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Home My WebLink About99-06724 1 SHERIFF'S RETURN - REGUi.AR CASE: NO: 1999-06724 P COtIli•ON4IEALTH OF PENNSYLV.4Nii1: COUNT? OF CUMBERLT:D?D _OLT^•.'i isETHAi'i i. vs. 2041E ERRT L SHA4IN HARRISON _ SherlL O:' DP.DLIt_ Si._:1L _° OT CUMBERLAND County, Pennsylvania, being duly s::orn accord in to lae%, says, Zh^- .. ]. l'1L.^. I_O]•]P .? _____ :i2.S served upon. ROWE TERRI L _ the defendant, at 1932:00 IIOLiRS, on the '2th day o_` November - 1999 at 2505 RIT^ER. WAY CARLISLE, PA 17013 CUMBERLAND , County, Pennsylvania, by handing to DARA ROS7E, SISTER a true and attested copy of ti:e COIGPLAINI' _ and at the saine time directing Her E.tcej L'_O.^. to the contents thereof. Sheriff's costs: i? JO aP.sl9c•rs Se Service r-Jicc- 6.20 , Affidavit .00 Surcharge 8.00 a ?.TD-HA DS/R9J?Ni.IDi ROSENTBERG by U o ?L X Sworn and subscribed to before ,ne this d f d`f Oi Q.L41tw(tt_ 19__99_ A. D. ? _ ,: t? Ctn. ?) ' ` %C(? ??•. - =- Ls o ? u?n?noCarr j------ .?....._ ,?: ?'t"J:S'^'Ii Cam. ^n•-. r Law Offices of Charles Rector, Esquire, P.C. 1104 Femwood Avenue, Ste. 203 Camp Hill, PA 17011 w mxharlcsrcctorxam Tammy S. Faust Paralegal (717) 761-3101 Fax (717) 761-2161 December 19, 2001 W. Scott Henning, Esquire Handler Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Brigid W. Alford, Esquire Boswell, Tintner, Piccola & Wickersham 315 N. Front Street/PO Box 741 Harrisburg, PA 17108-0741 Re: Holtry v. Rowe No. 99-6724 Dear Counsel: I confirm by this letter that the Arbitration in the above-referenced matter is now scheduled for January 24, 2002, at 10:00 a.m.. in the Conference Room on the 2nd Floor of the Old Courthouse, Carlisle, Pennsylvania. Enclosed please find a Notice confirming same. Very truly yours, CR\tsf Enclosure cc: Anthony DeLuca, Esquire Laura Gargiulo, Esquire Cumberland County Prothonotary I .y Charles Rector BETHANY M. HOLTRY and IN THE COURT OF COMMON PLEAS MARSHALL V. HOLTRY, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : NO. 99-6724 TERRI L. ROWE, Defendant NOTICE OFARBITRATION To: W. Scott Henning, Esquire Brigid W. Alford, Esquire Handler Henning & Rosenberg Boswell, Tintner, Piccola & Wickersham 1300 Linglestown Road 315 N. Front Street/PO Box 741 Harrisburg, PA 17110 Harrisburg, PA 17108-0741 PLEASE TAKE NOTICE that a hearing in the above-captioned matter will be held before the panel of arbitrators at 10:00 a.m. on January 24, 2002, at the 2nd Floor Hearing Room of Old Cumberland County Courthouse, Center Square, Carlisle, Pennsylvania. Please attend promptly with your witnesses and be prepared to present yourcase. The arbitrators reserve the right to adjourn the hearing from time to time as necessary. Upon request of a party for good cause shown or upon their own motion, the arbitrators may postpone the hearing to a time not later than a date fixed by the agreement for making the award, unless the parties consent to a later date. The arbitrators may decide this controversy upon the evidence produced at the arbitration hearing, notwithstanding the failure of a duly notified party to appear. Any party desiring to have a stenographic record of the testimony taken should make arrangements with a certified court reporter in advance of the hearing, and shall be responsible for all associated costs. BY: C ?" at .UtJ 1 , C to r Charles Rector, Esquire Arbitration Panel Chairman Date: cc: Anthony DeLuca, Esquire Laura Gargiulo, Esquire I N'ri m. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETHANY M. HOLTRY and MARSHALL V. HOLTRY, her husband, Plaintiffs V. NO. 6724 CIVIL 1999 TERRI L. ROWE, Defendant RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following fonn: PETITION FOR API'O1N'ITh?N'1' OF Altill'I'RA1'ORS TO THE HONORABLE, THE JUDGES OF SAID COURT: W. Scott Henning, Esquire counsel for the plaintiffAMtMAHn the above action (or actions), respectfully represents that: L The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $ to excess of $25, 000.00 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: W. Scott Henning & Brigid Q. Alford WHEREFORE, your petitioner prays your honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, Handle , He enberg ORDEROFCOURT W• Scott Henning, quire #32 8 AND NOW, O?N??• ti?U 1'h?C??in consideration of the foregoing petition, ?Gta? Esq., f gnct l" `? Esq., and Esq., are appointed arbitrators in the a (L captioned action (or actions) as prayed for. By the Cour / , MOI-, I P.J. ?U ?C ?r Itri d V. :Nlw,d, r.quu. Snpmns ('uwt 11). 113y590 G. ki"'d S,h,nlnt IV, I .ywrc Supreme Caun I.U... F 1976 aOSWIA, [IN FNIfR.19(TOLn k l\'l('URS"Am 115 North r"nn Suc,I PoSt Office It,), 741 Ihm,bom. 1'enm)1,nde 17iN.()74I Atmrn.11 for Ut'ICndln{ Roue BETHANY M. IIOLTRY anti MARSHALL V. 1101-TRY, Plaintiffs V. TERRI L. ROWE, Defendant : IN HE COURT OF COi\IMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-6721 CIVIL, TERM : CIVIL ACTION- LAW :.IU12Y,rRIU, DE-HANDED ARBrrRAT1ON MEMORANDUM OF DE,FENDANTTERRI L. ROWE 1. ST.,VI'EMENT OF CASE. On March 5, 1995, Defendant, Terri L. Rowe was traveling in an easterly direction on Route 465. The morning was very sunny and Rowe was operating her vehicle behind that of Plaintiff, Bethany M. Floltry. As \4s. Rowe and 1%-1s. Floltry approached the underpass for Interstate Sl (hereinafter "l-S I"), several of the vehicles ahead of them began to stop, to make left cross-traffic turns onto 1-8 I. Ms. Holey had started to slow down when site stopped abruptly and, without warning, causing Ms. Rowe to strike the rear of Ms. Holtry's vehicle. Ms. I loltly exited her vehicle without any assistance and did not receive any medical treatment at the accident scene. Ms. Floltry complained of slight neck arld shoulder pain, but declined to . to the hospital for treatment. Later in the clay, Ms. Floltry went to the hospital and .,:.-....,..:z,.xaresa•?e,-a??a+src.^_'ro'r._.n.? e.f ...... ..............s^.Sm..y _- received treatment. 'file treating physician diagnosed Ms. Holtry with a cervical strain and prescribed a muscle relaxer. Later, Ms 1-1011"y's family physician advised her to wear a cervical collar while driving, but otherwise did not restrict her physical activity. Ms.Ifollry'sf rnilyphysicimtreferredherforphysicaltherapy. Ms.Holtryreceivedphysical i therapy, comprising electrical slinttilation and hot packs oil her shoulders and exercises for approximately two months. Because Ms. Holtrydid not have any further pain, she and her family physician subsequently decided to discontinue the physical therapy treatments. The physical therapists told Ms. 1-foltry to be careful lifting heavy objects but did not, in any way, limit her operation of a motor vehicle, restrict her from lifting or carrying her daughter, limit or restrict her from working, or limit or restrict her physical relationship with her husband. (Months later, on October I, 1995, Nis. Floltry was opening a file drawer at her office and heard her shoulder "pop." She presented to her family physician complainingofshotdderand neck pain. Ms. Holtty's family physician, again, referred her to the same physical therapy center. The physical therapy center treated Ms. Holtry as a new patient and opened a new file, citing the pain onset date as October 1, 1995. 11. LEGAL BASIS FOR DEFENSE. A. Comparative Negligence. Under Pennsylvania law, a plaintiffs award ofdamagcs may be reduced under the theory of' comparative negligence. 42 Pa. C.S.A § 7102 provides that "[i]n all actions brought to recover damages for negligence ... the fact that the plaintiffmay have been guilt ofcontributorynegligence -1- -"-I shall not bar recovery by the plaintiff ... bnt any damages sustained by the plaintiff shall be diminished in proportion to the amount of negligence attributed to the plaintiff." A finding of comparative negligence requires that there be "avo negligent acts: a breach ofduty by the defendant to the plaintiff and a railure by the plaintiff to exercise care for his own protection." Corrender v. Fiaerer 469 A .2d 120, 125 (Pa. 1953); [see also Lolm v. McGee, 540 A .2d 111 (Pa. Super. 19SS); Elder r. Orlack, 515 A .2d 517, 525 (Pa. 19S6)]. "A plaintiffwho acts undercircuntslanecs in which he knows or a reasonable person would know that what he is doing is dangerous is merely negligent. His conduct is properly analyzed under the Comparative Negligence Act." Berman v. Radnor (tolls, Inc., 542 A .2d 525, 533 (Pa. Super. 198S) [citing Fish v. Gosnell. 463 A .2d 1043, 1049 (Pa. Super. 1983)]. In the current case, the facts are such that Plaintiff's actions are Properly considered under the comparative negligence statute, 42 Pa.C.S.A § 7102. Specifically, at the time of the accident, Plaintiffwas in the process of slowing down in morning rush hour traffic on Route 465, waiting for vehicles ahead of her to merge onto Interstate 81. 'file morning was very sunny and the parties' vehicles were facing into the sun. Plaintiff has admitted that, as other traffic slowed in front of her, she leaned across in her scat to retrieve a compact disc from its case on the front passenger scat. Defendant submits that this action caused her to depress the brake in such a way that tier car came loan immediate,abrupt,and unexpected stop. Defendant, unable to avoid Plaintiff's vehicle,struck Plaintiffs vehicle in the rear. Plaintiffs actions were comparatively negligent. Plaintiffwas leaning over in her seat and not paying adequate attention to the traffic in her vicinity. find Plaintiff been sitting upright in the -3- ?_ -Y24T?F?.?YY.V?u:,u+i'aNLS?_K\??_.?:.u_..._.......,.-..?....-???u..-._.?_a_ driver's scat, she would have been able to control her deceleration time, and would not have come to such :m abrupt and total stop. InslCad, Plai[Itiff Was distracted from the traffic around herbecause site was Icall ingover tothepassenger scat look ingforit compact disc. Plaintiffkncw,orshoulc]have known, that her failure to payaltenlion, to the traffic around hcrand to her act ofbraking, could lead ti it rear-end collision. See Berman, supra. 'therefore, Plaintiffs actions are properly evaluated under 42 Pa.C.S.A. § 7102 and an ;Huard should be entered in the Dcfcndant's favor oil that basis. 6. Causation. "In a personal injury case, the plaintiff nntsl prove the existence of a causal relationship between the injury complained of and the alleged negligent act to be entitled to recover for the injury." / auanze v. S'ilverslrini, 448 A.2d 605, 60S (Pa.Supcr. 19S2) [citing /lamil v. Basldine, 392 A.2d 1280 (Pa. 1975)]. "Generally a plaintiff nwst prove causation by expert medical testimony. .. [unless] there is an obvious causal relationship between the two [injuries]. An obvious causal relationship exists where the injuries are either an immediate and direct or the natural in(] probable result of the alleged negligent act." !d. [citing Smith I,. Gernum. 253 A.2d 107 (Pa. 1969); Tabureem v. London G. ct A. Ltd., 40 A .2d 396 (Pa. 1945)]. In thecurrent case, Plaintiffcannot prove a definitive causal relationship between heralleged ongoing injuries and the motor vehicle accident. Specifically, Plaintiffs emergency room x-rays were negative. She had only it slight tenderness in the right shoulder and it full motion of her ccn,ical spine, with no specific tenderness. Later, Plaintiffs family physician referred her for physical therapy. Plaintiffwent to physical therapy for only two months before she and her doctor discontinued treatment. She had returnee] to work two days after the accident. -4- Over the next several months. Plaintiffcontinucd to work her regular schedule. She drove, worked, cared for her infant dau-liter, and otherwise conducted lie[' daily activities without any medical restrictions. She vacationed at the shore that summer. On October I, 1995, Plaintiff injured her shoulder while opening a filing cabinet at work. Plainti ffretunted to physical therapy where she was treated as a new patient with an October I, 1995, "pain onset" date. Subsequent to her October 1995 injury, Plaintiff complained of right shoulder pain and right hand numbness. The physical therapist noted this pain as having stemmed from her work-related injury. In her Complaint, Plaintiff seeks damages for alleged injuries resultant from the motor vehicle accident. However, Plaintiff ceased receiving treatment for her alleged injuries approximately two months after the accident. Thereafter, Plaintiff injured herself while opening a filing cabinet at her office. Plaintiff also seeks damages from Ms. Rowe for the injuries she sustained at work. Using the Lattrutze standard, Plaintiffcannot prove a causal chain that links the injuries she received when site opened the filing cabinet at work to the motor vchicle accident. Plaintiff injuries arc directly related to the October 1, 1995, incident in which she injured her shotdder at work. Plaintiff cannot prove that her injuries were an immediate and direct or natural and probable result of the motor vehicle accident. Lcruanze, supra. The report authored by David Baker, M.D. confirms this fact. If no direct link exists, Plaintiff must prove causation through expert medical testimony. Lrdtanze, supra. Plaintiff received treatment for the motor vehicle accident for only two months -5- before voluntarily discontinuing treatment. Plaintiffs complaints later resurfaced after site injured herselfat work. It is not consistent with the natural history of sprain/strain type injuries to have six month painfrce intervals, followed by the resumption ofsymptoms. Penns Woods records ofOctober 1995 also note that Ms. Floltry herself stated "these symptoms seem to be somewhat different than those experience with her earlier episode." Thus, Plaintiffs medical records indicate that her injuries resulted from the work-related injury,notfromthemotorvehicleaccidcnt. Plaintiffcannot prove through expert medical testimony that a causal link exists between the motor vehicle accident and the majority of her injuries. Therefore, Plaintiff should not receive compensation from Ms. Rowe for injuries that Plaintiff sustained at work, and Defendant respectfully submits that the Arbitrators' award should be in favor of the Defendant. Respectfully submitted, By: Brigid Q. Alford, Esquir" Supreme Court I.D. 1138 0 G. Edward Schweikert IV, Esquire Supreme Court I.D.1181976 Boswell, Tintner, Piccola &Wickersham 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17105-0741 Attorneys for Defendant Rowe Date: 112-401- CERTIFICATE. OF SERVICE. 1 do hereby certify that I have served a true and correct copy of the foregoing Arbitration Memorandum of Defendant Terri L. Rowe by Hand-Delivering the same, addressed as follows: W. Scott Henning, Esquire 1300 Linglestown Road Post Office Box 1177 Harrisburg, PA 17108 Attorney for Plaintiffs Anthony DeLuca, Esquire 113 Front Street Post Office Box 358 Boiling Springs, PA 17007-0358 Charles Rector, Esquire 1 104 Femwood Avenue, Suite 203 Camp Hill, PA 17011-6912 Arbitration Panel Chairman Laura Gargiulo, Esquire Law Office of Richard Gaffney 2120 Market Street Camp Hill, PA 17011 By: rigid' . Alford, Esqu' e Date: 1 4 'AI DP BETHANY M. HOLTRY and MARSHALL V. HOLTRY, her husband, Plaintiffs V. TERRI L. ROWE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 9?- L7-' l /LM CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your 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 relief riclaim notice for any money claimed in the complaint o f a other important requested by the Plaintiff. You may lose money or property or other to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT OFFICES T FORTH BELOW TO FIND OOUT WHERE YOU CAN GET LEGALOHELP.HE CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone 717-249-3166 or 800-990-9108 HANDLER, HENNING & ROSENBERG By ? W. Scott`Henn ni g, Esq. I.D. #32298 319 Market Street P.O. Box 1177 Harrisburg, PA ,17108 (717) 238-2000 Attorney for Plaintiffs ,71 I "I'mmplaimr Ilollvm BETHANY M. 11OLTRV, and. MARSHALL V. IIOLTRY, her husband': Plaintiff -rERRt L. ROVE, Defendant IN •1'II li COURT O1-'COAIAION PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - L.ANN' . 1 No. 9 `i_ & --rV 61 JURY TRIAL DEMANDED COMPLAINT AND NOW, come the Plaintilis, Bethany IM. Holtry and Marshall V. 1 Ioltry, her husband, by and through theirattorneys, IIANDLER, IIENNING & ROSENBERG. by \V. Scott Henning, Esq., and makes the within Complaint against Defendant, "Perri L. Rowe, as follows: 1. Plaintiffs, Bethany M. Holt y and \larshall V. I loltry, are adult individuals currently residing at 361 Sawmill Road, Newville. Cumberland County, PA 17241. 2. Defendant, Terri L. Rowe, is an adult individual currently residing at 2505 Ritner Way, Carlisle, Cumberland County, PA 17013. 3. At all times material hereto, Plaintilt, Bethany N1. 1 loltry, was the owner and operator of a 1991 Chevrolet Cavalier, bearin; Pennsylvania Registration Plate L\T169 (hereinafter "PlaintifYs vehicle"). 4. At all times material hereto, Defendant, "Perri L. Rowe, was the owner and operator of a 1959 Toyota Corolla, bearing Pennsylvania Registration Plate No. A.11-13200(hereinalier "Defendant's vehicle"). 5. At all times material hereto, Leslie C. I lullen, was the owner and operator ofa 1991 Chevrolet Caprice, bearing Pennsylvania Re,isuation ['late No. AI-G 1297 (hereinalier "The 1-lollen vehicle"). 6. On or about March 5, 1995, at approximately 5:00 a.m., the Plaintifl-s vehicle was traveling soutftbound and had come to a stop doe to traffic on T-6S7, South Middleton Township, Cumberland County, Pennsylvania. 7. On or about March 5, 1995, at approximately 5:00 a. ill., the llullen vehicle was traveling southbound and had come to a stop doe to tratlic immediately in Iron( of Plaintiff's vehicle on T-687, South Middleton'rownship, Cumberland County, Pennsylvania. S. On or about klarch 5, 1995, at approximately 5:00 the Defendant's vehicle was traveling southbound immediately behind the Plaintifl-s vehicle on T-687, South Middleton Township, Cumberland County, Pennsylvania. 9. At approximately that saute time and place, Defendant, 'Perri L. Rowe, fooled to observe that the Plaintiff's vehicle had stopped directly in front ofher vehicle. Suddenly and without warning, Defendant,'rerri L. Rowe, struck the real- ol'the Plaintill-s vehicle, forcing the Plaintiffs vehicle into the rear of the I-lullen vehicle. 10. At the time ofthis collision, Plaintiff, Bethany \f. I-loltry, was insured under a motor vehicle policy through Allstate Insurance Company. Under this policy, Plaintifl, Bethany M. Holtry elected the Pull Tort option pursuant to 75 I'll. C.S.A. `I705(d)(+). 1 1. As it direct and proximate result of the negligence of Defendant, Terri L. Rowe, Plaintiff, Bethany M. I-Ioltry sustained serious and extensive injuries as set forth more specifically below. COUNT 1 - NEGLIGENCE BETHANY M. HOLTRY v. TERRI L. RONVE 12. Plaintiffs herein incorporate and make part of this Complaint paragraphs I through I I as if filly set forth below. 13. The occurrence of the aforementioned collision and all of the resultant injuries to Plaintiff, Bethany NI. Holtry, are the direct and proximate result of the negligence, carelessness, and/or recklessness of the Defendant, Terri L. Rowe, generally and more specifically, as set forth below: (a) In failing to be reasonably vigilant to observe position ofthe Plaintiff's vehicle on the roadway; (b) In failing to operate her vehicle in such a manner that would allow her to apply the brakes and stop before striking the Plaintiff's vehicle; (c) In failing to operate her vehicle under proper and adequate control in order that she could avoid striking the Plaintiff's vehicle; (d) In failing to operate her vehicle at a speed, and under such control, so as to be able to stop within the assured clear distance ahead, in violation of 75 Pa.C.S.A. § 3361; 3 f t (e) In tailing to operate her vehicle in it speed that was safe for existing traffic and road conditions, in violation of75 Ila.C.S.A. § :1361; (1) In tailing to maintain proper and adequate observation of the traffic conditions then and there existing; and (g) In oiling to exercise the high degree of care required of an operator of a motor vehicle entering and/or approaching an intersection. Ill. As it direct and proximate result ol'the negligence ol'Defenclant, Terri L. Rowe, the plaintiff; Bethany \I. I loltry, has suffered extensive and serious personal injuries, including, but not limited to, acute cervical strain, pain in the neck, strains and pain in both trapezius areas, back and right shoulder traveling down through into the right arm. 15. As it result ofihe negligence ol'Defiendnnt, Terri L. Rowe, the PlaintilT Bethany i9. I loltry, has sullered great physical pain, discomfort, and mental anguish, and will continue to endure the saute Cor an indefinite period of tints in the fitulre, to her great physical, emotional, and financial detl'llllent and loss. 16. As a result of the negligence ol'Delendant, Terri L. Rowe, the Plaintiff, Bethany \q. I lolly, has sullered lost wages and will in the future continue to suffer a loss of income and/or loss of earning capacity. 17. As it result of the negligence of Defendant, Terri L. Rowe, the Plaintiff', Bethany N1. I loltry, has been compelled, in order to affect a cure for the aforesaid injuries, to spend money for medicine and/or medical attention, and will be required to expend money for the same purposes in the liture, to her great detriment and loss. 4 1 8. As a result orthe nylWence of Defendant, Terri L. Row, the Plaintiff; Bethany M. I-Ioluy, has been, and probably twill in the Rnure be, hindered Rom attending to her daily duties. to her ,rent detriment, loss, humiliation, and embarrassment. 19. As a result ordw negligence orDefentlant. Terri I.. Rowe, the Plaintifl', Bethany M. I foltry, has suffered a loss of life's pleasures, and will continue to endure the same in the finure, to her great detriment and loss. 20. Plaintiff; Bethany Nl. lioluy, believes and, therefitre, avers that her injuries are permanent in nature. y1' ERITOR2. Plaintiff; Bethany NI. Why, seeks damages front Defendant, Terri L. Rowe, in an amount in excess oftwenly-five thousand dollars ($25,000.00). exclusive ofinterests and cogs. COUNT 11 - LOSS OI' CONSORTIUM INIAIRSIIALL Y. 11OLTRY v. I I?Rltl I. RO11'P 21. Plaintills herein incorporate and make part of this Complaint paragraphs I through 20 as Wildly set forth below. 21 As a result or the negligence of Defendant, Terri L. Rowe, MAY \larshall V. 1-10111-}', has suffered it loss ofconsorlium, society, and corm n't Iiont his wile, Bethany \1. lioluy, and he will continue to sutler a similar loss in the finure. 5 1VI I EREFORE, Plaintiff, Marshall V. 1-foltry, seeks damages from Defendant, Terri L. ROWC, in an amount in excess of twenty-five thousand dollars ($25,000.00), and demands a trial by jury. Respectfully Submitted, IIANDLER, HENNING & ROSENBERG i iI VERIFICATION The undersigned hereby verifies that the statements in the foregoing COMPLAINT are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the above-named COMPLAINT is of counsel and not my own. I have read the COMPLAINT and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the COMPLAINT is that of counsel, I have relied upon my counsel in making this verification. The undersigned also understands that the statements therein are made subject to the penalties of 18 Pa.R.C.P. 2252(d) C.S. Section 4904, relating to unsworn falsification to authorities. BETHANY HOLTRY MARSHALL V. HOLTRY Date: a r?;?? ;• ;.r,q in:\hnnle\ bqa\ Iit igat\ statefriu\ roxve\entry.apr Jellies E. Piccolo. Esquire Supreme Coup I.D. #1FAMS Brigid Q. Alford. Esquire Supreme Court I.D. !!3851)() BOSWELL. TINTNER. PICCOLA R t\'ICURSHAM 315 North Fwnl Street Past Office Box 741 Harrisburg. Pcnnsytvania 1711184)741 Attorneys Il,r Defendant. Terri L. Rowe BETHANY M. IIOLTRY and MARSHALL V. HOLTRY, Plaintiffs V. TERRI L. ROWE, Defendant Draft #I November 29, 1999 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6724 CIVIL TERM : CIVIL ACTION - LAW : JURY TRIAL DE;NfANDED PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter the appearances of Jeffrey E. Piccola, Esquire, Brigid Q. Alford, Esquire, and Boswell, Tintner, Piccola R Wickersham on behalf of Defendant Terri L. Rowe. Respectfully submitted, By: Jeffrey E. iccola. Esquire / Supreme Court I.D. #18018 Brigid Q. Alford, Esquire Supreme Court I.D. #38590 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Terri L. Rowe nber 30. 1999 11 1 i f CERTIFICATF, OF SFRVIC71= 1 do hereby certify that I have served a true and correct copy of the foregoing Praecipe for Entry of Appearance by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: W. Scott Ilenning. Esquire 319 Market Street PO Box 1177 Harrisburg, PA 17108 By: Brigid Q. Alford, rsquire' Date: November 30, 1999 ;? - ,? _ ?_ - ?, _ c., c r BETHANY M. HOLTRY, and MARSHALL V. HOLTRY, her husband, Plaintiff V. TERRI L. ROWE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 99-6724 JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO NEW MATTER AND NOW, comes Plaintiff by and through their attorneys, Handler, Henning and Rosenberg, and submit their Reply to New Matter as follows: 23. Denied. The allegation set forth in Paragraph 23 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, it is denied that the Plaintiff's Complaint fails to state a cause of action upon which relief can be granted, and proof to the contrary is demanded at the trial in this matter. 24. Denied. It is denied damages sustained by the Plaintiffs were caused in whole or in part by the acts or omissions of any person other than the Defendant, and proof to the contrary is demanded at the trial in this matter. 25. Denied. The allegation set forth in Paragraph 25 is a conclusion of law to which no responsive pleading is required, however, to the extent that the t r; i -1- Honorable Court deems a response necessary, it is denied that the Plaintiff's claims should be barred in whole or in part by any comparative or contributory negligence on the part of the Plaintiff, and proof to the contrary is demanded at the trial in this matter. WHEREFORE, the Plaintiffs demand judgment against the Defendant for the relief set forth in their Complaint. Date: / - ,'/- 0 C-OCu Respectfully Submitted, HANDLER, HENNING & ROSENBERG i l" By:' W. Scott Henning, Esi I.D. #32298 319 Market Stree / P.O. Box 1177 Harrisburg, PA 17108 (717) 238-2000 Attorney for Plaintiffs -2- BETHANY M. HOLTRY, and MARSHALL V. HOLTRY, her husband, Plaintiff V. TERRI L. ROWE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 99-6724 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE On the 21st day of January, 2000, 1 hereby certify that a true and correct copy of Plaintiff's Reply to New Matter of Defendant, Terri L. Rowe, was served upon the following by depositing in the United States Mail in Harrisburg, Pennsylvania: Brigid Q. Alford, Esq. BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street PO Box 741 Harrisburg, PA 17108-0741 HANDLER, HENNING & ROSENBERG Date: _ 11) ? C By W. Scott-I4enn ng, Esquire I.D. iJ3 29ti 31 Market Street P.O. Box 1177 Harrisburg, PA?17108 (717) 238-2900 ATTORNEY FOR PLAINTIFF -? : .., - _ -? i. ?V .J ... .J :) BETHANY M. HOLTRY, and MARSHALL V. HOLTRY, her husband, Plaintiff V. TERRI L. ROWE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99-6724 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE On the 21st day of January, 2000, 1 hereby certify that a true and correct copy of Plaintiff's Reply to New Matter of Defendant, Terri L. Rowe, was served upon the following by depositing in the United States Mail in Harrisburg, Pennsylvania: Brigid Q. Alford, Esq. BOSWELL, TINTNER, PICCOIA 8, WICKERSHAM 315 North Front Street PO Box 741 Harrisburg, PA 17108-0741 HANDLER, HENNING & ROSENBERG i Date: By W. Scott?qenning, Esquire I.D. #32298 319 Market Street P.O. Box 1177 Harrisburg, PA 108 (717) 238-2000 ATTORNEY FOR PLAINTIFF Y .. BETHANY M. HOLTRY, and MARSHALL V. HOLTRY, her husband, Plaintiff V. TERRI L. ROWE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6724 JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO NEW MATTER AND NOW, comes Plaintiff by and through their attorneys, Handler, Henning and Rosenberg, and submit their Reply to New Matter as follows: 23. Denied. The allegation set forth in Paragraph 23 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, it is denied that the Plaintiff's Complaint fails to state a cause of action upon which relief can be granted, and proof to the contrary is demanded at the trial in this matter. 24. Denied. It is denied damages sustained by the Plaintiffs were caused in whole or in part by the acts or omissions of any person other than the Defendant, and proof to the contrary is demanded at the trial in this matter. 25. Denied. The allegation set forth in Paragraph 25 is a conclusion of law to which no, responsive pleading is required, however, to the extent that the -1- J Honorable Court deems a response necessary, it is denied that the Plaintiff's claims should be barred in whole or in part by any comparative or contributory negligence on the part of the Plaintiff, and proof to the contrary is demanded at the trial in this matter. WHEREFORE, the Plaintiffs demand judgment against the Defendant for the relief set forth in their Complaint. Respectfully Submitted, HANDLER, _HENNING 8, ROSENBERG Date: By: ??CJ W. Scott n R , Esqui I.D. #3 319 Market Street/ P.O. Box 1177 Harrisburg, PA 7108 (717) 238-2000 Attorney for Yflaintiffs -2- ` s 17, angW Q.:\Ilmd. ISquiu: supreme Cuort I.D. =7559V O. Ld„urJ Sch,,ilat 1\', ISgm¢ Supreme Coun I.O. = 51976 ?OSWELL. r1NTNr:R.I1ICC0L\.F SCICKLRSIU.\I 315 Mmh From SINCE Pust Office Bo, 741 Ilvrti?burc. Nnn,0,=a 171OS-0741 Ammmns (lu Dcf:nJ.ml Rune BETHANY M. 1IOLTRY anti MARSHALL V. HOLTRY, Plaintiffs P. TERRI L. ROVE, Defendant : IN THE COUR'F OP CODIMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-6724 CIVIL TERM : CIVIL ACTION- LARD :.JURY TRIAL DEMANDED AR13l'1'RA'1'10N R11:R10R•\NDUi11 OF DEFENDANT TERRI L. RORVE 1. STATEMENT OF CASE. On ,%,I arch 5. 