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Home My WebLink About01-3259MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF DONALD SNYDER, Individually, and as : IN THE COURT OF COMMON PLEAS Parent and Guardian of CHRISTOPHER : CUMBERLAND COUNTY, PENNA. SNYDER, RYAN SNYDER and : JESSlCA SNYDER, Minors, : NO. ~ {' '~ Z 5'~ 341 West 17' Avenue : Apache Junction, AZ 85220, : Plaintiffs : CIVIL ACTION - LAW : v. : JURY TRIAL DEMANDED : JOHN P. SULLIVAN : 84 Broad Street : Montgomery, PA 17752 : : and : : FRANK J. SULLIVAN : 1718 Josiah Chowning Way : New Cumberland, PA 17070, : ~JIl: (.,OP¥ FROM Defendants : In ]'~ ~, I ~tO OffiO You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgmont may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO Le hah demandado a usted en la torte. Si usted defenderse de estas demaodza expuestas en law paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notifieacion. Hace falta asentar una compareocia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, ia corte tomara medidas y puede continuer ia demanda en contra suya sin previo aviso o notifieacion. Ademas, la corte puede decodor a favor del demandante y requiere que usted cumpla con todas law provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE ELDINERO SUFICIENTE DE PAGAR TAL SERVlCO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MORGAN & MORGAN, P.C. BY: SCOTt W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 A'I'FORNEYS FOR PLAINTIFFS DONALD SNYDER, Individually, and as : IN THE COURT OF COMMON PLEAS Parent and Guardian of CHRISTOPHER : CUMBERLAND COUNTY, PENNA. SNYDER, RYAN SNYDER and : JESSICA SNYDER, Minors, : NO. 341 West 17'~ Avenue : Apache Junction, AZ 85220, : Plaintiffs : CIVIL ACTION - LAW : v. : JURY TRIAL DEMANDED : JOHN P. SULLIVAN : 84 Broad Street : Montgomery, PA 17752 : : and : : FRANK J. SULLIVAN : 1718 Josiah Chowning Way : New Cumberland, PA 17070, : Defendants : COMPLAINT Plaintiffs, by and through their attorneys, Morgan & Morgan, P.C., hereby complain against Defendants and avers as follows: 1. Plaintiff is an adult individual, and parent and guardian of his minor children identified above and residing at the above address. 2. Defendant John Sullivan is an adult individual residing at the above address. 3. Defendant Frank Sullivan is an adult individual residing at the above address. 4. On or about December 25, 2000, minor Plaintiffs were passengers in a vehicle being operated by their mother, Donna Snyder, traveling north on Route 11-15 in East Pennsboro Township, Cumberland County, PA. 5. At the same time and location, Defendant John Sullivan was operating a vehicle owned by Defendant Frank Sullivan south on Route 11-15, and Defendant John Sullivan caused a collision with the Snyder vehicle, resulting in death and serious bodily injuries. 6. As a result of the collision, caused by the negligence of Defendants, individually, jointly and/or severally, minor Plaintiffs' mother, Donna Snyder, suffered severe injuries causing her death. 7. As a result of the collision, each of minor Plaintiffs suffered severe and disabling injuries, including but not limited to, injuries to their nerves, bones, muscles, joints and fascia, pain and suffering, mental and emotional distress, which are continuing. 8. As a further result of the collision, and the injuries to and death of their mother, which were witnessed by the minor Plaintiffs, each minor Plaintiff suffered severe emotional distress, which is continuing. 9. As a result of their injuries, the Plaintiffs have incurred medical bills for treatment, care, rehabilitation and transportation, and minor Plaintiffs may have suffered loss of potential earning capacity, and have suffered loss of life's pleasures and diminution of daily activities, which are continuing. 2 COUNT I PLAINTIFF. DONALD SNYDER. PARENT OF CHRISTOPHER SNYDER v. DEFENDANT JOHN P. SULLIVAN 10. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 11. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Traveling at an unsafe speed; B. Failing to have his vehicle under proper control; C. Operating a motor vehicle while asleep; D. Failing to warn Plaintiffs of an unreasonable risk of harm; E. Failing to keep a proper lookout; F. Operating his vehicle on the wrong side of the roadway; G. Entering the opposing lane of traffic without due regard to the rights and safety of oncoming vehicles; H. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. 3 PLAINTIFF. DONALD SNYDER. PARENT OF CHRISTOPHER SNYDER v. DEFENDANT FRANK J. SULLIVAN 12. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 13. Defendant owned the vehicle operated by Defendant John Sullivan, and granted permission to said Defendant to operate the vehicle at all times material hereto. 14. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was an incompetent driver. B. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was unable or incapable of safely operating a motor vehicle at all times material hereto. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. 4 COUNT III PLAINTIFF. DONALD SNYDER. PARENT OF RYAN SNYDER v. DEFENDANT JOHN P. SULLIVAN 1S. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 16. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Traveling at an unsafe speed; B. Failing to have his vehicle under proper control; C. Operating a motor vehicle while asleep; D. Failing to warn Plaintiffs of an unreasonable risk of harm; E. Failing to keep a proper lookout; F. Operating his vehicle on the wrong side of the roadway; G. Entering the opposing lane of traffic without due regard to the rights and safety of oncoming vehicles; H. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. PLAINTIFF. DONALD SNYDER. PARENT OF RYAN SNYDER v. DEFENDANT FRANK J. SULLIVAN 17. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 18. Defendant owned the vehicle operated by Defendant John Sullivan, and granted permission to said Defendant to operate the vehicle at all times material hereto. 19. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was an incompetent driver. B. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was unable or incapable of safely operating a motor vehicle at all times material hereto. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $2:5,000.00, exclusive of interest, costs and delay damages. PLAINTIFF. DONALD SNYDER. PARENT OF JESSIE SNYDER v. DEFENDANT .IOHN P. SULLIVAN 20. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 21. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Traveling at an unsafe speed; B. Failing to have his vehicle under proper control; C. Operating a motor vehicle while asleep; D. Failing to warn Plaintiffs of an unreasonable risk of harm; E. Failing to keep a proper lookout; F. Operating his vehicle on the wrong side of the roadway; G. Entering the opposing lane of traffic without due regard to the rights and safety of oncoming vehicles; H. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. PLAINTIFF. DONALD SNYDER. PARENT OF JESSIE SNYDER v. DEFENDANT FRANK J. SULLIVAN 22. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 23. Defendant owned the vehicle operated by Defendant John Sullivan, and granted permission to said Defendant to operate the vehicle at all times material hereto. 24. The Plaintiffs' injuries and damages were due to the negligence, car~lessnass and recklessness of Defendant, individually, jointly and/or severally, including: A. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was an incompetent driver. B. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was unable or incapable of safely operating a motor vehicle at all times material hereto. 8 POST & SCHELL, P.C. ATTORNEYS FOR DEFENDANTS BY: AMY L. CORYER JOHN P. SULLIVAN I.D. # 82718 FRANK J. SULLIVAN 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 DONALD SNYDER, Individually, and as IN THE COURT OF COMMON Parent and Guardian of CHRISTOPHER PLEAS SNYDER, RYAN SNYDER and CUMBERLAND COUNTY, JESSICA SNYDER, Minors, PENNSYLVANIA Plaintiffs, NO. 01-3259 v. CIVIL ACTION - LAW JOHN P. SULLIVAN and JURY TRIAL DEMANDED FRANK J. SULLIVAN Defendants. ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Defendants, John P. Sullivan and Frank Sullivan, in connection with the above-captioned matter. Respectfully submitted, POST & SCHELL, P.C. DATE:~ V L. ~CORYEI~ ESQUIRE CERTIEICATE OF SERVICE I, Kelley A. Spangler, an employee of Post & Schell, P.C. do hereby certi~, that on the date listed below, I did serve a true and correct copy of the foregoing document upon the following person(s) at the following address(es) by sending same via United States mail, first-class, postage prepaid: Scott W. Morgan, Esquire MORGAN & MORGAN, P.C. 120 South Street Harrisburg, PA 17101-1210 Kelley A. ~pangler - Or MORGAN & MORGAN, P.C. BY: SCOTF W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101=1210 (717) 236-7959 ATFORNEYS FOR PLAINTIFF DONALD SNYDER, Individually, and as : IN THE COURT OF COMMON PLEAS Parent and Guardian of CHRISTOPHER : CUMBERLAND COUNTY, PENNA. SNYDER, RYAN SNYDER and : JESSICA SNYDER, Minors, .' NO. 0 *' - ~ J-~'~ (' x-C/~C.~ 341 West 17~ Avenue : Apache Junction, AZ 85220, : Plaintiffs : CIVIL ACTION - LAW : v. : JURY TRIAL DEMANDED : JOHN P. SULLIVAN : 84 Broad Street : Montgomery, PA 177S2 : : and : .- FRANK J. SULLIVAN : 1718 Josiah Chowniag Way : New Cumberland, PA 17070, : Defendants : You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO Le ban demandado a usted en la corte. Si usted defenderse de estas demandas expuestas en law paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notifinacion. Hace falta asentar una comparen¢ia eserita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, ia corte tomara medidas y puede continuer ia demanda en contra suya sin previo aviso o notifina¢ion. Ademas, la corte puede decodor a favor del demandante y requiere que usted cumpla con todas law provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos impormntes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATFORNEYS FOR PLAINTIFFS DONALD SNYDER, Individually, and as : IN THE COURT OF COMMON PLEAS Parent and Guardian of CHRISTOPHER : CUMBERLAND COUNTY, PENNA. SNYDER, RYAN SNYDER and JESSICA SNYDER, Minors, :: NO. O/-- --~-~-~"~ C.o.;~'~'~..- 341 West 17~ Avenue : Apache Junction, AZ 85220, : Plaintiffs : CIVIL ACTION - LAW : v. : JURY TRIAL DEMANDED : JOHN P. SULLIVAN : 84 Broad Street : Montgomery, PA 17752 : and : : FRANK J. SULLIVAN : 1718 Josiah Cbowniag Way : New Cumberland, PA 17070, : Defendants : COMPLAINT Plaintiffs, by and through their attorneys, Morgan & Morgan, P.C., hereby complain against Defendants and avers as follows: 1. Plaintiff is an adult individual, and parent and guardian of his minor children identified above and residing at the above address. 2. Defendant John Sullivan is an adult individual residing at the above address. 3. Defendant Frank Sullivan is an adult individual residing at the above address. 4. On or about December 25, 2000, minor Plaintiffs were passengers in a vehicle being operated by their mother, Donna Snyder, traveling north on Route 11-15 in East Pennsboro Township, Cumberland County, PA. $. At the same time and location, Defendant John Sullivan was operating a vehicle owned by Defendant Frank Sullivan south on Route 11-15, and Defendant John Sullivan caused a collision with the Snyder vehicle, resulting in death and serious bodily injuries. 6. As a result of the collision, caused by the negligence of Defendants, individually, jointly and/or severally, minor Plaintiffs' mother, Donna Snyder, suffered severe injuries causing her death. 7. As a result of the collision, each of minor Plaintiffs suffered severe and disabling injuries, including but not limited to, injuries to their nerves, bones, muscles, joints and fascia, pain and suffering, mental and emotional distress, which are continuing. 