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HomeMy WebLinkAbout99-07527c SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-07527 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SOBOTOR SUSAN VS ONOMASTICO ANTHONY J R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: ONOMASTICO ANTHONY J but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within WRIT OF SUMMONS On January 6th , 2000 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: So Lans e? Docketing 18.00 Out of County 9.00>??? , ?lh Surcharge 8.00 R /'Thomas Kline Dep. Dauphin Co 27.22 Sheriff of Cumberland County .00 62.22 01/06/2000 HANDLER, HENNING & ROSENBERG Sworn and subscribed to before me this day of ?? / ?ppJ A.D. // Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 1999-07527 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN SOBOTOR SUSAN VS ONOMASTICO ANTHONY J THEODORE L KONCSOL Deputy Sheriff of FRANKLIN County, Pensylvania, who being duly sworn according to law, says, the within SUMMONS was served upon ONOMASTICO ANTHONY J the DEFENDANT , at 0830:00 Hour, on the 29th day of December , 1999 at 5075 LINCOLN WAY EAST FAYETTEVILLE, PA 17222 by handing to ANTHONY J ONOMASTICO-SHERIFF'S OFFICE a true and attested copy of SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Ans s: Docketing 9.00 pl Service 9.00 Affidavit 4.00 Surcharge .00 By Mileage 5.22 epu y eri ?r 12/29[1999 CUMBERLAND COUNTY SHERIFF Sworn and Subscribed to before me It 29TH day Of DECEMBER C_ /I 1 o ar NOTARIAL SEAL PATRICIA A. STRINE. Notary Public Chambersburg. Franklin County M Commis9ion Expires Nov. <. 2000 In The Court of Common Pleas of Cumberland County, Pennsylvania Susan Sobotor VS. Anthony J. Onomastic() No99-7527 Civil Now, 12/17/99 _,19 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to - a and made known to copy of the original the contents thereof. So answers, Sheriff of Sworn and subscribed before me this _ day of , 19 19_, at o'clock M. served the County, PA COSTS SERVICE $ MILEAGE AFFIDAVIT i I Plaintiffs Arbitration Memorandum Plaintiffs: Counsel for Plaintiff: Defendant: Counsel for Defendant: Susan Sobotor Gregory M. Feather, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road P.O. Box 1177 Harrisburg, PA 17110 Anthony Onomastico Matthew R. Gover, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17110 jc ilarb itrati o nlsobotocwpd I 4 t I, Background Information At the time of the collision, Plaintiff, Susan Sobotor, was a 43 year-old female who resided in Highspire, Pennsylvania. She was employed at PennDot as an Administrative Assistant. II. Summary of Collision On or about December??, 1997, at approximately 3:18 p.m., Plaintiff, Susan Sobotor, was traveling slowly through the parking lot of the Camp Hill Shopping Mall near the Boscov's Department Store in Cumberland County. At approximately that same time and place. Defendant, Anthony Onomastico, failed to observe Plaintiff's vehicle directly in his path. Suddenly and without warning, Defendant, Anthony Onomastico, slammed into the rear-end of Plaintiffs vehicle.. 111. Issue of Liability The issue of liability in this matter is clear. The collision described herein was directly and proximately caused by the negligence and recklessness of Defendant, Anthony Onomastico. Liability has been admitted by the Defendant. IV. Medical Treatment and Iniuries Shortly after the collision, Plaintiff, Susan Sobotor, began experiencing pain in her neck and her back. She also had complaints of ongoing pains in her shoulders down to and through her hands, decreased range of motion, and acute emotional and psychological turmoil. All of Plaintiffs medical records associated with this collision have been submitted. Additionally, a treatment summary indicating the date services were provided, the name of the provider, and the type of treatment is attached. It is Plaintiff's position that these injuries were caused by the collision that took place on December??, 1997. 1 .I The paramount rule in assessing damages is that every person unjustly deprived o flier rights should at least be fully compensated for the injuries she sustains. The primary [unction of compensatory damages is to shift the loss from an innocent party to one who is at fault. Spangler v. Helm's Netiv York-Piti.rbtrrgh fbfoior E.Ypress, 393 Pa. 482 (1959); Esmond v. Liscia. 209 Pa.Super. 200 (1966). Respectfully Submitted, By; DATE: I 0 ?&ry M. Peathec_F( 1 No. 79456 1300 Linglestown Road PO Box 1177 Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiff SUSAN SOBOTOR, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-7527 : CIVIL ACTION - AT LAW ANTHONY J. ONOMASTICO, DEFENDANT JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Susan Sobotor, and her attorney, Gregory M. Feather, Esquire Handler, henning & Rosenberg 319 Market Street P.O. Box 1177 Harrisburg, PA 17108 YOU ARE HEREBY NOTIFIED, that the Answer to Complaint set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Respectfully submitted, NEALON & GOVER By Ma thew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 Date: 07/18/00 (717) 232-9900 SUSAN SOBOTOR, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7527 CIVIL ACTION - AT LAW ANTHONY J. ONOMASTICO, DEFENDANT JURY TRIAL DEMANDED ANSWER WITH NEW MATTER AND NOW, comes the Defendant, Anthony J. Onomastico, by and through his attorneys, NEALON & GOVER, P.C„ and files the following Answer: 1. Admitted. 2. Denied. To the contrary, the Defendant resides at 142 Riddle Road, #2, Chambersburg, Franklin County, Pennsylvania 17201. 1-7. Denied pursuant to Pa.R.Civ.P. 1029(e). 8.-11. Denied. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. 12. Denied pursuant to Pa.R.Civ.P. 1029(e). 11-19. Denied. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. WHEREFORE, Anthony J. Onomastico, respectfully requests that the Complaint be dismissed with costs of this action. NEW MATTER 20. Paragraphs 1 through 19 of Defendant's Answer are incorporated herein by reference thereto. 21. Plaintiffs claims may be barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Anthony J. Onomastico, respectfully requests that the Complaint be dismissed with costs of this action. Respectfully submitted, NEALON & GOVER z-21 ( cc Matthew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Date: Harrisburg, PA 17108-0865 (717) 232-9900 VERIFICATION I, Anthony J. Onomastico, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. CERTIFICATE OF SERVICE AND NOW, this 18th day of July, 2000, 1 hereby certify that I have served the foregoing Answer with New Matter on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Gregory M. Feather, Esquire HANDLER, HENNING & ROSENBERG 319 Market Street P.O. Box 1177 Harrisburg, PA 17108 *Matth Esquire SUSAN E. SOBOTOR, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ANTHONY J. ONOMASTICO, No. 99-7527 Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Susan E. Sobotor, by and through her attorneys, HANDLER, HENNING, & ROSENBERG, by Gregory M. Feather, Esquire, and makes within Complaint against the Defendant, Anthony J. Onomastico, as follows: 1. Plaintiff, Susan E. Sobotor, is an adult individual currently residing at 229 Cherry Street, Highspire, Dauphin County, Pennsylvania 17034. 2. Defendant, Anthony J. Onomastico, is an adult individual currently residing at 5075 Lincoln Way East, P.O. Box 122, Fayetteville, Cumberland County, Pennsylvania, 17222. 3. At all times material hereto, Plaintiff, Susan E. Sobotor, was the owner and operator of a 1986 Nissan Sentra, Pennsylvania Reg. AAL9616 (hereinafter "Plaintiff's vehicle"). 4. At all times material hereto, Defendant, Anthony J. Onomastico, was the owner and operator of a 1995 Honda Accord (hereinafter "Defendant's vehicle"). 5. On or about, December 22, 1997, at approximately 3:18 p.m., the Plaintiff's vehicle was traveling slowly in the parking lot of the Camp Hill Shopping Mall near Boscov's Department Store, Camp Hill, Cumberland County, Pennsylvania. 6. On or about, December 22, 1997, at approximately 3:18 p.m., Defendant's vehicle was traveling in the parking lot of the Camp Hill Shopping Mall near Boscov's Department Store, Camp Hill, Cumberland County, Pennsylvania. 7. At approximately that same time and place, Defendant failed to observe the Plaintiff's vehicle directly ahead of his vehicle. Suddenly and without warning, Defendant hit the roar-end of Plaintiff's vehicle and a violent collision resulted. 8. The oforomentioned collision caused extensive property damage and was so severe that Plaintiff, Susan E. Sobotor, required medical attention. 9. Prior to the collision, State Farm Mutual Insurance Company, issued a policy of automobile Insurance to the owner of the vehicle driven by Plaintiff, Susan E. Sobotor. This policy was in effect on December 22, 1997, the date of the collision. 10, The Insurance policy elected the full tort option as enumerated in the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. § 1701 (a) (1) (A), qt sou, as amended. 11, As a direct and proximate result of the negligence of the Defendant, Plaintiff, Susan E. Sobotor, sustained extensive injuries as set forth more specifically below. 12. The occurrence of the aforementioned collision and all the resultant injuries to Plaintiff, Susan E. Sobotor, are the direct and proximate cause of 2 negligence, carelessness, and/or recklessness of the Defendant, Anthony J. Onomastico, generally and more specifically as set forth below: (e) In failing to be reasonably vigilant to observe position of Plaintiff's vehicle or the roadway; (f) In failing to operate his vehicle in such a manner that would allow him to apply the brakes and stop before striking Plaintiff's vehicle; (g) In failing to operate his vehicle under proper and adequate control so that he could have avoided striking Plaintiff's vehicle; (h) In failing to operate his vehicle at a speed at which he could stop within the assured clear distance ahead, in violation of 75 Pa. C.S.A. § 3361; (1) In failing to drive at a safe speed when special hazards exist with respect to pedestrians and other traffic, in violation of 75 Pa.C.S.A. § 3361; (j) In failing to maintain proper and adequate observation of the existing traffic conditions; (k) In failing to keep a proper lookout for vehicles lawfully in the parking lot of the Camp Hill Shopping Mall; (U In failing to exercise reasonable care in the operation and control of his vehicle, in violation of 75 Pa.C.S.A. § 3714; (m) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have his 3 vehicle under such control that injury to persons or property could be avoided; and (n) In driving his vehicle upon the highway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 13. As a direct and proximate result of the negligence of the Defendant, Plaintiff, Susan E. Sobotor, has suffered extensive and serious personal injuries, including, but not limited to, a severe injury to her neck and back, ongoing pains in her shoulders down to and through her arms and hands, decreased range of movement, and acute emotional and psychological turmoil. 