1995, Defendant. Terri L. Rowe was traveling in an easterly direction on Route '65. The mornin- was very sunny and Rowe was operating her vehicle behind that of Plaintiff, Bethany M. Holtry. As Ms. Rowe and NIs. Hohiy approached the underpass for Interstate S1 (hereinafter" I-SI"), several of the vehicles ahead of them began to stop, to make left cross-traffic turns onto 1-8 L iv1s. Holtry had started to slow down when she stopped abruptly and, without warning, causing Ms. Rowe to strike the rear of Ms. hfohry's vehicle. Ms. Holtry exited her vehicle without any assistance and did not receive any medical treatment at the accident scene. Ms. Fioltly complained of slight neck and shoulder pain, but declined to eo to the hospital for treatment. Later in the day, I'vIs. Holtry went to the hospital and received treatment. The treating physician diagnosed Ms. Holtry with a cervical strain and prescribed a muscle relaxer. Later, Ms Holtry's family physician advised her to wear a cervical collar while driving, but otherwise did not restrict her physical activity. IvIs. Holtry's family physician referred her for physical therapy. Ms. Hot try received physical therapy, comprising electrical stimulation and hot packs on her shoulders and exercises for approximately two months. Because Ms. Floltry did not have any further pain, she and her family physician subsequently decided to discontinue the physical therapy treatments. The physical therapists told Ms. Holtry to be careful lifting heavy objects but did not, in any way, limit her operation of a motor vehicle. restrict her from lifting or carrying her daughter, limit or restrict her from working, or limit or restrict her physical relationship with her husband. ;Months later, on October 1, 1993, Nts. Holtry was opening a file drawer at her office and heard her shoulder "pop." She presented to her family physician complaining orshoulder and neck pain. Ms. Holtry s family physician, again, referred her to the sane physical therapy center. The physical therapy center treated Ms. Holtry as a new patient and opened a new file, citing the pain onset date as October 1, 1993. It. LEGAL BASIS FOR DEFENSE. A. Comparative Negligence. Under Pennsylvania law, a plaintiff's award of damages maybe reduced under the theory of comparative negligence. 42 Pa. C.S.A § 7102 provides that " [iln all actions brought to recover damages for negligence. . . the fact that the plaintiff may have been guilt of contributory negligence -1- shall not bar recovery by the plaintiff ... but any damages sustained by the plaintiff shall be diminished in proportion to the amount of negligence attributed to the plaintiff." A finding of comparative negligence requires that there be "two negligent acts: a breach ofduty by the defendant to the plaintiff and a failure by the plaintiff to exercise care for his own protection:' Carrender v. Fitterer-469 A.2d 120, 125 (Pa. 1953); (see also Lopa v. ,HcGee. 540 A .2d 31 1 (Pa. Super. 19SS); Elder v. Orkrck. 515 A 2d 517, 525 (Pa. 1956)]. "A plaintiffwho acts undercircuntstances in which he knows or a reasonable person would know that what lie is doing is dangerous is merely negligent. His conduct is properly analyied under the Comparative Negligence Act." Berman v. Rwhior Rolls, Inc., 5=42 A .2d 636, 533 (Pa. Super. 19SS) [citing Fish v. Gosnell, 463 A .2d 10-43, 1049 (Pa. Super. 1983)]. In the current case, the facts are such that Plaintiffs actions are properly considered under the comparative negligence statute, 42 Pa.C.S.A § 7103. Specifically, at the time of the accident, Plaintiffwas in the process ofslowing down in morning rush hour traffic on Route 465, waiting for vehicles ahead of her to merge onto Interstate S 1. The morning was very sunny and the parties' vehicles were facing into the sun. Plaintiff has admitted that, as other traffic slowed in front of her, she leaned across in her seat to retrieve a compact disc from its case on the front passenger seat. Defendant submits that this action caused her to depress the brake in such a way that her car came to an immediate, abrupt, and unexpected stop. Defendant, unable to avoid Plaintiffs vehicle,'stnuck Plaintiffs vehicle in the rear. Plaintiffs actions were comparatively negligent. Plaintiff was leaning over in her seat and not paying adequate attention to the traffic in her vicinity. Had Plaintiff been sitting upright in the -3- driver's seat, she would have been able to control her deceleration time, and would not have conic to such an abrupt and toed stop. Instead, Pleintiffwas distracted from the traffic around her because she was leaning over tothepassengerseat lookingfor acompact disc. Plaintiffkncu•,orshouldhave known, that her failure to pay attention, to the traffic around her and to her act of braking, could lead ti a rear-end collision. See Berman, supra. Therefore, Plaintiffs actions are properly evaluated under 42 Pa.C.S.A. 7103 and an award should be entered in the Defendant's favor on that basis. B. Causation. "In a personal injury case, the plaintiff must prove the existence of a causal relationship between the injury complained of and the alleged ne_,ligent act to be entitled to recover for the injury." Lattance v. Silverstrini, 445 A .2d 606, 60S (Pa.Supcr. 19S2) [citing Hanel v. Bashline, 392 A .2d 1250 (Pa. 1975)]. "Generally a plaintifflnust prove causation by expert medical testimony. .. [unless] there is an obvious causal relationship between the two [injuries]. An obvious causal relationship exists where the injuries are either an immediate and direct or the natural and probable result of the alleged negligent act." Id. [citing Smith to German, 263 A .2d 107 (Pa. 1969); Tabuteau t? London G. & A.. Ltd., =40 A.2d 396 (Pa. 1946)]. In the current case, Plainti ffcannot prove a definitive causal relationship between lieralleged ongoing injuries and the motor vehicle accident. Specifically, Plaintiffs emergency room x-rays were negative. She had only a slight tenderness in the right shoulder and a full motion-of her cervical spine, with no specific tenderness. Later, Plaintiffs family physician referred her for physical therapy. Plaintiff went to physical therapy for only two months before she and her doctor discontinued treatment. She had returned to work two days after the accident. -4- Over the next several months, Plaintiffcontinued to work her regular schedule. She drove, worked, cared for her infant daughter, and otherwise conducted her daily activities without any medical restrictions. She vacationed at the shore that summer. On October 1, 1998, Plaintiff injured her shoulder while opening a filing cabinet at work. Plaintiff returned to physical therapy where she was treated as a new patient with an October 1, 1993, "pain onset" date. Subsequent to her October 1998 injury, Plaintiff complained of right shoulder pain and right hand numbness. The physical therapist noted this pain as having stemmed from her work-related injury. In her Complaint, Plaintiff seeks damages for alleged injuries resultant from the motor vehicle accident. However, Plaintiff ceased receiving treatment for her alleged injuries s approximately two months after the accident. Thereafter, Plaintiff injured herself while opening a filing cabinet at her office. Plaintiff also seeks damages from Ms. Rowe for the injuries she sustained at work. Using the Lattan_e standard, Plaintiff cannot prove a causal chain that links the injuries she received when she opened the filing cabinet at work to the motor vehicle accident. Plaintiff injuries are directly related to the October 1, 199S, incident in which she injured her shoulder at work. Plaintiff cannot prove that her injuries were an immediate and direct or natural and probable result of the motor vehicle accident. Lattan_e, supra. The report authored by David Baker, M.D. confirms this fact. If no direct link exists, Plaintiff must prove causation through expert medical testimony. Lattanze, supra. Plaintiff received treatment for the motor vehicle accident for only two months -5- before voluntarily discontinuinn, treatment. Plaintiffs complaints later resurfaced after she injured 1 _ herself at work. It is not consistent with the natural history of sprain/strain type injuries to have six month painfree intervals, followed by the resumption ofsymptonts. Penns Woods recordsof October 1995 also note that Ms. Holtry herself stated 'these sYMPtoms seem to be somewhat different than those experience with her earlier episode:' Thus, Plaintiff's medical records indicate that her injuries resulted from the work-related injury. not from the motor vehicle accident. Plaintiffcannot prove throughexpert medical test imonv that a causal link exists between the motor vehicle accident and the majority of her injuries. Therefore, Plaintiff should not receive compensation from Ms. Rowe for injuries that Plaintiff sustained at work, and Defendant respectfully submits that the Arbitrators' award should be in favor of the Defendant. Respectfully submitted, Bv- Brigid Q. Iford, Esgt Supreme Court I.D. #3So 0 G. Edward Schweikert IV, Esquire Supreme Court I.D. ""31976 Boswell, Tintner, Piccola &Wickersham 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17105-07=41 Attorneys for Defendant Rowe Date: 1 Z o? CERTIFICATE OF SERVICE. I do hereby certify that I have served a true and correct copy of the foregoing Arbitration btemorandum of Defendant Terri L. Rowe by 1-land-Delivering the same, addressed as follows: W. Scott Henning, Esquire 1300 Linglestown Road Post Office Box 1177 Harrisburg, PA 17108 Attorney for Plaintiffs Charles Rector, Esquire 1104 Femwood Avenue, Suite 203 Camp Hill, PA 17011-6912 Arbitration Panel Chaimtan Anthony DeLuca, Esquire 1 13 Front Street Post Office Box 35S Boiling Springs, PA 17007-0358 Laura Gargiulo, Esquire Law Office of Richard Gaffney 2120 Market Street Camp Hill, PA 17011 By: L" ` j? - rigid . Alford, EsgVc Date: _1 2 ti10.; _ Jcllicy E. Picada. Esquire Supreme Court I.D. #18018 Brigid Q. Alford. Esquire Supreme Conrl I.U. N38590 BOSWELL. TINTNER. PICCOLA fi WICKERSIIANI 315 North Fruit Stre.t Post Office Box 741 Harrisburg. Penn,Ylranin 171084)7,11 Attorneys lir Defendant. Tcrri L. Roac BETHANY M. HOLTRY and MARSHALL V. HOLTRY, Plaintiffs V. TERRI L. ROWE, Defendant : IN THE COURT OF COD4MON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 991724 CIVIL TERM CIVIL ACTION - LAW JURY TRIAI. DEMANDED NOTICE TO PLEAD TO: Bethany M. Hollry and Marshall V. Holtry C/O W. Scott Henning, Esquire 319 Market Street Post Office Box 1177 Harrisburg, PA 17105 You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. BOSWELL, TINTNER, PICCOLA & WICKERSHAM By: GA":.6 2 Brigid Alford, Es wire Date: I 110C) m:\ 1101116 bqa\ litigat\ state l'nu1 row6entry.apr Je17}ey E. I'icndn. Is"Suirc Supreme Court I.U. #19018 Brigid Q. Alford, rs%joire Supreme Court I.D. #3S590 ROSWELL. TINTNER. PICCOLA R WICKERSHAM 315 North Prunt Street Post Mice Box 7,11 Harrisburg, Pcnns)'Iraniu 1710907,11 Aitnrnc)'s brc Defendant, Terri L. Rowe Draft #2 January 17,21X70 BETHANY NI. HOLTRY and : IN THE COURT OF COMilION PLEAS DIARSIIALL V. IIOUI'RY, : CUMBERLAND COUNTY, PENNSYLVANIA I'lainliffs V. : NO. 99.6724 CIVIL TERM TERRI L. ROWE, : CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED DEFLNDANT ROWF'S ANSWER TO COMPLAINT WITH NEW MATTER Defendant Terri L. Rowe, by her attorneys, Jeffrey E. Piccola, Esquire, Brigid Q. Alford, Esquire and Boswell. Tintner, Piccola and Wickersham presents his answer to the Complaint with New Matter, as follows: Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph I: proof thereof is demanded. 2. Admitted. 3. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 3: proof thereof is demanded. 4. Admitted. 5. Defendant is Without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 5: proof thereof is demanded. 6. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 6: proof thereof is demanded. 7. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 7: proof thereof is demanded. A. Admitted, except as to the reference to Defendant's vehicle being "immediately" behind the Plaintiff's vehicle. 9. Denied as stated; to the contrary. Plaintiff, suddenly and abruptly stopped tier vehicle directly in front of Defendant's vehicle, and Defendant was unable to avoid impacting Plaintiff's vehicle. 10. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 10; proof thereof is demanded. H. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 11; proof thereof is demanded. Answer to Count I - Negligence Bethany M. ltottrv v. Terri L. Rove 12. Defendant incorporates herein by reference her answers to Paragraphs I through 11. above. 13. Paragraph 13 sets forth a conclusion of law to which no response is required. To the extent a response should be deemed required. Defendant: (a) denies that she failed to be reasonably vigilant to observe position of plaintiff's vehicle on the roadway; -7- rM (b) denies that she failed to operate her vehicle in such a manner that would allow her to apply the brakes and stop before striking Plaintiff's vehicle; (c) denies that she failed to operate her vehicle under proper and adequate control in order that she could avoid striking Plaintiff's vehicle; (d) denies that she failed to operate her vehicle at a speed, and under such control, so as to be able to stop within the assured clear distance ahead, in violation of 75 Pa.C.S.A.§3361; (c) denies that she failed to operate her vehicle at a speed that was safe for existing traffic and road conditions, in violation of 75 Pa.C.S.A.§ 3361; (f) denies that she failed to maintain proper and adequate observation of the traffic conditions then and there existing; and (g) denies that she failed to exercise the high degree of care required of an operator of a motor vehicle entering and/or approaching an intersection. 14. Paragraph 14 sets forth a conclusion of law to which no response is required. To the extent a response should be deemed required, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 14; proof thereof is demanded. 15. Paragraph 15 sets forth a conclusion of law to which no response is required. To the extent a response should be deemed required, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 15; proof thereof is demanded. -3- I:_- 16. Paragraph 16 sets forth a conclusion of law to which no response is required. To the extent a response should be deemed required, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 16; proof' thereof is demanded. 17. Paragraph 17 sets forth a conclusion of law to which no response is required. To the extent a response should be deemed required, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 17; proof thereof is demanded. 18. Paragraph 18 sets forth a conclusion of law to which no response is required. To the extent a response should be deemed required, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 18; proof thereof is demanded. 19. Paragraph 19 sets forth a conclusion of law to which no response is required. To the extent a response should be deemed required, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 19; proof thereof is demanded. 20. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 20; proof thereof is demanded. WHEREFORE, Defendant Rowe respectfully requests that judgment be entered in her favor and against the Plaintiffs on the Complaint. 4- Answer to Count 11 - i,oss ol'Consorliunt Marshall v. Iloltrv v Terri 1 Rowe 21. Defendant incorporates herein by reference her answers to Paragraphs I through 20. above. 22. Paragraph 22 sets forth a conclusion of law to which no response is required. To the extent a response should be deemed required, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in Paragraph 22: proof thereof is demanded. WHEREFORE. Defendant Rowe respectfully requests that judgment be entered in her favor and against the Plaintiffs on the Complaint. New Matter 23. Plaintiffs' Complaint fails to state a claim upon which relief can be granted. 24. The damages sustained by Plaintiffs, it' any, were caused in whole or in part by the acts or omissions of persons other than Defendant. 25. Pennsylvania's Comparative Negligence statute bars all or part of Plaintiffs' claims. WIIEREFORE, Defendant 'Ferri L. Rowe respectfully requests that this Court enter judgment in her favor and against the Plaintiffs. Respectfully submitted. By: lie Jeffrey P. Piccolii, Esquire Supreme Court I.D. #18018 Brigid Q. Alford. Esquire Supreme Court T.D. #38590 BOSWELL,TINTNER, PICCOLA & WICKERSHAM 315 North Front Street, P. O. Box 741 Harrisburg, Pennsylvania 17108-0741 Date: I (7?J> Attorneys for Defendant Rowe CERTIFICATE OF SERVICE I do hereby certify that 1 have served a true and correct copy of the foregoing Defendant Rowe's Answer with New Matter by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: W. Scott Henning, Esquire 319 Market Street PO Box 1177 Harrisburg, PA 17108 Attontcys for Plaintiffs J By Brigidl . Alford 'squire Date: I I 170 -4 n-.,. -j CERTIFICATE OF SERVICE 1 do herebycertify that i have served a true and correct copy of the foregoing Defendant Rowe's Answer with New Matter by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: W. Scott Henning, Esquire 319 Market Street PO Box 1177 Harrisburg, PA 17108 Atuuncys for Plaintiffs By: J L. Brigid( Q. Alford 'squire Date: t i t7 ) it r .. ? i<l DAVID C. BAKER, M.D., F.A.C.S. 19 Brookwood Avenue, Suite 104 Carlisle, PA 17013 (717) 213-9010 Here Ce: ia:_ec :a Z:cacpaecec Surgery ..er..^.er American Acaeemy o[ Octnoe.ecic surgeons October 9. 2000 Brigid Q. Allbrd Boswell. 'fintner. Piccola &: Wickersham 315 North Front Street P.O. Box 741 Harrisburg. PA 17108-0741 RE: Beth Holtr - Dear Prls. Alford: Thank you for allawing me to perform a Record Review on the records you provided regarding Beth Holm% RECORES REVIEWED: 1. Emergency Room record from Carlisle Hospital. 3/5/98. Joey Wisner. PA-C 2. Votes from Dr. Stephen Becker. family doctor. 3. Motes from Penns Woods Physical Therapy. 4. VIRI report of the right shoulder from 11/18/98 and plain film right shoulder views from 1 l: 18/98. HISTORY: The Emergency Room record from 3/5/98 states that the car she was driving was stopped and hit from behind by another car. The speed of the car hitting her was not recorded. IvIs. I lohr was noted to have been wearing a seatbeit. At that time no x-rays were performed. She had "tenderness in the right shoulder." Full active range of motion of the cervical spine was noted with no specific cervical tenderness. Nis. Holtry was seated with Motrin. She presented to her family doctor. Dr. Stephen Becker on 3/6/98. He noted tenderness over the right stemocleidomastoid muscle and right upper trapezius and right paracervical muscles. He recorded that her "seat went back and down:' He referred her to Physical Therapy at Penns Woods. It seems that the patient stopped going on 4/8/98 and was "therefore discontinued from P.T." •" w Page 2 RE: Beth Iloltr: Neit'ler tee Gm,::gcncy Room. Dr. Becker's notes, nor the notes Irons Penns Woods document any neurologic findings. The records then become more confusing. According to the notes from Penns Woods dated October 15. 1995 it states tira. -approximately two Weeks a,o, while at %%ork. the patient was pulling on a filing cabinet drawer when she Iclt a pop that seemed to be in her right posterior shoulder blade area." The record from that visit goes on to state that "the patient states that these symptoms seem to be somccehat different than those experienced with the x:rlicr e.)isude." A separate note from Penns \\'ouds on I I/30 95, however, stated tinder history "MVA as noted. has responded to therapy. s}mptonts ham exacerbated." They listed the pain through the right shoulder, do'.vn the ants and up the neck intemtittentl}'• Notes from Penns Woods on 2/3/99 give a history of ..rap'.d onset last week with pain and spasm in the rhomboid area." The notes from Dr. Becker during this period state that on 10/13/98 °thc patient has been having right shoulder pain v.ilt numbness in the right hand Ibr the last I % months offand on." Dr. Becker's notes from October 27, 1998 st<:t "shoulder is better with P.T. three times last week." It was durine tail: time that the patient underwent an %IRI of the right shoulder. This was perfornied on 1 I/ IS M at Carlisle Hospital. The impression was -normal MR1 examination ofthe right shoulder." II\_1PRI_:itiION: It appears than th,_ patient sustained a sell' limiting cervical sprain at the motor vehicle accident on 3/5/95. From the records. this apparenth improved as she stopped physical therapy and there were no references in her family doctor's rittes until October of 1998. At this point the record becomes unclear. Penns Woods notes of October 15 listed the date of onset of this second bout of pain as "October 1. 1995 approximately injury. " and describe a work Based on the fact that there was a six month hiatus between the cessation of treatment from the March 1995 injury the nl_,r; t o1'sy;,;pto„ s it October; I would not relate the syntptonts in October to the motor vehicle accident in any v;av. I certainly would not relate them to the motor vehicle accident given the record ofa work related injury in approximawfly the beginning of October 1998. All the treatment between March and April of 1995 was reasonable. The treatment from October of 1998 into February of 1999 also appeared reasonable, but aeain. I sec nothing that ties it to the._vent ol'March 1998. It is not consistent with the natural history of sprain/strain qpe injuries to have six month painfree intervals. followed 'n' die resumption of symptoms. Penns Wood s records of October 1998 also state that the Ms. Floltry stated "these symptoms seem to be somewhat different than those experienced with her earlier episode." Page RE: Beth Holm If then: aie any other records that you would like to provide. I would be happy to review these and provide an adden•:hmi to the report. Ifyou have any questions. please do not hesitate to contact m: in writing or by phone. Thank you again. Si Incer::Iv. V David C. Baker. I.D. F r CURRICULUM VITAE DAVID C. BAKER, M.D. 19 Brookwood Avenue Suite 104 Carlisle, PA 17013 (717) 243-9010 License No: MD 043738-E EDUCATION: Residency: University of south Carolina, Richland Memorial Hospital , Dorn Veterans Administration Hospital, Columbia. South Carolina 1984-1989 Internship: U"'ersity of Texas Science Center at Houston, Houston. Texas. Internship - Anatomic Pathology Nov b , em er 1981 to July 1982 Baylor College of Medicine, Houston, Texas . Clinical Internship - rotating, 1982-1983 MMDICALSCHOOL: Doctor of.Medicine (M.D.) - 1977•1982 Uni i . vers ty of Pennsylvania. Philadelphia, Pennsylvania COLLEGE: Boston University, Boston, Massachusetts. 1972.1973 McGill University, Montreal, Canada B.A.. Political Science with Honors - 1973-1977 HIGH SCHOOL: Hempfield High School, Lancaster. Pennsylvania, graduated 1971. BOARD CERTIFICATION: American Board of Orthopaedic Surgery'July. 1992 . HOSPITAL AFFILIATIONS: Carlisle Regional Medical Center. 246 Parker Street Carlisle PA , , Pinnacle Health. Harrisburg, PA Fulton County Medical Center, McConnellsburg, PA PRIVATE PRACTICE: July 1989 to November 1989 - Evans Orthopaedics. Ephrata. Pennsylvania December 1989 to 1993 - Lehigh Valley orthopaedics 1401 North Cedar Crest Boulevard, Allentown, PA 1993-1994 Cayman Islands - Team Physician Cayman Island Soccer Team 1994-1999 - 8so Walnut Bonom Road, Carlisle, PA 17013 1999 to present -19 Brookwood Avenue, Suite 104, Carlisle. PA 17013 ACADEMIC AFFILIATION: Clinical Assistant Professor of Orthopaedics and Rehabilitation. Penn State University, September 1. 1999. Page 2 David C. Baker, M.D. Curriculum Vitae MEDICAL ASSOCIATION MEMBERSHIPS: Fellow, American College of Surgeons Pennsylvania State Medical Society American Medical Association Austin-Moore Society Cumberland County Medical Society American Academy of Orthopaedic Surgeons Physicians Recognition Award for Continuing Education requirements have been met and complied with. American Academy of Disability Evaluating Physicians 1997, American Board of Independent Medical Examiners. September 1998 DAVID C. BAKER, M.D., F.A.C.S. 19 Brookwood Avenue, Suite 104 Carlisle, PA 17013 (717) 243-9010 . ......., __ :.?ec_ca: Aca.?.eny o: J: or.cpa?etc Su:y^2o?s October 9. 2000 Brigid Q. Alford Boswell. limner. Piccola & Wickersham 115 North Front Street P.O. Pox 741 Harrisburg. PA 17108-0741 RE: Beth Hohn Dear ;`:Is. Alford: Thank you PoralloNving me to perform a Record Review, on the records you provided regarding Beth Holtrv. RFCOPCS EE,riEWFD: • • Ente:;.ency Room record from Carlisle Hospital. 3;5/98. Joey Wisncr. PA-C ?. Motes from Dr. Stephen Becker. family doctor. :. Motes from Penns Woods Physical Therapy. 4. MRI report of the right shoulder front 11/1'8/98 and plain film right shoulder views from 11/18/98. HISTOR`f: The Emergence Room record from 3/5/98 states that the car she was driving was stopped and hit from behind by another car. The speed of the car hitting her was not recorded. NIs. Holtry was noted to have been wearin, a scatbelt. At that time no x-rays were performed. She had "tenderness in the right shoulder." Full active range of motion of the •_ervical spine was noted with no specific cervical tenderness. t?ls. Holtry was :reated with Ntotrin. She presented to her family doctor. Dr. Stephen Becker on 3/6/98. He noted ten-lerness over the right sternocleidomastoid muscle and right upper trapezius and right paracervical muscles. He recorded that her "scat went back and down." Fle referred her to Physical Therapy at Penns Woods. It seems that the patient stopped going on 4/8/98 and was -therefore discontinued front P.T." d: . Paue 2 RE: Beth I lohr.. Neither tirle Enurgetcv Room. Dr. Becker's notes. nor the notes front penes woods document an} neurolo-sic findings. The records then become more confusing. According to the notes from Penns Woods dated October 15. 1998 it states that "approximately two weeks ago. while at work, the patient was pulling on a filing cabinet drawer when site felt a pop that seemed to be in her right posterior shoulder blade area." The record from that visit goes on to stag. that "the patient states that these symptoms seem to be sonic\%hat different than those experienced with the -arlier episode:' A separate note from Penns Woods on 11!30/98, however. stated under histon *%IVA as noted. has responded to therapy. symptoms have exacerbated." They listed the pain through the right shoulder. down the amt and up the neck intermittently. Notes from Penns Woods on 2/1!99 give a history of ..rapid onset last ?%eck with pain and spasm in the rhomboid area... The notes from [A•. Becker during this period state that on 10'13/98 "the patient has been having right shoulder pain v: ith numbness in the right hand for the last 1 !,2 months off and on." Dr. Becker's notes from October 27. 1998 star: '•shou'der is better with P.T. three times last week." It was during t)is tint, that the patient underwent an \IRI of the right shoulder. This was performed on I li ts;'98 at Carlisle Hospital. The impression ltas "normal MIZI examination ol'the right shoulder." tI\•1PR1_:i;10N: It appears that th-., patient sustained a self-limiting cervical sprain at the motor vehicle accident on 315/93. From the records. this apparontl% improved as she stopped physical therapy and there were no references in her family doctor's rotes urtil October of 1998. At this point the record becomes unclear. Penns Woods notes of October IS listed the date of onset of this second bout of pain as -October 1. 1998 approximately" and describe a work injury. Based on the fact that there was a six month hiatus between the cessation of treatment from the ,fare h 1998 in 1Ur811:: the ors-1, .)t . s?;;pLOms f1i OCCObCr. 1 wOLilii not relate the eyiiipl0i11S In (iCLUber to the I11GIOf vehicle accident in any way. 1 certainly would not relate them to the motor vehicle accident given the record of a work related igjur• in approximately the beginning of October 1998. All the treatment between ,,larch and April of 1998 %\as reasonable. 'file treatment Iron! October of 1998 into February of 1999 also appeared reasonable. but again. I see nothing that ties it to the ?vent of \-larch 1998. It is not consistent with the natural history of sprain/strain type igiuries to have six month painfree intervals. followed Sy the resumption of symptoms. Penns Wood s records of Octobcr 1998 also state that the Ms. Holtry stated "these sVir.ptonts seem to be somewhat different than those experienced with her earlier episode." I would be happy to review these and provide an wt hesit:ue to contact me in writing or by phone. CURRICULUM VITAE DAVID C. BAKER, M.D. 19 Brookwood Avenue Suite 104 Carlisle, PA 17013 (717) 243-9010 License No: MD 043738-E EDUCATION: Residency: University of South Carolina, Richland Memorial Hospital. Dom Veterans Administration Hospital, Columbia. South Carolina 1984-1989 Internship: University of Texas Science Center at Houston, Houston. Texas. Internship - Anatomic Pathology, November 1981 to July 1982 Baylor College of Medicine, Houston, Texas. Clinical Internship - rotating, 1982-1983 MEDICAL SCHOOL: Doctor of Medicine (M.D.) - 1977-1982, University of Pennsylvania. Philadelphia, Pennsylvania COLLEGE: Boston University, Boston, Massachusetts. 1972-1973 McGill University, Montreal, Canada B.A.. Political Science with Honors - 1973-1977 HIGH SCHOOL: Hempfield High School, Lancaster. Pennsylvania, graduated 1971. BOARD CERTIFICATION: American Board of Orthopaedic Surgery. July 1992 HOSPITAL AFFILIATIONS: Carlisle Regional Medical Center. 