8. As a further result of the collision, and the injuries to and death of their mother, which were witnessed by the minor Plaintiffs, each minor Plaintiff suffered severe emotional distress, which is continuing. 9. As a result of their injuries, the Plaintiffs have incurred medical bills for treatment, care, rehabilitation and transportation, and minor Plaintiffs may have suffered loss of potential earning capacity, and have suffered loss of life's pleasures and diminution of daily activities, which are continuing. COUNT I PLAINTIFF. DONALD SNYDER. PARENT OF CHRISTOPHER SNYDER v. DEFENDANT JOHN P. SULLIVAN 10. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 11. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Traveling at an unsafe speed; B. Failing to have his vehicle under proper control; C. Operating a motor vehicle while asleep; D. Failing to warn Plaintiffs of an unreasonable risk of harm; E. Failing to keep a proper lookout; F. Operating his vehicle on the wrong side of the roadway; G. Entering the opposing lane of traffic without due regard to the rights and safety of oncoming vehicles; H. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. 3 COUNT II PLAINTIPP. DONALD SNYDER. PARENT OP CHRISTOPHER SNYDER v. DEPENDANT PRANK J. SULLIVAN 12. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 13. Defendant owned the vehicle operated by Defendant John Sullivan, and granted permission to said Defendant to operate the vehicle at all times material hereto. 14. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was an incompetent driver. B. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was unable or incapable of safely operating a motor vehicle at all times material hereto. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. 4 COUNT II1 PLAINTIFF. DONALD SNYDER. PARENT OF RYAN SNYDER v. DEFENDANT JOHN P. SULLIVAN 1S. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 16. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Traveling at an unsafe speed; B. Failing to have his vehicle under proper control; C. Operating a motor vehicle while asleep; D. Failing to warn Plaintiffs of an unreasonable risk of harm; E. Failing to keep a proper lookout; F. Operating his vehicle on the wrong side of the roadway; G. Entering the oppoaing lane of traffic without due regard to the rights and safety of oncoming vehicles; H. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. 5 COUNT IV PLAINTIFF. DONALD SNYDER. PARENT OF RYAN SNYDER v. DEFENDANT FRANK J. SULLIVAN 17. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 18. Defendant owned the vehicle operated by Defendant John Sullivan, and granted permission to said Defendant to operate the vehicle at all times material hereto. 19. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was an incompetent driver. B. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was unable or incapable of safely operating a motor vehicle at all times material hereto. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. 6 COUNT V PLAINTIFF. DONALD SNYDER. PARENT OF JESSIE SNYDER v. DEFENDANT JOHN P. SULLIVAN 20. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 21. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Traveling at an unsafe speed; B. Failing to have his vehicle under proper con~'ol; C. Operating a motor vehicle while asleep; D. Failing to warn Plaintiffs of an unreasonable risk of harm; E. Failing to keep a proper lookout; F. Operating his vehicle on the wrong side of the roadway; G. Entering the opposing lane of traffic without due regard to the rights and safety of oncoming vehicles; H. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. 7 COUNT VI PLAINTIFF. DONALD SNYDER. PARENT OF JESSIE SNYDER v. DEFENDANT FRANK J. SULLIVAN 22. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 23. Defendant owned the vehicle operated by Defendant John Sullivan, and granted permission to said Defendant to operate the vehicle at all times material hereto. 24. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was an incompetent driver. B. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was unable or incapable of safely operating a motor vehicle at all times material hereto. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. MORGAN & MORGAN, P.C. $~t~. M~r an.~.~_.squire DATED: ~r~~ ~'.C, 2001 A~t~rneys for Plaintiffs 9 VERIFICATION Donald Snyder states that he is Plalntiffin this matter, and parent and guardian of minor Plalmiffs, and that the statements made in the foregoing Complaint are true and correct to the best of his knowledge, information and belie~. He understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom falsification to authorities. Donald Snyder, Parent and ~umZdian of Minor Plaintiffs MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36'/21 120 SOUTH STREET HARRISBURG, PA 17~01-1210 (717) 236-7959 A'CFORNEYS FOR PLAINTIFF DONALD SNYDER, Individually, and as ]lq THE COURT OF COMMON PLEAS Parent and Guardian of CHRISTOPHER CUMBERLAND COUNTY, PENNA. SNYDER, RYAN SNYDER and JESSICA SNYDER, Minors, NO. 01-3259 Civil 341 West 17~ Avenue Apache Junction, AZ 85220, Plaintiffs CIVIL ACTION - LAW v. JURY TRIAL DEMANDED JOHN P. SULLIVAN : 84 Broad Streot : Montgomery, PA 17752 and : FRANK J. SULLIVAN 1718 Josiah Chowning Way : New Cumberland, PA 17070, : Defendnnts PRAECIPE TO REINSTATE COMPLAII~ TO THE PROTHONOTARY: Kindly ~-instate the Complaint in the above-captioned matter. MORGAN & MORGAN, P.C. s~t~ w. M~, ~.~q;,ire/ Atmm~-ys for ~ffs / DA~: Ju~/~ . 2~1 POST & SCHELL, P.C. ATTORNEYS FOR DEFENDANTS BY: AMY L. CORYER JOHN P. SULLIVAN AND FRANK J. I.D. # 82718 SULLIVAN 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 DONALD SNYDER, Individually, and as IN THE COURT OF COMMON Parent and Guardian of CHRISTOPHER PLEAS SNYDER, RYAN SNYDER and CUMBERLAND COUNTY, JESSICA SNYDER, Minors, PENNSYLVANIA Plaintiffs, NO. 01-3259 v. CIVIL ACTION - LAW JOHN P. SULLIVAN and JURY TRIAL DEMANDED FRANK J. SULLIVAN Defendants. ANSWER AND NEW MATTER OF DEFENDANT JOHN P. SULLIVAN TO PLAINTIFF'S COMPLAINT AND NOW, comes Defendant, John P. Sullivan, by and through his attorney, Post & Schell, P.C., and for his Answer to Plaintiffs' Complaint, states as follows: !. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. 2. Admitted. 3. Admitted. 4. Denied. At~er reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. 5. Denied. The corresponding allegations are denied as conclusions of law to which no response is required. All allegations of cansation and consequential injury are specifically denied as impwper legal conclusions and strict proof thereof is demanded at trial. 6. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furthermore, the corresponding allegations are denied as conclusions of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. 7. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furthermore, the corresponding allegations are denied as conclusions of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. 8. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the Iruth of the allegations and, accordingly, all such allegations are denied. Furthermore, the corresponding allegations are denied as conclusions of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. 9. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furthom~ore, the corresponding allegations are denied as conclusions of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. COUNT I Plaintiff. Donald Snyder. Parent of Christopher Snyder v. Defendant John P. SnllivAn 10. Answering Defendant incorporates herein by reference the averments contained in paragraphs one through nine of the foregoing Answer as if fully set forth herein. 11. Denied. Al~er reasonable investigation, Answering Defendant is without knowledge or h-fformation sufficient to form a belief as to the truth ofthe allegations and, accordingly, all such allegations are denied. Furthermore, the corresponding allegations are denied as conclusions of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. It is specifically denied that Answering Defendant was negligent, careless or reckless. WHEREFORE, Answering Defendant, John P. Sullivan, respectfully requests that this Honorable Court grant judgment in his favor and against the Plaintiff on the Complaint, together with costs and expenses. COUNT II Plaintiff. Donald Snyder. Parent of Christopher Snyder v. DefendAnt Frank J. Sulliv== 12. Answering Defendant incorporates herein by reference thc averments contained in paragraphs one through eleven of the foregoing Answer as if fully set forth herein. 13. Admitted. 14. Denied. A~ter reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to thc truth of thc allegations and, accordingly, all such allegations are denied. Furth=rmore, the corresponding allegations are denied as conclusions of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at V/al. It is specifically denied that Answering Defendant was incompetent or unable or incapable of safely operating a motor veh/cle. WHEREFORE, Answering Defendant, John P. Sullivan, respectfully requests that this Honorable Court grant judgment in his favor and against the Plaintiff on the Complaint, together with costs end expenses. COUNT III Plaintiff. Donald Snvder. Parent of Rvan Snyder v. Defendant John P. Sulllvg- ! 5. Answering Defendant incorporates herein by reference the averments contained in paragraphs one through fourteen of the foregoing Answer as if fully set forth herein. 16. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furth~,more, the corresponding allegations are denied as conclusions of law to which no response is required. Ail allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at v/al. It is specifically denied that Answering Defendant was negligent, careless or reckless. WHEREFORE, Answering Defendant, John P. Sullivan, respectfully requests that this Honorable Court grant judgment in his favor and against the Plaintiff on the Complaint, together with costs and expenses. COUNT IV Plaintiff. Donald Snyder. Parent of Ryan Snyder v. Defendant Frank J. Sullivan 17. Answering Defendant incorporates herein by reference the averments contained in paragraphs one through sixteen of the foregoing Answer as if fully set forth herein. 18. Admitted. 19. Denied. After reasonable investigation, Answering Defendant is w~thout knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furth~..ore, the corresponding allegations arc denied as conclusions oflaw to which no response is required. All allegations of causation and consequential injury arc specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. It is specifically denied that Answering Defendant was incompetent or unable or incapable of safely operating a motor vehicle. WHEREFORE, Answering Defendant, John P. Sullivan, rcapeetfully requests that this Honorable Court grant judgment in his favor and against the Plaintiff on thc Complaint, tngcther with costs and expenses. COUNT V Plaintiff. Donald Snyder. Parent of J,~,io Snyder v. Defendant John P. Sulliv#- 20. Answering Defendant incorporates herein by reference the aw..ents contained in paragraphs one through nineteen of the foregoing Answer as if fully set forth herein. 21. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations and, accordingly, all such allegations are denied. Furthermore, the corresponding allegations are denied as conclusions of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict pwofthereof is demanded at trial. It is specifically denied that Answering Defendant was negligent, careless or reckless. WHEREFORE, Answering Defendant, John P. Sullivan, respectfully requests that this Honorable Court grant judgment in his favor and against the Plaintiff on the Complaint, together with costs and expenses. COUNT VI Plaintiff. Donald Snyder. Parent ofJ~zz[~ Snyder v. D~f*ndant Frank J. Sullivan 22. Answering Defendant incorporates herein by reference the averments contained in paragraphs one through twenty-one of the foregoing Answer as if fully set forth herein. 