necessarily at weekly intervals. Even then, however, Mrs. Hawbaker will not feel completely "whole" again. 201 South 32nd Street Camp Hill, PA 17011 (717) 761-1814 FAX (717) 761.1942 EMAIL: Pwallin0paonlinexont January 31, 2000 David Lutz, Esq. Angino & Rovner 4503 N. Front St. Harrisburg, PA 17110-1708 Enclosed is a bill for my services to date. Sincerely, V ? au me Wallil ,iPh.ke D. Licensed Psychologist r 0. CONSULTATION • EVALUATION • I'sYCI10'riIERAPY n 44 Ap1 Pauline Wallin, Ph.D. Licensed Psychologist 0 & Associates r, June 9, 1999 David L. Lutz Angino & Rovner C) 4503 North Front Street Harrisburg, PA 17110-1708 RE: Sharon Hawbaker 10 O 201 South 32nd Street Camp Hill, PA 17011 (717)761.1814 FAX (717) 761-1942 EMAIL: pwallin0paonline.wm Dear Mr. Lutz, Enclosed is my report on Mrs. Hawbaker, along with copies of office notes and a bill for services. Please call me if you have any questions. Sincerely, Pauline Wallin, Ph.D. Licensed Psychologist PW/re v v CONSULTATION • IiVALUATION • PSYCIIOTIIERAPY r, ? ? Pauline Wallin, Ph.D. Licensed Psvcholoeisr n & Associates 201 South 32nd Street Camp Hill, PA 17011 (717) 761.1814 FAX (717) 761.1942 EMAIL: pwallin@paonline.com n Name: Sharon Hawbaker Birth date: 3/15/52 Accident date: 4/11/98 PSYCHOLOGICAL REPORT June 8, 1999 Referral Mrs. Hawbaker was referred for psychological evaluation and treatment by Daniel DeFalcis, M.D., who had been treating her chronic pain. C Initial Interview I first saw her on 3/18/99. At that time she reported having severe pain in her back, as well as weakness and pain in her arms. She felt discouraged by her lack of progress in the 11 months since her auto accident, especially with regard to the use of her arms. She had been a hair dresser O and loved her job: "My job was my life. It was who I was," she stated. Now she cannot move her arms without pain, and therefore cannot work. In addition to the pain, Mrs. Hawbaker complained of "terror" when she is a passenger in a car. The accident had occurred while her daughter was driving and the vehicle was stopped at a traffic U light. Their car was hit from behind. Ever since the accident, Mrs. Hawbaker said that she becomes so anxious that she feels she's going to explode. Her heart races and her hands get clammy. She acknowledged that she had felt uneasy in the car for several years. She attributed this to the erratic driving habits of her first husband, an alcoholic who drank while driving. Nevertheless, she did not feel the level of terror that she reports currently. She also G acknowledged a general pattern of worry dating back several years. Diagnosis Adjustment Disorder with Mixed Anxiety and Depressed Mood, chronic DSM-IV 309.28 v Course of Treatment I began a program of weekly cognitive behavior therapy along with behavioral desensitization, to help her overcome her fear of riding in a car. Specifically, she was assigned homework in graduated steps. At first she rode with her husband for only a short distance. Time and route (i.e. highway vs local streets) were gradually modified, with the goal that she could visit relatives V in a distant town. She was also instructed in anxiety-management strategies, i.e., deep breathing and positive self-talk, designed to deal with her fears in the car. to CONSULTATION - EVALUATION - PSYCI IOTHERA PY n Aft Sharon Hawbaker... Page 2 n Mrs. Hawbaker made good initial progress, and reported feeling more optimistic. We then addressed her depression concerning her job. Since leaving her job she felt useless. She believed that she had no skills other than working with her hands. Nevertheless, she did want to get back to work. One of her shortcomings was her lack of confidence in reading. This would h preclude most desk jobs. She admitted that she had never read a whole book. Along with the driving exercises, I assigned her some reading. She did read an article in a newsletter and a book about health and stress, which she found interesting. Her self-confidence was improving. She felt ready to extend time between sessions to two weeks rather than one week. Then Mrs. Hawbaker suffered a setback. She panicked while riding with her husband, and felt discouraged. We discussed this in the session of May 5, 1999, and talked about additional coping strategies. This turned out to be our last session. Prior to her next visit, Mrs. Hawbaker called and cancelled her appointment, because she said that she didn't think the psychotherapy could do much more for her. I have not heard from her since. Prognosis There is a clear relationship between the accident and Mrs. Hawbaker's fear of riding in a car. Although she had been prone to worry, she had not felt terror nor experienced physical manifestations of anxiety while driving. The fears she has were acquired through the psychological process of conditioning, and with practice, can be unlearned. Mrs. Hawbaker did not give it enough time, and was easily discouraged by setbacks. In order for to be restored to her previous level of functioning, it will take about 18 months of therapy. Weekly sessions will probably not be necessary. The total number of sessions needed will be approximately 20 to 30, at a cost of $2200 to $3300. -' Her vocational adjustment will prove more troublesome. Accustomed to working with her hands, this is currently impossible. According to Mrs. Hawbaker, her doctor told her that little improvement can be expected. Thus, she must learn a new job. Lacking confidence in her ability to read, she must first overcome her resistance to doing light duty office work or other work where she does not have to use her arms. She will need to have a vocational assessment to evaluate her abilities for alternative work. This will cost $500 to $1000. Respectfully submitted, Pauline Wallin, Ph.D. Licensed Psychologist v Is, M AS* ?i "I .. I 0 ?(•' We" LI:C-? 1_t9,' ?-J. 0 i1j, ylIJ I 1 f \1 t.? ;tv -.\Z eAS .??\ y.li t. Y ? rP. ?J rl:?>.z.r' f • Siz-' 4y ` ??'?e.. C?IJI..{' 111111 \ t \ 1 t/` 111 i / 0 rt.t.l((xr. a 1 \f..•;c'-, ?."j J,J'.•,; J ? If.}c•r-, IM ?lo-raV +-GcJ `J '?? r t J kA: ?CG o ? `j ? ` JIy _ (/r1 ??i W... l.. C-n ..v._, r!. ley; ?1GJ.}\ ?Rr., ti ii...v.•.'1 ?P?)1'?'h yvfJ? r?.'t/NJ?/\..i?'?-? C r o _ r y'•U.t lJ (_)'.,:.. , :w?• ?? '.??' J I',111 ?U. r?`.U.LI. `I I y' ?l C b ,_'W ,,t>. F 0- . a,(,) dell TIAr, n l I':1) J (/fCGa C ? /•1 V - G2, ?', c%(di+-(JYcK1j -' C?r'?ln•. ? r . , lrL/ Ok 0 iv '? ) .p.??. , U V ?? ? ?-•(„?( - ??-yr-,... ..,-,r,,.r,,_ r "u.> _ .,Q.(lilt' T ?J O :0 O v L) l ?JI '..I '::,':..,?.ra•?, l <e :.c.• r I?UY.'Y.J7.?,1 ??l•U'C• I1 l*•n' A ?- ? f a I? r I r ??U7 ?- ,; ?j`- Q,,; ? "?,?-p jV `, ? J ? ? Y a • ` 0,1 .yL? ? ? k r'?-(.?Lt?? ? V V 40 n 3-Z,-`)c1 ??: uti. c?%,?-?C? ? -h r??'cw-? ?•rzk? ? ?Yr?-.' w, C? I'lz rio L.?eX? <(!"Jc7r,v? -I;?z ?31.?-4' ? FG'-2- G?? r? ??// I a S?G?? G?•'?/1?.? l? bZ:?r-t??' f " / d?? (av •t??? ?1 4.?s??t? : ?,t?ri:v?r pJwc'L .J ?IC d, ?)p=tGU??. CC.?-R'J4 ?Lr?t.I 11 M Q ? q 1 //n `, ' 7y I? ' -ut ),6L. Cam ? ?`?' ?• ice`? ?i G'<???? > tziV? A ? - r CZi'1 7 m.2 r7.,L,,C.I:L cL(S-PLvI. rytiwlva'1???? ,(,?• Ll /hkov?r°i 3?? l,1/7?1 ?C (zrr,ti? i e l p,+?? 1 ?I t v S( J? ` . V v ? r ev? l n AS, Ii ri C 67-6, .d ,r, ,_i ?'?.: i /(1 fir' f;.. A. (n•r ?1,1?-( ? 6^.-? f' `v_. ?j-V [-Q . [%??!-(.:'?'?!/,. r ;:-?.;.?n; ..?L ?.4';? /?.JJ?i!=?L.? ?? 9J ? ''?? j,??; )C. ?q-, / `y.tN G;? 7 0 rrF-r?1-?1?1 - ? l rl J'l.i. r1!<,?, r• ??U[9n? V? ?. vIC:LGJ-ycr U rs ?i?, Caw 7 C1,64c'e u.,' ye<i y?-7 •i ?i, (?/7//,`?1 V l? iV?i[.L9ir'Jr?p „vvYC. {.. •V 3?U2.- ?/1. Ll LJ"?^ti -C??? CNw-Wl ( /. . c?3 ? -._/ "\ • ?'7 ?zfi'?G v CG4 C. {?4:C L.7 Y ?i! i (,, c), C e on al ° 1>T (-Qz (Ale j?J c:Gt?K.r? br?• C?{ , ??l.?? ?; C'C ??!L: ? !Il.u' •ULl i? 1. ? (7?' /fI,UL? /?r-?? klV4 r, AFB ? Personal `? Problems ? Checklist'" ? for Adults John A. Schinka, Ph.D. ?> `? Y1 V n W Name Age Sex Marital Status ? Date 3 ` / 5 - 99 J DIRECTIONS O U On the following pages you will find a list of problems which people commonly face. This list surveys work, family, school, attitudes, and other problems of everyday life. Read the list carefully and make a check (rr) next to each problem that you are now having. Circle those problems which you feel are the worst or cause you the most trouble at this time. Remember that there are no correct or Incorrect answers. Do your best to answer each Item on the list as honestly as you can. EXAMPLE 43 ? having arguments on the job 44 _ working too many hours 45 _ job creating health problems ------------------------ If you are having problems which are not listed on the following pages, please write them on the bottom of the last page. Your answers will only be discussed with your doctor or counselor. P? Psychological Assessment Resources. Inc. A P.O Box 998 / Odesso. Floido 73556 / Telephone 1817) 968-3803 J COPYRIGHTC) 1984 by PSYCHOLOGICAL ASSESSMENT RESOURCES, INC. All rights reserved. Not to be reproduced In whole or In part by any process without written permission of Psychological Assessment Resources, Inc. 7 8 9 n AC= n n 0 Check all problems which trouble you. Circle the most Important. soc/tfi 1 _ not getting along with other people 2- being criticized by others 3- not fitting In with peers 4- feeling uncomfortable In social settings 5- acting rude or overbearing 6- acting In an Immature way 7 _ being suspicious of others 8 _ being shy 9 _ not having close friends 10 not having anyone to share Interests with 11 feeling lonely 12 being unpopular 13 being uncomfortable when talking to people 14 feeling Interior 15 feeling like people are against me 16 being embarrassed by family background 17 being let down by friends 18 feeling different from everyone else APP/12 being overweight 20_ being loo short or too tall having physical handicap - . O 22_ 6Tg faa-w n'._._. 23 looking too old 24 having unattractive face VOCI18 25 being clumsy and awkward 26 not being clean and well-groomed 27 not having suitable clothes 28__ being noticed for physical appearance 29 having scars 30 having facial blemishes L> ? (? not having a job • 32 job not paying enough 33_ disliking type of job 34 job being dirty 35 disliking fellow employees 36 being disliked by co-workers 1=.i 37. being afraid of failing on the job 38 being afraid of being fired or laid off 39 working in unsafe conditions 40 friends or relatives criticizing job 41 lacking supervision on job 42 boss being critical or unfair 43 having arguments on the job 44 working too many hours 45 job creating health problems 46 job having no future 47 needing more education to succeed In job 48 being bored on job FAMIHOMI34 49 children misbehaving 50 Jisagreeing.on how. to raise children _ (51;, , _ L d.or spouse having medical problem-=' ($ S,-chOd or spouse having emotional proble? 53 spouse hav m-wllh thugs or alcohol 54 having problems with In-laws v 55 having problems with parents 56 _ being separated or divorced from spouse 57 _ having constant arguments with spouse 58 parents being separated or divorced 59 parents constantly arguing 60 wanting to have children 61 not wanting to have a child or more children 62 parents being too strict 63_ parents Interfering with decisions 64 spouse having different Interests 65 spouse having different background 66 spouse being unfaithful 67 having sexual problems In marriage 68 not being understood by spouse 69 being unfaithful to spouse 70 having too much contact with relatives 71 _ spouse working too many hours on job 72 arguing with spouse over money 73 arguing with spouse over household chores 74 house or apartment being loo small 75 house or apartment needing repairs 76 having problems with landlord 77 not gelling along with neighbors 78 not having any privacy at home 79 not being able to afford living alone 80 living under unsanitary or dirty conditions 81 _ children leaving home 82 living in dangerous neighborhood Continue on next page ? n A* ? Check all problems which trouble you. Circle the most Important. n SCH/12 83 getting bad grades 89 not understanding class material 84 85 not getting along with teachers deciding on the right course of studies 90 _ not gelling along with other students ry 86 not having good study habits 91 92 _ feeling out of place In school feeling education is a waste of lime 87 not having a good place to study 93 having a language problem In school 88 taking the wrong courses 94 being in the wrong school FIN/12 95 _ budgeting money J,61 - depending on others for financial support 96 - 4Z? not making enough money t h i 102 lending money to friends or relatives _ no av ng a steady Income 103 not being able to pay medical bills 98 _ having to spend savings 104 - spouse being careless with money 99 _ having unpaid bills 105 not having enough money for education ?.? 100 wasting money 106 dealing with bill collectors REL/14 • 1107 feeling guilty about religion 114 not being able to get to church 108 not having any religious beliefs 115 feeling abandoned by God 109 arguing about religion 116 work Interfering with religious practices 110 being confused about religious beliefs 117 being upset by religious beliefs of others 111 _ not having good philosophy of life 118 worrying about being accepted by God 112 failing In religious beliefs 119 being rejected by church 1113 arguing with spouse about religion 120 failing to support church EMOT/20 anxious or 123 having the same thought over and over again 124 being tired and having no energy V (@- feeling depressed or sad 126 having trouble concentrating ?.1 2? not remembering Ih gs% 128 getting loo emotional 129 feeling guilty 13 worrying about diseases or Illness V 131 _ being afraid or hurting self 132 feeling things are unreal 133 crying without good reason 134 worrying about having a nervous breakdown 1 not being able to slop worrying J * - - 36_ not being abie lo rewx - 137 being unhappy all the time not having any enjoyment in life 139 being influenced by others 140 behaving In strange ways SEX/14 141 _ being uncomfortable with opposite sex 142 being afraid of sexual diseases V 143 having a sexual disease 144 being gay 145 worrying about sexual performance 146 not knowing enough about sex 11,17 not leaving someone to talk to about sex 148 having problems with sexual relationship 149 having unsatisfactory sexual relationship 150 thinking about sex too often 151 _ disliking sex 152 being Iroubled by sexual altitudes of others 153 being troubled by unusual sexual behavior 154 being sexually underdeveloped W Continue on next page ? /, , 06 Check all problems which trouble you. Circle the most Important. n LEOI10 (15 needing legal pdvlce 160 being legally disowned by family 15 - being sued 161 _ not receiving child support 157 not having retirement funds 162 not receiving alimony n 158_ being someone's guardian 163 having legal problem with neighbors 159_ being on parole 164 facing criminal charges HEAIHABI20 165 being physically hurt or abused ."1z5 having physical dlsabilil f?1 166_ losing temper and hurting someone 178,_, having chronic illness 167_ having thoughts-of. suicide 177 having recurring health problems having a car accident C 7 :)- having many health problems _ 169 being eftacked by an animal 179 being unhappy with medical care Smoking too many cigarettes, ' LSZfD -<Z 180 watching loo much television 171- - using drugs Ur -alcahbl- - 161 not having any hobbles q Gf72 _ not getting enough exercise 182 needing a vacation having poor sleeping habits 183 having poor eating habits eating too much 184 not making lime for leisure activities ATTI12 q having a poor attitude about everything 191 _ not understanding attitudes of others 188_ not having any Interest In things 192 having problems with attitudes about religion 187_ having a recent change In attitude 193 having problems with opinions about politics 188 holding opinions too strongly 194 _ having a poor attitude toward work 189_ having no opinions about anything 195 having a poor altitude toward family 190 having different opinions than others 1C?6. j_ having a poor altitude toward self CRIS/12 V v v 197_ friend or family member committing suicide QZ -- friend or family member having serious illness , friend or family member gelling a divorce ?6? 0? friend or family member dying 201 _ pet dying 202 losing something valuable 203 friend or family member attempting suicide 204_ friend or family member losing lob ?2II5?_ friend or family member being emotionally upset 206being robbed 207 child running away from home 208 losing job List any other problems you might have. v 0 0 0 0 0 0 U G q? u HARTMAN REHBILITATION ASSOCIATES Stuart A. Hartman, D.O. 2645 North 3'° Suite 490 street n Harrisburg, PA 17110 717-232-7246 FAX: 717-236-5408 INITIAL EVALUATION RE: Sharon Hawbaker SS #: 187-42-8381 DOI: 4/11/98 Ms. Hawbaker was seen for a physiatric pain management evaluation on 7/18/2000, at my Harrisburg office. She is complaining of pain all over. She denies any previous problems and states that her problems started on 4/11/98 when she was a passenger in a car that was stopped and they were rear-ended. She denied loss of consciousness but was sore but her main pain started about four to five days after the accident. She was at work and had more pain and started dropping things and started taking Advil and gradually got worse. She saw her family doctor, Dr. Bruaw, who x-rayed her and she was told they were unremarkable and then the pain got worse. She was treated with medications. She was sent for physical therapy and got worse and then tried Voltaren. She was then referred to Dr. Hallock. He saw her in June or July of 1998 and she was having a lot of neck and shoulder pain at that time and spasms, which got worse and Dr. Hallock referred her to Dr. DeFalcis. He did some trigger point injections and continued therapy and then she got worse with pain in the neck and shoulders and low back. She was referred again for therapy and she had some work hardening at Health South on two occasions and this only seemed to G make her worse. Except for returning to work in June of 1998, she has been off work since that time. She was employed as a hairdresser/barber/stylist. Her symptoms in the lower extremities come and go but recently they have been worse since the winter. Last summer, she tried to increase her activity more but now is feeling more fatigued. She feels a pulling v sensation when she tries to walk. Since last fall and winter, she has had a lot more symptoms. It is primarily in the low back and hip girdles. She sleeps terribly and is restless. A good night, she is only up two times and on a bad night she is up four times or more. She does take hot showers or soaks in a tub and this helps. She uses the Theracane, which helps a little bit. She occasionally gets some numbness or tingling in the arms and hands and this comes and goes. She occasionally gets a headache but these are v not bad. She had an MRI of the cervical spine and x-rays, which showed some mild degenerative changes primarily at the C4-5 and C5-6 levels. She does have hypertension. She had teeth pulled and had her tubes tied. u After the accident, she was smoking two packs a day and now is down to one pack a day. She does not drink and drinks one to two cups of coffee in the morning. She is off work as noted above. She has been on numerous medications all with side effects and they did not help and she gained weight u with Elavil. She is now on Prinivil 5 mg p.o. daily, Voltaren 100 mg daily, Hydrocodone 51500 and she only takes five to ten on a bad week but she tries to take as few as possible. She takes Flexeril as needed. She denies any allergies. When she is riding in the car, she has to take Xanax 0.25 mg for her anxiety with riding. V INITIAL EVALUATION RE: Sharon Hawbaker Page 2 M July 18, 2000 Her physical examination reveals a pleasant, cooperative, alert and oriented 48-year-old female. She is right handed. Her cervical, thoracic and lumbar curves were normal. Her cervical spine range of motion was functional with a slight decrease and she complained of pulling. 