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HomeMy WebLinkAbout09-4141LundyLaw BY: HERBERT L. OCKS, ESQUIRE IDENTIFICATION NO.: 04137 ATTORNEY FOR PLAINTIFFS 19th FLOOR 1635 MARKET STREET PHILADELPHIA, PA 19103-2297 (215) 567-3000 E-Mail Address: hocks(a,lundylaw.com COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA IN RE: ESTATE OF DAEKWON SHEPPARD, A MINOR NO. 0 9- yI 'i t! T-?-- PETITION FOR LEAVE TO SETTLE OR COMPROMISE MINOR'S ACTION TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Petition of Daekwon Sheppard, a minor, by his parent and natural guardian, Sharral Hall Mwangi, and attorney, Herbert L. Ocks, Esquire, respectfully represents: 1. Petitioner is Daekwon Sheppard, a minor, by his parent and natural guardian, Sharral Hall Mwangi. 2. The minor was born on 06/29/1997 and his social security number is 028-80-8500. 3. The minor resides with his parent and natural guardian, Sharral Hall Mwangi, at 825 Factory Street, Carlisle, PA, 17013. 4. A guardian was not appointed for the minor. 5. The minor's mother and father are Sharral Hall Mwangi and James Mwangi who reside with the minor at 825 Factory Street, Carlisle, PA, 17013. 6. The Defendant is Theresa Nist, an individual, residing at 809 Factory Street, Carlisle, PA, 17013. This case settled with the defendant's insurance company, GEICO Insurance Company. 7. On 04/19/2008 the minor sustained the following injuries at the following location: The minor was a restrained rear passenger in a 1997 Ford Escort being operated by the Defendant which was travelling too fast on Burgners Road in Lower Frankford Township, Cumberland County, PA. The vehicle travelled off the roadway, overturned and came to rest on its roof in a creek. Following the accident the minor was taken by ambulance to the Emergency Room at Carlisle Regional Medical Center. As a result of this incident, the minor sustained acute moderate cervicothoracic sprain/strain, acute moderate lumbosacral sprain/strain and an abrasion on the left side of the neck. The minor treated with his physician from May 24, 2008 to August 18, 2008. 8. Attached hereto is a copy of the Emergency Room report from Carlisle Regional Medical Center dated April 19, 2008, and copies of the Office Notes of Boland Chiropractic & Sports from May 24, 2008 to August 18, 2008, the date of discharge. 9. Attached hereto is a statement, under oath, of the minor's parent and natural guardian certifying the physical and/or medical condition of the minor, as well as the parent and natural guardian's approval of the proposed settlement and distribution. 10. The minor is under sixteen (16) years of age and no written approval is necessary. 11. The following settlement has been proposed: Daekwon Sheppard, a minor - $6,500.00 12. Counsel is of the professional opinion that the proposed settlement is fair and reasonable and adequately compensates the minor for the injuries sustained from which he has made a full and complete recovery. Counsel is of the professional opinion that there is no question of liability in this case as the minor was a passenger and liability is not an issue. 13. Counsel has incurred the following expenses for which reimbursement is sought: Court Filing Fees Investigation, Photographs, Police Report Medical Records TOTAL EXPENSES $ 78.50 Travelling Expense 610.00 8.00 67.69 $764.19 14. The following costs have been incurred by or on behalf of the minor and must be paid from the proceeds of the settlement: None except those listed in Paragraph 13 15. The Department of Public Welfare does have a claim or lien against the minor in the amount of $1,001.00. Attached hereto is a copy of a letter from the Department of Public Welfare dated March 9, 2009, 2009, agreeing to reduce their lien and accept the payment of $640.53. 16. Counsel requests a fee in the sum of $1,433.95 which is 25% of the net settlement payable to the minor. A copy of the Contingent Fee agreement is attached. 17. Counsel has not and will not receive collateral payments as counsel fees for representation involving the same matter from third parties (i.e. subrogation). 18. The net settlement payable to the minor (after deduction of costs and attorneys fees) is $3,661.33. WHEREFORE, Petitioner requests that he be permitted to enter into the settlement recited above and that the Court enter an Order of Distribution as follows: A. TO: LundyLaw (Reimbursement for Costs) B. TO: LundyLaw (Counsel Fee) C. TO: Department of Public Welfare (Lien of $1,001.00 reduced to $640.53) D. TO: Daekwon Sheppard, a minor, in a restricted account not to be withdrawn before majority or upon prior leave of the Court. TOTAL SETTLEMENT LundyLaw $ 764.19 1,433.95 640.53 3,661.33 $6,500.00 BY: L 0,A- Herbert L. Ocks, Esquire Attorney for Petitioner VERIFICATION Sharral Hall Mwangi hereby states that she is the Petitioner in the above-action and verifies that the statements made in the foregoing Petition for Leave to Settle or Compromise a Minor's Action are true and correct to the best of her knowledge, information and belief. She understands that the statements therein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. C?et?1? 4Sharr Hall Mwangi, as p e t and na guardian of Daekwon Sheppard, a minor LundyLaw BY: HERBERT L. OCKS, ESQUIRE IDENTIFICATION NO.: 04137 19th FLOOR 1635 MARKET STREET PHILADELPHIA, PA 19103-2297 (215) 567-3000 E-Mail Address: hocks(a),lundylaw.com ATTORNEY FOR PLAINTIFFS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA ORHPHANS' COURT DIVSION IN RE: ESTATE OF DAEKWON SHEPPARD, A MINOR I NO. CERTIFICATION OF COUNSEL Herbert L. Ocks, Esquire, certifies that he is counsel for Plaintiffs herein and that in his professional opinion, the proposed settlement offer is fair and reasonable, in light of all the circumstances in the case and there has been a complete recovery. Furthermore, counsel is of the professional opinion that there is no question of liability in this case as the minor was a passenger and liability is not an issue. LundyLaw BY: I ?'? ? , 0J.'- Herbert L. Ocks, Esquire Attorney for Petitioner(s) CERTIFICATE OF SERVICE I hereby certify that I have this date served a copy of the foregoing pleading by first class mail, postage pre-paid, upon all counsel of record as follows: Mr. Mark Heberger Claims Department GEICO Indemnity Company One Geico Boulevard Fredericksburg, VA 22412-0004 Tele. No.: 800-841-1003 ext. 4251 Driver: Theresa Nist Insured: Charles Nist Claim No.: 034426909-0101-029 LundyLaw Herbert L. Ocks, Esquire Attorney for Petitioners Date: June 15, 2009 ? ADMISSION M&DICAL CII RECORD 361 Alazandar Spring Road a Q4rin,19, PA 170154,29 • (717) 249.1212 :... :: < M P ADMIT DA /TIM ROOM N5 - F AGI: -:93.9$554. 