23. Admitted. 24. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the troth of the allegations and, accordingly, all such allegations are denied. Furthermore, the corresponding allegations are denied as conclusions of law to which no response is required. All allegations of causation and consequential injury are specifically denied as improper legal conclusions and strict proof thereof is demanded at trial. It is specifically denied that Answering Defendant was incompetent or unable or incapable of safely operating a motor vehicle. WHEREFORE, Answering Defendant, John P. Sullivan, respectfully requests that this Honorable Court grant judgment in his favor and against the Plaintiff on the Complaint, together with costs and expenses. The Answering Defendant hereby raises the following New Matter: 25. Answering Defendant incorporates herein by reference the averments contained in paragraphs one through twenty-four of the foregoing Answer as if fully set forth herein. 26. The Plaintiffs may have failed to state a cause of action upon which relief can be granted. 27. Answering Defendant was not negligent. 28. Any acts or omissions of the Answering Defendant alleged to constitute negligence were not substantial causes or factors of the subject incident and/or did not result in the injuries and/or losses alleged by the Plaintiffs. 29. Answering Defendant, John P. Sullivan, was not acting as an agent of the Defendant, Frank J. Sullivan, at the time the subject accident occurred. 30. At the time the subject accident occurred, Answering Defendant, John P. Sullivan, was not acting in furtherance of the affairs and/or business of the Defendant, Frank J. Sullivan. 31. Answering Defendant, John P. Sullivan, and Defendant, Frank J. Sullivan, had not engaged in, agreed upon, or actively participated in carrying out a joint enterprise ora business or other non-social nature for mutual gain or profit which led to Defendant, John P. Sullivan, having been involved in the subject motor vehicle accident. 32. The incident and/or damages described in Plaintiffs' Complaint may have been caused or contributed to by the Plaintiffs. 33. The negligent acta or omissions of other individuals and/or entities may have constituted intervening, superseding causes of the damages and/or injuries alleged to have been sustained by the Plaintiffs. 34. The Plaintiffs may have assumed the risk. 35. The Plaintiffs may have been contributorily negligent. 36. The incident, injuries and/or damages alleged to have been sustained by the Plaintiffs were not proximately caused by Answering Defendant. 37. Plaintiffs may not have properly mitigated their damages. 38. Plaintiffs may be bound by the limited tort option, and, as their injuries may not be considered "serious," non-economic damages would not be recoverable. WHEREFORE, Answering Defendant, John P. Sullivan, respectfully requests that this Honorable Court grant judgment in his favor and against the Plaintiffs on the Complaint, together with costs and expenses. Respectfully submitted, POST & SCHELL, P.C. Date: 7/lel/OI ~,,-~ ~m~,.~, ID #82718 Counsel for Answering Defendant John P. Sullivan I, John P. Sullivan, do hereby swear and aft'mn that the facts and matters set forth in the Answer and New Matter are tree and correct to the best of my knowledge, information and belief. The undersigned understands that the statements made therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. //~hn P. Suh'fv& I, Kelley A. Spangl~r, an employee of Post & Schell, P.C. do hereby certify that on the date listed below, I did serve a true and correct copy of the foregoing document upon the following person(s) at the following address(es) by sending same via United States mail, first-class, postage prepaid: Melissa M~i~ Rivera, Esquire MORGAN & MORGAN, P.C. 120 South Street Harrisburg, PA 17101-1210 Kelley A.-Sp~[ngler t ~ DATED'. July ~ 2001 Scott W. Morgan, Esquire states that he is counsel of record for Plaintiffs in the within action, is authorized to take this Verification on their behalf, and that the statements made in the foregoing Reply to New Matter are true and correct to the best of his knowledge, information and belief. He understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Scott W. Mo~rgan, Esqu' CERTIFICATE OF SERVICE I, Scott W. Morgan, Esquire, hereby certi~ that service of the original within Plaintiffs' Reply to New Matter was made on this ~day of July, 2001, to the persons below named, by First Class United States Mail, postage prepaid. Amy Coryey, Esquire Post & Schell, P.C. 240 Grandview Avenue Camp Hill, PA 17011 Steven Williams, Esquire 508 North Second Street Harrisburg, PA 17101 MORGAN & MORGAN, P.C. 120 South Str~ H~'risburg, PA 17101-1210 (717) 236-7959 Attorneys for Plaintiffs SHERIFF' S RETURN - REGULAR CASE NO: 2001-03259 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SNYDER DONALD ETC VS SULLIVAN JOHN P ET AL TREVOR KENT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SULLIVAN FRANK J the DEFENDANT , at 1900:00 HOURS, on the 31st day of May , 2001 at 1718 JOSIAH CHOWNING WAY NEW CUMBERLAND, PA 17070 by handing to JO~IN SULLIVAN, ADULT SON OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Service 10.54 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 38.54 08/17/2001 MORGAN & MORGAN Sworn and Subscribed to before me this /~ ~ day of Deputy SHERIFF'S RETD-Rig - REGULAR · CASE NO: 2001-03259 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SNYDER DONALD ETC VS SULLIVAN JOHN P ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SULLIVAN JOHN P the DEFENDANT , at 1845:00 HOURS, on the 8th day of August , 2001 at 1718 JOSIAH CHOWNING WAY NEW CUMBERLAND, PA 17070 by handing to JOHN SULLIVAN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Additional Comments SHERIFF OF LYCOMING COUNTY WAS DEPUTIZED ON 5/29/01 TO SERVE DEFT., JOHN P. SULLIVAN. THEY RETURNED COMPLAINT "NOT FOUND," DEFT. CAN BE SERVED IN CUMBERLAND COUNTY. Sheriff's Costs: So Answers: Service 11 05 Out of County 9 00 Surcharge 10 00 R. Thomas Kline Lycoming County 28 00 64 05 08117/2001 MORGAN AND MORGAN Sworn and Subscribed to before By: me this /~ day of Deputy Sheriff ~ P~othonotary In The Court of Common Pleas of Cumberland County, Pennsylvania nald Snyder, IndlPrntlGrdn of Christopher, Ryan & Jessica Snyder, minors VS. John P. Sullivan etal No. 2001 3259 civil Now', May 30, 2001 , L SHERIFF OF CUMBERL.~rD COUNTY, PA, do hereby deputize the Sheriff of Lyccmin.q Cotmty to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County., PA Affidavit of Service Now, ,20 , at. o'clock __ M. served the within upon at by handing to a copy of the original aad made known to the contents thereof. So answcrs~ Sheriff of CountF, PA COSTS Sworn and subscribed before SERVICE $ me this day of ,20 MILEAGE AFFIDAVIT $ In The Court of Common Pleas of Cumberland County, Penmsylvania ~hnald Snyder, Ind/Prn~/Grdn of Christopher, Ryan & Jessica Snyder, minors VS. John P. Sullivan etal SERVE: John P. Sullivan No. 2001 3259 civ J_~ NOW, July 18, 2001 , I, SHERIFF OF CUNfBERLAND COUNT-Y, PA, do hereby deputize the Sheriffof Lyccminq County to execme this Writ, this deputation being made at the request and risk of the Plaintiff. Shm'iffof Cumberland Cout~B,. PA Affidavit of Service Now, ,20 , at o'clock M. served the within upon by handing to a copy of the ori_M, nal and made known to the contents thereof. So answers~ Sheriff of County.', PA COSTS Sworn and subscribed before SERVICE $ me this day of ,20__ .MILEAGE .kFFIDAVIT $ SHERIFF ' S RETURN - NOT SERVED CASE NO: 2001-03259 T COMMONWEALTH OF PENNSYLVANIA COUNTY OF Lycomlng DONALD SNYDER & ET AL VS JOHN P SULLIVAN & ET AL Charles T Brewer , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: SULLIVAN JOHN P & ET AL but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT SERVED , as to the within named DEFENDANT , SULLIVAN JOHN P & ET AL NOT SERVED DEFENDANT IS STAYING WITH HIS FATHER IN CUMBERLAND COUNTY FOR THE WEEK OF AUGUST 6TH. Sheriff's Costs: So answers: Docketing 9.00 Service . O0 Affidavit 2.50 Surcharge .00 Charles T Brewer, Sheriff Mileage 16.50 28.00 00/00/0000 Sworn and subscribed to before me this I~ day of A.D. Notar~J W~U~AM J. BIJRD l'rOtllO.O',~y & Clsrk of Courls WIIliamsp~t, Lycoming County · My Commission Expires Jan. 2, TRUE COPY FROM RECORD MORGAN & MORGAN, D.C. BY: SCOTT W. MORGAN, ESQUIRI~ IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATFORNEYS FOR PLAINTIFF DONALD SNYDER, Individually, and as : IN THE COURT OF COMMON PLEAS Parent and Guardian of CHRISTOPHER : CUMBERLAND COUNTY, PENNA. SNYDER, RYAN SNYDER and : JESSICA SNYDER, Minors, : NO. bi- ~ ).-fi"~ ~.-~--~ 341 West 17~ Avenue : Apache Junction, AZ 85220, : Plaintiffs : CIVIL ACTION - LAW : v. : JURY TRIAL DEMANDED : JOHN P. SULLIVAN : 84 Broad Street : Montgomery, PA 17752 : and : c-. .. FRANK J. SULLIVAN · ~.... .... 1718 Josiah Chowning Way : .~:.' ' ,~. New Cumberland, PA 17070, : :...: .. -- Defendants : ~-:,'. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You arc warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AvIso Le hah demandado a usted en la corte. Si usted defenderse de estas demandas expuestas en law paginas $iguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma ascrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, ia corte tomara medidas y puede continuer ia demanda en contra .~uya sin previo aviso o notificacion. Ademas, la corte puede decodor a favor del demandante y requiere que usted cumpia con todas law provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MORGAN & MORGAN, P.C. BY: SCOTt W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATrORNEYS FOR PLAINTIFFS DONALD SNYDER, Individually, and as : IN THE COURT OF COMMON PLEAS Parent and Guardian of CHRISTOPHER : CUMBERLAND COUNTY, PENNA. SNYDER, RYAN SNYDER and : JESSICA SNYDER, Minors, : NO. 341 West 17~ Avenue : Apache Junction, AZ 8:5220, : Plaintiffs : CIVIL ACTION - LAW : v. : JURY TRIAL DEMANDED : JOHN P. SULLIVAN : 84 Broad Street : Montgomery, PA 17752 : : and : : FRANK .I. SULLIVAN : 1718 Josiah Chowning Way : New Cumberland, PA 17070, : Defendants : Plaintiffs, by and through their attorneys, Morgan & Morgan, P.C., hereby complain against Defendants and avers as follows: I. Plaintiff is an adult individual, and parent and guardian of his minor children identified above and residing at the above address. 2. Defendant John Sullivan is an adult individual residing at the above address. 3. Defendant Frank Sullivan is an adult individual residing at the above address. 4. On or about December 25, 2000, minor Plaintiffs were passengers in a vehicle being operated by their mother, Donna Snyder, traveling north on Route 11-15 in East Pennsboro Township, Cumberland County, PA. 5. At the same time and location, Defendant John Sullivan was operating a vehicle owned by Defendant Frank Sullivan south on Route ! 1-15, and Defendant John Sullivan caused a collision with the Snyder vehicle, resulting in dnath and serious bodily injuries. 6. As a result of the collision, caused by the negligence of Defendants, individually, jointly and/or severally, minor Plaintiffs' mother, Donna Snyder, suffered severe injuries causing her dcath. 7. As a result of the collision, each of minor Plaintiffs suffered severe and disabling injuries, including but not limited to, injuries to their nerves, bones, muscles, joints and fascia, pain and suffering, mental and emotional distress, which are continuing. 8. As a further result of the collision, and the injuries to and dnath of their mother, which were witnessed by the minor Plaintiffs, each minor Plaintiff suffered severe emotional distress, which is continuing. 