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HomeMy WebLinkAbout03-4447IMAGF TROY A FOSTER, Plaintiff JUAN JIRAL, Defendant IN THE COU. RT OF QOMMON PLEAS DAUPHIN.coUNTy, PENNSYLVANIA NO. 261 ]'CV 2oo3-C'v"----. ORDER AND NOW, this / tday of August, 2003, upon consideration of the attached Joint Stipulation of Counsel, the Prothonotary is directed to transfer this case to the Court of Common Pleas of Cumberland County. Distribution: David L. Lutz, Esquire, 4503 North Front Street, Harrisburg, PA 17110 Andrew C. Lehman, Esquire, 2411 North Front Street, Harrisburg, PA 17110 Stephen Farina, Dauphin County Prothonotary Curt Long, Cumberland County Prothonotary, One Courthouse Square, Carlisle, PA 17013-3387 TROY A. FOSTER, Plaintiff, V. JUAN JiRAL, Defendant. iN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO.: 2003-CV-2611-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED JOINT STIPULATION OF COUNSEL AND NOW, come the parties, by and through their respective ~,sel,~ho:::: hereby stipulate that the above-captioned action has proper venue in the ~ount~of crt Cumberland, Pennsylvania. Therefore, the undersigned heretofore requests this Honorable Court transfer the within action to the Cumberland County Court of Common Pleas. Respectfully subrn'~d, By: David t s ire Harrisburg, PA 17110 717/238-6791 -Counsel for Plaintiff Respectfully submitted, NEALON & GOVER, P,C. By: Andrew C. Lehman, I.D. #: 81937 2411 North Fron[ Street Harrisburg, PA 17110 717/232-9900 Counsel for Defendant - TROY A. FOSTER, Plaintiff, V. JUAN JIRAL, Defendant. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO.: 2003-CV-2611-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER Based upon the Joint Stipulation of Counsel, IT IS HEREBY ORDERED that the above-captioned matter is transferred to Cumberland County for proper venue. Any costs to initiate and/or file this action in the Cumberland County Court of Common Pleas shall be borne by Defendant. BY THE COURT: Distribution: Cumberland County Prothonotary's Office (with enclosed Pleadings to date) David L. Lutz, Esquire, 4503 North Front Street, Harrisburg, PA 17110 Andrew C. Lehman, Esquire, 2411 North Front Street, Harrisburg, PA 17110 Date: 8/29/2003 Time: 02:01 PM Page 1 of I Dauphin County ReA Report Case: 2003-CV-2611-CV Current Judge: No Judge Troy A Foster vs. Juan Jiral Civil User: LGARCIA Date 6/13/2003 7/3/2003 7/18/2003 8/15/2003 8/19/2003 8/29/2003 Judge New Civil Case Filed This Date. No Judge Plaintiff: Foster, Trey A Attorney of Record: David L Lutz No Judge Filing:Complaint Paid by: Lutz, David L (attorney for Foster, Troy A) No Judge Receipt number: 0036589 Dated: 6/13/2003 Amount: $105.00 (Check) Complaint reinstated. See Praecipe, filed. No Judge Complaint: Sheriff's Return filed stating service was completed. So No Judge answers J.R. Lotwick, Sheriff. Juan Jiral Assigned to Dauphin Co Sheriffs Office Service fee $43.25 Served 7/18/2003 Joint stipulation of counsel, filed Upon consideration of the attached Joinit Stipulation of Counsel, the Prothonotary is directed to transfer this case to the Court of Common Pleas of Cumberland County. See ORDER filed. Copies Dist. 8-19-03. The above case is hereby Transfer to the Court of Common Pleas of No Judge Cumberland County. ****NO MORE ENTRIES CASE TRANSFERRED**** No Judge TO CUMBERLAND COUNTY COURT OF COMMON PLEAS No Judge Richard A. Lewis I hereby certi~j that th~ fgreg0ing is a, true and correct co~yf~f the 0ril3inat Iited. { ~ . Proth~no~ry TROY A. V. JUAN JIRAL, Defendant. IN THE COURT OF DAUPHIN COUNTY NO.: 2003-CV-:-- CIVIL ACTI, - LAW DEMANDED .-< ORDER Based upon the Joint Stipulation above-captioned matter is costs to initiate and/or file this ac in thc shall be borne by Defendant unsel, iT iS HEREBY ORDERED that the rland County for proper venue, Any County Court of Common Pleas Re AN( By.. Cumber~ David Andr County, Prothonotary's Office (with enclosed Pleadings to 4503 North Front Street, Harrisburg, PA 17110 C. Lehman, Esquire, 241 'i North Front tStree~, Harrisburg, PA TROY A. FOSTER, Plaintiff, V. JUAN JIRAL, Defendant. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO.: 2003-CV-2611-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED JOINT STIPULATION OF COUNSEL 3> ~ AND NOW, come the parties, by and through their respective (;~sel,~.who , : hereby stipulate that the above-captioned action has proper venue in the~'-~ou~ of Cumberland, Pennsylvania. Therefore, the undersigned heretofore requests this Honorable Court transfer the within action to the Cumberland County Court of Common Pleas. Respectfully subm&ed, Harrisburg, PA 17110 717/238-6791 Counsel for Plaintiff Respectfully submitted, NEALON & GOVER, P.C. By: Andrew C. Lehman, ~ I.D. #: 81937 2411 North From Street Harrisburg, PA 17110 717/232-9900 Counsel for Defendant TROY A. FOSTER, Plaintiff 1N THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PA CIVIL ACTION - LAW JUAN JIRAL, Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days afl.er this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. DAUPHIN COUNTY LAWYER'S REFERRAL SERVICE 213 North Front Street Harrisburg, Pennsylvania 17101 (717) 232-7536 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o pot abogado y archivar en la corte en forma ascrita sus defensas o sos objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previn aviso o notificacinn y por cualquier queja o alivio que es pedido en la peticinn de damanda. Usted pueda perdar dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFIC1ENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. DAUPHIN COUNTY LAWYER'S REFERRAL SERVICE 213 North Front Street Harrisburg, Pennsylvania 17101 (717) 232-7536 261504.1 \MTG\LC3 TROY A. FOSTER, Plaintiff JUAN JIRAL, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PA CIVIL ACTION - LAW NO. Cox/ JURY TRIAL DEMANDED COMPLAINT 1. mlaintiffTroy A. Foster is an adult individual and a citizen of the C~nw~th __ Pennsylvania who resides in Camp Hill, Pennsylvania. 2. Defendant Juan Jiral is an adult individual who resides at 684 South Second Street, Steelton, Dauphin County, Pennsylvania, 171 l 3. 3. The facts and occurrences hereinafter related took place on or about November 21, 2002, at approximately 11:15 a.m. at the intersection of Gettysburg Road and Zimmerman Drive near the Capital City Mall in Cumberland County, Pennsylvania. 4. At that time and place, it was raining. 5. At that time and place, Mr. Foster was operating his 1991 Acura Integra on Gettysburg Road and was stopped at a traffic light at the intersection of Gettysburg Road and Zimmerman Drive. There was a Ford Explorer in fi~ont of him, and there were approximately two cars behind him. 6. At the same time and place, the Defendant was operating a 1992 Honda owned by Arturo Acevado on Gettysburg Road. 7. The Defendant failed to stop his vehicle in time to avoid hitting the vehicle in f~ont of him. 261504. IhMTG\LC3 8. The Defendant's Honda struck the vehicle in front of it w/th such force that it caused a chain collision. The chain collision caused the vehicle behind Mr. Foster's Acura to strike the Acttra and caused it to push the Acura into the Explorer that was stopped in front of the Acura. 9. The aforesaid collision and all of the injuries and damages set forth hereinafter sustained by the Plaintiff are the direct and proximate result of the negligent, careless, wanton, and reckless manner in which the Defendant operated his vehicle as follows: a) failure to keep alert and maintain a proper and adequate watch for the presence of other vehicles on the roadway; b) failure to keep a proper distance between vehicles so as to be able to stop in the assured clear distance ahead; c) driving too fast for road conditions; and d) driving a vehicle in a manner endangering persons and property and in a reckless manner with careless disregard for the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 10. As a result of the aforementioned accident, Mr. Foster sustained painful and severe injuries which include, but are not limited to neck pain, shoulder pain, back pain, numbness and tingling in his left arm, muscle spasms in his neck, loss of range of motion in his left arm, straightening of cervical lordosis, and tendemess on the left side of his cervical spine. 11. Because of the aforesaid injuries, Mr. Foster was forced to incur liability for medical treatment, physical therapy, medications, and similar miscellaneous expenses in an effort to restore himself to health, and a claim is made therefor. 12. Because of the nature of his injuries, Mr. Foster has been advised and therefore avers that he may be forced to incur similar expenses in the future, and a claim is made therefor. 261504.1 ~ITG\LC3 2 VERIFICATION I, Troy A. Foster, Plaintiff, have read the foregoing COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are tree and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. WITNESS: Dated: 26150& 1 \MTG\LC3 ~[NSTAT~ CON~PEA]NT Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sh~xiff Commonwealth of Pennsylvania County of Dauphin AND NOW:July 18, 2003 Sheriff's Return No.2611-CV - - -2003 at i:20PM served the within COMPLAINT upon (YORK CO) to DEFENDANT by personally handing 1 true attested copy(ies) of the original COMPLAINT and making known to him/her the contents thereof at YORK COUNTY SHERIFF'S OFFICE 28 EAST MARKET ST YORK, PA 17401-0000 So Answers, Sheriff of Dauphin County, Pa. Plaintiff: FOSTER TROY A Sheriff's Costs: $43.25 PD 06/13/2003 RCPT NO 179693 IMAGED TROY A. FOSTER, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COLrNTY, PA JUAN JIRAL, Defendant CIVIL ACTION - LAW NO. 2003-CV-2611-CV JURY TRIAL DEMANDED PRAECIPE ~ -c To the Prothonotary of Dauphin County: Please reinstate the attached Complaint and forward same to the Sheriff with the Sheriff's Directions for service on the Defendant. Date: ANGINO & ROVNER, P.C. LD. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiff 262934.1~DLL~VlTG TROY A. FOSTER, Plaintiff, JUAN JIRAL, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 200:3.4447 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Troy A. Foster, and his attorney, David L. Lutz, Esquire ANGINO & ROVNER, P.C. 4503 North Front Street Harrisburg, PA 17110 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, P.C. Date: Andrew C. Lehman, Esquire I.D. #: 81937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 TROY A. FOSTER, Plaintiff, JUAN JIRAL, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 200:3-4447 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER 1. Admitted upon information and belief. 2. Denied as stated. However, it is admitted tllat Defendant Juan Jiral is an adult individual who currently resides at 261 West Market Street, Apartment 3, York, PA 17404. 3.-4. 5.-8. Admitted. Denied as stated. However, it is admitted that on November 21, 2002, at approximately 11:15 a.m., Defendant was operating a 1992 Honda owned by Arturo Acevado on Gettysburg Road. It is further admitted that as Defendant approached traffic in front of him, he was unable to stop in time to avoid his vehicle coming into contact with the vehicle in front of him. Including Defendant's vehicle, there were four vehicles involved in this chain reaction accident. However, Defendant is without sufficient information or knowledge to admit which vehicle Mr. Foster was occupying at the time of the accident. Any remaining averments contained in these Paragraphs are denied pursuant to Pa.R.C.P. 1029(e). 9. This Paragraph and all its subparts are denied pursuant to Pa.R.C.P. 1029(e). 10.-16. 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. Any remaining averments contained in these Paragraphs are denied pursuant to Pa.R.C.P. 1029(e). NEW MATTER 17. Paragraphs 1 through 16 are incorporated herein by reference thereto as if set forth at length. 18. Plaintiff's claims may be barred in whole or in part by operation of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Defendant, Juan Jiral, respectfully requests the within Complaint be dismissed with costs as allowed by law. Respectfully submitted, NEALON & GOVER, P.C. Date: ?--//~ 6.Y Andrew C. Lehman, Esquire I.D. #: 81937 2411 North Front Street Harrisburg, PA 17110 717/232-~c~900 2 VERIFICATION I, JUAN JIRAL, verify that the statements made in the foregoing ANSWER WITH NEW MATTER 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 unswom falsification to authorities. Date: ~-~"'-4~3 t~ ~'-u'd~'~'~ 7J"1~¢'('/-I JUAN JIRAL CERTIFICATE OF SERVICE AND NOW, this ~ day of September, 2003, I hereby certify that have served the foregoing ANSWER WITH NEW MATTER on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David L. Lutz, Esquire ANGINO & RQVNER, P.C. 4503 North Front Street Harrisburg, PA 17110 Andrew C. Lehman, Esquire TROY A. FOSTER, Plaintiff JUAN JIRAL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 2003-4447 JURY TRIAL DEMANDED PLAINTIFF'S REQUEST FOR ADMISSIONS TO DEFENDANT - SET NO. 1 To: Defendant Juan Jiral, by and through his attorney Andrew Lehman, Esquire Please take notice that you are hereby required, pursuant to Rule 4014 of the Pennsylvania Rules of Civil Procedure (Federal Rules of Civil Procedure 36), to serve upon the undersigned within thirty (30) days from service, your response to the admission(s) requested herein: 1. Do you admit that on November 21, 2002, you were involved in a motor vehicle accident at the intersection of Gettysburg Road and Zimmerman Drive, Cumberland County, Pennsylvania? Admit __ Deny ____ 2. Do you admit that you were operating a 199:2 Honda on Gettysburg Road and failed to stop your vehicle in time to avoid hitting the vehicle in front of your vehicle? Admit __ Deny Date: ~ ,-- 1<2) -' ~)~ ANG1NO & ROVNER, P.C. Dl&i" TLutz I.D. No. :15956 4503 N. Front Street Harrisburg, PA 17110 (717) 238.-6791 Attorney for Plaintiff 265742.1 ~DLLWiTG CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Pmgino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PLAINTIFF'S REQUEST FOR ADMISSIONS TO DEFENDANT - SET NO. 1 upon all cotmsel of record via postage prepaid first class United States mail addressed as follows: Andrew Lehman, Esquire 2411 North Front Street Harrisburg, PA 17110 Attorney for Defendant Dated: ~ 1~ ~)~ 265742.1\DLL~vlTG IN THE MATTER OF: TROY A. FOSTER CERTIFICATE PREREQUISITE TO SERVICE OF A SL~BPOENA PURSUkNT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, JUAN JIRAL -VS - CASE NO: 2003-CV-2611-CV AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including ti~e proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/04/2003 A~W behalf of ~ ~ C. LE Attorney for ~FENDANT ~/ DEll-455282 3 3 1 2 7 --LO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN IN THE MATTER 0F: TROY A. FOSTER JUAN JIRAL -VS - COURT 0F COMMON PLEAS TERM, CASE NO: 2003-CV-2611-CV NOTICE OF I~'£~qT TO SERVE A SUBPOENA TO PRODUCE DOcuMENTS AND THII~ FOR DISC~)VERY PIIRSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ORTHO SURGEONS OF CENTRAL PA QUANTUM IMAGING & THERA. ASSOC JOYNEE SPORTS MEDICINE MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS& XRAYS MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that in attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/15/2003 CC: ARDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03459 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244902 3 3 12 7 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN TROY A. FOSTER .. -VS- JUAN JIRAL : File No. 2003-CV-2611-CV TO: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED MCS GROUP INC, 1601 MARKET STREET, STE 800 , PHILA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or p~oducing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN, ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG PA 17110 TELEPHONE: (215)246-0900 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE: 11/4/2003 Seal of the Court Proth. - 73 the Court: Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 33127 TROY A. FOSTER Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, ties, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medicanon, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-469140 3 3 1 2 7 --LO 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSU~IT TO RULE 4009.22 IN THE MATTER OF: TROY A. FOSTER COURT OF COMMON PLEAS TERM, JUAN JIRAL -VS - CASE NO: 2003-CV-2611-CV AS a prerequisite to service of a subpoena for documents and thin§s pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/04/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-455283 3 3 1 2 7--LO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN IN THE MATTER OF: TROY A. FOSTER JUAN JIRAL -VS - COURT OF COMMON PLEAS TERM, CASE N0: 2003-CV-2611-CV NOTICE OF IB'r~NT TO SERVE A SubPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISC0~KY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ORTHO SURGEONS OF CENTRAL PA QUANTUM IMAGING & THERA. ASSOC JOYNER SPORTS MEDICINE MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/15/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03459 NCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE NCS GROUP INC. 1601 MARKET STREET #000 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244902 3 3 12 7--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN TROY A. FOSTER -VS- JUAN JIRAL File No. 2003-CV-2611-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL (Name of Person or Entity) V~thin twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC, 1601 MARKET STREET, STE 800 , PHILA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or p~:oducing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAiq, ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG PA 17110 TELEPHONE: (215)246-0900 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE: 11/4/2003 Seal of the Courl Proth. - 73 By the Court: Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21 ST STREET CAMP HILL, PA 17011 RE: 33127 TROY A. FOSTER Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SUI0-469142 33 12 7--L02 C~RTI?IC~TE PREREOUISITE TO SERVICE O~ A SUBPORNA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TROY A. FOSTER COURT OF COMMON PLEAS TERM, JUAN JIRAL -VS- CASE NO: 2003-CV-2611-CV AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/04/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-455284 3 312 7--LO3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN IN THE MATTER 0F: TROY A. FOSTER JUAN JIRAL -VS- C0URT OF COMMON PLEAS TERM, CASE N0: 2003-CV-2611-CV NOTICE OF I~'r~lT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL ORTHO SURGEONS OF CENTRAL PA QUANTUM IMAGING & THERA. ASSOC JOYNER SPORTS MEDICINE MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS NEDICAL RECORDS & XRAYS MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/15/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03459 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244902 3 3 12 7--CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN TROY A. FOSTER -VS- JUAN JIRAL File No. 2003-CV-2611-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ORTHO SURGEONS OF CENTRAL PA (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC, 1601 MARKET STREET, STE 800 , PHILA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN, ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG PA 17110 TELEPHONE: (215)246-0900 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT DATE ' 11/4/2003 Seal of the Court Proth. - 73 I Prothono~-y Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHO SURGEONS OF CENTRAL PA 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE: 33127 TROY A. FOSTER INCLUDING DIAGNOSTIC FILMS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, fries, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray f'flms and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-469144 33 12 7--L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-CV-2611-CV