000105738 A 04/19/2008 18:51 0000 El P 10 DAT OF BIRTH 06/2E9/1997 M 2A Ms L ATI N PROGflAM T S l S $PI33RD I)AERWO D P R E :, It B25 ?,?10? ST 028-80-8500 STUDENT HAMZLTON MPL vER N N CAR:L3 SLE PA 17Ek13 E ER T US (717)254-1541 UNTY CUMB HALL SHARRALL , V. , 825 FACTORY ST HOMEMAKER 017-54-3828 A R CARLISLE PA 17013 US (717)254-1541 LAn IP T A i EMERGENCY C NTACT NAME EMERGENCY CONTACT MOTHER RESP PHONE EMERGENCY CONTACT RELA71pNSHIP TO PATIENT MAANGI, JAMES (508)410-5085 FRIEND PRIVACY ?Y ?N ME IV QV SIN AD . BY Y KMK 0:01oo.oaczv GR P OU NUMB A R T77 7T 'R I GROUP R R AME :A. ' AUTHORIZA MLM )7.: G GROUP AIUMBEFI GAO AUTHORIZATION j;; FRIERSON, PATRICIA L DR. FAMILY ! I ARE NONSTAFF, FAMILY PRY :0:.? CXAGN0515 i SIGNS III SYMPTOMS ?C. MVA--MINOR INJURY ACCIDENT NO FAULT 04/19/2008 PRINCIPAL DIAGN0619 (TM --I'- es[abllshad after study to be chiefl otGasioninp [he "."On of the patient to the HOSPITAL for carol y roaponeibk for . COMPLICATIONS COMORBIDITVIIESI PRINCIPAL PROCEDURE NMA7110 ml MEDICAL RECORDS COPY I??AAI?N?I?I?A? iuvr', - ' ` Carlisle Re Iona! Medical Center ?' fsPe e: :.. Date In:04119/2008Pros Time: 18:51 Pt#:9399554 MR#:0001057387 Triage Time 18: 51 Triage Note: Name: SHEPHERD, DAEKWON Arrival Mode: BLS T:97.7 PO PT IN MVA. CAR FLIPPED AND Age: 10YRS DOB: 06/29/1997 Sex: M Wt:ibs: 81 kgs: 36.8 P:94 Regular WENT INTO A CREAK. R:20 Unlabored RESTRAINED DRIVER. NECK PAIN. PCP:` NON-STAFF, FAMILY, PHY' LAC TO NECK. NO COMPLAINTS. EDP:•FRIERSON_MD, PATRICIA L. BP-132/061 NO LOC. SEVERE DAMAGE TO tCief Complaint MVA-MINOR INJURY 02 Sat 100 % NL / hypo CAR. Pain/Location: 01Denies Paln Wit Level 1-9 =1-3 elsrtter4s 1.w 1614 ?{ ekm :. , = R!ris Lave15? 5 elrftreMls cam.. - _. Souroe: t t family spouse EMS nsg. home other: ................. Ltd BY poor historian dementia severity hearing intoxicated set: m' days wks mths ago rarity: mild mod sev 110 current _/10 max *of Vehicle: auto s bicycle moped motorcycle auto vs. pod s s p _y-•• ....... ai a de io ed--' reload }iekinei..................... of Collision: multi vehicle e v . fell asleep t control ' of Impact: front back right left Position in Vehicle: driver asseng t rear cftY -- Dam otiti oderate high - minimal / e severe er Iss m to ejected extricated assisted out of vehicle fatalities otion painlsxs: head Few a /lower c es men u m y: right /left lower extremity: rig LOC ec !min remember/ personnel /transfer to ED/ remains unconscious ociated SUS: dY ess: 511 left pares e / left nausea / su chanoes lacaraikmnrs r"ru ei rnsiory: , -r , .. L' CIL,J d/ ?J- /-, t' ............... -l ? 1 o? C/-" KVS: 1.1606111.4 = i syslem Le4e1 a .4 -9 sysfertis l+4ya l 15 :¦.1 W ayste?x General Eyes ENT Respiratory Cardiovascular (;aatrointsstinal Genitourinary Fever / chills Weight loss Visual Changes Redness Sore Throat H Shortness of Breath Chest Pain Nausea / Vomiting Dysurie General Weakness Dryness oarse Voice Epistaxis Cough Con estion Palpitations P Diarrhea Frequency Polyurea Diplopia I 4 Auditory Acuity g Hemoptysis ND Orthopnea Constipation Rectal Bleeding Vaginal Bleeding Vaginal Discharge Polydipsia tching Nasal Drain/Gong. DOE Black Stool Penile Discharge Musculoskelsial Neurological Psychological Skin Immunilogicai owed Joint Pain Joint Swelling Syncope Headache Anxiety Depression Rash Pr iti Recurrent H All other systems negativ Neck Pain Focal Weakness Hallucination ur c Lesions HIV/AIDS Anaphylactlc Rxn ue to: ALOC acuity Back Pain Paresthesia Insomnia Bruising dementia poor historian Myaigtas Confusion Stress Bleeding intoxicated P"E f=smlJ '90 610/ Wx: level 1,3 w orie Levei'4 T sectloh; . , I vV11 !? 2.3 sedfons ' Past Medical History: Additional Past Medical History: Medications: Past Surgical History: None CABG y TSH/BSO Other: Family History: N CAD / MI OM CA CVA Reproductive History: G_ P_ A_ Last Menstrual Period: Menses History: Regular ! Irregular / Post-partum / Pre-menarch Last Tetanus: social Mstory. Tobacco: Y _PPD / N / Quit Living: M / S 1 D / Ak Alcohol: Denies / Social / Heavy ! Alcoholic Substance Abuse: Other: _S LRvel?t:.`5.7 s 04 8 Leve12-3: 2.4 systems yetprhs Level g`S+:sy ma . ' indicates system examined sod negattw General: Distress: k_yffl mild moderate severe well nourished no evidence of trauma 'Elf cachetic obese disheveled dehydrated chronic Illness nsy, home pt, malnourished other HENT:: / AT pharynx NL ears NL nose NL tenderness: maxillary: R / L frontal: R / L nasal drainage: clear / purulent ear canal: R / L erythema / obscured R / L erythema bulging perforated pharynx: exudate erythema abscess other: Eyes: • PERRL EOMI conjunctiva NL NL fundus R pupil: _ mm L pupil: _ min conjunctiva: injected / drainage R / L other .......vywrrar Mwuruar VCnter Name: SHEPHERD, DAEKWON Date In:04/19/2008 MR#:0001057387 Pt#:9398554 Physical ke cont. Level 2-3:24 systems Lave) 4: 5-7 systems Level 5: 8+ systems NL• i dicat system examined and negative Nock: NL• non-tender painless ROM ea m' ' ' non-tender ", C•collar in place spasm muscle tender to palpation: R / L bony tender to palpation: R / L limited / painful ROM Chest: RL chest wall non-tender NIL excursion/ expansion no retractions ` der to palpation: R / L chest wall sternum retractions flail chest subcutaneous emphysema other: CV.• • RRR no murmur no gallup PMI NL pulses NL chycardic bradycardic irregularArregular rhythm extra systoles murmur /8 systole/diastole pulses: decreased/ absent R I L carotid femoral dorsatis pedis radial uinar other: aspiratory .• no respiratory distress breath sounds NL effortless unequal I decreased sounds crackles wheezes rates rhonchi labored stridor retractions cheyne stokes other . Abdomen: appearance NL BS NL soft non-tender rectal NL guiac negative no organomegaly - t c 7 e BS: hyper/ hypo / absent guarded tender mass/pulsatile heme + stoBS: hypo /absent guarded tender home + stool /blood Back: ROM NL no CVAT tenderness / bil CVAT tenderness: bony/ muscle dorsal lumbar sacral coccyx Exfremi'Bes: non-tender full ROM no edema / erythema pelvis stable hips non-tender sho ened / ext. rotated: R / L effusion: R / L Omited ROM: R / L other !dr warm dry color NL no rash hof. cold diaphoretic cyanotic pallor edema erythema acchymosis other: Neur'o: • AA&Ox3 CN's NL (2-12) motor l sensory NL cerebellar function NL DTRs symmetric lethatgic somnolent obtunded disoriented R / L CN deficit other: Psych: affect NL behavior NL anxious hostile flat affect depressed combatative psychosis other OU. NL• ext genitalia NL no urethral bleeding no lesion no edema deferred urethral blood other: L=-ac A=Abraslon E-Echymosis Medical Decision Makin NL I except >-< UA: NIL / except C-Spine: _ Interpreted by EDP 1 /2 / 3 Views WBC LE - neg acute _other ROC Blood CXR: Interpreted by EDP _ NAD NL !except - preg Screen: urinelserum: nag /pos +-f-< NAI Infllitrete _ Tox Screen: nag /pos ALT Amy Trop PT Abd: NSBGP obstruction - - EKG: neg / pos AST Lipase CKMB INR Head CT: Other / Procedures: Consultation: Clinical Course & Re-evaluation: Time: . Disc with Dr. Mods: Time: Improved / Worse / Unchanged will _"a patient In office _ admit _ see in consult Time: Improved / Worse / Unchanged Time: . Disc with Dr. IVF: p Patient re-examined will see patient in office _ admit _ see in consult E3Cdtical care: 30-74 minutes / 75-104 minutes ?See procedure note ?See addendum Clinical l g lon: Dls leson: 1. _t c-st?r? 