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HomeMy WebLinkAbout10-4478 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff(s) & Address(es): Ronald and DeeAnna Pompeo, as parents and natural guardians of Chelsea Pompeo, a minor child 1298 Brandt Road Mechanicsburg, PA 17055 VS. Case No. /0 - #V;?e Civil Term Defendant(s) & Address(es) Anthony R. Knight, Jr. Inmate No.: HZ7438 SCI-Houtzdale Box 1000 State Route 2007 Houtzdale, PA 16698 Jeffrey Unitis 1340 Kuhn Road Boiling Springs, PA 17007 Karen Unitis 1340 Kuhn Road Boiling Springs, PA 17007 Civil Action - Law PRAECIPE FOR SUMMONS TO THE PROTHONOTARY OF SAID COURT: Issue summons in the above case. n a _ r 4- - Writ of Summons shall be issued and forwarded to Attorney heriff lease circle one) Signature of Attorney George J. CoAMulos 153 North Hanover Street Carlisle Pennsylvania 17013 Telephone- (717) 243-0407 Date: July 7, 2010 Supreme Court ID Number 78423 WRIT OF SUMMONS TO: ANTHONY R KNIGHT JR. JEFFREY UNITIS AND KAREN UNITIS YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. r, ), ?, y au?- ro otary/Cl rk, Civil Division Date: 7 ' 7- X1 > by Deupty IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 10- ~l4~78 N RONALD and DEEANNA POMPEO NO:~t'6"~8 CIVIL TERM ~ as pazents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs v. ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants CIVIL ACTION -LAW ~. -~:~ ~- ;~~ ~.. _-F ~= T=~ r ~. ~. {..: ~- ~-- JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO PA.R.C.P. 1012 TO THE PROTHONOTARY: %::~ ~,..._ r~ 0 _~, r? .G- T~ ~'~ 1 ~: ;=-, _` >..7 -_ ~~ ..~ Kindly enter the appeazance of Michael B. Scheib, Esquire, of Griffith, Strickler, Lerman, Solymos & Calkins, as attorney for the Defendants, Anthony R. Knight, Jr., Jeffrey Unitis and Kazen Unitis, in the above-captioned matter and mark the docket accordingly. GRIFFITH, STRICKLER, SOLYMOS & CAI,~IN~ Date: July ~ ~.Q , 2010 By: MICHAEL B. SCHEIB, ESQU PA 63868 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheib(a~gslsc.com Attorney for Defendants, Anthony R. Knight, Jr., Jeffrey Unitis and Kazen Unitis IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD and DEEANNA POMPEO, NO. 10-448 CIVIL TERM as pazents and natural guazdians of CHELSEA POMPEO, a minor child, Plaintiffs v. CIVIL ACTION -LAW ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this ~~ day of July, 2010, I, Michael B. Scheib, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Praecipe for Entry of Appeazance Pursuant to Pa. R.C.P. 1012, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: George J. Costopoulos, Esquire 153 North Hanover Street Cazlisle, PA 17013 (Attorney for Plaintiffs) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: MIC'~iALL B. SCHEIB, ESQUIRE PA 63868 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheib(a)gslsc.com Attorney for Defendants, Anthony R. Knight, Jr., Jeffrey Unitis and Karen Unitis IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA io-4y~8 RONALD and DEEANNA POMPEO NO. T~S~IVIL TERM as pazents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs V. ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants TO THE PROTHONOTARY: • ~ c- CIVIL ACTION - LAW.„T~ ~] c_: ._l -n ~' -- ~ r..~_ ~ c-`-t ~~ ~ ~ c~ , -+ , . ~'- ~ JURY TRIAL DEMAN~~~ _~ ~~• _ ~ PRAECIPE ~ .. ~ =! a Please enter a Rule upon Ronald and DeeAnna Pompeo, as pazents and natural guazdians of Chelsea Pompeo, a minor child, Plaintiffs, to file a Complaint within twenty (20) days from the date of the service of this Rule or suffer Judgment non-pros. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & C~ILKIN~ Date: July ~ ~ , 2010 By: York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheib(a7~gslsc.com Attorney for Defendants, Anthony R. Knight, Jr. and Jeffrey Unitis and Kazen Unitis NOW, ~~~/~ ~/~/ , 2010, RULE ISSUED AS ABOVE. Prothonotary By: Deputy PA 63868 110 South Northern Way IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD and DEEANNA POMPEO, NO. 10-447$ CIVIL TERM as parents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs v. CIVII. ACTION -LAW ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KARh-'N UNITIS, Defendants JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and the Court without further notice may enter a judgment against you 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYEk. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 34 S. Bedford Street, Carlisle, Pennsylvania Telephone: 717-249-3166 ~ ' _ _,~ ,~~ ~,' ~ ~~ ~;~ _Ic~. --- ~~ ~ ~, c~_ d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD and DEEANNA POMPEO, as parents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs NO. 10-4478 CIVIL TERM v. ANTHONY R KNIGHT, JR., JEFFREY UNITIS and KAREN LJNITIS, Defendants CIVIL ACTION -LAW JURY TRIAL DEMANDED COMPLAINT 1. Plaintiffs, Ronald and DeeAnna Pompeo, are the adult parents and natural guardians of Chelsea Pompeo, a minor child, who together reside at 1298 Brandt Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, Anthony R. Knight, Jr., is an adult individual who currently resides as an inmate at the State Correctional Institution at Houtzdale, Box 1000, State Route 2007, Clearfield County, Pennsylvania 16698. 3. Defendants, Jeffrey and Karen Unitis, are adult individuals who reside at 1340 Kuhn Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 4. The events giving rise to this cause of action occurred shortly before 2:51 a.m. on or about August 9, 2008 on York Road/Route 74 in South Middleton Township, Cumberland County, Pennsylvania. 5. At said time and place, Defendant, Anthony R. Knight, Jr., operating a 2002 Ford ZX3 automobile owned by his parents, Defendants, Jeffrey Unitis and Karen Unitis, was driving southbound on York Road/Route 74 while Plaintiff, Chelsea Pompeo, was afront-seat passenger. 6. At that same time and place, Defendant, Anthony R_ Knight, Jr., attempted at a high rate of speed to pass a vehicle traveling ahead of him and lost control, sideswiping a barn and smashing into a utility pole, thereby causing the collision and injuries giving rise to this cause of action. 7. The foregoing collision and all of the injuries and damages resulting therefrom were Caused by the negligent, careless, and/or reckless actions of Defendant, Anthony R. Knight, Jr., in that he: (a) failed to keep proper and adequate control over his vehicle; (b) attempted to pass another motor vehicle when it was not safe to do so; (c) failed to keep alert and maintain proper watch for the presence of other motor vehicles on the highway; (d) failed to drive his vehicle with due regazd for the highway and traffic conditions which were existing and of which he was or should have been awaze; (e) operated his vehicle in cazeless disregazd for the safety of others and the Plaintiff, Chelsea Pompeo, in particulaz violation of 75 Pa.C.S. § 3714; (f) operated his vehicle too fast for the conditions then and there existing in particulaz violation of 75 Pa.C.S. § 3361; (g) failed to operate his vehicle within a single lane of travel in particular violation of 75 Pa.C.S. § 3309; (h) failed to notice the imminence of an accident and to take the necessary steps to avoid the same; (i) failed to yield the right-of--way to other motor vehicles on the highway; (j) violated the Pennsylvania Motor Vehicle Code, which is intended to protect persons lawfully on the highway such as Plaintiff, Chelsea Pompeo, from personal injury, and thus constitutes negligence per se; and (k) otherwise operated his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregazd to the rights and safety of other motorists and their passengers, including Plaintiff, Chelsea Pompeo. COUNT 1 Plaintiffs, Ronald and DeeAnna Pompeo, as parents and natural guardians of Chelsea Pompeo, a minor child v. Defendant. Anthony R Kni t. Jr • Neglige, nce 8. The averments set forth in paragraphs 1 through 7 above are incorporated by reference as though fully set forth herein. 9. As a result of the negligent, careless and/or reckless acts of Defendant, Anthony R. Knight, Jr., Plaintiff, Chelsea Pompeo, has suffered severe and permanent injuries, including but not limited to, a splenic laceration, fractures of the 9'" through 11'~ ribs, transverse process fractures of the L-1 and T-12 vertebrae, abrasions to the right temporal area of head, abrasions to the right temporal area of the face, and amnesia, as a result of which she suffered great physical pain and mental distress, which she yet suffers and may continue to suffer for an indefinite time in the future. 10. As a further result of the negligent, cazeiess and/or reckless acts of Defendant, Anthony R. Knight, Jr., Plaintiff, Chelsea Pompeo, was forced to incur medical treatment, caze and expenses for the injuries she has suffered, and will or may be obligated to undergo treatment and incur expenses for an indefinite time in the future. 11. As a further result of the negligent, cazeless and/or reckless acts of Defendant, Anthony R. Knight, Jr., Plaintiff, Chelsea Pompeo, has suffered, or may suffer, a severe loss of earnings and impairment of her earning capacity, and the loss of income and impairment of earning capacity will or may continue for an indefinite time in the future. 12. As a further result of the negligent, careless and/or reckless acts of Defendant, Anthony R. Knight, Jr., Plaintiff, Chelsea Pompeo, has suffered medically determinable physical impairments which have prevented her from performing all of the normal acts and duties which constitute her usual and customary daily activities, and will or may continue to so suffer for an indefinite time in the future. 13. As a further result of the negligent, careless and/or reckless acts of Defendant, Anthony R. Knight, Jr., Plaintiff, Chelsea Pompeo, has experienced severe pain and suffering, mental anguish and humiliation, and will or may continue to so experience for an indefinite time in the future. 14. As a further result of the negligent, careless and/or reckless acts of Defendant, Anthony R. Knight, Jr., Plaintiff, Chelsea Pompeo, has suffered a loss of life's pleasures, and will or may continue to so experience for an indefinite time in the future. WHEREFORE, Plaintiffs, Ronald and DeeAnna Pompeo, as parents and natural guardians of Chelsea Pompeo, a minor child, demand judgment against Defendant, Anthony R. Knight, Jr., in an amount in excess of the compulsory arbitration limits, plus costs and interest as provided by law. COUNT II Plaintiffs, Ronald and DeeAnna Pompeo, as parents and natural guardians of Chelsea Pompeo, a minor child v Defendants Jeffery Unitis and Karen Unitis• Negligent Entrustment 15. The averments set forth in paragraphs 1 through 14 above are incorporated by reference as though fully set forth herein. 16. On or about August 9, 2008, Defendant, Anthony R. Knight, Jr., with the implied and/or express permission of his parents, Defendants, Jeffrey Unitis and Karen Unitis, drove the 2002 Ford ZX3 automobile owned and controlled by his parents, Defendants, Jeffrey Unitis and Karen Unitis, and caused the collision detailed above. 17. The collision and injuries resulting therefrom were caused by the negligent, careless and/or reckless actions of the Defendants, Jeffrey Unitis and Karen Unitis, in that they: (a) knew or should have known that Defendant, Anthony R. Knight, Jr., was incapable of safe driving at the time in question; (b) permitted Defendant, Anthony R. Knight, Jr., to operate their motor vehicle at the time in question when they knew or should have known that he was incapable of safe driving; (c) failed to take whatever steps were reasonable and necessary to prevent Defendant, Anthony R. Knight, Jr., from operating their motor vehicle at the time in question when they knew or should have known that he was incapable of safe driving; and (d) acted without regard for the safety and rights of other motorists and their passengers, including Plaintiff, Chelsea Pompeo. 18. As a result of the negligent, careless and/or reckless acts of Defendants, Jeffrey Unitis and Karen Unitis, Plaintiff, Chelsea Pompeo, has suffered severe and permanent injuries, including but not limited to, a splenic laceration, fractures of the 9~' through 11 ~ ribs, transverse process fractures of the L-1 and T-12 vertebrae, abrasions to the right temporal area of head, abrasions to the right temporal azea of the face, and amnesia, as a result of which she suffered great physical pain and mental distress, which she yet suffers and may continue to suffer for an indefinite time in the future. 19. As a further result of the negligent, careless and/or reckless acts of Defendants, Jeffrey Unitis and Karen Unitis, Plaintiff, Chelsea Pompeo, was forced to incur medical treatment, caze and expenses for the injuries she has suffered, and will or may be obligated to undergo treatment and incur expenses for an indefinite time in the future. 20. As a further result of the negligent, careless and/or reckless acts of Defendants, Jeffrey Unitis and Karen Unitis, Plaintiff, Chelsea Pompeo, has suffered, or may suffer, a severe loss of earnings and impairment of her earning capacity, and the loss of income and impairment of earning capacity will or may continue for an indefinite time in the future. 21. As a further result of the negligent, careless and/or reckless acts of Defendants, Jeffrey Unitis and Karen Unitis, Plaintiff, Chelsea Pompeo, has suffered medically determinable physical impairments which have prevented her from performing all of the normal acts and duties which constitute her usual and customary daily activities, and will or may continue to so suffer for an indefinite time in the future. 22. As a further result of the negligent, careless and/or reckless acts of Defendants, Jeffrey Unitis and Karen Unitis, Plaintiff, Chelsea Pompeo, has experienced severe pain and suffering, mental anguish and humiliation, and will or may continue to so experience for an indefinite time in the future. 23. As a further result of the negligent ,careless and/or reckless acts of Defendants, Jeffrey Unitis and Karen Unitis, Plaintiff, Chelsea Pompeo, has suffered a loss of life's pleasures, and will or may continue to so experience for an indefinite time in the future. WHEREFORE, Plaintiffs, Ronald and DeeAnna Pompeo, as parents and natural guardians of Chelsea Pompeo, a minor child, demand judgment against Defendants, Jeffrey Unitis and Karen Unitis, in an amount in excess of the compulsory arbitration limits, plus costs and interest as provided by law. RESPECTFULLY SUBMITTED: Geor . Costopoulos, Esquire Attorn I.D. # 78423 153 North Hanover Street Carlisle, Pennsylvania 17013 Phone: (717) 243-0407 Attorney for Plaintiffs Date: g'/~//0 VERIFICATION We, Ronald & DeeAnna Pompeo, do hereby verify that the statements made in the foregoing document are true and correct. We understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. § 49U4 relating to unsworn falsification to authorities. /~°~~.. RONALD POMPEO D EANNA PO EO ~ s ~, DATE CERTIFICATE OF SERVICE I, George J. Costopoulos, Esquire, hereby certify that on August 5, 2010 I served a true and correct copy of the foregoing document by United States Mail, postage prepaid, upon counsel for Defendants as identified below: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402-3737 C ~---- Geo J. Costopoulos, Esquire Dated: ~' / S' / / o FFICE Of T!5 p-7- 'O . TARY 10 A: ',G 25 AM 10= 18 curl nv Wuta anua IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD and DEEANNA POMPEO, as parents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs : NO. 10-44 CIVIL TERM V. : CIVIL ACTION - LAW ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Ronald and Deeanna Pompeo, as parents and natural guardians of Chelsea Pompeo, a minor child, Plaintiffs c/o George J. Costopoulos, Esquire 153 North Hanover Street Carlisle, PA 17013 You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. GRIFFITH, STRICKLER, LERMAN, SOL XHAL LK90 Date: August 2010 BY: l?l MCH EIB, ESQ., ID 638168 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheib a,gsisc.com Attorney for Defendants, Anthony R. Knight, Jr. and Jeffrey Unitis and Karen Unitis IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD and DEEANNA POMPEO, as parents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs V. ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants NO. 10-448 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER COME NOW, Defendants, Anthony R. Knight, Jr., Jeffrey Unitis, and Karen Unitis, by and through their attorney, Michael B. Scheib, Esquire, of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, and responds to the allegations in Plaintiffs' Complaint as follows: 1. Denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 1 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 2. Admitted. 3. Admitted. 4. Admitted 5. Admitted. 6. Admitted in part and denied in part. It is admitted that the vehicle operated by Defendant Knight made contact with a barn and utility pole. The remaining allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 6 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 7. Denied. Paragraph 7 states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied and strict proof thereof is demanded. COUNTI Plaintiffs, Ronald and DeeAnna Pompeo, as parents and natural guardians of Chelsea Pompeo, a minor child v. Defendant, Anthony R. Knight, Jr.: Negligence 8. Paragraphs 1 through 7 of Defendants' Answer with New Matter are incorporated herein as though fully set forth at length. 9. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 9 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 10. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 10 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 11. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 11 of Plaintiffs' Complaint, and the same are denied and strict: proof thereof is demanded. 2 12. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 12 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 13. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 13 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 14. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in :Paragraph 14 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. WHEREFORE, Defendants, Anthony R. Knight, Jr., Jeffrey Unitis and Karen Unitis, respectfully request this Honorable Court to enter judgment in their favor, together with costs of this lawsuit. COUNT II Plaintiffs, Ronald and DeeAnna Pompeo, as parents and natural guardians of Chelsea Pompeo, a minor child v. Defendants, Jeffrey Unitis and Karen Unitis: Negligent Entrustment 15. Paragraphs 1 through 14 of Defendants' Answer with New Matter are incorporated herein as though fully set forth at length. 3 16. Admitted in part and denied in part. It is admitted that Defendant, Anthony R. Knight, Jr., operated the 2002 Ford ZX3 automobile with the permission of his parents, Defendants, Jeffrey Unitis and Karen Unitis. It is specifically denied that Defendants, Jeffrey Unitis and Karen Unitis, controlled the vehicle at the time of the accident. The remaining allegations in Paragraph 16 are denied generally, and strict proof thereof is demanded. 17. Denied. Paragraph 17 states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied and strict proof thereof is demanded. 18. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 18 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 19. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 19 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 20. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 20 of Plaintiffs' Complaint, and the same are denied and strict: proof thereof is demanded. 4 21. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 21 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 22. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 22 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 23. :Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 23 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. WHEREFORE, Defendants, Anthony R. Knight, Jr., Jeffrey Unitis and Karen Unitis, respectfully request this Honorable Court to enter judgment in their favor, together with costs of this lawsuit. By way of further defense: NEW MATTER 24. Paragraphs 1 through 23 of Defendants' Answer with New Matter are incorporated herein as though fully set forth at length. 5 25. Plaintiffs' injuries, if any, may be barred or limited by the Motor Vehicle Financial Responsibility Law. 26. Plaintiffs' injuries, if any, may be barred or limited by a limited tort selection. 27. Plaintiffs' injuries, if any, were caused by the acts or omissions of a third party over whom Defendants had no control. 28. Plaintiffs' injuries, if any, were caused by events which either predated or postdated the motor vehicle accident which is the subject of this lawsuit. 29. Plaintiffs' injuries, if any, were caused by their own conduct. 30. Plaintiffs' recovery may be barred or limited by the amount of uninsured or underinsured motorist's benefits, if any, to which Plaintiffs may be entitled to recover. 31. Defendant is entitled to have the Court mold any verdict in Plaintiffs' favor to reflect the amount of uninsured or underinsured motorist's benefits, if any, which Plaintiffs have received. WHEREFORE, Answering Defendants, Anthony R. Knight, Jr., Jeffrey Unitis and Karen Unitis, respectfully request this Honorable Court to enter judgment in their favor, together with costs of this lawsuit. 6 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS Date: August 2-3 5 2010 By: { MICHAEL B. S HEIB, ESQUIRE PA 63868 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheibkgslsc.com Attorney for Defendants, Anthony R. Knight, Jr. and Jeffrey Unitis and Karen Unitis 7 VERIFICATION I, Jeffrey Unitis, hereby verify that the statements made in the foregoing Answer with New Matter are true and correct to the best of my personal knowledge or information and belief, as well as reports, records, conferences and other investigatory material made available to me. To the extent that the foregoing contains averments which are inconsistent in fact, I verify that my knowledge or information is sufficient to form a belief that one or more of them is true, although I am currently unable, after reasonable investigation, to ascertain which of the inconsistent averments are true. To the extent that the foregoing contains legal conclusions or opinions, I hereby state that my Verification is made upon the advice of counsel, upon whom I have relied in the filing this document. This Verification is made subject to the penalties of 18 Pa.C.S. § 4904 related to unsworn falsifications to authorities. Date: uC, Jeffrey ?' VERIFICATION I, Karen Unitis, hereby verify that the statements made in the foregoing Answer with New Matter are true and correct to the best of my personal knowledge or information and belief, as well as reports, records, conferences and other investigatory material made available to me. To the extent that the foregoing contains averments which are inconsistent in fact, I verify that my knowledge or information is sufficient to form a belief that one or more of them is true, although I am currently unable, after reasonable investigation, to ascertain which of the inconsistent averments are true. To the extent that the foregoing contains legal conclusions or opinions, I hereby state that my Verification is made upon the advice of counsel, upon whom I have relied in the filing this document. This Verification is made subject to the penalties of 18 Pa.C.S. § 4904 related to unsworn falsifications to authorities. Date: Karen nitis IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD and DEEANNA POMPEO, as parents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs V. ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants NO. 10-448 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 23 day of August, 2010, I, Michael B. Scheib, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Answer with New Matter, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: George J. Costopoulos, Esquire 153 North Hanover Street Carlisle, PA 17013 (Attorney for Plaintiffs) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: 4/1 MICHAEL B. SC IB, ESQUIRE PA 63868 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheibkgslsc.com Attorney for Defendants, Anthony R. Knight, Jr. and Jeffrey Unitis and Karen Unitis r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD and DEEANNA POMPEO, as pazents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs NO. 10-4478 CIVIL TERM v. : CIVIL ACTION -LAW ANTHONY R. KNIGHT, JR., '~ c JEFFREY UNITIS and KAREN UNITIS, ~ Defendants JURY TRIAL DEMANDF,D ~ T' PLAINTIFFS' REPLY TO DEFENDANTS' NEW MATTER ~ ~ w w 24. No response required as this is a statement of law. To the extent a respo se ~ deemed necessary, the averments contained in this paragraph are denied. 25. No response required as this is a statement of law. To the extent a response is deemed necessary, the averments contained in this paragraph aze denied. 26. No response required as this is a statement of law. To the extent a response is deemed necessary, the averments contained in this paragraph aze denied. 27. No response required as this is a statement of law. To the extent a response is deemed necessary, the averments contained in this pazagraph aze denied. 28. No response required as this is a statement of law. To the extent a response is deemed necessary, the averments contained in this paragraph are denied. 29. No response required as this is a statement of law. To the extent a response is deemed necessary, the averments contained in this paragraph aze denied. 30. No response required as this is a statement of law. To the extent a response is tt, -~t G~'f 't7 ~3 '~ T -~ -~ _.~ .-~ -s deemed necessary, the averments contained in this paragraph are denied. 31. No response required as this is a statement of law. To the extent a response is deemed necessary, the averments contained in this paragraph are denied. WHEREFORE, Plaintiffs respectfully request that this Honorable Court issue an Order in their favor. RESPECTFULLY SUBMITTED: ..~- George ostopoulos, Esquire Attorney I. . # 78423 153 North Hanover Street Carlisle, Pennsylvania 17013 Phone: (717) 243-0407 Attorney for Plaintiffs Date: ~ - ~. _ ~ p 2 CERTIFICATE OF SERVICE I, George J. Costopoulos, Esquire, hereby certify that on September 7, 2010 I served a true and correct copy of the foregoing document by United States Mail, postage prepaid, upon counsel for Defendants as identified below: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402-3737 George Costopoulos, Esquire Dated: ~ - ~- --( d SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 4 ~..~~~#. ~D~ p~ ~ ~ ~~~ Sheriff w ~~a~itr of ~utnbrx~~~~ Jody S Smith ,, ~, t ,,, ~, 2~t0 OCl' 13 P~ I ~ 13 Chief Deputy '~''" ~l:rf ,,tg Richard W Stewart ~v~f~~~L~~~ ~~U~T~ Solicitor c~t~ ~ F -,.~ ~~E~(~F ~C~P~S YIw~A I'~t,~ Ronald Pompeo (et al.) Case Number vs. 2010-4478 Anthony R. Knight, Jr. (et al.) SHERIFF'S RETURN OF SERVICE 07/07/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Anthony R. Knight Jr., but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Clearfield County, PA to serve the within Writ of Summons according to law. 07/13/2010 09:13 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2010 at 2113 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Jeffrey Unitis, by making known unto himself personally, at 1340 Kuhn Road, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. C AEL BARR K, EPUTY 07/13/2010 09:13 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2010 at 2113 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Karen Unitis, by making known unto herself personally, at 1340 Kuhn Road, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to her personally the said true and correct copy of the same. MICHAEL BAR CK, EPUTY 07/23/2010 09:26 AM -Clearfield County Return: And now July 23, 2010 at 0926 hours I, Chester A. Hawkins, Sheriff of Clearfield County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Anthony R. Knight Jr. by making known unto himself personally, at SCI Houtrdale, P.O. BOX 1000, State Route 2007, Houtrdale, PA 16698 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $74.84 October 12, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySui[e Sheriff. Teleosoft, Inc. To Deputy 7/12/10 IN THE COURT OF COMMON PLEAS OF CLEARFIELD COUNTY, PENNSYLVANIA NO: 2010,4478 RONALD and DEE ANNA POMPEO, as parents and natural guardians of Chelsea Pomeo, a minor child vs SERVICE # 1 OF 1 ANTHONY R. KNIGHT JR. al PRAECIPE & WRIT OF SUMMONS SERVE BY: 08/05/2010 HEARING: PAGE: 107337 DEFENDANT: ANTHONY R. KNIGHT JR. ADDRESS: SCI HOUTZDALE. PO BOX 1000, SR 2007 HOUTZDALE. PA 16698 ALTERNATE ADDRESS SERVE AND LEAVE WITH: DEFENDANT ONLY CIRCLE IF THIS HIGHLIGHTED ADDESS IS: VACANT OCCUPIED ATTEMPTS SHERIFF'S RETURN 2 ~p , `~~n NOW, is ~ /Ul~ O ~ AT ~""' A PM SERVED THE WITHIN PRAECIPE & WRIT F SUMM NS ON ANTHON R. KNIGHT JR., DEFENDANT BY HANDING TO / A TRUE AND ATTESTED COPY OF THE ORIGINAL DOCUMENT AND MADE KNOW TO HIM /HER THE CONTENTS THEREOF. ~ ~ ADDRESS SERVED V~ NOW AT PRAECIPE & WRIT OF SUMMONS FOR ANTHONY R. KNIGHT JR. AT (ADDRESS) NOW AM / PM AFTER DILIGENT SEARCH IN MY BAILIWICK, I MAKE RETURN OF NOT FOUND AS TO ANTHONY R. KNIGHT JR. REASON UNABLE TO LOCATE SWORN TO BEFORE ME THIS ~.-~ DAY F `~`'~1 AT AM / PM POSTED THE WITHIN So A r. CHES A S I 2010 p X5+9 t ~ - ~j , WILLIA P uty am '^vf M A. SHAW Prothonotary 1st Mondaysish Jan~2014 Clearfield Co., Clearfield, PA FILED-OFFICE UP i P. E PRO T H 0 N 0 TA R 2011 FEB I I AM 11: 25 OBI PENNSYLVA1 A T'! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA gy7j RONALD and DEEANNA POMPEO, NO. 10448-EIVIL TERM as parents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs V. ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO ATTACH VERIFICATION TO THE PROTHONOTARY: Kindly attach Defendant, Anthony R Knight, Jr.'s Verification to Defendants' Answer with New Matter. Date: February 16, 2011 GRIFFITH, STRI SOLYMOS &-C By: MICHAEI,.R SCHEIB, ESQ., ID 63868 ERICK V. VIOLAGO, ESQ., ID 202344 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheibggslsc.com Eviolagog-gslsc.com Attorney for Defendants R VERIFICATION I, Anthony R. Knight, Jr., hereby verify that the statements made in the foregoing Answer with New Matter are true and correct to the best of my personal knowledge or information and belief, as well as reports, records, conferences and other investigatory material made available to me. To the extent that the foregoing contains averments which are inconsistent in fact, I verify that my knowledge or information is sufficient to form a belief that one or more of them is true, although I am currently unable, after reasonable investigation, to ascertain which of the inconsistent averments are true. To the extent that the foregoing contains legal conclusions or opinions, I hereby state that my Verification is made upon the advice of counsel, upon whom I have relied in the filing this document. This Verification is made subject to the penalties of 18 Pa.C.S. § 4904 related to unsworn falsifications to authorities. Date: 1 1. l ? Antho R. t, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD and DEEANNA POMPEO, as parents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs NO. 10-448 CIVIL TERM V. CIVIL ACTION - LAW ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this ( day of February, 2011, I, Erick V. Violago, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Praecipe to Attach Verification, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: George J. Costopoulos, Esquire 153 North Hanover Street Carlisle, PA 17013 (Attorney for Plaintiffs) By: GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKIpI8 --> ERICK V. T#IOLAGO, ESQ., ID 202344 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Eviolago(a-) gslsc. com Attorney for Defendants, Anthony R. Knight, Jr., Jeffrey Unitis and Karen Unitis RONALD and DEEANNA POMPEO, IN THE COURT OF COMMON PLEAS as parents and natural guardians of CUMBERLAND COUNTY, CHELSEA POMPEO, a minor child, PENNSYLVANIA C.._ Plaintiffs . V. NO: 10-4478 CIVIL TERM ` ANTHONY R. KNIGHT, JR., .a_ .teZ Z a JEFFREY UNITIS and KAREN UNITIS, Defendants JURY TRIAL DEMANDED ` !.rt OBJECTIONS TO SUBPOENA PURSUANT TO RULE 4009.21 Plaintiffs, Ronald and Deeanna Pompeo, as parents and natural guardians of Chelsea Pompeo, a minor child, object to the proposed subpoena that is attached to these objections for the following reasons: This request is over-broad, vexatious, and oppressive, would cause unreasonable annoyance, embarrassment, oppression, burden and expense, and is beyond the permissible scope of discovery as set forth in the Pennsylvania Rules of Civil Procedure 4003.1 through 4003.6. Furthermore, Defendants' proposed subpoena seeks information not reasonably calculated to lead to the discovery of relevant and admissible evidence. Defendants' proposed subpoena is additionally an abuse of subpoena power and violates the Pennsylvania Rules of Civil Procedure. LAW OFFICES OF GEORGE J. COSTOPOULOS By 01 Geo . Costopoulos, Esq. Pall). #78423 153 North Hanover Street Carlisle, Pennsylvania 17013 Phone: (717) 243-0407 Counsel for Plaintiffs Date: 6 --11 - /z PENNSYLVANIA COURT OF COMMON PLEAS COUNTY OF CUMBERLAND Ronald and DeeAnna Pompeo, as parents and natural guardians of Chelsea Court of Common Pleas Pompeo, a minor child vs. 10-4478 Anthony R. Knight, Jr., Jeffrey Unitis and Karen Unitis NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Provider: Record Type: Cumberland Valley School District Scholastic TO: George J. Costopoulos, Esquire note: please see enclosed list of all other interested counsel Litigation Solutions, LLC ('LSLLC') on behalf of Erick Violago, 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: 5/23/2012 CC: Erick Violago, Esquire of Griffith, Strickler, Lerman, Solymos & Calkins - Court of Common Pleas If you have any questions regarding this matter, please contact: Litigation Solutions, LLC (412.263.5656) Brentwood Towne Centre 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 Litigation Solutions, LLC on behalf of: Erick Violago, Esquire Defense COMMONWEALTH OF FENNSYLVA14Lk COUNTY OF Ci3MBERLA14D Ronald and DeeAnna Pompeo, as parents and natural guardians of 10-4478 Chelsea Pompeo, a minor child Rtle?va_-.--------- VS. Anthony R. Knight, Jr., Jeffrey Unitis and Karen Unitis SUBPOENA TO PRODUCE DOC UAMNTS OR. THINGS FOR DISCOVERY PURSUANT IF0 RULE 4009.22 Cumberland Valley School District TO: (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 Ginnrj: PLEASE SEE ATTACHED RIDER 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 at (Address) You may deliver or mail legible copies of the documents or produce things requested 4y 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 it court order compelling you to comply with it THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Erick Violago, Esquire p?D aY -Yor4 TELEPHOM St1PREMB COURT JP ATTORNEY FOR PeTr" Datr. S a I d.- ___ Seat oftbe overt ?? Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Cumberland Valley School District 6746 Carlisle Pike Mechanicsburg PA 17050 Attention: Office of the Registrar Subject: Pompeo, Chelsea Anna Maria SS#: 4465 Date of Birth: 1/13/1993 Requested Items: Complete copy of entire scholastic file from 1/13/1993-present , including : grade reports, medical records, disciplinary reports and counselor records, SCHOOL ATTENDANCE RECORDS, PHYSICAL EDUCATION RECORDS INCLUDING ATTENDANCE AT THE PHYSICAL EDUCATION CLASS, AND GYM CLASS RECORDS INCLUDING ATTENDANCE AT GYM CLASS. CERTIFICATE OF SERVICE I, George J. Costopoulos, Esquire, hereby certify that on June 11, 2012, I served a true and correct copy of the within Plaintiffs' Objections to Subpoena Pursuant to Rule 4009.21 by United States Mail, postage prepaid, upon counsel for Defendants as identified below: Eric Violago, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402-3737 l 4Geoe Costopoulos, Esquire Dated: ( --/< ? lk i Law Offices of George I Costopoulos George J. Costopoulos, Esquire PA ID No.: 78423 153 North Hanover Street Carlisle, PA 17013 Phone: (717) 243-0407 0 C, 17 Fri IJI, 3 ?: .tl A1d, f i v t of 1 Ell t "i S Y1 I'1+l° ? Counsel for Plaintiffs RONALD and DEEANNA POMPEO, as parents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs V. ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 10-4478 CIVIL TERM JURY TRIAL DEMANDED PLAINTIFFS' ANSWER TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT AND NOW come the Plaintiffs, Ronald and Deeanna Pompeo, as parents and natural guardians of Chelsea Pompeo, by and through their attorney, George J. Costopoulos, Esquire, and in opposition to Defendants' Motion for Summary Judgment, respectfully submit the following Answer: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. By way of further answer, the collision occurred when Defendant, Anthony Knight, Jr., attempted at a high rate of speed to pass a vehicle traveling ahead of him and lost control, sideswiping a barn and smashing into a utility pole. See Plaintiffs' Complaint at 1 Paragraph 6. 6. Admitted. By way of further answer, in addition to suffering a splenic laceration, fractures of her 9`' through I I' ribs, transverse process fractures of the L1 and T12 vertebrae and abrasions, Chelsea lost consciousness and is amnestic regarding the collision. See id. 7. Admitted that Chelsea testified at her deposition on September 16, 2011 to occasional ongoing back and rib pain triggered by physical activities such as "standing for long periods of time or sitting, bending, twisting, lifting." See Deposition N.T., 9/16/11, attached hereto as Exhibit "A," at 31-33.' By way of further answer, on September 27, 2010, Plaintiffs submitted answers to Defendants' interrogatories about Chelsea's ongoing difficulties, discomforts and limitations at that time including: [B]ack and rib pains, pain with deep breaths, trouble sitting or standing for extended periods, pain with jerking motions, trouble lifting or carrying heavy objects, and a restricted ability to participate in sports, cheerleading, recreation, walking, biking, dancing, socializing, shopping, driving, grooming, household chores, and going on amusement rides. See Plaintiffs' Interrogatory Answer No. 12, attached hereto as Exhibit "B." 8. Admitted. 9. Admitted that Plaintiff was insured under her parents' automobile policy with Geico Insurance which included a limited tort election. 10. Admitted. 11. No answer required as this is a statement of law. 12. No answer required as this is a statement of law. ' The undersigned counsel has appended herewith Chelsea's complete deposition testimony pertaining to the level, extent and triggers of her ongoing pain and limitations, including those excerpts omitted from Defendants' Motion. 2 J 13. No answer required as this is a statement of law. 14. No answer required as this is a statement of law. However, a motion for summary judgment should not be granted where even undisputed facts can support conflicting inferences. Washington v. Baxter, 719 A.2d 733 (Pa. 1998). 