JUAN JIRAL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/04/2003 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-455285 3 3 1 2 7 --LO4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN IN THE MATTER OF: COURT 0F C0MMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-CV-2611-CV JUAN JIRAL NOTICE OF INT~TT ~) SER%q~ A SUBPOENA TO PRODUCE D~S AND ~-NGS FOR DISC-~)%~RY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL X-RAY ONLY ORTHO SURGEONS OF CENTRAL PA MEDICAL RECORDS & XRAYS QUANTUM IMAGING & THERA. ASSOC MEDICAL RECORDS & XRAYS JOYNER SPORTS MEDICINE MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/15/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03459 PATRICIA HOFFMAN Any questions regard/ng this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244902 3 3 1 2 7 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN TROY A. FOSTER ' -VS- : File No. 2003-CV-2611-CV JUAN JIRAL .. : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING & THERA. ASSOC (Name of Person or Entity) Within twenty (20) days afar service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC, 1601 MARKET STREET, STE 800 , PHILA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or p~:oducing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN~ ESQ. ADDRESS: 2411 N. FRONT STREET T-IA'R'RTRRURG PA 1711 TELEPHONE ' (215)246-0900 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT By the Cou~~ {~__~, DATE ' 11/4/2003 · SealoftheCouzt ] -- Prothono~a~ / · Proth. - 73 Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING & THERA. ASSOC 405 ST. JOHN CHURCH RD. CAMP HILL, PA 17011 RE: 33127 TROY A. FOSTER INCLUDING DIAGNOSTIC FILMS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items ~as. may be stored in a computer database or otherwise in electronic torm, re~atmg to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-469146 3 3 1 2 7 --LO 4 CERTIFICATE PREREQUISITE TO SERVICE 0F A SUBPOENA PURSUANT T0 RULE 4009.22 IN THE MATTER 0F: COURT 0F COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-CV-2611-CV JUAN JIRAL As a prerequisite to service of a subpoena for documents and thin§s pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will' be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/04/2003 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-455286 3 3 12 7 --LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN IN THE MATTER OF: COURT 0F COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE N0: 2003-CV-2611-CV JUAN JIRAL NOTICE OF I~T~NT TO SERVE A SUBPOENA TO PRODUCE DOcuM]~TTS AND THINGS FOR DISCOVERY FuKSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL X-RAY ONLY ORTHO SURGEONS OF CENTRAL PA MEDICAL RECORDS & XRAYS QUANTUM IMAGING & THERA. ASSOC MEDICAL RECORDS & XRAYS JOYNER SPORTS MEDICINE MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/15/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03459 PATRICIA HOFFMAN Any questions regard/ng this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-244902 33 12 7--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN TROY A. FOSTER : -VS- : : ~ile No. 2003-CV-2611-CV JUAN JIRAL : : : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: JOYNER SPORTS MEDICINE (Name of Person or Entity) '~thin twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC, 1601 MARKET STREET, STE 800 , PHILA PA 19103 (Address) You maY deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or pioducing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the paxty serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN, ESQ. ADDRESS: 2411 N. FRONT STREET gARRY RRT1R~. PA 17110 TELEPHONE' (215)246-0900 ATTORNEY FOR: DEFERDANT By the Court.',4 _ / DATE ' 11/4/2003 · se~a of the Cou,~ I Prothono%/ _ ~ Proth. - 73 6/ -- Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOYNER SPORTS MEDICINE 875 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 33127 TROY A. FOSTER Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical f'fle, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, fries, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-469148 33 127--L05 CRRTIFICATR PRRREOUISITR TO SRRVICE OF A SUBP0gNA PURSUANT TO RULR 400~.22 IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serw~ the subpoena. DATE: 11128/2003 ANDREW C. LEH~, ESQ. Attorney for ~fEFENDANT DEll-459944 35 971--LO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBE~RLAND IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL NOTICE OF INT~TT TO SERVE A SUBPOENA TO PROnUCE IK)CUMI~FfS AND 'I'~/_NC~S FOR DISCOVERY PURSUANT TO Rr~.R 4009.21 SUSQUEHANNA VALLEY PAIN MGMT. MEDICAL RECORDS & XRAYS EOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL X-RAY 0NLY JOYNER SPORTS MEDICINE MEDICAL RECORDS & XRAYS ORTHO. SURGEONS 0F CENTRAL PA. MEDICAL RECORDS & XRAYS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/07/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03459 PATRICIA HOFFMAN - Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-247207 3 5 9 7 1--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TROY A. FOSTER : : File No. 2003-4447 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.29 TO: Custodian of Records for SUSOUEHANNA VALLEY PAIN MGMT. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by' the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grouts_ Inc.. 1601 Market Street_ Suite 800. Philadelnhia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the document3 or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. I,EI4MAN, ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 171 lO TELEPHONE: (215'1246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: thonotary/Clerk, ~2ivil ~iv~--- Date: _.a/L~ ~. /~. -9 ~e'~.~ Deputy $ Seal of the Court 35971-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SUSQUEHANNA VALLEY PAIN MGMT. 2025 TECHNOLOGY PKWY SUITE 201 MECHANICSBURG, PA 17050 RE: 35971 TROY A. FOSTER INCLUDING DIAGNOSTIC FILMS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic File, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, Files, memoranda, handwritten notes, history and physical reports, medication/presc.ri, ption records, medical billing and payment records, x-ray Films and tests wit~ subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electro~c form, relating to any examination, consultation, diagnosis, care or treamaent pertaining to: ~ua~j.es Requested: upto and including the present. ect: TROY A. FOSTER - 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-473176 3 5 9 7 1 --LO 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER 0F: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/28/2003 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-459945 3 5 9 7 1 --LO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL NOTICE OF Il~T~d~T T~) SER%/E A SUBPO]~q ~) PRODUCE DOCu~S ~ 'I'a3_NGS P~)H DISC~Y ~u~(SUANT ~) RDT~ 4009.21 SUSQUEHANNA VALLEY PAIN MGMT. MEDICAL RECORDS & XRAYS HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL X-RAY ONLY JOYNER SPORTS MEDICINE MEDICAL RECORDS & XRAYS ORTHO. SURGEONS OF CENTRAL PA. MEDICAL RECORDS & XRAYS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/07/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03459 PATRICIA HOFFMAN Any questions regard/ng this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-247207 3 5 9 7 1 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TROY A. FOSTER : : File No. 2003-4447 VS. : SUBPOENA TO PRODUCE DOCUMENTS OR THING~ FOR DISCOVERY PURSUANT TO RULI~, 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun. Inc.. 1601 Market Street. Suite 800. Philatt~lphia. PA 1910;3 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEItMAN, ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: othonotary/Clerk, Civil Division~ Date: Deputy Seal of the Court 35971-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 35971 TROY A. FOSTER Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, re, lat.ing, to ~y ,examination, consultation, diagnosis, care, treatment, aoxmsslon, a~scnarge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social .Se_c. urity #: 172-60-1821 Date of Birth: 05-19-1967 SU10-473178 35971--L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSU~ TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS~ CASE NO: 2003-4447 JUAN JIRAL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/28/2003 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-459946 3 5 9 7 1 --LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL NOTIC~ OF I~T~NT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS ANm, '£n/-N~S FOR DISCOVERy PURSUANT TO ~rrr.~ 4009.21 SUSQUEHANNA VALLEY PAIN MGMT. MEDICAL RECORDS & XRAYS HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL X-RAY ONLY JOYNER SPORTS MEDICINE MEDICAL RECORDS & XRAYS ORTHO. SURGEONS OF CENTRAL PA. MEDICAL RECORDS & XRAYS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/07/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03459 PATRICIA HOFFMAN _ Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHII~J)ELPHIA, PA 19103 (215) 246-0900 DE02-247207 3 5 971--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TROY A. FOSTER : : File No. 2003-4447 JUAN JIRAL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2? TO: Custodian of Records for HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** E E **** ' at. The MCS Groun. Inc.. 1601 Market Street. Suite 800, Philadelvhia. PA 19105 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the fight to seek, in advance, the reasonable cost of prepafing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREw C. LEHMAN, ESQ. ADDRESS: 2411 N. FRONT STREET ~HARRISBURG. PA 17110 TELEPHONE: (215) 246~0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Proth~n~t,~ry/Clerk, ~i~il~ws~ Date: _ ~ ~1 _,~_tE~t~ Deputy Seal of the Court 35971-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 35971 TROY A. FOSTER INCLUDING ANY AND ALL DIAGNOSTIC STUDIES Please call for prior approval for fees in excess of $I00.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in pertaining to:a computer database or otherwise in electronic form, ~ua, t.es Re. qu._~_te_d: up to and including the present. bject. TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-473180 3 5 9 7 1 --LO 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PUBSU;LNT TO RULE 4009.22 IN THE MATTER OF: COURT OF C0MMON PLEAS TROY A. FOSTER TERM, -VS- CASE N0: 2003-4447 JUAN JIRAL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice Of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/28/2003 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-459947 3 5 9 7 1 --LO 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL NOTICE OF INT~FT TO SERVE A SUBP~,-~ TO PRODUCE DOCUMENTS AND · rHJ-NGS FOR DISCO~¥ ~ TO RULE 4009.2] SUSQUEHANNA VALLEY PAIN MGMT. MEDICAL RECORDS & XRAYS HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT ROSPITAL X-RAY ONLY JOYNER SPORTS MEDICINE MEDICAL RECORDS & XRAYS ORTE0. SURGEONS OF CENTRAL PA. MEDICAL RECORDS & XRAYS T0: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/07/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03459 PATRICIA HOFFMAN Any questions regard/ng this matter, contact THE MCS GROUP INC. 1601 MARKET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-247207 3 5 9 7 1--CO 2 COMMOt~WEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TROY A. FOSTER : : File No. 2003-4447 VS. SUBPOENA TO PRODUCE DOCUMKNTS OR THING~ FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOYNER SPORTS MEDICINE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things **** SEE ATTACHED RIDER **** at The MCS Groun. Inc.. 1601 Market Street. Suite 800. philadolnhia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving fi'ds subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: . ANDREW C. LEHMAN, ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0901) SUPREME COURT ID #: ATTORNEy FOR: Defendant Prothonota~/Clerk, Civil Di~,~ Date: ._,/~..~ ,/~, .~/,'l~t Seal of the Court 35971 -O4 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOYNER SPORTS MEDICINE 3438 TRINDLE ROAD CAMP HILL, PA 17011 RE: 35971 TROY A. FOSTER INCLUDING DIAGNOSTIC FILMS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, fries, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: sDua. t.es Requested: upto and includin, the nresent I~ject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 DSocial Se.c. urity #: 172-60-1821 ate of Birth: 05-19-1967 SU10-473182 35 971--L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER 0F: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena wi~h a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice Of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/28/2003 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-459948 3 5 9 7 1 --LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE N0: 2003-4447 JUAN JIRAL NOTICE OF IA]TENT %~O SERVE A SUBPO~ TO PRODUCE D(~S ~ · r~±NGS FOR DISCO~¥ p~.~ TO RI/Y~E 4009.23 SUSQUEHANNA VALLEY PAIN MGMT. MEDICAL RECORDS & XRAYS HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL X-RAY ONLY JOYNER SPORTS MEDICINE MEDICAL RECORDS & XRAYS ORTHO. SURGEONS OF CENTRAL PA. MEDICAL RECORDS & XRAYS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/07/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03459 PATRICIA HOFF~3%N Any questions regard/ng this matter, contact THE MCS GROUP INC. 1601 MARKET STREET ~800 PRILADELPHIA, PA 19103 (215) 246-0900 DE02-247207 3 5 9 7 1 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TROY A. FOSTER : : File No. 2003-4447 VS. SUBPOENA TO PRODUCE DOCUMENTS OR THING.~ FOR DISCOVERY PURSUANT TO RULE 4009.2'~ TO: Custodian o£Records for ORTHO. SURGEONS OF CENTRAL PA. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grouts. Inc.. 1601 Market Street. Suite 800. Philadelnhia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN. ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Deputy Seal of the Court 35971-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHO. SURGEONS OF CENTRAL PA. 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE: 35971 TROY A. FOSTER INCLUDING DIAGNOSTIC FILMS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire ~e.d. ical, billing, and diagnostic file, including but not limited to any ana a~t records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, histo~ and physical reports, medication/prescription records, medical billing and payment records, x-ray f'flms and tests with subsequent repons, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-473184 35 971--L0 5 CERTIFICATE PREREQUISITE TO S~RVICE OF A S~POENA PURSUANT TO RULE ~009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCan ,b~half o~ ~/ <~ DATE: 12/10/2003 attorney' for DEFENDAN~ /~ DEll-462135 3 5 9 7 1 --LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL NOTICE OF INT~z~T TO SERVE A SUBPOENA TO PRODUCE DOC73q~f~%]TS ~ 7~IINGS FOR DISCOVERY ~IFA1TT TO RULE 4009.21 HARRISBURG HOSPITAL MEDICAL RECORDS HARRISBURG HOSPITAL X-RAY ONLY KNIGHT, BOLINE, ET AL OTHER TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/20/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03459 PATRICIA HOFFMAN - Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-248402 3 5 97 1--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TROY A. FOSTER : : File No. 2003-4447 VS. : SUBPOENA TO PRODUCE DOCUMENTS OR TILINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the croat to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN. ESO. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215)246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: /~ Prothonotary/Clerk, Civil Divi~ Deputy Date:~(3. ,~Ot~, &t~l3 Seal of the Court 35971-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 S. FRONT STREET HARRISBURG, PA 171012099 RE: 35971 TROY A. FOSTER Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-475154 3 5 9 7 1 --LO 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE N0: 2003-4447 JUAN JIRAL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 12/10/2003' ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-462136 3 5 9 7 1 --LO 7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL NOTICE OF INT~T TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HARRISBURG HOSPITAL MEDICAL RECORDS HARRISBURG HOSPITAL X-RAY ONLY KNIGHT, BOLINE, ET AL OTHER TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/20/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03459 PATRICIA HOFFMAN - Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-248402 35971--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TROY A. FOSTER : : File No. 2003-4447 VS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. ] 601 M0xket Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN, ESO. ADDRESS: 2411 N, FRONT STREET HARRISBURG. PA 171 lO TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Prothonotary/Clerk, Civil Divisi~ Deputy Seal of the Court 35971-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 S. FRONT STREET HARRISBURG, PA 171012099 RE: 35971 TROY A. FOSTER Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and repons, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-475156 3 5 9 7 1 --LO 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 12/10/2003 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-462137 3 5 9 7 1 --LO 8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL NOTICE OF I~Tif~gT TO SERVE A SUBPOENA TO PRODUCE DOCu~RNTS ~ THINGS FOR DISCOV~u(Y PURSUANT TO RULE 4009.21 HARRISBURG HOSPITAL MEDICAL RECORDS HARRISBURG HOSPITAL X-RAY ONLY KNIGHT, BOLINE, ET AL OTHER TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/20/2003 NCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03459 PATRICIA HOFFMAN A~y questions regard/ng this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-248402 3 5971--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TROY A. FOSTER : : File No. 2003-4447 VS. SUBPOENA TO PRODUCE DOCUMENTS OR TILINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for KNIGHT. BOLINE. ET (Name of Person or Entity) Within twenty (20) days at~er service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group, inc., 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the fight to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days al~er its service, the party serving this subpoe~m may seek a court order compelling you to comply with it~ THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN, Ese. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT 1D #: ATTORNEY FOR: Defendant BY THE COURT: Date: ~~/~ ~./~ ~.Odg,.~ Deputy Seal of the Court 35971-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KNIGHT, BOLINE, ET AL 2626 NORTH 3RD STREET HARRISBURG, PA 17110 RE: 35971 TROY A. FOSTER ANY AND ALL MEDICAL RECORDS AND DIAGNOSTIC FILMS' Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-475158 3 5 9 7 1 --LO 8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/18/2003 ANDREW C. LEE~N, ESQ. Attorney for DEFENDANT DEll-463751 3 3 12 7--LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE N0: 2003-4447 JUAN JIRAL NOTICE OF I~T~FT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCO~KY PURSUANT TO RULE 4009.21 DR.CLAUDETTE JATTO, M.D. MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03-459 PATRICIA HOFFMAN Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249095 3 3 12 7--CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TROY A. FOSTER : : File No. 2003-4447 VS. : JUAN JIRAL : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2? TO: Custodian of Records for DR.CLAUDETTE JATrO. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grouts. Inc.. 1601 Market Street. Suite 800. Philadelt~hia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the fight to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN, ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Di~(sion Date: ~.~ C ~Z~. 2~ ._.