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Home My WebLink About11-4327BENNETT, BRICKLIN & SALTZBURG LLC BY: Curtis C. Johnston I.D. No. 64059 222 EAST ORANGE STREET LANCASTER, PA 17602 (717) 393-4400 STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY One State Farm Drive Concordville, PA 19331-0041 Petitioner V. MI KYONG CHOI 5 Cardamon Drive Mechanicsburg, PA 17050 Respondent ORIGIN ATTORNEY FOR PETITIONER, State Farm Mutual Automobile Insurance Company -s mF V ;ter r r -i -*? COURT OF COMMO E CUMBERLAND COZY' s'ue' ? r CIVIL ACTION - LAW NO: - q3a7 0,ivirrerm PETITION TO COMPEL INDEPENDENT MEDICAL EXAMINATION Petitioner, State Farm Mutual Automobile Insurance Company (hereinafter "State Farm" or "Petitioner") by and through its attorneys, Bennett, Bricklin & Saltzburg, LLC, hereby moves this Honorable Court for an Order compelling the Respondent, Mi Kyong Choi, to appear for an independent medical examination within thirty (30) days of this Court's Order, to be performed by Disability Management Consultants, 920 West Sproul Road, Suite 202, Springfield, PA 19064, or face sanctions upon further application to the Court. 1. THE PARTIES 1. Petitioner, State Farm Mutual Automobile Insurance (hereinafter "State Farm") is a mutual insurance company incorporated under the laws of the State of Illinois, with its principal place of business in Bloomington, Illinois and a business office located in the Commonwealth of Pennsylvania at One State Farm Drive, Concordville, Pennsylvania, among others. O 44x.00 Po AT'E-C* 'q&513(, & a e9J98 2. Respondent, Mi Kyong Choi, is an adult individual residing in the Commonwealth of Pennsylvania at the address captioned above. II. INSURANCE POLICY At all times material hereto, State Farm had issued a motor vehicle insurance policy (Policy #: 7022-8431-C23-38I) pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. § 1701 et seg., to its named insured, Young Jin Choi, which listed and continues to list Respondent, Mi Kyong Choi as an insured driver at her address captioned above. 4. The insurance policy provides in relevant part: Mental or physical examination Whenever the mental or physical condition of a person is material to any claim for medical expenses or income loss benefits, a court of competent jurisdiction may order the person to submit to mental or physical examination by a physician. If a person fails to comply with the Order, the court may order that the person be denied benefits until he or she complies. Policy Form 9838A, page 16. The Policy further provides a duty to cooperate and provides in relevant part: 3. Insured's Duty to Cooperate with Us: a. The insured must cooperate with us and, when asked, assist us in: ... (2) securing and giving evidence. Policy Form 9838A, page 37. A true and correct copy of the subject Policy is attached hereto as Exhibit "A." The Policy provides first party medical expense coverage in the amount of $100,000 and first party wage loss coverage in the amount of $1,000.00 per month/$15,000.00 per accident. Id. 2 III. THE ACCIDENT 6. On March 19, 2010, Respondent, Mi Kyong Choi (DOB: 2/23/67 - age 44), was traveling westbound on Market Street in Hampden Township, Cumberland County, in heavy, stop and go traffic. Respondent had come to a complete stop when she was rear ended by a 1998 Chevrolet Cavalier. The impact caused relatively minor rear end property damage to Respondent's 2007 Honda Odyssey minivan in the amount of $2,920.62. See Exhibit "B" - property damage photograph. The airbags did not deploy. IV. INJURIES CLAIMED AS A RESULT OF THE 3/19/10 ACCIDENT 7. As a result of the subject accident, on March 19, 2010 Respondent presented to Holy Spirit Hospital Emergency Room complaining of head and neck pain for which she underwent a Brain CT scan of the brain which revealed no acute abnormality, and x-rays of her neck which revealed no acute fractures. Ms. Choi was treated and released, with a diagnosis of neck and shoulder sprain, and provided prescriptions for Vicodin, Valium, and Prednisone. Exhibit "C" - Medical Records Packet at p. 4-10. 8. On March 22, 2010, Respondent presented to her family physician at Pennsylvania Family Care in Mechanicsburg, PA complaining of musculoskeletal pain and was referred for physical therapy. She was released from work until April 12, 2010. C-11-13. 9. At the time of the accident, Respondent was employed by Clean Scene Dry Cleaning pressing and folding shirts among other duties. Respondent was working part time, approximately 30 hours per week. She has remained out of work to the present date, and has collected first party wage loss benefits in the amount of $1,000.00 per month, which benefits will be exhausted on or about June 21, 2011. She has collected $13,000.00 of wage loss benefits to date. C-2-3,13-16. 3 10. From March 23, 2010 until June 11, 2010, Respondent attended approximately 34 physical therapy sessions at Drayer Physical Therapy for her neck, left shoulder and low back pain with right radiculapathy, utilizing hot packs, aquatic PT, electrical stimulation, and other therapy modalities. C-17-26. 11. On April 9, 2010, Respondent submitted her application for first party benefits to State Farm. C-1-2. Respondent has continued to seek medical treatment to the present date and has submitted her medical bills for said treatment to State Farm. State Farm has made payment for said medical expenses as required by Act 6 of the Pennsylvania Motor Vehicle Financial Responsibility Law (hereinafter "MVFRL"), specifically, 75 Pa. C.S.A. § 1797. As of April 19, 2011, State Farm had paid approximately $9,804.35 in medical expenses. 12. On or about April 29, 2010, Respondent presented to Orthopaedic Surgeons of Central PA, Ltd. for evaluation by Dr. Fultz. Dr. Fultz reviewed her prior cervical x-rays taken at the Emergency Room which revealed no acute fractures and mild degenerative changes at C5-6 with narrowing of the disc space. i.e., pre-existing degenerative disc disease ("DDD)". Dr. Fultz referred Plaintiff for a Cervical MRI. C-27-29. 13. On May 10, 2010, Respondent's Cervical MRI revealed a disc protrusion at C34 without spinal cord compression; a broad based central disc bulge at C5-C6, but otherwise a normal spinal cord throughout. C-30-31. 14. On May 27, 2010, Respondent returned to Dr. Fultz for are-evaluation. His diagnosis was: 1. Pain referred to intrascapular area, upper extremity status post motor vehicle accident 3/19/10, possibly myofascial 4 ideology vs. cervical spine occult injury. (Emphasis added). 2. Degenerative disc disease with disc protrusion at C34 and C5-6 of unclear significance. Dr. Fultz planned to send her for an EMG/NCS study and, if there is no evidence of radiculopathy on her EMG, to consider referral to a pain management physician. C-32-33. 15. On June 21, 2010, Respondent underwent the EMG/NCS of the left upper extremity from C5-T1 which was normal. C-34. 16. Despite the normal EMG/NCS and cervical MRI which revealed DDD at C5-6, Dr. Fultz referred Respondent to HealthSouth Rehab for cervical epidural injections at C5-6, which were performed on July 26, 2010, September 20, 2010 and November 22, 2010. Each injection evidently provided pain relief for approximately up to two weeks following which Respondent claims that her left sided cervical/shoulder pain returned. C-38-48. IT On December 27, 2010, Respondent returned to Dr. Fultz whose diagnosis remained as indicated above. He discussed non-operative treatment options including referral to non- interventional pain management such as with Dr. Cho whom she has seen in the past, versus a bone scan with SPECT and cervical discogram to see if there are any surgical options that may help her. Respondent elected the latter approach rather than Dr. Cho. He stated that if the bone scan and discograms are negative, he would have little to offer her from a surgical stand oint. C-49-50, 57. 18. On December 29, 2010, Respondent underwent a bone scan which revealed increased uptake at C34 and C5-6. C-51. 5 19. On January 31, 2010, Respondent underwent a cervical discogram which revealed no pain on injection of the C3-4 or C4-5 discs, but an intense concurrent pain on injection of the C5- 6 disc only. C-52-55. 20. On February 10, 2011, Respondent returned to Dr. Fultz whose diagnosis was now: 1. Pain referred to inter scapular area and upper extremities status post motor vehicle accident 3/19/10. 2. Degenerative disc disease with disc protrusion C3-4 and C5-6 of unclear significance. 3. Pain in C6 distribution with concordant response on discogram. Dr. Fultz reviewed surgical options with Respondent. Respondent indicated that she would follow up with Dr. Cho, whom she has seen in the past for her pain management, until she decides what she wishes to do regarding surgical intervention. C-56-57. 21. On March 10, 2011, State Farm wrote to Disability Management Consultants seeking to have Respondent scheduled for an independent medical examination pursuant to the terms and conditions of her insurance policy with State Farm. State Farm was seeking an independent opinion of the diagnosis of Respondent's medical conditions, the reasonableness and necessity of the treatment she has received to date for said conditions, and a determination of whether said conditions and treatment are causally related to the subject 3/19/2010 accident. C-58-60. V. REQUEST FOR INDEPENDENT MEDICAL EXAMINATION 22. Pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law (specifically 75 Pa. C.S.A. § 1796), an independent medical examination is authorized whenever the physical condition of a person is material to a claim for medical benefits, and upon a showing of good cause. 6 23. By contrast, under the subject Policy of insurance attached hereto as Exhibit "A," State Farm is contractually entitled to an independent medical examination of the insured "whenever the mental or physical condition of a person is material to any claim for medical expenses." Policy at p.16. Thus, unlike the MVFRL provision, State Farm's Policy does not condition the right to an independent medical examination to a showing of "good cause". 24. It is well settled Pennsylvania law that an insurer is contractually entitled to an Order compelling an independent medical examination without establishing good cause, where the policy language does not require a showing of good cause. Fleming v. CNA Ins. Co., 597 A.2d 1206, 1208 (Pa. Super. October 9, 1991) (insurer was not required to make showing of good cause, as provided under statute, before it could compel insureds to be examined by physician of insurer's choice, as insurer had right to compel such examination, without good cause being required, under terms of policy). Accord Williams v. Allstate Ins. Co., 595 F. Supp.2d 532, 539 (M.D. Pa. 2009). Compare State Farm v. Swantner, 594 A.2d 316, 320-22 (Pa.Super. July 3, 300 1) (upon Motion to Compel IME, State Farm was entitled to the IME without conducting further discovery or depositions, without demonstrating a controversy exists, and without argument on said Motion), appeal denied, 606 A.2d 903 (Pa. 1992). 25. For the reasons stated below, State Farm submits that Respondent's mental and physical condition are "material" to her claim for ongoing first party medical benefits, in that there are questions as to: 1) whether or not Respondent's recent and proposed future course of treatment is causally related to the subject accident , or due to her pre-existing cervical degenerative disc disease, or to other unrelated causes. 7 2) whether Respondent's recent and proposed future course of treatment is reasonable and necessary to treat any injuries sustained in the subject accident which occurred on March 19, 2010; and 3) whether Respondent remains totally, partially or not currently disabled as a result of the subject accident. 26. Moreover, although State Farm need not make a showing of "good cause" to seek an independent medical examination given the subject Policy language, State Farm submits that the following facts also demonstrate that good cause for an independent medical examination of Respondent exists. 27. In connection with State Farm's consideration of Respondent's pre-accident and post- accident medical history, the record shows that Respondent provided a pre-accident medical history to Dr. Fultz of treating with a pain management specialist, Dr. Cho for chronic pain symptoms. C- 49-50; 56-57. In addition, Respondent's pre-accident medical records from Pennsylvania Family Care in Mechanicsburg reveal a pre-existing history of persistent daily back pain. For example, the history presented on February 5, 2004 by Respondent was that: Mi works in dry cleaners and is constantly lifting and hanging clothing and holding her arms up. Tonight Mi complaints of lower back pain. She reports that ten years ago she had a back x-ray, which showed that she had a `curved back'. She has persistent daily back pain. She uses hot compresses. C-66. Respondent was referred for a back x-ray and diagnosed with back pain. C-66. The back x-ray revealed mild narrowing of the U-S 1 inter vertebral disc due to her history of low back pain radiating into the right leg, just as she complained of following the subject accident. C-67 Respondent's pre-accident records also reveal a significant prior history of complaints of vertigo on May 17, 2004, June 22, 2004, chronic fatigue as of May 16, 2005; chronic vertigo on June 2, 2005 8 with diagnosis of benign positional vertigo several years previously; and continuing vertigo as of May 17, 2006. C-68-73. However, it is not clear to what extent, if at all, that these symptoms relates to her pre-existing cervical DDD. 28. State Farm is unable, without an independent medical examination, to determine whether the Respondent's alleged ongoing chronic cervical/left shoulder problems are the result of any alleged injuries sustained in the automobile accident of March 19, 2010, or are due to her pre- existing cervical degenerative disc disease, or to other unrelated causes. State Farm is further unable to determine whether the treatment rendered by her treating physicians to date and the potential future cervical surgery proposed by Dr. Fultz is reasonable and necessary and/or reasonably calculated to bring about any change or improvement in her mental and/or physical condition. Lastly, State Farm seeks an independent assessment ofRespondent's current work capabilities and/or restrictions, if any, which relate to any injuries sustained in the subject accident. 29. Accordingly, pursuant to the terms of the subject Policy, on March 10, 2011 State Farm retained Disability Management Consultants, a rehabilitation services vendor, to coordinate the scheduling and completion of an independent medical examination of Respondent, principally to determine whether Plaintiff's recent and ongoing medical treatment is causally related to any injury or condition from the subject accident, or due to other unrelated causes, and whether said treatment is reasonable and necessary. C-58-60. 30. On April 1, 2011, Respondent's counsel, who is representing her for a personal injury claim, wrote to State Farm advising that Respondent would refuse to submit to an independent medical examination unless ordered to do so by the Court. C-65. 9 31. Accordingly, State Farm respectfully requests that this Honorable Court now intervene to compel the independent medical examination pursuant to the terms of the subject Policy of insurance and/or the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, Petitioner respectfully request that this Honorable Court enter an Order compelling the Respondent to submit to an independent medical examination within thirty (3 0) days of this Court's Order, or at the earliest possible opportunity. BENNETT, BRICKLIN & SALTZBURG LLC BY: LIL Curtis C. Johnsto torney for Petitioner State Farm Mutual Automobile Insurance Company Date: 5-11-01011 10 IV. CONCLUSION For the foregoing reasons, Petitioner respectfully requests that this Court enter an Order compelling the Respondent, Mi Kyong Choi, to submit to an independent medical examination with Disability Management Consultants at a date and time to be provided to the Court, or within thirty days of the this Court's Order, plus grant all other relief available under law. BENNETT, BRICKLIN & SALTZBURG LLC BY: Curtis C. Johnsto squire Attorney for Petitioner, State Farm Mutual Automobile Insurance Company 7 7/ . ler State Farm Mutual Automobile Insurance Company Home Office, Bloomington, Illinois 61710 STATE fAtM INSUEANCE Concordville Operations Center One State Farm Drive Concordville, Pennsylvania 19339-0001 CERTIFICATE I, the undersigned, do hereby certify that I am custodian of the records pertaining to the issuance of policies by the Central Pennsylvania Division of the State Farm Mutual Automobile Insurance Company of Bloomington, Illinois. I further certify that the attached policy, number 702 8431-C23-38I is a copy of the policy issued to Young Jin Choi, of 5 CARDAMON DR, MECHANICSBURG PA 17050-7989, together with any endorsements issued subsequently based on our available records. Endorsements: N/A The policy was in effect on the loss date of March 19, 2010. Robert V Crisanti, UNDERWRITING TEAM MANAGER State of Pennsylvania County of Delaware Subscribed and sworn to before me this 3`d day of May, 2011. NOTARY PUBLIC My Commission Expires: COMMONWEALTH OF PENNSYLVANIA NoteMl seal Karon Ann Marks, Notary Public L MY corwo Twp.. ONeware Cowry CWW119 0rl Feb. 5, 2013 February 5, 2013 Member, enns ation of Notaries EXHIBIT A State Farm Mutual Automobile Insurance Company One State Farm Dr Concordville PA 19339 NAMED INSURED 38-3678-5570 CHOI, YOUNG JIN 5 CARDAMON DR MECHANICSBURG PA 17050-7989 ?nd??ud??nu?JJ?ndm??Ju?n?ddu??n?dddJu? ?0?? 93935-5-0 MUTL VOL DECLARATIONS PAGE NAIC# 25178 PAGE 1OF: POLICY NUMBER 7028431-C23-381 POLICY PERIOD MAR 23 2007 to SEP 23 2007 AGENT JIM CHON 267 N FRONT STREET STEELTON, PA 17113-2240 DO NOT PAY PREMIUMS SHOWN ON THIS PAGE. IF AN AMOUNT IS DUE, THEN A SEPARATE STATEMENT IS ENCLOSED. PHONE: (717)939-8918 or (717)939-9373 YOUR CAR V£I-OCLE Yf M MAKE mom BODY STYLE VEHICLE ID. NUMBER GLASS 1 1996 FORD TAURUS STA WAG IFALP57U5TA243984 1D3030F000 2 2007 HONDA ODYSSEY VAN 5FNRL38287BO16495 1 B3F3OF000 SYMBOLS COVERAGE & .IMITS PREMIUMS 1996 2007 FORD HONDA A Liability Coverage $88.04 ; $85.51 Bodily Injury Limits Each Person, Each Accident $100,000 $300,000 Property Damage Limit Each Accident $50,000 C Medical Payments Coverage $50.57 $51.66 Limit - Each Person $100,000 D Comprehensive Coverage $17.03 $28.83 G Collision Coverage - $100 Deductible $51.48 $116.77 H Emergency Road Service Coverage $1.80 $1.80 R1 Car Rental and Travel Expenses Coverage $14.00 $14.00 Limit- Car Rental Expense Each Day, Each Loss 80% $1,000 U Uninsured Motor Vehicle Coverage $5.00 $5.00 Bodily Injury Limits Each Person, Each Accident $15,000 $30,000 W Underinsured Motor Vehicle Coverage $11.70 $11.70 Bodily Injury Limits Each Person, Each Accident $15,000 $30,000 F Funeral Benefits Coverage $.50 $.51 Eaeh Person Limit $1,500 Y1 Death, Dismemberment, and Loss of Sight Coverage $'96 $,96 Z2 Loss of Income Coverage $6.01 $6.16 Total premium llor this p01icy period MAR 332007 to SEP 23 2007. This is not a bill IMPORTANT i11ASSAGES Replaced policy number 7028431-38H. New Policy Form CONTINUED I Q97A nnncn -Q- Ce..e.. ei.l.. This policy is issued by State Farm Mutual Automobile Insurance Company. MUTUAL CONDITIONS 1. Membership. While this policy is in force, the first insured shown on the Declarations Page is entitled to vote at all meetings of members and to receive dividends the Board of Directors in its discretion may declare in accordance with reasonable classifications and groupings of policyholders established by such Board. 2. No Contingent Liability. This policy is non-assessable. 3. Annual Meeting. The annual meeting of the members of the company shall be held at its home office at Bloomington, Illinois, on the second Monday of June at the hour of 10:00 A.M., unless the Board of Directors shall elect to change the time and place of such meeting, in which case, but not otherwise, due notice shall be mailed each member at the address disclosed in this policy at least 10 days prior thereto. In Witness Whereof, the State Farm Mutual Automobile Insurance Company has caused this policy to be signed by its President and Secretary at Bloomington, Illinois. Secretary /Ir President THIS MESSAGE APPLIES TO CAR POLICIES: IF YOU HAVE "COLLISION" COVERAGE ON THIS POLICY, YOU ALSO HAVE "COLLISION" COVERAGE ON ANY RENTED CAR WHILE IT IS DRIVEN BY OR IN THE CUSTODY OF AN INSURED. PLEASE NOTE THESE LIMITATIONS AND EXCEPTIONS: 1. THIS COVERAGE APPLIES FOR NO MORE THAN 30 CONSECUTIVE DAYS BEGINNING ON THE DAY YOU BEGIN USING THE CAR. 2. THIS AUTOMATIC EXTENSION OF COVERAGE IS FOR COLLISION COVERAGE ONLY. NO OTHER CHARGES IMPOSED BY YOUR RENTAL AGREEMENT ARE COVERED. 3. THIS COVERAGE IS SECONDARY TO OTHER INSURANCE CARRIED ON A RENTED CAR AND IS SUBJECT TO ALL OTHER POLICY PROVISIONS AND APPLICABLE ENDORSEMENTS. THIS MESSAGE APPLIES TO RECREATIONAL VEHICLE POLICIES: ANY "PHYSICAL DAMAGE" COVERAGE THAT YOU MAY HAVE ON THIS POLICY DOES NOT APPLY TO RENTED RECREATIONAL VEHICLES. State Farm Mutual Automobile Insurance Company One State Farm Dr Concordville PA 19339 NAMED INSURED 38-3678-5570 CHOI, YOUNG JIN r y ??, D-e R 5 CARDAMON DR Q (vj) \A?/' MECHANICSBURG PA 17050-7989 93935-5-Q MUTL VOL DECLARATIONS PAGE NAIC# 25178 PAGE 2 OF: POLICY NUMBER 7028431-C23.381 POLICY PERIOD --M--AR--2--3- AR 23 2007 to SEP 23 2007 EXCEPTIOMS, POLICY BOOKLET & ENDORSEMENTS (See po icy booMet & individual endorsements for coverage details.) YOUR POLICY CONSISTS EEOFFTHIS DECLARATIONS PAGE THE POLICY BOOKLET - CREDITOR8SCARE2U NPENNRSTATELEMPLOYEESTFCU, PO BOXIACL67013UDING,THARRISBURGHOSE YOU 17106-7013. CAR THIS IPOLICY PROVIDES FULL TORT OPTION. CAR 2 ORIGINAL COST OF CUSTOMIZATION NONE OR UP TO $1000. Agent: JIM CHON Telephone: (717)939-8918 This policy is issued by State Farm Mutual Automobile Insurance Company. MUTUAL CONDITIONS 1. Membership. While this policy is in force, the first insured shown on the Declarations Page is entitled to vote at all meetings of members and to receive dividends the Board of Directors in its discretion may declare in accordance with reasonable classifications and groupings of policyholders established by such Board. 2. No Contingent Liability. This policy is non-assessable. 3. Annual Meeting. 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Q CD --t CD CD CD•s m O ' Q' O bq '"" sv CD + O ' CD vt, CD a O r.+ w O COD ,,€••' O' ??„ `. ?, ,y n'. O ...- 0. CD .^O ?r C CD or'', `? O a' A VC ?? CD v c? `C CD "' N u, a .1 P) CD 0 P CL CL = Z- 0-0 (D 0 (7-0 Olo C) lp A) 0-0 *C3 (C) CD n C) °, °LL CD ?' o cn ? w 0. CD o m C) - 0 0 C) aq CD t3- 0 --r 0 CL CD (D CD n CD 0 w (D CD CD CD w a O O .y ? 'CD a " O p CD CD CD ,.._, CAD A) Z WC) N 0 .' C7 CAD p' ?. ?.. <D ?- "n O? CD CD ???,?;? a' e } I twsataawt ? APPLICATION FOR BENEFITS TO ENABLE US TO DETERMINE IF YOU ARE ENTITLED TO BENEFITS, PLEASE REFER TO INSTRUCTIONS BELOW. DATE OUR POLICYHOLDER DATE OF ACCIDENT CLAIM NUMBER 3/22/2010 CHOI, YOUNG AN 3119/20io 38"1-884-956 INSTRUCTIONS: 1. Where the word 'YOU7 or *YOUR" appears in this form, I refers to the person injured. 2. If you WERE NOT INJURED, complete only Ines 1 through 7 and return the application. 3_ if you were INJURED, complete the entire form and return the Application for Benefits and the signed Authorization for Release o U4om ation promptly wi7s copies of any medical bills received to date. 4. If you need to communicate regarding your claim, be sure to REFER TO THE CLAIM NUMBER and address your correspondence to: Retum To: STATE FARM INSURANCE CLAIM OFFICE PO Box 41 Concordville, PA 19331 Michele M. Dcoola Claim Representative PHONE NO. (888) 7134694 x3614629 RECSOM APR 15 2010 cONC UE 1. [APPLICANT'S j?NNAME (MAIDEN NAME) SEX HOME BUSINESS CC0iy / N1 " / 1 InW 4 elf I PHONE PHONE o NUMBER t )9F6/-9!4a1 NUMBER W-1r7 2. I PARENT'S NAME, IF MINOR 3. 4. 5. 6, 7 B. ADDRESS (NO., STREET, CITY OR TOWN, STATE AND 21P CODE) DATE OF BIRTH SOCIAL SECURITY NUMBER OWNER OF VEHICLE YOU OCCUPIED OR OPERATED CE OF ACCIDENT (STREET, CITY OR TOWN AND STATE) BRIEF DESCRIPTION OF ACCI Y ?- d#a- wn a- f'YDEis l ipt a+, J otkr CPI' nSv-Ve1ra it rte i n -iw-U 6a cK neera,ee .?,Tna?nnu cc riven ev vni I no AMV UPURGR M: Y(MIR FAILeI Y RFSInING IN THE SAME HOUSEHOLD AUTOMOBILE OWNER INSURER POLICY NO. LIC. PLATE NO. VEHICLE 1 1 otu A VEHICLE 2 B AC31 VEHICLE 3 VEHICLE 4 AS A RESULT OF THIS ACCIDENT WERE YOU INJURED7 %f YES 1-,J No IF YUUK ANSWtK IS TtS, UVWI-t It THE REST OF THIS FORM. IF NO, SIGN HERE AND RETURN THIS FORM TO US. SIGNATURE X DATE DESCRIBE YOUR INJURY' 1n a ao- r-kit SN!' in v ct x- id 4..r i-* rf' Oct. As Ae> t 'e1 N &,? 14 6M 1 0--alps ?a 'WHO IS YOUR FA LY PHYSICIAN7 (Name and A ddress) Founi (y & ro. M -4?7J-o --?"h r ? Tan el keiV C)t A) ° 910 cex r or i? ? - ,y"21toI ) ? 123702 1 1-2(704 SDI J j ilt fja?(JI n?? '? j fJ Page b of r Z+tt Addy ?„ J Z ?T/ J"'4 .l 1 PY141RIT C 9. 14. 11. 12. 13. 14. 15. 16. 17. NAME OF APPLICANT'S HEALTH CARRIER ADDRESS OF CARRIER WERE YOU TREATED BY A DOCTOR OR OTC R JAME AND ADDRESS OF SUCH PERSON: PERSON FURNISHING HEALTH SERVICES? plf YES ? NO OM) R D;e{2 ?s?e 4V060-(Ma6mrit &p 30 iA>y1 r A . G IF TREATED IN A HOMITAL, WERE YOU ? INPATIENT 0 OUTPATIENT DATES} AND HOL' NAM A ADD ESS lpk4 "a-' WILL HAVE MORE MEDICAL BILLS? DID THE A C) NT OCCUR WHILE YOU WERE WORKING? YES ? NO ? YES NO DID YOU LOSE TIME IF YES, HOW AT IS YOUR AVERAGE IF YES, NAME, ADDRESS, AND TELEPHONE NUMBER OF DOCTOR PROVIDING PROOF OF DISABILITY. FP,a+wORK7 Nf YES ? NO MUCH TIME? WEEKLY EARNINGS? CRAW ?'AST le-ell y !;ix, „P MACA 22- . q E o Lep-wim poet IF YOU LOST TIME, PROVIDE DATE DISABILITY FROM WORK DATE YOU RETURNED TO WORK f+yl,P(1, prs>! ??ly I7 BEGAN: 0 C/?tp?1 [ ,J HAVE YOU CJ9fVED OR ARE YOU ELIGIBLE FOR ANY MEDICAL OR DISABILITY BENEFITS UNDER: WORKER'S COMPENSATION? ? YES U NO HAVE YOU MADE ANY WORKERS' COMPENSATION CLAIMS IN THE PAST? IF YES, WHEN? MIA DATE(S) DO YOU HAVE ANY OTHER INSURANCE APPLICABLE TO THIS INJURY? (IF YES. DESCRIBE.) ? YES NO LIST NAMES AND ADDRESS OF YOUR EMPLOYER AND OTHER EMPLOYERS FOR ONE YEAR PRIOR TO ACCIDENT DATE AND GIVE OCCUPATION AND DATES OF EMPLOYMENT? d1,!n,u Sc.J-t Dry 0-e&jea mac. -cam 2000 P?-rs?-??` EMP UO, C R fNDAADD7SJC $,, OCCUPATION w?t? ?cy"J?g FROM TO 7 f? /ex s . a , EMPLOYER AN ADDRESS OCCUPATION FROM TO EMPLOYER AND ADDRESS OCCUPATION FROM TO AS A RESULT OF YOUR INJURY HAVE YOU HAD ANY OTHER MEDICAL EXPENSES? ? YES )(NO IF YES, ATTACH EXPLANATION AND AMOUNTS OF SUCH EXPENSES. The applicant au>horizes the insurer to submit any and all of these forms to another party or insurer if such is necessary to perfect its rights of recovery provided for under this act. Any person who knowingly and with intent to defraud any insurance company or other person files an application for insurance or a statement of claim containing any materially false information or conceals for the purpose of misleading, information concerning any fact material thereto commits a fraudulent insurance act, which is a crime and subjects such person to criminal and civil penalties. SIGNATURE X ,..^ DATE 0 ONAPRED PERSON OR REPRESENTATIVE 123702 10.21-2004 Page 2 of 3 WAGE AND SALARY VERIFI Aec Date Our Policyholder =331/19/2010 April 29, 2010 YOUNG J. CHOI Name and Address of Employer E+rpi MI K 4407 A Carlisle Pike Camp Hill Pa 17011 L92 S The above named person has applied for benefits as a result of injuries sustained in an auto understand this person is or was your employee or former employee. To determine wage completed and returned to us in the attached postage paid envelope, A signed authorize enclosed. State Farm Thank you for your cooperation, ION Im Name and Address Jon Wisneski Claim Representative I occupation 3, Wage or salary (gross) as of date of accident: Pre- 5 s01" Check box which corresponds to $ amount entered. Per Week EI!7 Per Hour Per Month Per year 2. claim Office Phone NoAf Date(s) of Employ 3a. Average number of Average weekly ovi Number of days woi Check days worked S M T W T F S 4. Dates absent due to this accident I 4a. if not consecutive, t From: -2.2 AM& 10 Through-, number of days: _ 5, Has employee filed claim for benefits under any workers compensation or similar law as a ? Yes No if 'yes", name of insurer: 6. Has employee received, is he/she receiving, or is helshe entitled to receive benefits under state or federal law as a result of this accident? ? Yes j4 No ? Undetermined If 'yes', name of Insurer. 