9. As a result of their injuries, the Plaintiffs have incurred medical bills for treatment, care, rehabilitation and transportation, and minor Plaintiffs may have suffered loss of potential earning capacity, and have suffered loss of life's pleasures and diminution of daily activities, which are continuing. 2 COUNT I PLAINTIFF. DONALD SNYDER. PARENT OF CHRISTOPHER SNYDER v. DEFENDANT JOHN P. SULLIVAN 10. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 thwugh 9, as if fully set forth at length. 11. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Traveling at an unsafe speed; B. Failing to have his vehicle under proper control; C. Operating a motor vehicle while asleep; D. Failing to warn Plaintiffs of an unreasonable risk of harm; E. Failing to keep a proper lookout; F. Operating his vehicle on the wrong side of the roadway; G. Entering the opposing lane of traffic without due regard to the rights and safety of oncoming vehicles; H. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. COUNT II PLAINTIFF. DONALD SNYDER. PARENT OF CHRISTOPHER SNYDER v. DEFENDANT FRANK J. SULLIVAN 12. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 13. Defendant owned the vehicle operated by Defendant John Sullivan, and granted permission to said Defendant to operate the vehicle at all times material hereto. 14. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was an incompetent driver. B. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was unable or incapable of safely operating a motor vehicle at all times material hereto. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. 4 COUNT III PLAINTIFF. DONALD SNYDER. PARENT OF RYAN SNYDER v. DEFENDANT JOHN P. SULLIVAN 15. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 16. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Traveling at an unsafe speed; B. Failing to have his vehicle under proper control; C. Operating a motor vehicle while asleep; D. Failing to warn Plaintiffs of an unreasonable risk of harm; E. Failing to keep a proper lookout; F. Operating his vehicle on the wrong side of the roadway; G. Entering the opposing lane of traffic without due regard to the rights and safety of oncoming vehicles; H. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. 5 COUNT IV PLAINTIFF. DONALD SNYDER. PARENT Ol~ RYAN SNYDER v. DEFENDANT FRANK J. SULLIVAN 17. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 18. Defendant owned the vehicle operated by Defendant John Sullivan, and granted permission to said Defendant to operate the vehicle at all times material hereto. 19. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was an incompetent driver. B. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was unable or incapable of safely operating a motor vehicle at all times material hereto. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $2~i,000.00, exclusive of interest, costs and delay damages. 6 COUNT V PLAINTIFF. DONALD SNYDER. PARENT OF JESSIE SNYDER v. DEFENDANT JOHN P. SULLIVAN 20. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 21. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Traveling at an unsafe speed; B. Failing to have his vehicle under proper control; C. Operating a motor vehicle while asleep; D. Failing to warn Plaintiffs of an unreasonable risk of harm; E. Failing to keep a proper lookout; F. Operating his vehicle on the wrong side of the roadway; G. Entering the opposing lane of traffic without due regard to the rights and safety of oncoming vehicles; H. Violating state laws and local ordinances relative to the above allegations of negligence. WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. 7 COUNT VI PLAINTIFF. DONALD SNYDER. PARENT OF JESSIE SNYDER v. DEFENDANT FRANK J. SULLIVAN 22. Plaintiffs incorporate herein by reference the allegations of paragraphs 1 through 9, as if fully set forth at length. 23. Defendant owned the vehicle operated by Defendant John Sullivan, and granted permission to said Defendant to operate the vehicle at all times material hereto. 24. The Plaintiffs' injuries and damages were due to the negligence, carelessness and recklessness of Defendant, individually, jointly and/or severally, including: A. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was an incompetent driver. B. Allowing Defendant John Sullivan to operate his motor vehicle when Defendant Frank Sullivan knew or should have known that Defendant John Sullivan was unable or incapable of safely operating a motor vehicle at all times material hereto. 8 WHEREFORE, Plaintiffs demand judgment against Defendant, individually, jointly and/or severally, in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. MORGAN & MORGAN, P.C. .. $~tt.~! Mot ~squire DATED: (',~.~' ~'.C, 2001 AR'ffrneys for Plaintiffs 9 VERIFICATION. Donald Snyder states that he is Plalntiffin this matter, and parent and guardian of minor Plaintiffs, and that the statements made in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. He understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom falsification to authorities. Donald Snyder, Parent and ~a~dlan of Minor Plaintiffs DONALD SNYDER, : IN THE COURT OF COMMON PLEAS OF Individually, and as : CUMBERLAND COUNTY, PENNSYLVANIA Parent and Guardian of : CHRISTOPHER : SNYDER, RYAN : SNYDER, and JESSICA : SNYDER, Minors, : Plaintiffs : : v. : CIVIL ACTION - LAW : JOHN P. SULLIVAN and : FRANK J. SULLIVAN, : Defendants : NO. 01-3259 CIVIL TERM ORDER OF COURT AND NOW, this 22na day of January, 2002, upon consideration of Plaintiffs' Petition for Court Approval of Minors' Settlement, a hearing is scheduled for Monday, February 25, 2002, at 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. DEFENDANT'S COUNSEL has indicated that she will not be attending the above hearing but has no objections to Plaintiff Donald Snyder, parent and guardian of the minor children, testifying by telephone. BY THE COURT, esley O16~k-..~ J.- ~Melissa Merritts, Esq. 120 South Street Harrisburg, PA 17101-1210 Attorney for Plaintiffs ~Am~ L. Coryer, Esq. 240 Grandview Avenue Camp Hill, PA 17011 Attorney for Defendants .'rc MORGAN & MORGAN. P.C. BY: MELISSA MERRITTS RIVERA, ESQUIRE IDENTIFICATION NO. 70303 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF DONALD SNYDER, Individually, and as : IN THE COURT OF COMMON PLEAS Parent and Guardian of CHRISTOPHER : CUMBERLAND COUNTY, PENNA. SNYDER, RYAN SNYDER and : JESSICA SNYDER, Minors~ : NO. 01-3259 Civil Plaintiffs : : CIVIL ACTION - LAW V. : : JURY TRIAL DEMANDED JOHN P. SULLIVAN and : FRANK J. SULLIVAN : Defendants : PETITION FOR COURT APPROVAL OF MINORS' SETTLEMENT Plaintiffs, by their attorneys, Morgan & Morgan, P.C., hereby petition the Court to approve this minors' settlement, and aver the following in support thereof: i. Plaintiff, Donald Snyder, is the parent and guardian of Christopher Snyder, who is 15 years old and was born on December 13, 1986, Jessiea Snyder, who is 10 years old, and was born on July 6, 1991, and Ryan Snyder, who is 11 years old, and was born on May 1, 1990. 2. On December 2.5, 2000, Plaintiffs Christopher, Ryan and Jessiea Snyder were injured when an automobile in which they were passengers, being operated by Donna Snyder Adams (deceased), their mother, was involved in a head-on collision with another vehicle being operated by John P. Sullivan. Mr. Sullivan was operating a vehicle owned by his father, Frank J. Sullivan. 3. At the time of the accident, Christopher Snyder was 14 years old, Ryan Snyder was 10 years old, and Jessiea Snyder was 9 years old. 4. As a result of the accident, Christopher Snyder suffered injuries in the nature of a broken femur of the left leg and a broken thumb on the right hand, bruised spleen, liver and kidney. 5. Jessiea sustained an injury to her head which involved scalp repair and brain damage. The right side motor skills were affected, as well as her speech. She also sustained a broken left femur. 6. Ryan sustained a broken right clavicle and right wrist. He sustained a serious injury to his head, including a shattered forehead and brain damage, which involved a partial Iobectomy. Attached to this petition are Exhibits A - I, medical reports outlining the diagnosis, treatment and prognosis for each child. 7. Minor Plaintiffs Christopher Snyder, Jessica Snyder and Ryan Snyder have substantially recovered from the above injuries. 8. Defendants, through their liability insurance companies, AllState and USAA, have agreed to pay $145,000.00 to the three children in exchange for a general release. The under insured motorist company, Motorist Mutual Insurance, has agreed to pay $15,000.00 to the children, in exchange for a general release, for a total of $160,000.00 to be divided among the three minor children. The remaining $120,000.00 in policy limits is being paid to the Estate of their mother, Donna Snyder Adams, who died as a result of this automobile accident. The children will receive a portion of the proceeds which will go to the Estate. Plaintiffs are in agreement with the funds being paid to the Estate. 9. The settlement is beneficial to each Plaintiff because (1) most medical bills have been paid for, there remain some outstanding co-pay through their current insurance, and (2) Plaintiffs appear to have made a very good recovery. 10. Plaintiffs retained the law firm of Morgan & Morgan, P.C. to represent them in this regard, and signed a contingent fee agreement providing for one-third fee to be deducted from the gross amount recovered. Morgan & Morgan, P.C. has reduced it's fee to 25% in accordance with ~Jl~, 399 Pa. Super. 599 (1990). The reduced fee is $40,000.00. i 1. Settlement proceeds payable to Christopher Snydcr, minor Plaintiff, will be $23,418.63. Proceeds payable to Jc~siea Snyder, minor Plaintiff, will be $45,960.08, and proceeds payable to Ryan Snyder, minor Plaintiff, will be $46,059.60. 12. The proceeds [myable to minor Plaintiffs, Christopher Snyder, Jessiea Snyder and Ryan Snydcr will be deposited into federally insured interest bearing accounts in their names, with the appropriate notation that no withdrawals may be made except upon Order of Court or until the minor attains their majority. 13. Settlement proceeds payable to Donald Snyder, parent and gnardian of the minors named in this petition, for medical bills paid out of pocket will be $3,035.16. Proof of payment is attached as Exhibit 'J." 14. Plaintiff, Donald Snyder, parent of Christopher, Jessiea and Ryan Snyder, believes this settlement to be reasonable and in his children's best interest. His statement of consent to settlement is attached as Exhibit 'K.' ]5. Upon approval of this settlement, minor Plaintiffs' natural parent and guardian, Donald Snyder, on behalf of minor Plaintiffs, Christopher Snydcr, Jessiea Snyder and Ryan Snyder, will be required to sign a release discharging Defendants, and their liability insurance carrier, and under insured motorist carrier, from further liability relative to this accident. WHEREFORE, Plaintiffs request this Court to enter the attached Order approving the minors' settlement. Respectfully submitted, MORGAN & MORGAN, P.C. Me~i.~a Merritts Rivera,-Esquire Attorneys for Plaintiffs, Christopher, Jessica and Ryan Snyder DATED: December ]l ., 2001 May-lB-O! O4:31P .. P.01 From: Richard Shindell M.D., P.C. 333 E. Osborn Rd. Ste. 255 · ." Phoenix, Arizbna 8.5012 *Enclosed is n copy of our currtnt dictation. Thank you for your referral. If you have any complications with this transmis.qkm please call us at 602-604-894 I. 1'hank You!!!! JESSZCA SNYD~R 05-09-01 . ' ~-'~-w un of a femoral ~raccure. She Jessica is ~.,een 111 £o&&u - V L - w~tt%out any pain a~%d does not appear co nay= any ambulatory .... '. ~-hou"h we know zadiograph.i, cally, she has deformity c]ln~c~l~.y_~xu_=_~. Do deformity on the A~' t~]m. The approximatel~ 20 · ~ne u~w~. . . · . she lateral film iu unfortunately ~nadequate to evaluatu thxs but 6till does havu a ~light deformity which is as anL%cl, patcd. believe she will remodel this with growth. She will b~ leaving (or the summer and I would like to see her when she returns in approximately two months. Richard L. Shindell, M.D./Db EXHIBITS "A-I' PENNSTATE W Tbe Milton S. Hersh~ Medical Center The College of Medione Health Information Serviea~ HU24 P,O, Box 850 Hershey, PA 17033-0850 DISCHARGE SUMMARY PATIENT NAME: SNYDER, JESSICA PATIENT NUMBER: I 117582 DATE ADblI'YI'ED: 12/26/00 LOCATION: DATE DISCHARGED: 12/29/00 SEX: F DATE OF BIRTH: 07/06/91 REFERRING PHYSICIAN: Kym A. Salness, M.D. SENIOR RESIDENTS ON SERVICE: Richard J. King, M.D. and Michael D. Diodato, M.D. ADMISSION DIAGNOSIS: Multiple trauma with a closed head injury. PRINCIPAL DIAGNOSES: 1. Right frontal subaranhnoid hemorrhage. 