~ Deput3f/ Seal of the Court 33127-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR.CLAUDETTE JATTO, M.D. 207 HOUSE AVENUE CAMP HILL, PA RE: 33127 TROY A. FOSTER Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject :TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-476548 3 3 1 2 7 --LO 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT 0F COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. ANUBEN C. Attorney for DEFENDANT DEll-463751 3 3 12 7--LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN TEE MATTER 0F: COURT OF COMMON PLEAS TROY A. FOSTER TERM, -VS- CASE NO: 2003-4447 JUAN JIRAL NOTICE OF II~','~NT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND ~TNGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DE.CLAUDETTE JATT0, M.D. MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 03-459 PATRICIA HOFFMAN Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249095 33 12 7--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TROY A. FOSTER : : File No. 2003-4447 VS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR.CLAUDETTE JATTO. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grouv. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN, ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Diqision Date: ~/~,~_d~ ~ C ~ 20~ ~ DepUt~'/ ' Seal of the Court 33127-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR.CLAUDETTE JATTO, M.D. 207 HOUSE AVENUE CAMP HILL, PA RE: 33127 TROY A. FOSTER Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stOred in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatmem pertaining to: Dates Requested: up to and including the present. Subject: TROY A. FOSTER 1102 YVERDON DRIVE, CAMP HILL, PA 17011 Social Security #: 172-60-1821 Date of Birth: 05-19-1967 SU10-476548 3 3 12 7 --LO 6 Troy A. Foster, : IN THE COURT OF CO}~ON PLEAS OF Plaintiff : C5%IBERLAND COUNTY, PENNSYLVA~{IA vs. : NO. 2003-4447 CIVIL X_~ Juan Jiral, : : Defendant : 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: David L. Lutz, Esq. , counsel for the plaintiff/~g~,Y~a~ in the above action (or actions),, respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue- 2. The claim of the plaintiff in the action is $ unliquidated The counterclaim o~ the defendant in the action is N/A The following attorneys are interested in the case(s) as counsel or are other- wise disqualified to sit as arbitrators: David L. Lutz, Esquire, and Andrew Lehman, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. cc Andrew Lehman, Esquire Respectfully submitted, David L. Lutz, Esquire 9RDER OF COURT AND NOW, , 19 , in consideration of the foregoing petition, Esq., Esq., and ,Esq., are appointed arbitrators in the above-captioned action (or actions) as prayed for. By the Court, Po Troy A. Foster, : IN THE COURT OF CO~ON PLEAS OF Plaintiff : C5%[BERLAND COUNTY, PENNSYLVANIA vs. : NO. 2003-4447 CIVIL ~ Juan 0±ral, : Defendant . RULE 1312-1, The Petition for Appointment of Arbitrators shall be substantially in :he following form: ~.T!~.~OS FOR g2POI~TH~-'NT OF ^RBITP~TORS TO THE HONORABLE, THE JUDGES OF SAID COURT: David L. Lutz, Esq. , counsel for the plaintiff/~g~i~ in the above action (or actions),, respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue· 2. The claim of the plaintiff in the action is $ unliquidated The counterclaim o~ the defendant in the action is N/A The following attorneys are interested in the case(s) as counsel or are other- wise disqualified to sit as arbitrators: David L. Lutz, Esquire, and Andrew Lehman, Esquire W~LEKEFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. cc Andrew Lehman, Esquire ~full~:ed, David L. Lutz, Esquire ORDER OF COURT ~sq,, and ~ above-captioned action (or actions) as prayed for. By the : CUMBERLAND COUNTY, PENNSYLVANIA : No. OATH We do sole~ly swe~ (or affix) ~at we ~11 suppoa, obey ~d defend the Cons6m6on of the United States ~d ~e Cons6m6on of ~is Co~onweal~ ~at ~~ge the du6es of AW~ We, ~e ~d~si~d ~bi~ato~, ha~g been duly appoNted and sworn (or affixed), make ~e follo~ng awed: ~ote: 'If damages for delay are awarded, they shall be separamly stated.) ~- "~bi=tor, disse,ts. (ins~nmei~li~:), Date of Aw~a: ~ I~ ~ ~ ~o~c~ o~o~w~ was ~tered upon the doaket ~notice thereof ~ven by mail to ~e p~es or the~ a~meys. ~ibi~ators'comp~safion to be m*~: Paid upon appeal: ~o~mo~ 2 0.o0 TROY A. FOSTER, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNA. v. NO..' 2003-4447 JUAN JIRAL, CIVIL ACTION - LAW Defendant. JURY TRIAL DEMANDED NOTICE OF APPEAL FROM AWARD OF BOARD OF ARBITRATORS TO THE PROTHONOTARY: Notice is hereby given that Juan Jiral appeals from the award of the Board of Arbitrators entered in this case on June 16, 2004. A copy of this award is attached hereto and incorporated herein by reference. A jury trial is demanded ~]. I hereby certify that the compensation of the arbitrators has been pa d. Respectfully submitted, NEALON & GOVER, P.C. Andrew Ci Lehman, Esquire "' I.D. #: 81937 2411 North Front Street Date: _ ~-7- ~,// Harrisburg, PA 17110 717/232-990,0 : CUMBERLAND COUNTY, PENNSYLVANIA OAT~ We do softy swe~ (or a~) ~at we ~11 suppo~, obey ~d de~d ~e Cons~mfion of ~e U~md States ~d ~e Cons~mfion of ~s Co~onweal~ ~:~ ~~ge ~e du~es o~ AW~ ~ We, ~e ~d~si~ed ~bi~tors, hamg been duly appo~ted ~md sworn (or af~ed), ~e · e follo~g awed: ~ote: If &mag~ for delay are awarded, thq shall be sep~amly stated.) NO~ OF E~Y OF AW~ Now, ~e ~ ~y of ~ 200¢, at * :~, ~ .M., ~e above aw=a was mtered upon ~e docket ~notice ~eof ~ven by mil to ~e p~es or ~k a~omeys. ~ibi~ators'compmsafion to be ~ r. ~ ff ~ , .Paid upon appeal: -- - ' CERTIFICATE OF SERVlCF AND NOW, this ~:;7/~d~y of July, 2004, I hereby certify that I have served the foregoing NOTICE OF APPEAL FROM AWARD OF BOARD OF ARBITRATORS on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David L. Lutz, Esquire ANGINO & ROVNER, P.C. 4503 North Front Street Harrisburg, PA 17110 TROY A. FOSTER, 1N THE COURT OF COMMON PLEAS Plaintiff CUMBERL~MND COUNTY, PA v. CIVIL ACTION - LAW NO. 2003-4447 JUAN JIRAL, Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO OFFER DOCUMENTARY EVIDENCE PURSUANT TO RULE 1311.1 To: Juan Jiral, Defendant, by and through his attomey Andrew Lehman, Esquire Plaintiff, by and through counsel, Angino & Rovner, P.C., intends to offer the documents attached hereto at the trial of the appeal from the award of arbitrators, in the manner provided by Rule of Civil Procedure 1311.1. The following documents are attached: 1. Holy Spirit Hospital records (Exhibit A). 2. Medical records from James Shaer, M.D. (Exhibit B). 3. Physical therapy records from Joyner Sports Ivledicine (Exhibit C). Troy Foster Name of Plaintiff ANGINO & ROVNER, P.C. D~4ih'q~. Lutz I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717)238-6791 Date: '~/t~ ~74 Attorney for Plaintiff 279128-1 ADM. DATE: 11/25/2002 CHIEF COMPLAINT: Some neck discomfort, left shoulder pain, and numbness and, tng ing down the left arm. HISTORY OF PRESENT ILLNESS: Patient states that on Thursday morning, he was rear ended. He was the belted driver. He stopped at a red light and was rear ended. He was the third car in the domino effect of a person hitting the cars behind him. MEDICATIONS: Ibuprofen. ALLERGIES: No known drug allergies. REVIEW OF SYSTEMS CONSTITUTION: Patient states that he is generally very healthy. Has not seen a health care provider in sev_eral years. NECK: Patie~_t states he has some discomfort in the back of his neck. He states it feels Ilke a muscle spasm. CARDIAC: Patient denies chest pain, chest tightness. RESPIRATORY: Patient denies shortness of breath and states that the steering wheel did not hit him in the chest. Gl: Patient denies nausea and vomiting or any abdominal pain. GU: Patient states he has had no urinary or bowel problems ,'since the accident. MUSCULOSKELETAL: Patient states that he has discomfod: in the left shoulder, scapula area. He states it feels like "when you stub your finger." NEUROLOGIC: Patient states that he did not hit his head. He has expedencad no dizziness or black outs. He does have a sensation of some numbness and tingling down his left arm and into his fingers. He works as a waiter and has not had any problems lifting things or delivering trays. He has not had any experiences of dropping anything. EXTREMITIES: Patient states that his left knee hit either the doorknob or the armrest dudng the acoident.'"He has had some discomfort of that area. He has not had any change or difficulty in gait, and he has had no hip pain. PHYSICAL EXAMINATION: Vital signs--blood pressure 110/66, pulse 72, respirations 20, temperature 97.3. CONSTITUTION: In general, this 35 -year-old gentleman was sitting on the chair when I entered the room. He is able to stand and move without any physical discomfort. Page 1 of 3 HOLY SPIRIT HOSPITAL Camp Hill, PA NAME: Foster, Troy A 17011 MR#: 181325 ROOM# ER3 EMERGENCY ROOM REPORT NAME: ' Foster, Tro~ MR#: 181325 NECK: Suppl.e, symmetr ca, nontender, no lymphadenopathy. Trachea midline. Thyroid nonpalpable. LUNGS: Normal respiratory effort. Breath sounds equal. No rules, rhonchi, or wheezes. CHEST: Non-tender to palpation. CARDIAC: Regular rate and rhythm without murmurs, ectopy, rubs, or gallops. No pedal edema. Gl: No nausea, vomiting, diarrheA, constipation,- abdominal pain, or rectal bleeding. SKIN: Normal color and turgor. No rashes or lesions. EXTREMITIES: Patient is not able to raise his left arm the whole way over his head. He is limited in that_he is not able to touch the back of his neck with ;his left hand or reach under and touch his mid Back with his left hand. He states that the limitation is not because he cannot but ... because it feels like it is pulling and going to spasm if he force,,; it. He has equal grip strength in both hands, good radial pulses bilaterally. There is no obvious abnormality of his shoulder or shoulder blade. He has no tenderness on palpation to his thoracic spine. There is slight tenderness to the left of his cervical spine. He states when it is pressed that it feels like a muscle spasm. Patient has good sensation and reflexes of his arms and legs bilaterally. He has full range of motion of his left knee and hip with good pedal pulses bilaterally. NEUROLOGICAL: Alert and odented to person, place, and time. Cranial nerves intact. Sensory and motor function normal. Reflexes symmetrical. MEDICAL DECISION MAKING: Cervical spine x-ray was read by the radiologist as no fracture, straightening upper C-spine, questionable muscle spasm. The case was discussed with Dr. Sharma. She gave no new orders. Patient was discharged with a prescription for Celebrex 200 milligrams p.o.b.i.d., dispense 14, and Flexed110 milligrams p.o.t.i.d., dispense 12 tablets. Limitations on use of Flexeril and not driving or operating machinery while taking the Flexeril were discussed. Patient was given information on the family doctors associated with Holy Spidt Hospital and a card for OIP. He was encouraged to follow with a doctor of his choice, either the doctors inforrrration given to him or one that he had used before that was recommended to him. He was given a note to be off work until the 27th and a note for no gym or sports until reevaluated by his family doctor or ortho. Patient was encouraged to return if his symptoms worsened or became severe. He was told that he may be recommended by the family doctor or orthopedics for physical therapy. Page 2 of 3 HOLY SPIRIT HOSPITAL Camp Hill, PA NAME: Foster, Troy A 17011 MR#: 181325 EMERGENCY ROOM REPORT NAME: Foster, Trc. M R#: 181325 Signed ., DIANE WHITCOMB, CRNP 12/26/2002 15:46 DIANE WHITCOMB, CRNP DW/rw DOC #: 293245 D: 11/25/2002 T: 11/27/2002 3:29 P 009263 - - Page 3 of 3 HOLY SPIRIT HOSPITAL Camp Hill, PA NAME: Foster, Troy A 17011 MR#: 181325 EMERGENCY ROOM REPORT E5 ER~,ENCY CENTER URGI CENTER DISCHARGE INSTRUCTION.;; HOLY SPIRIT HOSPITAL (717) 763-2316 ~[(~717) 763-2424 Petient Informeflon: Patie~l Information sheets contain importent itfformetlon to review and keep, ( ) Abdominal pain · o. ,'% s ( ) Corneal abrasiorffforeign body ( ) Headaohe ( ) Pain Management ( ) Threatened Miscaniage ( ) Alcohol reaction ( ) Croup/bro~x:hitis ( ) Head Iniury ( ) Pedistri¢ Head lnj~ ( ) Toothache ( ) Allergic reaction ( ) Crutch walking ( ) Hypertension ( ) Pediatric URI ( ) URI and Colds ( ) Asthma ( ) Diarrhea and Vomiting/Peal. Vomiting ( ) Immuntzatlon/Tetanu.=; ( ) PID/STD ( ) UTI and Pyelonephritis ( ) Back pain ( ) Dislocation - ( ) Kidney Stones ( ) Pneumonia ( ) Wound Recheck ( ) Bites-Human/AnlmaVInsect ( ) Drug/Alcohol abuse/addiction ( ) Lablynthitis ( ) Rash ( ) 24 hr. Pharmacies ( ) Bum ( ) Febrile Convulsion ( ) Laceration ( ) Seizure ( ) Other ( ) Chest Pain ( ) Fever/Peal. Fever ( ) Neck Strain ( ) Sore Throat ( ) Con unctivitis ( ) Flu ( ) Nosebleed ( ) Sprains and Strains ( COPD ( ) Fracture ( ) Otitis Media ( ) Suture Care & Removal WOUND CARE MEDICATIONS ( ) May gently wash over wound in 24 hours with soap and water or ( ) Continue present medications except: peroxide. Do not soak in water. ( ) Change dressing times daily. Redress with Bacitracin/Neospodn ( ) Use Advil (Ibuprofec) or Tylenol as needed for pa~, fever and sterile dressing, according to package instructions for age, weight. ( ) Keep wound clean, d~7, covered. ( ) Tetanus/Diptheda Booster given. ( ) Use the following medicines according to package instructions: SPRAINS, STRAINS, BRUISES, FRACTURES 1: ( ) Elevate the injured part for__days to reduce swelling. 2: ( ) Apply ice packs intermittently for__days to reduce swelling. 3: ( ) Ace wrap for support for__days. <~::~olfowing medicines may cause drowsiness: ( ) Wear splint ( ) At all times, unfit follow-up. DO NOT DRIVE OR OPERATE MACHINERY WHILE TAKING: ( ) For activity ss needed. ( ) Use crutches: ( ) As neaP-ed, weight bearing as tolerated. FOLLOW-UP This is our recommendation for follow-up. If your ( )At all ames. NO WEIGHT BEARING insurance (HMO) requires a physician referral for specialty NECK/BACK consultation, iT IS YOUR RESPONSIBILITY TO OBTAIN THE ! .) Wear cen, ical collar for support for_ days. NECESSARY APPROVAL. C:~,)c.%k~st, avoid bending, lifting, strenuous activity for__days. C~ollow-up with: ( ) UrgI Center ply moist heat for ,~--,~ 4 ¢ tee beginning in ADDITIONAL INSTRUCTIONS c.,_ in '-. days fo~. ( ) Follow-up ( )'Off woddschool from to ( ) Suture removal ~) u;tUm to work on ! I - c~ "? - C) ~ ( ) Call as soon as possible for appointment ht Duty until: ( ) Pick up your X-Rays from the Radiology Department prior to Restrictions: your follow-up appointment. Call 763-2696 to have films ( ) Follow instructions on Wodecan s Compen'sationI Form. [ ~ ( ) See your physician or Spaciallst if not improved in ( ) Wear eye patch for houm. O~ days. ( ) If nose bleed recurs, pinch nose firmly for 5 mlnutas (:~eturn to Emergency Center ti you feel your condition is worsening, continuously, rstum if bleeding not controlred, especially if the pain Inoreasas despite pain relief rnedlcatlon. ( ) The prescifbed antibiotic may reduce the effectiveness of ( ) Your blood pressure was Oievated. Please have it rneqication you ars currently taking. Check package rechecked by your physician. instroct~ons or consult with PharmacisL ( ) Test results have been given to you. Take them with you to ( ) The inte~ststJon of your X-Rays are prelimina~ reading, the follow-up appointment. Your films witl be reviewed by a rediologisL You or your Test results given: [] CBC [] CMP [] EKG [] X-RAY COPY physician will be contacted if there is a change in the [] BMP [] RECORDS COPY CHART [] GLUC. diagnosis. A copy of your dictated Emegency Room Report is available to your Additional InstnJctions: physician from Medical Records (763-2660), if not aJready sent. '"" I hereby ecknowisdge receipt of these Instmcitons and understand them. / I understand that I have had emergency treatment onN and that I may be released befoce all of my medical problems are known or treated. I will arrange for 'follow-up care as I have b&en instructed. It is your respons~itlty to notify your Primary Care FJhys'~ian 6f this Visit. ' ' ' : ( ) PATIENT VERBAL~ES UNDERSTANDI~ ' . · Pal:ie/~/or Ras~s~le Pbr~En-" /Date ~OLY SPIRIT HOSPITAL F_2V/ERGENCY CENTER ;03 NORTH 21ST STREET CAMP HILL, PA 17011-2288 (717) 763-2316 ) vaaltha Abra~am, M.D. 0381MOL , ) Jon Dubin, D.O. OS 006991L ( ) Lawrence Paut, M D 039524-L ) Thomas Aldous. MD. 017075E ) Merlys Hasson, M.D. 072553L ( ) Howard Redaick, MD. 040562-L . ) Salvatore Alfano, M.D. 025502E ) John P. Judson, MkD. 038368-E ( ) Ranjaca Shanna, M.D. 031265-E ) Ram~h AJot~ M.D. 016727E ) Richard Laley, M.D, 029960-E ( ) Aha Teplis, M.D. 030018-E ) Glen Daugh~y, D.O. 0S006776E ) Phillip Maguire, M,D. 015063-E . -- [ ) David 7imra.rman; M.D. 005636-E ) Nicolau DaCos~, M.D. 053..2_88-L ) Pushpa Medan, M.D. 051514L ~ I ( ) Apply ice pa¢~s int;m3iftenfiy for '.~._ days to reduce s~velling. 3: ( ) Ace wrap for support for__ days. (~ctlowing n les may cause drewslness: ( ) Wear splint { ) At all times until fo[Iow. " ( ) For actlvEy as needed. DO NOT D~yE uR OP. ER~TE MACHINERY WHILE TAKING: ( ) Use crutches: ( ) As needed, weight bearing as tctem ed . FOLLOW-UP This is bur recommendation for follow-up. If your ( )At all times. NO WEIGHT BEARING insurance (HMO) requires a physician referral for spocta~ty NECK/BACK consufiatJon, IT IS YOUR RESPONSIBILITY TO OBTAIN THE ( ) Wear cen4cal co[lar for support for__days. NECESSARY APPROVAL .... ~ avoid bending, lifting, strenuous activity for__days. C~,~ollow-up with: ( ) Urgi Center (~;J~/~ply moist heat for ~s.-,~ ~ t4~tee times daily t~ffFa~ily Doc?or ~ t~)l~,-~ . beginning in hours.' - ADDITIONAL INSTRUCTIONS r:,. in ~-. days for. ( ) Fo[Iow-up ( )'Off worktschcoi from to ( ) Suture removal (~g~alum to work on I I - ,~ '~ - o ~ ( ) Call as soon as possible fo~' apl~intmant ( ) Light Duty until: ~-' ( ) Pick up your X-Rays from the Radiology Department pdor to Rest~ctions: your fo[Iow-~p appointment. Cell 763-2696 to have films (::~o gym/s~orts until .... OJ , ~ ,.~ J_ ~,_. ~.~Z.. ~"o¢-~'~ ready. - ) Fo Iow nstmctions on Workman's Compansatior] Form. t ~ ( ) See your physician or specialist if not improved in ) Wear eye patcfffor ' hours. {:~)k-~/~:a days. ) if nose bleed recurs, pinch nose firmly for 5 minutes (~4~etum to Emergency Center if you feel your condition is worsening, continuously, return if bleeding not controlled, eepecially if the pstn Inereeeee deaplt~'pstn relief medication. ) The preschbed antibiotic may reduce the effectiveness of ( ) Your blood pressure was elevated. Please have it medication you are currently taking. Check package rechecked by your physician. instnJctions or consult w~th Pharmacist. ( ) Test results have been given to you. Take them with you to ) The interpretation of your X-Rays are preliminary reading, the f~llow-up appointment. Your ~ms will be reviewed by a radiologist. You or your Test results given: [] CBC [] CMP ~'1EKG ~] X-RAY COPY physician will be contacted if there Is a change in the [] SMP [] RECORDS COPY CHART ~] GLUC, diagnosis. A copy of your dictated Emegency Room Report is available to your Additional Instructions: physician from Medical Records (763-2660}, if not already sent. ~ I hereby acknowledge receipt of these instructions end understand them. / I understand that I have had emergency treatment ~ and that I may t be released before all of my medical problems are known or treated. I will arrange for follow.up care as I have been inatnJcted, It is your responsibility to notify your Pdmary Care I~hysk:ian of this visit. Clinical Imlz,~sslonm ,'~, ~- f~- //q,~ ~-~. ~4.