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02-0327
IN RE: Petition of KlM L. WOLF, Parent and Natural Guardian of STEPHANIE ANNE BAILES, a minor. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-0327 CIVIL TERM ORDER OF COURT AND NOW, this ~'~ day of January, 2002, a hearing on the within petition for approval of compromise settlement and distribution of proceeds of a minor's claim, shall commenced at 1:30 p.m., Wednesday, January 30, 2002, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. Lee C. Swartz, Esquire For Petitioner EdgarB'~'~J. :saa ViNVAq~5~N~ JAN 1 B 2002 IN RE. Petition of KlM L. WOLF, IN THE COURT OF COMMON PLEAS Parent and Natural Guardian of · CUMBERLAND COUNTY, PENNSYLVANIA STEPHANIE ANNE BAILES, · CIVIL ACTION - LAW ORDER OF COURT On this day of ,200_, it is hereby ordered that the Petition for Approval of Distribution of Proceeds and Distribution of Proceeds of a Minor's Claim is approved and the settlement proceeds shall be distributed in the following manner: a. Payment of $44,080 to Kim L. Wolf, as reimbursement for lost wages and miscellaneous expenses set forth in the foregoing Petition; b· Payment of counsel fees for the law firm of Tucker Arensberg & Swartz in the amount of $37,500; c. Payment of $2,886 to the Commonwealth of Pennsylvania, Department of Public Welfare, to satisfy its lien for monies paid to the medical providers of Stephanie Anne Bailes; d. Payment of $165,534 to Stephanie Anne Bailes, a minor, which is to be deposited in the minor's name in a discretionary supplemental trust for Stephanie Anne Bailes with AmerServ Trust and Financial Services as Trustee; and e. Proof of deposit for the trust shall be filed of record in 30 days. BY THE COURT: IN RE. Petition of KlM L. WOLF, Parent and Natural Guardian of STEPHANIE ANNE BAILES, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW PETITION FOR APPROVAL OF COMPROMISE SETTLEMENT AND DISTRIBUTION OF PROCEEDS OF A MINOR'S CLAIM PURSUANT TO PA,R,C,P. 2039 Petitioner, Kim L. Wolf, files this Petition pursuant to Pa.R.C.P. 2039 to settle her minor daughter's automobile accident claim, and in support thereof avers as follows: 1. Petitioner, Kim L. Wolf is the parent and natural guardian of her minor child, Stephanie Anne Bailes, who was born on April 13, 1989. 2. On March 27, 2001, Stephanie Anne Bailes, then 11 years of age, was a passenger in a 1989 Ford Tempo owned by her stepfather, Brad E. Wolf, and operated by her sister, Jennifer L. Bailes. 3. While Jennifer was operating the Ford Tempo in an easterly direction on State Route 0174 in South Middleton Township, Cumberland County, Pennsylvania, she attempted to turn north on township road 537 and entered the path of a 1993 Ford F-150 truck operated by Sherri K. McCleaf who was traveling eastwardly on State Route 0174, approaching the intersection with Township Road 537. 4. Jennifer failed to observe the McCleaf vehicle as it was proceeding toward her and the two vehicles collided virtually head-on, with the Ford Tempo striking the McCleaf vehicle in the front center of the vehicle with the Ford's right front. Stephanie was seated as a passenger in the right front seat of the Ford Tempo. 45901.1 5. As a result of the collision, Stephanie sustained severe catastrophic and permanent injuries as will be set forth hereinafter. 6. After reasonable investigation by the Pennsylvania State Police, Troopers Kelly and Hanlon, it was determined that the accident happened so fast that Sherry K. McCleaf had no time to react or avoid the accident. 7. No responsible theory of liability will lie against Sherry K. McCleaf, which would in any way establish that she contributed to the accident. (See Commonwealth of Pennsylvania police accident report attached hereto as Exhibit 1 .) 8. At the time of the accident, the Ford Tempo was covered with a single limit $250,000 liability insurance policy issued by State Farm Insurance Company, and there are no other liability coverages available to pay damages for injuries sustained by Stephanie Anne Bailes. 9. State Farm Insurance Company has offered its total limits of $250,000 in settlement of the claim of the minor Stephanie Anne Bailes. 10. The injuries sustained by Stephanie Anne Bailes will be summarized briefly. Attached hereto are her admission record, operative reports and discharge summary marked Exhibit 2. She was flown in by Life Lion to the Hershey Medical Center whereupon an initial examination she was found to be unconscious and unresponsive to all verbal and painful stimuli, and her pupils were non-reactive. In addition to a severe head injury, she had a deformity noted to her right femur and a gross deformity of the right tibia-fibula with an eight-inch laceration vertically. She underwent brain surgery for multiple skull fractures and because she had a tear-like wound, she had to have a dual flap placed over the cortex of her skull, with scalp flaps 45901.1 down towards the skull base behind the ear and over the central flap, closing the wound. The general diagnosis was a severe closed head injury, including intrahemispheric subdural hematoma, left frontal subdural hematoma with punctate front polar contusions, dural tear s/p left compressive craniotomy with a valuation of subdural hematoma and repair of a laceration of the sagittal sinus, right occipital frontal and left frontal contusions, elevated ICP secondary to significant cerebral edema, s/p EVD, multiple skull fractures, respiratory insufficiency, pulmonary contusions, right wrist fracture, right femur fracture, right tibia and fibula fracture, s/p right ORIF. In effect, Stephanie sustained 15 separate fractures of her skull. She was discharged from the Hershey Medical Center on June 11,2001. An extensive discharge summary is attached to Exhibit 2, which indicates that she was still in a coma. 11. Stephanie remains in a coma and in the care of her mother and private duty nurses who attend to her 24 hours a day. Although she can utter sounds and move parts of her body, sh'e is unaware of her surroundings, can only be fed through a tube and is unable to attend to her physical needs in any fashion. She will need skull reconstructive surgery in the future. 12. In addition to Stephanie and Jennifer, the Klm and Brad Wolf family consists of their young son, John, four years of age. Stephanie's injuries have had a drastic impact on the family, not only emotionally but economically as well. At the time of Stephanie's injuries, her mother operated a thriving daycare center business of which she was the sole proprietor. Schedule 3 of Kim's income tax return, Exhibit 3, shows that she reported net income in the year 2000 of $10,693 with gross 45901.1 receipts of $31,229. The amount of $4,393 in deductions was depreciation, which represents a loss of cash flow to the family. In addition, miscellaneous expense, repairs and maintenance and utilities add another $4,000 worth of expenses which really was a loss of cash flow. Thus, the family has lost somewhere between $15,000 and $20,000 annually in spendable income as a result of the accident. As a result of Stephanie's injuries, Kim Wolf had to sell her business and spend all of her waking hours with Stephanie while she was at the Hershey Medical Center and following that period, at home where she acts as one of the round-the-clock nurses, spending 14 hours per day with Stephanie while two other nurses, provided by health insurance, care for Stephanie the rest of the time. While health insurance has paid the bulk of the medical expenses, the family has sustained numerous out-of-pocket expenses not provided by insurance. They are as follows: a. Miscellaneous monthly expenses of $222 which have been paid by the family for the over nine months since Stephanie was released from the hospital and which total $1,998.00. See Exhibit 4 attached. b. Over-the-counter medicine expenses of $184.89 per month payable since June 11, 2001, by the family which total $1,109. These expenses have now been picked up by Access, a Department of Public Welfare agency. See Exhibit 5 attached. c. April 9, 2001 to June 12, 2001 - gasoline expenses for traveling back and forth from Harrisburg to Hershey Medical Center- $900. Since that time, although Stephanie has come home, she is taken to doctors' appointments and trips are made to pick up supplies, medication and other items for her care which total $257 for a 45901.1 three-month period and continue to average approximately $85 per month, for a total loss of $510. See Exhibit 6 attached. d. Increased automobile insurance for Jennifer Bailes at a cost of $71.84 per month. e. $50 per month increase in electricity bill in light of Stephanie's need for remaining in a constantly lit room. She is unable to sleep much of the time and needs light while awake. Loss to date - $300. f. A handicap van was purchased through public contributions. The cost of insuring said vehicle is $28.12 more per month than the vehicle it replaced. g. $2,218 in miscellaneous expenses for various supplies for Stephanie from May to September 2001. See Exhibit 7 attached. h. During Stephanie's stay at Hershey Medical Center, her mother had to place her four-year-old son in daycare for four weeks at a total cost of $480. 13. In addition to the aforementioned expenses, Kim Wolf was forced to sell her daycare center equipment at an option which brought $3,000, approximately one- half of the value, thus sustaining a loss of $3,000. 14. In order to meet the family's expenses, the Wolf family had to sell their camper at a loss of $3,365. 15. In order to further upgrade Stephanie's bathroom to handicapped accessible, the Wolfs are going to have to renovate their home at an approximate cost of $14,500. See estimate attached as Exhibit 8. 16. The Wolfs have to purchase a larger washer and dryer at a cost of $700. 5 45~1.1 17. In computing the expenditures on behalf of Stephanie as above-stated, the Wolf family has expended approximately $44,080, excluding above-enumerated items 12. d. and f., and will have continued monthly expenses of $357 or $4,284 annually. 18. The Department of Public Welfare has a lien of $4,327 which has been reduced to $2,886 and will be reimbursed out of the proceeds of the settlement. See Exhibit 9 attached. 19. The private health insurance covering Stephanie has a maximum limit of $500,000 which, in all likelihood, will be exhausted within the next six months, at which time the Department of Public Welfare will pay for a major portion of Stephanie's medical needs. Special Needs Trust 20. Counsel for Petitioner has retained Lacy Hayes, Jr., Esquire, for the purpose of creating a Discretionary Supplemental Trust for Stephanie Anne Bailes. 21. The purpose of this trust is to preserve Stephanie Anne Bailes' eligibility for governmental benefits. The trustee would hold the money and decide whether to disburse any of the trust principal or income on behalf of Stephanie E. Bailes. 22. Petitioner proposes that AmerServ Trust and Financial Services be appointed as trustee. AmerServ Trust and Financial Services is a trustee for numerous trusts, including special needs trusts, and is a qualified corporate trustee. 23. Counsel for Petitioner strongly believes that the creation of this trust would be of great advantage to Stephanie Anne Bailes and her family. The trust is intended to enable the trustee to preserve the principal and income and keep it from being depleted 45901.1 by medical care that would otherwise be covered by governmental programs. The revised 2001 trust document is attached hereto as Exhibit 10. 24. In light of the financial losses enumerated herein, the loss of Kim Wolf's business income and the continued expenses, the Wolf family is losing approximately $19,284 to $24,284 per year. Proposed Distribution 25. Petitioner requests that from the settlement, Kim Wolf be reimbursed in the sum of $44,080 for her past lost wages and miscellaneous expenses and losses. While Stephanie's recovery to the status of a functioning teenager cannot be predicted, it is anticipated that at least two more years will pass before Kim Wolf will be able to once again enter the labor market. 26. Petitioner has been represented in this matter by the firm of Tucker Arensberg & Swartz. Their fee agreement, attached hereto as Exhibit 11, provides for a one-third contingent fee and costs. Tucker Arensberg & Swartz, however, has voluntarily agreed to reduce its fee to 15% and to pay from that fee the costs and fees in the sum of $5,400 incurred by Mr. Hayes for creating the trust and coordinating the trust and medical bills with the Department of Public Welfare. Consequently, the fee has been reduced to $37,500. Mr. Hayes' bills are attached as Exhibit 12 and total $5,400. 27. After payment of attorneys' fees, costs and distributions as requested above, $2,886 would be paid to the Commonwealth of Pennsylvania, Department of Public Welfare, to settle its subrogation interest. The remaining $165,534 of the settlement would be placed directly in the discretionary supplemental trust for Stephanie Anne Bailes with AmerServ Trust and Financial Services as trustee. 45~1.1 28. Petitioner believes that this proposed settlement is fair and reasonable, and asks that this Court approve the settlement and distribution of proceeds set forth above. WHEREFORE, Petitioner requests this Court approve the settlement and authorize the distribution of the settlement proceeds in the manner set forth in the proposed Order of Court. Respectfully submitted, TUCKER ARENSBERG & SWARTZ Lee C. S(Nartz ~ ~ I.D. No. 07258 Dennis R. Sheaffer I.D. No. 39182 111 N. Front St., P.O. Box 889 Harrisburg, PA 17108 ATTORNEYS FOR PETITIONER VERIFICATION I, Kim L. Wolf, hereby certify that I am the Petitioner in this action, and that the statements contained in the foregoing Petition are true and correct to the best of my knowledge, information and belief. I understand that any false statements made to this verification are subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. DATE: January ~ ,2002 Kim L. Wolf Exhibit I 00,! 994:. ** / /~ COMMONWEALTH OF PENNSYLVANIA ' '/ POLICE ACCIDENT REPORT REPORTABLE POUCE INFORMATION ACC!DENT LOCATION ~,~Mm H2-1183895 ~ F~,-.-,i~lvania State ~k;~ 2~ MU~CpAU~ SOUth. _~__,~. twp. COOE 213 P~CmCTSTAr"~' Co~ilMf2120 J 4ZOe~"~mO~ 24 PR/NC/PAL ROADWAY/NFORMA T/ON ,, TW o~ IN~RSECTING RO~: ACC~ INFO~ON ~, 0~5 ~ ~ 2 IF NOT A T IN~RSECTION: 0 3 ~T I ~T2 I -L~T ~ mT~ ~ W~~. MI, I I UNIT ~ 1 UNIT ~ 2 TITLE ~ ~ ~8~ PA ~T~-STATE ~ 419~7~ ~ PA~ ' Br~ E. ~css 314 ~-~ RO~ 4~ ~ss 1~ N~ R~ : ~c~ Ca~. PA 17013 ~ c*~.sT,~ &~c~ S~. PA 1~57 " 1M9 I Ford 1~3I F~ -:::_ -.-- 1 ~ 1 s~ 0 ~ ' --'- t2 0 ~ J~ L. ~S " ~.~ ~ 314 ~ ~ 1~ ~ R~ ~ ~ 717-2~ F PAG~ 01 PennDOT - BHSTE :' ~ARPJ~.IRG HAY 2 5 2001 00'J.995 I { 3 { F { 11 i 3 { 1 j 0 $-'-~-~h~.,;.BAlI.ES314 I I I I I '---- ~A No C~lpho~ ~is ~o v~e ~ ~ as un~l ~t on SR0174. Un~ ~p~ to ~m of ~ s~ ~e ~ s~e ~ ~ un~l. ~ ~ ~ ~ on ~ ~ ~ of SR0174 ~ ~e ~ SR0174. P~ ~ ~ ~ ~e ~nsis~ by ~ U~ ~ a~. ~ ~ w~ in ~ ~ ~. I~~~ C~B~S a ~ ~ ~ 0~101 at 0~ ~ ~ 1~ ~s ~i~ ~1 ~m ~ ~sh. MORE ~ m ~ 1417~12 ~l ~ ..... CHAMBERS told me that he first saw un~l as it pulled out ahead of him onto SR0174 from Bonnybrook road. i asked him what his spc=d was and he informed me that he wasn't looking at it at the time but he thought he was going about 45mph. He advised that she was pulling away from him as they travelled east. He did not observe any traffic in front of unit#l. He told me that the sun was not that bright but he recalled that he had his visor down. He related that as she approached the intersection, there was no sign of her slowing down. He told me that unit~l turned in front of uniW2. He indicated that unit~2 had no time to react. I interviewed Matthew KOSER at the scene on 03/27101, at 0738 hours and he related that he was a passenger in CHAMBERS vehicle. He recalled following the vehicle from Petersburg road. He told me that they were six or seven car lengths behind uniW1. He did not observe any traffic' ,.? front of uniffil. He did not think that it was that bright but he did have his visor down. He thought that unit~l was travelling faster than the speed limit. I interviewed operator#2 at the scene on 03/27101 at 0743 hours, and she related that she was going to Shippensburg when the car turned in front of her. She told me that it happened so fast she dicYnt have time to react. She thought there may have bean a vehicle travelling east in front of unitJl prior to the crash. She thought this vehicle continued east on SR0174. I interviewed operator1 at the scene on 03/27/0i, at 0755 hours, as she was being treated by medical personnel. She could not recall the details of the 'accident. I was assisted at the scene by Tpr. KELLY and Tpr HANLON. Measurements were taken and the scene and shall be retained if needed. Tpr. HANLON photgmphed the scene and these photos shell retained at PSP Carlisle. Operator~l received an SP7-0015 at Carlisle hospital and one was mailed to operator/FR. Both units were removed by Richwine's towing, Carlisle, PA. 0 0 0 0 g4 mVF. STIGAlIOfl PennOOT - BHSTE Exhibit 2 MAIN OFFICE 412 Erford Road Camp Hill, PA 17011 Stanley E. Schneider, Ed.D. Director SSOCIATES OF Camp Hill: (717) 732-2917 Hershey: (717) 533-4312 Carlisle: (717) 245.2289 Chambersburg: (717) 263-9392 FAX: (717) 732-5375 C PSYCHOLOGICAL EVALUATION Client: Birth Date: Age: Education: Referring Agency: Intake Coordinator: Evaluation Date: Stephanie Bailes 04/13/89 12yrs 7mos 3days Home schooling (7th) CP MH/M2R Christina K. Penn 11/16/01 Referral Information. Stephanie has been referred for a psychological evaluation to help determine intelligence and daily adaptation levels toward qualification for coun .ty services. I met with Slephanie and her mother in their home to conduct the evaluation. Assessment Tools. Review of records, Observation, Parent Interview. Review of Records. Materials available for review included the 2000-2001 Report Card, CP MH .M~R Intake, Hershey Medical Center records, and the school district Comprehensive Evaluation RePort and IF.p. Stephanie's report card for the 2000-2001 school year at Yellow Breeches Middle School indicates an average 3rd quarter subject grade of 91. A typical comment was. "Work completed to high standards." Subsequently, Stephanie was in an automobile accident on 03/27/01 and suffered a "severe closed head trauma." A letter from Dr. Ramer (10/12/01) indicates continued "very slow recover)'" with little change in neurologic status. Stephanie is in a deep coma. Treatment goals include relearning x%ual skills, relearning expressive language, relearning auditory/receptive skills, relearning beo~ming perceptuaL, motor skills, passive listening to information from immediate, recent, and remote memors.', passive reception of sensory stimulation, and demonstration of a differential response to people. Pulmonary. status was stabilized by 6/1/01 with healed trach site, but swallowing remains problematic. Observation. I made an afternoon visit (1:30PM) to the home. One large room, formerly used for child care, is devoted to meeting Stephanie's needs. Stephanie, her mother, and a neighbor who had come to help were present. Stephanie appeared to be laying on her side comfortably in her bed. She was dressed casually and made a neat and clean appearance. There were occasional vocal/zations, and she may have been aware of my presence by the sound of a new voice, but I cannot be sure. She evidenced no purposeful verbal or perceptual/motor skills. Mother would stimulate Stephanie with touch and the ~4bration of her mattress. During my visit Stephanie did omprehensive Psychological Services · Drug and Alcohol Treatment~ not appear to become emotionally distressed, but some vocalizations were louder than others. There was little evidence of specific reactions to particular adult behaviors or statements. Parent Interview. Living at home are mother, Klm Wolf,, Stephanie's stepfather Brad, her brother John (5), and her sister Jennifer (17). Father, Don Bailes, visits briefly, the last time about one month ago. The neighborhood is well organized to help Stephanie. Someone helps out with direct care almost dally, and a number of fund raisers have been held. Prior to the accident Stephanie was a good student, and her concentration benefited, beginning in 5th grade, with a mild (5mg) daily administration of Adderall. Subsequent to the accident, Stephanie has received various ~erapies from two service tracks. The school provides one hour per week in-home of speech, occupational therapy, and physical therapy, the a teacher is present for two hours. Health insurance provides two hours per week of occupational therapy and physical therapy, and one hour per week of speech. Mother's additional goal is to provide music therapy. Prior to her accident Stephanie was very active. Interests included field hockey, playing the trumpet and piano, soccer, bicycling, reading, camping, and jumping on the trampoline. She had begun to baby-sit and was a member of the school choir and band. She was a member of the church choir and had just begun to participate in a church youth group. She had a good friend Abby, and three girls still visit her regularly. She might have had six girls over for a birthday and slumber party. Problems occasionally take the form of loud vocaliTations when agitated by being on her side too long or from wetting her diaper. Heat regulation has to monitored very closely since that brain function has been impaired, and there is seldom oppommity to be outdoors. Stephanie does run fevers, and a delicate temperature balance in the environment is required. Diagnostic and Clinical Impressions. Stephanie has experienced a catastrophic decrease in functioning. Level of person/environment interaction falls in the profoundly mentally retarded range with IQ estimate below 20 following severe closed head trauma. Stephanie is certainly deserving of all county services available to a profoundly multiply handicapped child. Eug~f~ H. Stecherl M.A. Psychologist GAP/CPM]l/MREval/StephanicBailes 11/16/01 2 THE MILTON S HERSHEY MEDICAL CENTER PO BOX 853 HERSHEY, PA 17033 .... MEDICAL RECORD COPY: .