'Upper and lower extremity range n were normal. Her lumbosacral flexion was to 80 degrees. Her reflexes were equal and s ymmetrical in the upper and lower extremities and her sensation was intact. Her strength was essentially normal to normal minus in the upper and lower extremities. She was tender at all myofascial tender points and generally tender at the neck and shoulders and low back and hip girdles. She had a lot of tightness. Her gait was normal. r+ Ms. Hawbaker is suffering from a post-traumatic cervicothoracic and lumbosacral strain with a post. traumatic fibromyalgia syndrome with a post reactive depression as a result of her motor vehicle accident related injuries. We had a discussion about a pain management program and I think she is a good candidate but she is not driving and so this could be difficulty in getting her to the program. I am starting her on Effexor XR 37.5 mg at bedtime at supper to increase to 75 mg after two weeks. I also suggested 5-Hydroxytritiphan for sleep. I feel that she would be a good candidate for the Rehab Options Pain Management Program to help her improve her function, strength and endurance and possibly even get her back to some part-time work. Her husband seemed quite agreeable but she was not too sure about the program. They will discuss it and I will see her for follow-up in two months time. She will call with any problems and be seen sooner if needed. Stuart A. Hartman, D.O. SAH/tld u cc: David L. Lutz, Esquire, 4503 N. Front St., Harrisburg, PA 17110-1708 M V W • • • • • • W • Q s 'a a n i 2418 NORTH SECOND STREET HARRISBURG, PENNSYLVANIA 17110 TELEPHONE (717) 2337779 PAUL A. ANDERSON, D.Ed. ON 0 Q 0 0 VOCATIONAL EVALUATION REPORT To: David Lutz, Esquire Law Offices of Angino and Rovner 4503 North Front Street Harrisburg, PA 17403 Phone: (717) 238-6791 Fax: (717) 238-5610 Re: Sharon Hawbaker 124 Woods Dr., Lot 10 Mechanicsburg, PA 17055 DOB: 3/15/52 AGE: 47 SSN: 187-42.8381 Phone: (717) 795-9286 W December 27, 1999 W TABLE OF CONTENTS Page Introduction . . . . . . . . . . . . . . . . . . . . . . . . . 1 Review of Records and Reports 1 Specific Test Administered . . . . . . . . . . . . . . . . . . 1 Background . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 Significant Vocational and Medical Findings . . . . . . . . . 2-3 Diagnostic Interview . . . . . . . . . . . . . . . . . . . . 3-4 Vocational Background . . . . . . . . . . . . . . . . . . . . 9-5 q Educational Background . . . . . . . . . . . . . . . . . . . . 5 Preinjury/Postinjury Vocational Aspirations . . . . . . . . . . 5 Specific Tests Results . . . . . . . . . . . . . . . . . . . . 5 O Definition of Strength Factors . . . . . . . . . . . . . . . 7-8 Vocational Implications . . . . . . . . . . . . . . . . . . . 8-9 Economic Implications . . . . . . . . . . . . . . . . . . . 9-11 V Summary . . . . . . . . . . . . . . . 11-12 0 V = to n Vocational Evaluation Report Re: Sharon Hawbaker December 27, 1999 Page 1 INTRODUCTION f3 A vocational evaluation of Mrs. Sharon Hawbaker was conducted in the offices of Anderson Associates Psychology and Consulting on 12/27/99. The assessment consisted of a records review, a diagnos- tic interview and the administration of vocational tests which measured educational achievement and vocational interest and aptitude. The purpose of this evaluation was to evaluate Mrs. Hawbaker to assign economic consideration to any diminution of her vocational potential in light of injuries she sustained. REVIEW OF RECORDS AND REPORTS FROM A 1. Donald Bruaw, D.O. 2. Richard Hallock, M.D.Family and Community Health Associates, 3. Daniel DeFalcis, M.D. 4. Pauline Wallin, Ph.D.(Psychologist) 5. McCuen and Associates Physical Therapy 6. Health South Rehabilitation Center of Mechanicsburg 7. Various diagnostic and treatment records. 8. Cynthia Heinl (Employer) 9. Mrs. Hawbaker's appointment book 10. Federal government W-2 Forms for the years 1993 through 1998. a SPECIFIC TESTS ADMINISTERED 1. Jastak Wide Range Achievement Test-3 2. U.S. Department of Labor Occupational Check List 3. Minnesota Clerical Test 4. Purdue Pegboard Test v BACKGROUND On 4/11/98 Mrs. Hawbaker was injured in a motor vehicle accident. On that date she was a passenger in a vehicle operated by her daughter, Renee, outside of Enola, PA, in Cumberland County. The vehicle in which Mrs. Hawbaker was traveling was at a stop, in preparation for a left turn when it was rear-ended. Following the accident, Mrs. Hawbaker experienced neck discomfort, as well as pain involving her shoulders. Later, her lower back area became involved as well. Mrs. Hawbaker treated with a number of different physicians with respect to her condition, including those enumer- ated above in the review of medical records. She was given several diagnoses which included degenerative disc disease of the cervical spine aggravated by automobile accident, low back pain with right V n Vocational Evaluation Report n, Re: Sharon Hawbaker December 27, 1999 lower extremity radiculopathy, cervical facet dysfunction, myofascial pain, chronic pain syndrome, as well as diagnoses relating to associated emotional problems. Mrs. Hawbaker's treatment regime included conservative treatments, such as medication, provision of physical therapy and work hardening with the physical therapy taking place in the spring of 1998 and again in late summer and early fall of 1998. It lasted for a period of approximately two months. With respect to the work hardening, this lasted about one month and took place in the fall of 1998. At the time of this evaluation, Mrs. Hawbaker continues to experience pain and dysfunction, including intermittent numbness and tingling of her neck and high shoulder area with involvement in both arms and hands. The numbness and tingling is especially predominant in the right upper extremity. Her pain and discomfort is worsened with activities, especially those involving reaching, pushing, pulling, and those that are over-head or shoulder-height. With respect to her lower back, she states that the pain and discomfort she experiences is intermittent, whereas the cervical area pain is more constant. She states that, with respect to her lower back, this tightens up especially if the symptoms in her upper back become worse. With respect to prior history of injury or trauma to her cervical lower neck or upper extremities, or her low back, Mrs. Hawbaker indicates that there is no prior history of pain or discomfort in either area. In fact, she indicates she never received medical treatment for upper neck or lower back problems prior to the injuries that she sustained on 9/11/98. SIGNIFICANT VOCATIONAL AND MEDICAL FINDINGS 1. In a report dated 5/25/99 of Daniel C. De Falcis, a specialist in physiatric medicine, notes the following: "[She] demon- strates the ability to tolerate light duty; however, she has difficulty with overhead [activities] and [her] shoulders at 90 degrees flexion or abduction, secondary to pain. Given that she has been out of work since greater than a year, her likelihood of returning to work is less than 50%, although I feel that she should be able to return to some sort of gainful employment in the future, if she is willing." 2. Pauline Wallin, Ph.D.(psychologist), also noted in her report on 6/8/99 that, in light of her being accustomed to working with her hands, which she notes is currently impossible, Mrs. Hawbaker will have a troublesome vocational adjustment, as she must learn a new job in an area of light work where she would not have to use her arms. to Vocational Evaluation Report A Re: Sharon Hawbaker December 27, 1999 3. According to Mrs. Hawbaker's U.S. W-2 Wage and Tax Statements, her wages were as follows: Year Earnings 1999 $19,332 1995 $19,909 1996 $15,398 1997 $17,039* 0 1998 $ 5,397** * Updated to $18,618 in year 2000 dollars. ** Year of injury. DIAGNOSTIC INTERVIEW Q Mrs. Hawbaker lives in the community of Mechanicsburg, Cumberland County, PA, with her husband. She stands 5 feet 9 inches tall and weighs approximately 185 pounds. Her weight at the time of the accident was approximately 165 pounds, and she relates this increase to a more inactive lifestyle. She also notes an effort to O lose weight, in which she has had some success, but considers it an "ongoing battle." She occasionally repositioned herself during the evaluation. She was neatly and casually attired, appropriate for the evaluation. No abnormality of Mrs. Hawbaker's senses of vision, hearing, smell, taste or balance was noted. With respect to the sense of touch, she experiences, on a daily basis, some numbness in her right hand, which worsens with activity. Bowel and bladder functions are reported to be normal. Mrs. Hawbaker is right-hand dominant. Use of her upper extremities is reported as abnormal. She notes frequent dropping of items, having less strength in her hands than she had previously, and an overwhelming tiredness of her upper extremities. Gait was observed to be normal. She does not use any artificial appliances or bracing. She did try using a TENS unit for a period of approximately one month and found it to be somewhat helpful. With respect to medications, Mrs. Hawbaker uses the prescribed medications, Voltaren and Vicodin, as well as a prescribed muscle relaxant. She also uses over-the-counter Advil to u help control pain. Her appetite is reported as "good," while her sleep is reported as "poor." When asked about this, she states that she takes awhile to get to sleep, then awakens, repeating this throughout the night. When asked whether this was a new develop- ment, she states that she never was a particularly good sleeper, but because of her pain and discomfort in her shoulders and lower W back, she finds it difficult to find a comfortable position in which to sleep. Libido is reported as post-traumatically depressed. to Vocational Evaluation Report n Re: Sharon Hawbaker December 27, 1999 Mental health was reported as good, notwithstanding a change in her mood since the injury she sustained on 4/11/98. When asked about this, she notes that she becomes frustrated by her limitations, her n mood is more labile, and she is more pessimistic and anxious about her future than she had been previously. She has not, in the past, received psychiatric treatment other than with Dr. Wallin since the injury she sustained on 4/11/98. She was treating with Dr. Wallin with respect to a driving phobia which was secondary to the motor vehicle accident. She has been taking the psychotropic medication, Xanax, or Alprazolam to help in this regard. JOB AT TIME OF INJURY At the time of her injuries on 9/11/98, Mrs. Hawbaker was ?C functioning as a barber/stylist in Cynthia Heinl's beauty salon. She had been performing this work for approximately 9 years at the time she sustained her injuries. She stated that she enjoyed this work a great deal, especially those facets involving client interaction and working with her hands. She stated that she had aspirations of being a hairdresser since early childhood, and was V finally able to realize them with the taking of a course at The Hairstyling Institute located in Camp Hill, PA in 1986 and 1987. Following the injuries of 4/11/98, she returned to work for about 8 days, working in pain, in an attempt to work through it. Mrs. Hawbaker indicates that she very rarely, if ever, missed a work day while working as a hair stylist. When she did return she was taking i? pain control medication to enable her to continue working. After approximately seven days on the job, when she could no longer endure and ceased working. Hair-dressing is classified as "light" vocational activity by U.S. Department of Labor standards, but does entail constant use of the hands in an extended fashion while holding hair dryers, electric shears, scissors, as well as fast and constant manipulation of the hands. Hence, it is considered an upper-extremity manipulative-intensive occupation. Since ceasing work in April of 1998, she has not returned to work, although she did make another attempt to return to work in June of 1998, while under the care of Dr. Hallock. After performing one perm, she found her symptoms recurring, and again, had to cease working. VOCATIONAL BACKGROUND As noted above, Mrs. Hawbaker had been employed at The New You W Hairstyling Salon as a hairdresser. This was a light duty position which required her to stand throughout the work shift. Lifting was to 20 pounds or less, but her hands were required to be extended throughout the work shift requiring constant handling, fingering r O'N Vocational Evaluation Report n Re: Sharon Hawbaker December 27, 1999 and reaching. In addition to working at the hair salon, Mrs. Hawbaker worked in a full-time position as a donut maker in a donut shop from 1985 to 1986. 'n EDUCATIONAL BACKGROUND Mrs. Hawbaker attended Cambria Heights High School, to the ninth grade. She was a significantly below average student at that time. She indicated that she was recommended for special assistance in school, but her father resisted. She also indicates that she was never particularly academically oriented. However, Mrs. Hawbaker was able to complete a General Education Development diploma in 1982. Additionally, in 1988, Mrs. Hawbaker completed a certificate for a barber's license at the Barber Styling Institute in Camp O Hill, Pa. PREINJURY/POSTINJURY VOCATIONAL ASPIRATIONS Prior to the motor vehicle accident, Mrs. Hawbaker states that her career aspiration was to remain in the hair dressing field with her O current employer. Postinjury, she states that her career aspira- tions are confused and uncertain. She indicates that she might be able to be a receptionist in the hair dressing field, on a part- time basis (10 hours/week) for her former employer. other career occupations that would be less intensive with respect to using her C hands or, head and neck, would be information clerk, receptionist, and surveillance system monitor. The receptionist and information clerk would have to be in fields where typing would not be a critical component. Wages associated with these positions would be around minimum wage, which is $5.15/hr, up to as much as $6.50/hr, for someone having Mrs. Hawbaker's vocational profile. This j averages to $5.85/hr or $12, 116 on an annual basis, whereas as a hair dresser in 1997, she was able to earn as much as $17,039. PERSONAL EFFECTS OF INJURY Reported Preinjury Activities _Reported Postinjury Activities Interaction w/ grandson, shopping, All of these activities are now driving, yard work restricted. Heavier house chores such as All of these activities are Vacuuming, over-head painting, precluded. Wallpapering, and general house- hold repairs Vocational Evaluation Report Re: Sharon Hawbaker December 27, 1999 SPECIFIC TEST RESULTS The Jastak Wide Range Achievement Test-Revision 3 (WRAT3) was administered because of the range of grades and abilities which it encompasses. Mrs. Hawbaker received the following scores on this test: n n On the WRAT3, Mrs. Hawbaker revealed deficiencies in all academic skill areas. She was able to correctly spell words such as "must" and "light," but missed those such as "enter" and "circle." She was able to recognize words such as y "horizon" and "triumph," but missed those such as "municipal" and "alcove." With respect to math, she was able to correctly solve simple addition, subtraction, multiplication and simple division problems, but missed those involving complex divi- sion, fractions, percentages and algebra. u Through the administration of the U.S. Department of Labor's Interest Check List, Mrs. Hawbaker's highest levels of vocational interest were found to exist in these areas: 1. Create artistic designs. 2. Play a musical instrument. v 3. Paint or do paper-hanging in houses or buildings. On the Minnesota Clerical Test, Mrs. Hawbaker's score on the Number Comparison Test fell at the 5th percentile, indicating significantly below average aptitude for simple, rapidly paced clerical tasks. v The norms of bank tellers were used for comparison. The Purdue Pegboard Test measures dexterity for two types of activity: one involving movements of the hands, fingers and arms, and the other involving primarily what might be called "fingertips" dexterity. When compared to norms of industrial applicants, test results indicate that for the right hand, Mrs. Hawbaker's gross manual dexterity is at the 171h percentile, and for the left hand, it is at the 15`h percentile. Bimanual coordination is at the 81h percentile, and fine finger dexterity is at the 32nd percentile. v n Vocational Evaluation Report n Re: Sharon Hawbaker Decembor 27, 1999 These are primarily below average results. „i DEFINITION OF STRENGTH FACTORS .% According to the Dictionary of Occupational Titles, Fourth Edition, Revised, 1991, published by the U.S. Department of Labor, Employ- ment and Training Administration, the following are descriptions of the five terms in which the Strength Factor is expressed: "Sedentary Work - Exerting up to 10 pounds of force occasionally (Occasionally: activity or condition exists up to 1/3 of the time) and/or a negligible amount of force frequently (Frequently: activity or condition exists from 1/3 to 2/3 of the time) to lift, carry, push, pull, or otherwise move objects, including the human body. Sedentary work involves sitting most of the time, but may involve walking or standing for brief periods of time. Jobs are sedentary if walking and standing are required only occasionally and all other sedentary criteria are met. Light Work - Exerting up to 20 pounds of force occasionally i (Occasionally: activity or condition exists up to 1/3 of the time), and/or up to 10 pounds of force frequently (Frequently: activity or condition exists from 1/3 to 2/3 of the time), and/or a negligible amount of force constantly (Constantly: activity or condition that exists 2/3 or more of the time) to move objects. Physical demand requirements are in excess of those for Sedentary Work. Even though the weight lifted may be only a negligible amount, a job should be rated Light Work: (1) when it requires walking or standing to a significant degree; or (2) when it requires sitting most of the time but entails pushing and/or pulling of arm or leg controls; and/or (3) when the job requires working at a production rate pace entailing the constant pushing and/or pulling of materials even though the weight of those materials is negligible. NOTE: The constant stress and strain of maintaining a production rate pace, especially in an industrial setting, can be and is physically demanding of a worker even though the amount of force exerted is negligible. w Medium Work - Exerting 20 to 50 pounds of force occasionally (Occasionally: activity or condition exists up to 1/3 of the time), and/or 10 to 25 pounds of force frequently (Frequently: activity or condition exists from 1/3 to 2/3 of the time), and/or greater than negligible up to 10 pounds of force constantly (Constantly: activity or condition that exists 2/3 or more of the time) to move objects. Physical demand requirements are in excess of those for Light Work. V n Vocational Evaluation Report Re: Sharon Hawbaker December 27, 1999 Heavy Work - Exerting 50 to 100 pounds of force occasionally (Occasionally: activity or condition exists up to 1/3 of the time), and/or 25 to 50 pounds of force frequently (Frequently: activity or condition exists from 1/3 to 2/3 of the time), and/or 10 to 20 pounds of force constantly (Constantly: activity or condition that exists 2/3 or more of the time) to move objects. Physical demand requirements are in excess of those for Medium Work. n Very Heavy Work - Exerting in excess of 100 pounds of force occasionally (Occasionally: activity or condition exists up to 1/3 of the time), and/or in excess of 50 pounds of force frequently (Frequently: activity or condition exists from 1/3 to 2/3 of the time), and/or in excess of 20 pounds of force constantly (Constant- ly: activity or condition that exists 2/3 or more of the time) to move objects. Physical demand requirements are in excess of those for Heavy Work." VOCATIONAL IMPLICATIONS 0 1. Mrs. Hawbaker is a 47 year old female who has a vocational history of performing as a barber/stylist in the hair dressing field. Vocational testing and review of educational and vocational backgrounds identify an individual well suited to participate in this occupation, prior to injury. However, C) subsequent to the injuries that she sustained on 4/11/98, and in association with medical advice, she is no longer able to participate fully in this field. Hence, Mrs. Hawbaker's labor market access is now classified as restricted. 