7. Date of return to work: A Full status ? Partial Status ? If Partial '--t °':' / irs per week 30-s? - ne hours: 0- d per week: ?7 -- average week: ??(®?®? as absent or total of this accident? workers compensation act or similar hoursldays worked Any person who knowingly and with intent to defraud any insurance co party or other person files an application for insurance or a statement of claim containing any materially fats information or conceals for the purpose of misleading, information concerning any fact material thereto corn its a fraudulent insurance act, which is a crime and subjects such person to criminal and civil penalties. Date. /0 /L,/4)? ' (year) Phone. (2z-7-) (Print) Title: ne 511! Signatu --• FOLD is aoaident on the date indicated. We :fits due, we ask that this form to be for the release of this information is Claim Office 123877 03-25-2005 3 CHoi, Mi KYLNc 36" 47475 - 03/19/20.0 £RMEDRF.C 010 6 Po APR 0 5 x W" Lab & On am: COWMAME emo (. {Manor [ 1 Low t I Aatw*wOw [ I R [ I Tb*OOWFM [ J Aastons (SACE) t t I} Twwnb*OC Lsbs I I! 1 1 1 1 at?t+of tALC01 [ J [ i TOR Saar I I--?' E 1 J Amyios&ljp- [ 1 [ J Urine To (DOA$R [ J 02.Sst;b AMM [ I AM Gas ( I TSHR I 1 Beta ( I IV ( I TvMACHM-1 of unft i ? '/ t ! Addftmd'O ( I Blood cukm [ I • • 4K RI ( I BAP I J pw®a I I Type & Saar I t 1 f! t !tk( IOIPI IOAti t JCIAP i I [ jU*wca9 ( 1 CK.CKAB.TNT t J [ 1 Urine mce f 1 D t 1 [ I WC B180 AIM Tat 11 D pain [ 1 t 1 we Dag Soresn ( ! 1 DWUSn [ 199 1 101-- 9th [ I AbdjK) { sear [ I Knee R t { )ARM R [ I KLIS 0w,* R 1 I I Lis Sol" , Csbv. son-PAWS V iew) ( lImsrtdbis I I Cam Spro-MA.M t { Nast I I Cev SO*4'oMhb At i 1 Orw R L t Ise Pw O W (IPA E I Elbow R L 1 1 pysbv- MP ( ) Fsotd ( ) Ribs R L Fen- R L t l [ 16tiotider R L [ I Finger R L [ i Sad { { Fcot R L [ I SWr- ( I FOMM R L ( I Trio- { j Fard R L [ i Tb, Fib R L I IHO R L ( ITss R LL ! 1 tisnsnr R L ! I wnsa R 1 101- Turk Z' REAM W vik i -a 10tre owed- CT: E I At,cbm E I ( 1ouOU Dsppar - fly fl [ I P" t 1 (I Trewgg5wl [ I t l ""RfAcm [ 156% strap Ae Rspd I ) CsrvtesMCiaoet t 1 CME144ft 1 I GC cutsn [ 1 Mearpot tMPIM ( I spbm,n? c s s MOVPM t # FACM I 1 t t I LS tl N iILN tl a [1 1v tlls t J v t As 17100694 17100058 17100660 17100033 VP OX_ C pr. 90"wee o wo-wwoldt "W" w wo ( I vo San ow COON [18*0 W wdtot7sm awl fe PE L- ( IswdCtFs [ { Sad O i P ( I Stod c. ol6ois '' . t 1 Trldtotao w ( ]wwwCat ' t 10th-- 4k. Fit . BedaNA w Rap. Tx. kpkd T ? _tnlsA r [ Obw. blbi.M& I I T a ti [ ?) Pratwf inilsUd tor: i Z010 -1,19t (b AA 4?4 L- Pl- - n(? VV ? E b i t - ? t t ?•'? Vr_ YV` I I ' Ovo read buck N* 11 A MLAR Y 11 1G091R AIM CAR! A"1177" PwY>tRCXAIY T" r WRIESSNW. [ cNAac;E tr ? 1 d Idtlsls: Slpr>kexra• - b ( {Cwt ? ----?- >Y I I EMndsd Nn. v e?prne" Raw f twos `"i 'rn?a a 123 196'1 17100686 4 F 17200767 ERl 2)149 17182385 GROUP 967 7175 17180652 297496 03/19l10 -MN---TD-- [ RO MA [I ftbbd 4 Page 1 of 6 CHOI, MI KYUNG 36747475 - 0311912010 ERMEDREC 04/01/2010 6 pg - Awaks - Abrt 1 ? AppropdW Mm Co1Or ftn bftd td*N) nods! raponss OCOd Do<phw * DAbraobn ORph D rrMNww + S OCWmal s. Ohm OTsmV OEodgmoW& 06m u obudom :OWNL 00dbwMftdTkw bppropdab OPds OFlt*W OPrsrcam Wound / R omc" OAP" rado ODadq Omow OUWWmftV AWMM L / R 19W Tong OWam OCod C tAtooopwaers OPNNWMa Ocvln* cww dco 0 `' Dina! Pube:OPrsssrs cpm pop. OtlsrbserAbudrsOCmddive bspgropiass r-`:: L7?4?= EdMef Oyu ONO OAmdwA OCrybO pyYtpl spaarniq prd 1 blOest OContrded D vIp Y OS ONO Q OCoiuwd oumts tD pdn OPds Doyaoft Omm cwwow Local= 7 Y ?t `Z ll? O Soon ? Ohndache OPERL A L EYES Y010R AESPONBE VERBAL oderAn We uuw sw { uo" pain ostil nsrlr Slts............ ..?. dlrrlrpr I ° ?rradt pain P190, O O 1 SpaYrrao I OW 1004" 3 TO wib Oorsrnend 5 Loco d 4 DW " owp-Y 0"00 ---- Ssrsr?r 110 D1ae{st MOP DkW Cl Cl m P n I 2 To pb 4 Pdiw ibdgd 31 gpr 41 11 oDP As erspmr Opaor chandom odwo ClnLwb sss: Fbmd o 13 1 NO ret0anes 3 Abroad Maim Mad OMmN No Dkrtgr ? 0sdwss GM wNNMq Odllal Savowh U La 2 Abroad Elmwm 2 boorpdwotM Dntrrdon a Obrmmq Open" O . th up m sow& i Wow Le1P Wow OJVD OS08 Olwo • UM i No Ro OPYA ; Opp9uY anwsa Dptnrde D Pain QDun MW hwd;y Lot 9M OAbdwmon WAw I O cnft" nrpsa Odwdm DYOwAM Owns pM w0Hwm tOmwb gars{ Sounds OdlsW ded OArm Dsolt I OCatt R 1 L E1'ES OPaln L / R Ac*,' ObkwM VWM L 1 R Ears Maas Throat Web LAR Oeonpsdm Usaa bP ? ? ' % _RK r bo - 6 OdO" VWW L / R won Ddisdurgs Odrabspa OdrOOErq Cal rseeh ltlnt DPholOphobla L / R 00dw. OEpiom L i R Ddysp" OSR +p +Q ER N or-Ammobma ON= 1.sosws e.? Wft Dab Stad Stop Amt Stlutiat SL Site Reis A9pi Card wm 0e" T 01 1 Done Rota sb b" 1 1"" o t o r' d 5? 4L?1 lu c 1 I Off/ TW N Nobs tn{ue+ W t lop pll ?- f RL - OSef OFarsiy / IW Q..*0 OAMA OOR A, S-b 1-14 R ? AOf9? OPsNrM 0001w f Ar r? A_ E / ambd At ' N Y Z L 1S Z u a ti.' ` "m to Oda" duo dons Osram[ar etrsekist aosrplab 1 IC. G lc s e. vi" W oer?.? r ?F O mm DDscaand Io Nova X00 f eft- O q rk • 1f it?ve.1AZA zcd nN ' * 11 f?+ f?DwltlcYts? 0802 .1[I Ky= Q'3 F cow PA 17011 ERl /2 3/1967 Jdn DWU ECU ED GROUP 974 36 MS 67675 7 RX01 A s MMmWV Nobs 297696 03/19/10 ; 205,-ECU dt 1111 Pav. LLW f BUSINESS FFICE Page 2 of 6 CHOI, MI KYUNG 36747415 - 03/14/2010 ERMEDREC 04/01/2010 5 pg } 7 A (5) Nurvift Assessmam Rwasw Yl b Review 4 Q Taunus iesusam. l1TD PHYSICAL EXAM DATE IME O an arrmaa gauRe? ?Psssttti?ICE c- tar ( PT I, mNd ROOM: EMS /beirai -n?Ua datress anti J mo{de l7eS ueaans=ee alert ? ' HIST ( e ramedia? ^ o ?,;danu of trwma 2tac4l?a ! ais't AGE l t / NECK life _HX ! -EXAM UNITED B iron-tender HPI ? ?ne W Nexus crksria not as I dtstraetlmg injury- w arriwl ake+ mental oa rr" bona mcmETOH- maw/ ov vehicle momreye{e Art r , w*nMM comae) PaT , ether LUZ locaUDt= of DWII J '• -49bt-. , s shldr hip shidr hip s _ head face mouth arrn d* arm _mm neck these abdomen elbow knee 1 ebow knee )Ae uneginf pWb R__ dohmmct (E-R - t , L? back apper mid. lower i I'-arm let I farm leg _ l EOt a ! 9aisy------- eo&Ulnt to (R / 4 thlth i let wrist snide I wrist ankle l=rke?+al -------- hand foot hand hot srevaslty ai nairt: ?!L?7? lBI? FM-t wMarnat TM ?b d {ost eo?i»do?Ste>a t dried bn t?atsi b mod duration: _x dekual injury injury 1 usion- fee ( rrvasa) remm+baa ASR ! Cf ?? comkv I to ho?Kal T?? ??k? an ! belt brvish? seven ? q scchymosis c ! subs amphyaema sounds nml I moven"M "P" = rMnary S" = Saco none *0 rt wend= kmd dmr eel ttxmkh - p doesn't whetltas I rates Vhonchi ar seat Md4cardla I b - au aployed ""di r no part - CZi DOMEN) see e?otram (o rsrane )_.--- helmet protectlve dotlyru tender tandernessl Irebound rum ve >tsnomspl7 mass!! °rt+n a1y ram ? o ?santion direa i exttiatioa -rant bowel ands'' ' { TOEAL I RECTAL. mi ant inspection bioo?! at urettv VnMws_ ROS P- - - - - - - - - - - - - - ' - , -ntam{ recall exam decriand r ec rorre_ amw low !swing I power arm= I iet= , trwYl bnatiring I st pain ; b:: of bladder ::he" na=tive sool function _na biaadlnt in ;skin laearsdan , YC !cis led- '-Emma vision I hauft ion racem laver I illness x3 facis? nausea I von ti pMpt',oonbr edhome tea t, erect tam! u / atlx pit` abdornl-' p =,) in net «eept u marind _ s mil son I m degdt - - ----------- - - - - - - - " - ensacbn 6 motor rani rep questi= - - - ?{; - - - --- drug use I abuse sea ' lives aloft ' s / diap rests r dry horn- osis - -sing ' lives in ma ' ............ -?------------------------ ten, o Adernoat s« point PAST Fq( etati"a __prior records reviewed vertebral CY Weda diabetes Type t 2 d /,,d / ksu6rr tuidarneaa RON1_ l?s- we hare -rota l sponwwou* (4) to (3) ro R) -ease ( noes (t} - KDA /ace • ° S21 extae R} nose (l) tank! ( 1) eoearh« R) O 1946 -1806 T dbortented 11) a3 F /me as eterck CoeldasA n sYsa Clio% 6 7 Holy pirit Hospital t:R1 02113/19 Hilt. Pn 29 496 John R. D EMOWICY Center ED GROUP ! 67474 5 297496 03/19/1 EMERGENCY HYSICIAN RECORD Rev. 06 t 22 / 06 Page I of 2 Page 4 of 6 6 CHO!, MI KYUHG 36747475 - 03/19/2010 ERHEDREC 04/01/2C1C 6 pq d R Pts tetervention t Pls IlunI6 Encounter Pokt of Can T it1 arse: OUT Time: 20 BOG TI- initial 15 BBIV- btdside, ea. Trhw 20 OnhDitllfiC A 15 blood - took s 15 - 9009 UA ltahers sloe 15 Sew ofteataftu and test 2Monitor I 15 visual acuity 1X 1Yaal Signs. coca ' mp 1' 15 Splint simple sloe d ookar , toe, hand, ace, sr%cast 2is 20 lint inunpb. 25 cabomw ownba" psy"C_ 15 Re-K"m Patient once to 25 Soda* at bedside QNc4fflq kin. I General Pmbedwo Disd4w s 25 Fled enema 15 Crisis Social Se 15 Dreisim - 20 15 JAIWASopwMit 20 Evell Ear Irriciptim 25 Admistion I r rt 2D IY aduk 50 •on 25 ry look CtNlcal Can 25 FV Meds - - ea. 25 1 IV Medaed D ' - ea. -IV- 48-1 Products - ea. 15 - PC?t rectivW&JM ow - SQ 1 W 10 HeciLock Conversion 200 150 100 60 125 75 Cardwc Arrest asl Deft iladon 1Dr 1 Chock ube' Lu isl assist ` assist st 15 UNrAvAbown adrnhtistraGou? 200 I 15 paldbolow -a" (once) 200 aw nsmWon 10 25 I Central Gne access (Labs Drawn 15 Suckom - oral 2a Suclorkg- tracheal 25 Sucibc Owns bor4 i IL D assist T le X{ Tradsmirl -CT VQ.U Mla DMIT l 2a Tubk - sL call h. , NG 15 waird bums - deanse. irriptim, C&S Tool! its 15 04 cam t levels level ! 1 ON points 15 Msion trains 15 pkiowaphs 15 Whed re level it 1 Lewd IV 51-1 91-1 3 is 60 'nffi -12D 00043 Phobe calls, old records level V 221 kW w 10 Recbrd I x-ray co ONGYM 25 Pd& exam assist 20 Pe* dowler 17101080 17101098 17101205 1 2 3 125 Rwk exam-limited i 175 Rwk exam - Extended Add+tioad Maas po" 14 hrs. I 24hrs or mots CAM I 48 tn. f 2 1;16 ivs TIDI AL SCORE 16-24 hrs Y Splint ' John Nun ing Dietz Emergency Center intavenfion Shoo 11A1lacrjru ? Y-4L? m? c Patient ID , 9 119 110 Page 5 of 6 - ?CZ, y`vj%G '6'e'e' - C'I'.','2^>^ F?hMErFEC 041^1t2^'^ 5 oc EXji?EMITIES -see ram _!!a m:uc _b point-tenderness ___- stable / unable to bear weight non-tender W deficit _ ederna ROM* nlat pulses nmf _ liml RCM / Ilgamertts+tY -joint Sion PROCEDURES J - - - - - - - - - - - - - - - - Wound Oascription / R pair length cra ors superficial *subtut 'M a linear stellate irregular , dean contaminated distal NVT. nouro E vascu status intro no tendon Injury ; anesthesia: kcal block ML ; Ildoc 1% 2% epiltsiearb marnuu 0.25% 05% LET ? moderate sedadan required attached 23d tampiate prep: Betadlne I normal saline , irrigated I washed w/ saline debrided ; minnkned / mod / 'extensive minimal / *mod f • ` ^eraera?ve , wound moored undermined ; foreign Material removed me and / mod / ^e:trr m ; partk* ez Mpieteir 'wand margim revised ; M&VMd / mod t *eM,W multiple flaps aligned no foreign body Identffnd repair. Wound dosed with: wand od mxve / Dem=bwrd 1 swn st* ; SKIN. # -0 nylon I prolem / staples / in-upecd -wikT ample mot6esr / h / v j ' ISUI6CUT-# -0 vicryl / chromic inamrpmd , matrrass(b/v) 'snn ;ndic? i [Intap. by me ltenkmw by me ?D owd w/ radidogix T-Spine LS-S P* / NAD _ I saaightening of cerv. lordosis ro DjD _ Mont fra spondylosis /spurring rs nortdispdacad dlsptxed _ oft tissues nml CXR rib cwro _ nml I NAD _' 1 no infiltrates IIm1 heart size nrtn! medasdrnxn OTHER ?See svrparate r iLAS3 CBC - - nomna! arrspz - - - - - - -' Chernrtrfes -------- orext;0c -- le wBC :.r Na Quc_- ' Rec bends K flUN Ng4 nymphs G Crest ; Platdaea_AHCR C02 Ca UA- _normal WBC R9C bacteria ' , is= fact urim POS / Toxfco"y ASA etamin ETCH - ---------- -------------------------- iladalioa irdicarss organ *MUM e1srrva4et Or mmt mom reryired son Sweem emnv r , IIIHiillt?tUllilN lIt18Ni Hsi Ill! , / J?7 T-Teedwwn E4 edeeaeis rSuellf w4wayswis F6om L ref.Nretaers sv?rswref e•Gee (?-titrbau e r PROGRESS Fyne utnd4.gend itnpro re-examined initial fracture are pr ' ad.- W ow-up Discussed widh Dr. Time - w6 sea Pao ent ter ED J f mpitcl - - Counsek - fiueeil- - i - - - - dditioenl Nstory from: - ; fob /fed resuits ter i k caretaker pesremedna ; Rx given CRIT CARE TIME { s?arg ndY biilo8le Hues) 3474 men 73-11 04 min ndn ' L------------------ CLI?!IICALI ---- ----- - -----------± ,,Hair con Sion arm ?y,? elbow torearml R/ L R J L R t ? . oracic Manion ? wrist R I L restDrative hand head hip f a c e thigh R / L RI L R I L oncussion ith LOC w/o LOC chest knee abdomen kg R / L R/fr oration A bads ankh R I L -A shoulder R / L foot R / L I MPQSLTiQityf ,??0 home ®admi* Kl!/qQ1 ? trendarred tP /NP TVRI: ATTENDM!iG f?TE; Resident I PA / NPs history r Briefly. pertinent MR it tvkvve? pnoent in awed and acan fined. my persaw eon of padent revv /a Assamnent and plan mWirwed w studies show- idn neon 1 Lab and anol" I confirm dne dispwsis of -Care plan reviewed. Pstleht w ill need" Plow me resident / mldlewl oa je fix d ioifa Phyalegrn Slyrtapse fen turned on over at 1 + Slgnsun Template Complete ? on tan f T-Sheeot assumed cue at Dktated A.dfandurn ERZ CROX rJU XVUW 43 P ED GROapp 021 31296; 297196 0311.9110 297 96 36 {775 f Page 6 of 6 8 Holy Spirit Hospital Department of Radiology and Diagnostic Imaging Camp Hill, Pennsylvania 17011 (717) 9724900 PATIENT: MR#: PT CLASS: ORD DR: PT TYPE: DOB: LOCATION: GENDER: CHOI, MI KYUNG 297496 E SELENA DIPAOLO,CRNP E 02/2311967 ER1- F DICTATION DATE: Mar 19 2010 8:20P TRANSCRIPTION DATE: Mar 19 2010 8:2017' ADM#: 36747475 ADM DATE: 03/1912010 ARRIVAL DATE: HOSP SERVICE: ER1 ACC#: 3802665 ***Final Reports" EXAMINATION: CT BRAIN WO CONTRAST - Mar 19 2010 COMMENTS: Exam: Brain CT without contrast Clinical History: 43-year-old female post MVA with headache. Evaluate for bleed. Comparison: None. Technique: Axial 4.5 mm images were obtained through the brain without contrast. The images are presented in brain and bo windows. Findings: The ventricles and sulci are normal in size and position. There is normal gray-white differentiation without evidence hemorrhage, mass effect, or findings to suggest acute ischemia. The paranasal sinuses and mastoid air cells are well aerate The bony calvarium is intact. The superficial soft tissues are unremarkable. CONCLUSION: No acute intracranial abnormality. I Ct DICTATED BY: GINA M CREUTZBURG MD / PSC W Z. it, DATE OF EXAM: Mar 19 2010 Ott` SIGNED BY: GINA M CREUTZBURG MD DATEfTMME: Mar 19 2010 8:20P study interpretation provided by Quantum Imaging. To provide the best and safest patient care. During routine daytime Qtantum weekday. weekend and holiday rm-site coverage, a Quantum Radiologist can be contacted at 717-763-2948 (Holy Spirit IMAGING Hospital). Alternatively, a Quantum Radiologist can be reached by phone 24 tours a day, seven days a week at 717-932- tm30. CONFIDENTIAL: This report contains private patient information. N you have received this report in error, please call 717-972-4941 immediately. Confidentiality Disclaimer. The information contained in this communication may be confidential, is intended for the use of the recipient named above, and be legally privileged. It the reader of this message is not the intended recipient, you are hereby notified that arty dcsseminatron, distribution, or copying of t communication, or any of its contents, is strictly prohibited. if you received this communication in error, please resend this oommunication to the sender a delete the original message and arty copy of it from your computer system. Thark You. Imaging Services Consultation Page 1 9 Holy Spirit Hospital Department of Radiology and Diagnostic Imaging Camp Hill, Pennsylvania 17011 (717) 972-4900 PATIENT: MR#: PT CLASS: ORD DR: PT TYPE: DOB: LOCATION: GENDER: CHOI, MI KYUNG 297496 E SELENA DIPAOLO,CRNP E 02/23/1967 ER1- F DICTATION DATE: Mar 19 2010 6:25P Mar 1 010 6:43P TRANSCRIPTION DATE: 36747475 ADM#-. ADM DATE: 03/19/2010 ARRIVAL DATE: HOSP SERVICE: g8pER1 2628 ACC#: -"Final Report*** EXAMINATION: SPINE CERVICAL MIN 4 VIEWS - Mar 19 2010 COMMENTS: Exam: AP, lateral, bilateral oblique, odontoid, and tip views of the cervical spine History: 43-year-old female post MVA complaining of pain in the neck. Comparison: None. re of Findings: The cervical spine is visualized through th?Cmi d1 level. Then i sno pace nanrment at C rvatu Therees o sign fica? -C6. i Vertebral body heights are well maintained. There osseous narrowing of the neural foramina. The visualized odontoid is nominal. There is normal alignment of the lateral masses C1 with C2. The prevertebral soft tissues are CONCLUSION: Mild degenerative change at C5-C5 without acute osseous abnormality. DICTATED BY: GINA M CREUTZBURG MD I PSC DATE OF EXAM: Mar 19 2010 SIGNED BY: GINA M CREUTZBURG MD DATEfTIME: Mar 19 2010 6:43P Study interpretation provided by Quantum Imaging. To provide the best and safest patient care: During routine daytime Spirit Quantum 763- I contact day,seven days a 2948 ? 7 32- Rad M A G IN f ? m weekday, ?ternatively, a Quantum Radiologistcan be reached by p phhone 24 ho 717- .?' W30. CONFIDENTIAL: This report contains private patient formation. If you have received this report in error, please call 717-972-4941 immediately. Confidentiarrty Disclaimer. The information contained in this communication may be confidential. is intended for the use of the recipient named above. an tt be legacy privileged. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying received this communication in error, please reseed this communication to the sender at , or any of its conterds, is strictly prohibited. If you communication delete the original message and any copy of it from your computer system. Thank You. Imaging Services Consultation 10 Page 1 4*), PINNACLE HEALTH 03122/2010 5:35 PM PATIENT: DATE OF BIRTH: DATE: VISIT TYPE: FAMILY CARE MECHANICSBURG 910 CENTURY DRIVE MECHANICSBURG. PA 17055 Phone: (717)506-4720 Fax: (717)506-4734 MI K CHOI 02/23/1967 03/22/2010 4:30 PM Office Visit I 00 3A, Reasonls) for visit 1. mva 2. Musculoskekdal Pain Onset: 3 Day(s) ago. it occurs constantly and is worsening. Location: (arm) neck. There was no radiation. The pain is aching. Context: there was an injury and motor vehicle accident. The pain is aggravated by movement. There are no relieving factors. Associated symptoms include decreased mobility, difficulty going to sleep, tenderness and weakness. Past Medical History Reviewed, no changes. Family History Reviewed, no changes. Social History Reviewed, no changes. The patient is a non-smoker. Review of Systems Musculoskeletal: Positive for. - Boneljoint symptoms. JointlBone: neck. Side: bilateral. Symptoms: stiffness. The severity is described as mild. Improved by NSAIDs. JointlBone: arm. Side: left. Symptoms: aches. The severity is described as mild. Joint/Bone: shoulder. Side: left. Symptoms: aches. The severity is described as mild. Trauma occured. Type: MVA. When: last week. Comments: seen in ED; xrays negative for fractures. Soft cervical collar; prednisone, vicodin, valium. - Muscle weakness. - Neck stiffness. See History of Present illness. Vital Signs BP Temp F Pulse Reso Rate HtIn 110/70 98.4 78 18 Comments W Lb Pain Score 115.0 Z? CHOI, MI K 02/23/1967 7/7 11 Physical exam Constitutional: Level of distress is in pain. Well nourished. Well developed. Musculoskeletal: Cervical spine has muscle spasm, moderately reduced ROM Left shoulder has sling in place Clinical Assessment The patient is a 43-year old female who presents with mva and musculoskeletal pain. Assessment! Plan 719.41) Pain in joint Involving shoulder region Neck sprain (847.0) on vicodin, valium,prednisone Referrals Timefrarne Status Physician ordered Refer to drayer physical Therapy ordered Refer to Physical Therapy Patient Plan: instructions Refer to physical Therapy Refer to drayer Physical Therapy nosis 847.0 718.41 AQpointment vie Provider: JANET KELLY CRNP Document generated by, Janet Kelly 0312212010 5:35 PM Reason 12 CHOI, MI K 02/23/1967 717 PINNACLEHEALTH FAMILY CARE MECHANICSBURG 910 CENTURY DRIVE MECHANICSBURG, PA 17055 Phone:(717) 506-4720 Fax-(717)506-4734 03/22/2010 To Whom It May Concern: MI K CHOI is currently under my medical care and may not return to work at this time. Please excuse her for 3 weeks}. ? g Y/ She may return to work on 04/12/2010. Activity is restricted as follows: none. If you require additional information please contact our office. Sincerely, JANET KELLY CRNP MAY 0 6 201 CONCORI MLLE cm 13 PINNACLEHEALTi'i FAMILY CARE ME0 IANIVSKURG 910 CENTURY DRIVE MECI iANICSSURG. PA 17055 Phone:(717)506-4720 Fac(717)50G-47,1-1 To Whom It May Concern: MI K CHOI is currently under my medical care and may not return to work at this time. Please excuse her for 21 day(s). She may return to work on 031312010. Activitv is restricted as follows: none. If you require additional informatioc) please contact our office. Sincerely, JANET KELLY CRNP ?r 1,4e?V. 6t4,f-ej' jg,?- f,-fy h o-zl k I?e 04/0912010 Low MAY p 6 To co n"E ewe 14 1 1,1 AM aa??rl ORTHOPAEDIC SURGEONS of CENTRAL M ! PENNSYLVANIA, LTD 550 N. 12`' Street, Lemoyne, PA 17043 (717)-901-8000 Fax(717)761-6860 - Craig W_ Fultz M.D. Robert J. Maurer M. D. Jeffrey W_ Finn M.D. Brandy M. Ktnnykoski, PA-C DISABILITY CERTIFICATE} D.A. E I Ellis is to certify that Has been under my professionWkare. lipase note the following disability information. DIAGNOSIS - Surgeryn'esting./Physical Therapy Referred to Another Physician. Other Notes: - ? May Retain to Work Elective I l with no work restrictions. j May Not Return to Work Effective f-Za ? ?_AZ_ to 1 j u May Return to Work. Effective ! f with the restrictions noted below: ? Limitations on hours worked Flours per day .. # of weeks Hours per day # of weeks Left Right O Reped ivt A rW14and t;se NO Yes No Yes Other Notes: o Use of eomputeritype - o Simpie grasping - o Pushing/praling - 1 nine manipulation. o Overhead work -- - O Lifting No -,1-10lbs -10-25lbs 25-50lbs Over 541bs Other - Not Permitted Oce&%ivnaily Frequently No Restriction Q Walking - ? Standing o Sitting u Bending - ? Climbing - ? Kneeling - ? Squatting _ --- Next S edu14 App tment -,?=Y ! ; ![.?' Physician .? Signat" Patient's Initials M Enter 17V Fax to:Ur?.? ?/3 (J 15 ORTHOPAEDIC SURGEONS OF CENTRAL PENNSYLVANIA, L'I'D _ 550 North 12'h Sired, Lemoyne, PenWlvania l ?043 (717)-901-8000 Fax (717) 761-6860 Craig W Fultz. MD. Robert J. Maurer M D Brandy M Komykoski PA-C DISABILITY CERTITICATIE DATE /0? l 0? ? l 41 This is ro Certify that / 16 Hu been under my "proofes_si`oiW care. Please note the following disability information- EMPLOYER DTNGNOSIS h"Me- Ag11 /J CiRli? a/td?iC>r/aC.? Surgery is oitic /I. Referred to Another Physician ? May ReWily to Work Effective with no work restrictions. May Not Return to Work Iffeetive ? May Return to Work Effective _ -' i I with the restrictions noted below: ? R2peciiive Arm,'ETsnd U.?c (LT.RT) Other Rcseietions o Use of computcrkypo o Simple stw*g o PuAingtpulliag U line manipulariota C Overhead work Not Pennitted (k-casionally Prequentiy No Restriction 0 Walking ? Standing _ ? Sitting - ? Bending ? Climbing ? 1{nec:ling _ ? Squatting _ U Lunging; ? Pivoting ? Driving - -- ? Lifting -- - Next Scheduled Appointment &101 /_ 40" tie- Physician Name d ,YC. ZlL-- Signature Fax to: S .C. Claim 4 twxe V57.jz 16 DRAYER7 Physical Therapy Institute Lx"ng the liter m Good ttmtth . Initial Evaluation Patient Name: Mi Choi Date of Evaluation: 3123/10 Date of Birth: 2/23/67 Sex: F Date of Onset: 3/19/10 Diagnosis: Neck Radiculopathy, Lumbar, Thoracic RadicuIo ath , L Shoulder Pain Surgical Procedure: N/A Referring Physician: Dr. Janet Kell Date of Surgery: N/A SUBJECTIVE HISTORY: Subjective History: Patient is a43-year-old female status post a motor vehicle accident on 3/19/10. Patient's primary language is not English with minimal understanding of the English language. She comes to physical therapy with her husband to help communicate. She complains of severe neck/head pain, (B) shoulder (L) UE, low back and (B) LE (L) > (R) pain following a rear end collision. Patient notes head hit on the steering wheel during the incident. Patient reports going to hospital approximately one hour after the incident and receiving x-rays, CT scan. She denies abnormities of images. Patient denies prior history of injury of multiple body locations prior to this injury. Current Complaints: Patient complains of neck and head pain that is a constant pinching, swelling, sharp sensation. She reports pain radiates into the head; this pain is a pinch pain like " hitting the wall with headaches". Patient also complains of pain which radiates to the (B) shoulder region, all aspects. Patient reports severe pain into the (L) UE to the hand. She reports (B) numbness and tingling sensation on the (B) hands and fingers (L) > (R), that is intermittent and varying in intensity. Patient also complains of pain along the entire spine with most severe pain located at the scapular level and at low back with complaints of (B) buttock pain (R) > (L). Patient reports this pain is a pinch pain. Patient also complains of (B) LE symptoms from thigh to foot, all aspects. Patient notes it is a throbbing sensation (L) > (R). Patient also reports a numbness and tingling sensation in the (B) feet that varies in intensity (L) > (R). Function/ADL Ability/Restrictions: The patient has pain sitting immediately, walking immediately, don/doff clothing, cutting food, transferring into and out of a car. Patient is unable to perform stairs, lift or wash dishes. The patient is unable to identify any easing factors. Prior Level of Function: Patient was able to complete all ADLs and home care activities w/o pain. Pain Rating: Worst: 9 /10 Current: $ /10 Best: 6/10 24-hour pain pattern. Patient reports symptoms worse in morning with symptoms decreasing at lunch, however, pain returns and progresses throughout mid day with difficulty going to sleep secondary to positioning. Patient reports waking 2 to 3 times per night since injury secondary to pain. Oceupation/Work Status: The patient is works at a drycleaning facility. Work tasks include washing shirts, packaging and ironing shirts. Patient works Monday through Friday for six to 10 hours, however, she has been unable to perform work duties secondary to injury. Patient also is responsible for all household chores and is the home maker for her children. She has been unable to perform her chore activities secondary to her symptoms. Social History/Interests/ Living Environment: Includes gym activities such as cardio work outs 2 to 3 times a week at the Y.M.C.A. PMHx: Significant for surgical procedure of an ovarian cyst four years ago, a fracture of the (L) foot approximately one year ago. Patient identifies dizziness, headaches, nausea, difficulty swallowing and coughing secondary to cervical symptoms. Patient also reports inability for bowl movement/voiding following injury with a throbbing sensation (B) inner thighs when attempting to void. Medical Precautions/Contraindications: N/A Patient Name: Mi Choi 17 Atechnnirsbur¢ Center -510A R. Trindle Rnad - 01, it- 91V1 Pa 1 7n+n _ u A ,r. 717.7OA_01b" - o.r. 717 70n 0010 t? . DRAPER" Physical nerapy Institute Leading the May to Good Hearrh Plan of Care Patient Name: Mi Choi Date of Evaluation: 3/23/10 Date of Birth: 2/23/67 Sex: F Date of Onset: 3/19/10 Diagnosis: Neck Radiculopathy, Lumbar, Thoracic Radiculo th , L Shoulder Pain Surgical Procedure: N/A Referring Physician: Dr. Janet Kelly Date of Su : N/A Initial Certi rcation Period Effective Date: From: 3/23/10 Through: 4J21/10 ASSESSMENT: Therapy Diagnosis/Treatment Rationale/Impairments that Justify the Medical Necessity of Skilled Therapy Services: The patient comes to therapy with complaints of 9/10 pain at its worst in the neck, back, (B) UE/LE and head. She presents with decrease function with ambulatory and standing activities secondary to deficits in ROM, flexibility, strength as well as decreased overall postural awareness. Patient with symptoms consistent with neck radiculopathy and lumbar radicuiopathy. Patient presents with possible (L) shoulder injury, however, unable to thoroughly evaluate secondary to possible red flags of the cervical spine. Patient presents with symptoms consistent with whiplash following motor vehicle accident as well. Rehabilitation Potential: Good Long Term Objective Goals: (to be achieved in 6-8 weeks) I . Decrease pain to 0/ 10. 2. Therapist will follow up with MD, if needed, regarding patient's pain. 3. Increase cervical spine rotation ROM to 70° (B) and equally. 4. (1) with HEP. 5. Patient able to demonstrate good sitting posture > than 10 minutes w/o pain 6. Improve (B) shoulder flexion 188. Long Term Functional Goals: (to be achieved in 6-8 weeks) 1. Patient to return to work w/o difficulty with lifting > than 15 lbs. 2. Patient able to overhead reach w/o deviation or pain. 3. Patient able to stabilize with (L) UE while cutting food w/o pain. 4. Patient able to drive > 20 minutes w/o pain or difficulty. 5. Patient able to transfer in/out of car w/o pain or difficulty. 