( 9 OOS! 2 't'g~4 04/13,/1 gSg BAIL£S $1LPHANI[ + .......... ++ ........... ++ .......... ++ ....... ++ ........ ++ .... ++---++---++-+ MR# OOS # DATE TIME ROOM/BED LOC SVC SRC 09~30 21954 03/27/01 2000-19 + .......... ++ ........... ++ .......... ++ ....... ++ ........ ++ .... ++__-++---++-+ + ......................... ++---++ .......... ++---++--++ .... ++---++---++ .... + 04/13/1989 11 + ......................... ++---++ .......... ++---++--++ .... ++---++---++ .... + + ................................ ++ .................... ++---++ ............. PATIENT ~DRESS J CITY ST ZIP CODE 314 BONNYBROOK ~ I CARLISLE PA 17013 + ................................ ++ .................... ++---++ ............ + + ............ ++ ........................... ++ ............... ++ ............. + I PT PHONE EMPLOYER J 185-70-6116 + ............ ++ ........................... ++ ............... ++ ............. + + ......................... ++ ............. ++ ........... ++ ............ ++ .... + + ......................... ++ ............. ++ ........... ++ ............ ++ .... + ...... ......... ...... ..... ::::::::::::::::::::::::::::::::::::::::::::::: DIAGNOSIS:HEAD T~UMA ~ Ic°'E~s J + .................................... ++ ................................... + 22400 KAN~V PA~ M 22400 KANEV PA~ M + .................................... ++ ................................... + + .................................... ++ ................................... + F~ILY PHYSICIAN REFERRING PHYSICIAN SAL~SS KYM A iPO BOX 850 J UNI~RSI~ HOSPITAL JHERSHEY PA 17033 FAX: J717 531-8174 FAX: PennState Gei._~ger Health System LIFE LION Critical Care Tra. nsport The Milton S. Hersh~ Medical Center Helicopter Interhospital Transport Note 01-0465-A 03/27/2001 On-Scene N29 ILL Patient Transported Slp.,phanie Bailes 12 Y/O F 04/13/1989 363052 Multiple Tm~ ~eludlng h~ pel~s, ~d ~1:{~ S P ~ ~ ~'/:35 CI~ J~on ~ey, ~s Hour, ~e C~ Rus ~ 07:26 ~ 08:08 ~ 08:16 ~ ~, ~.~.az ~ 08:19 ~ 08:20 LIFE LION TRANSPORT NOTE PATIENT NAI~E: BAILES, STEPHANIE A PATIENT NUMBER: 0363052 DATE OF SERVICE: 03/27/2001 SEX: F DATE OF BIRTH: 04/13/1989 SS ~: 185-70-6116 FLIGHT #01-0465-A DISPATCH INFORMATION: Life Lion was initially requested to be on standby, then to respond stat to Cumberland County to assist Medic $83 for a motor vehicle accident with entrapment. While en route,-Life Lion communications center reports of possibly two patients entrapped, with no further details available. During the flight, landing zone command reports of one trauma arrestand a second patient who our crew would be transporting. Weather at the time of the flight posed no difficulties, and the flight was able to be conducted under visual flight rules. Aircraft 291LL arrived at the landing zone approximately 100 yards from the motor vehicle accident at 0747 hours. Initial patient contact occurred at 0751 hours in the basic life support unit where the patient was being attended to by two paramedics, Sheedy and Devon from Medic ~83. Source of information at that time was by verbal report from Paramedics Devon and Sheedy. HISTORY: Prehospital reports that the patient was a restrained front seat passenger in a small passenger vehicle that impacted head-on into a large pickup truck. Most of the damage is noted to the patient's side of the vehicle, and there is significant front end damage with approximately 12 inches of intrusion reported into the passenger compartment. The patient was entrapped by the dash and had to be extricated by the fire department. This extrication lasted approximately 10 minutes. On EMS evaluation, the patient was found to be unresponsive, ant Life Lion was requested to the scene to transport the patient t, the closest trauma center for definitive care, evaluation, and treatment. PAST MEDICAL HISTORY: Unknown. MEDICATIONS: Unknown. ALLERGIES: Unknown. Page 1 of PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 0363052 The patient's weight is estimated to be 30 kg. TREATMENT PRIOR TO ARRIVAL: Included full C-spine precautions including long backboard, CID, cervical collar and straps, also extrication by the fire department. There were several IV attempts and at least two attempts at intubation by prehospital crews. PHYSICAL EXAMINATION: Initial exam finds this 12-year-old female patient.supine on the long spine board with full C-spine precautions in the place in the rear of the basic life support unit, with attending paramedics at the bedside. Neurologic: The patient is unconscious and unresponsive to all verbal and painful stimuli. C-spine/spine: There is crepitus palpated on the posterior cervical spine, predominantly noted on the right side. The rest of the spinal area was not visualized by this crew due to full cervical spine precautions being in place, but prehospital reports no further obvious injuries. HEENT: Pupils nonreactive, with the left at 7 mm and the right at 3 mm. The patient has a 2-inch laceration above her right eye with minimal bleeding. There is blood and vomitus noted in the airway. The neck has a large abrasion noted on the right side laterally. Chest: Breath sounds equal bilaterally with rhonchi auscultated in all fields. Chest is symmetrical on inspiration, but the patient has a poor respiratory effort. No crepitus palpated. She has a large contusion noted on the right upper chest/right shoulder area. The rest of the chest exam appears to be atraumatic. Abdomen is firm and distended, with no contusions, abrasions, punctures noted. Pelvis is unstable, with no gross deformity. Extremities: All extremities flaccid x 4. Upper extremities: Right shoulder is unstable on palpation, and ther~ are abrasions noted on both hands. Lower extremities: The patient has deformity noted to her right femur with external rotation. This injury is closed. She also has gross deformity of the right tib-fib, with an approximate 8-inch laceration vertically with obvious deformities of the bones. This right extremity is pulseless on palpation and has an extended capillary refill of >5 seconds. Capillary refill in the upper extremities is approximately 4-5 seconds. Radial pulses are weak. Left leg has numerous contusions noted on the left lower leg. Further exam of the extremities is without additional obvious gross injury. Skin is pale, cool, and dry. The patien' is acyanotic with the exception of the nailbeds oR the right foot. ~. Initial vital signs as reported to us by prehospital: heart rate 160, current respiratory rate 6, blood pressure 80/62. Pulse ox had not yet been attached. The patient is being ventilated via BVM with 100% oxygen via mask. An EKG monitor also had not been attached as of yet. Page 2 of PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 0363052 TREATMENT/PROGRESS: Life Lion arrived, landed at remote landing zone, and walked to the basic life support unit. At that time, the crew was introduced to the prehospital crews, and a verbal report is received from paramedics Sheedy and Devon at the time of patient contact. The patient was then assessed by Jason Clark, R.N. At the time of assessment, the patient is supine on a long spine board with CID, C-collar, and straps in place. She is being ventilated by Paramedic Devon via a bag valve mask with oxygen at 100%. Due to the patient's unstable airway, the Life Lion crew felt that intubation was required immediately. Paramedic Sheedy was able to obtain IV access with an IV of normal saline infusing wide ope~n through a 20-gauge catheter in the left antecubital ~. The IV flowed easily without signs of infiltrate. At that time, Jason Clark, RN, administered 30 mg of succinylcholine IV to facilitate intubation. After being ventilated for an additional 1-2 minutes, the airway is secured with oral intubation by Paramedic Macauley with a 7-mm ET tube. Placement is confirmed with visualization, auscultation, and "frosting of the tube." The tube is secured, and ventilations continued via BVM with 100% oxygen at a rate of approximately 24 per minute. The patient was given 3 mg Versed intravenously by Jason Clark, RN. This Versed was given at approximately 0804 hours. The crew and patient were transported in the basic life support unit to the landing zone. Upon arrival at the landing zone, the patient was removed from the basic life support unit and secured to the Life Lion transport litter. The patient is transported to the aircraft and hot-loaded in the head-first primary \0~position. The oxygen is switched to the lo~k system for flight. At that time, monitoring devices including EKG, pulse oximetry, and blood pressure cuff are attached for continuous monitoring during flight. Pulse oximetry is revealing 100% saturation via ET and BVM, and the monitor is sinus tach without obvious ectopy. In flight, the patient is ventilated via BVM by Jason Clark, RN. Chest rise at that time appears to be unequal, and breath sounds are reauscultated with breath sounds noted in all fields, but somewhat decreased on the left side. The endotracheal tube at that time is backed up from 23 mm at the lip to 21 mm at the lip and resecured. There is no obvious improvement noted to patient aeration with this change. A feeling that this may be due to some abdominal distention due t( the ventilations via BVM prior to our arrival, a 12-French orogastric tube was inserted by Jason Clark, RN. Page 3 of PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 0363052 A brief report was relayed to medical command at M.S. Hershey Medical Center, with an update on the patient's condition. No orders were offered and no further treatment is indicated. For a list of vital signs and a copy of the EKG, please refer to the attached EKG strips and Propaq printout. IMPRESSION: Multiple trauma, with the patient being unresponsive, with head injuries and unstable pelvis, a possible right closed femur fracture, and a possible right tib-fib fracture. DISPOSITION: Life Lion arrived at M.S. Hershey Medical Center helipad at 0816 hours. The patient was hot off-loaded and oxygen was switched to a portable cylinder. She was then transported to the trauma room where transfer of information an6 care was completed to the attending RN and trauma team. Total fluids infused by prehospital staff was approximately 300 cc of normal saline. At the time of transfer, the patient was unstable. Page 4 of PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 0363052 No questions were voiced by the trauma team, so this crew returned available. PRIMARY CREW MEMBER: Kristin J. Macauley, ~Jason Clark, R.N. Peter W. Dillon, M.D. EMT-P KJM/beg D: 03/27/2001 T: 03/27/2001 19:34 Page 5 of. PENNST TE WThe Milton S. Hershey Medical Center The College of Medicine Health Information Services HU24 P.O. Box 850 Hershey, PA 17033-0850 \OPERATIVE REPORT PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 1138054 DATE OF BIRTH: 04/13/1989 LOCATION: 7115 DATE OF SERVICE: 04/28/2001 SEX: F SURgEON(S): Paul M. Kanev, M.D., ~M.S.* ASSISTANT (S): PREOPERATIVE DIAGNOSIS: POSTOPERATIVE DIAGNOSIS: OPERATION PERFORMED: ANESTHESIA: ESTIMATED BLOOD LOSS: Skin break down, left craniotomy site, superficial infection. Skin break down, left craniotomy site, superficial infection. Debridement'of three sites of the left craniotomy incision and skin closure. General endotracheal. 100 cc. INDICATIONS: Stephanie is a 12-year-old young lady who five weeks ago was in a motor vehicle accident sustainin~multiple skull fractures, subdural hemorrhage, intraparenchymal hemorrhage, and injury to the sagittal sinus. She survived her initial injuries and at this point was in rehab with a tracheostomy in place and developed CSF leak from a site of superficial skin breakdown. The spine fluid had extensive inflammatory cells and the wound appeared purulent and deep enough to require debridement. After lengthy discussion, consent to proceed with surgery was granted. OPERATION: After identification of the child she was transferred to the OR and underwent successful induction of general endotracheal anesthesia. The patient was positioned supine'with left shoulder elevation and head rotation from the left to the right. · Hair around the path of the previous trauma flap was shaved. The previously placed multiple sutures of Prolene were then removed and the region was extensively shampooed, decreased, and the~ draped and prepped in the usual sterile fashion. After infil~tion of the planned elliptical.incision sites'with .5% Lidocai~e, 1:200,000 Epinephrine, a finger size 5 cm x'l 1/2 cm elliptical incision was incised just above the ear at thC site of the breakdown. The deep tissues were purulent and partially necrotic. All devitalized tissue was debrided and we removed an extensive amount of the surgicel that had been placed, layered over the surface of the brain to promote a pseudodura. After extensive irrigation a dural, flap was HAY 0 9 Page 1 of 2 An Equal Opportunily Universily PATIENT NAME: BAILES, STEPHANIE A PATIENT NIIMBER: 1138054 reapproximated over part of the cortex with interrupted 4-0 Vicryl. After extensive further irrigation and undermining of the scalp flaps down towards the skull base behind the ear and over the central flap, the wound was closed in a deep layer with inverted 3-0 Prolene followed by multiple interrupted 3-0 Prolene mattress sutures. At the midfrontal region in the plane of the midpupil line at her drain site, a partial breakdown at that site was elliptically excised. The- deep tissues were not at all purulent, but there had been superficial \necrosis of the skin. After extensive irrigation and hemostasis, this wound was closed with inverted deep 3-0 Prolene and then with multiple interrupted 3-0 Prolene vertical mattress sutures in the skin. In the posterior frontal midline skin incision there was a pinpoint area of pending breakdown, this was elliptically excised after debridement of the deep tissues and extensive irrigation that wound was closed in a similar fashion with inverted deep 3-0 Pr~%ene sutures augmented by 3-0 vertical ~attress skin stitches. Sterile dressings of Telfa and tape were applied at all three sites. DICTATING MD: Paul M. Kanev, M.D., M.S.* PMK/jkk c: PCR D: 05/01/2001 Word Processing Clerk Surgical Fees 05/02/2001 06:50 Page 2 of 2 Health System ~The Milton S. Hershey Medic ' O. enter PROGRESS REPORT PICU Attending Note 3/28/01 Stephanie Bailes I The Milton S. Hershe)4r-! Medical Center History: M~N )6305Z 7121-} 75 BAiL£$ ST[PHANIE A D:ILLOn PETER W ROil 12 year old s/p MVA with severe closed head injury, including intrahemispheric subdural hematoma, left frontal subdural hematoma, with punctate frontal polar contusions, dural tear s/p left decompressive craniotomy with evaluation of subdural hematoma and repair of a laceration of the sagittal sinus, right occipital frontal and left frontal contusions, elevated ICP secondary to significant cerebral edema, s/p EVD, multiple skull fractures, respiratory insufficiency, pulmonary contusions, historY of hypotension, fight wrist fracture, right femur fracture, right tib/fib fracture, s/p right ORIF. Patient examined and reviewed by systems with pediatric ICU housestaff: CNS: On exam her left eye is difficult to open secondary to edema. Right pupil is sluggishly reactive. The patient displayed some spontaneous movement of her right upper extremity. To painful stimuli the patient does have movement of her lower extremities and left upper extremity. There is no decorticate or decerebrate posturing consistently noted on exam at this time. In addition the patient also has an intermittently positive corneal reflex, along with a positive cough and gag during suctioning. The ICP has ranged between 28-35, with ICP drainage of approximately 73 cc's over the past 12 hours. This morning the patient was sedal~l, mildly hypervenfilated, and received osmolal therapy with an improvement in the ICP to approximately 17-22. In addition we have continued CPP management, along with EVD drainage. The patient also has been placed on prophylactic anticonvulsants consisting of Dilantin. RESP: Chest x-ray shows bilateral interstitial markings consistent with pulmonary edema/beginning ARDS. The PO2 has ranged between 51-70. This morning the PO2 was greater than 100. The patient was on volume control SIMV ventilation on 100% oxygen with a PEEP of 7. Plan today will be to place the patient in PRVC with a tidal volume of ,500, rate 16, which has been decreased to 14, I-time of 1 second, PEEP 8, FIO2 80%, yielding mean airway pressure of approximately 13, peak pressure of approximately 30-31. With these changes the arterial blood gases show an improvement in the PO2 to 160. Base deficit, which was -3, has improved after bicarbonate, however the pH was 7.51 with a PCO2 of 26, therefore the rate was decreased. A repeat blood gas will be obtained with an overall goal to maintain the PCO2's in the low 30's. CV: Heart rate has ranged between 56-90. Mean arterial blood pressures range between 102- 113. On exam the patient has a IH/VI systolic ejection murmur at the left middle sternal border,. Currently the patient is on Phenylephrine, which has been maintained at .8 mcg/kg/min. The plan today will be to add Dobutamine at 5 mcg/kg/min, which has been subsequently been titrated to 8 mcg/kg/min to enhance cardiac output, especially given the right lower extremity pulses. In addition we will titrate thg, phen~lephrine to maintain a CPP between 70-90. 