2. Left skull fraclure with pneumoeaphaiy. 3. Left parietal scalp la~mtion. 4. ~ femur mid-shaft fracture. OPERATIONS OR PROCEDURES: 1. Repair of the opan/dopresscd skull fracture and scalp laceration on 12/26/00. 2. Repair of the left femur fracture on 12/28/00. HOSPITAL COURSE: This is a 9-year-old white female involved in a motor vehicle accident, backseat passenger, possibly unre~hained, with positive loss of conaciousness and positive amnesia, transported via LifeLion to Hershey Medical Center and admitted under the Pediatric Surgery scrvi~ for multiple traumas consisting of: (1) Right frontal subarachnoid hemorrhage, (2) loft frontal fracture with pneumocephaiy, (3) left parietal scalp ianeration, and (4) left femur franture at the sh~. The patient was taken to tho operating mom by Neurosurgery for repair of the head traumas on 12/26/00. The patient tolerated this procedure well and without complications. The patient was later taken on 12/28/00, by Orthopaedic Surgery service for rapair of the loft femur fracture; agnin, the patient tolerated this procedure well without complications. The patient's vital signs had always remained afebrile, normal and stable within normal parameters. The patient atarted awakening around 12/29/00, and was withdrawn to pain. The patient will be discharged to relocation to continue her treatment at that location. DISCHARGE MEDICATIONS: 1. Zantac 50 mg IV every eight hours. 2. Morphine I to 3 mg IV every hour as needed for pain. 3. Tylenol 650 mg orally or per rectum every four hours as needed. ~1~ .: ~ ,~:¢~...~. Page 1 of 2 An ~quld Oppo~unily Unive~sily PATIENT NAME: SNYDER, JESSICA PATIENT NUMBER: 1117582 4. DS normal saline with 10 mEq of KCI running at 60 c~ I~r hour. DISCHARGE INSTRUCTIONS: I. The discharge instructions were reviewed with the Rehabilitation Center and with the patient's pur~nts. 2. The patient' s parents may call at (717) 531-8521 or page the Pediatric Surgery Resident on-call with any questions or concerns. 3. The patient was discharged on a diet as per Speech Rehabilitation Pathology, Dr. Ramer. 4. The patient was discharged on activities as tolerated. 5. The patient's approximate pr~-admission w~ight is 40 kg. DICTATING MD: Anthony Conde, M.D. P~ter W. Dillon, M.D. ~- ~1 ~ ', Division of Pedialric Sur~ry ~ ' ~"-' AC/all D: 12/29/00 T: 01/03/01 dm 1/3 c: WP Clerk - 315221 *** Dictated but NOT Re~d *** Page 2 of 2 PENNSTATE The Milton S. Hershe]( Medical Center The College of Medicine Health Information Services HU24 P.O. Box 850 Hershey, PA 17033-0~$0 DISCHARGE SUMMARY PATIENT NAME: SNYDER, JESSICA PATIENT NUMBER: 1117582 DATE ADMri-r~:D: 12/29/00 LOCATION: DATE DISCHARGED: 01/19/01 SEX: F FINAL DIAGNOSES: 1. Closed head injury. 2. Left femur fracture. HISTORY OF PRESENT ILLNESS: Jessiea is a 9-year-old girl who was injured in a motor vehicle accident on 12/25/00. She was unconsoiens at the scene with a Glasgow Coma Scale of 7 on admission to the emergency room. Her injuries included a left femur fracture, status post flexible nail placement on 12/27. She had a left parietal scalp laceration, left hip abrasion and right knee abrasion, in addition to the closed head injury. A CT scan showed a questionable right frontal subaraohnoid hemorrhage, a left parietal skull fracture which was depressed out with pneumoeephaly, and some effacement of basal cistern. She was intubated and sedated upon admission and extubated successfully on 12/26. She underwent elevation of the left parietal fractu~ on 12/26 without complication. She has had dally improvement of neurological status with vocalizations mostly crying, intermittent following of commands, purposeful movement of the left arm, and occasional head nod, yes or no. Some agitation as well but this settles quickly. PAST MEDICAL HISTORY: Past medical history shows that she is healthy with no chronic problems. She attended third grade with reportedly honor roll grades. PHYSICAL EXAMINATION: On admission to Rehabilitation, her examiner showed a heart rate of 100 to 120, respirations 18 to 24 and weighed about 40 kg. General exam showed that her eyes were open. She is easily agitated. HEENT exam showed a well-approximated s~lp wound on left parietal region. The area was dry. There were no other abnormalities. Neck had full range of motien without pain. Chest was clear. No wheezes or rales were noted. Heart rate was regular. Normal S1 and S2. No murmurs. Abdomen was obese and full but apparently non-tender. Bowel sounds were present. There was no enlargement of liver or spleen. External genitalia were Tanner stage I. Extremities showed multiple bruises and abrasions. Left thigh with an ACE wrap dressing present and was somewhat swollen compared to the right thigh. Neurological exam showed that she was arousable than alert. She follows commands about 50% of the time. There were purposeful movements of the left arm. She vocalized but was easily agitated. Cranial nerve exam showed that she had visual fix and follow in all quadrants. She shifted gaze from one speaker to another. Pupils were equal, round and reactive to light. She had equal facial strength from right to left. Gag, cough and tongue movements were intact. Tone was decreased on the right ann with positive movements observed. It was slightly increased in the Page I of 3 PATIENT NAME: SNYDER~JESSICA PATIENT NUMBER: 1117582 right leg but normal on the left side. Strength exam showed that she moved the lefl ann and leg against gravity. There were few right ann movements noted on admission. She was able to weightboar on her hands when sitting. This was more apparent on the left than the right, and was able to sit without support but very briefly. HOSPITAL COURSE: Jessica made continuous progress and neurologic recovery. She experienced resolution of the right arm weakness. Measured grip strength were within 1/2 pound of each other. She learned stand and pivot transfers but initially required a great deal of support because of the non-weightbcering status on the left side. She improved in gait. She did some walking with a platform walker. But because of complications from the le~ femur and need for spica cast by the time of discharge, she was not ambulating independently. She initially had a great deal of agitation which was shown by crying out, frequent request to bo moved and to go to the bathroom. Ultimately, she was treated with clonidine in a dose of 0.5 mg thre~ times a day. With resolution ofthaso symptoms, she resumed her previous temperament which was pleasant and cooperative. There were occasional periods of crying or agitation toward the end of the stay but these were minimal and she was quite re-dlreotable. There was some anxiety as well. Her cognitive skills improved markedly. By the time of discharga, higher level language skills w~re the only deficit, along with minor degren of word-finding difficulty. Her academic skills wore around the third grade level but scattered from late second grade in to early fourth grade. Left femur fracture. Jessica had some intermittent discomfort over the left femur fracture site. By January 12th, thoro was swelling and significant discomfort over this ama. At that time, a venous duplex Doppler was performed to exclude DVT as thc origin of the swelling. An x-ray showed some angulation at the fracture site. It was decided to place her in a hip spica cast which was accomplished on 01/17/01. At~r the hip spica east, sbo had experienced some pein for tho first 24 hours, but this improved markedly the. reai~er. She was able to learn bed mobility and was able to be transferred to car by her family. CONDITION ON DISCHARGE: Good, DISCHARGE MEDICATIONS: Clonidine 0.05 mg t,i.d, to be continued for approximately one month then weaned by a physician in Arizona. FOLLOW-UP CARE: Follow-up care will include need for physical therapy once per week while in cast and then two to three times per week thereafter, Occupational therapy one to two times per week and speech therapy three times per week. Page 2 of 3 PATIENT NAME: SNYDER, JESSICA PATIENT NUMBER: I 117582 These were all arranged in Arizona. She will be on homebound instruction for one month and then begin part-time school placement. No follow-up was arranged here because of the move to Arizona. Department of Pediatrics/Pediatric Gene~ics JR/lua D: 01/19/01 T: 01/23/01 dm 1/23 c: WP Clerk - 331743 FAMILY MEDICAL CENTER OF MARYSVILLE 506 SOUTH STATE STREET MARYSVILLE, PA 17053 Dictated but NOT Read *** Page 3 of 3 From: Richard Shindell M.D., P.C. 333 E. Osborn Rd. Sic. 255 Phoenix, Arizona 8.5012 *Enclosed is a ropy of our current dictalion. Thank you for your referral. If you have any complicalkms with this trmtsmis,qion please call us al 602-604-8941. Thank Vou!!!! CHRISTOPHER SNYDER 05-.09-01 Christoph¢:r is doing well. He ambulates without a limp. He has no obvious p:,Jn or deformity. I would like to see hi:~ fzactuze line disappea£ compleX, ely before returning him to full sports. There is abundant ~:a]lus but the ~racture line ia visible anteriorly, lie has no pain and ambulates without a limp. He will be lea¥ing for the summer. We will s~e him upon h~s return in two months. Richard L. Shindell, M.D./pb ~ PENNSTATE The Milton S. Hershey Medical Center The College of Medicine Health Information Servk'es HU24 RO. Box 850 Hershey. PA 17033-0850 DISCHARGE SUMMARY PA'I'u~NT NAME: SNYDER, CHRIS PA'ru~NT NUMBER: 1117586 DATE ADM~'YI'ED: 12/25/00 LOCATION: DATE DISCHARGED: 12/31/00 SEX: M DATE OF BIRTH: 12/13/86 ADMISSION DIAGNOSIS: Motor vehicle accident with multiple trauma. DISCHARGE DIAGNOSIS: I. Grade I to 1I splonic hematoma. 2. Left renal hematoma. 3. Left femur fracture. 