246 Parker Street, Carlisle, PA Pinnacle Health, Harrisburg, PA Fulton County Medical Center, IofcConnellsburg, PA PRIVATE PRACTICE: July 1989 to November 1989 - Evans Orthopaedics. Ephrata. Pennsylvania December 1989 to 1993 - Lehigh Valley Orthopaedics 1401 North Cedar Crest Boulevard, Allentown, PA 1993-1994 Cayman Islands -Team Physician Cayman Island Soccer Team 1994-1999 - 850 Walnut Bonom Road, Carlisle, PA 17013 1999 to present -19 Brookwood Avenue, Suite 104, Carlisle, PA 17013 ACADEMIC AFFILIATION: Clinical Assistant Professor of Orthopaedics and Rehabilitation. Penn State University, September I, 1999. :R Page 2 f David C. Baker, M.D. Curriculum Vitae MEDICAL ASSOCIATION MEMBERSgIPS: Fellow, American College of Surgeons Pennstilvania State Nfcdical Society American Nledical Association Austin ,Moore Society Cumberland County Medical Sociey American Academy of Orthopaedic Surgeons Physicians Recognition Award for Continuing Education requirements have been , Amet and merican complied aith Academy of Disability Evaluating Physicians 1997. American Board of Independent Medical Examiners. September 1998 ®' - -1 PLAINTIFFS' ARBITRA T/ON MEMORANDUM Plaintiffs: Bethany M. Holtry Marshall V. Holtry Counsel for PlaintifL W. SCOTT HENNING, Esquire HANDLER, HENNING & ROSENBERG 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Defendant: TERRI L. ROWE Counsel for Defendant: BRIGID Q. ALFORD, ESQ. BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street P. 0. Box 741 Harrisburg, PA 17108-741 BETHANY M. HOLTRY and MARSHALL V. HOLTRY, Plaintiffs V. TERRI L. ROWE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6724 CIVIL ACTION - LAW PLAINTIFFS' ARBITRATION MEMORANDUM 1. FACTUAL BACKGROUND: On March 5, 1998, at approximately 8:00 a.m., Plaintiff, Bethany M. Holtry was operating a 1991 Chevrolet Cavalier and was traveling southbound on Allen Road in South Middleton Township, Cumberland County, Pennsylvania. Defendant, Terri L. Rowe was operating a 1989 Toyota Corolla and was traveling directing behind Ms. Holtry on Allen Road. Ms. Holtry's vehicle was stopped in a line of traffic when her vehicle was violently rear-ended by the vehicle being operated by the Defendant. The force of the collision caused Ms. Holtry's vehicle to be pushed into the rear of the motor vehicle in front of her. The Police Report indicates that the Defendant's vehicle left approximately 30 feet of skid -i marks upon the roadway before impacting the Plaintiffs vehicle. The Police Report indicates that the damage to the Plaintiffs vehicle was "moderate" on a scale of "none", "light", "moderate" and "severe". Similarly the Police Report identifies the damage to the Defendant's vehicle as being "moderate". The Plaintiff's vehicle had damage to the front and rear of the vehicle. II. LIABILITY: Given the facts of the collision, the Plaintiff anticipates that the Defendant will acknowledge negligence, that is, liability, for causing the collision. It is clear that the Defendant, Terri L. Rowe, violated the assured clear distance rule identified in 75 17 Pa.C.S.A. §3361. The Defendant was either following to closely to the Plaintiffs vehicle or was inattentive to the traffic conditions existing in front of her thereby preventing her from being able to stop her vehicle within the assured clear distance ahead. There can be no comparative negligence attributed to the Plaintiff, since she was lawfully stopped due to the traffic conditions. Consequently, as a matter of law, the Plaintiff cannot be found to have contributed in any manner to the cause of this motor vehicle incident. Gross v. Smith, 388 Pa. 92, 130 A.2d 90 (1957). No defenses exist to absolve the Defendant from liability. Defendant was the sole cause of this accident and is responsible for the injuries and damages sustained by Ms. Holtry. III. DAMAGES: Bethany M. Hoitry is a 30 year old individual (26 at the time of the incident), who is married and has one daughter, Samantha. Plaintiffs daughter is currently age 5. Immediately following the collision, Ms. Holtry sought treatment at the Carlisle Hospital Emergency Care Unit. Ms. Holtry advised the attending physician that she was experiencing pain in the right side of her neck and into her right shoulder. Ms. Holtry was diagnosed by the Emergency Room physician with acute cervical strain status post motor vehicle incident. She was given Flexiril and Ibuprofen and was discharged with instructions 1) If to follow-up with her physician. The Emergency Room physician also provided Ms. Holtry with a Disability Certificate to remain off of work for one day. Following the visit to the Carlisle Hospital, Ms. Holtry reported to her family physician, Steven M. Becker, M.D. In the few day span following the motor vehicle incident, Ms. Holtry's pain and discomfort worsened and she developed pain and tenderness in the right lower rib cage area. Dr. Becker diagnosed the right sided cervical sprain/strain, but also included a diagnosis of a right upper trapezius strain/sprain and right sternocleidomastoid strain/sprain. Dr. Becker prescribed physical therapy and the use of a cervical collar. Ms. Holtry attended physical therapy at Penns Wood Physical Therapy commencing -z March 10, 1998. The physical therapist noted that she presented with complaints of right neck and right uppershoulder pain with periodic sequella into the right arm with numbness and tingling sensations. The physical therapist identified Ms. Holtry's problem areas as decreased range of motion of the cervical spine with complaints of stiffness with flexion (bending the neck forward) and extension (bending the neck backward); decreased rotation to the right and restricted lateral tilt of the cervical spine (bending the head to the left or the right). The physical therapy modalities consisted of hot packs, electrical stimulation and ultrasound. Ms. Holtry also underwent manual traction which was designed to increase her cervical spine range of motion and stretch the injured musculature. Ms. Holtry was also instructed to engage in a home exercise program which involved gentle range of motion exercises and the use of a heating pad. 3 1 Throughout the ensuing months Ms. Holtry continued her course of physical therapy and continued treatments with Dr. Becker. The records indicate that Ms. Holtry underwent physical therapy for nine sessions between March 10, 1998 through April 8, 1998. During this time frame she was also periodically seeing Dr. Becker for follow-up visits, including the following dates: 3/6/98; 3/13/98; 3/20/98; 4/3/98; 4/24/98; 5/22/98; 10/13/98; 10/27/98; 11/16/98; i 2/1/99; 7/9/99. Ms. Holtry's symptoms improved to some extent following the initial round of 1 .A I physical therapy, however, she was by no means fully recovered from the effects of the collision and the injuries that she sustained in the collision. During the later part of 1998 Dr. Becker prescribed a further course of physical therapy, which included 23 physical therapy sessions commencing October 15, 1998 extending through February 12, 1999. Ms. Holtry continued to treat with Dr. Becker on a periodic basis throughout the second - round of physical therapy. J Although her symptoms once again improved with the second round of physical therapy, her symptoms did not completely disappear on a long term basis. By June of 2000, Ms. Holtry consulted with Stuart A. Hartman, a board certified doctor, who specializes in Physical Medicine and Rehabilitation, that is, a physiatrist. Dr. Hartman diagnosed Ms. Holtry as suffering from a post-traumatic cervicothoracic strain/somatic dysfunction with myofascial pain with trigger points and a shoulder bursitis. Dr. Hartman saw Ms. Holtry on two follow-up appointments on August 8, 2000 and September 21, 2000. As of September 21, 2000, Dr. Hartman was of the opinion that Ms. Holtry was improved, J but not fully recovered. Dr. Hartman noted that his physical examination revealed that she ? ... WF LL 4 was "still tight at the right cervicothoracis paraspinal region". "She was tender at the trapezius and subocipitally and even at the sternocleidomastoid". Dr. Hartman once again performed an active OMT and advised her to continue with her home exercise program, coupled with the use of ice and heat as needed. Ms. Holtry has continued to have a waxing and waning of her symptoms, that is, good days and bad days. She continues to experience occasional pain and discomfort in the neck, especially on the right side of her body. The pain and discomfort becomes more pronounced when engaging in certain activities, which causes Ms. Holtry to eliminate or modify certain activities that she was accustomed to performing. Since the date of the injury, such day to day activities as grooming, grocery shopping and performing general household chores have been affected by her injuries. Whereas Ms. Holtry for the most part is able to perform these activities, she must pace herself and modify the manner in which she performs the activities. Additionally, Ms. Holtry's leisure activities, such as reading, cross-stitching and playing with her daughter have been at some times eliminated and at most times modified in terms of the duration during which Ms. Holtry can participate in these activities. In terms of lost wages, at the time of the incident Ms. Holtry was employed by Primedia as an Accounting Assistant. As a result of the subject motor vehicle collision, Ms. Holtry missed work from March 5,1998 through March 9, 1998. This resulted in lost wages in the amount of $143.85. Ms. Holtry missed two actual work days. She worked 7 hours per day at an hourly rate of $10.27. 5 Additionally, Ms. Holtry was caused to miss numerous hours on an ad hoc basis to attend doctor appointments and physical therapy visits, although she endeavored as best she could to schedule the appointments so that it would not conflict with her work hours. IV. DOCUMENTARY EVIDENCE: 1. Medical Records from Carlisle Hospital Emergency Room; 2. Medical Records from Stuart A. Hartman, D.O. 3. Physical Therapy records from Penn's Wood Physical Therapy; 4. Medical Records from Stephen M. Becker, M.D.; 5. Medical billing statements from Stephen M. Becker, M.D.; 6. Medical billing statements from Carlisle Hospital; 7. Medical billing statements from Penns Wood Physical Therapy; 6. Wage loss documentation from Primedia and Cowles Enthusiast Media; 9. Copy of the Police Report. 6 V. CONCLUSION: Plaintiffs request the Arbitration Panel to enter an Award in their favor in an amount to adequately compensate them for the injuries that they sustained and the pain and suffering experienced by Ms. Holtry. Respectfully submitted, HANDLER, HENNING 8, ROSENBERG Date: W. Scott Henning; Esi I.D. #32298 1300 Linglestown Roy Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiffs 7 1 [?1; Carlisle Hospital and Health Services 246 P.,ker Biree! Carlisle PA 17013 CONVENIEN flEGNO .., Pw. A C/•Ne -0310 . 717.245-5500 EV ? T CARE/EMERGENCY REGib i m ION 1 p. :204416 `5 03/05/98 10: C LC..AL !, GrW cY 551 SLSI I +:. :?. YG PLII i.CI PAII 4 NUMBE I I 1 1 I PRVIWbNAME E.F:ni1CE ./ 80 75 01 W •`4336509 0.:C-CENT CAIEI iO£ ' I55. OILER I LO .t PflE.CE . ' 1 .NA!E/{DDR 55/Frgv /Ki /bEA/FACc/M1VS. Pq 717) 7 .76-4518 03/05/98 OB:00 NONE F;-cra/ol„EFE+rFLJYEF IROLTR'B THh M : > 361 SRW '4ILL R`D 26Y F W N COiILES 03/14/'71 ' L -1 B5 66'7132: HARRISBURG PA aIENVIL E Pk 1724.1 , NME/{OOFE55/vr01E/fiEUTiON/OCE/SOCSLGNJ. (717)77(•1-4518 • . CIOLTRY, MARSHALL V. KEEN LEASING INC 361 SAW MILL RD . @!EHVILLE Pq 211-62-7876 CARLISLE, PA 17013 , 1 7241 NME/ACOFE59/l,pfc/FELATION/BOPS C+1J WTI?Y OILER, SUSAN (717)776-7452 • 18 6ILL51ATE INSURANCE 75 BLUE CROSS 361 01 Qh C211627B76 026803005 HOLTRY, BETHANY O1 366 uwuxECCMNEN HOLTRY, MARSHALL V. 02 MLE CAL e.SUa,:NCE RLlal FOR visit AUTO Al I STATE BS CC HVA DRIVER BELTED PAIN R SIDE OF NECK 70 SHOULDER GUAP.RACINO, ANTHONY 0 cwMEV REAR ENDED ON ALLEN RG GETTING BECKER, STEPHEN N ON 181 N -) B RIEF VISIT 26700 I C AST POLL, PLASTER 26075 '•;ALL ADDITIO NAL CHARGES - 1 CLASS I VIST 26710 I B/P MONITOR 26037 _ _ - - - , - - - - - - , CLASS 11 VISIT 26720 I PACER PADS 79064 I I I I 1 I I CLASS III VISIT 26730 1 GASTPO/HEMO SLIDE 26060 1 1 1 1 CLASS IV VIST 26740 I KIDD- . c TOURNIQUET 26048 --_----- 1 -_-__-_- r CLASS V 1 MST 26750 I OCL PER FOOT 79670 1 I I I 'I CONIENIENT CARE 1 70 F S B S I I . . . . 80081 ` 1 1 I ICONYNIENT CARE 11 27025 ( TUEE GAUZE PER FOOT 26 - -- - - - - J `- - - - - - - - JMINCR SUTURE EDS01 074 _ _ _ _ _ _ ? ED STAT ESTAT MEDIUM SUTURE EDS 02 PULSE OX CD04 -7` O 1 I I POX ED I I I MAJGR SUTURE ?? ` ? EDS 03? . EXTENDED CHARGcl 26760 _ _ - - - - - - J ` - - - - - - - - J . INTO RATION EDS 04 I EXTENDED CHARGE I r --------1 ?--------1 I 26770 I i t ' N SET UP EDS O6 1 I 1 I - 1 'CARDIAC MONITOR ED511I - I I I PELVIC EXAM EDS 141 ----_--- I- - -1 I r-------- l r-------- - -IN NTR0 SETUP EDS 16 I I 1 CAST,SCOTCH SHORT ARM 26031 I L _ - -- CAST. SCOTCHLONG ARM 260321 ----_-- - _, ?--------1 --____ CAST, SCOTCH SHORT LEG 26033 I 1 I 1 I 1 1 I 1 I I CAST, SCOTCH LONG LEG 26034 I 1 1 I I I 1 ER-0508 (REV. 8/96) C HOLTRY, BETHANY M. MR #280416 03/05/1998 CHIEF COMPLAINT: Motor vehicle accident. HISTORY OF PRESENT ILLNESS: This is a 26-year-old female who comes to the emergency depart- ment reporting the above. She was the restrained driver. She was the only person in the car when she was stopped and getting ready to pull onto 81 behind another car, and someone rear-ended her vehicle. It pushed her car into another car. Significant damage was done to the front, and the back of her car. The patient said that she had a jolt, and then she had immediate neck pain. No numbness, or tingling. However, she said that the pain also hurts slightly in her right shoulder. No previous neck injury. She did not hit her head on the ceiling, or the windshield. No broken glass. No chest pain. No abdominal pain. No other complaints. L? PAST MEDICAL HISTORY: None. ALLERGIES: No known drug allergies. MEDICATIONS: None. PHYSICAL EXAMINATION: Vital Signs - Temperature 36.9, pulse 80, respiration rate 16, blood pressure 120/80. J General Appearance - This is a 26-year-old female who is in no acute distress. She ambulates with- out gait alteration. -Her heart is regular rate and rhythm at 80. Lungs are clear to auscultation. Her abdomen is soft, nontender. No AP lateral compression tenderness of the chest. Neck: There is no specific cervical tenderness. No thoracic lumbar spinal tenderness. Full active range of motion in neck flexion, extension, and side bending rotation. She has slight reproducible tenderness in the right shoulder, but nothing that seems to need x-rays. No AC separation. Full active range of motion in ( upper extremities. Good pulses. Good reflexes. No other signs of trauma. J DIAGNOSIS: Acute cervical strain status post motor vehicle accident. I-, DISPOSITION: She was given Flexeril 10 mg t.T.d. as needed. Do not drive while taking this. She should take Motrin with it. She will follow up'with Dr. Becker. She was given a work not for tomor- row. JLW/dk D: 03105/1998 - 12:17 pm T. 0310911998 Joey L. Wisner, PA-C OVI: 61105 I I Paoe 1 of 1 CARLISLE HOSPITAL ORIGINAL EMERGENCY ROOM RECORD ITAL '-- -- , A 17013-0310 246 PAR iEET CARLISLE P JIENT CARE/EMERGENCY IREGISTRATIOP FOR NURSING ASSESSMENT SEE NURSING DOCUMENTATION SHEET III FWSICAL EXF I I 1- I TIME FHYS'CAN OROE!R 'ATE ?YCST.:N DISPOSITION FROP NGNC TR?:S OTHER curoralcvns.;..FCE 0 SAIAE -<mPROVEO 4 O ED -?O?N?V<NIENT rs "?\CENTcR r CC MVA F NE BELTED PAIN =N'nFlEO r `!RME - N-,, R-SIDE OF NECK TO SHOULDER 950=Y 101 IT RESPONOEO I - f1µv iiv? i4T1EIli NYVBEfl GA N VINE 330036 433550'x." HOlT7+Y; BETHANY o`•e'i E 1 /LE 1541R;N? ^ON M:WfO 1 ?j. i 03/05/33 I0:55 2bY F/y i W L ER-0508 (REV. 6/96) r ( Carlisle Hospital and Health Services CONVENIENT CARE C NURSING DOCUMENTATION g-lt -- NAME. L. ? lC TRIAGE NOTE: 1 , ROOh.I # AGE WT, Mode of Arrival: VITAL SI S: TIME 0 U T --- ? ALS ? BLS j P R , Bp! ?a/ ;SCJ ,f?Amhuiatory i ALLEFOES: NIV-A ?Vlheelchalr ? Carried CURR3dT MEDICATIONS: TIME DATE Chlef Com lnt: LAST Cos- 2. IAST DOSE G' LAST •-t DOSE T Onset of symptomZz_?)M / 14' DOSE Nursing Action/Comments: t 5. LOST Childhood Immunizations: ? UTD ? Never ? •?r S LAST Treatment Prior to Arriv; DOSE PULSE: 1 T• CS Regular ? Irregular 8. LAST (] Full ? Weak ' DOSE LAST ? Shallow ? Rapid ? Audible ? Deep ? Slow Wheeze ? Labored ? Strider ? Retractions 8. - DOSE OLOR: ? Dusky ? Cyanotic SKIN: ? Cool [3 Edema 10 DLAST DS=_ Gootl [I Flushed ? Pale Jaundiced ? Nallbeds ? Circumoral Warm ? Clammy El Ecchymosis P , D PAST .MEDICAL HISTORY: ?/ _.-.. , ry ? Rash ? Laceration Surgery TETANUS STATUS: Hoed. Smoke: Y N ? Within 5 Yeas ? 5- 1 o Yrs ? More than 10 Yrs ? Never) MedicaCPrcblems Drugs: Y tt A!concl: Y N TRIAGENURSe'S SIGNATU lp _,1 ' / , I" l ' Ti RE: 1 L/ l1 \ me to Exam Room: Visual Activity: Pupils: PUPIL SIZES Lung Sounds; Right: ? Rales ? Wheeze OO Right- Size t 2 3 a ? N hl 0-61W Le';: ? Rhoncnl ? Roles ? , Abse; ., OS Reaction 5 a ? ? V;heoza , iq e ® ? Rhoncnl ? A_sen: ? With Glasses Left- Size 0 Pulse Ox: LMP: Witnout Glasses ? WRn C ? ? Reac:on 2 3 4 ontacts CENTAIETERS Thee BP P R NOTES: ?'?ATIENT / FAMILY VERBALIZED UNDERSTANDING OF DISCHARGE-INSTRUCTIONS: ,?/ ?-,?W? L'7 Verhal Instructions By ? N/A L7 giTTEN INSTRUCTIONS GIVEN HlnipA ' ) DISCHARGE: .E1C ['IAmtrdatory ? El So!( Gj Fatuity ? Ambdatory E Assistance []Friend ?Whoeiehalr []Police ?Ambdance []Other - Othe: DISCHARGE NOTES: Special Instructions ?Gereral ?CL`,or ?Aa'Proclem ?Ches: []Muscle Strain ID Work,Schcol c case ?Mergic Reaction ?C:ear Liquids ?Nsaid []Anima! Site []ior DIC ? OCUSplinUCast ?FresripTCns []AntioCt:c ?Cmtenes ?URI ?ASlima LEye ?UTI ?Eack ?Fe at ?vomlling/ofanhea []Earn []FxlSprain ?Wcund Care ? Head Injury ER2012 (6197) Date: Arrived With : ? Police M Friend ? Parent ;- Family ? Self ? Other I NURSES SIGNATURE Carlisle Hospital -- Emergency Departn( , t HOLI BETHANY 246 Parker St. Carlisle, PA 17013 - (7' -5500 3l ):50am DISPOSITION SUMMARY Patient: HOLTRY. BETHANY Age/DOB: _ - SS #: Current Ph: - CURRENT Address: Medical Record: 280416 City: _ Zip: Arrival: 315/98 10:50am Disch:315/98 11:19am Disposition: MD ED: Anthony J. Guarracino. DO PMD: Res/PA/NP: Joey L. Wisner, PA-C PMD Ph: Dx #1: Cervical Strain ICD-9 :1: 847.0 m1 Dx Engl: SPNECK.ESW r1 Dx Span: SPNECK.SSW Dx m2: Motor Vehicle Accident-Driver ICD-9 R2: E819.0 #2 Dx Engl: MOTORVA.ESW m2 Dx Span: MOTORVA.SSW Rx #1: Flexeril (Cvclobenza orine) i 10 m9 1 tablet by mouth three times a day as needed #24 tablets Follow-up: BECKER. STEPHEN M 91 SOUTH HIGH STREET NEWVILLE. PA F1U MD Ph: F/U D/T: Other Instr: May return to work/school: 317198 MY SIGNATURE BELOW INDICATES: > I have received and understood the oral instructions regarding my current medical problem. > I will arrange follow-up care as instructed above. > I acknowledge receipt of the written instructions as outlined on this and as y previous page(s). I will read and review these instructions. J(x J r Jn . r?r7 x 141- /J Patient (or Legal Guardian) Signature Staff (Witness) Signature Carlisle Hospital and Health Services CONSENT TO HOSPITAL ADMISSION AND _ MEDICAL TREATME _ _ Name of Attending Physician (s) ; I - Date of Admission: Time: (AM)_(PM)_ (or . Name of Authorized Representative acting on behalf of) l suf:ering from a condition re ! •a OfPatieat 4uiring hospital care, hereby consent to rendering of such care, which may include routine diagnostic procedures and such is medical treatment as the named attending physician(s) or other of the hospital's medical I staff consider to be necessary, 2. I understand that the practice of medicine and surgery is not an enact science and that diagnosis and treatment may involve risks of injury, or even death. I acknowledge that no guarantees have been made to me as to the result of examination or treatment during this hospitalization. 3. 1 understand that: +j (A) It is customary, absent emergency or extraordinary circumstances, that no ?j substantial procedures are performed upon a patient unless and until he or she has had an opportunity to discuss them with the physician or other health professional to the patient's satisfaction; is (B) Each patient has the right to consent, or to refuse consent, to any proposed procedure or therapeutic course; and (C) No patient will be involved in any research or experimental procedure ii without his or her full knowledge and consent. I? I understand that many of the physicians on the staff of this hospital, including ?I the attending physician(s) named above, are not employees or agents of the hospital but, rather, are independent contractors who have been granted the privilege of using its facilities for the care and treatment of their patients. Further, I realize that among those who attend patients at this hospital are medical, nursing, and other health care personnel in training who, unless requested otherwise, may be present during patient care as a part of their education. Still or motion pictures and closed circuit television monitoring of ' patient care also may be used for educational purposes or for documentation of the clinical ?I course unless a patient expressly requests otherwise. S. I release CARLISLE HOSPITAL from all responsibility for all articles which I am retaining or will have with me during my stay at the hospital, 1 understand this includes clothing, bridgework, false teeth, eyeglasses, jewelry, money, radio, razor or any other item kept in my possession. I understand I may deposit valuables in a safe provided by the hospital; only if this is done will the hospital assume any responsibility for the !; ! safekeeping. 6. L hereby acknowledge that I have received written information on the tonics of i, - Patient Rights and Advance Directives. t i ate of Signature:- I-lc?>Lri? _^o {SIGNATURE OF P IPIENT} 'i ,IPAllC) iSIGoWxURE OF W=TNESS (If patient is unable to consent or is a minor, complete the following:) J Patient [is a minor __ years of age] [is unable to consent because]: , SIGNATURE OF LEGAL GUARDIAN OR CLOSEST AVAILABLE RELATIVE) {SIGNATURE OF WS TNESS} AD 0315 (10/91) Carlisle Hospital and Health Services PATIENT'S NAME: I ?f 1"( ?t I E`I ?l l tt-f.• INSURANCE CO.: Statement to Permit the Release of Medical Information and Payment of Medicare and/or Other Health Insurance Benefits and/or Physician. I authorize Carlisle Hospital as the holder of medical information pertaining to me to release the necessary and appropriate medical information to the fiscal intermediary of the Social Security Administration and/or to my primary or supplemental health insurance company or it's designated review agency for payment for services rendered. I authorize the Carlisle Hospital's and/or. the physician's billing agent to submit a claim to Medicare or other health insurance on my behalf, or to request, on a one time only basis, from the Social Security Administration, such information necessary to complete the claim submission process. I am the individual to whom the information/record pertains, or am authorized to consent, on behalf of the individual, to the release of the information/record. I understand that any false statement or representation knowingly and willfully made or caused to be made for use in determining rights to Medicare benefits or payments may be punishable by a fine of not more than $10,000.00 or one year in prison, or both. I request that payment of authorized benefits be made on my behalf. I assign the payment of inpatient or outpatient hospital benefits to Carlisle Hospital J for those services provided by Carlisle Hospital and/or I assign the benefit payable for phy- sician services to the physician. I certify that the information given by me in applying for payment of Services, under \ ^Title XVIII of the Social Security Act or for any/all other health insurance is correct. ?// Illrll f t.l?l,t Ir Cc I, i1=;.1 y.•r "iY%".) Date .. Responsible Party if Patient Unable to Sign Relationship Date Insured Person's Signature Date (If different from patient or if patient is a minor.) Reason Patient could not sign. Heelthaare Billing Copyj White Canary Copy.-v-. V.gdloa,) Records:/,Ancillary. Departments: -.: AD 1825 (1196) ; . 1 2645 North 3`° Street Suite 490 Harrisburg, PA 17110 717-232-7246 FAX: 717-236-5408 HART, kN REHBILITATION ASSOC. Stuart A. Hartman, D.O. PROGRESS NOTE RE: Beth Holtry SS : 185-66-7132 DOI: 3/ 05/ 98 Claim: 1553022946R34 .TES OC T - v -7000 September 21, 2000 Ms. Holtry was seen for a physiatric pain management follow-up on 9/21/2000, at my Harrisburg Office. She is doing much better overall. She is still getting headaches about once a week that put her down and this is because she takes 2 Phrenalin and they knock her out.. However they do help the headaches. She definitely feels that the last visit the osteopathic mobilization therapy helped significantly. It did not help the headaches significantly because they were still intense but overall she felt much looser in the neck and shoulders. She is getting massage therapy once a week and this does help. She is not using any ice or heat regularly but is using IcyHot. She is not taking any medication regularly other than the Phrenalin. She does continue working. She definitely feels that the weather effects her symptoms and she takes hot showers. Her good days are better overall. Her physical examination shows improved mobility and flexibility in the neck and the shoulders. She was less tender tight and ropey overall. She was still tight at the right cervicothoracic paraspinal region more than the left. She was tender at the trapezius and subocipitally and even at the stemoclidomastoid. She was less tender anteriorly. Ms. Holtry is stable with her post traumatic cervicothoracic strain/ somatic dysfunction, myofascial pain and her bursitis is better. Her muscle tension headaches are better. I again performed active OMT and she was much looser. We had very good mobilization. She will continue with her present program and medications. She will continue with massage. She will use ice and heat as needed and the IcyHot. She will call with any problems or be seen sooner if needed. The massage that she is getting is myofascial release and this is beneficial. I Stu A. Hartman, D.O. SAH/emp r 'cc: W. Scott Henning, ESQ, 1300 Linglestown Rd., Box 1177, Harrisburg, PA 17110 Allstate Ins., 6345 Flank Drive, Suite 100, Harrisburg, PA 17112 HARTi\ N REHBILITATION ASSOC., TES Stuart A. Hartman, D.O. 2645 North SStreet Suite 490 Harrisburg, PA 17110 717-232-7246 FAX: 717-236-5408 I PROGRESS NOTE AUG 1 7 2000 RE: Beth Holtry SS m: 185-66-7132 j DOI: 3/5/98 Claim: 15530229461134 7 -i August 8, 2000 Ms. Holtry was seen for a physiatric pain management follow-up on 8/8/2000. Overall she is doing about i the same as her initial eval. She is still tight in the neck and the shoulders. However, she did feel looser for at least a few days after the OMT. She still gets headaches. She is having good and bad days. She is doing her stretches. She definitely feels that the weather effects her symptoms and she is looser when she takes hot showers. She feels soreness primarily in the shoulders and also is getting some headaches _ primarily on the right. She is not taking any medication regularly. She does continue working. Her shoulder seems to come and go. Her physical examination shows her to be less tender, right and ropey overall. She is tight at the right cervicothoracic paraspinal region, greater than the left. Range of motion is functional with some pulling in the right neck and shoulder. Her strength is functional. Sensation is still slightly decreased on the r , right. Her trigger points were less overall but she was quite tender, tight and ropey on the right. The right was less tender anteriorly. Ms. Holtry is stable with her post-traumatic cervicothoracic strain/somatic dysfunction and myofascial -j pain and shoulder bursitis. She is having muscle tension headaches. I did perform active OMT to the cervicothoracic paraspinal region bilaterally. She was much, much a looser afterwards and we had very good mobilization especially at the first rib. She will continue with her home program and I gave her some samples of Phrenilin to try every four to six hours for her headaches. If this does not work, I would suggest Midrin and she will call for a prescription. She will call if she has any problems and be seen sooner if needed. Otherwise, I will see her for some mobilization in six to eight weeks time. I also discussed possibly some myofascial release therapy. She will call with any problems. i Stu A. Hartman, D.O. SAH/tld cc: W. Scott Henning, Esquire, 1300 Linglestown Rd., Box 1177, Harrisburg, PA 17110 Allstate Ins., 6345 Flank Drive, Suite 100, Harrisburg, PA 17112 u 12000 -1 ??LirdVy-,u HARTMAN REHABILITATION ASSOCIATES Stuart A. Hartman, D.O. ?bnnon Office Harrisburg Office ,,,i & Willow Sts., 3rd Fl. 2645 N. 3rd SL, Ste. 490 Lebanon, PA 17046 Harrisburg, PA 17110 7lephone 717.272.1050 Telephone 717-2324246 M 717-272-1740 FAX: 717-236-5408 June 8, 2000 W. Scott Henning, Esquire 319 Market Street Box 1177 Harrisburg, PA 17108 RE: Beth Holtry SS "M: 185-66-7132 .a DOI: 3/5/98 Claim: 1553022946R34 Dear Atty. Henning: Ms. Holtry was seen for a physiatric pain management evaluation on 6/8/2000, at my Harrisburg office. She denies any previous problems until 3/5/98. She was the driver of a car, which was rear-ended. She denied loss of consciousness but apparently her seat snapped back and to the right. A little later that day, she had pain and started to get a headache and was seen in the Emergency Room. She states that the pain J has always been in the right neck and shoulder and she gets burning from the neck into the arm and hand with some numbness. She had a lot of shoulder pain and did have an MRI and x-rays in the past, which were unremarkable. I did have the opportunity to review these. She has gotten physical therapy on and off for about a year from March until February of 1999. She would get the physical therapy when she would get flare-ups of pain. She has good and bad days. With the cold, rainy weather, she was effected. She just recently started to get some massive headaches. When she lies down, they decrease. She has tried Icy Hot. A hot shower does not help. Today, she is sore. She does have an increase in symptoms with activities. She denies any significant weakness. J She is not taking any medications regularly other than a birth control pill and Claritin. The only medicine she had was in the Emergency Room. She denies any allergies. She does work doing accounts receivable and is on the phone, computer and filing. At home, she has a two and a half-year-old. She does not smoke, occasionally drinks and drinks decaf. She does have allergies but denies any surgeries. -Physical examination revealed a very pleasant, cooperative, alert and oriented 29-year-old female. She is right handed and denies previous problems as above. Cervical spine range of motion was functional i t ?j p w. Scott Henning, Esquire RE: Beth Holtry ro. Page 2 June 8, 2000 except for a slieht decrease with left side bending and left rotation with more pulling on the right. Upper extremity range was normal. Her reflexes were equal and symmetrical. Her sensation was mildly decreased in the right ann. Her strength was all normal. She was tender, tight and ropey at the cervicothoracic paraspinal region with trigger points at Cl, TI and T2 and she was tender at the right shoulder anteriorly with the arm in extension. She had numerous areas of somatic dysfunction. She was t nontender at the chest. i lvls. Holtry is suffering from a post-traumatic cervicothoracic strain/somatic dysfunction with myofascial pain with trigger points and a shoulder bursitis. I did perform some active OMT to the cervicothoracic paraspinal region and she felt much looser. She had better mobility and less pulling. She responded quite well. She also has a very mild shoulder bursitis. She is getting a component of a muscle tension headache. I instructed her in a number of stretching exercises and gave her a stretching chart. She does not need any medications. She does not require any formal physical therapy. She should do quite well and I will see her for follow-up in six to eight weeks time and see how she is progressing. She will call with any problems. Please feel free to contact me if you require any further information or clarification of my report and recommendations. Very truly yours, Stuart hartmanD(O. '-•' . SAH/tld cc: Allstate Ins., 6345 Flank Drive, Suite 100, Harrisburg, PA 17112 I I I I A t 1 D TE. I / L I I PROCEDURE: ?n '°? mwe:ulcmr.nltrn ymniv.wgw.r: :mr _^ liul 4';i0..4S.AliGi'4iL?",r4W(•, yCIM'allliu1111ti7'j?7yrh iy " ?