14. As a result of the Defendant's negligence, Plaintiff, Susan E. Sobotor, has suffered lost wages and will in the future continue to suffer a loss of income and/or loss of earning capacity. 15. As a result of the Defendant's negligence, Plaintiff, Susan E. Sobotor, has suffered great physical pain, discomfort, and mental anguish, and she will continue to endure the same for an indefinite period of time in the future, to her great physical, emotional, and financial detriment and loss. 16. As a result of the Defendant's negligence, Plaintiff, Susan E. Sobotor, has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her great detriment and loss. 4 18. As a result of Defendant's negligence, Plaintiff, Susan E. Sobotor, has been, and probably will in the future be, hindered from attending to her daily duties, to her great detriment, loss, humiliation, and embarrassment. 19. Plaintiff, Susan E. Sobotor, believes and, therefore, avers that his injuries are permanent in nature. WHEREFORE, Plaintiff, Susan E. Sobotor, seeks damages from Defendant, Anthony J. Onomastico, in an amount in excess of Twenty-Five Thousand Dollars ($25,000.00), exclusive of interests and costs, which is in excess of jurisdictional amounts requiring compulsory arbitration. Respectfully Submitted, HENNING & DATE: (? d By I.[[6/No. 79456 319 Market Street P 0 Box 1177 Harrisburg, PA 17108-1177 (717) 238-2000 Attorney for Plaintiff 5 VERIFICATION 1, Susan Sobotor, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: L . a a . ciz) Susan Sobotor I CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of a Complaint upon counsel of record on this gal day of 2000, by placing the same in the U.S. first class mail, postage prepaid at Harrisburg, Pennsylvania addressed as follows: Matthew R. Gover, Esquire Nealon and Gover 301 Market Street - 9th Floor Harrisburg, PA 17108-0865 Respectfully submitted, HANDLER, HENNING & ROSEN Date: & - D D -crz) G rylM. Feather, Esquire D o. 79456 19 Market Street P.O. Box 1177 Harrisburg, PA 17108 (717) 238-2000 Attorney for Plaintiff SUSAN E. SOBOTOR, Plaintiff V. ANTHONY J. ONOMASTICO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 99-7527 RULE 1312.1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Gregory M. Feather, Esquire, of Handler, Henning & Rosenberg, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is $15,000.00. The counterclaim of the defendant in the action is N/A The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: Gregory M. Feather, Esquire, Handler, Henning & Rosenberg, P.O. Box 1177, Harrisburg, PA 17108 and Matthew Gover, Esquire, Nealon and Gover, 2411 North Front Street, Harrisburg, PA 17110. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. ORDER OF COURT AND N_ OWWI, 2001, actio sideration of the fore oing petition, _4 - .?v quire _ . s_Esquir e, and s,Zsquire, are appointed arbit tors in thabove-ca n ass-prayed for. By tl?q Court, el^ J. P -. i Harrisburg, PA 17108 (717) 238-2000 Attorney for Plaintiff O! !. fI .J ::: .7?!;Q SUSAN S013o'rm I'laintil7, ANTIMONY ONOMASTICO. Defendant IN THE COURT OF COMMON I'LEAS CUM13ERLAND COUNTY. PENNSYLVANIA NO. 99-7527 CIVIL ACTION - LAW JURY TRIAL DEMAND CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of Petition for Appointment of Arbitrators to Defendant, Anthony J. Onomastico upon counsel of record on this a n?4 day of / , 200Q1 by placing the same in the U.S. first class mail, postage prepaid at Harrisburg, Pennsylvania addressed as follows: Matthew R. Gover, Esquire Nealon and Gover 301 Market Street - 91h Floor Harrisburg, PA 17108-0865 Respectfully submitted, HANDLER, HENNING & ROS Date: By: Grego M. Feather, Esquin (I.D. No. 79456 1300 Linglestown Road P.O. Box 1177 Harrisburg, PA 17110-1177 (717) 238-2000 Attorney for Plaintiff SUSAN E. SOBOTOR, Plaintiff V. ANTHONY J. ONOMASTICO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-7527 CIVIL CIVIL ACTION - LAW NOTICE OF HEARING BY BOARD OF ARBITRATORS You are hereby notified that the Board of Arbitrators appointed by the Court in the above captioned case will sit for the purpose of their appointment on Wednesday, October 3, 2001 at 9:00 a.m. in the Hearing Room, 2nd Floor of the Old Cumberland County Courthouse, Carlisle, Pennsylvania. Dale F. Shughart, Jr., Esquire Gregory H. Knight,, Esquire Barry Kronntohal, P.q i e `/ By: P Dale F. Shughart, r., Chairman Board of Arbitrators DATE: July 9, 2001 TO: Gregory M. Feather, Esquire 1300 Linglestown Road P. O. Box 1177 Harrisburg, PA 17110-1177 Matthew R. Gover, Esquire 2411 North Front Street Harrisburg, PA 17110 Gregory H. Knight, Esquire 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 Barry Kronthal, Esquire 3510 Trindle Road Camp Hill, PA 17011 Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 SUSAN SOBOTOR, PLAINTIFF V. ANTHONY J. ONOMASTICO, DEFENDANT TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7527 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED PRAECIPE Please enter the undersigned's appearance on behalf of the Defendant, Anthony J. Onomastico, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER By: A ?/?_ Matthew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 S/ i,1Do Harrisburg, PA 17108-0865 Date: (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 19`h day of May, 2000, 1 hereby certify that I have served the foregoing Praecipe on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Gregory M. Feather, Esquire HANDLER, HENNING & ROSENBERG 319 Market Street P.O. Box 1177 Harrisburg, PA 17108 41 e,7j? All, Matthew R. Gover, Esquire SUSAN SOBOTOR, PLAINTIFF V. ANTHONY J. ONOMASTICO, DEFENDANT TO THE PROTHONOTARY: 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7527 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED PRAECIPE Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Date: 05/19/00 TO THE PLAINTIFF: Respectfully submitted, NEALON & GOVER By: ?V11 Matt ew R. Gover, Esquire Attorney I.D. #47593 301 Market Street-- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 Ruf A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED: /'&ay aZai acUO C P othonotary SUSAN SOBOTOR, : IN THE COURT OF COMMON PLEAS 3de1 Q, e-cc.1 S-}rettPlaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. y q - 75 a'7 ANTHONY J. ONOMASTICO, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue the Writ of Summons against the following Defendant and have the Sheriff of Cumberland County deputize the Sheriff of Franklin County and have the Sheriff of Franklin County serve the Writ: ? Mr. Anthony J. Onomastico 5075 Lincoln Way East P. 0. Box 122 Fayetteville, PA 17222 Respectfully submitted, HANDLER, HENNING & ROSENBERG Date: / 7- - By: Gr of M. Bather, Esquire Supreme Court ID No. 79456 319 Market Street P.O. Box 1177 Harrisburg, PA 17108-1177 (717) 238-2000 Attorney for Plaintiff Commonwealth of Pennsylvania County of Cumberland Susan Sobotor 229 Cherry St. Highspire, PA 17034 VS. Anthony J. Onomastico 5075 Lincoln Way East P. 0. Box 122 Fayetteville, PA 17222 Court of Common Pleas Vo. __99.-7527_-_-_Civ l_Texm---_-_ !9x In ___CJ•.Yil_ACtinn.-=--La-w---------------- To ---Anthony__J-_Onomasticn You are hereby notified that _-_____-__-Susan Sobotor the Plaintiff ha scommenced an action in __--C.inil-Lasz_______________________________________ against you which you are required to defend or a default judgment may be entered against you. (SEAL) ------- gS1Itlx_R__._-L9Jlg---------------------- Prothonotary pp aa__ Date ------ --------- 19__25 By ---?1Jlzs? _a-. 61-) ------------ ) Deputy s z N O 41 N U N N r M iJ ( ] .{ o ul r E m a + S H< j r N OUl W > O c(V N aJ ri .1 .1 0 ? ° p m a o > UI O1 -H ?•'I CQ UJ 4 a c a +J C U N O yJ m . C moN N of tn iJ r >y :J N•.i CO NNx <LO W G%i a w w z i W El) 3i 0 G w N ••• I C i U . 2 +J J z w ww U; M < i >? ao G b, U i z 0) x 0 UNTIFFS KHIBITS 3. __ u N 'C d ? n E 'u E ? U COMMUNITY MEDICAL ASSOCIATES, P.C. 3601 North Progress Avenue 36 South River Road Harrisburg, PA 17110 Halifax, PA 17032 Tel (717) 652-7266 Tel (717) 896-3901 4' 's`° Pier (717) 657-9734 Rm (717) 896-2705 May 29, 2001 Gregory M. Feather, Esq. 1300 Linglestown Road Harrisburg, Pa. 17110 Re: Susan Sobotor Dear Mr. Feather, I last saw Mrs. Sobotor for her neck injury in 1998. She is at the Hershey Pain Management Center for treatment. There is no new update here since my last letter sent to you on November 10, 1999. Sincerely,, }' / c_.-C/(?, Gunhilde M. Beck, M.D. GMB/ds ?aY 31200 ?gpi:lV?p ''I I TELEPHONE (717) 652-7266 FAX (717) 657-9734 601 NORTH PROGRESS AVENUE • HARRISBURG, PENNSYLVANIA 17110 March 6, 2000 Gregory M. Feather, Esq. Handler, Henning & Rosenberg 319 Market Street Harrisburg, PA 17108 Re: Our Letter Dated 11110199 Regarding Susan Sobotor Dear Mr. Feather: Please be advised that our letter dated November 10, 1999 regarding your client, Susan Sobotor, contained an incorrect date. Ms. Sobotor was first seen in our office on January 23, 1998, not January 23, 1999 as indicated in our letter. We are sorry for the error and hope this has not inconvenienced you or your client in any way. If you have any questions or we can be of any further help, please feel free to call. SincerelA69-- Gunhilde , Beck, M.U. NOV 1 5 1999 fiecti CD 3601 NORTH PROGRESS AVENUE TELEPHONE (717) 652-7266 FAX (717) 657-9734 HARRISBURG, PENNSYLVANIA 17110 November 10, 1999 Gregory M. Feather, Esquire Handler, Henning & Rosenberg 319 Market Street Harrisburg, PA 17108 Re: Susan Sobotor Dear Mr. Feather: Ms. Sobotor was involved in a motor vehicle accident on December 22,1997. She was fast seen in our office on January 23, 1999. Ms. Sobotor was the driver of the car that was rear-ended. She was wearing her seat belt at the time. Most of her problems began two days after the accident with pain, stiffness (neck and back), and numbness of the right hand. The diagnosis was cervical strain secondary to the motor vehicle accident. Ms. Sobotor's care was taken over by Dr. Peppehnan, Orthope Rehabilitation die Surgeon, and Dr. Wood, Specialist. Ms. Sobotor's neck pain never resolved, and she is currently still in treatment for chronic pain. As part of her treatment, Ms. Sobotor has learned biofeedback and how to use a TENS unit. Her medications include Relafen 500mg twice a day, rare use of Tylenol with codeine, and daily Ultram. Hershey Pain Management Center also gave her a muscle stimulator to try and she was instructed in its use. Ms. Sobotor continues receiving care at the Hershey Center. It is unlikely that Ms. Sobotor's neck pain will disappear completely. She will have to remain on medication and continue to manage her pain to function normally. Ms. Sobotor has been our patient since 1985 with no recorded neck complaint prior to her motor vehicle accident. The accident started her chronic myofascial neck pain. Sincerely, D l? Gunhilde Beck, M.D. COMMUNITY MER`. AL ASSOCIATES ? 