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HomeMy WebLinkAbout14-6592 Supreme Connsylvania Con 0%tud leas For Prothonotary Use Only: Oil Docket No: z A, Cu, r and County3 The information collected on this form is used solely for court administration purposes. This form do supplement or replace the filing and service ofpleadings or other papers as required bylaw or rules of coy Commencement of Action: S (M Complaint 17 Writ of Summons OPetition E [3Transfer from Another Jurisdiction 0 Declaration of Taking C. Lead Plaintiffs Name: Lead Defendant's Name: T Craig Stone Laurence Paul, M.D. Dollar Amount Requested: Owithin arbitration limits Are money damages requested? 0 Yes 0 No (check one) R]outside arbitration limits Is this a Class Action Suit? 13 Yes 0 No Is this an MDJAppeal? 0 Yes 0 No A Name of Plaintiff/Appellant's Attorney: E3 Check here if you have no attorney(are a Self-Represented [Pro Sel Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARYCASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS 0 Intentional 13 Buyer Plaintiff Administrative Agencies 13 Malicious Prosecution [3 Debt Collection:Credit Card rl Board of Assessment [3 Motor Vehicle 0 Debt Collection:Other [3 Board of Elections [3 Nuisance ril Dept.of Transportation 11 Premises Liability [3 Statutory Appeal:Other S [3 Product Liability(does not include mass tort) n Employment Dispute: E ® Discrimination Slander/Libel/Defamation C [3 Other: Employment Dispute:Other [3 Zoning Board T 13 Other: I Other: o MASS TORT 0 Asbestos N [3 Tobacco 13 Toxic Tort-DES [3 Toxic Tort-Implant Q Toxic Waste REAL PROPERTY MISCELLANEOUS [3 Other: ril Ejectment 0 Common Law/Statutory Arbitration B Eminent Domain/Condemnation n Declaratory Judgment Ground Rent Mandamus 17 Landlord/Tenant Dispute Non-Domestic Relations 0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY n Mortgage Foreclosure:Commercial M Quo Warranto [3 Dental 171 Partition Q Replevin [3 Legal M Quiet Title r-il Other: rx-1 Medical [3 Other: 0 Other Professional: Updated 1/b2o1 01 ROSS FELLER CASEY, LLP ! 't f/1x4 0 By: ROBERT ROSS, ESQUIRE f 10!/SHANON S. LEVIN, ESQUIRE C(//;1 4 4 13 Af r IQ: ,59 Attorney ID Nos. 47152/86040 �S,j��f;`. cof f F One Liberty Place Y yl VAtilA ! v 1650 Market Street Suite 3450 Philadelphia,PA 19103 (215) 574-2000 Attorneys for Plaintiffs CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS 1460 LUTZTOWN ROAD CUMBERLAND COUNTY BOILING SPRINGS PA 17007 NOVEMBER TERM 2014 Plaintiffs, V. No: LAURENCE H. PAUL, M.D. JURY TRIAL DEMANDED JOHN R. DIETZ EMERGENCY CENTER HOLY SPIRIT HOSPITAL 503 North 21" Street Camp Hill, PA 17011 and EMCARE 503 North 21" Street Camp Hill, PA 17011 and EMCARE MEDICAL SERVICES OF PENNSYLVANIA, P.C. c/o Corporation Service Company 2595 Interstate Drive : Suite 103 Harrisburg, PA 17110 and/or 600 Six Flags Drive Suite 300 Arlington, TX 76011 : and EMCARE OF PENNSYLVANIA,INC. c/o Corporation Service Company 2595 Interstate Drive Suite 103 Harrisburg, PA 17110 I,, A ��s XP and/or A } a 62 South Syracuse Way Suite 200 Greenwood Village, CO 80111 and EMCARE PHYSICIAN PROVIDERS, INC. c/o Corporation Service Company 2595 Interstate Drive Suite 103 Harrisburg, PA 17110 and/or 62 South Syracuse Way Suite 200 ms 100 Greenwood Village, CO 80111 and EMCARE PHYSICIAN SERVICES, INC. c/o Corporation Service Company 2595 Interstate Drive Suite 103 Harrisburg, PA 17110 and/or P. 0 . Box 13477 Philadelphia, PA 19101 and EMCARE, INC. c/o Corporation Service Company 2595 Interstate Drive Suite 103 Harrisburg, PA 17110 and/or LOP6200 South Syracuse Way Greenwood Village, CO 80111 and CYNTHIA LYNN JACKSON,M.D. 629d Lowther Road Lewisberry, PA 17339 and QUANTUM IMAGING & THERAPEUTIC ASSOCIATES, INC. a/k/a and/or d/b/a QUANTUM IMAGING 629-D Lowther Road Lewisberry, PA 17339 and 2 HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHRISTIAN CHARITY a/k/a and/or d/b/a HOLY SPIRIT HOSPITAL 503 North 21" Street Camp Hill, PA 17011 and HOLY SPIRIT HEALTH SYSTEM 503 North 21St Street Camp Hill, PA 17011 and HOLY SPIRIT VENTURES, INC. 503 North 21St Street Camp Hill, PA 17011 and WEST SHORE ADVANCED LIFE SUPPORT SERVICE 503 North 21St Street Camp Hill, PA 17011 and COMFORT CARE OF HOLY SPIRIT, INC. 503 North 21St Street Camp Hill, PA 17011 and HOLY SPIRIT CORPORATION 503 North 21St Street : Camp Hill, PA 17011 : and SISTERS OF CHRISTIAN CHARITY HEALTH CARE CORPORATION 1100 Grampian Boulevard : Williamsport, PA 17701 Defendants. 3 Civil Action Medical Professional Liability Action NOTICE TO PLEAD NOTICE AVISO You have been sued in court. If you wish to defend against the Le han demandado a used en la cone. Si usted quiere defenderse de claims set forth in the following pages,you must take action estas demandas expuestas en las paginas siguientes,usted tiene veinte within twenty(20)days after this complaint and notice are served, (20)dias de plazo al partir de la fecha de la demanda y la notification. by entering a written appearance personally or by attorney and Hace falta asentar una comparencia escrita o en persona o con un filing in writing with the court your defenses or objections to the abogado y entregar a la cone en forma escrita sus defensas o sus claims set forth against you. You are warned that if you fail to do objeciones a las demandas en contra de su persona. Sea avisado que si so the case may proceed without you and a judgment may be usted no se defiende,la corte tomara medidas y puede continuar la entered against you by the court without further notice for any demanda en contra suya sin previo aviso o notification. Ademas,la money claimed in the complaint or for any other claim or relief corte pueda decidir a favor del demandante y requiere que usted cumpla requested by the plaintiffs. You may lose money or property or con todas las provisioner de esta demanda. Usted puede perder dinero other rights important to you. o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE, ONCE. 1F YOU DO NOT HAVE A LAWYER,GO TO OR SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO TELEPHONE THE OFFICE SET FORTH BELOW TO FIND SUFICIENTE DE PAGAR TAL SERVICIO,VAYA EN PERSONA 0 OUT WHERE YOU CAN GET LEGAL HELP. LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE Lawyer Referral Service PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 S.Bedford Street Lawyer Referral Service Carlisle,PA 17013 Cumberland County Bar Association 717-249-3166 32 S.Bedford Street Carlisle,PA 17013 717-249-3166 CIVIL ACTION COMPLAINT MEDICAL PROFESSIONAL LIABILITY ACTION Plaintiffs Craig Stone and Brenda Stone, husband and wife, bring this medical malpractice action against the defendants named herein and demand damages from all defendants,jointly and severally, in a sum in excess of the local arbitration limits, exclusive of pre judgment interest, post judgment interest and costs, upon the causes of actions set forth below. In support of their Complaint, plaintiffs aver as follows: SUMMARY OF THIS ACTION 1. This medical malpractice action involves the entirely preventable catastrophic and permanent injuries to Craig Stone, at just 54 years of age, as a direct and proximate result of the 4 defendants' deviations from the accepted standards of medical care on November 14, 2012 when Mr. Stone presented to the emergency department at Holy Spirit Hospital with progressively worsening back pain and extremity weakness and numbness after lifting heavy objects, including, inter alfa, the complete failure of the defendants to accurately, appropriately and timely appreciate, evaluate, diagnose and treat Craig Stone's life-altering and irreversible neurologic injuries secondary to nerve compression, order appropriate testing, including an MRI, and admit him to the hospital for treatment. As a result of the defendants' negligence, as more fully set forth herein, Mr. Stone's injuries include: permanent and irreversible neurologic conditions requiring bladder catheterizations multiple times per day, fecal incontinence, erectile dysfunction and impotence, decreased sensation of the perineum and per-rectal region, gait dysfunction, and partial paralysis and weakness of the lower extremities. PARTIES AND JURISDICTIONAL FACTS 2. Plaintiff Craig Stone is an adult individual and citizen of the Commonwealth of Pennsylvania residing at 1460 Lutztown Road, Boiling Springs, Pennsylvania 17007. Craig Stone was born on September 18, 1958 and was 54 years old at the time of these events. 3. Plaintiff Brenda Stone is an adult individual and citizen of the Commonwealth of Pennsylvania residing at 1460 Lutztown Road, Boiling Springs, Pennsylvania 17007. Plaintiff Brenda Stone is and was at the relevant time period the wife of plaintiff Craig Stone. 4. Defendant Laurence H. Paul, M.D. is an adult individual who at all relevant times was and is a duly licensed and practicing physician specializing in the field of emergency medicine, with professional medical and a business address at Holy Spirit Hospital, 503 North 21St Street, Camp Hill, PA 17011. At all relevant times, Laurence H. Paul, M.D. was engaged in the provision of health care services to the public, including Craig Stone. Plaintiffs are asserting 5 a professional liability claim against this defendant in connection with his acts and omissions as well as for the professional negligence of his agents, employees and servants, who participated in and/or were responsible for the care of Craig Stone during his visit to the emergency room at Holy Spirit Hospital on November 14, 2012. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will been filed separately with the Court, a copy of which is attached as Exhibit A. 5. Defendant EMCARE is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, with a principal place of business located at 503 North 21St Street, Camp Hill, Pennsylvania. At all relevant times, EMCARE was a professional practice association affiliated with Holy Spirit Hospital which owned, maintained, operated and/or controlled various medical practices and employed physicians, residents, fellows, interns, physician assistants, nurse practitioners, nurses, technicians and other ancillary staff to provide medical care, treatment and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents servants and employees, who participated in and/or were responsible for the care of Craig Stone during his visit to the emergency room at Holy Spirit Hospital on November 14, 2012. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit B. 6. Defendant EMCARE Medical Services of Pennsylvania, P.C. is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, with a principal place of business located at c/o Corporation Service Company, 2595 Interstate Drive, Suite 103, Harrisburg, PA 17110 and/or 600 Six Flags Drive, Suite 300, 6 Arlington, TX 76011. At all relevant times, EMCARE Medical Services of Pennsylvania, P.C. was a professional practice association affiliated with Holy Spirit Hospital which owned, maintained, operated and/or controlled various medical practices and employed physicians, residents, fellows, interns,physician assistants, nurse practitioners, nurses, technicians and other ancillary staff to provide medical care, treatment and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents servants and employees, who participated in and/or were responsible for the care of Craig Stone during his visit to the emergency room at Holy Spirit Hospital on November 14, 2012. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit C. 7. Defendant EMCARE of Pennsylvania, Inc. is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, with a principal place of business located at c/o Corporation Service Company, 2595 Interstate Drive, Suite 103, Harrisburg, PA 17110 and/or 62 South Syracuse Way, Suite 200, Greenwood Village, CO 80111. At all relevant times, EMCARE of Pennsylvania, Inc. was a professional practice association affiliated with Holy Spirit Hospital which owned, maintained, operated and/or controlled various medical practices and employed physicians, residents, fellows, interns, physician assistants, nurse practitioners, nurses, technicians and other ancillary staff to provide medical care, treatment and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents servants and employees, who participated in and/or were responsible for the care of Craig Stone during his visit to the emergency room at Holy Spirit Hospital on 7 November 14, 2012. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit D. 8. Defendant EMCARE Physician Providers, Inc. is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, with a principal place of business located at c/o Corporation Service Company, 2595 Interstate Drive, Suite 103, Harrisburg, PA 17110 and/or 62 South Syracuse Way, Suite 200, Greenwood Village, CO 80111. At all relevant times, EMCARE Physician Providers, Inc. was a professional practice association affiliated with Holy Spirit Hospital which owned, maintained, operated and/or controlled various medical practices and employed physicians, residents, fellows, interns, physician assistants, nurse practitioners, nurses, technicians and other ancillary staff to provide medical care, treatment and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents servants and employees, who participated in and/or were responsible for the care of Craig Stone during his visit to the emergency room at Holy Spirit Hospital on November 14, 2012. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit E. 9. Defendant EMCARE Physician Services, Inc. is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, with a principal place of business located at c/o Corporation Service Company, 2595 Interstate Drive, Suite 103, Harrisburg, PA 17110 and/or P.O. Box 13477, Philadelphia, PA 19101. At all relevant times, EMCARE Physician Services, Inc. was a professional practice association affiliated with Holy Spirit Hospital which owned, maintained, operated 8 and/or controlled various medical practices and employed physicians, residents, fellows, interns, physician assistants, nurse practitioners, nurses, technicians and other ancillary staff to provide medical care, treatment and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents servants and employees, who participated in and/or were responsible for the care of Craig Stone during his visit to the emergency room at Holy Spirit Hospital on November 14, 2012. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit F. 10. Defendant EMCARE Inc. is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, with a principal place of business located at c/o Corporation Service Company, 2595 Interstate Drive, Suite 103, Harrisburg, PA 17110 and/or LOP6200 South Syracuse Way, Greenwood Village, CO 80111. At all relevant times, EMCARE Inc. was a professional practice association affiliated with Holy Spirit Hospital which owned, maintained, operated and/or controlled various medical practices and employed physicians, residents, fellows, interns, physician assistants, nurse practitioners, nurses, technicians and other ancillary staff to provide medical care, treatment and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents servants and employees, who participated in and/or were responsible for the care of Craig Stone during his visit to the emergency room at Holy Spirit Hospital on November 14, 2012. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit G. 11. Defendants EMCARE, EMCARE Medical Services of Pennsylvania, P.C., 9 EMCARE of Pennsylvania, Inc., EMCARE Physician Providers, Inc., EMCARE Physician Services, Inc., and EMCARE Inc., shall be referred to hereafter collectively as the "EMCARE defendants." 12. Defendant Cynthia Lynn Jackson, M.D. is an adult individual who at all relevant times was and is a duly licensed and practicing physician specializing in the field of radiology, with professional medical and a business address at Quantum Imaging & Therapeutic Associates, Inc., 629-D Lowther Road, Lewisberry, PA 17339 and Holy Spirit Hospital, 503 North 21" Street, Camp Hill, PA 17011. At all relevant times, Cynthia Lynn Jackson, M.D. was engaged in the provision of health care services to the public, including Craig Stone. Plaintiffs are asserting a professional liability claim against this defendant in connection with her acts and omissions as well as for the professional negligence of her agents, employees and servants, who participated in and/or were responsible for the care of Craig Stone during his visit to the emergency room at Holy Spirit Hospital on November 14, 2012. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will been filed separately with the Court, a copy of which is attached as Exhibit H. 13. Defendant Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, with a principal place of business located at 503 North 21St Street, Camp Hill, Pennsylvania. At all relevant times, Quantum Imaging & Therapeutic Associates, Inc. a/k/a and/or d/b/a Quantum Imaging was a professional practice association affiliated with Holy Spirit Hospital which owned, maintained, operated and/or controlled various medical practices and employed physicians, residents, fellows, interns, physician assistants, nurse practitioners, nurses, technicians and other ancillary staff to provide 10 medical care, treatment and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents servants and employees, who participated in and/or were responsible for the care of Craig Stone during his visit to the emergency room at Holy Spirit Hospital on November 14, 2012. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit I. 14. Defendant Holy Spirit Hospital of the Sisters of Christian Charity a/k/a and/or d/b/a Holy Spirit Hospital is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, which at all relevant times owned, maintained, operated and/or controlled a hospital located at 503 North 21 st Street, Camp Hill, Pennsylvania. At all relevant times, Holy Spirit Hospital of the Sisters of Christian Charity a/k/a and/or d/b/a Holy Spirit Hospital was engaged in the provision of medical care and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents, servants and employees who participated in and/or were responsible for the care and treatment of Craig Stone on November 14, 2012, as more particularly described herein. The claims against this defendant also include a claim for corporate (direct)negligence under Thompson.v. Nason, 527 Pa. 330, 591 A.2d 703 (1991), and its progeny, including Welsh v. Bulger, 698 A.2d 581 (Pa. 1997) and Whittington v. Woods, 768 A.2d 1144 (Pa. Super. 