~,,. ( ) PATIENT VERBAUZES UNDERSTAND GIN/~'~-~,---, Patieh~'or Res~o~hsible Pers6*rr' / Date "~hy~pcia~' -- ' ~/ M.D,/D.a. Nurse RN .. HOLY SPIRIT HOSPITAL EMERGENCY CENTER 503 NORTH 21ST STREET CAMP HILL, PA 17011-2288 (717) 763-2316 (*) Vanitha Abraham, M.D. 038840L ( )Jon Dubin, D.O. OS 006991L ( ) Lawrence Paul, M.D. 039~24-L ( ) Thomas Aldous, M.D. 017075E ( ) M~rlys Hasson, M.D. 072553L ( ) Howard Rudnicl~ M.D. 040862-L ( ) Salvamre Alfano, M.D. 02S502E ( ) John p. Jedson, M.D. 038365-E - - ( ) Ranjana Sha~na, M~D. 031265-E ( ) Ramesh Arora, M.D. 016727E ( ) Richard Luley, M.D. 029960-E ( ) Alan TepEs, M.D. 030018-E ( ) Glen Daughuy, D.O. 05006776E ( ) Pldltip Maguire, M.D. 015063-E ) David Ziraraennan, M.D. 005636-E ( ) Nicolau DaCoslz, M.D. 053,288-L ( ) Pushpa Mudan, M.D. DA~, //_~m ~)~ ro ~ VtSP~SED .... mEOtC^LLY NECESS,~r¥" iN TI~ SPaCe I~LOW. f 0 ~, I E t', , i ,', 0 ¥ C~? ,ILL ?~, iT011 "~ DLABEL DSL3~STITIJTION PEP~ISSIBLE [4.~t ; ~/i ,~,] 737-753(~ r (., ;~ [ L:~ , '~ ix0 h~,| 5bZ 45.9540 ~ i/,.~/O : ]7~ (3/0] } - C'ONSENT TO MEDICAL TREATMENT I HEREBY CONSENT AND AUTHORIZE Holy Spirit Hospital, its agents, and employees, to the rendering of medical care, which may include routine diagnostic proceduresand such medical treatment as my attending or consulting physician considers to be necessary. I also under- stand it is customary, alSsent emergency or extraordinary circumstances, that no substantial procedures will be performed upon me unless or until I have had an opportuni .tX to discuss them with a physician or other health care professional to my satisfaction. If have the right to consent or refuse to consent. I understand that the practice of medicine and surgery is not an exa(~t science and that diagno- sis add treatment may involve risks of injury or'even death and acknowledge that no guarantee has been made to me as to the results of any examination or treatment in this Hospital. I understand many of the physicians on the staff of Holy Spirit Hospital are not employees or agents of the Hospital, but rather are independent contractors who have been granted the privilege of using these facilities for the care and treatment of their patients. Further, I realize this Hosp ta s a teach ng Hospital and at the Hosp tel are hea th care personnel in training whc~, unless expressly requested otherwise, may.~arficipate or may be present during my care as part of the reducat on. Sti or motion p ctures and closed circuit monitoring of pat ent care mhy a so be used for educational purposes, unless I expressly request otherwise. I understand that n order to ensure a safe environment for patients, visitors and staff aH property on the premises.~ospital is subject to reasonable search and/or seizure at any time without further notice. ' /~nitia~( RELEASE OF MEDICAL INFORMATION ~ . I authorize Holy Spirit Hospital to release to requesting health insurance carrier(s), their representatives and auc]i'fi3/'{~'~nd any referring health care providers, such diagnostic and therapeutic information (including any information relating to treatment for alcohol and substance abuse ~nd/or treatment of oevchiatric disorders, and/or confidential HIV related information, as may be necessary for them to determine benefit enti- tlement; to process paymen~ claims for health-ca~e services provided during this hospitalization/treatment episode, and for continuing care/treatment A photocopy or carbon copy of this authorization shall be considered as effective and valid as the original. The undersigned also authorizes Medicare, w'~n applicable, to release to another insurance carrier, upen their request, medical inform~eded to make payment upon that claim. ~- understand and consent that the manufacturer of any implantable device inserted by my physician during the co~e of my s~u ~-d~/ocedure may be provided with my identification information, including social security number, as mandated by Federal La~. INSURANCE ASSIGNMENT OF BENEFITS / ""~ I authorize payment d rectly to Holy Spirit Hospital and my treating physicians of all benefits payable under my instance policie,s,J,~derstand I am responsible to the Hospital and physicians for all charges not covered by this assignment. ( Initial~"~J STATEMENTTO PERMIT PAYMENT OF MEDICARE BENEFITSTO PROVIDERS, PHYSICIANS'AND-PATIENT I request payment of Authorized Medicare benefits to me or on my behalf for any services furnished me by or in Holy Spirit Hospital including physician services. I authorize any holder of medical and other information about me, to release to Medicare and its agencies any information needed to determine these benefits for related services. Initials. MEDICAL ASSISTANCE RECIPIENT My signatures certifies that I received a service or items from Holy Spirit Hospital and Dr. on the date listed below. I understand that payment for this service or item will be from Federal and State funds, and that any false claims, statements, or documents, or concealment of material may be prosecuted under applicable Federal and State Laws. I understand that certain tests and procedures may not be reimbursed by Federal and State funds and that I may be responsible for non covered charges. Aisc, I agree that if at the time of service, if I am not eligible for Medical Assistance, I will be responsible for balances owed to Holy Spirit Hospital. Initials I have read and understand each of the sections contained above. I understand that by~gnlng thl~s cument, I am agreeing and provldlng,the'aul[hor zat on/co.,qsent conta ned n each of the above sections where n]y I~lltlats ars Iocate{:L I have had the oppbrtunl- ty to a~-questlo,~s regar~g~aqh of these sections and all such questions asks4 ha~e/~een answer, ed~,t~ my s, at~fa_ctlo~n. - HOLY SPIRIT HOSPITAL, CAMP IHLL, PA Z "~ i ": , ~.'; .~ ~ ,~,~ 15 CONSENT FOR TREATMENT/ RELEASE OF INFORMATION ~ ~ '~ . i ¢ ~ INSURANCEASSIGNMENT ! k, ~ / { '~ / { .~b ~ Y .3 ~- ~ 3 ~'u . CHART COPY ' Appearance: . Mental Status: ~J~es~jratory: Gastrointestinal I~ Trauma ,~'~.~,~,~TemO'.Ge ~1: ~1o · Speech: ~ous ~un~peraflve ~e~l ~Denies pain/symptoms , L~tion ~NL ~ ~ ~~ ~L ~-~ ~al ~le~argic ~mbative and unlabored ODuratio~ Intensl~ ~abrasion:/../ ' ~nfused ~anxlous ~la~md ~nau~a ~dia~ea ~laceration: Neuro QNIA GU I GYN ~ Cardiovascular ~Chest pain NURSING ASSE~ME~ '~ ~//~ ~ '~ ~ ~ ~ ~ Signature: Initial Signature Initial T~N=~A OR DISCHARGE - ~charg~/a~mpanied by: ~bulat~ Ow/c Oambulan~ t~oma, ~numing home ~A~ ~OR lent OMmily ~parent ~o~er: · - - OverlOad underacting of ~c ins~ons ORe~A ~lled ~ to - Oold m~s ~nt to fl~r O~othing sheet done · _ O~nsfeff~ ~ O~nsent sign~ ~ ~nd~: ~ . -: .~ ~Us~o~ ~Cfifi~l ODeceased ~ m~ue HolySpifitHospi~l ~,u. ilL.b0~ ~ Nursing Assessmen~ Notes ,~it,~ ,i.~ ~ol HOLY SPIRIT HOSPITAL Camp Hill, PA 17011 Holy Spirit FHC Dillsburg FHC Duncannon FHC Fai~iew FHC Green Hill FHC Sporting Hill FHC Camp Hill, PA Dillsburg, PA Duncannon, PA Etters, PA New Cumberland, PA Mecha~nicsburg, PA 763-2461 432-2411 8343108 938-9191 774-8400 731-8223 Work/School Excuse ForrQ ~lrs ' It,-~c.~ ~-'~e,~.~, _ (~as not seen by me on and may return to workJschool on /'//~ 7/0 ~-- " Please excuse from work/school from '"--- ............... ~-~'-- Restriction: Physical Education: Medications during work/school hours: ,.-.~ Remarks: Signatur ! ,I_ J~,r~.t~ CP.X./Y'-~ M.D./D.O. ____ Date: No. 59 CERTIFICATE TO RETURN TO WORK OR SCHOOL Rev. 8~93 NOU-25-2802 ~.3:52 HSH RC~DIOLOGY ~.ST FLOOR 71"7 9?2 46&2 . .._ ~IO~GIST/FTL~ COPY - - STATUS' STAT "HOSP V ' ~ ~ATIENT: FUSTY, ~OYA ADDRESS' 1102 WE~ON DR "'"'¢~ '~{ ~UER ~. 90001 PHONE; (717) 737:~i30 MEO REC ~: 181325 ADM ~ 19997535 AGE; 35Y DOB: 05/191~967 ~RDDATE: Nov252002 1:05PM S~: M ~RD DR: ~TZEN~OYER CRNP/ PATRClA - 0 ~t P~nan~ y N Tech: ~J' ] :' ~M DATE: Nov 25 2002 0gPM " ~" :'~ PROC ¢ DESC -' ~ CERVI~L SPINE 72052 .'- 1936588 .., .~: FOR ~DIOLOGIST'S USE ONLY : R~DING ~IOLOGIST: . TIME R~D: REPORT DICTATE ' TOTRL P,~[ Holy Spirit Hospital Department of Ra.diology and Diagnos~tic Imaging Camp Hill, Pennsylvania 1701 (717) 763-2600 pATIENT: FOSTER, TROY A DICTATION DATE: Nov 25 2002 2:04P · TRANSCRIPTION DATE: Nov 25 2002 7:00P MR#: . 181325 SOC SEC: 172-60-1821 ORD DR: PATRCIA KATZENMOYER,CRNP/M.D. PT TYPE: E ADM DATE: 11/25/2002 DOB: 05/19/1967 ARRIVAL DATE: 11/25/2002 LOCATION: ER3- HOSP SERVICE: I-_-R3 ***Final Report*** EXAMINATION: CERVICAL SPINE (6V) 72052 - 1112512002 COMMENTS: Indicati~n: MVA. .. The posterior alignment is normal. There are no fractures. There is no precervical soft-tissue swelling~ There is, however, straightening of the usual cervical lordosis above the C5-6 disc level which could be a reflection of muscle spasm? There is no rotational deformity. There is no neural foraminal encroachment. There are no significant degenerative changes in the cervical spine. The Cl-C2 relationships are normal. CONCLUSION:' Straightening of the upper cervical lordosis. This could be re'lated to spasm? No fractures or other significant anatomical abnormalities seen about the cervical spine. DICTATED BY: HOWARD BRONFMAN M.D. / DEB DATE OF EXAM: 11/25/2002 ~ SIGNED BY: HOWARD BRONFMAN M.D. DATE/TIME: Nov 25 2002 7:28P Imaging Services Consultation Page I Age: ~---'~-"~'"~ Log BP:. O~SAT · Triag~ Mode of Arrival: BLS [] .ALS [] T !__ Room: Triage Chief '-'""' Yes [] No Attached Yes [] No ~, chxn pox, TS? Yes'C] No PMH Checklist: None [] HTN [] CAD [] ~ CHF[] ASTHMA O.~CA~EI~] STROKE [] Baker [] NIDDM [] IDDM El\ I/~ __ Othe~h~rE~ j Burning [] Throbbing [] Ra(liating [] Allergies~ ' ' ~~,, , ~ DuratiOnS, ~X~'~, ~, f~, })// Frequency. What relieves Latex AlLergy Yes ~ N~. Immunizations: UTD~ Not UTD~ Triage Notes: Tetanus L~,~. ' HOH~ Speaks Enolish: ~No~ Treatment ~ Tdage. Medications: Info obtained by: EMT ~ Medic ~ List ~ Bo~les ~ Patient ~ ~~~~D°se~l~sds ~ :)~ose Mods Dose 'Mods Unknown [] !njury: Place Occurred: :[] Skin Color: WNL [] Mottled [] Cyanotic Skin temp: Warm [] Cool [] Distal Pulses: Yes [] No [] :Edema: Yes[] No[] Deformity: Yes [] No [] Ecchymosis: Yes [] No [] Triage to Radiology at. Holy Spidt Hospital - Nursing Assessment CH~T CO~Y Initial 'Lab & X-Ray Orders: Labs Cardiac Respiratory [ ] Acetaminophen ] DOAS [. ] Thrombolytic Labs [ ] Monitor [ ] ABG's [ ] Acetone (SACE) ] ESR [ ] Tox Screen [ ] EKG [ ] Peak Flows Before/After Rasp. Tx. [ ] Alcohol (ALCO) ] Glucose [ ] Urine Tox Screen [ ] 02 L/Min. [ ] Respiratory Tx. [ ] Amylase/Lipese ] HCGS [ ] TSHR _ [ ] 02 Saturation [ ] AP3"]' ] HIV [ } Type&Cross __ # of units ' [ ] BBH ] Uver (BOR) Medications / IV's / Additional Orders [ ] B~ood CuJtures profile [ ] Type & Screen [ i BMP [ ]Lytes [ ] UA: [ ] DiP [ ] DIAG. Date/Time 3ate/Time/Int [ ] CBCP [ ] Phenobarb [ } Urine C & S IV: NSS/DSWl LR/D5/.45NS/D5.9NS [ ] CMP [ ] PTP [ ] Urine HCG WO/KVO/Infuse at mis/hr [ ]CRP1 [ ]Salicylate [ ]WCBreathAIcoTes~ . [ ] Digo~in [ ] Theo [ ] WC D~g Screen I [ ] Obtain old records [ ]Td [ ] Dilantin [ } Other:. Radiolo.qy ' ] Protocol Initiated for: [ ] ~bstr. Series ] KUB , [.~ Sb~v. Spinl~)/[.aL ] Nasal ] Chest Rtn. I Port I TPA - ] Ofoit _ Fi_ L ] Elhow R L ] Pelvis "- L/ ] Femur R L ] Ribs .R L ] Finger R L ] Shoulder R L "' } FOOt R L ] Skull ~ .... ] Forearm R L ] sternum ] Hand R L ] T/Spine ]Hip R L ]Tib/Fib R L ] Humerus R L ]Toe R L ]Knee R L ]Wrist R L s/P rnv - Special Procedures: Ultrasound: CT: ON=With contrast; WO=Wlthout) [ ] Abdomen [ ] Abdomen/Pelvis W WO [ ] VQ Scan Specimens/Cultures Inltlals.'~_~-~ Signature: ] Cewlc, al~ienital -~ [ ] Stool O & P Initials: Signature: RN/MA ]GC Cuiture [ ] Trichomonas Dictated: Half [ ] Completed [ ] · C.P,~,L CARE: -- hrs. ] Sputum C & S .~ - [ ] Other: Diagn stlc Impression: 'Billing Classification: [ ]Lavellll [ ]Levellll [ ]Case1 re..~_~. ',~7',~.~. OPMP/~J~.-gI~ 'MD~D~RNP Date: lll'~"/~A ~ ' J~ Time: IA3° \1 ,~"',~ [ , LevelV , , LevelV .... ~' ' l(' ''~''''~ ~''' /V ~.~ Holy Spirit Hospital ~ ~J ;; I' [ ~ , [ k o 'f ,~ CampHilI, PA ;,0, ~v~CO,~ [,k John R. Dietz Emergency Center 7 C ~ ~. t~ ;~ J L L ~ ~, Physician Order Sheet ~ i~'d ~t.,.: F[],R'~'~ REG "'~ '-" ~-'")~:: ~......,, ........ t]R-'.~ 1;~:1:}',.25 ~;~,}7 ~ FDS-I-ER : FRO'f A SS .~: .!L!i:,'.ES?}: 1~1')2 YVERD'..!N Lii',: /L-jAI'iFL r,T~i ,r:-,/~.,,_,!~ F'ii~: 7~ / .r. ~£.~-, =.. ~. _,/. · . 1 .... 7 AGE"- .-,.-, SEX -'- ~:, ' yin-:,. PiA'...LE'fS OCC~JF'AT!Oh~ -r~%'S~: / / / F'H'~ :~;'!E ~ FOSTER ~ BARB REL ~.R'.~= , DR /CAMP HILL ~, .... ., :! F'H 7].7 -- :-:.-~q--~()4.~ [ DRF~ S: i 102 ..... '"Fp.' " -'" ~ - ..... ~;'iE: REL TOr- ~ .' ~,~ .... ~... F'H .-- ODRESS ~ / /' / F'H - _~ CASE I ~.iFORMA"F I ON ~.n. ] ::' ]18 ED GROUP ::~=n,L,...: F'A,.,.E. FN~ 7YPE: E '"' DR: ,-,~-- o :.~.,J 1,:.L..~Jt .... EO GROUP HOSF' ~:ERV: ER3 -T~,~ "" ~ CLS: T ?{FER .... V I .... ~ ~.~ ~ ,T: t,~ .,~C,.~ ?!B BRT IN BY: BRT IH B'f: SELF O:'~M~r~ T: ACCIDENT !NFORMATI ATE/TIb!E: 11/21/02 ~1:15 ACC INL: P; dOB RELATEB~ N LGCATION: ESCRIF'TIDN: MVA-F'T [:RIVER HI7 FROM BEHINB GUAFtANTOR INFORMATIO~ :M~'., F'QSTER ,TRDY F'T :B[iRESS: 1102 YVERDOH DR ./CAMF' HILl_ /PA/!7011 F'H 717 - 737-7:B:BO LtlPLOYER: HALLEYS CON FACT ~4A~'~E: ~[ DIxESS · / / / PH 717 '= ...... ~ .... 47 INSLIRANCE ' ~ .... I.qr ORMATtu PLAN INSURANCE CO COB POLICY SUBSCEBER REL F'C VFY CARD "='=C~ "' ~ . 1 lq:~l AUTO INSURANCE I/0 I .~.-~4.-:..-~J FOSTER ,TROY S Y N ( ']'-' :' ]"] 5~'= - - I ~SUR. A[[RESS. 2 3IN~[IR'ADDRESS' -- ~ . .... tNSUR. ADDRESS: ]OMMEN]'S: CEAIM '~ 02'~230585 :'ATIENT NAtfiE FOSTER ,TROY A PT~: 1; Y: 7._.:,._ HR~: 1,_,1~,~ ~EGISTERED B~: KtDUS EDITED BY: DATE: END OF DOCUMENT bATE CHART PULLEb/AVAILABLE: BY: ' US LAB/X-RAY REPORTT_NG RESULT LAB/X-RAY RESULT: bATE ~&LE A~ON TAKEN: Holy Spirit Hospitol Camp Hill, PA 17011 ~TOHN R. DIETZ E/,IERGEN~/ CENTER Follow-up ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. FOSTER,TROY ACCOUNT ~ 105248 1102 YVERDON DR APT A-8 CHART # 009444 CAMP HILL, PA 17011 SS # 172601821 June 3, 1973 CAMP HILL OFFICE DOB: 05/19/1967 HISTORY OF PRESENT ILLNESS: This 36-year-old gentleman is here for follow up of MRI of his lumbar spine. Since his last visit he has not had any further numbness in his legs nor has he had any incontinence. When questioned further regarding his incontinence he states he had gone to the emergency room about that and he was sent to a urologist who worked him up and did not find anything wrong with him. PHYSICAL EXAMINATION: On physical examination he has negative straight leg raises today in the office and denies any numbness with light touch throughout his bilateral lower extremities. DIAGNOSTIC STUDIES: Review of MRI of his lumbar spine shows no abnormality whatsoever. There is no evidence of disc degeneration. DIAGNOSIS: Low back pain with intermittent numbness, question etiolo~y. PLA/q: At this point in time I would start, him on a course of physical therapy and see how this helps his low back pain. Regarding his complaint of incontinence I would have him be seen by an internist for routine evaluation so that there is one person who knows a little bit more about his entire medical history rather than him going from specialist to specialist. do not see any neurogenic cause of his nu~ness or his incontinence based on his MRI and if these symptoms persist consideration for a nerve conduction study test will be made. I will see him back in six weeks. James A. Shaer, M.D. JAS/rjg DD: 06/04/03 DT: 06/23/03 ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. FOSTER,TROY .ACCOUNT # 105248 1102 Y~ERDON DR APT A-8 CHART # 009444 CAMP HILL, PA 17011 SS # 172601821 May 28, 2003 CAMP HILL OFFICE DOB: 05/19/1967 CHIEF COMPLAINT: "My back is hurting again." HISTORY OF PRESENT ILLNESS: This is a 35.-year-old gentleman who has not been seen for approximately four months. He states his back and left arm had been doing reasonably well up until approximately two weeks ago, when his back started bothering him again. It was very painful for approximately seven days. He started doing some exercises and now for the last several days he has had no pain whatsoever. He describes the pain as radiating down his left leg, and at one point in time he had numbness into his groin and extending over to his right buttocks. He also states that in the last month or two he has had three episodes of incontinence of bowel which have been interspersed, the most recent of which was a week ago when his back was bothering him. The previous two were not during times when his back was bothering him or when there were any other symptoms of numbness. PHYSICAL EXAMINATION: He is able to walk on his heels and toes without any difficulty. Flexors and extensors of bilateral lower extremities are 5/5. Sensation is ~[rossly intact. He has a negative straight leg raise in his left leg. Deep tendon reflexes are diminished at the left knee compared to the right. There is no clonus in either foot. There is a normal Achilles reflex. DIAGNOSIS: Question HNP lumbar spine L5-S1 left side PLkN: His story and physical examination do not necessarily correlate that well. I will obtain an MRI of his lumbar spine and proceed accordingly. He will continue with his physical therapy exercises and use nonsteroidal medications. James A. Shaer, M.D. JAS/skg DD: 05/28/03 DT: 06/02/03 ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. FOSTER,TROY ACCOUNT # 105248 1102 ~VERDON DR APT A-8 CHART # 009444 CAMP HILL, PA 17011 SS # 172601821 February 3, 2003 CAMP HILL OFFICE DOB: 05/19/1967 CHIEF COMPLAINT: Pollow-up nerve conduction study of left upper extremity. HISTORY OF PRESENT ILLNESS: This is a 35-year-old gentleman who has been using a nighttime pillow to keep his elbow from flexing. He states that the numbness and tingling in his left arm have improved. He is not sure if it is related to the pillow. He states that his back pain stil~L occurs but he has no pain running dow~ his leg and his neck is not bothering him. Review of the nerve conduction studies shows no evidence of cubital tunnel syndrome. PHYSICAL EXAMINATION: On physical examination he walks with a normal gait pattern. DIAGNOSIS: 1. Cubital tunnel syndrome of left upper extremity 2. Resolving low back pain PLAN: I will see him back on a prn basis. If his symptoms get worse in his arm, he will present sooner ~]d we will consider a formal nighttime resting splint holding his arm in about 15 degrees of flexion. He is happy with this. He will continue with his exercise program. James A. Shaer, M.D. JAS/pa DD: 02/03/03 DT: 02/07/03 ORTHOPAEDIC SURGEONS OF CENTR~ PA, LTD. FOSTER,TROY ACCOUNT # 105248 1102 YMERDON DR APT A-8 CHART # 009444 CAMP HILL, PA 17011 SS # 172601821 December 23, 2002 CAMP HILL OFFICE DOB: 05/19/1967 CHIEF COMPLAINT: "My neck is feeling better but I am really noticing my back bothering me now, as well as some numbness in my left arm." HISTORY OF PRESENT ILLNESS: This is a 35--year-old gentleman who was seen several weeks ago and started on a home exercise program for his neck. He states his neck is doing much better. He has some numbness in his fourth and fifth fingers of his left hand, which is particularly worse when he awakens in the morning. It intermittently bothers him throughout the day. He has not specifically it noticed its occurrence with moving his neck. He also states that he has pain in his back but it does not radiate down into his legs. He denies any bowel or bladder incontinence, night sweats, or fevers. He is also not awakened from sleep by this pain in his back. He states that after prolonged sitting and getting up it will be a little stiff and then it tends to resolve. PHYSICAL EXAMINATION: He states that his hand is numb in the fourth and fifth digits with flexion of his elbow maximally for approximately 60 seconds. He does not have any worsening of his symptoms in his left hand. He is able to walk on his heels and toes without any difficulty. The flexors and extensors of bilateral lower extremities are 5/5. He has a fingertip-to-toe distance of 0. Deep tendon reflexes at the knee and ankle are symmetrical at 2/4. There is no clonus in either foot. DIAGNOSIS: 1. Cubital tunnel syndrome left upper extremity 2. Resolving cervical sprain 3. Low back pain PLAN: I will send him for a nerve conduction study