4. Right proximal thumb fracture. OPERATIONS OR PROCEDURES: I. CT scan of head, abdomen and pelvis on December 2$th. 2. Cervicothoracic and lumbar spine x-rays, and right hand x-ray on December 25th. 3. Loft femur fracture repair with nail on December 27th. HOSPITAL COURSE: The patient is a 14-year-old male who was an unresUained passanger in a motor vehicle accident on December 25th. The patient was one of tho four occupants cfa passenger vehicle that was brought to the Hershey Medical Center Trauma Bay. The patient was evaluated and noted to have a grade I to ii splenic hematoma, left renal hematoma, loft femur fracture, and a right thumb fracture. Thc patient was admitted for observation of his neurological and intra-abdominal status with serial examinations and humatocrits. Thc patienfs CT scan was within normal limits at the time of admission. The patient was also admitted for repair of his loft femur fracture end splinting of his right thumb fracture. The patient's hospital course was otherwise urtremarkable, with gradual improvement of his nenrologic status. The pationfs abdominal exams ware unchenged, end his hematccrits were stable at the time of discharge. The patient underwent repair of his left femur fracture on December 27th without incident by Orthopaedics, and splinting of his right thumb fraeturc by Plastic Surgery. The pationt's blood pressures wore within a normal range during his hospitalization, end his renal injury was considered to be stable. The pationt had Physical Therapy and Occupational Therapy consultation and Rehabilitation Medicine evaluation. The patient improved with physical therapy and non-woightbearing on his Ich leg. On the day of dischurge, the patient was tolerating a regular diet end functioning well with tnmsfers and mobility, and non-waighthearing on his left leg. The pationt*s neurologic status was followed by Ncurosurgery. His cognitive and motor function was intact on thc day of diseharge. Page I of 2 JAN 1 2 An Equal O~porlunity Univ~rsily PATIENT NAME: SNYDER, CHRIS PATIENT NUMBER: IIi?S86 DISCHAROE MEDICATIONS: 1. Tylenol With Codeine one to two tablets p.o.q.6h, as needed for pain. 2. Colace 100 mg p.o.b.i.d, while on Tylenol No. 3. The parents were instructed that the patient could have Tylenol 650 m$ p.o.q, four to six hours as needed for pain in lieu of Tylenol No. 3 DISCHARGE INSTRUCTIONS: The patient and his family were instructed that he should have a regular diet as tolerated and to be non-weightbearing on left leg as per Orthopaedics and Physical Therapy. The patient was advised to keep his right wrist splint in place until follow-up with Plastic Surgery. The patient was advised to call the Pediatric Surgery Resident on-call with any questions or concerns at 531-8521. The patient and his family were ins~ucted to seek immediate medical attention should he develop headache, nausea, vomiting, increased abdominal pain, visual changes, or any change in his mental status. The patient and his family verbalized understanding oftbe discharge insmictions, and the patient was discharged home in improved condition. The patient and his family were advised that he should be under "house arrest", meaning that he should remain indoors for the next two weeks with limited movement about the house. This should continue until follow-up with Pediatric Surgery in two to three weeks. FOLLOW-UP: The patienfs follow-up appoin~nents were to be with Pediatric Surgery in two to three weeks with a repeat CT scan to be scheduled then, Plastic Surgery with Dr. Hauck in two weeks, and Orthopaedic Surgery with Dr. Wallach in 10 to 14 days. DICTATING MI): Richard J. Kin$, M.D. ~ Ai-i't~NDING 1VI~: Peter W. Dillon, M.D. Department of Pedia~ic Surgery RK/imbD: 12/31/01 T: 01/03/01 dm 1/3 c: WP Clerk- 316111 *** Dictated but NOT Read Page2 of 2 PENN STATE EMERGErqCY MEmC E The Milton S. He.hey Medical Center CENTER The College of Medicme P.O. BOX 850 HERSHEY. PA 717531 8333 TEL EMER6~ENCY DEPARTMENT NOTE PATIENT NAME~ SNYDER, CHRIS L PATIENT N~MBER~ 0362834 DATE OF 8ERVICE~ 12/26/2000 SEX~ M DATE OF BIRTH~ 12/13/1986 HISTORY OF PRESENT ILLNESS: This is a 14-year-old who was involved in a head-on motor vehicle accident at a high rate of speed. There was a significant amount of damage to the vehicle. The patients were entrapped for an extended period of time. There were multiple trauma patients from this accident arriving to the Emergency Department at the same time. Because of that, both the pediatric and adult trauma attending physicians were present. He has an obvious deformity to his femur. He also had some wrist pain. He is alert and oriented with a Glasgow Coma Scale of 15. He recalls most of the events. He has a little bit of belly pain. His vital signs were stable. Care was turned over to the trauma team. See their note for more complete details. DICTATING MD: Jeffrey Orledge, M.D. JO/clm D: 12/26/2000 T: 12/26/2000 20.-19 Page i of i 19:37:84 RightFAX-> f~2 991 ~','~3 RighO~X Page CHILDREN'S HOSPITAL TM March 13, 2001 Kirit Patel, M.D. 1056 S. Vni Vista Dr., #2 Mesa, AZ 85204 RE: Si~/DER, RYAN l~fl~: 02-26-29 DOB: 05/01/1990 Dear Dr. Pateh It was my pleasure lo see Ryan in Neurosm'gery Clinic today. Ryan was involved in a motor vehicle accident in Pennsylvania, and he was treated for his head inju~ in a local hospital. He has had evaluation ora frontal skull depressed frneture as well as contusion of the left frontal lobe. He ~eovered very well. Now he has some problem with the memory and eosnition, lie is not complaining of any headache, nausea or voroitinS. There is no history of seizure. He is not on any medication. His recent CT scan of the heed is su~estive of the postop changes in the frontal region with a small infarcted area on the left frontal lobe. His sK'vll wound has already healed nicely. However, there are a few scaxs without any discharie. We have reassured the father, and we are going to see him a_eain in six months' time. Diclated by Mohammnd Salaluddin, IvlD Sincerely, S. David Moss, MD Pediatric Neerosurgenn ~...~~ cc: Parena ofRyan Snyder 341 W. 17th Ave. Apaebe Junction, AZ 85220 SDM/959/DD:03/13/2001 10;35:26/DT:03/13/2001 11:09:06/$:744125/D:75668 999Eost :.-~ Str~e~ oPhoeniz, AZ 8S096-s'(602),239,48UOe Fox: (602)2S4,-7202 02-07-01 RYAN SNYDER REFERRING PHYSICIAN: KIRIT N. PATEL, M.D. CHIEF COMPLAINT: FRACTURE RIGHT RADIUS, RIGHT CLAVICLE AND HEAD INJURY HISTORY: Ryan Snyder is a 10-1/2-year-old who child who was injured in a motor vehicle accident in Hershey, Pennsylvania on 12-25-00. His mother unfortunately did not survive.' He was hospitalized for head injury for which he has had surgical care with a long incision on the right temporal region. He has a right clavicular fracture as well as a fracture of the right distal radius. He is doing well at this point and appears perfectly appropriate. He has multiple well healed lacerations over the forehead as well as a curvilinear surgical incision at the right temporal region. His cast is removed from his right wrist and he is nontender at the fracture site without obvious deformity. The range of motion is limited as anticipated with a fresh removal. He has a palpable mass at the right midshaft clavicle. He is minimally tender with compression and is not wearing a sling or protective brace. Radiographs demonstrate a completely healed fracture of the distal radius with dorsal angulation of the joint line by approximately 10° to 15°. This is checked against his original films and there was a comminuted distal radial fracture with approximately the same degree of angulation. This should be of no consequence and should remodel quite easily. The clavicular fracture is healing with a large but barely visible fracture callus holding bayonet apposition to the fracture fragments. IMPRESSION: Motor vehicle accident with fracture right clavicle and right forearm as well as head injury. PLAN: From the orthopedic standpoint, it appears that Ryan is doing quit~ well. His wrist fracture does have some angulation but this should be taken care of simply with his growth. I would like to see him in follow-up in four weeks at which time we will not obtain x-rays. Richard L. Shindell, M.D./pb c: Kirit N. Patel, M.D. PennState Geisinger The Milton Health System Medical Cen~er DAY OF DISCHARGE FORM HMC A~e~ Provider of Service Patient Date of Service Charl~e Amount Dr. Shindell Jessica 04-11-01 co-pay $40.00 Dr. Shindell Jessica 05-09-01 co-pay $20.00 Dr. Shindell Jcssica as of 09-21-01 not paid by ins. $119.40 Dr. Shindell Jessica 09-12-01 co-pay $20.00 Dr. Shindell Christopher 04-11-01 co-pay $40.00 Dr. Shindell Christopher 05-09-01 co-pay $20.00 Dr. Shindell Christopher as of 09-21-01 not paid by ins. $113.20 Dr. Shindell Christopher 09-12-01 co-pay $20.00 Dr. Shindell Ryan 04-11-01 co-pay $20.00 Dr. PateI-AZ AIl3/Acc# Total owed as of not paid by ins. $92.88 Inst. Of Med& A3343 10-01-01 Ped Dr. Patel Ryan 10-17-01 ce-pay $20.00 Dr. Moss Ryan 09-10-01 co-pay $20.00 Dr. Moss Jessica 09-10-01 co-pay $20.00 Dr. Moss Jessica& Ryan 20% of co-pay $168 ' Balanceof $840 East Valley Christopher acc# 06002509 not paid by ins. $82.88 Diag. Pbx Child. Host. Ryan 09-25-01 co-pay $20.00 Dr. Wodrich Pbx Child. Host. Jessica 09-25-01 co-pay $20.00 Dr. Wodrich Phx Child Hosp Jessica 03-07-01 not paid by ins. $788.90 Pbx Child Hosp Ryan 03-07-01 not paid by ins. $788.90 Amal Jabra Jessica. 05-09-01 not paid by ins $33.00 TOTAL 3o35. EXHIBIT "7' PHOENIX CHILDREN'S OP CENTER Acct: A34574 Date: 0g/28/01 P 0 BOX 52579 PHOENIX.AZ 85072 From: 02/08/01 (602)322-1878 Thru: 09/10/01 DORALD SNYDER 341W 17TH AVE APACHE JUNCTION.AZ 85220 f, vc Date Pi Name Physician Description CPT/ICOg Insurance Patient Acct Bal 02~08/01 RYAN HOSS,S OFFICE CONSULTATION 99245/854.00 284.00 0.00 JESSICA HOSS,S OFFICE CONSULTATION g9245/854.00 284.00 0.00 03/13/01RYAN HOSS,S OFFICE OUTPATIENT VISIT EST 99215/800.10 !46.00 0,00 04/30/01 ~YAN INSURANCE PAYHENT 79.00- 0.00 RYAN' CONTRACTUAL INSURANCE ADJ 47.00- 0.00 03/13/01 JESSICA HOSS,S OFFICE OUTPATIENT VISIT EST 99215/800.09 148.00 0.00 34/30/01 JESSICA INSURANCE PAYHENT 79.00- 0.00 JESSICA CONTRACTUAL INSURANCE ADJ 47.00. 0.00 C9114/01 JESSICA INSURANCE PAYHENT 16.00- 0.00 JESSiCA CONTRACTUAL INSURANCE ADJ 4,00- 0,30 09/I0/G! ~AN HOSS.S OFFICE OUTPATIENT VISIT EST 99215/959.01 146.00 0.00 ~AN ~OSS.S TRANSFER TO GUAR FOR G9/10/01 /959.01 20.00 20.00 RYAN HOSS.S CASH PAYHENT /959.01 20.00- 0.00 JESSICA MOSS,S OFFICE OUTPATIENT VISIT EST 99215/959.01 146.00 0.00 JESSICA HOSS,S TRANSFER TO GUAR FOR Og/lO/O1 /95g.o1 20.00 20.00 JESSICA HOSS,S CASH PAYHENT /g59.O1 20.00- 0.00 Insurance pending: 840.00 Account balance : 840.00 Pay this amount--> 0.00 Z~ITE: Lag-lS~.81 RICHARD ~qINO~LL, .iL]L, P.C. TI~ETi 672~.2 333 E. ~, ~ITE 2~ ( Tax I.D. I ~RflI~ DR: ~ KIRIT ~.O, ~Et ~ 288 RETU~ glSI~ ~a R~I~Y ~ F~ El 7E~ ~oliesis ~ V 0 ~1~ Limited I [3 7~ Clavicle ~ V t [] 72~ 5a~um/Co~yx ~9~13 Intermediate S [] 7~ Elbo~ 1 U ~ [3 7~88~ T-L Spine I g (~) ~1~ Extended S [3 7~ Elbea ~ V $ [] 7~ T-L 6pine ~ V O ~15 Comprehensive S D 73~6 Elbow 3+ V $ [] 7~16~ T-L Spine Inf ~JLT~TI~ [] 7~ Femur ~ V $ [] 7~ Toes ~ 9 0 99~&1 Brief I [3 731~-~ Finger I V $ D 7~6~ Toes 2+ V O ~ Limited I~ [3 73146 Finger ~+ V 6 [] 7~5~ Tibia/fibula O ~ Intermediate t [] 7~ Forearm ~ V S [3 7~ Tibia/Fibula O ~ Extended ~ [] 7~ Feet t V ~ [] 731~-~ ~is~ I V S~ ~INIDN C] 7~ Feet 3+ V I~ C] 731~ ~ist ~ V O ~71 Limited ~ D 7~ Hips/PaDis I ~ ~ E) 73Ur Wrist ~ V O 9~ Intermediate ~ E3 7~e Hips/Pelvis t+V ~ 0 ~3 Ex~ended S [J 7~ Hips 1 V S~ ~ C~IN6 m 0 ~74 Com~ehenstve $ D 7~I0 Hips 2 V ~tlat t [3 ~ Long Arm 0 g~ CompDx l__ [] 73120-~ ~nd 1 g $ [] ~5 ~o~ ~m OT~R PflO~U~S [] 73]~ Hand Z V $ E3 ~ Clubfoot Cast 0 FX ReductJon/~ntpuIat~on (} 731~ ~nd 3+ V ) [] 29~ Long Leg Cast [] 7~ Heel ~+ V $ [3 ~5 ~ort Leg Cast [] ~ Humerus ~+ V S [] ~7~ Wedging C] 7~ Knee ~ V [] 7~9 Knee g V S ~H ~IE~ ~)[ [] 7~ Knee 3 V S D Plas~ee [] 7~ Long Leg/gcanogr I [] H~ ~DIO~Y m [3 7359~ Lower Ext/2+ V $ [] ~her: [] 73~6-5~ fl-C Joint, 1 side S__ [] 7~I~ L-S Spine ~-3 V $__ [] Cast Sandal [] 7~ A-C Joint Bilat $__ [] 7~11~ L~ Spine 5 ~ $__ [] Ace ~ap [] 73~ · ankle~ ~ ~ ~ (] 7116t Ribs ~ V ~ [] Knee laaobi;tze~ D 7361~ Ankle, ~ V ~__ [] 7~16 6capule ~ 9 ~__ D Cock~p WriSt Splint D 7&O~ Bone ~ge Studies $__ [3 7~ 5-! Joint L 3 U $__ D Air Stirrup Splint D 7~-~ C-Spine 1 U t__ [3 73~0 Shoulder 1 U 6__ [3 Other: [] ~6 C~pine FIE ~ V S__ [] 7~39 ~oulder 2+ 9 $__ C] 7~-5~ C-Spine 3 U J__ C] 711~ B~ernoclav 3 V C] ~2 ~eoliosis I 9 ck ~ / cash / visa t mc / BAL~ ~llE: 69-12-L:161 NIDgl~ ~INBELL~ M,B,~ P,C, TICKETt) 6724, B 333 E. Oi~O[~ ~UITE 255 ~ P~NIX~ ARIZGNA B~l~ ~...~ OFFICE (662) 6S¥89~1 [ ] SCOI-~BALE OFFICE / Tan l.S. i~ 8G-~634~9 P~TIEHT NA~E-. CHRISTQOHER ~YI)ER DE: 1~-13-1~81~ A[CT6 16798 REFERRINO BE: PflTEL~ KIRIT H,I). PI~) INSURIINCE: ~ERICA~S CHOICE HEALll4Pt. AN~ cDAqY ~ ~,W6 AUIH: IETUI~ VISITS o~ ~IDI[I.OBY *~ FEE r] ~ 6~olinsis 2 g 0 9~12 Liaitod S [] 736~ Clavicle a V $ £] 7222~ Sacrum/Coccyx ~13 Intermediate $ [] 73676-5~ Elbo~ I V $ £3 7~986-5~ T-L Spine 1 V I~, Extended $ [] 7307~ Elbo# ~ g $ [] 7~686 T-L Spine 2 V 0 ~9P.15 Comprehensive $__ [1 73~M Elbo~ 3+ V $ £] 7~61~-5~ T-L Spine Inf CLIIStILTATIn~ £3 73b-~ FgotO" E ') $-- rl 7366~--'?- Toes i g () !)