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Home My WebLink About03-6368IN THE COURT OF COMMON PLEAS OF STEVEN E. RATHGEBER and GRACE D. RATHGEBER, as Parents And Natural Guardians of STEPHANIE E. RATHGEBER, a minor vs. JEAN TAYLOR Claremont Nursing Home A Wing 1000 Claremont Road Carlisle, PA 17013 and JOHN M. WHITTEN 630 Conodoguinet Avenue Carlisle, PA 17013 CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-~- & 3~' ~-~ CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Issue Writ of Summons in the above-captioned matter. X Writ of Summons shall be issued and forwarded to Attorney/Sheriff. Date: December ~, 2003 GRIEST, ~~0~UMANN LLP By: /~~- ~ Christopher A. Ferro, Esquire Sup. Ct. I.D. No. 85057 129 East Market Street York PA 17401 (717) 846-8856 Attorney for Plaintiffs SUMMONS IN CIVIL ACTION TO: JEAN TAYLOR and JOHN M. WHITTEN YOU ARE HEREBY COMMENCED AN ACTION AGAINST YOU. Date: ~ ~ 2003 NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF (S) HAS/HAVE Prot[/on~tary/~I~k,~vi 1 by: Deputy Division SHERIFF'S RETURN - CASE NO: 2003-06368 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLJtND RATHGEBER STEVEN E ET AL VS TAYLOR JEAN ET AL REGULAR CPL. MICHAEL BARRICK Cumberland County, Pennsylvania, Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the llth day of December , by handing to together with says, the within WRIT OF SUMMONS WHITTEN JOHN M DEFENDANT at 1336:00 HOURS, on the at 630 CONODOGUINET AVENUE CARLISLE, PA 17013 JOHN M WHITTEN a true and attested copy of WRIT OF SUMMONS 2003 and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me .this ~ day of So Answers: R. Thomas Kline 12/12/2003 ,'7 /~ GRIEST HIMES HER~//~2~IAU~ Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2003-06368 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RATHGEBER STEVEN E ET AL VS TAYLOR JEAN ET AL CPL. MICHAEL BARRICK Cumberland County,Pennsylvania, Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the llth day of December , by handing to POA FOR JE~2q TAYLOR WRIT OF SUMMONS together with says, the within WRIT OF SUMMONS TAYLOR JEAN DEFENDANT at 1330:00 HOURS, at 630 CONODOGUINET AVENUE CARLISLE, PA 17013 JOHN M WHITTEN, HUSB OF TERRI WHITTEN, a true and attested copy of 2003 and at the same time directing His attention to the Additional Comments NURSING HOME REQUESTED THAT TAYLOR'S POA BE SERVED. contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before oth~: ' ' oth~no~ary ~ So Answers: R. Thomas Kline 12/12/2003 GRIEST HIMES ~~~/~ ~-~ Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEVEN E. RATHGEBER and GRACE D. RATHGEBER, as Parents and Natural Guardians of STEPHANIE E. RATHGEBER, a Minor VS. JEAN TAYLOR and JOHN M. WHITTEN No. 2003- 6368 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED PETITION FOR APPROVAL OF A MINOR SEI-rLEMENT AND NOW, to wit, this day of October, 2004, come the Petitioners, Steven E. Rathgeber and Grace D. Rathgeber, parents and natural guardians of Stephanie E. Rathgeber, a minor child, by their attorneys, Griest, Himes, Herrold, Schaumann, LLP, by Christopher A. Ferro, Esquire, and file their Petition for Approval of a Minor Settlement as follows: 1. Petitioners, Steven E. Rathgeber and Grace D. Rathgeber, are adult individuals residing at 4 Edward Court, Ortanna, Pennsylvania 17353. 2. Stephanie E. Rathgeber, date of birth, August 9, 1996, is a minor child residing with her parents and natural guardians, the Petitioners above. 3. Defendant, Jean Taylor, is an adult individual residing at Claremont Nursing Home, 1000 Claremont Road, Carlisle, Pennsylvania 17013. 4. Defendant, John M. Whitten, is an adult individual residing at 630 Conodoguinet Avenue, Carlisle, Pennsylvania 17013. 5. On or about December 26, 2001, the minor Plaintiff was visiting her grandmother's home located on Conodoguinet Avenue in North Middleton Township, Carlisle, Pennsylvania. 6. While on her grandmother's property, the minor Plaintiff was attacked by a dog cared for by Defendant, Taylor. 7. As a result of the attack, the minor Plaintiff received facial wounds and lacerations to her face and head. 8. Immediately following the attack, the minor Plaintiff was treated at Carlisle Regional Medical Center. A copy of the. hospital notes for the treatment the minor Plaintiff received in the emergency room of the Carlisle Regional Medical Center are attached hereto and incorporated herein as Exhibit "A". 