Loading...
HomeMy WebLinkAbout03-5654BILLIE JO FISHER-SANERSRI, IN THE COURT OF COMMON PLEAS and NIPON SANERSRI, CUMBERLAND COUNTY, PENNSYLVANIA her husband, Plaintiffs NO. ?3 - SLS? l Iv???ERJ?? V. PETER MURPHY, CIVIL ACTION - LAW Defendant : NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice is served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense or objections to the claim set forth against you. You are warned that if you fail to do so the case may proceed without you and judgement may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone 717-249-3166 or 800-990-9108 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas signuientes, usted tiene vienta (20) dias de plazo al partir de al fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona a por abogado y archivar en la corte en forma escrita sus defensas o sus objectiones a las demandas en contra de su persona. Sea avisado que si usted no se fefiende, la corte tomara medidas y puede una orden contra usted sin previo aviso o notificacion y por cualquier queja o akuvui que es pedido en la peticion de demanda. Usted puedo parder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DIMERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEPONO A LA OFICINA CUYA DIRECCION SE EMCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSSGUTAASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone 717-249-3166 or 800-990-9108 HANDLER, By: David H R 130 inc H risbu (717) ttorney! 7OSENBERG,LLP enberg, Esquire ' 20569 lestown Road 'g, PA 17110 238-2000 for Plaintiffs J FUcom piai nt/mva/lanechange/davidfsher BILLIE JO FISHER-SANERSRI, and NIPON SANERSRI, her husband, Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D3 5" 6S'/ ?)/ ci ( 1 PETER MURPHY, CIVIL ACTION - LAW Defendant : COMPLAINT AND NOW, come the Plaintiffs, Billie Jo Fisher-Sanersri and Nipon Sanersri, her husband, by and through their attorney, HANDLER, HENNING & ROSENBERG, LLP, by David H Rosenberg, Esquire, and make the within Complaint against the Defendant, Peter Murphy, as follows: 1. Plaintiffs, Billie Jo Fisher-Sanersri and Nipon Sanersri, her husband, are competent adult individuals currently residing at 565 Sawmill Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. Z Defendant, Peter Murphy, is an adult individual currently residing at 600 Nauvoo Avenue, Lewisberry, York County, Pennsylvania 17339. 3. At all times material hereto, Plaintiff, Billie Jo Fisher-Sanersri, was the owner and operator of a 1988 Chevrolet Blazer (hereinafter "Plaintiffs vehicle"). 4. At all times material hereto, Defendant, Peter Murphy, was the operator of an off-red colored vehicle (hereinafter "Defendant's vehicle"). 5. At all times material hereto, Plaintiff, Billie Jo Fisher-Sanersri, was insured by Prudential Insurance Company and covered by the limited tort option. 6. At all times material to this action, there were no adverse weather or road conditions. 7. On or about January 18, 2002, at about 9:45 am, Plaintiff's vehicle was heading northbound on Lisburn Road and slowed down to make a left turn, between the intersections of Main Street and Old Forge Road, in Cumberland County, Pennsylvania. 8. On or about January 18, 2002, at about 9:45 am, Defendant, Peter Murphy, was traveling behind Plaintiffs vehicle on Lisburn Road, in Cumberland County, Pennsylvania. 9. At approximately the same time and place, Defendant, Peter Murphy, who refused to wait for Plaintiff to make her left turn, suddenly and without warning crossed over the double yellow line and attempted to go around her on the left, violently colliding with the Plaintiff's vehicle as she was turning. 10. Pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law 75 Pa. C.S.A. § 1701 et seq., Plaintiff, Billie Jo Fisher-Sanersri, is permitted to seek non- economic damages as if she retained full tort rights because she suffered a serious impairment of bodily function as a result of the injuries she sustained in this crash. See 75 Pa. C.S.A. § 1705(d). 11. As a direct and proximate result of the negligence of the Defendant, Peter Murphy, the Plaintiff sustained extensive injuries as set forth more specifically below. COUNTI - NEGLIGENCE BILLIE JO FISHER-SANERSRI v. PETER MURPHY 12. Paragraphs 1-11 are incorporated herein as if set forth at length. 2 13. The occurrence of the aforementioned collision and all the resultant injuries to Plaintiff, Billie Jo Fisher-Sanersri, are the direct and proximate result of the negligence, carelessness, and/or recklessness of the Defendant, Peter Murphy, generally and more specifically as set forth below: (a) In driving on the left side of the roadway within a no-passing zone, in violation of 75 Pa. C.S.A. § 3307; (b) In disregarding the pavement striping designed to mark a no-passing zone throughout its length, in violation of 75 Pa. C.S.A. § 3307; (c) In driving to the left of the center line of the roadway or marked center line when overtaking and passing another vehicle proceeding in the same direction, in violation of 75 Pa. C.S.A. § 3305; (d) In disregarding the speed of vehicles, the condition of the highway, and the traffic upon the highway, in violation of 75 Pa. C.S.A. § 3361; (e) In failing to maintain proper and adequate observation of the existing traffic condition while ascertaining if the changing of lanes could be completed safely, in violation of 75 Pa. C.S.A. § 3309; (f) In failing to pass promptly and safely, while exercising proper caution, which the physical demand of lawful traffic on Lisburn Road demanded, in violation of 75 Pa. C.S.A. § 3303(a)(1); (g) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have his vehicle under such control that injury to persons or property could be avoided; and 3 (h) In failing to pass to the left of the Plaintiffs vehicle at a safe distance and staying left of the vehicle until safely clear of the Plaintiffs vehicle, in violation of 75 Pa. C.S.A. § 3303(a)(1). 14. As a direct and proximate result of the negligence of the Defendant, Peter Murphy, the Plaintiff, Billie Jo Fisher-Sanersri, has suffered extensive personal injuries, including, but not limited to, restricted range of motion of the neck and left shoulder, a C6- C7 disc herniation, a C5-C6 disc herniation, headaches, left arm pain, numbness, and dizziness. Further, she suffered frequent blackouts. 15. As a result of the negligence of Defendant, Peter Murphy, the Plaintiff, Billie Jo Fisher-Sanersri, has suffered lost wages/income and will in the future continue to suffer a loss of income and/or loss of earning capacity. 16. As a result of the negligence of Defendant, Peter Murphy, the Plaintiff, Billie Jo Fisher-Sanersri, has suffered great physical pain, discomfort, and mental anguish, and she will continue to endure the same for an indefinite period of time in the future, to her great physical, emotional, and financial detriment and loss. 17. As a result of the negligence of Defendant, Peter Murphy, the Plaintiff, Billie Jo Fisher-Sanersri, has been compelled, in order to effect a cure for aforesaid injuries, to expend large sums of money for medicine and/or medical attention, and will be required to expend money for the same purposes in the future, to her great detriment and loss. 18. As a result of the negligence of Defendant, Peter Murphy, the Plaintiff, Billie Jo Fisher-Sanersri, has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her great detriment and loss. 4 19. As a result of negligence of Defendant, Peter Murphy, the Plaintiff, Billie Jo Fisher-Sanersri, has been, and probably will in the future be, hindered from attending to her daily duties, to her great detriment, loss, humiliation, and embarrassment. 20. Plaintiff, Billie Jo Fisher-Sanersri, believes and, therefore, avers that her injuries are permanent in nature. WHEREFORE, Plaintiff, Billie Jo Fish er-Sanersri, seeks damages from Defendant, Peter Murphy, in an amount in excess of the compulsory arbitration limits of Cumberland County exclusive of interest and costs. COUNT II - LOSS OF CONSORTIUM NIPON SANERSRI v. PETER MURPHY 21. Plaintiffs, Billie Jo Fisher-Sanersri and Nipon Sanersri, incorporate and make part of this Count paragraphs 1 through 19 of this Complaint as if fully set forth. 22. As a result of the negligence of the Defendant, the Plaintiff, Nipon Sanersri, has suffered a loss of consortium, society, and comfort from his wife, Billie Jo Fisher- Sanersri, and he will continue to suffer a similar loss in the future. 23. As a result of the negligence of the Defendant, the Plaintiff, Nipon Sanersri, has been compelled, in order to effect a cure for his wife's injuries, to expend money for medicine and medical attention and will be required to expend money for the same purposes in the future, to his great detriment and loss. 5 WHEREFORE, Plaintiff, Nipon Sanersri, seeks damages from Defendant, Peter Murphy, in an amount in excess of the compulsory arbitration limits of Cumberland County exclusive of interest and costs. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP Date: l? t 2h !D3 By: David "osenberg, Esquire Attorney I.D. #20569 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiffs 6 VERIFICATION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Nipon Sanersri Date: le4-17 VERIFICATION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. j d1z 4;,t,4? Billie Jo Fi er d Date: 10 -1?7-0, 3 0 0 t1l c 9. e; :r G 0 0 n N W N 0 z "70 ly IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BILLIE JO FISHER-SANERSRI, and NIPON SANERSRI, Plaintiffs NO. 03-5654 Civil Term V. PETER MURPHY, Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of George H. Eager of Eager, Reinaker & Spinello as attorney of record on behalf of Defendant in the above captioned action. EAGER, REINAKER & SPINELLO BY: George H. Ea r, Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for Entry of Appearance upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road P.O. Box 60337 Harrisburg, PA 17106-0337 EAGER, REINAKER & SPINELLO DATO 710q 103 i BY: George H. ager ire Attorney for De ndant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ? r: ?? 7 'C:1 ?.? ? .. ; L . , G° GI.: r' 1` ry < _= C` Y C. .. -, [?? --( WHEREFORE, Defendant asks that judgment be entered in his favor and against the Plaintiffs on all claims set forth in Plaintiffs' Complaint. COUNT II - LOSS OF CONSORTIUM NIPON SANERSRI v. PETER MURPHY 21. Paragraphs 1 through 20 of Defendant's Answer are incorporated herein by reference as though fully set forth. 22.-23. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendant asks that judgment be entered in his favor and against the Plaintiffs on all claims set forth in Plaintiffs' Complaint. NEW MATTER 24. Paragraphs 1 through 23 inclusive above are incorporated herein by reference and made a part hereof. 25. Plaintiffs' recovery is barred and/or limited pursuant to the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Act, 75 Pa.C.S.A. 1701, et. seq., and Answering Defendant hereby assert all of the rights and defenses available to them under the aforementioned act. 26. Plaintiffs' claims are barred and/or limited pursuant to the applicable Statute of Limitations, the relevant portions of which are incorporated herein by reference. 27. Plaintiffs' claims are barred and/or limited by the tort thresholds, applicable by election or law, of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. §1701, et. seq. 28. Plaintiffs' claims are barred and/or limited by the preclusion of pleading, proving and/or recovering special damages as set forth in §1722 of the Pennsylvania Motor Vehicle Financial Responsibility Law, Pa.C.S.A. §1722. WHEREFORE, Answering Defendant respectfully demands judgment in his favor and against all other parties together with the costs of this action. EAGER, REINAKER & SPINELLO BY: George H. ager, squire Attorney for Defe dant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 VERIFICATION I, PETER MURPHY, hereby verify that I am the Defendant in the foregoing action, and that the averments of the foregoing Answers with New Matter to the Complaint are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments of the Answers with New Matter to the Complaint are based upon an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities for any false statements made herein. `TER , PETER MURPHY Dated: I1?`/q 0 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Answer with New Matter upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road P.O. Box 60337 Harrisburg, PA 17106-0337 EAGER, REINAKER & SPINELLO DATE; IZ l d J&3 BY: ,' George H. ger, Es s Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 c U ;'7 "? „_. L: . r . I :i .fi =iJ -< J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BILLIE JO FISHER-SANERSRI, and : NIPON SANERSRI, Plaintiffs NO. 03-5654 Civil Term V. PETER MURPHY, Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of Defendant's Request for Production and Copying of Documents - Set No. 1 Directed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road P.O. Box 60337 Harrisburg, PA 17106-0337 EAGER, REINAKER & SPINELLO DATE: 01101b3 BY: / George ager, quire Attorney for D ndant I. D. No. 27 1347 Fruit ille Pike Lancaster, PA 17601 (717) 290-7971 C.5 o Y- ./ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BILLIE JO FISHER-SANERSRI, and NIPON SANERSRI, Plaintiffs NO. 03-5654 Civil Term V. PETER MURPHY, Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served an original of Interrogatories of Defendant Addressed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road P.O. Box 60337 Harrisburg, PA 17106-0337 EAGER, REINAKER & SPINELLO DATE: 12110,03 BY: /`?? George H. Eager, Esgy?°° Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 n o O C w n (71 rl rj O BILLIE JO FISHER-SANERSRI, and NIPON SANERSRI, herhusband, Plaintiffs V. PETER MURPHY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-05654 CIVIL ACTION - LAW Defendant : PLAINTIFFS' REPLY TO NEW MATTER AND NOW, come the Plaintiffs, Billie Jo Fisher-Sanersri and Nipon Sanersri, her husband, by and through their attorney, HANDLER, HENNING & ROSENBERG, LLP, by David H Rosenberg, Esquire, and responds as follows: 24. Denied. The allegation set forth in paragraph 24 is a conclusion of law to which no responsive pleading is required. 25-28. Denied. The allegations set forth in paragraphs 25-28 are conclusions of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, they are specifically denied. WHEREFORE, Plaintiff, Nipon Sanersri, seeks damages from Defendant, Peter Murphy, in an amount in excess of the compulsory arbitration limits of Cumberland County exclusive of interest and costs. Respectfully submitted, / S?o3 HANDLER, HENNING & ROSENBERG, LLP DATE David H R enberg, Esquire I. D. #20 9 1300 L'nglestown Road Harrisburg, PA 17110 717-238-2000 Attorney for Plaintiffs BILLIE JO FISHER-SANERSRI, and NIPON SANERSRI, herhusband, Plaintiffs V. PETER MURPHY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-05654 CIVIL ACTION - LAW Defendant : CERTIFICATE OF SERVICE On the 15`h day of December, 2003, 1 hereby certify that a true and correct copy of Plaintiffs' Reply To New Matter was served upon the following by depositing in U.S. Mail; George H. Eager, Esq. EAGER REINAKER & SPINELLO 1347 Fruitville Pike Lancaster, PA 17601 Respectfully submitted, fZ4s6 DATE HANDLER, HENNING & ROSENBERG, LLP David H Ros erg, Esquire I.D. #205 1300 Linglestown Road Harrisburg, PA 17110 717-238-2000 Attorney for Plaintiffs ?, a o n TI cr1 BILLIE JO FISHER-SANSERSRI, and NIPON SANSERSRI, Plaintiffs V. PETER MURPHY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5654 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 22nd day of January of 2004, I hereby certify that I have, on this date, served the within Plaintiffs Answers to Defendants First Set of Interrogatories and Request for Production Addressed To Plaintiff, via first class mail by sending a true and correct copy of same to their attorney and including copies to all parties of interest as follows: George H. Eager, Esquire Attorney for Defendants Attorney ID#27740 1347 Fruitville Pike Lancaster, PA 17601 HANDLER, HENNING & ROSENBERG By: David Esquire Attoryfey ID# 20569 130,9 Linglestown Road Harrisburg, PA 17110 (717)238-2000 C? C v C5 C-? L' ?? .?{ L 4 ? _ rim n -,-? m ? ?, ? _: i ? , , CJ ` (:> > -':.? C_> - '_ ' 'l t_.l i ? ii C`. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-05654 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SANERSRI BILLIE JO FISHER ETAL VS MURPHY PETER R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: MURPHY PETER but was unable to locate Him in his bailiwick He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On January 23rd , 2004 , this office was in receipt of the attached return from YORK Sheriff's Costs: So answers ?- Docketing 18.00 Out of County 9.00 Surcharge 10.00 R.-'Thomas Kline Dep York County 30.80 Sheriff of Cumberland County .00 67.80 01/23/2004 HANDLER HENNING ROSENBERG Sworn and subscribed to before me -7 this day of ,2avq A.D. C _ ro hones Prothonotaty COUNTY OF YORK OFFICE OF THE SHERIFF S;R;I719 01L 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE INSTRIMMINS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINE 1 TNRU 12 DO NOT DETACH ANY COPIES 1. PLAINTIFF/S/ 2. CQt1RT?gNTR Billie Jo Fisher-Sanersri et al V.3 b civil 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANT/S/ Peter Murphy Notice and Complaint SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Peter Murphy 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE) AT 600 Nauvoo Avenue Lewisberzy, PA 17339 7. INDICATE SERVICE: J PERSONAL U PERSON IN CHARGE CI DEPUTIZE L??U 1a td o 1ST CLASS MAIL ? POSTED -1 OTHER NOW October 29 20 03 I, SHERIFF OF St COUNTY, PA, do hereby deputiz t sheriff of York COUNTY to execute this ?j. de retuEn th co ding to law. This deputization being made at the request and risk of the plaintiff. SHERIFF OF COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Clanberland OUT OF COUNTY -CUMBERLAND ADVANCE FEE PAID BY ATTORNEY HANDLER HENNING & ROSENBERG NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof 9. TYPE NAME and ADDRESS of ATTORNEY/ ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED 17110 1717-238-2000 10/23/2003 David H. Rnp;Pnhprqq 13n0 lin lpstown Pd Harrisburgp PA 12. SEND NOTICE OF SERVICE COPY TOTVAME AND ADDRESS BELOW: (This area must be completed if notice is M be mailed). SEE LINE # 9 SPACE BELOW FOR USE OF THE SHERIFF - DO NOT WRITE BELOW THIS LINE 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15. ExpiratlonlHeari Date or complaint s indicated above. R o n d a M. A h r S/ RAT 110/20/2003 1/22/2003 16. HOW SERVED: PERSONAL( ) RESIDENCE ( POSTED ( ) POE( ) SHERIFF'S OFFICE ( ) OTHER ( SEE REMARKS BELOW 17. ? I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. name above. (See remarks below.) D TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHO (Relationshi t Defendant) 19. ate of ervice 20. Tigre of Se 1>>1i3?os ifQa 21. ATTE? S1 Dij ?'1-?e es Ir t. 1 Date; Time 1 s ,`I t\ ?Dq't9T Tima Miles 1 Int. 1 Date 1 Time des y lot Date 1 Time lei Int. 1 Date 1 Time 1 Miles 1 IM. 22. REMARKS: V I I( 23. Advance Costs 24. Service Costs 25. NIF 26. Mileage 27. Postage 28. Sub Tote $75.00 118.00 10.84 28.80 34. Foreign County Coifs 135. Advance Costs 136. Service Costs 137. Notary Cert. 41. A IRMED and s?6yAed a, Lofo,? me thic 3 -44. Si NC) IARIAL S,Q De , hers 42. da dNFA..e•./ Sf orr [R¢yim{ r*IW" INOTARY 46. nature of v'or City of York, York county my Commission F_xpires April 20, 2006 C my Shen WIL 48. Signature of F reign /]/?(j County Sheriff 50JhN L D GE RECEIP70F 7HE SHERIFF'S RN SIG ATURE OF AUTHORIZED ISSUING AUTHORITY AND TITLE IZ 1 29. Pound 30. Notary 1 31. Surchg. 1 32. Tot. Costs 33. Costs Due Ref. Check No. 1 2.00 30.801 44.20 1 38. Mileage/Posted/Not Found 1 39. Total Costs 1 40. Costs Due or Refund z 4 4tiwtA C 4. A HOSE 12-3-03 49. DATE 1 51. DATE RECEIVED 1. WHITE- Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4, BLUE - Sheriffs Office BILLIE JO FISHER-SANERSRI and NIPON SANSERSRI, her husband, Plaintiffs V. PETER MURPHY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW No. 03-5654 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 13`h day of January of 2005,1 hereby certify that I have, on this date, served the within Plaintiff's Answers to Defendants Second Set of Interrogatories Addressed To Plaintiff, via first class mail by sending a true and correct copy of same to their attorney and including copies to all parties of interest as follows: George H. Eager, Esquire Attorney for Defendants 1347 Fruitville Pike Lancaster, PA 17043-0109 HANDLER, HENNING & ROSENBERG By: David H Ro nberg, Esquire Attorney I20569 1300 Ling estown Road Harrisburg, PA 17110 (717)238-2000 r.i l ??J 1 C... til'??'