- ;, j; ?P A T I EN T .1' A \I E ? fl s?/(/u1 /? / l y , ? I //S II f I I I i I PATIENT !: / ? j?, Z_ s I I I I I I I I i D7A GNOSIS ???o?/ I ATTENDING THERAPIST i I I I I I ' /J REFE RERING PII1'SI CLAN s? DATE COMMENTS .? .Z ._ I I i i r i ,a l9 I ,.j 't I r RESPONSE TO G SIGNATURE ???„?uon?z?ercc ?I /1IIP?I&tLALTHERAPIST ? i 3 / S- 9L DATE z i 7 I'I it i r t. II b Pfn'SIC.AL TIIERAPIST DATE COMMENTS RESPONSETO _ - TREATG7ENT PAIN RgTING SIGNATURE i Ii. - z I?LEASE REVIEW, SIGN PA RETURN 0 0 9 Physical Therapy 'INITIAL EVALUATION AND PLAN OF DARE Aquatics, Orthopaedics cd Wound Car, EVALUATION AND PLAN OF CART: fa .E.).e'zi 423 Stonehedge Drive ?L Carlirle, PA 17013 REFERRED BY T. 717,240.0330 i y F. 717.240.0233 ONSET DATE: /•9 TREATMENT WAS INITWTED ON: Z - 2^F,j' This Z7 year Ronald D. Greenivay, P.T. Owner was referred to PENN'S WOOD PSYSICAL rr'E.RAPY!cr treas.^e,. of. Koren J. Bair, P. 77. Arrociate Valerie J. Fora, I, p. T. Associate Stacy E. Rorenber,y, P.T.A. i -? Clinic Speeialtier DiLenndnoio AQUATIC rHE.RaPY ..,, &nrmi:in UPPER C-LOY'L.9 EtTP_n}(TYREHAa ,..? WmmdCurr CHRONIC' SOUND CAR-- .? FareraFaer TlQTHERAPY "'1 SporirgLifr 5"OR:S III .J J i , .The Treatment Plan for each problem i as follo•,vs: 7.\ %/1_' .._... .ice Today's Repair. PUlenlidi: I Y f" ?m uwELLE,., ( GOOD i cAIF I I POOR Frequency and Duration ara to be nods per vieek for Z I I Re•evaluatio g vxecks vrth n/RE•certiticatiDn and Goal Revision or (?Q DiLChar a a: the end of this pedcd. ,J I REepe, :^u eUti .... P.T., Karer, Ba! P.T. Piysio!sn CCmmerds/Inst;uCicns: ?? ? _ .? 2.-2-?S Date 1 DCr1CI11r-n r•rD l1 'O 'foe Frob:cros to LE ' a:IdrESSL'd by pay Sl.•d: lf,El'apj ulE as fLI.L:::: r/ In discussing the Diagnosis, Prognosis, and Trealmen: Plan, the I oc follovdng Short Term and/or Long Term Goals: Paden; and I have es:abli;hed the P i i i 4TE AROC 11,17 DATE RESPONSE TO SIGNATURE .-, PAY LR4PIST A /Z/ z9 / S,::?' DATE _i (DATE: / 9® PROCEDURE: /L?I? nK n u ?Wt2 ulw 4 i fL,• ? yr ??n.'w`. n • ni4tmu ta? u1?wJn? ?¢VUIU.• lnnu Jl3ia Li i 7L Z?iwnn err PATIENT a?tE Ave I I I f 1 1 I PaTrENr a /023 cJ I I / US I I I I I I I I I DrAGNOSI• re G.,A _ fff///f AA ATTENDING THERAPIST I I I oo //f? REFERERING PIIYSICIA•, ?QC•?[?- DATE P nRA AA G\I T G. RESPONSETO -°°-•• • 1 rtcx l mtrv I FAIN RATING SIGNATURE /? I I ? - - vs I I I P.T. /z s P.T. /G I I I I P.T. / Z G.i I I - I ? I I I I P.T. I I I I I I P.T. tub ecth•e: Patient comments/resoonses J )blerthe: progress n treatment (Chan2•s in RO?t semen e,,l 111 nc flexabilitv, iunchor 1 burvl PHYSICAL THERAPIST i DATE ii I I -, PHFSICALTHER- FIST ?. DATE _ c. reuau comm.?[5/T25DCf15?5 SASE REVIe'V!e SIGN } R-TURN 1001 Physical Therapy iNITIAL EVALUATION AND PLAN OR CARE Aqua:ies, Orthopaedics & Wound Care EVALUATION AND PLAN OF CARE for ?6GPi!?h. 425 S:or.!hrdg! Drive j ,?? , Drive / Carlule, PA 17013 REFERRED DY T 717 .240330 F. 717.240.0233 ONSETDATE: ?-S-f! TR E7STEdENT WAS INITIATED ON: 3y -;F8 'his- 27 year old j Roua&D. Grecnivav, AT. Owner vrs refr.;ed to PENN's MOOD PHYSICAL THEP.AFY for treatment of. Karen J. Bair, P.T. 'Amocirre Vaterie J. Komun, P.T. Associa:e Sracy E. Rosenberry, P.T.A. Clinic Spru:l:ics Dimn:S:rA - AQUATIC THEPAPY Fxaemieia -' VPPEF C:OU•q;geTp,E,t!;ry;EHAa .WauneCare CHAMIC WOUND CAPS _ FaceTaFare 7A(/THE&IPY "Sparirs?L;n. F oATs aEHAE I _r 4 e_ I: Treatment Plan for each problem is as follows: v - /7//? z CS fJ ^r.+ rF Y 3 ?/S? 7Y? In discussing the Diagwsie. P;ogns;is, and Treatment plan, the patient and I Lave establish?d the Ec90wine Shho/art/ Teerrma?nd?/or Long Term Coals:_ Today's Treatment: eiv.e . rehab. Po:eriial: FAIR FOC..;; Frequency anal Duration aie to be F Visits ervrek for I 1 Re evaloationfRe-•e rtiEieaiion and Goal Revision cr vL. Heeks vi;h iii 'scharge it th e end cf t:is per;od. R'ep?=rye' ..r..edr ' .Ron - -_ •, P.T.. Y.a: en Ear - P T //-2<0 , . . - Ua:e F(ysicis., Ccmmeas/Ins., __tten;. Dare PIE?E1? EQ ro i I. I •,,_ ue,ems a le adoresscd b . Y physic,.:he: apy arc as fa:l::.: s:_- \? ?Il 11?1? ?, ? __ ? I I I ? II ? I I I I Z `I ? I?? J I J S , ? I I ? O I I I I I 2 I ? 3 a kM {k h a W I ? I LLI ?.r d ? I W I I ao I ?o I I ?NKx?lil I IIII a'm ? .., . .: ,,:.... t PLEASE g D 0 0 0 SIGN & RETURN' Physical Therafiy INITIAL EVALUATION: BETH HOLTRY 361 SAWIMILL ROAD Penn's Wood Physical Tilelapy. NE" VILLE PA 17241 Aquatics, Orthopaedics d wound Care DOB: MARCH 14, 1971 DATE OF EVALUATION: OCTOBER 15, 1998 . DATE OF ONSET: OCTOBER 1, 1998 - APPROX. REFERRLNG PHYSICIAN: Stephen M. Becker, M.D. t DIAGNOSIS: Cemical and upper shoulder pain. TRE•ATME\T ORDERS: Evaluate and treat. HISTORY OF PRESENT ILLNESS: Approximately, two weeks ago while at work; the patient %vas pulling on a filing cabinet drawer when she felt a pop that seemed to be in her posterior right shoulder blade area. She states that her'symptorns have been on a continual course of worsening since that time. At rest; she is relatively pain free most of the time but the arm immediately begins to react to any kind of use. She is currently not on any medication. PAST MEDICAL HISTORY: The patient was seen in this clinic -for cervical strain secondary to a motor vehicle accident which occurred on 315/95. The patient states that these ' symptoms seem to be somewhat different than those experienced with the earlier episode. Her general health is reported to be good. Surgical history is unremarkable and fracture history included a nondisplaced wrist fracture that occurred sometime in the past with which she has had no problems. Aller6es mcludc milk and eggs- 'SOCIALIhSTORY: This is a 27-year-old married white female. She is employed doing office type work and has a chill that is approumately one year old. S-. At this point in time,; she is complaining of pain in the.upper trapezius at 8.5/10. At its best, this pain will drop to•a 2/10. She describes her pain as being at the to' of the shoulder with numbness and tingling extending down into the thumb and first two digits of her hand. 01 Nis. Holtry came to the clinic independent of any assistance. --- Mental Status: She appears to be alert, oriented normally and has normal communication. Inspection: Inspection reveals an otherwise healthy-looking white female. She appears to be her chronological age. Posture: She is not posturing her head or shoulders in any unusual manner. RECEIVED OCT:2 31998 1 C? li Page 2 Re: Beth Holuy October 15, 1993 Palpation: Palpation reveals tenderness in the distal portion of the upper trapeaus and sometimes in the anterior portion of the shoulder. i bne cervtc ev uatton was also camed out and there appeared to be some - centralization of symptoms pith neck retraction and extension with'slight overpressure. F,. ti , 11 .1 ? d..o d ROM: Range of motion appears to be within normal ]knits bilaterally. There is some symptom.aggravation particularly with horizontal adduction. Strength: Strengthwise, there appears to be a slight decrease when comparing right to left. This is notable because the patient is right side dominant. ?neurologic As Neurologically, the patient has a complaint of tingling or numbness extending through her arm through the median nerve distribution of her right hand. Sleep/Bed Mobility: The patient reported that she had a poor night's sleep last night but typically has not had a problem with sleeping. Balance: Unaffected. ' Gait/Ambulation: 'Nof applicable. Wound Description: Not applicable. Girth:. Not applicable. Transfers: ..Not applicable. Special Tests: An'Adson's test was carried out and found to be negative . for any type of thoracic pressures to the vascular bundle. Placing the carpal tunnel on slack or the median nerve on slack did little to aMctsymptoms. Tightening the carpal ;tunnel area also did not seem to cause any change in her symptoms. A -11 . unc ona eve, prior to onset. Pauent was y m epen em. m actrvrhes of daily lnulg: TREATMENT: Treatment today consisted of this evaluation followed by moist heat to the right shoulder girdle complex. The area surrounding the brachial plexus was treated with interferential stimulation on preset r2. Also, the brachial plexus tract through the anterior, portion of the shoulder and in the axilla area was treated with ultrasound and the patent was subsequently placed on some neck retraction extension with overpressure types of exercises. Home Instructions: No home instructions were provided at this time. II? j Page 3 Re: Beth Holtry October 15, 1993 _ ASSESSMENT: At this point in time, it was difficult to determine the exact cause of her symptoms because of mixed signals. This could be cervical in nature with mild impitigement to some of the brachial roots or possibly brachial plexus stretch. Other tests seemed to rule out thoracic outlet, scalenus anticus symptoms and rotator cuff symptoms. X - Short Term Goals(To be achieved in 1 week): 1. A determination will be made of the most effective treatment for the reduction j of symptoms. Long Term Goals(To be achieved in 2-4 weeks): t 1. Patient will be reporting a cessation of her symptoms particularly the symptoms in her right arm and hand. 2. Patient will be independent in a home program. . Rehab Potential: Good to excellent. 1 TREAT.?VT PLAINT: The patient will be followed on a three time per week basis to further clarify the cause of symptoms and to subsequently set up a consistent follow up program to achieve the above=mentioned goals. Thank you for this referral.'-. Sincerely, Ro . Greedwjay, .T. Ph sici. s Sigtalture Date RDGkara : fIleamsworks\evcrgicam I I I I I I I i P T h . . ?/ sc x ?o e-ib - I I ?o s- /Sw I I I I T ' . u I J a '0 I I I I IN S S Sc - S I I P.T. s N Z3 _ f, -,6 I I ' /O 2'7 - I c- I I i I ! I I P.T. P LTHER_APIST /o / -ze ; 5'd' DATE - RESPONSETO DATE COid PdENTS TRFATid FNT PAIN PATIA,a clnueru v a 0.0 Physical Therapy . L\TLIAL EVALUATION: BETH HOLTRY 361 SAkArl .ROAD Penn's Wood Physical Therapy NENVVILLE PA 17241 Aquatics, Orthopaedics Q Wmtnd Cart DOB: MARCH 14, 1971 PLEASE REVIEW, SIGN & RETURN DATE OF EVALUATION: 1L-kRCH 10, 1998 7 DATE OF ONSET: MARCH 5, 1998 - MVA REFERRING PHYSICIAN: S tephen M. Becker, M.D. t DIAGNOSIS: Cervical strain - right upper trapeaus greater than left. TREATMENT ORDERS; Evaluate and treat as necessary. HISTORY OF PRESENT ILLNESS: The patient is currently complaining of right neck and right upper shoulder pain with periodic sequalae into the right arm which she describes as numbness with a feeffi4sensation of tingling. Her medications curently include Flexeril which she was given in the emergency room. However. she reports she is not taking it because it "made her fall asleep": PAST MEDICAL HISTORY: Past medical history is noncontributory. The patient's general health is good. The patient does report that she has asthma but has not needed any medication or inhalers for several years. Surgical history is unremarkable. Fracture history includes 'a nondisplaced wrist fracture sometime in the past of which she has had no problems. Allergies include milk and eggs. SOCIALHISTORY. This is a 26-vear-old married white female. She is employed,m office e work She has 'a four-month-old child at home. III j i tYP , .. , S: Currently; she is rating her pain of a 5, ai its worst a 9 and at its best a 2; using a 0/10 scale. Her best is usually in, the morning. She states that her symptoms seem to be aggravated with her work. particularly Towards the iniddle to the end_of the day. She states that she bought a -cervical collar'and has been using it, typically just at home. ' O: Mrs. Holtry came_to the elinic independent of any assistance. She does not appear to be in acute pain. She is not holding her head in any skewed mariner associated %ith muscle spasm. Mental Status: She is alert, oriented normally and has normal'coinmunication. Inspection: Inspection reveals a healthy-looking white female. She appears to be her chronological age and once again, does not appear to be acutely uncomfortable. RECEIVED MAR 2 0. 1998 i- F_ 1l. 1 f', I i i I i I I -, I Page 2 'Re: Beth Holtry March 10, 1998 Posture:' Posture was erect and within normal limits. Shoulder musculature does not show any elevation when comparing left to right. Palpation: Palpation revealed some increase in muscle tone in the right musculature especially the upper trapezius but no obvious muscle spasm. ROM: Range of motion of the cervical spine showed a moderate reduction in all motions with a complaint of stiffness in flexion.and extension. Decreased rotation to the right was noted and rotation to the left appeared to be more freely achieved. Lateral tilt was restricted more to the left than to the right. Shoulder range of motion was unaffected. Strength:. Strength of the upper extremities and neck appear to be unaffected other than the restriction caused by the patient's complaint of pain. . ' ' i i i t Neurologic Assessment: Neurologically, the patient is grossly intact to light.touch and ' pressure at this time. As noted, there is no loss of strength. The patient does state that ' she periodically experiences a "tingly" feeling and that it "feels like its going to go numb Sleep/Bed Mobility: Unaffected. Balance: Unaffected. 'GaiVAmbulation Unaffected. Wound Description: Not applicable. Girth: Not applicable. Transfers: Uriaffected. Special Tests:. Not applicable. TREATMENT: Treatment today consisted of placing the patient in a supported prone position.using galvanic muscle stimulation to the upper trapeaus on both sides with a noted sensitivity to stimulation on the right which would be expected With this type of injury. This was done in conjunction with moist heat. Following this, the area of complaint was treated with ultrasound and pulsed gahanic at 5 pulses per second for approximately 5-7 minutes. This whole area was then treated to a relating massage with a complete cessation of the patient's symptoms. I I Page 3 Re: Beth Holtry March 10, 1998 Home Instructions: The patient was provided with the "Neck Owner's Manual" and encouraged to do gentle range of motion exercises, particularly after using a heating pad or hot water bottle or hot shower. Patient was encouraged to try to change her activities during the day to prevent aggravation of her cervical and upper shoulder symptoms. ASSESSMENT: Acute cervical strain secondary to a motor vehicle accident. Goals(T.o be achieved in 2-4 weeks): 1. Patient will essentially be symptom free and will have returned to . her normal activities of daily living. Rehab Potential: Excellent. TREATMENT .PLAN: The patient will be followed on a hvo to three time per week basis for two to four weeks with a reduction in frequency as the above-mentioned goals are achieved. In addition to palliative modalities for relaxation, manual traction may be utilized to increase range of motion and stretch the affected musculature and therapeutic exercise'will also likely be ..added. Thank you for this referral. ' Sincerely Ronald D. Greenway, P.T. J Physician' Signature a ? I..I r DATE: PROCEDURE: '?/?I 1713111 1 I I 3 kP13 3? 1 ?, -? PATIENT NAME 'J 'c}'`+V+- I I I 1 1 1 1 PATIENT b US Nv 1 ms v5 I I \ I ? I I 1 DIAGNOSIS A k: S ATTENDING THERAPIST l.. I I I I I REFERERING PEYSICIA.N ? V . RESPONSE TO ! c! AMCAITC TREATMENT PAIN RATING SIGNATURE DATE _... _ _ I g4. y V -\ c G n C1' b6 v ?K r t I P.T. c G r\\ CL. x. S cs) \ SwC\?'x S. /S I 5 . Da .aid k .Ws I P.T. 5?w 2 1?0 6-171A l ?? I t n ° _ M 3 I P.T. I I pp?? ? I I P.T. ? ? '/ n\ i C\11?C l T ?i\' ? I fem. IMF P.T. P SICALTRER IS?T DATE 9 _ _ vn?wn?wna®Nma D i i DATE: 1`11 1311° T? = I PROCEDURE: I I PATIENT xralE `ti ? `LSV I I PA TIENT# 1V?3?7 v5 l I I , IAGNosIS . S?-ci.:_.••??LQIti-? ?--?.p ATTENDING THERAPIST \LC."?lJ?"`" I I I 1 RE FE RER ING PHYSICIAN RESPONSE TO DATE COMMENTS TREATMENT PAIN RATING SIGNATURE (V kz'Q-X N x L4 nr?- i nnr? t-) ' t 1 P.T. 14 p -L I. ,-? coo ; s . -rt- I 1 p? Q 31 ?. 3 rte, , VJ ?? \ V Gt\ ('" F \= (. i I P T tub :'G'•, ' •. 1 .?.c.,:? . . . Lf .a I P T I I . . I 1 I P.T. I I I I ?, I 1 I I I I P.T. Sub ecttve: Patient comments/responses ')blecitve: progress in treatment (Changes in ROMf stren+h endurance flexability funcdo^al abl•'tvl \ssessmmt: Changes in status or cooperation (Specific references to current physical capacitv relevant to disability) PHYSICAL L DATE Physical Therapy halal Patient Name: DX: _J - & Precautions: Please evaluate and treat with the tollolvin recommendatlons. V Ph7 sicians Signature Freq. l4VK. Fechec% Wae%s 6!usa2 rr2nc:h a^d CGCi;'.rina v:di be evalualea vn;h abz=v,ale esl:ng when apor:ar:a:e. N2crcnusa ar facillta::tn, prcproc-::,e yvamml; and AOL irs:%caan mil be inccrpc'Ved ir:c all arrcpa:e rehZti :;t;icn prpSrans. Ronald D. Greenway, P.TlOwrer Karen J. Bair, P.T./.•Lmra:e Valerie J. Kere;m. P.T.L•Umcixe J15 Sronere?ge Dcite Carlin,, PA 17013 Te!. 717.2?0.0330 Fax. 717.240.0233 l ? I i ' =ahl STEPHEN SE.KEP., M. D. i i I I i 1 .: I' I I i J I I i i J I PHONE NO. 717 7754391 Nov. 23 15'3a 02:45Ph1 P1' Date: 1L? '7 0 PhysitalTkcruDY-`?%t'-\ ^1?'?/?J Patient Namel (`?l DX-. Precautions: .tear, ruc commendations the pleasefollowing re Physicians Signature RecheCV ` we-,Ks PNK, Fria % e-ndifi0nine will be evaluate0 vr.:^ appmQnalE t:5lir:y III to stranrJlr an' ve training any AOL ,u. Ncumm•=fcu:a: hptllation. DtoFriocrptl vn.un OCC•^p•b ;,,1? u, uvu•w.;..!r. rf,..:7i'it>tinn fdc.: Y'?=• FRDI STEPHEN EEC::EB, M. D. :. - i mot` ?' r'/ty.t iA'rrl Tt...... Ay /, /?- / O .up.•%,, bM.e, Patient NaMc; DX: P: Please evaluate and treat with the n following recommendations. ? i Physicians Signatura Przq. /WK, Recheck--._.._.., v/ 7 I-0JSCIC :IrC;la;O ;;p, CundiOCnin wiL dedS whG'n r.fJpr00:Id:Y. NGJICRIUY.'.L'?d9' larili(edpWperL v".'pIl'lCM:f?Jp?9I? (?$!In(j ., Instn:aicn wCl en Ictmpr,,ra•er. n1;p cll 6opro 7 arU P,OL 1?,(? Roncld D. Grrrn;usv, P.'iaUu•r.;r 1f1t1? Karen J.Bnir.P.T.fiuco;i<:< :r 0c:. !3 19y:3 02:57PN Pi r_ 0 N I ? '. Macy- ee? •n Physical Therapy .• Data: -?-p _ ( r .y,.•x,.. o.,brdv., e ua.??w!! c• PatienttName: frIl DX: CP.i 1)lM S? tom! t1 Precautions: Please evaluate and treat with the following recommendations... uaQ QS '0 hr 2 n, Physicians Signature Freq. M1K, Recheck Weeks Muscle s:.engtn and cordltiomrg will be evaluated with appropriate testing wren appropriate. Neuromuscular lacililation, propdocepCw training and AD! Ins;mC.ien will be Incorporated Into all apprcpria:e rehabilitation programs. Rorer D. Greenuay, P.T./Oumer .. Karer.l. Bair, P.TlAssociete . .. 423SronehedgeDnte Carlisle, PA 17013 Tel. 717.240.0330 • Fax. 717.240.0233 i V n" m Ol Y U N m J JUN 0 :000 STEPHEN N1. BECKER, M.D. 91 South High Street V,--; 0 Nm%ille, PA 17241 , Telephone: (717) 776-4495 Fax: (717) 7764391 June 1, 2000 Handler Henning & Rosenberg Attorneys At Law 319 Market Street PO Box 1177 Harrisburg, Pa 17108 RE: Beth Holtry DOI: 03-05-98 PT SSN: 185-66-7132 DOB: 03/14/1971 Dear Atorney Henning: KAU? I have been following Beth Holtry since October 3, 1994. Prior to reported MVA of March 5, 1998 she had been without complaints referrable to the neck and shoulders. I first saw Mrs. Holtry after the MVA on March 6, 1998. Since then I have seen her for issures related to this on March 13, 1998, March 20, 1998, April 3, 1998, April 24, 1998, May 22, 1998, October 13, 1998, October 27, 1998, November 16, 1998, February 1, 1999 and July 9, 1999. Please refer to my office notes for a narrative description of the symptoms and treatments. I believe that the MVA of March 5, 1998 is the direct cause of Mrs. Holtry's ongoing neck and shoulder problems. While no one can predict the future, the chronicity of her problems to date, would lead me to belive that she is likely to have ongoing problems for years into the future. I am unable to assign a percentage of disability in accord with the AMA Guidelines. I belive Mrs. Holtry will be in need of continued treatments on an occassional basis in the future. Physical therapy has been helpful in the past and I suspect it will be needed in the future. Questions or comments can be directed to the telephone number listed above. Sincerely, 49??? Stephen M. Becker, M.D. SMB/ljl STEPHEN M.BECKER MD 91 SOUTH HIGH STREET NEWILLE, PA 17241 Lss ::ng o! comments for Batt Holtry Coda Date Comment -' ------------------------------------------- -- CC-Auto atcid............................................... Sub- At stout a An Yesterday i vlnq ape Las her ehavy cavalier uhan she vif' r..r ended at a atop sign. Had sea: baalt on. No asrcags, All she knows is sat her ue: sent back and dovn. Does no. remember of coneip hittin h g aanep er hear. No loose s. Had same aorv ' t _1 nasf In her neck light after he ac::dent and . he. w s w of vea urday at I orse this AN. Went W the :OICO and she wa OS hat a no, .k -train. Had vsn flazo rll antl told she Cage the.vas soma pain ever tee right lover rib noticed t his An• 0bJ- 100/70 PS2 lase rl-I Tendelne46 of :pe right a p i gh. r orno. I Boom.. told and the O ht nd ri ' g cue Cervical muscles Tenear tea a OI the floati r.g,t ng rite anteriorly on the Asses-Cervical strain ' Co.;,,sad ribs Plan-PT refer,,: - red Carl Cervical collar Fle.oril HS F-Check one ueok T PUl N N ..... Imb .............. " . 4"A CC-f r"a ?? 03-CO-iB •.-Carvlcai -',,in ........................................ Sub- Was filing Yesterday and she really hurts today. Has mare P - p 1 , bap next week . OCJ- 0 00 1 1 t, 1 57.1 14-# r.2 Still 1 it, some .encerness in the th 11? e right poor trap, P>L and at v.noc lad.mastocd FSCC in the ne11: with Pain uhan she flexes to the left DTAI. sym Asses-Cervltal strain ' ' Plan-Continue PT and stretching l Facnack in C veeks PUl sot ry .v.. OJ-0C-S2 . •c , CC-Cervica l ••••• ........................ s t ra i n I.VA. B/P 1 Sut- Th ere are d ata It is f_ne. Has an at out tatter ate CiYS that it is Ott' 1lD/T 14Cpeaka rhC,=,.madp. :enoefneas in t"o •ipber trap bilaterally no the ' DTR•s sYm Sensory intact • Asses-Cervical strain ' Plan-,Recheck in p veeks ii Ccntirue the streahing and use iachemic comp....... over the nc?m c•p:e a. Pur sot .,u 04`4....,.....••. •. • ....u ,vuuvvvv,vvuv,uu.u. CZ--e dit-l 6 train ? Sub" The neck pain had be-n on and of! until it rained on Su MBAY and sin th ce en It has coon sor.. Not ...r If A. bad as it had been. She kncvs it is there but it nn not kept her from doing thing.. Dn WBdnesday at h e ad tingling In some l her right hand voila she as u..... .. : In Led for .•l0 -Bond-. Has rot returned. Work-maK.s Phone Cil{a, Sits in front of a Computer and fi{as. CbJ- : Neck-tendarresa in cte rhem]oih •m inimal sternoc leddmas:olds-ok l3PPer of hock trap with ..as, and :endernosi tov.rde bas. • tome tandernesf in the fight Pa.. Cef Vl[al m•?s<les Can flex the neck nornally. S]o lda. - u s n-C o nal sera in im:roving F lAnC rti -OLidue the sere aping but try :o do a: l ent 3 Per day. C Beiheck L. 4 veeks. sot 1 Progress Notes 91 SOUTH HIGH IGH 5 i REF SET - RPl lr?.fLT, 114 ( ?i ! .T: Progress Not es Name STEPH ' ` '1 EN Account « OUTH ` H r, ,., _ IGHS ... DATE 'I . _y 11 C. z [ .11 V, Ile -51 -vm I i 1 BP CProgress Notes . 91SO AFI IGt3H H ST KcH FIO Bi EMIL H 172CI C Account NWILLE, PA F Progress Notes vvr 1;6( Ill Q- 'A/) P y/ qR ry/ n i?i/m / /TTTicGA r nv???y?J //i<?j! lZ? t ??1.. Patx/^ i r' _ 7?s-cu?T Carlisle Hospit, DEPARTh '.. OF RADIOLOGY and Health Services 246 Parker Street • P.O. Box 310 • Carlisle, Pennsylvania 17013-0310 • (717) 249.1212 CARLISLE IMAGING ASSOCIATES, P.C. HOLTRY, BETHANY 27Y 11/18/1998 361 SAW MILL RD. X-RAY #90872 NEWVILLE „ PA 17241 MED. REC. #280416 DR. BECKER, S. MRI OF THE RIGHT SHOULDER The MRI examination of the right shoulder was performed in the oblique coronal, axial and sagittal planes of imaging. This examination shows the supraspinatus tendon appears intact. No signal abnormality is seen within the tendon or rotator cuff to suggest the presence of tear or tendonitis. There is no evidence of impingement. No signal abnormality is seen within the humerus 'or scapular glenoid. The soft tissues are unremarkable. IMPRESSION: Normal MRI examination of the right shoulder. ¦ RIGHT SHOULDER The views of the right shoulder in two projections show no fracture or other acute osseous abnormality. No destructive or erosive bony changes are seen. The soft tissues appear normal. IMPRESSION: Normal radiographic examination of the right shoulder I AF A=1 n KEITH S. PUMROY, M.D. KSP/mn T: 11/18/1998 02:31 pm U Cr"F-1iTUyS1C1A,v t ?I ATTENDING PHYSICI.4-N. "S REPORT Date Policyholder 01-20-99 Beth Holtry Date of Accident File Numbe: PLEASE NOTE: THE A 03-05-98 TiENDING PHYSICIAN SHOULD COMPLETE 153302-1946 THIS REPORT AND RETURN IT DIRECTLY TO: Tna:esa Salirge- AMstate Insurance Company 6345 Flank Dr., Suite 1000 Harrisburg, PA 17112 i. I I i.. 1. Patient's Name and Address 2. Age l7 3. Sex F 4.Occ4Fation (if know-,) - - S. History of Occurrence as Described by Patient & 0,1 ;/1-/-?? Div ?-,+m . h, llrlGl c cd 6. Diagnosis, Diagnosis Codes, and Cc turn tl1or Cont-ibuting Conditions Ct9-' G2l S? /n /p 6q, 7t46 e,? I-lb-T / 7. When Did Svmptoou Fist, ppear? Date: .T 1 ?t/q? • -lkTlulC I ?_/) S. When Did Patient First Consult You for 9. Has Patient Had Same Si this Condition? Date: / G or milar Conditions? YES ,o (circle one) If "YES- state wh d ' , en an describe 10.ls ditionSolelyaResultofThisAccident, 11 O (circl " " e one) If NO , Explain' 11. Is Co n Due to Sickness or Injury Arising Out of Patient's Employment? YES i' (circle one) n / / 12. Will Injury Result in Permanent DisfigurementorDisabilih•? uRTwY Pr n¢5 /??? Y=S / ^SC ,ci c'.e cne) If "YS_u" • - p n73 ?"t D?r 2J? 'b , . P x yri t s/7?r<. .n k $u t? uee-z(.tT ?? r i??n P?'Isr?'r? 13. Patient Was Disable (Unable to W or From: Through: ) 14. If Still Disabled, Date Patient Should Be Able to Return to Work: 16. I?°-tient Still Under Your Care for This Condition? (x? / NO (circle one) Estimated Future Charges S ?aen //` [Sf3?r Carlisle Hospiti-') DEPARTMOON OF RADIOLOGY and Health Services 246 Parker Street* P.O. Box 310 • Carlisle, Pennsylvania 17013-0310 • (717) 249.1212 CARLISLE IMAGING ASSOCIATES, P.C. HOLTRY, BETHANY 27Y 11/18/1998 361 SAW MILL RD. X-RAY #90872 NEWVILLE „ PA 17241 MED. REC. #280416 DR. BECKER, S. MRI OF THE RIGHT SHOULDER The MRI examination of the right shoulder was performed in the oblique coronal, axial and sagittal planes of imaging. This examination shows the supraspinatus tendon appears intact. No signal abnormality is seen within the tendon or rotator cuff to suggest the presence of tear or tendonitis. There is no evidence of impingement. No signal abnormality is seen within the humerus or scapular glenoid. The soft tissues are unremarkable. IMPRESSION: Normal MRI examination of the right shoulder. RIGHT SHOULDER The views of the right shoulder in two other acute osseous Projections show no fracture or abnormality. No destructive ear norms or erosive bony changes are seen. The soft tissues appear normal. l . , IMPRESSION: Normal radiographic examination of the right shoulder. ?J KEITH S. PUMROY, M.D. i. KSP/mn T: 11/18/1998 02:31 pm 1 CHART/PHYSICIAN I ¦III?IiMI 1 - _ 4 ? Code Date ---- -------- 02-26-97 I 11-04-97 L' 03-06-98 )ephen M. Seckea, M. D. Lenting oG comments {got Beth Ho.etty Page: 4 11-25-98 Comment ------------ --------------------- hc9-po4itive --------------=- smb/t,jt = CC-Sinu4 Sub- Has been Nasat can sick since Sunday with head conges.t.ion. In xhe 9esxion, PND and bad xast in the back mouth. morning and at night the seetet Obj- 110160 p64 HEENT-yettow secaetiun4 9inathe 129# ion4 tae o 0G 6 n12 tthhe the m tendetnes4 to percussion oven the the tight no.6tt t; Neck-nad y sinus Lungs-cteaa A4•aes-Sinusitis ptan-Augmentin 500 bid Gat 7 days PUI smb Dischan5e summany.... tehm pae9nancy. detivened 26 yo GtP1001 nuchat toad times two Detiveau oG a 3300 gram ¢emate inGcnx with Apgaa.s oG 8 and 9 rnGant wag Rh positive and the mother is Rh negative and received RhoGAM in postpaatum smb/tit CC-Auto accident__________ Sub- At about 8 AM eavatiet when 4he was teat tended ateawt p sign. het Chevy beatt on. No aiabag4. Att she knows stop sign. Had seat back and down. Does•not remember hit14enthat her seat went o{, cunciuusness. Had some muteness 9 hen heat. No tuose the accident and xhax was woten in hen neck tight a-6t et yesterday at 10: this AM. Went to the ER had a 30 and she wa4 given Gtexotit and turd she neck s.ttain. Had some pain oven the tight tower 'rib cage thatwas 4it4t noticed thi4 AM. Obj- 100/70 Tendetnes,s o p68 1449 t12 tight u G the tight 3teAnoctedoma4toid and the ppet trap and tight papa cetvicat mu4cte4 tight Tenderness over the Gtoating nibs antet.Loaty on the Asse4-Ceavicat 4tnain Contu4ed aibs ptan-PT re{,et,tat Med dens cetvicat cottar Ftexotit HS Recheck one week PUI CC-hIVA ---------------- I - phen M. Becket, M.D. Page: 5 Li4ting of comment4 tun Beth Holtry 11-25-98 Code Date Comment ---- -------- ------------------------------------------------------------_ _ Sub- The pain i4 basically in the tight zhoutdc& area. The rib area i4 not sore now. Ha4 been to PT 3 times la.et week. 1.6 able 4.o get away without the collar. i Obi Still with 4ome tendetne4s in the tight upper 4ternocledoma4to.id and the tight trap and thomboid4. DTR's 4ym A44es-Improved plan-Continue the PT Recheck in i week. Ha4 continued with work. PUI 4mb _i 03-20-98 CC-Cervicalk 4tr.ain Sub- Wa4 tiling ye4teaday and 4he really hurts today. Ha4 2 mote PT appt next week. Obj- 118/80 p100 97.1 1439 t12 Still with 4ome tendetne4s in the uppet trap, R>L and the tight 4te4nocledoma4toid FROM in the neck with pain when 4he 6lexe4 to the left DTR'4 4ym A44e4-Cervical 4train plan-Continue PT and 4ttetching Recheck in 2 week4 PUI J 4mb --- 04-03-98 CC-CetvicaLk strain 4/p MVA Sub- There ate day4 it i4 better and day4 that it is tine. Ha4 been about 4 week-4 Obj- 118/72 143# Some tehdetne4s in the upper trap bilaterally and the thomboid4. DTR'.4 s_um Sensory intact A44e4-Cervical 4ttain I plan-Recheck in 2 week4 ? J I Continue the 4tretching and u4e i4chemic compte44ion oven the rhomboids. PUI 4mb 04-24-98 - --------------- CC-Cervical strain Sub- The neck pain had been on and 066 until it pained on Sunday and 4inee then it has been sore. Not nearly as bad a4 it had been. She knows it i4 there but it has not kept -- hex (,nom doing thin-9Z. On Wedne4day .size had 4ome tingling in het right hand while she was wtiting. it lasted ton 5-10 4econd4. Ha4 not returned. Work-make4 phone calf,sU-s in ttont of a computer and ----- I Code ---Date I - If If __== 05-22-98 tJ II 1 1 II 1 I 'ephen M. Secken, M.D. Page: 6 Listing oU comments 6o4 Beth Hottny 11-25-98 Comment --------------------------------------------- ---------- - Uites. Ob,j - Neck-tenderness in the rhomboids-mintmat zteanoctedomaztoids-ok 06 neck Upper trap with spasm and tenderness towards base musctes come tendeaness in the night papa ceavicat Can {tex the neck no4matty. Shoutdens-nad Asses-Ce4vica.e strain imp4oving Plan-Continue the .stretching but .try to do az teast 5 times per day. Recheck in 4 weeks. smb CC=Cenvicat stain Sub- as tong a.s it is not 4aining she is {.ire. Obj- 110/70 p88 98.6 i38K a12 Sti.e.e with home upper t4ap muscte tenderness Asses-Cervical strain essentiatty nezotved and ctea4ty better Ptan-Continue the 3taetches and aeeheck pan. PUI .smb Progress Notes Account # f 3 STEPHEN M.BECKER MD 91 SOUTH HIGH STREET rP(s•L? /'i-i j = ?1 4.1 HT &5T1 Arll-- ha /nz ,j/ rte, h„ 'i - ic< in wnn/? ? J lrir4 1 j" Progress° Notes Name' i e -+ STEPHEN'm Account » 9 SOUTH HIGH STAF: DATE 0 l VVI BP •Tq?? (1 d iMA'- . iwn/l?? 4,?i 042 ??? ._?