9. After her emergency treatment at Carlisle Regional Medical Center, the minor Plaintiff received follow-up treatment and plastic surgery evaluation from Dr. Paul Manson of the Johns Hopkins Medical Center. A copy of Dr. Manson's clinic notes for his treatment of the minor Plaintiff on February 13, 2002, May 15, 2002, and November 6, 2002, are collectively attached hereto and incorporated herein as Exhibit "B". 10. On November 6, 2002, Dr. Manson reported that the only permanent scar on the minor Plaintiff's face is the one on her nose. Dr. Manson also indicated that the minor Plaintiff's "improvement is sufficient that one could not offer her any additional improvement by further surgery." SeE; Exhibit "B". 11. All of the medical expenses relative to the foregoing treatment have been paid by the Defendant's insurance coverage. 12. A Writ of Summons was filed on December 9, 2003. 13. The Writ of Summons was served on the Defendants by the Cumberland County Sheriff's Department on or about December 19, 2003. 14. The Defendants, through their insurance carrier, Evercash Mutual, have proposed a settlement in the above-referenced matter whereby Defendants, through Evercash Mutual, would pay the Petitioners the sum of Twelve Thousand ($12,000.00) Dollars. 15. Your Petitioners and counsel for the Petitioners recommend the approval of the settlement with the insurance carrier for the Defendants on behalf of the minor Plaintiff in the total sum of Twelve Thousand ($12,000.00) Dollars because they consider it fair and reasonable and believe that it adequately compensates the Plaintiff for the injuries sustained on December 26, 2001. 16. A copy of the proposed Order distributing the proceeds of the above- referenced settlement is attached hereto and marked as Exhibit "C". WHEREFORE, Petitioners move this Honorable Court to enter an Order approving the compromised settlement and Order a distribution in accordance with the proposed Order of Distribution attached hereto and incorporated herein. IRespectfully submitted, GRIEST, HIMES, HERROLD, SCHAUMANN, LLP IBY:~ Chr~ A: Ferro, Esquire PA85057 129 East Market Street York PA 17401 (717) 846-8856 FAX: (717) 845-3330 Cferro@ GHHSLaw.com VERIFICATION We, STEVEN E. RATHGEBER and GRACE D. RATHGEBER, hereby verify that the facts set forth in the foregoing document are true and correct to the best of our knowledge, information, and belief. We understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unsworn fal- sification to authorities. Date: I0/~' ¢/o ~/ Steven E. Rathgeber Grace ~ Rathgeb~r Apr,j5. 2'003 11i25A1~ No,5498 P, 40/49 ~,~,. ~,,,~,^ ,,o,~ ~,:7~.~.~,~ ..:.~:.i~:~:~::~!~:~.:.~'~... ......tit': ~~'.~.~.~.~.~:~?~,:~?':~: 777- 77 - 7777 CHILD ~ US .. (410) 836-8%82 FATHER ~TH~BB~2, SHIRLEY (717) 243-8830 G-MOT~ER DOG ATTAC~D IN THE FAC~ ~v ~ ~RT ......., ............................... ~%~.,..,...,.z~:~ .................. ~ .......... ~ ............... . ..... ~..~.~: ................................................................................ :':::[::::: ~~T~--.,.---._....__~z~,s~c~ ~ ............................... '?.'Z{:.' 104~S MILL R~ CIRCLE · ,~',: OWINGS MILLS MD 21117 :::~:';~.:~:'. ( 800 ) 342 - 7287 I =.....~ ........ ~.~ = ............................. ~ ................. ..................... .~. .... ~ ............................... ~ ~,,.,.,.~., .~ .............. ~,..~ .. ,,,,, ............... ~ ......................... · ...................... ~....,~,'~.~ ~=.~,.{~:~5~5~v:z:'='.'~':..':~: - ........................................................................................................... I .' .,:::::,.,:,::] :~i"j~:~.~'.~::.,, '~ ~' '~'--' ~" ~"~'~"' ./.:.~::~ FALVO, THOMAS NONSTAFF, 0~ 0F TOW~ ~I~L ~IT~ OTHER 12/26/200,1_ IIIIlllllllllJl IIIIlllllllllllll co ,¥ IJl llJJJlJJlJJJJJ Apr.15. ~003 11:29AM Carlisle Regional Medical Center No.5498 P. 4]/49 mild ~ 1-10 florl8 ~ld / ~amily ~t racoon gewr ~ .... OTO Un~b~lnabl~ Due Tot ~L.O~ In--on ~e'~fiS' ~ ~:,~n ~ ............ ,~; ~ ~l~i~ ...... C,P. ~;~ DOE PND ;': ..... YES (d~a) H1M [DDM / NIDDM none Appy C~oly H)~t~- Animal / Human Bite. Page 1 of 2 Apr.!5. 200,3 ]l':30A~I N0.5498 P, ~2/49 ~ , Carllslo R~gional Modical ¢~nter EKO: NSR no ~ di~ase IMF. Da: D.T. ,5 cc IM DIFF $ B L X-Rayt I~T/Pi-r: INR: ..... ~ulae ox: L'=T~: SGOT SGPT RA O2: UA: ~lG prot EBCa WBC~ AllO: UCa: + I - % NL / hyp~ ~ human'b~" dog bite Ot]leC. Mtb~ ~lulffis puncture wound ]VF: I~:~,EY: I~ S~me YIN Pro- MED Maximus MD/DO Animal / Human Bite. Page 2 of 2 Apr.lS, 2~0,3 11i30AM No.5498 P, 43/49 Carlisle Regional Medical Center flap ste~late avulsion foreign body digital block } Z.), oc's ~lJ~) 2% lido .5% man,'alne ~ .~T'~r-'-'~7'~_ ~,~T..7"-'--'- ' -'":7.~.._. ........... ,~ubcutaneo~*, .......... # - 0 vl~/~ simple !ntaf~...p~l running mattman horlz / ve~t . .. fascia / muscle / tendon # - 0 vl=.ryl' simple inter.m, pted running mat~eas horlz/yen ~...o~ ' ~ .1~,~!~ YIN Other; ~i tendon functl°~"nta= vascular intact superficlel" subcutaneouS' ' mu~e tendon ~'o~e linear irregular flap s~late avulsion ~:~ ~' fore~ ~o~ ~.hi~,'! Io.~,.. digital ~=g ~ .. 1% lldo 2% lido w/epi w / btcarb ~l~a~T~-'-~etadlne ' ~JbJclene saline ~'rigation debridamant ,~a'~ skin # - 0 prolene nylo_n..., staples simple I.n~r~upted runqir)g..._metlmss harlz / vat ~ensaflen intact ,5% marcaine Dermabond subcutaneous # ~ 0 vk~ auk slmRt.e !ntenuptad rennin9 mattress ho~ / vart fascia / muscle / tendon # simpl~.interrup~ed running mattre.~s horiz/vett Other. Pro-MED Maxlmus YIN Oote Jn: 12/2B/01 Carlisle Reg~onm MeO~ca; (;enter NammRATHGABER, STEPHANIE E 1=~9214741 DOB: 08/09/1996 Age: 5YR$ Sec F MRR0001006832 EDP;FALVO,THOMAS PCP:' NON.STAFF, OUT OF TOWN CMP .... D.._~ Same~ (Urine). (Serum) UA Bel~ HOG Lactic Aclcl s~x~ Cur~r~ x¢ t wound Cullum ABG [] KVO De, vim r'llv [] (;ardlsc IV~IW' ~ NIBP Monitor [] Pulse Ox/meb7 [] Warming/Cc~ling Blanke~ ~i~ ~:] Irrigation ONound), r'i NGT Inser~on I~ Ur~ary Catheter Insertion rt Central Une Placement ~ Sp[Ir~ng/lmmobl~zatJon [] CPR r~ Endos~olo P~edure [] Notir~a~n of Pml~r AgenoT(s) [] L~cera[on Re. Ir r~ F~g~ ~ocly Removal E~;r.]5. 2i0~ lli32AM I~u=w~fD~u,A~(;'MENT No,5498 P. 45/4.9 Carlisle Regional Medical Center ONGOIN(; NURSIN~ ASSE,~SMENT ~r~ ~THG~;E~ ;TEPH~IE E ~ 9214741 ~e: 5Y~ DO~:08~/1996 ;~: F M~:0001006~2 ~: 1~26/01 ~P:F~VO,THO~ PCP: ' NON~T~F, OUT OF TOV Airway Gearenee, Ineffective Communication Impaired Info,on, PoMntJal Self Cam Defl~ ~An~y '~Coplng, Ineffe~ve '-~nJury, Potm~ '--"SXIn INegff~' Iml~rment ~erea~ing Pattem~, Ine~ ~'~""Fluid Volume, Aitem~n in ~"~'~o~edge Oef~t ~---'rheught Pr~asses, Impaired __C~'dlao Oulput, Oeoteased ~Gaa Excflange, Irnpai~ld .~Mo~l~[y Impaired __~ought Pm,'*,.--,,.,/,Jt~mi~m in Cemfort. Altem~on in ~Hype~em~ia (Fever) ~Hon-Compllanm ~'ri~u; Pen'udon, Ntma~on in ~O'~er Other [] Pll la~_MOVAL [] Ib~MOBILIZATION I PROPER AUGNMENTi D IMPROV~.NT OF BREATHING n PAIN CONTROL o MNNTAIN STABLE HOI~TA~I$ 0 r~ ENt/IR~NMENTAL NEEO$ ~ DECREASE AN~ETY I [] IR6JNTAIN I iMPROVE CIRCULAllON [] ~ EDUCATIONN. NEED6 ...... "-- .. D/C I/mtTuc~ne gt;n to~~/'J~ = Verbalized ',J~demtandln, 0 Treated & Relea~ecl []Admit. ~ t .~o Dr, ...... i-j Ttan~. to D L~t without ~eaf~tent o Left NdA RelXat mired at __ and given to ..... Pain; SevedtyScall: '~/ _ Dlmprovecl ~Un~llanged ~Wora~ D/C VRaW; T. P, R BP ,. J Apr,J5. 2'00,3 I1':32AM . EMEI~GENCY DEPARTMENT MUSCULOSKELETAL NURSING ASSESSMENT Su~e N~: -No,5498.. P, ¢6/49 Carlisle ~e~,~,,,=, Me~;<,~ ~**~J~r Namet~G~ S~H~IE E ~ 92~4741 Age: ~RS ~a:O8/O9/1996 8~ F ~ ~01008832 EDP:FALVO,~O~ PCP[" NON-~AFF, O~ OF LocaUon'. Quail~g.B~llat'p oDull nCramping ogurrdng hACking Sevedlysmle; Oreet:. Provocation: [] Other:. Aggrava6ng factor: R~dlmtng: ~3NOI3Yes ~ ......................... DConstanl nlntarmltt~t IR~evf~gfa~3t~; ~~!1 ~~t~.