to further evaluate his symptoms in his left arm and to see if there is any focal entrapment either at his elbow or his neck. He will continue with his home exercise program for his neck. For his back I will send him to formal physical therapy for a home program to be developed and he will start on that. I will see him back in six weeks' time. He will continue with his activities as tolerated. I have no restrictions for him at work. James A. Shaer, M.D. JAS/skg DD: 12/23/02 DT: 01/07/03 ORTHOP~EDIC SURGEONS OF CENT~AL PA, LTD. FOSTER,TROY ACCOUNT # 105248 1102 Y-gERDON DR APT A-8 CH3LRT # 009444 C~u~4P HILL, PA 17011 SS # 172601821 December 2, 2002 CAMP HILL OFFICE DOB: 05/19/1967 CHIEF COMPLAINT: "My neck hurts." HISTORY OF PRESENT ILLNESS: This is a 35-year-old right-hand-dominant waiter who is still working. He was involved in a motor vehicle accident on 11/21, where he was the third of four cars involved in a chain reaction where they were all stopped at a light. A car started it off.by striking a car in the back. He was a driver that was belted. He did not have any loss of consciousness. He was not seen in the Emergency Room. Several days after the accident, he started noticing left arm discomfort and neck pain. He states that his fourth and fifth and some of his third finger started going numb intermittently. He has been on nonsteroidal medication on his own accord. He was seen in the Emergency Room and referred for follow-up. He denies any bowel or bladder incontinence, night sweats, or fevers. He has some difficulty with sleeping. PAST MEDICAL HISTORY: Past medical history, none. Past surgical history, tonsillectomy. Medication, over-the-counter ibuprofen. He has no known drug allergies. Psychosocial, tobacco half a pack per day times 11 years, alcohol six per week. Family history, both parents are alive with no problems; mother has had breast CA in the past. Review of systems, he complains of frequent urination and blood in the urine. He awakens from sleep to urinate. PHYSICAL EXAMINATION: Height: 5 feet 8 inches. Weight: 148-1/2 pounds. Blood pressure: 115/74. Pulse: 70. He is in no apparent distress. He has a full range of motion of his neck. He has some discomfort with turning his head to the left side. He has normal scaptation. He has no evidence of shoulder muscle girdle wasting. Flexors and extensors of bilateral upper extremities are 5/5 with deep tendon reflexes at C5, C6, and C7 being unremarkable. There is no Hoffman. There is negative cross-body adduction test. There is no evidence of subluxation of his ulnar nerve or snapping scapula. On the left side with his elbow bent maximally after about 45 seconds, he had some some numbness in his fourth and fifth digits. CONTINTJED ORTHOPAEDIC SURGEONS OF CENTPJ~L PA, LTD. FOSTER, TROY ACCOUNT # 105248 1102 YVERDON DR APT A-8 CHART # 009444 CD~MP HILL, PA 17011 SS # 172601821 December 2, 2002 CAMP HILL OFFICE Page 2 i~o~r~ ~s~ r~om] ~!1731~, DIAGNOSTIC STUDIES: Rad f · g P / 5 from Holy Spirit Hospital show no abnormalities. DIAGNOSIS: Acute cervical sprain PLAN: I have asked him to start back into his routine at the ~ym. I have given him some neck exercises that he can do on his own. I will see him back in three weeks. He will continue with his nonsteroidal medication and use ice as necessary. I have counseled him about returning to a normal lifestyle and not to avoid things. We will see how things progress. James A. Shaer, M.D. JAS/skg DD: 12/02/02 DT: 12/05/02 DISCHARGE SUMMARY DOB: ~[l~1~ PHYSIC~N: l~* ~l D~GNOSIS: ~ ~~ DATE OF ~ALUATION: I/~ TOTAL g VISITS: ~ TOTAL ~ CANCELATIONS: O TOTAL GOALS OF TR~TMENT Met Pa~Jally Met Not Met Unable to Assess D $ Pain level to /10 D ~ D D ~ Inflammation of ~ ~ ~ Q ~I$ Gi~h of D D ~ D ? ROM of ~ ~ D D T S~eng~ of D ~ ~ C Improve ~n~ional abili~ _ _~ Q D D C TR~TMENT GOALS NOT MET SECONDARY TO: D Insufficient Treatment Time D Surgical Intewention Required ~ Treatment Ineffec~ve c Severi~ of Dys~nction D Rx Discontinued by Physician Z Patient Non-Complianca D Patient Did Not Keep Appts D Other: DISCHARGE ~TIONALE D Pt has received maximum benefit from physical therapy/has returned to normal and pre~orbid status at this dine (pt concurs). ~t has met all or at least 90% of discharge criteria (pt concurs). ~ No subjecdve/objectivel~nctional improvement in pt's status in a minimum period of 4 wks of PT (discussed with MD pdor to DtC of pt). D ~ discontinued by physician. D Pt did not keep appointments/unable to contact. (MD notified prior to D/C of pt). D Fu~her ~eatment indicated but has not been ordered by physician. Q Patient choice. D Le~er sent to pt to ale~ hi~her of D/C decision (MD a~thoHzed). COMMENTS: Objec~ve Status ~ D/C: ~ ~ ~ C~ The~p,st Slgnature~g~ [(~~ /~ Date: 3438 Td~dIe Road, Camp Hil[, PA [70i[ (7]7) ~75-9844 F~x ~7~7) 975-3336 a S~I~cr MdlcaJ company INITIAL EVALUATION ~5 DOB: 5/19/67 AGE: 35 PHYSICIAN: Dr, Shaer DIAGNOSIS: Low back pain DATE OF ONSET: 11/21/02 DATE OF SURGERY: NA Subjective History: Patient is a 35 year old male who presents to PT with chief complainls of Iow back pain with ADL's. Patient reports that he was in MVA on 11/21/02 where he was hit from behind causing his vehicle to hit an SUV in front of him. Since the accident, he has had pain in his central Iow back, left hip, left knee. He states that the pain is not muscular in origin and is more of a "skeletal" nature. He notes the left hip and knee pain as intermittent with weight bearing activities, especially whan carrying heavy trays in his job as a waiter. He notes that stretching helps to decrease his pain including both trunk extension and toe touches. Patient underwent both x-ray and MRI, with no significant pathology noted. Patient was given clearance 3 weeks ago to return to exercising at a gym and was referred to PT for development of HEP for Iow back. Functional Ability/Restrictions: Patient notes Iow back pain with ADL's, including getting out of bed, ¢letting out of a chair, lifting and carrying trays at work. ' Work Status: Full time, full duty Pain Ratin,q 7-8/10 at worst, 1/10 at best, 1-2/10 currently Past Medical History: Unremarkable. No precautions or contraindications to physical therapy. Medications: None Patient's Goals: To decrease pain and return to previous level of function. Objective Findin.qs Posture Inspection: Patient presents with increased mm tone in bilateral lower thoracic and lumbar paraspinal mm. palpation Tenderness elicited over lumbar spine (L4- L5), over left posterior illium and left gluteal mm. Ranqe of Motion: Trunk: All motions WNL with pain noted in central Iow back with bilateral SB. ~-~ Hip: Internal Rotation WNL bilaterally, External Rotation 28° left, 30° right. ,? ~',, Camp Hill Center 3438 Trindle Road, Camp Hill, PA 17011 (717) 975-9844 Fax (717) 975-3336 ~S~ PORTSM~DI CII~E Troy Foster ~ S~l~c~ Mcd~I company Page 2 Initial Evaluation Manual Muscle Te~ Abdominals 515 Back Extensors 4+/5 Hip Flexors 4-/5 left 4-/5 right Extensors 4/5 4/5 Abductors 4-/5 4-/5 Internal Rot 4/5 4+/5 Knee Extensors 4-/5 445 Hamstrings 4-/5 4-/5 Ankle 4/5 4/5 Special Tests: Negative SLR testing bilaterally. Joint mobility testing WNL with pain noted in lumbar spine during spring testing. Patient notes pain in central Iow back with last 10-15° trunk extension when returning from a fully flexed position, however no change in symptoms with repeated testing. No other significant findings during the evaluation. The above information represents all significant subjective and objective findings. Please refer to the enclosed Plan of Care for my assessment, treatment goals, and treatment plan. Please sign and retum one copy of the Plan of Care to JOYNER SPORTSMEDICJNE INSTITUTE, Inc. and retain one copy i'or your records. Thank you for this referral. I will keep you informed of any changes in the patient's status or the treatment plan. Alexis McAIlister MS, PT License # PT 015679-L Camp Hill Center 3438 Trindle Road, Camp Hill, PA 17011 (717) 975-9844 Fax (717) 975-3336 ~ Sc]~c~ ]vf~a] come.my NAME: Troy Foster DATE: 1/8/03 ~ DOB: 5/19/67 AGE: 35 PHYSICIAN: Dr. Shaer DIAGNOSIS: Low back pain DATE OF ONSET: 11/21/02 DATE OF SURGERY: NA Assessment: Patient is a 35 year old male who presents to PT with diagnosis of Iow back pain following MVA on 11/21/02. Patient would benefit from PT inte~ention in order to increase streng~ and flexibili~ and to decrease pain with ADL activities through independent HEP. Rehabilitation Potential: Good Goals: (to be achieved in 2 visits) 1. Patient will be independent and compliant with HEP including trunk stabilization exercises. 2. Patient will independently manage Iow back s~ptoms through integration of trunk stabilization a~ivitJes with work activities and HEP. 3. Patient will be independent wi~ postural self corre~ion techniques. 4. Patient will demonstrate appropriate body mechanics with pe~o~ance of HEP and work related activities. Treatment Plan: Patient will be instructed in HEP including flexibili~ activities, t~nk stabilization exercises and t~n~LE strengthening Jn ~njun~ion with postural education and instruction in proper body mechanics. Reassessment will be ongoing and treatment plan will reflect appropriate changes. Frequency: 2 visits I have discussed ~e above trea~ent plan and expected outcomes with the patient. He/She is aware of the diagnosis and prognosis and has voluntarily agreed to padicipate in physical therapy. Thank you for this mfe~aE Alexis M~li~er MS,PT ...... License ~ PT 015679-L In a~ordance with accepted medici practice s~nda~s, I hereby cedi~ that the abort named patient requires mhabili~tion se~ices for ~e problem (s) iden~fi~ above. As such, I request that the centers professional staff evaluate ~:~;~e::~hs)~ patient's need for said se~es and provide a deta,l~ patient care plat, for my approval (,o be reviewed Physician's Signature: -- X~ Date: ~]~]~ 01/08/2003 I~B: 10 ?]. ??~'1 26~16 SVPM PA~E S ue nna Valley Pain M agement. 175 ~ter M~h~ioburg, p~ 17055. 717~9~-3731. P~t: ~, T~ DOB: ~/~/67 P~ici~: No~ ~: ~OST~O~030107_ SEX: M~c Ref. Phys: l~es S~ C H ~ s:~ CO~T: Pa~ i~ ~ 35 y~ old ~e ~o p~ ~ le~ u~ ~bn~ ~ ~ ~ng ~ ~e ~bow ~ ~e ~ ~. The ~ent ~ ~p~s b~ 11-21 ~2 ~ ~ ~ ~e ~6~t ~ ~d x-~ys ~d l~b~ ~ne ~ch be r~ ~ n~, S~Y OF ~GS: ~ f~s VNu~* ........ '- -- y. . n ~, [~m offi~lla~on~ ~ve ~ ~v~ ~fl Abd ~1~ ~im ~8-~ ~ml ~ ~ml Nmi Nmi 0 Nmi Nmi ~fl ~~ ~m ~ ~ml ~ml Nmi N~ ~ml 0 ~ Nmi ~fl ~f ~ C8, TI Nmi ~ml ~ml Nmi ~ 0 N~ Nmi ~ ~Tu~ ~ G&7 ~ml ~l Nmi ~ Nmi 0 ~ ~ ~s ~d~(P~t) C7~ Nmi ~ml Nmi N~ N~ 0 ~ml Nmi ~ ~ P~P ~mi ~ N~ N~ Nmi ~1 N~I 0 Nmi ~ C5 P~p ~mJ C$ Nmi N~ Nmi Nmi Nmi 0 Nmi ~ ~Pamsp R~i C6 Nmi ~1 Nmi Nmi ~ml 0 Nmi Nmi ~ C7 ~ ~i C7 N~ Nmi ~ Nmi Nmi 0 N~ Nml ~ 08 P~ ~i C8 Nmi Nmi Nmi N~ Nmi 0 N~ ~R T1 P~ ~i TI Nmi Nmi N~ Nmi Nmi 0 Nm] Nml MoOr Nc~ ~ ~*t N~eV ~p Nom~p N~ ~tN~e ~ ~t Vel ~ 3J2 ~.2 10.~ >5.0 5.?g ~l~w-~6$t 4.~ ~ 52.13 E~w 7,7~ 11.17 6.41 W~ 3.05 ~ 7,45 >3.0 6.~ B ~-W~ 3.52 20 ~.~ >~.0 ~w 6.~ 6.~ 7.03 A ~w-15 ~w 1.~ t0 58.14 >53.0 E~ g,2g 6,~ PAGE ~7 Patent: Foster, T~y Test Date: 1/7103 p. 2 Sensory Nerves W~e ~.~ ~.7 ~ >15.0 W~-5~ ~ 3.~ 14 ~.~ >~.0 A ~w 8.~ ~,35 A ~ ~to~ 1,~ 10 ~. 10 W~ ~.~ ~.6 21.65 >10.0 W ~-2nd ~ 3.50 14 ~,~ ~39.0 Thank-you for your kind retetrnl. No.nan I-Iaueisc-n, D.O. IlOly ~ of Radiolog:y~l~d Diagnostic .. _~mp Hill, Pennsylvania 17011 (717) 763-2600 TIENT: FOSTER, TROY A DICTATION DATE: Nov 25 2002 2:04P ',#: 181325 TRANSCRIPTION [;)ATE: Nov 25 2002 7:00P ,C SEC: 172-60-1821 ',D DR: PATRCIA KATZENMOYER,CRNP/M.D. TYPE: E ADM DATE: 11/25/2002 ~B: 05/19/1967 ARRIVAL DATE: 11/25/2002 CATION: ER3- HOSP SERVICE: E,R3 ***Final Report*** AMINATION: CERVICAL SPINE (6V) 72052 - 11/25/2002 COMMENTS: Indication: MVA. The posterior alignment is normal. There are no fractures. There is no precervical soft-tissue swelling. There is, however, straightening of the usual cervical lordosis above the C5-6 disc level which could be a reflection of muscle spasm? There is no rotational deformity. There is no neural foraminal encroachment. There are no significant degenerative changes in the cervical spine. The C1-C2 relationships are normal. CONCLUSION: Straightening of the upper cervical lordosis. This could be related to spasm? No fractures or other significant anatomical abnormalities seen about the cervical spine. DICTATED BY: HOWARD BRONFMAN M.D. / DEB DATE OF EXAM: 11/25/2002 SIGNED BY: HOWARD BRONFMAN M.D. DATE/TIME: Nov 25 2002 7:28P Imaging Services Consultation Page 1 JUNE 2, 2003 DR. SHAER ORTHOPEDICS OF CENTRAL PA 99 NOVEIv~ER DR/VE CAMP I-IILL, PA 17011 RE: TROY FOSTER DOB: 05/19/67 DOS: 05/30/03 MRI OF THE LUMBAR SPINE HISTORY: Low back pain. DISCUSSION: Magnetic resonance imaging of the lumbar spine was performed on an open MR unit in the axial and sagittal planes utilizing multipulse sequences. FINDINGS: There is normal vertebral body height and n~axow signal intensity. The disc spaces appear preserved. Multilevel Schmorl's node formation is present within the lower thoracic and upper lumbar region. There is no evidence for significant disc bulging at any of the lumbar spine levels. The central canal and exit foramina are patem. IMPRESSION: 1. No significant disc bulging at any of the lumbar spine levels. The central canal and exit foramina arc patent. Please see comments. LMR/lkj FAX: DR. SHAER (717) 761-4360 ~ " · 5400 Chambers Hill Road Har~'isbui'g, PA 17~ I ! Pi]one 7!7-558-8300 Fax 717-561-8024 "The Patient F~'i~'~dl3, Soh;rio~z " 1/7/03 Susquehanna Valley Pain Management. 175 Lancaster Bird, Mechanicsburg, PA. 170S5. 717-691-3731. Patient: Foster, Troy DOB: $/19/(57 Physician: Norman Haueisen ID#: FOSTER_TROY_030107_ SEX: Male Ref. Phys: James Shaer CHIEF COMPLAINT: Patient is a 3 $ year old male who presents with left upper numbness and tingling starting from the elbow radiating to the fifth digit. The patient reports symptoms began 11-21-02 after a ]VIVA. The patient has had x-rays or the neck and lumbar spine which he reported as normal. IMPRESSION: 1. Normal study. 2. The above electrodiagnostic study reveals no evidence of cubital tunnel, carpal tunnel syndrome or cervical radiculopathy at this time. SUMMARY OF FINDINGS: Motor and sensory nerve conduction studies revealed normal distal lat~acies, amplitudes and conduction velocities for lei~ median and ulnar nerves. In particular no slowing or amplitude drop accross the elbow. Monopolar needle EMG was performed in selected left upper extremities, innervated by C5-T1 nerve roots inclusive. No spontaneous activity was seen in any muscles tested in the form of fibrillations, positive sharp waves or fasciculations. Voluntary motor unit morphologies are otherwise normal. EMG Side Muscle Nerve Root lusAct Fibs Psw Amp Dur Poly Recrt IntPat Comment Left Abd Poll Brev Median CS-T] Nml Nml Nmi Nmi Nmi 0 Nmi Nmi Left ABD Dig/ffmimi Ulnar C8-TI Nmi Nmi Nmi Nmi Nmi 0 Nmi Nmi Left FlexDigProf Ulnar C8, T1 Nml Nmi Nm1 Nmi Nmi 0 Nmi Nmi Left PronatorTeres Median C6-7 Nmi Nmi Nmi Nmi Nmi 0 Nmi Nmi Left ExtIndieis Radial (Post tnt) C7=8 Nmi Nmi Nml Nmi Nmi 0 Nmi Nmi Left C4 Parasp Rami C4 Nmi Nmi Nmi Nmi Nm[ 0 Nmi Nmi Left C5 Parasp Rami C5 Nmi Nmi Nml Nmi Nmi 0 Nmi Nmi Left C6 Parasp Rami C6 Nmi Nmi Nmi Nmi Nml 0 Nml Nmi Left C7 Parasp Rami C7 Nmi Nmi Nmi Nmi Nmi 0 Nml Nml Left C8 Parasp Rami C8 Nm] Nml Nmi Nmi NmJ[ 0 Nmi Nml Left TI Parasp Rami Tl Nm] Nmi Nmi Nmi Nmi[ 0 Nml Nmi Motor Nerves Site NR Onset Norm Onset O-P Amp Norm Amp Neg Dur Segment Name Delta-O Dist Vel Norm Vel (ms) (ms) (reV) (reV) (ms) (ms) (cra) (m/s) (m/s) Left Median (Abd Poll Brev) Wrist 3.52 <4.2 10.82 >5.0 5.78 Elbow-Wrist 4.22 22 52.13 >50.0 Elbow 7.73 11.17 6.41 Left Ulnar (Abel Dig Min)-elbow at 90 degrees Wrist 3.05 <4.2 7.45 >3.0 6.88 B Elbow~Wrist 3.52 20 56,82 >53.0 B Elbow 6.56 6.77 7.03 A Elbow-B Elbow 1.72 10 58.14 >53.0 A Elbow 8.28 6.63 7.27 Patient: Foster, Troy Test Date: 1/7/03 p. 2 Sensory Nerves Site NR Peak Nora Peak P-T Amp Norm Amp Segment Name Delta-P Dist Vel Norm Vel (ms) (ms) (pV) ~V) (ms) (cm) (m/s) (m/s) Left Ulnar Anti (Sth Digit)-elbow at 90 degrees Wrist 3.44 <3.7 68.44 >15.0 Wrist-Sth Digit 3.44 14 40.70 >50.0 B Elbow 6.88 71.95 B Elbo,x,-Wrist 3.44 20 58.14 >53.0 A Elbow 8.44 73.35 A EIbow-B Elbow 1.56 10 64.10 >54.0 Left Median Anti (2nd Digit) Wrist 3.50 <3.6 21.65 >10.0 Wrist-2nd Digit 3.50 14 40.00 >39.0 Elbow 1.94 43.94 Elbow-Wrist -1.56 7 44.87 >48.0 Thank-you for your kind referral. Norman Haueisen, D.O. Left Median Anti Sensory a Select Mccall DOB: ~llq IO~ - DA~ OF ~ALUA~ON: TOTAL SVIS~S: ~ TOTAL $ cANCEL~ONS: Met Pa~ially Met Not Met Unable to ~sess GOALS OF TR~~ENT ~ ~ Pain I~et to /10 O ~ inflammation of O TI~ Gi~ of O T ROM of 0 ~ ? S~eng~ of ~ Imorove ~ncfionai abili~ _ _ ~ ~O~er~.~CO~ [(CL~6 ~ TR~T~ENT GOAL~ NOT ~ sEOONDARY Z insufficient Treatment Time 2 Surgi~l inte~ention Required E Treatment Ineffec~ve ~ ~ Discontinued by Physician ~ Pa~ent Non-Compliance ~ Seved~ of Dys~nctian ~ Pa~ent Did No~ Keep Appts ~ O~en DISCHARGE ~TIONALE ~ Pt has receiv~ maximum benefit from phySi~l ~empy/has re~med to no~al and premorbid status at this time (pt con,rS). cdteda (pt concurs). ~t has met all or at least 90% of discharge ~ No subjec~ve/objecQvel~nc~onal imgrovement in pfs status in a minimum pedod of 4 wks of PT (discussed with MD pdor to D/C of ~ ~ d scontinued by physidan. ~ Pt did not keep apgointmenmlunable to con~ (MD notified pdor to D/C of ~ Fu~er ~ea~ent indicated but has not been ordered by physician. ~ PaQent choice. ~ Othen DISCHARGE p~N ~Pt is to follow a specific home exercise program (see coMMENTS). . as been o~e~ for home u~ (see Co~ENTS). Q Equlpmen~ ~J _. ,..~.~ hi~ of DIG d~sion (MD Q COMMENTS; ~ Camp ~11 Center 3438 Trindle Road, Camp Hill PA ~7011 (?17) 975-984{ Fax (717) 975-3?6 INITIAL EVALUATION_ j ~/.