6. Patient able to sit -stand w/o pain or deviation. Treatment Plan: Functional activities, strengthening, neuro re-ed-, balance, posture, manual therapy, mobilization, ROM, flexibil HEP, spine stabilization, McKenzie Program, job skills, aquatic therapy, taping, traction, infrared, a-stim, vasopneumatic, hot pack cold pack, whirlpool, ultrasound. Treatment Frequency of: 3 times per week Treatment Duration of: 6-8 weeks flow disrr ad the ahore ftadiag, reared rrm .n0. awl ZYWC(al asate es with the pmimc NNStra is awrrrc of the rliagawiJ andP rmd and wramarily npoQ m rnntln pJnsipalloccvryaco. Therapist's Signature: t License: PT-020295 Date: 3/23/I0 Anne Capitn1nrnlno, DPT Crrrife W., ! 4'ehy 'nay that rdwbi$mrias urNice we seedicafy necm-yJor the above araaionod PW-9- !also raderarawd rim ary.dpmrtoe rijvifras a?r?aearbY auh tic 6itiaf Plaa q(Gw, iachdirr: ric estia uWfrepreacy oad drsrm m, as rarabrishad by the f=mssd th*,gW aid the koala! Poaa y(L-are saparara the iastnCfiaw orarhted orr thrp re *,p dmt ne "Ned'"abiraatian rarvkC- Physician's Comments: Physician's Signature: Tx: dmb Date: Patient Name: Mi Choi 19 Mechanicsbure Center 5108 E. Trindle Road + Suite 200 - Adnrhanirchnro P4 170,,n ? mrnvo -77JOn.Q09t1 ft --717 70Ao0on D R AY E R7 APR 2 9 toli' Physical Therapy Institute Leading ,he wag ro C,ood Health Re-Evaluation Patient Name: Mi Choi Date: 4/14/10 Date of Birth: 223/67 Sex: F Date of Evaluation: 3/23/10 Diagnosis: Neck Radiculopathy, Lumbar, Thoracic Radiculo ath ', L Shoulder Pain Date of Onset: 3/19/10 Referring Physician: Dr. Janet Kelly Total # of Visits: 12 # Cx: 0 # NS: 0 Sur ical Procedure: N/A Date of Sure : N/A Re-Cerfi rcation Period Effective Date: From: 421110 Throu h: 5/20/10 SUBJECTIVE STATUS/PROGRESS: Current Complaints/Functional Limitations: The patient has been attending Drayer Physical Therapy Institute for 12 visits following a MVA on 3/19/10. The patient reports improvements in symptoms as now able to Z/j stairs and wash hair. The patient continues to experience pain with activities; however, symptoms are less severe and/or onset of symptoms have improved. The patient notes (L) UE symptoms remain worst pain and is described as a -stuck" and "heavy" pain. The patient notes "pinch" pain t/o low back, (13) LE and neck. The patient can sit for 10 min before onset of symptoms. The patient able to don/doff clothes; however, symptoms occur. The patient has pain cutting food and walking after 10 min. The patient still unable to walk through entire grocery store secondary to pain. The patient remains out of work secondary to symptoms. Exacerbating/Complicating Factors and/or Comorbidities Impacting the Rate of Recovery: Language barrier Pain Rating: Worst: 7/10 Current: 6/10 Best: 5/10 Previous: Worst 9110, current 8/10, best 6/10 I OBJECTIVE AND FUNCTIONAL STATUS/PROGRESS: Objective Prior Current j Goal Measurement/Functional Measurements Measurements M Limitations/Special Tests ROM: C-s ine Rotation 50° (B) in (R) 47° L 50° 70° (B) equal C-spine Flexion/Extension WNL flexion 40°; ERP (R) shoulder/UT; extension 26°, ERP (R) shoulder/UT Shoulder Flexion NT (L) 140° ERP 180° (R) 145° ERP ( L-s ine extension compensation L-s ine Extension 15" 15° > 20° w/o pain L-s ine Flexion 40° 70"; (R) (L calf symptoms LBP 700 w/o pain Side Bending (L) painful, (B) lateral joint line ER contralateral minimal loss, (R) side/DL pain & WNL Rotation (L) pain min loss; WNL (8) WNL (B) R inful WNL ASSESSMENT OF STATUS/PROGRESS: Rationale for Need to Continue Skilled Therapy Services Including Goals Not Met and Why: The patient presents with gains in ROM, function and strength. She presents with I severity of pain and is able to execute a greater amount of functional tasks. The patient continues to present with disability to perform home management tasks and work roles, as she is unable to grocery shop, cook for her children, vacuum her house, or perform laundry duties as required for her job. She is not appropriate for discharge to HEP at this time secondary to need for skilled intervention remains. Patient Name: Mi Choi M....1.........,.1.......!'.._ __ c,no C T- _Jl,. D__A - C...,_ non - ?R..-t.-...__a,.. n.? ,nncn - .......... n,T - noon - -- - non noon Rehabilitation Prognosis[Potential: Good Updated Objective Short Term Goals (to be achieved in 4 weeks): 1. Decrease pain to 0/10. 2. Therapist will follow up with MD, if needed, regarding patient's pain. 3. Increase cervical spine rotation ROM to 700 (B) and equally. C (1) with HEP. 5. Patient able to demonstrate good sitting posture > than 10 minutes w/o pain. 6. Improve (B) shoulder flexion ISO*. Updated Functional Goals to be Achieved by Next Progress Report (to be achieved in 4 weeks): I . Patient to return to work w/o difficulty with tilting > than 15 lbs. 2. Patient able to overhead reach w/o deviation or pain. 3. Patient able to stabilize with (L) UE while cutting food w!o pain. 4. Patient able to drive > 20 minutes w/o pain or difficulty. 5. Patient able to transfer in/out of car w/o pain or difficulty. 6 Patient able to sit -stand w/o pain or deviation. Treatment Plan: Functional activities, strengthening, neuro re-ed, balance/coordination, posture, manual therapy, mobilization, flexibility, HEP, McKenzie program, job skills, gait, aquatic therapy, McConnell taping, infrared, a-stim, and hot/cold pack. Treatment Frequency or: 3 tithes per week Treatment Duration of: 4 weeks the Therapist's Signature: aaeroma airh rhr pndcw. H*Ww is aurae of rbe d&rgnasis and pr u and wlwrrnrtly ag?sv ro mniinar phvsiocrf/oaaperhrm+! rhernry sar+irer. lk A-I1 License: PT-020295 Date: 4114/10 Anne Capitumthino, DF F Ra-Ccref extian: t hady cvrify aSro rdrddtawiaur:m3ro mr a.ed ext?y neasary jar dre aJ+v a menrrawcd pwrent. t alto w d&mRd dw+ry sina"c rr ie a;Tmnret xvli tke Updatm! Plnr ne of ars aoe/tding rba estirrmra! fmjrwrcr and dw,aiaa, ru eraW+sAa! ty thr ficeasad rLeratrire ! radersrand r6ir Pfaer q/Cnn .'ru.'aa+er e?feerive en the dare weed and .axaeas aJ -6-fa. dre drvarian of aewr,ew aul di Cnthe plan of Care Physician's Comments: Physician's Signature: Tx: paa P(arae Rd- drv Prager Rgran ar Dreyer Phyneaf Tki py Date: Patient Flame: Mi Choi 21 DRAYEI2 Physical Therapy Institute Leading the Way to Good Health Patient Name:'// Date of Birth: -I - 3 - ?,"'1 Sex: ? Mate s-Female Diagnosis: L/R/B A/tz=rC !i{?1 c 7(?sJzY ?v_t-r Referring Physician: eL-t Re-Cert Period Effective Date: W40 4, Through: l Current Complaints PY! f hi>;-' r L - :SUBJECTIVE STA' Rating: Worst: (0120 Current:5/10 Best:,_j/10 comments: since Staring Therapy. Perceived Functional impairments to Factors and/or Comorbidities Impacting the Rate of ?-OBJECTIVE: PLEASE SEE'ATTACHED OBJECTIVE & FUNCTIONAL STATUSJPROGRESS/GOALS WORKSHEETS ASSESSMENTO_t:STATUS%PROGRESS• Impairments that Jzfv the Need for SkilledJfierapv Services: Pain ecreased ROM }creased Function reared Postural Awareness ecreased Strength o Swelling ? Gait Dysfunction NcreasedJoint mobility/Flexibility o Balance Dysfunction/Fali Risk E3 Other: Rai' le for Why Goals Not Met and Justification for the Need to Continue with Skilled Thera : oefeverity of Dysfunction E3 Insufficient Treatment Time o Poor Tolerance o Unable to progress o Treatment Interrupted b/c of illness o Chronicity of Dysfunction o Limited # of visits due to o Other: Rationale for Why Patient Cannot Safely or Appropriately Be Discharged to HEPai'This Time: o Sa ty(home environment o MD/Protocol Need for skilled intervention of progression of therapeutic exercise t?ed for skilled manual therapy treatment o Poor retention o Other. Comments: PLAN- r nctional Activities eiveuromuscular Reeducation b-Manual Therapy o Spine Stabilization o Hand Therapy o drSfrengthening deait/Assistive Device Training &Mobilization 64 ttKenzie Program o Wound Care o o A/AA/PROM o Orthotic Fitting/Training &Mb SkUls o Bracing/Splints 11 plexi ility o to-Wance/Coordination - %Aome Exercise Program o Aquatic Therapy camping g.Posture ? ctrical Stimulation drde o Ultrasound/Phonophoresis o Vasopneumatic old Packs b infrared 0 o Paraffin o WNripool/Auidotherapy o lontophoresis o Traction O ? o Further Objective/ Functional Testing as appropriate per MD protocol and/or therapist discretion Comments: Treatment Frequency of: ? times per week Treatment Duration of., weeks t how dheaswd the abow fintrnps snm M oft% and eweeredamtu with the ppt#nt fft/SW U anmre of the dbpreash and progmsft ono vGWnftX* apron m m+rmae P=Zt00tlan In We lerdces Signature of Therapist: License #_ 02?qf) Date:_ q Printed Therapist Name; rte-COMPMOoa: tim or arch uor?rrehtat.oisn,ervtou mr.rerC0r XVWSWWdarme eeow meaty wtpodam r aso wwwm"d am my srpnot«e dynyks apaareet w+u of uoamm Mon./a&%reerrd v at r ammwe h+we.q or drrodwti as ntohL4rd rN tnrlensrd thrmyix rwnkn seed came Ws prat nJ tar hxomsr ePtta. a der dote sohad and wm.rs effeRlwt ?br ter damtlw of treatewra ewder6 re tM pier aft. Physician's Comments: Physician's Signature: Date: Date: Date of Eval: ?j--?-3 -f MAY 2 0 2010 RE-EVALUATION Date of Onset: Date of Surgery: Surgical Procedure, Total # Visits: R:4 A Cx: It NS: 0 22 Aiechaniesburg Center 5108 E Trindle Rd 0 Suite 200 • Mechanicsburg, PA 17050 9 PHONE: 717-790.9420 • FAX: 717-790-4923 MAY 2 0 2010 Aft D RAYS K Physical Therapy Institute Leading the way to Goa! Hratth RE-EVALUATION - OBJECTIVE STATUS AND GOALS - 511.q 11b Patient Name: I Date of Birth: 3 Date: Involved Body Part: fr ?. o L eft o Right ilateral OBJECTIVE STATUS/PROGRESS/GOALS Objective Measurements Prior Current Goals Goal Met Time Frame Special Tests Measurements Measurements Y? M1b Weeta o prior PAIN: £ a) £f F t G o new - O prior o new prior r? u li S o V (J tlew " ?t S L -10 rior ` tl rJ f l1 Q rJew o 0 C c fl P" r[or e, O .7 o new o prior t7 new o prior o new o prior O new o prior o new o prior o new o prior o new o prior o new o prior o new o prior o new o prior o new o prior o txw o prior O new o prior o new o prior o new O prior O new o prior o new o prior o new o prior O new O prior i I o new n - Therapist's Signature: License #: Date: 23 Printed Name of Therapist: ( 4 Aft D RAYS R MOW Therapy Institute Leading the Way to Good Health MAY 2 0 2410 RE-EVALUATION - FUNCTIONAL STATUS AND GOALS Patient Name: m -l Cho', Date of Birth: - Date: j .912 Involved Body Part: c Y ! ' J (. 1. b 1Y ? left o Right Wbilateral FUNCTIONAL STATUS/PROGRESS/GOALS Functional Limitations Prior Current Goals Goal Met Time Frame (List Specific Activities from Functional Outcome Tool) Measurements Measurements Yes No Weela Functional Outcome Tool: Ujl {L :F0 LL -?ht.?1 o prior 41r{i ?Gl• 7 A new o Optional Score: a/tri o prior F-u nuil on ': o new -11 prior 0 H I eah ° Cl new 56 o Ft- bit to ?i? is ??r p06 -hem Ii?f L, k W II . i, CU ?r dl tut ?r[[t?+?' Cll lzt?iV'?10Y1 5 prior -?1 (?t1ft4 ? new pp^^ lilt A-b! Z o prior o new ? prior O new o prior a new o prior ? new ? prior o new o prior O new a prior O new ? prior ? new O prior O new Therapists Signature; Printed Name of Therapist: License # Date., f2' I Ateehanicsburg Center 5108 E Trindle Rd • Suite 200 • Mechanicsburg, PA 17050 • PHONE: 717-790-9920 • FAX: 717-790-9923 24 1 . I.D. # 75-3050291 r FED q DRAYER PHYSICAL THERAPY INSTI TUT E 9 EvAu don Time Basal. Modallities • Direct Contact Required CPT UNITS S9 Description CPT i UMIS S9 DescripIllm CPT uNrrs pn TENS loon 64550 dtial Evaluation-PT 97001 Ultrasound (ea. 15 min) 97035 97760 e•evatua6on-PT 970021 lonlophoresis (ea. 15 nrn) 97033 Orthatic Mgft Training (ea.15 min) i OT 97003 E-Stim Attended (ea. 15 min) 97032 OrMc Checkout (ea. 15 rrdn) 97762 " Evaluation- 1 15 min) (ea tt k Trainin P 97761 ud ProeedurestMo??tk B a Dim Co mm Mot lt?md . g ros e-ewaheation-0T hysical Pertcxmance Twill m 1970041 97750 s old Pack 97010 { { Electrodes (per pair) li t S A4556 ! .C.E. Functional D6a548. 15 min} Mechanical Tra 97012 ( 4 n p Splint Tmie Sued p - Djnwt Condlat E-Stim Un d 9701 wapeuac Adviees (ea_ 15 min) 91, Vasopnevmatic 97016 Supplies: wwm& Prom (ea. 15 min) 91110 t raffai so {97018 id { Me T dicare Non-Med ca oilFluidoltmapy Whi l 97022 i rae euromusmiar Read (ea. 15 min) 97112 r po { / f anal Therapy (ea. 15 min) 97140 Mbared 97026 Time In ail Training (ea. 15 min) 97116 Group Therapy 97150 i 90901 Tim Out Total Treatmerd Time assage (ea. 15 min) 197124 1 Biofeedback Mound Care Total Service Based Time auatic Therapy (ea. 15 min) t 97113 ' 97535 + Wound-Se*c ive S 20SQ. CAA 97597 Total Torre Based Time fi elf Careliiome Managemen ommu114YA Nak Reintegration 97537 1 1 1 Wound-Selective > 20SQ. CAA 97598 Total Trine Based Units ogrii0ve SkBstTraining 97532 ; Wourrd-Non Selective 9760E Total Unitts SB + TB t• ? t• RIS Date I 1C f A t 1 - 1-A U U Cx NS CA gI ?ICttLIIIS [4$"i G. N j 723.4 Reason: ubjective: Patients perceived changes/progress toward functional Mient's chief complaint: tuner bjective: Ptease refer to this patient's flow sheet for details specific to the eatment Droaression: ther (Function, Special Tests, Sensation): ssessment: Patient's progress towards functional STG/LTG: they. an: Progress/modify current treatment plan -Achieve by next visit t week Other: Total ff visits ierapst $igna?ur - - - - and specific exercises utifized during today's Brief Re evaMrogress Report next visit D/C patient License # 3UARANTOR NAME AND ADDRESS PATIENT NO. PATIENT NAME DOCTOR NO. 6/11? 1 CHOI, NI 1 38140895 CHOI Ni [ 37 100 5 Cll[MM RM 'IF INSURANCE DATE OF TELEPHONE BIRTH NO. CODE DESCRIPTION CERTIRCATE NO. NBCHANICSBQ&G, PA 17150 91cket0 140250316 2/23/67 717 746 8102 !11 Auld) LxavIANCS Na MIT P4ypa0 48 ??, 25 #4DRAVEK• I'h WA TWW Iaititule Lmalsde ayK.o "Mm DISCHARGE SUMMARY-- OBJECTIVE/FUNCTIONAL STATUS AND GOALS ww n Patient Name Date of Birth: Z?Date: U ji 011 Q_ !L ? Cx: 3 25 1011 Total Visits: _ __ -- - - Date of Discharge: Csoat Met Objective Messuser nis FunctimW Limitations Initial M urements 3 Current Measurements Long Term Goals special Tern Date: Yes No LJ 5 ?- ? ? s L ?o0 0 20 L45 5D -7 0 L? .l rV 1 0, -7 v co k? a a" N 0 ° 90 a ld 1 un to .04 &MO ? ap >k a i:? ? m ?d 1 211 tn' 41 V"_0 n ? ??? Olr G (•10'1 ?aCi?-? j? 1 eoth ria P+ t r S?pb ik t-tk4- M- s Tty - ?- t li'u r All met •_ Partially Met_ % Met Not Met Long Term Treatment Other: Explanation of why goals not met (if needed): Goals Were- Please list all of the medications (with specific dosages) that the pt has been taking (including Over- The-Counter, prescriptions, herbals, and vitamins/minerals:) o Same as initial Evaluation For Medicare Patients ? Changes since Initial Evaluation: Only- Patient Signature: Date: Patient returned to premorbid functional status Patient achieved maximal benefit from therapy Treatment was discontinued by the physician Discharge Rationale: Patient choice to discontinue therapy _ MD contacted Patient noncompliance _ MD contacted Other: HEP• Discharge tnstrun:tions: - - - --- - - Participation In Wellness program - -Follow-up wittrPT/OT if-questitsns artse-or-patient-experiences Increased/unexpected symptoms: Other: pg?aQS Date- L4 v TheranlWs Si>nature• __ License N. Printed Name of Therapist. p fiA YYL l? i t') Q Mechaoiesburg Center 5108 f=ast Trindle Road • Suite 200 • Mmhani *w& PA 17050 • PHONE: 717-790-99?tt • FAX: 717-790-9923 26 ORTHOPAEDIC SURGEONS OF CENTRAL, PA, LTD. CHOI „MI K 5 CARDAMON DRIVE MECHANICSBURG,PA 17050 ACCOUNT # 122513 CHART # 024314 SS # 209720959 April 29, 2010 LEMOYNE OFFICE r} CONSULTATION: Janet Kelly, CRNP (DIN EMiAL MEDICAL RECORD For PrOf"Sional Usc Only DOB : 2 / 2 3 / 6 7 3?._ L p'?7? QsTv Propcrty of Orthopaedic Surgcons of Central Pennsylvania, LTD. CHIEF COMPLAINT: "My neck and shoulder hurt". HISTORY OF PRESENT ILLNESS: Mi Choi is a 43 year old right hand dominant female, who reports being involved in a motor vehicle accident on 3/19/10. She was the driver wearing a lap belt and shoulder strap. The area of impact was the rear of her automobile. Initially, she did not think she had any significant injuries, but within one hour started developing significant pain down her neck, difficulty swallowing, had a headache. She was taken to Holy Spirit Hospital where she reportedly had a CT scan of her head and x-rays of her neck. She brings the x-rays of her neck along for my review. She was treated with hydrocodone, Prenand and Diazepam. She - followed up with her family physician Physical Therapy. She has had fourteen sessions of therapy and notes she is seeing an improvement in her symptoms, but not resolution. She is now referred to our office in consultation for evaluation and treatment recommendations. On presentation today, the patient is complaining of pain in her neck radiating into her periscapular area, bilaterally upper extremities to a greater degree on the left side. She describes herself as having pain quadrilaterally, having dysesthesias quadrilaterally to a greater degree in the left arm. She is currently taking Darvocet in addition to the Diazepam prescribed by her family physician. She is also complaining of other polyarthralgias, low back pain for which she is not her for these to be evaluated. She denies any previous history of neck injuries, neck pain or shoulder upper extremity injuries or pain. PAST MEDICAL HISTORY: I reviewed with the patient her past medical history. She has had no recent hospitalizations. Medical illnesses: Patient is having back pain, chronic headaches and neck pain from the automobile accident. She denies any previous history of that. Medications: Prednisone, Hydrocodone, Diazepam and Darvocet. - CONTINUED - REPEOMD_ MAY 17 2M CONCORDVILLE ctos 27 r ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. CHOI „MI K 5 CARDAMON DRIVE MECHANICSBURG,PA .17050 ACCOUNT # 122513 CHART # 024314 SS # 209720959 04/29/2010 LEMOYM AL MED'^kL RECORD Page 2 For Professional i}se Only C(Ofpy Properly of: Orthopaedic Surgeons of Central PcnnsylvAnia. LTD. Allergies: NKDA. Social history: She is a right hand dominant individual, denies any tobacco use, ethanol consumption. Family history: Negative for diabetes, hypertension, cancer, heart disease. PHYSICAL EXAMINATION: Physical examination today demonstrates height to be 5 feet 3 inches, weight 112 pounds, blood pressure 127/79, pulse 62. Patient is awake, alert, oriented x 3. She is in no acute distress. Examination of the cervical spine demonstrates diffuse tenderness-over the paracervical muscles, periscapular muscles. Negative impingement testing, negative Hawkins test. She has good range of motion of her shoulders. Subjectively she has circumferential decreased sensory acuity in the left upper extremity. There is no focal motor deficits. Reflexes are symmetrical. Negative Hoffmann's reflex. She has no clonus in the lower extremities and negative Babinski reflex. She appears to have symmetrical soft tissue pain in her cervical, thoracic and lumbar spine. Her shoulders have no glenohumeral instability, no mechanical symptoms and no focal motor deficits on manual muscle testing. DIAGNOSTIC STUDIES: X-rays of her cervical spine from Holy Spirit was reviewed. There is no evidence of any acute fracture or bony destruction. There is some mild degenerative change at the C5-6 with narrowing of the disc space. No abnormal soft tissue swelling. DIAGNOSIS: Pain referred to intrascapular area, upper extremity status post motor vehicle accident 3/19/10, possibly myofascial etiology versus cervical spine occult injury. PLAN: I advised the patient, as well as her husband my clinical impressions. I suspect she has a myofascial injury, but would recommend an MRI scan of her cervical spine to make sure there is no cord injury or other significant structural abnormalities that may benefit from orthopaedic intervention. If this is negative, I believe she would be best managed by a physical medicine pain management physician and we will refer her to the - CONTINUED - 28 f 1 r t ' ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. CHOI „MI K 5 CARDAMON DRIVE MECHANICSBURG,PA 17050 04/29/2010 LEMOYNE OFFICE Page 3 ACCOUNT # 122513 CHART # 024314 SS # 209720959 D same if there is no pathology identified that would benefit from orthopedic surgical intervention. We will keep her off work and she is to follow up after the MRI scan. CONFIDENTIAL MEUNCAI, RECORD Completed by Craig W. Fultz, M.D. For Professional Use Only Property of: Orthopaedic Surgeons CWF/baf of Central Pennsylvania. LTD. DD: 04/29/10 DT: 05/05/10 Next appointment: 5/27/10 Craig W. Fultz, M.D. TK-fax sent to Janet Kelly, CRNP 29 Diagnosic Report - Sunrise RIS Page 1 of 2, FIVARAMIC MAGNETIC IMAGING CENTER Wba" 1"jW isear7fbftW Patient: Choi, Mi K MRN: 14012 DOB: 23 Feb 1967 Date of Exam: 10 May 2010 FINAL Diagnostic Imaging Report Accession Stud Clinical History 20268 ___ [M-RI CERVICAL SPINE W/O CONTRAST left shoulder in Report Exam: MRL Cervical Spine: Indication: Neck pain. Numbness - arms. Technique: 1.5 Tesla Sag T2, TI / Ax MERGE, COSMIC Findings: 1.? 3 MAY 17 2010 CONC01M LLE cm Mild reversal of the upper cervical lordosis which could be secondary to patient positioning or muscle spasm. The vertebral bodies maintain their height. Discogenic endplate changes at C5-C6. Axial images were obtained from C2 through T1. C2-C3: Normal. C3-C4: Central disc protrusion indenting the ventral thecal sac and flattening the spinal cord. Protruded disc touches the spinal cord without compression (series 8, image 29). The central spinal canal and the neural foramina are normal. C4-C5: Normal. C5-C6: A broad-based central disc bulge indenting the ventral thecal sac. Slight flattening of the spinal cord without compression. The central spinal canal and the neural foramina are normal. C6-C7 and C7-T1: Normal. 30 https:// 10.150.7.102/viewDxReport.do?examld=20268&noContainer--1 5/13/2010 Ref. Dr.: Craig W. Fultz MD Diagnosic Report - Sunrise RIS The visualized posterior fossa is normal. The cervical spinal cord maintains normal signal throughout. Conclusion: 1. A disc protrusion at C3-C4 which touches the spinal cord without compression. 2. A broad-based central disc C5-C6. 3. Slight flattening of the cervical spinal cord at C3-C4 and C5-C6. Normal cord signal throughout. 4. The neural foramina are normal. Reported by Khan Kapadia on 11 May 2010 at 07:52 a.m Electronically signed by Kiran Kapadia on at 07:52 a.m https:// 10.150.7.102/viewDxReport.do?examid=20268&noContainer= l 5/ 13/20 ?6 77y AUN ORTHOPAEDIC SURGEONS OF CENTRAL PA, G0CTO?rr??yl1?-- I,MI K 5 CARDAMON DRIVE MECHANICSBURG,PA 17050 May 27, 2010 LEMOYNE OFFICE DOB: 2/23/67 LTD. ACCOUNT # 1:2 2 513 CHART # 0243,14 e(?j1jENP SS # 2097:20959 (?+ r r PtaF or Profess • AA/ a ? pert Of 0 CHIEF COMPLAINT: "My neck and arm still hurt." HISTORY OF PRESENT ILLNESS: Mrs. Choi is a 43 year old right hand dominant female who was seen in our office on 4/29/10 for neck and shoulder pain status post motor vehicle accident on 3/19/10. It is unclear as to the etiology of her symptoms. There were physical findings supportive of myofascial pain versus cervical spine occult injury. We recommended an MRI scan and she is here today for follow up evaluation after having the MRI scan completed. The patient notes she is still having ongoing symptoms. She is complaining of pain in her neck radiating into the periscapular area and bilateral upper extremities, to a greater degree on the left side. She describes herself as having quadrilateral dysesthesias, to a greater degree on the left side. She is currently taking Darvocet in addition to Diazepan which was prescribed by her family physician. PAST MEDICAL HISTORY: I reviewed with the patient her past medical history as well as her review of systems. These are unchanged from her last exam and are outlined and updated on her PMH sheet today. PHYSICAL EXAMINATION: Her physical examination today demonstrates her to be awake, alert and oriented to person, place and time. She does not appear to be in any acute distress. Examination of her cervical spine demonstrates diffuse tenderness about her paracervical muscles and periscapular muscles. She has negative impingement test, negative Hawkins test. She has good range of motion of her shoulder. Subjectively she has decreased sensory acuity in her upper extremities circumferentially on the left side. She has no focal motor deficits. She has negative Hoffmann's reflex, negative Babinskis in her lower extremities. DIAGNOSTIC STUDIES: I reviewed the MRI scan of her cervical spine dated 5/10/10. It shows a central disc prominence at C3-4 and C576. It impinges against the thecal sac. There is no abnormal spinal cord signal. She has IN disc-desiccation at those 32 ORTHOPAEDIC SURGEONS OF CENTRAL PA, CHOI,MI K 5 CARDAMON DRIVE MECHANICSBURG,PA 17050 05/27/2010 LEMOYNE OFFICE Page 2 LTD. COUNT # 122513 RT # 024314 Ate r pr_ur- sSr4 209720959 `? .t Of 'Qf sfot?if I P f'' ,. opSy;? if 'etrr n,Y te'a'. levels as well. She has discogenic endplate changes at C5-6- to There is no evidence of any acute fractures. Foramina appear be intact. DIAGNOSIS: 1. Pain referred to intrascapular area, upper extremity status post motor vehicle accident 3/19/10, possibly myofascial etiology versus cervical spine occult injury. 2. Degenerative disc disease with disc protrusion C3-4 and C5-6 of unclear significance. PLAN: I reviewed with the patient my clinical impressions. It is unclear to me as to the clinical significant of the disc findings on her MRI scan. Given her nondiscrete radicular pattern of symptoms, I have recommended EMG and nerve conduction studies to try to better define the potential source of her symptoms. I have recommended an epidural steroid injection at C5-6 following the EMG studies to see if this gives her improvement. If there is no evidence of any radiculopathy on her EMG studies we may want to consider referral to a pain management physician. The patient states she understands and agrees with the treatment plan. Completed by Craig W. Fultz, M.D. CWF/rjg DD: 05/27/10 DT: 06/11/10 TK-FAX sent to Janet Kelly, CRNP ?3C PENN REHABILITATION ASSOCIATES, P. ED S. VIOLAGO, M.D., FAAPMR MACIEJ T. CHARCZUK, M.D., FAAPMR //adndsfng Function • ReaWng QuaOly of Lffe ELECTRONEUROPHYSIOLOGIC MEDICAL CONSULTATION INTERPRETATION: 1. Needle EMG of the left upper extremity and neck from C5-T1 rnyotomal distribution is silence at rest, normal motor units, and complete interference pattern during maximum effort. 2. Left Median distal motor and sensory peak latencies and motor conduction velocity are normal. 3. Left Ulnar distal motor and sensory peak latencies and motor conduction velocity are normal. CONCLUSION: Electrodiagnostic studies of the left upper extremity, shoulder, a neck l Syndromes or evidence ce of'cervical radiculopathy or acute entrapment neuropathy such as Carps nn Syndrome. This is a normal electrodiagnostic study of the left upper extremity from C5-T 1. Thank you for the referral of your patient. If you have any further questions, please feel free to call me at the office. ame ft JIN 2 8 2M s.oNC reesstwwaass D. ., med medic ally necessary by the referring physician- CMS Tei.: (717) 5414700 • F=(717)541-6100 1 "am= C ou?offu tlnwrraowa CASAatOf= 2M iatws+aft 19000 Dula Nuffma"= X LRna Roan e NWPW0"W FX0N0QW0&WA r * ft Nu Cr. M Fe.. Marx 1rW0W MK q u TstT=" a • Ih.11Q PR 1T? o . 