~41 Brief $ C] 7316~-5~ Finger I g S-- D 7366~ Toes ~+ g 0 99~ Limited $ il 73146 Finger 2+ V $-- £1 73596-5~ Tibia/fibula I V $ () ~ Intermediate $ [] 73~9~ Forearm 2 V $. [] 73~ Tibia/Fibula S V [) 99Ell Extended $ il 73F~q~ Feet ~ V $' rl 73189-5~.Wrist I V ~ECONI) OPINION [1 7353~ Feet 3+ U $ [1 731~ Wrist 2 g () 9~'/1 Limited $__ £1 73516-~ Hips/Pelvis I g $ [] 73116 ~ist 3+ U () 99E72 IntePeediats $ [] 7~ Hips/P~Ivis a+ ~ $ 16 ~3 E~e,mded $__ [1 7~ Hips I V S ~** ~I~ ~ () 99~74 Com~ehensJve I [] 7~1~ Hips ~ V Unila~ S [] ~ Long ~m ~st 0 ~5 Complex $ [] 731~ Hand I V $~ [] ~5 ~o~ ~m Cast ~R Pg~U~ [] 73126 Hand ~ g $. [] ~ Clubfoot Cast () FX Red~on/ManipuIaUen (} 731~ Hand 3+ V 6' U ~g~5 Long Leg ~st [] 7~ Heel ~+ P ~ [] ~4~ ~ort Leg Cast [] 73~0 Humerus ~+ V $ [1 ~7~0 Wedging Cast C] 7~6~ Knee I V E] 7~ Knee 3 V ~ [3 Plaster [] 7~ ~ Joint~ I side $ [] 72166 L-~ Spine 2-3 9 $ D Cas~ Sandal [] 73~ A~ Join~ Bila~ t [] ~11~ L~ ~pine 5 g t [1 ~e ~ap [] 7~ ~nkl~ ) U ~ [3 7~17~ Pelvis ) g I [] ~m Sling [] 7~ ~nkle~ ~ U S [] 711~1 R~bs ~ g t [] Knee I=iobiliz~ [] 73610 Ankle~ 3+ g $ [3 7~1~ ~capula ~ ~ S [3 Cock-Up ~is~ Splint El 7G~ Bone gge ~udies l~ E3 ~ ~i ~oint L 3 U I El ~ir 3ti~up Splint [] ~ C-Spine ] V S [] 73~ Shoulde~ I V ; ._ [] O~her: [] 7~9 C~pine FIE ~ V $ [] 7~ ~oulder 2+ g ~ [] 72~ C-Spine 3 9 S [1 711~ Ste~oclav 3 9 S .... [) 7~ Scoliosts I V ***[:::: ********************************************************************** **--****************** ok $ / cash / visa / mc ~E Select Medical Corporation P.O. Box 60432 King of Prussia, PA 19406 Explanation of Benefits h,h,hh,,I,l,,I,IIh.l.,I,hh.,ll,lh,,h,l,,,lll,l,, SNYDER, SUSAN 341 West 17th Avenue Apache Junction AZ 85220 Grouo and Provider Information Insured and Patient Information Master/Group # 2000-2049 Insured Name SNYDER, SUSAN Group Name SELECT MEDICAL EPO PHCS Address 341 West 17th Avenue Location City, St Zip Apache Junction AZ 85220 Provider AMAL JABRA Provider ID 99-0036159 Social Sec# 177-50-6269 Patient Name Jessica Snyder Provider PHCS-PRIVATE HEALTHCARE SYSTEM Network Patient Acct # 316356 belcrJpflon Gf 5mrvlu~ fJIt~B of.qervlce Anlourl! r)llb:.uunt ~l~ Cov'd 14~nlarkR' Paid At Plan Claim I~osa.(le rron, To Charged Ammlflt Ami'' % Pap DUPLICATE CLAIM 5/9/01 5/9/01 $56.00 $23.00 $33.00 36 0 $O.00 *Remarks ~ THI$ CI-41M AI. READY CON~IDERED TOTAL AMOUNT CHARGED $56.00 H2001276183220660:040:0 AMOUNT NOT COVERED $33.00 ELIGIBLE AMOUNT $23.00 TOTAL DEDUCTIBLE TAKEN $0.00 Check Number: 0 DEDUCT. REMAINING IN NET. $0.00 Check Date: Monday, October 15, 2001 DEDUCT. REMAINING OUT OF NET $0.00 Claim Number: 1127701700 Benefits Payable To: AMAL JABRA COBAMOUNT $0.00 Check Amount: $0.00 TOTAL DISCOUNT AMOUNT $23.00 ....b.......~,...~....,..~,.~...~..~.~.~.,~ "'""~'~"'~'"'~''""'~'~'"~"- ~'"'~'=~'"~*"~"~"'s~..~.....~.~....~ Total Plan Payment $0.00 ,.... .....~...=..,........~, .~. ~ .....,..~......~ Employee Responsibility $33.00 If you have a quesSon regarcJng 8;is cl~m. please contact AmeSca's Choice Hselthplans at 1. 800-633-4226 orvisit ourwebs#e at~.ACl-lonkte, com Note: This is not a bill. lO1~20o~ ~ Select Medical Corporation P.O. Box 60432 Kinl; of Prussia, PA 19406 Explanation of Benefits h,h,hh, hh,hllh,,h,,hhh,,,ll,lh,,I,,I,,,llhh, SNYDER, SUSAN 341 West 17th Avenue Apache Junction AZ 85220 GrOUD and Provider Information Insured and Patient Information Master/Group# 2000-2049 Insured Name SNYDER, SUSAN Group Name SELECT MEDICAL EPO PHCS Addl'ess 34! West !7Ih Avenue Location City, St Zip Apache Junction AZ 85220 Provider PHOENIX CHILDREN'S Provider ID 99-~.912668 Social Sec # ).77-50-6269 Provider Network Benefits Are Not Applicable To This Patient Name Ryan Snyder Network Claim Patient Acct # 180043778 · ~'~~.~,~:~.,.,::~~i~?~:~',,.~~~.~,.,,..,~" ~ ...... "~'~=='~ ~'"'~'~'~" '~'~ TM ..... ~"'~" "'~'~"~"~'~'~~'~=~?~ ~:~.=~' '%'""~'=: OUTPATtENT DIAG 3/7/0 ~ 3/7/ ........ '~"""'~'" '" '¥'" ""' ~ ~ '" ~'~' '"' '~:'~ ~ ~'=:":~%:~ ~='" ~'~%' "':~:~:'~v~ ~'~; ¢;~ :='"? :=' ? · uz ~oz.u~ $0.00 $581.05 4 0 $O 00 OUTPATIENT DIAG 3/7/0~ 3/7/01 $207 85 $0 00 $207 85 4 0 $O 00 *Remarks 4 E~C-NSE NOT COVc~=U BY YOUR PLAN TOTAL AMOUNT CHARGED $788.90 U2001239181650139:040:O AMOUNT NOT COVERED $788.90 ELIGIBLE AMOUNT $0.00 TOTAL DEDUCTIBLE TAKEN $0.00 Check Number:. 0 DEDUCT. REMAINING IN NET. Check Date: Thursday, October ]. 1, 2001 $0.00 Claim Number: 1 ! 26900095 DEDUCT. REMAINING OUT OF NET $0.00 Benefits Payable To: PHOENIX CHILDREN'S COB AMOUNT $0.00 Check Amount: $0.00 TOTAL DISCOUNT AMOUNT ~0.00 "'"~"~'"'""~""~'~'~''"'"'0""'"'"~'~"~'~"~"~~ Total Plan Payment $0.00 If you have a clueslion regarding f~ls claim, please contact Ame~fca'$ Choice Healthplans at 1- Employee Responsibility $788.90 800-633-4226 or visit our website at www. ACHonline. com Note: This is not a bill. 1012200115348/5701 Select Medical Corporation P.O. Box 60432 King of Prussia, PA 19406 Explanation of Benefits h,h,h h,,hl,,I,IIh,,I,,,I,h h,,,ll,ll,.I,,!,,,llh h, SNYDER, SUSAN 34! West 17th Avenue Apache Junction AZ 85220 Grouo and Provider Information Insured and Patient Information Master/Group # 2000-2049 Insured Name SNYDER, SUSAN Group Ncme SELECT MCD~CAL EPO PHCS Address 341 West iTtrt Avenue Location City. St Zip Apache Junction AZ 85220 Provider PHOENIX CHILDREN'S Provider ID 99-).912668 Social Sec # 177.50-6269 Provider Network Benefits Are Not Applicable To This Patient Name Jessica Snyder Network Claim Patient Acct# 180043779 ~ ~~!~i~i~~!~!~:,!~i~¢~.i!:': ~''' "'"' :~"" "! ii. i'~ 'i! i..":!i.' ..':!.: ~i!i ,'"~.' :~:'"' '~;,'"':" ~'°':' ~' '." ~;~ ~i''''' ~: '"" ~Y~? ~.~ ~¢.;i'?ii''~''' :~ .' :' '*., '~ ~'.~'.' '~.' '~' ':,":'.~ :~':' ,' '., ~:.~ :!., :.? ".~ ?' :'~'. ~ ":?..' ~.'%.'..' :?~}~}~.,~ :~ ,? ',,'. ? ,:-:. ,;:~ ?., ............................................. ~~:~.y~ '.'.'. ?~.,,',, :.? ....... ?.;. ? :.:. ? ?.t,.~:,.~,~,~?::::,.~:,?i DUPLICATE CL-~,IM $/7/0! 3/7/01 $207.85 $0.00 $207 85 36 0 $O 00 DUPLICA? E CL.&,rvl 3/7/0] 3,/7/0] $581.05 $0.00 $581 05 36 0 $0 O0 *Remarks 3~ THI$ CLAJM ALREADY CONS1DERED TOTAL AMOUNT CHARGED $788.90 U2001269051560353:040:O AMOUNT NOT COVERED $788.90 ELIGIBLE AMOUNT $0.00 TOTAL DEDUCTIBLE TAKEN $0.00 Check Number: 0 DEDUCT. REMAINING IN NET. Check Date: Thursday, October 11, 2001 $0.00 Claim Number: 1 ! 27000652 DEDUCT. REMAINING OUT OF NET $0.00 Benefits Payable To: PHOENIX CHILDREN'S COB AMOUNT $0.00 Check Amount: $0.00 TOTAL DISCOUNT AMOUNT $0.00 ~--.-,..~,~~.,~-.~,.,.~...=~.~,~.==~.~...~.,.~..~o~.~.~_~.~ Total Plan Payment $0.00 #'you have a question mgardlng ~ls cl~m, please confact Americe~s Choice Heelth~ens et 1- Employee Responsibility $788.90 800-633.4226 or ~ our webs#e at www. ACHon#ne.com Note: This is not a bill. 10122001 ~4S~5701 RICHARD L. SHINDELL, M.D. 333 E. OSBORN RD, #255 PHOENIX, AZ G501~ 602-604-B941 G T A T E ME N T PREPARED 8eptembe~ 21~ 2801 ACCOUNT #: 16710 DONALD 8NYDER 341W 17TH AVE APACHE JUNCTION AZ 852~0 Amount Enclosed TO ENSURE PROPER CREDIT TO YOUR ACCOUNT PLEASE RETURN TOP PORTION WITH PAYMENT .................... SERVICE PATIENT CODE DESCRIPTION AMOUNT Balance Fop~apd 0.00 02-07-81 JESSICA 99244 COMPR. CONSULT-NEW JESSICA 73558 FEMUR, 2V 75.0G(2~ JESSICA 73090 FOREARM~ 2¥ 60.00(2) 03-08-81 JEGSICA IN8 DOS:2.?.01 POLICY HA 0.00 03-13-0! JE88ICA BX DOS:2.7.01 REDED. WI 0.00 03-14-01 JESSICA 99213 INTERMEDIATE O.V. 75.00 JESSICA RUTH 37593 0.00(1] 03-29-01 JEGSICA INS DOS:3.14.81 DENIED F 0.00 04-11-01 JESSICA 99213 INTERMEDIATE O.V. JESSICA COCH~ #2216 -40.08 04-19-01 JESSICA SX DOS:3.14.01 RESUBMIT 0.00 04-20-01 SESSICA PHCS DOS~3.~4.0! -~1.00 PHCS CONTRACT ADJ. -34.00 04-26-81 JESSICA ~X DOB:2.7,81 DUPLICATE 0.00 JESSICA INS COVERAGE HAVE BEEN E 0.00 05-08-81 JESSICA BX DOS:4.11.01DEDUCTI~ 0.~0 BX CONTRACT ADJUSTMENT -19.00 05-09-01 JESSICA 99213 INTERMEDIATE O,V, 75.00 JESS/CA COCHK #~212 05-18-01 JESSICA PHCS DOS:4.11.01 -21.00 05-15-01 JESS/CA EX DOS:2.7.01DUP CLAIM 0.00 ~5-~2-01 JEGSICA BX D08]~.?.01DUP CLAIM 0.00 JESSICA BX DOS:4.1~.01 PREVIOUS 0.~0 06-20-01 JESSICA PHC8 DOS:5.9.01 -21.00 PHCS CONTRACT ADJ. 06-21-01 JESSICA ~X DOS:2.7.01 -197.68 BX CONTRACT ADJUSTMENT -133.00 Continued RICHARD L. SHINDELL~ 333 E. OSBORN RD~ PHOENIX~ AZ 8501~ 6~-604-8941 STATEMENT PREPARED 8epteebee 21~ ~001 ACCOUNT #,' 16710 DONALD SNYDER 341W 17TH AVE APACHE JUNCTION AZ 85~0 Aeount Enclosed TO ENSURE PROPER CREDIT TO YOUR ACCOUNT · PLEASE RETURN TOP PORTION WITH PAYMENT ....... SERUICE PATIENT CODE DESCRIPTION AMOUNT 06-21-0! JESSICA BX DOS~3.14.01 -60.00 08-20-01 JESSICA COCHK NEED TO APPLY TO DIF 0.00 09-04-01 JESSICA CHECK CK#9489 MORGAN & MQR -~7.00 MR COPIES OF MED. RECOR ~7.00 09-1~-01 JESSICA 99~13 INTERMEDIATE 0.¥. 75.00(1) 09-14-01 JESSICA COCHK ALLOCATION OF PRE¥IO 0.00 JESSICA PHCS ALLOCATION OF PREUIO 0.00 09-19-01 BX SX DUP PMT DOS=3.14. 40.00 BALANCEi Cuppent 30 Day 60 Day 90 Day 120 Day T 0 T A L (!) - This item has been ~iled fop insupance (~) - This item has been denied by insurance PAYMENT IS DUE UPON RECEIPT. THANK YOU. PLEASE PAY THIS AMOUNT -) 119.40 RICHARD L. SHINDELL~ M.D. 333 E. OSSORN RD~ #~55 PHOENIX~ AZ 8501~ 60~-604-8941 STATEMENT PREPARED 8epte~be~ ~1~ ACCOUNT #: 16788 DONALD SNYDER 341 14 17TH APACHE JUNCTION AZ Amount: En~l osed TO ENSURE PROPER CREDIT TO YOUR ACCOUNT .................... PLEASE RETURN TOP PORTION WITH PAYMENT .................... SER g I CE PAT I ENT CODE DESCR I PT I ON ............ AMOUNT ~-~7-~1 CHRIgTDPHER 99~43 EXT. CONSULT-NEW 17~. CHRISTOPHER 735~ FE~UR~ ~g 6~. ~8 (~) CHRISTOPHER 73148 FINSER~ 3V ~3-~7-~1 CHRISTOPHER BX DO~. 7.81 BILL OTHE ~-88-81 CHRISTOPHER INS DOB:~. 7. ~1 POLICY HA · 3-14-81 CHRISTOPHER 99~13 INTERMEDIATE O.g. 7~. CHRI 8TOPHER ~UTH 37599 83-~9-81 CHRISTOPHER IN~ DO~3. 14.81 DENIED F 84-11-81 CHRISTOPHER 99~13 INTERMEDIATE O. ~. CHRI ~TOPHER COCH~ 84-19-81 CHRISTOPHER BX DOS:3. 14.81 RESUBNIT 8~-~8-81 CHRISTOPHER PHC8 D08~3. 14.81 -~1. PHC~ CONTRACT ADJ. _34. 85-88-81 CHRISTOPHER BX DOB:4.11.81 DEDUCTIB ~X CONTRACT ADJUSTMENT -19. · 5-eg-el CHRISTOPHER 99~13 INTERMEDIATE O. ~. 7~. CHRZ ~TOPHER COCHN 8~-15-81 CHRISTOPHER BX D08:~. 7.81 DUP CLAIM 8~-~-~1 CHRISTOPHER BX DOS:~. 7.81 DUP CLAIH CHRISTOPHER BX DOS:~. 11.81 DUP CLA~ 86-81-81 CHRISTOPHER PHO~ DOS: ~. 11.81 · 6-19-~1 CHRISTOPHER BX DO~. 7.81 -~1. BX CONTRACT ADJUSTMENT -99. 86-~8-81 CHRISTOPHER INS DO~:5.9.81 -~1. INS INSURANCE ADJUSTMENT · 6-~1-~1 ~HR~STOPHER BX D08:~. 14. ~1 -68. 89-84-81 CHRISTOPHER CHECN C~ 94~9 ~ORSAN S MO -~7. Continued RICHARD L. SHINDELL~ N.D. 333 E. 08BORN RD~ #2~ PHOENIX, AZ 85812 682-604-8941 B T A T E M E N T PREPARED 8eptembep ~I~ ~801 ACCOUNT #t 16705 DONALD 8NYDER 341 W 17TH AVE APACHE JUNCTION AZ B5~8 Amount Enclosed TO ENSURE PROPER CREDIT TO YOUR ACCOUNT PLEASE RETURN TOP PORTION WITH PAYMENT .................... 8ERg I CE PAT ! ENT CODE DEBCR I PTI ON AMOUNT 09-04-0! MR COPIES OF ~ED REC TO ~7. ~0 09-1~-81 CHRISTOPHER 99~13 INTERMEDIATE O. ~. 75. ~8(1) · 9-19-81 BX ALLOCATION OF BX & p 4~. 88 BALANCE: Cuppent 30 Day 60 Day 98 Day 1~0 Day T 0 T A L 75.00 (1) - This item has been filed fop insupance (~) - This item has been denied by insupan~e PAYMENT IS DUE UPON RECEIPT. THANK YOU. PLEASE PAY THIS ANOUNT -) 113.20 RICHARD L. 8HINDELL~ M.D. 333 E. 08BORN RD~ #~55 PHOENIx~ AZ 8501~ 60~-604-8941 '~ T A T E N E N T PREPARED ~ep~eabe~ ACCOUNT #: 167~cj DONALD ~NYDER 3~ N ~TTH R~E RP~CHE ~UNCT~ON RZ Raount En~ osed TO EN~URE PROPER CREDIT TO YOUR ~CCOUNT .................... PLEASE RETURN TOP PORTION NiTH PAYMENT .................... SER~ ~ CE PAT ~ ENT CODE ....... DEBCRZPT~ON fl~OUNT Bal an~e Fo~a~d 8~-~7-81 RYRN 99~43 EXT. CONSULT-NEW 1 RYAN 73~ CLAgZCLE~ RYAN 73~9~ 83-87-81 RYAN BX DOSa~. 7.81 REBLD. WI DOS:~. 7. ~881 EXHAUBT 83-14-81 RYAN 99~13 INTERMEDIATE O. ~. RYAN RUTH 37~97 75.88 (~) 83-~9-81 RYRN IN8 D08:3.14.81 DENIED F ~4-11-8~ RYAN CHECK ~16 84-1~-81 RYAN BX D08~3.14.81 -~8' BX -47. CONTRACT ADJuSTmENT -~3. RYAN IN8 FIRST PARTY COVERABE ~.~ ~-1~-~1 RYAN BX 85-~-81 RYAN BX DOB:~. 7.81 DUP CLAIN ~6-84-81 RYAN BX D08:~. 7.81 PREgIOUSL BX DO~:~. 7.81 -189. CONTRACT RDJUSTNENT 86-~-81 RYRN IN8 D08:3. 14. ~1 -~1. MISC ALLOCATION OF PMT 16. 