?.... -??? SUBPOENA RECORDS ORIGINAL COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Billie ]o Fisher-Sanersri and Nipon Sanersri Court of Common Pleas VS. Peter Murphy Case Number: 03-5654 CERTIFICATE PREREQUISITE TO THE SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 Page 3 of 4 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Litigation Solutions, Inc. ('LSI') on behalf of George H. Eager, Esquire of Eager, Reinaker & Spinello 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: 2/16/2005 Litigation Solutions, Inc. on behalf of George H. Eager, Esquire of Eager, Reinaker & Spinello CC: George H. Eager, Esquire Eager, Reinaker & Spinello 1347 Fruitville Pike Lancaster PA 17601 Attorney for the Defense http://newrats.litsol.com:8081 /ratsevents/subpoena records. asp?WRid=WR10177&PLid=... 2/16/2005 SUBPOENA NOTICE OF INTENT Pagel of 3 PENNSYLVANIA COURT OF COMMON PLEAS COUNTY OF CUMBERLAND Billie Jo Fisher-Sanersri and Nipon Sanersri Court of Common Pleas vs. Peter Murphy 03-5654 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Provider: Villa Theresa Nursing Home Health America-Legal Svcs Keystone Health Plan Central T0: David Rosenberg, Esquire note: please see enclosed list of all other interested counsel Record Type: Employment Health Insurance Health Insurance Litigation Solutions, Inc. ('LSI') on behalf of George H. Eager, Esquire 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. Date of Issue: 1/27/2005 CC: George H. Eager, Esquire - Court of Common Pleas lu(C" ;?ein/Ke?c? 15,;!) we1% If you have any questions regarding this matter, please contact: Litigation Solutions, Inc. (412.263.5656) Brentwood Towne Centre 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 Litigation Solutions, Inc. on behalf of: George H. Eager, Esquire Defense http://newrats.litsol.com:8081/ratsevents/notice of intent.asp?save_report_to_db=X&PLi... 1/27/2005 SUBPOENA NOTICE OF INTENT Page 2 of 3 COUNSEL LISTING FOR BILLIE JO FISHER-SANERSRI AND NIPON SANERSRI VS. PETER MURPHY County of Cumberland Court of Common Pleas Counsel Firm Counsel Type Rosenberg, Esquire, David 1300 Linglestown Road Harrisburg PA 17108 Opposing Counsel /1 /7-R3 FS'--Ro 00 hup:Hnewrats.litsol.com:8081/ratsevents/notice_of intent.asp?save_report_to_db=X&PLi... 1/27/2005 COMMONWEALTH OF PENNSYLVANIA Billie Jo Fisher-Sanersri an qObT1NTYnOF CUMBERLAND Sanersri VS. File No. 03-5654 Peter Murphy SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:Health America-Legal Services (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: PLEASE SEE ATTACHED RIDER at101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 (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:George H. Eager, Esquire ADDRESS:-i env Di U. TELEPHONE: 717 - 2gQ -17 9 i SUPREME COURT ID# 2 r 7 0 ATTORNEY FOR: Re f. n .. BY THE COURT: / p_ Prothonotary, Civil Div sio ?J Date: ?uv .075: 1GC2fJaz ?' ,?iO %? /Seal of the Court U // Deputy RIDER Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Health America-Legal Svcs 3721 Tecport Drive Harrisburg PA 17111 Attention: Correspondence Patient: Fisher-Sanersri, Billie Jo SS#:220-08-8922 Date of Birth: 1970-09-14 Page Requested Items: Complete copy of any and all insurance records from 1/1/97 to the present, regarding ID#220-08-8922; Group# Q06 and Group #Q14 including: claims paid, denials, statements, EOB's and correspondence. http://newrats.litsol. com:8081 /ratsevents/subpoena rider. asp?PLid=PL 12753 7& WRid=W... 1/27/2005 COMMONWEALTH OF PENNSYLVANIA Billie Jo Fisher-Sanersri YcW CUMBERLAND Sanersri vs. Peter Murphy File No. 03-5654 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Keystone Health Plan Central (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: PLEASE SEE ATTACHED RIDER at 101 'Cowrie Square Way, Suite 251 Pittsburgh, PA 15227 (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 George H. Eager, Esquire ADDRESS. rui vi e Pi e Lancaste TELEPHONE:/i/-Z9U-7971 SUPREME COURT ID# 7 7 4 0 ATTORNEYFOR:Defense Date: AR . J S -'2eeK ial of the Court BY THE COURT: Prothonotary, Civil Divis' n Deputy y SUBPOENA RIDER Page 1 of 1 Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Keystone Health Plan Central P. O. Box 898819 Camp Hill PA 17089 Attention: Insurance Records Department Patient: Fisher-Sanersn, Billie Jo SS#: 220-08-8922 Date of Birth: 1970-09-14 Requested Items: Complete copy of any and all insurance records from 1/1/97 to the present, including: claims paid, denials, statements, EOB's and correspondence. http://newratslitsol.com:8081 /ratsevents/subpoena rider. asp?PLid=PL 127540& WRid=W _. 1/27/2005 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Billie Jo Fisher-Sanersri and Nipon Sanersri vs. Peter Murphy File No. 03-5654 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:Villa Theresa Nursing Home (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: PLEASE SEE ATTACHED RIDER at101 Towne Square Way, Suite 251 Pittsburqh, PA 15227 (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:Gaorne H Facer Esquire ADDRESS:137 F= -i t_v; llA Pike Tangaster RA, 17601 TELEPHONE: SUPREME CO 2 7 7 4 9 ATTORNEY FOR: 1) P f e n S a BY THE COURT: Prothonotary, Civil Division Date: Seal of the Court Deputy ?1 'SUBPOENA RIDER Page 1 of 1 Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Villa Theresa Nursing Home 1051 Avila Road Harrisburg PA 17101 Attention: Human Resources Department Patient: Fisher-Sanersh, Billie ]o SS#:220-08-8922 Date of Birth: 1970-09-14 Requested Items: Complete copy of employment files from 1/1/97 to the present including, but not limited to the application for employment, pre-employment physical, date employment began, workers compensation claims and medical reports, health insurance documents, performance evaluations, year end payroll records for each year of employment, disciplinary notices, leave or absence dates and reason for leave and date of termination. http://newrats.litsol.corn:8081/ratsevents/subpoena rider.asp?PLid=PL127536&WRid=W... 1/27/2005 ?;> r ? J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BILLIE JO FISHER-SANERSRI, and NIPON SANERSRI, Plaintiffs NO. 03-5654 Civil Term V. PETER MURPHY, Defendant MOTION FOR PARTIAL SUMMARY JUDGMENT AND NOW, comes the Defendant, Peter Murphy, and by his attorneys, Eager, Spinello, Quinn & Stengel, files the following Motion for Partial Summary Judgment averring as follows: 1. This is an action for personal injuries filed by the Plaintiff, Billie Joe Fisher- Sanersri, which injuries allegedly arose out of an automobile accident which occurred on or about January 18, 2002. 2. At the time of the accident, the Defendant was insured under a policy of insurance which had the Limited Tort option set forth in the Motor Vehicle Financial Responsibility Law. 75 Pa.C.S.§1701, et seq. 3. The pertinent provision of the MVFRL provides as follows: Each person who elects the limited tort alternative remains eligible to seek compensation for economic loss sustained in a motor vehicle accident as the consequence of the fault of another person pursuant to applicable tort law. Unless the injury sustained is a serious injury, each person who is bound by the limited tort election shall be precluded from maintaining an action for any non-economic loss,.... 75 Pa.C.S.§1705(d). Serious injury is defined as "a personal injury resulting in death, serious impairment of body function or permanent serious disfigurement. 75 Pa.C.S.§1702. 4. Plaintiff alleges that as a result of this automobile accident, she has suffered neck pain, left arm pain and numbness and left shoulder pain. A copy of the Plaintiff's deposition testimony transcript is attached hereto as Exhibit "A". 5. David C. Baker, M.D. has performed an independent medical examination of the Plaintiff. Dr. Baker opines, "I do not find it unusual for someone who has been in an automobile accident to have aches and pains for several months; however, I see nothing about the type of accident she was in, the physical examination, and the diagnostic studies to explain the persistence of her pain". A copy of Dr. Baker's IME report is attached hereto as Exhibit "B". 6. In May of 2002, it is reported that the Plaintiff had a complete resolution of her left arm pain. This was temporary since the Plaintiff cotninued with full-time employment which aggravated her injuries. (See Exhibit "C") 7. The admissions contained in the Plaintiff's deposition read in conjunction with the independent medical examination and opinion of Dr. Baker establishes that she is fully and completely recovered from any injuries sustained in the accident and that she did not suffer serious injury. 8. Pursuant to the Rules of Civil Procedure, a Motion for Summary Judgment should be granted in the following circumstances: (1) Whenever there is no genuine issue of any material fact as to a necessary element of the cause of action or defense which could be established by additional discovery or expert report; or (2) If, after the completion of discovery relevant to the motion, including the production of expert reports, an adverse party who will bear the burden of proof at trial has failed to produce evidence of facts essential to the cause of action or defense which in a jury trial would require the issues to be submitted to a jury. Pa.R.C.P. 1035.2. 2 9. It is clear that the Plaintiff can never sustain his burden of proving that he suffered serious injury as a result of the accident of December 8, 2001. There exists no genuine issue as to any material fact and the Defendant is entitled to judgment as a matter of law. WHEREFORE, it is respectfully requested that the Court grant this Motion for Partial Summary Judgment and order that the Plaintiff is precluded from seeking any non-economic damages at the trial of this case. DATE: 5 EAGER, SPINELLO, QUINN & STENGEL BY: George H. Eager, Es uire Attorneys for Defendant 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 Atty. I.D. No. 27740 3 ? r 1 b?t A Exbi ? r 1 ORIGINAL BILLIE JO FISHER-SANERSRI,: IN THE COURT OF COMMON PLEAS AND NIPON SANERSRI, HER CUMBERLAND COUNTY, PENNSYLVANIA HUSBAND, . PLAINTIFFS NO. 2003-05654 CIVIL ACTION - LAW V PETER MURPHY, DEFENDANT DEPOSITION OF: BILLIE JO FISHER-SANERSRI TAKEN BY: DEFENDANT BEFORE: DIANE F. FOLTZ, RMR NOTARY PUBLIC DATE: OCTOBER 12, 2004, 9:55 A.M. PLACE: HANDLER, HENNING & ROSENBERG, LLP 1300 LINGLESTOWN ROAD HARRISBURG, PENNSYLVANIA APPEARANCES: HANDLER, HENNING & ROSENBERG, LLP BY: DAVID H. ROSENBERG, ESQUIRE FOR - PLAINTIFF EAGER, REINAKER & SPINELLO BY: DENNIS E. REINAKER, ESQUIRE FOR - DEFENDANT 0 PRESENT: PETER MURPHY 2080 Linglestown Road • Suite 103 • Harrisburg, PA 17110 717.540.0220 0 Fax 717.540.0221 e Lancaster 717.393.5101 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 WITNESSES NAME EXAMINATION BILLIE JO FISHER-SANERSRI BY: MR. REINAKER 3 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 STIPULATION It is hereby stipulated by and between counsel for the respective parties that reading, signing, sealing, certification and filing are hereby waived; and that all objections except as to the form of the question are reserved to the time of trial. BILLIE JO FISHER-SANERSRI, called as a witness, being duly sworn, testified as follows: EXAMINATION BY MR. REINAKER: Q Good morning. Could you give us your name for the record, please? A Yes. My name is Billie Jo Sanersri. Q Do you mind if I call you Billie Jo this morning? A That's fine. Q All right. Billie Jo, my name is Dennis Reinaker. I represent Peter Murphy in the lawsuit that you have filed as a result of the auto accident that you were in. Let me just ask you a couple of introductory questions, first of all. Have you ever had a deposition taken before? A No, sir. Q Okay. There are a couple of things then that I want to tell you to make this go a little more smoothly. i 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Obviously there's a court reporter here that's taking down my questions and your answers. A Okay. Q It's important during the course of the deposition that you make sure all of your answers are verbal responses. There's a tendency as we go through this for you and I to begin to feel like we're just conversing with each other which ultimately results in things like nodding of the head and saying huh-uh or uh-huh, responses like that, but I would ask you to try to refrain from that so that she doesn't have to try to interpret your answer. Likewise if you could make sure that you wait until I've completely finished my question and I'll try and make sure I completely wait until you answer the question, that way she doesn't have to try to take down two people talking at the same time. If I ask you a question that you don't know the answer to, it's perfectly fine to say that. If it's a question that you can give us an estimate or something that you're comfortable with, that's fine. Just tell us that that's what you're doing. If you need to take a break for any reason, whether it's to consult with Mr. Rosenberg or for whatever reason, just let us know, and we'll be happy to do that. Fair enough? A Yes. i 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q All right. Do you have any questions about those instructions? A No. Q Okay. Let me just ask you one preliminary thing. Have you had any medications in the last 24 hours? A Have I had any medication? Q Are you taking any medications? A For anxiety. Q Okay. And what was that? A Chloropam. Q Chloropam? A Chloropam. Q All right. Have you had any alcohol in the last 24 hours? A No, sir. Q Is there any reason for you to be concerned about your ability to understand my questions or to provide accurate answers? A No. Q All right. What is your address? A My address is 565 Sawmill Road, Mechanicsburg, 17055. Q And how long have you lived is there? A I lived there seven years. Q All right. And so on the date of the accident i 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you would have been living there as well? A Yes, sir. Q All right. Who else lives there with you? A At this time just my children and myself. Q All right. How many children do you have? A I have the two. Q How old are they? A I have a thirteen-year-old, and I have a three-year-old. Q Are you married? A I'm separated. Q Okay. How long have you been separated? A Approximately six months, maybe longer. Q Can you tell me a little bit about your educational background? Let's start with high school. Did you graduate from high school? A Yes, I did. Q When and where? A I graduated this year with Thompson Institute. It's an education direct program. It's 2004. I can't particularly give you the correct month. Q Okay. And this was the high school equivalent degree you got from Thompson Institute? A I got a diploma. Q But it was high school? i 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes, a high school diploma. Q All right. Where did you go -- did you attend public school for a time? A Yes, I did. Q Where was that? A I attended West Shore School District. Q And how far did you go in school there? A I completed the eighth grade. Q All right. And have you had any other training besides the diploma from Thompson Institute, academic training? A I'm in Thompson education direct right now. I'm taking a PC specialist course. Q PC specialist? A Yes. Q And how long of a program is that? A It varies. It can go up to six months. I'm almost completed. Q And do you get a certificate when you finish? A I get a diploma. Q And what will that train you to do? A To learn Excel, Powerpoint. Q Okay. So it's just -- A Word Perfect. Q So it's just teaching you how to use a computer? 1.11 - '' 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 8 A Teaching me, yes. Q All right. Are you working? A Yes, I am. I'm part-time working. I'm a part-time caregiver. Q Where? A I work for private people. Q And is this just something that you set up on your own, or did you do this through an agency? A I work through an agency, and I make my own hours. Q Who pays you? A Kelly Assistance. Q Okay. How long have you worked in that capacity? A I just started. I just started back to work, but I can only work so long because I can't tolerate the pain. Q You say you just started back to work. When did you start? A I just started back last week. Q All right. Do you remember the day of the accident? A Yeah, it was 1/18. Q 2002? A 2002. Q All right. Where were you working at that time? 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I was working at Messiah Village. Q Was that a full-time position? A Yes, sir. Q How long had you been at Messiah Village as of that date? A I'm going to say about approximately two years maybe, maybe less. Q All right. And do you remember how much you were getting paid? A I started out at 10.53. Q Is that about what your salary was on the 18th of January in 2002? A Yes. Q 10.53 an hour? A 10.53 an hour. Q And did you work 40 hours a week? A Yes, sir. Q Did you ever work overtime? A Yes, I did. Q And what kind of work did you do for Messiah village? A I was a CNA. Q Tell me some of your daily duties. What kinds of things would you do? A Bathing, washing, transferring, using special 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 equipment to get them up out of bed. Q Okay. Prior to Messiah Village, where did you work? A I worked at Bethany. Q And is that a similar position, providing -- A Yes, sir. Q -- assistance to elderly people? A Yes, sir. Q How long did you work at Bethany? A Approximately two months. Q Why did you leave there? A Absenteeism, I was calling off a lot. I couldn't handle the job. I was trying. I was in pain. I was calling off so many times, they fired me. Q Okay. So this is at Bethany where you worked before going to Messiah Village? A No, I worked at -- I worked at Messiah, and then I transferred. I quit Messiah because I was afraid I was going to get fired because of my absenteeism. Q All right. So the position at Bethany was actually after you left Messiah? A Yeah, I left Messiah. I quit Messiah before I ended up getting fired because I was calling off a lot because I couldn't perform my job, because a lot of my co-workers went on to other places, so then I transferred 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to Bethany before they ended up firing me. I figured I'd try to go on because I needed to support my family. Q All right. I want to know where you worked before you took the job at Messiah Village? A At Messiah, before I worked at Messiah Village? Oh, geez. I don't recall. I can't remember what jobs. I mean it was a CNA, but I worked, I believe, at Villa Teresa at one point, but I -- and then I also did home care, too, before I started working at Messiah. Q All right. You said that you had been at Messiah about two years A Right. Q -- before the accident? A Right, and then I did -- before that I worked for this gentleman and his wife. His wife was dementia, so I worked at his house for approximately eight years, taking care of her, and then I -- she got real bad, and she had to go into a nursing home, and that nursing home, I went and worked at the place that she was taken to which was Villa Teresa because he wanted me to be with her. Q All right. Okay. And you said you may have had that position for as long as eight years or worked with that gentleman? A I worked with that -- his wife for eight years. Q All right. Have you filed tax returns each of 1 .11 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 these years? A Yes, I was -- they were getting it from the Medicare. They were going through Medicare, and Medicare was paying me. Q Do you still have copies of your tax returns? A Yes. Actually if I remember correctly, it's been such a long time, I was paying -- he was actually -- no, he was actually paying me, and then I would pay -- and then he would pay the taxes on for me at the time. He would pay my taxes. Q But have you filed tax returns? A Yes, sir. Q And could you provide copies of those to your attorney? A If need be. Q Well, I'm asking you to do that. A Yes, yes, yes. I don't have those papers with me today. Q I understand. All right. Let's talk about the accident. January 18th of 2002, is that the correct day? A That's the correct day. Q All right. About what time of day did it occur? A It was at 9:45 a.m., approximately 9:45. Q All right. And where were you going at the time? A I was going to the store. i 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Any particular store? A No, not any particular store, just going to the store. Q For groceries, or what were you intending to buy? A I was intending to buy a pack of cigarettes. I was out of cigarettes that morning. Q And were you -- were you heading to the store from the Sawmill Road address? A I was heading from my house. Q All right. And were you going -- A I was leaving from my house going to the store. Q Any particular store? A It was -- I believe -- I don't recall what store I was going to. Q Well, do you recall whether you had ever been to that store before? A Yes, I have been to that store before. I believe I was going to Giant. Q And how far is this Giant store from where you lived? A Approximately -- I don't know. I'm going to say about 20 minutes away. Q You were familiar with the route? A Yes, sir, I lived there for seven years. 1. 