9m m CMS, FA am 0 a Rr. W NaMr - Fri IM4 7toSINOW how v 1W=%WM , 34 NAmonoR PA 171 NK0016 FQ t11Rt XVM BRIEF HISTORY: and neck This is a 43-year-old Korean female (does not speak English) who is complaining of dysphagta pain that radiates to the left upper extremity with numbness of the hands at times. Past medical history: Noncontributory. FAMILY CARE MECHANICSBURG 910 CENTURY DRIVE MECHANICSBURG, PA 17055 Phone: (717)506-4720 Fax: (717)506-4734 06/29/2010 5:48 PM 4'*> PINNACLEHFALTH ? ? ?Jw 1) ?U8,9 ale PATIENT: DATE OF BIRTH: DATE: VISIT TYPE: MI K CHOI 02/23/1967 06/29/2010 4:15 PM Office Visit ?A9 t(o Reasonts) for visit 1. sore throat Onset: 2 day(s) ago. it occurs acutely. Context: exposure to strep. There are no relieving factors. Associated symptoms include aching joints, fever, halitosis, headache, not eating and swollen glands. Additional information: seen at HSH ED last night for sore throat; called this AM with Rx for strep; penVK; culture came back positive strep 2. neck pain Onset: 3 Month(s) ago. The problem is severe. The problem has not changed. The frequency of pain is constant. Location of pain is bilateral anterior neck and bilateral posterior neck. The event(s) surrounding the occurrence of the symptom include injury and motor vehicle accident. Aggravating factors include exertion, flexion, hyperextension and sitting. Denies relieving factors. Additional information: ongoing neck pain ever since MVA in March; planned steroid injections. Past Medical History Reviewed, no changes. Family History Reviewed, no changes. Soul History Reviewed, no changes. Active Medications (started before visit) Drug Name Dose QtY Propoxyphene Nap-acetaminophen 100-650 Mg 30 hours as needed for pain The patient is a non-smoker. Review of Systems HEENT: Positive for: - Dysphagia. - Pharyngitis. Respiratory: Negative for cough. Description take 1 tablet by ORAL route every 4 - 6 NeurolPsychiatric: Negative for headache- CHOI, MI K 02/23/1967 7/7 35 Mysculoskeletal: Positive for: - Neck stiffness. Comments: seen by orthopedics; planned steroid injections. requests EGD because of prolonged sore throat and esophagus. Vital Signs BP Temo F 110/68 102.5 Comments Pulse Resp Rate Ht In Wt Lb BMt Calc Pin core 102 16 63.5 118.0 20.57 Physical exam Constitutional: Level of distress is moderate distress, due to pain, lethargic. Nourishment type is thin. Overall appearance is ill appearing. Nose / Mouth / Throat: Breath Odor is foul. Tonsils: enlarged 1+. Oropharynx: erythema and mucopurulent exudate. Neck 1 Thyroid: Range of motion isthas decreased. Positive for cervical adenopathy; see Lymphatic for details. Clinical Assessment The patient is a 43-year old female who presents with sore throat and neck pain. Assessment/ Plan Pharyngitis (462) take meds prescribed at HSH Neck pain (723.1) Acute gastritis (535.0) will order EGD Streptococcal pharyngitis (034.0) (Anemia 285.9) take iron; otc; will recheck cbc in 3 months; also do EGD Medications tactive or stopped this visit): Drug Name Dose Q_yt Description Stop Date Propoxyphene Nap-acetaminophen 100-650 Mg 30 take 1 tablet by ORAL route every 4 - 6 hours as needed for pain To be scheduled/ordered Status Order completed Office visit Referrals Status Physician ordered Refer to Gastroenterology Patient Plan: Instructions Signs of emergency Reason Assessment Timeframe Appointment Comments 462 Timeframe Appointrnent Diagnosis 723.1 Reason 36 CHOI, MI K 02/23/1967 7/7 Symptom management Refer to Gastroenterology Alternative treatments Medication side effects Saline gargles Continue current medication OTC medication Reviewed medications Take new medication as prescribed Followup Needed: Reason/ Comment Diagnosis 462 Office visit 723.1 535.0 462 462 462 462 462 462 462 Description Timeframe if symptoms persist / worsen X11 . - 4454 V?eol&?006' Provider: JANET KELLY CRNP Document generated by: Janet Kelly 0612912010 5:48 PM Evaluate and Treat CHOI, MI K 02/23/1967 7/7 37 HEaMSOUM, SPECIAL PROCEDURES CLINIC Malik N. Momin, MD - Medical Director INITIAL PAIN MANAGEMENT EVALUATION NAME: CHOI, MI PATIENT#: 743863 DOB: 02/2311967 DOS: 07/26/2010 REFERRING PHYSICIAN: Craig Fultz, MD DIAGNOSES: 1. Chronic neck pain. 2. Left upper extremity radiculopathy. 3. Broad base disc bulge at C5-6. HISTORY OF PRESENT ILLNESS: Patient is a 43-year-old female who was involved in a motor vehicle accident on 03/19/10. Apparently, her car was rear ended. Since then, she has had persistent pain involving her neck radiating pain in to her shoulders more towards the left than on the right and occasionally pain radiating in to her hand. She has tried some physical therapy and anti-inflammatory drugs without success. She had an MRI done of the cervical spine on 05/10/10 and that study showed a broad base central disc bulge involving the ventral theca) sac at C5-6, a central disc protrusion also was seen at the C3-4 level. She was seen by Dr. Fultz for an Orthopedic evaluation recently and he felt that a diagnostic therapeutic epidural steroid injection at C5-6 level to treat a possible C5-6 radiculopathy in the left side would be useful. PAST MEDICAL HISTORY: Significant for chronic headaches. She has a history of chronic neck pain as described. PAST SURGICAL. HISTORY: She had an ovarian cyst resection six years ago. CURRENT MEDICATIONS: She takes hydrocodone as needed for pain- ALLERGIES: NO KNOWN DRUG ALLERGIES. FAMILYISOCIAL HISTORY: Patient is married. She lives with her children. She works at a dry cleaner on a part-time basis. REVIEW OF SYSTEMS: Denies any history of fevers or chills, shortness of breath, chest pain, nausea or vomiting, abdominal pain, no history of incontinence of bowel and bladder, easy bruising or bleeding disorders. PHYSICAL EXAMINATION: GENERAL: She is alert and oriented in no acute distress. Paae 1 175 Lancaster Blvd., Mechanicsburg, PA 17055 Phone (717) 691-3731 Fax (717) 691-3858 38 NAME: CHOI, MI DOB: 02/23/1967 DOS: 07/26/2010 PATIENT#: 743863 VITAL SIGNS: Blood pressure 138/80, heart rate is 70, respirations 16, and weight is 115 pounds. HEENT: Normal. LUNGS: Clear. HEART: Regular rate and rhythm. ABDOMEN: Soft. EXTREMITIES: She had some tenderness in cervical muscles more towards the left than on the right. Deep tendon reflexes were diminished in the knees and the ankles and straight leg raising was negative bilaterally. PLAN: After evaluating her and explaining to her the procedure for fluoroscopy guided cervical posterior injection to treat her possible C5-6 radiculopathy on the left side, we agreed to proceed. I explained to her that the injection can be repeated again after two weeks if needed and she will give us a call in one week. She will also followup with Dr. Fultz otherwise as scheduled. Malik Mornin, MD MM/am2408 DD: 07126/2010 05:37 PM DT: 0712712010 3:00 PM JobiD: 2727251 cc: Craig Fultz, MD o?nc '-I 175 Lancaster Blvd., Mechanicsburg, PA 17055 Phone (717) 691-3731 Fax (717) 691-3155U 39 HEAL TH® Rehabilitation of Mechanicsburg 175 Lancaster Blvd., Mechanicsburg, PA 17455 PROGRESS & PROCEDURE NOTE NAME: CHOI, MI PATIENT* 743863 DOB: 02/23/1967 DOS: 07/212010 8P41 -9 REFERRING PHYSICIAN: Craig Fultz, MD PROGRESS: Patient is a 43-year-old female with pain involving her neck radiating pain in to her left arm to have a cervical posterior injection. She has a protruding disc at C5-6. i EXAMINATION: As per initial evaluation sheet. PROCEDURE: The patient family member has been informed of the risks and benefits of the planned procedure. Cervical posterior injection. after obtaining informed consent, the patient was taken to the fluoroscopy room and of s placed in the prone position. The patient was identified by armband. TLed sitteine 1 r ice was identified and confirmed with the patient. Sterile prep and drape. % was injected into the skin and deeper tissues. Using a translaminar approach at C5-6 towards the left side, a 20-gauge, 3-112-'inch needle was guided under fluoroscopy.and using loss of resistance technique into the epidural space. After confirming placement in AP and lateral views and negative aspiration for cerebrospinal fluid or blood, 10 mL of normal saline, and 80 mg of Depo-Medrol was injected. The patient tolerated the procedure well. COMPLICATIONS: None. FOLLOW UP: Patient was asked to give us a call in one week with the results and possibly schedule repeat injection if needed. She will also followup with Dr. Fultz as scheduled. Malik Momin, MD REC MW MM/am2408 DD: 07/2612010 05:37 PM DT: 07/27/2010 3:03 PM JoblD: 2730279 cc: Craig Fultz, MD AUG 0 9 2010 CONCOPANLLE 003 Page 1 40 ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. CHOI,MI K ACCOUNT # 122513 5 CARDAMON DRIVE CHART # 024314 MECHANICSBURG,PA 17050 SS # 209720959 August 23, 2010 LEMOYNE OFFICE DOB: 2/23/67 HISTORY OF PRESENT ILLNESS: Ms. Choi is a 43 year old female who comes to the office this date to follow up on her neck. She initially was seen for neck and arm pain on 4/29/10 after she was involved in a motor vehicle accident. She was a driver wearing a lap belt and shoulder strap. The impact was at the rear of her automobile. Within an hour of the accident she started developing significant pain to her neck. She had difficulty swallowing and had a headache. She was seen at Holy Spirit Hospital where she had a CT scan of her head, x-rays of her neck and was placed on a course of Hydrocodone, Prednisone and Diazepam. She was seen by her family physician and was sent for a course of physical therapy through Drayer. She had seen significant improvement with her therapy but no frank resolution of her symptoms. Upon being evaluated in our office she was sent for an MRI scan. The MRI scan showed a central disc prominence at C3-4, C5-6 and she was recommended EMG's and nerve conduction studies and an ESI at C5-6. She comes in now for follow up evaluation stating that the shoulder pain and neck pain was better for approximately two weeks and now it has gradually started coming back. She localizes most of her pain to the left trapezial area with discomfort that is gradually getting worse.' She denies any frank numbness or tingling coming into her arms although she does note she drops things with her left hand. She does note she gets increased discomfort if she keeps her neck in one position for any period of time. She does feel like she has pain into the left side of her neck which she feels at times makes it difficult for her to swallow or talk. She has been taking medication on an as needed basis. She is concerned because her symptoms are now returning after the ESI. PAST MEDICAL HISTORY: Past medical history, social history and family history were reviewed this date with no changes. PHYSICAL EXAMINATION: The patient is awake, alert and oriented x 3. She is in no acute distress. She answers questions quickly and appropriately through her husband, who translates for her today. On examination of the patient's cervical spine she has no erythema, no edema, no signs of any infection. She has no tenderness along the cervical spine. She does have some paracervical tenderness, no periscapular tenderness. She has - CONTINUED - 41 38L VWyI Sfo ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. .CHOI,MI K ACCOUNT # 122513 5 CARDAMON DRIVE CHART # 024314 MECHANICSBURG,PA 17050 SS # 209720959 08/23/2010 LEMOYNE OFFICE SEP 07 2W Page 2 CO?i00RdYr.?.E cm positive sensation to her upper extremities. She has no focal motor deficits. Her reflexes are symmetrical. She has good range of motion of her neck. She does get positive Tinel's into the carpal tunnel on the left side with numbness going up her arm and into her fingers. She has positive Phalen's. She has negative Tinel's over the cubital tunnel on the left, negative Tinel's over carpal and cubital tunnel on the right side. She has no pain with range of motion of her shoulders. DIAGNOSTIC STUDIES: EMG's and nerve conduction studies were reviewed and are normal as far as carpal, cubital and cervical radiculopathy. DIAGNOSIS: 1. Pain referred to intrascapular area, upper extremity status post motor vehicle accident 3/19/10, possibly myofascial etiology versus cervical spine occult injury. 2. Degenerative disc disease with disc protrusion C3-4 and CS-6 of unclear significance. PLAN: The patient was discussed with Dr. Fultz. The patient was given clinical impression. It was decided at this time, secondary to her getting some symptomatic relief with the C5-6 ESI we will try a repeat one and see if she continues to get more relief and maintain the relief. If she does well following the ESI and continues to be pain free, we may consider a course of therapy for her neck. The patient and her husband state they understand and agree with the current treatment plan. Completed by Brandy M. Komykoski, PA-C Craig W. Fultz, M.D., Supervising Physician BMK/rjg BMF/rjg DD: 08/23/10 DT: 08/31/10 TK-FAX sent to Janet Kelly, CRNP 42 if EAUNSOUTH@ Rehabilitation of Mechanicsburg 175 Lancaster Blvd., Mechanicsburg, PA 17055 PROGRESS & PROCEDURE NOTE NAME: CHOI, MI DOB: 02/23/1967 DOS: 09/20/2010 REFERRING PHYSICIAN: Dr. Craig Fultz. PATIENT#: 743863 DIAGNOSES: 1. Chronic neck pain. 2. Left upper extremity radiculopathy. 3. Degenerative disk disease. 4. Disk protrusion at C5-6. 9c;b PROGRESS: Mi Choi has been referred to the Pain Clinic. She was last seen here in the Pain Clinic about 2 months ago. She underwent an initial cervical epidural steroid injection due to chronic neck pain and left upper extremity radicular pain, which is due to disk protrusion at C5-6. She reports having considerable improvement in her left arm pain and almost complete resolution in the shoulder and arm pain. However, she continues to have some neck pain and did see Dr. Fultz recently. Based on her presentation and her findings, Dr. Fultz suggested a repeat epidural steroid injection to see if this would alleviate some of her neck discomfort. Examination showed some tendemess in the cervical spine muscles, but no neurologic deficits. EXAMINATION: As per initial examination. PROCEDURE: The patient milY member has been informed of the risks an benefits of the planned procedure. Cervical epidural steroid injection #2. After obtaining informed consent, the patient was taken to the fluoroscopy room and placed in the prone position. The patient was identified by armband. The site of service was identified and confirmed with the patient. Sterile prep and drape. Then 1% lidocaine was injected into the skin and deeper tissues. Using a translaminar approach at C5-6 towards the left side, a 20-gauge, 3-1/2-inch needle was guided under fluoroscopy and using loss of resistance technique into the epidural space. After confirming placement in AP and lateral views and negative aspiration for cerebrospinal fluid or blood, 10 mL of normal saline, and 80 mg of Depo-Medrol was injected. The patient tolerated the procedure well. COMPLICATIONS: None. Page 1 43 NAME: CHOI, MI DOB: 02/23/1967 DOS: 09/2012010 PATIENT* 743863 FOLLOW UP: The patient was asked to give us a call in one week with the results of today's injection and to possibly schedule a repeat injection if needed. She will also follow up with Dr. Fultz as scheduled. Malik Momin, MD MM/am2593 DD: 09/2012010 12:27 PM DT: 09/2012010 4:27 PM JobID: 2917750 cc: Craig Fultz, MD 44 Page 2 -.. MY 15 2010 CCU=V1LLE ctios ORTHOPAEDIC SURGEONS OF CENTRAL PA, 3?• L$14 -• 93;ro LTG (D V fr[D) CHOI,MI R ACCOUNT # 12251 41T? ,,?,n?$ CHART # # 024314 5 CARDAMON DRIVE 209720959 ? Par " MECHANICSaURG, PA 1705e `?1 October 21, 2010 LEMOYNE OFF 944a ?C fly DOB: 2/23/67 HISTORY OF PRESENT ILLNESS: Ms. Choi is a 43 year old female who comes to the office this date to follow up on her neck. She is accompanied by her husband who helps translate for her. She was initially seen in our office for neck and arm pain that started on 4/29/10 after she was involved in a motor vehicle accident. She was the driver wearing a lap belt with a shoulder strap. Impact was at the rear of her automobile. She noted within an hour of the accident she started developing pain in her neck. She had a headache and was having difficulty swallowing. She was seen at Holy Spirit Hospital Emergency Room where she had a CT scan done of her head and x-rays done of her neck. She was placed on Hydrocodone, Prednisone and Diazepam. She followed up with her family physician who put her through a course of therapy which improved her symptoms but gave her no frank resolution. She was then sent for an MRI scan which showed a central disc prominence at C3-4 and CS-6. EKG and nerve conduction studies were ordered. These were normal. She was sent for CS-6 epidural steroid injection and noted her symptoms were gradually returning. She was therefore sent for repeat C5-6 epidural steroid injection at her last appointment on 8/23/10. The patient returns today for follow up. She states she was approximately 90V improved for a two week period but her symptoms returned gradually. It seems to be harder for her to talk for longer periods of time. She has some pain in the front of her neck and lateral side of her neck on the left. At times when she is lying down it feels like something is getting stuck in her throat. She denies having any pain coming down her arms. She occasionally notes tingling in the lateral aspect of her left arm, ulnar side of the forearm and into the fifth digit. She notes her neck seems to bother her when she holds it in one position for any period of time. She denies having any frank weakness in her arms. PAST MEDICAL HISTORY: Past medical history, social history, family history and review of systems were reviewed this date with no changes. PHYSICAL EXAMINATION: The patient is awake, alert and oriented x 3. She is in no acute distress. She answers questions quickly and appropriately. On examination of her cervical spine she has no erythema, no 45 ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. CHOI,MI KNT # 122513 5 CARDAMON DRIVEHART # 024314 MECHANICSBURG, PA 17050S # 209"'T-nim-4. .:ZI CAi, mca? 10 / 21 / 2 010 LEMOYNE OFFICE =Z* Page edema, no signs of any infection. She is nontender to palpation over the cervical vertebrae but does have some tenderness to the paracervical muscles on the left side, no tenderness on the right side. She has good range of motion of her neck. She has positive sensation to her upper extremities. She has no focal motor deficits. Her reflexes are symmetrical. With lhermitte testing she has tingling that goes down the lateral side of the left arm, ulnar side of the forearm and into the fourth and fifth digits. She has negative Spurling's testing. DIAGNOSIS: I. Pain referred to intrascapular area, upper extremity status post motor vehicle accident 3/19/10, possibly myofascial etiology versus cervical spine occult injury. 2. Degenerative disc disease with disc protrusion C3-4 and C5-6 of unclear significance. PLAN: The patient was discussed with Dr. Fultz and the patient was given clinical impression. Once again it was decided to proceed by trying another C5-6 epidural steroid injection secondary to her getting good pain relief for a brief period of time, to see if we can get lasting pain relief. It was in explained through her husband if she fails to get adequate pain relief and she is interested in proceeding with possible surgical intervention we would want to get a bone scan with SPELT and also discogram at C3-4, C4-5 and C5-6. If she fails to get adequate pain relief and does not want to proceed with surgery we would consider setting her up for pain management. If she does well following the injection and gets good long term relief we may consider a course of therapy at her next appointment. They understand and agree with the current treatment plan. Completed by Brandy M. Komykoski, PA-C Craig W. Fultz, M.D., Supervising Physician BMK/ r j g BMF/rjg DD: 10/21/10 DT: 10/25/10 TK-FAX sent to Janet Kelly, CRNP 46 PROGRESS & PROCEDURE NOTE N , : CHOI, MI PATIENT#: 743863 DO 02123!1967 DO 11 !22!2010 REF BRING PHYSICIAN: CRAIG W. FULTZ, MD MI i C i has been referred to the pain clinic for repeat lumbar epidural steroid injection to h p with the neck pain and left upper extremity radicuiar pain. She has a disk pro sion at C5-6. She saw Dr. Fultz who suggested she should come in for a repeat inj n. She states that her second injection seemed to help her better than the first one. However, she still has pain particularly tlk Drr. when Fultz suggested that she try ar?? she swallows, she says, inj 'on and she has followup appo in her and when she attempts torment with Dr. Fultz in the near future. EXAMINATION: Unchanged. No neurologic deficits. p : We agreed to perform cervical epidural steroid injection. P CEDURE: The patient ?ryflamly member has been informed of the risks and enefits of the planned procedure. Cervical epidural steroid injection #3. Aftei obtaining informed consent, the patient was taken to the fluoroscopy room and pla in the prone position. The patient was identified by armband. The site of service was identified and confirmed with the patient Sterile prep and drape. Lidocaine I% was injected into the skin and deeper tissues. Using a translaminar approach at C5-6 tow rds the left side, a 20-gauge, 3-1/2-inch needle was guided under fluoroscopy and usi loss of resistance technique into the epidural space. After confirming Placement in A and lateral views and negative aspiration for cerebrospinal fluid or blood, 10 mL of no 1 saline, and 80 mg of Depo-Medrol was injected. The patient tolerated the ure well. ,TtONS: None. of Mechanicsburg Blvd., Mechanicsburg, PA 17055 P: The patient vwll be following up with Dr. Fultz as scheduled for further ID: 2330680 4ACILITY: 030031.00 ACCOUNT: 743863 DATE: 201042-02 PAGE: 2 47 : CHOI, MI 02/23/1967 11/2212010 PAT?EN1V 7 43^ 3 ,ndations. The patient knows to give us a call in the future shc) C a repeat be needed. Momin, MD OD: 111221201011:42 AM DT: 11/2212010 1:09 PM Jobl : 3150839 cc: Oraig Fultz, MD Pace 2 ID: 2330680 FACILITY: 030031-00 ACCOUNT: 743863 DATE: 2010.12-02 !PAGE: 3 1 48 REC'_-tea JAN 12 2011 ????f . ?j ?cOMVIUX of °ry of ?°'o??! ?4t ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. PA{??'! t?kn CHO I , M I K ACCOUNT # 122513 %.p& %17, 5 CARDAMON DRIVE CHART # 024314 p MECHANICSBURG,PA 17050 SS # 209720959 December 27, 2010 LEMOYNE OFFICE DOH: 2/23/67 CHIEF COMPLAINT: "That last shot didn't help." HISTORY OF PRESENT ILLNESS: The patient is a 43 year old female with pain referred to the interscapular area and upper extremities status post motor vehicle accident on 3/19/10, possibly myofascial etiology versus cervical spine pathology. She has degenerative disc disease with disc protrusion at C3-4 and C5-6 of unclear significance. She has had negative EMG and nerve conduction studies. She has had three epidural steroid injections. The first one gave her some short term improvement. The second and third ones did not seem to help her significantly. On presentation today she is complaining of pain and numbness in the left side of her neck radiating into her upper extremity. It seems to follow a C6 distribution. She does not appear to have radicular symptoms with valsalva maneuvers. She has no loss of bladder or bowel control, no myelopathic symptoms. PAST MEDICAL HISTORY: I reviewed with the patient her past medical history as well as her review of systems. These are unchanged from her last exam and are outlined and updated on her PMH sheet today. PHYSICAL EXAMINATION: Her physical examination today demonstrates her to have tenderness about her paracervical muscles. She has a negative lhermitte's test and negative Spurling's test. She has decreased sensory acuity in the biceps, radial aspect of her forearm, first web space on the left side. Reflexes are symmetrical. She has negative Hoffmann's reflex. DIAGNOSIS: 1. Pain referred to intrascapular area, upper extremity status post motor vehicle accident 3/19/10, possibly myofascial etiology versus cervical spine occult injury. 2. Degenerative disc disease with disc protrusion C3-4 and C5-6 of unclear significance. PLAN: I advised the patient as well as her husband on my clinical impressions. I suspect that her symptoms are largely coming from the C5-6 level, given her clinical presentation. It is unclear, though, whether there are other sources of pain in 49 ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. j?,? 4 CHOI , MI KNT # 122513 0,.,, Of: 5 CARDAMON DRIVEHART # 024314 0959 _" q^?y MECHANICSBURG, PA 170505 # 20972 ?,- ^? Yly?f$, ins ti 12/27/2010 LEMOYNE OFFICE Page her cervical spine. we discussed nonoperative treatment options including referral to noninterventional pain management such as Dr. Cho, whom she has seen in the past, versus working her up with a bone scan with SPELT and discograms to see if there are any surgical options that may help her. They elected the latter. we will see her back after the discograms and bone scans are available. If they are negative we will have little to offer her from a surgical standpoint. If they are positive we can address out options at that time. They state they understand and agree with that treatment plan. Completed by Craig W. Fultz, M.D. CwF/rag DD: 12/27/10 DT: 01/03/11 TK-FAX sent to Janet Kelly, CRNP 50 3 Holy Spirit Hospital Department of Radiology and Diagnostic Imaging Camp Hill, Pennsylvania 17011 (717) 972-4900 DICTATION DATE: Dec 29 2010 3:37P PATIENT: CHOI, MI K TRANSCRIPTION DATE: Dec 29 2010 4:38P MR#: 297496 ADM#: 38768263 PT CLASS: O ADM DATE: 12/29/2010 DR; ORD CRAIG FULTZ ARRIVAL DATE: 12127/2010 PT TYPE: R HOSP SERVICE: HSN DOB: 02!23!1967 ACC#: 4212237 LOCATION: OP REG- GENDER. F -Final Report"' smgmm EXAMINATION: NM BONE SPECT 78320 - Dec 29 2010 'JAN !2 201 COMMENTS: Exam: Nuclear medicine bone spectroscopy. CONCORDKIE r•tr? Radiopharmaceutical 27.4 mCi technetium 99m MOP. History: Neck pain. Back discomfort. Evaluate for facet versus 20disc uptake cervical spine. Previous cervical MR exam of Magnetic Imaging Center, Mechanicsburg, Pennsylvania, dated Findings: Correlation is performed with cervical MRI 5111/2010. A moderately large central and right paracentral disc protrusion and disc extrusion of C3-C4 extends above and below the interspace on the MR. On bone scan there is very minimal radioisotope uptake of the facet joints at C3-C4 slightly more prominent on the left. On MR, a posterior broad-based shallow central disc protrusion at C4-C5 or posterior convex bulging annulus is observed. No significant radioisotope uptake is present at the C4-C5 level. On MR at C5-C6 there is a moderate central disc protrusion broad based resulting in diminution of the anterior spinal capacity. Facet uptake to a mild degree is present at the C5-C6 level slightly greater to the left and there is increased radioisotope uptake along the endplates at C5-C6 on SPECT imaging. Minimal increased radioisotope uptake is present in the facet joints at C6-C7 slightly more prominent to the left. CONCLUSION: Slight increased radioisotope uptake of left facet at C3-C4, about the interspace, likely of the endplates at C5- C6 and of the facets at the C5-C6 level left greater than right, and mild increased radioisotope uptake of the facets of 617 slightly greater to the left. Please correlate with cervical spine MRI of Magnetic Imaging Center of May 11, 2010 which demonstrates significant disc protrusions and extrusions of C3-C4 and C5-C6. DICTATED BY: DEBBIE DURISEK MD / PSC DATE OF EXAM: Dec 29 2010 SIGNED BY: DEBBIE DURISEK MD CONFIDENTIAL: This report contains private patient inhumation. If you have received this report in error. please call 717-972-4941 immediately. ConfidenuaW Disclaimer. The information contained in this communication may be confidential, is intended for the use of the recipient named above, and may this be legally privileged. If the reader of this message is not the intended recipient. you are hereby notified that arry? io dii ?on.to co sender and communication, or any of its contents, is strictly prohibited. It you received this commoucation in error, please delete the original message and any copy of it from your computer system. Thank You- - - Imaging Services Consultation 51 Page I ?t?lk - - H `OUMs fig 14 20ii u? SPECIAL PROCEDURES CLINIC Malik N. Momin, MD - Medical Director PAIN MANAGEMENT RE-EVALUATION PATIENT#: 743863 NAME: CHOI, MI DOB: 02/2311967 DOS: 01/_4//2011 REFERRING PHYSICIAN: Craig Fultz, MD DIAGNOSES: 1. Chronic neck pain. 2. Left upper extremity radiculopathy. 3. Broad-base disk bulge C5-C6. 