~, Caregivec El]elf nFamltymember Dslgal~ca~tother Qgrouphoma Employmaat: g3Fullfime QPafffime ~3 Unampioyad ACIM[yIQVeI: oAmb~late~tnde~eradenlly OReo~b'es~tance nNon-am~lo~y oPerfom~s ADL's Inde~ndently DRe~ulre~ ae~i~tance w~ ADL's En,~ronmenu aNomps aPewste~s aMany~teps NulriUana] ~ ~,NmTnal [] Cache~ ~ Obese Yes What waa felt or ~emd up~ InJu'~. Pm-hospital tmab'nent; Q Full spinal Immobllzdon 13 C-Cotla' OSpllnt i:]Pmmumdre~slng QIc~ 13Heat QAcam-ap PMH fi'em tttelie: NONE Previous Sx i~volvtng mu~culo~keletal w~tem and dmz: ~Diabetes aA..thdl~ oOsteopame~ oHemc~hlUag~Cancm': ~lty A~eument RUE Pulses:.DYe~ r-INO Cap. Ref.: r'l<2s. []>2s. LUE Pul~e~:r'lYe~ []No Cap. RE.: RLE Pulses:r-/Yes E]No Cap, Raf,: [~<Zs. r-1>2s. ii1= pulsas:i"lyea r'lNo Cap. Re[: r-l<21. I-1>2a. lvlo~,ion: DYes rlNo Uotkm: OY~ r'lNo MotJ~:/'1Y~s ["iN{3 Senaalion~ []Ye~ [] No ~l~lj~:: [] Yes [::] No Temp. l-lW DC C~or T~I:),~3W I-lC Ca{or Temp.[]W []C Color Temp,~ w r'Ic Apr.~5. 200,3 lli33AM ,INITIAL ASSESSMENT FORM PRIONITY: 3 Urgent DATE; 12/26/2001 Presentation'rime: 14;18 Hel~c Chief Complaint: N0.5498 P. 47/49 Carlisle Regional Medical Center PaUen~ RATHGABER, STEPHANIE E DOB: 08/0911998 ACE: 5YR$ ;DP: FALVO,THOMAS PCP: * NON-STAFF, OUT OF TOWN PHY" T~ge Time: 14:19 Atfl~ll Mode: CARRIED · Weight: 40,0 lbs, 18.2 kgs. LM~ La~tTatanu:;; unk~m~n ANIMAL BITE Brle{ DOG BiTE TO FACE FROM NEIGHBORHOOD DOG ABOUT 45 MiN AGO. Assessment: HEMOFTYSI$ NO FEVER NO NIGHT SWEATS NO WEIGHT LOSS NO ANOREXJA NO KNOW THE ANIMAl. YES KNOW THE ANIMAL'S LOCATIOYES I:~: 9214741 Sex: F MR#: 0001006832 W~s .Emp. R~: Vital Sluns T: 98.9 T P: 120 Regular R: 20 Unlabored BP: 000/'000 o~: % RA P~ln Int~n~ty $=~e: / '10 Pain Lo~J~o~: Unable ~ ~ Pre..Hosplta! Treatment: Peclla~t¢ Pa~ Niacin: N~ G&D Apl3, for Age - NO, Immunization UTD - YES, Height ~t. i~.. Head ~ · Grad,=-, with GRANDPARENT~ NONE Medicines: NONE Addition~ NO~; cm-a~lApr. 1.5. 200~3n.I 1..:'33A. M~:~I~a,t ~ Pa.<er St, Ca~ll~la, PA ,17013 - (717) 2.,45-r~00 DI~ PosrrloN SUMMARY .~ATHC~,a~. S'r~lo' 54,98~ '12/~/0t 4-"41 pm P. 48/49 Patient: RATHGABER. STEPHANIE SS · CURRENT Address; City: Current _ Zip: Age/DOB: Medical Record: Arrival: Disc, h: 12/26/01 4:49pm Disposition: MD ED: Donne Fehmr~bach, D,O, Res/PA/NP: ~J. pa¥ L. Wiener, PA..C Dx #1: Doe Bite lCD-9 #1:E906.0 Dx//2: Laceration. Face (Unsoecifled Slte~ ICD-g #2:873.40 PMD: PMD #1 Dx Engl: ~ ~2'Dx Engl: ~ Mad th~ Auamen§n (Amoxioillin & Clavulanic acid1 Mad #1 Engl; AMOXlClL.EDP Follow-up: YOUR FAMILY I~OCTOR #1 Dx Span: ANIMALBT.SSW ~ Dx Span: LACERATS.SSW FlU MD Ph:: _ F/U D/T: Other In~tr. RETURN IF ANY SIGNS OF INFECTION. KEEP CLEAN AND DRY AND FOI,~Ow VP W~TH THE QUARANTINE OF THE DOG AS WE DISCU.S,.~ED OR YOU NEED TO RETURN FOR RABIES IMMUNIZATIONS. IBUPROFEN A~ DIRECT£r) FOR DISCOMFORTl MY SIGNATURE EELOW INDICATES: > I have re~v~:~ and understood the or~J instructions r~arding my ~urrent medical 13roblem. > I will arrange follow-up care as instructed abOve. > I acknowledge receipt of the written instructions as outlined on this and any pm,/ie, u= pag~..~ I ',~J,' I read and review these inetru~ons. x Patient (or Legal ~uardi~) Signature St=ff (V~tness)Signature Apr,15. 2003 11!33AM No.5495 P. ~9/49 CONDITIONS OF TREATMENT AND ADMI8810H Accoum No. 9214741 DATE & TIME OF ADMII;$10N 12/26/2001 14:18 ~ONTAININ~ FA~, INCOM~ ~ ~N~ IN~RMAT ~ ~Y BE ~ TO ~EC~ON UNDER ~BLE LAW, ~VAN~ ~R~ I~R ~ON TO ~AL O~Y~ :arlisle Hospi:tal -- Emergency Department 40 Parker St. Carlisle, PA 17013 - (717) 245-5500 Patient: RATHGABER, STEPHANIE Disch: 12/26/01 4:49pm MD ED: Donna Fehranbach, D.C. Medical Record: Res/PNNP: Joey L. Wisher, PA-C AFTERCARE INSTRUCTIONS We are pleased to have been abte to provide you with emergency care. Please review these instructions when you return ~ome in order to better understand your diagnosis and the necessary further treatment and precautions related to your .~ondition. Your diagnoses/prescriptions today are: Dx #1: Dod Bite Dx #2: Laceration, Face (Unspecified Site) Med Instr #1: Auqmentin (Amoxicillin & Clavulanic acid) ;:G~neral: lnfo~tion :on 7ANIMAL BITE':iWOUN DS An "animal bite wound" is any injury that results from contact with the mouth of an animal. Most animal bite wounds result from being bitten by a dog or cat. Depending on the circumstances, there may be a bruise, a cut or both. Bruises do not ordinarily require any special treatment. Cuts, on the other hand, need to be thoroughly washed with lots of water and may need to be stitched. This almost always requires a visit to the emergency room. What are the dsks? Most animal bite wounds heal in s week or two, and do not produce any sedous medical problems. There are, however, some dsks: 1. By far, the largest risk is that of infection. An infected animal bite is usually red, warm swollen and tender. It results from small germs (from the animals mouth) that get into the wound and start to grow and multiply. Even small, seemingly insignificant bites often get infected. If not treated dght away, these infecfions can become very serious. Because of the risk of infection, animal bite wounds are sometimes not stitched. 