2. Mrs. Hawbaker does retain the capacity to perform work in other less physically demanding areas, including the following positions: information clerk, receptionist, or surveillance system monitor. Unfortunately, in these positions, she would not be able to use her acquired and learned job skills. Hence, her wage potential would be less than or around $13,239. 2. When Mrs. Hawbaker looks for work, as permitted, she can expect to confront a negative employer attitude. She now has a history of disability and work absences since injury. Employer resistance is well documented in the rehabilitation literature. U.S. Census data reveals the vocational disadvan- tages faced by disabled individuals in comparison to their nondisabled counterparts as follows: to n Vocational Evaluation Report Re: Sharon Hawbaker December 27, 1999 FEMALES AGED 45 TO 54 YEARS WITH A WORK WITH NO WORK DISABILITY DISABILITY A. Unemployment Rate (1986) 13.0 6 2.8 6 B. Mean Earnings (1987) $16,380 $20,022 n C. Percent of Workers Covered 40.16 52.68 by Employer-Provided Health Insurance (1987) (Males/Females Aged 25 to 64 Years) (Source: Current Population Reports, Special Studies, Series P-23, No. p 160, U.S. Department of Commerce, Bureau of the Census, July, 1989 4. In The New Worklife Expectancv Tables for Disabled and Non- disabled Persons by Sex and Level of Educational Attainment, developed by Anthony M. Gamboa, Jr., Ph.D. and published in U 1998, the worklife expectancy of a 47 year old female (of all races) who has completed 9 years of education, is for an additional 9.7 years for the nondisabled worker, yet only an additional 5.4 years for the disabled worker. The worklife expectancy tables were developed through the use of government data collected on disabled and nondisabled persons during the 0 1982, 1988 and 1997 Current Population Survey (CPS). They are an update of the first worklife expectancy tables for persons meeting the definition of disability. Dr. Gamboa developed the tables using raw data supplied by the U.S. Department of Commerce, Bureau of the Census, and the U.S. Department of Health and Human Services, Public Health Service. W ECONOMIC IMPLICATIONS 1. Mrs. Hawbaker is 47 years of age. According to data presented y by the U.S. Department of Labor, Bureau of Labor Statistics in Bulletin 2254, Worklife Estimates: Effects of Race and Education, she normally could expect a life expectancy to the age of 80.4 (rounded to 80), and a worklife expectancy to the age of 56.7 (rounded to 57). This reflects time spent both in and out of the workforce during her worklife. However, v according to the U.S. Department of Health and Human Services, Social Security Administration in SSA Publication No. 05- 10035, January 1992, the "full retirement age" for individuals born in 19 is 67. 0 n Vocational Evaluation Report n Re: Sharon Hawbaker December 27, 1999 10 2. It is a fact that loss of capability to work results in loss of capability to earn a living. With this in mind, a model will be presented to depict Mrs. Hawbaker's past loss of earnings, while two models will be presented to depict her diminution of earnings capacity. Every individual, given his or her innate mental and physical abilities as well as educa- tional and work backgrounds, or absence thereof, has an inherent and/or acquired ability to earn wages. This is the n specific "economic horizon" of a given individual. When a loss of physical and/or mental capability following injury has/have an adverse effect on employability and when there is an associated permanence of injury, the required criteria that establish a foreshortening of economic horizons have been met. The capacity to earn is a concept that is quite distinct and 4 different from the concept of income realization. To estab- lish Mrs. Hawbaker's shortened economic horizons, several models will be provided because a future loss cannot be predicted with 1008 certainty. With the use of several models, a forecast of loss of earnings potential can be presented with the reasonable likelihood of Mrs. Hawbaker's falling between the extremes of the range. 3. Past loss of earnings will be calculated from 4/11/98 to the present at the level of her projected 1997 earnings of $18,618, annually or $1,552, monthly. PAST LOSS OF EARNINGS $1,552 x 20 months = $31,040 The first projection of Mrs. Hawbaker loss of earnings potential will compare her preinjury earnings potential of $ 18,618 per year, to her postinjury earnings potential of $13,239 (both figures adjusted to present-day value consistent with U.S. Department of Labor standards), as outlined above. It is likely that she will have to work with restrictions all of her worklife. These restrictions may include taking breaks from work activity and limits the types of work which she can now perform because of limitations. Her worklife will be calculated from her present age, 47 to the age of 57, in keeping with U.S. Department of Labor worklife data, or for additional 10 years. u LOSS OF EARNINGS POTENTIAL Preinjury Earnings Potential A Vocational Evaluation Report Re: Sharon Hawbaker December 27, 1999 11 $18,618 X 10 years = $186,180 ^ 2% Productivity Factor = $ 17,681 PREINJURY SUBTOTAL = $ 203,861 Postinjury Earnings Potential $13,239 X 10 years = $132,390 2% Productivity Factor = $ 12,573 TOTAL LOSS OF EARNINGS POTENTIAL = $ $58,898 S7 4. A second projection of Mrs. Hawbaker's loss of earnings potential will utilize the same income figures as above. Worklife will be calculated in keeping wi th Social Security Administration requirements for full retirement age to age 66, or for an additional 19 years. LOSS OF EARNINGS POTENTIAL $18,618 X 19 years = $ 353,742 2% Productivity Factor = $ 71,504 PREINJURY SUBTOTAL = $ 425,246 Postinjury Earnings Potential $13,239 X 20 years = $ 251,541 2% Productivity Factor = $ 50,845 POSTINJURY SUBTOTAL = $ 302,386 TOTAL LOSS OF EARNINGS POTENTIAL, _ $ 122,860 SUMMARY u Mrs. Hawbaker's is a 47 year old female who was injured on 4/11/98 in a motor vehicle accident. The injuries and associated limita- tions have resulted in a significant curtailment of her vocational outlook. Prior to her injury, Mrs. Hawbaker had a successful career as a hair dresser with The New You Hair Salon for nine years. v Although Mrs. Hawbaker's vocational goals are now unclear, and her pre- and postinjury career goals are different, as she is no longer able to work in this field. There is the strong likelihood that her performance in any career will be adversely affected, as earlier 10 Vocational Evaluation Report !^ Re: Sharon Hawbaker December 27, 1999 12 1 detailed. Given her vocational profile, her alternative career choices would be in areas with less remuneration, such as a non- typing receptionist, information clerk or surveillance system monitor, where earnings would range from $5.15 to $6.50 per hour, averaging $5.85 per hour or $13,239 annually. A forced career choice into one of these or a similar area would result in diminished earnings comparable to the first projection above. This report depicts projections of Mrs. Hawbaker's past loss of earnings as well as her loss of earnings potential. Her past loss of earnings total $31,090. Her economic horizons have been foreshortened, and this foreshortening has been estimated to range between $58,898 and $122,860 depending on the criteria used. Averaged and rounded the anticipated economic impact of the accident, in my opinion, is $90,879. When added to the past loss of earnings the total economic impact of the accident is $121,919. If you have any questions, please advise. Sincerely, f o X4 A.,' Paul A. Anderson, D.Ed. Psychologist PAA/rbf V k_J v L • • • • 7 0 0 MdKUEW fi ASSOCIATES PHYSICALRAPY SPINAL EVALUATION n I n Q Pain Scale No Pain Worst Pain 4, Where did pain start? nee /e Wheze aid it spread? L13r7S. Nature L Constant- Intermittent Increasing Static Decreasing %j Aggravates Teases + ,. ?L va..-a.C l I v Rate Pain. Night AM (ems Afternoon i o?sc? Evening Bed/Pillow/Position t(o_ y 7i ra L `°1= '.S BR RL BF R12 d ? Bowel/Bladder Cough/Sneeze I I I SBL Comments: Nervous; Irritable; V Anxious; hostile; Current Historv: '.clavan Past History & Treatmer.}: Radiological: (Date): Paresthesia/and other symptoms: Headache no e nun,,' Gait orma ; Guarded; List: L, R; Limp L, to and from chair guarded Sitting Attitude: orm ; Protected; • on R, L Ischium; Moves constantly. Active Movements: Restricted; Blocked'' Pain/Restricted X Hypermobile e,/ SBR RL BB Patient -' Asa '0y--N _DX: tf?-T rn Age L , worr,/Status /.i, . S = j, Date Date of onset - ?°' " ? l Zx g f _ 4-11-7F- ?T?T va ? Play__ n Neurological: lipt, SLR: L R a - Cx Flexion Dorsi Flexion Reflexes: A L3-4 Knee JK L R S1 Ankle JK L R C5-6 Biceps JK L R C7 Triceps JK L R C5-6 Brac Red L R A Sensation Sacroiliac: Standing: PSIS L R ASIS L R Sitting: PSIS L_R_ ASIS L_R_- Leg Length: Supine Long Sitting Compression Distraction ROM:__ W ?L?? ?iF -- 0 Palpatior.ft ?'IIII -7- - e- f a? J-1- -7- 1111 =s,,,lill I ? GIVT`? A r KEY: X Tender ® Centre Pain Pain Referen ' Hypomobile rM Hypermobile. Spasm ------------- --------- M Posture w -? ? ? ,Zw 'L t I r ;nccommenaatlons: Discharge/Long Term Goals yr.r. uiagnosis: C_• Frequency 3x I ?,. k Duration Y-16 c @PhysicalTherapist Signature. ,6-,,,Iwg J ov v f? Date MCCU= MCCUEN & ASSOCIATE'S PIIYSICAL THERAPY 4905 LAST '1'R1 NDLE ROAD MECIIANICSBURG, PA 17055 717-761-4999 m PATIENT:-Shahav, f?cV,. P.T. DIAGNOSSGNOSI PHYSICIAN: DATE OP INITIAL EVAL: ATTENDANCE RECORD: -LiQ ?NO SHOWS PROGRESS REPORT DA'Z'E: 1 SITS n 0 C) v v v CELLATIONS P.T. SIGNATURE (Q?O?n? t.D.rT V - r eu Pwn< S4 9+ qk ae 1 ro+a d,'o ?, a`a G,p,u b a cl2 c ufo SCE oh Q, 9S"! Po;.,to 4„k QocCL{ d (.cc :44 Pos,Lwoq- • said ,44;4? *Ct" .??? 1"" 4`u'Q '?n •?2. ?,?q?n 0-? ° f Zkae c- ckl`cwo n d&, l,--Lka?A".pp wn-Kw `P? QLA. # P ' - 7'ti" na'uz°> Lo PATiENT NAME DATE DESCRIPTION/DAILY NOTES y-zs -s s TE ?? C . ?z.. r- , l (2 SIGNATURE - L . _ .,/ A • I '? -d?r4.? A y? 1'1w4.. Grm. ? a i.t A ?? ICT. /Qe w d Y ? t „Ce-? Ti e ti to L- . 5 a - r A. f A A PROGRESS RRPolel' DATE: 9/21/98 A PATIENT: Sharon Hawbaker PHYSICAL THERAPY DIAGNOSIS: Cervical PHYSICIAN: Daniel Delfalcis. MD DATE OF INITIAL EVALUATION: 8/21/93 ATTENDANCE RECORD: 12 VISITS 0 4 ('I. -f Facet Dysfunction. DDD CANCELLATIONS 0 NO SHOWS A TREATMENT PLAN (CURRENT): Myofascial release. 'TENS, scalene stretching, head retractions, lying spine with a rolled towel between Lhe scapulae. lower trapezius stabilization exercises. SUBJECTIVC: Patient continues to complain or burning in the neck and right arm but it is less frequent than initially. When she uses her TENS unit. A helps to alleviate the burning bu't she said that it has not been bad enough since 4/9/98 for her to use the TENS unit. At worst her pain is now an 8/10 on the pain scale and at best 5110. She continues to complain of a feeling of heaviness in her right arm whenever she holds her arm up to do anything. She tried to do a few arm circles the other day and after only a few reps her arm burned and felt really heavy. OBJECTIVE: Cervical ROM: right sidebending, 45c no pain: Jeft sidehendinle. 401) with a feeling of tightness in the right side of the neck; right rotation. 731wiLh pain on the right around C5, C6; left rotation, 7511 with no pairs, flexion. 551) with pain and burning between scapulae; extension. 6511 with no pain. If patient sits very straight when she extends her neck. she does not have pain but if she slouches at all, a sharp pain shoots into the area around T2 and TJ and then 44 radiates down between the scapulae. ' Head retractions cause some pain around CS and C6 but when she stops them, the pain does not linger. Sensation: This is variable, on 9/17/98 she reported decreased sensation on the right in the anterior and posterior forearm, the palm of the hand, and the thumb. With palpation she is tender in the left scalene more so than the right. the intrascapular area. and the right paracervical muscles. The right levator rr scapulae was not tender on 9/17/98. Shoulder, elbow, and wrist strength is WNL. FUNCTIONAL STATUS/LIMITATIONS: Patient still cannot do anything that requires her to hold her arms up for. any period of time. NEW GOALS: Decrease pain to 6/10 at worst: full rotation to the right without pain. TREATMENT PLAN/RECOMMENDATIONS: Spray and stretch to the scalenes. initiate more self stretch exercises. invofascial Pfp CP M McCuen & Associates Physical Therapy, pC. • 240 Grandview Avenue, Buts 1o1, Camp Hill, PA 17011A7171 737-9818/8170 Adams Done, Suite 101, Hummalstown, PA 1703BA717156&e006 1790 Old 141 Road, Suite F, Etters, PA 17319/171719380584/4905 E. Trindia Road, Machii icabury. PA 17055/(7171761-0939 FAX 737.2818 n 0 Page 2 RE: Sluu'on lluwbaker PROJECTED DISCHARGE TN ? If you concur with the treatment plan Outlined above + new prescription to bring to our Country Meadows off cee onvherin xttivisit. Thank you. Sincerely, r9 n-plZa O`GzQ Debra Latsha, G 0 0 Q r 0 A 0% n MCCUEN & ASSOCIATES PHYSICAL THERAPY 4905 EAST TRINDLE ROAD PATIENT P.T. DI. PHYSICIAN: DATE OF INITIAL EVA ATTENDANCE RECORD: NO SHOWS PLAN (CURRENT h 11 I:l FUN Ili V . V ONAL STATUS/LIMITATIOA )ALS: ? nn,,, 1. S . -- -- D DISCHARGE DAYS/WEEKS i' 11 . 'P.T. SIGNATURE *****IF YOU CONCUR WITH THE TREATMENT PLAN OUTLINED ABOVE, PLEASE GIVE THIS PATIENT A NEW PRESCRIPTION TO BRING TO OUR OFFICE ON HIS NEXT :VISIT. THANK YOU.. • McCuen & Aeeociatea'Physicel Therapy, P.C. 205 OrerxMm Am, Suite 211, Camp H8, PA 1701147171 737.881813170 Adams Drive, Suite 101, Hu elemwn, PA 17038/(717) 588.8008 1780 Old Tna Flood, Eden, PA 173134717) 8330584/4305 E TAr4e Fbed. MedWhahuy, PA 17055/(717) 7a1.4838 PAX 7a7.eela - ?_CANCELLATIONS n r.1 ON n INITIAL PVAIA)ATION DATE: 8/24/98 PATIENT: Sharon Hawbaker PHYSICAL THERAPY DIAGNOSIS: PHYSICIAN: Daniel DelralciS. MD DA'Z'E 010 lNlTlAl. EVALUA'T'ION: I (12f Cervical Facet Dysfunelion DDD 8/21 /48 HISTORY: Patient was involved in a . MVA on 4/ I 1 /98 in which the car was riding was hit from behind as she was turning her head to the left. to work but could not tolerate the pain, She received physical therapy i Vew%t' McCuen and Associates from 4/28/98 until 5/18/98 for a total of 10 visits but did not feel that she improved. Since she was last seen here on 5/18/98. she said that she received an Mill that showed degenerative arthritis. She told me that Dr. Hallock said that lie could not help her and referred tier to Physicians Or Rehabilitation hled.icine. CHIIPF COMPLAINT/StII3JIiC'PIVI::: Patient said she haS it burning pain in Lila right side of her neck, the right Lrapezius, and into the rikhl. upper arm. In ;rddiLion her "whole arm" burns when ever she uses her arm to do anything such as, n washing dishes, peeling vegetables, driving, doing laundry. or blowing dry her hair. She tried to go to work one day around August I and both arms then began to hurt and burn. The pain and burning in her neck ant] upper Lrapezius is constant while that in the arm is intermittent. She also said that she has pairs in her whole back. Right after the car accident, though. she said she had pairs from her "neck to (her) feet". About a month ago, she said that she tried her husband's stationary bike, but her right leg began to burn and ever since this C.1 time, both her legs feel weak. At worst her pain the pain scale which occurs later in the day and at best a5/105 a She / said nthat she takes Voltaren every day, a muscle relaxer infrequently, and pain medication maybe once a day. OBJECTIVE: Posture: Patient has forward heats posture and round shoulders, 'r Cervical ROM: right sidebending, 400 with pain in the right trapezius: left sidebending, 400 with no pain; right rotation, 740 with pain in the right trapezius; left rotation, 75 with no pain; flexion. 550 with pain to the right of C7; extension, 35 with pain bilaterally around C7. Extension was by far the most painful and the most limited. The other motions were basically WFL. When I had her do repeated head retractions, she complained of pain in the bilateral trapezius muscles. When she was done with 10 repetitions there was no change in her pain. Her reflexes were equal bilaterally and' her upper extrernfty strength was WFL. She reported decreased sensation to light touch on nil L11e digits of the right hand except the third digit. She also thought that the right arm had decreased sensation but "wasn't sure because it was not ball today". W She is tender to palpation in the right paracervical muscles. the right trapezius, and the right levator scapulae. Pressing on the insertion of the levator scapulae muscle on the right made her arm "feel funny". The right paracervical muscles and right trapezius felt more tense than those on the left. FUNCTIONAL STATUS/LIMITATIONS: Patient said she can barely do anything with her right arm without it causing increased pain and burning. h1 TREATMENT PLAN/RECOMMENDATIONS: Myofasical release, spray and stretch, electrical stim, cervical exercises, scapular exercises. and it TENS unit. McCuen & Associates Physical Therapy, P.C. 240 Grenddnv Avenue, Suite 101, Camp Him, PA 17011/17171737-9818/8170 Adam, 066. Suite 101, Hummelstmn, PA 17036/(717) 565-B006 1790 Old Trail Road. Suite F. aters, PA 17319/1717) 9380584/4905 E. Thtdle Reed, Mechanicsburg, PA 17055/(7171761-4939 n Page 2 RE: Sharon tlawbaker A SHORT TERM GOALS: Decrease pain Lo 8/10 at worst, wtrsh dishes without increased pain. LONG TERM GOAI.S: Dccreasc puin to 4/10 ILL worsL, WOW dry 11101' without pain. FREQUENCY/DURATION: T1W x 4-6 weeks as per prescription. ,Thank you for reFerring this patient to our service. Should you have any questions or further recommendations, please feel free to call our Country Meadows Office. Sincerely, 0L`).al?i-lelc o`?e?ciG'tc>;,Y?( Debra I.atsha, p.7'. 1< < C> O 0 V w 40 0% ow;k PATIENT NAME ?Shanan Rau36al.,on o DATE w DESCRIPTION/DAILY NOTES SIGNATURE l I pp?? ' l.U « 5 r Ir v r ? Y VS- Y r C/ 3 a. L s - 6L.,n" se 1 ?0 9 J r CtAr?l o% Aov- 4cfheve ` - J'Z c?eivl i S :S 6+2x(u 4., R1) 'ohl Rq s > A77 s?bsi o f_ L k?c?? fi' j (dive A?fA,;?g t ': r+ ATIENT NAME ,J rt !I ml DATE e? DESCRIPTION/DAILY NOTES SIGNATURE Q$ GlI 'o S a? 7 Ip? 7E , o D' o a o h ` e s ba 4-r -t '"sr -L ti , I?ALkA) (P l . (d )G21A dAAn nL.I._ I . o U: )b I In la 8 S: IAU)a kwAa F . . N dcr -? S? 6 dv WorsE /lo ?2c a 3/10 ayj 4 '4- E{e4vy .a ,nay , L L ro o c o s S c uAAkQ on- 5 ct tnt_ 2 s c. S Q S ov)o (Allot o s /s A PATIENT NAME 1 Wn iSPn n m AY 0 Co SJ M w w 0 E DESCRIPTION/DAILY NOTES SIGNATURE ?E Fr #. t o h) G 48 s : p 501d: SAW /F,/4r. WOUS Ali QAAA On-9 ADA G r ' lloln g N - I I WA cztxd em sio?eo - ?? l 4: ? lrn.o s? . , WhkA,,- + ulo S ! F-i- PLA'Led In sr. LJI? ups a F I n + 2 cQ:ra ! J 1'f? ? G l.? l y }- 1101 oir, a9$iz_ of ' su.a tl cLt' ch vm ; uCYL O CC-U t& t 1: CT y 0# ` ,moo 0 Pi a cu ?o t _ s t . _ 12) o 4-vt LA a ?Lf ?a PATIENT NAME DATE 9/,., I 'a S ct Mlu EIv ¦IH 'N DESCRIPTION/DAILY NOTES L &Q &Q ' n ^ OtAmilA ?J 0 PT 912Ir98 c /? AAAjAiC. enin,,Zt2 sct ah 7tn .. _ ,. ?_ .. L . . .. ? wll? {?CLdiY?' E AW-tot 7 1?% `Knc 6-¢ fmw shAO . L??CIJ?cnh' M??rL, (o?p R Qnyri Un_n Of 12 it L?-c'/l r 7,?fu+-s?? nio !1'P°')(Y Y1?Ct ??m/1 C! cl .O OL- 4:nz Zrm v2te -Vtu pop s dAl CO n o WASO .SCalano 1 klo_Au yy onn n ov !Y, ?a? _ SIGNATURE A PATIENT NAME cShano h E fn r l7 a? DATE DESCRIPTION/DAILY NO'EL'S SIGNATURE r O$x u... {' t oS+ 123!=GA M wt rut !2 Pal o : 7 a,?, ? L scc? R i r< 41-A sc . W, 2 c , s fi no Ige&d 4t Sho - .(¢)(-! B e.l$,w WFL s FL f 'o S ?1 IY?R CU/Vl (1w ? C/p a Q A& l t? ?l-v?J f 41-d:t S + S coo( 'aZAJ2 - V o* -r- <'Y'6 r0, ;, : cam, (9 -f- _.fr,., ) - lnI-- </nn?. 0:0.,., 0,.__. f- n PATIENT NAME DATE n = 10 mito s DESCRIPTION/DAILY NOTES d Q ,I W o ?r e 2, .-c)-LA f - a.f- w ?s g// o - ? sdywe I?,,, . 's ? (o(o_ * ,.., f? o a n 1 in A- -e 1 0 - w Or ILrzd o 2-n c dl ?Yt In o r h i lE X MF2 it' -T cr,,tia oat off ?p - • U ri / -j- qAA r ' ' ©sPdse 55° our oK• 65° A& SIGNATURE lco) J t1?CQ.. ? S I{ WcsvZSi; g/1 ?? ,/Ve o .? si n c° q ,US r i 4 7n -ft a- il• ??Mo - PATIENT NAME ?iYlan,w ci ,,s 0, Oo e FDATE DESCRIPTIONIDAILY NOTES SIGNATURE s - , Iv P? s EM f A) a t- -IA)s #-A LAX oA !s p -s C l ? , Sf- -e (A, 124 - ?. IL ? - Z OkAfy, t7 ' Sta6n o? D_ Zo M L 6 C a f> A d ?4-u G?