1 R. 14 1 L 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q All right. And what road were you on at the time of the accident? A I was on Lisburn Road, headed northbound. Q All right. Tell me what happened as far as the accident is concerned. A I was traveling on that road. I had realized that I forgot my pocketbook, so then I decided to turn around to go back to my house which was only -- I was only -- it's only five minutes away where I was at. It was only five minutes away from my home, so I decided to turn around. I had put my turn signal on, and there was no oncoming traffic, and I had seen Mr. Murphy in my rearview mirror. He was behind me, and I proceeded. I had my turn signal on, and I proceeded into the -- into my turn, and he just -- it just all of a sudden happened. He just decided to go around. Q All right. Now, you said you put your turn signal on. You mean your left turn signal? A My left turn signal, yes, sir. Q And what were you going to pull into in the process of -- A A driveway. There was no oncoming traffic. The road was clear. It was clear for me to go, so I went ahead. I was proceeding into my turn, and then all of a 11 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 sudden boom. Q What's the speed limit in that area; do you know? A The speed limit is 40 miles per hour. Q At what point in the process of the trip did you realize that you didn't have your pocketbook with you? A When I was on that road, when I was traveling down that road, I said, oh, crap, I forgot my pocketbook, so then I decided -- I wasn't in no hurry that day or anything. I just decided, okay, well, I can't get -- I can't buy anything without my pocketbook, so I'll turn -- I'll just turn here into this driveway, and that's what I did. Q All right. And would you have had to back out onto Lisburn Road then to complete your turn? A Yes, I would have. Q All right. Now -- A I went into the driveway. The driveway is up like onto a hill, and then I would have had to back out to get into the southbound lane and go out towards south, to go south. Q All right. At any point prior to making the left-hand turn did you pull your vehicle to the right? A No, sir. Q Now, you said earlier that you saw Mr. Murphy at some point in your rearview mirror? ? t 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes, sir. Q When was that? A When I was getting -- I was checking behind me, and there was people. He was behind me, and that's when I was turning. I had my turn signal on. This was just a little bit of a distance. I can't give you the exact distance, but he was behind me. I seen him in my rearview mirror. I was making sure that there was no oncoming traffic in the southbound lane, and I started to proceed in my turn. I had slowed down, and I started making my turn. Q Okay. So just before you made the left-hand turn is when you looked in the rearview mirror and saw Mr. Murphy; is that right? A He was -- he was already -- I had looked before. I mean I seen traffic behind me before. I mean I seen him before that time. I mean I glanced in the back before I turned, and I had made sure that letting him know that I was going to turn. I had my turn signal on. Q All right. So were there other vehicles behind Mr. Murphy, or couldn't you tell? A No, sir, there wasn't any other persons behind me at that time, no, just his vehicle. Q All right. And so as you put your left-hand turn signal on, I believe you said there was no traffic coming in the southbound lane? I.-, I e 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A That's correct. Q So there was no reason for you to stop or anything before making your left-hand turn? A I slowed down. I slowed down, had my turn signal on, and I started proceeding in my turn. There was no traffic coming at all in the southbound lane. Q Now, as you started to make your left-hand turn, tell me what happened then. A I was just proceeding into my left-hand turn, and just all of a sudden, he apparently was going around me, and I didn't even see him going around, trying to go around me. I was paying attention to my turn, going into my turn, and that was -- that's what happened, and just boom, it just happened instantly. Q Okay. So at some point you saw Mr. Murphy in your rearview mirror? A Yes, and he seemed -- he was slowing -- he seemed to be slowing down. I mean I didn't expect him to go around me at the time. Q Okay. So -- A I was already proceeded in my turn. Q After seeing him in your rearview mirror, the next time you notice his vehicle is when your vehicle and his collided? A I just -- it just happened. I was just turning. 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 It happened so instantly. I don't know why he was going in that other lane if he knew I was turning. Q What were you driving at the time? A I was driving my Chevy Blazer, and that's a 1988 Chevy Blazer. Q And what was Mr. Murphy driving, if you know? A I don't. All I know it was an off red color vehicle. Q A small car? A It was a small car. Q Would you agree that your Blazer was considerably larger than his car? A Yes, sir. Q And what part of your Blazer was impacted? A The front panel, bumper, the left front panel, bumper. Q The left front of your Blazer? A Yes, the left front panel. Q And which part of Mr. Murphy's car did it strike? A I don't know because it happened so suddenly, I don't recall. Q Do you have any idea how fast you were going at the time? A I was already almost in -- I was already very 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 slow going into my turn. Q Did your vehicle sustain damage? A Yes, it did. Q Do you know how much? A I'd estimate -- I don't know. David, do you? Q Did you get an estimate? A I think we did get an estimate on it. Q Who provided it if you know? A I don't remember. Q Did you ever have the damage repaired? A No, sir. Q Is there a particular reason that you didn't have it repaired? A I couldn't afford it. Q Well, did you ever -- A I don't know if the insurance -- I don't know what -- they were debating. I don't know. I don't know why it wasn't repaired. I just didn't drive it. I ended up selling it. Q Oh, you sold the Blazer? A I ended up -- eventually I ended up selling it. Q Do you know when that was? A No, I don't. I don't recall. 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. REINAKER: Do you have anything in there, Mr. Rosenberg, that would be an estimate? MR. ROSENBERG: Yes, we do. MR. REINAKER: I mean could you show it to her to see if that's what she's referring to? MR. ROSENBERG: Sure. It was provided to you or to your firm and to the insurance carrier. You should have that on file. THE WITNESS: Yes, I think it was like -- MR. ROSENBERG: Just one second. Off the record. (Discussion held off the record.) BY MR. REINAKER: Q Let me just ask first, I've been handed a document that appears to have been provided by Dellingers Auto Body, Incorporated, on South Market Street in Mechanicsburg. Are you familiar with that business? A Yes, I am. Q And did you take your vehicle there for the purpose of getting this estimate? A Yes, I believe I did. Q And it appears to me that the total from this estimate is $1,638.74. Does that sound right to you? A That's correct. Q All right. Where is the othe r one from? MR. ROSENBERG: It's hard to read. Off the I-, 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 record. (Discussion held off the record.) BY MR. REINAKER: Q Okay. A Uh-hum. Q There's also another estimate that apparently was prepared by the State Farm office on Limekiln Road. Do you remember taking your Blazer there? A I don't recall. Q Okay. Thanks. Okay. Immediately after the impact, what did you do? A We transferred information on the vehicles and our car insurance, and then I went home. Q Well, after your impact, where did your vehicle stop? A I don't remember at this time. Q Do you remember if you were in the middle of the road, or were you able to get off to the side? A It's been such a long time ago, I don't remember. Q Did you get out of your vehicle? A Yes, I remember getting out of the vehicle. Q And did you have any conversation with Mr. Murphy? A Yes, we transferred information on our car 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 insurance. Neither one of us had a cell phone. Q I'm sorry. A I said yes, we had -- we transferred information on the car insurance. Q All right. Did you have any conversation with Mr. Murphy about the accident itself? A No. Q Was there a discussion about calling the police? A Neither one of us had a cell phone. Q Well, there was at least one home in the vicinity; is that correct? A None of them -- nobody was home there. It's hard -- the mansion's gates were closed. Nobody was there. Q Okay. Well, the question was did you have a conversation about calling the police with Mr. Murphy? A Not that I recall. Q Do you recall any conversation with Mr. Murphy about whether either of you were injured? A No. I just remembered just transferring the insurance information, and that was it. Q Do you recall having any physical problems immediately after the accident? A I started having neck pain and lower -- my arm, my left arm. It started going numb. Q How soon after the accident did that start? 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Right after the accident. Q You mean at the scene or sometime after that? A Sometime, it was about -- as soon as I got back home, my arm started going numb. Q So it happened when you got home? A Right. Q You said your arm started going numb? A My arm started going numb, and then I called my doctor, my doctor's office right away. Q Which arm? A My left arm. Q All right. And who was your doctor? A Dr. Abraham. Q Where is Dr. Abraham's office located? A Dillsburg Family Health Center. Q Was he -- is it a he? A It's a she. Q Was she your family doctor at the time? A Yes, sir. Q How long had she been your family doctor? A For many years. Q Let me ask you this. Before this accident, had you ever had a problem with numbness in your left arm? A No, sir. Q Had you ever had any neck pain problems before 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this accident? A No, sir. Q Okay. So other than your left arm going numb, were you having any other problems? A My neck. Q Your neck? A Uh-hum. Q What was wrong with your neck? A And my chest. Q What was wrong with your neck? A It was hurting. Q Any particular area? A Up in through here (indicating). It radiated down my arm. Q Left arm? A Yes, left arm. Q And you said there was a problem with your chest? A I was feeling chest pain. Q So you called Dr. Abraham's office and what -- A And they got me, took me in, brought me in. Q Was that the same day? A Yes, sir. Q All right. And what did they tell you your problems were? L., - .1 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A They sent me to get some x-rays done. Q Let me just interrupt with one thing. You said that you are taking Chloropam? A Yes, that's for just anxiety. Q How long have you taken that? A I just started on it. Q Just how recently? A I don't know. Approximately a couple -- probably a couple months. Q Were you taking any medications at the time of the accident? A No, sir. Q None? A None. Q Had you had anything -- any alcohol to drink before the accident? A No, sir. Q Okay. So where did they send you for these x-rays? A I don't recall. I don't remember. I don't know. David, do you know? MR. ROSENBERG: Off the record. (Discussion held off the record.) THE WITNESS: I don't know. I don't know. BY MR. REINAKER: L, - I 26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q But they were the same day as the accident? A Yes. Q Okay. And did anyone ever discuss with you the results of those x-rays? A Yes, they did. Q Who was that? A There was -- oh, gosh. I don't remember their names. Q It was not Dr. Abraham though? A I don't remember. I don't remember who discussed them, but I remember what the results of them were. Q And what were they? A I had herniated disks. Q All right. And was there any type of treatment recommended for this disk problem? A Physical therapy. Q Who recommended that? A I don't recall. Q All right. Let me ask you about the chest pains. How long did you continue to have the chest pains? A For a pretty long time. I can't give you a specific time. Q Are we talking about days or months or how long? A Well, I'm still having the pains. Q In your chest? 27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I'm still having the pain in my chest and in my arm and in my neck. Q Okay. I want to just concentrate on the chest pains, okay? A Okay. Q Are you still having the chest pains even till today? A Off and on. It's not a regular thing. It's only when I'm -- it's only if I'm tugging or trying to do my daily chores. Q Have you consulted with anyone about the chest pains? A It's just coming -- yes, it's -- Dr. Lupinacci. I have nerve damage. Dr. Lupinacci said it's coming from the nerves. The nerves are being pinched, and that's what's causing the chest and the arm pain because my nerves are being pinched. Q And this is Dr. Lupinacci that told you that? A Yes, sir. Q And does he have a specialty? A Yeah, he is a specialist in nerve. Q All right. Do you get any specific treatment for these chest pains at the moment? A No, I had -- no. Q Do you take any medication for it when you have L. - -? 28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the problems? A No, I was -- no, at this point I'm -- I can't afford the medicine so I -- no. Q How often would you say that you have these problems with chest pains? A Not very often. I have it more in my neck and in my arm. Q I'm going to ask you some more questions about your neck and arm problems, but before I get to that, are there any other problems or injuries that you feel happened to you in this automobile accident? A No, just what I've told you. Q All right. And is it your understanding that the neck pain and arm pain is related to this disk problem? A Yes, sir. Q All right. When did you first go to see Dr. Lupinacci? A I don't recall the date. Q All right. Did someone refer you to him, or did you go to him on your own? A I believe I was referred to him, but I don't recall from who. Q You said before that physical therapy was recommended initially? A Yes, sir. 29 7 L 4 E E 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Did you have physical therapy treatments? A Yes, I did. Q And who provided those? A I'm not -- I don't remember the names of the places that I did go. Q Was there more than one? A Yes, sir. Q And how long did these treatments last? A I don't remember how long I was in there. Q Do you still receive physical therapy treatments? A Not at this time, no. Q Do you remember when the last time you had one was? A No, I don't remember. Q Okay. Other than physical therapy have you received any other treatments for your neck or arm problem? A Yes, I have. Q What was that? A Injections. Q How many? A Three, I believe. Q And did Dr. Lupinacci provide these, or was it someone else? A It was another gentleman from his office. It was Dr. Rolle. 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Rolle? A Rolle. He performed the injections into my... Q And did these provide any relief? A No, not at :,y Q Not at all? A (Shakes head from side to side.) Q Is that a no? A Yes, it's a no. Q Okay. Other than the physical therapy and the injections, have you received any treatments? A No. Q Do you remember how long ago it was when you had the last injection? A No, I don't remember. Q Has there been any other discussion with any providers about additional treatments that you might receive? A Just, you know -- I don't have insurance at this time, so I don't know. I don't. Q But have you had any discussions with any providers about any other treatments that might be available to you to help with whatever problems you're having? A Yeah, I have had -- Dr. Lupinacci had said about surgery. 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q What did he tell you? A That it could help, but it's a 50/50 chan ce whether I would recover or not. Q And is it your testimony that you haven't pursued that be cause you don't have insurance? A That's correct. Q How is the problem today compared to what it was like a day or two after the accident? A I'm in poor condition. I can't lift. I can't do any of the normal things I used to do. Q But is it more painful today than it was then, or has it stayed the same? A It's stayed about the same. Q So your condition within a day or two of the acciden t is basically the same as it is today? A Yes, sir. Q And what is the problem today? Is it numbness, is it p ain, or all of those things? A It's the pain radiating -- it's the pain radiati ng down my arm and the tugging on my neck. Q And do you have pain every day? A I have pain every day. Q All the time? A It's not constant, no. Q It comes and goes? 32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A It comes and goes. Q Is there anything in particular that causes it? A Any kind of -- any kind of chore, any kind of lifting, like if I lift my son or if I need to lift my son, it tugs. It hurts. It starts really hurting bad. Q Do you have any medication that you take for the pain? A I don't have any insurance. I'm just trying to get insurance at this time so I can get some medicine that I need. I've been just dealing with the pain. Q You mean you don't take Advil or aspirin or anything like that? A I tried all that, and none of it, none of it seems to help. Q What kind of insurance are you trying to get? A Right now I'm going through the social services to try to get some help through them so I can get some, because right now I just don't have any insurance to pay for medicine or anything. Q When -- the day of the accident, were you scheduled to work that day? A I don't recall. Q Did you have regular working hours at the time? 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I had regular working hours. They changed my schedule, you know, off and on, so it varied. It varied. One day I'd be off one week. The next day, you know, I worked 40 hours a week, but the scheduler would take you off in between one of those days. It wasn't any particular day. I don't recall whether or not if I was working that day, no. Q But somebody, either Dr. Abraham or someone else told you you would not be able to work for awhile; is that right? A That's correct. Q And was that because of the lifting or what particular problems did work present? A Because I was in pain. Q And did they tell you how long you should stay off work? A She took me off of work. She took me off the job. Q Dr. Abraham? A Dr. Abraham, I believe, yes. Q And how long were you off of work? A I don't remember how long I was off of work. Q Well, at some point you went back to Messiah Village, correct? A That's correct. 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Do you remember approximately when that was? A No, I don't. I don't have no specific dates. No, I can't remember. Q All right. Were are you released to go back on light duty work at some point? A Yes, I do. Yes, I was. Q And it seems to me there was a letter from Messiah that said they weren't going to take you back with light duty? A Right. Q Is that right? A That's correct. Q All right. So at some point when you went back, there weren't any light duty restrictions; is that right? A I -- they would not give me the light duty. I couldn't -- they wouldn't let me come back because they didn't agree with the light duty restrictions. I wasn't allowed to come back to work. Q I understand that. My question is when you did go back I'm assuming there weren't any restrictions on you then; is that fair to say? A There wasn't any restrictions? I don't understand the question. Q Okay. Well, it's my understanding that you could 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have gone back to work with light duty restrictions, but Messiah Village wouldn't take you back under those circumstances; is that right? A Yes, they would not take me back even under light duty restrictions. Q But at some point you did go back to work at Messiah Village, correct? A Yes, I did at some point. Q All right. So would you agree that when you went back to work at Messiah Village there weren't any light duty restrictions on you at that time or they wouldn't have taken you back, right? A That's correct. Q Okay. Now, how long did you continue to work at Messiah Village after you went back before you quit? A I don't remember how long I was there. I don't. Q I think you had said earlier that you were missing work and you were afraid you were going to be fired? A I was missing work, yeah. I was missing work because I was calling off tremendously a lot because I couldn't perform the job. Q All right. And that's when you then took a job with Bethany? 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I had, yes. Q Was that a full-time job when you started at Bethany? A Yes. Q Did you fill out any kind of an application at Bethany? A Yes. Q Did they require you to undergo any kind of a physical examination before starting to work there? A I don't remember if they did or they didn't. Q Where is Bethany? Is that just the name of it, or is there something more to the title? A No that's just Bethany. Q And where are they located? A Rossmoyne. Q Do you recall in this application that you filled out whether they asked you any questions about your health? A I don't remember. Q All right. And I think you said that you worked there for about two months; is that right or not? A That's correct. Q And why did you leave there? A I couldn't perform my job. I was missing too many -- I was missing too many days. . 