'L tom. Time: 2. '\l., Discharge: Home NH PsychFac Jail 3. ,/ C, v? ?? Admit: Floor ICU PCU Obs OR Tole Psych Peds ?Orders written 4. Transfer: Facility: Rcv Physician: 5. AMA LWOT DOA Expired gTransfer forms competed C diti St bl on on: a e Satisfactory Improved Critical Guarded Emergent Non-emergent Instructions: Follow up with: O Prescription(s) given: _ Follow up care discussed with: patient family spouse other. ? PMD Additional Instructions: ? Doctor QED ?Other In_ day(s) 0 AM Signatures: PA/ARN MDlDO k) Pro-MED Complegow - (circb r oarwes. t naa aiasn Per ?? octo?) Rev. Wiwi ORDAR PROCEDURE FORM ORTHOPEDIC EMERGENCIES Date In: 4/19/2008 Time: Name:SHEPHERD, DAEKWON Age: IOYRS DOB: 06129/1997 Sex: M Carlisle Regional Medical Center Pt#:9399554 MR#:0001057387 EMERGENCY DEPARTMENT ONGOING NURSING ASSESSMENT Name: Carlisle Regional Medical Center SHEPHERD, DAEKWON Pt#:9398554 Age:10YRS D08:06129/1997 Sex: M MR#:0001057387 Date: 4/19/2DDS EDP: 'FRIERSON MD, PATRICI PCP:' NON-STAFF, FAMILY, PHY' te?a:prls?tep?t?g} :.. ..'::'•'. Airway Clearance, Ineffective Communication Impaired Infection, Potential Self Care Deficit Anxiety ?oping, Ineffective -injury, - skin Integrity Impairment Breathing Patterns, Ineffective Fluid Volume, Alteration in -`Knowledge Deficit -'ihought Processes Im i -C di d O , pa re ar ac utput, Decreased Gas Exchange, Impaired Mobility Impaired Th fort, Alteration in Fiyperlhennie Fever ought Processes. Alteration in N C an- ompliance Tissue Perfusion, Alteration in Other - Other Not Nol Mq met Nx Met Mot lot MN Met lot O FB REMOVAL O IMMOBILIZATION 1 PROPER ALIGNMENT O IMPROVEMENT OF BREATHING O BLEEDING CONTROL P DECREASE 1 PREVENT SWELLING O PAIN CONTROL AIN STABLE HOMEOSTASIS O STABILIZE PATIENT IN DISTRESS O ALLEVIATE NN O meet ENVIRONMENTAL NEEDS O MAINTAIN SKIN / TISSUE INTEGRITY ? meet PSYCHOSOCIAL NEEDS O FEVER CONTROL q PREVENT FURTHER IN,1URY O meet SELF CARE ABILITY NEEDS O DECREASE ANXIETY 13 MAINTAIN / IMPROVE CIRCULATION O meet EDUCATIONAL NEEDS O SAFETY IN THE ED p INFECTION CONTROL O after Mt: N = dotxxnentalkin In nurses rotes. other 'codes' per Hospital Policy. Tlfr?s fiut#!? Proprtrq Obs , g T P SIP' NO / CWdleL - ; K?UU LS? r L ILIW 010A L ol I 1 LA? I J, _ wV"-J')L' .Q ri l Discharged in care of: A b /C m p 13Strett3 Carried Disch a instructions given to rbalized understanding --- - t: Room #: to Dr. Ready for Room Time: _v R rt tied at and given to T ered to D Transfer Verified R o called at and given to a L without treatment O Left Against Medical Advise - ndition at Disposition: ?Improv Stable aSerious DExpired Pain Scale: Pain Location: --- Patient nt repo rts that pa' is;?0 Im rovedR % Pnvm Dis position Vita T 11 l ? Dispos ition Da Nurse. Ci Rev. U3!OSrD4 ? EMERGENCY DEPARTMENT SMENT SHEPHERD, DAEKWON Carlisle RegioPIC93 Medical 4 Center. PEDIATRIC NURSING ASSES Name: Age: 10YRS DOB: Q8129/1987 Sex: M MR#: 0001057387 Date In:4/19/2008 Time: EDP: `FRIERSON_MD, PATRICI PCP:' NON-STAFF, FAMILY, PHY' SAectWe Notes: n 11 - , Quality:OSharp bibull OCramping OBuming OAching a Rating Mode of nset: O Sudden O -Gradual O Intermittent g Scale: Onset: Date: Time: Duration: WONGIBAKER FACES RATING SCALE Onset > 24 hrs. medical attention was s - t90? Qp .?. ?, ought? pNo pYes Date: Radiating: ONo OYes (sp.?&y1 Caregiver: OParents OMother OFather OOther. Accompanied by: Appearance: OClean OUnkempt pother Activity level: OAwake OPlayful ?Smlies / Laughs oOther ORtktlesa' . t?Ohalfetttei! OUnr.. _ aponsiti!s - Fgpl? 'sii:e .acid (811110011;1:r Capillary Refill. a <2 Secs (Normal) Turgor: O Normal O Decreased Pulses: L Radial: ? Present ? Absent L Pedal: ? Present ? Absent Effort Cough: Q None Lung Sounds: ?Clear OWheezes OR OL OR pL O>2 Secs (Delayed) R Radial: ? Present ? Absent R Pedal: ? Present ? Absent u i.N.W.W O WMPIQry u y0veraty}, - O Rr#rdd(ono 17 9Vldor ?? tiae`? Fiarinyl .. O Productive a Non-Productive ?Rhonchl0Crackles [3 Diminished DAbsent OR OL OR OL OR (31. OR 13L Environment: O No steps O Few steps O Many steps Nutritional status: ONormal a Cachetic O Obese Religious / Cultural preference: ONone t%MC1fy Best leam by: (pt / caregiver) OVerbal pwrltten ORetum demo Learning Barriers: Abdo oft O Flat 1 Rigid O Distended P,ffon-Tender O Tender (Area) Bowel Sounds: OPresent ODecreased OAbsent Elimination: O Normal OConstipation ODiarrhea # of Stools: Voiding: pContkrent Olncwntinent' ODiaper ODysuria 0Frequency Color: Other findings: Lacerations / Abrpslons ! qo9tusIons Location: , . Size: Bleeding: 13 Absent Pr ent El Scant O erate eavyOPulsating ROM: r1WNL O Decreased OAbsent Edema: O Absent 01+02+132+ DeformityO Yes C No Scars: o Yes O No Distal pulses: O Absent O Present WIM -77777;77 13NEW BORN Asw o t Month ?INFANT i -12 Month. Language! ?Cries Often OSmiles ?Coos / Gurgles OBabbles Bom at Term:OYes ONo Delivery: OVaginal OC-Section Diet: O Breast Feed OFormula type: Uses: OBottle OSpoon OCup Elimination: O3 - 8 stools a day Other. _ Acttvity: Lifts Head: OYes ?No Sits up: ?with help ? without help Crawls: ? Yes ? No Teething: ? Yes ? No Observation of Interaction with caregiver is ? Appropriate OSee Nursing Assessment ?TODDLER Ao. t-s Y"m ? Pre-School Ay. a - 5 Y.ers Language: OFew Words ?Sentences ? Easily Understood Diet: OFNer Foods ?Regular Diet OFeeds Self Uses: OBottle 0 Cup Teething: ?Yes ?No Elimination: 01 - 2 Stools per day ODiapers OTollet trained OWets bred: O Rarely 13 Occasionally OFrequently Activity: Walks: ? Yes ? No OWalks with assistance OWalks Independently Observation of interaction with caregiver is OApproprbate OSee Nursing Assessment ?SCHOOL AGE A" o-11 You. ?ADOLESCENT Age +s - v Y. Reached Puberty: ? Yes ONo Learning disability: O Yes School grade: Diet: E3 Eats 3 meals/day OEating disorder: (specify) WearsBraces pYes ONoT Elimination: ? N bl - o pro em reported ? Wets bred: ORarely ?Occasionally OFrequenuy Social Habits: Smokes O Yes ? No Uses Alcohol: ? Yes ?No Uses Dru Yes ONo ? Observation of interaction with caregiver is ? Appropriate OSee Nursing Assessment Vital Signs: 16:51 T: 97.7 P: 94 Regular R: 20 BP: 1321061 Nurse Sionat INITIAL ASSESSMENT FORM Carlisle Regional Medical Center PRIORITY: 3 • Patient: SHEPHERD, DAEKWON Pt#: 9399554 Urgent DOB: 06/29/1997 AGE: 10YRS sex: M MR#: 0001057387 EDP: *FRIERSON_MD, PATRICIA L. DATE: 04/19/2008 PCP: ' NON-STAFF, FAMILY, PHY' Worker's Comp: Emp. Referred: Presentation Time: 18:51 Triage Time: 18:51 Arrival Mode: BLS Height: Weight: 81.0 Ibs. 36.8 kgs. LMP: Last Tetanus: Acc By: MOTHER Chief MVA-MINOR INJURY Complaint: Vital Sion Brief PT IN MVA. CAR FLIPPED AND WENT INTO A CREAK. RESTRAINED