3601 North. Avenue Harrisburg, PA t .0 ? 36 South River Road Halifax, PA 17032 PROGRESS NOTES Z t `eE ? l P"l AVA? fc Name .\.e.?l law, COMMUNITY A. 04AL ASSOCIATES ? 3601 North Progress Avenue Harrisburg, PA 17110 ? 36 South River Road Halifax, PA 17032 PROGRESS NOTES i /l' - MAR 18 1998 Name 'n i c 2???C1L1' G //e?d z 998 1 i„ J WO J )` a /,[.O? D c F s (' :r i r i ,t 'c h a .q. ci c e 'UQ I to .ern-` CENTRAL PENNSYLVANIA t r > SPINAL ASSOCIATES Waller C. Peppelma0A, D.D February 19, 1998 Deb O'Leary, P.A.-C. MAY 18 1999 Community Medical Associates 3601 North Progress Avenue Re?.e+r e6! Harrisburg, PA 17110 R°: Susan Sobotor Dear Ms. O'Leary: I would like to thank you for referring Susan to our office for evaluation. As you know she is a 34-year-old female who is complaining of posterior cervical pain with any type of lifting. The patient states that her pain is constant in nature extending to both her shoulders and her bilateral arms with numbness and tingling at the C6 distribution of her right hand. The patient initially was involved in an injury back on December 24, 1997 where she was involved in a motor vehicle accident and was struck from behind. She was wearing her seat belt at the time of the injury. She was seen at your office at the time of the injury, she was placed on a host of pain medications and anti -inflammatories and these do not resolve the patient's overall symptomatology. She continues to have symptoms and I therefore was referred here. Current medications include Advil in a p.r.n. basis, she lists allergies to Penicillin where she gets severe hives. No past surgical history and on review of systems the patient denies any cardiovascular, respiratory, gastrointestinal, abnormal bleeding, endocrine,laneoplastic,or neuromuscular blood trasfusion history nt denies any On physical examination she is a 43-year-old slender 5 foot 7 inch, 135 pound female with deep tendon reflexes equal and symmetric. She had increasing pain with extension of the cervical spine with. radiation into her shoulders. She has no evidence of any gross supraspinatus tenderness on exam. I reviewed her MRI shows some early degenerative changes at the 5-6 area, some early foraminal stenosis. Flexion and extension show some increased motion at that level, I feel she may have a traumatic ailment creating her overall symptomatology. What we will do at this point in time is start her on a physical therapy program. I will have her seen by Dr. Woods, 805 Sir Thomas Court s Harrisburg, PA 17109 1 (717) 510.7993 a Fax (717) 652.2636 r, i 1 Page 2 RE: Susan Sobotor February 19, 1998 one of our physiatrists, a rehabilitation doctor who treats these measures on a conservative basis. I feel she will have quick responses to these treatments. I want to thank you very much. Sincerely, Walter C. Peppelman, D.O. WCP/dlb CC: Michael J. Woods, D.O. - MG r . u 1, 999 h r- r.1J ?h 1 ',tK Y,. CENTRAL PENNSYLVANIA SPINAL ASSOfIATES February 19, 1998 Michael J. Woods, D.O. 805 Sir Thomas Court Harrisburg, PA 17109 Dear Dr. Woods: Waller C. ., DA. pll MAY 18 1999 I RF?c?vCO ?E: Susan Sobotor I would like to introduce you to Susan Sobotor. Susan was referred to me by Ms. O'Leary, enclosed you will find that note, basically-- she requires a conservative care measure for advanced cervical strain and sprain, I would like to thank you very much. Sincerely, 444C.- ZQ.06?? WCP/dlb Walter C. Peppelman, D.O. 805 Sir Thomas Court , Harrisburg, PA 17109 a (717) 540.3993 s Fax (717) 652.2630 •:;:`' 12/01/1999 DEC 13 1999 64 RECRIdEO & Rosenberg Harrisburg, PA 17108 Handler, Henning, 319 Market Street PO Box 1177 Steven E. Morganstein, DO- Michael J. Woods, D.O. RE: SliS:1N E. SODOTOR Dear Sirs: This is in response to your letter dated 11/19/99, regarding Susan Sobotor. She is a 44-year-old female who was 43 at the time I initially saw her on 3/9/98. At that time she presented with well as complaints of neck pain and bilateral upper extremity pain as numbness in the first three d:igi.tS of the right hand since the time of a motor vehicle accident on 12/22/97. At the time of her accident she was the restrained driver of a motor vehicle that was struck from behind. My initial diagnosis wa:i cervical strain with mild bilateral rotator cuff tendinitis. cervical strain was also my final diagnosis. When I last saw her on 6/23/98, she was doing better but was still bothered by anterior and posterior neck pain. She was having no upper extremity or shoulder pain and was requiring no medications. I not discharged her at that point to a home exercise program. schedule her for follow-up appointment. I felt at that time that the patient may have persistent pain but did not think she would suffer any significant disability and should not suffer any permanent injuries as a result of this motor vehicle ., 4.._. ' bei cvl: the 'iy ptome 'er which I vnv neeing for ,_rom the period of 3/9/98 through 6/23/98, were directly related to her motor vehicle accident of 12/22/97. If you have any further questions regarding this patient, please contact me. Sincerely, Michael / oods, DO MJW/sf Dictated but not read ;re A?X"iM Gro 805 Sir Thomas Court• Harrisburg. PA 17109 • (717) 6526623 • Fax (717) 6522630 DEC-02-1999 THU 04 10 PM API INGTON MGMT SVS FAX NO, 6524297 _ P. 02/02 June 23, 1998 Sfewn E MOTMIe7n, ao• AW6dl wooa? as %.i T, yqv Walter C. Peppelman, Jr,, D,O,<n 805 Sir Thomas Court Harrisburg, PA 17109 RE: Susan E. Sobotor Dear Walt: I saw Susan Sobotor for follow up today. She is doing somewhat better but is still bothered by anterior and posterior neck pain. she is having no significant upper extremity or shoulder pain, She . has been through a course of physical therapy and wellness program which ends today. She is currently requiring no medications. On physical examination she has full cervical range of motion with some pain on extremes. Spurling's maneuver is negative bilaterally. Impingement sign is negative in both shoulders.. Deep: tendon reflexes, sensation and muscle strength are within normal limits in both upper extremities, IMPRESSION: cervical strain With symptomatic improvement. I have advised the patient to continue her daily home exercise program, Unfortunately she is still having some residual pain and is frustrated by this. I do not feel any further work up is indicated at this time. I have not scheduled her for follow up appointment but would be happy to see her at anytime in the future if her symptoms worsen or change. If you have any questions regarding this patient's care, please contact me, MJW/dmr Dictated but not read Sincerely, Michael Woods, D.O. 605 S1r711CMS Cow! • Hudshuy, PA 17109 • (M 652.6623. Fu Vf1 652.2630 TREATI,. -NT AND PROGRESS NOTE tApc^& P vT ; le vc? lit s . d = P? i p sh-vc.?ca ti g. ?A ?. P: c?%hl auAk PATIENT: ?. sa/1 Soboqzx S.S. #: ARLINGTON REHAB AND SPORTS MEDICINE ADMIT. DATE: 805 SIR THOMAS COURT DIAGNOSIS: HARRISBURG, PA 17109 DISCIPLDYE: r OUeiCri5?i G< o GeJ? i!'1G? ?/7 plop, r, uj12 c U S L G? "Zt iW ARLINGTON REHAB &SPOMS MEDICINE May 1, 1998 Walter C. Peppelman, Jr., D.O. 805 Sir Thomas Court Harrisburg, PA 17109 RE: Susan Sobotor Dear Walt: MAY 18 7999 RE(;tl V40 Re ,V In 004 I saw Susan Sobotor for EMG and nerve conduction studies today. Her symptoms are about the same. She is bothered mostly by the pair in her shoulders and upper arms which is caused by shoulder protraction. She also has persistent neck pain and intermittent_ numbness in the fourth and fifth digits of the right hand. On physical examination she has mildly decreased cervical range of motion and left rotation and extension. Spurling's maneuver increases basilar neck pain bilaterally but does not cause any radiative upper extremity symptoms. Impingement signs are mildly positive in the left shoulder and negative on the right. Deep tendon reflexes, sensation and muscle strength are within normal limits in both upper extremities. Phalen's and TinelIs signs are negative bilaterally. L5 is negative at the elbows. Passive elbow flexion test on the left does not cause paresthesia into the hand. Using standard surface electrode technique the following nerves were studies: Right and left median motor response to the abductor pollicis brevis, left median F wave, right ulnar motor response to the abductor digiti minimi including conduction across the elbow, right and lef t median sensory response to the second digit, right and left ulnar sensory response to the fifth digit, and right median radial sensory responses to the thumb. Using a monopolar needle electrode the following muscles were studies: Right and left deltoid, biceps, triceps, extensor carpi radialis, first dorsal interosseous, flexor carpi radialis, right abductor pollicis brevis and abductor digiti minimi and right and left C5 through C7 cervical paraspinal muscles. 1. Normal study. 2. There is no electrodiagnostic evidence for: a. right or left cervical radiculopathy. b. right or left carpal tunnel syndrome. c. right ulnar neuropathy. n Steven E. Morganstein, 0.0. Michael J. Woods, D.O. 805 Sir Thomas Court • Hanisburg, PA 171D9 o VM 652-6623* Fax Q17) 652.2630 Page two RE: Susan Sobotor May 1, 1998 clinically, the patient's symptoms are difficulty to confidently diagnose. I think she has a chronic cervical sprain that hopefully will lessen with time. I am unable to explain her finger paresthesias by today's testing but it may be a mild cervical radiculitis or mild ulnar neuropathy which is not significant enough to make today's testing abnormal. I asked her to continue her current wellness program and I have refilled her Darvocet. I will see her back for follow up in four weeks or sooner if she is having any problems. If you have any questions regarding this patient's care, please contact me. MJW/dmr Dictated but not read sincerely, Michael J?J Woods, D.O. Mq y 1819g9 ?? is S Central Neurologic Assoc / Occupational Rehab 805 Sir Thomas Court Harrisburg, PA. 17109 5/01/98 4:40 pm Patient: SOBOTOR, SUSAN E. Physician: MICHAEL J WOODS, DO Patient ID: 208461248 Ref Phys: MICHAEL J WOODS, DO Sex: Female Nerve Conduction Report: Motor Nerves Nme Site On ct Lat Amplitude Seg Name Delta Distadce Velociry (?) (Rtll) (tm) (m/5> R Median APB O-P (mv) o Mri.t 2.39 l.2s R3t9M?Mrl.t 6.69 23.06 51.6 RLt L66 5.33 R Ulna ADM o-P (mV) O WL.t 3.16 6.69 atlla9-Mrl.t 2.95 18.00 61.0 aalbo. 6.09 6.9s Aalb9.