_ 2sti? o 2. 4:E ow 6 ks-e-It Wrr, o r' T h oto Y ,. CVLP CL.? sLe cili. k4U I f tj ur# % o(f e ko R (T8 S : (, &411 C) `l?c.?ccnci A N U 17 A PATIENT lYAME Sh°?,?,,?? o„ b on 1 DATE DESCRIPTION/DAILY NOTES 91 a 9s A;? XaA S • 1 ?d ?~ 1 C? n n? 9 fliin bra S Lp err? S d SIGNATURE L 'All ?I a 1k7 F, R, ?c 5? `?/ 10 bes F 7/ l 2 DA rr) S E i ? o¢ (n ur W 44M o(0 I 1 ' ` e s + Si ° &? 4,°, 'f lwafs ?4, o ry 4 OK {{y,.???`? s Nor" T ?- l + a 2 i n S m PATIENI' NAME n DATE. . y?Wt. Yl1 Gin o 0 DESCRIPTION/DAILY NO'T'ES _rJI 01'1--e a bzPEyn ? "fur ' .11 V.n • fZ?cy??: ?SQ? P ?o- A aP? a? ?- ?C( o {zc S - -"" V ?'+ J ?6 rtR 'UC V N Coa ' 1 !"YIiMnIlJP e P: P+ wese^ Lon o n 7E /y 5 3 ar P01 Q5 $avio ccvn ?? S u -f t?N S I fbh a a r rre ?4f? " Q2?e,L wa ek e (-o ocln P h ??oofi;1P h SIGNATURE 3 A PATIENT NAIbiE.?r, ?<• I ?r ?? ?? ?a DATE DESCRIPTION/DAILY NOTES A 8 loiE cio r1 (n /. n } 1?Y tnT° aej Gtt IL1lei o.. J_ I SIGNATURE Ia7 o a ' 'i1R. CALF-?? nnl< <t3? JQwen) -f n / J i r q vt o! ? p s l i Ar I L?!~ 6yuol 'r h cz 2 jig U;R- UAQ 61: rA #1 -2 hN 'F L E -• sf, /n a. '° ;.Crnt s s f 14, 1M.I C?4. A .III Mc,jEN & ASSOCIATES PHYSICAL 1 / SPINAL EVALUATION Patient C,6C?1 f ujk?(?2i. DX: D4 fain J.U , n AgeWOrk_/Status ?ha;, ,,_A = A„s + d., Date of OnsetMyq ylyg I Ga Play_alUt&aWL4vdea. Prinr T.ovel s -_ .,,?1 aWhola ¢rtN 6unnS ? - // If UUA GNVYI Y) Q Q No Pain I? Of Tu. ;RAP; 'bi)D -Date Current History: byrrl? 1 HCA, l' f' e. J fi 1 to 1 . .yacu6CiGd`T ? n A I !clevant Past History & Treatment: - I - I - I Radiological (mate): o I I Paresthesia an?d?other symptoms:_ gUf nan.n (µ, ((C.)0. vaJ } ?i 1 I 1071 y?? ;n i Headache I I Gait: Normal; Guarded; List: L R• - Limp LI R; to and from Wont Pan chair guarded a`"VeCV+ofee}" 1 Where did pain start? `Rucrt(PAXIL." I Where aid it spread? _ 1 Sitting Attitude: Normal; Protected; Nature 6urnl I on R L Ischium; Moves constantly. Constant Intermittent urq?;?.p ; I{„nun° arwand Increasing Static ? -°i -°-° Decreasing A ravates 1 Active Movements: Restricted) Blocked,) g4 - r Pain/Restricted X Hypermobile nJ 3 -Fnr 66 H Eases a o n st a i FBSS' ?^ +^I', 1 ,v --fxFensioy?? 0..` N$o i Oa µ V5 I dLe. nocfi a Pain: Nighty"nom Abut SBL'`da B R h, Afternoon so,,,, T Evening_? s} Bed/Pillow/Position 1 9s? a s B A i ow 35a ?Y,Qvat' o 10.7 r Medication a%_rvlM I& lc?a 2? _ i RL BB® R®(?? GC a?l't -*M he •M.. A0l 7 a cb -?- Vo(?-alnoan _p..I ?? Bowel/Bladdwer- Cough/Sneeze i FB I r SBL SBR Comments: Nervous; Irritable; 1 Anxious; hostile; __-__ 1 PT nn nn Patn+burn I j? avck ? S ' Gllthx. time. ?, aFart 1. I,I?aII Auchona d .SC'IC? ?a3 StWa .u?J^ / 1??a7I W Shceue;5,?,::a ?C Pai:I ? Scale 1 1 1 1 1 i I I I I I I I I I I ^ neurological: SLR: L e R o Cx Flexion Dorsi Flexion Reflexes: L3-4 Knee JK L_ R S1 Ankle JK L R C5-6 Biceps JK C7 Lei R-;-2.-- Triceps JK C5 6 Brae Rad L*R R _ ---- L +a R*y Sensation A- 1-1\ OA ?p ? Q,1n ?" Sacroiliac. net bnd + Standing: PSIS L Sittin : PS g IS L_ R ASIS L_R n Leg Length: _ Supine Long Sitting Compression Distraction ORom: l2e i Le0_; d h ?l =_____ a acJ2 a-do RE 0 jt cr 1 Strength: r Palpation ?? II -7 -e l ? -7- -7- I III •'•' ,I'I i II .. . ul 1 mt?Cf?o O.?r• c Ear KEY: X Tender w Centre Pain Pain Referen ' Hypomobile rM Hypermobile Spasm Posture L3Ua + n ta;, Q ?? V )ischarge/Long Term r. ajiagnos v requency_ uration Recommendations: 9?jsical Therapist signature ? &h I o ?_ Dated/al/98 A J?6't?i•-c`?'I I.JCtcCI{i?':".Z..?-r I? PAIN SCALE Patient Date - I I^c) pT/PTA e A 0 1 2 3 4 ? 5 re 6 7 8 I ? 9 10. No PI r ............. Worst Pain CILUM 2 3 4 5 6 I 7 8 9 10 I----I--I--- No Pain Worst Pain ?,q - - -• _ . "Munn 0 1 2 3 4 I 5 6 7 8 9 10 I No Pain Worst Pain M i r1HJ1 ature 0 1 2 3 4 5 I 6 7 8 9 10 in I I I I I -L_I_? No Pain Yr - Worst Pain McCuen & Associates Physical Therapy, P.C. 7.30-98 m O 0 I" r 4d 0 3 h .N L' U C U ei S ?! +a ?a C dl „L !tl (d 2 ? J a N N U O 4r 'U = U i ii '?! A? n 0r CIP C> Q- 04 1 11 Z4 k N o_ c s U M > ? a U tt v Q 48 1 o ? L LhrX? b 0 E QA + (d to > G) • 4+ M O ?, I _3} •? w >a g-.1W bra }t I s U Id b 04)r N V'. b W m L 'O U) 'A 4411 I/1 J x o 0 r 9 (a r !/3 V 4J A, N Igo .E{ W o C oH ?H rn t N? ?? 8v', ro 014 IZE v 10% 10,14 0 0 40 N all u a 7 N b 1 U 0 ? w o?Mb ? 9 mau at vm °m a 1 1 a) '4 Ooem ' D 1 x Li N a C r .+L a r d IIQQQQ I I > > > >? r ? c c CON E c C c t 3 ? Z 0 1J (n 43 iE li .- E d N U FI w J ;, w A 0 • 0 0 0 A A A A /(?I19/t't?a3rp1 VISMO?/ CLIENT: EMPLOYER: DATE OF INJURY: DATE OF INITIAL EVALUATION: DATE OF SECOND RE-EVALUATION: DATE OF REPORT: HEALTHSOUTH I.D. NO.: REFERRED BY: PHYSICIAN: INSURANCE CARRIER: INSURANCE I.D. NO.: Sharon Hawbaker New You 4/11/98 10/21/98 11/16/98 11/16/98 618590 Daniel DeFalcis, M.D. Daniel DeFalcis, M.D, Allstate 155307082OK33 WORK HARDENL?iG SUMMARY REPORT Ms. Sharon Hawbaker has continued to attend her daily Work Hardening program at the HEALTHSOUTH Regional Work Performance and Hand Center since her initial evaluation on 10/21/98. She was referred to this facility by Dr. DeFalcis with a diagnosis ofDDD cervical spine/myofascial pain. ' As per her last visit with you on 11/3/98, she has continued to attend Work Hardening five times a week for two weeks at four hours per day. Although Ms. Hawbaker's injury was sustained as a result of a motor vehicle accident, she has been out of work since 10/22198. She was previously employed as a barber/stylist by the New You. She estimates the maximum lifting that she would have to perform as a barber/stylist is 40 lbs. REASSESSMENT RESULTS: Dynamic progressive lifting on this date indicated Ms. Hawbaker's ability to frequently lift l l lbs, from knuckle to shoulder level (previously l i lbs.) and frequently lift 11 lbs. from floor to knuckle level (previously 21 lbs.). These current results place her into the LIGHT level of work according to the DOT category. Please refer to pages 1, 3, and 4 of the enclosed ARCON computer sheets for additional lifting data as well as subjective comments made during testing. Her subjective comments include "burning, heaviness, weakness, and fatigue" with lifting. W Cervical AROM was assessed on the ARCON computer inclinometry indicate mobility that is WNLs for flexion, extension, lateral flexion right and left, and rotation tight and left. Please refer to page 8 of the enclosed ARCON computer sheets for specific numeric ROM results. Jamar hand grip testing on position 2 (standard position) indicates Ms. Hawbaker's RUE grip strength to be 54.4 lbs. (previously 60.4 lbs.) and her LUE grip strength to be 47.1 lbs. (previously 43.7 lbs.). Her current results are 105% and 99% of the AMA Norms respectively. All coefficient of variance statistics on 6 out o£6 trials were less than 20% thus indicating consistency of effort response by the patient. A Kasch step test was attempted with Ms. Hawbaker during the reassessment as this test was unable to be rr completed during the baseline as well as during the first re-evaluation. Due to complaints of bilateral leg soreness and "exhaustion". She, again, was unable to complete the 3 minute step test (the patient had 1 9 840 North Front Street • Wormsteyburg, PA 17043 • 717 975-3337 • Fax 717 975-3973 04 Reassessment 64 RE: Sharon Hawbaker minute and 41 seconds remaining in the test prior to stopping the test). Her initial attempt at completing m this test resulted in 1 minute and 58 seconds remaining and her second attempt resulted in 1 minute and 48 seconds remaining in the test. Since beginning the Work Hardening Program, Ms. Hawbaker has attended a total of 18 Work Hardening treatment sessions (this number excludes her initial evaluation). Her sessions have been averaging 4 hours in length and include the following: total body flexibility exercises, a cervical thoracic stabilization program, a multistation gym program, cardiovascular exercises (treadmill and stationary bike), specific job simulation activities, moist heat to the cervical spine, and myofascial release. She also uses a theracane sporadically in the clinic as needed. n Although Ms. Hawbaker has reported some relief with the pain management techniques offered by the physical therapist, she continues to report no significant increases in her function or significant decreases in her pain level. She continues to demonstrate significant difficulty with prolonged periods of job simulation which include working with her arms outstretched at shoulder and overhead levels. She has not demonstrated the ability to perform her job simulation tasks over two minutes. According to her reassessment on this date, her physical capabilities as far as lifting and job simulation endurance have not R? improved. On this day, Ms. Hawbaker did report increased symptomatology as she reported coloring her hair over the weekend. At this point in time, Ms. Hawbaker appears to have reached her maximum potential from the Work Hardening program. Her functional improvements within the program appear to be reaching a plateau and w she consistently presents with increased symptomatology. As a result, I offer the following recommendations: 1. Recommend that Ms. Sharon Hawbaker be considered for strict physical therapy treatments for pain relief and continued myofascial release and/or a pain management program for the same. Ms. Hawbaker a also appears to respond well to relaxation techniques as she has verbalized several stressors in her life. Thank you for this referral. If you have any questions or concerns regarding Ms. Hawbaker's performance in Work Hardening, please do not hesitate to contact me at 975-3337. As of this time, the Work Hardening staff recommends that Ms. Hawbaker be discharged from Work Hardening due to maximum benefitreached. X72 f L Dolma o y Work Hardening Coordinator cc: Daniel DeFalcis, M.D. Allstate Insurance V 41 A HEALTH SCUM. Work Performance center 840 North Front Street !? Worm/eysburg, PA 17043 Phone (717) 975-3337 Fax (717) 975-3973 A A 0 w 00 r M tir PATIENT INFORMATION: Report Date: 11/16/98 Patient: Sharon M. Hawbaker Address: 124 Woods Drive #10 Mechanicsburg, Pa 17055 Phone (H): 717-795-9286 Initial Visit: 10/21/98 ... Referred by: Dr. DeFalcls ... Resting Pulse Rate: 100 ... Blood Pressure (sitting): 140190 Physician: Dr. Lutness Tested By: Donna Lorince, OTR/L ID#: 187428381 DOB: 03/15/52 Age: 46 Sex: F Height: 64 in Weight: 18016 Phone (W): 717-732-2174 Occupation: Barber/Stylist DOT: ... SIC: Employer: Carlisle hospital Insurance Co: Erie Attorney: n/a 0 A Sharon M. Hawbaker W The Figure to the right shows the patient's heart rate response during the Dynamic Progressive Lift. The X-axis shows the weight lifted at each level of the test (in pounds), while the Y-axis shows the patient's heart rate at the end of that lifting level expressed as a percent of the patient's age-adjusted maximal heart rate. in 0 V M M V W 11/16/98 - Page 2 so _ 70 'a 60 so no at 30 2n o )) Weight Lined (Lb) 0 Sharon M. Hawbaker 11/16/98 -Page 3 DYNAMIC PROGRESSIVE LIFTING © 1995 Phillip Osborne, M.D. 0% PROTOCOL: CERVICAL (Knuckle-To-Shoulder) (1) BEGINNING ENDING Weight Lifted 11 Ib 11 Ib 04 Perceived Load 1 - (Like Nothing) 8 - Heavy) (Very Pain Level 0 - (No Pain) 4 - (Mild to Moderate) Heart Rate (Target = 130) 101 79 Reason for Discontinuation of Testing Psychophysical: Examinee rated current load of 11 Ibs as "Very Heavy". Lifting Capacity (DOT Category) Indicated 0 by this Performance Light Compatible with isometric Performance? ?? Heart Rate (beata/min) Cumulative Work Ib•ft 260 6000 ( ) 176 6000 00 166 4000 126 3000 100 2000 76 1060 600 1 2 3 4 6 00 1 2 3 4 6 N W W M 40 PROTOCOL: LUMBAR (Floor-To-Knuckle) (2) Sharon M. Hawbaker 200 Heart Rate (beats/min) 173 - 130 123 - 100 73 300 1 2 3 4 3 A n C.) 6:7 sw! v W rw 11/16/98 - Page 4 cumulative Work (Ib-a) A000 eaoo 4000 7000 2000 1000 00 1 2 3 4 3 Physical Demand Characteristics of Work PHYSICAL DEMAND LEVEL OCCASIONAL 0-33% of the workday FREQUENT 34-66% of the workda CONSTANT 67-100% of the workda Sedentary Up to 10 lbs. Neg 1, ble Light Up to 20 lbs. le Medium 20 - 50 lbs. lbs. Heavy 50 - 100 lbs. 1 bs. Very Heavy Over 100 lbs. lbs. (1) Pt. reports "burning, heaviness, and weakness" acro ss the upper back and shoulders, as well as the head. (2) Pt. reports increased "fatigue" at the conclusion of lifting I I pounds from floor to knuckle level. Bibliography: Garg, A., et al. (1980). A comparison of isometric strength and dynamic lifting capacity. Ergonomics, 23: 13-27. W Test Endpoint Conditions for Dynamic Progressive Lifting A Sharon M. Hawbaker 40 11/16/98 - Page S Mayer, T., at al. (1988). Progressive isoinertial lifting evaluation: A standardized protocol and normative data base. Spine, 13: 993-997. U.S. Department of Labor. (1991). Dictionary of Occupational Titles, Vol. II (Fourth Edition, Revised). w N 0 In 0 w w YI R 49 w Sharon M. Hawbaker 4 11/16/98 - Page 6 A JAMAR HAND DYNAMOMETER © 1995 Phillip Osborne, M.D. DOMINANT HAND STRENGTH NON-DOMINANT HAND STRENGTH no MVE graphs no MVE graphs Coefficients of Variation (COV's) ~ ! iii ? I (v:r 6 fll IST ITION POS 2ND POS T ON POS T ON POSITION POSSTH ITION Dominant (R) n/a 10.4 n/a n/a n/a Non-dominant (L) n/a 4.4 n/a n/a n/a Rapid Exchange Grip Testing Oft to MVE Performance REG Performance REG Score" REG % Change Dominant (R) 54.4 lb Non-dominant (L) 47.1 Ib 'REG score Is positive when performance on Rapid Exchange Grip is greater than that on MVE (2nd pos.) performance. A positive REG score should alert the physician that submaximal performance is suspected. Strength Performance vs. AMA Norms (Guides Table 32. P. 65): Right Strength = 24.7 kg, AMA Norm = 23.4 kg, Percent of Norm =105% Left Strength = 21.4 kg, AMA Norm = 21.5 kg, Percent of Norm = 99% Validity Summary. Coefficients of variation > 20% on 0 of 6 trials (MVE testing). Elibliooraahv: American Medical Association. (1993). Guides to the Evaluation of Permanent Impairment (4th ed.). Chicago: Author. Hildreth, D. H. & Lister, G. D. (1989). Detection of submaximal effort by use of the rapid exchange grip. Journal of Hand Surgery, 14A: 742-745. ?y Mathiovvetz, V., Kashman, N., Volland, G., Weber, K., Dowe, M., & Rogers, S. (1985). Grip and pinch strength: Normative data for adults. Arch Phys Mad Rehabil, 66: 69- 72. 4110 A A A M 0 0 Q 0 Sharon M. Hawbaker W 60 Stokes, H. M. (1983). The seriously uninjured hand - Weakness of grip. Occupational Medicine, 25(9): 683-684. 11116198. Page 7 Journal of 0 Sharon M. Hawbaker IA r I iry M\ r-1 t1 0 M M V 4 11116198 - Page 8 ARCON ROM - Spinal ROM Inclinometer Report: The patient was tested in our facility using the ARCON ROM computerized dual inclinometer system. This system is designed to quantify an individual's spinal range of motion (ROM) in the cervical, thoracic and/or lumbar regions, and to compare these ROM values to recognized population norms. $ rrom "Guides to the Evaluation of Permanent Impairment", Third Edition (Revised), American Medical Association, 1990. t The AMA "Guides" validity criterion is three consecutive measurements within f50 or tl0%of median value. to i mn rnun:ates resuns mat are not available or applicable for the listed task) " 4 40 H Mq. ?1 tat C LENT Cad Vochancsbug Sharon Hawbaker EMPLOYER: New You DATE OF INJURY: 4/11/98 DATE OF INITIAL EVALUATION: 10/21/98 DATE OF RE-EVALUATION: 11/2/98 DATE OF REPORT: 11/2/98 HEALTHSOUTH I.D. NO.: 618590 REFERRED BY: Daniel DeFalcis, M.D. PHYSICIAN: Daniel DeFalcis, M.D. INSURANCE CARRIER: Allstate INSURANCE CLAIM NO.: 1553070820K33 WORK H ARDENING SUMMARY REPORT Ms. Sharon Hawbaker was referred to the HEALTHSOUTH Regional Work Performance and Hand Center by Dr. DeFalcis with a diagnosis of DDD cervical/myofascial neck pain. The referral was for Ms. Hawbaker to participate in a daily Work Hardening program for two weeks at four hours per day to increase her physical capabilities. 0 Ms. Sharon Hawbaker is employed by a hair salon (The New You). She reports being employed with this company for ten years. She performs the job duties of a barber/stylist. She estimates the maximum lifting that she would have to perform as a barber/stylist is 40 lbs. FUNCTIONAL REASSESSMENT RESULTS (11/2/98): Dynamic progressive lifting indicated patient's ability to frequently lift I 1 lbs. from knuckle to shoulder level and frequently lift 21 lbs. from floor to knuckle level. These current results are equal to her previous cy results. from 10/21/98. These results indicate LIGHT level work according to the DOT category. Please refer to pages 3 and 4 of the enclosed ARCON computer sheets for additional lifting data as well as subjective comments made during testing. She specifically commented on increased burning sensations in the cervical region as well as "heaviness and tingling" throughout the RUE with lifting. Cervical ROM was reassessed on the ARCON computer inclinometry system. Her current ROM results indicate mobility that is WNLs for flexion, extension, lateral flexion right and left, and rotation right and left. Please refer to pages 8 and 9 of the enclosed ARCON computer sheets for additional ROM data. Jamar hand grip testing on position #2 indicated Ms. Hawbaker's RUE grip strength to be 60.4 lbs. and her LUE grip strength to be 43.7 lbs. (117% and 92% of the AMA norms respectively). All coefficient of u variance statistics were less than 20% thus indicating consistency of effort response by the patient. One out of two strength curves were inappropriate as well as one rapid exchange grip score thus suggesting the possibility of submaximal effort. A Kasch step test was again attempted with Ms. Hawbaker during the reassessment as this test was unable to be completed during the baseline due to patient's complaints of feeling "exhausted". She again was unable to complete the 3 minute step test (patient had 1 minute and 48 seconds remaining in the test prior 0 840 North Front Street • Wormsleyburg, PA 17043 • 717 975-3337 • Fax 717 975-3973 A t 400 to stopping the test). Her previous attempt at this test resulted in 1 minute and 58 seconds remaining in A the test. This comparison indicates her ability to tolerate an increase of 10 seconds of stepping. Since beginning the Work Hardening program, Ms. Hawbaker has attended a total of 7 Work Hardening treatment sessions (this number excluded her initial evaluation). Her sessions have been averaging three to four hours in length and include the following: total body flexibility exercises, a cervical thoracic w stabilization program, a multistation gym program, cardiovascular exercises (treadmill and stationary bike), and specific job simulation activities reflecting her responsibilities as a barber/stylist. She has also completed a series of educational videos for the management of neck pain as weN as proper body mechanics and lifting techniques training. She also continues to perform a theracane program for pain management. 