DRIVER. NECK PAIN. LAC Assessment: TO NECK. NO COMPLAINTS. NO LOC. SEVERE DAMAGE TO CAR. NIGHT SWEATS NO HEMOPTYSIS NO WEIGHT LOSS NO FEVER NO ANOREXIA NO SAFETY NO TRAVEL NO IMMIGRATION NO RESTRAINED YES DRIVER NO AIRBAG DEPLOYED NO T: 97.7 PO P: 94 Regular R: 20 Unlabored BP: 1321061 02: 100 % RA Pain intensity Scale: 0 110 Pain Location: Denies Pain Pre-Hospital Treatment: Pediatric G&D App. for Age - YES, Immunization UTD • YES, Height ft. in., Head Circ. - Grade -, with MOTHER Assessment: Past Medical DENIES History: Allergies: NKDA Medicines: DENIES Nurse Signature: VLB Rev 0518104 Carlisle Flegional Medical Center -- Emerqencv Department 361 Alexander Sprinq Rd Carlisle, PA 17013 -- (717) 960-1695 Shepherd, Daekwon 4119108 7:18pm 1057387 DISPOSITION'SUMMARY Patient: Shepherd, Daekwon SS #: Age/DOB. CURRENT Address: Current Ph: City: Zip: Medical Record: 1057387 Arrival: 4/19/08 7:18pm Disch: 4/19/08 7:19pm Disposition: MD ED: Kathy Ferraro, MD PMD: ReWPA/NP: Kevin Gold, PA-C PMD Ph: Dx #1: Motor Vehicle Accident-Passenger ICD-9 #1: E819.1 #1 Dx Engl: MOTORVA.ESW #1 Dx Span: MOTORVA.SSW Dx #2: Abrasion, Neck ICD-9 #2.910.0 #2 Dx Engl.- ABRAS.ESW #2 Dx Span: ABRAS SSW uw¦ Follow-up: YOUR FAMILY DOCTOR F/U MD Ph: F/U DR: as needed Other Instr: MY SIGNATURE BELOW INDICATES: > I have received and understood the oral instructions regardinq my current medical problem. > I will arranqe follow-up care as instructed above. > I acknowledge receipt of the written instructions as outlined on this and any previous page(s). I will read and review these instructions. ?/ } X anent (or Leqal Guardian) Signature F Staff ness) Si lure PATIENT CONTACT RECORD Emergency Contact Please list the person(s) you would like us to contact in the event of a medical emergency Name: Relationship to Patient: Home Phone: Work Phone: Cell Phone: 2. 3. Patient Right and Responsibilities 2natients Only) I have received a statement of the Patient's Rights and Responsibilities. (minw tan) Patient Confidentiality (Inpatients Only) Dear Patient, To protect patient confidentiality, the following personal identification number has becn assigned to you. Medical information will not be disclosed or discussed with anyone who cannot ftimish this number to our staff; -.qL (Personal Identification Number) i of Patient/Responsible Pay 0, kkA (4 Ig -()g Date GI?NAL . (717) 249-1212 PATiEPrr LaseL MCDIChL crw re, No 1609 0312008 White (Medical Record Yellow (Patient) Permission to discuss details of your account: Yes Name: Relationship to Patient: Home Phone. Work Phone: Cell Phone: Permission to discuss details of your account: Yes No Patient is a resident of a nursing home: _ .. no If yes, name of facility No ME *1 CAL 60 k a 351 Alaxandar Sping Road* Carts", PA 170158129 • (717) 249-1212 CONDITIONS OF TREATMENT AND ADMISSION PATIENT'S NAME SHEPHERD, DAEKWON ATTENDING PHYSICIAN FRIERSON, PATRICIA L ACCOUNT No. 9 3 9 9 5 5 4 DATE 6 TIME OF ADMISSION 04/19/2008 1$:51 CONSENT TO HOSPITAL CARE AND TREATMENT I AM PRESENTING MYSELF FOR EMERGENCY SERVICES OR ADMISSION TO THE HOSPITAL AND I VOLUNTARILY CONSENT TO THE RENDERING OF SUCH CARE, INCLUDING DIAGNOSTIC TESTS AND MEDICAL TREATMENT, BY AUTHORIZED AGENTS AND EMPLOYEES OF THE HOSPITAL, AND BY ITS MEDICAL STAFF, OR THEIR DESIGNEES, AS MAY IN THEIR PROFESSIONAL JUDGEMENT BE DEEMED NECESSARY OR BENEFICIAL TO MY WELL BEING. I ACKNOWLEDGE AND UNDERSTAND THAT MANY OF THE PHYSICIANS ON THE STAFF OF THIS HOSPITAL, INCLUDING THE ATTENDING PHYSICIAN(S) NAMED ABOVE, AND RADIOLOGISTS, ANESTHESIOLOGISTS, PATHOLOGISTS AND EMERGENCY PHYSICIANS, ARE NOT EMPLOYEES OR AGENTS OF THE HOSPITAL, BUT RATHER ARE INDEPENDENT CONTRACTORS WHO HAVE BEEN GRANTED THE PRIVILEGE OF USING THE HOSPITAL FACILITIES FOR THE CARE AND TREATMENT OF THEIR PATIENTS. I AGREE TO ACCEPT THEIR CARE EVEN THOUGH THEY ARE NOT EMPLOYED BY THE HOSPITAL. I UNDERSTAND THAT THE EXAMINATION AND TREATMENT THAT I RECEIVE ON AN EMERGENCY BASIS IS NOT INTENDED AS A SUBSTITUTION OR REPLACEMENT FOR COMPLETE MEDICAL CARE. CONSENT TO RELEASE INFORMATION 1 HEREBY AUTHORIZE THE HOSPITAL TO DISCLOSE TO INSURANCE COMPANIES, INCLUDING WORKERS COMPENSATION CARRIERS, OR OTHER PARTIES THAT MAY BE LIABLE FOR ALL OR PART OF THE HOSPITAL CHARGES, ALL OR PART OF MY HOSPITAL RECORDS AS MAY BE NECESSARY (INCLUDING ANY TREATMENT FOR ALCOHOL OR DRUG ABUSE OR DEPENDENCE), TO DETERMINE BENEFITS ENTITLEMENT AND PROCESS PAYMENT CLAIMS FOR HEALTH CARE SERVICES PROVIDED. MEDICARE CERTIFICATION RELEASE I CERTIFY THAT THE INFORMATION GIVEN BY ME IN APPLYING FOR PAYMENT UNDER THE TITLE XVIII AND TITLE XIX OF THE SOCIAL SECURITY ACT IS CORRECT. 1 AUTHORIZE ANY HOLDER OF MEDICAL OR OTHER INFORMATION ABOUT ME TO RELEASE TO THE SOCIAL SECURITY ADMINISTRATION OR ITS INTERMEDIARIES OR CARRIERS ANY INFORMATION NEEDED FOR THIS OR A RELATED MEDICARE CLAIM. I REQUEST THAT PAYMENT OF AUTHORIZED BENEFITS BE MADE ON MY BEHALF TO THE HOSPITAL OR TO THE PHYSICIAN WHO ACCEPTS ASSIGNMENT. PERSONAL EFFECTS AND VALUABLES I UNDERSTAND THAT THE HOSPITAL SHALL NOT BE LIABLE FOR THE LOSS OR DAMAGE OF ANY PERSONAL EFFECTS OR VALUABLES (MONEY, JEWELRY, GLASSES, DENTURES, DOCUMENTS, CLOTHING, ETC.) UNLESS SUCH ITEMS ARE DEPOSITED IN THE HOSPITAL SAFE. THE HOSPITAL WILL NOT BE LIABLE IN EXCESS OF $50 FOR THE LOSS OR DAMAGE OF ANY PERSONAL EFFECTS OR VALUABLES DEPOSITED WITHIN THE HOSPITAL SAFE. ABOUT YOUR BILL I UNDERSTAND THAT I WILL RECEIVE A BILL FROM THE HOSPITAL FOR PROVISION OF THE HOSPITAL SERVICES, INCLUDING STAFF AND EQUIPMENT, AND FOR ANY SUPPLIES OR MEDICINES UTILIZED. I WILL ALSO RECEIVE A BILL FROM ANY PHYSICIAN WHO PROVIDES PROFESSIONAL CARE TO W. FOR EXAMPLE. I MAY RECEIVE A SEPARATE BILL FROM ONE OR MORE OF THE FOLLOWING TYPES OF PHYSICIANS WHO RENDER SERVICES TO ME: MY ATTENDING PHYSICIAN OR PERSONAL PHYSICIAN, EMERGENCY ROOM PHYSICIAN, RADIOLOGIST, ANESTHESIOLOGIST, PATHOLOGIST, OR ANY OTHER SPECIALIST. INSURANCE ASSIGNMENT I HEREBY ASSIGN TO AND AUTHORIZE THE HOSPITAL AND PHYSICIANS INVOLVED IN CARE DURING THIS PERIOD OF ILLNESS OR TREATMENT (HEREINAFTER 'PHYSICIANS'), OR THEIR DULY AUTHORIZED ASSIGNS TO TAKE ALL NECESSARY STEPS, WITHOUT LIMITATIONS, TO ENSURE THAT ANY INSURANCE BENEFITS OTHERWISE PAYABLE TO ME OR MY ESTATE ARE PAID DIRECTLY TO THE HOSPITAL OR PHYSICIANS. THIS ASSIGNMENT OF INSURANCE BENEFITS INCLUDES BUT IS NOT LIMITED TO BILLING INSURANCE, FILING PETITIONS, FILING SUIT, IN MY NAME OR ON BEHALF OF THE HOSPITAL OR PHYSICIANS, FILING PROOFS OF CLAIM, FILING PROBATE CLAIMS AND FILING GRIEVANCES AND ALL OTHER SIMILAR PROCEDURES, AS MAY BE AMENDED FROM TIME TO TIME WITH THE STATE DEPARTMENT OF INSURANCE. I ALSO AGREE TO PROVIDE AND SIGN ANY OTHER DOCUMENTS THAT MAY BE REASONABLY NECESSARY TO ACCOMPLISH ANY OF THE OTHER PURPOSES. STATEMENT OF FINANCIAL RESPONSIBILITY 1 UNDERSTAND THAT 1 AM FINANCIALLY AND LEGALLY RESPONSIBLE FOR CHARGES NOT COVERED IN FULL BY ANY THIRD PARTY. 