15. No answer required as this is a statement of law. However, the threshold determination of whether a Plaintiff sustained a serious injury is not to be made routinely by a trial court judge on motion for summary judgment; rather, it must be left to the jury in all but the clearest of cases, and only when reasonable minds could not differ on question of whether a serious injury has been sustained. Id. 16. No answer required as this is a statement of law. 17. No answer required as this is a statement of law. 18. No answer required as this is a statement of law. 19. No answer required as this is a statement of law. 20. No answer required as this is a statement of law. 21. No answer required as this is a statement of law. 22. Denied as stated. It is expressly denied that Chelsea, a 15-year old minor at the time of the accident, received only "limited medical treatment." Strict proof to the contrary demanded. 23. Admitted. 24. Admitted. By way of further answer, Carlisle Regional Medical Center emergency room personnel discovered that Chelsea suffered critical injuries including a Grade 1- 2 splenic laceration, multiple broken ribs and a fractured L1 vertebra. Due to the extensive 3 nature of these injuries, and the need for prompt critical care, Chelsea was transferred by ambulance to Hershey Medical Center's pediatric trauma unit, where she was classified as a Level 2 pediatric trauma patient and admitted as an inpatient for the next four days. See Carlisle Regional Medical Center Records, 8/8/08, attached hereto as Exhibit "C;" see also Hershey Medical Center Records, 8/8/08-8/12/08 attached hereto as Exhibit "D." 25. Admitted that Chelsea was discharged as an inpatient from Hershey after four days with a diagnosis of a splenic laceration, fractures of the 9' through 11 " h ribs on the left, and L 1 transverse process fractures. See Exhibit D (discharge summary). 26. Admitted. By way of further answer, Chelsea's injuries were not amenable to surgical intervention. See, e.g., Exhibit D (discharge summary) ("orthodpaedics was consulted for the transverse process fracture and stated that there was nothing to do for the fracture except control pain and her T and L spine were cleared"). 27. Denied as stated. Upon her discharge from the hospital, Chelsea was advised of the following "Activity Guidelines": 1 week/1 month rule" of activity restrictions --1 week of bed or couch rest, walking to the bathroom only, at home; this is followed by 1 month of walking only - no sports, PE class, riding things with "wheels," contact/impact activities including manual labor. See Exhibit D (discharge summary). There is no indication that these were the "only" restrictions or limitations imposed on Chelsea. Nevertheless, these are significant restrictions for a 15-year old girl in the final month of summer vacation and at the start of a new school year. Strict proof to the contrary demanded. 28. Denied as stated. Chelsea did not "follow-up" at Carlisle Regional Medical Center on August 22, 2009. Rather, she was rushed to the emergency room after waking that 4 morning with worsening symptoms of left side abdominal pain and shortness of breath. At Carlisle, Chelsea was given dilaudid for her extreme pain, and a full radiologic work-up was conducted; specifically, CT Scans of the abdomen and pelvis revealed: Follicular cystic changes in the right adnexa and small amount of free fluid in the cul-de-sac are now noted, likely related to post physiologic change. Stable appearance of the left low rib fractures and left-sided T12 and L I transverse process fractures? It was thereafter determined that Chelsea's increased pain and shortness of breath were manifestations of the abdominal injuries she sustained in the collision. Consequently, after treatment with intravenous narcotic pain medications and approximately five hours of monitoring, Chelsea was discharged from the emergency room with prescriptions for Vicodin and Reglan. See Carlisle Regional Medical Center Record, 8/22/08, attached hereto as Exhibit «E 29. Denied. Chelsea returned to Hershey for a follow-up visit with her attending pediatric surgeon, Dr. Peter Dillon, on August 28, 2008. See Hershey Medical Center Record, 8/28/08, attached hereto as Exhibit "F." Over the next 6 months, Chelsea was persistently burdened with pain and a limited range of motion about her low back, and thus consulted with orthopedist Dr. Mark Holencik on March 4, 2009, who diagnosed lumbar strain and sprain and ordered physical therapy, fording: What [Chelsea] does need is a significant amount of lumbar paraspinal and hamstring stretching and some paraspinal strengthening as she tends to have a kyphotic postural slump. Her posture and hamstring flexibility are equally dismal and since I did not examine her prior to trauma, it may be that her hamstring tightness is a reaction to several months of low back pain as it cause pain to bend 2 Of note, this repeat CT scan was interpreted to include spinal fractures of both the T12 and LI levels of Chelsea' spine. forward and stretch them. For this reason I am sending her to physical therapy for lumbar and hamstring flexibility and instruction in a home program. See Dr. Holencik Record, attached hereto as Exhibit "G." Strict proof to the contrary demanded. 30. Admitted. 31. Admitted. By way of further answer, Chelsea was discharged from physical therapy with instructions to continue an independent home exercise program. See Cumberland Orthopedic & Spine Record, 3/11/09, attached hereto as Exhibit "H." 32. Admitted. 33. Denied as stated. Dr. Holencik did not opine that Chelsea's symptoms were permanently resolved, but instead emphasized: Mother and patient both state that [Chelsea] has aches in the left thoracolumbar and rib area with weather change. This will persist for 18 months post trauma, or about another 10-11 months. How she feels next spring [2010] will be how [s]he feels for the foreseeable future but I believe it is quite reasonable to expect her to continue to do well. I advised mother and patient that if... any back pain recurs that is significant or disabling the patient should first initiate the same flexibility exercises that I hope she will maintain on a regular basis at home and that should take care of the problem. I will consider her dismissed from care pending any further adverse development ... but again remind anyone reading this that it will be another 10 odd months before she reaches maximum medical improvement. See Dr. Holencik Record, 4/8/09, attached hereto as Exhibit "I" (emphasis added). Consistent with Dr. Holencik's opinion, Chelsea's accident related symptoms, and resultant limitations, did persist in the year and half following the accident. Strict proof to the contrary demanded. 34. Denied as stated. In fact, Dr. Holencik noted: "I agree with radiology that the left lower rib fractures are minimally displaced[.]" He did not state "only" minimally displaced. See Exhibit 1. Strict proof to the contrary demanded. 35. Denied. This is a blatant mischaracterization of Dr. Holencik's treatment record given his unequivocal confirmation that Chelsea's spleen was lacerated: 6 Diagnostic studies on a disc arrive along with her today as per my previous request and the hard copy in disc form of her vertebral and rib injuries was reviewed as was the report copy of the CT scan of the abdomen and chest that reveal a visceral injury, specifically a splenic laceration and hematoma that was observed without splenic excision being required as her blood count stabilized post trauma.... I don't think that the rib fractures actually penetrated the spleen but it was a contusional injury associated with sufficient velocity to fracture these bony structures. See Exhibit I (emphasis added). Reading the record in context, Dr. Holencik is merely opining on the cause of Chelsea's rib fractures and splenic laceration (contusional injury rather than penetration). He is in no way stating, however, that Chelsea's spleen was spared in the collision. For Defendants to argue to the contrary belies common sense, as well as the entire medical record. Indeed, Chelsea was transferred from Carlisle to Hershey as a pediatric trauma patient precisely because of the splenic laceration, and admitted, in part, for hemodynamic monitoring and serial hematocrit checks to safeguard against a worsening of this condition. Strict proof to the contrary demanded. 36. Denied as stated. On April 8, 2009, Dr. Holencik noted that he considered Chelsea dismissed from his care pending any further adverse development, and instructed her to maintain a home exercise program, stressing that her symptoms would persist for 18 months following the collision, and that she would reach maximum medical improvement at that time. See Exhibit I. Chelsea's ongoing symptoms and limitations were illustrated in her answers to Defendants' interrogatories as of September 27, 2010, and during her deposition on September 16, 2011. See Answer to No. 7 above, citing Exhibits A & B. Strict proof to the contrary demanded? 3 By way of further answer, Dr. Holencck passed away in 2010. 7 37. Admitted. By way of further answer, Chelsea testified that although she continued to suffer from low back and left rib pains, she did not want to take stronger medications: "Because I know what it's causing, and I know that there can be no further treatment to fix that except stronger medications, and I don't want to go that far." See Exhibit A, at 41-42. 38. Admitted. 39. Admitted only that Dr. Hely opined as indicated. By way of further answer, Dr. Hely concurred that Chelsea suffered a splenic laceration, rib fractures and a fracture of the transverse process of the L1 vertebra. See Dr. Hely Report, dated 1/9/12. 40. Admitted. By way of further answer, Chelsea indicated her dislike for "stronger medications" and uses over-the-counter pain medications. See Exhibit A, at 42-44. In addition, while an inpatient at the Hershey Medical Center, Chelsea was treated with narcotic pain medication including dilaudid, hydromorphone and percocet, and was discharged from the Carlisle Hospital emergency room on August 22, 2008 with a prescription for vicodin. See Exhibits D & E. 41. Admitted. 42. Admitted. 43. Denied as stated. This is sheer speculation; it is equally possible that Chelsea did not participate in gym class in October 2008, or for an indefinite period of time thereafter. Strict proof to the contrary demanded. 44. Admitted. By way of further answer, the accident occurred in early August when school was not in session. In addition, due to Chelsea's injuries, and the restrictions imposed on 8 her following her discharge from Hershey, Chelsea was not permitted and unable to resume her part-time job at a local Wendy's restaurant as a result of the accident. See Exhibit A, at 37-39. 45. Admitted. 46. Admitted. By way of further answer, Chelsea testified at her deposition to activities she could no longer do, such as sports, going to the gym, lifting, or anything that has a lot of physical activity. See Exhibit A, at 35-36. She also testified that she was unable to drive a car comfortably, and that certain activities aggravated her pain, such as standing or sitting for long periods of time, and bending, twisting or lifting. See id, at 31-33; 37. 47. Admitted. By way of further answer, Chelsea testified that her injuries prevented her from going to Hersheypark with her family in the aftermath of the collision. See Exhibit A, at 46. Chelsea added that her first visit to Hersheypark following the accident was during the summer of 2011, and that she had to refrain from riding certain roller coasters because of her injuries. See id., at 44. 48. Admitted that Chelsea is not currently on narcotic pain medications. By way of further answer, Chelsea indicated her dislike for "stronger medications" and uses over-the- counter pain medications. See N.T. 42-44. 49. Admitted. 50. Denied. See Expert Report of Bernard I. Zeliger, D.O., attached hereto as Exhibit "J." Coupled with the extensive medical records which plainly illustrate the severity of Chelsea's injuries, Dr. Zeliger's report, and anticipated expert trial testimony, will be more than sufficient to allow "reasonable minds to differ" on the issue of whether Chelsea's injuries pierced the limited tort threshold. 9 51. Denied. See Answer to No. 50 above. By way of further answer, the medical record, on its face, contains abundant objective medical evidence (e.g. treatment records, x-ray & MRI reports) confirming the severity of Chelsea's injuries. 52. Denied. See Answers to Nos. 50 & 51 above. 53. No answer required as this is a statement of law. However, Dr. Zeliger's expert report, anticipated trial testimony, and existing medical record, are more than sufficient overcome summary judgment and allow this matter to go to a jury. See Washington v. Baxter, supra (threshold determination of serious injury is not to be made routinely by a trial court judge on motion for summary judgment; rather, it must be left to the jury in all but the clearest of cases, and only when reasonable minds could not differ on question of whether a serious injury has been sustained). 54. No answer required as this is a statement of law. WHEREFORE, Plaintiffs respectfully request that this Honorable Court deny the Defendants' motion for summary judgment. RESP CTFULLY SUBMITTED: Ge . Costopoulos, Esquire PA I.D. No. 78423 153 North Hanover Street Carlisle, PA 17013 Phone: (717) 243-0407 Fax: (717) 243-0950 ATTORNEY FOR PLAINTIFFS DATED: October 17, 2012 10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD AND DEEANNA POMPEO, Civil Action - Law • • • as parents and natural guardians of CHELSEA POMPEO,. No. 10-4478 Civil Term a minor child, Plaintiffs Jury Trial Demanded VS. ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants . . . . . . . . . . . . . . . . Deposition of: CHELSEA POMPEO Taken by Defendants Date September 16, 2011, 12:59 p.m. Place 153 North Hanover Street Carlisle, Pennsylvania Before Bethann M. Schoneman, Notary Public Registered Professional Reporter APPEARANCES: LAW OFFICES OF GEORGE J. COSTOPOULOS By: GEORGE J. COSTOPOULOS, ESQ. For - Plaintiffs GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: ERICK V. VIOLAGO, ESQ. For - EXHIBIT ALSO PRESENT. Exam.Niolago - C. Pompeo 31 t 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 22 24 2E indicated how long that occurred for? A. I don't remember. Q. If. I told you your records indicated it was about a month, would you have any.reason to disagree with that? A. No. Q. Are you still receiving medical treatment as a result of the accident? A. No. Q. Do you currently have a family physician? A. Yes. Q. Who is it? A. Jumper, Chad Jumper. Q. Do you know if he is a sole practitioner or if he's part of a practice? A. I don't know. Q. Do you know what city he's located in? A. Boiling Springs. Q. Do you have any scarring or disfigurement as a result of the accident? A. Scarring, no; disfigurement, not that I know of. Q. Do you currently have any ongoing symptoms or complaints as a result of the accident? A. Yes. Q. What? Filius & McLucas Reporting Service. Inc. Exam.Nioiago - C. Pompeo 32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2- 24 2E A. Q. A. Q. A. Q. A. Q. A. Q. A. Q- A. Q- A. Q• A. Q. Back pain and rib pain. Low back? Yes. And as far as rib pain, would that be the left side? Yes. Not the right side? No. And how frequently does that pain occur? Depends on the physical activities that I'm doing. Over the summer how frequently would it occur? This summer? Yes. I don't remember. Would it bother you on a daily basis? No. Do you remember if it bothered you at least once a week? No, not once a week. You've testified that you have ongoing low back and left rib pain because of this accident. What's the range in severity on a scale of 1 to 10 with 10 being the most severe? It depends on the physical activities that I'm A. Filius & McLucas Reporting Service, Inc. Exam.Niolago - C. Pompeo 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 1E 1c 2C 2] 2? 2: 21 2! 33 doing, wh atever triggers it. It could be from a nine to a two. Q. Sometimes as little as a two you're saying? A. Yes, and sometimes as ba d as a nine. Q. And it's also sometimes as little as zero? A. Yes. Q. What are the activities that aggravate your pain? A. Standing for long periods of time o r sitting, bending, twisting, lifting. Q. Have your injuries or complaints fr om the accident gotten better at all since when it first occurred? A. Yes, pain wise. Q. As far as severity? A. Yes. It's not as severe as it was when the accident occurred. Q. What about the frequency, has that reduced as well? A. Yes. Q. You testified earlier that you had whiplash or neck pain because of the accident. Did that S pain resolve, the neck pain? I A. Rephrase that. i Q. Sure. When I asked you earlier what injuries Filius & McLucas Reporting Service, Inc. ExamJViolago - C. Pompeo 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2C 21 2? 2? 