37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q And did you take another -- A They fired me. Q They fired you? A They fired me because I missed too many days. Q Did you have a job after that? A No, I went on unemployment. Q So you haven't worked anywhere since Bethany fired you? A That's correct. Q Now, has any physician or health care provider told you that you are not capable of working? A I haven't seen a doctor since, since then, since after Bethany. Q Okay. A I just stayed on the unemployment. Q Do you still receive unemployment? A No, sir. It ran out. Q When was that? A I believe two, maybe two months ago, two, three months ago. Q And have you been looking for a job at any point since Bethany? A I've been training. I've been going through Thompson Institute to train for another career. Q And this is with computers? 38 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes, sir. Q How often do you attend classes? A It's a program where you take -- do your own -- they send you the books in the mail and then you do as you can. Q This is at home? A This is at home. Q You have a computer at home? A Yes, sir. Q And do you work on these classes every day? A No, sir. Q How often during the week are you working on your class? A As much as I possibly can do. Q How much is that roughly? A Maybe sometimes only three hours out of a week. Q And you have completed the high school equivalency portion? A Yes, sir. Q How long did that take you to complete that? A About the seven months. Q Seven months? A About that. Q And how long have you been involved with the computer training portion? ` r 39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I just started. I've been into it for maybe approximately four months now. Q All right. So I think you had earlier said that you haven't seen any doctor since roughly when you left Bethany; is that right? A That's correct. Q Any other treatments or any other providers you've seen since then? A No, sir. Q And would that have been sometime in 2002? A I haven't seen any doctors this year, I mean I believe this year. Q Do you think -- A I know I was seeing a lot of doctors. My insurance ran out. That's why I could not see any doctors. I couldn't afford to see any doctors. I didn't have any money. Q Okay. You said that you take Chloropam for anxiety or depression or -- A Yes. Q When were you first -- A Anxiety. I just started taking that. I've been going under a lot of anxiety because I don't know what to do. I'm -- I don't know what to do. Q All right. You said you've been taking this for 40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 a couple months? A Yeah. Q Who prescribed that for you? A My doctor. Q Dr. Abraham? A Yes, sir. Q Has anyone told you that those particular problems have anything to do with the auto accident? A There's a lot of stress on my family, and it's a lot of stress on me, and I just started having -- not knowing what I'm going to do to support my family which is bringing on the anxiety, not knowing. Q You and your husband, were you married to your husband at the time you separated? A We were married and we separated, yes. Q All right. And that was since the accident? A That was after the accident. Q Okay. A We got married a little bit later and things just didn't work out. Q And your husband's name is Nipon? A Nipon. Q Where is he living today? A He moved into another apartment. Q In the Harrisburg area? 41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Uh-hum. Not in the Harrisburg area. It's right down by -- it's right off of Rossmoyne Road. Q And do you believe that these problems from the auto accident affected your relationship with your husband? A Yes, sir. Q In what way? A It was too much. Q What do you mean by it was too much? A To -- I couldn't -- you know, it was too much -- I was dependent on everybody and dependent on him, and he's sick. Q He's sick? A He's sick, too. Q What's his problem? A He has -- he's ill. He's terminally ill. Q With what? A With hepatitis C. Q Do you have any idea how he contracted that? A That was years ago. We were fine. Q All right. How has -- how have the injuries that you had in this accident affected your life? What things can't you do today? A I can't do -- I can't lift my son. It hurts to lift him. He wants to play, and I can't play with him. 42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Has anyone given you restrictions on how much you can lift? A I just have to be -- I don't remember how -- I don't know. I do not know. I don't remember. Q Okay. How else has it affected you? A I have to -- I was dependent on my mother and my 13-year-old daughter to do a lot of things for me that I can't do anymore. Q Like what? A Oh, like take care of the yard work and stuff that needs to be taken care of out there, taking caring of Shawn, my son, put a lot of responsibility on her. Q On your mother? A On my mother and my daughter. Q Who does the yard work? A My mother and my daughter. She goes out and pulls the weeds and stuff that needs to be done. Q All right. Other than yard work and taking care of your son, what other things have been affected? A The house, the house chores, the vacuuming. Q Are you able to do any of that? A To a certain extent, and then I start hurting, and then I have to stop. Q So your mother and daughter help with that? A My mother and my daughter takes care of all that 43 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for me. Q Okay. Anything else? A Just the regular chores of the day, the laundry. Q You said that you continue to look for employment; is that right? A I had to. Q What -- A I -- my parents, I mean my mother can't take care of, you know, my financial. She's doing everything that she can. I'm trying to look for -- I'm trying to go into another career. Q What kind of job are you hoping to get? A Well, I'm training for a PC specialist. I'm hoping that I'll be able to sit there and be able to type because, you know -- Q So you're looking for a job where you could be working with a computer? A Yeah, something that I don't have to do any lifting or anything. Q And have you investigated any particular positions at this point? A No, I'm not completed with my course. I'm waiting to be done with my course. Q Okay. All right. Is there anything in terms of how these injuries have affected you that I haven't 44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 asked you about? A Just the driving. I'm a little leery about driving at times. Q Why is that? A Because it's a scary situation when somebody runs into you, and, you know, you're just scared when you get behind the wheel about, you know, what's going to happen that day. Q Do you still drive? A I still drive because I must. Q Are you the only person in your home that has a driver's license at the moment, I take it? A I'm the only person in my household that has a driver's license, yes. MR. REINAKER: Thank you. That's all I have. (The deposition was concluded at 10:51 a.m.) 45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 COUNTY OF DAUPHIN SS COMMONWEALTH OF PENNSYLVANIA . I, Diane F. Foltz, a Notary Public, authorized to administer oaths within and for the Commonwealth of Pennsylvania, do hereby certify that the foregoing is the testimony of Billie Jo Fisher-Sanersri. I further certify that before the taking of said deposition, the witness was duly sworn; that the questions and answers were taken down stenographically by the said Reporter-Notary Public, and afterwards reduced to typewriting under the direction of the said Reporter. I further certify the said deposition was taken at the time and place specified in the caption sheet hereof. I further certify I am not a relative or employee or attorney or counsel to any of the parties, or a relative or employee of such attorney or counsel, or financially interested directly or indirectly in this action. I further certify that the said deposition constitutes a true record of the testimony given by the said witness. IN WITNESS WHEREOF, I have hereunto set my hand this 28th day of October, 2004. NOTARIAL SEAL DIANE F. FOLTZ, Notary Public City of Harrisburg, Dauphin County M Commission Expires March 19, 2007 r'a- ?' 4?*11??_?"__ Diane F. Foltz, RMR `` Notary Public exhibit b DAVID C. BAKER, M.D. 19 Brookwood Avenue, Suite 104 Carlisle, PA 17013 (717) 243-9010 Boars COMM in O edfc BarM Mambsr AMN Ito Academy 0 Onhopeeft Surgeons August 10, 2005 GCWFEW Eager; Reinaker & Spinello 1347 fruitv+ille Pike Lancaster, PA RE: Billie Jo Fisher-Sanersi Dear Mr. Eager: Thank you for Arcing me to perform an Orthopaedic Independent Medical Evaluation on bb. Billie Jo Fisher-Sanersi at my Carlisle office on August 8, 2005. The ;following report is based on review of the records and history and physical examination. I explained to Ms. Fisher-Sanersi that she was here for an independent Medical Evaluation at the request of E ftf, R6naker & Spinello. I explained to the patient I was not, nor would I be, the treatilig physician. Ms. Fisher-Sanerd expressed understanding of this. She also understood that if anything caused pain during the ton she could and should request me to stop. Ms. Fisher-Saaersi expressed understanding of this. RECORDS REYMMD, - 1. Records of D illsburg Family Practice, primary care physician. 2. Records of Dr. William Bauder, Neurosurgeon, 2128/02. 3. Keystone Spine Center. 4. Health South Rehab, epidural steroids. 5. Health South Physical Therapy. 6. Pinnacle Health Physical Therapy. 7. Records of Dr. Lupinacci, Prism Rehab. 8. EMG, 4/18/02, Dr. Lupinacci. 9. Records of Dr. Becker, Chiropractor. 10. MRI and report, 2/14/02, cervical spine, Magnetic Imaging Center. I L MRI and report, 3/1/02, Community Imaging Associates. 12. MRI and report, 10/27!02, Magnetic Imaging Center. 13. MN and report, cervical spine, 5/23103, 14. X-ray report, left shoulder, 8/14101, 15.3 -ray report, left shoulder and cervical spine, 1/19102, Holy Spirit Hospital. R ? Palm RE: Billie Jo Fisher-Sanersi 16. CT scam of abdomen report, 2(5/03. (Motor vehicle accident, mid epigastric pain). Holy Spirit Hospital, 17. X-ray rye mja , left forewma 2!4/03, Holy Spirit Hospital. IS. CT scan report, brain, 2/4103. MU AS 7 BY TAE 1?ATIENT AND ACCORDING TO THE RECD-RDS: Ms. Fisher-Sanersi is a 35-year-old female who motes that is January of 2002 she was involved in a motor vehicle accident. She was the seatbelted driver of a car that was making a left hand turn. The car she was driving was fait on the driver's side door by a car passing her ftom the left, I asked her more details about the accident such as whether any seatbelt broke or the seat brdw. She states she does not remember, but does not think the seatbelt broke. She does not remember how mnaoh dollar damage was done to the car she was in. She states she is not sure how fast the car was going that fait her. I asked her if she went to the hospital that day and she states she did not remember. In review of the records it appears that she did see her family doctor on January is, 2002 and they make no mention of her going to the hospital. They record neck and left shoulder pain and she was sent to Holy Spirit Hospital for neck and left shoulder x-rays the next day. These were reported as normal. Ms. Fisher-Sanersi states she is not exactly sure what happened next. She saw ;many doctors. I went through the history with her based on the records I have. She dad have multiple MRI's in 2002 and these were reviewed. She had MRT's of February 2002, March 2002 and October 2002. Very small noncompressive disc herniations were present at C5- C6 and C6-C7 and very slight degenerative changes were present at C3-C4 and C4-C5. The records indicate that Ms. Fisher-Sanersi saw Dr. Beutler on 2/28/02. Dr. Beutler's diagnosis was "Ms. Fisher has persistent neck pain after a motor vehicle accident. There does not appear to be a specific nerve rant impingenteftt on the ME. However, she did exacerbate her pain on 2115/03 at work" The body of Dr. Bender's report states "she reports actually feeling somewhat improved until February 15, 2002. At that time she was lifting a resident at the place of her work at Messiah Village. She exacerbated the same pain. She notes a sensation of numbness along with the pain in her left arm. She notes that they stopped physical therapy awaiting further evaluation." It was this increase in symptoms that prompted Dr. Bender to order another MRI which was done on March 1, 2002 and this showed the same findings of minimal bulging of discs at CS-C6 and. C6-C7 and minimal degenerative changes at C3-C4 and C4-C5. Dr. Beutler placed her on light duty and apparently did not see her again until 4/16/04. The Patient was refetred to both Keystone Spine Center as well as Health South Physical Therapy. Page 3 RE: Billie Jo Fisher &mcni She also was refaced to Prism Rehabilitation. The records indicate she had an epidural steroid that she states helped a little bit temporarily. The EMG performed on 4/18/02 was reported ss normal. Ms. Fisher Sans~rsi is under the impression that the EMG shows "nerve damage." Ms. Fisher-Sanersi also was referred by Dr. Lupinacci at Prism Rehab for chiropractic care at Becker Chiropractic. The records indicate that there was not much treatment after 2002. Ms. Fisher-Sanerd states she could not afford more treatment. ??DIAi-s_TORY: PAST She states she has borderline diabetes that is controlled by diet. She denies any history of asthma, hypertension, previous neck or shoulder problems. Patient states she does smoke cigarettes, but denies any history of alcohol use. The records indicate that she has been treated both as an outpatient and as an in-patient for recurring alcohol problems. O Ms. Fisher-Sanersi states she can not remember being involved in any other accidents. The records indicate that in 1993 she was in a car that was hit by a train. In 1995 she was in a motor vehicle accident in which her car was hit by a deer and in 2003 she was in a motor vehicle accident that oec im ed when the car she was driving was totaled after it slid on ice and hit a true. Wpm HISTORY: Ms. Fisher-Sanersi states she has recently started working at Beverly as a ON,Ar She states she stopped working in 2002 at Messiah Village. C „R , Y14?TQ11S: Ms, FisherSanersi complains of a variety of symptoms. She states she has headaches, as well as dizziness. She states she has neck pain as well as left arm pain.. She states the 10 ft arm does not feel the same way the right does. She does not complain of any dermatomal numbness upon questioning, however. Upon questioning, she also states the left side of her face feels different than the right side. She states the left hand cam cramp up and she has to move it around. She states she sleeps poorly, sometimes too much and sometimes too little. She smatea she gets headaches daily. She states at titres she has trouble breathing. She also states she has swelling in the left anterior chest. i , Page 4 RE: Billie Jo Asher,Sanersi N'A UN: Examination reveals no visible abnormalities to the cervical, thoracic spine, left shoulder, left arm or anterior dhest. She has slight increased upper thoracic kyphosis, but not in the pathologic range. The spine is well aligned with no obvious ecoliosis or accentuated lumbar lordosis. There is no palpable spasm in the anterior or posterior owvical muscles. Range of motion of the cervical spine revealed 50° of forward flexion, 40° of extension, 40° of right and left lateral bending, and W of left and right lateral rotation. The right arm was '/4 inch larger in circumfereace than the left arm and the forearms were equal circumference. Measurements were taken equal distant points above and below the elbow crease. There were no neurologic deficits in the left upper extremity with respect to strength, weakness or sensation. She had normal strength in deltdid, biceps, triceps, wrist extensors, wrist flexors and hand intrinsic muscles. There was nondermatemaJ altered sensibility to light touch in the left arm in a nondermtatomal fasbson, but this altered sensation was also present on the left side of her face when compared to the right. Grip strength using the Jamar dynamometer revealed invalid effort on both portions of the examination in the left hand. Spuriing's test and Hofftnan's test were both negative. There is no spasticity in either lower extremity. She was able to toe and heel walk. Examination of the left chest wall revealed no Abnormalities, although she complained of it being swollen. Examination of the left shoulder revealed an intact rotator cuff and full painless range of motion of the left shoulder joint. DI&(&L0S3JC 5 IE MRI of the cervical spine of 2/4/02 and 3/1/02 And 10/22/02 show mild disc bulging at C5-C6 and C6-C7 with no evidence of any herniation, spinal canal compromise or nerve root impingement. These are mild disc bulges which are normal for her age. The EMG pezfornted in April of 2002 was reported as normal. +1P 'SI : Diffuse pain involving neck, left shoulder and left arm accompanied by headaches and dizziness, unknown etiology. Page S RE: Billie Jo Fisher-Sanersi Ms. Fisher-Sanersi is under the impression that her EMC showed nerve damage and her MRI's showed bulging and herniated discs that are "moving around." This is not the case. Her altered sensibility in her left arm is not only not explainable from a cervical standpoint, but present in the left side of her face. If this was a consequence of a neurologic abnormality it would be something in her brain. The reason I think it is not is that she had similar symptoms in 1995 where her family physician recorded on November, 29, 1995 "complete neurologic won is remarkable only in that the patient has different sensation on the entire left side of the body and face as compared to the right." At that visit they also described symptoms of headaches, tightness in the neck, trouble breathing. These symptoms developed after a motor vehicle accident when she hit a dear on November 27, 1995. That note also records an accident in 1993 where the car she was in was hit by a train. That note also records that her sister states she has "a trouble with amddy and `nervous breakdown. t" Ms. Fisher-Sanersi has problems with andety and substance abuse. Although she denied using alcohol, the records indicate that she has been in rehab. Also the records indicate that she has multiple sources of trauma and a husband with a terminal illness. Her diagnostic studies were unremarkable. Those studies and her exvWnation do not explain her persistm pain. The history recorded on 2/28/02 by Dr. Beuder is revealing in that it states "about an hour after the accident she developed neck pain .... she reports actually feeling somewhat improved until February 15, 2002. At that time she was lifting a -resident at her place of work at Messiah Village. She exacerbated the same pain. She notes a sensation of numbness along with the pain in her left arm." In other words, Ms. Fisher-Senersi told Dr. Beutler that she was improving and then had a problem at work on February 15, 2002 lifting a patient. I do not find it unusual for someone who has been in a motor vehicle accident to .have aches and Pis Ior several months, however, I see nothing about the type of accident she was in, the PhYskW examination and the diagnostic studies to explain the persistence of her pain. r All of the above statements have been made with a reasonable degree of medical certainty. If you have any questions, please feel 8fee to give my office a call. Tbank you. Sincerel David C. Aker, IVLD. t , Exhibit C Y e ---- May 15, 2002 Vanitha Abraham, M.D. Dillsburg Family Health Center 204 Mumper Lane Dillsburg, PA 17019 RE: BILLIE JO FISHER ACCT #: 26963 DATE: 5/15/02 Dear Doctor Abraham: ffdS?