2. Deep cuts sometimes injure blood vessels, tendons or nerves. 3. Depending on the circumstances there nffay be a small dsk of rabies. If there is a significant risk, the emergency room doctor will recommend rabies vaccination (shots). ) If you have a cut or scratch, you should keep the wound clean, dry and bandaged. If the bandage gets dirty or wet, change it right away. Otherwise, you should change the bandage oncE; a day. To change the bandage you should: A) take off the old bandage, B) gently wash the area with a soap and water, C) if you are not allergic to it, using a Q-tip, gently apply a thin layer of antibiotic ointment and D) put on a fresh bandage. 2) If you are not allergic to it, acetaminophen (Tylenol) may help ease the pain. Stronger pain medications are not usually necessary. 3) Tetanus shots are good for 5 to 10 years, provided you have had all your "baby shots" as a child. 4) SEEK IMMEDIATE MEDICAL ATTENTION if:. A) you develop a fever, persistent bleeding, vomiting or B) the wound gets red, warm, swollen or tender or C) you develop red streaks on the skin around the wound or D) you notice a creamy liquid (pus) draining from the wound. 5) If you had stitches, have them taken out in days. General Information on LACERATIONS (CUTS) The word "laceration" is the medical term for an accidental cut in the skin. Lacerations often result from auto accidents, falls or contact with broken glass or other sharp objects. Although .'some lacerations are very large, most are only one to two inches long and can be easily repaired in the emergency (department. Treatment usually consists of: 1. a shot of numbing medication to deaden the area around the wound, 2. opening up the wound and cleaning it with lots of water and 3. stitching the wound back together with special thread. St;'tching the wound usually results in less scarring and quicker healing. What are the risks? Most lacerations heal in about two weeks and do not produce any serious medical problems. There are, however, some risks: 1. When the skin is disrupted by a laceration, germs sometimes get into the wound and start to grow and multiply, producing an infection. These wound infections occur in roughly 1% to 3% of ali lacerations and can result in serious problems. 2. Most lacerations do leave some form of a permanent scar, although it may not be very noticeable. Many scars gradually improve for the first 6 to 12 months after the initial injury. 3. Deep lacerations sometimes go into the blood vessels, tendons, nerves or bone. This can be sedous. 1) Keep the wound CLEAN and dry. Cover it with a plastic bag when bathing. 2) If the bandage gets dirty or wet, change it right away. Otherwise, you should change the bandage once a day, starting the second day after the injury. To change the bandage you should: A) remove the old bandage, B) gently wash the area with soap and water, C) if you are not allergic to it, using a Q-tip, gently apply a thin layer of antibiotic ointment and D) put on a fresh bandage. 3) Most lacerations ars not painful once they have been cleaned, stitched and bandaged. Pain medications are not usually necessary. 4) Tetanus shots are good for 5 to 10 years, provided you have had alt your childhood immunizations ("baby shots"). 5) SEEK IMMEDIATE MEDICAL A'~'ENTION if: A) you develop a fever, persistent bleeding, vomiting or B) the wound gets warm, rsd, swollen or tender or C) you develop rsd streaks on the skin near the wound or D) you notice a crsamy liquid (pus) draining from the wound. 6) Be extra careful if you have a very large laceration, an animal bite, a small puncture wound or a human bite wound. These types of injuries tend to get infected more often. 