3yL88 l-l9SG who was last HISTORY OF PRESENT ILLNESS: The patient isa 2 months,lwhen femalehe had her 3rd seen here in the pain clinic back in November, about cervical epidural steroid injection to help wit Nh her avinc amprovement neher left extremity radicular pain. While she repo 9 considerable her arm pain, unfortunately she has continued to have see'DrnFultz recently,cwho and some recurrence of pain in her left arm. She had to determine recommended she come in to undergo diag no neck provocative diskography a possible diskogenic cause for her pe pain. PAST MEDICAL HISTORY: Significant for chronic headaches. She has a history of chronic neck pain as described. PAST SURGICAL HISTORY: Ovarian cyst 6 years ago. CURRENT MEDICATIONS: Hydrocodone as needed for pain. ALLERGIES: NO KNOWN DRUG ALLERGIES. FAMILYISOCIAL HISTORY: The patient lives with family, her husband and children. She works at a dry cleaner on a part-time basis. REVIEW OF SYSTEMS: The patient denies any recent history of fevers or chills, shortness of breath, chest pain, nausea, vomiting, or abdominal pain. No history of incontinence of bowel/bladder. No bruising or bleeding disorders. Page 1 52 175 Lancaster Blvd., Mechanicsburg, PA 17055 Phone (717) 691-3731 Fax (717) 699-3858 PATIENT#: 743863 NAME: CHOI, MI DOB: 02/23/1967 DOS: 01/3/12011 PHYSICAL EXAMINATION: The patient isalert e 7and 2, ?espiraions 18 and weight se115 and in no acute VITAL SIGNS: Blood pressure 118/60, heart pounds. HEENT: Normal. LUNGS: Clear. m ?t nciernessan the cervical rhythm. has ABDOMEN: Soft and nontender. She paravertebral muscles more on the left than on the ed he hhas e biceps awith nd extension, n, flexion and rotation of her neck. Reflexes were e extremities and also sensory exam was Grip strength was equal bilaterally in the upper intact. PLAN: After evacuating her and having a lent?discussion with the patient and her to them the procedure for diagnostic husband, who served as an interpreter, I explained use provocative diskography to determine the possible is limited ktogpeonss bae di for andain I explained to them the risks include, but are no with to unerstand and of today's d wished to exacerbation and of her usual pain. They seemed proceed. They will follow up with Dr. F Malik Momin, MD MM/am2819 DD: 02107/2011 01:36 PM DT: 02107/2011 2:03 PM JobID: 3456354 cc: Craig Fultz, MD Page 2 175 Lancaster Blvd., Mechanicsburg, PA 17055 Phone (717) 691-3731 Fax (717) 681-3858 53 tL? HEALTHSOUTN. Rehabilitation of Mechanicsburg 175 Lancaster Blvd., Mechanicsburg, PA 17055 PROGRESS & PROCEDURE NOTE NAME: CHOI, Ml PATIENT* 743863 DOB: 02123/1967 DOS: 01/31/2011 REFERRING PHYSICIAN: Craig W. Fultz, MD PROGRESS: the patient has been referred to the pain clinic by Dr. Fultz to undergo diagnostic provocative diskography to determine if possible diskogenic cause for persistent neck pain and left arm pain. She was last seen here in the pain clinic back in November when she had a third cervical epidural steroid injection, but unfortunately she still has persistent pain involving her left neck and extending into the left shoulder and arm. She has, by MRI, protruding disk seen at the C3-C4 as well as the C5-C6 level 'and some increased uptake was seen ' °hat?d agnostictpro? provocative d skography would presentation and findings, Dr. Fultz be useful for further diagnostic information. EXAMINATION: Unchanged. Most and radiates into the left shoulder. neck and it is aggravated with certain movee PLAN: After evaluating her, I had a lengthy Vdiscussion the patient and her explained to her then thend who interpreted for us since she speaks very little procedure and that it is a diagnostic provocative invasive study to determine a possible diskogenic cause for her pain. I explained to them that the risks include, but are not limited to possible diskitis and exacerbation of her pain and they acknowledged this and wished to proceed. PROCEDURE: PROCEDURE: The patient family member has been informed of the risks and benefits of the planned procedure. Diagnostic provocative diskography at the C3-C4, C4-C5, C5-C6 levels. After obtaining informed consent the patient was taken to the fluoroscopy room and she was placed in the supine position with his neck extended. An IV was inserted and antibiotics were administered. She was also given light IV sedation with versed. Appropriate monitoring was applied. A right anterior paramedian approach was used after sterile prep and drape and carefully palpating the vascular structures, 1 % lidocaine was injected into the skin and deeper tissues, followed by placement of a 22-gauge, 3-112-inch needles into the central portion of the 3 disks. Placement was verified AP and lateral views and negative aspiration each of the 3 disks were injected with a mixture of Omnipaque and antibiotic and using a 3 mL syringe by hand. The following findings are obtained. 54 Page 1 PATIENT* 743863 NAME- CHOI, MI DOB: 02/23/1967 DOS: 01131/2011 and a At the C3-C4 level a total of 0.15 mL of Omnipaq aand the s i je pane to did degenerative appearing disk was seen, but it was firm on injection acknowledge any discomfort on injection. was and At the C4-C5 level a total of 01 mL of Omnipaque was injected. oThe ndThe patent did injection. with intact disk height and nucleogram to affirm end point not acknowledge any pain. intense pain k was At the C5-C6 level a tots{ of 0.1 mL of Omnipaqu a awas injected. cknowledged a Degenerat seen which is soft and compliant on injection. Sh her usual extending into her left neck and shoulder are?aQf very cane andtshe had cornple dam This was followed by injection of 0.05 mL of o resolution of the concurrent pain. COMPLICATIONS:. None. FOLLOW UP: In conclusion, the patient has an intense concurrent the C3-C4 as well ection of the C5 disk only. No pain was acknowledged on injection as the C4-C5 disks. She was given copies of her diskogram and preliminary f o d t to beetaken to Dr. Fultz, n good condition. She was allowed to recuperate for appropriate time pr Malik Mornin, MD MM/am2682 DD: 01/31/2011 11:53 AM DT: 01/3112011 4:27 PM JobID: 3422577 cc: Craig Fultz, MD 55 Page 2 6r) EONS OF CENTRAL PA, LTD ORTHOPAEDIC SURGE PA, Cqt p?„_ ACCOUNT # OC U 'Q?tQly CHOI, MI K CHART # 024 P??C 5 CARDAMON DRIVE SS # 209720959?yfYBaj$S,,8 MgCHANICSBURG,PA 17050 trb. . February - 10, 2011 LEMOYNE OFFICE f MAR Q 2 2Qft DOB : 2/23/67 CONCORDVILLE C- C*S HISTORY OF PRESENT ILLNESS: Ms. Choi is a 43 year old female who comes to the office this date to follow up on her neck. She has a history of having pain referred from her neck to interscapular area and the upper extremities status post motor vehicle accident occurring on 3/19/10. She was found to have degenerative disc disease with disc protrusion at C3-4 and C5-6 of unclear significance. She had EMG and nerve conduction studies performed. She had three epidural steroid injections performed at the C5-6 level. The first one gave her some improvement. The second and third injections did not give her any significant improvement. Upon being followed up in our office on 12/27/10 she was having pain and numbness in the left side of her neck radiating into her left upper extremity in the C6 distribution. At that time it was decided to set the patient up for discograms and also a bone scan with SPECT. She comes in now for follow up. The patient is accompanied by her husband, who translates for her. She states she had discograms done and the C5-6 level showed a concordant response to her pain. They state that gave her pain that came down her arm with a "zinging" feeling that traveled the same pattern of pain she normally gets. She also had a bone scan done which did show some uptake in the left facet at C3-4 and the facet at C5-6. She states at this point.in time she is having pain in the neck that comes into the left shoulder area. She gets a heavy feeling in her neck and it feels like it needs to be supported. The pain continues to follow a C6 distribution to the left side. She states the worst part of her pain is in the first web space with a pinprick feeling in that area. She also notes she has been getting some numbness and pain on the left side but it seems to be intermittent and following the same pattern with C6 distribution. Her husband does note that she drops things. She has no pain with valsalva maneuvers. She does feel she has weakness into her left arm. PAST MEDICAL HISTORY: Past medical history, social history, family history and review of systems were reviewed this date with no changes. PHYSICAL EXAMINATION: The patient is awake, alert and oriented x 3. She is in no acute distress. She answers questions appropriately through her husband. 56 ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. C?AMSVTIAL Fo.DIG4L CHOI, MI KNT # 122513 PMfeaajoC`ORp 5 CARDAMON DRIVEHART # 024314 Of Pony of Use ow, MECHAT7ICSBURG, PA 17050S # 209720959 ?trj pa 0-1 ?LTD. r2-, 02/10/2011 LEMOYNE OFFICE Page on examination of the patient's cervical spine she has some extending tenderness in the mid aspect of her cervical spine into the distal aspect of her cervical spine. She has no paravertebral muscle spasticity or step off deformities. She has some decreased sensation to the left biceps area of the forearm into the first web space on the left side, not on the right side this date. She has positive pulses. Her reflexes are symmetrical. She has good strength. With lhermitte's testing she gets some pain that follows a C6 distribution. With Spurling's testing she just has pain into the area of her neck. She has negative Hoffmann's reflex. DIAGNOSIS: 1. Pain referred to interscapular area and upper extremities status motor vehicle accident 3/19/10. 2. Degenerative disc disease with disc protrusion C3-4 and C5-6 of unclear significance. 3. Pain in C6 distribution with concordant response on discogram. PLAN: The patient was discussed with Dr. Fultz, who also saw and examined the patient and went over treatment options and plan with the husband and his wife. We went over surgical intervention. She is going to follow up with Dr. Cho, whom she has seen in the past for her pain management, until she decides what she wishes to do regarding surgical intervention. Completed by Brandy M_ Komykoski, PA-C Craig W. Fultz, M.D., Supervising Physician BMK/rjg DD: 02/10/11 DT: 02/11/11 TK-FAX sent to Janet Kelly, CRNP 57 State Farm* Providing Insurance and Financial Services Fame Office, Bloomington, Illinois 61710 March 10, 2011 Disability Management Consultants 920 W Sproul Rd, Ste 202 Springfield, PA 19064 RE: Injured Party's Name: MI KYONG CHOI Claim Number: 38-1-884-956 Date of Loss: 3/19/2010 Vendor: Pennsylvania MPC of"M P.O. Box 41 Concordville, PA 19331-0041 Mi Kyong Choi was involved in a motor vehicle accident on 3119/2010. We are asking your company to perform a review of the clinical information and other materials relating to the patient's diagnosis(es) of 723.1(cervicalgia); 719.41 (pain in joint, shoulder region); 723.4(brachial neuritis or radiculitus NOS); 722.4(degeneration of cervical intervertebral disc); 722.0(displacement of cervical intervertebral disc without myelopathy); 729.5(pain in soft tissues of limb); 722.2(displacement of intervertebral disc, site unspecified, without myelopathy); 724.5(unspecified backache); 724.4(thoracic or lumbosacral neuritis or radiculitis, unspecified); 847.0(nec k sprain and strain); 462(acute pharyngitis); 535.00(acute gastritis without mention of hemorrage); 724.2(lumbago); 959.01 (head injury, unspecified); 959.09(injury of faceand neck, other and unspecified); 722. 1 0(displacement of lumbar intervertebral disc without myelopathy); 840.8(sprain and strain of other specified sites of shoulder and upper arm)along with a physical examination of Mi Kyong Choi. We ask that the review and examination be conducted by a othopedic surgeon. For purposes of scheduling the examination, David S. Wisneski Esq of Navitsky, Olson & Wisneski can be reached at 717-541-9205. We are seeking an objective opinion, including supporting rationale, relating to the following question(s): e What is/are the injury(ies) or condition(s) diagnosed and documented in the clinical records? • Is the provided treatment related to the injury(ies) or condition(s) diagnosed and documented in the clinical records? • What is the etiology of the diagnosed injury(ies) or condition(s)? • Based on your examination of the patient, your review of the submitted records, your clinical experience, and any applicable research, was the patients condition caused by the 3/1912010 accident? A 58 38-1-884956 Page 2 March 10, 2011 • Did the patient sustain any permanent or temporary impairment as a result of the injury(ies) sustained in the 3/1912010 accident? If so, what are the nature and extent of that impairment and what are the dates during which the patient was impaired? • Is the patient able to return to preloss activity levels, including occupational duties? What, if any, are the patient's restrictions? • Has the patient's condition reached pre-injury status? • What time frame is expected forpatients condition tostabilize, relative to injuries sustained in the 3/19/2010 accident? For the purpose of the review, we have enclosed the information itemized below: Letter of Representation Application of Benefits Medical Authorization AutoRX bills from 3-19-10 to 6-28-10 Camp Hill Emergency bill of 319-10 Drayer Physical Therapy bills from 3.23-10 to 6-10-10 Drayer Physcial Therapy notes from 3-23-10 to 6-10-10 Healthsouth Rehab bills from 7-26-10 to 1-31-11 Healthsouth Rehab notes from 7-26-10 to 1-31-11 Holy Spirit Hospital bills from 3-19-10 to 12-29-10 Holy Spirit Hospital notes from 3-19-10 to 12-29-10 Magnetic Imaging bill of 5-10-10 Magnetic Imaging notes of 5-10-10 Ortho Surgeons bills from 429-10 to 2-10-11 Ortho Surgeons notes from 4-29-10 to 2-10-11 Penn Rehab bill of 6-21-10 Penn Rehab notes of 6-21-10 Pinnacle Health bills from 3-22-10 to 6-29-10 Pinnacle Health notes from 3-22-10 to 6-29-10 Quantum Imaging bills from 3.19-10 to 12-29-10 Quantum Imaging notes from 6-28-10 to 12-29-10 Susquehanna Valley bills from 7-26-10 to 1-31-11 Photos of policyholder's vehicle Wage and Salary form Disability statements The report containing the findings and opinion should contain, as the first section, a specific list of all information reviewed. Please include the references to any professional publications or research used as a basis for an opinion contained in the report. State Farms requests that the completed review be returned to us no later than fifteen days following the examination of the patient. If for some reason this time frame cannot be achieved, please notify us with the reasons in writing. If necessary, State Farm will provide you with to subsequent due date, confirmed in writing. All verbal communicationswith State Farm, prior our receipt of your report, shall be limited to administrative items and should not address the merits of the issues subject to review. 59 38-L884-956 Page 3 March 10, 2011 Your acceptance of our request for your services and your performance of those services are expressly conditioned on and subject to your agreement that: (1) you will not use customer information we provide for any purpose other than the specific services we are asking you to perform, and (2) you will disclose or share customer information we provde only to the extent necessary to accomplish the services that we request. Thank you for your assistance in the above matter. Sincerely, Donna Samarya Claim Representative (888) 713-4694 x3615685 Fax: (888) 713-4693 State Farm Mutual Automobile insurance Company Enclosures: CD cc: Navitsky, Olson & Wisneski 2040 Linglestown Rd, Ste 303 Harrisburg, PA 17110 60 Orthopaedic rgeons of Gntral Pennsylvania.) LTD. u,?u 550 N. 12th Street, Suite 140, Lemoyne, PA 17043 (717) 901-8000 Fax (717) 761-6860 Craig W. Fultz, M.D. Robert J. Maurer, M.D. Jeffrey W. Finn, M.D. Eric M. Kutz, D.4- Brandy M. KomykOski, PA-C March 31, 2011 David S. wisneski NAVITSKY, OLSON, ? WISNESRI, LLP 2040 Linglestown Road Suite 303 Harrisburg, PA 17110 RE: Mi Kyong Choi DOB; 2/23/67 Dear Mr. Wisneski: 2011 I am writing in response to your letter dated March 30, Mi Kyong Choi' injury that she sustained in a motor regarding vehicle accident on 3/19/10 for which I have evaluated an treated her for. who first Ms. Choi is a 44 year old right hand dominant female, presented to my office on April 29, 2010 3119/10. after reportedly being involved in a motor vehicle acaiieapta an shoulder She claims strap at the that she was a driver wearing time of the motor vehicle accident. shehdidrnotothin?kashewhadtanY rear of her automobile. In significant injuries, but within one hour started de elopinga significant pain in her neck, difficulty headache. She was taken to Holy Spirit Hospital where reportedly a CT scan of her head and x-rays of her neck that obtained. She brought the x-rays of her neck along to up with her office visit for me to review. She wasStreated followedwith Hydrocodone, Prednisone and Diazepam. h sisal therapy at Drayer family physician and was treated ortedly improved her symptoms, Physical Therapy. The therapy eP but did not resolve them. Her complaint at the time of her initial evaluation was neck pain radiating into her periscapular area, bi upper extremities, to a greater degree on e eft side. She The describes herself as having quadrilateral dysesthesias. -- Providing Quality Orthopaedic Care to Central Pennsylvania - 61 RE: MI K Choi March 31, 2011 Page 2 patient denied any previous history of neck injuries, neck pain or shoulder/upper extremity injuries that caused any pain or any symptoms prior to this motor vehicle accident. It was my opinion after examining the patient, reviewing her x-rays, her diagnosis was pain referred to her irifrascapular area, upper extremity status post motor vehicle accidenervical t on 3/19/10, possible myofascial etiology versus occult c spine injury. I recommended the patient get an HRI scan of the cervical spine to better define the injuries to her cervical hat spine, rule out any significant structural) abnormalities that may not be evident on the available diagn study was completed on 5/10/10. She followed up in my office on 5/27/10 for follow up evaluation and review of that study. On 5/27/10 she was still having ongoing symptoms. She complained of pain in her neck radiating into her periscapular and bilateral upper extremities, to a greater degree on the left side. Her MRI scan was reviewed by me. It showed acentral the disc prominence at C3-4 and C5-6. Both of these impinged thecal sac, but no abnormal cord signal. There was disc desiccation as well as discogenic end plate changes at C5-6. There is no evidence of any acute fractures. It was my impression her diagnoses at that time included: 1. Pain referred to the intrascapular area, upper extremity status post motor vehicle accident 3/19/10 with possible myofascial etiology versus occult cervical spine injury. Additionally, she had degenerative disc disease and disc protrusion C3-4 and C5-6 of unclear significance. Given that she had a nondiscrete radicular pattern of symptoms. I had recommended EMGs and nerve conduction studies to better define the potential source of her sympY o stud These wercezvical completed on 6/21/10 by Dr. violago. Y of her spine and upper extremities was within normal limits. She was additionally sent for CS-6 epidural steroid injection which was carried out on 6/28/10. She saw excellent short term pain relief with that epidural steroid injection. She subsequently had three epidural steroid injections carried out at the C5-6 level, each giving her short term pain As she was followed along in a serial fashion, she continued to have neck pain primarily radiating into the left upper extremity in the C6 distribution. On 12/27/10 she was reevaluated by me. She presented complaining of pain and numbness in the left side of her beck, radiating into her left upper extremity. It appeared to radicular primarily the C6 distribution. She was not having any 62 RE: MI K Choi March 31, 2011 Page 3 los blad symptoms with Valsalva symptoms. nI reviewed with the patient, control, no myelopa YmPtoms• toms as well as her husband, my clinical impression that her symptoms appear to be largely coming from the C5-6 level. we discussed nonoperative treatment options versus surgical inn Ivention. They wished to pursue surgical intervention, would be the best chance at improving her symptoms. I recom end besidesothehCS potential disc. spinethere an algorithmic woene ators??inehersure generators structural pain This would include a bone scan with SwEth,thosewell as diagnostic discograms. They desired to proceed completed of her studies. On 1131/11 she hadrconcordant discogram at cervical spine. she had a positive C5-6, negative at C3-4 and C4-5. She the leflnfacetnat1C3-4pECT which showed some increased and the end plates of C5-6. Her last evaluation by me was on 2/10/11. She presented to our office after having the discogram and bone scan completed. The patient was tllprimarily followed at distribution uppnerthe extremity. The pain left side. She has decreased sensation in the G6 distribution in her biceps area and radial aspect of her forearm and first C6 rad web space. Lhermitte's test caused reproduction of and hericular symptoms in the left upper extremity. patient The husband were advised on my clinical impression and diagnoses. It was my opinion her diagnoses were, 1. Pain referred to the infrascapular area of upper extremity status post motor vehicle accident 3/19/10. 2. Degenerative disc disease with disc protrusion C3-4, C5-6 of unclear significance. 3. Pain in C6 distribution with concordant response to C5-6 on discogram. I explained to the patient and her husband the implications of these diagnostic study results. I discussed treatment options including surgical option of anterior cervical discectomy with interbody fusion at C5-6 versus noninterventionall painfor a management. She wished to pursue the pain mmanagem intervention. period of time before proceeding with any surgical We referred her to Dr. Cho for evaluation and treatment for noninterventional pain management. They will contact my office when they wish to proceed with the surgical intervention. I advised her on the treatment time lines that would need to occur or diagnostic studies would need to be repeated if they become outdated. They state they understand. 63 RE; MI K Choi March 31, 2011 Page 4 it is my opinion that the patient's best chance at improving her symptoms would be an anterior cervical discectomy with interbody fusion at C5-6 level. The prognosis with surgical intervention given her diagnostic studies and response to the CS-6 epidurals of marked improvement would suggest there is a high p of her symptoms with that surgical procedure. The surgical fees for that procedure are $8,300.00. I am unable to estimate the hospital costs or associated potential therapy cost perioperative time. ecertainty It is my opinion with a reasonable degree of medical xtremity that Mrs. Choi' neck pain referred to her left upper which developed after the motor vehicle accident on 3/19/10 is causally related to the motor vehicle accident on 3/19/10. There is no history or medial records to suggest that the patient had any preexisting symptomatic cervical spine pathology or any ongoing symptoms in the cervical spine referred to her upper extremities prior to the motor vehicle accident. She has not been asymptomatic since the motor vehicle accident. The algorithmic work up has identified a structural pain generator in the cervical spine at the C5-6 disc. In light of these facts, I conclude that the patient's neck pain referred to her left upper extremity is causally related to the motor vehicle accident an 3/19/10. If you need any lease further discussed in this report, please sincerely, raig W. Fultz, M.D. CWF/baf 64 ..N?VITSKY 11 OLSON &ISNESKI LLP A T T O R N E Y S A T L A W - April 1, 2011.- - Donna Samarya APR 0 4 2011 Claim Representative CONCORDVIL!<.E State Farm Insurance Company Me P.O. Box 41 Concordville, PA 19331 Rc: Our client: Mi Kyung Choi Your Insured: Young J. Choi & Mi K. Choi Claim th 38-L884-956 DOA: March 19, 2010 Dear Ms. Samarya: Please allow this letter to acknowledge your request that Mi Kyung Choi undergo an IME. I met with Mrs. Choi this week in order to discuss her options. She has indicated that she would like a court determination of good cause pursuant to Section 1796 of Pennsylvania's Motor Vehicle Financial Responsibility Law before submitting to such an exanl. If you would likc Mrs._Choi_to sign an authorization-form that will allow you_to contact her treating physicians, via phone, correspondence or otherwise. t obtain ainformation ccident of March eg 20110, 19, her medical condition and its causal connection to the motor vehicle she will be happy to do so. Please forward any such authorization form to my attention. Should you have any questions, or should you like to discuss this matter, please do not hesitate to contact my office. Ve ly gsn avi S. ki DSWlles 2040 Linglestown Road st Suite 303 a Harrisburg. PA 17110 Phone. (717) 541-9205 Fax: (717) 541-9206 Toll Free' 1-800-818-9608 www.nowllp cum 65 ? ? ! v aI MECHANICSBURG FAMILY MEDICINE CENTER CHOI, Mi K DOB: 02/2311967 SS* 249-72-0959 0210512404 S: Mi Choi returns this evening with continued complaints about anterior chest pain and abdominal pain. She was seen on 1127 and advised to take tantac twice a day. K this was not helpful.she was to switch to Rrilosec OTC. We have planned to schedule an EGD for her in the future. She reports that she had one in Vietnam over 10 years ago. The patient reports and her husband concurs that she continues to have anterior chest pain, which is worsening. This is not brought on by activity. She has no radiation of the pain or perspiration. It is communicated to me tonight that Mi works in a dry cleaners and is constantly lifting and hanging clothing and holding her arms up. Tonight Mi complains of lower back pain. She reports that 10 years ago she had a bade x-ray, which showed that she had a 'curved back.' She has persistent daily back pain. She uses hat compresses. O: Vital Signs: Normal. General: Mi is in no acute distress. Today is her birthday! Lungs: Clear. The patient is tender on palpation over the anterior stemum. EKG: Normal. A: 1. Primary costochondritis. 2. Secondary abdominal distress. 3. Back pain. P: 1. EGD has been scheduled at Pennsylvania Gastroenterology for April 7`?'. This information was relayed to the patient and to her husband. 2. An EKG was done tonight in the office, which was normal. 3. A gallbladder ultrasound is ordered and will be schedule tomorrow by the HMO office. 4. The patient was given samples of Prilosec OTC yesterday 214. She will continue to take these, one pill once a day. If there is no relief frorn this medication she will discontinue ii_ 6. She was also advised to utilize Aleve 2 tabled twice a day, everyday with food. This will decrease her anterior chest wall pain and her back pain. 6. Back x-ray is done tonight. 7. The husband is reassured, and reassured and reassured. 8. 1 will contact the patient with results. PATIENT NAME: CHOI, MI K Mx/ DO. 02105!2004 JANET LLY, CRNP DT: 02108/2004 8:24 Alcec D#: 1353948 66 IMagirtcj &7herape>rtit Assocl*hs,kK, P/aTtEN f AIAME CHOL M1 REFFRPING: JANET IA KELLY CRNP PROCEDURE Lis SPINE COMP WI OBL oos: 02M 1104 Exam: Lumbar spine complete 6 views. History: Low back pain radiating into the right leg. d.05 St. Jotw s CPw=h Roaid, SuM 102 CarM He, PA 17011 (717) 761-7470 Fax (M) 761.6291 www.4lta.eaan maw: 108262 Dos: 0212311907 F SS#: 209.72-mg OLW Im 11-00116706 A normal lumbar lordosis is present. The lumbar vertebral bodies have normal height and density. Lumbar vertebrai alignment is normal. There Is minimal narrowing of the 1-5-Si intervertebral disc. The remaining lumbar disc have normal height. Six lumbar-type vertebral bodies are IdentMed. The lowest vertebral body is labeled L5. The sacroiliac joa nts appear normal. The posterior elemerb of the lumbar spine are intact without degenerative change. impression: Mild narrowing of the L5-S1 intervertebral disc. DICTATED. KEITH HAIDET, MD 02111/2004 ELECTRONICALLY VERIFIED: KEITH NAIDET, MO 0211112004 ecarn #: E-W 116706 Page 1 CHOI,, U1 67 ------------ ------ MECHANICSBURG FAMILY MEDICINE CENTER CHOI, Ml K DOB: 02/2311967 SS#: 209-72-0959 OS/17/2NX S: This 37-year-oid female comes in today. The patient is accompanied by her husband who acts as a translator. The patient evidently has been having problems over the last five years with what is described as vertigo. The patient senses a spinning. The patient says these symptoms usually last 3-5 days and then tend to resolve. The patient does well for a long period of time. The patient evidently also in the past known to have a history of stomach disorders and was seen by Dr. Furlong and others in the past. Is doing well at this point on her medications. Evidently on a previous visit they did have an x-ray of the back and the patient is having back pain at times also. The patient now comes in today for assessment. O: Vital Signs: Raviewed and noted. HEENT: Ears - tympanic membranes intact without erythema. Eyes -pupils equal, round and reactive di light. Extraocular muscles intact. Fundi benign. During evaluation of the axtraocuiar ixiuscles the patient dd report increase of spinning sensation. Mouth without erythema. Neck: Supple without adenopethy or thyromegaly. Rungs: Clear. Heart. Regular rate and rhythm without murmurs. Abdomen: Saft. Positive bowel sounds, non tender. A: Veftiga. P: 1. Diagnostic - None today. 2. Treatment - Antivert 25 mg, #401 q.i.d. p.r.n.. two refills. 