1 FURTHER AGREE THAT SHOULD I NOT PAY THE BALANCE WITHIN THIRTY 130) DAYS AFTER THE DATE OF DISCHARGE, MY ACCOUNT WILL BE CONSIDERED DELINQUENT. I AGREE TO PAY COSTS OF COLLECTION, INCLUDING REASONABLE ATTORNEY'S FEES AND COSTS, COLLECTION AGENCY FEES AND COSTS, AND INTEREST WHICH SHALL ACCRUE AT THE MAXIMUM RATE ALLOWED BY LAW. FRAUD ANY PERSON WHO KNOWINGLY AND WITH INTENT TO INJURE, DEFRAUD, OR DECEIVE ANY INSURANCE COMPANY, OR FILES A STATEMENT OF CLAIM CONTAINING FALSE, INCOMPLETE OR MISLEADING INFORMATION MAY BE SUBJECT TO PROSECUTION UNDER APPLICABLE LAW. ADVANCE DIRECTIVE (FOR ADMISSION TO HOSPITAL ONLY) IF I AM TO BE ADMITTED TO THE HOSPITAL, I HAVE BEEN GIVEN WRITTEN MATERIALS ABOUT MY RIGHT TO ACCEPT OR REFUSE MEDICAL TREATMENT. 1 HAVE BEEN INFORMED OF MY RIGHTS TO FORMULATE ADVANCE DIRECTIVES. I UNDERSTAND THAT I AM NOT REQUIRED TO HAVE AN ADVANCE DIRECTIVE IN ORDER TO RECEIVE MEDICAL TREATMENT AT THIS HOSPITAL. I UNDERSTAND THAT THE HOSPITAL AND MY CAREGIVERS WILL FOLLOW THE TERMS OF ANY ADVANCE DIRECTIVE THAT I HAVE EXECUTED TO THE EXTENT PERMITTED BY LAW. (INITIAL THE FOLLOWING OPTION THAT APPLIES) • I HAVE EXECUTED AN ADVANCE DIRECTIVE AND WILL PROVIDE A COPY OF THIS FOR MY MEDICAL RECORD WITHIN A REASONABLE AMOUNT OF TIME. • I HAVE NOT EXECUTED AN ADVANCE DIRECTIVE AND DO NOT WISH TO DO SO. • I WISH TO COMPLETE AN ADVANCE DIRECTIVE DURING THIS HOSPITALIZATION INIT. !FOLLOW-UP DONE BY INIT. _ DATE I CERTIFY THAT I HAVE READ (ORR HAVE BEEN READ) THE ABOVE CONSENTS AND CAND AGREE WITH THEM. DATE: ls?l CAY Y ATURE OF PATIENT 01R. LEGALL Ui RIZEO REPRESENTATI ' 14 J?- WITNESS PRINT N RSON AOVE HMA7110 IIINIlINANiIlIlII 939966a i110 11111 milli Carlisle lReglonal Medical Center -- Emergency Department 361 Alexander Spring Rd Carlisle, PA 17013 -- (717) 960-1695 Patient: Shepherd, Daekwon MD ED: Kathy Ferraro, MD Disch: 4/19108 7:19pm Res/PA/NP: Kevin Gold, PA-C, Medical Record: 1057387 AFTERCARE INSTRUCTIONS We are pleased to have been able to provide you with emergency care. Please review these instructions when you return home in order to better understand your diagnosis and the necessary further treatment and precautions related to your condition. Your diagnoses/prescriptions today are: DX #1: Motor Vehicle Accident-Passenper Dx #2: Abrasion, Neck 0 General Information on MOTOR VEHICLE ACCIDENTS Each Year in the United States, about two million people are injured in motor vehicle accidents. Fortunately, many of these injuries are relatively minor, such as simple scrapes, sprains or bruises. However, other injuries can be more serious, and can even result in death. In fact, each year about 50,000 Americans die as the result of motor vehicle accidents. This is roughly the same number of Americans who died in the entire Vietnam war. Open vehicles like motorcycles and "Alf Terrain Vehicles" are particularly dangerous. In an accident, they leave the driver completely exposed to absorb the full force of the impact. What might have been a minor fender bender in a car can be a fatal accident on a motorcycle. What are the risks? Most people involved in minor motor vehicle accidents start to feel better within a few days and do not develop any serious medical problems. There are, however, some risks: 1. Often the aches and pains that result from a minor motor vehicle accident keep on getting worse for the first day or two. This is uncomfortable, but not dangerous. 2. Sprains of the neck or back sometimes produce pain that lingers on and off for weeks or even months. 3. Cuts or scrapes sometimes get infected. 4. On rare occasions, serious injuries may not become apparent for several hours or even days. INSTRUCTIONS 1) NEVER DRINK ALCOHOL AND DRIVE. About half of all motor vehicle accident fatalities are the direct result of drinking and driving. 2) ALWAYS USE A SEAT BELT. Seat belts save livesl 3) ALWAYS MAKE SURE ANY SMALL CHILDREN ARE SECURELY FASTENED IN AN APPROPRIATE CAR SEAT (In most states this is required by law). 4) If you ride a motorcycle, ALWAYS WEAR A HELMET when you ride, and try to wear protective clothing like a leather jacket. Better yet, sell your motorcycle and buy a car. 5) If you are not allergic to it, you may take acetaminophen (Tylenol) to help relieve the aches and pains. Stronger pain medication is not usually needed. 6) If you have sprained or bruised muscles, ice packs may help ease the pain for the first two days after the accident. Put the ice in a plastic bag. Roll up the bast in a towel and try putting it on the sore spots for 5 to 15 minutes at a time. After the first two days, warm packs usually work better. 7) If you have any cuts or scrapes, keep them CLEAN and dry. Contact your doctor if they become unusually red, swollen or tender. 8) SEEK IMMEDIATE MEDICAL ATTENTION if you develop chest pain, difficulty breathing, pain in the belly, vomiting, a severe headache, severe neck pain, bleeding, dizziness, confusion, difficulty walking, a fever, convulsion, blurred vision, excessive drowsiness or pass out. In children ALSO look for poor feeding or irritability. General lr formatlon on ABRASIONS An "abrasion" is the medical term for an accidental scrape or scratch on the skin. Abrasions often result from auto accidents, falls or contact with broken glass or other sharp objects. Depending on the circumstances, the abrasion may be relatively small and insignificant, or it may be quite large. What are the risks? Pq 2 Most abrasions heal in one to two weeks and do not produce any serious medical problems. There are, however, some risks: 1) When the skin is disrupted by an abrasion, perms sometimes get into the wound and start to prow and multiply, producinq an infection. If not treated right away, these infections can be serious. Immediately cleaning the wound is best way to help prevent an infection. 2) Deep abrasions sometimes leave a noticeable scar. 3) On rare occasions, there may be some damage to the muscles, tendons, nerves or bones underneath the abrasion. INSTRUCTIONS 1) When you get home, You should: A) wash the abrasion(s) thoroughly with lots of soap and water (unless this has already been done in the emergency room), B) if you are not allergic to it, gently apply a thin layer of antibiotic ointment and C) cover the area with a bandage. 2) Keep the area clean and drv. 3) If the bandage pets dirty or wet, change it right away. Otherwise, you should change the bandage once a day. To change the bandage you should: A) remove all of the old bandage, B) gently wash the area under running water, C) if you are not allergic to it, gently apply a thin layer of antibiotic ointment and D) put on a new bandage. 4) WARNING: Some antibiotic ointments can be toxic if used on large areas of skin. If your abrasion covers an area larger than the surface of your hand, talk with your doctor before using any antibiotic ointment. 