9 .~' " GI: Currently the patient is NI~. Her abdomen is soft and non-tender. . . FEN: Output exceeded the input by approximately 1 liter excluding the OR fluids. Examination of electrolytes reveals a mild anion gap metabolic acidosis. Sodium has ranged between 145-153. BUN and creatirdne are 12 and 0.5. Magnesium was low, which will be repleted and rechecked. The patient had received DDAVP yesterday for presumed DI. Plan today will be to follow serial sodiums, along with serum osmolarities and urine specific gravities. As previously stated, the patient was treated with osmolal therapy with a reasonable response. The plan will also be to maintain the serum osmolarity below 320. PROGRESS REPORT MR6.1Rev. 8/96 HEME: ID: Hematocrit is 33.7 post transfusion. Platelet count is 220 post transfusion. PT, FIT are grossly within normal limits. Subsequent PT however was elevated, therefore the patient received FFP. The patient is on prophylactic Kefzol. va, M.D. Assistant Professor Pediatric Critical Care Medicine TOTAL TIME SPENT WITH PATIENT TODAY PENNSTATE Milton S. Hershey Medical Center College of Medicine CXR (portable) BAILES, STEPHANIE A - 1138054 * Final Report * DX PORT CHEST-AP,SUPINE, INSP, PORT, PATIENT NAME: BAILES,STEPHANIE PATIENT MI{N: 01138054 PATIENT DOB: 13-Apr-1989 EXAM NUMBER: 374A-050901 EXAM: DX PORT CHEST - AP , SUPINE, INSP, ORDERING PHYSICIAN: PAUL KANEV PORT, Exam: Exara: DX PORT CHEST - AP , SUPINE, INSP, PORT, DX FEMUR RT - AP , LAT, XTAB, PORT, DX TIB-FIB RT - AP , LAT, XTAB, PORT, DX WRIST RT 1-2 VIEWS - AP , LAT, XTAB, PORT, PORTABLE CHEST X-RAY AND PORTABLE AP AND LATERAL X-RAYS OF THE RIGHT WRIST, RIGHT FEMUR, AND RIGHT LOWER LEG FROM 9 MAY 2001 AT 0835 CLINICAL HISTORY: MVA with fractures from March. The patient has a fever. DISCUSSION: CHEST: Comparison is made to the portable chest x-ray from 1 May 2001 at 0005. The tip of the tracheostomy tube is 4.0 cm above the carina. There are mildly increased interstitial markings in both lung fields; this may represent increased fluid status. There are no focal infiltrates identified. The cardiomediastinal silhouette is within nozaLal limits. RIGHT FEMUR: Comparison is made to the AP x-ray of the right femur from 2 May 2001 and the lateral x-ray of the right femur from 19 April 2001. There has been no interval change in the position or alignment of the-external fixation device. There is no evidence of fractur~f . or lucency about the orthopaedic hardware. Again noted is the' oblique fracture of the mid right femur with one-half shaft Printed by: Printed on: Men, Chanthan 09/20/2001 1:59 PM Page I of 3 (Continued) An Equal Opportunity University PENNSTATE Milton S. Hershey Medical Center College of Medicine CXR (portable) BAILES, STEPHANIE A - 1138054 diameter of lateral and posterior displacement of the distal fragment with respect to the proximal, without change. Callus formation adjacent to the fracture site is noted, consistent with some interval healinG. RIGHT LOWER LEG: Comparison is made to the similar study of the right lower leg from 2 May 2001. There has been no interval change in the position or alignment of the external fixation device. There is no evidence of fracture or lucency about the orthopaedic hardware. AGain noted is the complex fracture of the mid right tibia with valGus angutation and approximately one-quarter shaft diameter of medial displacement of the distal fragment with respect to the proximal, without change. AGain noted is the 4 cm long area of absent cortex along the lateral margin of the right tibia just proximal to the fracture site, without change. AGain noted is the transverse fracture of the mid right fibula with approximately two shaft diameters of lateral displacement of the distal fragment with respect to the proximal and 3 cm of overridinG, without change. An oblique fracture of the proximal right fibula is again noted with mild apex lateral angulation, without change. There is no evidence of callus fozmation at this time. RIGHT WRIST: Comparison is made to the AP x-ray of the right wrist from 30 April 2001 and the lateral x-ray of the right wrist from 2 May 2001. Overlying cast material obscures fine detail. There has been no interval change in the position or alignment of the Salter II fracture of the distal right radius with dorsal angulation and mild radial displacement of the distal fragment. Increased sclerosis with new bone formation is noted, consistent with some interval healinG. A buckle fracture of the medial margin of the distal right ulna is again noted, without change. IMPRESSION: 1. There are no focal infiltrates identified. Mild increase in the interstitial markings may represent changes in the patient's fluid status. Clinical correlation is suGGested. 2. There is a stable radiographic appearance of the fractures of the right radius, ulna, femur, tibia and fibula with some evidence of interval healinG, as described above. Printed by: Printed on: Men, Chanthan 09/20/2001 1:59 PM Page 2 of 3 (Continued) An Equal Opportunity University PENNSTATE Milton S. Hershey Medical Center College of Medicine CXR (portable) BAILES, STC:PHANIE A- 1138054 Dr. K. Eggli reviewed the images and discussed the interpretation with Dr. Downs. DICTATED: REVIEWED AND SIGNED: RICHARD DOWNS, M.D./KATHLEEN D. EGGLI, M.D. /csb Printed by: Printed on: Men, Chanthan 09/20/2001 1:59 PM Page 3 of 3 (End of Report) An Equal Opportunity University PENNSTATE Milton S. Hershey. Medical Center College of Medicine Head CT (peds, unenhanced) BAILES, STEPHANIE A- 1138054 * Final Report * CT HEAD UNENHANCED-PED PATIENT NAME: BAILES,STEPHANIE PATIENT MRN: 01138054 PATIENT DOB: 13-Apr-1989 EXAM NUMBER: 657A-051001 EXAM: CT HEAD UNEAVHANCED-PED ORDERING PHYSICIAN: JEANETTE RAMER Exam: CT HEAD UNENHANCED-PED UNENHANCED CT OF THE BRAIN CLINICAL HISTORY: This is a 12-year-old female who presents status post craniectomy, postop CSF leak. Verify for fluid collection in left frontoparietal region. TECHNIQUE: A routine unenhanced CT of the brain was performed and filmed in soft tissue and bone windows. DISCUSSION: Comparison is made to a prior study from May 2, 2001. There is marked interim increase in the degree of brain swelling, primarily involving the left frontal, parietal and temporal lobes with external herniation. Craniectomy defect is noted. There is marked interim enlargement of the ventricles consistent with communicating hydrocephalus. There is more marked enlargement on the left, as compared to the right. In the region of the frontal lobes bilaterally, there is hypodensity involving the gray and white matter consistent with areas of encephalomalacia which have progressed since the prior study. Also, in the region of the left middle cranial fossa, there is a large area of extraaxial decreased attenuation. This area of decreased attenuation may represent CSF extending externally along the defect of the left temporal parietal craniectomyo There is effacement of the basal cisterns. There is also marked effacement of the sulci bilaterally. Multiple calvarial skull fractures are noted involving the right parietofrontal region. Multiple clips are noted involving the parenchyma anteriorly. Pdnted by: Printed on: Men, Chanthan 09/20/2001 2:00 PM Page 1 of 2 (Continued) An Equal Opportunity University PENNSTATE Milton S. Hershey Medical Center Co~ege of Medidine Head CT (peds, unenhanced) BAILES, ST~PHANIE A - 1138054 There is a small extra-axial fluid collection along the left parietal region. IMPRESSION: 1. Postoperative changes with a craniectomy defect. Multiple calvarial fractures are noted. 2. There has been marked interim increase in the degree of brain swelling and external herniation involving primarily the left frontoparietal and temporal lobes. 3. Marked interim enlargement of the ventricles, consistent with communicating hydrocephalus, more pronounced, involving the left lateral ventricle and left side of the third ventricle. 4. Areas of decreased attenuation involving the frontal lobes bilaterally, suspicious for areas of encephalomalacia. 5. Decreased attenuation within the middle cranial fossa bilaterally, primarily on the left, consistent with CSF fluid collection with external herniation. 6. There is a left frontoparietal fluid collection, unchanged since the prior study. The clinical team is aware of the findings. Dr. Meisler reviewed the images and discussed the interpretation with Dr. Chawla. DICTATED: 16875 REVIEWED ~ SIGNED: SIMMI CHAWLA, M.D./WILLIAM J. MEISLER, M.D. 1/bar Printed by: Printed on: Men, Chanthan 09/20/2001 2:00 PM Page 2 of 2 (End of Report) An Equal Opportunity University PENNSTATE Femur XR Milton S. Hershey Medical Center College of Medidine BAILES, STEPHANIE A- 1138054 * Final Report * DX FEMUR RT - AP , LAT, PATIENT NAME: BAILES, STEPHANIE PATIENT MRN: 01138054 PATIEI~T DOB: 13-Apr-1989 EXAM NUMBER: 358A-051701 EXAM: DX FE/~UR RT - AP , LAT, ORDERING PHYSICIAN: JEANETTE RAMER Exam: DX FEMUR RT - AP , LAT, Exam: DX TIB-FIB RT - AP , LAT, RIGHT FEMUR AND LOWER LEG CLINICAL HISTORY: Follow up of a fracture to evaluate for interval healing. The patient is status post multiple trauma. DISCUSSION: Comparison is made to the portable xrays of the right femur and tibia from 11 April 2001 at 0500. The more recent 9 May 2001 studies are not in the patient's jacket. RIGHT FEMUR: There has been no interval change in the position or aligTament of the fixation device with two proximal and two distal fixation screws. There is no evidence of fracture or lucency surrounding the orthopaedic hardware. There is an oblique fracture of the mid right femur with approximately 1/2 shaft diameter of the posterior and lateral displacement of the distal fragment with respect to the proximal. Mild anterior and medial angulation of the distal fragment is also noted. Increased callus formation is noted, consistent with some interval healing. RIGHT LOWER LEG: There has been no interval change in the position or alignment of the external fixation device with two proximal and two distal screws. There is no evidence of fracture or lucency involving the orthopaedic hardware. There is an oblique fracture of the distal middle 1/3 of the right tibia with approximately 1/4 shaft diameter of medial and posterior displacement of the distal fragment with respect to the proximal. Mild anterior angulation of the distal tibial fragment is noted. There is a transverse fracture of the mid right fibula with 1 and Printed by: Printed on: Men, Chanthan 09/20/2001 2:00 PM Page 1 of 2 (Continued) An Equal Opportunity University PENNSTATE Milton S. Hershey_ Medical Center College of Medicine Femur XR BAILES, STf::PHANIE a - 1138054 1/3 shaft diameter of lateral displacement of the distal fragment with respect to the proximal and 3 cm of over-riding of the fragment. There is no callus formation identified at this time. A nondisplaced oblique fracture of the proximal right fibula is noted. There is no callus formation identified at this time. IMPRESSION: Fractures of the right femur, tibia and fibula as described above. Dr. K. Eggli reviewed the images and discussed the interpretation with Dr. Downs. DICTATED: REVIEWED AND SIGNED: RICHARD DOWNS, M.D./KATHLEEN D. EGGLI, M.D. /bar Printed by: Printed on: Men, Chanthan 09/20/2001 2:00 PM Page 2 of 2 (End of Report) An Equal Opportunity University PENNSTATE Milton S. Hershey Medical Center College of Medi6ine CXR (2-view) BAILES, STEPHANIE A - 1138054 * Final Report * DX CHEST2VIEWS-AP,SEMIER, LT,LAT, INSP, PATIENT NAME: BAILES,STEPHANIE PATIENT MRN: 01138054 PATIENT DOB: 13-Apr-1989 EXAM NUMBER: 359A-060601 EXAM: DX CHEST 2 VIEWS - AP , SEMIER, LT , ORDERING PHYSICIAN: LEE SEGAL LAT, INSP, Exam: DX CHEST 2 VIEWS - AP , SEMIER, LT , LAT, INSP, AP SEMI-ERECT AND LATERAL VIEWS OF THE CHEST TAKEN IN WHEELCHAIR Comparison to most recent study of May 9 portable film. This patient is status post severe head trauma and has questioned decreased breath sounds in the lower lobes. Tracheostomy tube is no longer present. The lungs are a bit hypoventilatory. Heart size is normal. There is actually some improvement and a mild prominence of interstitial markings noted in both perihilar regions and no acute area of consolidation is superimposed. No pleural fluid or other abnormality seen. Visualized upper abdomen is unremarkable. DICTATED: 4188 REVIEWED AND SIGNED: DANIELLE K.B. BOAL, M.D./ 4/jsr Printed by: Printed on: Men, Chanthan 09/20/2001 2:00 PM Page I of 1 (End of Report) An Equal Opportunity University PENNSTATE Milton S. Hershey_ Medical Center College of Medi6ine CXR (1-view) BAILES, ST~PHANIE a - 1138054 * Final Report * DX CHEST1VIEW-AP,SUPINE, INSP, PATIENT NAME: BAILES,STEPHANIE PATIENT MRN: 01138054 PATIENT DOB: 13-Apr-1989 EXAM NUMBER: 85A-061001 EXAM: DX CHEST 1 VIEW - AP , SUPINE, INSP, ORDERING PHYSICIAN: LEE SEGAL Exam: DX CHEST 1 VIEW - AP , SUPINE, INSP, SUPINE AP CHEST CLINICAL HISTORY: Fever. DISCUSSION: Comparison is made to prior chest radiographs from 6 June 2001. The lungs and costophrenic angles are clear. There is no evidence of a focal infiltrate, pleural effusion or pulmonary vascular congestion. The cardiomediastinal silhouette and visualized bony structures are age appropriate. IMPRESSION: There is no evidence of an acute cardiopulmonary abnormality. Dr. Eggli reviewed the images and discussed the interpretation with Dr. Sanghvi. DICTATED: 17270 REVIEWED AND SIGNED: KAVlTA B. SANGHVI, M.D./KATHLEEN D. EGGLI, M.D. 1/smc Printed by:. Pdnted on: Men, Chanthan 09/20/2001 2:00 PM Page 1 of 1 (End of Report) An Equal Opportunity University PENNSTATE WMilton S. Hershey Medical Center College of Medicine Tib-Fib XR BAILES, STEPHANIE A - 1138054 * Final Report * DX TIB-FIB RT-AP,LAT, PATIENT NAME: BAILES,STEPHANIE PATIENT MRN: 01138054 PATIENT DOB: 13-Apr-1989 EXAM NUMBER: 457A-062501 EXAM: DX TIB-FIB RT - AP , LAT, ORDERING PHYSICIAN: LEE SEGAL Exam: DX TIB-FIB RT - AP , LAT, Exam: DX FEMUR RT - AP , LAT, MULTIPLE VIEWS OF THE RIGHT TIB/FIB AND RIGHT FEMUR CLINICAL HISTORY: Fractures, status post bone graft of the right tibia. DISCUSSION: RIGHT FEMUR: Comparison is to May 31, 2001. In the interim, the external fixator has been removed. Again visualized is the fracture in the mid right femoral diaphysis with resultant lateral displacement of distal fracture fragment. The alignment is unchanged from prior exam. There has been slight interval callous formation. Ghost holes are visualized in the areas of the prior hardware. RIGHT TIB/FIB: Again visualized is an external fixator device through the proximal and distal tibial diaphysis. The fracture through the distal half of the tibial diaphysis is again noted. There is slight anterior and lateral angulation of the distal tibial fracture fragment. The lateral angulation appears worse in the interval, although this may be due to changes in obliquity between this study and the prior one. Also again noted is the fracture through the mid fibular diaphysis with lateral angulation and lateral displacement of the distal fibular fragment. A second more superior fracture through the proximal fibula with medial angulation is again noted. In the interim there has been placement of a bone graft around the tibial fracture. Printed by: Printed on: Men, Chanthan 09/20/2001 2:00 PM Page 1 of 2 (Continued) An Equal Opportunity UniversiS' PENNSTATE W Milton S. He_rs _h_ey Medical Center College of Medicine Tib-Fib XR BAILES, STgPHANIE A- 1138054 * Final Report * DX TIB-FIB RT - AP, LAT, PATIENT NAME: BAILES, STEPHANIE PATIENT MRN: 01138054 PATIENT DOB: 13-Apr-1989 EXAM NUMBER: 457A-062501 EXAm: DX TIB-FIB RT - AP , LAT, ORDERING PHYSICIAN: LEE SEGAL Exam: DX TIB-FIB RT - AP , LAT, Exam: DX FEMUR RT - AP , LAT, MULTIPLE VIEWS OF THE RIGHT TIB/FIB AND RIGHT FEMUR CLINICAL HISTORY: Fractures, status post bone graft of the right tibia. DISCUSSION: RIGHT FEMUR: Comparison is to May 31, 2001. In the interim, the external fixator has been removed. Again visualized is the fracture in the mid right femoral diaphysis with resultant lateral displacement of distal fracture fragment. The aligTmlent is unchanged from prior exam. There has been slight interval callous formation. Ghost holes are visualized in the areas of the prior hardware. RIGHT TIB/FIB: Again visualized is an external fixator device through the proximal and distal tibial diaphysis. The fracture through the distal half of the tibial diaphysis is again noted. There is slight anterior and lateral angulation of the distal tibial fracture fragment. The lateral angulation appears worse in the interval, although this may be due to changes in obliquity between this study and the prior one. Also again noted is the fracture through the mid fibular diaphysis with lateral angulation and lateral displacement of the distal fibular fragment. A second more superior fracture through the proximal fibula with medial angulation is again noted. In the interim there has been ~ placement of a bone graft around the tibial fracture. Printed by: Printed on: Men, Chanthan 09/20/2001 2:00 PM Page 1 of 2 (Continued) An Equal Opportunity University PENNSTATE W Milton S. Hershey Medical Center College of Medicine Tib-Fib XR BAILES, STEPHANIE A - 1138054 IMPRESSION: 1. Removal of the external fixator from the right femur with stable alignment. 2. Increased angulation of the tibial fracture maybe due to changes in positioning. Dr. Boal reviewed the images and discussed the interpretation with Dr. Huq. DICTATED: REVIEWED AND SIGNED: HASSAN HUQ, M.D./DANIELLE K.B. BOAL, M.D. /lem Printed by:. Printed on: Men, Chanthan 09/20/2001 2:00 PM Page 2 of 2 (End of Report) An Equal Opportunity Universit~ PENN$ ATE The Milton S. Hershey Medical Center The College of Medicine Health Information Services HU24 P.O. Box 850 Hershey, PA 17033-0850 DISCHARGE SUMMARY PATIENT NAME: BAILES, STEPHANIE PATIENT NUMBER: 1138054 LOCATION: SEX: F DATE ADMITTED: 05/09/01 DATE DISCHARGED: -~_0~17,. 01 FINAL DIAGNOSES: I. Severe closed head injury. 