7) Have the stitches rsmoved in days by a nurse or doctor. Pg 2 Drug Information on AMOXlCILLIN BRAND AND GENERIC NAMES - Amoxil, Apo-Amcxi, Augmentin, Clavuiin, Larotid, Moxilean, Novamoxin, Penamox, Polymox, VWmox. :.i~;i~),~.~'~?~AGE:I~FORMA TION Habit forming? No Prescription needed? Yes Available as generic? Yes Drug class: Antibiotic (penicillin) Treatment of bacterial infections that ars susceptible to amoxiciIiin. How to take: * Tablet or capsule - Swallow with liquid on an empty stomach 1 hour before or 2 hours after eating. * Chewable tablets - Chew well befors swallowing. * Liquid - Take with cold beverage. Liquid form is perishable and effective for only 7 days at room temperature. Effective for 14 days if stored in refrigerator. Don't freeze. When to take: Follow instructions on prescription label or side of package. Doses should be evenly spaced. For example, 4 times a day means before meals and bedtime. If you forget a dose: Take as soon as you remember. Continue regular schedule. VVhat drug does: Destroys susceptible bacteria. Does not kill viruses. Time lapse before drug works: May be several days befors medicine affects infection. ; WARNiNGS:&?RECAUTiONS iI. - Don't take if:. You are allergic to amoxicillin, cephaiosporin antfbiotics, other penicillins. Life threatening reaction may occur. Before you start, consult your doctor: * If you are taking beta-btockere (high blood pressure/other), chloramphenicoi, erythromycins, Ioperamide, paromomycin, tetrecyclines or troleandomycin. * if you are allergic to any substance or drug. Over age 60: You may have skin reactions, particularly around genitals and anus. Pregnancy: Studies inconclusive on harm to unborn child. Animal studies show fetal abnormalities. Decide with your doctor whether drug benefits justify risk to unborn child. Breast-feeding: Drug passes into milk. Child may become sensitive to penicillins and have allergic reactions to penicillin drugs. Avoid amoxicillin or discontinue nursing until you finish medicine. Consult doctor for advice on maintaining milk supply. Prolonged use: You may become more susceptible to infections caused by germs not responsive to amoxicillin. Super infection also a potential. Driving, piloting or hazardous work: Usually not dangerous. Most hazardous reactions likely to occur a few minutes after taking amoxicillin. Discontinuing: Don't discontinue without doctor's advice until you complete pn~scribed dose, even though sYmPtoms diminish or disappear. ~ PO~IBL~'E~-=F~AC~IONiWITH OTHEIR:iSUBSTANCES (Combined Effect) * Alcohol: Occasional stomach irritation. Pg 3 Follow-up: YOUR FAMILY DOCTOR FlU MD Ph: F/U D/T: Other Instr. RETURN IF ANY SIGNS OF INFECTION, KEEP CLE-'AN AND DRY AND FOLLOW UP VVITH THE QUARANTINE OF THE DOG AS WE DISCUSSED OR YOU NEED TO RETURN FOR RABIES IMMUNIZATIONS. IBUPROFEN AS DIREC'rED FOR DISCOMFORT. EKGs and X-Rays: If you had an EKG or X-Ray today, it will be formally reviewed by a specialist tomorrow. If there is any change from today's Emergency Department reading, you will be notified. IMPORTANT NOTICE TO ALL PATIENTS: The examination and treatment you have received in our Emergency Department have been rendered on an emergency basis only and will not substitute for definitive and ongoing evaluation and medical care. A follow-up physician has been designated for you. It is essential that you make arrangements for follow-up care with that physician as instructed. Report any new or remaining problems at that time, because it is impossible to recognize and treat all elements of injury or disease in a single Emergency Department visit. Significant changes or worsening in your condition may require more immediate attention. 