24 2! you sustained as a result of the accident, you said low back, left ribs, and whiplash. Then I asked you if you meant your neck by whiplash, and you said yes. Did your neck pain ever resolve? A. Yes. Q. Do you recall when it resolved? A. Shortly after the accident. Q. Are we talking a matter of weeks, days, or months? A. Weeks. Q. It's my understanding your physical therapy was to treat your back. Is that correct? A. Yes. Q. What did the doctor at the hospital say about your spleen? A. I don't remember. Q. Do you remember undergoing any active treatment to heal your spleen? A. No, I don't remember. MR. COSTOPOULOS: I object to the form of that, Erick. I'm not sure what you mean by active treatment, and I'm not sure she does either. BY MR. VIOLAGO: Filius & McLucas Reporting Service, Inc. Eaam.Niolago - C. Pompeo 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 1E 1s 2C 21 2L 2: 2z 21 Q. Let me ask it this way, aside from the ER -- aside from the visit at the hospital at Carlisle Hospital and Hershey Medical Center, did you receive any other medical treatment for your spleen? A. I still don't remember. Q. Are there any activities you can't do now which you could do before the accident? A. Yes. Q. What are they? A. Sports or anything that has a lot of physical activity. Q. What sports did you do before the accident which you can't do now because of the accident? A. Softball. Q. When is the last time you played softball before the accident? A. Fourth grade. Q. You also said that you currently can't do anything with a lot of physical activity. A. Yes. Q. Specifically what activities did you do before the accident that you can't do now because of the accident? i A. Such as going to the gym or running around, Exam./Violago - C. Pompeo 36 k 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1s 2C 2] 2L 2; 22 2! lifting. Q. Were you a member of the gym before the accident? A. No. Q. Are you presently able to bathe and groom yourself? A. Yes. Q. Dress yourself? A. Yes. Q. Prepare meals? A. Yes. Q. Make beds? A. Yes. Q. Vacuum? A. Yes. Q. Do laundry? A. Yes. Q. Do dishes? A. Yes. Q. Clean the bathroom? A. Yes. Q. Take out the garbage? A. Yes. Q. Cut the grass? i A. Yes. Exam.Niolago - C. Pompeo 37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2- 24 2E Q. Shovel snow? A. Yes. Q. Drive a car? A. Not comfortably. Q. Are you currently able to swim? A. Yes. Q. Ride a bike? A. Yes. Q. Do you currently belong to a gym? A. No. Q. Have you taken any vacations or trips outside of central Pennsylvania since the accident? A. Not that I recall. Q. Do you recall going to the beach at all since the accident? A. No. Q. Do you recall ever leaving Pennsylvania since the accident? A. Not that I recall. Q. At the time of the accident were you working? A. Yes. Q. Who were you working for? A. Wendy's. Q. Was that part time or full time? A. Part time. Exam.Niolago - C. Pompeo 38 1 2 3 4 5 6 7 8 9 10 11 12 13 14 1.5 16 17 18 19 20 21 22 23 24 25 Q. What was your position? A. Cashier. Q. How many hours per week do you work on average? A. Now or the accident? Q. At the time of the accident before it occurred. MR. COSTOPOULOS: At Wendy's. A. Sixteen hours. BY MR. VIOLAGO: Q. After school? A. Yes. Q. Do you recall on average about how many days per week that 16 hours would be divided up by? A. Four hours a day so three or four days. Q. Did you miss any time from work because of the accident? A. Yes. Q. How much time from work did you miss? A. I don't recall, but. Q. Can you estimate? A. Two weeks, maybe longer. Q. Do you recall if any doctor told you not to work or took you off work? A. Not that I recall, but I no longer did work there. Q. You stopped there before the accident? Exam.Niolago - C: Pompeo 39 i 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2E A. After. Q. I'm talking for the two weeks that you missed because of the accident, do you recall if a doctor took you off work for that time? A. I don't recall. I wasn't allowed to work, I know that, so yes. Q. Who told you, you were not allowed to work? A. I don't remember. Q. When you did resume work, did you resume the 16 hours per week? A. I didn't finish with work. I didn't resume work after the accident. Q. Never went back to Wendy's after the accident? A. Yes. Q. Was that because of your injuries from the accident? A. Yes. Q. Earlier we talked about how you treated at the hospital on the day of the accident, and then your next memory was physical therapy which was after seven months. A. Yes. Q. During that seven-month gap in treatment, were you still in pain? A. Yes. Exam.Niolago - C. Pompeo 40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2C 21 22 2_ 24 2E Q. Were you on any pain medications during that seven-month gap? A. Not that I remember. Q. If you were in pain, was there any reason that you didn't seek medical treatment? A. Rephrase that. Q. Sure. Your medical records indicate about a six- or seven-month gap in treatment. MR. COSTOPOULOS: I object to that. That's not what they indicate. MR. VIOLAGO: Okay. BY MR. VIOLAGO: Q. Before starting physical therapy, is there any reason that you didn't seek medical treatment sooner? A. I don't remember. MR. VIOLAGO: What do your records indicate? MR. COSTOPOULOS: Let's go off the record. (Discussion held off the record) BY MR. VIOLAGO: Q. In the fall of 2008 you were in ninth grade, right? A. Yes. Q. Can you tell me-what your average weekend was in Filius & McLucas Reporting Service, Inc. Exam.Niolago - C. Pompeo 41 E 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2E the fall of 2008? A. Rephrase that. Q. Sure. In September of 2008, that would be the September after the accident occurred, what did you typically do on weekends? A. I don't remember. Q. Do you remember if you went to high school football games? A. I don't remember. Q. Earlier you testified that the last time you treated for this accident was with Dr. Mark Holencik. Does that sound accurate? A. Yes. Q. The records indicate-- And I asked you if the records indicated that that last visit was in April 8 of 2009, would you have any reason to disagree with that, and you said no. A. Yes. Q. Do you recall that? A. Yes. Q. If you continue to have pain that gets as bad as a 9 out of 10, is there any reason why you're not seeking medical treatment? A. Rephrase that. Q. Sure. If you continue to have pain currently Filius & McLucas Reporting Service, Inc. Exam.Niolago - C. Pompeo 42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2C 21 22 2- 24 2E since that last visit with Dr. Mark Holencik, why aren't you seeking medical treatment? A. Money. Q. Do you currently have health insurance? A. Yes. Q. Do you not believe your health insurance will cover those bills? A. They would. I really don't understand the question that you're asking. Q. Sure. Usually if you're hurt, if you're in pain, you go seek medical treatment. You've just testified that you continue to have pain that gets as bad as a 9 out of 10 sometimes. Why don't you seek medical treatment? A. Because I know what it's causing, and I know that there can be no further treatment to fix that except stronger medications, and I don't want to go that far. Q. Who's told you that? A. Nobody. It's myself. Q. Are you currently on any pain medications? A. No. Q. Did you ever take Hydrocodone or Oxycodone as a result of the accident? A. I don't recall.' Filius & McLucas Renortine Service. Inc. Exam.Niolago - C. Pompeo 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 43 MR. COSTOPOULOS: Do you know what that is? A. No. BY MR. VIOLAGO: Q. Only if you know, do you know if you ever took any narcotic pain medication for this accident? A. After the accident-- Q. Yes. A. --or while I was in the hospital? Q. Anytime after the accident. A. I know in the hospital I had pain medication, but after the accident, I'm not sure. Q. By that you mean after the hospital you're not sure? A. Yeah. Q. Did you ever take over-the-counter pain medication for the accident? A. Such as Advil or Ibuprofen? Q. Yes. A. Yes. Q. Can you just describe how frequently or how often you would take that? A. Can you give me a time estimate like-- Q. Sure. Start with after the accident and after getting discharged from the hospital, August 12, '08. ExamJViolago - C. Pompeo 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 2E A. Every four hours after getting discharged. Q. Let's talk about let's say the fall of ninth grade, were you still taking over-the-counter pain meds? A. I don't remember. Q. Have you ever been to Hersheypark since the accident? A. Yes. Q. When is the first time you went to Hersheypark after the accident? A. This summer. Q. How many times did you go this past summer? A. I don't remember. Q. Did you refrain from riding any rides due to your injuries from the accident? A. Yes. Q. Which rides did you not ride because of the accident? A. The Wild Mouse and Wildcat. Q. Is the Wildcat a roller coaster? A. Yes. Q. Is the Wild Mouse also a roller coaster? A. Yes. Q. Did you ride any other roller coasters at Hersheypark? Filius & McLucas Reporting Service, Inc. Exam.Niolago - C. Pompeo 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 A. Yes. Q. About how many did you ride? A. I don't remember. Q. Did you ride the grand water river rapids or the river rapids ride, whatever name it is? A. I don't remember. Q. Did you ride the Sidewinder? A. No. Q. Did you ride the bumper cars? A. No. MR. COSTOPOULOS: Sounds like you've been to Hersheypark. BY MR. VIOLAGO: Q. Did you miss any time from school because of the accident? A. I don't remember. Q. Do you remember if the accident affected your social activities or limited them in any way in ninth grade? A. Name social activities. Q. Did it prevent you with hanging out with your friends or whatever else -- whatever it is that you would have done in ninth grade outside of school? A. Depending on what activities they were -- that Filius & McLucas Renortine Service. Inc. Exam.Niolago - C. Pompeo 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2? 24 2E they were doing. Q. What activities do you specifically remember not taking part in because of the accident? A. Hersheypark. That was with family, though. Q. When was that? A. In-- I don't remember. Q. Was it the summer after the accident? A. Yeah. Q. So it would have been the same year, 2008? A. Yes. Q. Anything else you remember? A. No. MR. VIOLAGO: I nothing further. (Discussion held off the record) BY MR. VIOLAGO: Q. Earlier I asked about your siblings. Off the record you said you had an older sister as well? A. Yes. Q. What's her name? A. Amber Pompeo. Q. How old is she currently? A. Twenty-four. Q. Did she live with you at the time of the accident? A. No. Filius & McLucas Reporting Service, Inc. - 9117 ",C I1GI14 v._a_ A19 QAG CA1Q 1 011A Law Offices of George J. Costopoulos George J. Costopoulos, Esquire PA ID No.: 78423 153 North Hanover Street Carlisle, PA 17013 Phone: (717) 243-0407 Counsel for Plaintiffs RONALD and DEEANNA POMPEO, as parents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs V. ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 10-4478 CIVIL PERM JURY TRIAL DEMANDED PLAINTIFFS' ANSWERS TO DEFENDANTS' INTERROGATORIES - SET NO. I Chelsea Anna Maria Pompeo; D.O.B.: 1/13/93; Address: 1298 Brandt Road, Mechanicsburg, PA 17055. 2. N/A. 3. Plaintiff Chelsea Pompeo is a high school student. 4. N/A. 5. Plaintiff has worked part-time after school/summer jobs at Kohl's Department Store (323 York Road, Carlisle, PA 17013)(job duties: cashier & stocking) and Wendy's Restaurant (6 Old Mill Road, Dillsburg, PA 17019)(job duties: cashier, cleaning & stocking). 6. 179-74-4465. 7. Plaintiff earned approximately the minimum wage for her part-time after school/summer jobs. By way of further answer, Plaintiff is not pursuing a claim for past lost wages. 8. Plaintiff was a passenger in a vehicle struck by an unknown hit and run driver on January 13, 2006. Plaintiff was not injured. The driver of the vehicle in which Plaintiff was a passenger was Barbara Sheridan. Samantha Sheridan was a second passenger in that vehicle. EXHIBIT s Plaintiff recalls treatment with Dr. Russell Macaluso, MD (850 Walnut Bottom Road, Carlisle, PA 17013) for ear infections, as well as routine general care visits with her family physician, Dr. Alexander Spasic, MD (816 Belvedere Street, Carlisle, PA 17013). 10. Plaintiff recalls treatment at the Fredricksen Outpatient Center (2015 Technology Parkway, Mechanicsburg, PA 17050) by Dr. Russell Macaluso to remove her tonsils and to insert ear tubes to treat her ear infections. H. Plaintiff's accident related injuries include, but are not limited to, a splenic laceration, fractures of the 9"' through I 1 `h ribs, transverse process fractures of the L-1 and 4'-12 vertebrae, abrasions to the right temporal area of the head, right temporal area of the face, and legs, and amnesia. 12. Plaintiff's ongoing difficulties, discomforts and limitations include, but are not limited to, back and rib pains, pain with deep breaths, trouble sitting or standing for extended periods, pain with jerking motions, trouble lifting or carrying heavy objects, and a restricted ability to participate in sports, cheerleading, recreation, walking, biking, dancing, socializing, shopping, driving, grooming, household chores, and going on amusement rides. Plaintiff has also sustained stress, fear and mental anguish. 13. Carlisle Regional Medical Center (361 Alexander Spring Road, Carlisle, PA 17015) on August 9 and August 22, 2008, and Penn State Milton S. Hershey Medical Center (500 University Drive, Hershey, PA 17033) on August 9 through August 12, 2008, and August 28, 2008. While the exact sum of money paid on Plaintiff's behalf for medical care has not yet been determined, the approximate pre-Act 6 amount of bills submitted by her providers exceeded $30,000.00. Moreover, Plaintiff's first party automobile carrier, Geico, expended its policy limits of $5,000.00 for her collision related treatment. Upon exhaustion of first party medical benefits, Plaintiff's medical insurer, Highmark Blue Shield, expended funds for her excess collision related bills. See PIP payout ledger and medical billing statements. The precise amount of expenditures paid will be provided when determined and available to the extent required by the Pennsylvania Rules of Civil Procedure. By way of further answer, and in accordance with Pa.R.C.P. 4006(b), the information requested in this Interrogatory can be ascertained from Plaintiff's medical records, billing statements and insurance documentation. 14. Plaintiff objects to this request as framed because the term "other medical person" is over broad, unduly burdensome, and seeks information not reasonably calculated to lead to the discovery of admissible evidence. Without waiving and subject to these objections, Plaintiff was or may have been treated and/or examined, and/or her condition was or may have been evaluated, by doctors including, but not necessarily limited to: 2 VERIFICATION We, Ronald & DeeAnna Pompeo, do hereby verify that the statements made in the foregoing document are true and correct. We understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. RONA.D POMPEO DE .ANNA POMPEO r j J DATE I C TRW& ADMISSION RECORD M a D I G A 4 G a N T R K ACCOURT- W- ?-- MEDICAL 381 Alexander Spring Road • Carlisle, PA 170154129 ¦ 17M 249-1212 91 4.0 9 4.19 8 0 0 0 0 7 7 8 8 4 P ADMIT DATE ! ME ROM N PT IC AG ATE OF BIRTH EX RA M LOCATION PROGRAM A 08/09/2008 03:37 0000 El I F 15 01/13/1993 F 1 S T i POMPEO, CHELSEA A 179-74-4465 PATIENT Y STUDENT-CVHS Y EN . E 12,98 BRANDY RD N MECHANIC'JBURG PA 17050 US PHONE NUIMSER (717)440-8279 COUNTY CUMBERLAND T :G RESPONSIBLE TY & ADDRESS POMPEO, DEEANNA D SS NUMBER RESPONSIBLE PARTY EMPLOYER CNRC EMPLOYER PHONE U 1298 BRANDT RD 233-19-0392 1000 CLAREMONT ROAD (717)243-2031 CARLISLE PA 17013 A PHONE NUMBER RELATIONSHIP P-kffM R MECHANICSBURG PA 17050 US (717)440-8279 MOTHER RESP EMERGENCY CONTACT NAME not in household EMERGENCY CONTACT PHONE EMERGENCY CONTACT RELATIONSHIP TO PATIENT POMPEO, BARBARA (717)249-6472 GMOTHER CbMMENTS M MED. K PRIVACY DMIT, BY pY MN pY ®N Y CGS PRIVACY 1 1 PAYER - 342 PLAN FOLICY NUMBER 058.771.070$ 111FITH DATE OF 10/16/1969 G I 0 AUTO INS IN PO PE DEEANNA D 1 GEICO BLVD GROUP NUMBER GRQVPNAME N FREDRICKSBURG VA 22412 NONE HORIZATION PAYER i R UP NUMBER A AUTHORIZATION N 3 PAYER PLAN POLICY BIRTH C 111=11M Co. "ME & ADDRESS INSURED S NAME GROUP NNUMBER GROUP M ,E AU A DR. ATTENDING /ADMITTING DR.-FAMILY I MIMARY A I MILLER, KATIE J. SPASIC, ALEXANDER S DIAGNOSIS I N SYMPTOMS C MVA--MINOR INJURY NO FAULT - 08/09/2008 PRINCIPAL DIAGNOSIS (The condition established after study to be chiefly responsible for - CHARGE DATEITIMIE occasioning the admission of the patient to the HOSPITAL for care). 7 I I/ COMPLICATIONS COMORSIDITYIIESI PRINCIPAL PROCEDURE EXHIBIT HMA7120 I OW11111 MEFTIM"M 9409498 ' INITIAL ASSESSMEW FORM PRIORITY: 3 Patient: POMPEO, CHELSEA A Urgent DOB: 01113/1993 AGE: EDP: "MILLER-MD, KATIE DATE: 08/09/2008 PCP: SPASIC, ALEXANDER Carlisle Regional Medical Center Pt#: 9409498 15YRS Sex: F MR#: 0000778849 Worker's Comp: Emp. Referred: Presentation Time: 03:37 Triage Time: 03:37 Arrival Mode: BLS Height: ' " Weight: 110.0 Ibs. 50.0 kgs. LMP: Last Tetanus: Acc By: Chief MVA--MINOR INJURY Complaint: Brief front seat passenger. no seatbelt, sitting on ground at scene. states has pain in I ribs and luq. Assessment: NIGHT SWEATS NO HEMOPTYSIS NO WEIGHT LOSS NO FEVER NO ANOREXIA NO SAFETY NO TRAVELILIVED NO RESTRAINED NO DRIVER NO AIRBAG DEPLOYED LINK Vital Signs T: 97.3 PO P: 89 Regular R: 18 Unlabored BP: 144/067 02: 100 % RA Pain Intensity Scale: 8 /10 Pain Location: Abdomen Sudden Onset. Pre-Hospital Treatment: Pediatric G&D App. for Age - NIA, Immunization UTD - NIA, Height ft. in., Head Circ. - Grade -, with Assessment: Past Medical BILAT MYRINGOTOMIES, depression, reflux History: Allergies: MORPHINE Medicines: prozac, protonix, bop Nurse Signature: SEN C)'3-3 L L Additional Notes: Rev 05/18104 ti.MVC 1a2 + Carlisle Regional Medical Center m ra ics and Tae: Date In:0810912008 Pres Time:03:37 Pt#:9409498 MR#:0000778849 Triage Time: 03:37 Triage Note: T: 97.3 PO Name: POMPEO, CHELSEA A Arrival Mode: BLS front seat passenger. no seatbelt. sitting on ground at scene states has P:89 Regular . Age: 15YRS DOB: 0111311993 Sex: F Wt:lbs: 110 kgs: 50 R:18 Unlabored pain in I ribs and luq. PCP: SPASIC, ALEXANDER BP: 144/067 EDP:'MILLER_MD, KATIE 02 Sat:100 % NL / hypo Chief Complaint: VIVA-MINOR INJURY Pain I Location: 8/Abdomen cc / HPh Level 1-3 =1-3 elements Level 4 r 4 elements Level 5 = 5 elements Time See ? Translator ursing Notes Reviewed Additional History: ly spouse EMS neg. home other. ent Hx Source fami Hx Ltd Bypoor historian dementia severity hearing Intoxicated < r L Onset m rs days wks mths ago > sev ?110 current _ 110 max Sever) , mild ACA ?c Type of Vehid ati truck bus bicycle moped motorcycle auto vs. pod ! al ag dePtvyed--lestt h;ed. helmet Type of Collision: multi vehicle ?airf a I asleep / Site of Im back right a Position in hide: driver passenger front rear Velocity -amae. st _ low moderate minimal I modera c ?Ta lilies Other Issu ambul at see ejected extricated assisted out of v Location atnlsxs: he- aid-f k back: upper 1 middle / lowe &-o-`m- e? ', upper extremity: right I left lower extremity: right I left _ ?..?_ LOC: LOC`?sec I min remembers: impact I personnel I transfer to ED I remains unconscious Associated S&S: dy ea head$che motor weakng_ right I left para-dMesiea: right / left naaseaivomiNag.... vis nges laceration(s) ROS: Level 1-3 = 1 system Level 4 = 2-9 systems Level 5 = 10+ systems General Eyes ENT Respiratory Cardiovascular Gastrointestinal Genitourinary Feve/chiils Visu hanges Sore at ShorDless of Breath Ch"Wain Nbusea I Von%gg D 'a Weight loss Redness Hoarse Voice Cough Palpitations Diarrhea Fru Y General Weakness Dryness Epistaxis Congestion PND Constipation Vaginal Bleeding Polyurea Diplopia I Auditory Acuity Hemoptysis Orthopnea Rectal Bleeding Vaginal Discharge Polydipsia Itching Nasal DraWCong. DOE Black Stool Penile Discharge Musculoskslstal Neurological Psychological Skin Immuniloocal *viewed Joint Pain Syncope AnxiW Rush Recurrent Hives AUftLsptems negate Joint Swelling NeticZain Headache Focal Weakness Depression Hallucination Pruhtis Lesions HIV / AIDS Anaphylactic Rxn unable to obtain due to: ALOC acuity Back Pain Paresthesia Insomnia Bruising dementia poor historian Myalgias Confusion Stress Bleeding intoxicated Past Famll Social Hx: Level 1-3 = none Level 4 = 1 section Level 5 = 2-3 sections Past Medical History: Additional Past Medical History: BILAT MYRINGOTOMIES, depression, reflux Current Medications: Past Surgical History: None CABG Appy Choly T&HIBSO prozac , protonix , bcp Other: Family History: Negative CAD / Ml DM CA CVA Other: Allergies: / ` Social Histo : TobaccA`PPD I N / Quit Living: M / S I D / Alone MORPHINE Alcoho enies ocial / Heavy / Alcoholic Reproductive History: G_ P_ A____ Last Menstrual Period: Substance Abuse: N I Y : Menses History: Regular / Irregular I Post-partum / Pre-menarch t t T L Other. anus: as e Ph slcal Exam: Level 2-3: 2-4 systems Level 4: 5-7 systems Level 5: 8+ systems ` Indicates system examined and negative General: Distress: NAD 1d moderate severe well nourished no evidence of trauma anxious cachetlc ese disheveled dehydrated chronic illness nsy. home pt. malnourished other RENT: NL` ears Ni- nose NL sinus endemass: ary: R / L frontal: R / L nasal drainage: clear! purulent ear canal: R / L erythema 1 obscured TM: R / L erythema igtng perforated pharynx: exudate erythema abscess other: Eyes: NL' R I njunctiva NL NL Tundus R pup . -- pupil: ^ mm conjunctive: Injected I drainage R/ L other Pro- Mtuuomplement ... r,.?,,..,.. -111-.11-111-, MVC 2d2 + Carlisle Reaional Medical Centar Name: POMPEO, CHELSEA A Date In: 08/0912008 MR#:0000778849 PW: 9409498 Slca am: cont. Level 2-3:2-4 systems Level 4:5-7 systems Level 5,8+ systems NL' indicates system examined and negative Neck: N "' -tend nless RO trachea midline non-tender -. SL,fV Q Qerx_t ??