3. Patient Ed -- Advised patient at this point on rationale for vertigo. Advised that this is not likely to be a brain tumor or a stroke and more benign condition does occur sporadically. Advised husband at this point will address the vertigo and will leave other concerns about abdominal discomfort and low back pain to another visit. Return to office in one month or p.r n. for reassessment of the vertigo and reassessment of other complaints. PATIENT NAME: CHOI, Ml K DD: 05/1712004 BRIAN t1NIACKE, MD DT: 05119/2004 2:16 PAjk D#: 1415687 68 MECHANICSBURG FAMILY MEDICINE CENTER CHO), Ml K DOB: 0212311967 SS#: 208-72-0959 06122104 S: All( Choi is brought to the office today by her husband. The couple are Korean and Mi Choi does not speak English. Fier husband acts as her interpreter. The patient is very concerned about fatigue and dizziness. Her husband states that she is very weak. She has been feeling this way for quite some time. The patient states that many days she is unable to get out of the bed. There is a previous history of complex ovarian cysts for which surgery was performed. The patient also has andemetriosis. Q: Vital Signs: Normal. The patient is afebrile. She does. appear pale. General: She does not attempt to understand conversations. She looks to her husband. HEENT: ENT exam is normal. Lungs: Clear, Heart: Regular rate and rhythm without murmur. Abdomen.: Normal exam. Neurologic: Intact. A: 1. Recurring vertigo, fatigue P: Labs, CBC, TSH, CMP. CAT scan of the head is ordered at the request of the husband. The husband and the patient were advised as to rationale for vertigo. I reassured the husband that this is unlikely a brain tumor, however, he continues to be very concerned. MI Choi's spouse will be contacted regarding results of blood work, etc. PATIENT NAME: Choi, rni DD: 06122/2004 DT: 061231200410:47 Aide a#: 1436822 JANET KELLY, CRNP jib K-- 69 MECHANICSBURG FAMILY MEDICINE CENTER CH©I, MI K DOB: 02/23/1967 SS#: 209-72-0959 05/16/2005 S: MI comes in, today with her husband for multiple complaints. Her husband is serving as the Interpreter, although she does speak a small amount of English. She is coming for several complaints. The first is that for the past year she has had feat aching and swelling in her right foot. First it was on the medial side of her sole of her foot in the" plantar area and now it has moved up more above her ankle. It is still on the right medial side of the right ankle. In the past month it has been without pain, but she thinks it is going to recur again and seems very anxious and wants an x-ray of this. Nothing she does makes it feel better for a very long time. She has tried some Advil and pest ice on it. She is also complaining of being fatigued for a very , very long time. She states her periods are a very heavy flow, very painful, and very cramping. She works full-time. Her husband says she does not have ft energy that everyone else's wife has. She wakes up as tired as she goes to bed. She adamantly denied being depressed. She shook her head and felt that that was an absurd idea. She is also complaining of thirst. Denies urinary symptoms of frequency or urgency associated with it. Denial of any foot trauma at any time in the past year. Negative history for foot or ankle trauma at any time in Ilfe. Q: Vital Signs: Temperature: 98; blood pressure: 110/70; pulse: 66; respirations 12; height: 63.5 inches. There is a 4-pound weight gain sine June of 2004. General; well-appeasing ferrule in no acute distress. She was picking at her fleet the entire 45+ minutes prior to exam while I was examining her husband. She does appear pale, however this may be the color of her complexion. HEENT: Eyes: Wftixwt injection. Conjunctivae are pink. Lungs: Clear to auscuftadon. Heart: Regular rate and rhythm. Skin: Pink, warm and dry. Abdomen: No CVA tenderness. Integumert Hair: Shiny. Nails: Without spooning. Extremities: Brisk capillary refill. Feet bilaterally are scaly red with fungal onychomycosis infiltrate of the toenails. Appears all five on the right foot are affected. The toes and inner webs are red and excoriated with some broken areas from a tinea pedis. Tinea pedis is also along the edges of the heel and the plantar surface of the foot. This time of the skin feels very rough and dry. There is no pain on palpation over any area of the foot. She has full range of motion, +2 pulses, no edema, and no deformity. The patient does appear very anxious and insists that there is something wrong with her foot, ankle, and also that there is something wrong that she feels so tired all the time. A: 1. Fatigue. 2, Tinea pedis. 3. Right foot and ankle pain. P: 1. X-ray right foot and ankle. 2, Lotrimin W.d, to the feet 3. CBC, CMP and a urine was done which was normal. 70 MECHANICSBURG FAMILY MEDICINE CENTER CHOI, MI K DOB: 02/2TI 907 SS#: 209-72-0959 06102/2005 S: She is here today with symptoms of a UTI, She denies eastoverkebral angle tenderness but she does have dysuria and urgency. She is vrith her husband. She speaks no English. He speaks a little English. They are both Chinese. 0: General: No acute distress. Heart: Regular rate and rhythm. Lungs: Clear to auscultation. HEENT: Within normal limits. Abdomen: Soft with normal bowel sounds. She does have urgency with deep palpation over the bladder. Urine dip: Moderate blood, moderate leukocytes A: UTI, P- We did do a dip on the urine as said before. I did put her on Sactrim DS to take one twice a day for seven days. On further questioning although communication was diffieult, the husband says that she has chronic vertigo. She was diagnosed with her seera mes a year and years ago. He is gets put out of concerned because this does seem to strike commission with it according to him. I did authorize a referral with an ear, nose and throat specialist with regard to the vertigo. Communications were difficult. I think he verbalized understanding of my instructions on discharge. PATIENT NAME: Mi K. Choi DO: 06/02/2005 JOHN QOUGHERTY, DO DT: 0610612005 4:46 P/ttf _^' D#: 1657586 Is 71 f MECHANICSBURG FAMILY MEDICINE CENTER CHOI, MI K DOB- 02/2311967 SS#: 209-72-0959 03/2312006 S: Chief compiaint: Hand pain. HPI: Patient presents today without arty significant complaints, other than the fact that she has significant pain in her right hand. Patient states it has been ongoing now for a couple of months. Patient does work in a Laundromat and does a lot of stapling and thinks that might be the reason for the pain. Patient is having trouble every time she kind of tries to grip with her hand. Patient states the pain is across the palms of her hand. Patient's past medical history is poeltive for endometriosis. Social history: Patient is a nonsmoker. Patient is Korean and does not speak any English. Review of systems: Denies any fevers, chills or sweats. Patient admits to tenderness in her hand. Denies any numbness or tingling, denies any edema. ecchymosis or erythema. Remainder of review of systems is negative. O: Extremities: Right hand - Patient has tenderness over the right hand Itself. Patient has pain with contractions of the right hand. Patient states that she does not any Tinel's sign or Phalan's sign. Does not notice any paresthesias. Range of motion within normal limits. A&P: Hand pain: Suspected tendinitis within the flexor tendons of her hand. Wig try and find a splint that will restrict her movement for closure of her hand. We will also put the patient on anti-inflammatorles 500 mg, 1 tablet PO BID. Patient to kind of cut back on her work a little bit. Patient will try rest and ,y follow up pm. If not better, we will have her onto orthopaedics. PATIENT NAME: CHOI, MI K DO: 03/2312006 DT: 03/28/200e 7:57 Alad D#: 1850973 THOMPSON, III, ME) 72 Via`, MECHANICSBURG FAMILY MEDICINE CENTER CHOI, Ml K DOB: 42123!3 867 SS*: 208-72-0959 0406 her husband chooses to S: : She She is here today with her husband. Choi speaks some English, although speak for her, She is here today with complaints of continued dizziness, nausea and vomiting. This has been going on about seven years. She has had problems off and on, This has been happening once or twice a year for the last seven years and as of the last year it has been happening about every other month, She has been to the emergency room at least twice, They have diagnosed her with vertigo, given her anti-nausea medication I believe probably Meclizine, but her husband was not absolutely sure of the name of the medication. They have been purchasing over-the-counter medication for nausea such as I believe Dramamine. She tells me the medication makes her drowsy and she gets better if she stays in bed fOr a couple of days. He tells me that she did have a CT scan which was normal. She has had some labs done in 2044 which were fine, but she has not had any referrals and he is very frustrated that this continues and he wants to know the reason why, On review of her chart she has a history of hemorrhoids, endometriosis, and she has had an EGD and was positive for H. pylori. She has had a ookwoscopy which was normal. She has had a left ovarian cystectomy with benign lesion. She has had laser to treat the endometriosis. She is married and lives with her husband. She has two children. She is on no prescription medications other than Prilosec OTC and a multivitamin on occasion. She eats well and feels well in all other ways except for when she gets the nausea. The last time she was in for treatment of the nausea was in May of 2004 and she was treated with Antivert. At that time she was reassured, but now tkl the dizziness is happening more often, her husband is a little more concerned about that. On review of her chart the last labs that were done in 2005 show a normal CMP and a CBC with differential count. Prior b that she had a CT scan of the head that was normal. ROS: She denies chest pain, shortness of breath, cough, congestion, or fever. 0: Vital Signs: Stable. General: HIEENT: Pupils equal and reactive to light. EOMI. TMs and canals are clear, Throat is non-red. Neck: Negative enlarged lymph or thyroid. Lungs, Clear to auscultation and percussion. Heart: Regular rate and rhythm. Abdomen: Soft and nontender. EAremities: She has equal muscle tone and strength. Neurologic: Cranial nerves It-XII grossly intact. Her balance is Intact and her speech is intact. She arnbuiates well without difficulty. She is able to go from a sitting position to a laying position on the table and laying to sitting without difficulty. A: 1. Vertigo P: 1. Reassurance was attempted to husband and patient that since this has been gang on seven years, it is probably more of a chronic problem and not an acute problem. Tried to reassure that it was not a hemo"age or a brain tumor and that the CT scan was a good test to evaluate for that. 2, Advised that they have scheduled her for some labs since it has been a couple of years since she has had anything done. Also I will refer to an ENT and allow them to evaluate her ears, nose and throat system to make sure that is not causing any of the problems. I did do some teaching on vertigo and how that can cause symptoms periodically and intermittently over time. The patient and her husband were running late to pick up their son at school, so they had to leave in a hurry. 73 ??JOOl•?n• npn? Cps., ?'?n?G???90 MPC 04/36/201L rue 15,08 VRX VRIZIBTCATIQN I, Donna Sapurya, hereby verHy that I m *s rep omtitive of the Patltioner heroin, and that the facts setfbrth 1n the foregoing Petition to Compel Indexdept Medial Examination are tree and correct to the beat of vW lowwledga infonwfion and belief. I utAmtend thst Echo sudeamts hemin nude ace subject to the penaldea of 1$ Pa, C.S. § 4904 relating to ussworn Waiftosdon to authorides. 7 DONNA SAMARYA. Audwdnd &epre09tative Stan Farm Mutual Automobile Irlsmanee Company ee?oawo?;:oow ursr9n FILED-oi FICi. - i PROT1-'O"0--??. 2011 JUN -7 AM 11: 559 IN THE COURT OF COMMON PLEA ??gg8ERLANu t;tl1JN Y CUMBERLAND COUNTY, PENNSYLVAI II ENNS LVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Petitioner V. : MI KYONG CHOI, Respondent CIVIL ACTION - LAW NO: 11-4327 ENTRY OF APPEARANCE Please enter the appearance of David S. Wisneski, Esquire of Navitsky, Olson & Wisneski LL P on behalf of Respondent, Mi Kyong Choi, in the above-matter. Please serve all papers at 2040 Linglestown Road, Suite 303, Harrisburg, PA 17110 Respectfully submitted, NAVITSKY. OLSON & WISNESKI Date: ?_(_ /) David S? Wisneski, Esquires I.D. No. 58796 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Respondent CERTIFICATE OF SERVICE I, Lois Stauffer, an employee of the law firm of Navitsky, Olson & Wisneski LLP, hereby certify that a true and correct copy of the foregoing Entry of Appearance was served upon the following person via first-class United States mail, postage prepaid on June 6, 2011: Curtis Johnston, Esquire Bennett, Briclklin & Saltzburg, LLC 222 East Orange Street Lancaster, PA 17602 Counsel for Petitioner Z i Lois Stauffer IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Petitioner CIVIL ACTION - LAW NO: 11-4327 MI KYONG CHOI `- Respondent = == =, NOTICE TO PLEAD "'- c=> To: STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY c/o Curtis C. Johnston, Esquire Bennett, Bricklin & Saltzburg, LLC 222 East Orange Street Lancaster, PA 17602 You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment maybe entered against you. Respectfully submitted, NAVIT^Y, OA SON & AVISNESVIS?LP David S. Wikeski, Esquire I.D. No. 58796 Duane S. Barrick, Esquire I.D. No. 77400 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Respondent Date: June 8, 2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Petitioner CIVIL ACTION - LAW V. NO: 11-4327 MI KYONG CHOI, Respondent MI KYONG CHOI'S ANSWER WITH NEW MATTER TO STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY'S PETITION TO COMPEL INDEPENDENT MEDICAL EXAMINATION AND NOW, comes the Respondent, Mi Kyong Choi, by and through her attorneys, Navitsky, Olson & Wisneski LLP, to hereby enter the following Answer with New Matter to Petitioner State Farm Mutual Automobile Insurance Company's Petition to Compel Independent Medical Examination: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. By way of clarification, the policy provides the following with respect to the insured's duty to cooperate: a. The Insured must cooperate with us and, when asked, assist us in: (1) making settlements; (2) securing and giving evidence; and (3) attending, and getting witnesses to attend, depositions, hearings and trials. (emphasis added). Any inference or suggestion that the cited policy provisions allow Petitioner to circumvent the statutory a requirements regarding requests for independent medical examinations set forth at 75 Pa. C.S.A. § 1796 is specifically denied. 5. Admitted. 6. Admitted in part and denied in part. The factual allegations contained in paragraph 6 of the Petition are admitted, with the exception of Petitioner's allegation that "The impact caused relatively minor rear end property damage" to Respondent's vehicle, which is denied. To the contrary, the impact caused relatively significant damage, not all of which is depicted in the photographs attached to the Petition as Exhibit "B". 7. Admitted. 8. Admitted in part and denied in part. It is admitted that on March 22, 2010, Respondent presented to her family physician at Pennsylvania Family Care in Mechanicsburg, Pennsylvania. It is denied that Respondent used the term "musculoskeletal pain" when reporting her symptoms to her physician. Rather, Respondent complained of neck and arm pain resulting from the motor vehicle accident of March 19, 2010. See, Exhibit "A". It is admitted that the Respondent was referred for physical therapy. It is also admitted that she was released from work until April 12, 2010. 9. Admitted in part and denied in part. The factual allegations contained in paragraph 9 of the Petition are admitted, with the exception of the allegations that the Respondent has remained out of work to the present date and that her benefits will be exhausted on or about June 21, 2011. Respondent returned to work on a part-time, trial basis on April 18, 2011. Her return to work has resulted in a reduction of her monthly wage loss benefits and a change in the date on which they will be exhausted. See, Exhibit "B". 10. Admitted. 2 11. Admitted. 12. Admitted in part and denied in part. The factual allegations contained in paragraph 12 of the Petition are admitted, with the exception of the allegation that Dr. Fultz made any diagnosis of "pre-existing degenerative disc disease (DDD)." To the contrary, Dr. Fultz's diagnosis was "pain referred to interscapular area, upper extremity status post motor vehicle accident 3/19/10, possibly myofacial etiology versus cervical spine occult injury." See, Exhibit "C". 13. Admitted in part and denied in part. It is admitted that on May 10, 2010, Respondent underwent a cervical MRI. It is denied that Petitioner's characterization of the findings is entirely accurate. At C3-C4, the MRI revealed a central disc protrusion indenting the ventral thecal sac and flattening the spinal cord. At C5-C6, the MRI revealed a broad-based central disc bulge indenting the ventral thecal sac. The MRI also showed slight flattening of the cervical spinal cord at C3-C4 and C5-C6. See, MRI report attached hereto as Exhibit "D_." 14. Admitted. Any inference, however, that Dr. Fultz is of the opinion that Mrs. Choi's neck and shoulder pain are not directly related to the motor vehicle accident of March 19, 2010 is specifically denied. To the contrary, Dr. Fultz authored a March 31, 2011 report outlining the Respondent's course of treatment and specifically stating that: "It is my opinion with a reasonable degree of medical certainty that Mrs. Choi's neck pain referred to her left upper extremity which developed after the motor vehicle accident on March 19, 2010 is causally related to the motor vehicle accident of March 19, 2010. There is no history or medical records to suggest that the patient had any pre-existing symptomatic cervical spine pathology or any ongoing symptoms in the cervical spine referred to her upper extremities prior to the motor vehicle accident. She has not been asymptomatic since the motor vehicle accident. The algorithmic workup has identified a structural pain generator in the cervical spine at the C5-6 disc. In light of these facts, I conclude that the 3 patient's neck pain referred to her left upper extremity is causally related to the motor vehicle accident of March 19, 2010." (emphasis added) See, March 31, 2011 report of Dr. Fultz, attached hereto as Exhibit "E". 15. Admitted. 16. Admitted in part and denied in part. The factual allegations contained in paragraph 16 of the Petition are admitted, with the exception of the allegation that the cervical MRI "revealed DDD at C5-6." To the contrary, the MRI revealed a finding of "a broad-based central disc bulge indenting the ventral thecal sac. Slight flattening of the spinal cord without compression. The central spinal canal and neural foramina are normal." with respect to C5-C6. See, Exhibit "D." 17. Admitted. Any inference, however, that Respondent had recently seen Dr. Cho prior to the accident is specifically denied. To the contrary, it had been many years since Mrs. Choi had a been a patient of Dr. Cho's. Any inference that the discogram that was ultimately performed upon Mrs. Choi on January 31, 2010 was negative, and that Mrs. Choi was therefore deemed not to be a surgical candidate by Dr. Fultz, is also denied. To the contrary, the discogram was positive for concurrent pain at C5-6, and Dr. Fultz consequently deemed Respondent a surgical candidate. See, Exhibit "E." 18. Admitted in part and denied in part. It is admitted that on December 29, 2010, Respondent underwent a bone scan. It is denied that Petitioner's characterization of the findings on the bone scan is entirely accurate. In particular, it was noted that there was very minimal radioisotope uptake of the facet joints at C3-C4 and facet uptake to a mild degree at C5-C6. 4 19. Admitted. By way of further response, the intense concurrent response identified by the discogram is objective proof of the structural nature of the injury caused by the March 19, 2010 motor vehicle accident. See, Exhibit "E" at p. 4. 20. Admitted. Any inference, however, that Mrs. Choi had ever been treated by Dr. Cho for a cervical disc injury or problem is specifically denied, as is any inference that Mrs. Choi had been recently treated by Dr. Cho prior to the accident. To the contrary, it had been many years since Mrs. Choi had been a patient of Dr. Cho's. Any inference that Dr. Fultz is of the opinion that Mrs. Choi's neck and shoulder pain are not directly related to the motor vehicle accident of March 19, 2010 is also denied. See, Exhibit "E." 21. Admitted. However, any inference that Petitioner State Farm followed the appropriate procedure to obtain an independent medical exam of its own insured is specifically denied. 22. Admitted. 23. Denied. State Farm's policy must be interpreted in accordance with applicable statutory law, particularly 75 Pa. C. S.A. § 1796. Additionally, the State Farm policy in question does not contain a provision requiring its insured to submit to physical examination by a physician of its choice. 24-31. These are conclusions of law to which no response is required. To the extent any responses are deemed to be required, said conclusions of law are specifically denied. The cases cited by State Farm speak for themselves. Moreover, Mrs. Choi's medical records speak for themselves. Any characterizations by State Farm of legal citations that are inaccurate or any inaccurate representations derived from Mrs. Choi's actual medical records by State Farm should 5 1 .3 be discarded. Mrs. Choi's actual medical records should be controlling in any adjudication of this matter. By way of further response, Petitioner's first cited case, Fleming v. CNA Insurance Companies, 597 A.2d 1206 (Pa. Super. 1991) is factually distinguishable and thus, not relevant to the matter sub judice. In Fleming, the insurance policy from CNA specifically provided that the injured person "shall submit to physical examination by a physician of our choice." In the matter sub judice, State Farm's policy does not provide that Mrs. Choi "shall" submit to a physical examination by a physician of State Farm's choice. Rather, the instant State Farm policy only allows a physical examination - "Whenever the . . . physical condition of a person is material to any claim for medical expenses or income loss benefits, a court of competent jurisdiction may order the person to submit to a ... physical examination by a physician." Therefore, since the State Farm policy does not contain the requisite mandate that appeared in the CNA policy from the Fleming, the Fleming case is not applicable. Additionally, since there is no contract provision mandate in the instant State Farm policy, such as there was in Fleming, which trumps the established "good cause" and "material" requirements of the Pennsylvania's Motor Vehicle Financial Responsibility Law (MVFRL) [75 Pa. C.S.A. §1796], the Fleming case is not applicable to the matter before this Honorable Court. In the instant case, State Farm's policy provision regarding physical examinations clearly contemplates the statutory process set forth at 75 Pa. C.S.A. §1796, as it indicates that "A court ... may order...," and is subservient to the statutory requirements concerning physical examinations contained in Pennsylvania's MVFRL. Thus, in the instant case, the language of 75 Pa. C.S.A. §1796 is controlling. The second case cited by State Farm, Williams v. Allstate Insurance Co., 595 F. Supp. 2d 532 (E.D. Pa. 2009), is also easily distinguishable from the matter sub judice. Williams found 6 that §1796 of Pennsylvania's Motor Vehicle Financial Responsibility Law (MVFRL) was intended to be applied where the parties did not have a specific contractual agreement as to the requirement of medical examinations. See, Williams at 543. For example, if the insurance contract had specific language (as did the Williams' Allstate contract) requiring medical examinations, the contract would control. However, if the insurance contract did not have specific language requiring medical examinations, then § 1796 of the MVFRL would control. In the matter sub judice, there exists no specific contractual agreement or provision in State Farm's policy that requires that Mrs. Choi must undergo a medical examination. To the contrary, the express language of the instant State Farm insurance contract provides: Whenever the ... physical condition of a person is material to any claim for medical expenses or income loss benefits, a court of competent jurisdiction may order the person to submit to a ... physical examination by a physician. State Farm insurance contract P9838A, page 16, attached to State Farm's Petition. State Farm's policy is ambiguous with respect to whether good cause must be shown in order to obtain the examination. Pursuant to Williams, citing, Med Protective Co. v. Watkins, 198 F.3d 100, 103 (3d Cir. 1999), where "the language of an insurance contract is clear and unambiguous, a court is required to enforce that language." Furthermore, where an insurance policy provision is ambiguous, it is to be "construed against the insurer and in favor of the insured." Williams citing, McMillan v. State Mut. Life Assur., 922 F.2d 1073, 1075 (3d Cir. 1990); State Farm Fire Cas. Co. v. MacDonald, 850 A.2d 707, 710 (Pa. Super. 2004) (emphasis added). Since the insurance contract in Williams is completely different than the instant State Farm contract, any finding in Williams as to the validity of its Allstate contract is completely 7 irrelevant to any adjudication whether the instant State Farm contract is valid concerning medical examination of the insured. The contract of insurance in Williams was unambiguous, whereas the contract of insurance in the instant case, is very ambiguous. Moreover, the Williams court acknowledges that since the Allstate contract before them was so unambiguous, it did not entertain the point whether the physical examination in Williams was "reasonably required." In the matter sub judice, since the State Farm policy is ambiguous regarding physical examinations, a determination must be made as to whether the physical examination of Mrs. Choi is "reasonably required." This goes to the "material" and "good cause" thresholds, which must be met for physical examination to occur in the absence of the necessary unambiguous insurance contract language in the instant matter. State Farm's final case, State Farm v. Swantner, 594 A.2d 316 (Pa. Super. 1991), actually supports Mrs. Choi's position. Swantner taught us that "when" the ... physical condition of the person was "material" to a claim for medical, income loss or catastrophic loss benefits, and proof presented "established good cause" to evaluate that condition, an independent physical examination could be ordered. The Swantner court taught us that "mere desire on the part of an attorney to know what his adversaries believe or mere desire to change a condition is not itself the "good cause" required to support a motion to compel persons to submit to a medical examination, under the provision of the Motor Vehicle Financial Responsibility Law" [75 Pa. C.S.A. §1796(a)]. A Motion to Compel a party to submit to a medical examination under the Motor Vehicle Financial Responsibility Law, will not be granted solely because there is a controversy or desire to know. The entire focus must be on the condition that is material to the claim. 14A Summ. Pa. Jur 2d Insurance § 16:150, citing Swantner. In the instant case, the entire focus is on Mrs. Choi's neck problems. A court could order an accident victim to submit to an 8 independent medical examination, under the Motor Vehicle Financial Responsibility Law, where her physical condition was material to her claim for entitlement to insurance benefits for medical treatment and it was evident that all reasonable non-intrusive means had been pursued. The Swantner court stated the requirement that the movant must show good cause for an order to compel persons seeking medical treatment benefits to submit to physical examination by physician was to prevent harassment, untoward intrusion, and unwarranted examination of persons claiming benefits. What is good cause depends on the circumstances of the individual case, and finding of its existence lies largely in the discretion of the officer of the Court making the decision. Swantner, supra, and Horne v. Sentry Ins. Co., 588 A.2d 546 (Pa. Super. 1991). An appellate court will not reverse the trial court's decision on the matter absent a palpable abuse of discretion. 14A Summ. Pa. Jur. 2d Insurance U7:29 citing, Horne. A good cause showing requires a certain amount of specificity so that an insured will not be required to attend an unnecessary examination sought in bad faith. McDaniel v. State Farm Mut. Auto. Ins. Co., 6 Pa. D. & C. 4th 520 (C.P. Mercer 1990); Keystone Ins. Co. v. Chenowith, 3 Pa. D & C. 4th 637 (C.P. Montgomery 1989) and Horne, supra. Mere allegations unsupported by developed record, are insufficient cause to order a medical examination. Swantner, supra, and Keystone Ins. Co. v. Caputo, 529 A.2d 1134 (Pa. Super. 1987). The insurance company must provide a factual basis to raise any questions concerning the accuracy of present treatment, or the adequacy of proof of injury and the insurer must provide specific facts to demonstrate in what respect insured's proof of her claims was inadequate, or indicate which medical treatment it had reason to question. Horne, supra. 