04 Although tolerating the program fairly well, she continues to report no change in her function. She reports increased spasms and tightness prior to beginning her Work Hardening therapy. She also complains of increased "tingling" throughout the right arm as well as "burning" since beginning Work Hardening. On a positive note, she does report overall feeling good as a result of the exercise regimen. Ms. Hawbaker continues to experience significant difficulty with prolonged periods of job simulation which include working with her arms outstretched and at shoulder and overhead levels. Recently Ms. Hawbaker has only been able to tolerate her simulated activities for less than 2 minutes. This is not adequate for her to return to her previous job as a barber/stylist as her client's appointments are a minimum of 30 minutes in length. Since Ms. Hawbaker has only been seen in Work Hardening for approximately two weeks, the Work Hardening staff would recommend that she continue for an additional two to four weeks in an effort to maximize her physical capabilities and continue to improve upon her function and endurance for her previous work responsibilities. a? If you are in agreement with this recommendation, please make the appropriate referral to continue Work H e ng treatment daily basis. If you have any questions or concerns regarding her current status or he p ormance wit nth past two weeks, please do not hesitate to contact meat 975-3337. Donna Lorince, OTR/L Work Hardening Coordinator r cc: Daniel DeFalcis, M.D. Allstate Insurance Company to 0 HEALTHSOUTH. Work Performance Center 840 North Front Street Wonnleysburg, PA 17043 Phone (717) 975-3337 Fax (717) 975-3973 ell 0 a PATIENT INFORMATION: Report Date: 11/02198 Patient: Sharon M. Hawbaker Address: 124 Woods Drive #10 Mechanicsburg, Pa 17055 Phone (H): 717-795-9286 Initial Visit: 10/21/98 ... Referred by: Dr. DeFalcis ... Resting Pulse Rate: 100 ... Blood Pressure (sitting): 140190 Physician: Dr. Rolle Tested By: Donna Lorince, OTR/L ID#: 187428381 DOB: 03/15/52 Age: 46 Sex: F Height: 64 in Weight: 180 lb Phone (W): 717-732-2174 Occupation: Barber/Stylist ... DOT: ... SIC: Employer: Peneky Auto Center Insurance Co: PMA Attorney: n/a BEGINNING ENDING Weight Lifted 11 Ib 21 It; Perceived Load 5 - (Medium) 7 - (Heavy) Pain Level 3 - (Mild) 4 - (Mild to Moderate) Heart Rate (Target = 130) 93 118 The Figure to the right shows the patient's heart rate response during the Dynamic Progressive Lift. The X-axis shows the = e1 weight lifted at each level of the test (in E pounds), while the Y-axis shows the .E patient's heart rate at the end of that lifting ate level expressed as a percent of the patient's age-adjusted maximal heart rate. to W BEGINNING ENDING Weight Lifted 11 lb 11 Ib Perceived Load 1 - (Like Nothing) 8 --(Very Heavy) Pain Level 0 - (No Pain) 4 - (Mild to Moderate) Heart Rate (Target = 130) 84 114 0 welaht Lifted tLbl A A w 4-0 e'1 ?.,, ad Sharon M. Ilawbaker 11/02/98 - Page 2 The Figure to the right shows the patient's heart rate response during the Dynamic 80 Progressive Lift. The X-axis shows the S 70 - 60 weight lifted at each level of the test (in E so A AA: pounds), while the Y-axis shows the ao _ patient's heart rate at the end of that lifting e ?o level expressed as a percent of the patient's 20 age-adjusted maximal heart rate. ° It Weight Lifted (Lb) +)?l,hu?fMP?:1Istl gl,5umlit a'y otieOeR!l?nb'''b'QdgrnellMPr1U!?hll;lil;l;l;ill?il! MVE DOMINANT HAND STRENGTH MVE NON-DOMINANT HAND STRENGTH Right Hand (Pounds) Len Hued (Pounds) ao +o so Io ]o ]o ao to 0 Pal Pool Pa) Pal Pa] 0 Pal Pa] Pool Pw1 Pa] .r MVE REG REG Test REG % .:... Performance Performance Score Change Dominant (R) 60.4 Ib 49.4 Ib -11 -18% Non-dominant (L) 43.7 lb 55 lb 11.3 25% d L , I' L '?. A t Right Strength = 27.5 kg, AMA Norm = 23.4 kg, Percent orNorm = 117% Left Strength = 19.9 kg, AMA Norm = 21.5 kg, Percent or Norm = 92% Coefficients of variation > 20% on 0 of 10 trials (MVE). Inappropriate strength curves on 1 of 2 curves (MVE). Positive REG scores on 1 of 2 sides (REG). 0 A A w rA ft to d 40 v Sharon M. Hawbaker 11/02/98 - Page 3 DYNAMIC PROGRESSIVE LIFTING © 1995 Phillip Osbome, M.D. PROTOCOL: LUMBAR (Floor-To-Knuckle) (1) BEGINNING ENDING Weight Lifted 11 lb 21 lb Perceived Load 5 - (Medium) 7 - (Heavy) Pain Level 3 - (Mild) 4 - (Mild to Moderate) Heart Rate (Target =130) 93 116 Reason for Discontinuation of Testing Psychophysical: Examinee requested that testing be discontinued. Lifting Capacity (DOT Category) Indicated by this Performance Light Compatible with Isometric Performance? ?? Heart Rate (boats/min) Cumulative Work (lb-ft) 200 8000 175 5000 150 4050 125 3000 100 2000 75 1000 ?0 1 2 3 4 5 00 1 2 3 1 5 PROTOCOL: CERVICAL (Knuckle-To-Shoulder) (2) BEGINNING ENDING Weight Lifted 11 lb 11 lb Perceived Load 1 - (Like Nothing) 8 - (Very Heavy) Pain Level 0 - (No Pain) 4 - (Mild to Moderate) Heart Rate (Target = 130) 84 114 Reason for Discontinuation of Testing Psychophysical: Examinee rated current load of 11 Ibs as "Very Heavy". Lifting Capacity (DOT Category) Indicated by this Performance Light Compatible with Isometric Performance? ?? 0 A Sharon M. Hawbaker Heart Rate (beets/min) 200 - A 170 1ti0 - -- - 125 - - 100 76 n 0 0 11/02/98 - Page 4 cumulative Work (lb-ft) 6000 4000 -- - 3000 2000 1000 00 1 2 1 Physical Demand Characteristics of Work ej W W V PHYSICAL DEMAND LEVEL OCCASIONAL 033% of the workday FREQUENT 34-60% of the workday CONSTANT 67-100% of the workday Sedentary Up to 10 lbs. Negligible Negligible Light Up to 20 lbs. Up to 10 lbs. Negligible Medium 20 - 50 lbs. 10 - 25 lbs. Up to 10 lbs. Heavy L 50 - 100 lbs. 25 - 50 lbs. 10 - 20 lbs. Very Heavy Over 100 lbs. Over 50 lbs. Over 20 lbs. Bibliography: Garg, A., at al. (1980). A comparison of isometric strength and dynamic lifting capacity. Ergonomics, 23: 13-27. O Test Endpoint Conditions for Dynamic Progressive Lifting A t Sharon M. Hawbaker *0 4 11/02/98 - Page S Mayer, T., et al. (1988). Progressive isoinertial lifting evaluation: A standardized protocol and normative data base. Spine, 13: 993-997. U.S. Department of Labor. (1991). Dictionary of Occupational Titles, Vol. II (Fourth Edition, Revised). 0 0 Q 0 0 W w 0 A Sharon M. Hawbaker 11/02/98 - Page 6 JAMAR HAND DYNAMOMETER © 1995 Phillip Osborne, M.D. A DOMINANT HAND STRENGTH Right Hand (Pounds) so 60 A 40 70 0 Pw I Pos 7 Pm 3 Pw 4 Pw A 4'4 NON-DOMINANT HAND STRENGTH Left Hand (Pounds) Coefficients of Variation (COV's) ;i IiiJU di'?i>IIWa(?) L ulllti?..+?,?I1t+t?N' iir 1ST POSITION N 3RD POSITION 4TH POSITION 5TH POSITION Dominant (R) 13.6 t 2.2 9.7 15.8 Non-dominant (L) 9.3 4.2 4.4 2.0 10.8 Rapid Exchange Grip Testing M MVE Performance REG Performance REG Scare" REG % Change Dominant (R) 60.41b 49.4 lb 11 -18% Non-dominant (L) 43.7 lb 55 lb 11.3 25% 'REG score is positive when performance on Rapid Exchange Grip is greater than that on MVE (2nd pos.) performance. A positive REG score should alert the physician that submaximat performance Is suspected. Stronnth Porforman.Ce vs, AMA,Norma fGuides..i:oble_32 ,Q 651: W Right Strength = 27.5 kg, AMA Norm = 23.4 kg, Percent of Norm = 117% Left Strength = 19.9 kg, AMA Norm = 21.5 kg, Percent of Norm = 92% Validity Summary: Coefficients of variation > 20% on 0 of 10 trials (MVE testing). Inappropriate strength curves on 1 of 2 curves (MVE testing). Positive REG scores on 1 of 2 sides (REG testing). rr Biblioaraahv: American Medical Association. (1993). Guides to the Evaluation of Permanent Impairment (4th ed.). Chicago: Author. 0 Sharon M. Hawbaker 40 W Hildreth, D. H. $ Lister, G. D. (1989). Detection of submaximal effort by use of he rapid $e' exchange grip, Journal of Hand Surgery, 14A: 742-745. Mathiowetz, V., Kashman, N., Volland, G., Weber, K., Dowe, M., 8 Rogers, S. (1985). Grip and pinch strength: Normative data for adults. Arch Phys Mad Rehabil, 66: 69- 72. Stokes, H. M. (1983). The seriously uninjured hand -- Weakness of grip. Journal of Occupational Medicine, 25(9): 683-684. a# a 0 C V W W 0 0 A M W e3 Sharon M. Hawbaker 60 ARCON ROM - SpinalROM Incl(nometer Report: 11/(12/98 - Page 8 i • ov aeg i Cn/a" indicates results that are not available or applicable for the listed task) r, aw N V 0 I Prom "Guides to the Evaluation of Permanent Impairment", Third Edition (Revised), American Medical Association, 1990. t The AMA "Guides" validity criterion is three consecutive measnrcmr.mq ,;t+ ; The patient was tested in our facility using the ARCON ROM computerized dual inclinometer system. This system is designed to quantify an individual's spinal range of motion (ROM) in the cervical, thoracic and/or lumbar regions, and to compare these ROM values to re norms. cognized population A A eA 0 0 0 W1 WI W Sharon M. Hawbaker 11/02/98 - Page 9 Cervical ROM Impairment Report Test Date: 11/02/98 Movement Description Range Cervical Flexion Occipital ROM 58 58 TI ROM 2 0 Cervical flexion angle 56 58 t 10% or 5° 7 Yes Maximum cervical flexion angle 61 %Impairment 0 Cervical Extension Occipital ROM 58 54 ,aa„'d i Is TI ROM 10 7 Cervical extension angle 48 47 m , I„ i 110% or 5° 7 Yes Maximum cervical extension angle 49 %Impairment 2 Cervical Ankylosis in Position (Excludes my impairment for abrxmal x Flexion/Extension %Impairnent aexion/extenaion motion) Cervical Right Lateral Flexion Occipital ROM 38 i yy 38 TI ROM 0 S` y4`` I ' t fa? ? E? 0 Cervical right lot flexion angle 38 +l8 s { ?IIII' 38 4:10% or 50 7 Yes Maximum cervical right lot flexion angle 40 %Impairment p Cervical Left Lateral Flexion Occipital ROM 40 42 TI ROM 0 „ 1 Cervical left lot flexion angle 40 41 +10%or 5° 7 Yes Maximum cervical left let flexion angle 41 %Impairment 0 Cervical Ankylosis in Position (Excludes any impairmnt for abnormal Lateral Flexion/Extension %Impairment lateral aexionrextensionmotion) Cervical Right Rotation Cervical right Rotation angle v"?,4r7$ 1'1 74 72 1I0%or 5° 7 Yes Maximum cervical right rotation angle 78 Impairment 0 Cervical Left Rotation Cervical left Rotation angle 76 77 +10% or 5° 7 Yes Maximum cervical left rotation angle 78 %Impairment p Cervical Ankylosis in Position (Excludes any impairment for abnormal Rotation %Impairment rotation) Total Cervical Range of Motion impairment (add all ROM impairments if no ankylosis; 2 ado use largest ankylosis impairment value if ankvlosis is rresenl) Note: Shaded column shows which measurement (of three consecutive within 5° or 10%) produced maximum ROM value 40 A ?FAL7HS0?lW At;IaeLx'rtatiar CenterdMed ierkstx.rg A CLIENT: EMPLOYER: DATE OF INJURY: DATE OF EVALUATION: A DATE OF REPORT: HEALTHSOUTH I.D. NO.: REFERRED BY: PHYSICIAN: INSURANCE CARRIER: A INSURANCE CLAIM NO.: Sharon Hawbaker New You 4/11/98 10/21/98 10/22/98 618590 Dr. DeFalcis Dr. DeFalcis Allstate Insurance 155307082OK33 40 FUNCTIONAL BASELINE ASSESSMENT REPORT Ms. Sharon Hawbaker was referred to the HEALTHSOUTH Regional Work Performance A and Hand Center by Dr. DeFalcis with a diagnosis of DOD cervical/myofiscial neck pain. The referral from Dr. DeFalcis was for Ms. Hawbaker to participate in a daily Work Hardening program for two weeks at four hours per day. Ms. Sharon Hawbaker is employed by the New You which is a hair salon. She reports a0 being employed with this company for ten years. Her job title is that of a barber/stylist. She reports the following positional tolerances as being required for her job: standing, walking, bending, squatting, forward reaching, overhead reaching, gross motor activities, and fine motor activities. She also estimates the following lifting requirements of herjob: floor to knuckle lifting 40 lbs. maximum (lifting a child into a chair), knuckle to shoulder lifting and shoulder to overhead lifting of less than 10 lbs. (clippers, towels, hair dryer, 'A etc.) and carrying of less than 10 lbs. (supplies). She specifies the tools and machinery th9t she uses as a barber/stylist as including the following: scissors, clippers, combs, brushes, hair dryer, curling iron, etc. At the time of her baseline evaluation, Ms. Hawbaker was reporting a pain level of 4 out w of 9 (mild to moderate) on a 0 to 9 pain scale. FUNCTIONAL BASELINE ASSESSMENT RESULTS Ms. Sharon Hawbaker participated in isometric strength testing during the Functionaj? r ? I ? b o w Baseline Assessment. Her results indicated appropriate horizontal changes on 3 out of 3 x tasks thus indicating valid results. Her heart rates, however, on 4 out of 5 tests did net increase to the expected levels thus questioning maximum effort. Also, her efforts oatwow out of three isometric tasks were below the recommended weight limit at which "neaFly all: " healthy workers can perform over a substantial period of time" (PIIOSH, 1994). r r = Dynamic progressive lifting indicated patient's ability to frequently lift I 1 lbs. from knuckle to shoulder level and frequently lift 21 Ibs, from floor to knuckle level. ThesE " M t7• C% Cn _ H n v C r 840 North Front Street • Wormsleyburg, PA 17043 • 717,975-3337 • Fax 717 971.3973 = - ,O A Functional Baseline RE: Sharon Hawbaker results indicate LIGHT level work (DOT category). Please refer to pages 4 and 5 of the A enclosed ARCON computer sheets for additional lifting data as well as subjective comments made during testing. Cervical ROM was measured utilizing the ARCON computer inclinometry system with results being WFLs/WNLs. Please refer to pages 7 and 8 of the enclosed ARCON A computer sheets for additional ROM results. A standard Jamar hand dynamometer was utilized to determine Ms. Hawbaker's current bilateral grip strengths. Her RUE grip strength equals 51 lbs. and her LUE grip strength equals 41 lbs. The patient is a right hand dominant individual. A A Kasch step test was attempted with Ms. Hawbaker to determine her current cardiovascular conditioning level, however, the patient was unable to complete the 3 minute step test due to being "exhausted". Ms. Hawbaker had I minute and 58 seconds remaining in the test when she requested to stop testing. A At the conclusion of the Functional Baseline Assessment, Ms. Hawbaker reported a pain level of 4 out of 9 on a 0 to 9 pain scale with specific complaints of increased "tiredness" and "heaviness" throughout the right arm and neck. COMMENTS: A Ms. Sharon Hawbaker is scheduled to begin her daily Work Hardening program on Friday, October 23, 1998 at 8 a.m. Her program will include a variety of components including cardiovascular activities, a multistation gym program, total body flexibility exercises, proper body mechanics and lifting education, and specific job simulation activities to improve her work capabilities and overall endurance. Thank you for this referral. If you have any questions or concerns regarding the Functional Baselin sessment performed on Ms. Sharon Hawbaker, please do not h it a to conta m at 975-3337. Donna Lorince, OTR/L Work Hardening Coordinator d cc: Dr. DeFalcis Allstate Insurance Company n r S s ^ r a :r A r ? z i r1 Cr ur A A HE4LTHBOUTH. Work Performance center 840 North Front Street r, Worm/eysburg, PA 17043 , „ t r , • e P n r, Phone (717) 975-3337 Fax (717) 976-3973 , i- X1•1;r PA 17(55 PATIENT INFORMATION: Patient: Sharon M. Hawbaker Address: 124 Woods Drive #10 Mechanicsburg, Pa 17055 Phone (H): 717-795-9286 Initial Visit: 10/21/98 ... Referred by: Dr. DeFalcis A ... Resting Pulse Rate: 100 ... Blood Pressure (sitting): 140190 Physician: Dr. DeFalcis Tested By: Donna Lorince, OTR/L a 0 M 40 W W 0 j 1]3!.7187428381 Ltu I)OB: 03/1r,5/S'2 I Age:. A6rl i fM. F 1-! 7 5 5 Height: 94 in Weight ISO lb Phone (W): 717-732-2174 Occupation: Barber/Stylist ... DOT: ... SIC: Employer: The New You Insurance Co: Allstate Attorney: n/a 10/21/98 V b n r" n r T) n r ' T n rf CP T T I . p C (-, 7 2 s lJ- -y (Y v r N A A A N go a!e Sharon M. Hawbaker 10/21/98 - Page 2 II'?iilly??'i?14 ?"iti41?'I,'`??Key1?!?4'#eaiti'Yili'.hi (f?ir4n :?t 11 N?'wi u'r1?'t ?:i:. ;l ?J:q !?'u:. II!;.i'II!L?tl!, •1:Irlllill!II ? c. BGINNI Gl v r r r fnlSr., .i'?q'R.fMllPlll' I ENDING n d 7Welght lb oad (Lik'e Nothing) 8 - (Very Heavy) 0•- (No Rain)1 i L3- lu I I ? " I Mild) ) Heart Rate (Target = 130) 99 -116 The Figure to the right shows the patient's heartrate response during the Dynamic Progressive Lift. The X-axis shows the = weight lifted at each level of the test (in E " 2 pounds), while the Y-axis shows the 9 40 # patient's heart rate at the end of that lifting ,x 30 level expressed as a percent of the patient's 20 age-adjusted maximal heart rate. Welaht Lined ILb) 1100AMMMOANIONOM BEGINNING ENDING Weight Lifted 11 lb 21 lb Perceived Load 6 - (Medium-Heavy) 9 - (Too Heavy) Pain Level 3 - (Mild) 3 - (Mild) Heart Rate (Target= 130) 97 127 The Figure to the right shows the patient's heart rate response during the Dynamic so Progressive Lift. The X-axis shows the = 70 weight lifted at each level of the test (in E so i b o pounds), while the Y-axis shows the 9 40 patient's heart rate at the end of that lifting ae 30 1-_1 o va o ..? . f #hn notin..Y .. 20 11 age-adjusted maximal heart rate. r I o 71 Wei ght Lifted M W r 0 • v r _ F r ..? .. to . n .+ r n to n >, r • ? A T ^n v a _ a tJ a•.. v Ln ?.. ,• s fl J 0 ?• N A , -J Sharon M. Hawbaker `?Y' WHOLE-BODY ISOMETRIIS STRENGTH TESTING A 04 e°y f'-A 64 10/21/98 - Page 3 ©1995 Phillip Osborne, M.D. i,f.h POSTURE H Distance ' ' V D)stanc "', '"" RWL• RESULTS Squat Lift 10 G " "F r A42 It i 51 17.8 lb Back Lift 15 • i5 , 30 lb 33.2 lb Pull In 13 02. ; i • •+ nfa 1755 20.9 lb Push Out 14 49 n/a 27.8 lb High Near Lift 10 60 40 lb 28 Ib Recommended Weight Limit is the level at which "nearly all healthy workers can perform over a substantial period of time" (NIOSH, 1994), H CHANGES H Distance V Distance RESULTS APPROPRIATE H Squat Lift 20 6 10.3 Ib Decrease? YES H Back Lift 5 15 60.3 lb Increase? YES H High Near Lift 20 60 14 Ib Decrease? YES I? Validity Summary: ! Minimal Effort (< 15 pounds) on 0 of 5 tasks. Effort below Recommended Weight Limit on 2 of 2 tasks. Inappropriate horizontal strength changes on 0 of 3 tasks. Bibliography: ?.r Berryhill, B. H., Osbome, P., Staats, T. E., Brooks, F. W., & Skarina, J. M. (1993). Horizontal strength changes: An ergometric measure for determining validity of effort in impairment evaluations. Journal of Disability, 3(1-4): 163-168. U.S. Department of Health and Human Services. (1981). Work Practices Guide for - - J Manual Lifting. v U.S. Department of Health and Human Services. (1994). Applications Manual fd( the T Revised NIOSH Lifting Equation. c? n n ? • - n t T Cl I.1 (? f. n -• L Y !1 Cr ,. O ?i N A A A M 0 00 W r 0 Sharon M. Hawbaker 10/21/98 - Page 4 DYNAMIC PROGRESSIVE LIFTING ©1995 Phillip Osborne, M.D. PROTOCOL: CERVICAL (Knuckle: lprAQulder) BEGINNING' N 1 Weight Lifted 11 lb I 11 lb Perceived Load 1 L(Like Nothing), I i . , >31 t (Very Hpavlr) Pain Level o Pain) 3 - (Mild) Heart Rate (Target =130) 99 116 Reason for Discontinuation of Testing Psychophysical: Examinee rated current load of 11 Ibs as "Very Heavy". Lifting Capacity (DOT Category) Indicated by this Performance Light Compatible with Isometric Performance? NO Heart Rate (beatarmin) Cumulaff a Work (11 ?ft) 116 e0v0 6000 t60 d000 126 J000 tOD 2000 76 1000 6D0 1 2 3 d 6 0n I .. v o PROTOCOL: LUMBAR (Floor-To-Knuckle) (1) BEGINNING ENDING Weight Lifted 11 lb 21 lb Perceived Load 6 - (Medium-Heavy) 9 - (Too Heavy) Pain Level 3 - (Mild) 3 - (Mild) Heart Rate (Target =130) 97 127, r? Reason for Discontinuation of Testing Psychophysical: Examinee r,3tedpekt load of 21 Ibs as "Too Heavy". r2 Lifting Capacity (DOT Category) Indicated by this Performance Light o a ?61fl?iF0 f9 00 1196016& F6/(6(M666 % • L /, a '[ R r-. r L a O cc? fJ n w A w A 0 Mil 4d Sharon M. Hawbaker 10/21/98 - Page 5 Heart Rate (beatsrmin) 200 173 160 120 100 -- , r"r r C,?A 73 600 1 2 3 4 k I u" 6 W Cumulative Work (lb-ft) 6000 4330 3000 @dtb 1t(33 5 / 532 4 6 Test Endpoint Cjonditions.for Dynamic Progressive Lifting CONDITION .. a LDESCRIPTI N' Psychophysical Voluntary, test termination by the examinee based on complaints of fatigue, excessive discomfort, or inability to complete the required number of movements during the testing interval (cycle). Physiological Achievement of an age-determined target heart rate (based on a percent of maximal heart rate). Biomechanical Achievement of a predetermined anthropomorphic safe lifting limit based on the examinee's adjusted body weight. Safety Intervention by the testing technician based upon an evaluation of the examinee's lifting posture or technique. If the examinee is observed to perform task while maintaining a horizontal distance of greater than 8" from the load or to perform the task with feet closer together than shoulder width testing is discontinued due to High Risk Work Style. Physical Demand Characteristics of Work as r 0 0 PHYSICAL DEMAND LEVEL OCCASIONAL 0J3% of the workday FREQUENT 34$0% of the Workde CONSTANT 07-100% of the workde Sedentary Up to 10lbs. Negligible Negligible Light Up to 20 lbs. Up to 10 lbs. Negligible Medium 20 - 50 lbs. 10 - 25 lbs. Up to 10 lbs. Heavy 50 - 100 lbs. 25 - 50 lbs. 10 - 20 lbs. Very Heavy Over 100 lbs. Over 50 lbs. Over 20 lbs. .?a $$ yS 'y i yY r x ?r r (1) Pt. reports feeling "exhausted." She reports "pulling" in the neck, "pulling" Icll IbICIII III, at the cUOCIUSiOll of the Iloor to knuckle lifting. - :p ?,., r n = A Bibliography: r n ... b Garg, A., et al. (1980). A comparison of isometric strength and dynamic lifting capacity. Ergonomics, 23: 13-27. rt .t A w OR Sharon M. Hawbaker iai 10/21/98 - page 6 Mayer, T., at al. (1988). Progressive isoinertial lifting evaluation: A standardized protocdF and normative data base. Spine, 13: 993-997. i.r hI c'.:nn U.S. Department of Labor. (1991). Dictionar ,& tdcbFatidtNTitles, Vol. Ii (Fou'Rh Edition, Revised). I V E Is'j t/ 15/52 I + CAO ;.erllE t+t-3755 + w a 0 40 W W to r rl .. ?r N T T - - n t T n z s Q' r? \ n - (n o r . \ .r .? o ? N A Sharon M. Hawbaker 10/21/98 - Page 7 ARCON ROM - Spinal ROM Inclinometer Report: t tl , ?? The patient was tested in our facility using the ARGON ROW'dbthputerized dual inclinometer system. This system is designed to quantify.an individbal'•s'sbNtral rAnge gfmgtkon (ROM) in the cervical, thoracic and/or lumbar regions, and to t oldpare these R valges,tq rocgtgnized population norms. n A KS M !d 00 W 11 17 T ,T • - a a t From "Guides to the Evaluation of Permanent Impairment", Third Edition (Revised), American Medical C! Association, 1990. r' t The AMA "Guides" validity criterion is three consecutive measurements within t5° or±10%of mgtliah value.; t • (--nia - marcates results that are not available or applicable for the listed task) A t^ ON r"o 0 W M t1o too Sharon M. Hawbaker 4 10/21/98 - Page8 . Cervical ROM Impairment Report ,. 