( c-t-jC,,-,, C-co or in place spasm muscle tender to palpation: R 1 L bony tend to palpation: R / L limited/ painful ROM 2!? Chest: nder NIL excursion 1 expansion no retractions pa o. hest all s?m retractions Hall chest subcutaneous emphysema other: _ N E CV: no ur gallup PMI NL pulses NL ycardic irregularrirregular rhythm extra systoles murmur _16 systole/diastole pulses: decregsed/ absent R / L carotid femoral dorsalis pedis radial ulnar other: Respiratory: NV 4Vi toq d;Ir th sounds effortless unequal / decreased sounds crackles wheezes rates rhonchi labored stridor retractions cheyne stokes other; Abdomen: NL' pearance N BS NL n?orl tender rectal NL guiac negative no orpanomegaly obese : hyper I hypo / absent guarded lender mass 1 pulsatile heme + stool / blood - Sack: NV OM NL, o CVAT emess ? . R 1 L I bil CVA boh'y / muscle dorsal lumbar sacral coccyx Extremities: NL` nCh-tende? ull ROM no edema / erythema pelvis stable hips non-tender shortened / ext. rotated: R / L effusion: R I L limited ROM: R / L other: yarr? kin: e ? no rash hot , ? hot co iaphoretic cyanotic pallor edema erythema ecchymosis other: ' Neuro: NL ri x CN's Lf?(2 1^ motor'1 sensory NL rebellar function NL DTRs symmetric 2 D.1 obtund R ! L CN deficit other: I I I alert a atgno a Psych: NL' act NL b vlor NL i I ah - anxious hostile -fiat a ec depressed combatative psychosis other GU: NL" ext genitalia NL no urethral bleeding no lesion no edema deferred C, urethral blood other; L=Lac A=Abrasion E=Echymosis Medical Decision Makin : UA: NL I except C-Spine: Interpreted by EDP 1 / 213 Views _ xcept WBC LE nag acute __ other: ` RBC Blood CXR /! Interpreted by EDP NIL I except Preg Screen: urinelserum: nag / pos _ NAI Infiiitrate ? t 1 Tox Screen: nag I pos , ALT Amy rop PT Abd: _ NSBGP obstruction /- q EKG: nag I pos AST Lipase CKMB IN Head CT: Other / Procedures: Ita!je L-/ /`!Z hu ?Zr-jgj? - ' i Consultation: Clinks/ Course & Re-evaluation: aza"t Time: . Disc with Dr. Mods: aklek" Time: Improved /"Worse I Unchanged will -see patient in office --??It ? see In consult Time: Improved / Worse / Unchanged Time: . Disc with Dr. IVF: [) Patient re-examined will _see patient in office __.- admit _ see in consult (]Critical care: 30-74 minutes/ 75-104 minutes ? See procedure note ?See addendum C110101 lm msslon: Disposition: 1. Time: 2 Discharge: Home NH Psych Fac Jail 3 Admit: Floor ICU CU bs OR Tele Psych Peds ?orders written Transfer: Facility: Rcv Physician: 4 f ?T AMA LWOT DOA E f t d rans orms compe er xp e 5. Condition: Stable Satisfa cr Improved Critical Guarded Emer ent Non-emer ent y g g Instructions: Follow up with: ? Prescription(s) given: _ Follow up care discussed with: patibrif family spouse other: ? PMD Additional Instructions: C1 Doctor ? ED ? Other In _ day(s) ? AM Signatures: PAIARNP MD/DO Pro-Mitu Compisment (arde poem es, r oaMlasn pemnem nagstpmvge aoattmnal1 7 ny V Rev. 08116105 • ORDER PROCEDURE !CORM ORTHOPEDIC EMERGENCIES Date In: 819/2008 Time: Carlisle Regional Medical Center Name:POMPEO, CHELSEA A Pt#;9409498 Age: 15YRS DOB: 01113/1993 Sex; F MR#:0000778849 EDP: WILLER_MD, KATIE PCP; SPASIC, ALEXANDER Laboratory Tests Other Diagnostic Tests Order Time Order Sent B Order Time Radiology Order sent B Y - CXR P Porte le 1 c 14 ed Rate C-Spine (X-table) (Complete) Uric Acid C1 d? 1v16 T, k V Can _ RA Factor serum), (urine) ( gH Screen or Cross #- _ -Units T CardlopulmonarL _ EKG UA ABG Beta HCG 02 LPM Misc. Orders Medical Necessity Information: i Previous Medical Records Physical Therapy - Eval 8 Tx Weight: Ibs:110 kgs: 50 Allergies: MORPHINE Order Time Medication I Dosage 1 Route VO Read Back Adm time Adm by Site Time Reassessment Pain Initials a* S ZI) 17 0'34 v $N ?? []Improved ? Worse ? Unchanged /I 'W Q Qlmproved ?Worse ?Unchanged f, Improved ? Worse Q Unchanged Olmproved ? Worse OUnchanged © ? Improved p Worse Q Unchanged Order Time IV I Solution I Added MediceWn StartTime Device / I - Size Loca tion # Attempts Amount Start by D/C Time Amt Infused 1C by ERGO Device: M ? IV Fluid Procedures I Nursing Assistance Q Cardiac Monitor Rate- Rhythm ? Splint Application p (Local), (Regional) Anesthesia ? NIBP Monitor ? Pulse Oximetry Q Ace Bandage Application Q Conscious Sedation Q (Cold), (Heat) Application ? Sling Application Q Laceration Repair p Wound Irrigation ??? ? C-Spine Immobilization ? Cast Application Q Dressings Q Foreign Body Removal ? Fracture Care (open), (closed) Discharge Instructions I ure: Initials/Signature: Inhials/Signature: Initials/Slgnature: PAIARNP: Physl s Si atur . A ?&/ ?4 / // V `--- Rev. 09M4104 Fax from : 67891042591 e6-99-ee e5:93a Pg: 1 USTeleradiology (Quantum Medical Radiology) PHONE (678) 904-2599 FAX (678) 904-2592 "PRELIMINARY PRELIMINARY REPORT ONLY" Received: 8/9/2008 4:48:56 AM EST Read: 8/92008 4:55:19 AM EST Facility: Carlisle Regional MC Status: Emergency Room Study: CT A/P w/ Contrast Name: POMPEO, CHELSEA A MVA Study Count: 2 Patient Information: Female DOB: 0111311993 MRN: 778648 Indleations/Histw . impressions. 1. Laceration of posterior pole of spleen, approxhuately 1.6 cm in depth. No associated hemoperitoneum is Identified. The vascular pedicle of the spleen is intact 2. the liver, pancreas, kidneys are Intact 3. nondispiaced fracture of left posterior ninth, 110th, and 11th ribs 4. nondisplaced fracture left transverse process of L1 Physician: Scott Pretodus, MD S' nature: Electronically Signed By Over read: Physician: Signature:: ElectronicaPY S/gned By Please circle the score that best summarizes your findings as it pertains to the urgent patient care setting l -Concur with interpretation 2-Difficult diagnosis, not ordinarily expected to be made 3-Diagnosis should be made most of the time 4-Diagnosis should be made almost zverytime-misinterpretation of finding Reason: CARLISLE REGIONAL MEDICAL CENTER 361 ALEXANDER SPRINGS ROAD CARLISLE PA 17015 (717) 960-1683 RADIOLOGICAL INTERPRETATION PATIENT NAME: POMPEO CHELSEA A X-RAY#: 778849 EXAM DATE: 8/09/2008 ORDERING: KATIE J MILLER,MD 717 245-5505 ATTENDING: CONSULTING: ALEXANDER SPASIC, MD 258-0099 HISTORY: MVA--MINOR INJURY TRAUMA. IV CONTRAST MVA--MINOR INJURY CT ABDOMEN & PELVIS WITH CONTRAST CLINICAL HISTORY: Motor vehicle accident. MED REC #: 778849 ACCOUNT #• 409498 D.O.B.: O1 13/1993 ROOM: E _ COMMENT: The studies were obtained with IV contrast. There is an lower pole laceration of the spleen. It measures approximately 15 mm. There is no associated hemoperitoneum seen. The solid organs in the abdomen are otherwise intact. There are left posterior 10th and 11th rib fractures as well as a nondisplaced left transverse process fracture of L1. The lung bases are free of a pneumothorax. PELVIS: There is a small amount of pelvic free fluid in the dependent pelvis. The pelvic soft tissue structures are otherwise without abnormality. There is no pelvic fracture evident. IMPRESSION: 1. Small lower pole laceration of the spleen. 2. Two left rib and left Ll transverse process fractures. REVIEWED AND SIGNED CHRISTOPHER LADD,MD INTERPRETING PHYSICIAN DATE DICTATED: DATE TRANSCRIBED: DATE SIGNED: TRANSCRIPTIONIST: 3407527 CT ABDOMEN WlCONTRAST CT PELN 8/09/2008 8/09/2008 11:45 8/09/2008 13:51:28 TE E.R. PAGE 1 OF 1 IS W/CONTRAST CARLISLE REGIONAL MEDICAL CENTER 361 ALEXANDER SPRINGS ROAD CARLISLE PA 17015 (717) 960-1683 RADIOLOGICAL INTERPRETATION PATIENT NAME: POMPEO CHELSEA A X-RAY#: 778849 EXAM DATE: 8/09/2008 ORDERING: KATIE J MILLER,MD 717 245-5505 ATTENDING: CONSULTING: ALEXANDER SPASIC, MD 258-0099 HISTORY: MVA--MINOR INJURY MVA--MINOR INJURY MED REC #: 778849 ACCOUNT #: 9409498 D.O.B.; 01/13/199 ROOM: ER PA CHWT CLINICAL HISTORY: Motor vehicle accident. COMMENT: There is no pneumothorax and the lungs are clear. There is no widening of the mediastinum. As visualized the bony thorax is intact. REVIEWED AND SIGNED CHRISTOPHER LADD,MD INTERPRETING PHYSICIAN DATE DICTATED: DATE TRANSCRIBED: DATE SIGNED: TRANSCRIPTIONIST: 3407519 CHEST AA SINGLE VIEW 8/09/2008 8/09/2008 11:45 8/09/2008 13:51:28 TE E.R. PAGE 1 OF 1 Nfilton & Hmhey Medical rtter College of Medicine Patient ]Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 E m e r g e n c y D e p a r t m e n t N o t e D o c u m e n t Final Document Electronically Signed by: Rodgers, Daniel R 8/12/2008 10:41:12 AM ED SUMMARY Name: POMPEO, CHELSEA A HMC Number: 7503644 DOB: 01/13/1993 Date of Service: 08/09/2008 CHIEF COMPLAINT: Pediatric trauma transfer. HISTORY OF PRESENT ILLNESS: By report of the outside hospital, Carlisle, and EMS, patient is a 15-year-old unrestrained passenger in a motor vehicle crash in the front seat. Moderate speed crash. Patient upon arrival of EMS was found "curled in a fetal position complaining of left upper quadrant pain." She states this pain increased with any motion. She was transported to Carlisle Hospital where she was evaluated with plain film radiography of the chest and CT of the abdomen and pelvis where a grade 1-2 splenic injury was noted without hemoperitoneum and fractures of the 9th through the 11th ribs on the left were noted. Patient was transferred to the Pediatric Trauma Center for further evaluation and care. She complained of some discomfort as noted above and this pain responded to morphine. There were no issues during transport. On arrival, the patient complains of the same pain which increases with range of motion or palpation localized to the left upper quadrant. She denies shortness of breath, cough, or hemoptysis. She does complain of a mild headache. PAST MEDICAL HISTORY: Gastroesophageal reflux, depression. ALLERGIES: Morphine. MEDICATIONS: Oral contraceptive, Prozac, Protonix. SOCIAL HISTORY: She denies alcohol and tobacco use. FAMILY HISTORY: Noncontributory. REVIEW OF SYSTEMS: Negative except as noted above. PHYSICAL EXAM: Vital signs: Please see trauma flow sheet. General: Well-developed, well-nourished female. Glasgow coma scale 15, alert and cooperative. HEENT: Head normocephalic. There is a superficial abrasion at the right temporal area. There are no palpable stepoffs. There are PE tubes visible in both ears with a small amount of dark material in the right ear. There are no oral lesions. Neck: Supple. There is no midline tenderness to palpation. Spine: There is mild midline tenderness to palpation of the thoracic and lumbar spine. No palpable stepoffs. Chest: Clear to auscultation bilaterally. Breath sounds are symmetrical. There is tenderness to palpation at the left costal margin. EXHIBIT Date Printed: 1013112008 PENNSTATE Milton & fey Medical Ceder College of Mine Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 E m e r g e n c y D e p a r t m e n t N o t e D o c u m e n t Final Document Electronically Signed by: Rodgers, Daniel R 8/12/2008 10:41:12 AM Abdomen: Soft with left upper quadrant tenderness to palpation. There are no peritoneal signs present. Pelvis is stable. Extremities: Exhibit no cyanosis, clubbing or edema. There is no tenderness to palpation of the upper and lower extremities. Neurologic: Cranial nerves II-XII are intact. Upper and lower extremity strength is 5/5. Sensation is grossly intact to the trunk and extremities. Skin: As noted above. ASSESSMENT AND PLAN: A 15-year-old female with grade 1-2 splenic injury with left rib fractures and fracture of the transverse process of the first lumbar vertebrae. Patient was called as pediatric trauma level 2. We appreciate the bedside evaluation. Patient will be admitted to the pediatric IMC for further evaluation and care by the Pediatric Surgery Service. ADMITTING DIAGNOSES: 1. Splenic laceration. 2. Multiple rib fractures. 3. First lumbar vertebra transverse process fracture. Patient is stable at time of dictation. 111985 Review/Sign: Rodgers, Daniel R, MD DRR /SDG DD: 08/09/08 DT: 08/09/08 10:37 Date Printed: 1013112008 Time Printed: 4:57 AM PENNSTATE Milton S. Hershey Medical Center College of M Mane Penn State Milton S. Hershey Medical Center Tel: (717) 531-8055 Penn State College of Medicine Health Information Services, HU24 500 University Drive P.O. Box 850 Hershey, PA 17033-0850 Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 Patient Sex: Female Date of Birth: 1/13/1993 Patient Location: 7MBS, 7238, 01 Visit Number: 10503644 Visit Type: Inpatient H i s t o r y a n d P h y s i c a l D o c u m e n t Final Document Electronically Signed by: Dillon, Peter W HISTORY & PHYSICAL Name: POMPEO, CHELSEA A HMC Number: 7503644 DOB: 01/13/1993 Date of Service: 08/09/2008 8/10/2008 11:24:29 AM Ms. Pompeo is a 15-year-old female who was transferred to The Hershey Medical Center as a level 2 pediatric trauma. She was the 15-year-old unrestrained passenger riding in the front passenger seat when she was involved in a motor vehicle collision. She states she was sleeping at the time and woke up to have her friend helping her out of the car. She does recall the ride before and after the accident. She states that she has no loss of consciousness. She does complain of some left-sided chest and abdominal pain. Her scans from the outside hospital show a grade 1 splenic laceration, an L1 transverse process fracture, and left 9-11 posterior rib fractures. Her past medical history is significant for reflux and depression. Her past surgical history is significant for tonsils and bilateral ear tubes. Her medical history includes Prozac, Protonix, and oral contraceptive pills. Her allergies are to morphine, which is a rash. On physical examination, her primary survey, her vital signs were that her temperature was afebrile, her heart rate was in the 80's, her blood pressure was 1-teens/70's, her oxygen saturation was 100% on room air. She was awake, alert and oriented with a GCS of 15. Her trachea was midline. Her lungs were clear to auscultation bilaterally. Her heart had a normal sinus rhythm. Her abdomen was soft, nondistended, and tender in the left upper quadrant with bowel sounds present. Her pelvis was nontender and stable. Secondary survey revealed some abrasions over the right side of her face with some TMJ discomfort. Additionally, she had some left costal margin tenderness. All of her pulses were 2+ and equal bilaterally and all extremities were warm. Her laboratory values from the outside hospital were not significant for any acute abnormality. Her films obtained here showed cervical spine that had no acute traumatic injury. Our assessment of her was that she has a grade 1 splenic laceration and L1 transverse process fracture, and multiple rib fractures that are all stable. Our plan is that we will admit her, keep her NPO with IV fluids. We will check serial hematocrits every 6 hours for the first 2 days and keep her on bedrest for 2 days as per splenic injury protocol. We will control her pain and observe her respiratory status and should she continue to do well we will advance her diet and allow her to resume activity on hospital day 2. This patient and her plan of care were discussed with Dr. Dillon, the attending pediatric surgeon, who agreed with the assessment and plan. Date Printed: 1013112008 Time Printed: 4:57 AM CoUege of N ia= Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 H i s t o r y a n d P h y s i c a l D o c u m e n t Final Document Electronically Signed by: Dillon, Peter W 8/10/2008 11:24:29 AM #112039 Review/Sign: Wolff, Brynn S, MD Review/Sign: Dillon, Peter W, MD Pediatric Surgery: Drs. Robert Cilley, Peter Dillon, Andreas Meier, Kerry Fagelman, Brett Engbrecht Coleen Greecher MS RD CNSD, Janet Shields MSN CRNP CS, Lynn Simmons MSN CRNP BSW /MMH DD: 08/09/08 DT: 08/09/08 11:49 Date Pnnted: 1013112008 Time Printed: 4:57 AM Mtl. Aledical Cente fiofleg ege of Wffidne Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 D i s c h a r g e s u m m a r y D o c u m e n t Final Document Electronically Signed by: per contribution per contribution Signed By: Dillon, Peter W (9/3/2008 12:22:47 PM); Flynn, James F (8/15/2008 5:48:20 PM) DISCHARGE SUMMARY Name: POMPEO, CHELSEA A HMC Number: 7503644 DOB: 01/13/1993 Date of Admission: 08/09/2008 Date of Discharge: 08/12/2008 Physician: Dillon, Peter W Service: Peds Surgery Discharge Diagnosis: splenic laceration left 9-11 rib fractures L1 trans process fx Surgical Procedures: none Vaccinations Received This Hospital Stay: No vaccinations were given this hospital stay. Brief History of Present Illness: Date of Service: 08/09/2008 CHIEF COMPLAINT: Pediatric trauma transfer. By report of the outside hospital, Carlisle, and EMS, patient is a 15-year-old unrestrained passenger in a motor vehicle crash in the front seat. Moderate speed crash. Patient upon arrival of EMS was found "curled in a fetal position complaining of left upper quadrant pain." She states this pain increased with any motion. She was transported to Carlisle Hospital where she was evaluated with plain film radiography of the chest and CT of the abdomen and pelvis where a grade 1-2 splenic injury was noted without hemoperitoneum and fractures of the 9th through the 11th ribs on the left were noted. Patient was transferred to the Pediatric Trauma Center for further evaluation and care. She complained of some discomfort as noted above and this pain responded to morphine. There were no issues during transport. On arrival, the patient complains of the same pain which increases with range of motion or palpation localized to the left upper quadrant. She denies shortness of breath, cough, or hemoptysis. She does complain of a mild headache. PAST MEDICAL HISTORY: Gastroesophageal reflux, depression. ALLERGIES: Morphine. MEDICATIONS: Oral contraceptive, Prozac, Protonix. Date Printed: 1013112008 Time Printed: 4:57 AM PENNATE Milton S. HIMSheY Me&cal Celntear College of M xhd nle Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 D i s c h a r g e S u m m a r y D o c u m e n t Final Document Electronically Signed by: per contribution per contribution Signed By: Dillon, Peter W (9/3/2008 12:22:47 PM); Flynn, James F (8/15/2008 5:48:20 PM) Hospital Course: A pediatric level 2 trauma activation was called for her arrival to HMC, ans ATLS protocols were followed, confirming a Grade 1 splenic laceration, rib fractures, L #9-11, and L1 transverse process fractures. CT scan was not obtained but outside films were read by HMC radiology, confirming splenic laceration, rib fractures, and L1 trans process fracture. Patient was admitted to pediatric IMC for hemodynamic monitoring and serial hematocrit checks. Her initial hematocrit was 34.5 on admission, then repeat hematocrits on hospital day 1 were 32.1 and 32.6. She was on strict bedrest. Orthopaedics was consulted for the transverse process fracture and stated that there was nothing to do for the fracture except control pain and her T and L spine were cleared. Her vital signs remained stable and she was transferred to the floor on hospital day 2 (post injury day 1 ). Hematocrits on PID 1 were 30.7, 29.9, and 34.7. She again remained hemodynamically stable and making adequate urine. On PID 2 (hospital day 3), she was allowed to leave bed to use restroom and tolerated this increased activity well. She remained stable and a final hematocrit check was 34.0. On post injury day 3 (hosp day 4) she was tolerating diet, pain well controlled on Tylenol, voiding and ambulating on her own. Exam on Discharge: Tm 37.0 Tc 36.2 HR 80 RR 20 880 (720 PO)/775+5 trips to restroom RRR CTA b/I tenderness over lower left ribs Ab S, minimally tender by L ribs, nondistended Care Instructions: 1. see the spleen injury care booklet. Tylenol for pain control Diet