` I Physicians of Rehabilitation, Industrial & Spine Medicine, PC Billie Jo Fisher was seen in follow up today with a history of cervical disc disease. _She has. had a dramatic response with complete resolution of her left arm and shoulder pain. She had some mild intermittent neck pain. She continues at Keystone Spine Center for McKenzie exercises and they are going well. PHYSICAL EXAM: Left upper extremity strength reveals 545 strength throughout. DTRs are l+ and symmetric. She has mild left cervical paraspinal muscle tenderness. Sensory exam is normal in the left upper extremity. Fine and gross motor coordination of the left upper extremity is normal. ASSESSMENT: Cervical radiculopathy with documented degenerative disease at C5-6 and C6-7 with an excellent response to initial rehabilitation intervention. . PLAN: At the present time she is going to continue her present outpatient therapies. I will see her back in follow up in two weeks. She works as a CNA and we are going to hold on return to work at the present time. We are looking to potentially returning her to work at the end of the month. Sincerely, Michael F. Lupinacci, M.D: Medical Director, Physical Medicine and Rehabilitation MFL/kts Dictated: 5/15/02 Transcribed: 6/3/02 A Spectrum of Medical Services. to Restore the Quality of Lift: Physical Medicine Rehabilitation Electrodiagnosis Michael F. Lupinacci, MD Si Van Do, MD William A. Rolle, Jr., MD Everett C. Hills, MD, MS Steven E. Morganstein, DO Julia Deputy, PA-C Jennifer L. Tanner, PA-C Rebecca H. Lingenfelter, PA-C Vincent J. Reed, PA-C Maria Trees, PA-C 175 Lancaster Boulevard., P.O. Box 2028 Mechanicsburg, PA 17055;, Phone 717 691-3755 ; Fax 717 691-3834 450 Powers Avenue Rear Entrance Harrisburg, PA 17109 Phone 717 561-4242 Fax 717 561-4903 www.prismdrs.com em2il:'info@prismdrs.com ! r Y June 5, 2002 Vanitha Abraham, M.D. Dillsburg Family Health Center 204 Mumper Lane Dillsburg, PA 17019 RE: BILLIE JO FISHER ACCT 26963 DATE: 6/5/02 Dear Doctor Abraham: I had the pleasure of evaluating Billie Jo Fisher today: She has a historyof a motor vehicle accident and cervical disc disease. She had a dramatic response from outpatient therapies. She now has mild occasional neck pain. She has completed her therapies at Keystone Spine Center, and they have gone very well. PHYSICAL EXAM: Her motor strength is 515 throughout. Sensation is intact to pin prick and light touch in both upper extremities. Sensory exam is within normal'limits. Her cervical neck range of motion is full and pain free. She has no cervical paraspinal muscle tenderness. ASSESSMENT: Cervical radiculopathy with documented degenerative disease at C5-6 and C6-7 with an excellent response to rehabilitation therapies. PLAN: At the present time she is transitioning to a home exercise program. I am going to be seeing, her back in follow up in 3 weeks. She wishes to return to work with full duties. I very much appreciate the opportunity to participate in her care and thank you for your continued interest in her rehabilitation management. Sincerely, • ?t/f Michael F. Lupinacci, M.D. Medical Director - Physical Medicine and Rehabilitation MFL/kts Dictated: ' 6/5/02 Transcribed: 6/17/02 Physicians of Rehabilitation, Industrial & Spine Medicine, PC A Spectrum of Medical Services to Restore the Quality of Life:. Physical Medicine Rehabilitation Electrodiagnosis Michael F. Lupinacci, MD Si Van Do, MD William A. Rolle, Jr., MD Everett C. Hills, MD; MS Steven E. Morganstein, Do Julia Deputy, PA-C Jennifer L. Tanner, PA-C Rebecca H. Lingenfelter, PA-C Vincent J. Reed, PA-C Maria Trees, PA-C 175 Lancaster Boulevard- P.O. Box 2028 Mechanicsburg, PA 1705,5: Phone 717 691-37SS Fax 717-691-3834 450 Powers-Avenue Rear Entrance Harrisburg, PA 17109 Phone 717 561-4242 Fax 717 561-4903 www.prismdrs.com email: info(_prismcirs.com r . ? . June 26, 2002 Vanitha Abraham, M.D. Dillsburg Family Health Center 204 Mumper Lane Dillsburg, PA 17019 RE: BILLIE JO FISHER ACCT #: 26963 DATE: 6/26/02 Dear Doctor Abraham: Billie Jo Fisher is seen in follow up today. She has returned to work full time, doing reasonably well in that capacity. She is working smartly and having assistance for any lifting activities, and overall her patient load has been reduced. from 15 to 8 generally throughout the hospital. She still has neck soreness and left upper arm soreness. She continues. to do her home exercise program. She has a very busy life with two children and full time work, and she is managing the best she can. The patient takes an occasional Darvocet, Flexeril, or Naprosyn as needed for neck or-arm discomfort. PHYSICAL EXAM: her motor strength is 515 throughout. Sensation is intact to pin prick and light touch in both upper extremities. Sensory exam is within normal limits. Cervical neck range of motion is full and pain free. She has mild left cervical paraspinal muscle tenderness. DTRs are absent bilaterally in triceps, 1+ bilateral biceps on the right, unobtainable left biceps, 1+ bilateral brachial radialis. ASSESSMENT: Cervical radiculopathy with documented degenerative disc disease at C5-6 and C6-7. She is still having some symptoms related to this. These have recurred since she has returned to work. Her neurologic exam is stable with the exception of an absent left C5 reflex. PLAN:. at the present time she is going to continue her home exercise program. We again reviewed precautions for work. She feels she must continue working full duty at fhe present time to help sustain he household. We reviewed the precautions of what she should not do and what type of lifting she should share. . Again, I also reinforced continuing her home exercise program. She is also going to look at working out at the Messiah gym to improve her upper extremity strength. I am going to see her back in follow up in eight weeks for re-evaluation. She knows she can call the office in the interim if needed. Physicians of Rehabilitation, Industrial & Spine Medicine, P.1 A 5peamm of Medical S.zm.cis, to Restore the Quality of Life: Physical Medicine Rehabilitation Electrodiagnosts Michael F Lupinacci, MD Si Van Do, MD William A. Rolle, Jr., MD Everett C. Hills, MD, MS Steven E. Morganstein, DO Julia Deputy, PA-C Jennifer L. Tanner, PA-C Rebecca H. Lingenfelter, PA-C Vincent J. Reed, PA-C Maria Trees, PA-C 175 Lancaster Boulevard. P.O. Box 2028 Mechanicsburg, PA 17055; Phone 717 691-3755 Fax 717 691-3834 45 0 Powers Avenue Rear Entrance Harrisburg, PA 17109 Phone 717 561-4242 Fax 717561-4903 www.prismdrs.com email: info@prismclrs.com f r 1 • Page 2 Billie Jo Fisher 6/26/02. I very much appreciate the opportunity to participate in her care and thank you for'your continued interest in her rehabilitation management. Sincerely, , Michael F. Lupinacci, M.D. Medical Director Physical medicine and Rehabilitation MFL/kts Dictated: 6/26/02 Transcribed: 7/9/02 y r 1 a August 21, 2002 Vanitha Abraham, M.D. Dillsburg Family Health Center 204 Mumper Lane Dillsburg, PA 17019 Physicians of Rehabilitation, Industrial Spine Medicine,P.C. RE: BILLIE JO FISHER ACCT #: 26963 DATE: 8/21/02 Dear Doctor Abraham I had the pleasure of re-evaluating Billie Jo Fisher today. She has recently had an increase of her neck A Spariru+e of Medical Services. pain. It is primarily mid to lower cervical, central, and slightly to the left. She has occasional to Restore the Quality of Life: shooting pains in her left arm, but that is rare. She has no weakness in her arms, no bowel or bladder . Physical Medicine changes. - Rehabilitation Elect:Qiagnosis She continues to work at her job, full capacity, full time, although she is getting more help with heavier lifts and that is going better. She takes approximately 3 to 4 Darvocet per day and a Flexeril at night. She continues to do her neck exercises and has completed an outpatient course of physical therapy. PHYSICAL EXAM: Her motor strength is 515 throughout. Sensation is intact to.pin prick and light touch. Sensory exam is within normal limits. Cervical neck range of motion is mildly limited in all planes with mild to moderate pain in the extremes of range. She has moderate left cervical paraspinal muscle tenderness. DTRs are absent bilateral triceps, 1+ bilateral biceps, 1+ bilateral brachial Michael F. Lupinacci, MD Si Van Do, MD radiates. William A. Rolle, Jr., MD Everett C. Hills, MD, MS ASSESSMENT: The patient has a history of cervical radiculopathy with documented degenerative Steven E. Morganstein, DO disc disease at C5-6 an d C6-7. She has no significant radicular symptoms, although she continues to have axial neck pain. Her neurologic exam is stable with a return of her left C5-6 reflex. She continues to do significant heavy labor in a nurse's aide osition at work, although she is asking for Julia Deputy, PA-C p _ Jennifer L. Tanner, PA-C help more frequently. She has been compliant with her home program Rebecca H. Lingenfelter, PA-C Vincent J. Reed, PA-C PLAN: At the present time we are going to proceed with her second epidural steroid injection. She Maria Trees, PA-C will continue with her cervical neck exercises. I will see her back ten days following her cervical injection. I very much appreciate the opportunity to participate in her care and thank you for your continued interest in her rehabilitation management. Sincerely, 175 Lancaster Boulevard- P.O. Box 2028 Mechanicsburg, PA 17055: Michael F. Lupinaccl, M.D. Phone 717 691-3755; Medical Director Fax 717 691-3834 Physical Medicine and Rehabilitation MFL/kts 450 Powers Avenue Rear Entrance Harrisburg, PA 17109 Dictated: 8/21/02 Transcribed: - 8/21/02 Phone 717 561-4242 Fax 717 561-4903 wwivprismdrs.com email: info@prismdrs.com ? a 3 October 16, 2002 Ppisi 9' Vanitha Abraham, M.D. Dillsburg Family Health Center 204 Mumper Lane Physicians of Rehabilitation, Dillsburg, PA 17019 Industrial & Spine Medicine, N RE: BILLIE JO FISHER ACCT #: 26963 DATE: 10/16/02 Dear Doctor Abraham: A Spectrumrof Medical Services I had the pleasure of re-evaluating Billie Jo Fisher today. She had a cervical epidural steroid to Restoff the Quality of i fe: injection done by Dr. Rolle on 9/12/02. She was improved for 7 days and then her symptoms Physical Medicine Rehabilitatlon returned with pain in the left side of her neck and' left arm. She takes Darvocet on an as needed Electrodiagnosis basis and-also has taken Skelaxin. PHYSICAL EXAM: her motor strength is 515 throughout. Sensation intact to pin prick and light touch. Sensory exam is within normal limits. Cervical neck range of motion is mildly limited in mfr.; all planes with mild to moderate pain in extremes of range. She has moderate left cervical paraspinal muscle tenderness. DTRs are absent in bilateral triceps, 1+ bilateral biceps, 1+ bilateral brachial radialis. Michael F. Lupinacci, MD ASSESSMENT: The patient has a history of cervical radiculopathy with documented Si V. Do, MD degenerative disease at C5-6 and C6-7 with both axial neck pain and left upper extremity pain, William A. Rolle, Jr., MD consistent with recurrence of radiculopathy. Everett C. Hills, MD, MS Steven E. M'organstem, DO PLAN: Julia Deputy, PA-C At the present time we are going to have a follow up cervical MRI to assess for progression of her Jennifer L. Tanner, PA-C Rebecca H. Lingenfelter, PA-C discogenic disease. Vincent J. Reed, PA-C Maria Trees, PA-C She will continue her present medications. I will see her back in follow up in approximately one week. I very much appreciate the opportunity to participate in her care and thank you for your continued interest in her rehabilitation management. Sincerely 175 Lancaster Boulevard , P.O. Box 2028 Mechanicsburg, PA 17055, ?.r?c t X110 Phone 717 691-3755 Fax 717 691-3834 Michael F. Lupinacci, M.D. Medical Director Physical Medicine and Rehabilitation 450 Powers Avenue MFL/kts Rear Entrance Harrisburg, PA 17109 Dictated: 10/ 16/02 Phone 717 561-4242 Transcribed: 10/23/02 Fax 717 561-4903 www.prismdrs.com email: info@prismdrs.com October 24, 2002 Vanitha Abraham, M.D. Dillsburg Family Health Center 204 Mumper Lane Dillsburg, PA 17019 RE: BILLIE JO FISHER ACCT #: 26963 DATE: 10/24/02 Dear Doctor Abraham: I had the pleasure of re-evaluating Billie Jo Fisher today. She had a cervical epidural steroid injection done on 9/12/02. Unfortuantely, she still has significant leftsided neck pain and left arm pain. We repeated her cervcial MRI on 10/22/02, which confirmed again degenerative disc disease at C5-6 and C6-7, but no focal herniation. She takes Darvocet on an as needed basis and also takes Skelaxin as needed. PHYSICAL EXAM: Her motor strength is 515 throughout. Sensation is intact to pinprick and light touch. Sensory exam was within normal, limits. Cervical neck range of motion mildly limitd in all planes with moderate pain in the extremes of range. She has moderate left cervcial paraspinal muscle tenderness. DTRs are absent in bilateral triceps, *1+ bilateral biceps, 1+ bilateral brachial radialis. ASSESSMENT: The patient has a history of cervcial radiculopathy involving her left upper extremity with documented degenerative disc disease at C5-6 and C6-7 with both axial neck pain and left upper extremity pain. PLAN: At the. present time we are going to proceed with a second course of outpatient cervical rehabilitation. We are going to hold on her third cervical injection for the time being: I am going to see her back in follow up in three weeks. I very much appreciate the opportunity to participate in her care and thank you for your continued interest in her rehabilitation management. Sincerely, Michael F. Lupinacci, M.D. Medical Director Physical Medicine and Rehabilitation MFL/kts Dictated: 10/24/02 Transcribed: 11/4/02 Physicians of Rehabilitation, Industrial & Spine Medicine, P.c A Spectrum of Medical Services to Restore the Quality of Lift: Physical Medicine Rehabilitation Electrodiagnosis Mic6d F. Lupinacci, MD Si Van Do, MD William A. Rolfe, Jr., MD Everett C. Hills, MD, MS Steven E. Morganstein, DO Julia Deputy, PA-C Jennifer L. Tanner, PA-C Rebecca H. Lingenfelter, PA-C Vincent J. Reed, PA-C Maria Trees, PA-C 175 Lancaster Boulevard P.O. Box 2028 Mechanicsburg, PA 17055 Phone 717 691-3755 Fax 717 691-3834 450 Powers Avenue Rear Entrance Harrisburg, PA 17109 Phone 717 561-4242 Fax 717 561-4903 www.prismdrs.com email: info @a prismdrs.corn V. _?bo CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Motion for Partial Summary Judgment upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 EAGER, SPINELLO, QUINN & STENGEL DATE: __9 15 a'p BY: G org . Eage squire Attorney for D endant Patton I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ? O LT I ". -TI _ a c_s r n rte. ...? PRAli CIPE FOR LiS VM CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. CAPTION OF CASE (entire caption must be stated in full) BILLIE JO FISHER.-SANERSRT and NIPON SANRRSR7 (Plaintiff) VS. (Defendant) No.03-5654 , Civil Term 1. State matter to be argued (Le.; plaintiff a motion for new trial, defendant's demurrer to comphtint, etc.): DefendanLl s Nbtion for Pea ial ?? ?a µ,:=1t,Aorranr_ 2. Identify counsel who will argue uses: (a) for plaintiff: David H. Rosent Harrisburg, PA 1718 ftl?A) (b) for defendant: Vincent J. _Chtirm - 11117 Fniituilla Pilra Lancaster, PA 176ftsma and Address) 3. I will notify all parties in writing within two days that this use has been listed for argument 4. Argument Court Date: October 25, 2006 Date: All-ey tm Defendant Peter Murphy Vincent J. Qum Print yours C? ?(7 G-3 -,Fri ? ;, N aQ v..- N C??to .p C- Om O co David H Rosenberg, Esquire I.D. No. 20569 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax: (717) 233-3029 E-mail: Rosenberg@HHRLaw.com Attorney for Plaintiffs BILLIE JO FISHER-SANERSRI, and NIPON SANERSRI, Plaintiffs V. PETER MURPHY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 2003-05654 CIVIL ACTION - LAW Defendant PLAINTIFFS' ANSWER TO MOTION FOR PARTIAL SUMMARY JUDGMENT AND NOW, comes the Plaintiffs, Billie Jo Fisher-Sanersri and Nipon Sanersri, her husband, by and through her Attorneys, HANDLER, HENNING & ROSENBERG, LLP, by David H Rosenberg, Esquire, and file their Answer in opposition to Defendant's Motion for Partial Summary Judgment, and in support of this Answer represent: 1. Admitted. 2. Admitted. It should be noted that pursuant to Pennsylvania's Motor Vehicle Financial Responsibility Law (MVFRL), an insured covered underan automobile policywith the limited tort option is entitled to non-economic damages if he or she sustains a serious injury. 75 Pa. C.S.A. §1705(d). Section 1702 of the MVFRL defines "serious injury" as "[a) personal injury resulting in death, serious impairment of body function or permanent serious disfigurement." 75 Pa. C.S.A. §1702. 3. Denied. The averments in Paragraph 3 of Defendant's Motion for Partial Summary Judgment contai n conclusions of law to which no response is required. 4. Admitted in part and Denied in part. The medical records and Ms. Fisher- Sanersri's deposition testimony speak for themselves. Ms. Fisher-Sanersd complains of S more than what is listed in Defendant's Motion. 5. Admitted in part and Denied in part. Dr. Baker did not perform an "independent" medical examination. To the contrary, Dr. Baker was hand-selected by Defendant's auto insurance carrier to perform a defense-oriented medical evaluation. Predictably, Dr. Baker could find no explanation for the persistence of Ms. Fisher- Sanersri's pain despite three MRI examinations that clearly document bulging of the discs at C5-6 and C6-7. All relevant medical records are attached hereto, made a part hereof and marked as "Exhibit A". 6. Denied. Defendant fails to include the fact that Dr. Lupinacci's report also noted Ms. Fisher-Sanersri continued to suffer from neck pain, and that Dr. Lupinacci recommended that Ms. Fisher-Sanersri continue treatment with Keystone Spine Center, and not return to work at that time. (See PI. Ex. A, Dr. Lupinacci's report to Dr. Abraham, dated May 15, 2002.) 7. Denied. The averments in Paragraph 7 of Defendant's Motion for Partial Summary Judgment contain conclusions of law to which no response is req uired. However, when considering the entire record, including the reports of Ms. Fisher-Sanersri's treating physicians, not merely the opinion of the Defendant's hand-selected insurance doctor, it is clear Ms. Fisher-Sanersri is not "fully and completely" recovered from her injuries, and said injuries have resulted in a serious impairment to Ms. Fisher-Sanersri's cervical spine and left arm. 8. Denied. The averments in Paragraph 8 of Defendant's Motion for Partial Summary Judgment contain conclusions of law to which no response is required. However, it should be noted that the Supreme Court has set forth a specific standard for summary judgment in limited tort cases. In Washington v. Baxter, the Court held that the determination of whether a plaintiff suffered a serious injury should not be made by a trial judge. Instead, the determination should be made by the jury in all but the clearest of 2 cases. Washington v. Baxter, 553 Pa. 434,446, 719 A.2d 733, 740 (1998). 9. Denied. The averments in Paragraph 9 of Defendant's Motion for Partial Summary Judgment con tain conclusions of law to which no response is required. However, as explained in Washington, the question of serious injury belongs to the jury in all but the clearest of cases. Id. It is not clear that Ms. Fisher-Sanersri did not suffer a serious injury in the January 2002 collision. The record presents conflicting medical records concerning the cause and extent of the plaintiffs injuries. Additionally, Ms. Fisher- Sanersri missed approximately four months of work following the accident, underwent months of treatment, including invasive epidural steroid injections, and has been forced to give up her career as a certified nursing assistant because of her injuries. Clearly, reasonable minds could differ as to whether Ms. Fisher-Sanersri suffered a serious injury, and the determination properly belongs to a jury. WHEREFORE, Plaintiff, Billie Jo Fisher-Sanersri, requests thatthis Honorable Court deny Defendant's Motion for Partial Summary Judgment because the Plaintiff has met her burden of establishing that questions of fact exist as to the seriousness of her injuries, and Plaintiff should be permitted to present her case to a jury. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP Date: I.D. No. 29669 1300 Li lestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for the Plaintiffs 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the Defendant, PETER MURPHY, by sending a copy of the same to his counsel of record, George H. Eager, Esq., Eager, Reinaker and Spinello, 1347 Fruitville Pike, Lancaster, PA 17601, by United States Mail, regular service, in Harrisburg, Pennsylvania on August 3 2006. HANDLER, HENNING & ROSENBERG, LLP ay -- J14 Dav Ro nberg, Esq. Attorney I. . 20569 1300 Linglestown Rd. Harrisburg, PA 17110 (717) 238-2000 361m Attorneys for Plaintiff DATE: G.- (fl ?T'1 n 4`7 ? ? N r1 ? r v s r - ? -?o ? r. 7=? y? < ? f' ? ? C- ? ? -G ,} David H Rosenberg, Esquire I.D. No. 20569 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Rosenberg@HHRLaw.com BILLIE JO FISHER-SANERSRI, : and NIPON SANERSRI, Plaintiffs V. PETER MURPHY, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 2003-05654 CIVIL ACTION - LAW AND NOW, comes the Plaintiff, Billie Jo Fisher-Sanersri, by and through her Attorneys, HANDLER, HENNING & ROSENBERG, LLP, by David H Rosenberg, Esquire, and files the within Praecipe to Supplement her Answer to Defendant's Motion for Partial Summary Judgment, and in support thereof, avers as follows: 1. On or about October 27, 2003, Plaintiff, Billie Jo Fisher-Sanesri, filed a civil complaint for personal injuries arising out of an automobile accident with Defendant, Peter Murphy, on January 18, 2002. 2. On or about May 18, 2006, Defendant, Peter Murphy, filed a Motion for Partial Summary Judgment alleging that the Plaintiff had not suffered a serious injury and seeking to preclude the Plaintiff from claiming non-economic damages because the Plaintiff was covered under an automobile insurance policy with the limited tort option. 