9 In the matter sub judice, State Farm has failed to provide a factual basis to raise any questions concerning the adequacy of Mrs. Choi's present treatment, or the adequacy of Mrs. Choi's injury to her cervical spine, and State Farm has failed to provide specific facts to demonstrate in what respect the medical records they have in their possession are inadequate proof of Mrs. Choi's claims or to question which medical treatment by Dr. Fultz or her physical therapists State Farm has reason to question. It is important to note, that prior to the rear end collision, which is the basis for the instant matter, Mrs. Choi only complained of low back pain. Subsequent to the accident, she has had problems with her neck, or the cervical area of her spine. All of her diagnostic tests, physical therapy treatments, and assessments by the orthopedic surgeon, Dr. Craig Fultz, have been focused on her cervical spine, or her neck area. State Farm has failed to provide any documentation or credible arguments to establish that the requested physical examination will in any way determine any correlation between Mrs. Choi's history of low back problems and her objective physical findings on diagnostic tests and by assessment by Dr. Craig Fultz as to her current neck problems. As such, State Farm has failed to prove that they have good cause for the ordering of a physical examination of Mrs. Choi. State Farm has also failed to prove that Mrs. Choi's history of having low back problems is in any way material to her current problems with her neck, which occurred subsequent to the rear end collision. State Farm has also failed to allege or provide support that any of the findings from Mrs. Choi's objective diagnostic testing or the findings of Mrs. Choi's treating orthopedic surgeon, Dr. Craig Fultz, are in any way inaccurate in establishing a causal connection between the rear end collision and Mrs. Choi's subsequent neck problems. Pursuant to Horne v. Sentry Ins. Co., 588 A.2d 546 (Pa. Super. 1991), State Farm must provide a factual basis to raise any questions concerning the adequacy of Mrs. Choi's present treatment, or the adequacy of proof of her 10 injury, and State Farm must provide specific facts to demonstrate in what respect Mrs. Choi's proof of her claims was inadequate, or indicate which medical treatment of Mrs. Choi State Farm has reason to question. 14A Summ. Pa. Jur. 2d Insurance § 17.30 and § 16:151. Furthermore, State Farm has less intrusive options available to them other than a physical examination. See, Swantner, supra and Nationwide v. Hoch, 36 Pa. D&C 4th 256 (C.P. Allegheny 1997). These less intrusive options include obtaining all of Mrs. Choi's medical records (which it is presumed they have done - Please see Exhibit "F" below) and reviewing the medical records of Mrs. Choi forwarded to them by undersigned counsel (Please see Exhibit "G"). Mrs. Choi's medical records and Dr. Fultz's report are adequate to address State Farm's needs and to answer any questions they may have regarding the causal connection between the rear end motor vehicle accident and Mrs. Choi's neck problems. At the beginning of this process, and as recent as within the last ninety day, Mrs. Choi executed authorizations for State Farm to obtain all of her medical records. Therefore, State Farm has at its disposal, the ability and adequacy to review the records of Mrs. Choi's treating physicians and of her diagnostic tests to answer any questions they may possess. WHEREFORE, Respondent respectfully requests that this Honorable Court deny State Farm's request for physical examination as without foundation. NEW MATTER 32. Respondent, Mi Kyong Choi, had no medical history of neck pain prior to the accident that is the subject of this litigation. 33. Respondent's medical records do not contain any evidence of any complaint of neck pain prior to the accident that is the subject of this litigation. 11 34. The January 31, 2010 discogram performed upon the respondent, which revealed intense concurrent pain on injection of the C5-6 disc, provides objective proof of the structural nature of the source of Respondent's neck pain. 35. Respondent's treating orthopedic surgeon, Craig W. Fultz, M.D., with a reasonable degree of medical certainty, directly relates Respondent's neck pain referred to her left upper extremity to the motor vehicle accident of March 19, 2010. See, Exhibit "E". 36. No medical care provider has indicated that Respondent's neck pain referred to her left upper extremity is not related to the motor vehicle accident of March 19, 2010. 37. Dr. Fultz has indicated that Respondent may have to undergo surgery to treat her accident-related injury. See, Exhibit "E." 38. Petitioner State Farm's insurance policy is ambiguous with respect to whether "good cause" is required for an independent medical examination of its own insured. 39. Petitioner State Farm's insurance policy does not contain a provision requiring its insured to submit to a physical examination by a physician of its choice. 40. Petitioner State Farm did not pursue less intrusive means to answer questions they may have regarding Mrs. Choi's medical condition. 41. Petitioner State Farm, has failed to provide a factual basis to raise any questions concerning the adequacy of Mrs. Choi's present medical treatment. 42. Petitioner State Farm, has failed to provide a factual basis to raise any questions concerning the adequacy of proof of Mrs. Choi's injury. 43. Petitioner State Farm, has failed to provide specific facts to demonstrate in what respect Mrs. Choi's proof of her claims is inadequate. 12 44. Petitioner, State Farm, has failed to indicate which medical treatment of Mrs. Choi State Farm has reason to question. 45. Faced with the prospect of having to pay for surgery, Petitioner seeks the independent medical examination in an attempt to escape its contractual obligations to Respondent. 46. Petitioner State Farm has failed to comply with the statutory requirements of 75 Pa. C.S.A. §1796 relating to independent medical examinations. WHEREFORE, Respondent respectfully requests that this Honorable Court deny State Farm's request for an independent medical examination. Respectfully submitted, NAVI KY, SON WISNESKI LLP David S. Wisneski, Esquire I.D. No. 58796 Duane S. Barrick, Esquire I.D. No. 77400 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Respondent Date: June 8, 2011 13 VERIFICATION I, Mi Kyong Choi, verify that the facts set forth in the foregoing Answer with New Matter are true and correct to the best of my knowledge, information and belief. I understand that this verification is made subject to the provisions of 18 Pa. C.S. §4904, relating to the unsworn falsification to authorities. Mi Kyong Choi Date: 6- k-2 oil CERTIFICATE OF SERVICE I, Lois Stauffer, an employee of the law firm of Navitsky, Olson & Wisneski LLP, hereby certify that a true and correct copy of the foregoing Mi Kyong Choi's Answer with New Matter to State Farm Mutual Automobile Insurance Company's Petition to Compel Independent Medical Examination was served upon the following person via first-class United States mail, postage prepaid on June 8, 2011: Curtis Johnston, Esquire Bennett, Bricklin & Saltzburg, LLC 222 East Orange Street Lancaster, PA 17602 Counsel for Petitioner Lois Stauffer ?X#s iT 4,%> PINNACLE HEALTH 03/22/2010 5:35 PM PATIENT: DATE OF BIRTH: DATE: VISIT TYPE: FAMILY CARE MECHANICSBURG 910 CENTURY DRIVE MECHANICSBURG. PA 17055 Phone: (717)5064720 Fax: (717)506-4734 MI K CHOI 02/2311967 03/2212010 4:30 PM Office Visit 9 03 Reasonis for visit 1. mva 2. Musculoskeletal Pain Onset 3 Day(s) ago. It occurs constantly and is worsening. Location: (arm) neck. is There was no radiation. The pain is aching. Context there was an injury and motor vehicle accident The pain aggravated by movement. There are no relieving factors. Associated symptoms include decreased mobility, difficulty going to sleep, tenderness and weakness. Past Medical History Reviewed, no changes. Family History Reviewed, no changes. Soclal History, Reviewed, no changes. The patient is a non-smoker. Review of Systems Musculoskeletal: Positive for. - Bonefjoint symptoms. Joint/Bone: neck. Side: bilateral. Symptoms: stiffness. The severity is described as mild. Improved by NSAIDs. JointtBone: arm. Side: left. Symptoms: aches. The severity is described as mild. Joint/Bone: shoulder. Side: left Symptoms: aches. The severity is described as mild. Trauma occured. Type: MVA. When: last week. Comments: seen in ED; xrays negative for fractures. Soft cervical collar, predniisone, vicodin, valium. - Muscle weakness. - Neck stiffness. See History of Present Illness. Vital Signs P-P Tom F Pulses &W Rate Ht in 115 110/70 98.4 78 18 Comments Pain Score Z? CHOI, MI K 02/23/1967 7n M exam Constitutional= Level of distress is in pain. Well nourished. Well developed- Musculoskeletal: moderately reduced ROM Cervical spine has muscle spasm, Left shoulder has sling in place Clinical Assessment The patient is a 43-year old female who presents with mva and musculoskeletal pain. Assessrnen Pip 719.41) Pain in joint Involving shoulder region Mock sprain (847.0) on vicodin, valium,prednisone Referrals Trneframe Status Physician al Therapy ordered Refer to drayer PhYsg ordered Refer to Physical 7heraPy Patient Plan: Instructions Refer to Physical Therapy Refer to drayer Physical Therapy nosis 847.0 719.41 Provider. JANET KELLY CRNP Document generated by: Janet Kelly 03/22/2010 5:35 PM Reason 7n CHOI, M,1 K 02123/1967 13/ NAVITSKY, OLSON & WISNESKI LLP A T T O R N E Y S A T L A W Via Certified Mail, Return Receipt Requested Donna Samarya Claim Representative State Farm Insurance Company P.O. Box 41 Concordville, PA 19331 June 3, 2011 Re: Our client: Mi Kyung Choi Your Insured: Young J. Choi & Mi K. Choi Claim #: 38-L884-956 DOA: March 19, 2010 Dear Ms. Samarya: Enclosed please find the State Farm Loss of Earnings Check, No. 1 13 594228 J, dated May 24, 2011, in the amount of $1,000.00 that was issued to Mi Kyung Choi for the wage loss period of April 22, 2011 through May 21, 2011. I am returning the check because it represents an overpayment of the benefits owed to Mrs. Choi. Please be advised that Mrs. Choi returned to work on a part-time, trial basis on April 18, 2011. She has been working approximately 20 hours per week. Enclosed please copies of her pay stubs for the pay period of April 18, 2011 through May 15, 2011. I will provide you with a copy of the pay stub from May 16, 2011 through May 31, 2011 as soon as I am receipt of same. I ask that the benefit owed to Mrs. Choi be recalculated in light of the fact that she has had earnings, and that a new wage loss check in the appropriate amount be issued to her. Although Mrs. Choi has been attempting to work, she still continues to experience considerable neck pain. It is unclear, at this time, whether she will be able to continue in her position. I will keep you apprised of any changes to her employment status. Thank you for your attention to this matter. DSW/les Enclosures cc: Mr. and Mrs. Choi (w/out enc.) Ve ruly y rs, av'd S. isnes i 2040 Linglestown Road • Suite 303 • Harrisburg, PA 17110 Phone: (717) 541-9205 Fax: (717) 541-9206 Toll Free: 1-800-818-9608 www.nowllp.com ?Yfh73?? l ORTHOPAEDIC SURGEONS OF CENTRAL PAS LTD. ACCOUNT # 122513 CHOi „ MI K 5 CARDAMON DRIVE CHART SS # # 2 02244314 314 9 MECHANICSBURG,PA 17050 April 29, 2010 LEMOYNE OFFICE ( 1 Q ?J N ENTIAL hiEDiCAL RECORD CONSULTATION: Janet Kelly, CRNP For Professional Use Only DOB : 2 / 2 3 / b 7 3? L p'?'l? •- 9Sb PfOpertY OP Orthopaedic Sufgcons or central Pennsylvania, LTD. CHIEF COMPLAINT: "My neck and shoulder hurt". HISTORY OF PRESENT ILLNESS: Mi Choi is a 43 year old right hand dominant female, who reports being involved in a motor vehicle accident on 3/19/10. She was the driver wearing a lap shoulder strap. The area of impact was the rear of her automobile. Initially, she did not think she had any significant injuries, but within one hour stara?l?wdevvelopina significant pain down her neck, difficulty headache. She was taken to Holy Spirit Hospital where she reportedly had a CT scan of her head and x-rays fliene k.was She She brings the x-rays of her neck along for my review. She treated with hydrocodone, Prenand and Dwaze?t to Drayer followed up with her family physician Physical Therapy. She has had fourteen sessions of buerapy and notes she is seeing an improvement in her symptoms, recoto curt office in consultation resolution. She is now referred for evaluation and treatment On presentation today, the patient is complaining of pain in her bilaterally upper neck radiating into her periscapular area, extremities to a greater degree on the left side. describes herself as having pain quadrilaterally, 9 dysesthesias quadrilaterally to a greater degree in the left arm. She rescribed currently taking Darvocet in addition to the Diazepam prescribed by her family physician. She is also complaining of other polyarthralgias, low back pain for which she is not her forneck these to be evaluated. She denies any previous history injuries, neck pain or shoulder upper extremity injuries or pain. PAST MEDICAL HISTORY: I reviewed with the patient her past medical history. She has had no recent hospitalizations. Medical illnesses: Patient is having back pain, chronic headaches and neck pain from the automobile accident. She denies any previous history of that. Medications: Prednisone, Hydrocodone, Diazepam and Darvocet. - CONTINUED - RE-?- MAY 17 2010 CONCOPMMtZ CtOS 27 ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. CHOI „MI K 5 CARDAMON DRIVE MECHANICSBURG,PA 17050 RECO 04/29/2010 LEMOYI? MMUAL MEDICEiL Only 3 Page 2 For ProfeV;iona"U c Surgeons properly of. Orthopwdic of Central PennaylVAnia. LTD. Allergies: NKDA. ACCOUNT # 122513 CHART # 024314 SS # 209720959 C(Olpy social history: She is a right hand dominant individual, denies any tobacco use, ethanol consumption. Family history: Negative for diabetes, hypertension, cancer, heart disease. PHYSICAL EXAMINATION: Physical examination today demonstrates inches, weight 112 pounds, blood . She height t 5 feet 3 e Patient is awake, alert, oriented x 3 pressure is in no acute distress. Examination of the cervical spine demonstrates diffuse tenderness-over the paracervical muscles, periscapular muscles. Negative impingement testing, negative Hawkins test. She has good range of motion of her shoulders. Subjectively she has circumferential decreased sensory acuity in the left upper extremity. There is no focal motor deficits. Reflexes are symmetrical. Negative Hoffmann's reflex. She has no clonusin the lower extremities and negative Babinski reflex. She appears to have symmetrical soft tissue pain in her cervical, thoracic and lumbar spine. Her shoulders have no glenohumeral instability, no mechanical symptoms and no focal motor deficits on manual muscle testing. DIAGNOSTIC STUDIES: X-rays of her cervical spine from Holy Spirit was reviewed. There is no evidence of any acute fracture or bony destruction. There is some mild degenerative change at the C5-6 with narrowing of the disc space. No abnormal soft tissue swelling. DIAGNOSIS: Pain referred to intrascapular area, upper extremity status post motor vehicle accident 3/19/10, possibly myofascial etiology versus cervical spine occult injury. PLAN: I advised the patient, as well as her husband my clinical impressions. I suspect she has a myofascial injury, but would recommend an MRI scan of her cervical spine to make sure there is no cord injury or other significant structural abnormalities that may benefit from orthopaedic intervention. If this is negative, I believe she would be best managed by a physical medicine pain management physician and we will refer her to the 28 f a ORTHOPAEDIC SURGEONS OF CENTRAL PA, LTD. CHOI „MI K 5 CARDAMON DRIVE MECHANICSBURG,PA 17050 04/29/2010 LEMOYNE OFFICE Page 3 ACCOUNT # 122513 CHART # 024314 SS # 209720959 CC PWI same if there is no pathology identified that would benefit from orthopedic surgical intervention. We will keep her off work and she is to follow up after the MRI scan. CONFIDENTIAL MED'CAL RECORD Completed by Craig W. Fultz, M.D. For Professional Use Only Propcrly of. Orthopaedic Surgeons CWF/baf of Central Pennsylyanla. LTD. DD: 04/29/10 DT: 05/05/10 Next appointment: 5/27/10 Craig W. Fultz, M.D. TK-fax sent to Janet Kelly, CRNP 29 ?????? rrom. iwt, i u. ?..ra!u vr. ruaz. Patient: Choi, NU K MRN: 14012 DOB: 23 Feb 1967 Date of Exam: 10 May 2010 Date: 511 112 0 10 ime: 7:31:44 AM Patin 'acne: Choi, Mi K Exam Date: May l 0 #1 .' C ...... .................. . 11t N5-CKNTRR Ref. Dr.: Craig W. Fultz MD FINAL Diagnostic Imaging Report MRI CERVICAL SPINE W/O CONTRAST Report Exam: MRI: Cervical Spine: Indication: Neck pain. Numbness - arms. Technique: 1.5 Tesla Sag T2, T1 / Ax MERGE, COSMIC Per "i shoulder Findings: Mild reversal of the upper cervical lordosis which could be secondary to patient positioning or muscle spasm. The vertebral bodies maintain their height. Discogenic endplate changes at C5-C6. Axial images were obtained from C2 through TI. C2-C3: Normal. C3-C4: Central disc protrusion indenting the ventral thecal sac and flattening the spinal cord. Protruded disc touches the spinal cord without compression (series 8, image 29). The central spinal canal and the neural foramina are normal. C4-C5: Normal. C5-C6: A broad-based central disc bulge indenting the ventral thecal sac. Slight flattening of the spinal cord without compression. The central spinal canal and the neural foramina are normal. C6-C7 and C7-T1: Normal. The visualized posterior fossa is normal. The cervical spinal cord maintains normal signal throughout. Page 1 of 2 ?11D, 4665 Trindle Road Mechanicsburg PA 17050 717.975.0444 Fax 717.731.9165 www.micmri.com Date: 5/11/2010 Time: 7:31:44 AM Path, 'name: Choi, Mi K Exam Date: May 0 Conclusion: 1. A disc protrusion at C3-C4 which touches the spinal cord without compression. 2. A broad-based central disc C5-C6. 3. Slight flattening of the cervical spinal cord at C3-C4 and C5-C6. Normal cord signal throughout. 4. The neural foramina are normal. Reported by Kiran Kapadia on 11 May 2010 at 07:52 a_m Electronically signed by Kiran Kapadia on at 07:52 a.m Page 2 of 2 4665 Trindle Road Mechanicsburg PA 17050 717.975.0444 Fax 717.731.9165 www.micmri.com ?x??;T athopaedic Surgeons of Central Pennsylvania, LTD. 550 N. 12th Street, Suite 140, Lemoyne, PA 17043 (717) 901-8000 Fax (717) 761-6860 Craig W. Fultz, M.D. Robert J. Maurer, M.D. Eric M. Kutz, D.O. Jeffrey W. Finn, M.D. Brandy M. Komykoski, PA-C March 31, 2011 David S. Wisneski NAVITSKY, OLSON, & WISNESKI, LLP 2040 Linglestown Road Suite 303 Harrisburg, PA 17110 RE: Mi Kyong Choi DOB: 2/23/67 Dear Mr. Wisneski: I am writing in response to your regarding Mi Kyong Choi, injury vehicle accident on 3/19/10 for treated her for. letter dated March 30, 2011 that she sustained in a motor which I have evaluated and Ms. Choi is a 44 year old right hand dominant female, who first presented to my office on April 29, 2010 after reportedly being involved in a motor vehicle accident on 3/19/10. She claims that she was a driver wearing a lap and shoulder strap at the time of the motor vehicle accident. The area of impact was the rear of her automobile. Initially she did not think she had any significant injuries, but within one hour started developing significant pain in her neck, difficulty swallowing and had a headache. She was taken to Holy Spirit Hospital where reportedly a CT scan of her head and x-rays of her neck were obtained. She brought the x-rays of her neck along to that office visit for me to review. She was treated with Hydrocodone, Prednisone and Diazepam. She followed up with her family physician and was treated with physical therapy at Drayer Physical Therapy. The therapy reportedly improved her symptoms, but did not resolve them. Her complaint at the time of her initial evaluation was neck pain radiating into her periscapular area, bilateral upper extremities, to a greater degree on the left side. She describes herself as having quadrilateral dysesthesias. The Providing Quality Orthopaedic Care to Central Pennsylvania RE: MI K Choi March 31, 2011 Page 2 patient denied any previous history of neck injuries, neck pain or shoulder/upper extremity injuries that caused any pain or any symptoms prior to this motor vehicle accident. It was my opinion after examining the patient, reviewing her x-rays, her diagnosis was pain referred to her infrascapular area, upper extremity status post motor vehicle accident on 3/19/10, possible myofascial etiology versus occult cervical spine injury. I recommended the patient get an MRI scan of the cervical spine to better define the injuries to her cervical spine, rule out any significant structural abnormalities that may not be evident on the available diagnostic studies. That study was completed on 5/10/10. She followed up in my office on 5/27/10 for follow up evaluation and review of that study. On 5/27/10 she was still having ongoing symptoms. She complained of pain in her neck radiating into her periscapular and bilateral upper extremities, to a greater degree on the left side. Her MRI scan was reviewed by me. It showed a central disc prominence at C3-4 and C5-6. Both of these impinged on the thecal sac, but no abnormal cord signal. There was disc desiccation as well as discogenic end plate changes at C5-6. There is no evidence of any acute fractures. It was my impression her diagnoses at that time included: 1. Pain referred to the intrascapular area, upper extremity status post motor vehicle accident 3/19/10 with possible myofascial etiology versus occult cervical spine injury. Additionally, she had degenerative disc disease and disc protrusion C3-4 and C5-6 of unclear significance. Given that she had a nondiscrete radicular pattern of symptoms, I had recommended EMGs and nerve conduction studies to better define the potential source of her symptoms. These were completed on 6/21/10 by Dr. Violago. The study of her cervical spine and upper extremities was within normal limits. She was additionally sent for C5-6 epidural steroid injection which was carried out on 6/28/10. She saw excellent short term pain relief with that epidural steroid injection. She subsequently had three epidural steroid injections carried out at the C5-6 level, each giving her short term pain relief. As she was followed along in a serial fashion, she continued to have neck pain primarily radiating into the left upper extremity in the C6 distribution. On 12/27/10 she was reevaluated by me. She presented complaining of pain and numbness in the left side of her neck, radiating into her left upper extremity. It appeared to be primarily the C6 distribution. She was not having any radicular RE: MI K Choi March 31, 2011 Page 3 symptoms with Valsalva maneuvers, no loss of bowel or bladder control, no myelopathic symptoms. I reviewed with the patient, as well as her husband, my clinical impression that her symptoms appear to be largely coming from the C5-6 level. We discussed nonoperative treatment options versus surgical intervention. They wished to pursue surgical intervention, which I believe would be the best chance at improving her symptoms. I recommend an algorithmic work up to make sure there was no other potential structural pain generators in her spine besides the C5-6 disc. This would include a bone scan with SPELT, as well as discograms. They desired to proceed with those diagnostic studies. On 1/31/11 she had discograms completed of her cervical spine. She had a positive concordant discogram at C5-6, negative at C3-4 and C4-5. She had a bone scan with SPECT which showed some increased uptake in the left facet at C3-4, and the end plates of C5-6. Her last evaluation by me was on 2/10/11. She presented to our office after having the discogram and bone scan completed. The patient was continuing to have pain referred to her left upper extremity. The pain primarily followed a C6 distribution on the left side. She has decreased sensation in the C6 distribution in her biceps area and radial aspect of her forearm and first web space. Lhermitte's test caused reproduction of C6 radicular symptoms in the left upper extremity. The patient and her husband were advised on my clinical impression and diagnoses. It was my opinion her diagnoses were: 1. Pain referred to the infrascapular area of upper extremity status post motor vehicle accident 3/19/10. 2. Degenerative disc disease with disc protrusion C3-4, C5-6 of unclear significance. 3. Pain in C6 distribution with concordant response to C5-6 on discogram. I explained to the patient and her husband the implications of these diagnostic study results. I discussed treatment options including surgical option of anterior cervical discectomy with interbody fusion at C5-6 versus noninterventional pain management. She wished to pursue the pain management for a period of time before proceeding with any surgical intervention. We referred her to Dr. Cho for evaluation and treatment for noninterventional pain management. They will contact my office when they wish to proceed with the surgical intervention. I advised her on the treatment time lines that would need to occur or diagnostic studies would need to be repeated if they become outdated. They state they understand. (11 A RE: MI K Choi March 31, 2011 Page 4 It is my opinion that the patient's best chance at improving her symptoms would be an anterior cervical discectomy with interbody fusion at C5-6 level. The prognosis with surgical intervention given her diagnostic studies and response to the C5-6 epidurals would suggest there is a high probability of marked improvement of her symptoms with that surgical procedure. The surgical fees for that procedure are $8,300.00. I am unable to estimate the hospital costs or associated potential therapy costs during the perioperative time. It is my opinion with a reasonable degree of medical certainty that Mrs. Choi' neck pain referred to her left upper extremity which developed after the motor vehicle accident on 3/19/10 is causally related to the motor vehicle accident on 3/19/10. There is no history or medial records to suggest that the patient had any preexisting symptomatic cervical spine pathology or any ongoing symptoms in the cervical spine referred to her upper extremities prior to the motor vehicle accident. She has not been asymptomatic since the motor vehicle accident. The algorithmic work up has identified a structural pain generator in the cervical spine at the C5-6 disc. In light of these facts, I conclude that the patient's neck pain referred to her left upper extremity is causally related to the motor vehicle accident on 3/19/10. If you need any further clarifications on issues discussed in this report, please feel free to contact me. Sincerely, raig W. Fultz, M.D?-?? CWF/baf ?,YthB?T G NAVITSKY, OLSON & WISNESKI LLP A T T O R N E Y S A T L A W March 24, 2011 Donna Samarya Claim Representative State Farm Insurance Company P.O. Box 41 Concordville, PA 19331 Re: Our client: Mi Kyung Choi Your Insured: Young J. Choi & Mi K. Choi Claim 38-L884-956 DOA: March 19, 2010 Dear Ms. Samarya: Pursuant to your request, enclosed please find the Authorization for Release of Information form executed by Mrs. Choi. Should you have any questions, or require anything further, please do not hesitate to contact my office. Ve y rs, David S. Wisneski DSW/les Enclosures 2040 Linglestown Road • Suite 303 • Harrisburg, PA 17110 Phone: (717) 541-9205 Fax: (717) 541-9206 Toll Free: 1-800-818-9608 www.nowllp.com fTATt tAAM INf Yf ANC® C AUTHORIZATION FORC RELEASE OF INFORMATION NOTE: Property and Casualty insurance is excluded from the definition of "health plan" in the privacy rules developed pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and is not a covered entity. However, this authorization meets the core elements criteria set forth in the HIPAA privacy rule, Section 164.508 (c). Name of Injured Person:Ml KYONG CHOI (hereinafter referred to as the "Injured Person") Social Security Number of Injured Person: ) o Y-7 2- 6 IrSYf (needed to locate records) Date of birth of Injured Person: 2/23/1967 (needed to locate records) State Farm Claim No.: 38-1-884-956 I authorize: (1) any medical, , osteopathic or chiropractic physician, dentist, any other medical practitioner or healthcare provider, hospital, clinic, rehabilitation facility, nursing home, or any other healthcare facility to disclose information from the medical and healthcare records of the Injured Person. I understand that the specific type of information to be disclosed includes, but is not limited to, medical and healthcare records and any other information including any history, treatment records, diagnosis, prognosis, narrative reports, and billing records. T4t0e- icn ns, c ; and (2) any firm, employer, or insurance company to furnish information about the earnings, loss of earnings, work history, workers' compensation claim, and other medical information in its/their possession concerning the Injured Person, as well as, Event Data Recorder (EDR) information, photographs and other information about the physical damage to the vehicle(s) involved in the accident; and (3) any educational organization to furnish the school records of the Injured Person to State Farm Mutual Automobile Insurance Company, its subsidiaries and affiliates, its claim associates, and legal representatives (hereinafter referred to collectively as "State Farm"). authorize the use of the above information to permit State Farm to investigate, process, and determine the amount payable, if any, for all claims made under any State Farm property and casualty insurance policy that applies to the accident or occurrence on 3/19/2010. 