2001). Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit J. 15. Defendant Holy Spirit Health System is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, 11 which at all relevant times owned, maintained, operated and/or controlled a hospital located at 503 North 21s' Street, Camp Hill, Pennsylvania. At all relevant times, Holy Spirit Health System was engaged in the provision of medical care and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents, servants and employees who participated in and/or were responsible for the care and treatment of Craig Stone on November 14, 2012, as more particularly described herein. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit K. 16. Defendant Holy Spirit Ventures, Inc. is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, which at all relevant times owned, maintained, operated and/or controlled a hospital located at 503 North 21St Street, Camp Hill, Pennsylvania. At all relevant times, Holy Spirit Ventures, Inc. was engaged in the provision of medical care and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents, servants and employees who participated in and/or were responsible for the care and treatment of Craig Stone on November 14, 2012, as more particularly described herein. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit L. 17. Defendant West Shore Advanced Life Support is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, which at all relevant times owned, maintained, operated and/or controlled a hospital located at 503 North 21St Street, Camp Hill, Pennsylvania. At all relevant times, West 12 Shore Advanced Life Support was engaged in the provision of medical care and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents, servants and employees who participated in and/or were responsible for the care and treatment of Craig Stone on November 14, 2012, as more particularly described herein. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit M. 18. Defendant Comfort Care of Holy Spirit, Inc. is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, which at all relevant times owned, maintained, operated and/or controlled a hospital located at 503 North 21St Street, Camp Hill, Pennsylvania. At all relevant times, Comfort Care of Holy Spirit was engaged in the provision of medical care and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents, servants and employees who participated in and/or were responsible for the care and treatment of Craig Stone on November 14, 2012, as more particularly described herein. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit N. 19. Defendant Holy Spirit Corporation is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, which at all relevant times owned, maintained, operated and/or controlled a hospital located at 503 North 21St Street, Camp Hill, Pennsylvania. At all relevant times, Holy Spirit Corporation was engaged in the provision of medical care and services to emergency room patients, including Craig Stone. 13 The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents, servants and employees who participated in and/or were responsible for the care and treatment of Craig Stone on November 14, 2012, as more particularly described herein. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit O. 20. Defendant Sisters of Christian Charity Health Care Corporation is a corporation or other legal entity organized and existing under and by virtue of the laws of the Commonwealth of Pennsylvania, which at all relevant times owned, maintained, operated and/or controlled a hospital located at 1100 Grampian Boulevard, Williamsport, PA 17701. At all relevant times, Sisters of Christian Charity Health Care Corporation was engaged in the provision of medical care and services to emergency room patients, including Craig Stone. The claims asserted against this defendant are for the professional negligence of its actual, apparent and/or ostensible agents, servants and employees who participated in and/or were responsible for the care and treatment of Craig Stone on November 14, 2012, as more particularly described herein. Pursuant to Pa. R. Civ. P. 1042.3, a Certificate of Merit as to this defendant will be filed separately with the Court, a copy of which is attached as Exhibit P. 21. Defendants Holy Spirit Hospital of the Sisters of Christian Charity a/k/a and/or d/b/a Holy Spirit Hospital, Holy Spirit Health System, Holy Spirit Ventures, Inc., West Shore Advanced Life Support Service, Comfort Care of Holy Spirit, Inc., Holy Spirit Corporation, and Sisters of Christian Charity Health Care Corporation shall be referred to hereafter collectively as the "Holy Spirit defendants." 22. At all relevant times, defendant Dr. Paul was engaged in the practice of medicine, pursuing his respective specialties and/or health care duties, and was obliged to use the 14 professional skill, knowledge and care which he possessed and to pursue his profession in accordance with reasonably safe and accepted standards of medicine in general and in his specialty in particular, as well as institutional standards of medical care, in his care and treatment of Craig Stone. 23. At all relevant times, defendant Dr. Jackson was engaged in the practice of medicine,pursuing her respective specialties and/or healthcare duties, and was obliged to use the professional skill, knowledge and care which she possessed and to pursue her profession in accordance with reasonably safe and accepted standards of medicine in general and in her specialty in particular, as well as institutional standards of medical care, in her care and treatment of Craig Stone. 