-er hol?r?! ?raA?r,??,,,?d? ?ri•? ?? r 17.,,,,,-? -??/- r/tr,ht .. ?. uti/?r .?75'?3 I/ T E Gl oris,7 0 ?- Gf G G?JCL. l? re 6,1 ;._ . , . L)All: i BP' _? (A1J L( ko (` .S ?.nrC/?/ii- , ?Z?'71??a? • ;?-?c, ? dCC? Cpl,-?-- d6 i ktL EiiiT ,•% ti S - htutnh ^G(?i--: -- ?- - `"C7c fro ,hl l?Ff} 9 ; MM 7 ,Yel' TF 31 a? l9 .. _ i' i - ? .J I Progress Notes r' Name -+-0m,, J jI -, C 1 1(e 8' Account k WT F R , _J .ry I J "SGUHSIGHS E?iD r AEnVIL E.Pa nn., - `C . ?C 1 d Y U d m O N m ?'1 1 Stephen M. Becker, M. D. 91 South High Street Newville, PA 17241 (717) 776-4/95 Beth Holtry ' 361 Saw Mill Road Service Rendered: 03-06-98 Newville, PA 17241 Pat. SS #: 185-66-7132 DOB: 03,114171 _ Patient #: 00839 .•? Diagnoses: Family Balance Prior To This Visit Was: 0.00 .?. 1) 847.0 Cervical Sprain 2) 924.8 contusion li s (multiple sites) Procedure Code Description Diao POS Re'# Amount 99213 Estab Patient E /M, level 3 ___ ____ --- ---_ 3 12 55.00 i -i W Insurance coverage remaining: 0.00 Total This Visit:. 55.00 Plus Prior Balance: 0.00 New Family Balance: 55.00 --------------------------------------------- Doctor's Signature (I' P. , i TIN #: 59_2 License For Insurance) :+5200 Li c•:_-se ;#: MG04'469L StephcC? M. ?..vcker, M. G. 91 South Hiwh Street Newville, PA 17241 (717) 776-4495 'geL'h Holm Service Rendered: 03-13-9.4 Col Savor Mill Road N---wville, PA 17241 "at: `.•°. 135-66-713:? DOS..: 03/14/71 i ?,ti?rrt' tt: 00839 Family Balance Prior To This Visit Nn.sc 55.00 ' r _nnoe"a 1) 547.0 Cervical S grain Proce.:fur.> code Da_cription Dia9 PO ; -Re ? - It Amo!rn!. -- ,'J17 1.3 Estat, Patient E/M, level 3 3 1 55.00' Total This Visit: 55.00 .J Plus. Prior Balance: 55.00 New Family Balance: 110.00 .)::!-.SUrenr_e covera<ie remaining: L?. on _ 1 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Doctor's Signature (IT Required For Insurance) ! TIN #: 59-2952200 License #: M0043469L Beth Holtry Service Rendered: 03-20-9 1 361 Saw Mill Road - Newville PA 17241 r Pat. SS #: 185-66-7132 DOB: 03/14/71 Patient #: 00839 -I Family Balance Prior To This Visit Was: Diagnoses: 1) 847.0 Cervical Sprain F Procedure Diag 55.01 ., Code Description POS Ref# Amoun* ----- ------------------------------------------------------- • 99213 Estab patient E/M, level 3 3 1 55.01 Total This Visit: 55.Ot Plus Prior Balance: 55.0 ?i Insurance coverage remaining: 0.00 New Family Balance: 110.01 ^ 1; IJ ? I J -¦ Stephen M. Becker, M.D C 91 South High Street Newville, PA 17241 (717) 776-4495 ----------------------------------------------- Doctor's Signature (If Required For Insurance) TIN #: 59-2952200 License #: MD043469L Beth Holtry 361 Saw Mill Road Newville, PA 17241 Pat. SS #: 185-66-7132 Patient #: 00839 1b vi soutn nlgn street Newville, PA 17241 (717) 776-4495 DOB: 03/14/71 A Service Rendered: 04-24-98 - Diagnoses: Family Balance Prior To This Visit Was: ' 1) 847.0 Cervical Sprain Procedure Diag Code Description POS Ref# I ----- ----------------------------- ____ 99213 Estab patient E/M, level 3 Insurance coverage remaining: II ?. Total This Visit: Plus Prior Balance: 0.00 New Family Balance: 0.00 Amount 55.00 55.00 ---- 0.00 55.00 ----------------------------------------------- Doctor's Signature (If Required For Insurance) TIN #: 59-2952200 License #: MD043469L A w i .j rrn i 1 ? l t t? 1 ?G T ^ 9 1 v t L krt J its; 3, 1 11. 1 11 TII 1 ,' .. Nt. ? + t Stephen M::Becker,.M.0 . - 91 South kl9h;Street - Newville;:PA 17241 (717) 776-4495 Noltry Saw Mill Road Service Rendered: 05-22- 7•c1 ,, .:o.rv.tle, PA 1.7241 _... :: 185-66-7132 D05: 03/14/71 .....i???t R: 00839 Family Balance Prior To This Visit Was: _ _?.,reses: .l 8•.7.0 Cervical Sprain rxeaurc ::a de Description ----- - - - - - - - - - - ------------------------ 99213 Estab Patient E/M, level 3 eq 1 Y•M coverage remaining: 0.00 t 1 r s I r..r n>? I1, 14 SI Diag POS ReP# ---------- --- ---- 3 1 Total This Visit: Plus Prior Balance: New Family Balance: ID, I Amou. 55. t 0.1 55 t ------------ ---------------------------------- Doctor's Signature (It Required For Insurance! TIN #: 59-2952200 License #: MD043469L Stephen M. Beclaea, M. D. Page; 1 Selected Individuat Patient Hi.stoay 12-08.98 Patient #00839 Beth Hot.tny Famity Balance 55.00 361 Saw Mitt Road Newvttte, PA 1'7241 Date Name------- POS DA Tzansact.ion/P40cedune Debit Cned-itt --- -- -------------------------- ---- -------- ------ 10-13-98 Beth 3 1 99213 Estab patient E/M, 55.00 L? i V E I "! IJ i II Stephen M. a ?,p 1 91 South Hly„ ,treet NONville, PA 17241 Beth Holtry (717) 776-449: 361 Sax Kill Road Service Renderac: l0-2? 9B Nexville, PA 17241 P3t, SS 7: 185-66-7132 008: 03/14/71 Patient 1: 00839 Family Diagnoses: Balance Prior To This I;,;, 1) 847.0 Cervical Sprain Procedure Code Description 0.00 °-• ::.,. I. 792l3 Estah patient E/M, level - : `••` ?I Insurance coverage remaining: If _: I -J` IJ Total Tha 445,"10 P!ue Prior ri.09 Na, farm., cal:bCC: SS,sO 0.00 ................................... Doctor's Sicnature (It Ax gair:d r:: . 2Sran[c; TIN 4: 59-2952200 Licene. Stephen M Bech¢ie, MrD '' 9 1 Sou.th 'H igh§tneet l ` .. 4 NewviRe¢? P,Ar,jZr24l,' :(7.171 776??4495 _,: HoLtny Senvice Rendened: 11-16-:d Saw hlitZ Road _ PA 17241 _ SS a: 185-66-7132 DOB: 03114171 9: 00839 FamiPy Satance Pnion To Thiz Viait Wae: 11347.0 Cenvica.2 Spnain - 2! 719.41 Pain, zhouYdea ?oin.t -, ._ccdune Diag J :de Deecntption --- ---------------------- - - ----------- --- ----- ---- POS Re6# Amoun:c 3E-stab patient E/M, 7 7 -teve.E 3 ------ --- ---- 3 12 ------ 35 .. Totat Thih Viz it: ::. . PQu.4 Pnion Satance: A --- - ll New FamiRy BaRance: ;14.._ ;.:.Lance covenage %emaining ?? 0100 10A .J i Cpa ? ? ? ssaoaa 9.y? 7 IJ i Docton..e Sigria#une TIN sr:' S9-2952200:;';, -Requined Fon In.bunancz; Lieen.ae-#: M0043469L •''tephen M. Becker, M.D. Page: 1 Selec d Individual Patient Hist. ; 04-13-99 Patient #00839 Beth Holtry Family Balance 41.00 361 Saw Mill Road _ Newville, PA. 17241 - Date Name POS Dr Transaction/Procedure Debit Credit -------- ----------- --- 11-16-98 Beth 3 1 99213 Estab Patient E/M, 55.00 i i --jephen M. Becker, M.D. Page: 1 Selec 3 Individual Patient Histc.f 04-13-99 Patient #00839 Beth Holtry 361 Saw Mill Road Family Balance 41.00 Newville, PA 17241 - Date Name POS Dr Transaction/Procedure ------- Debit Credit ----------- --- ___ _____ 02-01-99 Beth 3 1 99213 Estab patient E/M, 56.00 _J .J i I - -tephen M. Becker, M.D. Page: 1 Selec•. 1 Individual Patient Histo- ! 04-13-99 Patient #00839 Beth Holtry Family Balance 41.00 361 Saw Mill Road I' Newville PA 17241 Date 02-17-99 i' - I C .? Name POS Dr Transaction/ Procedure Debit Credit ----------- --- -- •------------ ------------------ -------- ------ Beth 3 1 99213 Estab patient E/M, 56.00 1 1J L II 1 I 1 i I' i k t!V[NO MIIG]A CARLISLE HOSPITAL 246 PARKER ST 33650 3 PA 17013 CARLISLE 0000 "?y"? ELI •?= I •==1 _••= I" , 717-249-6676 23-2141105 03059810305981 I I I nr•?d, w.[ •rt.•wap HOLTRY BETHANY M 361 SAW MILL RD NEWVILLE. PA 17241 I•e I Ni : n ..w Fvc ro.w otl.t awoG.aLOCw :wit[ _ v r a A „ M I I 1 7 11 01 1280416 1 3 4 97 IF M 1030598 110 ccrie?[ v uw.cc[ LGC[ ? G,C =•u • J2 ncmnc[ r-v?.zx is u:m.:evw v 'C..L[. GT GS:: ^JT ICS[ .W "'?>•' Ol 030598 I I I I I I I ` < ? ., .: : SHALL cm rs< .w,n cae . uant .wv. 361 SAW MILL RD I I NEWVILLE, PA 17241 , v.[+n tl2ar:a ? ..-c.:l.?.m :.•[ I .eu.. was .. roe.-o..?! ? uwcw!•n>v.?x! ? n 450 EMERGENCY ROOM 1 13.001 001 TOTAL CHARGES I 13.00 I p..Rli rTC.CAV I. ,.,•. ?d1YCY.C.M.`! InCf'..K1n"A[ ?F ALLSTATE INSURANCE 23-2141105 Y Y BLUE `CROSS:366 1 390058 Y? IY pVUE;FROM PATIENT> I nnlJ{?!'A.2 ItlI,?FC.S.dnnCC14 r bC.s•+\E anWVLS YL1ll HOLTRY, BETHANY , 0116 28261557 0911 • HOLTRY,'MARSHALL V QAC211627816 I 02 026803005 L I tl,X.'K"WIIM1.. Wn:C! MCL' p(I.nLK?wx[ ;tl INTL.-.'AL.'.J. 1 ICOWLES I ° ` 1 `KEEN LEASING INC > I n.«. Gan 's?e..?? LLLe ' ''nnLe ar.?.?,e?:wc n?-w ' nu:e'. .. u:e ': 'ncu ' Inua annlneca n 8470 I I I I I I 117231 E8120 I n.L itl ° u ,a. .•...?,[ :. [' ... >.. G? i p.- .,-l.o 0800718 I I I I I 1.a-•.s.w " arc.. I: :m "?.wn ui I rgewrrcnN puffin ?a.c' I I 03/19/98 75 r.crcn.[.21n*.,w p_.r X 1 C[IT.F •w[ L Cw,1.f.A`C.C G i.[ •I.IM[ us-.,v )w e.?..e..e u.c•...p - V [C ! 1 I e PB.1.1 ? I Number 4336509 i ;Nrv Chg. Qty 450 27020 1 'ZO1 01600 1 I, COI 05270 -1 !' ** End of List ** L I it ENTER Continue I; F2 Credit Notes II i _I CARLISLE HOSPITAL "• 11/20/98 P ,.TIENT MASTER INQUIRY CHARGES Name HOLTRY, BETHANY M. Amt Due .00 FC 98 Amount Date Bat Reference Description Post Dt 13.00 -12.06 030598 PHO 041498 C34 AAUTOALLST CONVENIENT CARE LEVEL 030598 -.94 041698 Z66 ALLSTATE INSURANCE O/P A PA 041598 UTO INSUPULTICE AD 041698 N Nxt Patient S Cha Inauiry F1 Charges F3 T-nsur Estmts F4 Insur Plans F5 Stmt Data ¦c 7, •. 71 ii C N EL F ?a L ? c •m 3 PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DR. -- CARLISLE, PA 17013 (717) 240-0330 FED TAX ID# 76-0430711 RONALD D. GREENWAY, P.T. BETH HOLTRY 361 SAWMILL ROAD NEWVILLE ACCT 102322 1 E 17'. 9 PA 17241 V RG DIAGNOSIS: CERVICALGIA - 723.1 SPRAIN/STRAIN, NECK - 847.0 DATE DESCRIPTION ------------------------------------------------------- BALANCE FORWARD 03110198 EVALUATION; COMPREHENSIVE - NEW PATIENT -03110198 HOT PACK - NO CHARGE 03110198 ELECTRIC STIMULATION; UNATTENDED 03110198 ULTRASOUND _03110198 e2ectxode.6 (.6upp4.Lea) 03110198 MASSAGE -P3110198 EDU. PAMPHLETS/BOOKLETS 03111198 ELECTRIC STIMULATION; UNATTENDED 03111198 ULTRASOUND ,03111198 MASSAGE )3112198 AV-ztate Inz billed 346.00 {pan 03/10-03/11/8 -03112198 HOT PACK - NO CHARGE 03112198 ELECTRIC STIMULATION; UNATTENDED 73112198 ULTRASOUND ._)3112198 MASSAGE 03117198 HOT PACK - NO CHARGE -93/17/98 ELECTRIC STIMULATION; UNATTENDED )3/17/98 ULTRASOUND -03117198 MASSAGE .03118198 HOT PACK - NO CHARGE 73118198 ELECTRIC STIMULATION; UNATTENDED -J3118198 ULTRASOUND 03118198 MASSAGE )3119198 A.226tate In,6 bi.U-ed 267.00 boa. 03112-0311818 .)3123198 HOT PACK - NO CHARGE 03123198 ELECTRIC STIMULATION; UNATTENDED '13123198 ULTRASOUND )3123198 MASSAGE -03126198 Attztate Inz biUed 89.00 bon. 03123-0312318 03130198 ALLSTATE pd.$131.85 FOR 03112-0311818 )3130198 ALLSTATE pd.$210.75 FOR 03/10-03/11/8 -1 ______________ CONTINUED ON NEXT PAGE STATEMENT DATE: 04105199 PATIENT: BETH HOLTRY INJURED: 03105198 PHYSICIAN: STEPHEN BECKER, M.D. ID NO: CLMF11553022946 EMPLOYER: TRAFCON INDUSTRIES 81 TEXACO ROAD MECHANICSBURG PA 17055 CHARGES --------- PAID ----- ADJUSTS BALANCE 11 --- 1 ---------- 11 -------- 0.00 150.001 108.45 -41.55; 0.00 1 25.00; , 14.64, r -10.36, 0.00 31.00; 12.09, -18.91; 0.00 15.00, 12.00, -3.00, 0.00 33.00, 17.22, -15.78, 0.00 3.00; 2.40, -0.60; 0.00 25.00; 14.64, -10.36, 0.00 31.00; 12.09; -18.91; 0.00 33.00; 17.22; -15.78,' 0.00 r 25.00; , 14.64; r -10.36; 0.00 31.00; 12.09, -18.91; 0.00 33.00; 17.22, -15.78; 0.00 25.00; 14.64; -10.36; 0.00 31.00, 12.09; -18.91, 0.00 33.00; 17.22, -15.78; 0.00 r 25.00, , 14.64; r -10.36; 0.00 31.00, 12.09, -18.91; 0.00 33.00; 17.22, -15.78; 0.00 25.00, 14.64; -10.36, 0.00 31.00; 12.091 -18.91; 0.00 33.00, 17.22; -15.78; 0.00 r I , r , , ---------- -------- ---------- ------- PENN'S WOOD PHYSICAL THERAPY I 425 STONEHEDGE DR. CARLISLE, PA 17013 (717) 240-0330 FED TAX ID# 76-0430771 RONALD D. GREENWAY, P.T. BETH HOLTRY 361 SAWMILL ROAD NEWVILLE STATEMENT DATE: 04105199 PATIENT: BETH HOLTRY INJURED: 03105198 PHYSICIAN: STEPHEN BECKER, M.D. PA 17241 ID NO: CLM#1553022946 EMPLOYER: TRAFCON INDUSTRIES 81 TEXACO ROAD -ACCT 102322 1 V RG DIAGNOSIS: CERVICALGIA - 723,1 MECHANICSBURG PA 17055 SPRAIN/STRAIN, NECK - 847.0 DATE DESCRIPTION --------------------------------- - CHARGES PAID -, ' d3/30/98 ----------------- BALANCE FORWARD c,%'$135.15 FOR 03112-0311818 C e --------- ------- ; Q3130198 _ ontnactuoU Wxit HOT PACK - NO CHARGE $135.25 FOR 03/10-03/11/8 ; )3130198 ELECTRIC STIMULATION; UNATTENDED J3130198 ULTRASOUND 25.00, 14.64; 03130198 MASSAGE 31.00; 12.09; 13130198 TheAapeut,ic Activitie.a 33-00,1 17.22 J4101198 NOT PACK - NO CHARGE 52.00 ,' 23.05, 04101198 ELECTRIC STIMULATION; UNATTENDED 14101198 Th¢,rccpeutic AcLiviLfea 25.00; 14.64; i 14102198 1 `04120198 Attdtate Ine bitted 218.00 {:ox 03130-0410118 ' ALLSTATE P14104 52.00; 23.05; .04120198 .69 FOR 03130-04101/8 Cont4actuat Wxite- c,% $113 31 ; j: '4120198 d ' X . . FOR 03130-0410118 ALLSTATE pd.$43.95 FOR 03123-0312318 ; ; I , - 4 20/98 J. 10/15/98 Can}rnct ,n? 11 , , rn S45 EVALUATION; COMPREHENSIVE - NEW PATZ l23/$? , , 0 ADJUSTS , -10.36,' -18.91; -15.78, -28.95, -10.36; -28.95, BALANCE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0115198 ' HOT PACK - NO CHARGE ENT 1 150.0 ,?- -87 06; pp j -0115198 10115198 ELECTRIC STIMULATION; U UNATTENDED 0 ' ' :0115198 LTRASOUND THERAPEUTIC PROCEDURE 25.0 31.00,' 14.64, 12 09, -10.36; -18 , 0.00 s 0120198 j 10120198 HOT PACK - NO CHARGE EL 52.00; . 21.91, .91 -30.09; 0.00 0.00 10120198 ECTRIC STIMULATION,- ULTRASOUND UNATTENDED ; 25 00; 14 0122198 -.10122198 AU-Mate Ina bitted H 314.00 60,t 70115-1012018 . ; 31.00; .64; 12.09; -10.36; -18.91' 0.00 0.00 OT PACK - NO CHARGE 10122198 ?0122198 ELECTRIC STIMULATION,- U UNATTENDED 23198 LTRASOUND ELECTRIC STIMULATION UNAT 25.00, i 31'00' 14.641 12 091 -10.36,' -18 0.00 10123198 1 ; ULTRASOUND TENDED 25.00,' . 14.64' .911 -10 36' 0.00 0 0129198 -1112198 AUUetate Ina bitted BETH HOLTRY 112.00 box 10122-1012318 ;- 31.00' 12.09' . -18.41' .00 0.00 _`-------- Bitted --------- 0 .00 Uux 10/15-10/29/8 r CONTINUED -------- ON NEXT PAGE _____---- ----- ------------- --------- ---------- ------ I' PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE OR. CARLISLE, PA 17013 (717) 240-0330 FED TAX ID0 76-0430771 RONALD D. GREENWAY, P. T. STATEMENT BETH HOLTRY PATIENT: 361 SAWMILL ROAD INJURED: NEWVILLE PHYSICIAN: PA 17241 ID N0: EMPLOYER: ..ACCT 102322 1 V RG DIAGNOSIS: CERVICALGIA - 723,1 SPRAIN/STRAIN, NECK - 847.0 DATE DESCRIPTION ------------------------------------------ 1112198 BETH HOLTRY B(QpedALANCE FORWARD----------- -- 11124198 BETH HOLTRY Bitted 0.00 ¢ax. 10/15-11/12/8 11127198 ALLSTATE INSURANCE 0.00 60x. 03/10-11/12/8 am, 1127198 Cont4actua.Q W,Lite- c $58.54 FOR 10122-1012318 .'1130198 ALLSTATE Pd.$138.31 FOR 10/15-10/20/8 11130198 Can txactuat Wx,Lte.- c,%.$175.69 FOR 10/15-10/20/8 1130198 RE-EVALUATION; ESTABLISHED PATIENT 11130198 HOT PACK - NO CHARGE 11130198 ELECTRIC STIMULATION; UNATTENDED 1,1130198 ULTRASOUND 1130198 etec ticade6 (4uppttea/ 0130198 The,%apeuti.c Activitieb 12102198 HOT PACK - NO CHARGE 2102198 ELECTRIC STIMULATION; UNATTENDED 2102198 ULTRASOUND 12102198 Therapeutic Act1.vtti" 2102198 AV-zta-e In,6 bitted 316.00 {,an 11/30-12/02/8 2104198 ELECTRIC STIMULATION; UNATTENDED 12104198 ULTRASOUND 12104198 Thvapeutlc Act.ivitze6 2/07/98 HOT PACK - NO CHARGE 'x2107198 ELECTRIC STIMULATION; UNATTENDED 12107198 ULTRASOUND 2/07/98 Therapeutic Activ.itie-5 _2109198 HOT PACK - NO CHARGE 12109198 ELECTRIC STIMULATION; UNATTENDED 2109198 ULTRASOUND 2109198 Therapeutic Activttiea 12110198 AV-4tate In.6 bitted 324.00 Uan 12104-1210918 12111198 HOT PACK - NO CHARGE ?-2111198 -ELECTRIC -STIMULATION; UNATTENDED CONTINUED ON NEXT PAGE' r i i i i r i r r r i i r i i i r r r , DATE: 04105199 BETH HOLTRY 03/05/98 STEPHEN BECKER, M.D. CLMs1553022946 TRAFCON INDUSTRIES 81 TEXACO ROAD MECHANICSBURG PA 17055 CHARGES PAID 85 25 31 15 52 25 31 52 25 31 52 25 31 52 r i i i .00; r r . 00, .00; .00; .00. r 00; 00; 00, 00; 00; 00; i 00, 00; 00, 25.00; 31.00; 52.00; r 25.00, i 62.76; 14.64; 12.09; 12.00; 23.05; r r 14.64; 12.09, 23.05; r r 14.64; 12.09; 23.05; 14.64! 12. 23.05, r r 14.64; 12.09, 23.05; r ADJUSTS i i i i -22.24,` i -10.36, -18.91, -3.00; -28.95; -10.36,' -18.91; -28.95; r r -10.36; -18.91, -28.95; -10.36; -18.91; -28.95; i -10.36; -18.91; -28.95; -10.36 BALANCE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 14. 64,' I PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DR. CARLISLE, PA 17013 (717) 240-0330 FED TAX ID# 76-0430771 RONALD D. GREENWAY, P.T. STATEMENT PATIENT: BETH HOLTRY INJURED: 361 SAWMILL ROAD PHYSICIAN: NEWVILLE PA 17241 ID NO: EMPLOYER: -ACCT 102322 1 V RG DIAGNOSIS: CERVICALGIA - 723.1 SPRAIN/STRAIN, NECK - 847.0 DATE: 04105199 BETH HOLTRY 03/05/98 STEPHEN BECKER, M.D. CLM#1553022946 TRAFCON INDUSTRIES 81 TEXACO ROAD MECHANICSBURG PA 17055 ..; DATE DESCRIPTION ----- ----- --- CHARGES --------- PAID --------- ADJUSTS --------- BALANCE -------- --------- - ----------- --------------------------- BALANCE FORWARD i i 1 11 0.00 12/11/98 ULTRASOUND 1 31.001 12.09; -18.91; 0.00 12/11/98 Thetapeutic Activities ; 104.00; 46.091 -57.911 0.00 _12114198 Thenapeati.c Acti.vttiee ; 104.00; 46.091 -57.911 0.00 12116198 HOT PACK - NO CHARGE ' ' ' -12116198 ELECTRIC STIMULATION; UNATTENDED 1 25.001 14.641 -10.361 0.00 12116198 ULTRASOUND 1 31.001 12.091 -18.911 0.00 ...12/16/98 Thecapeuttc Activtti.e6 1 104.001 46.091 -57.911 0.00 _12117198 ABZatate In.6 bi.ZP.ed 424.00 Uon 12/11-12/16/8 1 1 1 1 12118198 HOT PACK - NO CHARGE 1 1 1 1 -12118198 ELECTRIC STIMULATION; UNATTENDED 1 25.001 14.641 -10.361 0.00 12118198 ULTRASOUND 1 31.001 12.091 -18.911 0.00 12118198 TheAapeutic ActLvittes 1 104.001 46.091 -57.911 0.00 _12121198 ALLSTATE pd.$149.34 FOR 12104-1210918 1 1 1 1 12/21/98 Contnactua2 WA te- c,%.$174.66 FOR 12104-1210918 1 1 1 1 -12121198 ALLSTATE INS pd.$174.32 FOR 11/30-12/02/8 1 1 1 1 12/21/98 Contnactuat WA te- cvc.$141.68 FOR 11/30-12/02/8 1 1 1 1 12121198 HOT PACK - NO CHARGE 1 1 1 1 ,12121198 ELECTRIC STIMULATION; UNATTENDED 1 25.001 14.641 -10.361 0.00 12121198 ULTRASOUND 1 31.001 12.091 -18.911 0.00 12121198 Thenapeuti.c Activitie,6 1 104.001 46.091 -57.911 0.00 12123198 HOT PACK - NO CHARGE 1 1 1 1 12123198 ELECTRIC STIMULATION; UNATTENDED 1 25.001 14.641 -10.361 0.00 12123198 ULTRASOUND 1 31.001 12.091 -18.911 0.00 12/23/98 Thenapeut.ic Activitie,6 1 104.001 46.091 -57.911 0.00 -42124198 A.ZZ6tate IM bi,ZEed 480.00 ¢on 12/18-12/23/8 12128198 HOT PACK - NO CHARGE 1 1 1 1 72128198 ELECTRIC STIMULATION; UNATTENDED 1 25.001 14.641 -10.361 0.00 12/28/98 ULTRASOUND 1 31.001 12.091 -18.911 0.00 12128198 ThehapeutLc Acti.viti.e6 1 104.001 46.091 -57.911 0.00 -12129198 HOT PACK - NO CHARGE i 1 1 1 12/29/98 ELECTRIC STIMULATION; UNATTENDED 1 25.001 14.641 -10.361 0.00 CONTINUED ON NEXT PAGE" PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DR. CARLISLE, PA 17013 (717) 240-0330 FED TAX ID# 76-0430771 E. RONALD 0. GREENWAY, P.T BETH HOLTRY 361 SAWMILL ROAD NEWVILLE _ACCT 102322 1 1 DATE 12/29/98 "12/29/98 12/31/98 )1/12/99 _)1/25/99 01/25/99 -71/25/99 _11/25/99 01/25/99 _01/25/99 12/02/99 -J2/02/99 02/02/99 12/02/99 J2/04/99 02/04/99 -72/04/99 -2/04/99 02/05/99 P2/05/99 2/05/99 -2/05/99 02/08/99 `2/08/99 -2/08/99 02/10/99 .^2/10/99 2/10/99 `d2/11/99 02/12/99 2/12/99 STATEMENT DATE: 04/05/99 PATIENT: BETH HOLTRY INJURED: 03/05/98 PHYSICIAN: STEPHEN BECKER, M.D. PA 17241 ID NO: CLM#1553022946 EMPLOYER: TRAFCON INDUSTRIES 81 TEXACO ROAD MECHANICSBURG PA 17055 V RG DIAGNOSIS: CERVICALGIA - 723.1 SPRAIN/STRAIN, NECK - 847.0 DESCRIPTION BALANCE FORWARD ULTRASOUND Thenapeut.Lc Activ.i.tLez ACZetate I" bitted 320.00 {ion 12128-1212918 BETH HOLTRY B.ttpd 0.00 Uox. 10/23-12/31/8 ALLSTATE pd.$191.73 FOR 12/11-12/16/8 ContAactua. Wxite- c?L.$232.27 FOR 12/11-12/16/8 ALLSTATE INS pd.$218.46 FOR 12/18-12/23/8 Contnact=l WA te- cn.$261.54 FOR 12/18-12/23/8 ALLSTATE INS pd.$145.64 FOR 12128-1212918 ContAactuat Waite- c,%.$174.36 FOR 12128-1212918 *EVALUATION; COMPREHENSIVE - NEW PATIENT *ULTRASOUND *MASSAGE *THERAPEUTIC PROCEDURE A U-4tote In,6 bitted 266.00 bon 02102-0210219 *HOT PACK - NO CHARGE *ULTRASOUND *MASSAGE *HOT PACK - NO CHARGE *ELECTRIC STIMULATION; UNATTENDED *ULTRASOUND *MASSAGE *HOT PACK - NO CHARGE *ULTRASOUND *MASSAGE *HOT PACK - NO CHARGE *ULTRASOUND *MASSAGE AE14tnte Ire.4 bitted 281.00 Uon 02104-0211019 *HOT PACK - NO CHARGE *ULTRASOUND -------------------------------------- --------CONTINUED-------- ON NEXT PAGE 6. CHARGES PAID ADJUSTS 31.00; 104.00; 12.09; 46.09; . i -18.91; -57.91; , , 150.00; 31.00,' 33.00; 52.00,' , 31.00; 33.00,' 25.00,' 31.00; 33.00,' 31.00; 33.00; 31.00,' 33.00,' , 31.00,' 62.76; 12.09; 17.22,' 21.91; , 12.09,' 17.22,' 14.64,' 12.09,' 17.22,' 12.09,' 17.22,' 12.09,' 17.22,' 12.09; -87.24; -18.91; -15.78; -30.09; , -18.91; -15.78,' -10.36,' -18.91; -15.78; -18.91; -15.78,' -18.91; -15.78; , -18.91( BALANCE 0.00 0.00 0.00 , , 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DR. CARLISLE, PA 17013 i (717) 240-0330 FED TAX ID# 76-0430771 RONALD D. GREENWAY, P.T. S "i BETH HOLTRY 361 SAWMILL ROAD NEWVILLE PA 17241 I ACCT 102322 1 V RG DIAGNOSIS: CERVICALGIA - 723.1 SPRAIN/STRAIN, NECK - 847.0 r? DATE DESCRIPTION STATEMENT DATE: 04/05/99 PATIENT: BETH HOLTRY INJURED: 03105198 PHYSICIAN: STEPHEN BECKER, M.D. ID NO: CLM#1553022946 EMPLOYER: TRAFCON INDUSTRIES 81 TEXACO ROAD MECHANICSBURG PA 17055 CHARGES PAID ADJUSTS BALANCE ----------------- BALANCE FORWARD ' 1 ---------------- 2112199 '° *MASSAGE 1 1 33 00; i 1 ,' 0.00 2/18/99 A.eP,atate Irw b.L.P.eed 64.00 {,an 02112-0211219 1 . 7.22; -15.78; 0.00 03102199 ALLSTATE pd.$113.98 FOR 02102-0210219 1 3102199 Cont,%actuat WAtte- cc.$152.02 FOR 02102-0210219 ; 3104199 ALLSTATE pd.$29.31 FOR 02112-0211219 03104199 Cont4actua2 WAtte- ct.$34.69 FOR 02112-0211219 °°13104199 ALLSTATE pd.$131.88 FOR 02104-0211019 ,_.13104199 Cont4actua2 W&Ue- cn. $149.12 FOR 02104-0211019 ; CURRENT OVER 30 OVER 60 OVER 90 OVERTIYOLS 3821.00 1837.67 -1983 33 0.00 0.00 0.00 0.00 0.00 PLE 0.00 I? 1 1 1 1j m 3 WLES Enthuslast,media Absence Report Location: P Cowles Enthusiast Media 0 Retail Vision ? Q Cowles Creative Publishing 0 Southwest Art ? Bowhunter ? Cowles History Group Q Vegetarian Times O Walking Inc. Q Cumberland Publishing ? Horse & Rider ? Other t Name Pr Employee t Department F t)c, c--,c r First Date Absent mnrri Return Date Mm rchei 19 r, Reason Hours Reason I Hours O Sick I ? Jury Duty ? Vacation I J Leave Without Pay U Personal Day 0 Other Funeral Lure I TOTAL . H3, L\o gi LIG 4 1,1 hrs, Prepar? by n 1 t Date r Approved by /y / Date ftil2-0epa,lmenr Pink-Employe. WAGE AND SALARY VERIFICATION I hereby authorize you, to furnish all information you have in your possession regarding my employment, since my hire. This form authorizes you to release the following information to my attorneys, Handler and Wiener, and I further request that you NOT give such information to anyone else without a signed. authorization from.me. 1 ; Date ? 1F? c l L, n 1-?1 . 1a r Employee's Signatdrb , 1. Employee's NameLCtyt??(Y?_?p? }(y_ Social Security No. I -(n (a ?ja .., 2. Employer's Name and Address V?(? M P n;A LoL?OS ?'IC?t11, \?C1?' C e 2 5 f DA ll? A 3.JobTitle Ncc-?\c-\t -rr 4. Dates of Employment: From: ?-11 -q to ?js{ f If no longer employed, reason for leaving '-t-y 1UsS ??o n?( ` 5. Wages or salary as of accident date: f s ib.:?`ILriper 14CLC Hours per day -9--- Hours per week -3a List wages from the 2 years preceding the accident S, S ?I . L 6. Dates absent following accident: From through Tse-Yy"t (a) If not consecutive, list dates absent 7. List any dates in the above, that are for reasons other than injuries sustained in this accident. ?-- 8. Has employee filed claim for benefits under any worker's compensation or similar law as a result of this accident? Yes No ? L I If applicable, Name and Address of Worker's Compensation Carrier: Date complete d:'-_2-.; - _ Policy / Claim Number Signed: CD Title: 1? ?-P c Phone: i SZ(U , ( U? i r C v K 0 IL J r:. 4TH OF PE COMM0 POUCEA CCfDENT "•{r ?' EponTAe 5 0.A?5RNAt 2? 20: flOUTEN?AM TIME STREETS, jj, BPEEtJ IYPa1NR50DRMAFYOTA S?? ?t'? 18NUMGE0. 'cR035 IOFUNITE '. - - SEGMENT rJ tS.PRN PROP. Y ` , N 71.DIRE$i101 4 j 9UURED Acc DEW FROM SIT EDAM GE L -? U11IT 1 Z IYESO BE 0.11011C M'a{ESCENE2- 2 FooemiE yIyCONSTP UNR2((.----yy ].SEYEPE UNST2 ?.? `-' 20NE Y ,NI,u Y1 ,.I YCJ NC.1pRDPE0.TY i C? 1B.tEGAt ? I UNIT # ? " ]0.5fc?A ?f P1FK Y ?]T. ?TE,?CL.?.c-tl ?.. .- .f. OUTAF' E?_l!U(?171112 7 J a?.,... '41"o'vi 45 ?/ i UIIKI- IA e-44-T.M 1NDi L A AO.IYEHIOti NIP / I, jo cwt ?5 DwT+E, • j, su1 ? B.S?GE, . v 521 i?Ept ? SD s5a f rc ? ',? 6TA US O . SSICR ypIT cit 1 EI 1-Y LE bER 1?7. Stf? Off. ? '?. ppE6ENCE ft E.? IP4Oi G lr' '.VflC ????7-'J USAGE-..,. .'. y7;)YEriICLE 'IMPACT. -STATUS •„ LE .,}? 54?PR?S£ OE ER SFE4 pG?.. iVER „ _ Ass SS-•^"``? ADORE* g J„_....». 7, j1C2 i? NFIG:_....... 1?6?j{AZ AR l . T] CA0.GOr i5. NO OF 'C? ANTERU?S :_mq y? .. N •-PAGE:. 2116424 ? 'A W I FiY .. _s : PI.'/`U}T1?••, Y::hn`' i'4i :r-""7 •. 1. .:;. .. Y?I° .. ey i l. u' OO14VO1 ...., 1? r. ,.f14 } , K ` P I A\ COMMONWEAL TH OF PENNSYLVANIA ul i7+ 1 IL 4` 4 POLICE A CCIDENT REPORT S h XX REFER TO OV ERLAY SHEETS REPORTABLE jj ?) NON • REPORTABLE Q - P ENN00T U89 ONLY •4v , l(GF,JI ? FORMAt10Nti?" ,j s c , ,J%.?'1r'! kt 8} i .";A6GD L ••.. t. - 20. COUNTY . 'CODE NUMBER 2'AOENCY ' - 21. MUNICIPALITY • n•" ! + NAME 5 u C u .p, -•f Pi ECINCT G ? 4 20NEOL .? PRINCIPAL ROADWAY INFORMATION-1,P77 kp • :'L WYE9TI T BADGE 7 JG 22. ROUTE NO. OR - .w Ir• NUMBER STREET NAME .? ' Fy 0. APPROVED BY . BADGE 27. SPEED . 4. TYPE 5. ACCEB6'L`.•'+: `•:; NUMBER LIMIT HIGHWAY CONTROL': •.." •7 • h T. U7VES11GATION DATE B. ARRIVAL , O C (? S O• - INTERSECTING R OAD, ' + 0Z 'I J 1 i TIME • , • t, 1 TT?1 FORMATIONii,' `. N 2s. ROUTE N0, ON STREET NAME. :.,:? y' ._"'.•:-. .R4A P. ACCIDENT, DATE b? O IO. DAY OF WEEK T ? 27. SPEED 38. TYPE IT . ACCE66 f.'.•'t,?? •`I i ti TTMBDF' X G{f v. 12. NUMBER LIM wanwnr coNrno :. ; ' IFNOTATINTERSECT/ONt" `"` ` WWW DAY O OF UNITS : : . 7 • ` I3,1 NULLED 14. 1INJURED ? ' 15. PRIV. PROP. E] ACCIDENT 70. CROSS STREET OR SEGMENT MARKER !80 r Y N f ^ Yt 16 ??EeE TO BE REMOVED yy 7,yEHICLE DAMAGE VEHICLE ' E T? JI. DIRECTION 72. DISTANCE FROM SITE N S E W 'FROM SIT . ,1:?• [' E jy UNl7t.-S . UNIT 2 - I • LIGHT 77. DISTANCE WAS ? ? ` • '? ? ? 2 • MODERATE 7. SEVERE UNIT Z O MEASURED V,•I. II . ESTIMATED ] CO S UCTION ? 9 + N .Y A Y N 4 N TR 75 TRAFFIC ZONE CONTROL ? PRINCIPAL.. RlTERSECt 7 ' " 't ? • Y ' : t .fpp 11111, HAZ RDOUS RIA S ? g Y N 9. PENN00T z ? DEVICE ? • - 7 ^^7? p MATE L PROPERTY Y N .Ya !+ NIT. Na•3 ;'yt1 l'pr .NLTA£'P.f rr ]5. LEGALLY Y N 68 7B. 77I 78. LEGALLY Y N 07, REG a Je. STJTE:r 5 PARKED7 TE G LA PAHKE07 ?? PLATE I,?7t+ • '?: OO. PA TRLE OR 39. PA TITLE OR •,+A- ?1=4 T /S;• OUT-OF•STATE VIN O 7 • OUTAF•STATE VIN :. j: 40.OWNER . 40.OWNER 1. T' G • ,! 41 OWNER 41 OWNER ADDRESS . iN? f//Ft? . ADDRESS I{ : 42 'CITY. STATE - b ZIPCOOE e ,Iwe / J /* 42. CITY; STATE e ZIPCOOE _ . • p 43. Y - N. MAKE 47. YEAR 44, MAKE Fh MODEL -(NOT 45 dB INS a5 NOT MODEL- . DY TYP • . O ?' . S 45. IN5 • ( . BO EI LINK YTS N BODY TYPEI YO N? UNK , .:.t . tl. BOGY TYPE 18. SPECIAL 49 VEHICLE USAGE ? OWNERS P I a7. BOGY TYPE' 48 SPECIAL 4p. VEHICLE w , }( f { ? . HI USAGE OWNERSHIP N`i y i INITIAL IMPACT / Sl. VEHICLE 52. TRAVEL 50 INITIAL IMPACT. 31. VEHICLF. 52. TRAVEL t?'}' h POINT (% - STATUS 109 SPEED. O POINT STATUS SPEED ' VEHICLE • Sd. DRIVER 55 DRIVER N 57. VEHICLE 54. DH'VER r. 55. DRIVER , GRADIENT PRESENCE CONDITIO GRADIENT PRESENCE CONDITION -y 50. DRIVEN .NUMBER 57. $iAT 56. DRIVER A7, STATE 'f as I' • -% TJV ' .. NUMBER .Y? 88, DRIVEN 50. DRIVER - .., NAME _ _ NAME . to{;'! 52. DRIVER ' $9. DRIVER 'tt I ' AGGRESS ADDRESS t ' 50. CITY, STATE J[ fiO. CITY,S :y.• T ?? ati 0111111 : AZIPCODE bZIPLODE _ 11 7 01. SEX 82. GATE OF 6 NONE, 51. SEX 62. DATE OF W. PHONE BIRTH ' 3] pl Y 64 CCMM. yEH. BS VO N? . DRIVER 66. URIVER CLASS G_ SS• RI. CDNIM. VEII 65. DRIVER 08. DRIVER Y? NO 'CLASS 9S/ U k ,t ?7 . ?__ 67. CARRIER 67. CARRIER - 7.- • }•, j - ' 5B. CARRIER 5B. CARRIER . .? -ADDRESS ADDRESS j.•AI 1Y, 89. CITY, STATE b ZIPCODE --••_-- 63. CITY. STATE A ZIPCOOE 70. USDOT • (ICC • FIX • 70. US01 •• I-C • PUC p rS ry za ', 5 VEM. CONFIO J CARGO 74 G\1YR OOY TYPE 72 VEX. !] CARGO COVRO II ODY TYP 74, GVWR S 2 ?k4 777 . 75. NO OF p fiIHAZARD0U5 71 RELn5c nc HAZ MAT ? __ - E 75 N0. OF n'oJ HA2A1D0US _ 77 R ?5 NQ µ ?• (,.{ ALES i - _ MATERIALS Yd NU UNKO. _AXLE$ SSI ??""MA7ERIA1 I L Q? Y L-I N L? ? UNK y IY.Y.: m:\ItomclbgaUitigat\sl:ucfim!row'clprlccipc orb exhibit. Diafl;;2 Nmembcr 19, 2001 lc ll}cy E. 19acolu. lisquire supreme Coun I.D. ,I Sots' Brigid Q. Al liod. Esquire Supreme Court I.D. n38590 BOSN'Iil.l..'I IN "I NER. I'ICCOL\ R 1% ICKERNI INt 315 North Front street 1'1111 Office llo, 741 I lanisbtug. Iinnsyh'ania 17108.0741 Aoo.c,, lur Dctcndmt Rowe BETHANY M. HOLTRY and 1NIARSHALL V. IIOLTRI', Plaintiffs V. TERM L. ROWE, : IN THE COURT Or COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-6724 CIVIL TERM : CIVIL ACTION- LAW :.JURY TRIAL DENIANDED Defendant DEFENDANT"S ARBITRATION EXHIBITS Pursuant to Pa. R.C.P. No. 1305(b), Defendant Terri L. Rowe, by her attorneys, Brigid Q. Alford, Esquire and Boswell, Tintner, Piccola & Wickersham, respectfully submits the attached exhibits as documents which she intends to introduce into evidence at the arbitration of this case: Records Review by David C. Baker, M.D., F.A.C.S. 2. Curriculum Vitae of David C. Baker, M.D., F.A.C.S. Respectfully submitted, By: AD6.0. Jeffrey Picco re Supreme Court TS Brigid Q. Alford, Esquire Supreme Court I.D. 413S590 Boswell, Tintner, Piccola & \Vickersham 315 North Front Street, Post Office Box 741 ,,r Harrisburg, Pennsylvania 17108-0741 Date: ?{0 ?o( Attornevs for Defendant Rowe I I ' DAVID C. RAKER, tNLD., RA.C.S. 19 Brookwood Avenue, Suite 104 Carlisle, PA 17013 (717) 243-9010 .4G?L3 Ce:2::1 es :? O^'.^.cr az o:? SO L:2 L? iaFbCL i,,.._--[L:1 ncaCeny oC O: ChopaeoaC Su treors October 9, 2000 Brigid Q. Alford Boswell. T intner. Piccola & Wickersham 315 North Front Street P.O. Box 741 Harrisbur,,. PA 17108-0741 RE: Beth Holtrv Dear A9s. Alford: Thank you for allowing me to perform a Record Review on the records You provided regarding Beth Holtry. RECORDS REVIEWED- 1. Emergency Room record from Carlisle Hospital, 3/5/98. Joey Wisner, PA-C 2. Notes from Dr. Stephen Becker, family doctor. 3. Votes from Penns Woods Physical Therapy. . 