Guidelines: regular diet. encourage liquids. Activity Guidelines: "l week/1 month" rule of activity restrictions - 1 week of bed or couch rest, walking to the bathroom only, at home. This is followed by 1 month of walking only - no sports, PE class, riding things with "wheels", contact/impact activities including manual labor. Always wear your lap and shoulder seat belt for all travel in cars. Call your doctor if: Please call 717-531-8521 (operator - ask for the pediatric surgery resident on-call); fever greater than 101 F, increased severe pain, persistent vomiting, shortness of breath. Other Instructions: follow up in 2 weeks at university physician center suite 3200. you will be called with an appointment. clinic number is Date Printed: 1013112008 Time Printed: 4:57" PENN-STATE P Milton & Hershey Medical meter coiiege of M A inie Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 D i s c h a r g e S u m m a r y D o c u m e n t Final Document Electronically Signed by: per contribution per contribution Signed By: Dillon, Peter W (9/3/2008 12:22:47 PM); Flynn, James F (8/15/2008 5:48:20 PM) (717)531-8342 Follow-Up Appointments: Scheduled Penn State - Hershey Appointments Within the Next 90 Days. 1. Follow-Up with PRS, UPC Peds Surgery at Plastic Surgery - Univ Phys Ctr Suite 3200 on 08/28/2008 at 02:30 pm 115521 Review/Sign: Flynn, James F, MD Review/Sign: Dillon, Peter W, MD Pediatric Surgery: Drs. Robert Cilley, Peter Dillon, Andreas Meier, Kerry Fagelman, Brett Engbrecht Coleen Greecher MS RD CNSD, Janet Shields MSN CRNP CS, Lynn Simmons MSN CRNP JFF /SDG DD: 08/12/08 DT: 08/13/08 10:46 Date Printed: 1013112008 Time Printed: 4:57 AM PENNATE Milton & Hershey Medical Cater College of NkxRcaine Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 I S n i n e - S t u d v 1 Final X-RAY LUMBAR SPINE 2-3 VIEWS PATIENT NAME: POMPEO, CHELSEA A PATIENT MRN:07503644 PATIENT DOB: 01/13/1993 EXAM DATE OF SERVICE: 08/09/2008 EXAM NUMBER: 2817310 ORDERING PHYSICIAN: DILLON, PETER Three view cervical spine. AP, lateral, and lateral swimmer's views of the thoracic spine. Two the lumbar spine. Clinical History: Trauma. Findings: No priors. Cervical spine: Patient is in a cervical collar. Alignment is maintained from the craniocervical junction through TI. Vertebral body heights and disk spaces are well preserved. Lateral masses of C 1 are symmetric with respect to the dens, although the lateral masses of Clare partially obscured. No acute osseous abnormality seen. Prevertebral soft tissues are normal. Lung apices are clear. Thoracic spine: Alignment is normal. Vertebral body heights and disk spaces are well preserved. No acute osseous abnormality seen. Paravertebral soft tissues are normal. Visualized portions of the lungs are clear. Lumbar spine: There is contrast within the bladder. Alignment is normal. Vertebral body heights and disk spaces are well preserved. No acute osseous abnormality. Right SI joint is normal. Impression: Normal radiograph of the cervical, thoracic, and lumbar spine. Dr. Ryan P. Leonen is the dictating resident. Attending radiologist signature indicates review of both the images and the report and that the attending radiologist agrees with the interpretation. Preliminary reports may not have been reviewed as yet by the attending radiologist. DICTATED: HULSE, MICHAEL REVIEWED AND SIGNED: HULSE, MICHAEL DATE DRAFTED: 08/09/2008 08:11 AM DATE OF FINAL SIGNATURE: 08/09/2008 10:15 AM Date Printed: 1013112008 Time Printed: 4:57 AM PENNSTATE Mon & Hershey Medical Center CaUege of Metf c e Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 S p i n e - S t u d y Final X-RAY THORACIC SPINE LIMITED 2 VIEWS PATIENT NAME: POMPEO, CHELSEA A PATIENT MRN:07503644 PATIENT DOB: 01/13/1993 EXAM DATE OF SERVICE: 08/09/2008 EXAM NUMBER: 2817309 ORDERING PHYSICIAN: DILLON, PETER Three view cervical spine. AP, lateral, and lateral swimmer's views of the thoracic spine. Two the lumbar spine. Clinical History: Trauma. Findings: No priors. Cervical spine: Patient is in a cervical collar. Alignment is maintained from the craniocervical junction through T 1. Vertebral body heights and disk spaces are well preserved. Lateral masses of C1 are symmetric with respect to the dens, although the lateral masses of C 1 are partially obscured. No acute osseous abnormality seen. Prevertebral soft tissues are normal. Lung apices are clear. Thoracic spine: Alignment is normal. Vertebral body heights and disk spaces are well preserved. No acute osseous abnormality seen. Paravertebral soft tissues are normal. Visualized portions of the lungs are clear. Lumbar spine: There is contrast within the bladder. Alignment is normal. Vertebral body heights and disk spaces are well preserved. No acute osseous abnormality. Right SI joint is normal. Impression: Normal radiograph of the cervical, thoracic, and lumbar spine. Dr. Ryan P. Leonen is the dictating resident. Attending radiologist signature indicates review of both the images and the report and that the attending radiologist agrees with the interpretation. Preliminary reports may not have been reviewed as yet by the attending radiologist. DICTATED: HULSE, MICHAEL REVIEWED AND SIGNED: HULSE, MICHAEL DATE DRAFTED: 08/09/2008 08:11 AM DATE OF FINAL SIGNATURE: 08/09/2008 10:15 AM Date Printed: 1013112008 Time Printed: 4:57AM Milton & whey Medical Ceder College of Medaiane Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 S p i n e - S t u d y Final X-RAY CERVICAL SPINE LIMITED 2-3 VIEWS - PEDS PATIENT NAME: POMPEO, CHELSEA A PATIENT MRN:07503644 PATIENT DOB: 01/13/1993 EXAM DATE OF SERVICE: 08/09/2008 EXAM NUMBER: 2817308 ORDERING PHYSICIAN: RODGERS, DANIEL R Three view cervical spine. AP, lateral, and lateral swimmer's views of the thoracic spine. Two the lumbar spine. Clinical History: Trauma. Findings: No priors. Cervical spine: Patient is in a cervical collar. Alignment is maintained from the craniocervical junction through T1. Vertebral body heights and disk spaces are well preserved. Lateral masses of C 1 are symmetric with respect to the dens, although the lateral masses of C 1 are partially obscured. No acute osseous abnormality seen. Prevertebral soft tissues are normal. Lung apices are clear. Thoracic; spine: Alignment is normal. Vertebral body heights and disk spaces are well preserved. No acute osseous abnormality seen. Paravertebral soft tissues are normal. Visualized portions of the lungs are clear. Lumbar spine: There is contrast within the bladder. Alignment is normal. Vertebral body heights and disk spaces are well preserved. No acute osseous abnormality. Right SI joint is normal. Impression: Normal radiograph of the cervical, thoracic, and lumbar spine. Dr. Ryan P. Leonen is the dictating resident. Attending radiologist signature indicates review of both the images and the report and that the attending radiologist agrees with the interpretation. Preliminary reports may not have been reviewed as yet by the attending radiologist. DICTATED: HULSE, MICHAEL REVIEWED AND SIGNED: HULSE, MICHAEL DATE DRAFTED: 08/09/2008 08:11 AM DATE OF FINAL SIGNATURE: 08/09/2008 10:15 AM Date Printed: 1013112008 Time Printed: 4:57 AM Patient Name: POMPEO, CHELSEA A ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) Med Given 08/09/08 10:21 08/09/0810:15 hyDROMorphone 0.2 mg IV Pain Intensity Response 5 Reason for Medication: Pain - Mild. Perform: Shaffer, Stacey Not Done 08/09/08 10:45 08/09/0810:45 Perform:Sweppenhiser, Nicole Complete 08/09/0810:21 Performed By: Shaffer, Stacey hyDROMorphone(Dilandid) 0.2 mg (Order Id = 351912365.00) 0.2 mg, injection, IV, ONCE, PRN, Pain - Mild, Routine, 08/09/08 10:04:00, 08/12/08 10:03:00 Administration Note: 10 1 5-IVP-sps Order Modified By: Shaffer, Stacey ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) hyDROMorphone(Dilaudid) 0.2 mg (Order Id = 351912365.00) 0.2 mg, injection, IV, ONCE, PRN, Pain - Mild, Routine, 08/09/08 10:04:00, 08/12/08 10:03:00 Administration Note: 10 1 5-IVP-sps Order Modified By: Boger, Alicia M ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) hyDROMorphone(Dilaudid) 0.2 mg (Order Id = 351891389.00) 0.2 mg, injection, IV, q2h, PRN, Pain - Mild, Routine, 08/09/08 8:07:00, 3 day, 08/12/08 8:06:00 Order Entered By: Flynn, James F Nurse : Shaffer, Stacey accepted on 08/09/08 09:35 Pharmacist: Then, Janine accepted on 08/09/08 11:56 ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) Med Given 08/09/08 08:48 08/09/08 08:48 hyDROMorphone 0.2 mg IV Pain Intensity Response 5 Reason for Medication: Pain - Mild Perform: Shaffer, Stacey *Response* 08/09/08 09:56 08/09/0810:00 Pain Response Form Pain Response Pain Intensity Response: 4 Perform: Shaffer, Stacey hyDROMorphone 2 mg / mL 20 mL vial inj.(Dilaudid) 0.1 mL = 0.2 mg (Order Id = 351891389.00) 0.2 mg, injection, IV, q2h, PRN, Pain - Mild, Routine, 08/09/08 8:07:00, 3 day, 08/12/08 8:06:00 Order Modified/Verified By: Then, Janine ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) Med Given 08/09/08 13:17 08/09/0813:16 Med Given 08/09/08 15:39 08/09/0815:39 Med Given 08/09/08 18:29 08/09/0818:28 Med Given 08/09/08 22:01 08/09/08 22:00 Med Given 08/10/08 00:16 08/10/08 00:05 Med Given 08/10/08 04:33 08/10/08 03:15 Med Given 08/10/08 05:24 08/10/08 05:24 hyDROMorphone 0.2 mg IV Pain Intensity Response 5 Reason for Medication: Pain - Mild Perform:Beam, Linda H hyDROMorphone 0.2 mg IV Pain Intensity Response 2 Reason for Medication: Pain - Mild Perform:Rex, Jenny L hyDROMorphone 0.2 mg IV Pain Intensity Response 5 Reason for Medication: Pain - Mild Perform:Beam, Linda H hyDROMorphone 0.2 mg IV Pain Intensity Response 3 Reason for Medication: Pain - Mild Perform:Graham, Come L hyDROMorphone 0.2 mg IV Pain Intensity Response 3 Reason for Medication: Pain - Mild Perform:Graham, Come L hyDROMorphone 0.2 mg IV Pain Intensity Response 3 Reason for Medication: Pain - Mild Perform:Miller, LeeAnn Proxy:Graham, Come L hyDROMorphone 0.2 mg IV Pain Intensity Response 3 Pain Scale Primary 0-10 Pain scale MRN: 7503644 Patient Name: POMPEO, CHELSEA A Reason for Medication: Pain - Mild Perform:Clark, Bethany L Med Given 08/10/08 08:47 08/10/08 08:47 hyDROMorphone 0.2 mg IV Pain Intensity Response 5 Reason for Medication: Pain - Mild Perform:Beam, Linda H Med Given 08/10/08 12:13 08/10/0810:50 hyDROMorphone 0.2 mg IV Pain Intensity Response 5 Reason for Medication: Pain - Mild Perform:Beam, Linda H hyDROMorphone 2 mg / 1 ml, syr. inj.(Dilaudid) 0.1 mL = 0.2 mg (Order Id = 351891389.00) 0.2 mg, injection, IV, q2h, PRN, Pain - Mild, Routine, 08/09/08 8:07:00, 3 day, 08/12/08 8:06:00 Order Modified/Verified By: Cooper, William H ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) Med Given 08/10/08 22:41 08/10/08 22:41 hyDROMorphone 0.2 mg IV Pain Intensity Response 6 Reason for Medication: Pain - Mild Perform:Blevins, Lori E Discontinue 08/11/0818:06 Performed By: Flynn, James F acetaminophen-oxycodone(Percocet 5/325) 1 tab (Order Id = 352467388.00) 1 tab, tablet, PO, q4h, PRN, Pain - Mild, Routine, 08/11/08 13:07:00, 3 day, 08/14/08 13:06:00 Order Entered By: Ibrahim, Zuhaib Nurse : Jankouskas, Tara S accepted on 08/11/08 13:29 Pharmacist: Case, Lindsay accepted on 08/11/08 13:35 ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) Percocet / generic equiv (5 / 325) tab(Percocet 5/325) 1 tab (Order Id = 352467388.00) 1 tab, tablet, PO, q4h, PRN, Pain - Mild, Routine, 08/11/08 13:07:00, 3 day, 08/14/08 13:06:00 Product Note: Acetaminophen 325mg/oxycodone 5mg. Maximum 4gm acetaminophen from all sources daily Order Modified/Verified By: Case, Lindsay ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) Discontinue 08/12/0816:01 Performed By: SYSTEM CONTINUOUS INFUSIONS MRN: 7503644 Sodium Chloride 0.45% 1000 mL Every Bag (Order Id = 351886380.00) 1,000 mL, IV, Routine, 08/09/08 7:31:00,30 day, Hard Stop, 09/08/08 7:30:00, 100 mL/HR, 10 HR, 1000 Order Entered By: Flynn, James F Nurse : Shaffer, Stacey accepted on 08/09/08 07:37 Pharmacist: Then, Janine accepted on 08/09/08 11:56 ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) Begin Bag Bag 1 08/09/08 10:21 08/09/0810:20 Sodium Chloride 0.45% 1000 mL IV Volume: 1000 mL Rate: 100 mL/HR Site: IV, Peripheral Perform: Shaffer, Stacey Begin Bag Bag 2 08/09108 20:20 08/09/08 20:00 Sodium Chloride 0.45% 1000 mL IV Volume: 1000 mL Rate: 100 mL/HR Site: IV, Peripheral Perform:Graham, Come L Begin Bag Bag 3 08/10/08 05:58 08/10/08 05:58 Sodium Chloride 0.45% 1000 mL IV Volume: 1000 mL Rate: 100 mL/HR Site: JV, Peripheral Perform:Graham, Corrie L NaC10.45%(Sodium Chloride 0.45%) 1000 mL Every Bag (Order Id = 351886380.00) 1,000 mL, IV, Routine, 08/09/08 7:31:00, 30 day, Hard Stop, 09/08/08 7:30:00, 100 mL/HR, 10 HR, 1000 Order Modified/Verified By: Then, Janine ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) Patient Name: POMPEO, CHELSEA A SCHEDULED MEDS MRN: 7503644 docusate(Colace) 100 mg (Order Id = 352565208.00) 100 mg, capsule, PO, bid, Routine, 08/11/08 20:00:00, 30 day, 09/10/08 8:00:00 Scheduled: 0800 2000 Order Entered By: Flynn, James F Nurse : Fahringer, JoAnu accepted on 08/11/08 18:11 Pharmacist: Why, Amy accepted on 08/11/08 18:09 ACTION(S) CHARTED @ SCHEDULED ADMIN TIME(S) ADMIN DETAIL(S) docusate sodium 100 mg capsule(Colace) 1 cap =100 mg (Order Id = 352565208.00) 100 mg, capsule, PO, bid, Routine, 08/11/08 20:00:00, 30 day, 09/10/08 8:00:00 Scheduled: 0800 2000 Order Modified/Verified By: Leiby, Amy ACTION(S) CHARTED @ SCHEDULED ADMIN TIME(S) ADMIN DETAIL(S) Med Given 08/11/08 21:15 08/11/08 20:00 08/11/08 20:00 docusate 100 mg PO Perform:Fahringer,JoAnn Med Given 08/12/08 09:43 08/12/08 08:00 08/12/08 08:30 docusate 100 mg PO Perform:Weyhenmeyer, Kimberly A Discontinue 08/12/0816:01 Performed By: SYSTEM PRN acetaminophen(Tylenol) 650 mg (Order Id = 351884124.00) 650 mg, elixir, PO, q4h, PRN, Fever/Pain, Routine, 08/09/08 7:12:00, 30 day, 09/08/08 7:11:00 Order Entered By: Flynn, James F Nurse : Shaffer, Stacey accepted on 08/09/08 07:37 Pharmacist: Then, Janine accepted on 08/09/08 11:56 ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) Med Given 08/09/08 08:48 08/09/08 08:48 acetaminophen 650 mg PO Reason for Medication: Fever/Pain Perform: Shaffer, Stacey acetaminophen 650 mg / 20.3 mL cup soln.(Tylenol) 20.3 mL = 650 mg (Order Id = 351884124.00) 650 mg, elixir, PO, q4h, PRN, Fever/Pain, Routine, 08/09/08 7:12:00, 30 day, 09/08/08 7:11:00 Product Note: Maximum 4gm acetaminophen daily from all sources. Check if patient also receiving (darvocet, percocet tylenol with codeine) Order Modified/Verified By: Then, Janine ACTION(S) CHARTED @ ADMIN TIME(S) ADMIN DETAIL(S) Med Given 08/10/0813:37 08/10/0813:30 acetaminophen 650 mg PO Reason for Medication: Fever/Pain Perform:Blevins, Lori E Med Given 08/10/08 17:49 08/10/0817:30 acetaminophen 650 mg PO Reason for Medication: Fever/Pain Perform:Blevins, Lori E Med Given 08/11/08 08:33 08/11/08 08:25 acetaminophen 650 mg PO Reason for Medication: Fever/Pain Perform:Weyhenmeyer, Kimberly A Med Given 08/11/0812:26 08/11/0812:26 acetaminophen 650 mg PO Reason for Medication: Fever/Pain Perform:Mercuri, Sandra E Med Given 08/11/08 21:15 08/11/08 20:30 acetaminophen 650 mg PO Reason for Medication: Fever/Pain Perform:Fahringer, JoAnn Med Given 08/12/08 13:34 08/12/0812:30 acetaminophen 650 mg PO Reason for Medication: Fever/Pain Perform:Chalfant, Debra J Discontinue 08/12/08 16:01 Performed By: SYSTEM hyDROMorphone(Dilaudid) 0.2 mg (Order Id = 351912365.00) 0.2 mg, injection, IV, ONCE, PRN, Pain - Mild, Routine, 08/09/08 10:04:00,08/12/08 10:03:00 Order Entered By: Flynn, James F Nurse : Shaffer, Stacey accepted on 08/09/08 10:20 Pharmacist: Then, Janine reviewed on 08/09/08 11:56 rR^Y?? 3 ADMISSION RECORD M LD I CALCeNTCr. NO. 361 Alexander Spring Road 9 Carlisle, PA 170185129 9 (717) 249.1212 9410624 0 0 0 0 7 7 8 8 4 ADMIT DATE I TIME ROOM NO. PT FC AGE DATE OF BIRTH X R MS TIN LOCA PROG AM P 08/22/2008 09:03 0000 E1 B 15 01/131993 M A T PATIENT NAME & ACORM SS NNUMBER PATIENT EMPLOYER EMPLOYER ONE NO. ( POMPEO, CHELSEA 179-74- 4465 STUDENT-CVHS E 1298 BRANDT RD N MECHANICSBURG PA 17050 PHONE M13ER COUNTY T - US (71,7)440 -8279 CUMBERLAND RESPONSIBLE PARTY & ADDRESS POMPEO, DEEANNA D SS NUMBER RESPONSIBLE PARTY EMPLOYER CNRC EWLQYER PHONE U 1298 BRANDT RD 233-19- 0392 1000 CLAREMONT ROAD (717)243-2031 CARLISLE PA 17013 A PHONE NUMBER RELATIONS H T PATIENT R MECHANICSBURG PA 17050 US (717)440 -8279 MOTHER RESP EMERGENCY CONTACT NAME not in household EMERGENCY CONTACT PHONE EMERGENCY CONTACT RELATIONSHIP TO PATIENT POMPEO, BARBARA __ (717)249-6472 GMOTHER C MME WT T D. E PRIVACY PP MIT, BY ?Y (NN ?Y ®N 7 SAS PRIVACY 200 BS1 ZAR106066311001 01/13/1993 IPBSHMc 378 PPO P MPA CHELSEA PO BOX 890173 GROUP NUMBER GROVPNAME N CAMP HILL PA 17089 02894762 CNRC (866)803-3708 A H i ATI S 2 AYER POLICY U A R GRO NUMBER R U AME A AUTHORIZATION N 3 PAYER - L POLICY NUMBER T F MATH A C GROUP NUMBER GROUP NAME UTHORIZ I N M R. ATTENDING /ADMITTING FAMILY I PRIMARY CARE I FRIERSON, PATRICIA L SPASIC, ALEXANDER S DIAGNOSIS I SIGNS SYMPTOMS C ABD PAIN--PEDIATRIC PRINCI PAL DIAGNOSIS (The condition established after study to be chiefly responsible for occasioning the admiss on of the patient to the HOSPITAL for care). COMPLICATIONS COMORBIDITYIIESi PRINCIPAL PROCEDURE HMA7120 MED 9410624 1111111N111111111 INITIAL ASSESSMENT FORM Carlisle Regional Medical Center PRIORITY: 3 Patient: POMPEO, CHELSEA Pt#: 9410624 Urgent DOB: 01/13/1993 AGE: 15YRS Sex: F MRM 0000778849 EDP: "FRIERSON_MD, PATRICIA L. Worker's Comp: DATE: 08/22/2008 PCP: SPASIC, ALEXANDER Emp. Referred: Presentation Time. 09:03 Triage Time: 09:12 Arrival Mode: WALKED Height Weight: 113.0 Ibs, 51.4 kgs. LMP: Last Tetanus: Acc By: Spouse Chief ABD PAIN--PEDIATRIC Complaint Brief THIS AM STARTED WITH LEFT SIDED ABDOMINAL PAIN AND SHORTNESS OF BREATH Assessment: HX OF SPLENIC LACERATION, RIB FX, TRANSVERSE FX NIGHT SWEATS UNK HEMOPTYSIS UNK WEIGHT LOSS UNK FEVER UNK ANOREXIA UNK SAFETY UNK TRAVELJLIVED UNK NAUSEA/VOMITING/DIARRHEA YES BOWEL MOVEMENT IN 24HRS YES FEELS CONSTIPATED LINK EATING RELIEVES PAIN LINK EATING WORSENS PAIN UNK Sudden Onset: Pre-Hospital Treatment Pediatric G&D App. for Age - N/A, Immunization UTD - NIA, Height ft. in., Head Circ. - Grade -, with Spouse Assessment: Past Medical BILAT MYRINGOTOMIES, depression, reflux, RIB FX, SPLENIC INJURY History: Allergies: MORPHINE Medicines prozac, protonix, bcp, TYLENOL PRN Vital Signs T: 98.6 PO P: 69 Regular R: 18 Unlabored BP: 107/063 02: 95 % RA Pain Intensity Scale: 8 / 10 Pain Location: Multiple Areas Nurse Signature: KFF Additional Notes: r" Co b © Rev 05/18/04 • •jr: CARLISLE REGIONAL MEDICAL CENTER 361 ALEXANDER SPRINGS ROAD CARLISLE PA 1707.5 (717) 960-1683 RADIOLOGICAL INTERPRETATION PATIENT NAME: POMPEO CHELSEA MED REC ##: 778??a9 X-RAY#: 778849 ACCOUNT ##: 9410;'4 EXAM DATE: 8/22/2008 D.O.B.: 01/13/1;:33 ORDERING: PATRICIA L FRIERSON MD- ROOM: ER ATTENDING: CONSULTING: ALEXANDER SPASIC, MD 258-0099 HISTORY: ABD PAIN--PEDIATRIC ABD PAIN--PEDIATRIC CT CHEST WITH CONTRAST, PULMONARY EMBOLISM PROTOCOL 08/22/08 INDICATION: Fifteen-year-old female patient with history of MVA and left-sided rib fractures and splenic laceration, 08/09/08, now with shortness of breath and chest discomfort. COMPARISON: None. RESULTS: Multiple 3.75 mm axial CT images were obtained through the chest after administration of 50 cc of Isovue-3'70 nonionic intravenous contrast material. The patient received 50 cc due to receiving 65 cc for CT of the abdomen earlier today. Mediastinal windows demonstrate normal opacification of the pulmonary arteries. No evidence