1," Test Date: 10/21/98 1 Movement Description iRaltge: (, I V ' 1 Cervical Flexion Occipital ROM ^ L' 42 (. t 1 46 P A 47 1 52 51 TI ROM ? 2 0 0 ( = 520 0 1 Cervical flexion angle 4 46 47 52 51 110%or5°7 Yes Maximum cervical flexion angle 154 '34"1? ^!'+IE G>I-1755 's impairment 0/6 0 Cervical Extension Occipital ROM 61 64 TI ROM 10 13 Cervical extension angle 51 51 1I0% or 5° 7 Yes Maximum cervical extension angle 52 % Impairment 2 Cervical Ankylosisin Position (Excludes my impaimtentfm abmmW Flexion/Extension %Impairment 0exion/exlemion motion) Cervical Right Lateral Flexion Occipital ROM 4 44 48 TI ROM 6 11 Cervical right hat flexion angle 38 37 110% or 50 7 Yes Maximum cervical right hd flexion angle 39 % Impairment 0 Cervical Left Lateral Flexion Occipital ROM 37 37 TI ROM 0 0 Cervical left lat flexion angle 37 37 110% or 50 7 Yes Maximum cervical left lot flexion angle 40 % Impairment 0 Cervical Ankylosis in Position (Excludes any impairment ter atmomal Lateral Flexion/Extension %Impairment lateral flaxionlextensim motion) Cervical Right Rotation Cervical right Rotation angle 70 70 :H0% or 5* 7 Maximum cervical right rotation angle 72 % Impairment p Cervical Left Rotation Cervical left Rotation angle 73 70 ±10% Or 5* ? Maximum cervical left rotation angle 7q ---- %Impairment 0 Cervical Ankylosis in Position (Excludes any impairment for abnormal n Rotation % Impairment rotation) < r ,^ Total Cervical Range of Motion Impairment > (add all ROM impairments if no ankylosis; 2% use largest ank losis impairment value if ank losis is resent r' Note: Shaded column shows which measurement (of three consecutive within 5° or 10%) produced maximu ! R?,M value.,- Op U1 fo v r) .n N w IiW 40 x? HEALTHSOUTH Rehabilitation of Mechanicsburg CHARGE SLIP Clinic N2 & Clinic N10 ry (643) DATE ll "1? 2_yA )n f? Ticks Thenphl: Visltq or Ahtharhed CX NIS R/S RX .spires: Department Code: _ '?/•?• 6j u[r'[ ,,IVf6? c.NA CQry .. c ( I Yt i? enc. PA I7;5 y ( ?%tyiSz I ,?l I l ???Z 1'?f/.YI R/vv r . DAIL TE SURIP.CPIVE: ?UnrcmarWhle ?No newromplalny , r__cdl naxed pain after last visit O Patient pain level @ _/10 A a8'/ 06 to w r PLAN; 0 Upg¢delaetlvitles as talented/per r Comments:.. -kAm-d.) m D 0 Therapy TIIERAPI.STSIGNATURE: ??A1 i IVI. ?""'-x ?US''?`C 1t OZO'iP V` ?• sTOTAL CHARGES: TOTAL UNITS: CO-PAY: A:1Chrgslip Disk1CLIN2-10. DOC: 7/98 Diet: -? Meh Reset: Reset: PP ant toles treatment well 0 flame Exercise Program reviewed The gxerche Program advanced as per flow sheet Comments: 7 leN ?X.Y T i- Qi+i An /wL ?A•?!/?J lI) .+// ?1 /? t!L 17 /?1. V A HEALTHSOUTH Rehabilitation of Mechanicsburg A CHARGE SLIP -Clinic N2 & Clinic N10 (643) t A QJ(02- 43) [ DATE ; Tlcket a 11 Zid T'herap4: YIa1tN Authorized CX N/9 R/S A RX expires: Department Code: .. e H 04 Itg M =I M 9!? eel L, ;F:d It LAN " (tIv( tl' PA 17('55 15/52 ./. /r ,l ,;•111 9111+1???`?llf Gal -3755 4 ASSESSMENT: STG Cement: -: Met: Met: Reset: Reset: 0 dent tolerated treatment well ? Home Exercise Program reviewed ? The Exercise Progreso advanced as per now sheet r PLAN: M Comments: THERAPIST L TOTAL MUROES: - AAChrgslip DUICLIN2-I0. DOC. 7/98 ? Discharge from Physical Therapy rye ?0??2??f ?? (.(YN ,C(?tVWI• •a. rnoev.... DAILY NOTE - ' A r???, X011 *OJ LX-SOU SOU'1'11 Rehabilitation of Mechanicsburg SLIP Clinic #2) & Clinic #10 ?'r I I 77 teak).. _.. ? (02 643) ('?? 7'leketq Io?C( to V.C f' Authorised A N/S R/S nde: i, it f // DAILYNOTE SUIIJNCTIVF: II Ihu'annrknble L9"Noae+rromplnhrG ?Incresurd/decrmaed pain anerlast visit /Pat, t Palo level@-1/1a 1'.01ee11 Reporls:__ __.__- 74 _ OR.IEC HVE: Aren't'reated: _ CSC _ Snelling: ?-? 4 Ecchymosls: R0111: Sir,.p:nl?r,r -. i?•f--(-T ??f) e r hrvi e - L_ff 1dQda2.?_. 00530 PT Eval '/, hour 011535 IVeutpmuteularRp Ed Y kaur 00720 _ 0T Eva1 Ye hoour 00517 .I~rtiene/Patnlly;&d %r hpuf ; UU605 _ PT CE 2 hoUn _ 00309 Milat heat T min tlOGtl7 _ Of WNW 010ficityEvalIhour _ Otl533 CP 1coMaaspgp:'• min 06.114 _ PTE rgonomic COliauli U4 hour , tl0506 U5:5fngle ennt/puhe W/em2_ 60904 OT PCE 2 hours ' 00527 _ U5 Comb crinbpube?^ W/ttu2 OU91U?,,, OTPhyalcalCapacityEvallhour OOSOB; ElecfrleStlm ' minalo.; , 00806 _ OT Ergononile Cnnault %. hour , _, 00$15 Iontophoroa[aQ lifA min S tat) 0 0331 00331 _ PT Yaheur PT (Joint mob) % hour to 00$16_ Yhnpnphotxait ;__{Y!(rtz2 x .. 00424 bT inlHat T hp'nr tVprk Ilarebl0g :: M ley 00725,E OT addltlohal l Lour Work'Hai`dFNp 00310_ i hfFR to 0914 OTiOl3.9iLR6Nhbrlhour. OOSIO Massage ., 00610 PT Ipitisf 2 hops Work Asr lening 011721 i 7 OT'/, houF oil l PT odditionai 1 hr Wotkllakdcuing ; 00 23 O C ADL tralnilig Y. hour 00609 PT O/S & IRehab 10 17190_ CSTraetlell : Statie_ 1nt L, [1 ?('}' ?' C1ak S Ills, a on ibs off i Min_ f 17190,_ IS Traction: 5opiao___ __ ` - Ibs On Ibs ii f :min G ASSESSMENT: ?/ i IB.+? (r.n. r li+inn.• 6 `}' (e PY"'<J+1 rr t .si < t?.+.. haul ('k g •t7?1 )t.b :..m car llL( (? ?' / l 1 (' STG Current: . LTG Current: l r Mel: n4.1.- L1 Patient tolrnded treatment, ell ? Home Exercise Program reviewed ? The Exercise Program advanced as per Row sheet n I) 1_, ' \ Couuncnh: _ ,1_I ._ IL>1)-ZS?tw1? ?rsl/- ('?,.ry , ?. nx?d al(?it- fz.! ( L(, II CS`._ r PI_\N:_ ?I llpgrndr ncliviRns s tole-=algid/per protocol tl Discharge (mm Physical Therapy C.'mnmenls: ..__._-_-._-_.__ (< )) t ( ___ _ )i 'fIIF.RAI'1.5T SIL'NATIIRF,: (ice ?/. /jl r7•..i o?,'L / .?l7p?r T*r C?-CVL^ •{?-21.pJJ?/'i .l tic •r.,Ta nv....?..... ___._ -_.___ 11 A 1('higrlip I IlskWl iN2-10 . 1)0(', 7/98 n 6W HEALTHSOUTH Rehabilitation of Mechanicsburg A CHARGE SLIP - Clinic H2 & Clinic #10 (647) (02-647) BATE Thcraid II-10Z : r7Y1 Zt 161t fl_-I__ or_ Authorized R/a RX expire,:__ Iftepariment Codr: -- ___td sunJECrim rl Unremnr4 A Patient Repool:_j . OBJECTIVE: Area Frented: ROM:-_ /./; t J+ ffirenith: •• O.W. new complaints DAILY NOTE 0 A{I `I • I V) A 1 )) I ^. after last visit O Patlenl pain level@ln Swelling: Eeehymosb: / JM 60531 PT Evil V. hour 00435 40 011726 OTEVaI %boar 00517 00665 _ PT.$CE 2 hiure 06509:. 011607 PT,Pby7ical Capaolty EvalI hour 00333 ` 005114_ PT;Ergonamie'Consult%hour 00506 00604 aT I:CE 2 heurs -00527 y 00816 oTPhyalcalespacityEvnlIhour 00308_.<.. 00806 UT::ErgonolnlcConsult Ye heur 00515 .00331 PT.Ya haur . 60516 1 00531 _ PT?(Jointtoob).% hour to 00724:V Grades v?__ 00725 40 • ow ¦• 001141 massage. J 00610 PT Inl6al2 hani• Work Harde 00921 OT,?'/. hour 066t i Pt addilionii [ hr tVork Ha 00723 UT.ADL training r/, hour - 00609 _ PT (A & I Rehab 17121) CS Traction : Static ant . Ibs on Ib 6fY rain ZJR 7V 17190 45Irtaction: Static: Supine : Ibs on Ilis Off min ASSESSMENT: STG Correnl:._ J i,l //J1, !(i ITG Current: / r•.? Met; Mel: Reset: _.--_-_-. Reset:- - 1641timl Iolnaled Ircalmenl well U Horne Exercise Program reviewed I. ) The Exerche Program advanced as per flow sheet 4 0 - - PLAN: FIJI R' cnellvl es as Inleraled/per pi Moroi 11 Discharge ham Physical Therapy I Y / l . 71 1 11 ) ) ?1/L • I'? /-, I )e_r,,_ I III, It 11 11 •He.N•111111 La1 I _ - ,. . 1 A:\Chrgslip I )iskICI.IN2-1 U. 00C . 7/98 w 44 W HFALTH90UTH Rehabilitation of Mechanicsburg ['I 1 q ? ? ll r.r CHAKESUPt/Clinic N2 & ClinicHlll r..dr(I•I 1v( (64,T (02.643) nn'rE1!_)!?Q Tic et a?Z?lf'//r31t t :; 15; 51 1 Ilia" Plsl:_ ,I r.;_l?](.(tfl[/l__Ll.(?I 'P rr•I ? ' 7 1 1 Idl f Authorized A OX N/S R/S 1 4!d RX eTptres: 755 Department (fndr:_,____1C •1 OY I d01 E // o A 9110JE(fIVE+ I"I Unr<mnr knble ?Nonew complaints reut?d/ decrcaned pain aaerlutwhit gPoaent pain l <vq((O_/10 I / Patient lteport.:__'c •t? q (, r b i / Jua(I , rl/rICI (_,(, l [r( I t I I OIUECI'IyE: ArcmTrented:_-__?,. Sneluns: Ecchymosb: \ r Slrrn fh - te ( • l e : , a . +c hunctlon: t 'C c -P .[?I t.{?Ie{1 t ' 41L. Q`nnnnen/s: ' - ? ?-ti j, r j 1• If .S (tiL t•> ! r - 17LL (r z?1! ' ?? fP?CI rFYx Yr ?'1•tY.YYnAirY•Jy/lRrtl1['M.FYI!\Ynef'eYY.1T/tiYl'AYYIYYY?:fYYx'I?IYtiMYYY!•• i?fYV WW `i!'iw.l w•Y .011530 A PT Eval Y. hour - 00535 _ Neprpmuecular w 4d Y. hour ao420, '77 7 OT 6011 Y. hour 00517 _ 1+'atlaaU2'ain ly $d r/• hour 00605 _ PT FCF, 2 banns - 00509 Mdut heat Y loin nnl a'r 1•'1' t'hy.lr nl /'nparlty Rvnl l hnnr (IM33 CP, Ire MneenPre s _------ min 111151 I i• 1 ISI I(onumb /'nnPrh Y how 1111'!116 ..... 11!l aluµln W/eu12 ,,_ min ....... (10804 O l' FCE 2 hours - : 00527 - - US Comb copt/pube Wlcns2 mil Un>iln -'OTPbyattalCapacity vallhour' -'. :)05o _ 00806 OT Ergonnmlc Consult ?14 hour : 00515 ?: - lontophoresis @ 1HA iailn $ X L (y 00531 ? PT Y. hour 00316 Phnnophorelis •W/Cm2 x Mip ' OD531 _• , 1?T (Joinktrynb) Ye hour to 00724 T„_ , : Ofinit102 hbur Work.ff0rd001tig ': Grades 007?5 ` OT addlllonal ] hour WgtkHardeWtig 005111 _ MFR to 60814 _? OT 019 &I-Rehab Y. hour (1051D Massage 00610 _PTlnidalItiourWark2lardeaing , 09721 _ OT'/, hour 00611 PT addltian it 1 hr Workflifthning' 00723 OT AUL training Ye hour 00609 PT 015 & I Rehab ` 140 17190 CSTraction 'i Statle_. Int_ _ Cat) !e In A t.t.r+/"b {bson lbsotf coin- _ r )!j {1ifJ t 10 r_t tae 17190. I:S Traction: Static Supive- - lbs on IN off min . . . ASSFSSMFN.i.. (.ll •v(]J Ui:_. .$ks '1 ?I" ilu !\lr?lt if".i tev Lot tit(.' Uarrtnl: I.R. Current: L/ r RIO: Met: Ilrsrl: Reset: ' I Pnllrnl 10miled treatment well ? Home Exercise Program reviewed U The Exe rcise Program rdvanced as per flow shed ('nnnnrnle O-' I`y 1C Y Cd Cd J k (C t eLt r r _ . _ -. . _ I W PLAN: I V rude Activities m olerYled/ cr protocol 1 1 Dischnrge from Physical Therapy ('nnnnrnlc 1111;IMPIS'I SIGNAT U R E 1_I_RL -_1.?1lrLL=L ( /I ••k.1° '??('(Lt'?''/l cY 0 A A A ?74r HEALTLISOU'I•H Rehabilitation of Mechanicsburg I v CHARGE SLIP - Clinic N2 & Clinic #10 r (643) (02.643) DATE. // . b' i/I T'IchelM ThernRct/ Z? _ Vlalt of, Authorized `'. ) :. , f e 'I I E cx _ ws RIS 14% spires: -- DepartmentCndr:_4; _ e'- SlLikl(.TIVF.: ri Patient Repart7 A i .? ORJF.Cr1 VE: Area 1'renh ROM: 4A Strenelh:_ Function: Coroavntn: T EATA DAILYNOTE IMnla ? Increased/deer last visit ? P?that pain level @ __/lo '1 00536 rr4vio %nour uu5.15 Neurooluseularxe-za V4 hour. Mi IN1y2U_ , OT Eval Y, hopr OOSL9_77 ,_„ PaiNnyN niililld //. hour :• 00669_ P71:NCEZhours 00509,moist Wat Y.,,„ 00607 PT,PhyrkalcepacityEvalIhour, 00533_ CP;:IceMasssgtrlx mli 06M4 _ PT Ergonoiitla Consult '/. hour tl0506 TI5 Slagk tonf/pulwl W[ Willi W UC NCE Z hours 00537 US Comb tons/pat - Wl 611H10 OTPhyslealCe paeityllvellhour 00506 E1sEtric9tlm_;rolnrto 00806 OT` Ergoiromle'Consult'/..hour - 00513 1onEOphoreellQ_? M 00.531 7 PTYhour_' 00316_ Phand hot, is ^pl/liitZ 06531 pt (joint mob)-% hour to : 00724_„_„ qT ioitiel Z hour=)YorkHarden Grades 00725 qT u01 lUOnal1 tiour Work Hut (10510 _ MFR to . ": 00!114 _ OTO/9 .fir I lleNab Y. hour 00510_ Muiage 00616 PTleit1a12hour14ork7iardenl 00731 _ OT Y hour On611 PT addletonal l hr W,orkHePd 00723 _ 02 AbL trainliig 7 hour 00669 ? PT .O/5 & IRehoti d .17190_ CS'.Tracllon::5tatle -Int ibs on lb off_ min _ - A 7 c 17190 ` LS Trsetion: Static Supine_ _ 16i on lbs oH , min ' ASSFSSMEN'h > ,? •7,n /II I STG (:urrenl: LTC Currrnl: 1• - r t r Mrl: --- ------ _ Met: `. Rrarl: Rent: It potent fort med h ralrm•111 "on I I Ilmne Ewrl,, Pmpasa reviewed I I The Etudes Prnaram advanced ns per flow sheet 1'nlm...... 1'In\IV:. PI IIi.alnAf nrllulllre na l.rrulyd/ rr prulurnl III/lerhnrer hum i'byvirnl'1'hrrnpy '111FRAPISTPIGNATIIRE:---/7 1J? TOTAL CHARGES: ..? I eH] A:\Chrgslip UisMUN2.10. UOC: 7/98 1' 4 0 HEAL'CHSO(JI'll Rehnbilitation of Mechanicsburg A ?t CHARGE SUP -Clinic #2 & Clinic #10 A f '• '' (647) ? (02643) '• I 'it / , ?? qq?J Y DATE. Zile llrket q 0. Yd L r'A ' ///......f Thernpinl: lll 1G?+Pl) - I 5 t _ visit H_? of Authorized w CX __,_ N/S__ i R/S_ ' Rx exp res:- Deportment (lnde:_ (. . 1 raNl[ DAILY NOTE SUWECfIVE: ?Unrenurknhl e ?No new compWnt! q ?Incrcesed/decree/fed paht after leaf visit P a aen t p ant / { A I'nllent Reparfa:-An). 1`f..dU I /1?.?F.L, ?? FrTZ_ P• , g ` l . ? OBJECf1VE: Aren Treated: Swelling: /J 14 Eechymosh: ROA4: e? 1'- Stroglh: •9i _ .. Function: ! en Cnnw:ents: 1H z-_' 011530_ PTEval %hour 00335 M 00720 OTEval Ye hour 00517. 00605 ? PT FCE 2 boors Ob509. _ 60667 _ PT physical Capacity Eval I hour 00531' 00514 _ PT Ergonomic Consult % hour 005116. 011904 ? bT pCE 2 hours oom 00870 ?„_ OT physical Capacity Eval 1 hour 00508. , -00806 OTE C nsult'/hour 60 515 e1®_/10 I 40 00531 _ rgonomc 0 Pt q hour Ob316 ........... ^--m - Phunopii oresi _ W/E m2 z m1 00531 _ PT (Joint tnob) '/. hour t0 00724 OT' initisl 2 hour Work ITarde i ft Grades _ 60725 OT Wei tlOnalI hour Work HardeWUg 0115111 MFR to 06814 OT O/s & X Rohab y hour:; • „ _ 00310 M83sage 006107 JOT Initial IhoarWorkHardening _ 00721 - OT 9, hour 00617,r pT. addiNonallhrWork Hurdening 06723 OT AbL training Y hour 00609 PT O/s 44 Rlhnb to 17190 CS Traction i Static. Int _ Ihs on 1hi off min- 171911, US Traction. Static Supine- His on ibs off : .. min - ASSESSMEN I.-? ) 1L /4 LTC Current:.,/ ri•.? ?? >F `? R'I Cnrrcnl: 6 atrL•, .__._...___.__..___.___ Mel: to Reid! _.__-_______ Rexcl: 91J r lent Iolm oted Ireatment well Ll Home I:xerrtnn Program revlencd 0 The Exercise Program advanced as per Row sheet PLAN: 'Fal?lp/g5ade activities as folemled/per protocol ? Dlrchm ge frnm Physical Therapy Comments: 'I'URRAPIS'r SIGNATURE AAChrgslip DiskXCIAN240. DOC: 7/98 a 40 HEALTHSOUTH Rehabilitation of Mechanicsburg AI CHARGE', SLIP Clinic k2) & Clinic N10 (fidJ) (01-693) DATE It (/• ?(1. ?; 7'Ic t n 1 ? Therapist:_._ IN.IV?C-_.J,.- I_j..L_ VMII Nof Authorized RX _t j RX N3(s expires. Department Cade. L .._._(;y_.t;__ SUBJECTIVE: UUmremarkable O No new complaints Ob Patlent Reports: I' 60 ., :•A 1, r,q ... , f. I Y t ,•A I I: ,NEE D. , need pain after last visit (3 Patient pain level ® •t) /10 if 0 0 40 OBJECTIVE: l- Aren Treated: C?.x Swelling: ICI. I. F.cchymoels: OL- •J ROt11: J.al _ Strength: -- Function: WC- US Comments: AAJt '•t 1.L•c.'ly 11,1J) 531 SIO_ 5111 W 17190 CS Ttactlon : Sfa 16s on Ibi 11196 1S Traction: 56 ILs on i. 163: ASSESSMENT, kg, ? ,.<l. t r tr- c. r STG Vitt rent: __ c ? y coy.... W Met:_ hour Hur hour c 74 nour OO5I5- Otl516 •to 00724 ? OD725 - 00514 00610 _ 00611 . nr 06609 Ent min Suplue_' min. X.%o tw,v, lxto -- t t 91;- ', t e .?_ LTG Cnrrent:__ ? I Ltil ? rafted tolerated treatment well ? Home Exercise Program reviewed fl The Exercise Program advanced as per flow sheet Cmm?wnls:.__ Y) 1 - L'? ? ? L (.. L, I C C)? -1 }( ?.. n t C W PLAN: Q UFgm.lc activilles a(.ieratedper protocol U Discharge from Physical Therapy Comments: fr THERAPIST SIGNATURE ( x r T?,,n.wome. .. i 1 't AAChrgslip Disk\(.I,lN2-lit. DOC:: 7/98 w W HEALTHSOUTH R itation of Mechanicsburg I ' A CHARGE SLIP(Clinic #2 & Clinic #10 ! I YI OA'rF. III +tiC, Ticket#2 q Theraplah z von C_'. /_T C of Authnrirrd 1 C X ^N/rS R/S - R7C er 71 -0 Depnrlmeet W+?-4menl CAP: _, 1.. ' I ' .. 1 ^ I f . SIIDII?(.TIV_P,: Dihwenmxicable U No new complaints creme /denxase tlnafterlmewlsit 11 Paaentpain level/10 1'nllerl Itrpart:..__- ?I ' rV v \ ? lVv Y?)t"? ORJECI)VE: Aren'1•rruted: ?y Swelling: rtl Eeehymosis: A A' ROhft _lAWQ! .. M 0 40 M ASSPbaman r STG Current: \" 'I- ?aN ;.:. u(' (r jCb _sm?. \rr ll•.. r• 1,11( (:r(crest: ? UJ Niel: Met: r asset: _-___-_ React: ._- LI 1'nllrnl IalernwA Ircnlmenl sell U Home Exercise Program reviewed Ci The Exercise Program advanced as per flow sheet PLAN: k1 fT'pgrode activities ns t lernled/ er pr^tacnl U Dlschnrge from Physic Therapy '1'IIERAPIS'r SIUNATIIRF.:?i Il, }14c:•,,YyUL.?,-i;,_,t p(jl?ct ;?UJ??r/l A Whrgslip I)isk1CLIN2-10. DOC: 7/98 A HEALTHSOUTH Rellabilitation of Mechanicsburg A 'r CHARGE.SLIP Clinic #Z) & Clinic #10 C_f501' (02.647) DA'Z'E I I I ll I'? ?) Ticket H 2 j ty Thernplsl:__,_-?2f visit N_.-IyjAuthorised A CX__ N S RX crplrea:___ DPpartment Cn,41r: _?. •1 SBBJECrIVF: ? Unremarkable Patient Reporta:_' I C I - l9'4a new complaints ph :' .1 1 DAILY NOTE \ Increased/decreased pair after last visit O Patient pain level @ '? tlo , . 11 A !t M W ASSESSMENT'. r -r ' STG Current: __ S,r•\ ?GIflclttiO ki v? LTC CurrenL•_ r Met: ___ - M1lcl: Reset:_ Reset:_ LI Pollent lolernlcd treatment well 0' ome E.xerche Program reviewed ? The Exercise Program advanced as per Rmv sheet J / 1 f:ammenh:-/lj(LLL.E (,r----C?? 1 t o_.1e?t;:v__ cy-3 tx Ia P-i 1Dl r PLAN: rl I lp/glad! netlrllln ns tolerated/per prolnrvd ri J)Hchm'ge frnn: Physical Thorryiy A Corrancnls: _, -/ L J r -mot ??- 1I /?? ! "1'0-? -_ , i TIIIMAPIS'1- 1GNAr1)RF:_?,-,. ?'°- .t \ I / / .)•,1 (7 r( __ / , i [TOT A4 CIIARGES: TOTAL UNITS: -(. CO-PAY: A:1Chrgslip Disk\C1JN2-I0. DOC, 7198 OBJECTIVE.: //e tit/? Amn'Treated: Q.x Snelling: Ecchymosls: ROM: L&_)/,LL - -- Sirenglh: Functlon. ? -e a 04 HEAL'1•IISOUT1I Relln ittlalion oiMechnnicsburg t t A CHARGE SLIP - 'linic tl2 & Clinic NIO 64)) (02.643) DATE J1431 TichetIt L4& vi visit 0 (1 I +J, or Authorbcd CC (V!S R/S ' JRX expiror:_ ei-'`.F!', r ---- 1 Department Cnde: .f?• DAILY NOTE SUBJECTIVE: DUmxmmhable BTh.new complaints 0Increased/decreased pain once last visit /Patient Palo level@A 170 » Pallenl Rcpnrlsa-' l1 I I _ 1 \?tiIt. y_ ?_ _. ?? , v?.. l v l 1 K C ?L.. <<. l l11`) C+-' 'lC (Q LJ r -r. v 111 l- W-?- 1lt.' 0IlIEC'1'IV Area Treated: L IL Swelling: N A Ecchymosts: ROM: -L c, 4 to Functiln: FtlneltOm: 3t.(<rt.r tM?al [').4 f'?)•.•,. ? aN<nie. \[L_ el.v\ne,e'-ry? Comments: Mi_ _ 1c [ K B[he. M r U k y .n... _ -.. _ _ .. _ _ l . _ r. 6036 PTval'/e hour 00$35_ 6072U OTit'vel Y,haur ; 00517 M 00641 _,__, p'T FCE 2 hour 00509 r 00607 070kikeiCi0ki4iEvtlllhour 00333 00514 PT Brgonolnlc Cantflit Y. Abair b05116 60§64 __ OT FCE 2 hour ;` 00527 669i6 'OTPhyaltslCepaeifyEvellhour OOSpg W466. 6TRrgonomlec6neult I hour _ 00513 011531._ PTYhater; __ bb316 M 1111531.?„.• PT (Joint mob)'/. hour to _ 06,724 Gradef 00725 4.V' peplepgC ' ' " nnpul _ PI MITI ZaOur. Or1(Hardclung tl0721` /, hour gT 00611. PT additlon ill fir. CVotk)Elerdoil 00723'' OT AbL training''/. hoar 06669 PT.O/5 & IRe toff 1 7 1 9 0 CS T r ottlon : Statlt M o Ibt Ibe off- n ` , min 1 7 1 9 0 LSTraclion: Static T Supine`. : Ibd On Ibl o1t <_. min . :. ..:: i??1cAs :unvt A, cle(.ct A'^ I t.n.. 2 • ie• 3' ASSESSMENT:11r a s ko I (:nee It, - <rl I (? n'.? J STGCurrent: ._..._____.__. LTC. Current: Izi V Aloe: Mel: r Reset:__ _ Reset: -' ? Pallrul tolerated Ircalmenl wNI A' Ilome Exercise Pro ram revlesred fl The Exerrhe Program advanced as per flow sheet I Comment.-: IZxr.-lV 0V V*t Lein s?) \1+\( %It. t c % -1 v tit t: . PLAN_ ? Upgrade neuvl0es ns lolernfed/per protocol D Dhcharge from Physical Therapy r Y Comments:.. 1'.I SP g-: MO{I ?e' 2 'S l(!I+w• Il •.lr-Ql . .i??1} i>1C•_.. <s'[.. li C TBERAPISTSIGNA'runr4,.'Il 'ttE-J -t'} 1 • !l M. /7 r , ?'j/S 4 .A Whipsiip lARMCHN2-III. DOCK 7/98 A f'. A I HEAL•l-IISOIITH Rehftbilitetion of Mcchnnicsbui-g CHARGE SLIP- Clinic tie & Clinic #lo r• (647) !(9-643) DATE ;r Ticket# Thetnpisl. Visit N-?_ _ of_ Authorized A C.X ii NIS Y wi; RS expires: -I - UepmYntenl Cnde._ SUU.IECHVE: I I A -Unremarkable Patient Reports:/i i 1rsu M M E7 to OIWECI'IVE: Aren't ROM: U o nrn complaints A" ' ALL;N I Yt rA r t tl( I:. dnt11E DAILY NOTE 17 increased/decreased pain after last visit ? Patient pain level (o) -/IO / b, f y ir,= Zri ASSESSMENT: I ST(: Current: Gif.