-atlb9M 1.92 32.06 69.4 Atlb 9.66 6.99 AY11-AClbw 1.86 11AO 564 Aall 9.95 6.]5 L Median APB O•P(mV) O Mri.t 3.23 8.92 elba9-MRl.t 6.19 22.50 33.9 elbw 9.61 945 L Median F APB WL.t 29.53 Sensory Nerves Nerve Site O=t Lat Peak Lat Amprimde (ms) (ms) R Med Anti 2ndDig o-P (AV) Mrl.t 1.46 3.23 30.33 V.I. 1.01 1.69 90.01 R Med Anti Thumb O-P (AV) Nadi. 3.09 2.58 60.02 Radial 3.35 2.99 11.74 R Ula Anti SthDig O-P (PV) Y[l.t 2.39 1.14 10.31 0.64 1.63 46.53 L Med Anti 2adDig o-P (JIV) Mri.t 0.99 3.61 113.1 P.I. 1.01 1.86 206.3 L Ulu Anti StbDig O-P (t4V) Mri.t 1.01 3.40 4241 1.03 1.90 9.44 EMG Report: M4y.187 Rtcitl 99 Side Muscle Nme Roat INS FIBS PSW FASC AMP POLY RECR MTPAT COMMENT t/R nalt.ld Arlll. C5-6 Mal Mal Mal Mal Mal Mal eel nil L/R ale.p. Mu.e C9-6 M1 M1 Mal Mai w Mal Mal nil L/R Trlcapa Radial C6-9-8 Mal Mal Mal w all ' Mal w lull L/R eateaeRad Radial C5.6 Rai Mal "I Rhl Rlal Mal Mal Tull LA l.tnerint miner C"I Mal Mal M.1 Mal Mal Mal w nil L/R TlexCaraad Median C6-0 "I Mal Mal Mal Ral Mal M.1 Tull R Aga Manlan Ca-T1 Mal Mal wal Mal Mal Mal Mal Tull R Aa0 DiVinl Ml 4r csKl Mal Mal Mal Rxl Mal Mal Mal nil SOBOTOR, SUSAN pifl? 5/01/98 4:40 pm 2 Side Mule Nme Root INS FMS PSW FASC AMP POLY RECR INTPAT COMMENT 1/R a D.ee.D R/R Ce DuReD ? W pal ni w w w nil 1/R C) DuuD hl IeLL ul _ nit !u w MRl w Ll w Rfl w R?1 rnly Conclusions: SEE REPORT Mqy 1 ht?ri F 99 ? 117 OCCUPATIONAL nch AND RESEARCH ASSOCIATES Dear Walt: I saw Susan Sobotor for follow up today. She reports she is no better. She is taking Relafen and Darvocet which are helping intermittently and she has not experienced any adverse side effects. She has started the wellness program. She is still bothered by persistent bilateral shoulder and neck pain. She denies any paresthesias into the forearms or hands. On physical examination, she has decreased cervical range of motion especially on extension and bilateral rotation. Spurling's maneuver increases her posterior neck pain but does not cause any radiative upper extremity symptoms. Impingement signs are negative today but she does complain of pain in the anterior and lateral shoulders with certain movements, especially abduction from midline. She has mild tenderness to palpation over the lateral acromion and greater tuberosity bilaterally. Muscle strength and range of motion are within normal limits at the shoulders bilaterally. IMPRESSION: Cervical strain with resolving bilateral rotator cuff - tendonitis. I would like to obtain an EMG to see if we can find a reason why her cervical pain has not improved. I would like to rule-out any nerve entrapment or myotomal axonal loss. I will see her back for follow up to do the EMG and make further recommendations at that time. She may benefit from cervical epidural steroid injection.. I encouraged her to continue her current home exercise program. If you have any questions regarding this patient's care, please contact me. Sincerely, April 20, 1998 Walter C. Peppelman, Jr., D.O. 805 Sir Thomas Court Harrisburg, PA 17109 "Y 8 1999 1 RE: Susan E. Sobotor MJW/dmr Dictated but not read Michael J.'Woods, D.O. 121 Garrison Lane , Carlisle, 7A 17013 , 17111249.0670 , Fox 17171249.0734 005 Sir lhamas Court , Harrisburg, PA 17109 , (71716S2.2229 , Fax (7171652-4703 OCCUPATIONAL KEHAB AND RESEARCH ASSOCIATES April 2, 1998 Walter C. Peppelman, D.O. 8o5 Sir Thomas Court Harrisburg, PA 17109 Dear Walt: MAY 1 8 19S9 a.a a:6YCp i RE: Susan E. Sobotor I saw Susan Sobotor for followup today. She reports she is not significantly better. She is taking Daypro and Darvocet but does not notice a difference when she misses a dose. She has attended physical therapy and feels she has plateaued at this point. She is, however, experiencing no upper extremity numbness. Her complaints are primarily of posterior cervical pain. This pain is not disturbing her sleep. She does have occasional anterior shoulder pain with upper extremity movements. On physical examination, she has mildly limited cervical range of motion in extension and bilateral rotation. Spurling's maneuver causes basilar neck pain but not radiative upper extremity symptoms. She has no palpatory tenderness over the lateral acromion or greater tuberosity on either side, and impingement signs are negative. Muscle strength of rotator cuff muscles is 5/5 and does not cause shoulder pain. She has some mild palpatory tenderness over the periscapular muscles but no definite trigger points. IMPRESSION: 1. Cervical strain and cervical somatic dysfunction 2. Bilateral rotator cuff tendonitis with symptomatic improvement I have discharged the patient from formal physical therapy, and I have given her a prescription to attend a wellness program for continued strengthening and conditioning. I have asked her to discontinue the Daypro, and I have given her Relafen instead. She may continue to take Darvocet as needed. Osteopathic manipulation was done today including soft tissue techniques, muscle energy, and counterstrain to the cervical spine. The patient tolerated the procedure well. I will see her back for followup in two to three weeks, or sooner if she is having problems. If you have any questions regarding her care, please contact me. Sincerely„ Michael J. Woods, D.O. mjw/asp l Dictated but not read 121 Garrison Lane . Carlisle, PP 17017 (717) 2790670 - Far (7171249.0171 805 Sir Thomas Court . Harrisburg, PA 17109 (7171652.2229 Far (7171552-4200 present - Valid Test. ARLINGTON REHAB AND SPORTS HEDICINCE 805 Sir Thomas Court Harrisburg, PA •17109 REFERRAL SOURCE DISCHARGE REPORT PATIENT: Susan Sobotor SSN: 208-46-1248" DATE: 4-2-98 REFERRAL SOURCE: Michael Woods, DO DIAGNOSIS: Cervical Strain/Sprain Cervical DID; Mild B Rotator Cuff Tendonitis, Myofasical Pain Syndrome ADMIT DATE: 2-23-98 DISCHARGE DATE: 4-2-98 This patient had been scheduled to attend rehab TIW since admission. As per physician order s this patient was placed in a progressive upper quarter strengthening program with emphasis on rotator cuff. Modalities consisted o £ application of moist heat and ultrasound. Progress in program w m s as ordered. 1. DISCHARGE FUNCTIONAL STATUS: ADMISSION DISCHARGE ACTIVITY STATUS STATUS 1. Patient Subjective Comments: Pain level on admission reported at a 1120/10". Patient a ontinued to report discomfort c-spine. Intermittent BL sh o ulder discomfort. Cervical AROM: Flexion 4-9 DEG 30 DEG Extension a5 DEG 32 DEG R Lat Flexion a8 DEG 30 DEG L Lat Flexion 2 9 DEG 29 DEG R Rotation 6 1 DEG 70 DEG L Rotation f54 DEG 58 DEG 3. BL UE AROM: (Supine t) Full range of motion BL Shoulder. 4. Grip Strength: Position 1 Position 2 Position 3 Position 4 Position 5 Bell shaped curve Right (2-23-98) 324 444 424 354 344 MMT: R Shoulder Flexion 4-4+/5 L Shoulder Flexion 4-4+/5 R Shoulder Abducti o n 4+/5 L Shoulder Abducti o n 4+15 R Elbow Flexion 4-4+/5 L Elbow Flexion 4-4+/5 R Elbow Extension 4+/5 L Elbow Extension 4+/5 Special Tests: a. Cervical Compression Test: (3-18-98) 308 484 354 294 234 4+/5 4/5 4+/5 4/5 5/5 4+/5 5/5 5/5 'ry'e Left (2-23-98) (3-18-98) 234 274 504 384 474 364 404 274 324 254 reproduction of discomfort central C5-7. b. Spurlings Test: C+) for reproduction symptoms L paracervical region. No rad:icalar symptoms L UE or R UE. Susan Sobotor 2 Michael Woods, DO II. COMMENTS/RECOMMENDATIONS:,.This patient had plateaued in program. She may benefit from a continued strengthening and conditioning program via the Wellness Program (whrn appropriate). To date she had been issued a home exercise program. Mrs. Sobotor had indicated that she may undergo an EMG study. Await outcome of diagnositic testing. Patient may be a candidate for trial cervical traction. If results negative and myofascial issues persist recommend conditioning. program. Will follow orders as per physician. This patient was referred for the Wellness Program at Arlington Rehab and Sports Medicine. DATE - - : EVALUATOR' S SIGNATURE: P-7 l?. 1,. ARLINGTON REHAB AND SPORTS HEDICINCE 805 Sir Thomas Court Harrisburg, PA 17109 REFERRAL SOURCE UPDATE REPORT PATIENT: Susan Sobotor SSH: 208-46-1248 DATE: 4-1-98 REFERRAL SOURCE: Michael Woods, DO DIAGNOSIS: Cervical Strain/Sprain Cervical DDD; Mild B Rotator Cuff Tendonitis, Myofasical Pain Syndrome ADMIT DATE: 2-23-98 DISCHARGE DATE: 4-2-98 This patient has been scheduled to attend rehab TIW since admission. As per physician orders this patient was placed in a progressive upper quarter strengthening program with emphasis on rotator cuff. Modalities consisted of application of moist heat and ultrasound. Progress in program is as ordered. 1. UPDATE FUNCTIONAL ASTATUS: DMISSION UPDATE ACTIVITY STATUS STATUS t 1. Patient Subjective Comments: Pain level on admission reported at a "20/10". Patient continues to report discomfort c-spine. Intermittent BL shoulder discomfort. 2. Cervical AROM: Flexion 49 DEG" 30 DEG Extension 35 DEG 32 DEG R Let Flexion 28 DEG 30 DEG L Lat Flexion 29 DEG 29 DEG R Rotation 61 DEG 70 DEG L Rotation 64 DEG 58 DEG 3. BL UE AROM: (Su pine) Full range of motion BL Shoulder. 4. Grip Strength: Position 1 Position 2 Position 3 Position 4 Position 5 Bell shaped curve present Right (2-23-98) (3-18-98) 32# 30# 44# 48# 42# 35# 35# 29# 34# 23# Valid Test. Left (2-23-98) (3-18-98) 23# 27# 50# 38# 47# 36# 40# 27# 32# 25# 5. MMT: R Shoulder Flexion 4-4+/5 4+/5 L Shoulder Flexion 4-4+/5 4/5 R Shoulder Abduction 4+/5 4+/5 L Shoulder Abduction 4+/5 4/5 R Elbow Flexion 4-4+/5 5/5 L Elbow Flexion 4-4+/5 4+/5 R Elbow Extension 4+/5 5/5 L Elbow Extension 4+/5 5/5 6. Special Tests: a. Cervical Compression Test: reproduction of discomfort central C5-7. b. Spurlings Test: (+) for reproduction symptoms L paracervical region. No radicular symptoms L UE or R UE. Susan Sobotor Michael Woods, DO 2 II. COHHENTS/RECOMMENDATIONS: This patient.has plateaued in program. . She may benefit from a continued strengthening and conditioning program via the Wellness Program (when appropriate)." To date she - has been issued a home exercise program. Mrs. Sobotor has indicated that she may undergo an EMG study. Await outcome of diagnositic testing. Patient may be a candidate for trial cervical traction. If results negative and myofascial issues persist recommend conditioning program. Will follow orders as per physician. jr'v' DATE: 4" %-°ksr EVALUATOR'S SIGNATURE: 04 TREATMENT AND PROGRESS NOTE s r-b a,wd- g';°lq@ no comOW-4b p. 0 tLiF?N61 n U9PREs A', pC i' D;Ib11?K 1 u6 P? (?- OiD PATIENT,SflBwj,ksob0TR S.S. ARLINGTON REHAB AND SPORTS MEDICU' E ADMIT. DATE: 805 Sgt THOMAS COURT DIAGNOSIS: E ARRISBURG, PA 17109 DISCIPLINE TREATMENT AND PROGRESS NOTE 3?a31a8 .. . s P+v A P ac A .cm 6umb 0, rnRro .X(sfn m Pl ?? `s Pg? T?bumd ac's , C??l,c,C c E . i? cv A' O„ (Yl9Vo Altk\- 1? 15' ra 5c M ?t?t : 2 U `Sly cQ ??'x'' yt S Y/ !S S?Q ?? y?-ls Y/5 K(02 V?5- P (Z- op zo' bow W S/5 /s C / bo u) j-xT 57/ s s/s TO t 10Y VJ' P; Cwt-: UkuuJ1 S' Pf. to i?o A -s . o; c ml a-um u.P vas. Lt Flg6 - PF. pct6CLOQd U C (?(LES e ?tjYl? OSfc-l,t.C.c..Q S?.C.?. (?1?(?w?3`txik ;? ?w, ARLINGTON REHAB AND SPORTS M MICM 805 SIR THO&Lts COURT HARRISBURG, PA 17109 :: i F?II lel4 .. - !C I4o° TREATMENT AND PROGRESS NOTE • ?; ? - ? u..tzs f-v? ?'?"? 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ARLINGTON REHAB AND SPORTS MEDICINE ADMIT. 