'The Emergency Department is always open and available if this becomes necessary. Johns Hopkins Medicine CL IN! C NO TE Name: Rathgeber, Stephanle History: 2-345-67-54 Address: 1912 Bowen Way : Forrest Hill MI) 21050 Visit Date: 02/13/2002 Phone: (410)836-8482 Dob: 08/09/1996 Race: Unknown Location: 31 gA Sex: Female Document No: 91751310030 Primary Provider: Man,on, Paul N Other Provider: Reason for Visit: History of Present Illness: This patient is seen for the residual ora dog bite sustained at Christm~ time when a neighbor's German Shepherd mixed-breed dog from the neighborhood bit her at least 2 t~mes in the face. She sustained lacemtious to the bridge of the nose and the left cheek and the scalp. The scalp has healed the best with a barely perceptible scar. In the cheeks, she had quite a black eye and had a bump in her cheek as well. They have checked with Dr. Kurgansky, and he wished to have her seen for scar revision. She has previously been otherwise healthy. They have been puttiug vitamin E on the area and massaging. Medications: She takes no medications. Allergies: She has no allergies. Major Findings: On exammation, she has a periorbital hemaroma that has been slightly pigmented~ A I -cra laceration is present over the bridge of thc nose and over the left cheek. She has some induration present. The scars are slightly spread. Assessments: April 11, 2003 F~3VAL DOCUMENT Patient: Rathgeber, Stephanie ProblemsfDiagnosis: History # 2-345-67-54 Procedures and Immuni~t. iOIlS: Plans: I provided her a prescription to use for CicaCare, and she is to continue vitamin E massage. She may need a scar revision in the future. I discussed that in detail with the parents. They will let us know their plans. Medication Changes: CC List: DICTATED BY: MANSON, PAUL N, M.D./906/917 D: 02/13/2002 T: 02/:[5/2002 Provider MANSON, PAUL 02/25/2002 'r~LtS DOCUMENT HAS BEEN ELECTRONICALLY SIGNED April 11, 2003 FINAL DOCUMENT Johns Hopkins Medicine CLINIC NOTE Name: Address: Phone: Rathgebcr, Stcphunie 1912 Bowen Way Forrest Hill MI) 21050 (410)836-8482 H/story: 2-345-67-54 Visit Date: 05/15/2002 Dob: 08/09/1996 Location: 318A Race: Unknown Docma~ent No: 55799310030 Sex: Female Primary Provider: Manson,Paul N Other Provider: Reason for Visit: History of Present Hiness: The patient is seen for observation. The scars are fading. The scalp is not pexceptible. The ones over the nose and cheek are receding. It is my opinion that they will recede sufficiently that the2), do not requixe any surgery, but I will see her aga/n in 6 months to 1 year. Thexe is no evidence of any subcutaneou,,~ induration or of any growth restriction. Medications: Allergies: Major Findings: Problems/Diagnosis: Procedures and Imm~mi~aliOUS: April 11, 2003 FIN~IL DOCUMENT Patient: Rathgeber, Stephanie 2 History # 2-345-67-54 Plans: I should see her again in 6 months. Medication Changes: CC List: DICTATED BY: MANSON, PAUL N, M.D./005 D: 05/16/2002 T: 05/17/2002 Provider MANSON, PAUL 05/22/2002 THIS D OCT, IM~NT HAS BE~EN ELECTRONICALLy SIGNED April 11, 2003 FINAL DOCUMENT Johns Hopkins Medicine CLINIC NOTE Name: Rathgeber, 8tephanie ltistory: 2-345-67-54 Address: 1912 Bowen Way Visit Date: 11/06/2002 : Forrest Hill IvlD 21050 Phone: (410)836-8482 Dob: 08/09/1996 Race: Unknovra Lo,cation: 318A Sex: Female Document No: 92857510030 Primary Provider: Manson,Panl N Other Provider: Reason for Visit: The patient is seen again. This is a followup for considered scar revision. History of Present Illness: The only scar that is really prominemt is the one on the nose. The cheek scars while still red and barely perceptible are fiat and one would not thi~lc that any of these scars could predictably be improved. Medications: Major Findings: Problems/Diagnosis: April 11, 2003 F2NAL DOCUMENT patient: Rathgeber, Stepbanie 2 History # 2-345-67-54 Plans: I *hink that her degree of I discussed this with him ia detail. I will see them once more for a final evaluation, iraprovemant is sufficient that one could not offe~ her any ad6itional improvemant by further surgery. Medication Changes: CC List: Dennis KurganSky, M.D.; 2 Nog Avenue, Suite 100; Bel Air, MI) 21014; DICTATED BY: MANSON, PAULN, M.D./005 D: 11/10/2002 T: 11/12/2002 11/15/2002 Provider MANSON, PAUL TH~ DOCUMENT HAS BEEN ELECTRONICALLY SIGNED FINAL DOCUMENT April I 1, 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEVEN E. RATHGEBER and GRACE D. RATHGEBER, as Parents and Natural Guardians of STEPHANIE E. RATHGEBER, a Minor VS. JEAN TAYLOR and JOHN M. WHI'I-rEN No. 2003- 6368 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED PROPOSED ORDER AND NOW, to wit, this day of _ ,2004, upon consideration of the Petition of Steven E. Rathgeber and Grace D. Rathgeber, as parents and natural guardians of Stephanie E. Rathgeber, a minor, and after a hearing thereon, the