2:,, Postttaumatic hydroceph~lns. 3. Multiple fractures of right femur, tibia and fibula with nommion of the tibia. BRIEF HISTORY: Stephanie is an 11-year-old girl who was injt~red in a motor vehicle accident approximately eight weeks prior to admission to rehabilitation. She was originally admitted to rehabilitation on 04/24/01 but developed a scalp CSF leak on 04/25 and again on 04/28. This led to transfer to the intermediate care unit. on 04/28 for placement of a lumbar drain and flap revision, which was done on 05/01. Incisions are healing well at this point. The lumbar drain was removed on 05/17. Thus far, the flap is soft and full. A single CSF culture grew Staphylococcus epidennidis, which had been treated with vancomycin since 05/01. Stephauie had been afebrile until the morning of transfer when her temperature increased to 3819 degrees associated with increased respiratory secretions and change in color of the secretions to yellow. She returned to rehab to resume coma stimulation and parer/t teaching for getting her ready to return home. It is reported that Stephanie has become more active. She does visually fix and follow at times, reacts to pain with grimace and movement, and has had more vocalization and chewing movements over the last week. TRANSFER MEDICATIONS: 2. 3. 4. 5. Vancomycin 500 mg q.8h. IV. Lactulose twice a day. Senna syrup 15 ce every other day. Lacri-Lube to both eyes. Nystatin swabs to the mouth. PHYSICAL EXAMINATION: Examination showed that respirations were 22 to 26, heart rate was 105 to 124, blood pressure 96/57, and her weight was about 50 kg. Skin exam shown no breakdown evident. The scalp incisions were healing plus the sutures were out. Her right leg wound was healing as well, and pin site and looks quite clean. There was an IV in the left arm with a site that l~oked quite clean. HEENT exam showed absent bone at the left hemicranium. The area was soft but full. Dressings we~tact over An Equal Opportunity University PATIENT NAME: B~ ES, STEPHANIE PATIENT NUMBER: 1138054 ) the flap revision. The fight eye was without redness or corneal clouding. ,The left eye was primarily closed with no abnormalities externally. Neck exam showed a 5.5 Shiley traehe ~n place without breakdown or redness at the site. Chest exam showed transmitted large airway sound and rhonchi. No r/des or wheezes. She had mild increase in respiratory rate with minimal retractions. Heart exam showed regular rate and rhythm. Normal S1 and S2. No murmurs. Abdomen was soft and fiat. There was no enlargement of liver or spleen. The gastrostomy tube site was dean. Extremity exam showed a cast in the fight ann. The left ann had full range of motion. Decreased muscle mass was evident. Lower extremity exam showed an extenlal fixator on the fight, over the femur and over the tibia. Pin sites were without drainage. There was a stnall unhealed wound above the lower pin. The left leg had full range of motion. Neurologie exam showed that she alerted to sound. She did fix on visual stimuli and followed to the midline, but inconsistently. She moved when touched, but these were non-purposeful movements. Cranial nerves exam showed that there was visual fix with the fight eye and inconsistent follow. There was blink to confrontation. The teeth were not clenched. She had a weak cough with pharyngeal stimulation. With suctioning, an excellent cough was obtained. She had a delayed swallow. Tone was normal to decrease~{n the upper extremities, and normal in the lower extremities. Full range of motion on all joints. There was no posturing. Strength exam showed that there were no purposeful movements, although the left ann moved toward noxious stimuli and there was some spontaneous movements throughout. HOSPITAL COURSE: 1. CSF infection: From a culture obtained on 05/11/01 that gram-negative rods were growing, they ~, .were not evident until 05/14. At that time, treatment was,initiated with gentamicin and ceftfiaxone. Repeat culture by lumbar puncture was done on 05/15. At that time, organisms were evident on the smear. Ultimately, this grew Enterobaeter which was sensitive to gentamicin and intermediate to ceftriaxone. Cefepime was instituted at that time; the organism was sensitive to both this and gentamicin. Subsequently, the lumbopefitoneal shunt, which had been placed on 05/11, was exteriorized~ Repeat cultures were all negative. The last positive culture was from 05/15. At the time of discharge on 06/01, a lumbopefitoneal shunt was to be placed on that day. Sh~ was discharged to the operating room at that time. During her rehabilitation stay, she did not have obvious symptoms of CSF infection. Although a few temperature elevations were evident in the first several days of her stay, there was no neurologic deterioration noted. Traumatic hydrocephalus: At the time of admission, her surgical flap was full. This became increasingly distended to the first several days of her stay. A lumboperitoneal shunt was placed on 05/11/01 but as noted, because of infection, this was exteriorized to be replaced on 06/01/01 when the infection was treated. S Neurologic recovery: Stephanie had very little change during her stay in rehabilitation. She had inconsistent visual fix and follow. There were times when she appeared to respond with eye widening to sounds and there were even. times .when she was reported to mumble ormake occasional word approximation, 13ut none ofthes~ were consistent. She had'~i'/~Purposeful movements, although noxious stimuli did elicit movements toward the stimulus, and she certainly reacted to painful stimuli by grimae'mg and crying. Movement was evident in all four extremities, but minimal assistance with movement was present. Oral stimulation was continued. Taste was used but swallow continued to be significantly delayed, and it was deemed unsafe to work on oral feedings. She was able to hoid her head in midline briefly on an inconsistent basis. Page 2 of 3 PATIENT NAME: B, ES, STEPHANIE PATIENT NUMBER: 1138054 The mother and other earegivers were trained in positioning, transfers, stretching and other techniques needed at home. Therapies were arranged for home. She will receive PT/eT and speech therapy one to two times per week each. A wheelchair was developed and will be provided by Health Inspector. Tracheostomy at the time of admission. Stephanie required a small amount of suctioning through her tracheostomy. However, this diminished in frequency. Ultimately, the traeheostomy was able to be plugged. It was removed on 05/22/01 without complications. The site healed promptly and the pulmonary status was stable. There was no need for suctionlng. No wheezes, rales or other problems noted. CONDITION ON DISCHARGE: Good. FOLLOW-UP: Follow-up care will be in Acute Pediatrics after the shunt placement and bone gral~g. D,,I~TATING MD:~ "~'"~ Jeanette C. Ramer~I.D. D~partment of Pediatrics/Pediatric Genetics JR/mrp D: 05/31/01 T: 06/02/01 dm 6/4 c: WP Clerk - 438776 J. LYNN HOFFMAN, M.D. 804 BELVEDERE STREET CARLISLE, PA 17013 *** Dictated but NOT Read *** Page 3 of 3 PENNSTATE The Milton S. Hershey_ Medical Center The College of Medicine Health Information Services HU24 P.O. Box 850 Hershey, PA 17033-0850 OPERATIVE REPORT PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 1138054 DATE OF BIRTH: 04/13/1989 LOCATION: DATE OF SERVICE: 05/11/2001 SEX: F SURGEON(S): Paul M. Kanev, M.D., M.S.* ASSISTANT(S): Samuel D. Critides, M.D. PREOPER3~TIVE DIAGNOSIS: Post-trauma hydrocephalus. POSTOPERATIVE DIAGNOSIS: Same. OPERATION PERFORMED: ANESTHESIA: Placement of lumbar peritoneal shunt. General endotracheal anesthesia. INDICATIONS: Stephanie is a 12-year-old with severe post-hemorrhage hydrocephalus acutely in the last several days, with enlarging craniectomy defect and ventricle size. After discussion with the family, consent to proceed with surgery was granted. OPERATION: After identification of the p~ient, she was transferred into the operating room and underwent successful induction of general endotracheat anesthesia. The patient was positioned in a left lateral decubitus with axillary roll placement and pressure point padding. The back, right flank, and abdomen were prepped and draped in the usual sterile fashion. A midline incision was marked just above the site of her previous lumbar drain. The incision was infiltrated with 0.5% lidocaine with 1:200,000 epinephrine. A right subcostal incision was also marked and infiltrated with local. Both incisions were made with a scalpel, and hemostatic cla~ps were placed. On a single atraumatic pass, a Tuohy needle was inserted into the lumbar theca, allowing ready passage of the lumbar shunt catheter. This was tunneled to the abdomen incision. We then opened into the peritoneum through muscle- splitting technique and inserted the flowing-spontaneous}y distal end into the abdomen. A pqrsestring-suture was secured~..~n the peritoneum. '~ JUN 2 5 2001 Page 1 of 2 An Equal Opponunily Unive~ity PENNSTATE ~ Milton S. Hershey Medical Center College of Medic'me Tib-Fib XR BAILES, STEPHANIE A - 1138054 IMPRESSION: 1. Removal of the external fixator from the right femur with stable alignment. 2. Increased anqulation of the tibial fracture maybe due to changes in positioning. Dr. Boal reviewed the images and discussed the interpretation with Dr. Huq. DICTATED: REVIEWED AND SIGNED: HASSAN HUQ, M.D./DANIELLE K.B. BOAL, M.D. /lem Printed by: Pdnted on: Men, Chanthan 09/20/2001 2:00 PM Page 2 of 2 (End of Report) An Equal Opportunity University PATIENT NAME: BAILES, STEPHANIE A PATIENT NI/MBER: 1138054 After extensive irrigation, both wounds were closed in layers with inverted deep dermal 3-0 Vicryl, augmented by Mastisol and Steri- Strips. Sterile dressings of Telfa and tape were applied. DICTATING MD: Paul M. Kanev, M.D., M.S.* PMK/beg c: PCR D: 06/15/2001 Word Processing Clerk Surgical Fees T: 06/15/2001 20:20 Page 2 of 2 OPERATIVE REPORT PATIENT NAMEs BAILES, STEPHANIE A PATIENT NUMBER: 1138054 DATE OF BIRTH: LOCATION= DATE OF SERVICE: SEX: F SURGEON(S): Paul M. Kanev, M.D.~ M.S.* ASSISTANT(S): 04/13/1989 05/17/2001 PREOPERATIVE DIAGNOSIS: Infected lumbar peritoneal shunt. POSTOPERATIVE DIAGNOSIS: Same as above. OPERATION PERFORMED: Removal of lumbar peritoneal shunt and placement of externalized lumbar subarachnoid catheter. ANESTHESIA: General endotracheal. INDICATIONS: Stephanie is a 12-year-old young lady who had been in the hospital for many weeks following severe and devastating closed head injury. She developed post he,~orrhage hydrocephalus after the closure of scalp infected brea~kdown sites. A lumbar subarachnoid catheter at that time had revealed inflammatory cells in the spinal fluid but serial cultures were negative. The ventricles had enlarged considerably 8 days after removal of that drain and there was a transient leak of spinal fluid at the lumbar external placement site. In the afebrile patient, we placed an LP shunt successfully, and it was working well. There were 800 cells initially sterile but on the fourth day, gram~negative rods grew from the only and this was confirmed on lumb~r puncture. After discussion with family regarding removal of shunt and continue external drainage~ consent to proceed was granted. OPERATION: After identification of the patient, she was transferred tQ the operating room and underwent successful induction of'gene~al"~ndotracheal anesthesia. The patient was positioned in a left' lateral decubitus position and the region of the back, 'flank and right abdomen was draped and prepped in the usual sterile fashion. The previous midlumbar incision was infiltrated with 0.5% lidocaine- with 1:200,000 epinephrine. It was opened with a #15 blade and the subcutaneous Page 1 of 2 PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 1138054 Vicryl sutures were removed. The fibrous tissues were somewhat purulent without free pus but clearly showing signs of infection. I therefore elected to remove the entire lumbar peritoneal shunt and place an externalized subarachnoid drain. Through a transverse-oriented incision several inches below the lumbar peritoneal shunt placement site, a Tuohy needle was introduced into the subarachnoid space and catheter threaded ~eadilyinto the spinal fluid. It was flowing spontaneously, and the Tuohy needle was then withdrawn. Using a shunt passer, we tunneled this to a small incision in the right lower abdomen. It was flowing spontaneously, and the connection site was secured with 2-0 silk ligature and additional spinal fluid was withdrawn. The spinal fluid was clear but with a slight yellow tinge and.was sampled for chemistry and microbiological ~, analysis. After extensive irrigatioH, the externalized site was closed with inverted deep dermal 3-0 Vicryl augmented by Mastisol and Steri-Strips. A sterile Op-Site was placed over the externalized system. The entire LP shunt was then removed without difficulty. There was no leak from its site through the muscle fascia. Purulen~ subcutaneous tissue was removed with a Penfield #1 and after extensive irrigation of the wound, t~e area were closed with multiple 4-0 Prolene mattress sutures. After extensive irrigated the transverse incision was closed with the same suture. Sterile dressing of Telfa and tape were applied. The patient awoke readily with no change in her neurological examination and was transferred back to the recovery area. ¢ DICTATING MD: Paul M. Kanev, M.D., M.S.* PMK/lld c: PCR D: 05/17/2001 Word Processing Clerk Surgical Fees T: 05/18/2001 09:52 Page 2 of 2 PENNSTATE The Milton S. Hershey Medical Center The College of Medi6ine Health Information Services HU24 P.O. Box 850 Hershey, PA 17033-0850 INPATIENT PROCEDURE PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 1138054 DATE OF BIRTH: LOCATION: DATE OF SERVICE: SEX: F SURGEON(S): Stephen K. Powers· M.D. ASSISTANT(S): Samuel D. Critides,--M.D. PROCEDURE PERFORMED: Lumbar puncture. 04/13/1989 05/17/2001 INDICATIONS FOR PROCEDURE: The patient is a 12-year-old female status post motor vehicle accident with severe closed head injury and post-traumatic hydrocephalus with recent course of meningitis requiring removal of lumboperitoneal shunt. She subsequently has' redeveloped subgaleal fluid at the site' of her craniectomy and requires decompressive lumbar puncturef PREPROCEDURE DIAGNOSIS: Hydrocephalus. POSTPROCEDURE DIAGNOSIS: Same. ANESTHESIA: Local anesthesia with 1% lidocaine. SPECIMENS: CSF for analysis. ~ DESCRIPTION OF PROCEDURE: After obtainin~ informed consent, the patient was identified and made comfortable in a right side down, lateral recumbent position. The lumbar back was then prepped and draped in usual fashion. A 20-gauge needle was used to access the lumbar subarachnoid space without difficulty on the first pass. Page 1 of 2 An Equal Opportunity University PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 1138054 Approximately 120 cc of clear spinal fluid was obtained and sent for analysis. There were no complications. The patient tolerated the procedure well. DICTATING MD: Samuel D. Critides, M.D. ATTENDING MD: Stephen K. Powers, M.D. Professor; Head, Neurosurgery SDC/rem D: 05/27/2001 c: Surgical Fees PCR 05/29/2001 14:40 Page 2 of 2 PENNSTATE wThe Milton S. Hershey Medical Center The College 'of Medicine Health Information Services HU24 P.O. Box 850 Hershey, PA 17033-0850 OPERATIVE REPORT PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 1138054 DATE OF BIRTH: 04/13/1989 LOCATION: DATE OF SERVICE: 05/29/2001 SEX: F SURGEON(S): Paul M. Kanev, M.D., M.S.* ASSISTANT(S): Samuel D. Critides, M.D. PREOPERATIVE DIAGNOSIS: Post traumatic hydrocephalus. POSTOPERATIVE DIAGNOSIS: Same. OPERATION PERFORMED: Lumbar puncture. ANESTHESIA: INDICATIONS: The patient 'is a 12-year-old female status post motor vehicle accident with post traumatic, post hemorrhage hydrocephalus who experienced a lumboperitoneal shunt infection requiring a period of lumbar drainage and treatment of her infection with IV antibiotics. The lumbar drain was discontinued and she is being followed clinically for evidence of scalp fullness at the site of her craniectomy site while CSF is cultured prior to planned lumboperitoneal shunt replacement. On this date the patient had some fullness of her scalp flap in spite of volume tap of 120~c less than 48 hours previously. Plan to perform repeat lumbar puncture, send cerebrospinal fluid for analysis and decompress the scalp wound. FINDINGS: SPECIMEN: COMPLICATIONS: IMPLANTS: Clear CSF. 200 cc of spinal fluid sent for analysis. None. None. OPERATION: After obtaining informed consent, the patient was identified and made comfortable in a right side down lateral recumbent position. The lumbar skin was prepped.and draped in the usual fashion. Local anesthesia of 1% lidocai~e without epinephrine was used as-a. lbcal '~nesthetic. A 20 g~ge'lumbar needle was then inserted into the C3-4 l~mbar space without difficulty. Cerebrospinal fluid was then obtained and four serial samples which were sent to the laboratory for analysis. Volume tap continued and approximately 200 cc was ultimately obtained. The needle was withdrawn. The skin was then washed with alcohol and a Band-Aid was Page 1 of 2 An Equal Oppor un Iv Universily PENNSTATE wThe Milton S. Hershey Medical Center The College of Medicine Health Information Services HU24 RO. Box 850 Hershey, PA 17033-0850 \OPERATIVE REPORT PATIENT NAME: BAILES, STEPHANIE A PATIENT NUMBER: 1138054 DATE OF BIRTH: LOCATION: DATE OF SERVICE: SEX: F SURGEON(S): Paul M. Kanev, M.D., ~.S.* ASSISTANT(S): Samuel D. Critides, M.D. PREOPERATIVE DIAGNOSIS: POSTOPERATIVE DIAGNOSIS: OPERATION PERFORMED: ANESTHESIA: Hydrocephalus. Same. 04/13/1989 05/30/2001 Lumbar puncture. 1% local lidocaine without epinephrine. INDICATIONS: The patient is a 12-year-old female status post closed head injury with post traumatic and post hemorrhagic hydrocephalus requiring high volume lumbar punctures for control, of hydrocephalus pending planned lumboperitoneal shunt replacement on 1 June 2001. On the morning of procedure, the patient was noted to have a full mildly tense scalp at the site of the cranie~omy. SPECIMENS: CSF. Volume o~ tap approximately 200 cc. OPERATION: After obtaining informed consent, the patient's mother identified the patient. The patient was made comfortable in a right side down lateral recumbent position. The lumbar back was then prepped and draped in usual fashion. Local anesthesia was applied with 1% lidocaine, then a 20 gauge spinal needle was used to access the L3-4 interspace. The tap was performed atraumatically with the first pass. Immediate drainage of slightly yellow clear CSF W~s obtained under iow pressure. The spinal fluid was then sampled using the four sample containers from the lumbar puncture set, and then an additional 160 cc of spinal fluid Was obtained and disposed of. The spinal needle was withdrawn. Page 1 of 2 An Equal OplX~rtunily Universily PATIENT NAME: BAILES, STEPHANIE A PATIENT NI~MBER: 1138054 applied over the puncture site. The scalp was noted to be markedly decompressed following the procedure. The patient tolerated the procedure well. There were no complications. DICTATING MD: Samuel D. Critides, M.D. ATTENDING MD: Paul M. Kanev, M.D., M.S.