805 SIR THOMAS COURT DIAGN( HARRISBURG, PA 17109 DLSCTPY OCCUPATIONAL I%^ B AND RESEARCH ASSOCIATES R March 9, 1998 MAY 18 1999 Walter C. Peppelman, D.O. RECEIVED 805 Sir Thomas Court Harrisburg, PA 17109 RE: Susan E. Sobotor Dear Walt: I had the opportunity to see Susan Sobotor today. She is a 43-year-old female who was involved in a motor vehicle accident on 12/22/97, at which time she was the restrained driver of the vehicle which was struck from behind. She denies any head injury or loss of consciousness but reports she has been having neck pain and pain in both arms associated with numbness in the first three digits of the right hand. Her upper extremity pain is primarily in the upper arms but occasionally into her forearms. She reports she is having constant pain but denies any sleep problems. She is working her full-time, full-duty job and has recently started physical therapy. She has no other significant past medical or surgical history. She currently takes Advil as needed. She has taken other pain medications, muscle relaxants, and antiinflammatories in the past but has stopped all of them. She reoorts medication allergy to penicillin. on physical examination, the patient has significant limitation in her active cervical range of motion. Spurling's maneuver increases her pain in the posterior neck and upper thoracic spine but does not cause any radiative upper extremity symptoms. Deep tendon reflexes are 1 to 2+ and symmetric throughout both upper extremities. Muscle I, strength is within normal limits in both upper extremities with some ?l. give-way weakness in the right hand. She reports decreased sensation to light touch over the first three digits of the right hand. In i addition, she has palpatory tenderness over the greater tuberosities bilaterally and pain with impingement tests bilaterally. The patient had x-rays and an MRI done of her cervical spine that showed some degenerative changes at the CS-6 level but no frank disc herniation and no acute bony abnormality on plain films. IMPRESSION: 1. Cervical strain 2. Mild bilateral rotator cuff tendonitis I have modified the patient's physical therapy program somewhat to include some rotator cuff modalities and strengthening exercises. I also think she would benefit from generalized conditioning in an effort to decrease the myofascial pain components of her symptoms. I have given her Daypro as an alternative to take as 1200 mg. daily i ii i 121 Garrison Lane Carlisle. PA 17017 (717)245.0670 Fa: (717)249.07J4 695 Sir Thomas Court Harrisburg, PA 17109 (717(652.2229 Fax(717)652.4203 oft :A Page 2 RE: Susan E. Sobotor March 9, 1998 with food in place of the Advil. I have also given her Darvocet for breakthrough pain. I will see her back in three weeks for followup, or sooner if she is having problems. Thank you for allowing me to participate in the care of your patient. If you have any questions regarding her care, please contact me. MJW/asp Dictated but not read cc: Debra O'Leary, PA-C Sincerely, Michael J. Wo ds, D.O. Mav x 1 ? 8 1999 I ACVC?YCu .. TREATMENT AND.PROGRESS NOTE 4 ")Ahv 6 lb US M? c? (,?.ucc,D?nc<,ld x 5r? ?Y . ?? . ?uJru,1c( cxcuv? ? sfu.?G? , 30 o L C X wom - c,?i? 3C7 ?;nUf WL(?• N?S?y?c c R?Nt. 316/y s- p4. agpLadnocioS. o m X ?s mono ?o ??- X is fYt u,? a Qo I b u SK srn.. ? t? O?-? ?cc . ?I•SWlGnz insi?in?, A c-ki ?k c cu.am st-Ict?ao • i 4o pptq cum CX ism s 9 0a sobmccm"emu x A-.; Pf, hu d VIv coo 31y1 as s. pF fo t `?`1 ?''`Lw a , m J+ ro nuLk'X rsrtiVI/M 15o um y X(D ?u. 4-o9a ?} } ,? U T Cum CD S.S. # ARLINGTON REHAB AND SPORTS MEDICINE ADNTr. ??I 805 SIR THOMAS COURT DDIAGN( HARRISBURG, PA 17109 e'_ TREATMENT AND PROGRESS NOTE zA? /9 61 c? o, m 1+ .to adu ..__ •? ? si •fi i n ? i??•S W I cw? ?- ? ? GX ?GU-? i CK a? -C M X 119 Sf, j c?YV1 ?? 0 fYl-2 27C C sf uT . e cicLh lhcVyl , m f :5: P? lb P? ? ?a held to I,, ?UCA ????f1 Cdpc? p ce.juln u aim ?o I } d. 2l)ombiCt PCLcL If1Ul0 ` un ?s? n+ a t S 3/ `y?P e WaD 10 cry '" c? a f c c n y d Iwo cm lu` ? 51t??'?Z 'r ?r??n y ?? 5 ??cc1%anOti? I vto x c? p J0,loorc( Sf • / 16?? eaah/&,-?ps.s. ARLINGTON REHAB ? SPORTS WMICWE D GNOSIS: 805 SIR THONIAS COURT HARMBURG, PA 17109 00.4 ARLINGTON REHAB AND SPORTS MEDICINE 805 SIR THOMAS.COURT HARRISBURG, PA 17109 BASELINE PHYSICAL THERAPY EVALUATION RESULTS pATIENT: Susan Sobotor SSN: 208-46-1248 DATE! 2-23-98 REFMUIhL SOURCE: Welter Peppelman, DO DIAGNOSIS: Cervical Strain/Sprain ADMIT,DATE: 2-23-98 ANTICIPATED DISCHARGE DAT$: 8 Weeks JOB TITLE: Employed by Penn Dot - Administrative Assistant (desk) HX: Patient is a 43 yo who reportedly involved in MVA on 12-22-97 when her vehicle was struck from the rear. The patient denied seeking medical attention after the accident. She indicated that she went on holiday til 1-3-98. She reported that she returned to work and continued to work 2 weeks after 1-3-98. She reported that the symptoms present after the accident were exacerbated upon return to work. She sought medical intervention via family physician. She spent a period •.; of time with her family physician who prescribed her meds. The patient indicated that she was taking "muscle relaxants, pain meds and anti- inflammatory meds." She reported no relief with meds. Complaint of constant R>L Shoulder Pain, intermittent "pain/numbness" Right thumb, index and long finger. Patient reported that pain extends into BL elbow. Pain level reported on admission as, 1120/10." Patient stated, "It is difficult to hold my head up." Patient denied exacerbation in symptoms with cough/sneeze. Patient avoids lifting "anything" at home. MEDICATIONS: See medical chart. I. D 1,99 i& IYAR f t? 1. C-spine AROM WNL upon Discharge. 2. Right Grip Strength within normal limits for Right hand dominance. 3. BL UE Strength 4+-5/5. 4. Patient to transfer to independent ex. program. II. PHYSICAL STATUS: r " *AROM: C-spine AROM: Flexion = 49 DEG Extension = 35 DEG R Lat Flexion = 28 DEG L Let Flexion = 21 DEG R Rotation = 61 DEG L Rotation = 64 DEG *MMT: BL Shoulder Flexion = 4-4+/5 BL Shoulder Abduction = 4+/5 BL Elbow Flexion = 4-4+-5/5 BL Elbow Extension = 4+/5 *DTR'S: NL 2/4 BL Biceps/BL Brachioradialis/BL Triceps *PALPATION: R>L UT taunt. *POSTURE: C-spine protracted, BL rounded shoulders. *GRIP STRENGTH: 5 Position Test Right Left Position 1 32# 23# Position 2 44# 50# Position 3 42# 47# Position 4 35# 40# Position 5 34# 32# NOTE: Patient is Right hand dominant. Preferred position is given the patient hand size and mechanical advantage. However, minimal strength deficit noted R at position #2 2. Susan Sobotor Walter Peppelman, DO 2 III. " F PI1!!1. (STG): As per physician: PT Evaluate and Treat, Strengthening, Isometric, Modalities, active and active assisted ex. Moist heat to neck followed by ultrasound and ex. as per log. STG: 1. C-spine AROM improved by 5-10 DEG (3 weeks). 2. Patient to report a reduction in symptoms by at least 40% (3 weeks). V. COMMENTS/RECOMMENDATIONS: Will continue as per physician. l EVALUATOR'S SIGNATURE: DATE: ?3 gfr PATRICIA R. HOOVER, PT cc: Michael Woods, DO Consultation scheduled on 3-9-98 r i PxM YennState C eisin er g The Milton S. Hershey Health System Medical Center 1 i i m i 1 I y vv^.'.T 11 MR 6 Rev. 2/95 PROGRESSREPORT NOV 2 9 1999 RECEIva, 1 ;t s?. f E 3 C Y y? b 3 9 L PennState jeismger - Health System /"N Health 3ntorm360n Services { M.C. HU24 .. P.O. Box 850 Hershey, PA 17033.0850 N0V 2 91999 EiELFIV r-W RISBU May 19, 1999 j? COMMUNITY MEDICAL ASSOCIATES OF HAR 3601 NORTH PROGRESS VENUE ` HARRISBURG PA 11110 Dear Doctors: MSHMC 945835 Susan E ement where she is gg; Sobotor, at the Pain Manag syndrome. Today follow up ofascial She states a ?. I saw Susan Sobotor in radicular in nasuffering a severe F! seen for intractable partic assular theociated past with mYevening, her symptoms are not p did twist her wneck on stimulator that at home. that neck s she train. She underent muscle trial this morning an i:. be beneficial and will be using b i d. Tylenol and codeine one daily, found r in Medications: Relafen 50 0 mg day. Ultram 50 mg q.4-6h. about twice a Allergies: penicillin. pulse 77, respirations Blood pressure 121/57, ints physical examination: predominantly muscle tenderness No today, trigger PO 20, temperature 37* especially trapezius and sternocleidomastoid are athy today. identified. M ofascial syndrome. No evidence of radicu oP opinion: Y Use muscle previous medications. trial performed Continue Recommendations directed, as it was effective for 15 days tiiven t-i.d- cle ourse l 10 mg stimulator as c of Flexeri us els she aneeds today- Short term the end of her s nths or at Follow up in three mo program. She is offered interval follow up help in the meantime- Sincerely, ?i 1 Gregory Gullo, M.D. pain Medicine and Palliative Care Center 531-6834 GG/ 10:57 cap D. 05/19/99 T: 05/20/99 PENNSTATE -• ]?? Colleje of Medilioe ' Uniresiry Hospial•Chadreai Hospiol The Nihon S. Hmhey McEial Ccw,, - PAN MEDIME AND PALL[A7- VE CARE CSR OUT PATIENT PROGRESS P--Fnc7 . NOV 2 91999 0094:5835 RECavE6 SOB OTOR, SUStN_E _ 99 - 12/21'/1'954 F 7 D ?E:'J IIf1G yr t7 9 IN t r-WAL F.IST7=Y: IFaT1=V'_^ I PAIN: I Q ecrs;ar,; I Q chances L?I'^?Z??n g Z:itelu2a mel.id (. dd. nc a. - na War- Q 0 s:sar-a 0 / ! nc V, r-4 de:B 0 ac ?e Cl tc n Q 6 r I I f ? s G?-?c_ rn a •.? O ?'' !r ? tii ( I I tV1JIC TIGNS: i r SOD ?D I ? c ?? ( JY dy' I 54 T ?/r G °. /L 6iD I ALLERGIES:I C V5: 6.P.: Yr a IC•rl .. R: PR4CRESS REFOR i t , 1:2 Frocedure(s) F Q Perorr,(ed 6y: 0 Resuscitation Q Fluc I ? £ :hJ uu v -rte, 1 Ic14. rnu? mzzz i NO ee ... ,. ?•'i y _...NOU 1999 f r gent OK ? No ce Q Persantin F:ECOROS: T2 rse.(ax QCarxert IQ =Ca" Qox-/at POST i ION: Cl sc? re Q ?:one Q Liteni( L- R Q S;tlng SKIN PREP: C( =1.=1 T_.l aeoGire 0 Starla dnFax 0 (OGn SKIN L-A,- 0 = Y._rl 0 Nee?le: a encl.: 13 PL has -? .Q BLOCK: • cpiG_al_ / 'CAM( I i'wricc L=.tLar CsuG( 0 spiaa(_L / Q Faae:Narfe_ Q Ft?•• e(r_ T] =atiatatanS'Scn Cl ce.c;t.-.. 5:t] c G SF.`.e :cFa(a: C C? eecEFitil 1 0 svFrzLS' Y Q -rigger Aottttjsl• C= ? Ck Q '- Q L: 0 s 041:1=3:31 _ Q In:e ,Ia•_:( . rsyr? Q 3rae?ia(Ple:s eu'a `l .'A a=ItA.-I Q !ASnC1!:02f 0 CC^.? 3L :'= u CI j r•i-=R: FLOCK N=EuLE tea. _in I Cl L=rs's?or. _cvet 0 ,-ceF.ylvr•:" 0 S` _•rtc 0 Ca.ta s GOUGS: C! G ?up(•r_ = : 0 F.Ue n?4a wee Q s4rre04% rr :. G ceta:a r - Q:.1e?,•ed M; ice( 3eu rnaci. _m- Q' sanF(n r: u QTjE,R, •'• - r'7i MIX lNleC i c 0 Vc1cce _trI T_.l nel5asic : C F dci ifas: t. Z- - I.V. ACCESS Cir. _!a 0 -e,:teek ' • Q seludcr..: F._:rarks SeG; k. Statics: Q rain-an discharse /10 Q Na Chanse 0 Nc Ccr i:tIc¢tcrs 0 NeurologicallyTntl": D Cardiavasc Iar stable C1 l]isc`,arse Ticr:e 0 Inradent ward T Q A,---ream Insr:tc'.'crs PLAN: 11. 