1. %,IRI report of the right shoulder from 11/18/98 and plain film right shoulder views tram 11/18/98. HISTORY: The Emergency Room record from 3/5/98 states that the car she was driving was stopped and hit from behind by another car. The speed of the car hitting her was not recorded. Ms. I-Ioltrv was noted to have been wearing a seatbeit. At that time no x-rays were performed. She had "tenderness in the right shoulder." Full active range of mo=tion of the cervical spine was noted with no specific cervical tenderness. Ms. Holtry was treated with Nlotrin. She presented to her family doctor, Dr. Stephen Becker on 3/6/98. He noted tenderness over the right stemocleidomastoid muscle and right upper trapezius and right paracervical muscles. He recorded that her "scat went back and down." Fie referred her to Physical Therapy at Penns Woods. It seems that the patient stopped going on 4/8/98 and was "therefore discontinued from P.T." Page 2 RE: Beth hloltr; Neither the Gme.gency Room, Dr. Becker's notes, nor the notes from Penns Woods document any neurologic findinss. The records then become more confusing. According to the notes from Penns Woods dated October 15, 1998 it states than ''approximately two weeks ago, while at work, the patient was pulling on a filing cabinet drawer when she felt a pop that seemed to be in her right posterior shoulder blade area." The record from that visit goes on to state that *,tile patient states that these symptoms seem to be somewhat different than those experienced with the earlier episode." A separate note from Penns Woods on 11/30/98, however, stated under history "*VIVA as noted, has responded to therapy, symptoms have exacerbated." They listed the pain through the right shoulder, down the amm and up the neck intermittently. Notes from Penns Woods on 2/2/99 give a history of '.rapid onset last week with pain and spasm in the rhomboid area." The notes from Dr. Becker during this period state that on 10/13/98 "tile patient has been having right shoulder pain with numbness in the right hand for the last 1 '/_ months off and on." Dr. Becker's notes from October 27, 1998 state "shoulder is better with P.T. three times last week." It was during this time that the patient underwent an MRI of the right shoulder. This was performed on 11/18i98 at Carlisle Hospital. The impression was "normal MRI examination of the right shoulder." IMPRESSION It appears that the patient sustained a self-limiting cervical sprain at the motor vehicle accident on 3/5/98. From the records. this apparently improved as she stopped physical therapy and there were no references in her family doctor's rotes until October of 1998. At this point the record becomes unclear. Penns Woods notes of October 15 listed the date of onset of this second bout of pain as "October I, 1998 approximately" and describe a work injury. Based on the fact that there was a six month hiatus between the cessation of treatment from the March 1998 injury and the ors; t of symptoms in October. I would not relate the symptoms in October to the motor vehicle accident in any way. 1 certainly would not relate them to the motor vehicle accident given the record of a work related injury in approximately the beginning of October 1998. All the treatment between March and April of 1998 was reasonable. The treatment from October of 1998 into February of 1999 also appeared reasonable, but again, I see nothing that ties it to the event of March 1998. It is not consistent with the natural history of sprain/strain type injuries to have six month painfree intervals, followed by the resumption of symptoms. Penns Wood s records of October 1998 also state that the Ms. Holtry stated "these symptoms seem to be somewhat different than those experienced with her earlier episode." I Page RE: Beth Holtry, If there are any other records that you would like to provide.I would be happy to review these and provide an addendum to the report. Ifyou have any questions, please do not hesitate to contact me in writing or by phone. Thank you a,ain. Sinncerel?y. V David C. Baker. M.D. CURRICULUM VITAE DAVID C. BAKER, M.D 19 Brookwood Avenue Suite 104 Carlisle, PA 17013 (717) 243-9010 ` License No: MD 043738-E *• e EDUCATION: Residency: University of South Carolina, Richland Memorial Hospital , Dorn veterans Adrninistration Hospital, Columbia, South Carolina 1984-1989 Internship: University of Texas Science Center at Houston, Houston Texas . . Internship - Anatomic Pathology, November 1981 to July 1982 Baylor College of Medicine, Houston, Texas , Clinical Internship - rotating, 1982-1983 MEDICAL SCHOOL: Doctor of Medicine (M.D.) -1977.1982, University of Pennsylvania , Philadelphia, Pennsylvania COLLEGE: Boston University, Boston, Massachusetts, 1972-1973 McGill University, Montreal, Canada B.A., Political Science With Honors -1973-1977 WGH SCHOOL: Hempfield High School, Lancaster, Pennsylvania, graduated 1971. BOARD CER'T'IFICATION: + American Board of Orthopaedic Surgery, July 1992 HOSPITAL AFFILIATIONS: Carlisle Regional Medical Center, 246 Parker Street Carlisle PA , , Pinnacle Health, Harrisburg, PA Fulton County Medical Center, McConnellsburg, PA PRIVATE PRACTICE: + Julv 1989 to November 1989 - Evans Orthopaedics. Ephrata Pennsylvania I t December 1989 to 1993 - Lehigh Valley Orthopaedics 1401 North Cedar Crest Boulevard, Allentown, PA 1993-1994 Cayman Islands - Team Physician Cayman Island Soccer Team 1994-1999 - 850 Walnut Bottom Road, Carlisle, PA 17013 1999 to present -19 Brookwood Avenue, Suite 104, Carlisle, PA 17013 ACADEMIC AFFILIATION: Clinical Assistant Professor of Orthopaedics and Rehabilitation, Penn State University September 1, 1999. Page 2 David C. Baker, M.D. Curriculum Vitae w MEDICAL ASSOCIATION MEMBERSEIPS: Fellow, American College of Surgeons Pennsylvania State Medical Society American Medical Association Austin-Moore Society Cumberland CountyMedical Societv American Academy of Onhopaedic Surgeons Physicians Recognition Award for Continuing Education requirements have been met and complied with. American Academy of Disability Evaluating Physicians 1997. American Board of Independent Medical Examiners. September 1998 CERTIFICATE OFSERVICF. I do hereby certify that I have served a true and correct copy of the foregoing Defendant Rowe's Arbitration Exhibits by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: W. Scott Henning, Esquire 1300 Linglestown Road Post Office Box 1177 Harrisburg, PA 17105 Attomevs for Plaintiffs Date: ?4?of i By: r? Brig ?d Q. (ford, Esquiir 1 { i , C_7 6 BETHANY M.HOLTRYand MARSHALL V. HOLTRY, Plaintiffs V. TERRI L. ROWE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6724 PLAINTIFFS' ARBITRATION EXHIBITS In accordance with Pennsylvania Rule of Civil Procedure 1305(b), the following documents are attached which the Plaintiffs intend to introduce into evidence at the time of the arbitration of this case: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10 Medical Records from Carlisle Hospital Emergency Room; Medical Records from Stuart A. Hartman, D.O. Physical Therapy records from Penn's Wood Physical Therapy; Medical Records from Stephen M. Becker, M.D.; Medical billing statements from Stephen M. Becker, M.D.; Medical billing statements from Carlisle Hospital; Medical billing statements from Central Medical Equipment Company; Medical billing statements from Penns Wood Physical Therapy; Wage loss documentation from Primedia and Cowles Enthusiast Media; Copy of the Police Report; Respectfully Submitted, Date: November 16, 2001 By V W. Sco Henni Esq 1. D.. U3 1300 Linglestown oa P.O. Box 1177 Harrisburg, PA 7108 (717) 238-200 Attorney for Plaintiffs BERG .._. MMITM i t;:; !, _ i ?. :_? ._ - ,.. :;=? - -,:? .._ s _, i 1 Carlisle Hospital `"' ")r)(r 110N and Health SClY1Ces rnNVFN1FNT CARE/EMERGENCY REGISTRl1zae rarxrr nvcrr - - - - - - IAU].REGN Rc CAIEIUVC r IN CI' ,,..il. ?. -AI a1 r+: L+ ?YL .' LN ' JD 4ZU 1I. FA I'NIIIU.1UEfl 280416 03/05/99 1G:55 !_ SS 3 P.0 751 I 0 k 4336509 RIEVIGUG N.wE e"nnl l-A-L ttos_ rt eA=_: r.!'E :rnncrl c+rE cent no. - _ I0ILER P2 03/05/93 0? 00 NONE Nw1E/ kDORESb l FW!E I AGE thEA/RAOE/BAS (71.7)776-4516 LxuE1R +CInE6 :•:JP E:: BETHANY M. 2GY F S4 M -03LTRY COWLES , a61 SAH ?SILL RD 03/14/71 185-66-7132 HARRISBURG, PA 11ENVILLE, PA 17241 • 'AWE IA00RESSr Po0rR/ FL:IILA, rU 0G 1.1111 1.0 (717)776-4518 GUAF ANI CR S Exec-e. e,, ;1OLTRY, kARSHALL V. KEEN LEASING I?;C. :261 SAW i4ILL RD 211-62-7876 CARLISLE, PA 17013 "+E4!VILLE. PA 17241 NM1IE /ASl%RE55 /Fr'G:E /hEU,1ICN/ SOLSLpyp E VER's'.CI bCiv Y OILER., SUSAN (717)776-7452 • 1 PLLSTATE INSURANCE 75 FLUE CROSS 361 01 OAC211627G76 026803005 366 NOLTRY. ''ETHANY 01 HOLTRY, i4ARSHALL V. 02 TW RPNOE GGV,I.IEI:t !'EOIOAt, inSt?-FrICE AUTO ALLSTATE 8S b9 off REASON FOR VIER E D / M, Eeoe1G CC l.VA DRIVER, BELTED PAIN GUARRACINO, ANTHONY J R SIDE OF NECK TO SHDULDEP, DECKER. STEPHEN M L UMMENI REAP. ENDED 014 ALLEN RD GETTING ON 181 N B RIEF VISIT 26700 CAST ROLL, PLASTER 26075 ALL ADDITIONAL CHARGES CLASS I VISIT 26710 B/P MONITOR 26037 1 I I 1 I I CLASS II VISIT 26720 I PACER PADS 79064 I I I I 1 I 1 CLASS III VISIT 26730 GASTRO/HEIAO SLIDE 26060 CLASS IV VISIT 26740 I KIDOE TOURNIQUET 26046 r - - - - - - - - 1 - - - - - - - ---- CLASS V VISIT 26750 I OCL PER FOOT 79670 1 I I I 1 I 1 CONVENIENT CARE 1 70 S.B.S. 60081 I I CON1'ENIENT CARE II 27025 TUBE GAUZE PER FOOT 26074 - ') 7 - - - - - - - -, I ? I I I MINC)R SUTURE EDS 01 ED STAT ESTAT O I I nM'-7 I I MEDIUM SUTURE EDS 02 PULSE OX POXED , I I 0 - I I ia.. E8 J ` J _ ` - - - - - - - - MAJCR SUTURE EDS 03 I EXTENDED CHARGE I 26%60 _ _ - - _ _ I NTU EATION EDS 04 EXTENDED CHARGE 11 26770 1 1 I 1 1 I 1 I V SET UP EDS 06 i I I 1 ` J ` J CARDIAC MONITOR EDS 11 -------- -------- ---------- _` --------- --------- EXAM EDS 14 PELVIC 1 1 NITRO SET-UP EDS 16 I 1 I I I I I I CAST, SCOTCH SHORT ARIA 26031 1 L____--__-_ L___--___J CAST ONG ARM 26032 SCOTC , H L I I i I I I CAST, SCOTCH SHORT LEG 26033 1 I I ! I I I I I I CAST, SCOTCH LONG LEG 26034 L__________ ER-0508 (REV. 8/96) HOLTRY, BETHANY M. MR #280416 03/05/1998 CHIEF COMPLAINT: Motor vehicle accident. HISTORY OF PRESENT ILLNESS: This is a 26-year-old female who comes to the emergency depart- ment reporting the above. She was the restrained driver. She was the only person in the car when she was stopped and getting ready to pull onto 81 behind another car, and someone rear-ended her vehicle. It pushed her car into another car. Significant damage was done to the front, and the back of her car. The patient said that she had a jolt, and then she had immediate neck pain. No numbness, or tingling. However, she said that the pain also hurts slightly in her right shoulder. No previous neck injury. She did not hit her head on the ceiling, or the windshield. No broken glass. No chest pain. No abdominal pain. No other complaints. PAST MEDICAL HISTORY: None. ALLERGIES: No known drug allergies. MEDICATIONS: None. PHYSICAL EXAMINATION: Vital Signs - Temperature 36.9, pulse 80, respiration rate 16, blood pressure 120180. General Appearance - This is a 26-year-old female who is in no acute distress. She ambulates with- out gait alteration. Her heart is regular rate and rhythm at 80. Lungs are clear to auscultation. Her abdomen is soft, nontender. No AP lateral compression tenderness of the chest. Neck: There is no specific cervical tenderness. No thoracic lumbar spinal tenderness. Full active range of motion in neck flexion, extension, and side bending rotation. She has slight reproducible tenderness in the right shoulder, but nothing that seems to need x-rays. No AC separation. Full active range of motion in upper extremities. Good pulses. Good reflexes. No other signs of trauma. DIAGNOSIS: Acute cervical strain status post motor vehicle accident. DISPOSITION: She was given Flexeril 10 mg t.i.d. as needed. Do not drive while taking this. She should take Motrin with it. She will follow up'with Dr. Becker. She was given a work note for tomor- row. JLW/dk D: 03/05/1998 - 12:17 pm T: 03/09/1998 Joey L. Wisner, PA-C DVI: 61105 Page 1 of 1 CARLISLE HOSPITAL ORIGINAL EMERGENCY ROOM RECORD I CAR NURSE PITAL 246 PAR' BEET CARLISLE. PA 17013-0310 c {TENT 16- FOR NURSING ASSESSMENT SEE NURSING DOCUMENTATION SHEET z TED c D E, ? a01 .'rt Cos 1, Tn oT/iEa c"=c c:::w,.?E E W110Kn ON ns,r ,E 1 c I I l 11 SAME -9:5APROVED DISPOSITION FROM ? EDc--C;e[ONVENIENr cc HVR DP.IVER SELTED PATE) NOTIFIED I .- Th1E INIT. RESPONDED R SIDE OF NECK ID SHOULDER 350-7 O1 AV;." 'NIABEP ValEla //iiAe 33(}36 335509 HD LTRY, BETHANY A NE M Ml Fh EJ . 03/05/93 )i;« JJ o;i. LY . rI'I)??1 Yf ER-0508 (REV. 8/96) 1 I Carlisle Hospital and Health Services CONVENIENT CARE CENTER NURSING DOCUMENTATION IJ?,iI` l'Ini'ti•: NAME ROON# AGE ?-? WT . VITALSI S: TIME IOL)I T R / E P 7 Bp! O LLa p LIMA . ALLEMIES: CURRENT MEDICATIONS: TIME DATE LAST 1. DOSE LAST 2. DOSE LAST 3. DOSE LAST 4. DOSE LAST 5. DOSE LAST 6. DOSE LAST 7. DOSE LAST I ES2012 1"7) TRIAGE NOTE: Modo or Arrival: ? ALS ? BLS ? Ambulatory ? Wheelchair Date: Arrived With: ? Police .? Friend ? Parent ` ?ramily ? Self ? Other P-- v Onset of Symptom Nursing Action/Comments: Childhood Immunizations: ? UTD ? Never ? Treatment Prior to Arl PULSE: (Regular ? Irregular ? Full ? Weak SP: ? Shallow ? Rapid ? Audible Normal ? Deep ? Slow Wheeze ? Labored ? Strider ? Retractions LAST COLOR: ? Dusky ? Cyanotic SKIN: ? Cool ? Edema 9. DOSE Q Good ? Flushed ? Nailbeds I ID Warm ? Clammy ? Ecchymosis LAST ? Pale ? Jaundiced ? Circumoral [D Dry ? Rash ? Laceration 10 r DOSE DICAL S HISTORY j 1"+ T WE PA : TETANUS STATUS: Surgery r Smoke: Y N ? Within 5 Years ? 5-10 Yrs ? More than 10 Yrs ? Neverl Hostel. Drugs: Y N TRIAGE NURSE'S MedicalProblems Alcohol: Y N SIGNATURE: Time to Exam Room: Visual Activity: Pupils: PUPILSIZES O Ri Si e ht 1 2 3 4 5 6 Lung Sounds: flight: ? Ralas El Wheeze D g z - i R ? N Ed ? Rhonchl ? Absent OS ? eact on 6 b /A Left: ? Rates ? Wheeze 0117A Lett- Size 0 1 2 3 a ? Rhonchl ? Absent ? with Glossies / ? Wftil Glasses ? IAA Reacticn Pulse Ox: LMP: ? With Contacts CENTIMETERS Tune BP P R NOTES: L-PATIENT /FAMILY VERBALIZED UNDERSTANDING OF DISCHARGE. INSTRUCTIONS: Verbal Instructions By ? NIA ? WRITTEN INSTRUCTIONS GIVEN MD/('AJ DISCHARGE: El caa'll []Self IJAmbulatory ?•Fe y ? Arnmelory E Assistance []Friend ?Whoelehatr []Police ?Ambuaril []Other- ? Other Special Instructions []General []Other- []WorklScheol Esuse []Prescriptions DISCHARGE NOTES: ?Abd Problem []Chest []Muscle strain []Allergic Reaction []Clear Liquids ?Nsaid []Animal Bite -„ mputor DlC ? OCtJSplinUCasl ?AnLbiohc ?Crutcnos ?URI ?Azimma []Eye ?UTI [] Back []Fever []Vomiting/Diarrhea [] Burn ? Fr Sprain ? Wound Caro 17 Head Injury NURSE'S SIGNATURE Carlisle Hospital -- Emergency Departq t HOL'f BETHANY 246 Parker St. Carlisle, PA 17013 - (74 ^ .5500 31 " ):50am DISPOSITION SUMMARY Patient: HOLTRY. BETHANY SS #: Current Ph: CURRENT Address: City: _ Zip: Arrival: 3/ 5/98 10:50am Disch: 3/ 5/98 11:19am MD ED: Anthony J. Guarracino. DO PMD: Res/PA/NP: Joey L. Wisner. PA-C PMD Ph: Dx #1: Cervical Strain Age/DOB: Medical Record: 280416 Disposition: ICD-9 #1: 847.0 #1 Dx Engl: SPNECK.ESW #1 Dx Span: SPNECK.SSW Dx #2: Motor Vehicle Accident-Driver ICD-9 #2: E819.0 #2 Ox Engl: MOTORVA.ESW #2 Dx Span: MOTORVA.SSW Rx #1: Flexeril (Cvclobenzaorine) 10 mg 1 tablet by mouth three times a day as needed #24 tablets Follow-up: BECKER. STEPHEN M 91 SOUTH HIGH STREET NEWVILLE. PA F/U MD Ph: F/U D/T: Other Instr: May return to work/school: 3/7/98 MY SIGNATURE BELOW INDICATES: > I have received and understood the oral instructions regarding my current medical problem. > I will arrange follow-up care as instructed above. > I acknowledge receipt of the written instructions as outlined on this and apy previous page(s). I will read and review these instructions. `-Patient (or Lebal Guardian) Signature Staff (Witness) Signature i Carlisle Hospital and Health Services CONSENT TO HOSPITAL ADMISSION AND MEDICAL TRF.ATMENT? _ , f- , Name of Attending Physician (s) : Date of Admission: 'S - J - C?g Time: (AM) (PM)__. 1 I (or acting on behalf o£) Name of Authorized RepruentatBe \ ? %1 Y l Qn t, suffering from a condition requiring hospital care, hereby Na Of Fatlent consent to rendering of such care, which may include routine diagnostic procedures and such medical treatment as the named attending physician(s) or other of the hospital's medical staff consider to be necessary. 2. I understand that the practice of medicine and surgery is not an exact science and that diagnosis and treatment may involve risks of injury, or even death. I acknowledge that no guarantees have been made to me as to the result of examination or treatment during this hospitalization. 3. I understand that: (A) It is customary, absent emergency or extraordinary circumstances, that no substantial procedures are performed upon a patient unless and until he or she has had an opportunity to discuss them with the physician or other health professional to the patient's satisfaction; (B) Each patient has the right to consent, or to refuse consent, to any proposed procedure or therapeutic course; and (C) No patient will be involved in any research or experimental procedure without his or her full knowledge and consent. 4. I understand that many of the physicians on the staff of this hospital, including the attending physician(s) named above, are not employees or agents of the hospital but, rather, are independent contractors who have been granted the privilege of using its facilities for the care and treatment of their patients. Further, I realize that among those who attend patients at this hospital are medical, nursing, and other health care personnel in training who, unless requested otherwise, may be present during patient care as a part of their education. Still or motion pictures and closed circuit television monitoring of patient care also may be used for educational purposes or for documentation of the clinical course unless a patient expressly requests otherwise. 5. I release CARLISLE HOSPITAL from all responsibility for all articles which I am retaining or will have with me during my stay at the hospital. I understand this includes clothing, bridgework, false teeth, eyeglasses, jewelry, money, radio, razor or any other item kept in my possession. I understand I may deposit valuables in a safe provided by the hospital; only if this is done will the hospital assume any responsibility for the safekeeping. 6. I hereby acknowledge that I have received written information on the topics of Patient Rights and Advance Directives. ate of Signature: ?G -e.L-u > d-P/n4 r? {SIGNATURE OF PLA PIENT} t t .", rJ R SIG E OF WITNESS} (If patient is unable to consent or is a minor, comolete the following:) Patient [is a minor _ years of age] [is unable to consent because] : SIGNATURE OF LEGAL GUARDIAN OR {SIGNATURE OF WITNESS} `? - CLOSEST AVAILABLE RELATIVE) AD 0315 (10191) ' .l J • Carlisle Hospital and Health SetVices PATIENT'S NAME: 1,f l 1 f ?t ?7CIl? IlrO_. INSURANCE CO.: s-? C_ r JIY ,r„v„• other Health insurance Benefits and/or Physician. 1 authorize Carlisle Hospital as the holder of medical information pertaining to me to release the necessary and appropriate medical information to the fiscal i t rmediainsurance Social Security Administration and/or to my primary or supplemental company or it's designated review agency for payment for services rendered. I authorize the Carlisle Hospital's and/or the physician's billing agent to submit a claim to Medicare or other health insurance on my behalf, or to request, on a one time only basis, from the Social Security Administration, such information necessary to complete the claim submission process. I am the individual to whom the information/record pertains, or am authorized to consent, on behalf of the individual, to the release of the information/record. I understand that any false statement or representation knowingly and willfully made or caused to be made for use in determining rights to Medicare benefits or payments may be punishable by a fine of not more than $ 10,000.00 or one year in prison, or both. I request that payment of authorized benefits be made on my behalf. I assign the payment of inpatient or outpatient hospital benefits to Carlisle Hospital for those services provided by Carlisle Hospital and/or I assign the benefit payable for phy- sician services to the physician. I certify that the information given by me in applying for payment of services under Title XVIII of the Social Security Act or for any/all other health insurance is correct. ? n? 1 i 1 l SSN Date Patient's Signature Relationship Dale Responsible Party if Patient Unable to Sign Date Insured Person's Signature (If different from patient or if patient is a minor.) Reason Patient could not sign. ?,^1 n vnuiess dloal.Records /.Ancillary. DDepartment s White gopY AD 1825 (1/96)• Canary CopY@v_. ,.. .?_, •• ,?,Healthcsre Billing. :: .. . •nn uwwww???iri?rwwww®? 2 HART" AN REIIBILITATION ASSO( '.TES Stuart A. Hartman, D.O. i = '000 2645 North 3` Street Suite 490 Harrisburg, PA 17110 717-232-7246 FAX: 717-236-5408 PROGRESSNOTE RE: Beth Holtry SS#: 185-66-7132 DOI: 3/ 05/ 98 Claim: 1553022946R34 September 21, 2000 Ms. Holtry was seen for a physiatrie pain management follow-up on 9/21/2000, at my Harrisburg Office. She is doing much better overall. She is still getting headaches about once a week that put her down and this is because she takes 2 Phrenalin and they knock her out. However they do help the headaches. She definitely feels that the last visit the osteopathic mobilization therapy helped significantly. It did not help the headaches significantly because they were still intense but overall she felt much looser in the neck and shoulders. She is getting massage therapy once a week and this does help. She is not using any ice or heat regularly but is using IcyHot. She is not taking any medication regularly other than the Phrenalin. She does continue working. She definitely feels that the weather effects her symptoms and she takes hot showers. Her good days are better overall. Her physical examination shows improved mobility and flexibility in the neck and the shoulders. She was less tender tight and ropey overall. She was still tight at the right cervicothoracic paraspinal region more than the left. She was tender at the trapezius and subocipitally and even at the sternoclidomastoid. She was less tender anteriorly. Ms. Holtry is stable with her post traumatic cervicothoracic strain/ somatic dysfunction, myofascial pain and her bursitis is better. Her muscle tension headaches are better. I again performed active OMT and she was much looser. We had very good mobilization. She will continue with her present program and medications. She will continue with massage. She will use ice and heat as needed and the IcyHot. She will call with any problems or be seen sooner if needed. The massage that she is getting is myofascial release and this is beneficial. Stu A. Hartman, D.O. SAH/emp cc: W. Scott Henning, ESQ, 1300 Linglestown Rd., Box 1177, Harrisburg, PA 171 10 Allstate Ins., 6345 Plank Drive, Suite 100, Harrisburg, PA 17112 HART", N REHBILITATION ASSOC TES Stuart A. Hartman, D.O. 2645 North 3'° Street Suite 490 Harrisburg, PA 17110 717-232-7246 FAX: 717-236-5408 PROGRESS NOTE AUC 1 7 2000 RE: Beth Holtry SS #: 185-66-7132 =- D01: 3/5/98 Claim: 15530229461134 August 8, 2000 Ms. Holtry was seen for a physiatric pain management follow-up on 8/8/2000. Overall she is doing about the same as her initial eval. She is still tight in the neck and the shoulders. However, she did feel looser for at least a few days after the OMT. She still gets headaches. She is having good and bad days. She is doing her stretches. She definitely feels that the weather effects her symptoms and she is looser when she takes hot showers. She feels soreness primarily in the shoulders and also is getting some headaches primarily on the right. She is not taking any medication regularly. Site does continue working. Her shoulder seems to come and go. Her physical examination shows her to be less tender, tight and ropey overall. She is tight at the right cervicothoracic paraspinal region, greater than the left. Range of motion is functional with some pulling in the right neck and shoulder. Her strength is functional. Sensation is still slightly decreased on the right. Her trigger points were less overall but she was quite tender, tight and ropey on the right. The right was less tender anteriorly. Ms. Holtry is stable with her post-traumatic cervicothoracic strain/somatic dysfunction and myofascial pain and shoulder bursitis. She is having muscle tension headaches. I did perform active OMT to the cervicothoracic paraspinal region bilaterally. She was much, much looser afterwards and we had very good mobilization especially at the first rib. She will continue with her home program and I gave her some samples of Phrenilin to try every four to six hours for her headaches. If this does not work, I would suggest Midrin and she will call for a prescription. She will call if she has any problems and be seen sooner if needed. Otherwise, I will see her for some mobilization in six to eight weeks time. I also discussed possibly some myofascial release therapy. She will call with any problems. Stu A. Hartman, D.O. SAH/tld cc: W. Scott Henning, Esquire, 1300 Linglestown Rd., Box 1177, Harrisburg, PA 17110 Allstate Ins., 6345 Flank Drive, Suite 100, Harrisburg, PA 17112 - ° 2000 HARTMAN REHABILITATION ASSOCIATES Stuart A. Hartman, D.O. Lebanon Office Harrisburg Office 4th & Willow Sts., 3rd Fl. 2645 N. 3rd St., Ste. 490 Lebanon, PA 17046 Harrisburg, PA 17110 Telephone 717-272-1050 Telephone 717-232-7246 FAX: 717-272-1740 FAX: 717-236-5409 June 8, 2000 W. Scott Henning, Esquire 319 Market Street Box 1177 Harrisburg, PA 17108 RE: Beth Holtry SS R: 185-66-7132 DOI: 3/5/98 Claim: 1553022946R34 Dear Any. Henning: Ms. Holtry was seen for a physiatric pain management evaluation on 6/8/2000, at my Harrisburg office. She denies any previous problems until 3/5/98. She was the driver of a car, which was rear-ended. She denied loss of consciousness but apparently her seat snapped back and to the right. A little later that day, she had pain and started to get a headache and was seen in the Emergency Room. She states that the pain has always been in the right neck and shoulder and she gets burning from the neck into the arm and hand with some numbness. She had a lot of shoulder pain and did have an MRI and x-rays in the past, which were unremarkable. I did have the opportunity to review these. She has gotten physical therapy on and off for about a year from March until February of 1999. She would get the physical therapy when she would get flare-ups of pain. She has good and bad days. With the cold, rainy weather, she was effected. She just recently started to get some massive headaches. When she lies down, they decrease. She has tried Icy Hot. A hot shower does not help. Today, she is sore. She does have an increase in symptoms with activities. She denies any significant weakness. She is not taking any medications regularly other than a birth control pill and Claritin. The only medicine she had was in the Emergency Room. She denies any allergies. She does work doing accounts receivable and is on the phone, computer and filing. At home, she has a two and a half-year-old. She does not smoke, occasionally drinks and drinks decaf. She does have allergies but denies any surgeries. Physical examination revealed a very pleasant, cooperative, alert and oriented 29-year-old female. She is right handed and denies previous problems as above. Cervical spine range of motion was functional N. Scott Henning, Esquire RE: Beth Holtry Page 2 June 8. 2000 except for a slight decrease with left side bending and left rotation with more pulling on the right. Upper extremity range was nomtal. Her reflexes were equal and symmetrical. Her sensation was mildly decreased in the right arm. Her strength was all normal. She was tender, tight and ropey at the cervicothoracic paraspinal region with trigger points at cl, "rl and T2 and she was tender at the right shoulder anteriorly with the arm in extension. She had numerous areas of somatic dysfunction. She was nontender at the chest. Ms. Holtry is suffering from a post-traumatic cervicothoracic strain/somatic dysfunction with myofiscial pain with trigger points and a shoulder bursitis. i did perform some active ONiT to the cervicothoracic paraspinal region and she felt much looser. She had better mobility and less pulling. She responded quite well. She also has a very mild shoulder bursitis. She is getting a component of a muscle tension headache. i instructed her in a number of stretching exercises and gave her a stretching chart. She does not need any medications. Site does not require any formal physical therapy. She should do quite well and I will see her for follow-up in six to eight weeks time and see how she is progressing. She will call with any problems. Please feel free to contact me if you require any Rtrther information or clarification of my report and recommendations. Very truly yours, Stuart A. iartman, D.O. SAHltld cc: Allstate Ins., 6346 Flank Drive, Suite 100, Harrisburg, PA 171 12 !DATE: PROCEDURE: ?1?'S M 1 fl?h wAlli4'? avarlx!IU rmN,l :m:un rr37GC.i?dcr x•xi. YY CV?,? li Gi`arwa ?ur;n,: PaTIEN i a>rE Qt.GC I I L/S I / I I I PATIENT 9 I I I DIAGNOSIS ?^'o'? I I ATTENDING SIIEF AtIST REFERERING PIIYSICIAN; RESPONSE TO DATE COMMENTS TRCAThARhIT DAIhI DAnun - • nn ulrV JIUIVNI URC Z 40 - I I P.T. I I ! I I I I I P.T. I I i I I I P.T. I I I I I I P.T. ! I I i I P.T. 21 - ,r rnul?es recommennea wiui rauonaY/or continue lan 4 P 1'&It aLTIFER4PIST _? DATE I. t i Yi Ng _th•e, Padent commant•/rsoonses PHYSICAL THERApfST DATE i P, DATE COMMENTS RESPONSE TO _ TREATMENT PAIN RATING SIGNATURE z x z?. US /•S 4,? kS - US o ?I ,..:1 Physical Therapy Aquatics, Orthapaedia & Wound Care 425 Stonehedge Drier Carlisle, PA 17013 T. 717.240.0330 F. 717?40.0233 Ronafrl D. Greenoary, P.T. Owner Karen J, Bair, P.T. Associate Valerie f. Koraue, P.T. Associate Stacy E. Rosenberry, P.T.a. Clir:ic Special:ia Diiff mtSrmFa AQUATIC THER.L'r F.w,in, UPPERd LOU'ER WK E%ury 81,13 U'O"'dCurs CHFO.vfC'S'OL'.90 CIF S FacrToF,¢r Lt1J THERAPY SponingLifr EPoars Rit a ELEASE REVIEW, SIGN .& RETURN INITIAL EVALUATION AND PLAN OF CARE EVALUATION AND PLAN OF CARE fcr REFERRED By al-',?? ONSET DATE: TREATMENT WAS INITIATED ON: 2- - Z-Sy This -Z-7 year cldw? was referred to PENN; WOOD PHYSICAL THERAPY for treatment of. /i?w n n Inc >'rob;e:ns to o& anereI Ld cy physics; th5r2py ale as tr,:c:: r The Treatment Plan for each problem is as fo;la.ws: In In discussing the Diagnosis, Pro gnosis, and Treatment plan, the Patient and I have established the fa;lovrin3 Short Term and/or Long Term Goals: Frequency and Duration are to be ?2 Visits per vice's, for Z I I Re•evaiuationfRe•certification and. Goal Revision or [4 Discharge at the end of ttGs period. h Respe sub R ' -r< ony, P.T., Karer, Sa! P.T. sub Physician Ccmmectsllnstr'ac!ions: Dzt Z-2- Cl RFCFIVFD FFR 0 0 1959 rsenau. Fuirnlini: I ?E::CELLE? T i i SC-00 11 e;.,IF 1 oOna i ATE: URE °ROCED: ?5` I I/ t3 r . lii¢nr h?.;u?YiC z It of inn rcaare ic:u•:tia"i3! Z 1 ?f << ?:a„aa a. mn nnOm. nm v TrJ11Tki..ii?ufha?nvMvu:n?dmcva Z I I /eti. r,?rle?r},??