* SDC/dek D: 05/29/2001 T: 05/30/2001 10:33 c: PCR ~. Word Processing Clerk Surgical Fees Page 2 of 2 PENNSTATE WMilton S. Hershey Medical Center College of Medicine Femur XR BAILES, STEPHANIE A- 1138054 * Final Report * DX FEMUR RT - AP, XTAB, PATIENT NAME: BAILES, STEPHANIE PATIENT MRN: 01138054 PATIENT DOB: 13-Apr-1989 EXAM NUMBER: 390A-050201 EXAM: DX FEMUR RT - AP , XTAB, ORDERING PHYSICIAN: PAUL KANEV Exam: Exam: Exam: DX FEMUR RT - AP , XTAB, DX TIB-FIB RT - AP , XTAB, DX WRIST RT 1-2 VIEWS - AP , LAT, RIGHT FEMUR, RIGHT TIB/FIB AND RIGHT WRIST CLINICAL HISTORY: The patient was involved in an MVA. DISCUSSION: Right femur: This patient's femur has sustained a transverse fracture of its mid diaphysis and there is approximately two third shaft width lateral and posterior displacement of the distal fracture fragments with minin~al medial angulation. External fixators are in place. The remainder of the femur is normal. Right tibia/fibula: External fixator is extended across the proximal and distal tibia both above and below a comminuted fracture of the distal tibial diaphysis. There are two associated fibular fractures. With external fixation, there is evidence of mild valgus angulation at the fracture site and one cortex width medial and posterior displacement of the distal fracture fragment. There is additionally minimal anterior angulation of the distal fracture fragment. ~ Right wrist: The wrist is encased within a fiberglass cast which does obscure some detail but allows visualization of a healing Salter II fracture of the distal radius. Sclerosis at the fracture site is evidence of early healing but there is persistent dorsal angulation and displacement of distal fracture fragment. An associated ulnar fracture is minimally displaced. IMPRESSION: Fractures as described. Printed by: Printed on: Men, Chanthan 09/20/2001 1:59 PM Page 1 of 2 (Continued) An Equal Opportunity University PENNSTATE Femur XR Milton S. Hershey Medical Center College of Medicine BAILES, STEPHANIE A- 1138054 DICTATED: REVIEWED AND SIGNED: /lld KATHLEEN D. EGGLI, M.D./ Printed by: Printed on: Men, Chanthan 09/20/2001 1:59 PM Page 2 of 2 (End of Report) An Equal Opportunity University Exhibit 3 SCHEDULE C (Form 1040) Name of proprietor Klm L Wol~ A Pr,ncipal business or profession, including product or service (see page C-1 of the instructions) Day Care ' I Profit or Loss From Business o Mg~o ,(~ ~.~ .0o~4 (Sole Proprietorship) · Partnerships, joint ventures, etc., must file Form 1065 or F~rm 1065-B, ' Attachment ID) · Attach to Form 1040 or Form 1041. · See Instructions for Schedule C (Form 1040). Sequence No. 09 C Business name. If no separate business name, leave blank. tSocial security number {SSN} 202 5~ 96~4 B Enter code from pages C-7 & 8 E Business address (including suite or room no.) I~ ........ .~.],.4...~Qirl~.y])~'.O.O.k ..~,~, .................................................. City, town or post office, state, and ZIP code Cai' 1 i s ! e ?a 1 70 13 Accounting method: (1) [] Cash (2) [] Accrual (3) [] Other (specify) · .................................................. Did you "materially participate" in the operation of this business during 2000? If "No," see page C-2 for limit on losses . [~ Yes [] No If you star~ed or acqu red this business during 2000, check here ................... · I-] l~'T~ll Income 1 Gross receipts or sales. Caution. tf this income was reported to you on Form W-2 and the "Statutory [--"] employee" box on that form was checked, see page C-2 and check here ...... ·~ 1 2 Returns and allowances ........................ 2 3 3' z~.q _ 3 Su~,2~ract line 2 from line 1 ....................... 4 Cost of goods sold (from tine 42 on page 2) .................. 4 5 Gross profit. Subtract line 4 from line 3 .................... 5 6 Other income, including Federal and state gasoline or fuel tax credit or refund (see page C-2) . . 6 7 Gross income. Add lines 5 and 6 .................... Expenses. Enter expenses for business use of '~our home only on line 30. 8 Advertising ...... 8 ,~0 g, 19 Pension and profit-sharing plans 19 9 Bad debts from sales or 20 Rent or lease (see page C-4): services (see page C-3) . . 9 a Vehicles, machineP/, and equipment. 20a 10 Car and truck expenses ~¢~ b Other business property . . 20b (see page C-3) ..... 10 21 Repairs and maintenance . 11 Commissions and fees . . 11 22 Supplies (not included in Pad Ill) . 22 12 Depletion ...... 12 23 Taxes and licenses .... 23 13 Depreciation and section 179 24 Travel, meals, and entertainment: expense deduction (not included a Travel ........ 24a ~-~'~) ,n Part III)(see page C-3) 13 Z~ '~ ~,~) ' b Meals and 14 Employee benefit programs entertainment (other than on line 19). . . 14 c Enter nondeduct- 15 Insurance (other than health). 15 ible amount in- cluded on line 24b 16 Interest: ~ (see page C-5) . a Mortgage (paid to banks, etc.) . 16a d Subtract line 24c from line 24b 24d b Other ........ 16b .~?,qO " '25 Utilities ....... 25 17 Legal and professional 26 Wages (less employment credits) . 26 services ....... 17 ~,,~j~f) --~ 27 Other expenses (from line 48 on 18 Office expense ..... 18 /~ ~' page 2) ....... 27 28 Total expenses before expenses for business use of home. Add lines 8 through 27 in columns 29 Tentative profit (loss). Subtract line 28 from line 7 ................ 29~ 30 Expenses for business use of your home, .A~ttach ~Form 8829 ............. 30 31 Net profit or (Ioss). Subtract line 30 from · If a profit, enter on Form 1040, line 12, and also on Schedule SE, line 2 (statutory employees, see page C-5). Estates and trusts, enter on Form 1041, line 3. · If a loss, you must go to line 32. -,,. 32 If you have a loss, check the box that describes your investment in this activity (see page C-5). · If yo~ checked 32a, enter the loss on Form 1040, line 12, and also on Schedule SE, line 2 [ 32a [] All investment is at risk. (statutory employees, see page C-S). Estates and trusts, enter on Form 1041~ line 3. I 32b [] Some investment is not · It you checked 32b, you must attach Form 6198. at risk. For Paperwork Reduction Act Notice, see Form 1040 instructions. Cat. No. 11334P Schedule C (Form 1040) 2000 ,o.m 4562 Depreciation and Amortization OMB,o. tS.5-0~72 (Including Information on Listed Property) ~nlerna~ Revenue So.,ce (O} · See separate instructions. · Attach this form to your return. Sequence No. 67 Name(s) shown on return t Business or activity to which this form relates Identifying number Brad E & Klm L Wolf ] Schedule"C" 187 52 1230 ~ Election To Expense Certain Tangible Propel'ty (Section 179) Note: If you have any "listed property," complete Part V before you complete Part I Maximum dollar limitation. If an enterprise zone business, see page 2 of the nstructions [ 1 $20,000 · 2 Total cost of section 179 property placed in service. See page 2 of the nstructions. ' ' I 2 '3 Threshold cost of section 179 property before reduction n mtaton ' ' ' ' I 3 ~;200,000 ,4 Reduction in limitation. Subtract line 3 from line 2. If zero or less, enter -0- ' ' ' I 4 5 Dollar limitation for tax year. Subtract line 4 from line 1. If zero or less enter -0-. If married filing separately, see page 2 of the instructions ................ I 5 6 {a) Description of propeny (b} Cost (business use only) (c} Elected cost 7 Listed property. Enter amount from line 27 I 7 I 8 Total elected cost of section 179 property. Add amounts in column (c), lines 6 and 7 . . . 12 9 Tentative deduction. Enter the smaller of line 5 or line 8 ............. 10 Carryover of disallowed deduction from 1999. See page 3 of the instructions ..... 10 11 Business income limitation. Enter the smaller of business income (not less than zero) or line 5 (see instructions) 11 12 Section 179 expense deduction. Add lines 9 and 10, but do not enter more than line 11 . . 13 Carryover of disallowed deduction to 2001. Add lines 9 and10,1ess line12 I~ I 131 Note: Do not use Part II or Part III below for listed property (automobiles, certain other vehicles, cellular telephones, _certaJn__c°mputers, or property used for entertainment, recreation, or amusement). Instead, use Part V for listed property. ~ MACRS Depreciation for Assets Placed in Service Only During Your 2000 Tax Year (Do not include listed property.) Section A--General Asset Account Election 14 If you are making the election under section 168(i)(4) to group any assets placed in service during the tax year into one or more general asset accounts, check this box. See page 3 of the instructions ............ I- [] Section B--General Depreciation System (GDS) (See page 3 of the instructions.' of proper~y (b) Month and {c) Basis for depreciation (d) Recovery (nj Classification year placed in (business~nvestment use (e) Convention (f) Method (g) Depreciation deduction service only--see instructions) period 15a 3-year property ~ b 5-year property c 7-year property d 10-year property e 15-year property f 20-year property g 25-year property 25 yrs. S/L -- h Residential rental 2?. 5 yrs. MM S/L property 27'. 5 yrs. MM S/L i Nonresidential real 39 yrs. MM S/L property MM S/L Section C~Alternative Depreciation System (ADS) (See page 5 of the instructions. b 12-year ' 12 )~rs, S/L c 40-year . 40 }/rs. MM S/L iT,,~"~-Illl Other Depreciation (Do not include listed property.) (See page 5 of the instructions. 17 GDSandADSdeductionsforassets¢lacedinserviceintaxyearsbeginningbefore2O00 . 1179' Property subject to section 168(0(1) elecii~n ................. 18 ACRS and other deprec at on ..... 18 19 20 21 22 For Paperwork Reduction Act Notice, see page 9 of the instructions. Summary (See page 6 of the in$%uctions.) Listed property. Enter amount from line 26 .................. 20 / Total. Add deductions from line 12, lines 15 and 16 in column (g), and lines 17 through 20. Enter lqere and on the appropriate lines of your return. Partnerships and S corporations--see instructions 21 ~?,.~.2.~-- For assets shown above and placed in service during the current year, I I ~ enter the portion of the basis attributable to section 263A costs . . I 22 I Cat. No. 12906N Form 4562 (2000) SCHEDULE SE I Self-Employment lax oma .o. (Form 1040) ' ' ~' See Instructions for Schedule SE (Form 1040). Inle~nal Revenue Ser~ce (M) I ~' Attach to Form 1040. AItac~'nentsequence NO. 17 Name of person with sell-employment income (as shown on Form 1040) I Social sectJrity number Of person K'im lf. ~nlF withself-e~mploymentincome~. 202i54!9644 Who Must File Schedule SE You must file Schedule SE if: · You had net earnings from self-employment from other than church employee income (line 4 of Short Schedule SE or line 4c of Long Schedule SE) of $400 or more or · You had church employee income of $108.28 or more, Income from services you performed as a minister or a member of a religious order is not church employee income. See page SE-I. Note. Even if you had a loss or a small amount of income from self-employment, it may be to your benefit to file Schedule SE and use either "optional.,.method" in Part II of Long Schedule SE. See page SE-3. Exception, If your only self-employment income was from earnings as a minister, member of a religious order, or Christian Science practilioner and you filed Form 4361 and received IRS approval not to be taxed on those earnings, do not file Schedule SE. Instead, write "Exempt-Form 4361" on Form 1040, line 52. May I Use Short Schedule SE or Must I Use Long Schedule SE? Did YOU Receive Wages or Tips in 2000? NO A~e you usng one of the optional methods to figure your earnings (see page Die you ~eceive church employee income reported on Form W-2 el $10828 or more? You May Use Short Schedule SE Below Was the total of your wages and tips subject to social security or railroad retiremant t~ plus your ne{ earnings from seLl-employment more than $76.200? Did you receive tips subject to social securily o¢ Medicare that you did not reporl to your employer? '1 You Must Use Long Schedule SE on the Sack Yes Section A--Short Schedule SE. Caution: Read above to see if you can use Short Schedule SE. Net {arm profit or (loss) from Schedule F, line 36, and farm partnerships, Schedule K-1 (Form 1065), line 15a 2 Net profit or (loss) from Schedule C, line 31; Schedule C-EZ, line 3; Schedule K-1 (Form 1065), line 15a (other than farming); and Schedule K-1 (Form 1065-B), box 9, Ministers and members of religious orders, see page SE-1 for amounts to report on this line. See page SE-2 for other ~ncome to report ........................... 3 Combine lines t and 2 4 Net earnings from self-employment. Multiply line 3 by 92.35% (.9235). if less than $.400, do not file this schedule; you do not owe self-employment tax ......... ~;.~, 5 Self-employment tax. If the amount on line 4 is: ·$76,200 or less, multiply line.4 by 15.3% (.153). Enter the result here and on Form 1040, line 52. '" *More than $76,200, multiply line 4 by 2.9% (.029). Then, add $9,448.80 to the result. Enter the total here and on Form 1040, line 52. 6 Deduction for one-half of self-employment tax. Multiply line 5 by 50% (.5). Enter the result here and on Form 1040~ line 27 .... I 6 t For Paperwork Reduction Act Notice, see Form 1040 instructions. CaL NO. ~ ~358Z / ll I"" Schedule SE (Form 1040) 2000 ' Exhibit 4 Pg. 12 (Not $ 81.oo $ 4.00 $ 3.09 $ 5.99 $18.98 $ 15.75 $3.98 $ 2.99 $ 5.25 Ste h's Monthl Ex enses including medicine and over the counter expenses) Diapers (sale CVS 72 count $13.59) Change every two hours (16 diapers a day plus extra when she poops.) (104 + a week) (416 + a month) Diaper cream (2 a month) Lysol room spray (1 a month) dug of liquid refill hand soap. (Two 7.5oz a month in bathroom) (One 7.5oz every week in Steph's room) (Total 6 a month) Box of 90 white trash bags - $7.49ea. Empty 2 bags a day plus anytime she has bowel movement (Use all 90 a month) Average 6 a day Paper towels. Average $.75/roll I roll every 2 days for Steph's room (15 rolls) 1 ½ rolls a week in bathroom (6 rolls) (21 rolls a month) Dixie Cups- Needed for water flushes (2 boxes a month ~ 1.99 each) Q-Tips - Needed to clear puss l~om eye/clean ears, clean nose daily plus after she throws up (1 box a month) Baby Bath - Bathe Stephy in bed Average $2.49 - $2.89 (2 a month) $1.00 ..Peroxide - Needed for G- Tube care, was needed for pin care Average $.75 - $1.00 (was 2 a month now only 1 a month) Pg. 13 $16.00 $32.00 $ 3.30 ,Wet-ones - BJ's 6 boxes for $8.99/Giant $3.47 each (Uses 2 boxes a week) (8 boxes a month) .LaundrF Detergent- Needed to wash poop and throw up out of clothes Wash separate from family linens Do extra laundry for tube feeding leaks, medicine spills, wet or poops through clothes, throws up, wash bed linens once or twice a day on sale $8.00 a jug at Kmart/$13.99 Giant (Use 4 jugs a month just for Stephy) ,,Clorox- Needed for set in stains (poop, throw up, formula) $1.65 each (Use 2 jugs a month) $ 8.47 $20.00 Coffee- $4.94 on sale. Supply coffee for nurses Creamola - $1.37 Filters - $.59 Sugar - $1.57 .Soda - Always stocked for volunteers, visitors, and nurses TOTAL EXPENSES: $221.80 (each month) Exhibit Stephy's over the counter medicine expenses $7.79 Senekot (one bottle a month) Given as needed $14.00 Milk of Magnesia. $3.49 for small bottle. ( 4 bottles a month) Given twice a day. $126.32 Lacrilube or Ak'wa Tears $15.79 each. 2 tub~s a week, 8 a month, Given every two hours. $36,78 Refresh. $18.39 each, (2 boxes a month) $184.89 a month The following are used ~sil_y: Lotions - Keep skin soft, and prevent bed sores Mouthwash - Moisten mouth, can~not eat, get rid of throw-up taste Chap stick/Lip Balm - Every two hours on lips or they ~et very dry Soda - Staff, visitors, helpers, keep refrigerator stocked Exhibit 6 Gas Expenses Please note these are the sas receipts I have. However, we were spending seventy to eighty dollars a week on gas just for my husband to travel to work plus rake my dauffhter, Jennie to school from April to Sune. I would spend twenty dollars a week going to the hospital plus taking my son John to pre-school in Hershey. Now that we are home, I travel allot for doctor appointments, pick up supplies, get medicine, etc. My husband has a company truck. Therefore, the gu spent at our house is for Stephy's 4/29/01 $27,00 5/1/01 $17.00 5/4/01 $43.00 5/5/01 $20.00 5/11/01 $36.00 5/20/01 $28.00 5/20/01 $26.00 5/23/01 $35.15 5/30/01 $28.00 6/6/01 $44.50 6/12/01 $31.00 6/12/01 $12.69 April 9, 2001 to June 12, 2001 (9 week average $900,00) 6/25/01 $20,00 7/3/01 $19.50 7/17/01 $26.25 7/19/01 $26.01 7/25/01 $20.50 7/28/01 $20.00 8/11/01 $23.00 8/11/01 $14.50 8/18/01 $11.$0 8/18/01 $33.50 $/27/0i $16.00 9/17/01 $26.76 June 25, 2001 to September 17, 2001 * Again, I do not have all the receipts. I would sometimes just pay cash. However, you can verify all my doctor visits and prescription pick ups to know the gas expense is hish. Exhibit 7 Actual Expenses from May - September 5/5/01 M_am-ices $20.00 Scarves and Hats to cover head 5/19/01 Kmart $27.96 4 Big shirts to go over head. (Getting ready for rehab.) 6/1/01 Shermin $40.00 Paint, brushes, drop cloths for Stephy's room Williams 6/5/01 Springmaid $154.66 2 sets of Ivory flannel sheets ($59.98), Extra Outlet pillowcases for under legs ($35.98), 6 cushions for wooden chairs (29.97), White pillow cases ($7.96), 2 Bed mats(S9.98) ($143.87 + $10.79 tax) 6/10/01 Wal-Mart $13.47 Coffee ($4.94), DecaffCoffee ($7.16), Creamer ($1.37). Get nurses coffee station ready to keep them awake. 6/10/01 Wal-Mart $268.46 Rug by daybed ($24.96), Lg. Wastebaskets by bed ($14.96), Lg. Wastebasket by sink ($14.96), 2 accent lamps ($29.94), Baby monitor ($29.96), Scented Trash bags ($1.97), Scented trash bags ($1.97), Soft tooth brush ($2.44), dish cloths for Stephy's room ($5.00), Glad Aerosol ($1.23), milk of magnesia ($7.36), Baby bath ($2.64), 6 plug outlet for behind bed ($2.56), 6 plug outlet on counter ($2.56), set of night lights in room ($6.97), set of night lights in bathroom ($6.97), New portable phone ($39.97), Themsometer ($9.96), Light over sink ($25.96), 6 plastic drawers to organize Stephy's stuff.