for embolism. Normal appearance of the aorta. No para-aortic hematoma noted. There is likely mild residual or rebound thymic tissue in the superior anterior mediastinum. There is no evidence for lymphadenopathy or pericardial effusion. The remaining mediastinal structures are normal in appearance. Evaluation of the lung windows demonstrates a mild amount of dependent atelectatic changes in the left lower lung. There is no evidence for pneumothorax, focal consolidation or effusion. A small amount of pleural thickening is also seen. There is an overall unchanged appearance of mildly displaced left lower rib fractures and lateral left transverse process fractures of T12 and L1 when compared to the CT abdomen study of 08/09/08. No CONTINUED ON PAGE 2 E. R. CARLISLE REGIONAL MEDICAL CENTER 361 ALEXANDER SPRINGS ROAD CARLISLE PA 17015 (717) 960-1683 RADIOLOGICAL INTERPRETATION PATIENT NAME: POMPEO CHELSEA X--RAY## : 778849 EXAM DATE: 8/22/2008 ORDERING: PATRICIA L FRIERSON MD- ATTENDING: CONSULTING: ALEXANDER SPASIC, MD 258-0099 HISTORY: ABD PAIN--PEDIATRIC ABD PAIN--PEDIATRIC MED REC 778849 ACCOUNT 9410624 D.O.B.: 01/13/1993 ROOM: ER other acute chest wall abnormality noted. Remaining osseous structures are unremarkable. For evaluation of the upper abdomen, please refer to the separate CT abdomen dictation. IMPRESSION: There is no evidence for pulmonary artery embolism, pneumonia, pneumothorax or acute aortic abnormality. Mild left basal atelectasis and pleural thickening. Stable appearance of left lower rib fractures compared to the prior study. No other acute abnormalities are noted. A STAT reading was sent to the emergency department at dictation time. l" REVIEWED AND SIGNED RHONDEY HARFORD, MD INTERPRETING PHYSICIAN DATE DICTATED: DATE TRANSCRIBED: DATE SIGNED: TRANSCRIPTIONIST: 3376455 CT CHEST WICONTRASP 8/22/2008 8/22/2008 14:02 8/22/2008 15:34:01 MW E.R. PAGE 2 OF 2 CARLISLE REGIONAL MEDICAL CENTER 361 ALEXANDER SPRINGS ROAD CARLISLE PA 17015 (717) 960-1683 RADIOLOGICAL INTERPRETATION PATIENT NAME: POMPEO CHELSEA X-RAY#: 778849 EXAM DATE: 8/22/2008 ORDERING: PATRICIA L FRIERSON MD- ATTENDING: CONSULTING: ALEXANDER SPASIC, MD 258-0099 HISTORY: ABD PAIN--PEDIATRIC ABD PAIN--PEDIATRIC CT ABDOMEN AND PELVIS WITH CONTRAST 08/22/08 MED REC #: 778849 ACCOUNT #: 9410624 D.O.B.: 01/13/1993 ROOM: ER INDICATION: Fifteen-year-old female patient with history of splenic laceration status post MVA 08/09/08, complaint of persistent left-sided abdominal pain, dizziness and shortness of breath. COMPARISON: 08/09/08 exam. RESULTS: 3 mm axial CT images were obtained through abdomen and pelvis after 65 cc of Isovue-370 nonionic intravenous contrast. The lung bases demonstrate mild dependent atelectasis in the left lower lung. CT imaging through the abdomen demonstrates homogeneous enhancement of the spleen, most likely reflecting resolution of the previously noted splenic lacerations. A small splenule is seen. There is no evidence for free air, free fluid, focal fluid collection, lymphadenopathy or acute intestinal abnormality. Normal enhancement of the kidneys. The remaining abdominal organs and viscera are otherwise stable and unremarkable. CT imaging through the pelvis demonstrate interval development of 1.8 x 1.5 cm follicular cystic change in the right adnexa. There has been some decrease in the small free fluid in the cul-de-sac region. There is no other evidence for significant pelvic fluid, fluid collection, acute intestinal abnormality, free air or hematoma. The remaining pelvic organs and viscera CONTINUED ON PAGE 2 E. R. • CARLISLE REGIONAL MEDICAL CENTER 361 ALEXANDER SPRINGS ROAD CARLISLE PA 17015 (717) 960-1683 RADIOLOGICAL INTERPRETATION PATIENT NAME: POMPEO CHELSEA MED REC #: 778849 X-RAY#: 778849 ACCOUNT #: 9410624 EXAM DATE: 8/22/2008 D.O.B.: 01/13/-993 ORDERING: PATRICIA L FRIERSON MD- ROOM: ER ATTENDING: CONSULTING: ALEXANDER SPASIC, MD 258-0099 HISTORY: ABD PAIN--PEDIATRIC ABD PAIN--PEDIATRIC are otherwise normal in appearance. No new abdominal wall abnormalities are seen. There is an overall unchanged appearance of mildly displaced left lower rib fractures and nondisplaced transverse process fractures of T12 and L1 on the left. No evidence for abdominal wall muscular hematoma. IMPRESSION: 1. There is no evidence for acute abnormality within the abdomen or the pelvis. There has likely been resolution of the small splenic hematomas compared with 08/09/08. 2. Follicular cystic changes in the right adnexa and small amount of free fluid in the cul-de-sac are now noted, likely related to post physiologic change. Stable appearance of the left low rib fractures and left-sided T12 and L1 transverse process fractures. A STAT report was sent to the emergency department at dictation time. REVIEWED AND SIGNED RHONDEY HARFORD, MD INTERPRETING PHYSICIAN DATE DICTATED: DATE TRANSCRIBED: DATE SIGNED: TRANSCRIPTIONIST: 3377133 CT ABDOMEN W/CONTRAST CT PEL4 8/22/2008 8/22/2008 12:42 8/22/2008 15:32:11 MW E.R. PAGE 2 OF 2 IS WICONTRAST iEMERGENCY DEPARTMENT PEDIATRIC ABDOMINAL ASSESSMENT 6 ,.Date in: 8/2212008 Time: Carlisle Regional Medical Center Name: POMPEO, CHELSEA Pt#: 9410624 Age: 15YRS DOB:01/1311993 Sex: F li 0000778849 EDP:•FRIERSON_MD, PATRICI, PCP:SPASIC, ALEXANDER Subjective Notes; Pain []pat' eni pain 6 Location: Quality: []Sharp []Dull []Cramping []Burning []Aching o Rating Scale: Mode of onset ? u den L3 Gradual ? Intermittent WONGIBAAKER FACES RATING SCALE Onset Date: Time: _ Duration: Onset > 24 hrs. medical attention was sought? ?No ?Yes Date: Y Radiating: ?No ?Yes (specify) - -- 0 2 4 6 B 10 Psychosoclal ,. Caregiver: []Parents other ? Father []Other: Environment: ? No steps ? Few steps ? Many steps Accompanied by. - - k Oth A U t c Nutritional status: ?Nonnal ?Cachetic ? Obese ppearance emp [] [] n er _ ;y Religious l Cultural preference: []None tsoeafy- ; Activity level: wake []Playful []Smiles I Laughs Best learn by: (ptl caregiver) []Verbal ?Wntten ?Retum demo r []Other Leaming Barriers: m toms prior to arrival p As mptomatic P Y ; .. ....sPN 0hd'Rlsk Factors Asso 'ated signs and symptoms Relief Measures []Chicken poxpGerman measles?Mumps []Measles ausea DFlatulence []Blood in stools []Rest ? Food []Whooping cough ?Scadetfever []STD: ?•Vomiling []Fever ?Hematemesis []Antacids: ?Pyloricstenosis ?lntussusception ?Ulcerativecolitls ? Diarrhea ? Chills ? Back pain ? Position: []Congenital anomalies: -?•Constipation ?Dysuria ? Flank pain p p _ - ^ - Immunization up to date for age: Physical Assessment (Objective) Inspection Auscultation RUQ LU Palpation ? Normal for patient Bowel sound: DFlrm []Distended []Non-tender ? Distention N = Normal (5 - 35! min.) - -- []Soft []Rigid Umbilicus: []Intact []Herniated = Hypoactive T = Hyperactive Use number to indicate the location Genitourinary: D Not Assessed RLO LLQ ? t - Tender ?2 - Rebound tenderness Voiding: ? Continent D Incontinent ? Diaper ? Potty trained ?3 - Abnormal mass ?4 ?Dysuria El Frequency ? Color. -- _- System Review Neurological Cardiovascular Rssplrstory Airway,' '00180r pother: []Uncooperative Skin: tlVam1 pL)ty []Moist :r pDlaphgrotlG Effort: lr1186prod C1MAdly OSeverely " iented % X-3 ?Combatlve Color: k QPMe []Ashen ?Flushad ?Retraot)ons p$trfClar c3 Nasel Flaring Cooperative []Agitated p Cyanetlc ?Jaurtdiaad Lung; ?Q?FlO ?Orackles ,OAwakebut contused []Restrained pRhOnchi?Dec(89Q .; ., ttf3rowth and Development Weight: 51:4 KG. Height' 1t !, " Heac( itcttmfersr?cs: rxn nNEW BORN Ape o • 1 Month []INFANT 1.12 Months Language: []Cries Often OSmiles []Coos / Gurgles []Babbles Born at Term: ?Yes ?No Delivery: OVaginal ?C-Section Diet: ? Breast Feed []Formula type: Uses: []Bottle []Spoon OCup Elimination: ? 3 - 8 stools a day Other: Activity: Lift Head: ?Yes []No Sits up: Owith help ? without help Crawls: ? Yes O No Teething: ? Yes ?No Observation of interaction with caregiver is ? Appropriate OSee Nursing Assessment []TODDLER Age 1.2 Years ? Pre-School Age 3 - s rears Language: []Few Words OSentences ? Easily Understood Diet: []Finger Foods []Regular Diet OFeeds Self Uses: [3Botte 0 Cup OTeething: ?Yes ONo Elimination: O1 - 2 Stools per day []Diapers OToilet trained ?Wels bed: ? Rarely ? Occasionally []Frequently Activity Walks: O Yes ? No OWalks with assistance []Walks Independently Observation of interaction with caregiver Is ? Appropriate []See Nursing Assessment []SCHOOL AGE Ape 6.11 Yeah []ADOLESCENT Age 12 - 1s Years Reached Puberty: Cl Yes ?No Learning disability: ? Yes School grade: Diet: ? Eats 3 meals/day ? Eating disorder: (specify) Wear Braces []Yes ONo (Elimiration: ? No problem reported ? Wets bed: []Rarely OOccasionally OFrequently Social Habits: Smokes ? Yes ? No Uses Alcohol: ? Yes ?No Uses Drugs: ? Yes ?No / ' "CJboervation of interaction with caregiver is ? Appropriate OSee Nu rsing Assessment Vital Signs: 09:12 T: 98.6 P: 69 Regular R: 18 BP: 107/063 Nurse Signatur i Rev. 0310 Pediatric Abdominal Pain ,az Carlisle Regional Medical Center Demo ra hics and Tria e: Date 1n: 08/2212008 Pres Time:09:03 Pt#:9410624 MR#:0000778849 Triage Time: 09:12 Triage Nursing Note: Name: POMPEO, CHELSEA Arrival Mode: WALKED T: 98.6 PO THIS AM STARTED WITH LEFT SIDED Regular ABDOMINAL PAIN AND SHORTNESS 1 ,4 Age: 1!5Yrs 0 Mos 0 Wks DOB: 01 /13/1993 Sex: F Wt: kgs: 51 OF BREATH 8 R: 18 : „ Uniabored PCP:SPASIC ALEXANDER Ht: , BP: 107/063) HX OF SPLENIC LACERATION RIB DP. •FRIERSON_MD, PATRICIA L. 02 Sat: 95 % NL / hypo , FX, TRANSVERSE FX Chief Complaint ABD PAIN--PEDIATRIC Pain / Location: 8/1VIultiple Areas CC / HPI: Level 1-3 = 1-3 elements Level 4 = 4 elements Level 5 = 5 elements iTime Seen l 4 -j ? TraRsleter- es Reviewed Additional History: _ q A'Hx Source: ati t mot father family specify: EMS `k 6 Hx Ltd By ALOC poor historian age unreliable source severity of condition 1 Onset: min _hrs-_days_wks_mths ago sudden / aduk + Duration. consiad/ intermittent Lasted: _ secs_mins_hrs_days Timing (currently):(Qr /absent improving / worsening wax-wane / I C e r ?? (, -, r v Severity mild mod sev r 1 0 current / 10 max denies pain _ _ Location painlsxs pig?r+'h periumbilical flank: R / L RUQ LUQ RLQ LLQ / I ZZ 1 ??? 5' r ? Quality cannot describe sharp dull achy colicky indigestion like ` ?? V I?,- >0c f? Exacerbated By: nothing cough food movement Inspiration UG c7"h1a/' Relieved By. nothing antiacids flatulence food reminging still H2 Blockers PPI Associated S&S: constipation fever intake/output behavior diarrhea vomit ,Context- BM habits last BM poss. bad food recent abdominal surgery G 7 ' o$: Level 1-3 = 1 system Level 4 = 2-9 systems Level 5 = 10+ systems General Eyes ENT Respiratory Cardiovascular G trointestinal Genitourinary Fever)'Chills Visual Changes Sore Throat 6hGft--es-s-6fff reath Chest Pain a / Dysuria Weight gain / Loss Redness Hoarse Voice Cough Palpitations Diar? Frequency Lethargic Dryness Epistaxis Congestion PND Constipation Vaginal Bleeding Fussy Diplopia Pulling at Ears Hemoptysis Orthopnea Eat / Dring less Vaginal Discharge Persistent crying itching Nasal Drain/Cong. DOE Abd. Pain Penile Discharge Musculoskeletal Neurological Psychological Skin Immuniloglcal _AflS tem_s Reviewed Joint Pain Syncope Anxiety Rash Recurrent Hives other syste ve Joint Swelling Headache Depression Pruritis HIV 1 AIDS Unable to obtain due to: age severity Neck Pain Focal Weakness Hallucination Lesions Anaphylactic Rxn Back Pain Paresthesia Insomnia Bruising ALOC poor historian unreliable Myalgias Confusion Stress Bleeding Past Family Social Hx: Level 1.3 = none Level 4 = 1 section Level 5 = 2-3 sections Past Medical History. Additional Past Medical History: ear infections asthma bronchitis BILAT MYRINGOTOMIES, depression, reflux, RIB FX, SPLENIC INJURY tonsillitis UTI diabetes seizures,ardi urreni Medications: Past Surgical Hisiory: ne tonsillectomy appy myringotomy 'rozac , protonix , bcp TYLENOL PRN Other: Family istory: Negative CAD/ MI DM CA CVA Clergies: Social History: daycare / honodf MORPHINE Tobacco: Y IN Passive Smoke exposure: Y / N Reproductive History: G- P_ A_ Last Menstrual Period: Alcohol: Denies / Social I Heavy Substance Abuse: Y / N Menses History: Regular I Irregular I Post-partum 1 Pre-monarch Primary caregiver: mother 1 father I sibling I grandparents Last Tetanus. Older: Physical Exam: Level 2-3: 2-4 systems level 4: 5-7 systems Level 5: 8+ systems NL' i indicates system examined and negative General Distress: NAD ild oderate severe active smiles playful cries on exam I readily consoled good eye contact anxious etic obese disheveled irritable fussy lethargic weak cry appears ill / toxic other: RENT NL* fontanelle flat I closed ears NI- pharynx: NL nose NL fontanelle bulging sunken membranes dry nasal drainage: clear I purulent ear canal: R / L erythema / obscured / perforated TM: R / L e them / bulging / retracted pharyngeal: exudate / erythema / abscess Eyes: NIL- ER L I conjunctiva NL NL fundus R pupil _ mm L pupil _mm conjunctiva: R / L injected / discharge / hematoma k .- M ED Complement (o*de 0.0wes" %o.,x.w^ Ww*nt neo:, p-W• aaawny kft"a,pn) Rev OW16/05 Pediatric - Abdominal Pain,,,, Carlisle Regional Medical Center ame:POMPEO, CHELSEA Date In:08/2212008 MR#:0000778849 Pt#:9410624 Physical Exam: cont. Level 2-3:2-4 systems Level 4:5-7 systems Level 5:8+ systems ` indicates system examined and negative Neck: NL* no adenopathy supple non-tender full ROM adenopathy ant / post R / L meningismus / Kemig's / Brudzinski spasm vertebral tenderness decreased ROM painful motion Chest: NL* chest wall non-tender NL excursion / expansion no retractions tender: R / L chest wall / sternum retractions stridor other: CV: NL* RRR PMI NL pulses NL no mumur tachycardic bradycardic irregularlirreg rhythm murmur-/6: systole I diastole periph pulses: decreased ! absent other:_ Respiratory: NV no respiratory distress breath sounds NIL crackles wheezes rhonchi unequal / decreased sounds grunting fatigue stridor other: Abdomen: NL* normal appearance so BS NL non-tender rectal NL uiac negative no organmegaly distended rigid d?r guarded rebound BS: hyper/ pc `absence---f-? fL.• ?'" ?`' e mass orgarimegaiy hem + gross blood per rectum other: Back: NL' neg CVAT non-tender no kyphosis nosbottosis no spasm CVAT R / L spasm / vertebral tenterness: thoracic / lumbar / sacral remities: NI-`non-tender full ROM no edema no erythema limited ROM obvious defect edema erythema tenderness weakness paresthesia g 1 din; _. NL` wtiT1]5;? isolLr M- ko-tas l turgor NL no edema no erythema etic c hot dia ph or yannobc rash poor turgor other: Meuro: ? - ap? '' e NL rnotorlsensorY NIL DTRs symmetric cerebellar NIL Catiau+? F "acts different" decreased responsiveness disoriented facial asymmetry EOM palsy motor weakness: RUE LUE RLE LLE sensory deficit: RUE LUE RLE LLE GU: NL'deferred ext genitalia NL (male: circumcised / uncircumcised) vaginal / penile: discharge sores bleeding hematoma ecchymosis ' P=Pain, T=Tender, M=Mass Medical Decision Making: UA: NIL /except EKG: Interpreted by EDP _ NSR Seg NL / xcept = Bands -- Bds WBC LE othe 'O except Lym RBC Blood CXR:_ nterpreted by EDP Nitrites Bacteria - NAI _Infilitrate ALT Rapid Strep: neg / pos Abd: _ NSBGP obsuc '? - AST _ T, Bili RSV ESR Fecal Leuks: none I few / mod / man Other ! U CT: / V J ?_ Other / Procedures: LL. ? pnsultation: Clinical Cou e & Re-evaluation: SN r Time: Disc with Or. Time: Worse / Unchanged Mods: i 'A. u,)? V J will _see pa tient in office _ admit -see in consult / `a , j-- , t'1 L v Time: (InarAd / Worse / Unchanged Time: _i . Disc with Dr. IVF: J 0 Patient re-examined will -see pa tient in office admit - see in consult [Nritical care: 30-74 minutes 175-104 minutes ?See procedure note ?See addendum Clinical m ression: Dis osltion: 1. $ 1 J.-,., - Time: 2 Dishcarge: ?/ NH / Psych Fac / Jail Admit: Floor / ICU I PCU / Obs / OR I Tele / Psych I Peals [Orders written 3. Transfer: Facility: Rev Physician: 4. AMA / LWOT / DOA / Expired \ OTransfer forms com eted 5. p Condition: Stable ! Satisfactory / l muadt/ Critical / Guarded I Emergent / Non-emergent I instruc Follow up with ?Pre?cr'obqn (s) given: ->k<-up care discussed with: patient I family / pouse .OPMD Additional I Instructions: D Doctor t-ICED ?00thei ^ In day(s)0 A Signatures: CJi A/ARNP ovz? 'y V n[ / LU- n..1QMs,A.-n w-- yea., wvyi- a C.Maj,mor-nw„ Rev. 09/1 rru- mcu ?,Orn 7 ORDER PROCEDURE EQRM_ ?GASTROINTESTIN EMERGENCIES r ,Date in: 8/22/200$ Time: Carlisle Regional Medical Center Name:POMPEO, CHELSEA Pt#:9410624 Age: 15YRS D08:01/13/1993 Sex: F MR#:0000778849 EDP: *FRIERSON_MD, PATRIC PCP: SPASIC, ALEXANDER Laboratory Tests Io Order TIMe- rder $ ' B . r, TjM! :' - tNde? 8ent4 IS -%5 --I PAMT - 6rta le -- ?? C CX __ - `? -- _ - _ _ -CMP ?& RUB - - --- Am lasy a Lipase_ _ Acute A at Series Occult Blood (Stool) (Emisis) 0 p-' Stool Specimen i08P) (Leuk (Cult, bd2fy is ontras ?_ He-aticProfIe PT/PTT Gal adder Ultra Sound u? --- Type 8 Screen or Cross #_Units UA EKG Bela HOG --- - ABG 02 LPM Cardiac Profile Misc. Qrders -.---------------------- Mot CMI N#Iat 1" f , Ir rntlatlon: Previous Medical Records Physical Therapy - Eval & Tx ,Weight: Allergies: MORPHINE lbs: 113 kgS: 51.4 'Order Ti Me Medication / DosagO I Route Va Read, E38ck AOrn,„ Ad1xt,Mi?y' ilba:! ReaatsemeM dip (nl#Jpls, r14? Q, 5 ?? aJ U [] Improved[] Worse [] Unchanged ?/ . N ?- ? ? improved ? Worse ? Unchanged f? ? ? Improved ? Worse ? Unchanged ? O Improved ? Worse O Unchanged ? ? Improved[] Worse ? Unchanged Order Time IV I Solution ! Added Medication Staffirne; DAvtca / Sire-T6; Zon # Atte tnpfsA?unt SYptt by D/C ite AM V Infused LAIC O y KVO Device: 2U? D IV Fluid A Procedures /Nursing Assistance ? Cardiac Monitor Rate Rhythm ? Urinary Catheter Insertion # -Fr. ? Endoscopic Procedure 0 NIBP Monitor ? Gastric Lavage T ? Pulse Oximetfy ? Central Line Placement p NGT Insertion # Fr. ? Blood Product Infusion 1 1776. Discharge Instructions ? WRtiPf NJUVi l Initials/Sig re I slSi n nitlais/Signature; (? ARNP: , C i 11.? P ysician's Sign e: wat3 CI ot Rev. D91141041 Carlisle Req?lonal Medical Center -- Emergencv Department Pompeo, Chelsea 361 Alexander Spring Rd Carlisle, PA 17013 -(717) 960-1695 8122/0812:32om 0778849 DISP091TION SUMMARY Patient: Pompeo, Chelsea SS #: Current Ph: CURRENT Address: co: Zip: Arrival: 8/22/08 12:32pm Disch: 8/22/08 2:07pm MD ED: Patricia Frierson, MD PMD: Res/PAINP: Kevin Gold, PA-C PMD Ph: Dx #1; Abdominal Pain ICD-9 #1: 789.00 #1 Dx Engl: ABDOPAIN.ESW Dx #2: Rib Fracture, Closed (Unspecified) IC D-9 #2: 807.00 #2 Dx Engl: BROKRIB.ESW Rx #1: Vicodin Tablets (acetaminophen,hydrocodone) 500mq,5mq (Max 8 tablets/dav) 1-2 tablets by mouth every 6 hours as needed for pain 24 (twentyfour) Rx #2: Reglan Tablets (metoclopramide) 5mq 1 tablet by mouth 4 times a day before meals & bedtime PRN #18 tablets Age/DOB: Medical Record: 0778849 Disposition: #1 Dx Span: ABDOPAIN.SSW #2 Dx Span: BROKRIB,SSW Rx#1 Printed: 8/22/08 2:07pm Follow-up: Your doctor at Hershey as scheduled F/U MD Ph: F/U D/T: return to the ED as needed for worsening symptoms Other Instr. Activity as tolerated. MY SIGNATURE BELOW INDICATES: > I have received and understood the oral instructions regarding my current medical problem. > I will arrange follow-up care as instructed above. > 1 acknowledge receipt of the written instructions as outlined on this and any previous page(s). I will read and review these instructions. While the physicians and staff of the Emergency Department have made every reasonable effort to accurately determine your complete medication history, because of the limited know/edoe of your out-of-hospital medical care, and the need to address your emergency medical needs, we cannot be sure that a complete or fully accurate medication history was provided. It is therefore necessary for you to inform your primary care physician of your treatment in the Emerpency D artment so that your physician can properly evaluate y r urrent medication needs. r X V X Z(Witness) ' Pa (or Legal Guardian) Siqnature $t ture Carlisle Regional Medical Center -- Emergency Deaartment 361 Alexander Spring Rd Carlisle, PA 17013 -- (717) 960-1695 A Patient: Pompeo, Chelsea Disch: 8122108 2:07pm MD ED: Patricia Frierson, MD Medical Record: 0778849 Res1PA/NP: Kevin Gold, PA-C 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 diaqnoses/prescriptions today are: Dx #1: Abdominal Pain Dx #2: Rib Fracture, Closed (Unspecified) Rx #1: Vicodin Tablets (acetaminophen,hydrocodone) 500mq,5mq (Max 8 tablets/day) 1-2 tablets by mouth every 6 hours as needed for pain Disp. 24 (twentyfour) Refill: zero Rx #2: Reqlan Tablets (metoclopramide) 5mq 1 tablet by mouth 4 times a day before meals & bedtime PRN Disp: #18 tablets Refill: 0 General Information on ABDOMINAL PAIN The word "abdomen" is a medical term that refers to the belly. The abdomen (or belly) contains many different structures including the gallbladder, stomach, intestines, appendix, liver, kidneys, bladder, spleen, lymph nodes, blood vessels, and nerves. A problem with any one of these structures can cause pain in the abdomen. Some of the more common causes of abdominal pain include the stomach flu, gastritis, ulcers, hernias and sore muscles. Sometimes careful examination reveals the source of abdominal pain, but sometimes it does not. In the emergency room, it may not be possible to find the exact cause of a particular episode of abdominal pain. What are the risks? Most cases of abdominal pain get better over hours to days, causing no serious medical problems. However, there is always a risk that the pain may be from a potentially serious disease such as appendicitis or a bleeding ulcer. In these cases the pain usually continues to get worse. INSTRUCTIONS 1) Take only liquids until you are feeling better. This will help quiet your stomach. Adults usually do well with Gatorade, chicken soup, ginger ale, broth, Kool-aid or water. Take small, frequent sips to help avoid vomiting. 