89-84-81 RYAN CHEC~ C~ 9489 NORBRN & MO -~7. HR COPIES OF HED TO ~TT ~7. BALANCE: Current 38 Day 68 Day ........................ 9~ Day 1~8 Day T 0 T A L (1) - This /tee has been filed fo~ insupance (~) - This item has been denied by insurance AYHENT I8 DUE UPON RECEIPT. THA~ YOU. - .................................... PLEASE PAY THIS ANOUNT -) 8.~0 S T A T E M E N T Account No.: A3343 Statement Date: 10/01/01 ARIZONA INSTITUTE OF MEDICINE & PEDIATRICS 1056 SOUTH VAL VISTA DR STE 2 (480) g81- 8650 DONALD SNYDER 341 W 17TH AVE APACHE,JUNCTION 85209 Page I of 2 Date Patient Description Billed to Charges Pat Resp. ~1/2g/01JESSICA OFFICE OUTPATIENT VISIT NEW OTHER 176.00 22.88 05/08/01 Billed to patient $176.00 06/21/01 BCBS INS PAYMENT $91.52 06/21/01 BCBS CR ADJ $61.60 06/21/01 Billed to patient $22.88 05/08/01 Billed to patient $176.00 06/21/01 BCBS INS PAYMENT $109.40 06/21/01 BCBS CR ADJ $61.60 ~5~'~ ...... ~'6~i~'~'~ ................. 6~E~ ..... 5~i~ ...... ~i~ ...... 05/08/01 Billed to patient $176.00 05/24/01 BCBS INS PAYMENT $109.40 05/24/01 BCBS CRA DJ $61.60 ~-~-~-~w~-`v"v~`~Lvv~f"~`L~.~`~co~~~A~;~~;~ ................. ~E~ ...... ~ .....~i~ ...... 05/I8/0i OTH INS PAYMENT $21.00 05/I8/0I OTH CR ADJ $33.00 05/18/01 Billed to patient $20.00 -~-.--""`-~v."v~L~v~~`~"~`~~~A~A~;~;~ ................. ~E~ ...... ~i~ ..... ~i~ ...... 05/18/01 OTH INS PAYMENT $21.00 05/18/01 OTH CR ADJ $33.00 05/18/01 Billed to patient $20.00 Account No. Date Patient Balance A3343 10/01/01 CONTINUED PLEASE PAY llJIS AMOUNT--> CONTINUED FOR QUESTIONS,CALL LYNN AT 480-981-8650 X 232 IF MEDICARE CALL BEFORE PAYING SECONDARY BALANCE. ~l~$e~! ..... ,- YOUR ACCOUNT IS SERIOUSLY PAST DUE, WE WOULD APPRECIATE PROMPT PAYMENT. )_~¢~ ~OU..' ~J S T A T E M E N T Account No.: A3343 ARIZO~LA INSTITLF~E OF MEDICINE & PEDIATRICS Statement Date: 10/01/01 1056 SOUTH VAL VISTA DR STE 2 (480)981-8650 DO/~ALD SNYDER 341 W 17TH AVE APACHE. JUNCTION 85209 Page 2 of 2 Date Patient Description Billed to Charges Pat Resp. 05/18/01 OTH INS PAYMENT $21.00 ' · 05/18/01 OTH CR ADJ $33.00 05/18/01 Billed to patient $20.00 Account No. Date A3343 10/01/01 Patient Balance 92.88 FOR QUESTIONS,C~ALL LYNN AT 480-981-8650 X 232 IF MEDICARE CALL BEFORE PAYING SECONDARY BALANCE. )'.JUR ACCOUNT IS SERIOUSLY PAST DUE. WE WOULD APPRECIAllE PROMPT PAYMENT. PlemsePlai! Your &Check?o a EAST VALLEY DIASNOSTIC IMAGING PO BOX PHOENIX AZ 85072 (480) 545-977~ 0~/28/01 AC:COUNT NUMBER: BALANCE DUE: $82.88 AM~JNT REM ITT~D ~XPiRATION DAT~ : CARD~IOi..~F~ NAME : S i~NATURE : CHRiBTOFHER SNYDER PATIENT: CHRISTOPHER ~YDER 341 W 17TH AVE FOR SERVICES RENDE;~ED AT APACHE JCT AZ 85220 AFACHE JCT. IMAGING CTR !!TNI~ IS YOUR FINAL NOTICE!! OU~ R~CO~:~DS INDICATE ~AT THE ABOVE ACCOUNT WILL BE SENT TO A COLLECTION AG~ENCY IF WE BO D~]T RECEIVE IMMEDIATE PAYMENT. THIS PlAY AF~'Lm[~T YOUR ABILITY TO OBTAIN FUTUR£ CREI]IT. WE URGE Y~ TO CONCLUDE THIS MATTER BY PAYIN~ T~ BALANCE DUE ON YOUR A~COUNT IN FULL WITHIN T~N (10) DAY~. YOUR ACTION NOM WILL C~TAI~y ~iNINATE FU~ C~..L~CTION A~TIVITY. !!FINAL NOTICE!! EAST VALLEY DIAGNOST)~C IMAGINE] F21~T~ CHRI~TOPHEF~ SNYO~ PO BE]X 5'255~ ACCOU~iT: 0~00250~ PH~]ENi× AZ 85072BALANCE 8L~:: $82.88 CUSTOMER SERVICE HOURS: g:O0 A.M. -.. J:O0 P-M. MON - FRI OFFICE PHONE: (480~ 545-9779 Select Medical Corporation P.O. Box 60432 King of Prussia, PA 19406 Explanation of Benefits I,,h,hh,,hl,,I,IIh,,I,,,I,hh.,ll,lh,,I,,I,,,llhl,, SNYDER, SUSAN 341 West 17th Avenue Apache Junction AZ 85220 Groue and Provider Information Insured and Patient Information Master/Group # 2000-2049 Insured Name SNYDER, SUSAN Group N--ms SELECT MEDICAL EPa PHCS Add,ess 341 West 17th Avenue Location City, St Zip Apache Junction AZ 85220 Provider S D MOSS Provider ID 99-1932214 Social Sec # 177-50-6269 Provider PHCS-PRIVATE HEALTHCARE SYSTEM Patient Name Jessica Snyder Network Patient Acct # P022630963 Description of Rervlc. Dal,~ of 8a~vl~e Amount Dil~unl ~lnt rju~'d R~msrka' Paid At Plan Claim M~ju Fi'Gm re (:harg~d Amau.t Arnt" % Pa)i I~KIM~KT '~Kb UI' F 9/]0/01 9/10/01 $146.00 $47.00 $0.00 15 100 $79.00 *Remarks rs M~aBER'$ COPAY APPUED TOTAL AMOUNT CHARGED $146.00 H2001274182210032:040:O AMOUNT NOT COVERED $0.0 0 ELIGIBLE AMOUNT $146.00 TOTAL DEDUCTIBLE TAKEN $0.00 Check Number.' 37464 DEDUCT. REMAINING IN NET. $0.00 Check Date: Thursday, October 04, 2001 Claim Number: 112760! 172 DEDUCT. REMAINING OUT OF NET $0.00 Benefits Payable To: S D MOSS cos AMOUNT $0.00 Check Amount: $79.00 TOTAL DISCOUNT AMOUNT ~47.00 ~-1~'-~"--~--~-~-~"~-''~-~`~-'~`~-~'~-'~-~-y'"b~'-~"~;~`.~ .,..~..,.,..~..,.~.... ~.,~...~,,.~.~.~, Total Plan Payment $79.00 '~"'~"-~"'"'"""'"~'~'*"=*"~"~"'"*'"~ Employee Responsibility $20.00 If you have e c~se~se ~ f~is claim, please contact Amedca~ Choice Healthplens at 1- 800-633-4226 or visit our website at www. ACHonline.sem Not~: This is not a bill. ~.S~Ol r~lr~3 Select Medical Corporation P.O. Box 60432 Kin8 of Prussia, PA 19406 Explanation of Benefits L'I"I'I',,I,I,,I,III,-I,,,I,I,I,,,,II, II,,,I,,i,,,iii,i,, SNYDER, SUSAN 341 West 17th Avenue Apache Junction AZ 85220 Lr°:erl~nJJ~r°~vnidnen .,,.... rio Master/Group # 2000-2049 Group Name SELECT MEDICAL EPO PHCS Insured Name SNYDER, SUSAN Location Address 34[ West 17th Avenue Provider S D MOSS City, St Zip Apache Junction AZ 85220 Provider ID 99-1932214 Social Sec # ! 77-50-6269 Provider PHCS-PRIVATE HEALTHCARE SYSTEM Patient Name Ryan Snyder Network .~ .................. Patient Acct # P022629967 ~acrildlon of .e, erwc. e Oale~ of ~enflue Amuufl! I~lKuunl .'lie! Cov'd R~markl' Pdld At Claim Meaa,~ge From rD Cha~ged Amou.t Ami'- Plan ev.uu 15 100 $79.00 'Remarks fs ~'F-~aF--~'SCOPAy,~,,U~ H2001274182210031:040:O TOTAL AMOUNT CHARGED AMOUNT NOT COVERED $146.00 $0.00 Check Number: ELIGIBLE AMOUNT $146.00 2heck Date: 37465 TOTAL DEDUCTIBLE TAKEN 21atm Number: Thursday, October 04, 2001 DEDUCT. REMAINING IN NET. $0.00 $o.oo ! ! 27601173 DEDUCT. REMAINING OUT OF NET $0.00 3enefits Payable To: S D MOSS COB AMOUNT =hack Amount: $79.00 $0.00 TOTAL DISCOUNT AMOUNT $47.00 Total Plan Payment $79.00 you have a q~.s~n mga.,,..._ fl~ _ . ~33~422~rt~s~t~ur~e~b~at~www~rn'a~t~ctAme8c~Ch~ceHe~sat~ ~mployee Responsibility ;~o~,: This is not a bill. 10052001/3579~3873 INTERWEST HOME MEDICAL CORPORATE BILLING OFFICE -- STATEMENT SALT LAICE ClTY, UT 84107-7349 V~A [] [] [] (801) 261=7144 v CREnIT CARD NO. ID~,~E, .(....'. , .. I 09~28]01 XccT'.~: "....' '. 12465 2606 N 16TH PHOENLV., AZ N5006-1403 X (602)253-4116 CAR~OLO;R S~GNATURE PRINTED NAME ON CARD 3-t48EXPInATION DA~ · *:=::~UTO**3-DIGIT 652 PLEASE REMIT TO: ADNdS, JOHN 341 W 17TH AVE INTERWEST HOME MEDICAL - ARIZONA 2606 N 16TH STREET APACHE JUNCTION, AZ 65220-7516 PHOENIX. AZ 85006-1403 IL,h,hL-hh,hllJ.,,I.,,hl.I,.,.ll,lL,,I,.I.,.lll,h,I Ih,h,hhJl,,.ll,.,.IJ..,.lhh.lli.,,..li.lh..,Jh,J.,Ij 01/22/01 097599 RENT BED SE/ti ELEC t,//S RAIL & HA 161.00 161.00 NA/tE: SNYDER ! JESSICA 01/22/01 097599 RENT ~/ALKER FOLDING ~/t,/HEELS 25.00 25.00 NA/tE: SNYDER! JESSICA 01/22/0 097599 RENT t,/LCHR REC DETATCH AR/t FTRST 165.00 165.00 RECLINER DETATCH AR/tS FOOTRESTS NA/tE *' SNYDER, JESSICA 01/2/*/01 097602 RENT STATIONARY COH/tODE 26.00 26.00 NA/tE :SNYDER, JESSICA 02/22/01 0980/*,,6 RENT ~/LCHR REC DETATCH ARft FTRST 165.00 165.00 RECLINER DETATCH ARHS FOOTRESTS NA/tE *' SNYDER, JESS ICA o.o0 [ ~-~.oo I o.oo ~ ~ felk~ up MIb yimr Inmsmnc~ compmy Io Inaum Iwopef Im]mm~t. If vm hmm not [:":';~'!;;?~::'i.'i'.'?.[ 0.00 Home Care Equipment & Supply I~TERWE,,RT HOME MEDICAL CORPORA'rE BILLfNG OFFICE --,E.,.s -- STATEMENT · ~,cc.~.'~o' . 12814 260~ N 16TH STaF.~ P,o~ Az s~o~-14o3 X 0.00 (602)2S3,.41 ]6 CARDHOLDER SIGNATURE MT PRINTED NAME ON CARD 3-150 EXPIRA'I~ON DATE · / -- ::::: 'AUTO'"'3--DIGIT 852 ADAMs. JOHN PLF-ASE REMIT TO: 341 W 17'rH AVE INTERWEST HOME MEDICAL - ARIZONA 2806 N 16'rH STREET APACHE JUNCTION, AZ 85220-75'16 PHOENIX. AZ 85006--'1403 Ih,I,,hh,,hh,hllh,,h,,hhl,,,dhll,,,I,,h,,llh h,I Ih,h,hhlh,,Ih,,,Ih,,,,Ihh,llh,,,,Ihll,,,,Ih,h,,ll · ' D~,'TE'~?' :. ' .... " .. .. .'. PORT'!'ON.~:. '~:'f~i.b~lON.'::· .... ,..., .... ....... ...... .~.. . .. . .'....~ ~....~...,~....,.......': ..,...'..:..: ....i..,,.~u.~...:...':....i..'/ ... .. ..~.; : . . ....... ....:~.~....:.. 0~/2~/0 097608 RENT ~LCHR SANDARD DET AR~ FTRST 6~.00 6~.00 STANDARD DETATCHABLE AR~S FTRSTS NA~E =SNYDER, CHRISTOPHER Home Cam ~uip~m ~ Supply CONSENT TO SET~LEMENT Donald Snyder states that he is Plaintiffand parent and natural guardian of minor Plaintiffs Christopher Snyder, Ryan Snyder and .Jessica Snyder in this matter, and that the statemems made in the foregoing Petition for Approval of Minors' Settlement are true and correct to the best of his knowledge, information and belief. He understands that the statements in said pleading are made subject to the penalties of 1 g Pa. C.S.A. §4904, relating to unswom falsification to authorities. Donald Snyder, Pa~'~'~atural Guardian of Christophe'~ Snyder, Ryan Snyder and Jessica Snyder, Minors EXHIBIT "~' MORGAN & MORGAN, P.C. BY: MELISSA MERRrFrs RIVER~ ESQUIRE IDENTIFICATION NO. 70303 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236=7959 ATFORNEYS FOR PLAIN'rIP-I, DONALD SNYDER, Individually, and as : IN THE COURT OF COMMON PLEAS Parent and Guardian of CHRISTOPHER : CUMBERLAND COUNTY, PENNA. SNYDER, RYAN SNYDER and : JESSICA SNYDER, Minors, : NO. 01-3259 Civil Plaintiffs : : CIVIL ACTION - LAW V. : : JURY TRIAL DEMANDED JOHN P. SULLIVAN and : FRANK J. SULLIVAN : Defendants : petition is approved, and is hereby ordered and decreed that the subject settlement is approved for the sum of $160,000.00, which shall be distributed as follows: A. $1,526.53 to Morgan & Morgan, P.C. to be used to reimburse it for advances made on behalf of Plaintiff; B. $40,000.00 to Morgan & Morgan, P.C. as compensation for professional services rendered; C. $45,960.08 to Jessica Snyder, which sum of money shall be placed in a federally insured interest bearing savings account or other approved institution pursuant to 42 Pa. C.S.A. 2039 and payable upon Order of Court or when Jessica Snyder reaches majority. The account will be marked accordingly. Jessica's social security number is 201-72-4565. D. $46,059.60 to Ryan Snyder, which sum of money shall be placed in a federally insured interest bearing savings account or other approved institution pursuant to 42 Pa. C.S.A. 2039 and payable upon Order of Court or when Ryan Snyder reaches majority, pursuant to 42 Pa. C.S.A. 2039. The account will be marked accordingly. Ryan's social security number is 167-72-1582. E. $23,418.63 to Christopher Snyder, which sum of money shall be placed in a federally insured interest bearing savings account or other approved institution pursuant to 42 Pa. C.S.A. 2039 and payable upon Order of Court or when Christopher Snyder reaches majority, pursuant to 42 Pa. C.S.A. 2039. The account will be marked accordingly. Christopher's social security number is 17:5-68-7686. F. $3,035.16 to Donald Snyder, parent and guardian of the minors named in this petition, for medical bills paid out of pocket. Plaintiff, Donald Snyder, parent and guardian of minor Plaintiffs, is hereby authorized to execute a release to the Defendant and its liability insurance carrier on behalf of Jessica Snyder, Ryan Snyder and Christopher Snyder. BY THE COURT: MORGAN & MORGAN, P.C. BY: SCO'I'F W. MORGAN, ESQUIRE IDENTIFICATION NO. 36'/21 120 SOUTH STREET HARRISBURG, PA 1'/101-1210 (717) 236-7959 A'YI'ORNEYS FOR PLAINTIFFS DONALD SNYDER, Individually, and as : IN THE COURT OF COMMON PLEAS Parent and Guardian of CHRISTOPHER : CUMBERLAND COUNTY, PENNA. SNYDER, RYAN SNYDER and : JESSICA SNYDER, Minors, : NO. 01-3259 Civil Plaintiffs : : CIVIL ACTION - LAW V. ' : JURY TRIAL DEMANDED JOHN P. SULLIVAN and : FRANK J. SULLIVAN : Defendants : ORDER TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above matter settled, discontinued and ended upon payment of your costs, only. MORGAN & MORGAN, P.C. DATED: April 16, 2002