5. ?1 Q2 A.rer.?ny Fh?sie'a? P.asider: dFellow: PFIaGftSSS R:?CnT Q? C2 50 6 Q T Q days Q weeks Q dlc Nurse: VITAL SIGNS: Wt.: _ e -?. °C PennState?.jeisinger Health System elu1 Health Information Services M.C. HU24 P.O. Box 850 Hershey, PA 17033-0850 NOV 2 91999 RECEIVEV COMMUNITY MEDICAL ASSOCIATES OF HARRISBU 3601 NORTH PROGRESS AVENUE HARRISBURG PA 17110 April 20, 1999 Dear Doctors: RE: SOBOTOR, Susan MSHMC #: 0945835 It was my pleasure to see Susan Sobotor in Pain Medicine and Palliative Care Center on April 20, 1999. As you know she is a 44-year-old white female with persistent neck pain status post an MVA one year ago (at the end of 1997). Since that time she has noted a persistent "heaviness" in her neck, rating at an 8/10 on our pain scale. She notes that the pain does not radiate to anywhere else in her body. She notes no change in her pain level since her first visit here except a mild improvement with physical therapy. She notes an interest in "steroid injections". She had a bone scan on December 14, 1998 which proved to be normal. She has had no major abnormalities on previous x-rays or MRIs. Her medications include Ultram 50 mg 1-2 q.4-6 hours p.r.n., Tylenol #3 2-3 q.d. p.r.n., and Relafen 500 mg b.i.d. ALLERGIES: PENICILLIN. Physical examination: Blood pressure was 115/77, pulse was 96, respiratory rate 16 and temperature 37.0. In general, she was awake, - alert and oriented in no apparent distress. Head, ears, eyes, nose and throat examination was grossly within normal limits with Pupils were equal round and reactive to light except for a grimace to cervical palpation. Lungs were clear to auscultation bilaterally. Heart regular rate and rhythm, no murmurs. Abdomen soft, nontender, nondistended, positive bowel sounds. Extremities grossly within normal limits with good motor strength in all four extremities. Assessment: Persistent neck pain status post MVA. Plan: 1. Continue current medications with an increase to the Ultram to 100 mg q.4-6 hours. 2. Muscle stimulator trial. APR 3 019°. - AZL Fln PATIENT NAME: SOBOTOR, Susan PATIENT NUMBER: 0945835 PAGE 2 3. Cervical epidural steroid injection with next visit. 4. Followup 3-6 weeks. The patient was seen and examined with Dr. Greg Gullo. Sincerely, William C. Motter, M.D. Gregory Gullo, M.D. Pain Medicine and Palliati Care Center 531-6834 WCM/bjc D: 04/20/99 T: 04/21/99 12:08 NOV 2 91999 RECEIVED PENNSTATE Rii? Collegeaf`fcdicine University Haspiral• Children; Hospicrl ® The Nihon S. Hershey Yledinl Center 'AIN MEDICINE AND PA1/AT/VE CARE CENTER OUT PATIENT PROGRESS REPORT Oa:eMme I PaT23YT INTT---IVZZn Bv_ : dud. nandrl a i:. I. ( PAIN: 0 M ISYS ----------------------------- (A NC. is (D T: s V ? 1 A a ra.rr PROGRESS REFOfi T NOY291999•. L?? 1 4 . 3S_ REcFIVEO goTOR. SUSAH E 99 C-rul KY C 110 , F. rd'4?tEOICINE 6. PALUA TIVE CARE CEt OUTPATIENT PROGRESS NOTE M Procedure(s) performed: C2 Per,"ormed by: . G Resuscitation Equipment OK ? No counadin, hepa C! Fluoroscopic guidance ? Cryoneuroiysis R°-CORDS: Q.:.Ner=.ies Q consent I QSC.G. POSITION: G scpire Q a:ere (2 Went L . R SKIN PREP: ? te_t.el Q Se ad?re Q Stea7e dupes Q Icban Q• , SK11'4 L.A•• Qor_-y: nt ?Needle:_,,a metes _ BLOCK: =pduni_ / Q S i l CaMcat (] ihonde 4r. ?.ar Caudai c na _L r pae•: Ner,e Q Face Join! Q stenate gansacn Q c?aae SME Q R: ? L C1 SFhencpala:-3 Q N Qeec:pitat.N ?Supnaeap•N QTrisger Paint(s). _tr-arS ^ t ec:cr..a Q Ir.:erccs:al-_ Q tr.;errleura Y p Q 3nahiat Pleas red-:r: Q Na_Mary Q Mindtbular Q ccht ntmic Q OTHER: BLOCK NEEDLE:__yz, in I Q Lcr.VSaer. Sevd 0%chyrrldss QS tiuPtea QCaLtete DRUGS: ' Qlda__mt Q3uriv_!: rJ Qpn=-n°n hee Qsanrea9!:? t'. QCcta;e ) Q Mt P:e:__r..g ? ae!r..eL`. _r,.g Q Sanpin r..l Q -? OTHc . •. htI..INlEC i E]: Q Volume _rl Q ?nalgEsic °,: _ Q Additives: 1. 2• IN. ACCESS j '-a S.:e I Q earnula ( NepleeS Q solider.: VITAL SIGNS: W : _ Temp. °C E.P _/_ Hg H.? _ bcr„ , P R._.bcn, SaO, TiMa ( Dr.c/evan:/Par-.arid I EP I Fi?. ISaO: F.= .narks li Art.i_ _ ,Cp? /,Y r- r>z?-,n An 2 9"19 9' Persanti Q arrsat Cl Q Sit$rg VIA Q Pain an discharge _110 0 ,No Change 'Q No CcnplicaC s'?0 p(e rr gie I Intact Q Cardiovascular s aSle Q Discharge Hone Q Inpatient ward T Q At' r I cticns DISCHARGE S T A T US: PLAN' I Cc ,d d+ /a r.rwo?hA?ynr 11'& 7V 2. Folio ` A tier ding 21 ?Z QJ3 C24 ?5 e6 ?T ?s3 P.esidend eliow: PftOCfRcSS SE?OPIT weeks ? months Q Nurse: rd...wm'•d> ®J E n G w mm 3: m i m I 0 m OH F-. ON Ge m s6: 624 or , r- 4W P"I NOV291999 HECEIVEu DATE THE SSAGE FOR E AGTGII IAREN 0 6 L EATIE 5 E i .ATE O- m -E MEDi AEEON.NO. y r f- -2 3 E rt 0 o _ .ALLEN VIIONENO. Avu " . 3 -3 9 ) / w 7 - 6 3'? mt E MESSAGE / .. O eZ. e CA u u EIIAIUTACY iHANMACYPpHENO. DATE ME S b' ? ?, 7 1 A ENOIES MESSAGE TAKEN BY SHi A 1 LE ? /vVo L / Y? pN 2 ;Z 4 rs ;0w. 0 O w G 2 y L ::? r l Radiology Services FM PennState 0eisinger Health System 143A-121498 NOV 2 9 1999 SOBOTOR,SUSAN E 21-Dec-54 RECEjVj=u RAD M.C. H066 P.O. Box 850 00945835 Hershey. PA 17033-0850 Date of Exam: 14-Dec-98 DANIEL WILLIAMS MD ANESTHESIA HMC, Exam: NM BONE LIMITED/FLOW & TOMO C-SPINE TOMOGRAM CLINICAL HISTORY: 43-year-old with persistent C-spine pain, status post motor vehicle accident one year ago. RADIOPHARMACEUTICAL: Technetium-99m HOP 19.40 millicuries IV. DISCUSSION: There are no comparison studies. There are no foci of abnormal radiopharmaceutical uptake in the torso or cervical spine. IMPRESSION: Normal C-spine SPECT. Dr. D. Eggli reviewed the images and discussed the interpretation with Dr. Cartaya. Dictated: DAVID O. CARTAYA, M.D. Reviewed & Signed: DOUGLAS F. EGGLI, M.D. DOC/jsr cc: DOUGLAS F EGGLI, MD DEPARTMENT OF RADIOLOGY,HMC, DICTATED: 14-Dec-98 TRANSCRIBED: 14-Dec-98 SIGNED: 17-Dec-98 PennState Geisinger Health System els? Health Information Seri lees M.C. HU24 P.O. Box 850 Hershey. PA 17033.0850 N°?z 9 X999 COMMUNITY MEDICAL ASSOCIATES OF HARRISBU November 25, 1998 3601 NORTH PROGRESS AVENUE HARRISBURG PA 17110 Dear Doctors: RE: SOBODOR, Susan E. MSHMC #: 945835 Mrs. Sobodor came to the Pain Medicine and Palliative Care Center F='•?. today for a follow-up visit. As you remember, her symptomatology seems to be consistent with: Opinion: 1. Cervical spondylosis, possible cervical facet joint arthropathy, myofascial pain/muscle spasms. Plan: 1. The patient is to start using capsaicin cream 0.025% t.i.d. 2. The patient is to continue Ultram as she has a refill on the Ultram; a total of 90 pills were prescribed. 3. The patient is to obtain a bone scan of the cervical area to rule out facet joint arthropathy. 4. The patient is to start taking Relafen 500 ma h_i_r9_ History of present illness/chief complaint: Mrs. Sobodor returned to the Pain Medicine and Palliative Care Center today for a follow-up visit. Her pain today is 6/10 on a VAS. Most of her pain is in the cervical area. There is no radicular symptomatology involved. NJ has no fever, chills or night sweats and she has no incont She bowel or urine. inence to Medications: Ultram and Tylenol #3. Allergies: Penicillin. Physical examination: Blood pressure 132/66, pulse 64, respiratory rate 18, temperature 36.7'C. The patient is in no apparent distress. Her upper extremity neurological examination is without any focal findings. Lower extremity neurological examination is without any focal findings. Chest is clear to auscultation. Heart: Normal S11 S2. No S3, S4, no murmurs, no jugular venous distention. The patient had pain in the cervical area, C2-C3, bilaterally. There was no tenderness in the occipital nerve areas bilaterally. DEC i 119;43 Ad) f"'O1 NOV 2 9 195 PATIENT NAME: SOBODOR, Susan E. REGCio PATIENT NUMBER: 945835 PAGE 2 Dr. Williams was present during evaluation and we formulated our plan together. Sincerely, Ronny Kafiluddi, M.D., Ph.D. t do. G4? s" Daniel P. Williams, D.O. RK/smc D: 11/25/98 T: 11/30/98 15:18 ti a ?• ?;rl 'IJ L•11 C •" C.1 ear ?L •.• Unive:f!ry Hmpir_!•CSr.• 1Hotpica ••u• ® The ""'can S. H=hey Me,.-.:! C:nte: PAMI ATEO/CINE ANN pA-U/.4 77VE C.4 RE CEDER OUT PAT[EIVT PROGRESS 13 a:arrne IFi,''', R?cEORI ••?? ='•r.(?r'C--gin 8'!:inc4• ESL A 1 Onru, d. ,nmf!f (Y, c Vr^.L I Q hC 6.r. rT0 War eeree- ® - NOV 2 9 1939 Q.J.945835 • FiEC•Ellr?? •., 50.6OIOR, SUSAN p_ 11/11/1954- 'F 99' { 1 Z R r a w :y 0 dull R.LL'eRG!?S: I .J ever=,.,` REVIF N 1 IQN- c I V_ E.F. ? F: F.• '? T: ,(Q7 • i Ir ; FROCRESS RZF097 ' ?r ®FAN M-01ONE & OALUA 1IVE Cq• N 7 ER rl CUT-PA 1 TENT FAQCF. SS NO. ? Procedura(s) per."or„ ed• ? Perarm, ed by: ! Resuscitation Equipr„ent OK ? Fluarascapic Guidance P,=COROS: Q:ll<:ytes ? e,,r FOSI I ION: ? Supine ? P,•-re C3' No caumadirt, heparin, p ? Cryoneurolysis ? E.C.G. ? ? Lit--ml L . R CL SKIN PPE?: ?at-=hat ?se aere ?SUni<dzp3 ?.fetal SKIN L.A.: ? cr:;: ml ? Needle:.-ea as t ? R-F , ?- a BLOCK: Spidu:al? . ! car,ical Shand- LL:..--. ?.t Spr-al_L / ? Ficat mcNc_ ? '-a" Jcira ? S;atlacS Sar.i[;a,C ? caudal r e S:Oe ? R ? L ? S;fte..apara; a C ? ce':prtal N ? ?! Sup as :_. ? Td e. S; ^Fairt?s) ? .-- e,.-rtc L t t Veu:-r..s C1 Ir.:t:eas;al__ 1r,:?rle•:r.I 0 G 3ze4rdl Fle ?a?S; C l Maa:',lay CI Y..irdibular ? ack:haf.-ea _3 r l1 O I'r.?tZ: ?;e: =LOCK NEEDLE: ez in Lea;IShertwat ? C1 -u-h IP/eis Y sdr..ua ? te= ? r eac :.. OP,UGS: C1°_ida? _r..t Ct_ueFi_?_r.: ?P:a:ar,:ve::ee •^?sar:-ea_::?-?r .;,t? b-l C:.;e?:e! r..- C! :<:=-e:.`._r..; ? SanpF,:_r..t ' -! OT'r,E? -- - ---? n..c C3SC ,a n..,.l.i'le5: Z. Lv. ACCESS u u-- a c H<=lack Salctlaa: Vl T: L SIGNS: Wt- _ Temp. _ <C E.? _/ r,T,'r, F.0 S Ecr P r[. bo„-, Sao-. Tina Or_c%variVFa,,arc 6= H? ?SaOt+ Sti:tus: ? Pain cr, eischzrga_/•ia Q No Change Q Ne Cer„plica;;ers C2 Neureiecicallyint ? Card1CvzSc;;lar stamla Q Discharge Horne' 0 Inpatient wzrd T ? A.°,ereare IRSt l? 0ISCP .RGE S T AT44-S .FLAN: 1. 2. U1 Q2 C1:3 APrendinc Frtysiclar.: ? 5 ? 6 ? T ? davs ? we'<_i<s f ?- y (---) / PROCRESS RZ?Q; T I'iurse :,j , xwp° r FM PennState veisinger Health System eahh Information Services HU24 P.O. '850 Hershey. 17033.0850 NOV 2 91999 RECE1VEu COMMUNITY MEDICAL ASSOCIATES OF HARRISBU October 6, 1998 3601 NORTH PROGRESS AVENUE HARRISBURG PA 17110 Dear Dr. Beck: RE: SOBOTOR, Susan MSHMC #: 945835 Your patient Susan was seen today in Pain Medicine and Palliative v:.;,n Care Center. Thank you for consulting with us to evaluate your patient. As, I am sure you know, she is a 43-year-old female who is status post a motor vehicle accident in December of 1997. She sustained cervical strain following this accident. She has had continued neck and shoulder pain since this time. She has been seen by Dr. Peppelman as well as Dr. Woods over the spring of 1998. The patient today states that her pain is anywhere between a 5 and a 7 on a scale of 0-10. Her location is still neck and shoulder with the dull constant aching pain on the right side of her neck and shoulder greater than the left. The patient describes her pain as thought "feels like my head is too heavy for my shoulders to support". The patient also complains of pain in the front of her neck. Mrs. Sobotor talked about tingling in her fingers which had occurred several months past. She states that this is no longer going on. The patient states that nothing in particular increases this pain while heat will help decrease the pain. She states that her pain is constant, dull, and aching in nature, and never goes away. The patient has had x-rays. She had a cervical spine which showed one mild degenerative changes at C5, 67. No fractures were seen. MRI of the cervical spine showed mild cervical spondylosis; CS to C6 with minimal bulging annulus. No focal herniated nucleus pulposus. Minimal bilateral neural foraminal encroachment, C5 through C6. Severe neural foraminal encroachment on the left at C3, C4. The patient also says that she has had EMGs done. There are no records of this faxed to us. The patient, at this time is taking Tylenol with Codeine and ibuprofen to control her pain, although she states it is not controlled. She was in a physical therapy program, set up by Dr. Woods. This is the only thing that Ms Sorbotor indicated gave her relief. She states she felt toned and that strain on her neck improved when she was in the physical therapy and well fitness program. She states that at this time she has rotational exercises at home for her neck, but they did not help. Today the patient is to pick up a TENS unit. We will assess her when she returns for a visit to see if this helps her. 11 Off' tlft? PATIENT NAME: SOBOTOR, Susan PATIENT NUMBER: 945835 PAGE 2 oz-? NOV 2 9 1999 RECEIVED The patient states that her sleeping is okay, her appetite is unchanged and she has really not seen any change in her physical activity due to her injury. She continues to be employed at PennDot. Current medications as stated above: 1. Tylenol with codeine. 