5) If you are not allergic to them, you may take acetaminophen (Tylenol) or ibuprofen (Advil) to help ease the pain. 6) Tetanus shots are good for 5 to 10 years, provided you have had all your "baby shots' as a child- 7) SEEK IMMEDIATE MEDICAL ATTENTION 'rf: A) you develop a fever, persistent bleeding, vomiting or B) the abrasion gets very red, swollen or tender or C) you develop red streaks on the skin near the abrasion or D) the abrasion develops a foul odor, or starts to drain pus. 0 Follow-up: YOUR FAMILY DOCTOR FN MD Ph: F/U D/T: as needed Other Instr: EKGs and X-Rave: 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 iniury 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. Boland Chiropractic & Sports 915 N Mountain Rd, Ste C Harrisburg, PA 17112-1018 RE: DAEKWON D SHEPHERD -------- - ---------- 8/18/2008 Pain Level: 0 Height: Weight: SOAP NOTES Date: October 16, 2008 - - -------------- ----------- -------------------- req Level: 0 BP: Pulse: Temp: Field 1: Field 2: Field 3: Subjective: The patient returns to the office today for discharge evaluation stating that he feels his symptoms are mostly resolved at this time,- he denies any exacerbations since his last visit. He has resumed all ADL without complication. Objective: Spinal fixations present at C5, T4-5 and L5. Assessment: The patient has reached maximum chiropractic improvement. Plan: Full spine CMT. The patient is discharged at this time from active care. I do not anticipate: any permanent residuals for him. ------------------ 008 Pain Level: 0 Freq Level: 0 BP: Pulse: Temp: Height: Weight: Field 1: Field 2: Field 3: Subjective: . The patient returns to the office reporting that he is doing much better at the current time. His symptoms of neck and back pain are rated a 2 occurring between 5-25% of his day. He has returned to all of his normal activities without complication. Objective: Spinal fixations at C2-3, T2-5, L5-S1. Assessment: The patient has nearly achieved maximum medical-chiropractic improvement. Plan: Full spine CMT followed by 15 mins each therapeutic exercise and dynamic activities supervised by Dr. Boland: He is recommended to return in 4 weeks for final reassessment of his condition. Page 1 Of 5 RE: DAEKWON D SHEPHERD ---------------- -------- ----- ---------------- ------------------------------- --------- ------ ---- ---- -- ------------ ------- - ----- -------- -- -- 6/25/2008 Pain Level: 0 Freq Level. 0 BP: Pulse: Temp: Height: Weight: Field 1: Field 2: Field 3: Subjective: The patient reports mild degree neck pain radiating to left arm occuring between 5-25% of his day rated at a level 3. Objective: Spinal fixations at C2-4, T2-8, L5 with cervical spine ROM limited in rotation. Assessment: Plan: Full spine CMT followed by THREX and DYNA each 15 min. supervised by Dr. Boland -------------------------- --------------------------------------------- --------------------- ----- ----------- ------- ----- _ ------------ --------------------------------------------- 6/19/2008 Pain Level: 0 Freq Level: 0 BP: Pulse: Temp: Height: Weight: Field 1: Field 2: Field 3: Subjective: The patient returns to the office today stating his symptoms are again improving and rated his pain at a number 2 on a scale of 0-10 occurring no more than 25% of his day. His primary symptoms at this time are in his neck and occassionally in his low back and legs. His mother interjected to state she believes he still is not himself in regard to his activities. Objective: Spinal fixations at C2-4, T2-8 and L5. Cervical spine ROM limited mostly in left rotation by approximately 35%- Assessment: Plan: Treatment today consisted of FS-CMT and THREX with emphasis on abdominal and low back strengthening and DYNA for balance and coordination 15 minutes each supervised by Dr. Boland. The patient tolerated -treatment well. ---------------------- ------- - p - : -- 6/14/2008 Pain Level: 0 Freq Level: 0 BP: Pulse: - - - -- Tem - Height: Weight: Field 1: Field 2: Field 3: Subjective: The patient reports his symptoms today at a level 2 occurring approximately 25% of his waking day. He believes his treatments are helping him and he is feeling much better overall stating he has little to no pain in his chest at this time. He continues with neck and low back pain and intermittent pain in his extremities. Objective: Spinal fixations at C6-7, T3-6 and L5-S1 Assessment: Plan: FS-CMT followed by THREX and DYNA as previously described for a combined 30 minutes, supervised by Dr. Boland. The patient tolerated treatment well. Page 2 Of 5 RE: DAEMON D SHEPHERD --- ------- -------------------------- ------- --------------- -- ------------------------ -------------- --------- - -- --------------------------------------------------------------- 6/7/2008 Pain Level: 0 Freq Level: 0 BP: Pulse: Temp: Height: Weight: Field 1: Field 2: Field 3: Subjective: The patient reports to the office today stating his symptoms have decreased at this time occurring approximately 25% of his day and rated a 3 on a scale of 0-10 stating "its getting somewhat better but I still have pain in my neck, back, legs and radiating to my chest". Objective: Spinal fixations present C2-5, T3-10, L5. Assessment: Plan: Treatment today consisted of FS-CMT followed by 15 minutes each of DYNA and THREX supervised by Dr. Boland. The patient tolerated treatment well. ----------------------- --- -- - - ------ ----------------------------------------------------------------------------------------- ------------------------- --------------------- 6/4/2008 Pain Level: 0 Freq Level: 0 BP: Pulse: Temp: Height: Weight: Field 1: Field 2: Field 3: Subjective: The patient returns to the office reporting his symptoms occurring approximately 50% of his day rated at 5 on a scale of 0-10 again occurring in his neck, upper and middle back, lower back and legs. Objective: Spinal fixations at C5, T3-6 and L5. Assessment: Plan: FS-CMT followed by 10 minutes each DYNA for improving coordination and balance and 10 minutes THREX for abdominal and low back strength. The patient tolerated treatment well 5/28/2008 Pain Level: 0 Freq Level 0 BP: Pulse: Temp: Height: Weight: Field 1: Field 2: Field 3: Subjective: The patient returns tot he office reporting continued pain in his neck, legs and chest occurring between 25-50% of his waking day and rated a 5 on a scale of 0-10. Objective: Spinal fixations were noted at C5-6, T3-8 and L5-S1. Assessment: Plan: Treatment today consisted of FS-CMT followed by 15 minutes DYNA with emphasis on multiple balance movements and THREX 10 minutes with emphasis on abdominal bracing while riding the mechanical horse. Page 3 OF 5 RE: DAEKWON D SHEPHERD ---- --- - ------ 24/2008 ----- -- ------------------------ Pain Level: 0 Freq Level: 0 BP: Pulse: Temp: Height: Weight: Field 1: Field 2: Field 3: Subjective: ACCIDENT HISTORY.