3. On or about August 18, 2006, Plaintiff, Billie Jo Fisher-Sanersri, was served a copy of the Praecipe listing the case for oral argument on October 25, 2006. 4. On or about August 23, 2006, Plaintiff, Billie Jo Sanersri, filed her Answer and a supporting Brief in response to Defendant's Motion for Partial Summary Judgment, including relevant medical records attached as "Exhibit A." 5. Subsequent to the filing of the Plaintiffs Answer and Brief, Plaintiff's attorney, David H Rosenberg, Esq. received additional medical records documenting Plaintiff's on- going treatment for injuries she sustained in the aforementioned collision 6. Plaintiff submits the within medical records, attached hereto as "Exhibit A," to supplement the medical records attached as "Exhibit A" to Plaintiff's Answer and Brief filed on or about August 23, 2006. 7. A copy of the instant Supplement to Plaintiff's Answer to Defendant's Motion for Partial Summary Judgment and attached medical records were served on Defendant's attorney, Vincent J. Quinn, Esq., on or about October 13, 2006. WHEREFORE, Plaintiff, Billie Jo Fisher-Sanersri, requests that this Honorable Court deny Defendant's Motion for Partial Summary Judgment because the Plaintiff has met her burden of establishing that questions of fact exist as to the seriousness of her injuries, and Plaintiff should be permitted to present her case to a jury. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP Date: k7 By vur?u 1\uJCilutiry., Csqu I.D. N . 20569 130 Linglestown Road Ha isburg, PA 17110 (747) 238-2000 Attorney for the Plaintiff 2 BILLIE JO FISH ER-SANERSRI, and NIPON SANERSRI, Plaintiffs V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 2003-05654 PETER MURPHY, CIVIL ACTION - LAW Defendant CERTIFICATE OF SERVICE On the 13th day of October, 2006, 1 hereby certify that a true and correct copy of Supplement to Plaintiffs' Answer to Defendant's Motion for Partial Summary Judgment was served upon the following by depositing in U.S. Mail; Vincent J. Quinn, Esq. EAGER, SPINELLO, QUINN & STENGEL 1347 Fruitville Pike Lancaster, PA 17601 Respectfully submitted, --13-ob HANDLER, HENNING & ROSENBERG LLP DATE David H R enberg, Esquire I. D. #20 9 1300 L' glestown Road Harrisburg, PA 17110 717-238-2000 Attorney for Plaintiffs G9 H E A L T H S 0 U T H O U T P A T I E N T F A C E S H E E T Pat.ient#: ------------------- 000711457 Med Rec#:000206710-501-001 ------------- Regis Date: ------- 5/23/06 Time: 10:31 Locatn: OP CENTURY DRIVE Pat Type: 0 Med Serv:PM ' Subspc:NA FC:CA P A T I E N T Name: SANERSRI, BILLIE JO DOB: 9/14/1970 SANtKSKI UILLM JV k Address : 5 6 5 SAWMILL RD A e g 0 3 5 : ROLLE, MD DOB: 09114/70 (F D AGE: 36 ADMIT: 65123106 RM: 501 Address: Sex: F ACT: 711457 MRN:206710 City/St: MECHANICSBURG PA -17055 Marit al Status: S Phone: (717)790-0257 Race: WHITE G U A R A N T O R Name: SANERSRI, BILLIE JO Address: 565 SAWMILL RD Address: City/St: MECHANICSBURG PA 17055 Phone: (717)790-C257 Relationship: 01 PATIENT IS INSURED E M E R G E N C Y Name: FISHER ARLENE Relationship: Phone: (717)766-0337 Work Phone : Cell Phone: I N S U R A N C E S E C O N D A R Y T E R T I A R Y E M P L O Y E R DATES OF ONSET/INJURY Nave: 11 5/01/06 Addr: 29 5/23/06 Addr: City,St: Phone: Occupation: P R I M A R Y Ins. Name: AMERIHEALTH MERCY Address 1: PO BOX '7118 Address 2: City: LONDON St/Zip: KY 40742 Phone: (800)52:1-6007 Policy#: 40293661 Ccmplaint: Discipline:PT C O M M E N T S Admission Clerk Initials : WLD Discharge Date: LOS: D O C T O R I N F O R M A T I O N• . Referring: ROLLE JR MD, WILLIAM A Admitting: ROLLE JR MD, WILLIAM A Attending: ROLLE JR MD, WILLIAM A PCP/Family: ABRAHAM MD, VANITHA C O N T A C T S Discharge Location: SANERbKI BILLIE JO DOS: 09/141704.. Ck ROLLE, MD AGE: 35 ADMII`: 05/23/06 RM: 501 MMM7NSWM Rehab - Century DHve ACT: 711457 4RN:206710 Mo 920 Century Drive AAeChanfCSburg, PA 17055 Phone 991-3780 Fax 691-5564 -3alfe- Ju Oh,-r"'[ - ?? a F'"0" o was aWaft a whoWd* AkirWWm Only ? ° LE AddW"M a %"m a firer a tE Addwwtn a a P*M" a Ar*WFppt TM,nioetld, a,ynpr wuenbdr I %w vfw Ntmba Of a aM a DAP-M& o Uhuy hxr*w= ----mum 4: o VbW P.o.vW a Offer 0 shoo w agar 0 X10Wdar a Hurv4aw aa aoat ° Gu.d Cam, Ur" i SmeN ease O [)BS l7RW.d C S.? c D 13 Pain O No o O M?Ndoltlolyp?acMxe ° wWe. Locaftr .tdepesmp*t Pdn ODW e* M A D °Throbft o m4mm ? @My : No Of Propneft th - / kwjjj-g ° Asir, ° dmk¦eed r a ° lncOflft*%ft M+Modntl POWI ri a 8m i t11?ed mff? ° iron a a or 0 6qu?rrarn rf"ft 's D Rwrrr Thvepy Xf Folow up wMh pt"CW /rle a , --- O 4tl1ar d?l 611, HEALTH50UTH Rehab - Century Drive 920 Century Drive Mechanlcsburg, PA 17055 Phone 691-3260 Fax 891_5564 File m Patient Name Patient MRN D/C Date OUTPATIENT DISCHARGED MEDICAL RECORD cH_EcKu SANERSRI BILLIE JO DOB: 09114/70 F) DI2 ROLLE, MD Results of final chart review: AGE: 35 ADMW 05/23/06 RM: Sol C] The chart is complete. ACT: 711457 MRN:206710 ? The following items arc incomplete: Circle discipline(s): PT OT SP Item Present or 7Th t Dat s missin com lete ?) g P e/ Co- (in box below note (please check box missing date in question) bciow if present) elow note 1. Addressograph area complete on all documentation ame, ?vM#, DOB) 2. Patient Information Record / 3. Initial MD Orders v 4. Consent for Treatment 5. Outpatient Clinical Assessment b. .4ddcndunl(s): - V 7. Initial Plan of Care / 8. Recert/Updated POC (minimum 30 days) 9. Daily Notes / 10. Weekly Notes / 11. Flow Sheets 12. Discharge Stnnmary Reviewer's Signature: " 1 Date: Clinic Manager's Signature (if incomplete items): _34.L Date: The above items are unable to be completed because fgrgU o` vee)__ _ Has moved out of the area Is no longer employed with HBALTHSOLTTH Is other .. . es. _OR. o Not Cetxy or Rclee With., _ EMe brJE,"rr es7voaderrre:.?er?ori= C'V t ?r. . Rehabilitation of Mechaniptsurg Cw * Dr mmem a ampft UFE W mh*Am,, H-*W mrmw A#AbV 04mbmm OUTPATIENT PHYSICAL THERAPY CHARGE SHEET r/.?DAly NOTES GATE OF 5 Fix owu 3; 2 tM /4pigtsd DOS tbtt l3?LLIt JU AGE: 35 ADMIT - E, MD A CT: 711457 MRN,2pg710 M ?1 Islamimmims lan 0 f ? vv f of Mechanicsburg lent d M.w cure ta.K r.,k Ct.nb M LJFE V*n19+bcrg OUTPATIENT PHYS{CAL THERAPY CHARGE SHEET / DAILY NOTES DATE OF.SEFWCE C!W; wszw?- vuw a &ttorterae SANERSRI BILLIE JO DOB: 08/14f70 Fy Dh: ROLLE, MD AGE: 35 ADMIT; 05/23/08 RM: 501 ACT: 711457 MRN:206710 ooll .oms orb ?-- ?,?atlon Of Machanicaburg Curt Or .?iur cud 6ePd LWE Wrmyap?t, HAY aver AA-W.+e.uwrnu OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DAILY NOOTES DATE OF S RJ5 aao(.acx - d S ANERSRI BILLIE Jo DOB: 09114/70 ((F Dh: ROLLE, MD AGE: 35 ADMIT: 623/06 RM: 501 ACT: 711457 MRN206710+ --v IUD eMech anlcsburg kr.a LIFE ??Ks HW*W OryW AA4Q0*r'A4ww balm OUTPATIENT PHYSICAL THERAPY CHARGE SHEET! DAILY NOTES, ?? DATE OF SEWCE - R/5 RXswino j-z=vww d _ SANERSRI BILLIE JO DOB: 09/14170 ((F)) Dh ROLLE, MD AGE: 35 ADMIT: b5/23106 RM: 501 ACT: 711457 MRN:208710 immilmlill \v PWALINSOU7H. dilation of Mechanicsburg (Tmwcww fteFft LIFE Wrnr"wxk cv.md AMbomy'a4moft ? OUTPATIENT PHYSICAL THERAPY CHARGE SHEET/ DAILY NOTES DATE of s?tyhcE ws ws_ of SANERSRI BILLIE JO DOS: OWl4170 D?2: ROLLE, MID AGE: 35 ADM17: b5/2 M RM: 501 ACT_ 711457 MRN:206710 VV Rehabilitation of Mechanicsburg -- -• GntDr mmcwk 4etot LIFE Wrm*stxry Hwmw COY Mod AAMkWo 'wdWW bond OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DAILY NOTES C gp?oF SERWA Ric ? SANERS[( )RI BILLIE JO ;Zj :1 AGE: 35 1ADM11:FO5/2 Dk' ROL1.E, MD ACT: 711457 MRN-20671710 M_ 501 Mifflin Rehablllitabon of (Mechanicsburg • cwtor W.0ma amp," LIFE Wrm"&.% HrshY COV Mod + W.:?+are..d OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DAIdLL/YsNO,?..T,?//ES DATE OF ?f?" CX N!S_ R15 RX aupr? YwW1 ar IalMr?i , SANERSRI D0 gILLIE JO 6: 09H4/70 (F) Dh: ROLLE. MD AGE: 35 ADMI 3/08 RM: 501 ACT: 711457 MRN'2D0710 IIIfflill `v AWAURSOUM Rehabilitation of Mechanicsburg - cwdor ftwQmw ampm LFE Wrtnkiftq, OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DAILY NOTES DATE OF SOM ?/z3I C60 CX ws ws RX avian N. mddMMrs.t?d SANERSRI BILLIE JO AGE: 335 1AD I1?Fb5J23/06 RM: 5011 ACT: 711457 MRN:2D6710 UNION Reha6Ritation of Mechanicsburg Cwt Dr mmomb &mtp" LIFE WrmhvbLku Hwwwy allow AAWA& vm4w"4.00 OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / ONLY NOTES DATE OF S G L?1 O(al ax WS RIS RXe4*?_??` ylrfa_?a SANERSRI BILLIE JQ COB: 09N4/70 ((F) p?2- ROLLE. MD AGE: 35 ADMfl?. 05/23/Og RM: 501 ACT: 711457 MRN:206710 Im- CV MAL. Rehabilitation of Mechanicsburg Cat Dr mm Dana &wpm* LFE Wrmkabx6 Naralry CWjWd ys wa4re sera OUTPATIENT PHYSICAL THERAPY CHARGE SKEET //DAILY NOTES DATE 5_J _Lt 4 .* RX ' ?r -L;LT.. - D B:09JER &BouEIE JO AGE: 35 ADMIT., 23/06 RM: 501 ACT: 711457 MRN:206710 I M111111111 Ho 'eLN `v • Rehabilitation of Mechanicsburg cwt or wm omr earl LIFE wrm6vbury Ho-r Gfrbbd AAMkwMV'Amm" blow OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / CAlLY NOTES DATE OF SEW J ? r CX WS A!S_ Rx W*ft 7 "_"' 4 °r SAI+IERSRI BILLIE JO DOM 09/l4f70 (F) W ROLLE, MD AGE: 35 ADMIT: 05/231106 RM: 501 ACT: 711457 MRN:206710 lm?l'll tL% Rehabilftbon of Mechanicsburg C.ntOr Ns c A amp" U FE Wrmhslxn Hmr*my pry mw AAMi%W'AW Wbowl OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DA/IL?Y NOTES RATE 3_JR ? I J / C qC N!5` RJS RX apim i? oB: ??R Rom LLE IE JO AGE: 35 ADMI : RM: 501 ACT: 711457 MRN:206710 r(m omrm Total Vlafs tram SOC Total MVGW.>9/. St-. - ) HEALTH30UTH Rehab - Century Drive 920 Century Drive Medutaksburg, PA 17055 Phone 6913260 Fax 891-5564 UPUM PLAN OF CARE PHYSICAL THERAPY SANERSRI BILLIE JO DOB: 09/14!70..F) ph• ROLLS MD AGE: 35 ADMIT: 05/23N6 RM: 501 ACT.- 711457 MRN:206710 Iw ??IN Patient Name: c 1/1 t J) r c, i Oneet We Be* Date: ? Primary Ois8rlosis: PC r vii plf 1 ?. Prior ? ? CtXrent eDleocJsl; brom I !- ---- 1? Treatment Diaarloswesl: MA ----r--- Phy*ien: , - Pahab pctentlal: o Excelerlt 0 Good p.F* C, w perkod: Frarn to -- 0 CWVWW MecAc? Update Farm (Progress achieved from previously stated goads) LL 14 79 P",7 r/ Shwt ftrm 904104 acs wrmsn W addnan PG&w+t ProbOwiss and sl+ordld d,4sta to long tw17n gams. /ry, p re ??P pS -?-? weeks fie U 3. - 4. 5. t weals fr" 1. ecxesee pain to 1 to Glow for hL-7 b-7 or 2. ? how" bed/mat motlity to S 3. ? horsase tranadar stadas to 14. to demoratrate d to kriprme harctlorral rnoblfty/ADL§ G/ in and body meCheniCe Wkh ?. 4. ? ir=ease k i Ip Wainiance to „ AOLt1 and 5. E3 lnorsaw 1unCtiond ?• 15. E3 knprove belanc&toordination for AxtClianal skis such as wetiarrg an uneven aalec?alcixbs/etaie to 6. ? hcaaaee wt/o mobility to 18. ? to work at mod bd/ngmsl dudes. wMh 17, w-Pawbrrn norrW houaalm d ADUs o n 'c 7. ? hcraeee aaaimume. 18. D larpowe Are motor *ft for lunctiond ADLh such as poception lundional ADLy suit as to improve K 8. C3 ImpWe go medterdw by 78' ? aeph?r with care of patlarr in two areas _ 1IWaarat 3 f' a tdo - seas dtek d ish , 22x1. (3 Ob w A with Hone azerdse program. o D / 10. ? haseae fittnOtlOnel dandng weran cee to islCilonial mo Mill 0ll 22. O Onion / 11. ? impaom aidn I ftgrity 2& ? O 2a. a Oher 12. o krpvwbdm= todKmwn d*afak aedrrmd by jr? Phya/dan almondre Date Therapist slprtatuu,a (esWMhwV Poo Data My tarapist bas reviewed my Plan of Cars with me. Pa? r and/or Body btacfuanics ditorne F d ?arlarl</Fanay Tnihdrg raan 4 _ Rogran C3 Fire motonba+aarity Aeeduxtton ? Fy ?i? tt,,oo??? ^ tMVPF?M a G e> `' ?? pr?y? ? Edema M4nspenrxtt by Other a ? ?gerar4arCrr?s? S Participation in (3 ADL liatr*g ? Fndursrol Ac1ht1{ea a O Other ? her ?tr.eo,,.nc pion. 71a?ataartt Fhgwrrcy:_ TlrresnNeeic Dun rtlon: weeks !have rnvier+esd iNs Plan of Cane and re-certpy a c?orrdoul?g need for 8an+?ces. ftnakwe HEAL THSOUTH Rehab - Century Drive 920 Century Drive Mechanicsburg, PA 17055 Phone 691-3260 Fax 691-5564 VV MMUNDOUNf. Rehabilitation of Mechanicsburg CoM Dr Mw CuM Est PWk Cirmb M LIFE Wm4* r4 Mashy Lmmrw cry use AAM"o wait" boW OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DAILY NOTES DATE OF ?`?/ c? cx Ws- 0, VI?NE?d Z? __ Q' NERSRI BILLIE JO DOB: 69/14/70 F Dt: ROLLE, MD AGE: 35 ADMIT: 3/06 RM: 501 ACT: 711457 MRN:206710 V Rehabilitation of Mechanicsburg CAN Dr "m CW6 Eat M Mmnb HR LIFE WmiyMxn HOnhsy Lw o my mw ANI srw+omo bwo OUTPAMENT PHYSICAL THERAPY CHARGE SHEET! DAILY NOTES e DATE OF SE CE ! [j / CX WS_ R!S_ Rx *q**s vww d?Au•Iatrsd SAN?ERSRI, BILE{E JO AGE: 35 ,01"1 ?5; i1051ZN1. 501 10 ACT:-J11457 M 7 aims dar9h I?rgr, AcWlbq trMMd M P?M?a 9OMharetlonsl •0001 97001 ' aar Book; 30092 97002 71Nr. Pah FunCNWW Abg*. R01a 0 0 90119 97001 JMWW TOW. R IMAMM -1141X. 50120 0 97002 _ 1/4 hr. !0009 9=1 50007 90911 _ p?yya 50009 971.0 0!000$ 50074 97397 -N cm sa ft* h0sd: -- 7RPJITED -I $0079 UM adems s>n cm o PW PAW Shag 1 ? SOON 97.02 ODWMQMGML Non sakaw . tau I 5003• 002H B a ?rrp '?'t° X"?l v?9?aa4 aa •m (SbuaMtl? t5.arc Ilr9urtl 50019 OozQ 0-- arm Ainanrse) 40W ward FTC $0009 Mo EMe arm Non-W&AW 5000 645!0 l ng App al Tpla e e $0010 97o10 tlaLrm Psob 30077 97012 radmr Msd l l M3 S M3 97016 , vrl ot vemm" 1', Dsyk? Mwi PAW to er.ar hln Meal a1Mr trsst smi "oil ? ? 50006 •7022 psM>rrOwiYMSb ? ? ? ? O ? 50012 97022 SOOt4 97022 0 1 2 3 4 3 6 7 • 0 t0 P si MM: Tl ema y 30041! W410 . Prop WAW., Oft) IM M 50004 97112 114 tv 60017 97113 19 hr 50021 97119 (ka T 114 hr ISOM 97124 114 hr 50022 97140 1N hr 50025 $7504 1/4 hr 5002• 97320 T 104 hr 60027 97530 Thar. tarst 1/4 M datlNlCs 50016 07535 ! *d o Home a RaMswad 50015 975 37 104 50029 97542 OortslMc iN M iN hr 97546 Work Hwdw*W hits! 2 hours 50033 97$46 Wwk H wdwft Addl ttour M 90019 97703 _ Chh QMPrao. 114 hr aFIORT 50031 97750 Part. TOM or MwwrairM JFCE) 50091 911756 T Sam Sam 97032 97003 arm Mbrwound 104 hr enwwrK TrsOlnwtl RoyMs To: 04 1 M 50019 97034 aa•rtN hr 30039 97033 /N hr 50037 97098 104 h ToW W.,. TOW Trawa d. TMwd Tow Uaft T TOW 114wrtss TOW 7VOSYOmd - UWAv sd TOW Uoft HPMpm NOW 1 unk s 9 Mkofte to s 23 mbrAi a 3 uMM > 3• wAmbs tO c33 mhrrMs 171P PT M..... -- TOW Wft 2 uOrM ap wiarMa b <>? latll{IIM 4 VAMd s d rNrrw r. ? ?...._ FWW OPPT05 ,v MEWPON)UTH. Rehabllitation of Mechanicsburg Cant Or MW Cult EW rwk Chafrlb M IAFE Wrrr "WM H.rstW t..bmon Ctry Mad AWSWO.--hW bmW OUTPATIENT PHYSICAL THERAPY CHARGE SHEET 1 DAILY NO/T--ES DATE OF SERV)CE / V CX ws R/S_ RXanpka_l? vWtAdAu9+a?od SANERSRI BILLIE JO DOB: 09/14/704.F D?2: ROLLE, MD AGE: 35 ADMI0 23/06 RM: 501 ACT: 711457 MRN:2N710 IMMI + I 1 50001 67ao1 Thar. 6i a6M MerMb, Ae9Mly, l5rarcra raLw b problem MaMh+neaor?al , 80002 67002 pllln Fondue! AbOm 60119 !7001 TIM o"ApAbn - 1N hr. mom 0 O W120 67002 • Ui hr. 30006 90001 WW7 30006 90011 97150 p« or efua WWWO. Iha b9lad: 50076 97597 <0 an . E>c Per Flow atlaai 30079 97396 a00 orn 50004 07602 Nm 8.? 50036 (10261 19- 9llw pnow dw owor4t: Wand /oo9otraa b Q 50009 60262 L3oC.a6m(lblaYa116ad)drrweud 50000 GI02J17 ow-aft Np1-Wamd 50040 44S7o of-MM t7 50010 50077 $0013 97010 97012 97016 I HOWaid Ftiab Tmdkim kb&w" paykj t •601 JtnM to t"t a Fab! lash tYllr Yam P.w n w u !! , J 50012 50014 490= 50024 30017 97022 97022 01410 97112 97113 )/o P111C r.IdK.,.9an4 1A hr 114 V. Lmuoc by h 0 1 2 3 4 5 6 7 8 9 10 6RCO? Nom Yl1E my 1 7 Com 50021 9711! GO TMWM 1/4 h m 60003 97124 14 hr 50022 50025 07140 97504 t/4 hr akft 114 h 50026 50027 60016 50015 07520 97630 97536 97537 T 1A4 IV TMr. knot tN hr ADl ao6iliarrla M2Vt 114 hr AOL Coff#Wft ISM 114 hr b I 0 tiMnalk od O Honr EI Rarl.wod 0 Ex. advomd 50029 97542 yylyt 1W4 hr 50032 975th Work Hmftft m" 2 bows 50033 9760 WorkWardwft Addl How ART TNY9 60016 97703 Ohk Or6YP=M. Man V4 hr WOOL 97750 Too or IFCE) 30061 97766 T 50034 97032 iF4 FLAx: c-0114 Ctorom Tram** Fls go.WTQ: 50035 97033 him-hma 1N hr W019 97031 ORM 114 hr 50035 97036 Ulboaoaid 1K hr 30037 97006 114 hr T?tERAPIaT 9tON: Total ktbrutaa Orl Tloalrrtarrl - Thwd Tort Lbdr am.. Ta4a1 kibrAss on TRaut"m • Ut161aad Trial Uric b < 23 mb a 3 aM tJnllr n m mrft > 34 b 43 a > 1Z3 mbrwr to < J6 arYarp. 4 tame a q rrarrrl? 1o qt ralnuw Tz Forrrr OPPTOS fL% Rshadlitation of MwAanicsburg C" Dr "MOA10artPak ChaftFW LIFE Wttldyabur0 HWO" heron car Mod AAHd1Mftr44Ww' OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DAILY NOTES DATE OF SERRVIFE CX WS Rr_ Rx.t?r.._, / -Mat t?ttatarls a SANERSRI BILLIE JO DOB: 09/14/70 "F) Dk: ROLLE, MD AGE: 35 ADMIT: 05/23/06 RM: 501 ACT: 711457 MRN:206710 EME 111110 11111 50001 97001 o"m ? 996A ?br AeMAbi2atCMN mww to 1t ow ft*w erotwl Thar. lttllttA6n 40907 !7002 Ills. aar Fta MIW AMR= Q. 50119 97001 K atp?M t40M O 0 90170 !7007 -1 hr, T119r. - U4lM. 99999 90901 14997 90911 • pw? 00000 871so Orman 9007E 973W e?0 _ Yu bWtd: AREA TM 30079 97000 y? . Ex Por Flow Shea 90004 97002 "m Odecom t ? P, r A nm =m cl w lug r 4t + a b ?l - 30039 00202 datdo a" 9iteM1lerlreWMa9esteautd 00009 0096 ?• 99m Htat•Whatd 300W 6ax aTEtM !0010 97010 HaldCald $00'77 97012 3 0013 97016 bladtarial r 6 DaYYoa Fain bard to baa! !R?bt klenl filar 1eraC wall Fhtylbt - 3ms ? u O #? 'y . , 30012 8700'2 10014 Or= vw*imd 0 7 7 3 4 5 • 7 6 9 10 Rp0011Eq MOT!: WARKLY 00070 97110 ft6a aredur., 9aa 1A1 hr SOW !7112 ?4 d im t 30017 97113 v 114 hr 00021 87114 114 hr 3002) 97124 /M hr r 014 97140 1µ tr 10026 97104 Orat k V41er am 97020 T 1M hr 900¢7 97530 Thar. 4utR 1N hr 10 sms 0 App 1 --a-mmm 6L r 50015 07 AOL MWIL IM h, kw~ 30029 97542 114 hr Y 50032 97545 Wak bad 2 hater 50033 97546 Wak Wft Add! Hour 9F10 60015 97703 Chk im hr RT ? QOM 10001 97750 irrT. TM ar YMYatteterd 50061 97756 T -r' A r "IF <• 50034 97032 Nwmvoved 19 hr 50034 97033 11/4 hr l KAM: Catmant T Flut Or itattlas To, 10019 9'7034 1µA - QM*W Oft 970 35 tµ hr ubmw 00037 87036 MWIMOMM& 114 hr Tar mud" T 141i4Ar•19T 9qN: r417YattYwnM • Tbbad Tt1W lbeld mw Told katttar eld Tfodw M - lltelbmd Tar Lbft . 1 emit a • adttaae to < 23 ettbatba 3 wMm a 36 tabMlda b 493 mbtttl TOW ltttlb 7P Pr rh..... r..... o??? ......• 2 s ert6 > 2i "Pam 10 c 35 ttlbatha a natl. a as ..,...r ?.. ?_? _ 4 `v filliati2ilooDim ---.. eha litation of Mechat?csburq ti 01 f r.w cma K" fteA Choft He LIFE wmry,UV 1? HwW W L4~ c+, wa Mu3r,e o W.&ft" bftW OUTPATIENT PHYSICAL THERAPY CHARGE SHEET DAILY NOTES DATE of CE ?' 1 Z. /-L c?c ?ZL RM_ RX00" VWW d &O-tod SANERSRI BILLIE JO DOS: 09/14/70 F 6k: ROLLE, MD AGE: 35 ADMI : 05/23MG RM: 501 ACT: 711457 MRN:M710 1111111111111111 p-Momm 00002 97001 1002 ?y?n Tier. of e? * &bar#, jub, IV , al.ld.e raYbd b ?? 0rt9wletlerdl l1M Pon 0 tnaaaeaFWs;-WwA ism O kca inv?w ROM 0 0 00110 gm 114 M. 00170 am K, $0000 90001 90007 90011 . py fwy 5000e 07150 pmaa Vle ow 1116 bled: • 50076 U W °? an AREA TRE/1TE D: O The r. EL Per Flow Shed 50079 oT596 >20 an 90004 97002 Non a.ieow 500!0 ame1 gee 0wo is WQUW e reapame b too pro?ees 90090 00262 gas. S6m tUlndlwW@o Orwr wound 50000 00263 Etec Wm Npr Wcund 90040 41550 a1TM 50010 07010 HOMO Polo 50077 50013 97012 f701e Tra lsom tlsdeafad Valammumoft ONW= Pda bow to balk Pam bvd dyr apt 50011 97D1e Pe laA)R 5ooos 97o2z 50012 SM14 07012 17022 ]FkAbOwepy 0 1 2 3 4 s 0 7 e 9 10 rOKOM ii NOTE: MIEMY MAW 1107WIff, --- 50026 17110 , pft WON," 1/4 hr 50024 971t2 bmamooft 114 M 50017 97113 OMMIAhr Mai 97116 Oel T iM M 50023 97124 tM hr 50022 97110 7M M 00025 97904 tM hr mm 50027 30015 30013 97320 97530 $7535 97337 Pmsftk T tM hr Thar. AdWfrf6row%rcL 114 M AOL Sd9Henw 114 hr AIX Cm"mf Mr Mawt 1/4 hr b? O 0 Home C3c. Reviewed 0 Es Pmgrwn advwnmd per lowshW 50029 97342 114 hr 50032 97345 1Malk me - 2 bows 50073 97346 Wwk Addt Hour SHORT TERM GOALS 30016 97703 Chk 114 hr 30071 97730 PeA. T4W or 69ewr9mnl JFM 50061 97755 T 6003{ $7032 Ncmw9und 114 M PL /Itk f:eedMor CurweR TnaY?wnt PMa Ch AeYtee To: 970M 1M M 50019 $7074 CumbAW 114 hr 30036 30007 »m 7 UMMOO.WW 114 hr 9 036 IM hr T1y9fM?7 1 °? 3WMrtee T 1 old 91YKAee e4a1 TreatmmA • TYaed Teri Nrd1 e old Twe4eent. uwmmd TNd U111Y TNwVpW ? ' 7TILE lrnlt> e b c 23 maaA a 7 d eW Unlr - - 1 777 w Yr b >• b cfi aW191ee 2laetl > b m191 we to c n mk"" 4 Ialld 2,93 wAnubm to m FanM OPP703 .- Rehabilitation of Mechanicsburg • card Dr mw Cw6 and Pwk Cherub M WE Wmty9Durg 1° OWIDY U&MM Ctry Mad AAM001 elcear baW OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DAILY NOTES OATS OF SERVICE J?ej_L_/ CX M RIS? PX expires & I_- ? M? pf??MNgA7od SANERSRI BILLIE JO DOB: 09/14/70 f D?2: ROLLE, MD AGE: 35 ADMI74: d5J23106 RM: 501 ACT: 711457 MRN:206710 IW11191111I1 00001 97001 TMr. Metro Mold 1r, AWft, 9 re dm WAIed to pr9bitt9 6t99?rre6orrt &W 00002 97002 I IN 7A4r F%M Flr+Gion9FAAioes -Q ?ioe9w soil! 97001 Tom, Eft -1? k, 8091 0 0 00120 97002 I In 7tw. • 114 or. 00006 WWI e9pked,yi WWT 90911 wAk~ -pRWy 50006 00046 971W 970!7 ormo -a ae QWdM bow: AREA TWATFA, -0 T1w. Etc Per Flaw Weer 50079 97596 ',20 an 50004 97602 owwww"K Neu 0 0003e 00261 a6m (tbttt69rr19q Chtaik Warty b 1e , 30099 Q= EYc Nm 0*1011rMef) cow ttarq 30009 am bee. Wm NamWCUb 50040 445N C/Te348 50070 97010 Ferli9 50077 50013 97012 VOIS raC901L plce Pain SwW b tnrb 101117 P91n WNW alter treat ? " 50011 m 97011 ? per9l? ? 0 v 1W sooos 97022 ? \J _ 50012 50014 30026 50024 00017 07003 97022 97110 971121 47113 - ft"Wholopy .ROC MOM& . 999. 