1 understand as part of the claim handling process, State Farm may disclose medical or other information obtained by this authorization to physicians, dentists, other medical or healthcare providers or other professionals for their review and professional opinion. This information may also be released to other insurance companies for their use in connection with insurance transactions, or as required or permitted by law. Information obtained pursuant to this authorization may later be redisclosed and may not be protected under the HIPAA privacy rule. I understand that I may refuse to authorize disclosure of all or some of the requested information, but that refusal may potentially cause a delay in processing, or result in the denial of, insurance benefits for the pending injury claim(s). This authorization may be revoked at any time, except to the extent that State Farm has taken action in reliance on this authorization prior to notice of revocation. Such revocation must be in writing, dated, signed, and include the claim number referenced above. I understand that revocation of this authorization may potentially cause a delay in processing, or result in the denial of, insurance benefits for the pending injury claims(s). This authorization is valid for the duration of the claim referenced above, and a photocopy is as valid as the original. This authorization specifically applies to records made before, during, and after the date of signing this authorization for as long as the authorization is in effect. have read the authorization and signed this document as a free and voluntary act for the purposes noted above. I understand that I may obtain a copy of this authorization upon written request submitted to State Farm. Any person who knowingly and with intent to defraud any insurance company or other person files an application for insurance or a statement of claim containing any materially false information or conceals for the purpose of misleading, information concerning any fact material thereto commits a fraudulent insurance act, which is a crime and subjects such person to criminal and civil penalties. Date: 3/_ 4Z f Signature of indi ' al o ersonal representative Description of personal representative's authority or relationship to patient 105397.8 Rev. 07-20-2004 , NAVITSKY, OLSON & WISNESKI LLP A T T O R N E Y S A T L A W April 1, 2011 Donna Samarya Claim Representative State Farm Insurance Company P.O. Box 41 Concordville, PA 19331 Re: Our client: Mi Kyung Choi Your Insured: Young J. Choi & Mi K. Choi Claim 38-L884-956 DOA: March 19, 2010 Dear Ms. Samarya: Please allow this letter to acknowledge your request that Mi Kyung Choi undergo an IME. I met with Mrs. Choi this week in order to discuss her options. She has indicated that she would like a court determination of good cause pursuant to Section 1796 of Pennsylvania's Motor Vehicle Financial Responsibility Law before submitting to such an exam. If you would like Mrs. Choi to sign an authorization form that will allow you to contact her treating physicians, via phone, correspondence or otherwise, to obtain information regarding her medical condition and its causal connection to the motor vehicle accident of March 19, 2010, she will be happy to do so. Please forward any such authorization form to my attention. Should you have any questions, or should you like to discuss this matter, please do not hesitate to contact my office. Ve ly yo • avi S. sneski DSW/les 2040 Linglestown Road • Suite 303 • Harrisburg, PA 17110 Phone: (717) 541-9205 Fax: (717) 541-9206 Toll Free: 1-800-818-9608 www.nowllp.com ?.???;? c? • k NAVITSKY, OLSON & WISNESKI LLP A T T O R N E Y S A T L A W April 11, 2011 Donna Samarya Claim Representative State Farm Insurance Company P.O. Box 41 Concordville, PA 19331 Re: Our client: Mi Kyung Choi Your Insured: Young J. Choi & Mi K. Choi Claim #: 38-L884-956 DOA: March 19, 2010 Dear Ms. Samarya: Enclosed please find a March 31, 2011 report from Mrs. Choi's treating orthopedic surgeon, Craig W. Fultz, M.D., which confirms that Mrs. Choi's neck pain referred to her left upper extremity is causally related to the motor vehicle accident of March 19, 2010. The report should address any concerns that you might have as to the nature of her injuries and their causal relationship to the accident. Should you have any questions, please do not hesitate to contact my office. Ve truly ours, avid . Wisneski DSW/les 2040 Linglestown Road • Suite 303 • Harrisburg, PA 17110 Phone: (717) 541-9205 Fax: (717) 541-9206 Toll Free: 1-800-818-9608 www.nowllp.com ORIGINAL BENNETT, BRICKLIN & SALTZBURG, LLC BY: Curtis C. Johnston I.D. No. 64059 222 EAST ORANGE STREET LANCASTER, PA 17602 (717) 393-4400 ATTORNEY FOR PETITIONER, State Farm Mutual Automobile Insurance Company STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY One State Farm Drive Concordville, PA 19331-0041 Petitioner V. MI KYONG CHOI 5 Cardamon Drive Mechanicsburg, PA 17050 Respondent COURT OF COMMON PSEA9-' .? CUMBERLAND COUP ? r,-n PENNSYLVANIA -<> cn 0 -? , CIVIL ACTION - LAW' -- NO: 11-4327 r PETITIONER. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY'S REPLY TO RESPONDENT'S NEW MATTER AND NOW, comes Petitioner, State Farm Mutual Automobile Insurance Company, and herewith files the within Reply to Respondent's New Matter and states as follows: WHEREAS, it appearing that Respondent has filed purported New Matter contrary to Pa.R.C.P. Rule 206.2 and Rule 1017 which do not provide for the filing of New Matter in response to a Petition, State Farm accordingly respectfully requests that said New Matter be STRICKEN, and in the alternative nevertheless files this Reply to New Matter to avoid any determination that it waived its right to respond: 32. Denied. After reasonable investigation, Petitioner is without knowledge or information sufficient to form a belief as to the truth of the matter averred. } ?? ?? 33. Denied as stated. Respondent's medical records, to the extent Petitioner has been able to obtain them, are written documents which speak for themselves. 34.-35. Denied as stated. Petitioner's medical records are written documents which speak for themselves. 36. Denied as stated. After reasonable investigation, Petitioner is without knowledge or information sufficient to form a belief as to the truth of the matter averred. 37. Denied as stated. Petitioner's medical records are written documents which speak for themselves. 38.46. Denied as stated. The averments contained in Paragraphs 38 - 46 of Respondent's New Matter constitute conclusions of law to which no response if required. By way of further answer, Petitioner specifically denies each of Respondent's assertions as being without merit. Petitioner respectfully submits that its Petition to Compel Independent Medical Examination and supporting Memorandum of Law, specifically at pages 4-6, clearly establish Petitioner's entitlement to the relief requested. Contrary to Respondent's assertions, State Farm is contractually entitled to an Order compelling an independent medical examination without establishing "good cause" as required by the MVFRL, since its Policy language does not impose the "good cause" MVFRL standard.' Fleming v. CNA Ins. Co., 597 A.2d 1206, 1208 (Pa. Super. October 9,1991); Williams The State Farm insurance policy provides in relevant part: Mental or physical examination Whenever the mental or physical condition of a person is material to any claim for medical expenses or income loss benefits, a court of competent jurisdiction may order the person to submit to mental or physical examination by a physician. If a person fails to comply with the Order, the court may order that the person be denied benefits until he or she complies. Policy Form 9838A, page 16. 2 v. Allstate Ins. Co., 595 F. Supp.2d 532,539 (M.D. Pa. 2009). In State Farm Mutual Insurance Company v. Ashcroft, CI 11-00159, Madenspacher, P.J. (March 31, 2011) (Exhibit "A" hereto), the Lancaster County Court of Common Pleas recently addressed the exact same question presented in this case, and ruled in State Farm's favor following Fleming and Williams, supra. WHEREFORE, Petitioner, State Farm Mutual Automobile Insurance Company, respectfully requests that this Honorable Court grant the relief requested by Petitioner and enter an Order Compelling the Respondent to Submit to an Independent Medical Examination within thirty (30) days of this Court's Order, or at the earliest possible opportunity. BENNETT, BRICKLIN & SALTZBURG LLC 0 A., BY: Curtis C. Johnston, Attorney for Petitioner, State Farm Mutual Automobile Insurance Company 3 r Opinion No. 2011-17 March 31, 2011 Adam G. Reedy, Esquire Curtis C. Johnston, Esquire LAW REVIEW (Do Not Publish) Law Library File IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA rT1 CIVIL DIVISION -' STATE FRAM MUTUAL AUTOMOBILE. _ c o c? v z -' v vs. No. CI-11-00159 ,,`ten -? y p KIMBERLY A. ASHCROFT MEMORANDUM OPINION AND ORDER BY MADENSPACHER, J. Pending before the Court is Petitioner State Farm Mutual Insurance Company's Petition to Compel Respondent Kimberly A. Ashcroft to submit to an Independent Medical Examination pursuant to the terms of its policy of insurance issued to Joseph Gallo wherein Kimberly A. Ashcroft is listed as an insured driver. Respondent objects because section 1796 of the MVFRL, 75 Pa.C.S.A. 1796 states that an order shall only be made upon motion for good cause shown.' There are two cases which are relevant to this issue. The first, State Farm v. Swatner. 406 Pa. Super. 235, 594 A.2d 316 (1991) held that an order compelling an independent physical examination could be entered without depositions or a hearing when the mental or physical condition of the person was material to a claim, and proof presented established good 'The policy does not require a good cause showing but does require a materiality showing. EXHIBIT A V cause to evaluate that condition pursuant to 75 Pa. C.S.A. 1796. Then on October 9, 1991, a little more than three months later the case of Fleming v. CNA Insurance Companies, 409 Pa. Super 285 (1991) distinguished Swafier and held that if the contract of insurance requires submission to an independent medical examination that does not contain a "good cause" requirement the policy provision will be enforced. To this day Fleming remains good law. There are a mixture of trial court opinions dealing with this issue, but only one supports Respondent's position. That is Nationwide Ins. Co. V. Hoch 36 Pa. D&C 4' 256 (1977). This Court feels that the judge in that case overreached in not following Fleming. This Court agrees with the analysis of Williams v. Allstate, 595 F. Supp. 2d 532 that, Fleming is the law of this Commonwealth. Consequently, the Court issues the following: i • it ORDER r AND NOW this 31I day of March, 2011, Petitioner State Farm Mutual Insurance Company's Petition of Order Compelling Independent Medical Examination is GRANTED. Respondent Kimberly A. Ashcroft is directed to appear for an IME with Jeffrey H. Portner, M.D., of LMG Family Practice, 1019 South Broad Street, Lansdale, PA 19446 within sixty (60) days of this Order, or as soon as said examination can be scheduled. All costs shall be borne by Petitioner. ATTESTED: a_-?9AMT-1- copies to: Adam G. Reedy, Esquire - Curtis C. Johnston, squ're - BY THE COURT: JOSEPH C. MADENSPACHER PRESIDENT JUDGE NOTICE OF ENTRY OF ORDER OR DECPEE PURSUANT TO PA. R.C.P. NO. 236 NOTIFICATICA - THE !1M-OHED DOWilaZiiT HAS BE'=: I FILED 1;: TH!'- CASE PROTHOr:;1TAP.Y OF LANCASTER CO., PA DATE: 4_ 1 - q `-,? BENNETT, BRICKLIN & SALTZBURG, LLC BY: Curtis C. Johnston I.D. No. 64059 222 EAST ORANGE STREET LANCASTER, PA 17602 (717) 393-4400 STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY One State Farm Drive Concordville, PA 19331-0041 Petitioner V. MI KYONG CHOI 5 Cardamon Drive Mechanicsburg, PA 17050 Respondent ATTORNEY FOR PETITIONER, State Farm Mutual Automobile Insurance Company COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 11-4327 CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of State Farm Mutual Automobile Insurance Company's Reply to Respondent's New Matter on the person set forth below by first class mail, postage prepaid: David Wisneski, Esquire NAVITSKI, OLSON & WISNESKI, LLP 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 (Attorneys for Respondent) BENNETT, BRICKLIN & SALTZBURG LLC BY: Curtis C. Johnston, Attorney for Petitioner State Farm Mutual Automobile Insurance Date: Company l4 STATE FARM MUTUAL AUTOMOBILE : IN THE COURT OF COMMON PLEAS OF INSURANCE COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. MI KYONG CHOI, DEFENDANT NO. 11-4327 CIVIL goy _? IN RE: PETITION TO COMPEL INDEPENDENT MEDICAL EXAMIIN"O ORDER OF COURT th 4 1 f l!"'1 AND NOW, this 27 day of June, 2011, upon consideration of State harfn M- utua"+ " Automobile Insurance Company's Petition To Compel Independent Medical Examination, ]V i Kyong Choi's Answer thereto with New Matter, and State Farm's Reply to New Matter; IT IS HEREBY ORDERED AND DIRECTED that the Petition is GRANTED. Mi Kyong Choi is directed to submit to an Independent Medical Examination by a doctor selected by Disability Management Consultants. The Independent Medical Examination shall be scheduled by Disability Management Consultants with reasonable accommodation to Mi Kyong Choi, but shall be conducted on or before August 26, 2011. By the Court, Curtis C. Johnston, Esquire Attorney for Plaintiff David Wisneski, Esquire Attorney for Defendant K oil *A ba1 I oe6 M. L. Ebert, Jr., J. STATE FARM MUTUAL AUTOMOBILE : IN THE COURT OF COMMON PLEAS OF INSURANCE COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. MI KYONG CHOI, ; DEFENDANT NO. 11-4327 CIVIL IN RE: PETITION TO COMPEL INDEPENDENT MEDICAL EXAMINATION OPINION AND ORDER OF COURT Ebert, J., June 27, 2011 - Background Pending before the Court is Petitioner State Farm Mutual Automobile Insurance Company's Petition to Compel Independent Medical Examination ("IME")1 of Respondent Mi Kyong Choi. Respondent is an insured driver listed under the insured's, Young Jin Choi, motor vehicle insurance policy (#: 7022-8431-C23-38I) pursuant to the Pennsylvania Motor Vehicle Financial Responsibility LawZ ("MVFRL" ).3 Respondent asks the Court to deny Petitioner's IME request for failure to comply with the statutory requirements under 75 Pa.C.S.A. § 1796 (Mental or physical examination of person).4 Petitioner asserts, under the written provisions of the insurance policy ("the policy"), a contractual entitlement to an Order compelling the Respondent submit to an IME free of the statutory requirements of section 1796.5 Pet'r's Pet. to Compel Independent Medical Examination, May 13, 2011 [hereinafter Pet'r's Pet]. '' 75 Pa.C.S.A. § 1701, et seg 3 Pet'r's Pet. ¶ 3. 4 Mi Kyong Choi's Answer with New Matter to State Farm Mutual Automobile Insurance Company's Petition to Compel Independent Medical Examination, ¶ 46 June 8, 2011 [hereinafter Resp't Answer]. Pet'r's Pet. ¶ 24. 2 Discussion Contractual Provisions vs. Statutory Requirements "[T]he Pennsylvania Supreme Court has yet to opine on the breadth of [section 1796] and whether it forecloses conflicting policy provisions", however, the Superior Court has provided a line of cases from the late 1980's, early 1990's, to guide with interpretation of 75 Pa.C.S.A. §1796 (hereinafter §1796). Williams v. Allstate Ins. Co., 595 F. Supp. 2d 532, 538 (E.D. Pa. 2009); see Fleming v. CNA Ins. Cos., 597 A.2d 1206 (Pa. Super. Ct. Oct. 9, 1991); State Farm Ins. Cos. v. Swantner, 594 A.2d 316 (Pa. Super. Ct. July 3, 1991); Horne v. Sentry Ins. Co., 588 A.2d 546 (Pa. Super. Ct. Mar. 15, 1991); State Farm Ins. Cos. v. Hunt, 569 A.2d 365 (Pa. Super. Ct. 1990); State Farm Mutual Auto. Ins Co v Zachary, 536 A.2d 800 (Pa. Super. Ct. 1987). This Court agrees with the analysis in Williams stating Fleming has remained controlling and "has never been overruled, rejected, criticized, or meaningfully distinguished by any Pennsylvania court" in cases involving a request for an IME pursuant to a filed insurance policy. Williams, 595 F. Supp. 2d at 541 (citing Fleming and declining to afford weight to Judge Wettick's holding in Nationwide Ins. Co. v. Hoch, 36 Pa. D. & C.4th 256 (1997) stating, "notwithstanding its efforts to distinguish itself, the holding of Hoch flies directly in the face of the higher court's ruling in Fleming."). In Fleming, the Superior Court affirmed a trial court order granting the insurer's motion to compel an IME based on the insurance policy language as a contract provision entered into between both parties. Fleming, 597 A.2d at 1207. This Court agrees with Williams that "[n]othing in the plain language or history of the MVFRL suggests that it was intended to interfere with contractual bargaining rights between private individuals or to foreclose any such insurance policy provision." Williams, 595 F. Supp. 2d at 542. Additionally, as addressed in 3 Williams, an argument that contract provisions within an insurance contract in conflict with statutory language must yield is unnecessary when the contractual provisions support the purpose of the statute. See Id. at 542-43 n.5; see also Generette v. Donegal Mutual Ins CO., 957 A.2d 1180, 1190 (Pa. 2008). The "twin purposes" of the MVFRL is to prevent the insured from "ignor[ing] reasonable limitations on treatment by continuing in treatment without validation or justification" and prevent the insurer from "harassment, untoward intrusion and unwarranted examination" of the insured upon the policy. Id. (uotin Swantner, 594 A.2d at 322) (internal quotations omitted). In the instant case, this Court is presented with an insurance policy provision stating: Whenever the mental or physical condition of a person is material to any claim for medical expenses or income loss benefits, a court of competent jurisdiction may order the person to submit to mental or physical examination by a physician. If a person fails to comply with the order, the court may order that the person be denied benefits until he or she complies. Pet'r's Pet., Exhibit A, State Farm Car Policy Booklet p.16 (emphasis in original). Petitioner's insurance policy with Respondent not only supports the purpose of § 1796(a), but comes so close as to almost mirror the language. See 75 Pa.C.S.A. §1796(a). Existing contract provisions between parties, not in conflict with the statutory purpose of MVFRL, will be the standard for review in determining the outcome of an order by this Court compelling an IME. Therefore, this Court, in agreement with the holding in Fleming, issues the following order: AND NOW, this 27th day of June, 2011, upon consideration of State Farm Mutual Automobile Insurance Company's Petition To Compel Independent Medical Examination, Mi Kyong Choi's Answer thereto with New Matter, and State Farm's Reply to New Matter; 4 ,. R IT IS HEREBY ORDERED AND DIRECTED that the Petition is GRANTED. Mi Kyong Choi is directed to submit to an Independent Medical Examination by a doctor selected by Disability Management Consultants. The Independent Medical Examination shall be scheduled by Disability Management Consultants with reasonable accommodation to Mi Kyong Choi, but shall be conducted on or before August 26, 2011. By the Court, Nk '?' 4 M. L. Ebert, Jr., J. Curtis C. Johnston, Esquire Attorney for Plaintiff David Wisneski, Esquire Attorney for Defendant 5 ORIGINAL ENNETT, BRICKLIN & SALTZBURG, LLC i3Y: Curtis C. Johnston I.D. No. 64059 222 EAST ORANGE STREET LANCASTER, PA 17602 (717) 393-4400 ATTORNEY FOR PETITIONER, State Farm Mutual Automobile Insurance Company STATE FARM MUTUAL AUTOMOBILE COURT OF COMMON PLEAS INSURANCE COMPANY CUMBERLAND COUNTY, One State Farm Drive PENNSYLVANIA Concordville, PA 19331-0041 Petitioner CIVIL ACTION - LAW c? `. i : NO: 11-4327 porn ii _ MI KYONG CHOI ?' M, 5 Cardamon Drive Mechanicsburg, PA 17050 Respondent - "" " - PETITIONER, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY'S REPLY TO RESPONDENT'S NEW MATTER AND NOW, comes Petitioner, State Farm Mutual Automobile Insurance Company, and herewith files the within Reply to Respondent's New Matter and states as follows: WHEREAS, it appearing that Respondent has filed purported New Matter contrary to Pa.R.C.P. Rule 206.2 and Rule 1017 which do not provide for the filing of New Matter in response to a Petition, State Farm accordingly respectfully requests that said New Matter be STRICKEN, and in the alternative nevertheless files this Reply to New Matter to avoid any determination that it waived its right to respond: 32. Denied. After reasonable investigation, Petitioner is without knowledge or information sufficient to form a belief as to the truth of the matter averred. 1 .' 33. Denied as stated. Respondent's medical records, to the extent Petitioner has been able to obtain them, are written documents which speak for themselves. 34.-35. Denied as stated. Petitioner's medical records are written documents which speak for themselves. 36. Denied as stated. After reasonable investigation, Petitioner is without knowledge or information sufficient to form a belief as to the truth of the matter averred. 37. Denied as stated. Petitioner's medical records are written documents which speak for themselves. 38.46. Denied as stated. The averments contained in Paragraphs 38 - 46 of Respondent's New Matter constitute conclusions of law to which no response if required. By way of further answer, Petitioner specifically denies each of Respondent's assertions as being without merit. Petitioner respectfully submits that its Petition to Compel Independent Medical Examination and supporting Memorandum of Law, specifically at pages 4-6, clearly establish Petitioner's entitlement to the relief requested. Contrary to Respondent's assertions, State Farm is contractually entitled to an Order compelling an independent medical examination without establishing "good cause" as required by the MVFRL, since its Policy language does not impose the "good cause" MVFRL standard.' Fleming v. CNA his. Co., 597 A.2d 1206, 1208 (Pa. Super. October 9,1991); Williams The State Farm insurance policy provides in relevant part: Mental or physical examination Whenever the mental or physical condition of a person is material to any claim for medical expenses or income loss benefits, a court of competent jurisdiction may order the person to submit to mental or physical examination by a physician. If a person fails to comply with the Order, the court may order that the person be denied benefits until he or she complies. Policy Form 9838A, page 16. 2 v. Allstate Ins. Co., 595 F. Supp.2d 532, 539 (M.D. Pa. 2009 ). In State Farm Mutual Insurance Company v. Ashcroft, CI 11-00159, Madenspacher, P.J. (March 31, 2011) (Exhibit "A" hereto), the Lancaster County Court of Common Pleas recently addressed the exact same question presented in this case, and ruled in State Farm's favor following Fleming and Williams, supra. WHEREFORE, Petitioner, State Farm Mutual Automobile Insurance Company, respectfully requests that this Honorable Court grant the relief requested by Petitioner and enter an Order Compelling the Respondent to Submit to an Independent Medical Examination within thirty (30) days of this Court's Order, or at the earliest possible opportunity. BENNETT, BRICKLIN & SALTZBURG LLC BY: Curtis C. Johnst ttorney for Petitioner, State Farm Mutual Automobile Insurance Company Opinion No. 2011-17 :March 31, 2011 Adam G. Reedy, Esquire Curtis C. Johnston, Esquire LAW REVIEW (Do Not Publish) Law Library File IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYL?ANJ? CIVIL DIVISION _ STATE FRAM MUTUAL AUTOMOBILE. vs. No. CI-11-04159 s KIMBERLY A. ASHCROFT -?, n MEMORANDUM OPINION A.ND ORDER BY MADENSPACHER, J. Pending before the Court is Petitioner State Farm Mutual Insurance Company's Petition to Compel Respondent Kimberly A. Ashcroft to submit to an Independent Medical Examination pursuant to the terms of its policy of insurance issued to Joseph Gallo wherein Kimberly A. Ashcroft is listed as an insured driver. Respondent objects because section 1796 of the MVFRL, 75 Pa.C.S.A. 1796 states that an order shall only be made upon motion for good cause shown.' There are two cases which are relevant to this issue. The first, State Farm v. Swatner, 406 Pa. Super. 235, 594 A.2d 316 (1991) held that an order compelling an independent physical examination could be entered without depositions or a hearing when the mental or physical condition of the person was material to a claim, and proof presented established good 'The policy does not require a good cause showing but does require a materiality showing. EXHIBIT A z ^a. cause to evaluate that condition pursuant to 75 Pa. C.S.A. 1796. Then on October 9, 1991, a little more than three months later the case of Fleming v CNA Insurance Companies, 409 Pa. Super 285 (1991) distinguished Swatner and held that if the contract of insurance requires submission to an independent medical examination that does not contain a "good cause" requirement the policy provision will be enforced. To this day Fleming remains good law. There are a mixture of trial court opinions dealing with this issue, but only one supports Respondent's position. That is Nationwide Ins. Co. V. Hoch, 36 Pa. D&C 4' 256 (1977). This Court feels that the judge in that case overreached in not following Fleming. This Court agrees with the analysis of Williams v. Allstate, 595 F. Supp. 2d 532 that, Flemin is the law of this Commonwealth. Consequently, the Court issues the following: ORDER AND NOW this 3110 day of March, 2011, Petitioner State Farm Mutual Insurance Company's Petition of Order Compelling Independent Medical Examination is GRANTED. Respondent Kimberly A. Ashcroft is directed to appear for an IME with Jeffrey H. Portner, M.D., of LMG Family Practice, 1019 South Broad Street, Lansdale, PA 19446 within sixty (60) days of this Order, or as soon as said examination can be scheduled. All costs shall be borne by Petitioner. BY THE COURT: ATTESTED: " ?Ck? 1? copies to: Adam G. Reedy, Esquire - 1 Curtis C. Johnston, Esquire i- ?N JOSEPH C. MADENSPACHER PRESIDENT JUDGE i NOTICE OF E14TRY OF ORDER OR DECREE PURSUANT TO PA. R.C.P. NO; 236 NOTIFICATiCA - THE ATV.,;HED DO :UzZ T HAS bE`_: V t'-ED I : THi' CASE PRO T HOr::,TARY G LANUAS'i ER CO., PA DATE: k. - - *,, BENNETT, BRICKLIN & SALTZBURG, LLC BY: Curtis C. Johnston I.D. No. 64059 222 EAST ORANGE STREET LANCASTER, PA 17602 (717) 393-4400 STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY One State Farm Drive Concordville, PA 19331-0041 Petitioner V. MI KYONG CHOI 5 Cardamon Drive Mechanicsburg, PA 17050 Respondent ATTORNEY FOR PETITIONER, State Farm Mutual Automobile Insurance Company COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 11-4327 CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of State Farm Mutual Automobile Insurance Company's Reply to Respondent's New Matter on the person set forth below by first class mail, postage prepaid: David Wisneski, Esquire NAVITSKI, OLSON & WISNESKI, LLP 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 (Attorneys for Respondent) Date: & _/7- 011 . BENNETT, BRICKLIN & SALTZBURG LLC BY: C? Curtis C. Johnston, A torney for Petitioner State Farm Mutual tomobile Insurance Company David D. Buelr Prothonotary Office of the Prothonotary Cum6ertand County, Pennsylvania R irks. Sohonage, ESQ Solicitor 1/ — 327 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28Th DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 Carlisle, TA ® (Phone 717 240-6195 0 'Ta.:( 717 240-6573