24. At all relevant times, the EMCARE defendants, Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging and Holy Spirit defendants were engaged in the provision of medical services and were obliged to use the professional skill, knowledge and care which they possessed and to pursue their professions in accordance with reasonably safe and accepted standards of medicine in general and in their specialties in particular, as well as institutional standards of medical care, in their care and treatment of Craig Stone. 25. At all relevant times hereto, EMCARE defendants, Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging and Holy Spirit defendants and their affiliated health systems and/or physician practice groups, were acting by and through their actual, apparent or ostensible agents, servants and/or employees, who themselves were acting at all times within the course and scope of their actual and/or apparent agency and/or employment with defendants and under their exclusive control, and are liable for the negligent acts or omissions of their authorized servants, employees, and actual or ostensible agents under 15 theories of respondeat superior, master-servant, agency, and right of control. The identities of these agents, servants and employees are: the individually named defendants, Dr. Paul who attended to Craig Stone during his visitation at Holy Spirit Hospital on November 14, 2012, and Dr. Jackson who performed a CT of the lumbar spine and other physicians, physician assistants,, nurse practitioners, nurses, and other staff who were involved in and/or were responsible for the care and treatment of Craig Stone during his evaluation at Holy Spirit Hospital on November 14, 2012, including those individuals whose names appear in the medical chart, but are indecipherable to plaintiffs, are known only to defendants and not known or knowable to plaintiffs after reasonable investigation, and will require discovery from defendants. 26. At all relevant times, Dr. Paul was a shareholder, partner, actual, apparent and/or ostensible agent, servant and/or employee of Holy Spirit defendants and EMCARE defendants and was acting within the course and scope of his employment and/or agency with one or more of these defendants while providing medical care and treatment to Craig Stone. Accordingly, these defendants are vicariously liable for the negligent acts and omissions of Dr. Paul in his care and treatment of Craig Stone on November 14, 2012 under theories of respondeat superior, master-servant, agency, and right of control. 27. At all relevant times, Dr. Jackson was a shareholder, partner, actual, apparent and/or ostensible agent, servant and/or employee of Holy Spirit defendants and Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging and was acting within the course and scope of his employment and/or agency with one or more of these defendants while providing medical care and treatment to Craig Stone. Accordingly, these defendants are vicariously liable for the negligent acts and omissions of Dr. Jackson in her care and treatment of Craig Stone on November 14, 2012 under theories of respondeat superior, 16 master-servant, agency, and right of control. 28. At all relevant times hereto, defendant Holy Spirit Hospital of the Sisters of Christian Charity a/k/a and/or d/b/a Holy Spirit Hospital owed non-delegable legal duties directly to Craig Stone pursuant to the decision of the Supreme Court of Pennsylvania in Thompson v. Nason, 591 A.2d 703 (Pa. 1991), and its progeny of case law. These duties consisted of: (1) a duty to use reasonable care in the maintenance of safe and adequate facilities and equipment; (2) a duty to select and retain only competent physicians; (3) a duty to oversee all persons who practice medicine within its walls as to patient care; and, (4) a duty to formulate, adopt, and enforce adequate rules and policies to ensure quality care for the patients. 29. At all relevant times, Craig Stone was under the medical care, treatment and attendance of defendants, their actual, apparent and/or ostensible agents and employees who participated in and/or were responsible for Craig Stone's care at Holy Spirit Hospital on November 14, 2012, all of whom were acting within the course and.scope of their employment or agency with defendants, and under their right of control. 30. At all relevant times, defendants had actual or constructive knowledge of the medical and professional care and treatment provided to Craig Stone as recited herein. 31. At all relevant times, Craig Stone was under the medical and professional care, treatment and attendance of defendants, directly or indirectly, through their agents, servants, and/or employees, who participated in and/or were responsible for Craig Stone's care at Holy Spirit Hospital on November 14, 2012. 32. The amount in controversy exceeds the prevailing, local arbitration limits. 33. Venue for this action is properly laid in Cumberland County, Pennsylvania under the applicable rules and decisional law. See Pa. R. Civ. P. 1006. 17 OPERATIVE FACTS 34. At approximately 12:55 a.m. on November 14, 2012, Craig Stone presented with his wife, Brenda Stone, to the emergency department at defendant Holy Spirit Hospital in a wheelchair. 35. The reason for the visit was documented as lower back pain, weakness and numbness of both the lower extremities that started the previous morning after he had lifted substantial amounts of gravel and had progressively gotten worse. 36. According to the triage note, Mr. Stone had fallen that evening due to leg weakness. 37. According to the triage note, authored by Michelle R. Turpin, R.N., Mr. Stone was complaining of nausea and vomiting due to "severe pain,"which Mr. Stone rated a"10" on a 1 to 10 pain scale, and had labored breathing. 38. At approximately 1:35 a.m., Mr. Stone was noted to have numbness in his lower extremities. 39. At approximately 1:40 a.m., Mr. Stone was seen and evaluated by defendant Dr. Laurence Paul. 40. Dr. Paul noted that Mr. Stone injured his back lifting 3 tons of gravel. 