($1.97 ea. $11.82), 60 watt bulbs for new lights ($1.17), Accent blue rug by Steph's bed ($5.96), Small flashlight for Stephy's drawer to see in eyes ($1.97). ($253.26 + 15.20tax = 268.46) 6/12/01 Staples $34.78 3 nine volt batteries for baby monitors ($4.19ea; $12.57), Post it notes ($2.69), Labels to mark Stephy's drawers ($1.99), Notepad to write notes to nurses ($2.39), wipe offmemo board for Stephy's room ($6.99), Calendar for therapy ($8.15) 6/12/01 Si~nan's $306.34 White day bed (so we can sleep in Stephy's Furniture room) 6/13/01 Radio Shack $63.59 3 way intercoms(through home to call for help) 6/13/01 Giant $6.36 Huggies wipes ($3.47), Magic Bath ($2.89) 6/15/01 Home Depot $76.78 Wood for Stephy's exercise mat 6/16/01 Kmart $15.66 Kitchen towels for Stephy's room, new sneakers for Stephy's therapy 6/16/01 JoAun Fabrics $226.83 Cushion and Table cloth cover for exercise mat 6/19/01 CVS $71.78 2 boxes of trash bags ($6.49 each; $12.98), Paper towels 8 pk ($4.29), 2 boxes of Q-tips ($2,99 emch; $5.98), lmby wipes 130 count ($3.99), 3 bags CVS brmd diapers 72 count ($13.49 each; $40.47) ($67.71 + $4.07 tax) 6/21/01 Gimut $2,93 Coffee creomer for nurses 7/1/01 Yellow $60.00 Had to join for Stephy in case of an emergency' Breeches Ambulance Association 7/3/01 Staples $42.36 Therapist chair 7/10/01 Kmart $13.84 Soft hand soap refill ($5.99), Diaper cream ($1.99), Diaper Cream ($1.99), Lysol Spray ($3.09). ($13.06 + $.TStax) 7/16/01 Kmart $8.00 200oz. Era laundry deter~ent 7/17/01 Knmrt $31,98 2 p~ck ofdi~pers (~ $15.99 each 7/17/01 S.S. $81.88 Therapy Bail Worldwide 7/23/01 CVS $7.48 2 boxes of kitchen Ba~s ½ price 7/24/01 Head Injury $104.00 Three bOoks on head injury Association 8/5/01 BJ's $5.00 Baby wipes (Hartrnans wouldn't take anymore money for them) 8/8/01 Staples $6.35 Yellow paper for fundrasin~ 8/8/01 Kmart $2.58 Envelopes 8/17/01 Post office $42.26 Stamps 8/19/01 BJ's $17,98 Baby wipes 8/24/01 Staples $5.99 Paper Towels 8/25/01 Bon-ton $50.67 Ten new shirts for Steph,v 8/25/01 Home Depot $43.03 Two new spot lights for fundraiser 8/27/01 CVS $19.99 L~, ~aite diap~,u~s 9/1/01 B$'s $37.54 Plates ($6.99), Forks ($5.99), Assorted utensils ($5.99), Glad Trash bags ($6.99), Glad Trash Ba~s ($6.99), Clorox ($4,59) 9/1/01 BJ's $299.99 Recliner (Paid for by Penny Parks fundraiser) 9/5/01 Kmart $7.43 Little Nose spray ($2,69), Q-tips ($2.99), Clorox ($1.75) TOTAL $2,217.95 ... Exhibit 8 ;00~ [66£~ O~ XE/X~] LT:~I I~Id ~O/tO/~O Ro~a/d J. Ogker Cus~m Builder Oak Pa~r Ave. CaHielo, PA 17013 Invoi=e #: 000201~3 DI~: 12/24/2001 P~ge: I Bill Td: Brad Wolf 314 Bonnybrook Rd. CaHble, I~l. 17013 Brad Wolf 314 Bonnybrook Rd. Carlisle, Pa. 17013 Description Finnish interior of existing family room (380 sq. fl.) frame wall flush around blo~ insulate, drywall and finnish side walls move eletric to new walls new ceiling tile and wall angles for drop ceiling install two new doom (flush birch) remove old glue down carpet install new carpet 0 $20.00 sq. yd. · .painting haul away trash Material and Labor Amount Tmmm: Total Anmuflt: ~lount B~l~rm~ Due: $B,~7s.00 SO,O0 ~00~ [66£~ ON l~/l$] ~I:°~ IHd ~0/~0/I0 13'3~ 12'8 11' Ronf/d J. Ocker Custom Builder 11 Oak Park Ave. ZO/~O/TO S~wk~ MM=It 0O02O132 DMz: t2/24/2001 Pace: I Bill To: Brad Wolf 314 Bonnybrook Rd. Clrli$1o, Pl. 17013 Brad Wolf 314 Bonnybrook Rd. Carlisle, Pa. 17013 Description Build laundry room in existing basement 2x4 ;~,me walls drywall and finnish interior walls plumbing for washer and laundry tub laundry tub and pump tank wire room for eletric drop ceiling vinyl flooring ~ $15.00 SCl yd. *bnclose water heater and pump tank with a closet and door 3/0 laundry room door (flush birch) 3/0 steel door into basement painting Material and Labor TM,,k y,,u ~'y~r W $4,925.00 Tm: ~ ToMI AmmJitt: 900~ [66£~ ON XH/~] A~°~ I~ ~O/PO/TO 11'6 7'11 new flush door UP ~> Exhibit 9 TUCKER Ai~ENSBERG & SWARTZ LE~ C SWARTZ ESQUIRE 111 NOR~{ FRONT STREET P O BOX 889 HArrISBURG PA 17108-0889 December 28, 2001 Re: STEPHANIE BAILES tIS ~z 910152164 Incident Date= 03/27/2001 Dear Mr. Swartz: The Department of Public Welfare maintains a lien in the amount of $4,327.00 for the a~ove-referenced incident. The Department has agreed to reduce its lien by 33 1/3% and accept $2~886.00 to satisfy the total lien amou/at. Checks should be made payable to the Department of Public welfare and sent to my attention at the a~ove ad,tess. We request that with t~mn~ttal of Eunds, you Drovide the Department with a ~opy of the final In the event you have already brought or will bring any action resulting in a further recovery, we reserve the right =o seek recovery of any additional unpaid Dortion of our medical/cash lien. This settlement in no way a~fects our future rights. Thank you £or your cooperation in this matter. If you have any £urther questions, ~lease contact me. Sincerely, Sharon E. Smith TPL Program Investigator 717-772-6~9T 717-772-6~ FAX Exhibit 10 THE STEPHANIE ANNE BAI?.~.S 2002 TRUST Prepared for KIM L. WOLF by: LACY HAYES, JR. Attorney at Law 2216 Walnut Street Harrisburg, Pennsylvania 17103-2426 (717) 234-0700 TABLE OF CONTENTS Article I. Creation of Trust ............................ 1 Article II. Purposes of the Trust ........................ 1 Article III. Original and Successor Trustees .............. 3 Article IV. Distributions for Stephanie Anne Bailes ....... 5 Article V. Termination of the Trust ..................... 8 Article VI. Powers and Duties of Trustees ................ 10 Article VII. Definitions and General Provisions ........... 14 Article VIII. Irrevocability of Trust ...................... 16 Article IX. Acceptance of Trust ......................... 16 THE STEPHANIE ANNE BAIT.~.$ , 2002 TRUST THIS AGREEMENT /LND DECLARATION OF TRUST is made this day of , 2002, between Kim L. Wolf, as the mother and natural guardian of Stephanie ~-nne Bailes, (hereinafter referred to as "Settlor" or in the first person), and, AmeriServ Trust and Financial Services Company (hereinafter referred to as "the Trustee"). ARTICLE I. CREATION OF TRUST I hereby transfer particular property to the Trustee. That property and all proceeds, investments and reinvestments thereof and any property hereinafter received by the Trustee from me or from any other person (such property being hereinafter referred to as the "Trust Estate") shall be held, administered and distributed in accordance with the terms of the Trust herein expressed. I reserve to myself and to others the right to add property to the Trust Estate by lifetime or testamentary gifts, all of which added property shall be governed by the terms hereof. ARTICLE II. PURPOSES OF THIS TRUST A. BENEFICIARY This Trust is established for the benefit of Settlor's daughter, Stephanie A~ne Bailes, date of birth April 13, 1989. It is not the purpose of this Trust that it serve as a primary or main source of income or support for the beneficiary. This Trust is established in accordance with a special provision of Title XIX of the Social Security Act, specifically 42 U.S.C. 1396p(d) (4) (A), as amended by the Omnibus Budget Reconciliation Act of 1993 (and any federal or state regulations or other rules promulgated pursuant to that provision) which exempts the assets held in the Trust from being included in the determination of the beneficiary's eligibility for, or amount of, medical benefits under a State Plan under the Act, and therefore, the property directed to this Trust shall in no way be deemed to have been or to be available to the beneficiary, Stephanie'~unne Bailes. ?~ - 1 - B. SUPPLEMENTAL ASSISTANCE LIMITATION OF BENEFITS With respect to my daughter Stephanie, the express purpose of this Trust is to provide for Stephanie's extra and supplemental needs, over and above the benefits Stephanie otherwise receives as a result of handicap or disability from any local, state, or federal government or from private agencies, any of which provide services or benefits to disabled persons. Anything to the contrary herein notwithstanding, no trust income or principal shall be paid to or expended for the benefit of Stephanie so long as there are sufficient monies available to her for care, comfort, and welfare from federal, state, and local government agencies and departments. The Trustee shall consider such governmental funds in determining whether there are funds available to the beneficiary from sources other than the trust estate and shall use trust assets only to supplement and never to substitute for such funds. In no event may trust income or principal be paid to or for the benefit of a governmental agency or department, and the trust estate shall at all times be free of the claims of such governmental bodies. C. ADVOCACY The Trustee shall periodically contact Stephanie, any applicable local associations for citizens with disabling conditions, other relatives, guardian if applicable, and the staff of any group home or other residential facility where Stephanie may reside regarding items and directives of this Trust for my daughter and my daughter's well being. D. GUARD IAN I strongly recommend against guardianship and counsel other alternatives. If the issue arises, I direct the Trustee to seek the counsel of an appropriate local or statewide advocacy agency and to make any decisions in the light of the most current revision of my letter of intent and with regard toward the important object of encouraging and assisting Stephanie to be self-sufficient. If there is a need for a conservator of my daughter's estate or a guardian of her person, if appropriate, the Trustee shall seek appointment by the Court to serve. Preference shall be given first to any nominations in the Last Will and Testament of the Settlor, and then to the Trustee named in this document and if the named Trustee is unable to - 2 - serve, an appropriate local or statewide advocacy agency shall assist in obtaining a suitable conservator or guardian as the case may be. ARTIC?m III. ORIGINAL AND SUCCESSOR TRUSTEES A. INITIAL Trustee. I, Kim L. Wolf, the "Settlor" hereby transfer and deliver to "the Trustee" of this Trust some money concurrent with the execution of this Trust. Additional property interests of all kinds may be transferred to the Trust by any person in any manner. All property interests assigned, conveyed, or delivered to the Trustee must be acceptable to the Trustee before it becomes part of the Trust Estate. All such property is to be held, administered and distributed by the Trustee as provided in this instrument. During my life, and so long as I am not disabled, I reserve the right to remove any Trustee at any time and shall also have the right to appoint any successor or successors thereto. B. SUCCESSOR TRUSTEE(S). Settlor (or the guardian of Stephanie's estate) shall have the power to name one or more successor Trustee. Any successor trustee shall have the power to name one or more successor Trustee. C. REPLACING TRUSTEE IN EMERGENCY. If the currently acting Trustee shall for any reason be unable to participate in the Trust activities because of illness, disability, death, or any other reason, then each of the above-named Trustees shall be authorized to act as Trustee during such incapacity, in the order set forth above, and to make any and all decisions regarding the Trust estate as Trustee under this instrument. In determining the disability of the currently acting Trustee, the successor Trustee may rely on a certificate or other written statement from two licensed physicians who have examined the currently acting Trustee. In the absence of such a certificate or statement, the Successor Trustee designated above, shall petition a court of competent jurisdiction over this Trust for authority to proceed as Successor Trustee. The successor Trustee shall incur no liability to the beneficiary of the Trust or to the Trustee who is rep~ce~ as a result of any action taken under this provision. ~ - 3 - D. NON-PROFESSIONAL TRUSTEES. The provisions of the foregoing notwithstanding, I recognize that while the Trustees are financial institutions, they are not licensed nor skilled in the field of social services. The Trustees may seek the counsel and assistance of the guardian of Stephanie Anne Bailes (if any), state and local agencies which have been established to assist persons with disabilities. The Trustees may use these resources to aid my daughter's guardian as appropriate, in identifying programs which may be of social, financial, developmental or other assistance to my daughter. However, the Trustees shall not in any event be liable to the beneficiary, the remaindermen of the Trust or any other party for his acts as Trustees hereunder so long as he acts reasonably and in good faith. For example, the Trustees, as well as my daughter's guardian, shall not be liable for the failure to identify each and every program or resource which might be available to my daughter on account of my daughter's disabilities. E. DISCRETION OF TRUSTEES. No inference of imprudence or partiality shall arise from the fact that the Trustees, in exercising the discretion conferred herein on the Trustees, shall have allocated a receipt or expenditure in a manner contrary to any provision of the Pennsylvania Statutes regarding Trusts. Except insofar as the Trustees shall exercise the discretion conferred on the Trustees and except as otherwise provided by this Trust, matters relating to principal and income shall be governed by the provisions of the Pennsylvania Statutes regarding Trusts and fiduciary obligations from time to time existing. F. EXPENSES OF ADMINISTRATION. The Trustee is entitled to expend the funds of the Trust or is entitled to reimbursement from the funds of the Trust for the reasonable expenses incurred in carrying out its duties and responsibilities under this Agreement. The Trustee is also entitled to an annual fee for services of between seven-tenths (0.7%) percent and nine-tenths (0.9%) percent of the principal of the Trust in the discretion of the Trustee. No trustee shall be required to enter bond or other security in any jurisdiction. G. RESIGNATION OF TRUSTEE. At any time, the Trustee may resign as Trustee of the Trust by mailing written notice of resignation to each Trust beneficiary, or her guardian if the beneficiary is incapacitated, and to all successor Trustees. Such resignation shall be effective and all duties of the - 4 - resigning Trustee, except the duty to account, shall cease sixty (60) days after the mailing. The notice shall be sent by certified mail, return receipt requested. H. TRUSTEE AND CO-TRUSTEE. No Trustee designated in this instrument shall be liable to the beneficiary or to any heir of the Settlor for the Trustee's acts or failure to act, except for willful misconduct or gross negligence. In the event co-Trustees are named, and one ceases to act or is unable to act, the remaining co-Trustee is authorized to exercise full power and authority as allowed in this Trust instrument. ARTICLE IV. DISTRIBUTIONS FOR STEPHANIE ANNE The Trustee shall continue this Trust for the benefit of my daughter, Stephanie Anne Bailes, as long as she is living, on the following terms and conditions: A. I have left a letter of intent which I have updated periodically and signed and dated. I request the Trustee to read that letter and to use it as guidance in administration of this Trust according to its terms. This letter of intent provides information about Stephanie's day to day activities, and in no way is it intended to supercede or modify any terms of this trust. B. The Trustee may pay to, or provide for the benefit of the beneficiary, as much of the net income and the principal as the Trustee, in his sole discretion, may from time to ~time think desirable, in such amounts or proportions as the Trustee may from time to time think appropriate, in his sole discretion; provided, however, that the Trustee complies with the limitations included in paragraph VII.G hereinbelow. The Trustee may distribute discretionary amounts of income for special needs not otherwise provided by governmental financial assistance and benefits, or by the providers of services, which will not cause the beneficiary to be ineligible for governmental financial assistance benefits, in the event that beneficiary is receiving such benefits. Further, The Trustee may distribute discretionary amounts of principal for special needs not otherwise provided by governmental financial assistance and benefits, or by the providers of services, which will not cause the beneficiary to be ineligible for governmental financial assistance benefits,' in the event that beneficiary is receiving such benefits; prg~ided, - 5 - however, that the Trustee complies with the limitations included in paragraph VII.G hereinbelow. C. "Special needs" refer to the requisites for maintaining the good health, safety, and welfare of one or more beneficiary when, in the discretion of the Trustee, such requisites are not being provided by any public agency, office, or department of any state or of the United States. "Special needs" may include, but not be limited to, medical and dental expenses, annual independent checkups, clothing and equipment, programs of training, education, treatment and rehabilitation, private residential care, eye glasses, transportation (including vehicle purchase), insurance, and essential dietary needs. "Special needs" may include additional food, clothing, electronic equipment such as radios, record players, television sets, computer equipment, other monetary requirements to enhance her self-esteem or situation, and to facilitate any program of physical therapy or occupational therapy arising from or related to her disability, such as providing rewards to her for achievement of goals. It is my desire that the beneficiary be provided with the requisites which will foster her improvement and encourage independent living. D. The Trustee shall have no obligation to expend Trust assets for such needs, but if the Trustee, in his sole discretion, decides to expend Trust assets, under no circumstances (except as provided in paragraph V.i.C) should any amounts be paid to, or reimbursed to, the federal government, any state, or any governmental agency for any purpose, including for the care, support, and maintenance of the beneficiary. This Trust is created expressly for the beneficiary's extra and sup- plemental care, maintenance, support and education in addition to, and over and above the benefits she otherwise receives or may receive as a result of handicap or disability, from any local, state or federal government, or from any other private agency, any of which provides service or benefits to persons with disabilities. It is my express purpose that this Trust be used only to supplement other benefits that the beneficiary may receive. - 6 - E. Because the beneficiary may be dependent on the support and aid of others, the Trustee shall, in the exercise of his best judgment and fiduciary duty, seek support and maintenance for her, or request the guardian of the beneficiary to seek support and maintenance for her, from all available public resources, including, but not limited to, Social Security Administration benefits, the Supplemental Security Income Program (SSI), any such supplemental income program offered by or through the Commonwealth of Pennsylvania, the Old Age Survivors and Dis- ability Insurance or successor programs, U.S. Civil Service Commission benefits, Medicaid, and Federal Social Security Disability Insurance (SSDI), and any other comparable programs, state, federal, or local. The Trustee shall take into consideration applicable resource and income limitations of any public assistance programs for which the beneficiary is eligible when determining whether or not to make any discretionary distributions. F. If necessary, the Trustee may seek appropriate authority to collect, expend, and account for separately all such governmental assistance benefits, but shall not commingle them with these Trust assets. In addition, in making distributions for the special needs of the beneficiary, the Trustee shall take into consideration the applicable resource limitations of the public assistance programs for which the beneficiary is eligible. G. No part of the Trust shall be used to supplant or replace public assistance benefits of any county, state, federal or governmental agency which has a legal responsibility to serve persons with illnesses, handicaps or disabilities which are the same or similar to the disorders of the beneficiary. In the event the Trustee is requested by any department or agency to release principal or income of the Trust to or on behalf of him to pay for equipment, medication or services which other organizations or agencies are authorized to provide, or in the event the Trustee is requested by any department or agency administering such benefits to petition the Court or any other administrative agency for the release of Trust principal or income for their purpose, the Trustee shall deny such request and is directed to defend at the expense of the Trust estate, any contest or other attack of any nature. H. No interest in the principal or income of the TrYst shall be anticipated, assigned, or encumbered, or sha~ be - 7 - subject to any creditor's claim or to legal process, prior to its actual receipt by the beneficiary. The beneficiary is specifically prohibited from any right