1N hr I!Nmvqw_ww %PW 1K hr 1M hr 0 1 2 3 4 5 6 7 6 1 10 1410011 1107 E: WELK L.Y 50021 97116 114 hr 300¢9 97124 Aloesge 114 hr 00022 97140 114 hr 00025 5002e 50027 97504 97570 97510 1M hr Pmook T 1K hr Thar, 9neL 114 IV b Ri#wtl swig 97536 ADl 114 hr wee O Now Ex ftoram RwWaW 0 Ex ftym adwermed Sow sheet 50015 97537 ADl 114 hr 30029 17642 Wh4dch* Mord 1N hr 50032 97545 Wwk 2 "han 30033 97546 Wart ftrdw" "m Hour lHowr TERM 5001e 97703 Chk ftft!h U" 1N hr 50031 97750 Pert. TeM or WCE) 50061 97755 T 50034 50035 50019 97032 97093 97034 69ni 1N hr lkn%aVwmw 19 ti. Conk" Both 114 hr PLAN: C4dkw Carry* T 104" To: 50036 97035 Ukesox 9114 hr _ O( / 50037 97035 114 M T TFERAPWr sW 2lburtte Tout TtetNnsot • TYUW Toy UNIt THdiAM 16gN: Tay lebnlee TOW Tteerwtrtt • Un1Ywe0 Toy 4btNe 1 ww. > 9 mwn b c s3 urmrlse 7 un%x > 39 ntlmrtm b c9 1 nrnuh Tay unme . s 2 unto > 23 nMrertte In c 35 erMutrs 4 umtt a 53 rrrrertss to cY wAn t_ e, Rehabilitation of MechanicswM cans Or New amm Ere rank Chrnb M LIFE WrWlyOn Hershey Lasom Wy MW AAM t awlwp buo OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DAILY NOTES GATE OF SERVll4E CX,_ WS_ RJS_ RX aaplns VYk/_dAURget:ed SANER I BOLLLE lE JO AGE: 35 ADMI : 5/ aM RM: 501 ACT:711457 MRN:M710 plumm I IN Thar. n alaaOA 4. #,of, Airtlla nMsisd b pr9Mlra AwArlotlonsl yy gmk: !7002 97001 -1# hr, Pon D-intlOM Fundlo W Abi10w - 0-WA s Skeno ; !7002 90001 IMIM, 90911 97130 0akemp9ek-Prhm ar 11ga m ands(e) MANd: &Pedk 5OW078 cm TRFATt ?. b-"W, Ex Per Fbw Shoal 500 : n an 600 500 Bu >1rAm a9larwwW 50009 , , 6Mr, aft NwAft rd 60010 64150 jAm of T$M 30010 SOW SOOTS 97010 97012 016 PadM IAsdl9nieal Vesepumuft pwlp Pain b 119ae Pala Wool spar owe 60011 97016 PW@fkl O O _ 30006 W022 OsbMArarIIMYnA O T? v ?.. --? ?, W012 RM 0 1 2 3 4 3 a 7 6 9 f0 50014 90020 97022 8110 MISOPM *weft pox, Arc 114 hr 7' Nolen. MEENCLY 30024 97112 1M hr 50017 97113 1M M 60027 97116 1M M -,. _- IM, 47:=77771 -MM 97124 1M hr OA i 60022 90025 - 97140 97504 - 1M M QMM 1M hr 4 E e , c-7 ? 60026 50027 97520 97990 . - PM0fk'rmkft iM hr hlow.AcIft . 114 M b t buMarN Ect ftgmm R9M9wad SOME 975 1M M p"fummarm per low shed 50015 60028 97537 97642 114 M mom 1M hr 60032 67343 2 hewn 50033 97546 Work Mvdwft Add1 Hoer SHORE 7MM Q0ALW 50016 50031 97703 97760 ( . Use 114 M 1W. Tact or limmmn ecl IM v 50061 97755 T 50034 97D]2 1M hr Conant Tmbm)k Men or RwAm To: 87033 100, 114 hr 50019 97094 ik hr 50036 97006 1M hr 50037 97006 plgmkww 1M hr T1161AP19T 81011 TZWaeMa TOWTra9rrrtct- Thood TOMUsma mmommenw. ToW wnkrtr ass! T-lb-M - IMMhaad T84 WIM / aM> 6 aMrretaa to < 97 u1lnAaa i erdia a >t Y ahtl thells as wln b <9i reeMae6aa 2..* > 23 9kk.Mw to < w aMiaMn 4 wft 3,63 aM9eMw in 46 011101110 ;?-&,'kd Fwma OPt•TOS e R ftbiWation of Mechanicsburg Cent Or Now Gne am raA Clamb tU I LIFE Wm*paur0 Hershey 1aann coy m d ANShr..mAM b W OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DAILY NOTES GATE OF SMM 12(h Cl? cx WS R/S_ yyq/-?°r RX mptr" Lif 74 DDOB:09//11 [7 OLLLE, DJO AGE: 35 ADMI :05/23106 RM: 501 ACT: 711457 MRN:206710 ilueNilill aoool e7oot Affimm? +rb. . eaneb. r6MM to proU6rd ss6VY6rcuorr.b wMaw TIM. tnlMaahn 6000¢ 7 sdi 002 6 F..WW AMM. O kam" amp !Otis g001 -Ewkmfbn -U6 M. ROM 0 0 mdbmm W17D 67002 Pkvbd TIM. PAWA&Idkkn h . 14 . • r s0006 owl t 00611 p s fte 60076 90076 W3s7 s74Y1 Room "Dam <? an Wrobe npno? th 7? -0-7w 6r. Pn Flow g" 3-M so an 40001 9eo2 Plon je 10- 4i=" /A AlLfe-- LAM 40036 00261 see. RA+6MSri06tpC16oriCN1411ed reep0116eb prosre66 swu o42ex oerrwasld 90006 Gm g? ern ??b !0010 WM HOWVCey ply 5DW7 U012 T 50013 9010 DOdN l? berOb r but Pabr level aAsr 1rMC lip 30012 s70?1 0=4 W0Q2 0 1 2 3 4 3 6 7 a 0 10 MIlO06llq MM: vvmmY 30020 67170 l1w. Fns owrqw Oodrr 6OM 1N M _IVQZ4 1 1 67112 114 hr 60017 m13 1 W1le T 1N hr 60023 W124 MW? 1N hr MOM tN140 1N hr 30025 W304 7N hr 30026 Ww0 PnalaM60 1K M 30027 !7630 ThK, inet 1l4 M b 0 90016 W535 AOL 1N hr b6OYrrsrXVr6U 0 IionM 6t ft2M Reviewed 90013 W537 0 EL Pmww -AWN ee iar tK hr Soo26 9642 V16r"I?Nelr 1K hr 3003 2 DM6 work 2 hays 30033 9646 VMak W-ft Addlliar 6' 3009a 9703 Chk vam. "UTEM 50W1 W760 MAW PeA.Timorkiwwnnwa CE _50001 W756 Aedsiv6 T 60006 W032 W033 1K M M _ T or ftvi"To: 30010 W034 114 hr ?? s70aa U b6eored 19 hr 30067 670.76 7N hr row ma" s Tom Tnmomw* • Tb ra d Ta !bib T T HMWW s10k HpMP sT a w, raw R% Wbs TOW Tr6rrbdad • Ungand Tar! Uft 1 uak> 6 oalNAee to c 23 rrdrbAw 3 -ft > as plkrulw b <p nrbwbe rIP PT C)rti T?r o...-_. eV lords ?e..? 2 colt > 29 wAnufts to < n dWtldae • rwdh ! a5 wdr.r_ r w. ?-?_ eL,l k-v . Rehabilitation of Mechanicsburg Cwt Dr r+memb EmPwk LIFE W m Vdxsti, ?wvhW cwymw AAmh&mahmq bmw OUTPATIENT PHYSICAL THERAPY CHARGE SHEET / DAILY NOTES DATE OF SIMM S r Z c 4' rx ws RM SANtKSKl tilLUtz JU DOg: DEV14R0 (F) DR: ROLLE, MD AGE: 35 ADMIT: b5/23106 RM: 501 ACT: 711457 ....?...........wv a A 0 HEALTHSOUTH Rehab - Century 64~ 920 Century Drive AMedwksburg, PA 17055 Phone 8913260 Fax 691.5564 INITIAL " OF CARE PHYSICAL THERAPY Pad art Name: _ R i L IA Rry+a dan: _Dy RL ll Prt" wyDleg' o*:-e.- LaQ' O iteefrnerrt o?e?nosla(esk _.??? l,•-? Fbheb notmml n Bacelent Pfrhov&ftbm (for'wwteplsode): Rm r86ad O Pao +`aritgc8tlon Pe?ioat From _?! CU to i 04, fiyl?iih h JL PISOMM for p j RA %B tJE iICM ? !s 13 R" LE FK)M _ tleste dyatuxdoo *)g 4 1>Mb* w*-ja Abnmw g* C3,k*t haWAty of a to of Con D 4eakdawn won ? regtretory apad y D 1 beienca - 0 Marne 0 Akq* ? UE crl'p fterlp 11 lrcproper body meclwlcs 0 1 Ut mDbrly O ?° O Other 13 Other _ 0#gObur* st Wvth Q Abxrn-d tone ° 1 kh 0 Other tg-t tlildlarc adl AtJtlwclic *b CLI 140 htrdc t90M 0 1 end mere p llbrtamiel mouetnent ? 1 sertestbtVbr i El Joh tmocnwAw of np oreptla, 13 Joint kVwrcblly d t $ Md MWM 00A111-1 _. _ - Weeks lOwt ISM t"s MV written to address potlent proNww surd should relate to AMV town goals. 1. Padw vri ; 7 ell" 1Jwt `2 PalFant vdli: T - c } 3-fatten _ ` ___, lt??a 7_54 r h c 1 1 t i t yt1. t' !Conn Y •-r•+ ?('?y??Q ? n/ t . +E'1 &aeasa Pain to _ ?" - to aJGna for I?CZ'n2.. ! l 2. O kiaeese b ers/mat rrtouiity to _ ..-•_-- 3. 0 hcreass transkx status to _ - - a. Q krzaese functional waking rolerame to h n* KAes with - - _Idistarc e 5• O !tee functional - fah tstaau a. waking on uneven eurfacea!!vtus/stak? to 8. D lnaeesa wlc MdAir b (d lwlo with 7. O lbo- see asswO & VBDr nl AM such as PwqAbn to hprave 8. 13 ktlqx" gig rneghadcs by dWoo rich Of fat, ? ?_ 1o b ? 1lnoftonei rttetryr/A01.9, '10. 13 lrwom tttrrollontW 4 mimorroe to r yrlw, 11. O irpa+e akin k*g* X12 0 knprow bskm@ b de 3"M deft d Ice, ea awderrcred by Pamem Canaan. \'L'et VC ?? Re-et)uoetbt Smoot awmazorPUlloodlen In d vebp yogi of be hr t r these awvtloee SANtKKI blLUt: JV DOB: 09114/70 (t= OR: ROLLE, MD AGE: 35 ADMIT: 5/23/06 RM: 501 ACT: 711457 MRN:206710 l????N11?N??WI? L Onset Data; _ ci? c Cruz - • - • •• 8egtn Data. (p and Findings. .Q-? _ x2. &; - :! lY74r'IAC I C 'FLJ 7. tfF? Increase Rt7M c, . ?- from -SP S... to Irn4>'0ve iurIctlonal mobility/ADC's ,Q'l's' ,, anc nd Iltdernor? trita pr i40t's UPsr Po;,-cure ard sDtu tx c'/ rnrxhanics wrth hng. 15' q hPr ",'s balerx.ar'cWnJlnatkn for func2kytat skills such as 18 L7 P? to wor* at rrndlAed/namel dtutles 17• ? rlorrnai hataelhokt Ap f 8 Q Improve the motor etch for funcLgtional A(DLS such as 18. Cl AwWcopg) r,w lndeperlderx wllh care of patlent in these areas: 20.* 21. 0 Cther ? Harm ererese progarn 22.DMw 2& O Cfhw 24. 0 Other_ taBara? ?s WdW B0* t1tLi eng H iss ?n O Arm mokvUwjh* M0d1°r'? 13 13 ?a 13 erterciee ?ni1) rc? 1.L 0 AM -Ralrffrg 13 8xiog roe Acftlillfeer Tnat} vw* Frsgyi ldt.rAr M Man of Thrapiat Slonattt m (eetablstrhg POCK j H1? thorapW has re Ww9d wl Plat of tars with Ina ?? 7Te?g Dow 0 0dw 0 Cither ThM Week Luraltfow Waeits 13 1 x Nets hub Undw nV cam aoine Irate _ _5- _3 C to P,?f/ant/CsisDJtnar St?natvrle ALTA50UTH Rehab - Century Drive 920 Century Drive Mw%antcsburg, PA 17055 Phone 691-3260 Fax 691-5564 fF?ii?O?tJ?Hs HEALTHSOUTH Rehab - Century Drive 920 Century Drive Mechanicsburg, PA 17055 CE!)RCAL ASSESSMENT ADDENDUM ? Re-em 0 D/C SANERSRI BILLIE JO DOB: 4/70 SF) Dk- ROLLE, MO A .35 ACT: 711A5MIRN: 0 M: 501 GE, alt ob..nvollOwi 41&TVW ? Mtalpic R L 814ADE ARMS OF PAIN - titrt?etrral observation: ' Q,.,.,,,,l„ fr. es I6i Ci V A? Gulsel Folds _- Sacral Suicua helw r Mgb d Sacrum , Ciervical Lordoela ? iNCRnat ? Increased otecresead Thoreclo Kyphoais ? Normal jagamsesd ? Decreased Wmber Wviode ? Norrnai ? ka eeed W Decreased _ Lateral &A R/ L b4 mrsl r_ PoeWrw0bMous rnschar k al ebeee obft R L L p , p artn +oTt + Leg Longth DlacreMW qf4o ? Yee p?uoQS wtrotat: oR tlAarwnt LEFT RIQMT Chin Tuck (Cl-?1 0 -Abwt 3 - Wsk !? Push Chin Up Pl -2) i s OknPdalled 4- C traa r Sid/bend Hand ((,3) 3 2 - Alcrmd Upper Ttape (C4) Deltoid r ?- RRelamee Left pei t 810" P" alcom CS-a Wft Extsimb ?m C,5 $ --'y ' ////?TT •"'Rq ( ) Triceps G7 .. RL RR v 7j EaG. PaI101s 1.ortgus Pm L? Undxicals(T1) DIPWIAATOIMM tiENSA11M mm Twt CNINIV i?? v L } MAL. To ' wn's 1 ?:. J 7 l ?c T R 3 >. iraeeeed r G aRebral Artery ' v n . p Le 13 r - Decreased 4 - Not rested CaTpmar' 2 - &bmral Diatradion - cl L R Thoracic Outlet _ A C2 ? Tw ' C3 Other Tact: - C4 -- 06 ConvTonts: JI C7 i Pdpwbn: to l 'i . ?? co Ti 0-4 er tt t JOINT 1114cm 1ls" Carads I - iiypomobIs Qnrda II - Nomral Grade N - RAwmobb 0CWAW IVTS AM OTHM I OWN awn" FB SBL SBR RL RR B8 Data n n / T ula Dents / TRN -15' Z etl) et e4- Hr,ALTHSOUTH Rehab - Century Drive 920 Century Drive Mechanicsburg, PA 17055 Phone 691-3260 Fax 691-5554 HEAL7HSOM 0 OUTPATIENT CLINICAL ASSESSMENT ? e a?py ? Speech Therapy ? Other Y Q Netrosychobgy/Psygy Patient Name: t E f PAIN ASSESSMENT -- Pain? CI NO ES ra-? oiip d_ 2 3 4 5 6 7 .5 y ?p Pain Scale (0-10): pw __•? _ Best W. st 7-_ - - If Yes, loce6on• __-_. CO by (?J- L , Pain Symptoms: ? Dull --_'-fir- - t'??,_ ,? " ? Referred ? ThrobbkV ? Numbness p Other (use czmment section for detaiai descrip0orz) Prsquencyr. ? No Pan ? 1gs3 than daffy r Q pa,}1'_hraeases (Jay dely episodes )atonstant ? Night ph SANEKSKI BILLIE JU DOB: 09114/70 (F) W- ROLLE, MD AGE: 35 ADMIT: 05/23/06 RM: S01 ACT: 711457 MRN:2D6710 111HIN111111t1 Q Functional O Hand ? LE Addertium a Voice ? LIE Addendum ? Cogr*w ? MIdwT-w O 0wrm dcation ? oyspnae+a nbar O Visual peso! U CW7*W t icing Situation D Abne /Ra1111we Q Cafaow 31dution prior to INnew /PQWM ? Caregiver Set-up issues Q Wound D WhseWeir O Ly rOvden-a ? vesdWlar O Pdmmary ? Amputee O Unary trtocntn m ? Other O Assisted Uvng - ? Other O Alone Q Assisted Ll ft Q Other Does Patient currently have skin braaicdown? Q YES is patient considered to be at risk for skin breakdowns a YES DIET STATUS: EDUCATIONAL NEEDS Level o?kqw-- Patient: Caregiver ?0-7 ?8-12 tiat'le «:ON/?"A 0 0-7 08-12 OC Prirnarv Lana Patient Caregiver: Patient, Caregiver. O Love 10 d ? High ? Low ? ivied ? N/A s t+bed sleep O OCier: - 111111111111114. D am2hw e? t cm KEPAKRUJEEMNAmim ? Medcatlon/Prooadurs: None L Q n ?,tK ? Readng• Q ? Retaxatla-r Tectniques: avLage Q medical Caxtlon Q O ? Video Q ? .OMmialih'/fir that demassas pan: 0 Q WeerkV Q ? R _ ?----- - that haeeses pan 112 - vwm ehm on-no 17 ° Odw - c?.C? ?i_ Hearing Q o n NreacngIs dedmd, at saxavan ' ? a O metaF" s XxWb9/n thepeftW 1 ? 1 Q Other O 0-09%w t P4787 brvuage - A` lNye?ete, al 9at,caeon materier _ to nan•-resdV Dl i ............ ar.r?rtT Assistl+ra Devices: P_-Nom& ? 8tarlderd war ? Rig walker ? lierni Wakar O Quad Cane, Large / Srnam Base 17 Straight Cane ? Cn Aches p Oxygen ? Spilinmam ? OrU ? od,Q• X)t?-IetjC ? EYegiasses/Cattects t Tula. Date / Title Page t or t 309 ourrmerr CLWAaAL cr rRC 2000 DOB: Age: Date of a akaetion a Rai nft Physician P"mautiorm. > s ? PAnENT WFORMAnON RECORWHSTORY ASSESSMENT HEAL THSOUM Rehab - Century Drive 920 Centuy Drive Med dcsbum. PA 17055 $42: ? M DSOAB: 009/14/70 ) 5k: RRO? IMD J AGE: 35 ADMIT: 5123106 RM: 501 ACT: 711457 MRN:206710 Single ? Mealed ? Widowed O Mmrced Homework Phone Phone O MZ ?L , L Address i - CRY state P Employer Address 1-881 Day Worked Ply Language Spoken Phone Emergency Corrtaczt RdWooatdp Moore Pharte Work Phone ' caqular What Is the problem that bAW You to #WNW- Ad- J'z (7-44-1 VIE -1 Pdor Your oondUlm Auto Aociderk ? Fag ? Wait" E3 Olher Date of orteet •? aPY for ort: O ktpa0ertt HeltaibWNdlon ? Yes Q No ? HORMUSoulh Fac Rty ? Yes 1 .V awa L L ? ?^t ? wee ? Np c. ' SLOther Q Yes ? PL- f to a wodmi Yi a comp ", wtwe ware your worid4when Qte irtjury ocagred7 f Your P?ImarY artu nee 65 Medicare and you have sustained an ice: please describe in dsW how and where this Injury occurred late of Binh: -- - A..... Phone: DRUG Adverse Reactions to d I r azro+ corntr m is Pmemure Pr;e- Has" Major surgical procedure wiMt the last 60 days crarttooomx 'on?7 ? Yes No tJst Prior Stxgertes/Hospkahzatlon Dates OUTPATIENT ADMISSIONAEFUS Ft,t<2M Cafter/Phone t C all Date/Tlme: S- Clinlc #/Ddsc: Person Ta1[tng Ref l: Admission Date: = 9 ;AAa-t- Blue Plate SANERSRI BILLIE DO8: 09/4/70 (F) ROLLE ME) 0 AGE: 35 ADMIT: 05/2 ACT: 719457 MA /D6 RM. 5o9 11111hifirlif Transferred from another HEAL THSOUTH.• K Business Line Y Mr-le Oae) o'.2)0") Type of Location patient k coming from: Acme &dew OP #- G?rndvkw CH (Circle one)) How did the patient become aware of HEALTHSOUTH? ASA DCP DM P" RVS !NT MAG Section 1: PATIENT INFORMATION Business Dev Vehicle: OI OZ 03 imv., (Clnde Grandvlew Merh Work Perfect Ho Other Hospital (Name ofX.,ptavl) NEWS OTH PHAR RAD TV RP ?VT Patient Last Name: SCtr vl First ,Name: I t ,.f o MI.• Address: we «rwt. Cu ST: 4 Z County. Phone. 2ylJ- S.4 #: v?b D Fl•' ?-? DOB: i lJ Age: Sex: English: Y N Partial t( -7 At? Race:(?B A H O Martial Status:& M W X D 48 Hour Eval: Y N Expl 4ele one) (arde Oyu) Occupation: _ Employer: Phone: Address: -.-._-_.. ---- ...- -?. ------ ------------- - Emp. at time of Injury: - City: ST: _ _ __ Zip: Employer Contact: Phone: Last Date Worked: Hire/Retired Date: Verified with: Spouse's Spouse Employer;_ Retired?/When: Nc--arest Relativc/Relations /t - hip: -- Address. . Home Phone: } ,33'7 Work Phone: -) Date of Injury: Diagnosis: ProducvNubsp: / Referring Physkian: • L.c Phone: 2L J3 L 5 , _51 Attending Physklan:nn ,, Phone: Family Physician: _ L • Vc ^ y QrA Phone: (FIRSMUSTNAME- CAM OTBEA PRACTICE NAME) SECTION 2: INJURY/REFERRAL INFORMATION Attorney: Address: City: _ ST: Phone: Hospital Stays: - Hospital Name: - Major Surgery in the past 60 days: Date: - Referring Source Name. IA Company. Address: City: - ST: Zi _ p: Phone: Section 3: DENIAL/NON ADMIT INFORMATION Non-admit Reason: _ Date of Determined- _ You must give a reason why the patient to not coaelag Outside Facility: PATIENT WPORMATM RECORDMMTORY ASSMISMENT HEALTHSOM Rehab - Century Drive 920 Century Drive PA 1 Toe Ita?re problem ydf Yes No CwV"M - Cafwd Do you bane p??ts tttfu Y No CAtrttftents Biaddw Control ' Headaches Fs" BkffY Vi hmMouble Vision X Wowt Loa or Gam of Breath Chad Pain Names, or VotrtWtp Skin Ssdkgffi Isfaa Do you smoke? O No Ysa How Much? Do you drink aloofroMt a No Yes HOW Much? Spaaly any feWousOWN" oonsiderAlons: COMMENTS: is there anything ws need to know that Is not covered on this k m+? No 0 so, please explain: Patient's Goals For Treatment: \Ef Only for those patients In Pediatric Program (Linder ago.---Y What childhood aseases has your child had? ? Measles ? Chicken Pox ? Mumps ? Rubella Has your child been exposed to any of these in the past three weeks? ? No ? Yee Explain: Check ImrrwNzatlons that are In the process of completion or have been completed for your child: 0 TDx 3 ? WV O Varioeft 0 Hepatitis B Series ? MMR Please provide us with two people otlfer than yourself who are authorized to pick up your child from therapy and a password for them to use. We will not release.ywr child to any ono else but Vwm you Nat hero. Plesse updals us with any changes irmnodlabMY• Name HoonelNlork Phone CNYBeeper Ptrone NOW HoRWW°rk Phone CaOlBesper Phase P EEEI sssvrord !n ceder to reach your optimum relrebMatlon, It As esssnllfl Owt you Mlbw your pttyslolanlf preecarffbed treatment and the btaabnwlt plan sstabMOwd by your Uwa plst. N you nuAt cannel an appdrsmerr4 please noNly us as ww as poserile so ricer we can reedodwis your missed appofntr wt wNHirr the week. We Appreciate noMtlr.odw of caricefled" 24 hours p for to whoduiled sppdr? pfla &MM us b slime ynourappoiltrnarff *x fior aftr psdents. We are obligated so reowd ail cancsNaWns and no afibrw in your rnealml mgciord H you are covered by worfrer's nwryvermim. we are ob4pled to mart civxaaMed and -no afwW' RAQ& itrnsrifs to you insurance carrier. and co?npisesd by #WWIst. Dat?ie Date Date Date Clinical Signature/Tit[er'tnltials Clinical SignatureRlaw1nitials I?ILLmuRG FA1 W-i$wm "-Pw . carwl. Houp" t3 702 X131 49-1212 Paftnfs Name. Exe *nab.orr fia4ueded: _ Date. Clinical Data:. M ? Call Report 3A? $ e4OA 0 V GY SANERSIBIILLI EJO : a; ROLL RM. 5p1 008. pg1;914! AGE: 35 ?671p CT: 711457 MRN. Robert J. Musser, M.D. GNn E. Hfte M.D. Vanitha Ab?af??rn; 31 ` .':761-7470 ' '66Z'?,?; ia?ua0 u_;eah W wF? o;,9cs '0 Nvol;h 9002 lzl" m PRISM EAST SHORE Fax: 717-561-4903 v-SA EgSRl BILLIE JU DOB: Og114170?F) ?Og LLE MD AGE: 35 ADM 0 ACT: 711457 M Physicians of Ababikation, 4svid 6- $ih, N. W t ` ? l ? V ?Cbacl F. Lupti?1CC}i MD ,?[L)04? 310.E 4 W.tWMamA. ,.Ir MD MD01752DL Daw ? ? - - Pboae D. c t.E?7?t. 4f?! 1?5 l.anca?tc $oulevud, Mec1:.Gicsbucg pA 17453 PHONE: (717) 691-3753 PAX- (T17) 641-3834 QN Bloom But1&g, 4310 L a*& d=7 Rd, See 106, PBwtisbuz„ PA 17109 SHONE; ('717) 561-42Q FAX. (717) 5614903 1 A.L T Q Evaluw6on meatwear ? times T Iveel £or ^.vteks EY f for WeeIs - I wage and commxxmcatica - Stvg Asoclalieies Lk ?1 O?k t/rty( - C+owitoEe impai aneut _ Dome Fsetdse Proms - Otlzcr. ?. AOM -PRE _ ? -mmaic lumbar aion ' s t-./C?vicotboxec SbtbiizatiW Eaxsases - Stirtchiog and klez-bilitT kr - -- Ong - .-- PosbuA Re-Education fc r MO1MM Progmssive ambulation - Stair training - Neuromusct4= _ Balance _ Fuduamm excises Ptxsgrsm AQUATICS M EY?llgtaDn ? lxZMMCff : _timesf SpeCW instn C60A xL?? x"HE.RdX'Y ? Evalnatiwn ? tnatmmt _ Usnes/.Week f. -Veda - HoasekkoM umbilitg - Self cast Aloha Housebold activitr _ Puna! scroe eg - P=CtKMW Corn ity Mobity Assessuneuxt Felt ddvm evaluation { da o.& *"Ad ow&* Fbdfity: - Body Biomedmics Posts= coaa*l/ie'.anion/pw geducation Rom Exercise Prngra m Q Evalustiaa C] Loeabau?ar. _ times/.Week fax _ _ wteks Modalities for - FkaAAlf/Srieagthening tint - Horne Pkrst ee Pmgnaorr FsYCfraLaGY ? Evaluation ? taeatmGnt _ t MeS/.Week for weeks Neuropsycho7o$3 for. ? Evaluation [) treatment _ times/week for -meets FCE - Work Haug Program hmm/dap Work Site Evaluation/Frgwomic Assessment Other fOYMO ML "STORAr?o?v - uric Ptia Program: inpatient - outpatimt Ontgatiew Fubmurpal PwS,= Dal Treatment Prog r m for Consult - COMMENTS SIGNATURE - -c ??RSR'ft?BILL?E JO Clink # f L DOE: ? ADMIT: (F) 64: ROLLE, MD 05/23106 RM: 501 Patient El j ' "Zj ,7 1r R a2,DOB: ACT: 711457 MRN:206710 Guarantor. • ! DOB: Guarantor SSM mm"Ammill ? MEDICARE Hjc# - Any HMO? 0 YES • ? NO Days IP - - - EffDateA Eff Date B Days SNF Elf Date A Etf Date B O CoLI111A1 INS O HMO PPG O O OTHER: Bureau Code: Co. Name: ID # oZ ?!'?3l0 (o IWOrset Address Group # EFF. Data c? 7 a- Phone= i'i f - !o [?'7 Fa?c Deduct/CoPay 5 Me $ _ then Coverage @ % Until OOP Max ? Then Coverage @ - Y - % Unti Life Max of $ Q Djag . O?D,A(AEf ?,ql may. A?) Q t PreC it Required YES EINO PreCert # to Call: Insurance Representatlve7 Name we,o Verified B mefils PreCert # Date: -- Case Ma-ager ht_..a-me_rur Pre Referral # nCert I ReCert Case Mgr: ;EGOADAR?t'•'IIJSURArJc ";$ Pabeilt: ?: 'R C uaranto: i l r:nMM IN', __..., n;:.Ine. 11 r: :1 ,,t,, ...------- J{ Go. Name: -- - - / - --- i ns•et Address: --- r (.:Foup# _ EFF. Date - -- - - - -- Phone Fax - - DeducVCoPay ; - Met _? - - then Coverage @ Untii OOP Max $ Then Coverage @ %. Until Life Max of S 0 Dlag O DME t3 ANE dditfonal Inro: K nr. Medcare D. PnsCert PAnUred O YES X-40 PreCert # to Galt PreCert# Date: Referral #: Varltbrt Dale: ?? ?