^ iA LTG Current: nlel:. _----_ -=-------- -- Met: Reset:---_-- --- Reset: ... -- 1YPatlent tnlernted/treatment well ? Home Esemise Program reviewed 11 The Exercise Program advanced as per Row sheet Comments: /t./ •?? PLAN:_ t7?pgrode activities ns totermed/per rnto of / t_I Diachnrge from Physical Therapy 7 7'nEftAPISTSIt:NATURE:_? ) t r,?J TTNr!/ 0 A,1Cht7ts1ij,IrisklC1.IN2-10 DOC, 7/98 A Allill AGAN h).".:1 Il NEALTHSOUTH Rehabilitation of Mechanicsburg r ? ?? p ?• ?, y A ` cIV! SLIP e(643 & Clinic HIO "A 5 fpy (02-643) 1 1 `.• S 1 Tlckela 2y - i 1 , LI)MATF, or / N ws?/?7 S ndr: f DV ,V NOTE $l1BJF.CI'IVF: II Unremarkable C No new complaints /decressed pain after last visit 0 Patient pain Intl __jIo Pnllern Repatl^•..--?--11r'.t le `)Curl `zP t \Cs(1'Ji OIIJECI'IVE: Amn'1'renled: ?..y, Swrllln ym R: ,3 Lq Ecrh osla: ROM lStrentills FiFt Func Puncnont hs. 'rt 1 1 1. ?(i'• .( ty .L r'C r ') _ ',(n? -Lv Cnmmenfa:.(`1? yJ..G?_?lr•r L Z )I), (S IL I ?y)_34r, ClYt. KVIA-* 005311 .: PTEvaI'/.haur 00535 Neuromu.eulerA0,2 Y,hoor 6120 OTBvAl Y4 hour 00517 PotientYPamilyBd'Lhour 6605, PT FCE 2 flours 00509 . 0 at heat 00607 _ PT Physical Capacity Bval t hour 011533 CPI Ice N(sjfaga : 00514 - 7 PT Brgonoiuic Coneult '/. hour 7 00506 _: V5 5tngle eunt/puli? (yhMZ ' , to 00904 OT FCE i hours , 00527 •? US Consb eont/pahe : ' W/oml 00510_ x : OTPhysicnl Capacity Evat l hour - 00508 EhrfrlC Stiln miut.to ' .00906 _ 0 OT Ergonomic Consult! Y4 hour 00515 _ lontophorcals ?a :' lilA mhi ti M L 06531 _ PT x44 hour " 00516 ? Phonophoreair pV/em2 x tut 00531 PT (Joint rdob) Y hour to 00724 Or Initial2 hour Work 11ard.thbig Grodcf ? 00725OT additional I hour Workf#ardehl6g '• 011510 h1Fit to 00014. OT O/S & I Rehab Y. hour 00510 Massage '.. _ 00610 PT labial Z`hour Work Hardening. 11721 _ OT V. hour Doti I _ PT additioiiat l hr Work Ilardching . r 00723 _ OT AbL frothing Y. hour OUt09 PT O/S & rRchob 17190 CS Traction i Static- Int_ Cy-? ?7 . if c!? 4-, lhf an Ibs od min y ,c_ 17191) LS T tl roc on.. Stall Supine_ .. Ills on IN Off ... mi ASSP.SSN1ENT ' yh r C C •i «ppr?t• VxL iC pa.,,n rb r'1' (Ins hr ?k.. V s f i. is rl ??• J''?' s •m eu 4LU•I"? t?'• u Sr(: Current: w LTCCurrent: (L:t1-1J fal Ed' Met: Niel: Resel:_ nnrl:_ 11 Pallent loin aced treatment well ? Home Exerese Program reviewed `ZI•T`I¢ Exercise Program advanced as per flow sheet Comments: _._..,LL tL>_ y-Z I )-'Zuf incl 0 0 k t, 11 C_ PLAN: ktd 4grnde activities a. olerated cr protocol C Discharge from Physical Therapy Caumwals: vveunrLSrncrvn'I'n1tE: ! J!'.?..7 ?/ II/')•._ i )JJ (r/l.t?-/ ¦• A:1ChrgsHl) Disk1CI3N2.10. DOC: 7/99 A 411, .....A%t 61 '?' 1) H13ALTHSOUTH R ilitation of Mechanicsburg I: H A F C II A ) I vt nic # & Cliuic #10 CHARGE, SL C PA (02643) (643) '' tl L l J ' ' l1 I I'1•,:51 1 Tkke10 UA E _ . Visit H I o _ or__ Authorized I ( i A ex _ NIS R/S RX eapIrra:_Zl, L/ MLww - 1 "I E 111-3 755 Department Codr.__y!,L •7,_ 7 U TE SUILIRCTIVE: I I Ifucoarknhle C7 No new complaint, crease decrcated pair after laat visit 0 Patient pain level@ /10 9 Patient Rcp.. itr:L"___J-f ;Y. .. ltiln cSl L.F A -S ORIF.Cr1VV F lli E ??.'1 ,) h l Swe ng: \rc,, Trrnled: . ROM: J ( L s AI L+ Ecc ymor s: tlM . S1rcugIL: c - t?1 11? / r ^ e U I r' rt Rff1ul C-. ? C1E ? = ? Funcllnn: L. r 1 r • I vv d(-riL i rl (,d -? Cl7- . L ?r < 1? .°'?: •,, r r+ .? tsn_1 l 11 ' I ? Cnnnnenla A/k L-?Lrs=?u?lt? ?` ? pt7.p^ ) L _?11 f?+_1.Liu?.ALLaS. C 00530 ` I TMal r/ huur 09535 ? Nruromuaeutan At4d Y, bunr 00 0920 • OT Eval % hour 00517 _ Pallent/ Ikni1[y W/4 hour.; __ - 00605 PT PCR 2 hours 00509 ` •Molti heat Y :': min ?. 00407 _^ - PT Pbysieal Cupaci/y Fiat I hour 00533 CT lea Nlasiage x ii 00514 PT;Ergonomle Conduit /. hour tlo506 _ U551dgle ront/pubse_ _' VI , 6064 - OT FCR 2 hours 606k y w &ftfb eont/pulse VY IN8t0 OT PhysicalCapacityEvala hJur 00508,,,,,,_, Electri?Stlm :: minato..•:. 00806 OTErgonomlcConsalt %bour 00315_ loot ophoresli@ INA 110531 _ . PT Y4 hour 00516 Phunophoresis W/crux 00531 OT (doint mob) '1/e hour to; : OWN._ ETC nitial 2 hour Work Verde, _ (fades 00725 :hour WorkHe OTsidditionall: 60510 MFR to 06814 OTO/S+&IRalab!.hour ` 011510 TVlsrsagc 00610 _ PT Inltial 2 hoar Work Pfafilel _ 00721 OT:'/, hour 006114 PT?additional1 hr Work Ho 00723 , OT ADL training'/ hour 00609 _ PT (A & I Rehab. 171.011 CS Traction : Static Int (y? a 0 2- '4 Ibi on _ 1Ui off Irvin L? 171901STractlon: Static- Supine Ibs on lbs off - min ..I?(rrr,..'i'.,Thal l?':. .??r wF4 (,.-??.., (i •?v ',.,..Jett v-.. .i,c/tc., r't: ..7 L0 Ct,) ASSFSSMF.N14?1, 1 ,I CL?t'y• ?il //i. kr, uhf rt }1,LV.I[ffFs ? STC Cnrrenl L L . ITG Corrrnl: F 1 Gam' f"7- 1-0 Met: Met' Rtset:. _ - Reeel:_ '-. LI Patient tnlernled treatment well ? llome Ric, else Program reviewed 0 The Rreer?rise Program advanced as per flow sheet „ t ti - . fill • I, Commenta;_ ) Lh1?,Lr .r?l L% e - V J , ?L..._z.1L-Ll: t•IT T?Is 1 f/zAG- L? Q( ? PLAN: L147n?rnde activities nn fnleratrd/per protocol ? Discharge tram Physical Therapy f7 Cnmmrnta: ?j.-? ____-_-_ _ ___ v 'I'1 IRIIAI' IS 1' .¢ICNA'I fIR P.: AAChrgslip I hsk1CI.I1,12-I0 . HOC: 7198 A (A 04k A HEALTHSOUTH Re _ •fitation of Mecharlesburg I e F G'+ h) r t I CHARGE SLIP - ,linic H2 & Clinic N10 I v( (543) (02-643) ' P A I i DATE 'u Zi0?' o Ticket p ? ? PI Thernplal:_.__a ca 1 r1 t? - ) Visit a_A=_nr Authodred r.'X NIS R/S_ Department M 06 go a SUBJECTIVE.: 0Unremarkahle 11 No new complaints NOTE uusm maJpage ... 00610_ PTLplNal2hoar;Wotkfferdetiing, I. 00721_ OT%hoar 00611 _ 1'T eHdittaniifhFVlotkYYetrlening W 00723 OT AbL trnlning Y hour 00609 PT O/S & I RchA6 17140 CB Traction: Static Int IN an IN off_ min 17190 _ IS TfliCtinnt Static SUpine •__ IbJ.on Ibi!off min (j,'t 3a12 ef•p.<,?, IK..i t, b(w S1?+Iiw. 3)-Fr,. Luc .c,:' 7Jav1 r?c.hUl,fl.??. ASSNSSM1fEN'fy2j"P rlt,r hr •, In 1 'Iw ••, c:.R Ico / S l( J VI (maul: \\? , CI'Cf mural: Atrl: __ Met: __ - Itesrl:__ __ .-. __ Ree??el:?? -- I.I Patient tolerated treatment well 1`1Lrsome Exercise Program reviewed BThe Exercise Program advanced as per Bow sheet Comments: I?I IU?'Ctl[:Il'Ol ' x fzll'r<" - o.rr"•J ' n4) 1'r ku MIf ,r, 1e IC? PV)tn rr, air 'w PJAN: f`UPgrade activities Comments: M s U Discharge from Physical Therapy OR1EC11VE: - 1 Arcs 1'realed: _?. _ SwelUng: l1? Rerhymorb: /_ Reng Strengli 1 :fir--- -0 hi i h::??p?_-" R 6 1C I +nncllon: 1.S v a I ?-' ml's 1 Cmnmenls: e•? `vi,1 C•F.,r iL.n,l1 F-- (v?cL _ r : 11t,tt r61'"I f1vU.\Y,a.:? (?t?^(ZnK ) V AAChrgslip UIskW1AN2-10. DOC: 7198 w A ..ti A HEALTHSOUTH Rehabilitation of Mechanicsburg b t (I f) ? n CHARGE SLIP- Clinic #2 & Clinic #10 I Vt (643) (02-643) r b , r • ti , yi tf r ,' 1 •, r,y2 DAI-E? r:l Ticket# Thelapbt: e.Ci Ce• ,. ',7J Ci IVISHN-9, Authorized C'N -- /S ILS_ RX eapirn: ?tf? - --- I .. e, ?41 L I .) ; S 5 Department Cn SUBJECTIVE: ? Unremarkable Patient Repork: -111c?.., s _ OBJECTIVE: ArcnTrented: Xr-- . ROM: 10 Slreneth: Function: Comments: X110530- PT Evat_.%'ib - Yd) 00720 ' OT DO V4 h 00605 - PT FCR 2 rho MW(117 - PT Pbysieal i 06.514 - PT Ergonol(it ?? 00531- 116531 00510 oomo- - 0972t r1 00723 17190 171911,.- 1 1 ASSES.SMFN1: y CTf Current I_2,t nt.t s DAILY NOTE U No new complaints D Increased/dect 00610-' 1 00611 aifiing Y. hour 00609-J T: Statle mInt i Ibs off Inln? pail after last visit ? patient pain levfl®t0 n: 'Static Supine_ s off min , ?? IZ?..I / i?l •7 ? 4rcCurrent; ?r Mel: Reset: G C] tiom(c Be?crclse Program rcvimed Ll The F.uralu Program ndvenggcerrn per flow, faM1eel ? rntienl tolernleh treatment wel? ' Clo1111nen1n:-,_/?1.._) ?YI• IU?'(Jl Pf.,AN{_ L) F'pgrnde oellvlllea nn tolerated/per protocol Tnrrenrls'r ?;lcrvArmlE: ? -e « . ? ? U r)Mchnrge from Physical Then ;TOTAL CHARGES: I A\Clugslipl)isk1CI.IN2-Ili. 1)(X' 7/99 A A Alk HEALTHSOUTH Rehabilitation of Mechanicsburg CHARGE SLIP - Clinic kl & Clinic #10 A N / i ,-:(643) (02643) un•rF ?' • ,; ? T'mint a el `/J1 Therapl5:J;,<.d;,h,2_?/ .'Ir f Visit aof Aathorhea R/S_ 111. rapine: ._..._-.__?_._- _.- DeporlnentCodr:-j"'y , 9V_W_Qj. F.: fJ Unrcnlarknble Patient Renorta: ...i I r) n P, DAILY NOTE U No new cumplAnts U increased/derv OIJJFCrIyr: Aren Trented: ROM: ? Stretglh:-- I+unrllon: Comments li M M r AK ,, , ., AGII,, b i h ' I I ?f naerinlvisit U Patient pain level ®^/lo nJ 12 Eeehymosts f-- --- -A)/ Lt( ? C tL W (,-J ASSFSSNIENI : STC Current: LTC Current: r Met: Met: Rowl: Reset: , Ilent lnlerntr.i treatment well TY(fome Exercise Program reviewed o The Exercise /Program Rdvanced as per flow sheet (41 J J Comments. ,?,(, _? 4) V lk Vj, tvv, ek ? ? e1- l'l ? -? •v'1 r PLAN: I "I "'I. nrfl0lirm o, folrrnted/prr Pcnlnrn1 I Dh,ha, go faun Physical Therapy 1 ,....,... nl., JJa•. + 1 j, , JI -' TnettnrlSr SMNA'I'IIRF.., C -o, 'w? • TOTAI. CIIARCE.V: TnTAI.DNITa• 1 "I_DAV. A \Chrgelip I )i,kV:I.IN2.1/i. i )OC 7/98 w P HEALTIISOUTH Rehabilitation of Mechanicsburg A CHARGF. SLIP- Clinic N2 & Clinic #10 (613) (02643) r DATE IeketN Z`t fi Thern-Lpl,t: (,.q(1,?.?„r_-..?/,?•1; Vtsit N _.. ./_ of Authorized expires- Department Cnde:_?7 SUBJECTIVE: 1.1 04 Patient Report,: ue" complaints ,)/( r I v[ rn 5i i DAILY NOTE U Increased/decreased polo ogler last visit D Patient pain level @ 10 OBJECTIVE: /Y7 Aren'1'rcoled: `C _ citing: .(j ,i Ecchymoeb: nom.. C- AM ew i aN Strength: _ Funcllun: Comments: -00530 PT EvaI /hour I 40 00720 OTEval Yhour 1 00605 OT ME 2 hours 1 00607 PT Phyxfs:A,Capaclty Val l hour ' 60514 - TT Ergonomic Consult 'y. hour '. t o(IS04 ^ OT FC•.E 2 rrrrurs 't tI0S10? .OTPhyslcal-Capacity:Eval1 hour 0 00806 Of ErgnnDtnlc Comult Ye hour 0 fh 101531 - ' OT Y hour 0 60531 OT (joint riinb) h hour to 0 Grades 0 01)519 b1FR to 0 00510 Malsage - -- 0 00721 OT Y. hour.. 01 `60723 OT Aft training Y. hour 01 _ 111190 _ CS Traction : Static : Ini Ibs on _ Ihs off min_ _ 17190, - -I:5 Traction:- StatiC Supine_ - _Ihs on Ibs off min r I • of Elecine bunt :. 5 - Iontophnrc h'@ 6 Phonophnreali?. 4 ; . OT Initial :Onto 5 OT additional 11. 4 OTO/S&IReh 0 PTInitial 2`hou 1 ` PT addiiiunul I. 9 - PT 0/5&'IRehl f fe, C- `1, ..7y. GJrc.", .., .. ;J ASSP.SSM1tEN7•V.?: ', frt/ o• - .R.-JII'• 7 Y? I I,. F T ^ 5TG Cnrrcn/: 7 7. • LTG Current: L.? ?T / t Re,rl:. Reset: 6Tnlirnt tolerated treatment "ell 1 ? Itame Exercise Program reviewed L1 The Exercise Pragram advmced as per amv sheet / Comments:. 1 I.AN: 11.1 j gtt sir nr11,111, a folrrnlrA/Prl Prr•larol I I Dhrhnrgr r oar Phy0cnl Theropy Cma111^?1^:._ ?. 'f1IP,ItAI'ISf .':IGNA'I'OI18;. ? i/•L! cA't.M 1? _ tt7 7n,/C--'` TOTAL CIIATOTM, UNITS: w CO-PAY:. A.Utigglip I IlsktCI.IN2-Ill DOCK 7/98 A AOA HEALTHSOUTH Rehabilitation of Mechanicsburg A CIIA1?GE S1.11i - Clinic N2 & Clinic N10 (643) x(002-643) DATE..- fC/J IJ? TIC Visits _.--! _ f--- Authorized CvX _ NIS _ R/S RX expires:- Iepadmenl (*, ? 00536 PT Eval t/4 hiiur - I 00720 '. OT JEW Y4 hour 00669 „J P'I' PCE 2 hourt 1106117 _ P`f 0411cal Capado ival I hour 6814 PT Ergonanie 66sult e% hour 01164 -L OT PCE 2 hours 60910 ?, OT PhysicalCepieltyEvnl.Ihour 00806 _ OT EtRononik Consult % hour _ 00531 PT V4 hour 110531 PT(Jointtoob)V4hour to - CrAdos 011S10 MFR to 00510 Massage 00721 _ OT'/, hour (N1723 OT AbL training'/. hour 11700 _ CS Tractlon t Static Int IN oil IN off Join 17190 IS Tracllon. Static_ Supine lbs an Ibe off min ASSESSMENT: STO Current: LTG Cur DAILY NOTE SUnJECTIVI{: II Unremarkable tl No new complaints ?Inereased/decreased pain after last visit ~ Patient Rrnntrs: OOJECfIVE: Aren'1'reat ROM: A Strength: Ihmdinn: Comments: 40 M • 0 A No I I :. (I ` (I IV! PA 7C 7'i • 1 '/ISiSZ IE ,I +155 01611PT radditional I br. WQkkLHdrtj2 iji 00609 PT.O/S & I Reheb ? Patient Inlet pled treatment well ? Home Exercise Program reviewed U The Exercise Program advanced as per flow sheet Comments: PLAN- 0 Upgrade ndivltles as tolerated/per protocol t Ischarge from Physical Therapy i Comments; 111EItA19sTSIiNATURE: //t /JJ)11,1 7/P,-Z.11) // i9-7 /7d/ O Patient pain level ® _210 A:IChtpalip I1Lak\CLIN2-III. UOCS 7/98 HEAUNSOMM regonal brkFWbmsve&Hand L§•,(a • K t r, S i4 A r o v b j •4'S ri Q w WEEKLY PROGRESSMAM CONFERE&CE REPORT V-4/15/52 040 PATIENT:Svia w. J1w?Au?` ATE:j (Jl+J??lQ(?5, OANtE b vi-3755 , O w ' EMPLOYER: OCCUPATION: H u s (J??tv? r PHYSICIAN: h2 l u\ ??? DIAGNOSIS: 0 h n' w TYPE OF PROGRAM; OF TREATMENT PLAN LONGTERM GOALS: Return to work full / part time foil / modified duty. 1,. SHORT TERM GOALS: 2. DISCUSSION/PLAN: 1^n lG? '. V'UA vf" TV,4'( Mrsivv\l "6%11 ?`U? C. lJ?l cn (JIA ; <: ESTIMATED LENGTH OF STAY, LA_A \ o w C?. tv? l1 (JI?S.((i)Y? J jE' WORK PERFORMANCE STAFF MEMBERS: V ?Qvo ) tt 5 r K n rayna14 BS Donna Lorince, OTR/L Erin McGeary, BS Ale:ia Llarena, PT s ' '' 4 ; Ca a Msnager WH Coordinator --Exercise Specialist Clinical Specialist 840 N. Front St. • Wormleysburg, PA 17043 • (717) 975-3337 • Fax (717) 975.3973 0 a w w A H64LTHSOUTH r,eyb,wKfxk Ayfarr sine 8 Har dC6nter WEEKLY PROGRESSMAM CONFEREN E REPORT EMPLOYER: '1} l v) P``-, ,l) (: "\ PHYSICIAN: 0 e Fr^\L •y I'E: 1` I iV1 Lb ?GI.Cc.•l OCCUPATION: J??' ? i1 ? DIAGNOSIS: by) 6 TYPE OF PROGRAM: PLAN OF TREATMENT LONG TERM GOALS: Return to work full art time fu /!modlfl? duty. SHORT TERM GOALS: w 1' ' 2. 3. 11 Y DISCUSSIOMPLAN: CA V to v? uS 4 ?A Sha. h?-? rr.vs} - ES'T'IMATED LENGTH OF STAY: (•V?. ?VV.....Q Q WORKPERFORMANCESTAFF EMBE S: Karen Kraynak, DS • Case M anger CAA ?U{ LT 1 W?nLuU.Cp??-t.?-?' . N _k CL-4 CCV- IS ..3.c'A3 '1_Q 1 l ?C•nR , t _ - U v\,? YXA',A ..a:I. k\( Dom Lorince, OTR/L Erin Mn ea , DS WH Coordinator --Exercise Specialist Alexis Llnrena, PT Clinical Specialist 040 N. Front St. • Wormleysburg, PA 17043 • (717) 975.3337 • Fax (717) 975-3973 0 AW AW HAMUNSOUTH RagkydKb?, AvOtimm 6 HmdCw(er L7 WEEKLY PRO . ESStj'EAM ONF FENCE REPORT TIE `1'; .1V1L-.... D AT r: I lul ?b EMPLOYER:.(I`r Vl r`" ,l) ( \ OCCUPATION: 5 NUJ )- A PIIYSICIANt DIAGNOSIS: 'hp n TYPE OP 1'ROCNAMt ,"I PLAN OF'I'REATMEN1 ' • LONG TERM GOALS: Return to work ull )(er! time fu P odill? duty. SUOIVF TERM GOALS: 1. • 2. 3. DISCUSSIONIPLANt ?yl . v ?: v? u? 4 kpl ? t' 'iV?I t.1 ? c c IS ES'1'1MATED LENGTH OF STAY: • LVe?wU.?P Q W1211K PERFORMANCE STAFF MEMBERS: 171 Karen Kraynak, DS Case M t'nger C ( l;c sC? cn) ??V-tz gLori-11-:e, 1)om OTRIL Erin i Am , BS WII Coordinator --Exercise Specialist Alexis Marcum, PT Clinical Specialist fit 840 N. Front Sr. • Wonnloysburg, PA 17043 • 1717) 975.3337 • Fax (717) 975-3973 0 AW PHYSICL&A OF REHABILITATION R,.re„1ICINE P.C. 175 LANCASTER BOULEVARD, RO, BOX 2028, MECHANICSBURO, PA 17055 TELEPHONE: (717)691.3755 FAX: (717)691-3834 A MICHAEL F. LUPINACCI, MD MD041310E - DANIEL C. DEFALCIS, MD PAD065894L ST VAN DO, MD M M7241 L JULIA DEPUTY, PA-C MAO011661, WB.LIAM A ROLLS, )R., MD MD047520L LINDA DEIBF-RT, PAL MA000847L MARK A LUTNF.SS, MD MD035663E LAURF.EN CARCELLA, PA-C MA0023711, E VERETT C. IBLLS, MD MD045094E NAME: f/i+v l? Lug S? . r a. A PHONE: (H) DIAGNOSIS: n.µ! IREATMENT: (check all that apply) PHYSICAL THERAPY . . A Evvalualion _ treatment Frequency: _ times/wee_ or _ weeks Modalities: ROM _ PRE _ to Dynamic Lumbar Stabilization Exercises _ Cervicothoracic Stabilization Exercises Stretching and Flexibility for _ Strengthening to _ Postural Re-Education for MOBILITY _ Progressive ambulation _ Stair training _ Neummuscalnr _ Balance _ Endurance exercises _ Patient Education for Home Exercise Program AQUATICS Evaluation _ treatment Frequency: _ times/week for Special instructions: M OCCUPATIONAL THERAPY F.valuntion _ treatment _ Frequency: _ times/week for _ weeks _ Household mobility _ Self care skills _ Household activity _ Visual screening _ Functional Community Mobility Assessment - Full drivers evoluntion (includes on-the-road testing). Facility: Body Biomechanics for _ Posture control/relaxation/pacing education _ Home Exercise Program r HAND THERAPY Evaluation _ treatment _ Frequency: _ times/week for _ weeks Modalities for _ Flexibility/Strengthening for - Home Exercise Program • weeks SPEECH THERAPY Evaluation treatment _ Frequency: _ times/week for_ weeks _ Language and communication _ Swallowing _ Cognitive impairment _ Home Exercise Program _ Other: PSYCHOLOGY Evaluation _ treatment- Frequency: _ times/wcek for _ weeks Neuropsychology for WORKPROGRAMS Evaluation _ treatment _ Frequency: - Eiimes/week for -?2wceks _ FCE !-Work Hardening Program ( 9hours/dsy) _ Work Site Evaluation/Ergonomic Assessment _ Other: FUNCTIONAL RESTORATION PROGRAMS _ Chronic Pain Program: -inpatient _ outpatient _ Outpatient Fibromyalgia Program _ Day Treatment Program for Consult COMMENTS: IynO< / /`y 'Jacfoi SIGNATURE: r ) DATE: A Y8 A A.' ??e???l ,III 11(lllllli l? .r7.:, b I "?e,O l ivl'•vbdlll vl li vnl cn' ;.ll uu ll •rtlir ALit0ills CAiGMI?A I7G55 -PIIL' 91181 SGI(je treadmill is the hfl.'hlll'L`(I tL... however, if,a patleut cannot perfyr111 Pipli;o Ji mill protocol it is rectmonenllbd to allc llpted die Bicycle protocol, dgaci,i(f d in the manual. Vny yes response to Ilse fnllolviug heart dlreme quesllnn. requires Unlsullalilen wille, an I further :d alancyby Ilia prescribing physician before hnther testing may A annllnuclll SING LRA'MLR'Iit P.;( I)NI11.1, i' It ri-ro CO 1, 04U Item l I11rc110 Querllnl?a l f 6 I_ (' I;. D A 1{111E h - j 7 S 5 yea , 1. llave yon CVC1 ball n hwnl mck/ 2. Have yen hind bell s111gny7 -.---- I, Have Yale had all nbnnnnld Cleo Ioc: rdiogr:n117 . -1. Ia yon have 1lcalr dlscnsey A 5. Iblv0 you [faun sold by a physiciah you have bad angina? 6. hove yon been 1,11111 y 11 physician You have had paIpi1mhills '7 /. Ilave ynei Ind it s0nkcl --- 8. Ir itsmI bhleal pn:ameIa 1811/1161'1 -- 9 Am yon pi :8muu'/ ---.- 'hyr Lean Coln:rcled:__.._.___._._.._._._..__.?_...__._..._ 1'Ical once gl aulcd yur utt I'lao: A t4:4111ul _...._._._.. - Rudy WL 4_------- Resting Wait lease Nalliefell I I . . _ Ife les'1 ._... ,.X All MAX 1111,11 I'eiul, X ,711 it .511 ='I'nrgn hens late fin singe 1. hsl[fgI f llnuud I hscmc /_......_ I I.. 111111 bingo Is h1 hill .I nlhnnes blood plesswe and Kean 1aie will be Iccttuled doling the final miume 01,=11 stage. Ucg w ule-op al cnu llin l a h ht pecu fin Ill) 1111111111e:1. hlclolse s(eCll III bcllvccl1 2.0 and •1.51111,11 depelldhlg 1113011 co1lifil n arllle L•B • ale glued and Inke ilia bean title and blood pressure he the filial miouln. Increase Incline to 5%mnineaiublg final 1 1 m up pha e. SI11g0 2 bellies when the J".u glade is reached. Honest to 61e gradc far stage J. 9111110 1 (4 Mhntlcs) uglh___ a 19 grade q n w Will u•I l1, IIca n Base Blond 14csslele sUq{e 1 (d Mhmlesl mpll,-._._ _ °.. gmdc Y..rclclsn I Icart lease Ilkind I'lessllle singeI (I Nlbnnca 1171,11 ................... ?S, glade ZvT`- IICLtIVI'ly Beall hale _ 0113M lllessnrc /. Ilse Ilia li llosvinll Isledicliun cgmlliun to oblain max V02 --- /J • r• « 15.11 (21.8 X .rpced •11111.1 X hamlrNC _... _._.) ._... .._... __.. _ ............. _.J..._ • (11.2111 ;( 11jee /_-__ X nBc 1 (1) 1111 ill•I X luaus into __ X age 5 + 444 1 (1911 X genrlcr (0ufmnnlc, 1=male)) Ih rdlcbal 111nr VI12 '= 1111/?Cg/tltill llr0lnn fur . V Hifimnlu nma. VOI -mlAgAuits Q 1.3 Max ME i' Level pplj • &RT9IX 111)-Fimoou:d Aembic Capacity Iaurslllenl has W ,\m u[fii: C:-.1.1-: ___I'nor _.___...I+air \ru:q{a-Cnnd-Nsccllmtl (\ Yivnln:uar Ilaslit Ica little of Actable Calm, ily lllnih k.qn exv:d=nd./IyfminJ :IF;:_ rllili 1-114-He FMII AVii IY)OII VNITI:1.1;14'1' - \ -- !01- 1 25 25)1 7.e. 11 IJ•i2 • h.11;(l 10-111 •:21 21-10 11-J8 39-48 40-_U <20 211-26 27-15 36-14 50-59 <I8 IS-2'I 25.11 7.1-12 3? 110-11'1 •: IS 16.22 2.1-111 11-14I \ ----n --r We vyw I 111_19 20 211-27 28-II 14-44 4111-) 1/ i//l II 50-59 15 15-211 21-21 28-17 60-6'J < 17 IJ-11 I8-2J 24-1.1 11,10U hiuit.'il. IVu/ndr Inul PA 17(1.1;3 - - • I'i I. O17) 97.1i-3337 frls?71/'?!li`i-3DI8 w 04 vo- ?t fvwao ate- N11 ?J f?? U,, Crm u e? fa, /(Uj 0 0 (At r w 0 . Anil / S'I'A'1'IC S'1'IL11N GAUCL 'l'LS'1'ING/ DYNA?IOM1IIs'I'IsR CJgal 11C? Yes 6gor t r' A ? Dynamometer Squat Lill Avg • ? R(! Dev. CV A _ r l Avg, r r.r _ ?t4. Dev. CV Avg % Std. bev. I (.; 55 - CV Consistent effort 0-I5". ? r rr 15 /52 I^ A Ml r1 r r • MAXIMUM (OCCASIONAL) LIFT C.'hoosc all t some of.the,fibilowing based uPBq¢ob description, L-6 rndhVd@ype;gfgjips yteclrApics) Floor Io Knuckle L33S. Knuckle to Shoulder LDS. NA ti Shoulder to Overhead 1.13S. NA Carry (100 11.) LDS. NA Unilateral [.it) _ 1.135 NA - -- Job Specific I.ills--. ------ _ upon Walking Standing Silting Stnlic Rending Overhead Reach Crawling Rcpclilivc Squalling Kneeling Rcpclilivc Rending Slalic Squat Ladder Climb Forward Rcach Push/pull Asscmbh• Typing Rcpclillvc Ruch Writing Sorting Slacking Fine Moor Filing 9'vvisiing(Sup./Pronalion) Uiuar Dm-ialion STING Chose al (COMMENTS) or some of the following baser ADEQUATE FOR JOB YES NO YES NO ?