[E lhv 11 I -1-1 r I PATIENT c 6 Z? cSCJ I r ?- ? S I f I I ? DIA0NOSI-?- c ?G -:, -?f/ldly I I I I -? 0 I ATTENDING TDERArIST I I I i I I I rZFFERERING PHYSICIAN' RESPONSE TO DATF COMMENTS TREATMENT PAIN RATING SIGNATURE - I I I i I I P.T. I I " I I P T I . . I I I I I I P.T. I I I I I I I I P.T.1 __ PHl' L R:\PIST /zri z9 i rer DATE PHYSICAL 7II7 RpPIS7' / DATE . - REATPAENT PAIN RATING " SIGNATURE . - -vs- 'v I i ? ' • i i .. P. ?' -- (L i GL.-w - ? I I I I 2 /ham' n Tl? P.T. [.T y ! c C- I I --- P.T. ell= ? I I I I I _ P.T. Sub ective: Patient comment;/responses Ob ectiM progress in tr at c -, (Ch•mge- in ROM strength endurance fl xabilit functional ibvt i Assessment. Changcs in Status or coo oration (Specific references to current physical capacity relevant to disabilirv Plan: Arty Chang-s recommended with rationale/or continue lan PHYSICAL TIfiLRAPISl' DATE RESPONSE TO DATE COMMENTS T e oee Physical Therapy A uatics Orthopaedics & R'outd Care :?>r45E REVIEW, SIGN & RETURN INITIAL EVALUATION AND PLAN OF CARE I , 425 Stonebedge Drive Carlisle, PA 17013 T. 717.2.10.0330 F. 717.240.0233 Ronald D. Greenivay, P.T. Owner Farces J. Bair, P.T. Associate Valerie J. Fmzun, P.T. Associate Srary E. Rosenberry. P.7'.A Clinic Spechdries Di6naoSsruku AQUATrCTHERAPY Fxverniria UPPER 4- LOWER ECTRESrRY REHAa WourrdCure CHRo.VrCwoUVOCARE _ FaceTaFace -TAf1 THERAPY Spaningi.ifr SPDRTs REHAB EVALUATION AND PLAN OF CARE for &&C REFERRED DYy?t /ffQ , o ONSET DATE: T-5- f,g TREATMENT WAS INITIATED Ott: 30-78 This _Z7 -_Year old /1/lJ'?- fWLW G eras referred to PENN's WOOD PHYSICAL THERAPY for treatment of. A 21 HISTORY. The Problems to be adu ossctl by physical tharapy arc as The Treatment Plan for each problem is as In discussing the Diagnosis. P;ogaOsis, and Treatment Plar, the FatWt and I have established the foiloMng Short Term and/or Long Tenn Goals:_ C// /G¢ n a `/a SX S 76 2?i o ?S?q Today's Treatmenh rehab. Potential: jL?r-tEXUELLENT I *rzooc, 1 1 FAIR r t FOC.K Frequency and Duration are to be -_ visit s per vrek for `FeRasva.Bks Y.{;it I I Re-evaluationlRe-certification and Goal Revisicn or tx,'Discharge at the end of t•!! pered. RespectNhy s ? 'ted: P,cn P.T., Karen Ba:r, P.T. Physician Cemmenishnstvctions: Uate Y Date ???\VEp ?`? ? 4 1??8 R I O a` ? a W X ao ?I I I r? ? Yj: 1r T1 T1 Physical Therapy EQITIAL EVALUATION: Penn's Wood Physical Therapy Aquatics,' Orthopaedics d Wound Care DOB: eLEASE REVIEW, SIGN $ RETURN BETH HOLTRY 361 SAXVMILL ROAD NEIVVILLE PA 17241 MARCH 14, 1971 DATE OF EVALUATION: OCTOBER 15, 1998 DATE OF ONSET: OCTOBER 1, 1998 - APPROX. REFERRING PHYSICIAN: DIAGNOSIS: Stephen M. Becker, M.D. t Cervical and upper shoulder pain. TREATMENT ORDERS: Evaluate and treat. HISTORY OF PRESENT ILLNESS: Approximately, two weeks ago while at work, the patient was pulling on a filing cabinet drawer when she felt a pop that seemed to be in her posterior right shoulder blade area. She states that her'symptoms have been on a continual. course of worsening since that time. At rest, she is relatively pain free most of the time but the amt immediately begins to react to any kind of use. She is currently not on any medication. PAST MEDICAL HISTORY: The patient was seen in this clinic for cervical strain secondary to a motor vehicle accident which occurred on 3/5/98: The patient states that these 'symptoms seem to be somewhat different than those experienced with the earlier episode. Her general health is reported to be good. Surgical history is unremarkable and fracture history included a nondisplaced wrist fracture that occurred sometime in the past with which she has had no.problems. Allergies include mills and eggs. SOCIAL HISTORY: This is a 27-,year-old married white female. She is employed doing office type work and has a child that is approximately one year old. S: At this point in time, she is complaining of pain in the upper trapeuus at 8.5/10. At its best, this pain will drop to a 2/10. She describes her pain as being at the top# of the shoulder with numbness and tingling extending down into the thumb and fast two digits of her hand. O: Ms. Holtry came to the clinic independent of any assistance. Mental Status: She appears to be alert, oriented normally and has normal communication. Inspection: Inspection reveals an otherwise healthy-looking white female. She appears to be her chronological age. Posture: She is not posturing her head or shoulders in any unusual manner. RECEIVED OCT 2 3--1998 Page 2 Re: Beth Holtry October 15, 1998 Palpation: Palpation reveals tenderness in the distal portion of the upper trapezius and sometimes in the anterior portion of the shoulder. RObf: Range of motion appears to be within normal limits bilaterally. There is some symptom aggravation particularly with horizontal adduction. Strength: Strengthwise, there appears to be a slight decrease when comparing right to left. This is notable because the patient is right side dominant. Neurologic Assessment: Neurologically, the patient hqs a complaint of tingling or numbness extending through her arm through the median nerve distribution of her right hand. Sleep/Bed Mobility: The patient reported that she had a poor night's sleep last night but typically has not had a problem with sleeping. Balance: Unaffected. Gait/Ambulation: Not applicable. Wound Description: Not applicable. Girth: Not applicable. Transfers: Not applicable. Special Tests: An'Adson's test was carried out and found to be negative for any type of thoracic pressures to the vascular bundle. Placing the carpal tunnel on slack or the median nerve on slack did little to affect symptoms. Tightening the carpal tunnel area also did not seem to cause any change in her symptoms. A brief cervical evaluation was'also carried out and there appeared to be some centralization of symptoms .with neck retraction and extension with slight overpressure. Functional level prior to onset: Patient was fully independent in activities of daily living. TREATMENT: Treatment today consisted of this evaluation followed by moist heat to the right shoulder girdle complex. The area surrounding the brachial plexus was treated with interferential stimulation on preset #2. Also, the brachial plexus tract through the anterior portion of the shoulder and in the axilla area was treated with ultrasound and die patient was subsequently placed on some neck retraction1cxtension with overpressure types of exercises. Home Instructions: No home instructions were provided at this time. Page 3 Re: Beth Holuy October 15, 1998 ASSESSMENT: At this point in time, it was difficult to determine the exact cause of her symptoms because ofinieed signals. This could be cervical in nature with mild impingement to some of the brachial roots or possibly brachial plexus stretch. Other tests seemed to rule out thoracic outlet, scalenus anticus symptoms and rotator cuff symptoms. ;? 0- y?. l 7- ? Short Term Goals(To be achieved in 1 week): 1. A determination will be made of the most effective treatment for the reduction of symptoms. Long Term Goals(To be achieved in 2-4 weeks): t 1. Patient will be reporting a cessation of her symioms particularly the symptoms in her right arm and hand. 2. Patient will be independent in a home program. Rehab Potential: Good to excellent. TREATMENT PLAN: The patient will be followed on a three time per week basis to further clarify the cause of symptoms and to subsequently set up a consistent follow up program to achieve the above-mentioned goals. Thank you for this referral. Sincerely, Ro . Greedway, P.T. RDG/cam file:\msworks\evcr.-\cam Physicia s Signature D?tc DATE PROCEDURE: miwn n n+ t;;;';nnl? °? /Lv raum r,. wsnud tnnvti?.uri?J?.,'1G?i?en;ct lio a x ??? rtl=„inc?rv niuy:1;?n qI Q eAT lEtirIt aatE 1?-{'ti •????? i PATIENT k 1 I 6'SLI Lis I I I I I I I pp.,?? ? •A Q /J DIAGNOSIS 0f tcue o O TP I zZ ?,,, ,_ ATTEND Ll'G THERAPIST I I I I REFERERINC PHYSICIAN (.C?, RESPONSETO DATE COMMENTS TaanrrlFAIT PAINPATIAI!] CI^v aTI,mn ..._. ..... _ ... ......... ....... .a,v I uRc r t X611 C I i , I ? P T .o ( . . X.ZO P+/o I I ?A S- /.SW z i Tj _ J drK I I . tK S s So - S P.T. o Z3 _ ? I I I ' I i I I P.T 1 P LTHEPLA io / zg- ; 9Il DATE 0 8 Physical Therapy ,-=; INITIAL EVALUATION: Penn's Wood Plgsical Therap,v Aquatics, Orthopaedics & wound Care BETH HOLTRY 361 SAWMILL ROAD NEWVILLE PA 17241 DOB: MARCH 14, 1971 DATE OF EVALUATION: MARCH 10, 1998 DATE OF ONSET: MARCH 5, 1998 - MVA REFERRING PHYSICIAN: Stephen M. Becker, M.D. y DIAGNOSIS: Cervical strain - right upper trapezius greater than left. TREATMENT ORDERS: Evaluate and treat as necessary. PLEASE REVIEW, SIGN & RETURN HISTORY OF PRESENT ILLNESS: The patient is currently complaining of right neck and right upper shoulder pain with periodic sequalae into the right arm which she describes as numbness with a feeling/sensation of tingling. Her medications currently include Flexeril which she-was given in the emergency room. However, she reports she is not taking it because it "made her fall asleep". PAST MEDICAL HISTORY: Past medical history is noncontributory. The patient's general health is good. The patient does report that she has'asthma but has not needed any medication or iiihalecs for several years. Surgical history is unremarkable. Fracture history includes a nondisplaced wrist fracture sometime in the past of which she has had no problems. Allergies include mills and eggs. SOCIAL HISTORY: This is a 26-year-old married white female. She is employed in office type work. She has a four-month-old child at home. S: Currently, she is rating her pain at a 5, at its worst a 9 and at its best a 2, using a 0/10 scale. Her best is'usuany in the moming. She states that her symptoms seem to be aggravated with her work. particulaily to the middle to the end of the day. She states that she bought a cervical collar"and has been using it, typically just at home. O: Mrs. Holtry came to the clinic independent of any assistance. She does not appear to be in acute pain. She is not holding her head in any skewed manner associated with muscle spasm. Mental Status: She is alert, oriented normally and has normal communication. Inspection: Inspection reveals a healthy-looking white female. She appears to be her chronological age and once again, does not appear to be acutely uncomfortable. RECEIVED NO 2 0 1998 Page 2 Re: Beth Holtry March 10, 1998 Posture: Posture was erect and within normal limits. Shoulder musculature does not show any elevation when comparing left to right. Palpation: Palpation revealed some increase in muscle tone in the right musculature especially the upper traperius but no obvious muscle spasm. ROM: Range of motion of the cervical spine showed a moderate reduction in all motions with a complaint of stiffness in flexion and extension. Decreased rotation to the right was noted and rotation to the ]elf appearec4 to be more freely achieved. Lateral tilt was restricted more to the left than to the right. Shoulder range of motion was unaffected. Strength:. Strength of the upper extremities and neck appear to be unaffected other than the restriction caused by the patient's complaint of pain. Neurologic Assessment: Neurologically, the patient is grossly intact to light touch and pressure at this time. As noted, there is no loss of strength. The patient does state that she periodically experiences a "tingly" feeling and that it "feels like its going to go numb". Sleep/Bed Mobility: Unaffected. Balance: Un.'tffected. Gait/Ambulation: Unaffected. Wound Description: Not applicable. Girth: Not applicable. Transfers: Unaffected. Special Tests: Not applicable. TREATMENT: Treatment today consisted of placing the patient in a supported prone position using galvanic muscle stimulation to the upper trapezius on both sides with a noted sensitivity to stimulation on the right which would be expected with this type of injury. This was done in conjunction with moist heat. Following this, the area of complaint was treated with ultrasound and pulsed galvanic at 5 pulses per second for approximately 5-7 minutes. This whole area was then treated to a relaxing massage with a complete cessation of the patient's symptoms. Page 3 Re: Beth Holtry March 10, 1998 Home Instructions: The patient was provided with the "Neck Owner's Manual" and encouraged to do gentle range of motion exercises, particularly after using a heating pad or hot water bottle or hot shower. Patient was encouraged to try to? change her activities during the day to prevent aggravation of her cervical and upper iL shoulder symptoms. ASSESSMENT: Acute cervical strain secondary to a motor vehicle accident. Goals(To be achieved in 2-4 weeks): 1. Patient will essentially be symptom free and will have returned to her normal activities of daily living. Rehab Potential: Excellent. TREATMENT PLAN: The patient will be followed on a two to three time per week basis for two to four weeks with a reduction in frequency as the above-mentioned goals are achieved. In addition to palliative modalities for relaxation, manual traction may be utilized to increase range of motion and stretch die affected musculature and therapeutic exercise will also likely be added. Thank you for this referral. Sinceiely Ronald D. Greenway, P.T. Physician Signature / ate RDG/cam fde:\rirsworks\cvcrg\cam. II ' rctarvrvat iu lL ?TI1 arm • u \ $ tit ..?- } k?' •• P.T. v S ,?- `?' Ja r r'; " ? f S lwi ?.??Z ?C S'\hA7 ?S P.T. in P.T. r t P.T. Crr P.T. f "" Q^ 3 , -?L 3 , 5 p PHYSICAL THERAPIST' DATE Mvm . «a DATE: IL--f1 PROCEDURE: 3t 9- PATIENT NAME t'\ 1,44 1 `LS\I I PATIENT O 1 ? I l? v'? ^ -•^ DIAGNOSIS S?"'?l ^A I \ ( ? ? ATTENDING THERAPIST I i REFERERING PIrY SICIAN RESPONSETO DATE COMMENTS TREATMENT PAIN RATING SIGNATURE C AO o k ?o P.T. F r. ii I I P.T. -\)4- nxc\ Lf P I i P.T. I I I I I P.T. I I Sublecttve• Patient comments/resoonses Oblectlve• vrogress in treatment (Changes in ROM strength endurance flexability, functional ability) AssessmentAssessmen . Changes in status or cooperation (Specific references to current status or cooperation (Specific references to current physical capacity relevant to disability) PHYSICAL ' / P-- / A DATE Physical Therapy Arymio, W,4.Ndi.,NO'R.,J Gyre •, {/'Date: T Patient Name:??a? Y AC- / /U DX: Precautions: Please evaluate and treat with the ?following recommendations Z, ?t- /?? Physicians Signatu?e rl Freq. /WK, Recheck Weeks Muscle strength and cond,OCmng •%%m be eva:uated with appropriate tesnrg when apprcorate. Neuromuscular Iaclaeaon, prcphoceppve traming and AOL ms:rucocn will be inccrpara:ed into all appropriate rehab litahon programs. Ronald D. Greenway, P.T/Owner Faun J. Bair, P.T.lAmociute Valerie J. Torun, P.T.Diswciarr 425 Srorwhedge Drive • Carlisle, PA 17013 Tel. 717.240.0330 • Fax. 717.240.0233 *RON : STEPHEN BECKER, M.D. PHONE NO. 717 7764391 t rt Ph?:?icr+l TDate: 1L Patient Name: y1y)J`I?? M rnl?? Precautions: ..- ----?-- please following evaluate v d t rvll! Mtth the d n1ill(l 6`1c?c O's Physicians Signature AA. RLI&eCk----` weeks Freq, liatr, t:.$ng ttu:Cle sUanfl:h aotl c:nditAniny will be evah-at8d With epti B training and AOL ^ VIV ILfilti.Yn?n. P '?;\a11n1\ ta7t3ln= Y01111'dLGrn\villn. MCWOnNtC Clmmnn win 1c rr oly??.-% ^+^ ?'1 UVV"Y V:I'f, llii.'?17 f' ff 23 1993 02:45PH PI, ' • v FRal STEPHEN BEC.KER, PI. D. F i ' I'/ryi ieul Thv*ul i II Palieni N2rne:._?-/? II DX: (MFR;1??QQ?"? i Prec8lltier)S; _ '???391 Date:. ,_JrG? - Please evaluate and treat with the following recommendations .n ? J li ii ??? ?' J1 / PC < Physicians Signatur? Freq. MK. Recheck ---- weeks 1; ld,.,:! :12nq;n Zinc coma: or-it a vil' be •.va'u; ed witr, appropneta rES:i^p I( nhn-n eup•ucrla:e. Pl^urrmscc:a: IsriGra:ion, przpiigcep;ia !raring Md ADL Init.•Uctian will be ?.:nrppra'en ;nip qI: ;.pprop'i:^.:, rr P,:bill:a:ion p:op•ams Ronald D. Grcrnwuy, ; ? Knr7+t?. tS6lY. P.T.itmocin:< Oct. _13 159.3 02:57PI-I P1 I -i l ..w 30o_In- • • ? 2 Physical Therapy Date: Aq-,u,, OnMDwyc. 9 {t'-_, Cu.e PatientiName: lwih Ho fir Precautions: Please evaluate and treat with the following recommendations... euoQ?-?; t I-Or Physicians Signature Freq. /WK, Recheck Weeks Muscle strength and conditioning will be evaluated with appropriate testing when appropriate. Neuromuscular facilitation, proprioceptive training and ADL instrucon will be incorporated into ail appropriate rehabilitation programs. Ronald D. Greenuay, P.T./puma Karenl. Bair, P.T./Associate 425 Stonehedge Drive • Carlisle, PA 17013 Tel. 717.240.0330 • Far. 717.240.0233 { ,w., i R" I I n I ., STEPHEN M. BECHER, M.D. 91 South High Street Nomille. PA 172,11 Telephone: (717) 7764495 Fax: (717) 7764391 JulI G' 1000 June 1, 2000 Handler Henning & Rosenberg Attorneys At Law 319 Market Street PO Box 1177 Harrisburg, Pa 17108 Dear Atorney Henning: RE: Beth Holtry DOI: 03-05-98 PT SSN: 185-66-7132 DOB: 03/14/1971 I have been following Beth Holtry since October 3, 1994. Prior to reported MVA of March 5, 1998 she had been without complaints referrable to the neck and shoulders. I first saw Mrs. Holtry after the MVA on March 6, 1998. Since then I have seen her for issures related to this on March 13, 1998, March 20, 1998, April 3, 1998, April 24, 1998, May 22, 1998, October 13, 1998, October 27, 1998, November 16, 1998, February 1, 1999 and July 9, 1999. Please refer to my office notes for a narrative description of the symptoms and treatments. I believe that the MVA of March 5, 1998 is the direct cause of Mrs. Holtry's ongoing neck and shoulder problems. While no one can predict the future, the chronicity of her problems to date, would lead me to belive that she is likely to have ongoing problems for years into the future. I am unable to assign a percentage of disability in accord with the AMA Guidelines. I belive Mrs. Holtry will be in need of continued treatments on an occassional basis in the future. Physical therapy has been helpful in the past and I suspect it will be needed in the future. Questions or comments can be directed to the telephone number listed above. Sincerely, Stephen M. Becker, M.D. SMB/ljl STEPHEN M. BECKER MD 91 SOUTH HIGH STREET NEMILLE, PA 17241 Listing of cam.menta for Butt, Hot try Code Date _ Comment ___ ____ ...a 00.06-SB ____________________________________________________________ .. ,.vas x...u.v........................................... CC -Auto Act idont Sup- At About D AM yesterday she Was driving her [navy ca wailer when She was rear and 0d At A atop sign. Had seat "att on. No airbags. All she knows 11 that her seat wont back and down. Does not remember hitting her hear. No lease of concioesness. Had sane soreness in her neck right after the accident and that was worse this AM. Went to the ER , yesterday at 10130 and she w as given flecoril and told she had a neck Strain. Had %ca. pain over the right lower rib cAge thatwAS fir.: noticed "I, Al. Cb1- 100/70 pia 14A. r12 Tenderness of the right Sterndcl@COma4 told and the right upper trap and right Para cervical muscles - Tenderness over the flriating ribs anteriorly on the rgnt Adpa4 edI train Contused ribs plan-PT referral Mod dens cervical cellar Fle Flapril HS Hach ark anp Y@01: Pill s .m, 03 -13 -s2 .,x............................. av.v..v.,, ....... „ CC-M'JA ..., 03 ti0.1.2 ............................................................ strain CC-Cervical Sub- Was filing yesterday and she really hurts today. Has 2 more PT ups: ne,t week. Dbl' 116!80 p100 57.1 lain r13 Still with 502e tanaernoss in -he upper trap. Rik, and the r.gnt sternocledoaastotd FR CM in the noel: with pain when she fl...S to the left DTRIS sym Asses-Cervical strain plan-Continue PT and stretching Rach.Ck in 2 weeks PUI smp ..xx 04-03-52 .................................. x...................,v CC-CPI'/ical strain s/p MvA Sub- There are a.,% it is batter and days that it is fine. Has been about a weeks 06j 11.0/7: 1434 Same tanderrets in the upper trap bilaterally and the rhombotds. DTR's sym 52n.ary intact as sas-Cerv ical strain plan-Pech@ck in 2 weeks Continue the St,.tchlhq and us. I.chemic ce.mpression aver the rhomboias. PUI ,.no .... 04-24-1.e .............v................................. CC-CeryLcal strain Svb- Th. natl. pain had been on and off until it rained an Sunday Ana since then It has bean sore. Not nearly As bad as is had been. She kn.ws it is there but it has not kept her tram dainq things. CM Waanesday she had same tingling In her right hand wrnle she was writing. It lasted for 3-10 sa Wntls. Has hat returnee. Work-makes Store Calls, Sits in front of a computer and fil.s Cb)- r.v Ck-tenderness in the rhomboids-mihimal .tp •J ied i• -OY Upper trap With SPaSM And tenderness towards base of neck some tenderness in tna right Para cervical nu5f1H1 Can flea rte na tl: normally. 5lfaaldpr9 -naC AS Plan-CoonnttInnuuo ehtre:cning but try to do at lease 3 ti.ne% par day. ' Pdcne c1.: In a weer s. :.mp „ ., ?y + wrldr -ni Progress Notes STEPHEN M. BECKER MD 91 SOUTH HIGH STREET Progress Notes STEPhEtlM.SE r l SOUTH HIGH SCKER TREETO Accounta hEVNILLE,PAtn_, ?i (-,Progress Notes S7EPHEdd(.SECKEriM1ID 91 SOUTH HIeH STHSeT Name , ?L( Account 0 NE'MILLE, PA i0 Carlisle Hospi,a. DEPARTS 'OF RADIOLOGY and Health Services 246 Parker Slreel • P.O. Box 310 • Carlisle, Pennsylvania 17013-0310 • (717) 249-1212 CARLISLE IMAGING ASSOCIATES, P.C. HOLTRY, BETHANY 27Y 11/18/1998 361 SAW MILL RD. X-RAY #90872 NEWVILLE „ PA 17241 MED. REC. #280416 DR. BECKER, S. MRI OF THE RIGHT SHOULDER The MRI examination of the right shoulder was performed in the oblique coronal, axial and sagittal planes of imaging. This examination shows the supraspinatus tendon appears intact. No signal abnormality is seen within the tendon or rotator cuff to suggest the presence of tear or tendonitis. There is no evidence of impingement. No signal abnormality is seen within the humerus or scapular glenoid. The soft tissues are unremarkable. IMPRESSION: Normal MRI examination of the right shoulder. RIGHT SHOULDER The views of the right shoulder in two projections show no fracture or other acute osseous abnormality. No destructive or erosive bony changes are seen. The soft tissues appear normal. IMPRESSION: Normal radiographic examination of the right shoulder. , 1 KEITH S. PUMROY, M.D. KSP/mn T: 11/18/1998 02:31 pm c;- 'I I CI-A 7;FHYSICi,s.Al ATTENDING PHYSICIAN'S REPORT Date Policvholder Date of Accident File Number 01-20-99 Beth Holtry 03-05-98 1553022946 PLEASE NOTE: THE ATTENDING PHYSICIAN SHOULD COMPLETE THIS REPORT AND RETURN IT DIRECTLY TO: Theresa Salinger Allstate Insurance Company 6345 Flank Dr., Suite 1000 Harrisburg, PA 17112 1. Patient's Name and Address 2. Age 3:7 3. Sex F 4. Occupation (I,' known) 5. History of Occurrence as Described by Patient RE q/' zit ?e?f (?? lly1,?jl 0,7 3/ S/-I CY 4?-- , F- A-,A - C-Gr? 6. Diagnosis, Diagnosis Cordes, and current or contributing Conditions" &%'' SCo 7 e'Gk7 /t.r6 ?l gibs 7. When Did Symptoms First.,Appear? 1 Date: 31st /ld- C,;{r'?-ute77{a?t?J 9. Has Patient Had Same or Similar Conditions? YES O (circle one) If "YES", state when and describe' 8. When Did Patient First Consult You for this Condition? Date: 2 1 U//q'y- 10. Is dition Solely a Result of This Accident? -O (circle one) If "NO", Explain" 11. Is Co n Due to Sickness or Injury Arising Out of Patient's Employment? YES (circle one) Llas ?T ?? Ji,?,f ]?. Will Injury Result in Permanent Disfigurement or Disability? ub`nt PrL'hle-sn S 5/?jr{ YES / NO (circle c-e) If "YES", Describe` I' ?yrid uc'c,?viT ,+e,:,.,i•„may Q?,?c'c? 13. Patient Was Disable (Unable to Workl 14. If Still Disabled. Date Patient Should Be ?t From: Through: Able to Return to Work: `'rn IsYatient Still Under Your Care for This Condition? ?e`TSt,ys. ES NO (circle one) Estimated Future Charges S L ?cC/r /?' CS L Carlisle Hospit-A) DEPARTN OF RADIOLOGY and Health Services 246 Parker Street • P.O. Box 310 • Carlisle, Pennsylvania 17013-0310 • (717) 249-1212 CARLISLE IMAGING ASSOCIATES, P.C. HOLTRY, BETHANY 27Y 11/18/1998 361 SAW MILL RD. X-RAY #90872 NEWVILLE „ PA 17241 MED. REC. #280416 DR. BECKER, S. MRI OF THE RIGHT SHOULDER The MRI examination of the right shoulder was performed in the oblique coronal, axial and sagittal planes of imaging. This examination shows the supraspinatus tendon appears intact. No signal abnormality is seen within the tendon or rotator cuff to suggest the presence of tear or tendonitis. There is no evidence of impingement. No signal abnormality is seen within the humerus or scapular glenoid. The soft tissues are unremarkable. IMPRESSION: Normal MRI examination of the right shoulder. RIGHT SHOULDER The views of the right shoulder in two projections show no fracture or other acute osseous abnormality. No destructive or erosive bony changes are seen. The soft tissues appear normal. IMPRESSION: Normal radiographic examination of the right shoulder. KEITH S. PUMROY, M.D. KSP/mn T: 11/18/1998 02:31 pm U CHARTPHYSICIAN !cphen M. Becker, Al. 0. Listing 06 comment-6 60r Beth Hoetry Page: 4 lI-25-98 Code Date Comment ---- -------- ----------------------------------------------------------=- hc9-po,,t.tive smb/tjt 02-26-97 --- ------------- CC-Sinus Sub- Has been sick -since Sunday with head congazz.ion. Nasal con9es.tion, PND and bad tact in the back 0(, .the mouth. In the moaning and at night the zecnetiortz a-te yeetowi.sh. Obj- 110160 p64 97.3 129# r12 1IEENT-yeCeow -secnezCons in the right nozt tit; tendcnness to pcncu-scion oven the night maxiteaay sinus Neck-nad Lungs-dear Asses-Sinusitis pCan-Augmentin 500 bid bon 7 days PUT .smb 11-04-97 Dischanye zumma.ay.... team pregnancy, detivened ruchat coed times two 26 yo G-01001 Dceivery 06 a 3300 gram 6emate in6anz with Apgaa.s 06 8 and 9 In Gant was Rh positive and .the mother is Rh negative and received RhoGAM in postpartum smb/tj e 03-06-98 ============================-=======-- --- CC-Auto accident Sub- At about 8 AM ycatzaday .she was d•a.Lv.4n9 he,, Chevy cavatien when she was ;car ended at a atop .sLgn. Had -aea.t beatt on. No airbag-s. Ate she knows L-s that hcn seat went back and down. Does• not remember hitting he•i hear. No Loose 06 conciousnezs. Had some 3orene.i-s in her neck night a6ter the accident and that was wons2 this AM. Went to tile EP. yc-sterday at 10:30 and sf,,e was g.Lven 6texoxie and toed shc had a neck strain. Had some pain oven the night tower rib cage thatwa-s 6irst noticed this AM. Obj- 100/70 p68 144# rig Tenderriesa o6 the right ste4nocZcdomastoLd and the ttLght upper trap and night papa ccrvicae mu-scCes Tend,-.ancss oven the 6eoat4ny .tib-s anterLoaty on the ¢i9ht Asses-Ceavicae s.traLn Contused ,tabs pear-PT .c6cn•aaZ died dens ccrvicae coCCar FCexonie HS Recheck one week PUT srrb 03-13-98 - ------ ------- ------ CC-MVA ephen M. Beclaen, hl. D. Pace: 5 LL-sting 06 comments (,or Seth. HoeYny 1I-25-98 Code Date Comment ---- -------- ----------------------------------------------------------=-_ _ Sub- The pain is basicaZty in flee night shoLZdca anea. The rib anea is not -soic now. Has been to PT 3 times taet week. Iz abCe to get away without the co.CEar. Obi StiCC with -some tenderness in the night uppee stennocZedomasto.id and the -tight t•cap and rhomboids. DTR's .sum Asses-Impnovcd p.Can-Continue the PT Recheck in I week. Hu.s continued with wank. PUI smb 03-20-98 CC-CeavicaRlz .strain Sub- Was 6i tng yes.teaday and she acaeCy huntz today. Ha-3 2 move PT app.t next week. Obj- 118180 pi00 97.1 143# nl2 Stile with some tenderness in the uppers z¢ap, RsL and the n.Lght a.tennocCedamasio.id FROM in .the neck with pain when she f,.Cexcz to the Cc6t DTR's sym Aeaes-Cenv.Lca4 -strain plan-Continue PT and ;tactchtng Recheck in 2 weeks PUI smb 04-03-98 ----------- --------------- CC-Cenvicatla strain s/p 14UA Sub- Thenc are days it .i-s bettc, and days that it is Uine. Has been abour_ 4 weclzs Obj- 118/72 . 1430 Some tenderness in the upper trap biCatena.CCy and the rhomboids. OTR's sym Sen.soay intact Anse-s-Ceavicae ot¢ain pCan-Recheck in 2 week-s Continue the -stretching and use L.schemic compnes,lion ove•1 the rhomboids. PUI 'Mb 04-24-93 ----- -------------------------------------------- CC-Ce¢vicae -sttairl Sub- The neck pain had been on a;,d 066 unt.iC it aained on Sunday and since then it has been sane. Plot nea•tey as bad ad it had becll. Sllz lz,IJW-s %t. i s rilc ze but -- ha,-, not Izcpt hen 6a0m doing thing,. On Wednesday .sltc had some t.ingLing in her night hand wltiee she was wni--ulc. It Carted 60,1 5-10 -seconds. Has not Lcturrzcd. Woriz-makes phone ca.U., sits i,l (-aon.t 06 a computers and • , crizcn M. Bcckcn, AI, 0, Listuz9 oG comments Ga,z Beth NuC.t•zy Page: 6 Code Date Cummcnt 11-25-95 ------------ ------------------- ------------- 6 ice,3, ---- Obj- Neck-tend eanees Gz oche nhomboid-s-minimaC -stcrnucCcdomasto.id-s-Ole u{, neck UPPe-z taap wttlz spa..m and te.ndc-xncsa towands base musctc.s -some tendc,znc,s irz the night Paaa ccav.iCae Can 4Ccx tl:c ncciz nonmaCCy, Sl:uu2de,va-nad .la-scs-CcnVieaC -;t.za.trz %mpnovtn9 P4an-Cont+nuc the d s#nctch{n9 but .tny #o du at Ceao# 5 times pea ay, Recheck trz 4 week-s. ,smb 05-22-9a _ CC=CenvLcae s#,in Sub- aI 1s0/2oinc Obj- a% P3.i nor .Tatr1.LR[ src {q 0 p$$ 93. E J 1 3EN n StiC.C with Some upper l' . t%ap mu-scCe tenderness Asses-Ce,zvCcaC strain c.s.scntiaCCy ncsoEved and ctca.7,jZu bc.ttca Plan-Corztinue the stretches arid recheck pnrz PUZ ,n; b STUHEN M. EECKER MID Progress Notes , - ; 91 SOUTH HIGH STREET (?, t NE'NVILLJPA1 41 Name 1 7?f 1 1 I???? Account # / - jo- J" .1. G . / '/ V-M A 1 D wr HT n, CAN^ ?rti irk - tit, /3a R P i l (? fi- 0-1 ewpar-.,tt. id ? c hP'tl'oi- cv Progress Notes Vol SOUTH HIGH STprzp oarE 'I I BP T q 7 72?l c Cie /1??CJ t rw131? o, : J 11 DATE BP _ _ . q (A? l? ltd ?Lt DATE 9 1a4 - ?? _ CCw -emu - P R ??h- ) T7Jf? Snvr L • d-? /c l? ./, ? 1/?r?? , ZPI f"I Progress Notes Cc.: WT 161 " ' C- c _ IUD `?. ?°, Stephen M. Becker, M.D. 91 South High Street H MA Newville, PA 17241 (717) 776-4495 Beth Holtry Service Rendered: 03-06-98 361 Saw Mill Road - Newvil.le, PA 1.7241 - Pat. S$ #: 185-66-7132 DOB: 0-1/14/71 Patient #: 00839 Family Balance Prior To This Visit Was: 0.00 Diagnoses: 1) 847.0 Cervical Sprain 2) 924.8 contusions (multiple sites) Procedure Dia.7. Code Description FOS PC 4 Amount ----- ----------------------------------------------------- -- --- ---- ------- 99213 E=.tab Patient E/M, level 12 55.00 Total This Visit: 55.00 Plus Prior Balarr-e: 0.00 New Family Belaince- ----55.00 Insurance coverage remaining: 0.00 Doctor's-SiOnatUre (If Feciuired For In_urance) TIN #: 59-2951'"=00 Li-k: nse #: NE1041146S!LL. I! i. U, le. er. Hi-oh Street PA 17241 776-4495 Service Rendered. PA 11241 `.