41. Dr. Paul noted that there was no relevant history, including back surgery. 42. No examination of gait, ambulation, rectal tone or reflexes was documented. 43. No consultations with specialists were ordered or obtained. 44. At approximately 2:05 a.m., Mr. Stone was documented to be "medicated for 10/10 back pain." 45. CT scans were ordered.stat due to shortness of breath, nausea and vomiting, lower back pain, and weakness and numbness of both lower extremities. 18 46. A CT scan of the lumbar spine that was read and reported by defendant Cynthia L. Jackson, M.D. showed, among other things, neural foraminal narrowing and central canal narrowing at several levels, severe at L4-L5 with a diffuse disk bulge. 47. Dr. Paul noted that Mr. Stone did"need a Fu MRI." 48. Although the CT scan report recommended an MRI to better define abnormalities, and Dr. Paul noted the need for an MRI, Mr. Stone was discharged without performance of an MRI. 49. In violation of the standard of care, Dr. Jackson failed to recommend the need for an MRI with appropriate urgency. 50. In the alternative, in violation of the standard of care, Dr. Paul failed to properly understand and/or appreciate the urgency of Mr. Stone's need for an MRI. 51. In the alternative, in violation of the standard of care the Holy Spirit defendants failed to have policies, procedures or guidelines in place to provide for the timely performance of an MRI for Mr. Stone. 52. Dr. Paul diagnosed Mr. Stone with lower back pain and degenerative disc disease. 53. In violation of the standard of care, Mr. Stone was discharged to home with written discharge instructions that do not document the need for an MRI. 54. In violation of the standard of care, Dr. Paul failed to develop a necessary, proper, adequate, and/or sufficient differential diagnosis and failed to consider that Mr. Stone's ongoing and worsening symptoms of severe low back pain with weakness and numbness of the lower extremities were due to disease affecting the nervous system that, if left undiagnosed and untreated, could cause irreversible nerve damage with loss of bowel and bladder function, 19 erectile dysfunction, sensory disturbances,paralysis and weakness of the lower extremities, and/or gait dysfunction, among other injuries. 55. In violation of the standard of care, Dr. Paul failed to consider that Mr. Stone suffered from cauda equine syndrome, conus medularis syndrome, spinal cord compression, nerve root compression and/or nerve compression. 56. In violation of the standard of care, Dr. Jackson failed to communicate the necessity for emergent, urgent and/or prompt radiology imaging of the soft tissues of the spinal column to exclude disease that could cause irreversible and permanent injury. 57. The next day, November 15, 2012 at approximately 7:10 a.m., Mr. Stone again presented to the emergency department at Holy Spirit Hospital. 58. He was documented as having worsening back pain,problems urinating, difficulty walking, nausea and vomiting and numbness and weakness of both lower extremities. 59. On November 15, 2012, Mr. Stone's medical providers appreciated that he had cauda equina syndrome and spinal cord compression with a herniated disk and a disk fragment at the L4-5 level. 60. On November 15, 2012,the medical record reflects "ortho made aware of patient and serious dx. MRI ordered." 61. On November 15, 2012, Mr. Stone underwent a bilateral laminectomy involving L4-5,partial laminectomy for L3 and S 1 and bilateral foraminectomy of L4 through S 1 with removal of extruded disc fragments and repair of post-traumatic durotomy. 62. Mr. Stone has permanent and irreversible neurologic injuries causing him to suffer from areflexic neurologic bladder that requires frequent bladder catheterizations five to six times daily, neurogenic bowel with fecal hesitancy and incontinence, erectile dysfunction and 20 impotence, decreased sensation of the perineum and peri-rectal region, saddle anesthesia with paresthesia and numbness, decreased sensation of the lower extremities, partial paralysis and weakness of the lower extremities, gait dysfunction that requires foot and ankle orthotics and assisted ambulation with a cane as well as on-going physical therapy to improve strength, balance,proprioception and gait, chronic pain and neurogenic pain that requires on-going medication and evaluation by pain management specialists, and adjustment disorder with anxiety and depression that requires on-going counseling. 63. In addition to his permanent injuries, his early post-operative convalescence and rehabilitation was complicated by a deep vein thrombosis of the right lower extremity that required anti-coagulation medication. 64. Defendants undertook and/or assumed a duty to Craig Stone to provide him with timely and appropriate medical care, assessment, evaluation, management and treatment in connection with his condition and to avoid the risk of harm and additional injury to him. 65. At all relevant times, Craig Stone relied on the knowledge, care, skill, treatment and advice of the defendants in connection with the medical and professional care and treatment provided to him. 66. Defendants failed to provide Craig Stone with a proper assessment, evaluation, management and treatment as set forth herein. 67. The carelessness and negligence of defendants,jointly and severally, increased the risk of harm to Craig Stone and was a substantial factor in causing him to suffer catastrophic injuries. 68. The catastrophic injuries of Craig Stone were caiTsed by the negligence of defendants, their agents, servants and/or employees and were due in no manner whatsoever to any act or failure to act on the part of Craig Stone. 21 69. The medical care and treatment provided to Craig Stone by defendants and their, agents, servants and employees, including other physicians, nurses, residents, fellows, technicians and other medical and ancillary staff involved in and/or responsible for the care of Craig Stone during his visitation to Holy Spirit Hospital on November 14, 2012,jointly and severally, fell below accepted standards of medical care and caused Craig Stone to suffer catastrophic and severe injuries. 