~,_~ DATE: 1/8/03 NAME: Troy Foster AGE: 35 DOB: 5/19/67 DIAGNOSIS; Low back pain PHYSICIAN: Dr, Shaer DATE OF ONSET: 11/21/02 DATE OF SURGERY: NA Patient is a 35 year old male who presents to PT with chief complaints of iow back pain with ADL's. Patient reports that he was in MVA on 11/21/02 where he was hit fi'om behind causing his vehicle to hit an SUV in front of him. Since the accident, he has had pain in his central Iow back, left hip, left knee. He states that the pain is not muscular in origin and is more of a "skeleta'l" nature. He notes the left hip and knee pein as intermittent with weight bearing activities, especially when carrying heavy trays in his job as a Waiter. He notes that stretching helps to decrease his pain includin(] both trunk extension and toe touches. Patient underwent both x-ray and MRI, with no significant p;~thology noted. Patient was given clearance 3 weeks ago to return to exercising at a gym and was refe~rrad to PT for development of HEP for iow back. Functional AbilityIRestrictions~ Patient notes Iow back pain with ADL's, including getting out of bed, getting out of a chair, lifting and carrying trays at work. Work Status: Full time, full duty 7-8/10 at worst, 1/10 at best, 1-2/10 currently Unramarkable. No precautions or contraindications to physical therapy. Medications: None Patient's Goals: To decrease pain and return to previous level of function. _Obiective Findin.qs: Patient presents with increased mm tone in bilateral lower ~;horacic and lumbar parasplnal mm. Palpation: Tendemess elicited over lumbar spine (L4- L5), over left posterior illium and left glutaal mm. Ranqe of Mot on: Trunk: All motion's WNL with pain noted in central Iow back with bilateral SB. Hip: Internal Rotation WNL bilaterally, External Rotation 28° left, 30° right. I ' Camp Hill Center 3438 Trindle P~oad, Camp Hill, PA 17011 (717) 975-9844 Fax (717) 975-3336 a Self'cc Medi~l company Troy Foster Page 2 initial Evatuation Manual Muscle Testin0J.' Abdominals 5/5 Back ExtensorS 4+/5 Hip Flexors 4-/5 left 4-/5 right Extensors 4/5 4/5 Abductors 4-/5 4-/5 Internal Rot 4/5 4+~5 Knee Extensors 445 4-~5 Hamstrings 4-~5 4-/5 Ankle 4/5 4/5 Negative SLR testing bilaterally. Joint mobility testing WNL with pain noted in lumbar spine dudng spring testing. Patient notes pain in central Iow back with last 10-15" trunk extension when returning from a fully flexed position, however no chang~ in symptoms with repeated testing. No other significant findings during the evaluation. The above information represents atl significant subjective and objective findings. Please refer to the enclosed Plan of Care for my assessment, treatment goals, and treatment plan. Please sign and return one copy of the Plan of Care to JOYNER SPORTSMEDICINE INSTITUTE, inc. and retain one copy for your records. Thank you for this referral. I will keep you informed of any changes in the patient's status or the treatment 'plan. Alexis McAIlister MS, PT License Cf PT 015679-L Camp Hill Center 3438 Trinclle Road, Camp Hill, PA 17011 (717) 975-9844 Fax (717) 975-3336 CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law finn of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the NOTICE OF INTENT TO OFFER DOCUMENTARY EVIDENCE PURSUANT TO RULE 1311.1 upon all counsel of record via postage prepaid first class United States mail addressed as follows: Andrew Lehman, Esquire 2411 North From Street Harrisburg, PA 17110 Attorney for Defendant Ma~ T(~reraets ~ Dated: ~l ~/[Q ~ 279128-1 TROY A. FOSTER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA v. CIVIL ACTION - LAW NO. 2003-4447 JUAN JIRAL, Defendant JURY TRIAL DEMANDED STIPULATION TO LIMITATION OF MONETARY RECOVERY PURSUANT TO RULE 1311.1 To: Juan Jiral, Defendant, by and through his attorney Andrew Lehman, Esquire Plaintiff, by and through counsel, Angino & Rovner, P.C., stipulates to $15,000.00 as the maximum amount of damages recoverable upon the trial of the appeal from the award of arbitrators in the above-captioned action. Troy Foster Name of Plaintiff ANGINO & ROVNER, P.C. aw~. Lutz I.D. No. 35;956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-61791 Date: '~ i IQ -4fi} Attorney for Plaintiff 279127-1 CERTIFICATE OF SERVICE; I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a tree and correct copy of the STIPULATION TO LIMITATION OF MONETARY RECOVERY PURSUANT TO RULE 1311.1 upon all counsel of record via postage prepaid first class United States mail addressed as follow:s: Andrew Lehman, Esquire 2411 North Front Street Harrisburg, PA 17110 Attorney for Defendant ma~j~T~ G~[mets~ Dated: q .~C~ ~ 279127-1 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 TROY A. FOSTER Plaintiff JUAN JIRAL Defendant. (X) Civil Action - Law ( ) Appeal from Arbitration () (other) The trial list will be called on September 28, 2004 and Trials commence on October 25, 2004 Pretrials will be held on October 6, 2004 (Briefs are due 5 days before pretdals.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 2003 Civil 4447 Indicate the attorney who will try case for the party who files this praecipe: Andrew C. Lehman, Esquire, Nealon & Gover, P.C., 2411 North Front Street, Harrisburq, PA 17110 (Attorney for Defendant) Indicate trial counsel for ether parties if known: David L. Lutz, Esquire, Anqino & Rovner, P.C., 4503 North Front Street, Hardsburq, PA 17110 (AttomeyforPlainti~ This case is ready for trial. Signed: Print Name: Andrew C. Leh~ TROY A. FOSTER, IN THE COUP, T OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNA. v. NO.: 2003-4447 JUAN JIRAL, CIVIL ACTION - LAW Defendant. JURY TRIAL DEMANDED NOTICE OF INTENT TO OFFER DOCUMENTARY EVIDENCE PURSUANT TO RULE 1311.1 TO: Troy A. Foster, and his attorney, David L. Lutz, Esquire ANGINO & ROVNER, P.C. 4503 North Front Street Harrisburg, PA 17110 Defendant, Juan Jiral, by and through his counsel, Nealon & Gover, P.C., intends to offer the documents attached hereto at the trial of the appeal filed from the award of arbitrators, in the manner provided by Rule of Civil Procedure 1311.1. The following documents are attached: 1. Holy Spirit Hospital records (Exhibit No. 1). 2. Medical records from James Shaer, M.D. (Exhibit No. 2). 3. Physical therapy records from Joyner Sports Medicine (Exhibit No. 3). NEALON & GOVER, P.C. n Es uire Andrew C. . q Attorney I.D. No. 81937 2411 North Front Street Harrisburg, PA 1';'110 (717) 232-9900 Date: ~--.,,Z-~. -~,~" ADM. DATE: 11/25/2002 CHIEF COMPLAINT: Some neck discomfort, left shoulder pain, and numbness and. tingling down the left arm. HISTORY OF PRESENT ILl'NESS: Patient states that on Thursday morning he was rear ended. He was the belted driver. He stopped at a red light and was rear ended. He was the third car in the domino effect of a person hitting the cars behind him. MEDICATIONS: Ibupmfen. ALLERGIES: No known drug allergies. REVIEW OF SYSTEMS CONSTITUTION: Patient states that he is generally very healthy. Has not seen a health care provider in sev_eral years. · NECK: Patie~_t states he has some discomfort in the back of his neck. He states it feels like a muscle spasm. CARDIAC: Patient denies chest pain, chest tightness. RESPIRATORY: Patient denies shortness of breath and states that the steering wheel did not. hit him in the chest. Gl: Patient denies nausea and vomiting or any abdominal pain. GU: Patient states he has had no urinary'or bowel problems since the accident. MUSCULOSKELETAL: Patient states that he has discomfort in the left shoulder, scapula area. He states it feels like "when you stub your finger." NEUROLOGIC: Patient states that he did not hit his head. He has experienced no dizziness or black outs. He does have a sensation of some numbness and tingling down his left arm and · into his fingers. He works as a waiter and has not had any problems lifting things or delivering trays. He has not had any experiences of dropping anything. EXTREMITIES: Patient states that his left knee hit either the doorknob or the armrest during the accident.'"He has had some discomfort of that area. He has not had any change or difficu ty in gait, and I~e _h.~s had no hip pain. PHYSICAL EXAMINATION: Vital signs--blood pressure 110/66, pulse 72; respirations 20, temperature 97.3. CONSTI'TUTION:' ir~ general, this 35-year-old gentleman was sit:ling on the chair when entered the room. He is able to stand and move without any physical discomfort. Page 1 of 3 HOLY SPIRIT HOSPITAL Camp Hill, PA NAME:' ~oster;i Tr0~;'A- ........................ 17011 MP,~: 181325 ROOM# ER3 EMERGENCY ROOM REPORT NAA/IE: '. Foster, Tro, MR#: 181325 NECK: Suppl.e, symmetrical, nontender, no lymphadenopathy. Trachea midiine. ']'l~yroid nonpalpable. LUNGS: Normal respiratory effort. Breath sounds equal. No rales, rhonchi; or Wheezes. CHEST: Non-tender to palpation. CARDIAC: Regular rate and rhythm without murmurs, ectopy, rubs, or gallops. No pe. dal edema. Gl: No nausea, vomiting, diarrhea, constipation,, abdominal pain, or rectal bleeding. SKIN: Normal color and turgot. No rashes or lesions. EXTREMITIES': Patient is not able t0 raise his left arm the wholE; way over his head. He is limited in that. he is not able to [ouch the back of his neck with his left hand or reach under and touch his mid 15ack with his left hand. He states that the limitation is not because he cannot but because it feels like it is pulling and going to spasm if he forces it. He has equal grip strength in both hands, good radial pulses bilaterally. There is no obvious abnormality of his shoulder or shoulder blade. He has no tenderness on palpation to his thorack: spine. There is slight tenderness to the left of his cervical spine. He states when it is prassed that it feels like a muscle spasm. Patient has good sensation and reflexes of his arrns and legs bilaterally. He has fult range of motion of his left knee and hip with good pedal pulses bilaterally. NEUROLOGICAL: Alert and oriented to person, place, and time. Cranial nerves intact. Sensory and motor function normal. Reflexes symmetrical. MEDICAL DECISION MAKING: Cervical spine x-ray was read by the radiologist as no fracture, straightening upper C-spine, questionable muscle spasm. The case was discussed with Dr. Sharma. She gave no new orders. Patient was discharged with a prescription for Celebrax 200 milligrams p.o.b.i.d., dispense 14, and Flexeril 10 milligrams p.o.t.i.d., dispense 12 tablets. Limitations on use of Flexeril and not ~lriving or operating machineq! while taking the Flexeril were discussed. Patient was given information on the family doctor's associated with Holy Spirit Hospital and a card for OIP. He was encouraged to follow with a doctor of his choice, either the doctors inform'etlon given to him or one that he had used before that was recommended to him. He was given a note to be off work until the 27th and a note for no gym or sports until reevaluated by his family doctor or ortho. Patient was encoUraged to i'eturn if his symptoms worsened or became severe. He was told that he may be recommended by the family doctor or orthopedics for physical therapy. Page 2 of 3 HOLY SPIRIT HOSPITAL Camp Hill, PA ...... NAME: F~St~-,'Troy;A ............. 17011 MR#: 181325 EMERGENCY ROOM REPORT NAME: ' Foster, Trc. M R#: 181325 Signed DIANE WHIT'COMB, CRNP 12/26/2002 " 15:46 DW/rw DIANE WHITCOMB, CRNP DOC #: 293245 D: 11/25/2002 T: 11/27/2002 3:29 P 009263 ~ - - Pa__~ge 3 of 3 HOLY SPIRIT HOSPITAL Camp Hill, PA NAME: Foster, Troy A 17011 MRS: 181325 EMERGENCY ROOM REPORT (717) 763-2316 ~.~;7~17) 76~-2424 :' ~i~R~ ~'I'~TIO~ HOLY SP~T ~OSP~AL Patient Information: Patient I~tlon sheets contain impo~ant In~evlew and keep. ~ Abdominal pa n e "~ ( ) Cornea abraslo~foreign body ( ) H~adache ( ) Pa n MAnagement ( ( ) A~Is~ c reaction ( ) C~tch waJking ( ) Head fnju~ ( ) Pad atdc Head Inju~ ( ) Too~ache ( ) HypeRe~ion ()As~ma ' ()D[armea and Voml n~P~ V~miting ~lmmuniza~o~e~anus ()PedadcURI ()UR ~nd Co{ds ( ) Back pa n ( ) Disl~ on ( ) PID/STD ( ) UT and Pyelone~hHtis ( ) Bum Kidney Stones ( ) PneumonM ( ) Wound Recheck ( Febrile Con~isi~ ( ) Lacemt on ( ) 24 hr. Pha~acies ( ) Ches Pein ( ) Fever~ed. Fever ( ) Seizure ' ( ) Other ( ) Conjunc ~v tis ( ) Ru ( ) Nec~ Strain ( ) Sore ~roat ( ) COPD ( ) F~cture ( ) Nosebleed ( ) Sprains and StraMs WOUND CARE ( ) Otitis Media ( ) Suture Care & Remov~ ( ) May gentJy wash over wound in 24 hou~ with soap ~d water or MEDICATIONS ( ) Change drying, times daily. Redress with Bacitmcin/N~spofin and steele dre~ing. ( ) Use AdWi 0bupmfen) or Tylenol as need~ for pa~, fever ac~[ng to package insertions for age, we ght. ( ) Keep wound clean, d~, ~vered. ( ) Tetanus/Dip~eHa Booster given. ( ) Use ~e foJ~ow ng medicines a~o~Jng to package SPRAINS, STRAINS, BRUISES, FRAC~RES ' inst~cfions: ( ) Elevate ~e injured pa~ for~da~ to redu~ swelling. 1: ( ) Apply ice pac~ inte~en~ ~r~days to ~duce ~el~ing. 2: ( ) Ace w~ for sup~ fo?~ da~. 3: ) Wear splint ( ) At a~l ~mes un~l folJow-up. ~oflowing mad c nee may ~use drollness: ' ( ) For a~ as ne~ed. DO NOT DRtVE OR OPE~TE MACHINERy WHILE TAKING ) Use s,ng ~r sup~ - ~/~,., ~ . : ) Use c~ches: ( ) AS ne~ed, weight beating as tolerated. - ~ - - . - ( )At ~lJ ~mes. NO WEIGHT BE~ING FOLLOW-UP This is our recommenda~on for ~ollow-up. If your NEC~BACK insurance (HMO) requires a physician refer~ for speciai~ consuRation, IT IS YOUR RESPONStB~L~ TO OffiTAIN THE ( ) Weu ceM~ ~ll~ for su~od for~da~. ~ avoid ~nd]ng, i~ng, sFenuous act ~ for~ days NECESSARY APPROVAL ~ply moi~ heat for~ ~ ~tes ti ' ~o~{ow-up wRh: ~ in 7_~'~ ~ mas dai[y ( ) Urg{ Center ADDmONAL INSTRUC~ONS ~., In ~ -.. days fen ) F~ow-up' )~ff w~s~oo~ from ~ to _ ' ' ) Ught D~ una~: ~ ' ( } Ca~l as s~ as po~le for appoln~nt Rest~ions: ( } Pick up your X-Rays ~m ~e Radioi~ Dep~ent prior to ~o ~s~ unfiJ ~,, 0~ ~. ~ J ~'* ~ ~ ~1c~ your follow-up ~h~ent. CaJJ 76~2696 to have films ) ~llow i~ons on Wo~en s ~nsa~ Fo~. ~ ~ ( ) S~ ~ur ph~icl~.or ~ec alist if not ;mp~ed ) Wear eye pa~ for bourn. )" nose b.~ .~m, pin~ n~ fi~ ,or$ min~., O~ ~.~m to Eme~en¢e Center~;dy;':;.., your ~ndifion ,s WO~ening. ~nanuous~, ~Tm if bleeding not ~ntm[l~. esp~ia~y ~ ~e paM Inamases despite pain relief m~l~tlon. ) ~e pr~cn~ed ant~iotic may r~uce ~e effeteness of ( ) Your blood pressure ~ elevated. Ple~e have medi~on ~u ~ ~ently ~g. Che~ pa~ge r~k~ by ~ur ph~icJ~. ln~ons or ~nsult ~ Ph~a~sL ) ~e interferon ~ your X-~s ~e pre~min~ m~ding. ( ) Test msut~ have ~en gDen to you. T~e ~m w~h you · e ~l~-up ~intment. Your firms ~E be ~ewed ~ a ~o1~ You or'your Test msu~ g~en: E] CBC ~ CMP ~ EKG ~ X-~y COPy ph~ic~ ~ be ~tact~ F ~em ~ a ~ge ~ ~e ~agn~sis. ' ~ BMP ~ RECORDS COPy C~RT ~ GLUC. A~ifio~J Ins~ons: A ~py of your d[c~ted Emegen~ R~m Re~o~ ~ / t her~y a~o~edge m(~lpt of ~ I~ions ~d Unde~d ~em. · . I unde~ ~at I have had eme~e~y treatment ~ be re;~ be~m ~J of my medal problems ~e ~o~ or tmat~. - . ...... J w~l ~ge ~r lo,ow-up ~m ~ [ have ~en bs~ed. It is ~ur respons~il~ to nofi~ ~ Pdma~ Cafe Rhy~ician 5f ~lS ~s[ ( ) PATI~ V~RBA~ES UNDERSTAND~ - . . .. - - ' ................. ' .... ....... V' .... roR~ ~ S~ C~ ~n PA 17 ......... ~ ' ' "· ~ M~ ~ . ~) ~lys ~, ~D. 07~53L ( ) ~ce P~ ~D, Dau~, D.O. 0S~ ( )~ch~ L~, M~. 0299~E ( ) ~J~ Sh~ M~. 031265-E ' - ' ( ) ~ M~. M~. 01s0~a.E ·. ( ) ~ T=p~, ~D. 03~18-E ce wrap for support for~ days. " ( ) Wear [~ptint ( ).At all limes until foflow. (~'~ollowing n tss may cause drowsth ' ( ) For actJvfly as needed. ~ D ess: ( ) Use sting for suppo~ ' · O NOT DRIyE uH OPERA~TE MACHINERy WHILE TA~N~, ( ) Use crutches: ( ) As needed, weight bearing as tciersted,. ,~' t' - . - ( )At all times· NO WEIGHT BEARING FOLLOW-Up This is bbr recommendation for folicw-up. If your NECK/BACK Insurance (HMO) requires a physician referral for special/ ~( ).Wear ca--cai collar for Suppod for'days. ' consuifation, IT IS YOUR RESPONSIBILITY TO OBTAIN THE gicn,ng, houSeS-- fimssda,,y o,icw.u ADDITIONAL INSTRUCTIONS ' C~- Jn __ --~__ _days for:. ( ) FoJicw-up ( )'Off worY./ss~ool from __ to _, . (~---(:, ,:~.etum to work on __ I I - ~-~ ~ ~ O ~ ...... ( ) Suture remove [ ) Light Duty until: _ ( . ) Call as soon as psssibJe (o~' app;:)tht~ant Restrictions: ( ) Pick up your X-Rays from the Radiology Depad~ant prior to C~[SJo gym/sports until~:u, ,. ~,t ~ , ~ J /., /c~,.. ~ your follow-dp appcintmant. Carl 763-2698 to have films ( } FOllOW instmntJons on Workmen,$ Cornpen-sa~ior~ Form. '.~ ~_~[;c-I~:~ ready .......... ~ ( ) See your physician or specialist if not improved in .......... ( ) Wear eye patct{'t0r-__" hours. O/--~'/~ ' -- ' · ) If nose bleed recurs, pinch nose firmly for 5 minutes (~;~et[zm to --- days. 6octinuously, ~tum if bleeding not controfled. Emergency Center if.you feel your cond~on Is w~rsenthg, especially if the pain Increases dsepil~-pain re ef medication. ) The presort'bed antibiotic may reduce the effectiveness of ( ) Your blcod p assure was elevated..Please have it medicaffca you are currently taking. Check package rechecked by your physician, ) The inte~'etation of your X-Rays are preliminary reading. ( ) Test results have been given to you. Take th~m with you to the follow-up appolntmenL Your films will be reviewed by a radiologist. You or your ' Test'results given: rp CBC r] CMP ~ EKG [] X-RAY COPY physic!an will be COntacted if there is a change in the diagnosis, n BMP r~ RECORDS COPY CHART ~ GLUC. Additional instructions: A COpy of your dictated Emegency Room Report s available to your physician from Medical Records (763-2660), if not already sent. ~ I hereby acknowledge receipt of these Instructbns and understand them. ' I understand that J have had emergency treatment on and that I -----'------'--'--'--' be released before all of rn ....... onE, may J will arrange for fciicw-up care as I have been inst~cied, It is your responsibility to not~/your Pdmary Care P/hys~pian of this v slt ( ) PATIENT VEREIALI~E$ UNDERSTAND~'k SIGNATURE.. ~ OLY SPIRIT HOSPITAL EMERGENCY CEN~R ~h~'~a~" - - ~ M.D,/D,C. Nurse RN v~ ASmbam, H,D. 035S40L ~ ) Jca D~bia, D.C. O$ 006ggIL · -- Thomas Aldo~, ~.D. 0~7075E ( ) Madys Hassca, M.D. 0~2553L ( ) ~w'm. ace Paul, ~.D. 039524-L R,~casb A-ora. M.D. 0! 5727~ ( ) $otm p. Sudsoa, MZ). 038368-E - - ( ) R°waz'd P, ud~ic~ M.D, 040862-L GI¢~ Dauphin-y, D.C, 0S00~775E ( ) Pdchard La,ay, M.D. 02ggfO-E ~|coIa. u DaCos~ M.D, 0~3288-L ( ) ~l-J~p Ma~UL-~, M.D. 0~50,53-E ( ) ~Ja.n Tep~s, M.D. 030018.E ~, ....~-- .~.,- ( )~ushp~Mudaa, M.D 0515~4L ~ ~DavidZimm~,MD 005536E · ~EL DSL~$T[TLrFIoN PERMI$$mL£ C i i ? ~, IL L P i I 7 0 I I "~ , ].-bO-i.1, LI ;ONSENTTO MEDICAL TREATMENT ' ' HERESY CONSENT AND AUTHORIZE Holy Spirit Hospital, its agents, and employees, to the rendering of medical care, which may include 3urine d[agnosfic prgceduras, and such medical treatment as my attending or consulting physician considers to be necessary, [ also under- rand it is customary, aSse~t emergency or extraordinary circumstances, that no substantial procedures will be per'u3rmed upon me unless or ntil I have had an opportunity, to d scuss them with a physician or other health care profesaional to my satisfaction. If ave the right to consent or refuse to consent. I understand that the practice of medicine and surgery is not an exadt science and that diagno- is add treatment may involve risks of injury or'even death and acknowledge that no guarantee has been made to me as to the results of any xamination or treatment in this Hospital undamtand many of the physicians on the staff of Holy Spirit Hospital are'not employees cr agents of the Hospital, but rather are.independent ontractors who have been granted the privilege of using these facilities for the care and treatment of their patients. Further, I realize this tospital is a teaching Hospital and at the Hospital are health care personne n tra n ng who, unless ex r ,r may be present during my care as part of the r education St or m i ni~tHr~,~ ~,~,~ ..... p ??sly re. quested oth.e, rw~se, may.participate · Ct on ~. ......... ~. ,..ru~eu ClrCUl[ monitoring of patient care m~y also be ~sed for educational purposes, unless J expressly request otherwise. understand that in order to ensure a safe env ronmant for patients, visitors and staff a property on the premises .ubject to reasonable search and/or seizure at any time without further notice,, s~ :~ELEASE OF MEDICAL INFORMATION authorize Holy Spirit J-{ospital to release to requesting health insurance carrier(s), their representatives and au :are such diagnostic and therapeutic information (including any information relafing to treatment for alcohol and substance abuse ring healthPrOviders, md/or treatment of PsYchiatric disorders, and/or confidential HIV related informatiort, as may be necessary for them to determine benefit anti- lament; to process pa~/ment claims for health-care services p¢ovided during·this hospitalization/treatment episode, and for continuing are/traatment. A photocopy er carbon copy of this authorization sha be considered as effective and valid as th.e or re. al Th ~lso authorizes Medicare, w-Ften applicable, to release to another in ........... = ..... . 'g' . - e undersigned ~ayment upon that claim. ~,.,.,~.,..= '-,=.-~h upon [noir request, medical Inform~.~3--n~eded to ma~;e understand and consent that the manufacturer of any mp antable device inserted by my physician during the co e of my su / ocedure NSURANCE ASSIGNMENT OF BENEFITS authorize payment directly to Holy Spirit Hospital and my treating physicians of all benefits payable under my ins ance p01icie I derstand am responsible to the Hospital and physicians for all charges not covered by this assignment. ;TATEMENTTO PERMIT PAYMENT OF MEDICARE BENEFITS TO PROVIDE, RS, PHYSIClAN~ request payment of Authorized Medicare benefits to me or on my behalf for any services furnished me b o ' ENT ~hys~c~an serv~cas, I authorize any holder of medical and other informafion about ............ y r ~n H,.oly Spent Hospital including · ' ' mm ~u r~ease ~o Nleelcara and its agencies any information ~eeded to determine these benefits for related services. ~IEDICAL ASSISTANCE RECIPIENT Initials ,fy signatures certifies that I received a service or items from Holy Spirit Hospital and Dr. · ' on the date sted be ow. understand that payment for this service or item will be from Federal and State funds, and that any fa se claims, statements, or documents, or ~ncaalment of material may be prosecuted under applicable Federal and State Laws. I understand that certain tests and procedures may not ~e reimbursed by Federal and State funds and that I may be responsible for non covered charges. Aisc, I agree that if at the time of service, if ~m not eligible for Medical Assistance, I will be responsible for balances owed to Holy Spirit Hospital. initials have read and ·understand each of the sect cna contained above. I understand that lb nin this 'roviding.the31~thor'zat,on/ce. sent ocntained In each of the above sec., ........ ~ ..Y~..ig. '"' g t.hl~'~s _cument, I a~ agreeing and u,.,.= where i i*[lals are locate . I h~ve had the opp~rtunl- y to ap~ questlo§s regan:~[Jpg~ac, h c~f-t-t~e sections and all such questions asked ha/~t,~een an~ewle°r,~aJ~'ml~, s. at, I;sfac. c. tlo~.. x._ -fl I '1 ' .... '¥ / I f&a;rLz · ;~kt;'l' ~,- CON3ENTFOR2'REATMENT/RELEA3EOFLVFORMATiON ~ ~"~ [ ¢;~'~DO~ [~ · ' C.~tP ,""ILL - , INSURANCEAESIGNMENT ~ · F l I ~ O ~ '1 Appe.arance:' -. Mental Status: Gastroir Trauma ~a~ ~mo~ed ~rash ~baby ' Ode~a~d ~ugh Bowe~ Sounds Neuro ~N/A GU / GYN Cardiovascular ~Chest pain ~e~ pain Pinpoint ~ ~ ~requency disease ~pacer - l~No Response f Notes -' Notes TRANSFER OR DISCHARGE .............. (:~?i~charged/acCompanied by:... - ' C~'mbulato~ CIw/c ~ambulance toc:~om~ Clnursing home ~AMA_..OOR .... ~other:"-.. (~'o'o'~scharge instn~ctions given to: · - ~"aflent ClfamJly . ~lparent [~t~r;. r~verbalized understanding of d/c instru~ Ons -' O,%port called ~ to_ Qold records sent to floo~ - [3clothing sheet done '" Otxansfen-ed to.. Oconsent signed _ _. lJsfactory ClCrifical CIDecease~ to morgue Holy Spidt Hospital , ,u. ~T~L~O,J ~ Lt;5 CampHilI, PA17011 "C~>~' .kiLL ?'{ J~'0I~, · John R. Dlelz ECU rd.,/ ~ ~/ ~ ~57 ~3 7- 7.).~0 ~ - Nursing Assessment/Notes ' ~ ~ -~- ~ ~, I £~ (;~OUF ......... ~ ...... HOLY SPIRIT HOSPITAL Camp Hill, PA 17011 Holy Spirit FHC . Dillsburg FHC Duncannon FHC Fair'view FHC Green Hill FHC Spod[ng Hill FHC Camp Hill, PA Dillsburg, PA Duncanr,~n. PA Efters, PA New Cumberland, PA Mech~lnicsburg, PA 763-2461 432-2411 834--3108 83~.9191 774-8400 731-8223 · Work/Sc'hool Excuse For~ and may retu,'n to wor~'sohoo~ on .. ///; '7/0 ~-- ., Please excuse from work/school from to Restriction: Physical Education: .... Medications during wock/school hours: Remarks: Signature ~'~ )/~, '~-(; C'P.z,/Z"~ M.D./D.O._,, Date: i/-.~-6~ No. 59 CERTIFICATE TO RETURN TO WORK OR SCHOOL Rev. 8/93 P~ADIOLOGIST/FILE COPY e~ORITY ' ,J~ CAMP. HILE; PA 170] ~ ' ~RDER ~: 90001 PHONE; (717) 737:~30 M~ REC~; 181325 ... AGE: 35Y ADM ~ 19997535 .,. ~RDDATE: Nov252002 1:05P~ DOg: 0~1911967 .~:~ ~M DATE . '~ : Nov 25 2002 1:05PM .. PROC ~ DESC ~ CERVICAL SPINE 72052 ~ ~ MMENT~ ~ O~gen- " .: 1938588 _FOR RA~DIOLOGiST,8 USE ONLY READING RADIOLOGIST: [ME R DICTATE TOTRL P.01 "· Holy Spirit Hospital Department of Radiolog~ and Diagnostic Imaging Camp Hill, Pennsylvania 17011 (717) 763-2600 'lENT: FOSTER, TROY A DICTATION DATE: Nov 25 2002 2:04P ~: 181325 TRANSCRIPTION DATE: Nov 25 2002 7:00P ; S'EC: 172-60-1821 3 DR: PATRCIA KATZENMOYER,CRNP/M.D. TYPE: E ADM DATE: 11/25/2002 B: 05/19/1957 ARRIVAL DATE: 11/25/2002 ;ATION: ER3- HOSP SERVICE: ER3 · **Final Report*** AMINATION: CERVICAL SPINE (6V} 72052 - 1112512002 COMMENTS: Indicat~n: MVA. The posterior alignment is normal. There are no fractures. There is no precervical soft-tissue sweliingl There is, however, straightening of the usual cervical lordosis above the C5-6 disc level which could be a reflection of muscle spasm? There is no rotational deformity. There is no neural foraminal encroachment. There are no significant degenerative changes in the cervical spine. The C1-C2 relationships are normal. CONCLUSION: Straightening of the upper cervical lordosis. This could be related to spasm? No fractures or other significant anatomical abnormalities seen about the cervical spine. DICTATED BY: HOWARD BRONFMAN M.D. / DEB DATE OF EXAM: 11/25/2002 SIGNED BY: HOWARD BRONFMAN M.D. ~ DATE/TIME: Nov 25 2002 7:28P 4ode.~f Arrival: BLS [] .ALS [] Othert BP: Tr!age: ~ __- ^d nc dDir vee ~xposure to meas~s, chx~ pox, TB~ Yes'~ No~ , ' ~'~ PAI~ ASSgSSME T ~ Locati~ ~ None~ ~ HTN~ CAD~ int~¢~~ -/¢ 110 CHF~ ASTHMA~E~ STROKE _ N~DDM ~ IDDM U/ ~ U ~t~ong Baker U Ot~~ Pre~sure~ Burning ~¢ Allergies · _ -- Frequency_. . Latex Allergy Yes ~ N~ ~ What re ~ UTD~ Not UTD~ Triage Notes: Tetanus LMI HOH~ ~ No~ Treatment ~ Tfiage~ ~ info obtained by: EMT ~ Medic ~ List ~ Bo~les ~ Patient ~ Dose Meds Dose leds Unknown [] Injury: Place Occurred:- :[3 Other S~!n Color:. WNL [] Mottled [] Cyan6tic _r Skin 'l'emp: Warm [] ' C&ol [] Distal Pulses: Yes [] No [] IEdema: Yes[] No[] Deformity: . Yes [] No [] Ecchymosis: . Yes [] No [] Initial 'Lab & X-Ray Orders: Labs _Cardiac Respiratory [ ] Acetaminophen [ ] DOAS, i: ] Thmmbolytic Labs [ I Monitor [ J ASG*s [ ] Acetone (SACE) [ ] ESR [ ] Tox Screen [ 1 EKG [ ] Peak Flows Before/After Resp. Tx. [ ] Alcohol (ALCO) I ] Glucose [ ] Udne Tox Screen [ ] 02. [./Min. [ ] Respiratory Tx. . I ] Amylase/Lipase ( ] HCGS [ ] TSHR. [ ] 02 Saturation i ] APTr [ ] HIV [ ] Type&Cross -- # of units · [ ] BBH [ ] Liver (BOR) Medications / IV's / Additional Orders · [ i Blood Cultures Profile [ ] Type & Screen [ ]SMP [ ]Lyres [ ]UA:[ ]~lpi ]DIAG. Date/T~me [ ] CBCP [ ] Pher, obed3 [ ] Udne C & S Date/Time/~nt [ ] CMP [ ] PTP [ ] Urfne HCG iV: NSS/DSW/LPJ D5/.45NS/D5. gNS [ ] CRP1 [ ] Salicylate [ ] WC Breath AIco Tes( WO/KVO/lnfuse at_. mis/hr .[ ]Digo~th i ]Theo [ ]WCDmgScreen [ ] Obtain old records i ] Dilantin [ ] Othec .' [ ]Td Radiolo.q¥ [ ] Abd/Obstr. Sedes [ ] KUB [" ] Protocol initiated for: [ ] Clavicle R L [ ] Mandible [ ]ChestRm./Port/TPA. - [ ]Orbt - R_ L [ ]Elbow fl L [ ]PeMs ~, [ ] Factal -'_ [ ] Pyelogram IVp i ] Finger R L [ ] Shoulder R L [ ]Foot R L [ ]Skull [ ] Forearm R L [' ] Sternum [ lHand R L [ iT/Spine [ ]Hip R L [ ]'Jib/Fib R L [ ]Humerus R L [ ]Toe R L [ ]Knee R L [ ]Wdst R L [ J Other:. ~me/CRT/Jnt. .Special Procedures: Ultrasound: CT: 0NoW[th contrast; WO=Without) [ ] Abdomen [ l AbdomerVPelvls W WO [ ] VQ ~can [ ] Duplex Doppler [ ~ Brain/Head W WO [ ] Echo- [ ] Gaflbladder [ ] Chest W WO cardiogram [ ] Pe~virJ [ ] Spiral chest for PE TransvaginaJ [ ] Othec, [ ] Beta Strep AG Rapid [ ] Stoo~ C & 8 rlitJals.-~__~=.~ [ ] Cervica[/Gen~tst .-~ [ ] Stoo~ O A P R~ [ ] Chtamydia i J Stool C. Dth'~'le Initials: _ Signature:: RN/MA ( ]GC Culture [ ] Tdchomcnas [ ] Mor~sp0t (rapid) [ ] ~N~Und C A S Dictated: Halt [ ] Completed [ ] . C.P.,LTJ,CAL CARE: .. hrs. Billing Classification: - PHYSICIAN CHARGE · FACILITY CHARGE __ [ ] [.eve( I [ ] Lav~l I' ' ' [ ] Acc~ent · [ ]Level/! [ ]Lavelll [ ]Med'~al Consulting/Admitting physician: ~ ~-"~t/..~.,. ...... [ ] Level IV [ ] level IV [ ] Extended Hfs. Signatur · "~'~J~. OqE'/V P [ ]LevelV [ ]LevelV Dete:JIl.~/oA ~ '1 Ti ia" ' , ~k0r .......... JohnR. Dietz Emergency Center ~ ! C .~ t.t~ i~ I L~ E' FOSTER .TROY A -"' ........, , ..~ .:,.., ,,"~?. ~: , :, .-_, ~ .-_ "=5= ~ 1102 ¢HDATE: 05/!'~ "':~'' · - - - OCCUF'ATZ O,~ = ~ES~: / / / ~ '~ 717 .-- ~ ........... RCH: PROTESTAN ]- '~EH-I-: E?IERGEr,.~C y :i~:'.~]'A ~: FOSTER .BARB .... F INFORh~AT~ON ' REL ]'~ F'T: f,r., L~,, L'~ /~¢-~,'1P' HILL /?A/17'i~j, ,,, ,:: ........ ~ - ~ · Fn 717 -- ,_,._,~-~(.~.~ -,=~. ~ REL TO F'T' ' - - / / PH ':'~' ,-, ~] DR: 1,_,..~,1,:, ED r~: '.i,iDR: !:?,0018 ED GROUF' . ~T DX: ~ ~eZT CL!h',IC CODE: ER:3 ,.HOdi._.~ :R PAIN , BRT IN l=r~l': 5R'F IN BY: ~=~ - ACCIDENT I NFOR,~ AT t £]h,, E/TIP, E: 1i/~1./3,-. 11.15 ACC IND: A dOB RELATED." N LOCATIO?~: 3R!PTION: MVA-F'T DRIVER HIT FROM BEHIND GUAF~ANTOR INFORMATION E: FOSTER ,TROY F"F REI_ TO ....... S RESS: 1102 YVERDON DR /CAMF' ,4ILl_ '.~ .... /F'~/~/OI~ F'H 7&7 - 737'-73:30 LOYER: hR~LEYS CONTACT NAME: [~ESS: / / / F'H 717 = ¢- ..... INSURANCE INFORNATiON PLAN INSURANCE CO COB POLICY SUBSC~BER REL F'C VFY CARD PRECER]'/AUTH · - .- ~4.J . FOSTER ~TROY S Y N '~SUR ~ ADORESS: SUR. ADDRESS. .. 4SUR. ADDRESS: iSUR.ADDRESS: '0 .... BNT"N~E=-~ FDSTER %'TRQY ~ ....... STERED BY': KIDUS EDITED BY: DA TE: ........ '7 .... ~ END OF DOCUMENT DATE CHART PULLE~/AVAILABLE: _ BY: "U5 LAB/X-RAy P.E?OP.T'J:N~ RESULT LAB/X-P, Ay P. ESULT: ~ATE 'T]:ALE ACTION TA,Y. EN: G G · ~' RN/ALA ' ' Holy Spirit Hospital 6omg Hill. PA 17011 ~TOHN R. D_rETZ EAfER~EN~/ CENTER Fo/Iow-up 21~ E~ ~EY. IZ~9 AB ORTHOP~.EDIC SURGEONS OF CENTRAL PA, LTD. FOSTER,TROY ACCOUNT # 105248 1102 Y-VEl{DON DR APT A-8 CHART # 009444 CAMP HILL, PA 17011 SS # 172601821 June 3, 1973 CAMP HILL OFFICE DOB: 05/19/1967 HISTORY OF PRESENT ILLNESS: This 36-year-old gentleman is here for follow up of MRI of his lumbar spine. Since his last visit he has not had any further numbness in his legs nor has he had any incontinence. When questioned further regarding his incontinence he states he had gone to the emergency room about that and he was sent to a urologist who worked him up and did not find anything wrong with him. PHYSICAL EXAMINATION: On physical examination he has negative straight leg raises today in the office and denies any numbness with light touch throughout his bilateral lower extremities. DIAGNOSTIC STUDIES: Review of FLRI of his l'unfoar spine shows no abnormality whatsoever. There is no evidence of disc degeneration~ DIAGNOSIS: Low back pain with ntermzttent numbness, question i etiology. PLAN: At this point in time I would start him on a course of physical therapy and see how this helps his low back pain. Regarding his complaint of incontinence I would have him be seen by an internist for routine evaluation so that there is one person who knows a little bit more about his: entire medical history rather than him going from specialist to specialist. I do not see any neurogenic cause of his numbness or his incontinence based on his MRI and 'if these symptoms persist consideration for a nerve conduction study test will be made. I will see him back in six weeks. James A. Shaer, M.D. JAS/rjg DD: 06/04/03 DT: 06/23/03 ORTHOPAEDIc SURGEONS OF CENTRAL PA, LTD. FOSTER,TROY 1102 I'VERDON DR APT A-8 ACCOUNT # 105248 CAMp HILL, PA 17011 CHART # 009444 SS # 172601821 May 28, 2003 CAMp HiLL OFFICE DOB: 05/19/1967 CHIEF COMPLAINT: "My back is hurting again.,, HISTORY OF PRESENT ILLNESS: This is a 35-year-old gentleman who has not been seen for approximately four months. He states his back and left arm had been doing reasonably well ~p until apP{oximately two weeks ago, when his back started bothering him again. It was very painful for approximate2[y seven days. He Started doing some exercises and now for the last several days he has had no pain whatsoever. He describes the pain as radiating down his left leg, and at one point in time he had numbness into his groin and extending Over to his right buttocks. He also states that in the last month or two he has had three episodes of incontinence of bowel which have been interspersed, the most recent of which was a week ago when his back was bothering him. The previou when. his back was botherin~ him -- ~ two_were not during times symptoms of numbness = u~ when t~ere were any other PHYSICAL EXAMINATION: He is able to walk on his heels and toes without any difficulty. Flexors and extensors of bilateral lower extremities are 5/5. Sensation is grossly intact. He has a negative straight leg raise in his left leg.. Deep tendon reflexes are diminished at the left knee compared to the right. There is no clonus in either foot. There is a normal Achilles reflex. DIAGNOSIS: Question H/~p lumbar spine L5-S1 left side PLAN: His Story and physical examination do not necessarily Correlate that well. I will obtain an MRI of his lumbar spine and proceed accordingly. He will continue with his physical therapy exercises and use nonsteroidal medications. James A. Shaer, M.D. JAS/skg DD: 05/28/03 DT: 06/02/03 ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. FOSTER, TROY ACCOUNT # 105248 1102 YYERDON DR APT A-8 CHART # 009444 CAMP HILL, PA 17011 SS # 172601821 February 3, 2003 CAMP HILL OFFICE DOB: 05/19/1967 CHIEF COMPLAINT: Follow-up nerve conduction study of left upper extremity. HISTORY OF PRESENT ILLNESS: This is a 35-year-61d gentleman who has been using a nighttime pillow to keep his elbow from flexing'. He states that the numbness ~ahd tingling in his left arm have improved. He is not sure if it is related to the pillow. He states that his back pain still occurs but he has no pain running down his leg and his neck is not: bothering him. Review of the nerve conduction studies shows no evidence of cubital tunnel syndrome. PHYSICAL EXAMINATION: On physical examination he walks with a normal gait pattern. DIAGNOSIS: 1. Cubital tunnel syndrome of left upper extremity 2. Resolving low back pain PLAN: I will see him back on a prn basis. I:f his symptoms get worse in'his arm~ he will present sooner and we will consider a formal nighttime resting splint holding his arm in about 15 degrees of flexion. He is happy with this. He will continue with his exercise program. James A. Shaer, M.D. JAS/pa DD: 02/03/03 DT: 02/07/03 ORTHOPAEDIC SURGEONS OF CENTRAL, PA, LTD. FOSTER,TROY ACCOUNT # 105248 1102 YVERDON DR APT A-8 CHART # 009444 CAMP HILL, PA 17011 SS # 172601821 December 23, 2002 CAMP HILL 0FFI~CE DOB: 05/19/1967 CHIEF COMPLAINT: "My neck is feeling better but I am really noticing my back bothering me now, as well as some nlunbness in my left arm.,, HISTORY OF PRESENT ILLNESS: This is a 35-year-old gentleman who was seen several weeks ago and started on a home eXercise program for his neck. He states his neck is doing much better. He has some numbness -in his fourth and fifth fingers of his left hand, which is particularly worse when he awakens in the morning. It intermittently bothers him throughout the day. He has not specifically it noticed its occurrence with moving his neck. He also states that he has pain in his back but it does not radiate down into his legs. He denies any bowel or bladder incontinence, night sweats, or fevers. He is also not awakened from sleep by this pain in his back. He states that after prolonged sitting and getting up it will be a little stiff and then it tends to resolve. PHYSICAL EXAMINATION: He states that his h~ld is numb in the fourth and fifth digits with flexion of his elbow m~imally for approximately 60 seconds. He does not have s~y worsening of his symptoms in his left hand. He is able to walk on his heels and toes without any difficulty. The flexors and extensors of bilateral lower extremities are 5/5 He has a fingertip-to-toe d' ' lstance of 0. Deep tendon reflexes at the knee and ankle are symmetrical at 2/4. There is no clonus in either foot. DIAGNOSIS: 1. Cubital tunnel syndrome lef~ upper extremity 2. Resolving cervical sprain 3. Low back pain PLAN: I will send him for a nerve conduction study to further evaluate his symptoms in his left arm and to see if there is any focal ~ntrapment either at his elbow ~ ~ with his ~ .... --. ..... m ~a~=c~. ~e will continue . . . ~u~= exercise ~rogram for his neck. For his sen~ nlm to formal physical therapy for a home programb~gkb~ will developed and he will start on that. I will see him back in six weeks, time. He will continue with his ctlvitles as tolerated. I have no restrictions for him at work. a .... James A. Shaer, M.D. JAS/skg DD: 12/23/02 DT: 01/07/03 ORTHOPAEDIC SURGEONS OF CENTPJ~L PA, LTD. FOSTER,TROY 1102 Y-VERDON DR APT A-8 ACCOUNT ~ 105248 CH3LRT # 009444 C~kMP HILL, PA 17011 SS # 172601821 December 2, 2002 Ci~MP HILL OFFICE DOB: 05/19/1967 CHIEF COMPLAIA!T: "My neck hurts.,, HISTORY OF PRESENT ILLNESS: This is a 35-year-old right-hand-dominant waiter who is still working. He was involved in a motor vehicle accident On 11/21, where he was the third of four cars involved in a chain reaction where they were all stopped at a light. A car started it off.by striking a car in the back. He was a driver that was belted. He did not have any loss of consciousness. He was not seen in the Emergency Room. Several days after the accident, he started noticin~ left arm discomfort and neck pain. He states that his fourth and fifth and some of his third finger started ~toing numb intermittently. He has been on nonsteroidal medication on his own accord. He was seen in the Emergency Room and referred for follow-up. He denies any bowel or bladder incontinence, night sweats, or fevers. He has some difficulty with sleeping. PAST FfEDICAL HISTORY: Past medical history, none. Past surgical history, tonsillectomy. Medication, over-the-counter ibuprofen. He has no known drug allergies. Psychosocial, tobacco half a pack per day times 11 years, alcohol six per week. Family history, both parents are alive with no problems; mother has had breast CA in the past. Review of systems, he complains of frequent urination and blood in the urine. He awakens from sleep to urinate. PHYSICAL EXAMINATION: Height: 5 feet 8 inches. Weight: 148-1/2 pounds. Blood pressure: 115/74. Pulse: 70 He is in no apparent distress. He has a full range of motion of his neck. He has some discomfort with turnin~ his head to the left side. He has normal scaptation. He has no evidence of shoulder muscle ~irdle wasting. Flexors and extensors of bilateral upper extremities are 5/5 with deep tendon reflexes at C5, C6, and C7 bein~ unremarkable. There is no Hoffman. There is negative cross-body adduction test. There is no evidence of subluxation of his ulnar nerve or snapping scapula. On the left side with his elbow bent maximally after about 45 seconds, he had some some nuahbness in his fourth and fifth digits. - CONTINUED ORTHOPAEDIC SL~RGEONS OF CENTR_~5 PA, LTD. FOSTER,TROY 1102 YlrERDON DR APT A-8 ACCOUNT # 105248 C3t~p HILL, PA 17011 CPLART # 009444 SS # 172601821 December 2, 2002 CAMp HILL OFFICE Page 2 DIAGNOSTIC STUDIES: ad f /25 from Holy Spirit Hospital show no abnormalities. DIAGNOSIS: Acute cervical sprain PI~AN: I have asked him to start back into his routine at the gym. I have given him some neck exercises that he can do on his own. I will.see him back in three weeks. He w' ' his nonsteroldal medication =~ --- : mll continue with · · ~ ~= ~ce as necessary. I have cou~.