2. Ibuprofen. Allergies: Penicillin. Past Medical History: Significant only for sinus headaches. Past Surgical History is noncontributory. Family History: The father has history of coronary artery disease and the mother is healthy. Social History: The patient does smoke. She continues to work. Physical examination: Vital signs are stable today with a blood pressure of 138/77, pulse of 77, respirations of 18. Examination of the head is atraumatic and normocephalic and PERRL. Lungs are clear to auscultation bilaterally. Coronary, regular rate and rhythm. On upper extremity exam, her motor strength is 5/5, sensation is intact to pinprick and light touch. Bilateral deep tendon reflexes are intact and symmetrical, upper and lower extremities. Full range of motion of the neck including flexion and extension. There is point tenderness at CS-C6 level lateral to the midline, when the patient rotates her head to the right and/or the left. The patient is able to abduct bilateral arms without difficulty, but complains of dull aching pain in her bilateral deltoids, greater on the right than the left. The patient denies pain on palpation at the bilateral rotator cuff. External and internal rotation of the upper extremities is intact. Impression: Chronic cervical strain, status post motor vehicle accident December 1997. Plan: We will restart the patient on Relafen 500 mg one b.i.d., = Ultram 50 mg one to two p.o. q-4/6-hours p.r.n. pain, Biofeedback consult for the patient. The patient is to continue T3 on a p.r.n. basis and the patient is to follow up in 4-6 weeks. Thank you for this consultation. The patient was seen and examined by Dr. Gregory Gullo and myself. Sincerely, Allison Gullo, M.D. Gregory Gullo, M.D. Pain Medicine and Palliative re Center 531-6834 AG/jkk D: 10/08/98 T: 10/09/98 11:17 oG? ® '[1,e mil on S Hcahc; }iedi<nl Censer ? NOV 2 91999 IM5 PROGRESS REPORT 5 QJL SOBOiOB, SUSAN E 99 Oat ime PROGRESS NOTES: (Include Name, Title) P??N M_?N4L - ENL CL.TiVLC j rIITL4.L P4_TN 4.SSr- 4SS255'nt of Palm Lecetiapm,ii?, _a, ei A T-ntemsity (Scale 0-10) v G".e=acteristics/Patie tt Dasc=iptica: Nt? 'Y Type: Fh4`- 7i B {,,g h=na T?arrobbL*g rsPi I nr?,--ri rranr ' e r I ? fici t SeaSOry }refiCit i h y a es Hyperest d C": Dve- P_tivitiss Which Lmcrz=sa PaLn: to d P=r; vi ties Welch Lec=e._se Perin: lu t. u I • Diaspns-ic Tes`ino• .P:ati_oLs mv.a= py Effect' o r ?/ I Medication s : \_?' Q 3 i rcisa: Faysicel z^.eran ow xuc? d ` ?.. TFN; • ha r Ctu- Bi0f2°_CJr Ne_ve Blocks : wou-c v Ccher: b - r. ?? ,. ? Sleep: p,? _ { Appetite: o, Cia-zes in Fhysica? ?rtivity: pa• ,u4 . a i l ,?N^' d 4 !u ?- Eq3loy??t: ;A3 Liti.oatict/Co®alsati ca: - L G . '\ Eattionz Asti =s : ti D c MR s gav.993 PROGRESS REPORT ? -mss PROGRESS REPORT 1jyf?? A .L Datelrme PROGRESS NOTES: (Include Name, Title) ffil 2 Current Medications: C 1e Wies: Past History: Medical: e % 3 S=Zical Faz1 - Cr ' Social: - Ptn sic l Ex?a cad - e 2C - 677 •3l. dor-10 ?` 11, 4 s s Sup--U & s " Qb?v ?o [tWoUtc7r M?+s s diicw(?c Vtc o a ,' 8L s 5 1?' o-c. c Ix nL n ec?s asses es c ava vi I "`v co?[3tive? i I other deficits ciuicn i©'Pl*r ability to lea-m? yes n0 (if Yes, identify ) I Impression l wic s 5 U I 4? I - I Plan ,? ° ' The above plan was'discussed with the patient He/She verbalizes " umderstm.di*ns and asrees to the plan yes no ?T • ,6L kuj? wu 1 „L PROGRESS REPORT :.40 MR 8 Ray. 7195 Signam=e AtNoV 2-9;1999 ?>V ue.. - PennState Ge- ?kger Health System OUTPATIENT SERVICES REGISTRATION 9 SINT 080 ST VE 10/08/98 11:00 ANE PMGT F REFERRING PHYSIC" CIATES COMMUNITY ME:ROGRES:-?A E 3601 NORTH P HARRISBURG 17 11.0 52-7266 INSURANCE INFOR U1617 717-6MA TION STATE FARM STATE FARM NO V 2 9 1999 rlr???VtU TENT SSN HOME PHONE NUMBER 8-46-1248 717-985-IL.'36 PATIENT BIRTH PLACE PA 12/21/ H 208•-46•-124 RS ADDRESS 1 CHERRY STREET 717-985•-1656 HIGHSPIRE P AB COMMUNITY MEDICAL ASSOCIATES 3601 NORTH PROGRESS AVE HARRISBURG PA J.7110 717-652-7266 0161% 1.2221998 112418 GULL.O. GREGO 9 e S s s ICYI v^ " ?w® i d 0 Q 1 d -W? TRISTAN ASSOCIATES 4518 UNION DEPOSIT RD HARRISBURG PA 17111 Phone (717)652-6105 TRISTAN ASSOCIA% 4518 UNION DEPOSIT RD HARRISBURG PA 17111 Phone (717)652-5840 Fax (717)652-8152 PRACTICE LIMITED TO RADIOLOGY SS# 208461248 trd192285 Name SOBOTOR SUSAN E Age 43 Address 229 CHERRY STREET HIGHSPIRE PA 17034 Ref Phys CEO CLEARY PAC/OR BRYAN Code F198701 Exam Date February 17, 1998 Exam MRI OF CERVICAL SPINE CLINICAL HISTORY: Pain both shoulders radiating to both arms with right hand numbness since DEC 1997. Whiplash injury on 22 DEC 1997. TECHNIQUE: SAGITTAL: SE Tl, TSE T2, TSE PO TRANSVERSE: 20 FL, 30 FISP cervical Noy focal herniated with minimal DIAGNOSIS: Mild r nucleus pulposus. Minimal bilateral neural foraminal encroachment C5-C6. Severe neural foraminal encroachment on the left at C3-C4. COMMENT: The study was correlated with the plain radiographs dated 1-23-98. There is straightening of most of the cervical lordotic curve. Mild spondylotic changes are noted at C5-C6 with small osteophytes and minimal bulging annulus. There is mild bilateral neural foraminal encroachment at C5-C6 more on the right. There are degenerative changes in the uncovertebral joints on the left at C3-C4 causing severe encroachment on the neural foramina at this level on the left. The foramina on the right are normal. The remaining cervical foramina are also within spinal canal hat eC55C6n1There mild narrowing ano osignificant central diameter the normal spinal limits. stenosis. No focal herniated nucleus pulposus is seen. The cervical cord is normal in size, shape, and signal. The signal of the visualized bone marrow is also normal. The craniocervical junction is normal. J. 0. Bahia, M. D. JOB maf Sent by: TRISTAN ASSOCIATES .ate 7176522105, 02/0,1/99 6:,16A)1;Jetrx p25,1;Page 3/6 -Auk U2: 1111 PM %Y# U2/ TRISTAN ASSOCIATES TRISTAN ASSOCIATES 4510 UNI0.4 DEPOSIT RD 4518 UNInN DEPOSIT RD 11ARRISBUR13 PA 17111 HARRISBURG PA 17111 Phone 17tI)eb2-610-5 Phone (71/1552-5840 Fax (7171852-8152 PRACTICE LIMITED T) RADIOLOGY SSS 206461248 trd188121 Name SOBOT07 SUSAN E Age 43 Addross 229 CF:ERR:1 STREET HIGHSPIRE PA 17034 Ref Phys CEBORF- OLE.ARY PAC/BRYAN Code F194534 Exam Date .ianuarj 23, 1998 Exam CERVICAL SPINE DIAGNOSIS. 1. Mild degenerative changes at c5-6. 2. Nu fracture seen. COMMENT: The C5••6 disc space may be minimally narrowed and there is very minor or early type of anterior and posterior hypertropln:.c chanca. Ilo, or very little, encroachment on the neural fuee:mina is soon, I see no evidence of a compression or nther ty13-9 fracture. Ilo nialalignment is seen. There is good flexion/extension without abnormal motion seen. The dons appears inta--t. Ricnard M. Fencel, M.D. RMF/pem Sent by: TRISTAN ASSOCIATES 7176522165; 02/04199 G:48AE1;Jet{x N254;Pane 6/6 M. 34 PM M uZ733M Vag'e 1 as TRISTAN ASSOCIATES HARRISBURG BREAST DIAGNOSTIC CTR 4518 UNION DEPOSIT RD 4518 UNION DEPOSIT RD HARRISBURG PA 17111 HARRISBURG PA 17111 Phone 17171652-5163 Pnono (717(652-1438 Fax (717)652-9522 June 21, 1897 trd154803 GUNHILDE 3ECK Ro 3601 N PRZIGRESS AVE HARRISBURG PA 17110 RE: SOBOTOR SUSAN E 537 SPRINGHouSE no CAMP HILL PA 17011 SSTs: 209461248 Age: 42 Dear or. Berk: We had the privilege of examining Susan Sobotor at the Harrisburg Breast Diagnostic _enl:er on 6/21/97. There are no palpable masses. D_LL .TERAL HAh.,MOGRA_?HY; There Is dense fibrocystic change in the hreasts Irildterally. Tnere is no focal dominant mass, malignant- appearinq calcification, or skin thickening that would suggest mali.gnariny. No acanopathy is seen. The appearance of the mammagram tics not changed since the previous study dated 6/6/95. SUMMARY: NO evidence of malignancy. Because of the density of the breast tissue, thn importance of routine self examination is Stressed. Thank you for referring your patient to our office. Sincerely, James W. Warren, H. O. JWW/jeb Y--p4 I4ODC L SUSAN SOBOTOR - MEDICAL TREATMENT SUMMARY DATE OF SERV/CE I PROVIDER January 23, 1998 February 10, 1998 February 19, 1,999 Dr. Deb O'Leary Community Medical Assoc Dr. O'Leary Dr. Walter Peppleman February 23, 1998 February 25, 1998 February 26, 1998 March 2, 1998 March 4, 1998 March 6, 1998 March 9, 1998 March 11, 1998 March 16, 1998 March 18, 1998 March 20, 1998 March 23, 1998 March 25, 1998 March 27, 1998 March 30, 1998 April 1, 1998 April 2, 1998 April 20, 1998 May 1, 1998 t lington Rehab inEa ab inb Arlington R ehab Arlington Rehab Arlington Rehab Arlington Rehab Arlington Rehab Arlington Rehab Arlington Rehab Arlington Rehab Arlington Rehab Arlington Rehab Arlington Rehab Arlington Rehab Arlington Rehab Dr. Woods Dr. Woods Dr. Woods TREATMENT OV- Medication Rx 0V - Follow-up/Referral OV- Initial Evaluation/ Referral to Arlington Rehab PT PT PT PT PT PT PT PT PT PT PT PT PT PT PT PT OV - PT follow-up eval. 0V - Follow-up EMG and NC studies June 23, 1998 Dr. Woods OV- Follow-up August 28, 1998 Dr. Beck Community Medical Assoc 0V - Prescrip. for TENS Referral to HMC Pain October 8, 1998 HMC Pain Clinic OV- recomm. TENS unit November 25, 1998 HMC Pain Clinic OV - Follow-up December 14, 1998 HMC Pain Clinic Bone Scan April 20, 1999 HMC Pain Clinic OV- recomm. TENS unit may 19 , 1999 HMC Pain Clinic OV - TENS Unit SUSAN SOBOTOR, V. Plaintiff ANTHONY J. ONOMASTICO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7527 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this ?? day of 2000, I hereby certify that I have, on this date, served the within Amended Notice of Deposition upon the Defendant, by sending a true and correct copy of same to his attorney of record, and including a copy to all parties of interest via first class United States mail, postage prepaid, and addressed as follows: Matthew R. Gover, Esquire Nealon and Gover 301 Market Street, 9" Floor Harrisburg, PA 17108-0865 Date: I Z - / Z - oi; ).;fegory M. Feather, Esquire Attorney for Plaintiff I.D. # 79456 1300 Linglestown Road P.O. Box 1177 Harrisburg, PA 17110-1177 (717) 238-2000 Respectfully submitted, HANDLER, HENNING & ROSENBERG SUSAN SOBOTOR, IN THE COURT OF COMMON PLEAS Pluinlil'f CUMBERLAND COUNTY. PENNSYLVANIA NO. 99-7527 ANTHONY ONOMAS'I'ICO. Dclcndant CIVIL ACTION - LAW JURY TRIAL DEMAND CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of Plaintiffs Request for Production of Documents Directedt o Defendant, Anthony J. Onomastico upon counsel of record on this L day of (-OcLOL? , 2000, by placing the same in the U.S. first class mail, postage prepaid at Harrisburg, Pennsylvania addressed as follows: Matthew R. Gover, Esquire Nealon and Gover 301 Market Street - 91h Floor Harrisburg, PA 17108-0865 Respectfully submitted, HANDLER, HENNING & ROSENBERG Date: IC) to- W By: Gre M. Feather, Esquire I. o. 79456 1300 Linglestown Road P.O. Box 1177 Harrisburg, PA 17110-1177 (717) 238-2000 Attorney for Plaintiff L`?' r?? !