-?_PLJ WORK SIMULATIONS REQl1IRM (c.g. hand and fool enrols, IM'511111 td ( riving): EVALIIAI011_. ?= G . esqtj I rnrlr_N )10 g-dr DATr AGM b1ACiN( ?'y? SURGERY _- DATE /any, WORKING '1 S'I}AY 1V-ORK(1.D USUAL 1013 PHYSICIAN e- A flow long if this oc t ACTIVITIES Sitting Standing Walking Stair Climb A Rcpclilive Bend Sonic Bcttd Repetitive Squat Slatic Squat Ladder Climb Overhead Rcacb Kneeling push/pull Forward Retch Fine Motor Activities Gross Motor Activities Wr LIFTING REOUIREMEN9 Floor To Knuckle Knuckle To Shoulder Shoulder •1'o Overhead M Carry Other SpccifY any tools or Cnnnncnts:._ r Employer common cngrloycc L HIM R•= Itarc O- Occasionally LBS. LBS. e- o(e2 LBS. _ LBS. rope nscd r RECOMMENDATIONS (cho anc): CONTINUE THERAPY I I WORK CONDITIONING osWORK I IARDENING l I COX I I'LETr WCA I7OR RTW RESTRICTION RETURN TO WORK (Provided all job dentnnds arc tested I'or approprime time I}antcs) fRrATNIENT RECOfhIMENDATIONS/Ehll'IIASIS__. ____ - e 0 DISCIL RGE DISPOSITION be cougdcled upon discharge from eilber isnrlr Imrile nitw', nr n•tnIt rc-condilitinitog it rograms if entered tiff Functional cline. (Send copy of This face sheel to Natinnal Director oI' WOIiKST,\R'I' tehen cmnpletet Reuvn to Woik Pull Dm)' Rest I icied Dine _ Other) -- Putlbcr Medical Voauinnal Scn ices P enicdial'Hlctapv Tomi Nnnibcr rl' Scssiun: --- Coq . F NC?T1 NAL BAS )sls' _ TING f IIONE: 7QJ 9eZa ?N,SI1RANcr TYPE: L. }-6 •II liI c tploycr' 1 ' ? • TASK 1' FOR ORMED F'= ITrrgocullY C=Consl:utl • • • • • • • • • • • w JOSEPH M.MELI LO TERRY S. HYMAN DAVID I- LU7rZ w MICHAEL E KOSm PAMELA O. SHUMAN RICHARD A. SADLOCK w A Angino ®Rov u= IN THEBMLAWYERS -a- AMERICA RICHARD C. ANOINO NEB. J. ROWER June 23, 1999 Mr. Tom Helmig CNA Insurance P.O. Box 16203 Reading, PA 19612-6203 Re: Claimant: Sharon Hawbaker Insured: Charles Murphy Claim No.: R11305308HE Date of Loss: 4-11-98 Dear Mr. Helmig: M 0 r M • • DAVID S. WISNFSKI NDOLE C. OLSON MICHAEL J. NAVITSKY JOSEPH M. DORIA DUANE S. BARRICK JAMES MCINTI I have had many jury trials in Cumberland County. I would be very interested in presenting Mr. and Mrs. Hawbaker's case to a Cumberland County jury. First, I do not believe there would be an issue of liability. Enclosed as Exhibit A is a copy of Frederick Welsh's January 18, 1999, statement. Secondly, with regard to expert damage witnesses, we would call Dr. Donald Bruaw, family physician; Dr. Richard Hallock, orthopedic surgeon; Dr. Daniel DeFalcis, physi atrist; and Dr. Pauline Wallin, psychologist. Enclosed as Exhibit B is Dr. Bruaw's records. Please note that before the subject motor vehicle accident, Mrs. Hawbaker was healthy and experiencing no musculoskeletal problems. Secondly, enclosed as Exhibit C are Dr. Hallock's records confirming that Mrs. Hawbaker's pre-existing degenerative disc disease of her cervical spine was aggravated by her motor vehicle accident. Additionally, because Mrs. Hawbaker did not have a surgical problem, Dr. Hallock referred her to Dr. Michael Lupinacci, Dr. DeFalcis' partner. Enclosed as Exhibit D are Dr. DeFalcis' records, as well as his December 16, 1998, and May 25, 1999, physiatrist reports, and enclosed as Exhibit E is Dr. Wallin's June 8, 1999, psychological report and office notes. 14 2572 /MTG 4503 NORTH FRONT STREET, HARRISBURG, PA 17110.1708 . (717) 238-5791 • FAX (717) 238.5810 0 3w I' w A Mr. Tom Helmig A Page 2 June 23, 1999 Additionally, I would call Debra Latsha, a physical therapist with McCuen and Associates, and Donna Lorince, an occupational A therapist with the Work Hardening Division of HealthSouth Rehabilitation Center of Mechanicsburg. With regard to non-expert witnesses, I would call Cindy Heinl, the owner of New You Hair Styling Salon. Enclosed as Exhibit F is Ms. Heinl's employer report. I would also call Fran Cunningham, Linda Deraelea, and Sandy Box (customers/friends of Mrs. Hawbaker). Quite naturally, we would call Walter Hawbaker, Sharon Hawbaker, and Renee Conrad (daughter) to testify. Lastly, given Mrs. Hawbaker's work loss and loss of earning capacity, I would have a vocational rehabilitation expert testify. As you can determine f rom Mrs. Hawbaker Is tax returns that I have M previously supplied, she was earning approximately $17,000 per year. At the time of the accident, Mrs. Hawbaker was 46-years old. In fact, she just turned 46. Assuming that Mrs. Hawbaker would work to age 65, her work life was another 19 years. Accordingly, at the time of her accident, her earning capacity was $323,000. This figure is relatively conservative because it does not take into consideration a productivity factor. The exhibits we would utilize at trial are as follows: 1. Photographs depicting the property damage to each vehicle. 2. Photographs depicting the accident scene. 3. Diagram of the accident scene. 4. Mrs. Hawbaker's appointment books. • 5. Mrs. Hawbaker's tax returns. 6. Work loss summary. 7. MRI scan. 8. Charts from the Work Performance Center (Dynamic Progressive Lifting Summary, Jamar Hand Dynamometer, and ARCON Rom/Spinal Inclinometer Report). In my professional opinion, the most important witness at trial will be Mrs. Hawbaker. She has an extremely strong work ethic. She is very anxious about the fact that she is disabled. Moreover, Mr. and Mrs. Hawbaker's lives have changed given her driving phobia. n M A Mr. Tom Helmig Al Page 3 June 23, 1999 Mrs. Hawbaker finds that the theracane prescribed by Dr. DeFalcis has been helpful. She utilizes it regularly. Mrs. A Hawbaker continues with her home exercise program, but because of the medications and her inactivity, she has gained 35 lbs. Quite naturally, Mrs. Hawbaker is worried about her degenerative joint disease. She never realized that she had degenerative joint arthritis until this accident. Mrs. Hawbaker is fighting depression on a daily basis. She is trying to learn to live with her disability, but it is difficult. Given the clear liability and Mrs. Hawbaker's economic and non-economic damages, the exposure in this case exceeds your insured's policy limits. Therefore, we would respectfully request a tender of policy limits. Obviously, we must exhaust the limits of the tortfeasor before proceeding with an underinsured motorist claim. without a tender of limits, I am left with no option but to initiate litigation. Attached as Exhibit G is a copy of the Complaint that I am sending to my clients. Should you require further information and/or documentation, please contact me immediately. 40 DLL:mtg Enclosures 0 e • Very truly yours, Dave Lutz 0 A CERTIFICATE OF SERVICE 1, 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' PRE-TRIAL MEMORANDUM upon all counsel of record via postage prepaid first class United States mail addressed as follows: • William Addams, Esquire P.10 Box 208 28 South Pitt Street Carlisle, PA 17013-0208 Attorney for Defendant • ® Dated: • • • • 217434.1\DLI.\LC2 • 4MT N eme-ts SHARON HAWBAKER and IN THE COURT OF COMMON PLEAS OF WALTER HAWBAKER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 99-4775 CIVIL TERM V. CHARLES S. MURPHY, JR., Defendant JURY TRIAL DEMANDED DEFENDANT'S TRIAL MEMORANDUM I LOSS OF EARNINGS Mrs. Hawbaker earned $17,039 in 1997 as a hairdresser. Her average week was $337.31. The accident occurred on April 11, 1998. She continued working through April 22, 1998 and earned $5,397 for the year, or $337.31 a week. Paul Anderson is the Plaintiff's proposed vocational expert. He bases his analysis of her lost earnings on $18,616 a year which he characterizes as "updated to $18,618 in year 2000 dollars." This is an increase of 9.267% over the 1997 earnings, apparently for inflation. In Kaczkowski v. Bolubasz, 491 Pa. 561, 421 A.2d 1027 (1980), the Supreme Court directed that estimates of future earnings should not include an allowance for inflation by stating: [I]nflation shall be presumed equal to future interest rates with these factors offsetting. Thus, the courts of this Commonwealth are instructed to abandon the practice of discounting lost future earnings. By this method, we are able to reflect the impact of inflation in these cases without specifically submitting this question to the jury. 421 A.2d at 1039. Further, Dr. Anderson adds without any explanation a 112% productivity factor." In Kaczkowski, the court instructed, "Upon proper foundation, the court shall consider the victim's lost future productivity. t, Id. at 1038. The economist in the Kaczkowski, trial explained productivity increases as the ability: to produce goods and services at a faster more efficient rate. Namely, due to better technology. This . [is the] reason why a person's wages rise; if he can produce twice as much in an hour after learning to do his job better. . . . Id. at 1031. Dr. Anderson has offered no source or foundation that would provide a beautician with a 2% annual productivity factor. After ten years, she had probably reached her maximum level of productivity in this type of occupation. We request the Court to limit Dr. Anderson's testimony to pre-injury earnings of $17,039 per year and to require a sufficient foundation for any proposed productivity factor. Respectfully submitted, ADDAMS & RUNDLE 7 By:cs2%%?/???, Wil lam A. Addams Supreme Court I.D. No. 06265 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Defendant -2- SHARON HAWBAKER and WALTER HAWBAKER, Plaintiffs V. CHARLES MURPHY, JR., Defendant #6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4775 CIVIL TERM PRETRIAL CONFERENCE AND NOW, this 23rd day of August, 2000, before Edgar B. Bayley, Judge, present for the plaintiffs was David L. Lutz, Esquire, for the defendant, William Addams, Esquire. This case arises out of an automobile accident that occurred on April 11, 1996. Plaintiff, Sharon Hawbaker, was a passenger in a vehicle that was struck from the rear by defendant, Charles Murphy. Walter Hawbaker's claim is for consortium. Liability is admitted. Plaintiff seeks general damages. Plaintiff also claims wage loss in excess of the PIP threshold of $25,000. Defendant maintains that his causal negligence has not resulted in wage loss to plaintiff that exceed the $25,000 threshold. The consensus among both counsel is that a special interrogatory is needed whereby the jury will determine what, if any, wage loss that plaintiff has incurred since the date of the accident were caused by defendant's negligence. The jury will answer that interrogatory and also render a general verdict, a component of which will include plaintiff 's claim for future loss of earning capacity. After thinking this through, counsel shall advise the trial judge at the commencement of trial whether they agree with this approach. Estimated time of trial, two days. David L. Lutz, Esquire 4503 North Front Street Harrisburg, PA 17110 For Plaintiffs William Addams, Esquire P.O. Box 208 28 South Pitt Street Carlisle, PA 17013 For Defendant prs By the Court PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) (X) for JURY trial at the next term of civil court ( ) for trial without a jury CAPTION OF CASE (entire caption must be stated in full) Sharon Hawbaker and Walter Hawbaker, Plaintiffs V. Charles Murphy, Jr., Defendant (check one) ( ) Assumpsit ( ) Trespass (X) Trespass (Motor Vehicle) ( ) Other The trial list will be called on August 15, 2000. Trials commence on September 11, 2000. Pre-trials will beheld on August 23, 2000 (Briefs are due 5 days before pre-trials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 314-1.) No. 99-4473 Civil Indicate the attorney who will try case for the party who files this praecipe: David L. Lutz, Esquire, Angino & Rovner, P.C. Indicate trial counsel for other parties if known: William Addams, Esquire This case is ready for trial. Date: 6-2-00 Signed: Print Name: aid L. Lutz Esquire Attorney for Plaintiff(s) 214456. I UJLL\MTG Y al = i C'J J S VS. CIVIL ACTION - LAW No . (I1- 'y'n-s JURY TRIAL DEMANDED e ?t.L-? CHARLES S. MURPHY, JR., 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. Court Administrator 4th Floor, Cumberland County Courthosue Carlisle, PA 17013 (717) 240-6200 ORIGINAL 152101/MTG SHARON HAWBAKER and WALTER IN THE COURT OF COMMON PLEAS HAWBAKER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs VS. CIVIL ACTION - LAW CHARLES S. MURPHY, JR., NO. Defendant JURY TRIAL DEMANDED NOTICIA Le han demandado a usted en la torte. 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 o en persona o por abogado y archivar en la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator 4th Floor, Cumberland County Courthosue Carlisle, PA 17013 (717) 240-6200 SHARON HAWBAKER and WALTER IN THE COURT OF COMMON PLEAS HAWBAKER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs VS. CIVIL ACTION - LAW CHARLES S. MURPHY, JR., NO. S'9- `17 y5 ( //? ati? Defendant JURY TRIAL DEMANDED COMPLAINT 1. Plaintiffs Sharon and Walter Hawbaker, husband and wife, adult individuals residing in Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant Charles S. Murphy, Jr., is an adult individual who resides at 109 Orchard Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about April 11, 1998, on Wertzville Road, Cumberland County, Pennsylvania. 4. At that time and place, Mrs. Hawbaker was a fronL•- seat passenger in Renee L. Conrad's 1988 Honda Accord. 5. Mrs. Conrad was traveling eastbound on Wertzville Road and stopped her vehicle to turn north on Carol Lane. 6. At the same time, Defendant Murphy, operating a 1993 Chevrolet Blazer, was also traveling eastbound on Wertzville Road. 7. Defendant Murphy permitted the front of his Blazer to strike the rear of Ms. Conrad's 1988 stationery Honda Accord. 8. The foregoing rear-end accident and all of the injuries and damages set forth herein sustained by the Plaintiffs 1 are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Murphy operated his motor vehicle as follows: rule; a. failure to abide by the assured clear distance b. failure to observe Ms. Conrad's stationery vehicle on Wertzville Road; C. driving his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. CLAIM I Sharon Hawbaker v. Charles S Murohv Jr. 9. Paragraphs 1 through 8 of the Complaint are incorporated herein by reference. 10. Plaintiff Sharon Hawbaker sustained painful and severe injuries which include but are not limited to an aggravation of her pre-existing asymptomatic degenerative disc disease at C5-6, chronic pain syndrome, depression and anxiety, adjustment disorder with mixed anxiety and depressed mood, chronic, low back pain with right lower extremity radiculopathy, and a cervical strain. 11. By reason of the aforesaid injuries sustained by Mrs. Hawbaker, she was forced to incur liability for medical treatment, medications, physical therapy, work hardening, numerous doctor visits, and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 2 12. Because of the nature of her injuries, Mrs. Hawbaker has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 13. As a result of the aforementioned injuries, Mrs. Hawbaker has undergone and in the future may undergo physical and mental suffering, inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 14. As a result of the aforesaid injuries, Mrs. Hawbaker has been and in the future will be subject to humiliation and embarrassment, and claim is made therefor. 15. Mrs. Hawbaker continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. CLAIM II Walter Hawbaker v. Charles S. Murphy, Jr. 16. Paragraphs 1 through 15 of the Complaint are incorporated herein by reference. 17. As a result of the aforementioned injuries sustained by his wife, Plaintiff Sharon Hawbaker, Plaintiff Walter Hawbaker has been and may in the future be deprived of the care, companionship, consortium, and society of his wife, all of which will be to his great detriment, and claim is made therefor. 3 WHEREFORE, Plaintiffs Sharon and Walter Hawbaker demand judgment against Defendant Charles S. Murphy, Jr., in an amount in excess of Twenty-five Thousand Dollars ($25,000.00), exclusive of I interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Date: ANGINO & ROVNER, P.C. ADavid L_. Lutz I.D. #35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiffs 4 VERIFICATION We, Sharon and Walter Hawbaker, 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: Sharon Hawbaker Walter Hawbaker Dated: ,?: c :( ,'? ?., ?, ??: ?? ;: ?- r _ a ?? ?? ? ?_ ?? ? m o ? ? ? ? ??? SHERIFF'S RETURN - REGULAR CASE NO: 1999-04775 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HAWBAKER SHARON ET AL vs. MURPHY CHARLES S JR CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT was served upon MURPHY CHARLES S JR the defendant, at 19:16 HOURS, on the 11th day of August 1999 at 109 ORCHARD STREET MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to CHARLES S. MURPHY, JR. a true and attested copy of the COMPLAINT together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 6.20 Affidavit .00 Surcharge 8.00 omas one, ?5 eri 8/12/19990VNER by e y eri Sworn and subscribed to before me this day of 19_99 A. D. \h, o 0 o 01n ` 4no azy SHARON HAWBAKER and WALTER HAWBAKER, Plaintiffs V. CHARLES S. MURPHY, JR., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4775 CIVIL TERM JURY TRIAL DEMANDED ANSWER AND NOW, comes the Defendant, Charles S. Murphy, Jr., by his attorneys, Addams & Rundle, and makes the following answer to the Plaintiffs' complaint: 1-3. Admitted. 4. After reasonable investigation, the Defendant is without knowledge sufficient to form a belief as to the truth of the averment. The same is therefore denied. 5. The answer to Paragraph 4 is incorporated herein by reference. 6. Admitted. 7. Admitted. 8. The conclusion of law is denied. COUNT I SHARON HAWBAKER v. CHARLES S. MURPHY, JR. 9. The answers to Paragraphs 1-8 are incorporated herein by reference. 10. After reasonable investigation, the Defendant is without knowledge sufficient to form a belief as to the truth of the averments regarding the Plaintiff's injuries and damages. The same are therefore denied. 11-15. The answer to Paragraph 10 is incorporated herein by reference. COUNT II WALTER HAWBAKER v. CHARLES S. MURPHY JR. 16. The answers to Paragraphs 1-15 are incorporated herein by reference. 17. The answer to Paragraph 10 is incorporated herein by reference. WHEREFORE, the Defendant requests the Complaint be dismissed. ADDAMS & RUNDLE By: William: Addams Supreme Court I.D. No. 06265 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Defendant VERIFICATION Charles S. Murphy, Jr. hereby verifies that the facts set forth in the foregoing Answer are true and correct to the best of his knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904 relating to unsworn falsifications. DATE: S-30-9P CERTIFICATE OF SERVICE AND NOW, this 1st day of September, 1999, I, William A. Addams, of Addams & Rundle, attorneys for Defendant Charles S. Murphy, Jr., hereby certify that I have served a copy of the Answer by mailing a copy of the same by United States mail, postage prepaid, addressed as follows: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 //??/iSi?Ya/mot .. _ c??" .. . , ? i. ,.I ?..., ._.??L.?,..?r 1?1ul SHARON HAWBAKER and WALTER HAWBAKER V. CHARLES MURPHY, JR. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-4775 CIVIL TERM VERDICT 1. State the amount of damages, if any, sustained by Mrs. Hawbaker: a. Past work loss b. All other damages, including future loss of earning capacity, pain and suffering, loss of enjoyment of life, and embarrassment and humiliation Go to Question No. 2. 2. State the amount of damages, if any, sustained by Mr. Hawbaker: $ 4 81,0 $ '?'7 300 03 $ 29Q7. co Please alert the courtroom deputy that you have reached a verdict. q12? 34 (Date) (Foreper SHARON HAWBAKER and WALTER HAWBAKER, Plaintiffs VS. CHARLES S. MURPHY, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4775 Civil JURY "TRIAL DEMANDED PRAECIPE To the Prothonotary of Cumberland County: Please mark the above-captioned action settled, satisfied, and discontinued. ANGINO & ROVNER, P.C. Date: (L _C, cc William Addams, Esquire -4 Da d .Lutz I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiffs 200160.1\DLL\MTG n> ??- ?.. !_: _> ? : i?": `c? - ?. .? _, __,