to receive, demand, secure, give, assign, transfer, mortgage, borrow against, or will any Trust assets or income. I. It is the intention of the Settlor to conserve and maintain this Trust for the special needs of the beneficiary. Therefore, no part of this Trust, neither principal nor undistributed net income, shall be subject to the claims of voluntary or involuntary creditors for the provisions of care and services, including residential care, by any public entity, office, department, or agency of any state or government agency, or of the federal government of the United States, or of any other governmental agency. ARTICTm V. TERMINATION OF THE TRUST A. The Trustee shall hold any property acceptable to the Trustee which is added to this Trust, and shall manage, invest and reinvest said property, shall collect the income therefrom and shall distribute the net income and principal in accordance with the following provisions: B. Upon the death of Stephanie ~Lnne Bailes, the Trustee may pay the expenses of her last illness and funeral, and all Administrative expenses relating to this Trust, including reasonable attorney's and accountant's fees, if, in the Trustee's sole discretion, other satisfactory provisions have not been made for the payment of such expenses. It is my desire that upon the death of Stephanie Anne Bailes, that final arrangements be at the discretion of the Trustee. C. Upon the first to occur of Stephanie's death or the earlier termination of this Trust, the trustee shall pay to the Commonwealth of Pennsylvania, Department of Public Welfare, or any successor agency, and/or any other state which has provided Stephanie with medical care under a state medical assistance program, as a beneficiary hereunder, an amount which is equal to the lesser of the amount paid on behalf of Stephanie under such plan or plans from the time of creation of this Trust until his death or earlier termination of this Trust (as finally determined by such state or states), or the balance remaining in the Trust, in accordance with 42 U.S.C. 1396p(d) (4) (A). In order to assure - 8 - payment of this first priority, the Trustee is required to inquire with the Pennsylvania Department of Public Welfare, or any successor agency to determine if any such liability exists, and then to fully repay this liability before any disbursement can be made to any remainderman of the Trust. D. This Trust shall cease and terminate upon the death of my daughter Stephanie and thereupon the Trustee shall distribute any principal remaining in the Trust, after the distribution directed in the above paragraph, to any Settlor who is then living, or equally to Settlor's children if no Settlor is then living. In the event there is no living issue of Settlor at the time of Stephanie's death, then the Trustee shall distribute the entire residue according to the Pennsylvania laws of intestate succession then in effect, to the heirs of the Settlor. If an heir under this paragraph has not attained the age of thirty (30) years at the time of Stephanie's death, the share of that heir shall be held in trust for the benefit of that heir according to the following terms. My Trustee shall have the discretion either to create a separate Trust for each heir, or to combine my bequests to heirs who are in the same generation (or heirs who are close in age but in different generations) into a single Trust. The Trustee shall have the power to expend and apply so much of the net income and so much of the principal of each Trust as the Trustee shall consider advisable for the support, health, care, and education of each heir until the youngest heir of that Trust attains the age of twenty-two (22) years. When the youngest heir shall attain the age of twenty-two (22) years, one-third (1/3) of total corpus of the Trust remaining shall be distributed outright equally among the heirs of that trust who are then living, regardless of what amounts have been distributed previously. When the youngest heir shall attain the age of twenty-five (25) years, one-half (h) of total corpus of the Trust remaining shall be distributed outright equally among the heirs of that trust who are then living, regardless of what amounts have been distributed previously. When the youngest heir shall attain the age of thirty (30) years, the remaining principal and accumulated income of total corpus of the Trust shall be distributed outright equally among the heirs of that trust who are then living, regardless of what amounts have been distributed previously. No heir shall have any right to alienate, encumber, or hypothecate his or her interest in the principal or income of the~rust in - 9 - any manner, nor shall any interest be subject to claims of his or her creditors or liable to attachment, execution, or other processes of law. E. In the event the laws of the Commonwealth of Pennsylvania or the United States change in such a manner as to render the discretionary nature of this Trust invalid or unenforceable; or to allow creditors, including, but not limited to those agencies set out in this Trust Agreement which provide benefits to a beneficiary to reach the funds held in this discretionary Trust, or to otherwise have the effect of rendering the beneficiary ineligible for the governmental benefits enumerated in this Trust, then this Trust shall terminate immediately and my Trustee is authorized to terminate this Trust and to distribute and deliver the residue, free of Trust under the residuary provisions of this Trust contained in paragraph V.C. above. In addition, the Trustee may apply to a court of competent jurisdiction for authority to amend this Trust to carry out my intent. I specifically recognize and request that any such court modify this Trust Agreement as necessary to ensure that my directions for the care of the beneficiary are followed and that this Trust is not considered an asset so as to disqualify the beneficiary from federal, state, or local governmental assistance. F. Notwithstanding anything in this Agreement to the contrary, the Trusts created in this Agreement shall terminate not later than twenty-one years after the death of the last survivor of the Settlor and the issue of either living on the date of the survivor of the Settlor's death, when the Trustee shall distribute each remaining Trust to the beneficiary of the current income thereof. ARTICLE VI. POWERS AND DUTIES OF TRUSTEE During the continuance of the Trust and at the end thereof, for the purposes of making final distribution, the Trustee and all successors shall have and possess the following powers in addition to those granted elsewhere in this Trust and in addition to any powers given by law: - 10 - A. the power to retain or invest and reinvest the principal and any undistributed income held hereunder in any investments for as long as they may deem advisable and without regard to diversification. This power shall include the right to combine such principal and undistributed income with other assets held or maintained in Trust by Trustee or any successor. Notwithstanding a~y other provision herein or rule of law to the contrary, the Trustee and all successors are authorized to invest and reinvest the principal of the Trust in any form of legal investment as if they were the absolute owner thereof, including non-income or low income producing assets and pay the cost of carrying those assets from income or principal; B. the power to sell, pledge, exchange, mortgage, lease without limit of time or grant options for the purchase, lease or exchange of any asset held hereunder on such terms and conditions that provide for adequate consideration in money or money's worth as Trustee deems advisable; C. the power to make loan(s) of the Trust principal to any person(s), corporation or other entity, prQvided that such loan(s) bear a reasonable rate of interest and are properly documented, and that no loan is made to the trustee, to avoid any possible appearance of a conflict of interest; D. the power to borrow money for any purpose which Trustee considers to be for the benefit of the Trust or to facilitate its administration, and to mortgage or pledge assets held hereunder to secure the repayment thereof; E. the power to buy, sell and trade in securities of any nature; F. the power to buy liability, property damage, theft, flood and other insurance including policies of life insurance and/or annuities on the life of the Beneficiary and to hold and pay for the same as an investment and asset of the Trust, at any time and upon successive occasions, the premiums to be charged against income or principal, as the Trustee shall determine; G. the power to hold or register assets hereunder in Trustee's name, the name of a nominee, the nominee of a custodian or if bearer form, without disclosing any fiduciary relationship; - 11 - H. the power to retain and pay a corporate custodian, accountants and counsel (including investment counsel) for advice and other professional services; I. the power to compromise, adjust and settle claims in favor of or against the Trust Estate or Estates upon such terms and conditions as it may deem best; in the case of any litigation in connection with any part of such Trust Estate or Estates, it may, under advice of its counsel, arbitrate, settle, or adjust any such matter in dispute upon such terms as it may consider just and equitable, and its decision shall be binding upon the beneficiary; J. the power to distribute the principal or income of the Trust in cash or in kind, or partly in cash and in kind, as Trustee shall reasonably determine, and consistent with the express purpose of this Trust; K. the power to determine whether money or property shall be treated as principal or income and to charge or apportion expenses and losses to principal or income as they may deem just and equitable, in accordance with applicable law, and to bind the beneficiary by their judgment therein; L. the power to continue and manage any business, whether contributed to the Trust by Settlor (or others), or acquired by Trustee with Trust assets, including, but not limited to the right to incorporate such business; M. the power to do all such acts, to take all proceedings and to exercise all such rights and privileges, although not specifically herein mentioned with relation to any such property, to carry out the intent of the Settlor; and N. the power at any time to designate an additional Trustee to serve with him. Such Trustee may be a corporate fiduciary or an individual. Any corporate fiduciary shall be entitled to receive compensation in accordance with its standard schedule of fees in effect from time to time over the period during which its services are performed. O. Ail Successor Trustees shall render an annual account of the administration of the Trust to the Settlor during their lifetimes, and thereafter to the beneficiary. If no objection to - 12 - such account has been made in writing by the Settlor or any of the beneficiary within thirty (30) days after tRe date of delivery to them of such account by the Trustee, it shall be deemed approved and conclusive upon such persons. P. The Trustee shall file any income or other tax returns required of the Trust and shall pay from the Trust income any tax due thereon. Q. The Trustee is hereby relieved from any and all liability for loss or for any depreciation in value of the Trust which results from decisions, acts, or failures to act, provided they are arrived at in good faith. R. Until the Trustee shall receive written notice of any birth, marriage, death, or other event upon which the right to payment from this Trust may depend, the Trustee shall incur no liability for disbursements or distributions made or omitted in good faith. S. No Trustee shall be under any obligation to pay premiums or charges on any insurance policies. Y. No person or corporation dealing with the Trustee shall be required to investigate the Trustee's authority for entering into any transaction or application of proceeds. No Trustee has to obtain permission of any secondary beneficiary to enter into any contract, agreement, transaction, distribution or its application. U. In determining the amount of the discretionary distributions of income to a beneficiary of a Trust created hereunder, the Trustee should take into account all other means and resources known to or reasonably ascertainable by the Trustee, including any form of government assistance, which are available to such beneficiary for the purposes for which the Trustee is authorized to make said distributions. V. The Trustee may make any payments, in the Trustee's discretion, in any one or more of the following ways: 1. by paying sums directly to the beneficiary, but limited to sums that will not disqualify the beneficiary for any government benefits; ~ - 13- 2. by paying sums to the natural guardian, or the legally appointed guardian, conservator, or other fiduciary of the person or estate of the beneficiary, but limited to sums that will not disqualify the beneficiary for any governmental benefits; 3. by paying sums directly to any person or organization supplying either goods or services for the beneficiary; 4. by making expenditures directly on behalf of the beneficiary, including the purchase of real or personal property for the beneficiary that qualifies as an exempt resource under applicable governmental programs from which the beneficiary is receiving benefits or which, considered together with resources then available to the beneficiary, will not disqualify the beneficiary from receiving the governmental benefits; or 5. by purchasing items as trust assets to be used by the beneficiary. 6. The Trustee, in the Trustee's sole discretion, may make payment to a minor or other beneficiary under disability by making payments to the guardian of his person, or to any suitable person with whom he resides, or the Trustee may make payments directly to a beneficiary if in the Trustee's judgment he is of sufficient age and maturity to spend money properly. 7. In the event of the occurrence of any event which is beyond the control of the Trustee and which temporarily or permanently disqualifies the beneficiary from those governmental benefits referenced in this Trust Agreement, then and only then, the Trustee may, in the exercise of its sole discretion, make such payments to or for the benefit of the beneficiary as the Trustee feels are reasonably necessary to assure that her basic and special needs are satisfied. ARTICLE VII. DEFINITIONS AND GENERAL PROVISIONS A. PHYSICAL DIVISION OF TRUST PROPERTY NOT REQUIRED. Unless otherwise set forth herein, there need be no physical segregation or division of the various Trusts except as - 14- segregation or division may be required by the termination of any of the Trusts. , B. PROTECTIVE CLAUSE. To the fullest extent permitted by law, no interest in the principal or income of any Trust created under this instrument shall be anticipated, assigned, or encum- bered, unless specifically authorized by the terms of this agreement, or subject to any creditor's claim or to legal process, prior to its actual receipt by the beneficiary. C. FIDUCIARY BOND. No bond shall be required of any person named as Trustee in this Trust. If a bond is required by any law or court of competent jurisdiction, it is my desire that no surety be required on such bond. D. GENDER AND NIIM_BER CLAUSE. As used in this instrument the masculine, feminine, or neuter gender, and the singular or plural number, shall each include the others wherever the context so indicates. With respect to the beneficiary, and notwithstanding any possible inadvertent reference to more than one beneficiary shall be construed to mean the one and only beneficiary of this trust, Stephanie Anne Bailes and no one else. E. SEVERABILITY AND APPLICABLE STATE LAW. If any provision of this Trust agreement is declared by a court of competent jurisdiction to be invalid for any reason, such invalidity shall not affect the remaining provisions of the agreement. The remaining provisions shall be fully severable, and this agreement shall be construed and enforced as if the invalid provision had never been included in this agreement. The validity of this Trust shall be determined by reference to the laws of the Commonwealth of Pennsylvania. Questions with regard to the construction and administration of the various Trusts contained in this agreement shall be determined by reference to the laws of the state in which the Trust is then currently being administered. F. NAME OF TRUST. The Trust created in this instrument may be referred to as "The Stephanie Anne Bailes 2002 Trust." G. COURT SUPERVISION. The trust created under this agreement shall be administered free from the active supervision of any court. The Trust's books and records along with ali Trust documentation shall be available and open at all reaSg~able times - 15- to the inspection of the Trust beneficiary and her representatives. ARTICLE VIII. IRREVOCABILITY OF TRUST This Trust is and shall be irrevocable and may not be altered or amended in any respect unless specifically authorized by this instrument, and it may not be terminated except through distributions permitted by this instrument. Notwithstanding the above, the Settlor and/or the Trustees are specifically given the authority and discretion to amend the terms of this Trust in the event of changed circumstances or laws, to comply with the original intent as stated herein. ARTICT.~. IX. ACCEPTANCE OF TRUST AmeriServ Trust and Financial Services Company hereby agrees to perform their duties as Trustee in accordance with the foregoing conditions and limitations. IN WITNESS WHEREOF, Kim L. Wolf, as the Settlor, and AmeriServ Trust and Financial Services Company, as the Trustee, have hereunto set their hands and seals the day and year first above written. WITNESS: Kim L. Wolf, Settlor AmeriServ Trust and Financial Services Company By: Carol D. Stern, Trust Officer - 16- COMMONWEALTH OF PENNSYLVANIA : : COUNTY OF : On the day of , 2002, before me, the undersigned, a Notary Public in and for said Commonwealth, personally appeared Kim L. Wolf, personally known to me or proved to me on the basis of satisfactory evidence to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same as Settlor. Witness my hand and official seal. My Commission expires: C:\Clients%Bailes Ward SNT\$NT 2001-12-28.wpd - 17 - Exhibit 11 t~g UU~ LAW OFFICES TUCKER ARENSBERG, & SWARTZ ATTORNEY'S AGREEMENT THIS AGREEMENT, entered into thls 8thdayof May' .... 