~ele~ him about returning to ~ normal lifestyle and not to avoid things. We will see how things progress. James A. Shaer, M.D. JAS/skg DD: 12/02/02 DT: 12/05/02 SU' r AR¥ DOB: 51{ ~ /~T PHYSIC~N: TOTAL ~ VISITS: ~ TOTAL ~ CANCEL~TIONS: GOALS OF TR~TMENT Me~ Pa~iaUy Met Not Met Unable ~o Assess ~; Pa~n level ~o /10 ~ ~ ~ Streng~ ~ ~ ~ ~ C . D Improve ~nctional abili~ --~ C TREATMENT GOALS NOT M~ SECONDARY TO: ~ lnsu~cient Treatment Time ~ Surgical Jnte~entJon Required ~ Treatment ineffec~ve ~ Seved~ of Dysfunction ~ ~ Discontinued by Physician ~ Padent Non-Compliance C Patfent Did Not Keep Appts G Othe~ DISCHARGE ~TIONALE ~ Pt has received maximum benefit ~om physi~l therapy/has retume~ to normal and premorbid status at ~is ~me (pt concurs). - ~t has met all or at least 90% of discharge ~teHa (pt concum). D No subjective/objectiv~nctional improvement in pt's status in a minimum period of 4 wks of PT (discussed with MD prior to D/C of pt). D ~ discontinued by physician. D Pt did not keep appointment/unable to con~cL (MD notified pdor to D/C of pt). ~ FuAher treatment indicated but has not been ordered by physician. ~ atlent choice. D O~e~ DISCHARGE P~N ......... ~Pt is to follow a specific home exemise program (see COMMENTS). D Equipment has been o~ered for home u,e (see COMMENTS). C Le~er sent to.pt to ale~ h j~ o~ D/C decision (MD aOthodzed) DO~e~ - ' /'~r ', ,,, COMMITS. uojecuveStatus~D/C: ~)~ ~ ~erapist Signature( O¢~<~~ /~ I._NITIAL EVALUATION DOB: 5/19/$7 AGE: 35 PHYSICIAN: Dr. Shaer DIAGNOSIS: Low back pain DATE Of ONSET: 11/21/02 DATE OF SURGERY: Subjective History: Patient is a 35 year old male who presents to PT with chief complaints ol= Iow back pain with ADL's. Patient reports that he was in MVA on 11/21/02 where he was hit from behind causing his vehic e to hit an SUV Jn front of him. Since the accident, he has had pain in his central low back, leff hip, left knee. He states that the pain is not muscular in origin and is more of a "skeletal" nature. He notes the left hip and knee pain as intermittent with weight bearing activities, especially when carrying heavy trays in his job as He no,es th,=L stretching helps to decrease his pain including both trunk extension and toe touches. Patient underwent both x-ray and MRI, with no significant pathology noted. Patient was given clearance 3 weeks ago to return to exercising at a gym and was referred to PT for development of HEP for iow back. .Funct onal Ability/Restrictions: Patient notes Iow back pain with ADL's, including getting out of bed, getting out of a chair, lifting and carrying trays at work. Work Status: Full time, full duty 7-8/10 at worst, 1/10 at best, 1-2/10 currently Past Medical Histo : Unremarkable. No precautions or contraindications to physical therapy. Medications: None Patient's Goals: To decrease pain and return to previous level of function. P~osture Inspection: Patient presents with increased mm tone in bilateral lower thoracic and lumbar paraspinal mm. Palpation: Tenderness elicited over lumbar spine (L4- L5), over left posterior illium and left gluteal mm. R~anoe of Motion: Trunk: All motions WNL with pain noted in central Iow back with bilateral SB. Hip: Internal Rotation WNL bilaterally, External Rotation 28° left, 30° right. Troy Foster Manual Muscle Testin : Abdominals 5/5 Back Extensors 4+/5 Hip Flexors 4-/5 left 4-/5 right Extensors 4/5 4/5 Abductors 4-/5 4-/5 Internal Rot 4/5 4+/5 Knee Extensors 4-/5 4-/5 Hamstrings 4-/5 4-/5 Ankle 4/5 4/5 Negative SLR testing bilaterally. Joint mobility testing WNL with pain noted in lumbar spine during spring testing. Patient notes pain in central Iow back with last 10-15o trunk extension when returning from a fully flexed position, however no change in symptoms with repeated testing. No other significant findings during the evaluation. The above information represents all significant subjective and objective findings. Please refer to the enclosed Plan of Care for my assessment, treatment goals, and treatment plan. Please sign and return one copy of the Plan of Care to JOYNER SPORTSMEDIClNE INSTfTUTE, Inc. and retain one copy for your records. Thank you for this. refenaL I will keep you informed of any changes i ' ' n the patient s status or the treatment plan. Alexis McAIlister MS, PT License # PT 015679-L Camp ~I ~nter d M~PORTSM~)tCI~N'E I1WSTITUTE ~_ EVALUATION - PLAN OF CARF NAME: Troy Foster DATE: 1/8/03 DOB: 5/19/67 AGE: 35 . PHYSICIAN: Dr. Shaer DIAGNOSIS: Low back pain DATE OF ONSET: 11/21/02 DATE OF SURGERY: NA Assessment: Patient is a 35 year old male who presents to PT with diagnosis of Iow back bain following EVA on 11/21/02. Patient would benefit from PT intervention in order to increase strength and flexibility and to decrease pain with ADL activities through independent HEP Rehabilitation Potential: Good Goals: (to be achieved in 2 visits) 1. Patient will be independent and compliant with HEP including trunk stabilization exercises. 2. Patient will independently manage Iow back symptoms through integration of trunk stabilization activities with work activities and HEP. 3. Patient will be independent with postural self correction techniques. 4. Patient will demonstrate appropriate body mechanics with performance ef HEP and work related activities. Treatment Plan: Patient will be instructed in HEP including flexibility activities, trunk stabilization exercises and trunk/LE strengthening in conjunction with postural education' and instruction in proper' body mechanics. Reassessment will be ongoing and treatment plan will reflect appropriate changes. Frequency: 2 visits I have discussed the above treatment plan and expected outcomes with the patient. He/She is aware of the diagnosis and prognosis and has voluntarily agreed to participate in physical therapy. Thank you for this referraff ,~exls McAlli~er MS~"PT .... License # PT 01 ~(~79-L ========================================================================== and assess the patient's need for said servi~ces and provide a detailed patient care lan for, every 30 days). ,~ P my approval (to be reviewed Physician's S,gnatura \\ ~ ,~ 175 Lnnc~ter Bird, Mechanicsburg, PA. 17055. 717-~91-37~1. Patient: Fost~, T~ DOB: 5/~W67 P~'sici~: No~ ~au~s~ ~: FOST~O~030107_ SEX: M~e Ref~ Phys: ~cs S~er ~. ~ ~:ff CO~T: ~afimt is a 35 ye~ old ~e ~o p~m ~ le~ u~ ~b~e~ ~d fi~ng ~n8 W ~e fi~ ~, The ~fiem ~ ~p~ b~ 11-21~2 ~ a ~r~ ~e ~fimt h~ h~ x-~ys ~ ~e n~ ~d lu~ ~ne ~ch he r~ ~ no~. ~SSION: 1. Nom~ ~dy. 2. The =~ve ~od/~o~6c s~ reve~ no evidence of ~blt~ ~unn~ ~p~ ce~ie~ ~ulopa~ ~ ~b S~y OF M~ ~d ~ n~e ~du~ ~di~ ~ n~ ~ I~es, ~ii~ ~d ~a~0n vd~ M~o~ ~e ~G ~ ~ ~ ~1~ 1~ up~ ~fi~, i~m~ ~ C5-T1 n~e r~ ~ M~d~ ~e R~ [nS Act F~ P~ ~P ~ ft~ ~tPnt ~ent ~fl Abd Pdl ~~ C$-~ N~ N~ ~mI Nmi Nmi 0 N~ ~fl ~~ ~ C~ Nmi N~ Nmi N~ Nmi 0 N~ ~ ~f ~ C8, T1 Nmi Hml Nmi Nmi N~ 0 H~ ~ ~T~ ~ C~7 Nmi Nmi Nmi ~ Nmi 0 N~ ~ ~s ~d~9 C7~ ~ml Nmi Nmi N~ Hml 0 Nmi ~ ~ P~P ~mi ~ N~ H~ Nmi Nmi Nmi 0 N~l ~ff C5 P~ ~m} C5 Nmi N~ Nmi Nmi Nmi 0 N~ Nmi ~ff ~ Pamsp R~i C6 Nml ~ Nmi Nmi ~ 0 N~ Nmi ~ C~ ~ ~i C7 Nmi Nmi Nmi Nmi Nmi 0 N~ Nmi ~ ~ P~P ~i ~ H~ Nmi N~ N~ Nmi 0 N~ Nml Motor ~ ~ ~et NomO~et ~P~p Nom~p Neg~ (~ (~) (m~ (m (~) ~ent N~e ~ W~ 3~2 ~2 10.~ >5.0 5.7g ~l~W~st 4.~ ~ 52.13 ~w 7,73 11.17 6.41 >~.0 W~ 3.~ ~2 7.45 >3.0 6.~ B ~-Wfi~ 3.52 20 56.~ >~.0 ~ ~w 6.~ 6.~ 7.03 A ~w-B ~w 1.~ 10 5~14 A E~w g~g 6.~ Patierlt: Ft~ter, Troy' Te~t ~le: 7/7/03 P. 2 ~so~ Ne~es (ms) (ms) ~ ~e~ N~e ~-P ~t Vel w~t 3.~ ~.7 ~-~ >15.0 w~-5~ ~t 3.~ ~4 ~.70 >50.0 B~w 6.~ 71.95 W~ 3~ <3.6 21.65 >10.0 W~t-2nd ~ 3.50 14 ~.~ >39.0 Norman Hauci~a, D.O. -- * of RadiologyR~[l~d Diagnostic,, ~ ._ .:rnp Hill, Pendsylval~ia 17011 (717) 763-2600 ---NT: FOSTER, TROY A DICTATION DATE: Nov 25 2002 2:04P 181325 SEC: 172-60-1821 TRANSCRIPTION DATE: Nov 25 2002 7:00P DR: PATRCIA KATZENMOYER,CRNP/M.D. 'PE: E 05/19/1967 ADM DATE: 1 ']/25/2002 ,TION: ER3- ARRIVAL DATE: 11/25/2002 HOSP SERVICE: ER3 ***Final Report*** !INATION: CERVICAL SPINE (6V) 72052 - 11/25/2002 MMENTS: Indication: MVA' The posterior alignment is normal There are no fractures. There is no precervical soft-tissue swelling. :re is, however, straightening of the usual cervical lordosis above the C5-6 disc level which could be a reflection of scle spasm? There is no rotational deformity. There is no neural forarninal encroachment. There are no significant: 'enerative changes in the cervical spine. The C1-C2 relationships are normal. NCLUSION: Straightening of the upper ce~ical lordosis. This could be related to spasm? No fractures or other ~ificant anatomical abnormalities seen about the cervical spine. ' TATED BY: HOWARD BRONFMAN M.D. / DER rE OF EXAM: 11/25/2002 NED BY: HOWARD BRONFMAN M.D. rE/TIME: Nov 25 2002 7:28P Imaging Services Consultation Page 1 · JU~E 2, 2003 DR. SHA.ER ORTHOPEDICS 99 OF CENTRAL PA NOVEMBER DRIVE CAM~PH~L, PA 17011 RE: TROY FOSTER DOB: 05/1~}/67 DOS: 05/30/03 MRI OF THE LUMBAR SPINE I~LISTORY: Low back paln~ DISCUSSION: Magnetic resonance imaging of the lumbar spkue open MR ' · · umt m the axial and sagittal planes uti/iz~ng . was performed on an multipu~; sequences. FINDINGS: There is normal vertebra/body height and m~rrow signal intensi - ~_a. ces. app ,ear pre~rved. Mult/level Schmorl's noae fo-- -~ r ry. The d~sc ~uurac~c ana upper lumbar region, ,- ~,rmanon ~ present w/thin the lower There is no evidence for significant disc bul~ing at any Of the lumbar central canal and exit foramina are patent, spine levels. The iMPRESSION: Nex°.tsignificant disc bulging at any of the lumbar spine levels. ]7he central carol and foram/na are patent. Please see comments. · LM~kj FAX: DR. StL4ER (717) 761-4360 ~ .......... 5400 Chambers Hill Road Harrisburg, PA !7111 Phone 7!7-558-~300 Fax 717-56!-8024 Susquehanna Valley Pain Management. 1/7/03 175 Lancaster B/vd, Mechanicsburg, PA. 17055. 717-691-3731. Patient: Foster, Troy DOB: 5/19/67 Phys'~ician: Norman Haueisen ID#: FOSTER_TROY_030107_ SEX: Male Ref. Phys: James Shaer CB'~.F COMPLAINT: Patient is a 35 year old male who presents with left upper numbness and tingling starting from the elbow radiatin to the fifth d/git. The patient reports symptoms began 11-21 - . . and lumbar spxne which he reported as normal 02 after a MVA. The patient has had x-rays or the n~ck IMPRESSION: 1. Normal study. 2. The above eleetrodiagnostic study reveals no evidence of cnbital tunnel, carpal tunnel syndrome or cervical radiculopathy at this time. SU3iMARY OF FiND/NGS: ~{orO~e~a~d~n.s_o_r~ n,erve conduct~jon studies revealed normal distal latenci~ '. '* ,~aii d. litl Ulrlar n - v~ am h - erves. In pamcular no slowino or o,~,---.~- ~ ', p tn.des and conauct~on velocities · . o ""'v"mu~. aro. p ,,ccross the elbow. Monopolar needle EMG was performed in selected left upper extremiues rune mcluszve. No spontaneous activim ~ ....... .-- , , rvated by C5-T -J -~o ~.~ m any musaes tested in tho r~.~, ~t .,,-. 1 n_..~ or fasciculafions. Voluntary motor unit morphologies are otherwise normal. ,~ ~,~,m o~norlllatlolls, positive sharp waves EMG Side Muscle Nerve ~ Root Ins Act Fibs Psw Amp Dur Poiy Loft: Abd Poll Brev M~dian CS-T1 Nmi Nml Nmi Nmi Nml 0 Nmi Nmi - -- _Recr/ [ntPat COmment I,~t~ ABD D//LLf. mimi Ulnar CS-TI Hrnl Nml Nmi Nml lqml 0 lqmi /.~t~ Fl~xD/sProf Ul~ar C8, TI Nmi Nmi Hml lCmi Nmi 0 Nmi l¢'nl Le/~ PronalorT~res M~iia~ C6-7 Nml Hrnl lqml Nmi Nml 0 Hml Nml Left Extlmiids Radial ('Post/n0 C7-S Nmi Nmi Nmi Nmi Nm/ 0 Hml Nmi /.eft C4 Parasp Rami C,4 lqml }Cml Hral Hmi Nm] 0 Nmi Nrnl Left C5 Parasp Rami C5 Nmi Hmi Nmi Nmi Nmi 0 Nml Nmi I~t~ C6 Parasp Rami C6 Nml Nmi Nmi Nmi Nmi 0 Nmi Nmi Left C7 Parasp Rami C7 Nmi Nmi Nmi Nmi Nml 0 Nmi Nmi Lei C8 Pamsp Rami C8 Nmi N'ml Nmi Nmi Nmi 0 Nml Left T1 Pamsp Rarni T1 Nmi Nmi Nmi Nmi Nmi 0 N'ml Nmi Motor Nerves Site NR Onset Norm Onset O-P Amp .Norm Amp Neg Dm- Segment Name DeRa-O Dis/ Vel Norm Vel ('ns) (,ns) (mY) (,nv) Lelt Median (Abd Poll Brev) (ms) (,ns) - (cra) (m/s) (m/s) Wrist' 3.52 <4~2 10.82 >5.0 ~ow 7.73 5.78 Elbow-Wrist 4.22 11.17 6.41 22 52.13 >50.0 Left Ulnar (Abd Dig Min)-clbow at 90 degrees %rrist 3.05 <4.2 7.45 >3.0 6.88 B Elbow-Wrist 3.52 20 56.82 >53.0 ~ Elbow 6.56 6.77 7.03 A Elbow-B Elbow 1.72 10 , Elbow 8.28 6.63 7.27 58.14 >53.0 Patient: Foster, Troy Test Da~e: I/7/03 p. 2 Sensory Nerves Site NR Peak Norm Peak P-T Aanp Norm Amp Segmen! Name Delta-P Dist Vel Norm Vel (ms) (ms) OxY) (~.V) (ms) (cra) (m/s) (m/s) Left Ulnar Anti ('Sth Digit)-eJbow at 90 degrees Wrist 3.44 <3.7 68.44 >15.0 Wrist-5th Digit 3.44 14 40.70 >50.0 B Elbow 6.88 71.95 B Elboxv-Wrist 3.44 20 58,14 >53.0 A Elbow 8.44 73.35 A ElbowB Elbow 1.56 10 64.10 >54.0 Left Median Anti (2nd Digit) Wrist 3.50 <3.6 21.65 >I0.0 Wrist-2nd Digit 3.50 14 40.00 >39.0 Elbow 1.94 43.94 Elbow-Whst -1.56 7 44.87 >48.0 Thank-you for your kind referral. Norman Haueisen, D.O. Moro nti Senso 0om /(ql D~GNOSlS: ~ ~~m DA~ OF ~ALUA~ON: TOTAL~VtS~S: Met pa~a[[y Met Not Met unable to ~sess GOALS OF TR~~ENT 9 ~ Pain l~el to /10 Q ~ inflammation of Q TIS Gi~ of Q Q D Q Q t ROM of D G ? S~eng~ of C C rove ~nctionat abi TR~TM~NT GOALS NOT M~ s~GoNDARY TO: - Insu~cient Treatment Time ~] Su~i~J tnte~entlon Required ~ Tre3~ent tneffec~ve g ~ Discon~nued by physic!~n ] pa~ent Non-Compl~snce ~ Seved~ of Dys~nCfion D O~en ; patient Did Not Keep App~ DISCHARGE ~TIONALE ' ' ; Pt has received maximum benefit from physi~l ~empy/has re~med to normal and premorbid status at ~is Brae (pt concum). ~t has met alt or at feast 90% of dis~arge cdteda (PI concum). subje~velobjecfive/~n~onal improvement in p~s sta~s in a minimum pedod of 4 wks of PT ; No (discussed wi~ MD prior to D/C of pt). ~ ~ discontinued by p~ysid~n.. -He to con~ {MD not,ed pdor to DfC of pt). ~ Pt did not keep appo~ntmen~/unau ~ Fu~er ~ea~ent indicat~ but has not been ordered by physician. G patient choice. DISCHARGE p~N ~ is to follow sped~C home exercise program {see COMNIENTS). ~ Equ pment ha~ been o~e~ for home use (see Co~ENTS). ~ Le~er sent ~ Pt to ale~ hi~ of D/C d~sion (MD Ob]e~e S~tUS ~~ ~ ~ ~V~ 3438 Trindle Koad, Ca~ HILL. PA 17011 (717) 975-9~ Fax (717 975-376 INITIAL EVALUATION NAME: Troy Foster DATE: 1/8/03 DOB: 5/19/67 AGE: 35 PHYSICIAN: Dr. Shaer DIAGNOSIS: Low back pain DATE OF ONSET: 11/21/02 DATE OF SURGERY: NA Subjective History: Patient is a 35 year old male who presents to PT with chief complaints of Iow back pain with ADL's. Patient reports that he was in MVA on 11/21/02 where he was hit from behind causing his vehicle to hit an SUV in front of him. Since the accident, he has had pain in his central Iow back, left hip, left knee. He states that the pain is not muscular in origin and is more of a "skeletal" nature. He notes the left hip and knee pain as intermittent with weight bearing activities, especially whe~n carrying heavy trays in his job as a waiter. He notes that stretching helps to-decrease his pain including both trunk extension and toe touches. Patient underwent both x-ray and MRI, with no significant pathology noted. Patient was given clearance 3 weeks ago to return to exercising at a gym and was referrad to PT for development of HEP for Iow back. Functional Ability/Restrictions: Patient notes Iow back pain with ADL's, including getting out of bed, getting out of a chair, lifting and carrying trays at work. Work Status: Full time, full duty Pain Ratinq: 7-8/10 at worst, 1/10 at best, 1-2/10 currently Past Medical History: Unremarkable. No precautions or contraindications to physical therapy Medications: None Patient's Goals: To.decrease pain and return to previous level of function. Obiective F ndth.cls Posture inspection: Patient presents with increased mm tone in bilateral lower thoracic and lumbar paraspinaJ mm. Palpation: Tenderness elicited over lumbar spine (L4- L5), over left posterior illium and left gluteal mm. Ranqe of Motion: Trunk: All motions WNL with pain noted in central Iow back with bilateral SB. /q,.~ ....~-.~...,, Hip: internal Rotation WNL bilaterally, External Rotation 28° left, 30° right. / .................................................................................... ~. /OYN R Troy Foster Page 2 Initial Evaluation Manuai Muscle Testinc~: Abdominals 5/5 Back Extensors 4+/5 Hip Flexors 4-/5 left 4-/5 right Extensors 4/5 4/5 Abductors 4-/5 4-/5 Internal Rot 4/5 4+/5 Knee Extensors 445 445 Hamstrings 4-/5 4-/5 Ankle 4/5 4t5 Special Test. si Negative SLR testing bilaterally. Joint mobility testing WNL with pain noted in lumbar spine during spdng testing. Patient notes pain in central iow back with last 10-15° trunk extension when returning from a fulty flexed position, however no change'in symptoms with repeated testing. No other significant findings during the eva~uation. The above information represents all significant subjective and objective findings. Please refer to the encJosed Plan cf Care for my assessment, treatment goals, and treatment plan. Please sign and retum one copy of the Plan of Care to JOYNER SPORTSMEDICINE INSTITUTE, lnc. and retain one copy f=r your records. Thank you for fhis referral. I will keep you informed of any changes in the patient's status or the treatment'plan. Alexis McAllister MS, PT License # PT 015679-L Camp Hill Center CERTIFICATE OF SERVICE AND NOW, this .~'~Y"~ of July, 2004, I hereby certify that l have served the foregoing NOTICE OF INTENT TO OFFER DOCUMENTARY EVIDENCE PURSUANT TO RULE 1311.1 on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David L. Lutz, Esquire ANGINO & ROVNER, P.C. 4503 North Front Street Harrisburg, PA 17110 drew C. Lehman, Esquire TROY A. FosTER, plaintiff : IN THE CociRT OF coMMON pLEAS OF : cuMBERLAND couNTY, pENNSYLVANIA ~' ~I~IL 'ACTION - LAW V. : JuAN jIRAL, : 03-4447 CIVIL TERM Defendant L cONFERENCE pRETRIAL ~u~ ...... . r 2004, before Edgar . of OctoDe: , ~n NOW, this 6th day ..... ~ David ~' ~tz~ ~'~d~e, present for the plaintl~ ~=~n Es~~!re B. Bayley, u ~ . ~ Andrew C. Lehma , ~d for the defenGan%, ~ le accident Esquire, =" ~ -f an automOm~ ~{ ~ }-517 ' case ariseS ouL o ~n02' when ee== .... _ November 21,. zu. ~ch plaintiff waS rear ~n~eu chain reactiOn in wn~ admits negligenCe' This is an aPPeal from arbitration for noneconom~C damages which are capPed at $15,000.00 pursuant to pennsylvania If a verdict exceeds that Rule of civil procedure 1311.1. ,000 00 Documents may be amount, it will be molded to $15to t~at'Rule and read to the admitted intO evidence pursuant jury by counsel. If cousel wish to have the documents projected on a screen at the time they are read to the jury, they may do so. Estimated time of trial, °n~/~ Edgar - ' David L. Lutz, Esquire For plaintiff Andrew C. Lehman, Esquire For Defendant pre TROY A. FOSTER, Plaintiff, JUAN JIRAL, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 2003~ ~?.7 CIVIL ACTION - LAW JURY TRIAL DEMANDED Question 1: VERDICT SLIP Do you find that the Defendant, Juan Jiral, was negligent? Yes: X No:. If you answer Question 1 "No", the Plaintiff cannot recover. You should not answer Question 2 and you should return to the Courtroom. If you answer Question 1 "Yes", go on to Question 2. Question 2: Do you find that the negligence of the Defendant, Juan Jiral, was a factual cause in bringing about SOlVe harm to the Plaintiff, Troy Foster?. Yes: V No: If you answer Question 2 "Yes", proceed to Question 3. If you answer Question 2 "No," Troy Foster cannot recover and you should not answer any further questions and should return to the Courtroom. Question 3: State the amount of damages, if any, sustained by the Plaintiff as a result of the accident: Please have the Foreperson sign and date this Verdict Slip. The jury should then return to the Courtroom to make its verdict known. DATE FOREPERSON ~/ 83 101 72 79 CASE NO.: * ~ . ¢,. vs DOCKET NO.:. O5 - c/¥ c/7 Juror # Name 97 BREHM, ERIC R · , 94 WILLIAMS, MIKKI D 4 109 MARSH, BARBARA A WYIITrEN, JOHN M SPAHR, RICHARD C HAWK, lAMES 1 IR ...... t.'IILLF_,R, DA;'iD.; ;. IR MADRZYKOWSKI, GERALD F : :~-'3D, L;;;55,~, 73 MC GILLVRAY, ]EFF 74 DRAKE, MICHAEL E 98 STRING, GAIL M 104 REYNOLDS, CHRISTOPHER 105 MYERS, IOHN A. 86 ANDERSON, FREDA ! 74 2~ 92 2~' -- 110 ~ - 107 .'.X 89 £" 90 ;U 85 ZWIERZYNA, IOHN T DETWE~LER, JOYCE A ROMITO, BONITA I. PINCKNEY, VERNON J PICCIRILLI, WILLIAM HATCHER, WANETrA J. COURTROOM NO.: ~& Randnm No -1~3~6531 -1774222~6 -17~9358 -169~93051 -1~169149 -13374897~ -11821~9 -106~376 -10~703693 -6~556386 -~26~ ~ 1 41803~1 -~223~ 3~ 115691780 1~010~0 ~1051~9 5~31~ 5822865~ 856~18 1165050~1 11~8388 1~5576601 1655655~ 1717495531 178~12469 1986635170 2~32123 21~1~55 Monday, O~tober 2~, 2004 Page I of 1 ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID#: 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz~angino-rovner.com TROY A. FOSTER, Plaintiff Vo JUAN JIRAL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLg2qD COUNTY, PA CIVIL ACTION - LAW NO. 2003-4447 JURY TRIAL, DEMANDED PRAECIPE To the Prothonotary of Cumberland County: Please mark the above-captioned action settled, satisfied:~ and discontinued. Date: ANGINO & ROVNER, P.C. ~utz I.D. No. 35!¢56 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiff ORI$1NAL 265725. I'~DLL'~ITG CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of A~ngino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PRAECIPE upon all counsel of record via postage prepaid first class United States mail addressed as follows: Andrew Lehman, Esquire 2411 North Front Street Harrisburg, PA 17110 Attomey for Defendant Dated: 265725. B,DLLLMTG