/ 7/ r- Verrfied By M w BOBS 1P0' OPT CWMIADVASSION NSURANCE VERIFICATION REV 07-194Xt d°c (enter name offacfliryi SANERSRI BILLIE JO DOB: 09/14170 (F)) D?2: ROILE, MD AGE: 35 ADMIT: A5J23/O6 RM: 501 ACT: 711457 MRN:M6710 1101111111111 Patient Rlghts and Responsibility, Safety and Restraint Reduction/Elimination. A patient shall be fully informed of their rights and responsibilities and of all procedures governing conduct and responsibilities. A patient shall be provided information explaining a patient's right to expect reasonable safety i asofar as t he hospital practices i n an environment that is as restraint free as possible. The information will be provided to a patient verbally and via a written copy at the time of admission. The undersigned acknowledges receipt of this information. When a patient is physically or mentally incompetent, the signing MUST be witnessed by a third person. Information Privacy: HFALTHSOUTH will use and disclose personal health information to treat the patient, to receive paym t or the care provided, and for other health care operations. Health care operations generally include those activities performed to improve the quality of can. We have prepared a detailed NOTICE OF PRIVACY PRACTICES to assist in a better understanding of Hospital policies in regards to personal health information. The terra of the notice may change with time and the Hospital will always post the current notice at facilities, on the website and have copies available for distribution. The undersigned acknowledges receipt of this information. _ I Complaint/Grievance Procedure. The patient shall be fully informed of the Hospital Complaint/Grievance Procedure at the time of admission as well as receiving a copy of the procedure. The undersigned acknowledges a receipt of this information. Advance Directives. Advance Directives are documents such as Living Wills, Durable Power of Attorney, and Health Care Surrogate Appointment- If requested, a patient shall be provided information regarding the state law on advance directives and shall be provided assistance in completing the necessary documents. The patient MUST provide the Hospital with such information if an Advance Directive has been previously executed. Patient has executed an Advance Directive and will provide a copy to the Hospital. Patient has not executed an Advance Directive and requests information and/or assistance. -----Patient has not executed an Advance Directive and does riot request information and/or assistance. Organ and Tissue Donation. Upon request, a patient shall be provided the information for organ and tissue donation and shall also receive counseling or assistance in completing the necessary documents. The patient MUST provide the Hospital with such infomlation if an organ and tissue donation has been previously executed. ..___ -Patient has executed an Organ and Tissue Donation form and will provide a copy to the Hospital- .. -..--.--Patient has not executed an Organ and Tissue Donation form and requests information and/or assistance. -Patient has not executed an Organ and Tissue Donation and does not request information and/or assistance. --Follow -U p Release. H EALTHSOUTH strives to provide its customers with the highest quality rehabilitation services. Info tion that is provided is vital in helping the Hospital maintain customer satisfaction and attain positive outcomes. To ensure that programs continue to provide effective services, the treatment team conducts evaluations during specific periods of the patient's stay in the areas of self-care, mobility, communication and cognition. These assessments allow monitoring of the quality of our programs and outcomes. Because of the importance of the patient's ability to maintain their quality of life once they have left HEALTHSOUTH, attempts are made to assess each patient's functional levels after discharge. Approximately three months after discharge, a representative of Formations in Healthcare will initiate contact by telephone. HEALTHSOUTH has contracted with Formations to collect this data so that it may be compared to the patient's assessment levels at admission and discharge. This follow-up information aids in the pmgam evaluation system of the Hospital. The patient or their legal representative acknowledges that the above information was explained to them to their satisfaction. The patient agrees to the release of their name, phone number, demographic and functional status information to representative of Formations in Health Care. The patient also agrees that either they or their representative will do their bassi to cooperate with the interview. The,Undersigned certifies that he/she has read the above and received copies thereof, and to the patient, or is duly authorized by the patient as the patient's legal representative, to execute the above and accept its terms. Patient Parent/Legal Guardian/i.egal Representative Witness (Patient's Legal Representative) Relationship to Patient Date- Time COA-) (Rev. 012003) White - Health information Copy/ Canary - StWoom Office Copy/ Pink -Patient Copy/ Given- Can Managa page two of two MMUMW -Af (enter name of facility) Name i UTHORIZATION OF MEDICAL TREATMENT Name of Attending Physician: XL?i • /Ll?lt?'.?rt/ 11 dLL.e? X Consent for Care and Treatment: A patient who is admitted to the Hospital is under the supervision of his/her attending physician and all Hospital staff for the care and treatment of his/her condition. The patient consents to any examinations, laboratory procedures, radiology, other diagnostic teats, specialized themes, surgical procedures, other medical interventions including the use of protective side rails or restraints and/or transportation to and from appoiatmetts, as deemed necessary by and under the direction of the attending physician. The Hospital is not liable if the patient does not follow the instruction of his/her attending physician during the course of hospitalization and/or outpatient services. ALL PHYSICIANS ARE INDEPENDENT CONTRACTORS: All Physicians providing medical services at HEALTHSOUTH (enter name offaciJity) are independent professionals engaged in their private practice of medicine and are not employees of HEALTHSOUTH (enter name of facility). The patient recognizes that all physicians that consult and furnish services ordered by the attending physician are independent contractors and are privileged by the Hospital to provide such services. The patient understands that they have the right to select any physician on the medical stung if he/she agrees to accept theca as a patient. In the event of an emergency, in the event certain specialized services are required, or in the event that a physician has not been designated, the patient consents to treatment by the applicable attending physician. -Release of Information: The hospital may disclose all or any part of the patient's medical records to any person or corporation that is liable for the Hospital's charge, including but not limited to hospital or medical service companies, insurance companies and/or their contracting review agencies, workman's compensation carriers, welfare funds, and other government insurance companies. This release is strictly for reimbursement purposes to the Hospital for services rendered. The Hospital may disclose all or any part of the patient's medical record for this admission to the referring physician/social worker, treating physician(s), family physician, and/or other treatment agencies to aid in the continuing treatment once discharged from the hospital setting. Authorization must be signed by the patient, or in the case of a minor or when a patient is physically or mentally incompetent, by the nearest relative or legal guardian. The release of such information may contain psychiatric history, drug and/or alcohol history, and HIV/AIDS related information. Assignment of Insurance Beaeifts: The undersigned agrees, whether he/she signs as agent or as patient, to direct payment to the Hospital of any insurance benefits otherwise payable to, or on behalf o? the patient for this hospitalization or outpatient services, including emergency services if rendeped, at a rate not to exceed hospital's regular charges. TXIAnancial Agreement: The undersigned agrees, whether he/she signs as agent or as patient, that in consideration of services rendered to the patient, he/she hereby individually obligates himselfl'tleself responsible to fully reimburse the hospital for charges and associated incidental expenses incurred by the patient, not covered by benefit plans, If benefits under such benefit plan(s) cease while the patient continues to receive services, the undersigned is responsible for 111 payment. Patient vatusbleC It is understood and agreed that the Hospital maintains a safe for safekeeping of money and valuables. The Hospital shall not be liable for the loss or damage to any money, jewelry, documents, articles of value, or other personal property unless deposited and recorded with the Hospital for safekeeping. The liability of the Hospital for loss of personal property which is deposited and recorded with the Hospital for safekeeping, is limited by statute to Five Hundred Dollars (S504) unless a written receipt, signed by the Administrator of the Hospital, has been obtained for a greater amount. Transportation: The undersigned understands that while an Inpatient at the Hospital if transportation is provided by HEALTHSOUTH, it is at no charge and at the convenience of the Hospital. The undersigned understands that if transportation is provided by HEALTHSOUTH while receiving outpatient treatment at the Hospital, it will be at a charge and at the convenience of the Hospital. The undersigned is aware that hospital vehicles are not equipped to handle modical emergencies. The undersigned acknowledges that by accepting this transportation, they release, indemnity and agree to hold harmless the Hospital and its employees from any and all actions that might arise due to personal injury, damage or loss while a passenger in the hospital vehicle. If it is medically necessary to transport via an ambulance, the undersigned is aware that if this service is not covered by the patient's benefit plan that the patient or responsible party will assume payment for this service. 00A-1 (Rev, 01/2003) White - Health lnformation copy/ Canary - occurs Ofrke Cape / Put - Patient copy/ Green. Can Manager Page one of tw o CONDITIONS OF ADMISSION AND HEALTHSOUTH Patient Name: 2 (1/f c Jv ?Cr/lcrsr? Diagnosis: rygzg 10- bANERSRI BILLIE JO DOB: 09114/70 (F) DR: ROLLE, MD AGE: 35 ADMIT': 05123/08 RM: 501 ACT: 711457 MRN:206710 IMINN111l1M111 Cx/Thoracic Rehabilitation Program nativity Description Date Date: L3 ARCM Flexion _ Extension Lateral Flexion Rotation 6 0&& :retches Upper Trapezius '`5 7 7 ?" Levator Scapula Chest ,ar GkAz p Rhomboid _ Cx Flexion. Cx Roataicn Prayer ISOM Flexion Extension Lateral Flexion :her Ex Chin Tucks ",?/ ? ?/ Shoulder Shrugs Scap Retraction ./ Supine D1 Supine D2 7P0 'F C' c n C one Y - Shld Flexion T - Shld Hor. Abd rdi o UB E r 1, f (17 c -'t4 HP T-P V 1 5 --NtRSRt BtLLIt J U D% JW141704 0512 R ??D ROF- AGE: 35 ADMi : o ACT 711467 HEALTHSOUTH Patient Name : ji i t?, ? o arty rsr"? Cx/Thoracic Diagnosis: C.CX - Rehabilitation Program wtivity Description Date : Da ' ?D f te 9 t3 /S V p,R Flexion r Extension ateral Flexion tatin RRo J :re - -- - pper Trapezius ,' Levator Scapula Chest v » ?/ "?h '' ?o ? ? + ? »a?a L '? ? ? Rhomboid Cx Flexion Cx Roataion Prayer :: lii Flexion Extension Lateral Flexion :her Es Chin Tucks ? ",i " ! » Shoulder Shrugs Scap Retraction Supipe D1 per, ,n Shin w "one Y - Shld Flexion T - Shld Hor. Abd Xd 10 UBE r Lk V\ A, - ILd v ? iox -- . G _ i i G? ? p + ??j» IOr II&Z ,? i "i<f5 _J C7{ HIM co ? ?? y BILLIE J. FISHER-SANERSRI and NIPON SANERSRI, PLAINTIFFS V. PETER MURPHY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5654 CIVIL CIVIL ACTION - LAW IN RE: MOTION FOR PARTIAL SUMMARY JUDGMENT BEFORE GUIDO AND EBERT J.J. ORDER OF COURT AND NOW, this 26" day of October, 2006, upon consideration of the Defendant's Motion for Partial Summary Judgment and after review of the efendant's submitted on behalf of the parties, and argument of counsel; pleadings IT IS HEREBY ORDERED AND DIRECTED that the Defendant's Motio Partial Summary Judgment is DENIED. n for N %1% .0avid H. Rosenberg, Esquire Attorney for Plaintiffs orge H. Eager, Esquire ,9.? for Defendant bas -11 M. L. Ebert, Jr By the court, 1,34 4a 9Z 1abOZ xu, 110, ORIGINAL. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BILLIE JO FISHER-SANERSRI, and NIPON SANERSRI, Plaintiffs V. PETER MURPHY, Defendant NO. 03-5654 Civil Term CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant 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: /aLat )6G eorg er Esquire Attorn eyvo ndant I.D. No. 27 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 SUBPOENA NOTICE OF INTENT PENNSYLVANIA COURT OF COMMON PLEAS COUNTY OF CUMBERLAND Billie Jo Fisher-Sanersri and Nipon Sanersri Court of Common Pleas V5. Peter Murphy 03-5654 Pagel of 3 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Provider: Pinnacle Health Systems Pinnacle Health Systems Record Type: Medical Radiology T0: David Rosenberg, Esquire note: please see enclosed list of all other interested counsel Litigation Solutions, Inc. ('LSI') on behalf of George H. Eager, Esquire 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. Date of Issue: 11/27/2006 Litigation Solutions, Inc. on behalf of: CC: George H. Eager, Esquire - Court of Common Pleas George H. Eager, Esquire Defense If you have any questions regarding this matter, please contact: Litigation Solutions, Inc. (412.263.5656) Brentwood Towne Centre 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 http://rats.litsol.com/ratsevents/notice_of intent.asp?save_report_to_db=X&PLid=PL198... 11/27/2006 SUBPOENA NOTICE OF INTENT Page 2 of 3 COUNSEL LISTING FOR BILLIE 30 FISHER-SANERSRI AND NIPON SANERSRI VS. PETER MURPHY County of Cumberland Court of Common Pleas Counsel Firm Counsel Type Rosenberg, Esquire, David 1300 Linglestown Road Harrisburg PA 17110 Opposing Counsel (i- \ http://rats.litsol.com/ratsevents/notice-of intent. asp?save_report_to_db=X&PLid=PL198... 11/27/2006 COMMrOnN?WEEyALTH OF PENNSYLVANIA Billie Jo Fisher-Sanersri arTd.NiPoOFCUMBERLAND Sanersri VS. Peter Murphy File No. 03-5654 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Pinnacle Health Systems - Medical Records (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: PLEASE SEE ATTACHED RIDER at 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 (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: George H. Eager, Esquire ADDRES$: ruitvi e Pike ancas , 17601 TELEPHONE: 717-290-7971 SUPREME COURT ID # 2 7 7 4 0 ATTORNEY FOR D e ens e Date:!?. c,ZQ, G Seal of the Court BY THE COURT: 161 64zl- Prothonotary, Civil Divis?i66 SUBPOENA RIDER Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Pinnacle Health Systems 205 S. Front Street P.O. Box 8700 Harrisburg PA 17105 Attention: Medical Records Correspondence Subject: Fisher-Sanersri, Billie Jo SS#: 220-08-8922 Date of Birth: 1970-09-14 Page 1 of 1 Requested Items: Please remit: a complete copy of any and all medical records from 1/1/2002 to 11/14/2006, including records, charts, test results, reports, correspondence, office notes, and computerized records. http://rats.litsol.com/ratseventslsubpoena_rider.asp?PLid=PL 198315&WRid=WR 10177 11/27/2006 COMMONWEALTH OF PENNSYLVANIA PoOFCUMBERLAND OW?IY Billie Jo Fisher-Sanersri ana Sanersri VS. Peter Murphy File No. 03-5654 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Pinnacle Health Systems - Radiology (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: PLEASE SEE ATTACHED RIDER at 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 (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: George H. Eager, Esquire ADDRESS: 1347 ruitvi e i e Lancast'er , 17601 TELEPHONE: 717-290-7971 SUPREME COURT ID # 2 7 7 4 0 ATTORNEY FOR: Defense Date: ??(J? < 670. aLere, Seal of the Court BY THE COURT: Prothonotary, Civil Division De?? SUBPOENA RIDER Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Pinnacle Health Systems 205 S. Front Street P.O. Box 8700 Harrisburg PA 17105 Attention: Radiology Films Library Subject: Fisher-Sanersri, Billie Jo SS#: 220-08-8922 Date of Birth: 1970-09-14 Page 1 of 1 Requested Items: Please remit: Complete copy of any and all diagnostic films and film lists from 1/1/2002 to 11/14/2006, including X- Rays, MRI, and CT scans. http://rats.litsol.comlratseventslsubpoena_rider. asp?PLid=PL 198318& WRid=WR 10177 11/27/2006 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road P.O. Box 60337 Harrisburg, PA 17106-0337 EAGER, SPINELLO, QUINN & STENGEL DATE: i G BY: George H. ger, quire Attorney fo Defe dant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 rh 7_ 1 i l .. <<r ti - -i Gregory M. Feather, Esq. I.D. No. 79456 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorneys for Plaintiffs Fax: (717) 233-3029 E-mail: Feather(aftrlaw.com BILLIE J. FISHER-SANERSRI IN THE COURT OF COMMON PLEAS and NIPON SANERSRI, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 03-6664 CIVIL PETER MURPHY CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter the appearance of Handler, Henning & Rosenberg, LLP and Gregory M. Feather, Esq. in the above-captioned matter. Respectfully submitted, HANDLER, HENNING & BY: DATE: Gr)6go". Feather, Esq. Attorneys) for Plaintiff , LLP rn u ?; 161 -fiw PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: for JURY trial at the next term of civil court. ? for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) BILLIE JO FISHER-SANERSRI and NIPON SANERSRI (Plaintiff) VS. PETER MURPHY (Defendant) VS. (check one) P Civil Action - Law ? Appeal from arbitration (other) The trial list will be called on and -- Trials commence on 01 / 2 6 / n A Pretrials will be held on 01 / 0 71 n 9 (Briefs are due S days before pretrials No. 03-5654 , r4; ii Term Indicate the attorney who will try case for the party who files this praecipe: John P Stengel-, gs;giii i re Indicate trial counsel for other parties if known: This case is ready for trial. Date: /Q & dc) e Signed: Print NameY John P Attorney for: Defendant ire f 4 1 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for Listing Case for Trial upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Gregory M. Feather, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road P.O. Box 60337 Harrisburg, PA 17106-0337 Date: 26 L,. g By: EAGERiWINELLO, QUINN & STENGEL itd gtl, Esquire for D fendant I. D. NP. 6404)1 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 f 71 C-3 C, so a) ?w 'rn rr (_. N BILLIE JO FISHER-SANERSRI and NIPON SANERSRI, Plaintiffs v PETER MURPHY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 03-5654 CIVIL TERM IN RE: CASE STRICKEN FROM LIST ORDER OF COURT AND NOW, this 30th day of December, 2008, upon consideration of the call of the civil trial list, and no counsel having called the case for trial, it is stricken from the trial list. By the Court, J., esley 0 Gregory M. Feather, Esquire 1300 Linglestown Road Harrisburg, PA 17110-2838 For Plaintiffs ?John P. Stengel, Esquire 53 North Duke Street Lancaster, PA 17602-2839 For Defendant J. Court Administrator _ c ,o F1 ?l??c? r•J ?[? :mae ?, ?? ,`- ?s ?_ `?-- ?r?? ?? -_ ??, ?, ?,.: t ?? ??, t ?? ?. ? - ? ??, r - BILLIE JO FISHER-SANESRI and AiIPON SANESRI Plaintiffs V. PETER MURPHY, Defendant O MVI N A' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5654 20 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: John P. Stengel, Esquire counsel for the 0MU defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $3 , 5 0 0. 0 0 The counterclaim of the defendant in the action is $ 3 , 0 0 0.0 0 The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Gregory M. Feather Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respec s , ORDER OF COURT AND NOW, 200 , in consideration of the foregoing petition, Esq., and captioned action (or actions) as prayed for. Esq., and Esq., are appointed arbitrators in the above By the Court, EDGAR B. BAYLEY i CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Petition for Appointment of Arbitrators upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Gregory M. Feather, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road P.O. Box 60337 Harrisburg, PA 17106-0337 ELLO, QUINN & STENGEL Date: 0 By: Joh P?Ste el, Esquire Att r ey for fendant I . D. o. 64041 134 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 OF RE Fr;,rt NOT 2009 APP 13 Ni l : 51 fi`t'. f - BILLIE JO FISHER-SANESRI and NIPON SANESRI Plaintiffs V. PETER MURPHY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5654 20 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: John P. Stengel, Esquire , counsel for the PhUM defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $3 , 5 0 0.0 0 The counterclaim of the defendant in the action is $3,000.00 The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: -Gregory M. Feather. Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. ORDER OF COURT AND NOW, (JtAj °?q 200___, ' consideration of the foregoing petition, Esq., and Esq., and Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By e o , v EDGAR B. BAYLEY ,w J Wl ? J T Gregory M. Feather, Esq. I.D. #79456 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorneys for Plaintiffs Fax : (717) 233-3029 E-mail: Feather0-HIRLaw corn BILLIE J. FISHER-SANERSRI IN THE COURT OF COMMON PLEAS and NIPON SANERSRI, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 03-5654 Civil PETER MURPHY, CIVIL ACTION - LAW Defendant : PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the above-captioned matter settled, discontinued and satisfied. HANDLER, HENNING & BY: DATE: Gre=evs ,Feather, Esq. Attor or Plaintiff RG, LLP cu, BILLIE JO FISHER-SANERSRI, IN THE COURT OF COMMON PLEAS OF and NIPON SANERSRI, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS V. PETER MURPHY, DEFENDANT 03-5654 CIVIL TERM ORDER OF COURT AND NOW, this ?© day of June, 2009, the appointment of a Board of Arbitrators in the above-captioned case, IS VACATED. William S. Daniels, Esquire, Chairman, shall be paid the sum of $50.00. By the Edgar B William S. Daniels, Esquire - CO rrt5 LqcL Court Administrator sal (0/3 D/Oq t rL 140 pt I E_ RLED-OfTICE OF THE PROTHONOTARY 2009 JUN 30 AM 9: 15 WUNTY PENNSYLVANIA