- Master Shepherd, a 10 year old student was brought in for a consultation by his mother on May 24, 2008 for injuries sustained in a motor vehicle accident on April 19, 2008. Master Shepherd was seated in the rear seat of a late model station wagon which careened off the road, drove over an embankment, down and hill and ended up in a creek flipped over on the roof. The patient stated he was wearing his seatbelt at the time, but ultimately had to (kick out) a window to extricate himself from the vehicle. He reported that although he did not sustain any - bleeding cuts nor loss of consciousness he was transported to the Carlisle Hospital emergency room via ambulance on a back board with neck restraint. The patient recall having been examined at the hospital and released under his mother's care with instructions to follow up with the family physician. Due to the family not having lived in the area for an extended length of time, he did not have.a family physician and ultimately consulted the Sadler Clinic whereby, he was-r.:e,c ACenter:whereby'he had xrays taken of his neck on May 22, 2008. Immediately following the collision the. patient reports having the following symptoms- he was scared and shaken up and felt pain in his neck, middle and lower back, chest and arms. Later that day and the following day he reports having the same symptoms and also experiencing pain in the backs of his knees and lower legs. On the day of and poor to the accident; on April 19, 2008, Master Shepherd stated that he had no physical complaints and participated in several athletic type activities as do most boys his own age. Since that time he has been significantly restricted due to the afore mentioned symptoms. Past medical history was non-contributory. The patient is not under doctors care nor does he take medication for any reason. The patient uses over the counter topical cream for eczema. SOCIAL HISTORY: The patient is a full time student and lives with his mother and step father in Carlisle, PA. REVIEW OF SYSTEMS: The patient and his mother denied any other heart, lung, EENT, GI-GU, metabolic, endocrine or neurological disorders. CURRENT CONDITION: On May 24, 2008, Master Shepherd presented himself to this office for an evaluation at which time he related the following symptoms; pains in his neck, middle and lower back, pain in his chest, arms and backs of his knees and lower legs which had not significantly improved since the accident. Page 4 Of 5 RE: DAEKWON D SHEPHERD Objective: EXAMINATION: Physical examination results were as follows: mild distress was noted during the time of consultation. The patient often was noticed rubbing his neck where he had evidence of seat belt burn on the left side. General neck movements were painfully limited particularly in rotation to the right side which was limited by 50%; all neck movements were painful. Visual inspection of the patient revealed considerable head and neck tilt to the right. Motion palpation revealed articular blockage at C2-5 with associated tenderness on the left side and spinous tenderness at T2-8 with associated paraspinal muscle tenderness. Auscultation of the heart and lungs was with in normal limits. Motion Palpation of the remainder of the spine revealed spinal fixations C2-C7, T2-T8 and L4-S1. Report of xray from Walnut Bottom Radiology was negative for fractures or gross malalignment. The patient stands 47 &1/2 inches tall and weighed 80 pounds. Muscle strength evaluation in the upper extremities was normal however the patient could not perform resisted neck movements without pain in his neck and shoulders. Thoracolumbar range of motion was within normal limits however did cause the patient some degree of back and lower leg pain on both sides. Deep tendon reflexes and sensory examination were within normal limits. These findings on examination are consistent with the type of accident described by the patient which occurred on April 19, 2008. It is my opinion that the symptoms which the patient is currently experiencing are directly and causally related to the same accident. Assessment: DIAGNOSES: The patient initial diagnosis including: 1) motor vehicle collision with a non-vehicle object 2) acute moderate cervicothoracic sprain/strain 3) acute moderate lumbosacral sprain/strain Total time of evaluation was 55 minutes including decision making of moderate complexity. Plan: MANAGEMENT: Management of the patient's condition will include 1. Chiropractic manipulative treatment - a form of manual treatment to influence joint and neurophysiological function. 2. Spinal decompression employing forces given in the direction of pain - free motion in order to reduce discoradicular irritation. Decompression Therapy 3. Soft tissue mobilization and massage to relieve hypertonic musculature. 4. Ultrasound and electrotherapy to increase circulation for more rapid healing, reduce inflammation, pain and spasm. 5_ Therapeutic exercise to develop strength and endurance, range of motion and flexibility. 6. Neuromuscular reeducation to develop balance and coordination, posture and proprioception for sitting and or standing.. 7. Therapeutic dynamic activities to improve functional performance. 8. Self-care home management training in activities of daily living to minimize the risk of re-injury.. ADDENDUM - August 1, 2008: Spinal manipulation on 5-24-08 was rendered to the cervical, thoracic and lumbosacral regions. Page 5 Of 5 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE BUREAU OF FINANCIAL OPERATIONS DIVISION OF THIRD PARTY LIABILITY CASUALTY UNIT P.O.BOX 8486 HARRISBURG, PA 17105$486 March 9, 2009 LUNDY LAW FRANCINE H MONTGOMERY LEGAL ASSISTANT 1635 MARKET ST 19TH FL PHILADELPHIA PA 19103 Re: DAEKWON SHEPPARD (minor) CIS #: 530182075 Incident Date: 04/19/2008 Dear Ms. Montgomery: The Department of Public Welfare maintains a lien in the amount of $1,001.00 for the above-referenced incident. The Department has agreed to reduce its lien by 25% plus a prorata share of expenses and accept the net payment of $640.53 to satisfy the total lien amount. Checks should be made payable to the Department of Public Welfare and sent to my attention at the above address. We request that with all transmittal of funds, you provide the Department with a copy of the final distribution sheet. In the event you have already brought or will bring any action resulting in a further recovery, we reserve the right to seek recovery of any additional unpaid portion of our medical/cash lien. This settlement in no way affects our future rights. Thank you for your cooperation in this matter. If you have any further questions, please contact me. . erely, aren H. Peterson Claims Investigation Agent 717-772-6615 717-772-6553 FAX • L.PW arvinLundy TT A seiSells CONTINGENCY FEE AGREEMENT DATE: wmbe, I hereby retain, constitute and appoint the law firm of LUNDY LAW as my counsel to prosecute a claim for personal injuries. The cause of action arose on I hereby agree that the compensation of the firm and my