•° 3: 185-66-7132 DOB: 03/14/71 Family Balance Prior To This Visit !Ja=.: 1! 347.0 Cervical Sprain °. t eoh,::•, N S'1 South Newvill (717) ctl'i HO 1. L•r% >! _at+ h1ill road .,.aa Dc=cription --- ----------------------------- F.=tat: patient E/M, level 3 cover'aor r,emaininn: 0.00 55.00 1 Diaej POS Rerr' it Am'_,i.u-;!- --------------------- --- 3 1 55.00 Total This Visit: 55.00 Plus Prior Balance: 55.01- New Family Balance: -- 110. 01-' r ----------------------------------------------- Doctor's Signature (If Regr.rired For Insurance) TIN #: 59-2052200 License #; MD04.3469L Stephen M. Becker, M.D ° 91 South High Streets +.6 Newville, PA 17241 Beth Holtry (717) 776-4495 361 Saw Mill Road Service Rendered: 03-20-9 Newville, PA 17241 Pat. SS #: 185-66-7132 DOB: 03/14/71 Patient #: 00839 Diagnoses: Family Balance Prior To This visit was: 1) 847.0 Cervical Sprain Procedure Code Description Diag ----- --------------------- 99213 Estab --------------------- POS Ref# patient E/M, level 3 ------- 3 ---- 1 Total This visit: Plus Prior Balance: Insurance coverage remaining: 0.00 New Family Balance: 55.0, -Amoun 55.0f 55.0, 55.0 110.0 ----------------------------------------------- Doctor's Signature (If Required For Insurance) TIN #: 59-2952200 License #: MD043469L u_ .I'D 91 South High Street Newville, PA 17241 (717) 776-4495 Beth Holtry 361 Saw Mill Road Newville, PA 17241 Pat. SS 185-66-7132 DOB: 03/14/71 Patient 00839 P IA Service Rendered: 04-24-98 Diagnoses: Family Balance Prior To This Visit Was: 0.00 1) 847.0 Cervical Sprain Procedure Diag Code Description POS Ref# Amount ----- ------------------------------------ - ------------------ --- ---- ------- 99213 Estab patient E/M, level 3 3 1 55.00 Total This Visit: 55.00 Plus Prior Balance: 0.00 Insurance coverage remaining: 0.00 New Family Balance: 55.00 ----------------------------------------------- Doctor's Signature (If Required For Insurance) TIN #: 59-2952200 License #: MD043469L wi Stephen M: Becker, M.D_ 91 South Hioh 'Street Newville, PA 17241 (717) 776-4495 .....r. Holtry Service Rendered: 05-22- ?.c.- 4aw Mill Road lr, PA 17241 N: 185-66-7132 DOB: 03/14/71 00839 Family Balance Prior To This Visit Was: ??. 7.0 C.:rvical Sprain ?rt•c?-?ure• Diag ::ode Description POS Ref# ----- ------------------------------------------------------- --- ---- 4)9213 Estab Patient E/M, level 3 3 1 Total This Visit: Plus Prior Balance: .:..??.,•:.:•:ce coverage remaining: 0.00 New Family Balance: Amou. 55.[ 0.L 55 L ---------------------------------------------- Doctor's Signature (If Required For Insurance! TIN #: 59-2952200 License #: MD0436.69L Stephcrt M. Pcclzca. M. 0. Page: I ScCeotcd Ind ividuaQ Patlela Hidt0.ty 12-08.793 Patient #00539 Peth Hoetny Famt1fu P,aCanc:c 55.00 361 Saw ,MUZ Road NewvLZZc. PA 1,72,11 Date Name POS Da T an3ac t L:n; P-c'=-cdu.t Dcbit c4c.di.t ----------- 10-13-933 Pc.tlt -- - 3------------------------------ E,. _ti9 pat.ien : E/;! SS. UO Stephen M. V.-,I.D. 91 South Hly:, otreat Hewville, PA 17241 (717) 776-4495 Bath Holtry 361 SaN Mill.Aoad Service Aandtr:a: 1•?-27-9c NeNville, PA 17241 Pat. SS 1: 185-66-7132 008: 03/14/71 Patient 1: 00839 Family Balance Pricr To 75i;;;;;; ,,.,. Diagnoses: 1) 847.0 Cervical Sprain Procedure Coda Description - .. 95213 EStaD patient E/M, love) 3 Insurance coverage remaining: total this Pius Prior E........ 0.00 lie. Fa0117 G-!oir.:•. ..:': :.:v 30 2 &2 ? J ................................ . Doctor's Sigmture (Ii Aecaiaa , :. TIH 4: 59-29622D0 t•. I 1 Saw Mitt Road ., PA 17241 33 P: 155-66-7132 • 00339 Se.%vice Rendened: it-1G-d5 Stephen M. Beeken;: M. D,-w 91..'South'High Sticeet Neuiv.Lk.2e, ,'1;(l ''. . (7171 776`= 4495`-724 DOB: 03114171 j Family BaCance Pxion To Thi4 Viait Wa.s: ;i 347.0 Cenvicat Spaain i _ 719.31 Pain, ahoutden joint ctduae Dezc.z.iption D.tay ---- ------------------------------------------------------- --- ---- j .:. _ E.s.tab patient E/M, .level 3 3 12 .5 Total Thi.e Visa it: Ptu-s Pnio? Batancc: ::.. 00 New FamiRy Batance: t .._ I ar:ce coverage remaining: 0. iss30?o?Qy? 1Q` ``? Co ?? a? /5S7 ?i ' ------ ---------------------------------- Doctor'.e Signature (I6 Requ.ined For In.au)Lar,.ce; TIN #: 59-2952200 Licen.ae #: MD043469L i Patient #00839 Date 11-16-98 .'tephen M. Becker, M.D. Page: 1 Sele. A Individual Patient Hist _y 04-13-99 Beth Holtry Family Balance 41.00 361 Saw Mill Road Newville, PA 17241 Name POS Dr Transaction/Procedure Debit Credit ----------- --- -- ------------------------------ -------- ------ Beth 3 1 99213 Estab patient E/M, 55.00 _._. `ephen M. Becker, M.D. Page: 1 1 11 Sele, .,d Individual Patient Hist -y 04-13-99 Patient #00839 Beth Holtry Family Balance 41.00 361 Saw Mill Road _ Newville, PA 17241 = Date Name POS Dr Transaction/ Procedure Debit Credit -------- ----------- --- -- ------------- ----------------- -------- ------ 02-01-99 Beth 3 1 99213 Estab patient Eft 56.00 Patient #00839 -•,'tephen M. Becker, M.D. Page: 1 Sele? .d Individual Patient Hist-y 04-13-99 Beth Holtry Family Balance 41.00 361 Saw Mill Road Newville, PA 17241 Date -------- Name -------- POS --- --- Dr -- Transaction/ Procedure ------ Debit Credit 02-17-99 Beth 3 1 ------------ _---- 99213 Estab Patient E/M, -------- ------ 56.00 El PAK e".,, I 1, - monarte OUR NO. MA9 CARLISLE HOSPITAL -- 246 PARKER ST CARLISLE, PA 170130000 23-2141105 ,030598^030598 717-249-6676 4336509 3 ,- ( HOLTRY, BETHANY M _ 361 SAW MILL RD_ NEWVI LLE, PA 17241 --- - --7'-'--'T ,rhl -t. ?: H-? ?- LL 03141971 IF M 030598 10 7 11 O1 X280416 _ U.1YrlK( n D3V'f [ ..G ..h\•tC 9 OCC.... K( T r ' '?, MV LL 0 ( CC° G L (Sf(Sf C 2 C(%I t Lpy_ Jr( .M _ I ? I Rl' MARS All-V- - M-- SAW MILL RD 361 NEWVILLE, PA 17241 ---------____- ...- I _ nv_., n__ ozvn i_nuvn.'c ______ .a.ar•.':n 1 r ? 450 EMERGENCY ROOM I '•r •^•+ '..mccwroo.cs In _ .. °.w.i _ 1' 13.00 001 TOTAL CHARGES 13.00 in..rtn a.nvs.w ?iid-?fiiy..?(..•.^-\•a ASS es-.wxhr r-x ALLSTATE INSURANCE 23-2141105 YY BLUE CROSS 366 390058 YI DUE FROM PATIENI M9PL'IavN: a°rrC. yCSP'41\..L.]\C ?a'b'L.-'4K dh1UXKELL`IV• HOLTRY, BETHANY 011,6 28261557 0911 HOLTRY, MARSHALL V 02 QAC211627876 026803005 - \'M1nCY4'LV L°Fl4 4LSL?[M:."[n \.Vr rs 1-.w vry M (n I i E 1IKEEN LEASING INC Plv:: tL LC.TLL a Ornq y:.n aCRY ttCr r)L-Yr?r Ir COY??C.nZ CYO ' A< - ---- T ??L'\'V LAi C•(ICRYY - A 8470 L ' ? !7231 ?E812 0 -__- -_ - GIIAR IND ANTHONY RAC N.? ?L+:.nkG(=,( LeY nK;C(JJl G < Jnn4C - e L 03/19/98 75°'°^^'°--____ -I x --- -? UBA2 MCFA. 1450 -Tun n o-¢(ora..fr4 G (.r+(vw[.rn•.o ••A nu.onE.nu rm ro(or 0 PB .1.1 i Number 43 36509 Nrv Chg. Qty 450 27020 1 ZO1 01600 1 CO1 05270 -1 ** End of List ** ENTER Continue F2 Credit Notes CARLISLE HOSPITAL P a IENT MASTER INQUIR Y 11/20/98 CHARGES Name HOLTRY, BETHANY M Amt Due Amount 13.00 Date Bat Reference 030598 .00 Description FC 98 -12.06 PHO 041498 C34 AAUTOALLST CONVENIENT CARE LEVEL 0365 9-8 -.94 0416S18 Z66 ALLSTATE INSURANCE O/P A . PA 041598 UTO INSURANCE AD 041698 N F3 Nxt Patient Insur Estmts S F Chg Inquiry Fl Charges 4 Znsur Plans F5 Stmt Data r w xe [amozm CARLISLE HOSPITAL 'n'mTav ar u' 246 PARKER ST 33 509 1 1.31 CARLISLE, PA 110130000 "? ?r -° .x== 1=.= 717-249-6676 23-2141105 030598 030598 HOLTRY BETHANY M _ 361 SAW MILL RD NEWVILLE, PA 17241 .1M'-NYII 'a%?'IIW NY.I Sryi 1 nNR ['..f AWC TJ.II D.1 AVLIY .eNOrf. S• .'gT•IC` [. it Y 15 n 030598 1971 F (_O i10 11 ,01 2.80416 ___ y u rs art cu wn s???[ sex Grt Nw urt orx uyw . rv, nwnr 0OI 3 0598 t II Z RY-FfA SA I „° W -lam ~? ? 361 SAW MILL RD w,x , , NEWVILLE, PA 17241 I L .i Rim Iy.YSJ?'rt,. +.TS .ayN ?.[ I.a%W W'f i al'[R4 fa•4Yl! I.. a(TgTa[YFMf(f 450 EMERGENCY ROOM 11 13.00 001 TOTAL CHARGES i 13.00 t ? •.rtx rna¢n w .v.m,y I I ?r.rvcwa 1 i ner.ranry[ m ALLS TATE INSURANCE 23-2 141105 Y Y BLUE CROSS 366 3900 58 11 Y I Y C:'9DUEFROM: PATlENT mwa,cav«t I mrvc mani.aw.ccv aavuart vxaw\c trcv? HOLTRY, BETHANY 1 011 6 28261557 0911 HOLTRY, MARSHALL V 02 QAC211627876 I 026803005 mmu'acw wnov.•a.cws "[x m[..v^.rnx.v[ meaa,nrtn.rc.-a 1'COWLES 1 KEEN LEASING INC !IM\ e.fI LD SKP..y na t )e A'N' (19 IIF?L I. e 8470 7231 E8120 R.= rt e .. n = ". Ke OS007155L I I I I ACINQ ANTHONY KCE " 12 m:Rx???G2 ? C¢E nr2L[? G'E U C'+FT MS U I I 03/19/98 75 = ^^?_ OMCRY. ?A\i.M UG'[ X .a n n [ . [ a a 1 n 0--,A 9 PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DR. CARLISLE, PA 17013 (717) 240-0330 FED TAX ID# 76-0430771 RONALD D. GREENWAY, P.T. BETH HOLTRY 361 SAWMILL ROAD NEWVILLE i STATEMENT PATIENT: INJURED: PHYSICIAN: PA 17241 ID NO: EMPLOYER: DATE: 04105199 BETH HOLTRY 03/05/98 STEPHEN BECKER, M.D. CLM01553022946 TRAFCON INDUSTRIES 81 TEXACO ROAD MECHANICSBURG PA 17055 ACCT 102322 l V RG DIAGNOSIS: CERVICALGIA - 723.1 SPRAIN/STRAIN, NECK - 847.0 DATE DESCRIPTION -------------------------------------------------------- BALANCE FORWARD 03110198 EVALUATION; COMPREHENSIVE - NEW PATIENT 03110198 HOT PACK - NO CHARGE 03110198 ELECTRIC STIMULATION; UNATTENDED 03110198 ULTRASOUND 03110198 e2ectaode-e (.6upptie4) 03/10/98 MASSAGE 03110198 EDU. PAMPHLETS/BOOKLETS 03/11/98 ELECTRIC STIMULATION; UNATTENDED 03111198 ULTRASOUND 03111198 MASSAGE 03112198 A titate. Ile bitted 346.00 Uoa 03/10-03/11/8 03112198 HOT PACK - NO CHARGE 03112198 ELECTRIC STIMULATION; UNATTENDED 03112198 ULTRASOUND 03112198 MASSAGE 03117198 HOT PACK - NO CHARGE 03/17/98 ELECTRIC STIMULATION; UNATTENDED 03/17/98 ULTRASOUND 03/17/98 MASSAGE 03118198 HOT PACK - NO CHARGE 03118198 ELECTRIC STIMULATION; UNATTENDED 03118198 ULTRASOUND 03118198 MASSAGE 03119198 AU-4tate In-6 bitted 267.00 Uo4 03112-0311818 03123198 HOT PACK - NO CHARGE 03123198 ELECTRIC STIMULATION; UNATTENDED 03123198 ULTRASOUND 03123198 MASSAGE 03126198 AUtatate In-d bitted 89.00 Uoa 03123-0312318 03130198 ALLSTATE pd.$131.85 FOR 03112-0311818 03130198 ALLSTATE pd.$210.75 FOR 03/10-03/11/8 -------------------------------- ----------------------- CONTINUED ON NEXT PAGE CHARGES ---------- PAID -- ADJUSTS BALANCE ------ ---------- -------- 0.00 150.00; 108.45; -41.55; 0.00 25.00; 14.64; -10.36; 0.00 31.00; 12.09; -18.91; 0.00 15.00; 12.00; -3.00; 0.00 33.00, 17.22, -15.78; 0.00 3.00; 2.40; -0.60; 0.00 25.00; 14.64, -10.36; 0.00 31.00, 12.09; -18.91; 0.00 33.00; 17.22; -15.78; 0.00 25.00, 14.64; -10.36; 0.00 31.00; 12.09, -18.91; 0.00 33.00; 17.22; -15.78; 0.00 25.00; 14.64, -10.36; 0.00 31.00; 12.09; -18.91; 0.00 33.00; 17.22, -15.78; 0.00 25.00: 14.64; -10.36; 0.00 31.00; 12.09: -18.91: 0.00 33.00: 17.22: -15.78: 0.00 25.00: 14.64: -10.36: 0.00 31.001 12.09: -18.91: 0.00 33.00; 17.221 -15.78: 0.00 ---------- --------- --------- -------- PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DR. CARLISLE, PA 17013 (717) 240-0330 FED TAX IDN 76-0430771 RONALD D. GREENWAY, P. T. STATEMENT DATE: 04105199 BETH HOLTRY PATIENT: BETH HOLTRY 36 1 SAWMILL ROAD 61 SAWMILL 3 INJURED: 03105198 NEWVILLE PA 17241 PHYSICIAN: STEPHEN B-CKER, M.D. ID NO: CLMN15530 22946 EMPLOYER: TRAFCON INDUSTRIES 81 TEXACO ROAD ACCT 102322 1 V RG DIAGNOSIS: CERVICALGIA - 723.1 MECIfANICSBURG PA 17055 SPRAIN/STRAIN, NECK - 84 7.0 DATE DESCRIPTION ---------------------------- CHARGES ------ PAID ADJUSTS BALANCE BALANCE FORWARD 0 3130198 Contnactuae W&tte- 0,%.$135.15 FOR 03112-0311818 ------ ; --------- ---------- , 0 ---- _00 03130198 ca-$135.25 FOR 03/10-03/11/8 PA 03/30/98 HO C NO CHARGE 03130198 ELECTRIC STIMULATION; UNATTENDED ; 03130198 ULTRASOUND 25.00, 14.64, -10.36; 0.00 03130198 MASSAGE 31.00; 12.09; -18.91; 0.00 03130198 ThenapeuLic Activities 33.00' 17.22; -15.78; 0.00 04/01/98 HOT PACK - NO CHARGE 52.00 23.05; -28.95; 0.00 04101198 ELECTRIC STIMULATION; UNATTENDED 04101198 Thehapeu tLc Activi tLes ; 25.00; 14.64; -10.36; 0.00 04102198 A Zatate In,s bZUed 218.00 {ion 03130-0410118 52.00; ; 23.05,' -28.95,' 0.00 04120198 ALLSTATE pd.$104.69 FOR 03130-0410118 04120198 Cont4aciuat White- ".$113.31 FOR 03130-0410118 ; 04120198 ALLSTATE pd.$43.95 FOR 03123-0312318 0 4120198 Contnactuat WALte- cJL.$45.05 FOR 03123-0312318 ; 10115198 10/15/98 HOTLPACKON NOOCHARGENSIVE - NEW PATIENT 150.00 62.94; -87.06,' 0.00 10115198 ELECTRIC STIMULATION; UNATTENDED ' 10115198 ULTRASOUND ; 25.00, 14.64; -10.36,' 0.00 10115198 THERAPEUTIC PROCEDURE 31.00,' 12.09, -18.91, 0.00 10/20/98 HOT PACK - NO CHARGE 52.00 21.91,' -30.09,' 0.00 10120198 ELECTRIC STIMULATION; UNATTENDED ' 10120198 ULTRASOUND 25.00, 14.64,' -10.36,' 0.00 10122198 Attztate Iris bZUed 314.00 Uon 10/15-10/20/8 31.00; 12.09,' -18.91; 0.00 10122198 HOT PACK - NO CHARGE ; 10122198 ELECTRIC STIMULATION; UNATTENDED 10122198 ULTRASOUND ,' 25.00,' 14.64,' -10.36,' 0.00 10123198 ELECTRIC STIMULATION; UNATTENDED 31.00,' 12.091 -18.91,' 0.00 10123198 ULTRASOUND i 25.00,' 14.64,' -10.36,' 0.00 10129198 AU-4tate In.s bZUed 112.00 6o,% 10122-1012318 11112198 31.00 12.09 -18.91 0.00 BETH HOLTRY B.iUed 0.00 60z 10/15-10/29/8 ' -------------------------- CONTINUED ON NEXT PAGE -------- ---- --------- ---------- ------ , rr " PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DR.' CARLISLE, PA 17013 (717) 240-0330 FED TAX ID# 76-0430771 RONALD D. GREENWAY, P.T. BETH HOLTRY 361 SAWMILL ROAD NEWVILLE PA 17241 STATEMENT PATIENT: INJURED: PHYSICIAN: ID NO: EMPLOYER: ACCT 102322 1 V RG DIAGNOSIS: CERVICALGIA - 723.1 SPRAIN/STRAIN, NECK - 847.0 DATE: 04105199 BETH HOLTRY 03/05/98 STEPHEN BECKER, M.D. CLM#1553022946 TRAFCON INDUSTRIES 81 TEXACO ROAD MECHANICSBURG PA 17055 DATE ------ DESCRIPTION ------------------------------------------------- -- CHARGES ------ PAID ADJUSTS BALANCE BALANCE FORWARD ---- -------- ---------- ; -------- 0 00 11112198 BETH HOLTRY Bitted 0.00 {ion. 10/15-11/12/8 . 11124198 BETH HOLTRY Bitted 0.00 boa 03/10-11/12/8 1 ; 1 11127198 ALLSTATE INSURANCE pd.$53.46 FOR 10122-1012318 11127198 Cuntnactia. Wlti.te- cc.$58.54 FOR 10122-1012318 ; 11130198 ALLSTATE pd.$138.31 FOR 10/15-10/20/8 11130198 Contnactvat. Wni,te- cA.$175.69 FOR 10/15-10/20/8 ; 11130198 RE-EVALUATION; ESTABLISHED PATIENT 85.00; 62.76; -22.24, 0 00 11130198 HOT PACK - NO CHARGE 1 1 , . 11130198 ELECTRIC STIMULATION; UNATTENDED 25.00; 1 14.641 -10 36; 0 00 11130198 11130198 ULTRASOUND etectnodea (.&Lpptie.3) 1 31.001 12.091 . -18.911 . 0.00 11130198 Therapeutic Activ.iti.ea 1 1 15.001 52.001 12.001 23.051 -3.001 -28 951 0.00 0 00 12102198 HOT PACK - NO CHARGE . . 12102198 ELECTRIC STIMULATION; UNATTENDED 1 25.00; 14.641 -10 361 0 00 12102198 12/02/98 ULTRASOUND Therapeutic Acti v it Cea 31 .00 1 12.09, . -18.91, . 0.00 12102198 . . . AZ2atate Ina bitted 316.00 bon. 11/30-12/02/8 1 1 52 .00; 23 .05, 1 -28.95, 1 0.00 12104198 ELECTRIC STIMULATION; UNATTENDED 1 25.001 14.641 1 1 -10 361 0 00 12104198 12104198 ULTRASOUND Therapeutic Activittea ; 31.001 12.091 . -18.911 . 0.00 12107198 HOT PACK - NO CHARGE 1 52.001 1 23.05; -28.951 0.00 12107198 ELECTRIC STIMULATION; UNATTENDED 1 25.00 11 14.641 , -10 36 ' 0 00 12/07/98 12107198 ULTRASOUND Therapeutic Acti v i t e 4 ; 31.00, 12.091 09, . , -18.97, . 0.00 12109198 . , - HOT PACK - NO CHARGE 1 52.001 1 23.051 1 -28.951 0.00 12109198 ELECTRIC STIMULATION; UNATTENDED ; 1 25.001 1 14.641 , -10 361 0 00 12109198 12109198 ULTRASOUND Therapeutic ActLv it Lea ; 31.001 12.09; . -18.911 . 0.00 12110198 . . AZZata.te Ina bitted 324.00 bon 12104-1210918 ; 1 52.00; ; 23.05; -28.951 1 0.00 12111198 HOT PACK - NO CHARGE 1 1 ', ; 12111198 --------- ELECTRIC STIMULATION; UNATTENDED ------------------------ 1 ; 25.001 14.641 -10.36; 0.00 CONTINUED -------------- ----------- ON NEXT PAGE -- ---------- -------- ---------- ------- PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DR. CARLISLE, PA 17013 (7171 240-0330 FED TAX ID# 76-0430771 _ RONALD D. GREENWAY, A.T. STATEMENT DATE: 04105199 BETH HOLTRY PATIENT: BETH HOLTRY 1 SAWMILL ROAD INJURED: 03105198 36 361 SAWM PHYSICIAN: STEPHEN BECKER, M.D. NEWVILLE PA 17241 ID NO: CLM#1553022946 EMPLOYER: TRAFCON INDUSTRIES 81 TEXACO ROAD ACCT 102322 1 V RG DIAGNOSIS: CERVICALGIA - 723.1 MECHANICSBURG PA 17055 SPRAIN/STRAIN, NECK - 847.0 DATE ---------------DESCRIPTION -------------- ---------- --- -CHARGES PAID ADJUSTS BALANCE BALANCE FORWARD 12111198 ULTRASOUND ? ------ 11 --------- 11 ---------- 1 --- 0 _00 12111198 ThenaPattis Activities 31.00,' 12.09,1 1 -18.91; 0.00 12114198 Therapeutic Activities 104.00% 46.09; -57.91; 0.00 12116198 HOT PACK - NO CHARGE 104.00; 46.09, -57.91; 0.00 12116198 ELECTRIC STIMULATION; UNATTENDED 12116198 ULTRASOUND 25.00; 14.64! -10.36; 0.00 12116198 Therapeutic Activities i 31.001 12.09; -18.91,1 0.00 12117198 Attztate I" bitted 424.00 ¢04 12/11-12/16/8 ; 104.00; 46.09; -57.91; 0.00 12118198 HOT PACK - NO CHARGE 12118198 ELECTRIC STIMULATION; UNATTENDED 12118198 ULTRASOUND i , 25.00; 14.64; -10.36; 0.00 12118198 The4apeutic Acti.v.iti ee i 31.00 12.09; -18.91; 0.00 . 12121198 ALLSTATE pd.$149.34 FOR 12104-1210918 104-00; 46.09 -57.91; 0.00 12121198 Cont4actuaQ W&ite- c-%.$174.66 FOR 12104-1210918 1 2121198 ALLS TATE INS pd.$174.32 FOR 11/30-12/02/8 12121198 Contnactuat W4ite- c % 68 $141 ; , . . FOR 11/30-12/02/8 12121198 HOT PACK - NO CHARGE 12121198 ELECTRIC STIMULATION; UNATTENDED 12 25 00; 1 6 ' 121198 ULTRASOUND . . 4; -10.36 0.00 12121198 The4apeutic Activities i 31.00; 2 12.09; -18.91; 0.00 12123198 HOT PACK - NO CHARGE 104.00 46.09; -57.91; 0.00 12123198 ELECTRIC STIMULATION; UNATTENDED 12/23/98 ULTRASOUND i 25.00; 14.64; -10.36; 0.00 12123198 The4apeutic Activities 31.001 12.09, -18.91; 0.00 12124198 Attztate Irrs bitted 480.00 6o,% 12/18-12/23/8 104.00, 46.09; -57.91; 0.00 12128198 HOT PACK - NO CHARGE ; 12128198 ELECTRIC STIMULATION; UNATTENDED ; 25 00; 14 ' 12128198 ULTRASOUND . .64; -10.36 0.00 12128198 Therapeutic Activi.ti" 31 .001 12.09; -18.91; 0.00 12129198 HOT PACK - NO CHARGE 1 04 .001 46.091 -57.911 0.00 12129198 ELECTRIC STIMULATION; UNATTENDED ------- ; 11 25.00; 11 14 64; 11 -10 --------- ----------------------------- . .36; 0.00 -------- CONTINUED ON NEXT PAGE --- --------- --------- ---------- ----- - PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DR. CARLISLE, PA 17013 (717) 240-0330 FED TAX IDN 76-0430771 RONALD D. GREENWAY, P.T. BETH HOLTRY 361 SAWMILL ROAD NEWVILLE STATEMENT PATIENT: INJURED: PHYSICIAN: PA 17241 ID NO: EMPLOYER: ACCT 102322 1 V RG DIAGNOSIS: CERVICALGIA - 723.1 SPRAIN/STRAIN, NECK - 847.0 DATE DESCRIPTION BALANCE FORWARD 12129198 ULTRASOUND 12/29/98 The%apeutti.c ActLv.it.ie,4 12131198 A.ECatate In.4 bitted 320.00 6o4 12128-1212918 01112199 BETH HOLTRY Bitted 0.00 Uon 10/23-12/31/8 01125199 ALLSTATE pd.$191.73 FOR 12/11-12/16/8 01125199 ContAactua2 WA,ite- CA.$232.27 FOR 12/11-12/16/8 01/25/99 ALLSTATE INS pd.$218.46 FOR 12/18-12/23/8 01125199 ContAactuat W4ite- cA.$261.54 FOR 12/18-12/23/8 01/25/99 ALLSTATE INS pd.$145.64 FOR 12128-1212918 01/25/99 ContAactuat Wnite- cA.$174.36 FOR 12128-1212918 02102199 *EVALUATION; COMPREHENSIVE - NEW PATIENT 02102199 *ULTRASOUND 02102199 *MASSAGE 02102199 *THERAPEUTIC PROCEDURE 02104199 AU-6tate In.a bitted 266.00 444 02102-0210219 02104199 *HOT PACK - NO CHARGE 02104199 *ULTRASOUND 02104199 *MASSAGE 02105199 *HOT PACK - NO CHARGE 02105199 *ELECTRIC STIMULATION; UNATTENDED 02/05/99 *ULTRASOUND 02/05/99 *MASSAGE 02108199 *HOT PACK - NO CHARGE 02108199 *ULTRASOUND 02108199 *MASSAGE 02110199 *HOT PACK - NO CHARGE 02110199 *ULTRASOUND 02110199 *MASSAGE 02111199 A.¢X.etate I" bitted 281.00 6o4 02104-0211019 02112199 *HOT PACK - NO CHARGE 02112199 *ULTRASOUND DATE: 04/05/99 BETH HOLTRY 03/05/98 STEPHEN BECKER, M.D. CLMN1553022946 TRAFCON INDUSTRIES 81 TEXACO ROAD MECHANICSBURG PA 17055 CHARGES --------- PAID -- ADJUSTS BALANCE ------ 11 ---------- 11 -------- 31.00; 12.09; -18.91; 0.00 104.00; 46.09; -57.91; 0.00 150.00; 62.76; -87.24; 0.00 31.00; 12.09; -18.91; 0.00 33.00; 17.22; -15.78; 0.00 52.00; 21.91; -30.09, 0.00 31.00; 12.09; -18.91; 0.00 33.00; 17.22; -15.78; 0.00 25.00; 14.64; -10.36; 0.00 31.00; 12.09; -18.91; 0.00 33.00; 17.22; -15.78; 0.00 31.00, 12.09; -18.91, 0.00 33.00; 17.22; -15.78; 0.00 31.00, 12.09, -18.91, 0.00 33.00; 17.22; -15.78; 0.00 31.00; 12.09; -18.91; 0.00 CONTINUED ON NEXT PAGE l? it I i 1 I J. PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DR. CARLISLE, PA 17013 (717) 240-0330 FED TAX ID# 76-0430771 RONALD D. GREENWAY, P.T. BETH HOLTRY 361 SAWMILL ROAD NEWVILLE PA 17241 ACCT 102322 1 V RG DIAGNOSIS: CERVICALGIA - 723.1 SPRAIN/STRAIN, NECK - 847.0 DATE DESCRIPTION -------------------------------------------------------- BALANCE FORWARD 02112199 *MASSAGE 02118199 Att tote In.4 b.LQRed 64.00 bon 02/ 12-0211219 03102199 ALLSTATE pd.$113.98 FOR 02102-0210219 03102199 Cont4actuaQ Waite- cn.$152.02 FOR 02102-0210219 03104199 ALLSTATE pd.$29.31 FOR 02112-0211219 03104199 ContAactua2 W4ite- c-.%.$34.69 FOR 02112-0211219 03104199 ALLSTATE pd.$131.88 FOR 02104-0211019 03104199 Contnactuae. Waite- c-&.$149.12 FOR 02104-0211019 -------------------------------------------- `? STATEMENT DATE: 04105199 PATIENT: BETH HOLTRY INJURED: 03105198 PHYSICIAN: STEPHEN BECKER, M.D. ID NO: CLM#1553022946 EMPLOYER: TRAFCON INDUSTRIES 81 TEXACO ROAD MECHANICSBURG PA 17055 CHARGES PAID ADJUSTS BALANCE ------------------------------------- 1 i 11 0.00 33.00; 17.22; -15.78; 0.00 r r , , , , r r ------------------------------------- CURRENT OVER 30 OVER 60 OVER 90 OVERT120LS 3821PLEASE8PAy67 -1983.33 0.00 0.00 0.00 0.00 0.00 0.00 ,"-, rAdu WLES Enthusiast btedia Absence Report Location: P Cowles Enthusiast Media 0 Cowles Creative Publishing 0 Rowhunter 0 Cowles History Group 0 Cumberland Publishing 0 Horse 8 Rider 0 Retail Vision 0 Southwest Art 0 Vegetarian Times O Walking Inc. 0 Other Name _e? L- ?11 IG 1 I t t I Employee Department F-1 rla s\(- c First Date Absent r L, ,-r 6 Return Date Mn r ch e1 Ig? Reason Hours Reason Hours 0 Sick 0 Jury Duty 0 Vacation Q Leave Without Pay 0 Personal Day 0 Other 0 Funeral Leave TOTAL H3,35 Uo,,"IW1 Iq hrs) Prepared by rr_ n IiAnfj-Tj Date - c Approved by?i Date C/AS> While-Depatlment Pink-Employee WAGE AND SALARY VERIFICATION I hereby authorize you, to furnish all information you have in your possession regarding my employment, since my hire. This form authorizes you to release the following information to my attorneys, Handler and Wiener, and I further request that you NOT give such information to anyone else without a signed authorization from me. Date ? :l I? 1 \- r ,, . Employee's SIi'gnatur) 1. Employee's Name 2L,i1Y,nyn')•1-? ,14-( Social Security No. 2. Employer's Name and Address ot-I CAS i- ICU'1k C?C ;.,Z 3. Job Title A (_ LG ??c c \ c \T ?- 4. Dates of Employment: From: -?? ry Qr to (p -? r; If no longer employed, reason for leaving 5. Wages or salary as of accident date: S lbzoglyper JCIf Hours per day _ Hours per week -J_ - c - List wages from the 2 years preceding the accident 6. Dates absent following accident: From ?% t?" through rtT? (a) If not consecutive, list dates absent 7. List any dates in the above, that are for reasons other than injuries sustained in this accident. - 8. Has employee filed claim for benefits under any worker's compensation or similar law as a result of this accident? Yes No ? If applicable, Name and Address of Worker's Compensation Carrier: Policy I Claim Number - Date completed: ?j'?2 Gi Signed: Title: Phone: 'cri v'I-s N" t: 001200 COMMONWEALTHOFPENNSYLVANIA ?..TI POLICE ACCIDENT REPORT VERLAYSIEETS REPORTABLE NON REPORTABLEQ LICE,INFORMATION 20.000N,Y A- -'-_`-Q_/S_ --- -'-- - ..ii:MUUN PAtn S.1u771..1_+liOdc?J-oM?- I. PATROL /? ZONE PRINCIPAL ROADWi .?Jj/ /,f[ ??Z ? BADGE- - •2 .? _ _ _.. -?___ '/n _ 72. STREE NO .-- NVIAGER STREET NNAE_T ? / &4j ----BADGE 77. SPEED - 14. E NUMBER SE4L? -. _-LIMB .?s •__, , MIGIM'AV -8. ARRIVAL --' - INTERSECT s+ re TIME 1717 10. ROUTE NO.OR---'-- -___ ACCIDENTeINFORMATION STREET NAME III. DAY OF WEEK 27. SPEED 10.]TYFE J1 S??S /90 7(L LIMIT HIGHWAY NUUOER ti L*, O Pao . OF UNITS 3 _ A.t WJUREO _. 15. PROP. N 64 T Y 70. CROS SEGM _ ACCIDEN REC IT. OIREC ;LE HAVE TO BE I7.VENICLEOAMA E FROM FROMTHESCENET U 0•NOIIC tNT1 12-1 73DISTA q: UNIT 1 2. MODERATE I - y N _ 7-SEVERE UNIT2 2I t7,,' uS "ZONE -I l]S?TRAFFIC - CONTROL DEVICE UNIT iF7 . ..._......_...,... .. - - 1 ]0 S A1fj Y Y N 77. REG. //.1 00 Y N ]L REO. 70. LEGALLY LEGALLY 700 „,PLATE ' 7 O 39.PATITLEOR '/ •? p STATEVIN ? /? 37 A E VIN VV .yL/ - - OUT•OF• _7.. 40,OWNER ?l It. ADDLES - 7/ AGGRESS SIATC RATE ' 7 12. CITY, //,/ &ZIPCOOE /j/f"(11GC-'c"/_`1__1' / C-/JY.E--,?. .. DOE O: YEAR/ q 44 MAKE L7 aJ<G.INS. SIT C? I Y t NI I UIIKi I +S.Madci?foi ,_-oOOr.TYPc) G117.(/?c/f6e-j ?9. iPEL1A1 IB -?- B.S CIAL 19,:VEIIICLE / O ., 47IROGY 'I USAGE - USAGE U OWNEI751111` TRAVEL E I5i '-' . TYPE p( SI] SOIINITIAL imPALT ?1 . SLIVEMICL y,?/ i51'EEG ? ? STATUS 4 itI , / E IE .IGRNER PRESENCE / -IPRESEIILE CONDITION ' 'S7 bill AI{? ?? ? GRADIENT SG. NUMBL UMER ?s.z y y 75 7 OZ R?T . ....---'- 6RIVER R / AME SB. N SF? /lGOcft_./#._S'Q R ESS - ADURE 59. DRIVER __.. ' 7L C. AOURESS -- - -° - -- STATE - ? 60 A E .OITY. STL ?. 811P000E !7 _ ! _ f -- G]. Pt .{IE ODE ,62.OATE OF ---- - C F I62.OATE OF BIRTH i - OIRTII 11. 65.ORNER mt?65 EVEN. 65.OflNEfl : t1?C I U ER IER ER r IER ESS _.. 'ESS .._ S7ATE STATE 7% ICC 0 'PUC COOE T P ICL t _7aVWR G 77JCARGO ? _ ._ _._._._17JLMG0 '- CONFIG BODV TYPE -- ?- IlODY TYP 'I0. E __, OF IIAiiiA 7F 76 MAZ APE 71. RELEASE Y 0140 ' T ]6.RO OF - ?7G?HAZ AROOUS MATERWLS _ !!LT S _ PAGE. i1N5) 2176424 3 L 4, . 001201 zk\ COMMONWEALTH OF PENNSYLVANIA tlrF 9 ?? POLICE ACCIDENT REPORT Q REPORTABLE NON•REPORTABLE %A.REFEflTOOVERLAYSXEETS BI '' INFCRMATIONlt' fr!:':'+ 4!' °;'"'ACGpElJt 1, INCIDENT r 20 COUNTY :. NUMBER. G LAOENCY 21. MUNICIPALITY u f " TA7 "E 4.PATRD1. PRINCIPAL ROADWAY INFORMATION" S A • . PRECINCT C ? ZONE ;2 ,.. T BADUE 22. ROUTE NO. OR 1 0. HIVE NUMBER 7 74 STREET NAME BY r 0.APPROVED BADGE 27. SPEED N. TYPE S.AC INTROL; HIGHWAY CONTR. " NUMBER LIMIT - 7.INVEgTIpATgN B. ARRIVAL .12 2 S INTERSECTING ROAD: •, DATE - TIME ' . 26. ROUTE NO OR t .' ?INFOAMATIGN yy IG F , . STREET NAME _ , r { • ? 10. DAY OF WEED p j ' "•:'• Y ,i71 27. LIM TD 6. TYPE . CONTROL HIGHWAY CONTR DATE 4• . I TIME of ? .[ I 12. NUMBER 7.-., IF NOT AT INTERSECTION Y aJ. j I o 10.1 eu I on rtJ T6 P INJURE% OF UNITS 15. PRIV. PROP. ACCIDENT Y ? N r1 70. CROSS STREET OR Tl SEGMENT MARKER '• A, ?y 71. DIRECTION 72. DISTANCE •:rR J• N S E W FROM SITE IL D0 VEKW NAV E TO BE REMOVED 7. VEHICLE DAMAGE UNIT Y3 FROM SITE • pr FHdITHE SCEyE7 UNIT2 " 0•"ONE 1•LIGHT 77 DISTANCE WAS MEASURED ? ESTIMATED ? "`.'!?It' yF ' UNRt..SS • MODERATE UCTI0N 75 TRAFFIC PRINCIPAL •.UIJER6E 4 k [3 r- 'Y N,9 Y? N? 7•SEVERE Ut11T2 ? 7<CONSTR ZONE CONTROL ':?I• VICE U 1 Str 1 Z 10. ? Sb ? B. PENNDOT PROPERTY Y El I? N LJ ? DE T ` I MARI AI xJ?, N Y ° , ,. a *' t UNI ".?. T M43 . 7B. STRTE!G? A. OWNER 422 ADDRESS ?t?•?,, ACRY. STATE Fete;' BZIPCOpE G/RPC/JC /"/] i7?/.? YEAH N. MANE A'd t %6 INS O Utll {! ; IiT7 59. DRIVER DflIVER SV. AOGPESS AOGRESS 60. CITY. STATE B0. CRY, STATE r , r(?/? d ZIPCOOE ? -- r 8 ZIPCODE DATE OF 62 _ - 7 T•6 BORE 61. SEX 82. DATE OF 67. PHONE . 61. SEA F BIRTH 7 ff 5 ?J/?? SIRT11 u r.MU VEH. 65. DRIVER . Ifi6 DRIVER 61. COt.BA.VE11 I* 0llUET O6. q s. fig. CITY-STATE B2. CITY, STATE A ZIPCOOE 'f.J ? 6ZIPCOOE -- --""i0 VSO07 - 70. USUOT • ICC • PI IC 4%J VEH. 7 CARGO Td GL'YjR T`2 '/EH. - $ CONFIG ODY TYPE ___,-, CO4FIG_ {+ "? 75. NO OF 6 HAZARDOUS RR):A511Q? IA 7eKAI- 75 NO OF ti• AXLES MATERIALS In uu U t= M45111621 - 112 4 3 42 PAGE F H EE ffQq ELI UNK i1GHWAY SAFETY ; ?, -im 717 234 6239 NOV-16-2001 10 39 AFWHREDLER YESCO L` 717 234 6239 P.01 i ?? t d??y. Harrisburg 931SauthlilhStreet•(717)233-1621•Far(717) 233.1626 l ? York 915 \. George Street • (717) 843.9991 - Fax (717) 843-7123 O Lancaster 1291:v1arilteimPike •(117397-3101•Fax (717)397-5833 bu on;7n"a 0 Carlisle 452 Saudi MlenRoad •(717)2.19.0600•Fax(717)233.1626 ?/ ? Williamsport 3301 WahooDri % e•(570)321-0410•Fax(370)321-0520 www.sydist.com Toll Free 1-800.998.1621 Fax Cover Sheet Total number of page(s): o? To: - sc.ni:L I# L n i Q 'q Company: HQncUe.r Iknnmq_ Rb&-n" Fax: 0 '4-1$Da Comments: We re.c e, ?? ehy-01) T-LCo- Date: I I - I (o-D I From: ?') COLS 2015e,c Extension: -A a6,27 Tuff Grip Fish Tapes are now 20% Longer Offered in 60 ft., 120 ft., and 240 ft. lengths • A great advantage for those longer pulls - 20% more means each reel lasts longer • Non-slip handle and fingertip grooves provide sure grip and added handling comfort • Durable, impact-resistant case for the most rugged job-site conditions cataloEt c5 31-055 - 60 ft. 31-055 - 120 ft. - 31.057 - 240 ft. or Electrical Supplies, Lighting Supplies, Industrial Automation, and DataComm Networking 1LZ' y r -' NOU -1 6- 200 1 10:39 SCHAE DLER YESCO w - O 9 J O x x . I ? O. T U O n. v •n rv N x ? Y , ?" Cl l ?D 7 O ? .n w yr . n N' x 0' r ? I + h• Y G z x u w ? ? I r V, ? W M ? I m ? z x w 4 x I z ? w x I U p e3? ... i O Q? m a ^? o ? G? M w c2 I e rv u n? I j , ?n bT '? I O r u r ? M s 4 r I rn N I? x O W C O.' ?' U o I o o v rv W x¢ : a C 2 OQ V O C O U ? O 00 00 N n L ^ N N1. '. ?Y•T ?. N O N P NG _ ,. . '-., .., V E a o ' 0 0 o rv aVii ? o o rv o a C O o w m n n n N ?. O O C C O -, O O O U O Z .-. V P W ? c n r e N r + N ? n ti r v, r a w 717 234 6239 P.02 O P O m H tD rr Ln m Q' ui m O ? ti CD a rv C, O - „p; xy, II' `w TOTAL P.02 Q.(4L IN. A (".1 L,...t OATH In The Court of Common Pleas of Cumberland County, Pennsylvania No. 79 , C-1JL/ 19 We do solemnly swear (or affirm) that we will support, the Constitution of the United States and the Constitution wealth and that we will discharge the duties of our off ce fidelity. C' AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) .3 cv u i .. w Ct k3, n J applicable.) Date of Hearing: Ir d Date of Award: Arbitrat NOTICE OF ti7TRY OF AWARD Now, shed'//-?day of Ja?- <--'z Y b9Jin.?, at: /a award was entered upon the docket an notice thereof given by mail parties or their attornevs. Arbitrators' compensation to be paid upon appeal: obey and defend of this-Common- the above to the J. PjLcctL - Ll uL r) - .JiJV 2u../r?9- v? yam.. I. AS OF ia-19 CASE# i qqq - ? 7)- 4 HAS BEEN SCANNED. ALL EARLIER FILINGS TO THIS CASE HAVE BEEN MICROFILMED. W. Scott Henning, Esquire I.D.#32298 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiff Fax : (717) 233-3029 E-mail: Henning@HHRLaw.com BETHANY M. HOLTRY and MARSHALL V. HOLTRY, Plaintiffs V. TERRI L. ROWE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 1999-6724 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAEC/PE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please mark the above captioned matter settled and discontinued. HANDLER HENNING & ROSENBERG, LLP Date: /a - /. 0 4 By - t00 W. Scott He'rmt(g, fffiui Attorney I.D. #32298 1300 Linglestown Road/ Harrisburg, PA 17110 (717) 238-2000 ATTORNEY FOR PLAINTIFF 1?, ?f C?,J t.._l -TI Cr'"+