„ ? ?' <- c?, --_ ? i ?: ? . ? }? ? _ ?i ? Q ?- ?til ?- Ci Ci 'i ?.l SUSAN SOBOTOR, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7527 ANTHONY ONOMASTICO, Defendant CIVIL ACTION -LAW JURY TRIAL DEMAND CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of Plaintiffs Answers to ?n Defendant's First Set of Interrogatories upon counsel of record on this _L0 day of 2000, by placing the same in the U.S. first class mail, postage prepaid at Harrisburg, Pennsylvania addressed as follows: Matthew R. Gover, Esquire Nealon and Gover 301 Market Street - 911 Floor Harrisburg, PA 17108-0865 Respectfully submitted, HANDLER, IJEIVNING & ROSENBERG Date: IV IU vL) By. regnfy M. eat her, E I. [)M. 79456 319 Market Street P.O. Box 1177 Harrisburg, PA 17108 (717) 238-2000 Attorney for Plaintiff 1? ` f? •? r ? ? !tu _ L ?( U U ... 'r. SUSAN Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7527 ANTHONY ONOMASTICO, Defendant CIVIL ACTION - LAW JURY TRIAL DEMAND CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of Plaintiffs First Set of Interrogatories Directed to Defendant, Anthony Onomastico upon counsel of record on this M' day of 2000, by placing the same in the U.S. first class mail, postage prepaid at Harrisburg, Pennsylvania addressed as follows: Matthew R. Gover, Esquire Nealon and Gover 301 Market Street - 91h Floor Harrisburg, PA 17108-0865 Date: Respectfully submitted, HANDLER, HENNING & ROSENBERG By:. Greg /Feather, Esquire I.D .79456 319 Market Street P.O. Box 1177 Harrisburg, PA 17108 (717) 238-2000 Attorney for Plaintiff L t ? L') _ _)_ ' ? 4. ? ?. i.i .. ., -1 `J i':, _- ? ') ? v _ ;? ?, _ -: .?liU G ???_ L_ (_: ? ') U SUSAN E. SOBOTOR, IN TIME COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANTI-TONY J. ONOMASTICO, No. 99-7527 Defendant PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the above-captioned matter removed Isom the trial list. This case will be listed for arbitration. Respectfully submitted, NEALON AND COVER Date: B v: ° -J , Matthew R. Gover, Esquire Supreme Court ID No. 47593 2411 North Front Street 1-larrisburg. PA 17110 (717) 232-9900 Attorney for Defendant cir ec}fy NILVea her, Esquire upreme Court ID No. 79456 1300 Linglestown Road P.O. Box 1177 I larrisburg, PA 17110-1177 (717)238-2000 Attorney for Plaintiff SUSAN SOBOTOR, IN "riiE coURT OI' CoMNION I)LEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7527 ANTHONY ONOMAS'r?CO. Dclcndant CIVIL ACTION - LAW JURY TRIAL DEMAND CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of a Praecipe to remove from the trial list and list for Arbitration upon counsel of record on this 9-day of 200, by placing the same in the U.S. first class mail, postage prepaid at Harrisburg, Pennsylvania addressed as follows: Gregory M. Feather, Esquire 1300 Linglestown Road P.O. Box 1177 Harrisburg, PA 17110-1177 Respectfully submitted, NEALON and GOVER Date: By: X g2g=- Mat hew R. Gover, Esquire 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Attorney for Defendant ®ndler, enning Fj 1 ®senberg ATTORNEYS AT LAW Leslie B. Handler. Retired W. Scott Henning David H Rosenberg IPA, FLI Carolyn M. Anner IPA, NY, RN) Matthew S. Crosby IPA NJ) Gregory M. Feather IPA, N11 Stephen G. Held Samuel Handler 11922-701 September 26, 2001 Matthew R. Gover, Esq. NEALON & GOVER 2411 N. Front Street Harrisburg, PA 17110 Dale F. Shughart 35 East High St. Suite 203 Carlisle, PA 17013 Gregory H. Knight, Esq. Barry Kronthal, Esq. 19 Brookwood Ave, Ste 106 3410 Trindle Rd. Carlisle, PA 17013 Camp Hill, PA 17011 RE: Susan E. Sobotor v. Anthony J. Onomastico Dear Gentlemen: HARRISBURG OFFICE 1300 Unglestown Road Harrisburg, PA 171 10 717.238.2000 1-800.422.2224 717-233-3029 (fix) LANCASTER OFFICE 140A E King Street Lancaster, PA 17602 717.431.4000 DIRECT MAIL TO: P.O. Box 1177 Harrisburg, PA 17108 www.HHRLaw.com Feather@hhrlaw.com In connection with the above referenced matter, please find enclosed the Plaintiff's Arbitration Memorandum and Medical Treatment Summary. GMF/dml Very truly yours, PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( X ) for JURY trial at the next term of civil court. ( ) for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) ( X) Civil Action - Law Susan Sobotor (Plaintiff) VS. Anthony J. Onomastico (Defendant) VS. ( ) Appeal from Arbitration (other) The trial list will be called on and June 12, 2001 Trials commence on July 9 2001 Pretrials will be held on June 20, 2001 (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) N0.99-7527 Civil 19 Indicate the attorney who will try case for the party who files this praecipe: Matthew R. Gover, Esquire, 2411 North Front Street, Harrisburg, PA 17110 Indicate trial counsel for other parties if known: Gregory M Feather Esquire 1300 Linglestown Road, Harrisburg, PA 17110 This case is ready for trial. Signed i/?lf C V Q Print Name: Matthew R. Gover, Esquire Date: 03/14/01 Attorney for: Anthony J. Onomastico ?®s N n lj uJ Q ) Q.I in n ?-' ? Ill {y., 5 CD U ENEALONCa RAWpL July 12, 2001 Dale F. Shughart, Jr., Esquire 35 East High Street Suite 203 Carlisle, PA 17013 RE: Sobotor v. Onomastico Arbitration Dear Mr. Shughart: This is in reply to your letter of July 9, 2001. 2411 NORTH FRONT STREET HARRISBURG, PA 17110 TELEPHONE (717) 232-9900 FACSIMILE (717) 236-9119 MATnirw R. GOVER m;,ovcr n•Hrllon-govel'"111 It is the intention of both the defense as well as the Plaintiff to present the parties to the accident. It is my understanding that given this presentation of testimony, you will not require records submitted in advance. Very truly yours, N R , P.C. aw . Matthew R. Gover MRG:sls cc: Gregory M. Feather, Esquire F*---..1-.- DALE F. SHUGHART, JR. ATTORNEY AT LAW 35 EAST HIGH STREET SUITE 203 CARLISLE, PENNSYLVANIA 17013 Telephone (717) 241.4311 Facsimile (717) 241-4021 OF COUNSEL LEGAL ASSISTANT HAMILTON C. DAVIS BONNIE L. COYLE July 9, 2001 Gregory M. Feather, Esquire Matthew R. Gover, Esquire 1300 Linglestown Road 2411 North Front Street P. O. Box 1177 Harrisburg, PA 17110 Harrisburg, PA 17110-1177 RE: Sobotor v. Onomastico Arbitration Dear Mr. Feather and Mr. Gover: The above captioned arbitration, for which the Notice of Hearing is enclosed, is a motor vehicle/personal injury case. I anticipate you will have agreed upon medical records to be submitted by Stipulation, or alternatively, under the Rules governing arbitration. I request that a copy of such records as will be admitted into evidence be submitted to me at least twenty (20) days prior to the date of the hearing. I will circulate the documents to the other two arbitrators. Please do not expect us to be prepared to hear and decide the case if you do not submit this information to us in advance. If you will be having live witnesses, showing videotapes, or having someone read physician's depositions, please advise me, and do not send us any information in advance. Thank you for your cooperation. Very truly yours, Dale F. Shughart, Jr. DFS,JR/bc Enclosure cc Gregory H. Knight, Esquire Barry Kronthal, Esquire ndl¢e, anning ? Psenberg- ATTORNEYS AT LAW Leslie B. Handler, Retired W. Scott Henning David H Rosenberg IPA, FLI Carolyn M. Anne( IPA NY, RN) Matthew S. Crosby IPA, NJ) Gregory M. Feather IPA NJ) Stephen G. Held Samuel Handler 11922.701 September 13, 2001 Matthew R. Gover, Esq. NEALON & GOVER 2411 N. Front Street Harrisburg, PA 17110 Dale F. Shughart 35 East High St. Suite 203 Carlisle, PA 17013 RE: Susan E. Sobotor v. Anthony J. Onomastico Cumberland County No.99-7527 Dear Mr.Shughart HARRISBURG OFFICE 1300 Linglestown Road Harrisburg, PA 17110 717-238.2000 1.800-422.2224 717-233.3029 (fax) LANCASTER OFFICE I40A E King Street Lancaster, PA 17602 717-431.4000 DIRECT MAIL TO: P.O. Box 1177 Harrisburg, PA 17108 www.HHRLaw.com Feather@hhrlaw.com In connection with the above referenced matter, please find enclosed three (3) sets of the Plaintiffs Exhibits in regards to the arbitration hearing scheduled for October 3, 2001. Thank you for your attention to this matter. GMF/dml cc: Susan E. Sobotor Very truly yours, DALE F. SHUGHART, JR. ATTORNEY AT LAW 35 EAST HIGH STREET SUITE 203 CARLISLE, PENNSYLVANIA 17013 Telephone (717) 241.4311 Facsimile (717) 241-4021 OF COUNSEL HAMILTON C. DAVIS September 14, 2001 LEGAL ASSISTANT BONNIE L. COYLE Gregory H. Knight, Esquire Barry Kronthal, Esquire 19 Brookwood Avenue, Suite 106 3510 Trindle Road Carlisle, PA 17013 Camp Hill, PA 17011 RE: Susan E. Sobotor v. Anthony J. Onomastico Arbitration - October 3, 2001 Gentlemen: Enclosed are copies of Plaintiff's Exhibits for the October 3 arbitration. Very truly yours, Dale F. Shughart, Jr. DFS,JR/bc Encloses u5uv, 50bt4pa i Vh?S 1U0 ) oars In The Court of Common Pleas of Cumberland County, Pennsylvania No. ? q , 75 k -) 19 We do solemnly swear (or affirm) chat we will support, obey and defend the Constitution of the United States and the Constitution of this Common- wealth and that we will discharge the duties of our AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: Arbitrator, dissents applicable.) Date of Hearing: Date of Award: p NOTICE OF MMY 0Y AWARD (Inser„F name if Now, the,34"?ay of , W?1, at/pLa, the above award was entered upon the docket and-notice thereof given by ail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: (Note: If damages for delay are awarded, they shall be separately stated.) AA e m 3l Lc`, ?S J IP&- 9,7k,"t a&.E? oft SUSAN E. SOBOTOR, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 7627 Civil 1999 V. CIVIL ACTION - LAW ANTHONY J. ONOMASTICO, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the above-captioned matter settled, discontinued and satisfied. HANDLER MENIMIG & DATE: l D 3/ d ,Greg M. Fdather l sq. 1300 mglestown Rd. -P. Box 1177 Harrisburg, PA 17108 Tel. No.: 717-238-2000 Supreme Court ID No. 79456 Attorneys for Plaintiff 4:? _:., ?, ,. ' j ?? ?? ?= ?.u`.'. iv ??:` ? c.. ,: - ri'<. ? _ ?i ? >. _ `! ? ? _ ° _. ir. c' ?uci :JL - c. ? .^? "'7 U s, i ?'? ?, ??: i. i '? r' ; 'S `; '?^'? aiw??a ?w®? ?l