attorney for se ices shall be determined as follows: -t ,lv l haGc to/?c ?hu-z? 33113 6 The firm and my attorney shall receive ?1?G f??Percent of gross sum secured either or whether by way of settlement or verdict. All expenses incident to the prosecution or litigation of this case are to be borne by the client at time of distribution unless otherwise agreed in writing. I do hereby direct and authorize my attorney and Lundy Law to pay directly and without additional consent from any proceeds of/by settlement or verdict any unpaid balance for treatment, services or other costs made necessary by the injuries sustained in this accident and/or the prosecution/litigation of this claim. Expenses include, but are not limited to, such things as investigation, photos, experts, filing fees, court costs, photocopying, research costs and a one-time $150 administrative fee. In the event no money is recovered in this case, the client shall not be liable for any expenses or legal fees as a result. Lundy Law may withdraw as counsel at any time, without obligation, at its sole discretion. Client hereby acknowledges that Lundy Law has taken this representation on a contingency arrangement as stated in this document. As a result, Lundy Law is sharing in both the risk and recovery regardless of the number of hours invested. In consideration of Lundy Law accepting this case, and in the event that client discharges Lundy Law for any reason, client hereby specifically agrees to waive any hourly time accounting and instruct his/her new counsel to pay the following fee, whether this matter is settled or tried, as determined by a scheduled percentage of the total amount of gross settlement/recovery/award which is received or offered according to the stage of the representation when the discharge or withdrawal of Lundy Law occurs: Claim stage: 33 1/3%, Litigation stage, 40%, Within sixty (60) days of Arbitration/Trial : 50%. In addition, Lundy Law shall receive all costs advanced and/or expended to date before the file shall be transferred Client agrees to keep the attorney advised of his/her whereabouts at all times and to cooperate in the preparation and trial of the case, to appear on reasonable notice for depositions and court appearances, and to comply with all reasonable requests made of him in connection with the preparation and presentation of his/her case. Lundy Law, or its representative attorney, is authorized to endorse my name to any drafts, insurance drafts or settlement drafts only for the purpose of depositing said drafts into its escrow account. My counsel is further authorized to pay directly to any health care provider(s) any amounts due for services rendered upon receipt of said money. No representation has been made as to what amounts, if any, client may be entitled to recover in this case Further, I hereby state and affirm under penalty of law that the facts regarding me and my background, the accident, injuries, participants, and witnesses are true and correct as presented to Lundy Law, and I understand that the law firm is relying upon these facts to accept my representation for this matter. I hereby acknowledge that I have read this fee agreement, agree to these terms and I have received a duplicate copy of this Contingency Fee Agreement. N E? Revised: Pcbtuary 26, 2004 V -ty?lt ! ,?.-1..11,7 OF C!."? I; _ VIE $ 78.5o Po ATrY C e. * 3a449 FlL~D-C)t~rICE LundvLaw ~~' Ta-{" PR~~'~-`~'~'~T,A~Y BY: HERBERT L. OCKS, ESQUIItE IDENTIFICATION NO.: 04137 ZQ ~ 0 ~~" E $ ~ ~ ' ~' ~ ATTORNEY FOR PETITIONERS 19th FLOOR 1635 MARKET STREET ~U"~ r _ ' . _; _~''~~,"~~ PHILADELPHIA, PA 19103-2297r'=' " ~`> ~ _ ,. ` ~' (215) 567-3000 hocks(a~lundvlaw. com ~ ~~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA ESTATE OF DAEKWON SHEPPARD, A MINOR NO. 09-4141 CIVIL TERM AFFIDAVIT OF COMPLIANCE I, Sharral Hall Mwangi, hereby state and affirm that I have complied with the Order issued on August 5, 2009, by the Honorable M. L. Ebert, Jr. as follows: 1. On August 21, 2009, the sum of $3,661.33 was deposited by in an insured, interest-bearing Certificate of Deposit, No. 2055017541, in the Sovereign Bank pursuant to the Order of the Court. 2. The Certificate of Deposit, No. 2055017541, is entitled: Daekwon Sheppard, minor, not to be withdrawn until age of majority 3. A copy of said Certificate of Deposit is attached hereto. I verify that the statements in this Affidavit are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. f, , r DATE: March 16, 2010 W ~/n Sharral Hall Mwangi, arent natural Guardian of Daekwon Sheppar a minor IW4V.i~ YV.. .:, :. ~- ~ ~r:: overeign dank ., ;.. Certii~icate of Deposit Receipt Addition to Principal !Withdrawal from Principal Transactions ONLY This receipt is issued to: DAEKWOI~ SHEPPAitD 4tIlr'OR NOT TO BE wiTHI3RgyVN UNTII. ,AGE OF 1~iATORITY 825 FACTQRY ST CARLISLE PA I7Q13.1352 The account evidenced by this receipt is subject to and further explained in the terms and conditions as contained in the deposit account ag.~ement and the ccrtificate of deposit disclosure. ~~u~ollar Amount Balance before AdditiontWithdrawal 53,661.33 Addition to Principal gp,pp oa withdrawal from Principal $o. Penalty Amount ~~~ ~~ ~'4B grace aer+oa. New C$rttlicate of A~ t Det i!s '• .4ccount Number. 24 X017541 IRA Account: ^ Yes®No Date Opened: 0 !409 Term: MO':'dTHS MCY Date: 08:~ 1/2410 Interest Rate: 1,3g Annual Percentage Yield: 1.40 In~erest Disbursement: MOhTI-II..Y Interest Payment Frequency: ?vI(3NTHL.Y Et~ortiva fJt0/02 This account is not negotiable and net transferable. ~uN f ~ zoo9~ LundyLaw BY: HERBERT L. OCKS, ESQUIRE IDENTIFICATION NO.: 04137 19th FLOOR 1635 MARKET STREET PHILADELPHIA, PA 19103-2297 (215) 567-3000 E-Mail Address: hocks@lundylaw.com ATTORNEY FOR PLAINTIFFS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA IN RE: ESTATE OF DAEKWON SHEPPARD, A MINOR NO. ~ - 41 y 1 Csvi !`~-m FINAL DECREE AND NOW, this y of , 2009, upon consideration of the petition to compromise a minor's action, the proposed settlement having a gross value of $6,500.00, is hereby approved, to be distributed as follows: TO: LundyLaw ~ $ 764.19 (Reimbursement for Costs} TO: LundyLaw 1,433.95 (Counsel Fee) TO: Department of Public Welfare 640.53 (Lien of $1,001.00 reduced to $640.53) TO: Daekwon Sheppard, a minor, to be placed $3,661.33 in an investment/account authorized by Pa. RC.P. 2039(b)(2}, IN THE NAME OF THE MINOR, Which investrnent/account shall bear the notation "not to be redeemed or withdrawn except for renewal in its entirety prior to June 29, 2015 except upon Order of the Court." Total $6,500.00 Sharral Hall. Mwangi, parent and natural guardian of Daekwon Sheppard, a minor, is ORDERED and DIRECTED to file an affidavit of compliance regarding the opening of the restricted investment/account with the Clerk of the Orphans' Court within thirty (30) days. BY THE COURT: /~ `• ? ~ ~ l~ ~s~ ~ ~. 4 _ ` ~ .y