court hereby approves the ,compromise and settlement of the minor's action for the total sum of Twelve Thousand ($12,000.00) Dollars. It is further ORDERED and directed that ~[he sum of Twelve Thousand ($12,000.00) Dollars received in settlement of the claim of Stephanie E. Rathgeber, a minor, shall be distributed as follows: a. To Griest, Himes, Herrold, Schaumann, LLP, for counsel fees in representing the minor $ 3,000.00 b. To Griest, Himes, Herrold, Schaumnan, LLP, for costs advanced to obtain medical records, colored copies, and Accurint location information 36.87 c. To Stephanie E. Rathgeber, rninor Plainitff $ 8,961.13 It is further ORDERED and directed that the sum awarded to the minor Plaintiff shall be deposited in an account insured by the federal government agency. The account established on behalf of the minor shall contain a provision that no withdrawal can be made from the account until the minor attains her majority, except as authorized by a prior court Order. It is further ORDERED and directed that Plaintiffs shall mark the suit settled and satisfied of record and that they shall execute and deliver to the Defendants and their insurance carrier a proper release acquitting and discharging the Defendants of and from all further payments, claims, suits or demands, by reason of the incident which occurred on December 26, 2001. It is further ORDERED and directed that r)efendants shall reimburse Plaintiffs for all docket and court costs, in the amount of $102.95, incurred in the above referenced matter. BY THE COURT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEVEN E. RATHGEBER and GRACE D. RATHGEBER, as Parents and Natural Guardians of STEPHANIE E. RATHGEBER, a Minor VS. JEAN TAYLOR and JOHN M. WHITTEN No. 2003- 6368 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER AND NOW, to wit, this ._~ day of ~~ ,2004, a hearing on the within Petition for Approval of a Minor Settlement is fixed for the day of ~ ,2004, at ~'" ~ 4 o'clock~r .M. before the undersigned Judge in courtroom number ~ of the Cumberland County Courthouse. Both the minor Plaintiff and her guardians shall be present at the time of the hearing. Jo Au,'/LOi~,COHj,.Ou,:t :BFLL .40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEVEN E. RATHGEBER and GRACE D. RATHGEBER, as Parents and Natural Guardians of STEPHANIE E. RATHGEBER, a Minor VS. JEAN TAYLOR and JOHN M. WHITTEN No. 2003- 6368 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED PROPOSED ORDER · day of AND NOW, to wit, this ,2004, upon consideration of the Petition of Steven E. Rathgeber and Grace D. Rathgeber, as parents and natural guardians of Stephanie E..Rathgeber, a minor, and after a hearing thereon, the court hereby approves the compromise and settlement of the minor's action for the total sum of Twelve Thousand ($12,000.00) Dollars. It is further ORDERED and directed that the sum of Twelve Thousand ($12,000.00) Dollars received in settlement of the claim of Stephanie E. Rathgeber, a minor, shall be distributed as follows: a. To Griest, Himes, Herrold, Schaumann, LLP, for counsel fees in representing the minor $ 3,000.00 b. To Griest, Himes, Herrold, Schaumnan, LLP, for costs advanced to obtain medical records, colored copies, and Accurint location information 38.87 c. To Stephanie E. Rathgeber, minor Plainitff $ 8,961.13 It is further ORDERED and directed that the sum awarded to the minor Plaintiff shall be deposited in an account insured by the federal government agency. The account established on behalf of the minor shall contain a provision that no withdrawal can be made from the account until the minor attains her majority, except as authorized by a prior court Order. It is further ORDERED and directed that Plaintiffs shall mark the suit settled and satisfied of record and that they shall execute and deliver to the Defendants and their insurance carrier a proper release acquitting and discharging the Defendants of and from all further payments, claims, suits or demands, by reason of the incident which occurred on December 26, 2001. It is further ORDERED and directed that Defendants shall reimburse Plaintiffs for all docket and court costs, in the amount of $102.95, incurred in the above referenced matter. J=