2) Avoid aspirin, coffee, alcohol and caffeinated soda, since they tend to make abdominal pain worse. 3) Don't use any strong pain medication unless prescribed by your doctor. Increasing pain can be the first sign of a potentially serious disease. Strong pain medication may relieve the pain, but it can also prevent the timely treatment of a potentially serious medical problem. 4) Make sure to contact your doctor if the pain is not better within one or two days. 5) If your pain continues to get worse or becomes severe, call your doctor right away. If you can't reach him/her, return to the emergency room. 6) SEEK IMMEDIATE MEDICAL ATTENTION if you develop severe pain, chest pain, persistent vomiting, difficulty breathing, bleeding, a fever, persistent dizziness or pass out. General Information on BROKEN RIBS The ribs are long, thin bones that curve around each side of the chest. There are twelve ribs on each side. Any firm blow to the chest can break a rib(s). Most of the time this results from sports injuries, falls or motor vehicle accidents. Medically speaking, the words "broken", "cracked" and "fractured" all mean the same thing. What are the symptoms? Ordinarily there is a sharp pain in the chest, usually in the area of the broken rib(s). The pain is often worse with bending, lifting, deep breathing or any strenuous activity. What can be done? Simple rib fractures usually heal on their own within TWO TO SIX WEEKS. Splinting and other therapies used in the past PENNSTATE 40 Milton S. Hershey Medical Center College of Medicine Penn State Milton S. Hershey Medical Center Tel: (717) 531-8055 Penn State College of Medicine Health Information Services, HU24 500 University Drive P.O. Box 850 Hershey, PA 17033-0850 Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 Patient Sex: Female Date of Birth: 1/13/1993 Patient Location: PESU, , Visit Number: 10140994 Visit Type: Clinic O u t p a t i e n t L e t t e r D o c u m e n t Final Document Electronically Signed by: Dillon, Peter W August 30, 2008 Name: POMPEO, CHELSEA A HMC Number: 7503644 DOB: 01/13/1993 Date of Service: 08/30/2008 Alexander Spasic, M.D. 816 Belvedere Street Carlisle, PA 17013 Dear Dr. Spasic: 9/3/2008 12:01:29 PM I saw Chelsea in the office this past Wednesday, August 28th, for followup evaluation. As you may know, we had admitted her following a reported motor vehicle accident. At the time, she had suffered a number of rib fractures as well as a splenic laceration. Her post trauma course was unremarkable. Following discharge, she did have episodes of pain and shortness of breath localized to the left ribs for which she was reevaluated in the Carlisle at ER. Since then, she has had intermittent pain on the left side, but no new medical issues or problems. On physical exam, her weight was 54 kg. She was alert and active and in no discomfort. Her pupils were equal, round, and reactive. Her sclerae anicteric. Her neck was supple with no tenderness and had full range of motion. Her lungs were clear with good breath sounds bilaterally. There was still some tenderness along her left lateral lower rib cage. There were no areas of crepitants. Her abdomen was soft and nondistended. There are no masses and no areas of tenderness. She had good bowel sounds. Her extremities were unremarkable. Chelsea is slowly recovering from her injuries. Her spleen showed a heal without issues or problems over the next few weeks. Her rib fractures would probably take a bit longer before they are totally healed and asymptomatic. From our point of view, she may return to work if she will be more than a month about by next week. We would like to see her back in approximately 4 weeks for followup. However, if she is doing quite well and has no other issues or problems, she may call our office and cancel that appointment if she so chooses. She also noticed that if she has any issues or problems, she can contact us on anytime. Date Frinted: 10/31 /2008 EJEX?;HIBIT PENNSTATE - Milton & Hershey Medical Center UP College of Medicine Patient Name: POMPEO, CHELSEA A PSUHMC MRN: 7503644 O u t p a t i e n t L e t t e r D o c u m e n t Final Document Electronically Signed by: Dillon, Peter W 9/3/2008 12:01:29 PM Thank you so much for allowing us to participate in her care. Best wishes. 151326 CC: Spasic, Alexander, MD 816 Belvedere Street Carlisle, PA 17013 Sincerely, Dillon, Peter W, MD Pediatric Surgery: Drs. Robert Cilley, Peter Dillon, Andreas Meier, Kerry Fagelman, Brett Engbrecht Coleen Greecher MS RD CNSD, Janet Shields MSN CRNP CS, Lynn Simmons MSN CRNP PWD /CO DD: 08/30/08 DT: 09/02/08 15:41 Date Printed: 1013112008 Time Printed: 4:54 AA7 Mark P. Holenick„ D.O. 49 B(ook?vood iWenue Carlisle, PA 17013 March d, 2009 Pho-w-? (717) 243-0241 (717) 243-4395 fax: (7 i 7) 243-4019 Alexander Spasic, M.D. 816 Belvedere St. Carlisle; PA 17013 Re: Chelsea Pompeo SS: 174-7674465 MVA:014585854010106703 DOi: 8/9/08 Dear Dr. Spasic: Chelsea is a 16-year-old female who arrives today with her mother for evaluation of a persistent low back . pain uow about 7 months status post injury in a NWA. Unfortunately they did not bring My diagnostic studies frorn.their t vatment:at HOC nor did they bother to bring a report I will have to have these retrieved in the coming weeks to verify, my diagnosis but she is doing fairly well. She is a 16 year old who is a 10`b. grader at Cumberland Valley. She was the passenger in the front seat of a small car unrestrained and asleep on or about 8/8/08 when the driver lost control of the vehicle and "hit a barn and a pole". There was no loss of consciousness. The patient states that she got out of the car and had left sided rib.pain and felt faint. She was taken by ambulance to Carlisle Hospital where "scans were performed" and subsequently transferred to the HMC.apparently 'by ambulance where she was hospitalized for about a week for what sounds like observation for a "lacerated spleen". Often these can be -treated nonoperatively with observation and serial monitoring of the blood count. At some point sbe was told she has a "frachire in the low back" and mother thinks, after looking at my 3D models, that it was a spinous process fracture. It is unaccompanied by any radiative pain. Mother states they went back to visit doctors at a trauma clinic or at the orthopedic clinic, she is not sure, for "one or, two visits" and she was dismissed from care. Mother is concerned because Chelsea continues to complain of midline low back pain after prolonged positioning such as sitting or standing.or if she is extremely active. EXHIBIT ? A C, Page 2 Re: Chelsea Pompeo SS 174-•76-4465 MVA: 01458S954010106-103' DOL 8/9108 She takes no daily medications. She develops a "rash" with morphine which I do not believe is an allergy but I fisted it as one. She states that she has no radiative lower extremity pain or bowel or bladder symptoms. Clinically she transfers with minimal dyskinesia and is somewhat reticent and soft spoken. She has absolutely dismal hamstring flexibility for her age and at 16 years she is able to bend over and bring her fingertips only to about the knee joint before her hamstring tightness prohibits any further forward flexion- Extension is possible to about 15 degrees with only a ncild midlute ache at either end point. Side bending and rotation are one half of normal. Heel and toe walking are intact. She has symmetrical thigh and leg circumference measurements with no pain to passive internal rotation of either hip. She has no ankle clonus or hyper-reflexia. She has good pulses to the feet with no cutaneous changes compatible with ischemia in the legs. She has robust resisted hip flexion, knee extension and ankle dorsiflexion with negative straight leg raise testing. This young lady does not need further diagnostic studies and certainly does not need an MM as she has no lateralizing or radiative symptoms. What she does need is a significant amount of lumbar paraspinal and hamstring stretching and some paraspinal strengthening as she tends to have a kyphotic postural stump. Her posture and hamstring flexibility are equally dismal and since I did not examine her prior to trauma, it may be that her hamstring tightness is a reaction to several months of low back pain as it caused pain to bend forward and stretch them. For this reason I am sending her to physical therapy for lumbar and hamstring flexibility and instruction in a home program. I will see her back in 6 weeks and comment on her progress. I spent one half hour with this patient today. Diagnosis: Lumbar strain and sprain with history of presumptive spinous process fracture of minimal structand significance with no evidence of radiculopathy and conservative treatment initiated. Sinc ly, P/ K, Mark P. Holencik, D.O. Mar 17 09 04102p Conservative Orthopedics ma;,?. i r, an" 11: 49?M Cc.gp I CUMBERLAND ORTHOPEDiC & SPINE MIMT} Stm DATE: March 13, 2009 PATIENT NAME: Cheisca Pompeo DATE OF BIRTH: November 3, 1993 DIAGNOSIS. Low Back Pain EVALUATION DATE: March 11, 2009 PHYSICIAN: Mark Haleneik, DO 7'7-2z 3-Z 0' 10.1681 P. PLAID' OF CARE ASSESSMENT: Patient presents with lumbar pairs that is worse with functional activities such as standing and sitting for too long, limited lumbar range of motion, and soft tissue tightness and point tenderness. GOALS - SHORTILONG TERM: (4 weeks) 1. Patient to have full, pain free range of motion of the lumbar spine. 2. Patient to be independent with a home exercise program. 3. Patient to have no soft tissue point tendemoss or tightness. 4, Patient to report a 0/10 pain level with ail of her functional daily activities. TREATMENT PLAN: Lumbar stretching and strengthening progression, lumbar stabilization progression, instruction in, proper posture end body mechanics, instruction in a home exercise program, modalities end soft tissue techniques as needed. FREQUENCY: () QD () BIW (fit) T1:W DURATION- 4 weeks. W&RABILITATION PROGNOSIS: Excellent. Therapist's Signature: ?Dttte: Yokc-A. D ? -)'3',?'MS, ATC Vicense # PT-007707-L I agree with the plan of care outlined above, Ph7siciata's Signature: Date: - -1 V Thank you for the referral of this patient. Please sign, date and return via fait to (717) 591-3003. You will receive a written update either on the patient's next visit to your office or upon discharge from our care. JD/111 EXHIBIT 6375 Mercury Drive, Suite 100 - Afeche ? 1.3000- Ph- 717-591-3003=Fax m g?9 c7' P. CUMBERLAND ORTHOPEDIC & SPINE PHYSICALTHERAPY DISCHARGE SUMMARY Date: April 6, 2009 Patient: Chelsea Pompeo Date of Birth: November 3, 1993 Date of Evaluation: March 11, 2009 Diagnosis: Low Back Pain Referring Physician: Mark Holencik, DO Dear Dr. Holencik, Chelsea was evaluated at our facility on March 11, 2009 and was discharged from our care on April b, 2009. Her treatment at our facility consisted of McKenzie and lumbar stretching/stabilization exercises, along with instruction in proper posture and mechanics and instruction in a home exercise program. Her progress with physical therapy was excellent as her pain level decreased significantly and at this time she reports a 0/10 pain level on a regular basis. She currently has full range of motion of the lumbar spine along with no soft tissue point tenderness and normal trunk and lower extremity strength. Since Chelsea did so well with physical therapy and is independent in a home exercise program, at this time we will discharge her to continue with an independent home exercise program. She will contact us if she has any questions or problems at anytime, Thank you so much for the referral of this patient to Cumberland Orthopedic and Spine Physical Therapy. Please do not hesitate to contact me if you have any comments or questions regarding this patient. Sincerely, Jose A. Dominguez;,- T, MS, ATC JAD/tit 6375 Mercury Drive., Suite 100 • Mechanicsburg, PA 17050. 717-591-3000- Ph- 717-591-3003-Fax Mark P. Holencik, D.O., F.A.O.A.O. 40 Brookwood Avenue Carlisle, PA 17015 Phone: (717) 243-0241 (717) 243-4395 Fax: (717) 243-4019 Dear Dr. Spasic: Re: Chelsea Pompeo SS: 174-76-4465 MVA:014585854010106703 DOI: 8/9/08 April 8, 2009 Alexander Spasic, M.D. 816 Belvedere St. Carlisle, PA 17013 Chelsea was evaluated almost 5 weeks ago with persistent low back pain after a MVA which I described in my 3/4/09 note. Diagnostic studies on a disc arrive along with her today as per my previous request and the hard copy in disc form of her vertebral and rib injuries was reviewed as was the report copy of the CT scan of the abdomen and chest that reveal a visceral injury, specifically a splenic laceration and hematoma that was observed without splenic excision being required as her blood count stabilized post trauma. Today I reviewed her systems as well as her recent past medical and surgical history and family and social history. I sent her to physical therapy at a facility convenient for her and her hamstring and lumbar flexibility were what I described as dismal at the time of her presentation. She has made quite dramatic progress and I would have to say in retrospect that her low backache and tight paraspinal and hamstring muscular were a consequence of the prolonged recumbency and inactivity associated with healing of her left sided lower rib fractures and the transverse process fracture that were noted at T12 and L1 on the left. These transverse process fractures are nondisplaced. I agree with radiology that the left lower rib fractures are minimally displaced and I don't think that the rib fractures actually penetrated the spleen but it was a contusional injury associated with sufficient velocity to fracture these bony structures. EXHIBIT Page 2 Re: Chelsea Pompeo SS: 174-76-4465 MVA:014585854010106703 DOI: 8/9/08 Clinically she is doing very well. She states that her backache is now resolved with the return of flexibility which I expected to occur. She transfers with no dyskinesia. She is able to flex bringing her fingertips all the way to the floor and this certainly represents dramatic improvement and is associated with clinical improvement as well. Heel and toe walking is intact. Straight leg raise testing is negative as is passive internal rotation of either hip for any irritability. She has no ankle clonus or hyper-reflexia. She has symmetrical thigh and leg circumference measurements. She has robust resisted hip flexion, knee extension and ankle dorsiflexion. She has no significant paraspinal spasm. Mother and patient both states that she has aches in the left thoracolumbar and rib area with weather change. This will persist for 18 months post trauma, or about another 10-11 months. How she feels next spring will be how he feels for the foresseable future but I believe it is quite reasonable to expect her to continue to do well. I advised mother and patient that if they have any significant problems or questions they should call back for another appointment and if any back pain recurs that is significant or disabling the patient should first initiate the same flexibility exercises that I hope she will maintain on a regular basis at home and that should take care of her problem. I will consider her dismissed from care pending any further adverse development that they are to report immediately but again remind anyone reading this that it will be another 10 odd months before she reaches maximum medical improvement. I spent one half hour with this patient today. Sinc rely, ark P. Holencik, D.O. 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The fact ghat the' anent continu s,. er fr cQrnpla?rlts Qf } _z r > -sit ire for.:t r` dsbf"ttme.as, -1) and 1; 1 i'g a au?nR'Prstra n? pyrain'f atot?2?''inl shy hasu#...'why h?o' nc ?h?up`?rae?St?r?pl???r?A!s??tec-?me t " t? chanQes ndth?'p"t?itep ??5Mf,?o? ` fir these;. t`a'.'?-,:Xs I•? shpui tt? Y J sl?t1 hvwUsly ti )S a itt ve to avptdA e 3r ^>. ..... _ ;;..c fix. « ? x:?+•y??+,,E?y s 'i.ti., .r....- - x? ?oLCI t 54 > Z t , 4 f. i IAJ 0004/0004 w i 1k 4 -t - Y t a _ e?tr2?n3.vortf.fr Otess' rifrti?r 'e .10nclen?y; i sirs nso r, s r nsyersi n t# "t r , ro ur #s severe }s?s:at?c this?is tole `rn P> `rtkrtA+[thnd!nd .. W. .. 2st Bred rt? M42, -MIN-4 N SA m MW ; t pq _ "l:.e.Ftl'; -ybs '?.+C ?'""''"'ss'•;'v?' ??'': .s a'l. A'-- a = ur7Y 1?a `wga' --•'p 5.2 . Q?TJ4 m, IRS Y A CERTIFICATE OF SERVICE I, George J. Costopoulos, Esquire, hereby certify that on October 17, 2012, I served a true and correct copy of the within Plaintiffs' Answer to Defendants' Motion for Summary Judgment by United States Mail, postage prepaid, upon counsel for Defendants as identified below: Eric Violago, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402-3737 Ge . Costopoulos, Esquire Dated: ! • ( 1 ? /i Z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD and DEEANNA POMPEO, NO. W-44+CIVIL TERM as parents and natural guardians of CHELSEA POMPEO, a minor child, Plaintiffs V. CIVIL ACTION–LAW ANTHONY R. KNIGHT, JR., JEFFREY UNITIS and KAREN UNITIS, Defendants JURY TRIAL DEMANDED = - —C Cn a PRAECIPE FOR DISCONTINUANCE _- = TO THE PROTHONOTARY: Please mark the docket in the above-captioned matter as discontinued and ended with Prejudice. LAW OFFICES OF GEORGE J. COSTOPOULOS By: — G J. Costopoulos,Esquire A ID No.: 78423 153 North Hanover Street Carlisle, PA 17013 (717) 243-0407 Attorney for Plaintiffs Date: 3( , 2013