2001, byand between TUCKER ARENSBERG & SWARTZ, Attorneys-at-Law, (hereinafter "Attorney"), and Kim L. Wolf, parent and natural guardian of Stephanie Anne Bailes (hereinafter "Client~)~ WITNESSETH: That Attorney, for the consideration hereinafter stipulated, has undertaken and does hereby undertake and agree with Client to act as legal counsel in negotiating a settlement, and if the same is not effected, in bringing, conducting and prosecuting an action against all responsible parties, to recover damages for personal injuries sustained by the Client in an acddent which occurred on or about March 27, 2001. ATTORNEY FEE: In consideration for services so rendered by Attorney, it is hereby agreed by and between the parties hereto that Attorney shall be compensated as follows: (a) Thirty-Three and One-Third (33-1/3%) percent of the gross recovery if the case is seA!ed before jury selection in a jury trial case, before commencement of trial in a non-jur! trial case, or before the commencement of the hearing in a matter first heard by arbitrators; or (b) Forty (40%) percent of the gross recover if the case is se~ed any time after it proceeds to jury selection at trial or if a gross recovery is (~bteined in any other manner at or after the selection of the Jury in a jury tdal case, a~ter commencement of the tdal in a non-jury tdal case or after the commencement of the hearing in a matter first heard by a~itrators, The Attorney's fee as set forth above covers only the Attorney's services through and including the trial of the Client's case and an)' post trial proceeding before the trial court, If the case is appealed to a court beyond the trial court, then the Client must enter a new agreement with the Attorney or make additional arrangements for the Attorney's fee for services for representing the Client in the appeal. "Gross recovery" shall mean the full amount of settlement proceeds or the full amount of verdict, including any pre-judgment interest, without reduction for expenses or costs advanced or incurred. Attomey shall have a lien on any sum or sums recovered, whether by settlement or judgment, for services rendered, costs advanced and expenses incurred under this Agreement. If for any mason the services of the Attorney are terminated, either by the Attorney or by the Client, Attorney shall have a right to be compensated for the reasonable value of the services prov~ed to Client. The reasonable value of the Attorney's services shall be the greater of the amounts determined as follows: (a) by applying the houdy rates ominadly charged by the Attorney during the time of Attorney's representation to the time expended by Attomey in this matter, or (b) Thirty-Three and One-Third (33-1/3%) percent of the highest rifler to settle Client's case received prior :o termination. The right of Afforney to receive any such compensation will be oonfingent upon Client obtaining 01/04/02 a recovery in.:th s case by sett ement: Verdidt or othe~e...Actditiona y, the Client willthen als~ beceme r~sPOnslble for the payments Of all the expeil~e,~.and'~sts':i~Curred I~, TUCKER ARENSBERG & -' ~WARTZ.on the Clier~t's ne;: Said' expenses and ~st~ Will become immed~at~y due an.:l: Owing to TUCKER ARENSBERG & SWARTZ, ,' ..~:.. EXPENSES OF LITIGATION: Any necessary and reasonable costs advanced by Attomey in the preparation and presentation of C!ient's claim, and,all expenses attendant thereto, shall be the responsibility of the C;ier~t to pay upon the Client's obtaining a recove~ in the case. Attorney retains the dght to request that the Client advance said expenses and costs. Attorney may apply any funds held in escrow on behalf of Client to the costs and expenses of lit~g;at~o~. SETTLEMENT PROVISION.A~ All offers to settle, adjus~r compromise the above claim shall be rewewed between Client and Atto~ey before any Such offer is~either accepted or rejected. Client further agrees to consider seriously any recommendation for setl~ement made by Attorney and not to unreasonably withhold consent to such settlement recommendation. DISCHARGE OR WITHDRAWAL: In the event that Attorney subsequently detemlines that the claim or suit I,~cks ~13erit. or Client unreasonably withholds consent to any bona fide sett~eiTlent recommenc[at on r~ ada by Attorney, or Client-refuses or fails to cooperate with A~ordey, 0~ Client'cO~ceals or misrepreser~ts facts regard ng the abOVe claim; or Client commits a breach of this Agreerfienl: Afforney shal~ have the righ[to terminate his s~rvices upon giving reasonable notice to Client. Client understands, acknowledges and agrees that Attorney does not guarantee the outcome or eventual result of the above claim. IN WITNESS WHEREOF. the parties hereto, intending to be legally ~und, have hereunto set tJ'~eir hands and seals to this Agreement, in execution thereof, the day a~:year fimt above written. WITNESSES: TUCKER ARENSBEi~G & SWARTZ ~ J (/,Jd'-F-~/~"~_ __ {SEAL) Klm L. Wolf (SEAL) Exhibit 12 LACY HAYES, JR. Counselor at Law 2216 Walnut Street Harrisburg, PA 17103-2426 Telephone No. (717) 234-0700 Fax No. (717) 234-1831 January 5, 2002 Ms. Kim L. Wolf c/o Lee C. Swartz, Esq. 111 N. Front St. Harrisburg, PA 17101 RE: THE STEPHANIE ANNE BAILES 2002 TRUST FOR PROFESSIONAL SERVICES RENDERED and to be rendered on behalf of client and Stephanie Anne Bailes in connection with the drafting of the indenture and implementation of THE STEPHANIE ANNE BAILES 2002 TRUST, including meeting with client and husband and Attorney Lee C. Swartz, on December 11, 2001 and correspondence with Attorney Swas:iz and the trust officer of AmeriServ Trust and Financial Services Company to arrange for meetings between client and the trust officer and work to obtain court approval of the settlement of the claim and the creation of the trust. Professional fee ............................................................ $5,400 (Estimated 30 hours at $180 per hour, per agreement with client) IN RE: Petition of KlM L. WOLF, Parent and Natural Guardian of STEPHANIE ANNE BAILES, a minor. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 02-0327 CIVIL TERM AND NOW, this ~___day of January, 2002, a hearing on the within petition for approval of compromise settlement and distribution of proceeds of a minor's claim, shall commenced at 1:30 p.m., Wednesday, January 30, 2002, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. Lee (~. Swartz, Esquire For Petitioner Edgar'~ ~J. IN RE. Petition of KlM L. WOLF, Parent and Natural Guardian of Stephanie Anne Bailes, and AMERISERV TRUST AND FINANCIAL SERVICES, Trustee of the Stephanie Anne Bailes 2002 Trust : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002-327 CIVIL TERM PETITION FOR APPROVAL OF EXPENSES FOR MINOR'S MAINTENANCE ANI3 IMPROVEMENTS FOR MINOR'S HOUSING Petitioners, Kim L. Wolf and Ameriserv Trust and Financial Services, Trustee of the Stephanie Anne Bailes 2002 Trust, file this petition for expenses and improvements and in support thereof avers as follows: 1. Petitioner Kim L. Wolf is the parent and natural guardian of her minor child, Stephanie Anne Bailes, who was born on April 13, 1989. 2. Petitioner Ameriserv Trust and Financial Services is the Trustee of the Stephanie Anne Bailes 2002 Trust. 3. As a result of catastrophic injuries incurred by Stephanie Anne Bailes in an automobile accident on March 27, 2001, Stephanie Anne Bailes, then 11 years of age, obtained $165,534.00 as a result of a settlement of the minor's automobile accident claim, which was deposited in trust with Ameriserv Trust and Financial Services named as Trustee of the Stephanie Anne Bailes 2002 Trust, by the Order of the Honorable Edgar B. Bayley on January 30, 2002, a copy of which is attached hereto as Exhibit "A". The principal of the trust is currently $166,000.00. 4. The Petitioner Kim L. Wolf resides with her husband Brad Wolf, whose family consists of their young son, John, four years of age, along with Stephanie whose injuries have had a drastic impact on the family, not only emotionally but economically as well. At the time of Stephanie's injuries, her mother operated a thriving daycare center business of which she was the sole proprietor that generated gross receipts of $31,229.00. Due to miscellaneous expenses, repairs and maintenance and utilities paid out by the family, as well as loss of income previously mentioned, the family has lost between $15,000 and $20,000 annually in spendable income as a result of the injuries to Stephanie. As a result of Stephanie's injuries, Kim L. Wolf had to sell her business and spend all of her waking hours with Stephanie while she was at the Hershey Medical Center and following that period, at home where she acts as one of the round-the-clock nurses, spending 14 hours per day with Stephanie, while two other nurses, provided by health insurance, care for Stephanie the rest of the time. While health insurance has paid the bulk of the medical expenses, the family continues to sustain numerous out-of-pocket expenses not provided by insurance, and have had considerable increases in utility costs, refuse disposal, cell telephone expense, and additional insurance expense which averages $330.00 per month. See Exhibit "B" attached. 5. In order to maintain the highest quality of life for Stephanie Anne Bailes, the family at its own expense have made improvements to their home and incurred other expenses of almost $50,000. See Exhibit "C" attached. 6. Through early June 2003 the family has incurred additional day-to-day expenses on behalf of Stephanie totaling $2,706.68. See Exhibit "D" attached. 2 7. In order to continue to maintain the highest quality of life for Stephanie, additional improvements will have to be made to the Wolf family home. The improvements and reasons therefor are set forth as follows: a. An addition to the home to make it more accessible for Stephanie. At the present time, Stephanie is confined in one room of a split-level house. An architectural plan has been drafted which will enable Stephanie to be transported from one portion of the house to the other and into the upper floors of the split-level house. A plan is attached hereto and marked Exhibit "E". The plan includes the installation of an elevator, the cost of which will be paid through public funds available for this purpose, with a balance of $4,719.00 remaining unpaid. The cost of the additions to the home will be an additional $72,300.00, leaving a total of $77,019.00 necessary to complete the project, plus the cost of $8,500.00 for architectural services provided by JWF Architects, Inc., the architectural firm retained by the Trustee Ameriserv for the purpose of producing a design for the improvements requested in this Petition. 8. Petitioners submit the following proposal and ask for court approval: (i) That Klm Wolf, representing the Wolf family, receive the sum of $330 per month from the trust of Stephanie Anne Bailes until Stephanie Anne Bailes reaches the age of 18 which will be on April 13, 2007, at which time she will be eligible for Social Security Disability benefits or Supplemental Security Income. (ii) That the sum of $77,019.00 be appropriated from Stephanie's Trust to pay for the improvements to the real estate. (iii) That the sum of $8,500.00 be appropriated from Stephanie's Trust to pay the bill of JWF Architects, Inc. 3 WHEREFORE, Petitioners pray the Honorable Court to authorize the Trustee to disburse $85,519.00 from Trust principal to the Wolf family to make modifications to the home to improve the quality of life for Stephanie Anne Bailes and that the Trustee have the authority to pay to Klm L. Wolf the monthly sum of $330.00 from interest and principal, if necessary. TUCKER ARENSBERG, P.C. L~e C. Sw~rtz ~ Pa. Bar I.D. #07258 111 N. Front St., P.O. Box 889 Harrisburg, PA 17108-0889 Telephone: 717/234-4121 Facsimile: 717/232-6802 ATTORNEYS FOR PETITIONER KlM L. WOLF 2216 Walnut Street Harrisburg, PA 17103-2426 Telephone: 717/234-0700 Facsimile: 717/234-1831 ATTORNEY FOR PETITIONER AMERISERV TRUST AND FINANCIAL SERVICES 4 IN RE. Petition of KlM L. WOLF, : IN THE COURT OF COMMON PLEAS Parent and Natural Guardian of : CUMBERLAND COUNTY, PENNSYLVANIA STEPHANIE ANNE BAILES, : CIVIL ACTION ~ LAW ORDER OF COURT ~)'~day of "-~'~ "' 200''~ t ' ' On this _ ~~.~, ~ is hereby ordered that the Petition for Approval of Distribution of Proceeds and Distribution of Proceeds of a Minor's Claim is approved and the settlement proceeds shall be distributed in the following manner: a. Payment of $44,080 to Klm L. Wolf, as reimbursement for lost wages and miscellaneous expenses set forth in the foregoing Petition; b. Payment of counsel fees for the law firm of Tucker Arensberg & Swartz in the amount of $37,500; c. Payment of $2,886 to the Commonwealth of Pennsylvania, Department of Public Welfare, to satisfy its lien for monies paid to the medical providers of Stephanie Anne Bailes; d. Payment of $165,534 to Stephanie Anne Bailes, a minor, which is to be deposited in the minor's name in a discretiona~ supplemental trust for Stephanie Anne Bailes with AmerServ Trust and Financial Services as Trustee; and e. Proof of deposit for the trust shall be filed of record in 30 days. BY THE COURT: COPY FROM RECORD T~:imony w~ereof, I here unto set my han~ EXHIBIT Stephanie Bailes Special Needs IRR Trust - 4698 Electric Telephone Cell Phone Garbage Cable Insurance Mortgage/Bi-Wkly Key Loan/Bi-Wkly 2000 100.00 60.00 0.00 33.00 N/A 105.00 489,00 298.00 2003 Increase 225.00 125.00 76.00 16.O0 22.00 22.00 70.00 37.00 N/A 255.00 150.00 489.00 0.00 298.00 0.00 Total $330.00 EXHIBIT "B" $15506.54 $ 5600.00 $ 4385.65 $ 3295.00 2002 Stephanie Expenses in order to prepare for a handicap child WE Paid toward family room and handicap bathroom WE PAID to expand driveway for therapist ,nurses, and volunteers WE PAID to have electric increased in from 200 to 400 amp. WE Paid to have security camera's placed in house .Fund paid $2000.00 $1070.03 $ 3276.35 WE Paid 2002 handicap van expenses WE Paid 2002 Home care Expenses .Items to accommodate Steph $1898.71 $ 2400.00 $1044.00 $ 38476.28 We Paid 2002 Hotel rooms for nurses, In order to take Steph with us. We Paid Stephy's monthly supplies average $200.00 a month, times 12 We Paid for a Lap top for Stephy to practice ABC and Numbers We Paid out in 2002 $1456.00 $6243.00 $ 756.19 $ 2706.68 $11161.87 2003 Stephanie Expenses in order to prepare for a handicap child Our family paid toward an separate ac/heat pump unit in Steph room WE paid toward Central Air/Heat pump so when the addition gets Completed Stephy will be comfortable any where in our home. ( $9400.00 ) The school held a dance-a-thon .They raised $3157.00 We paid for 2 regular hotel rooms plus a condo in order to take 3 nurses on vacation with Stephy and our family. Cost $1705.10 for The rooms .and $229.09. We got a AAA discount. We took the handicap For Steph and the truck for all her supplies. ( $1934.19 ) Fund paid $1178.00 Home care receipts for 2003. Items to accommodate Steph. WE paid out in 2003 (Jan-June) EXHIBIT "C" January $ 8.98 $ 5.O0 $ 45.52 $ 63.59 $ 29.98 $305.00 $ 34.95 February $ 20.97 $ 7.38 $ 25.90 $ 59.68 $120.74 $1535.94 March $ 8.17 $13.08 $ 36.00 $ 21.98 $ 21.20 April $ 24.03 $ 79.21 $ 9.28 $ 23.82 $18.79 Home Care receipts 2003 Items to accommodate Steph Lowes Raybold Kohls Mayer Johnson Great Ideas Foam letters 2 pkg. 25 pk. Of white wash clothes Wood and nails needed to hold up Laundry Room sink due to weight of heavy BM soiled clothes Van wash, wax, interior cleaned 2 sets of flannel sheets Board maker- computer program with pictures for Steph Sign language cards Kmart Kmart Staples Wallmart Staples John-Deere Label binder 2 K-y jelly Fax cartridge, folder, tablets Mirror for her room/Humidifier (Teach self-care) File folders ,paper, computer Ink Walk behind snow blower. To keep path Open for nurses and therapies. Walknart Wallmart Comm. Of Pa. Zany Brany Highland Tire Plastic fruit for Steph to memorize 4 pkg of baby wipes Van Registration Portable Magnetic Board Van Inspection Avon Dolls and Bears CVS Wallman CVS Asst. Lip gloss and shower gel Stephy learning items..Finger puppets, play dishes, Velcro dress doll ,magnetic doll &clothes Huggie wipes, Milk of Mag. 6 large clear storage containers for Steph room Perxide,water shoes,Lounger to lay on EXHIBIT "D" Con't Page 2 May $ 27.99 $ 8.10 $ 12.97 CVS Wallmart Ikea TED socks/compression socks for after surgery K-y Jelly/tissues Bead toys,clay,paint brushes June $ 38.00 EP Exceptional Magizine $ 2706.68 Total so far Ronald J. Ocker Custom Builder If Oak Park Ave. Carlisle, PA 17013 Service Invoice #: 00200228 Date: 5/1/2002 Page: 1 Bill To: Brad Wolf 314 Bonnybrook Rd. Ca[Hisle, Pa. 17013 Description Front Porch 10'x31' concrete and block foundation concrete floor 5"x5" wood posts @ 8' gable roof vinyl ceiling 2 ceiling light and Bac~ con~ con( Service At: Br is 1701 $7,750.00 d gab frarr cut an carpet boards and from elevator :1. yd, Thank you for your business! $58 800.00 Terms: Cash EXHIBIT "E" Total Amount: Amount Balance Due: Rona/d J. Ocker Custom Builder 11 Oak Park Ave. Car/is/e, PA 17013 Service Invoice #: 00200228 Date: 5/1/2002 Page: 2 Bill To; Brad Wolf 314 Bonnybrook Rd. C~disle, Pa. 17013 Description Side Porch 7'x26' concrete and block foundation concrete floor 5"x5" wood posts gable roof vinyl ceiling 2 ceiling lights and Fror 42"x 56 rais~ Service At B 17C $4 550.00 $1 200.00 Thank you for your business! Terms: Cash Total Amount: Amount Balance Due: $72,300.00 $0.00 $72,300.00 [] ~ ' '~ ~i*i ~:: (717) 653'7177'l-8CX%477-7177,1150WestMalnSt,,Mt. Joy, PA 175.52 PROPOSAL AN© ACCEPTANCE Dated: May 6, 2002 Proposal No. TB3-1027 TO 'kd,.r and Mrs Brad Wolfe .;1~ Bonnybrook Road Carlisle, PA 17013 her¢inaner called "Purchaser" BLOCK ELEVATOR COMPANY (hereinafter called "Company"), proposes to Furnish the necessary labor and one ( I ) Ven¢chs home elevator lo service two landings with horn enlrances wilh a rise ogno more [han rwelye feec All For tnt sum ct' Twenr'v Four Thousand Seven Hundred Nineteen Temn.s of Payrncnl: ]0 % AI acceptance .'~0"/? When malerials are delivered 40 % Net completion ?olIa~s =I; 24.7]9.0_0 Thti p:oposal ts subjecl lo Ihe terms on Ihe reverse side hereof~t~d will be automatically withdra,,~n should Ibis proposal nol be accepted wtthin Sixty(dO) days ",poroved .Block Elevator Company (S,gnarure oFAuthortzed Of Ftcial) Thomas A Block Iii Legal Name ct'Purchaser) Title: SalesRepresental,ve Da~e: May 6, 2002 (S gn~rur¢ or Authorized Official) Thle IN RE. Petition of KlM L. WOLF, Parent and Natural Guardian of Stephanie Anne Bailes, and AMERISERV TRUST AND FINANCIAL SERVICES, Trustee of the Stephanie Anne Bailes 2002 Trust : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW NO. 2002-327 CIVIL TERM CONSENT OF COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF PUBLIC WELFARE TO PETITION FOR APPROVAL OF EXPENSES FOR MINOR'S MAINTENANCE AND IMPROVEMENTS FOR MINOR'S HOUSING ~ o~ ~L Hm'g, lm~ PA ! 710~ Decembe~ 16, 2003 Telephone: 717-783-~81 '~: 717.77~07t7 La~y Hayes. Xr., N.~qutr~ Coun~olor al Law Harti~but& PA 1710'~-~4~ De~r A~rney tfyou hsve nn~ .aa~tional queafio~ o~ concm-ns, ptca~o ~ivo me ~ ~, Counsel IN RE. Petition of KlM L. WOLF, Parent and Natural Guardian of Stephanie Anne Bailes, and AMERISERV TRUST AND FINANCIAL SERVICES, Trustee of the Stephanie Anne Bailes 2002 Trust : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-327 CIVIL TERM ORDER AND NOW, this. ;~.O~ day o~03, upon consideration of the Petition for Approval of Expenses for Minor's Maintenance and Improvements for Minor's Housing, it is hereby ordered that Kim L. Wolf, mother of Stephanie Anne Bailes, a minor, receive the sum of $330.00 per month toward the care and maintenance of said minor until she shall attain the age of 18 on April 13, 2007, and that the Trustee is authorized to disburse $85,500.00 from the trust principal, to the Wolf family to make modifications to the home to improve the quality of life for Stephanie Anne Bailes. Ameriserv Trust and Financial Services, Trustee for the Stephanie Anne Bailes 2002 Trust, is hereby authorized to make the payments of the above sums.