70. The negligent care and treatment rendered to Craig Stone by defendants and their agents, servants and employees, including other physicians, nurses, residents, fellows, technicians and other medical and ancillary staff involved in and/or responsible for the care of Craig Stone during his visitation to Holy Spirit Hospital on November 14, 2014 as set forth herein, allowed Craig Stone's condition to advance, worsen and develop and was a direct, proximate and substantial factor in causing his injuries. 71. The negligent care and treatment rendered to Craig Stone by defendants and their agents, servants and employees, including other physicians, nurses, residents, fellows, technicians and other medical and ancillary staff involved in and/or responsible for the care of Craig Stone, during his visitation to Holy Spirit Hospital on November 14, 2012 as set forth herein, allowed Craig Stone's-condition to advance, worsen and develop and directly and proximately increased the risk of harm and injuries to Craig Stone. 72. The negligence of all defendants as set forth herein,jointly and severally, directly and proximately caused Craig Stone to suffer grievous injuries. 73. The negligence of all defendants as set forth herein,jointly and severally, directly and proximately caused harm and injuries to Craig Stone and increased the risk of harm to Craig Stone including, but not limited to, the following: 22 a. permanent and irreversible neurologic injuries causing him to suffer from areflexic neurologic bladder that requires frequent bladder catheterizations five to six times daily; b. neurogenic bowel with fecal hesitancy and incontinence; c. erectile dysfunction and impotence; d. decreased sensation of the perineum and peri-rectal region; e. saddle anesthesia with paresthesia and numbness; f. decreased sensation of the lower extremities; g. partial paralysis and weakness of the lower extremities; h. gait dysfunction that requires foot and ankle orthotics and assisted ambulation with a cane as well as on-going physical therapy to improve strength, balance, proprioception and gait; i. chronic pain and neurogenic pain that requires on-going medication and evaluation by pain management specialists; j. adjustment disorder with anxiety and depression that requires on-going counseling; k. absent dorsiflexion of the right foot; and 1. significantly impaired dorsiflexion of the left foot. 74. As a further direct and proximate result of the negligence of the defendants as set forth herein, Craig Stone suffered excruciating and agonizing physical pain and suffering, emotional pain and suffering, discomfort, disfigurement, humiliation, embarrassment and distress. 75. As a further direct and proximate result of the negligence of the defendants as set forth herein, Craig Stone was caused to suffer economic injuries and losses. COUNT ONE-NEGLIGENCE Plaintiffs Craig Stone and Brenda Stone, h/w v. Defendant Laurence H. Paul,M.D. 76. The preceding paragraphs of this complaint are incorporated as though fully set forth herein. 77. The negligent acts and omissions of Laurence H. Paul, M.D, in the medical evaluation, treatment and management of Craig Stone, consisted of one or more of the following: 23 a. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely history and/or history of present illness; b. failure to perform appropriate, necessary,proper, adequate, sufficient and/or timely review of systems; c. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely physical examination; d. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely musculoskeletal examination; e. failure to perform appropriate, necessary,proper, adequate, sufficient and/or timely neurological examination; f. failure to perform appropriate, necessary,proper, adequate, sufficient and/or timely sensory examination; g. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely sensory examination of the perineum, 'rectum, genitals, and/or lower extremities; h. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely motor examination of the lower extremities; i. failure to perform appropriate, necessary,proper, adequate, sufficient and/or timely examination of gait and/or ambulation; j. failure to perform appropriate, necessary,proper, adequate, sufficient and/or timely examination of rectal tone; k. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely examination of reflexes; 1. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely of the reflexes of the lower extremities; in. failure to perform appropriate, necessary,proper, adequate, sufficient and/or timely examination of the anocutaneous reflex; n. failure to order and/or perform appropriate, necessary, proper, adequate, sufficient and/or timely diagnostic testing; o. failure to order and/or perform appropriate, necessary,proper, adequate, sufficient and/or timely radiology studies of the lower spine; p. failure to order and/or perform appropriate, necessary,proper, adequate, sufficient and/or timely magnetic resonance imaging (MRI) of the lower spine; q. failure to order, request and/or obtain appropriate, necessary, proper, adequate, sufficient and/or timely consultations with other specialists; r. failure to order, request and/or obtain appropriate, necessary, proper, adequate, sufficient and/or timely consultations with other specialists, including but not limited to internal medicine, hospitalist medicine, neurology, neurosurgery, and/or orthopedic surgery; 24 s. failure to recognize and/or appreciate the severity of the patient's symptoms; t. failure to recognize and/or appreciate the significance of the patient's history of present illness; u. failure to recognize and/or appreciate the significance of the patient's history of present illness, including but not limited to his returning to healthcare providers for evaluation and treatment of same or worsening chief complaint and condition; v. failure to recognize and/or appreciate the significance of the patient's clinical signs and findings upon physical examination; w. failure to recognize and/or appreciate the significance of the patient's clinical signs and findings upon physical examination, including but not limited to neurologic and/or musculoskeletal examination; x. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings; y. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings; z. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings of. the lumbosacral spine; aa. failure to formulate an appropriate, necessary, proper, adequate, sufficient and/or timely differential diagnosis of the patient's clinical condition; bb. failure to investigate, work-up and/or evaluate life-altering conditions within the differential diagnosis; cc. failure to consider appropriate, necessary, proper, adequate, sufficient and/or timely continued observation in the emergency department; dd. failure to consider appropriate, necessary,proper, adequate, sufficient and/or timely continued observation in the emergency department continued and on-going monitoring and evaluation for response to treatment and/or progression of signs, symptoms'and clinical findings despite treatment; ee. failure to consider appropriate, necessary, proper, adequate, sufficient and/or timely admission to the hospital for continued and on-going monitoring and evaluation; ff. failure to recognize and/or appreciate the necessity for response to treatment and/or progression of signs, symptoms and clinical findings despite treatment; gg. failure to recognize and/or appreciate signs, symptoms, clinical findings, and/or diagnostic test findings, including but not limited to radiology findings, suggestive of, consistent with, and/or concerning for cauda 25 equina syndrome, conus medularis syndrome, spinal cord compression, nerve root compression and/or nerve compression; hh. failure to exclude and/or rule-out potential life altering conditions from the differential diagnosis; ii. failure to exclude and/or rule-out potential life altering conditions from the differential diagnosis, including but not limited to cauda equina syndrome, conus medularis syndrome, spinal cord compression, nerve root compression and/or nerve compression; jj. failure to communicate with other healthcare providers; kk. failure to communicate with other healthcare providers radiological findings requiring additional urgent evaluation; 11. failure to communicate with other healthcare providers radiological findings requiring additional urgent evaluation of the spine, including but not limited to magnetic resonance imaging; mm. failure to communicate with other healthcare providers the necessity for prompt and urgent imaging of the spine; nn. failure to issue appropriate, proper and complete discharge instructions to the patient; and oo. failure to communicate the necessity for emergent, urgent and/or additional imaging. 78. The negligence of defendant Laurence H. Paul, M.D. increased the risk of harm to Craig Stone. 79. As a direct and proximate result of the negligent acts and omissions of defendant Laurence H. Paul, M.D, Craig Stone was deprived of necessary,timely and appropriate evaluation, treatment, and management of his condition. 80. As a direct and proximate result of the negligence of defendant Laurence H. Paul, M.D, Craig Stone suffered catastrophic injuries and damages. WHEREFORE, plaintiffs demand of defendants,jointly and severally, damages in an amount in excess of Fifty Thousand Dollars ($50,000.00), and in excess of the prevailing arbitration limits, exclusive of pre judgment interest, post judgment interests and costs. 26 COUNT TWO—NEGLIGENCE Plaintiffs Craig Stone and Brenda Stone, h/w v. Defendants EMCARE, EMCARE Medical Services of Pennsylvania, P.C., EMCARE of Pennsylvania, Inc., EMCARE Physician Providers, Inc., EMCARE Physician Services, Inc., EMCARE Inc. 81. The preceding paragraphs of this Complaint are incorporated as though fully set forth herein. 82. EMCARE Defendants are vicariously liable for the negligent acts and omissions of their actual, apparent and/or ostensible agents as set forth herein, including the acts and omissions of defendant Dr. Paul and any other of their actual, apparent and/or ostensible agents who provided or were responsible for providing medical care and nursing care, treatment or services to Craig Stone during his visitation to Holy Spirit Hospital on November 14, 2012 who are known to defendants but unknown to plaintiffs after reasonable investigation. 83. The negligent acts and omissions of EMCARE defendants, included one or more of the following: a. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely history and/or history of present illness; b. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely review of systems; c. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely physical examination; d. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely musculoskeletal examination; e. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely neurological examination; f. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely sensory examination; g. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely sensory examination of the perineum, rectum, genitals, and/or lower extremities; h. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely motor examination of the lower extremities; 27 i. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely examination of gait and/or ambulation; j. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely examination of rectal tone; k. failure to perform appropriate, necessary,proper, adequate, sufficient and/or timely examination of reflexes; 1. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely of the reflexes of the lower extremities; in. failure to perform appropriate,necessary, proper, adequate, sufficient and/or timely examination of the anocutaneous reflex; n. failure to order and/or perform appropriate, necessary, proper, adequate, sufficient and/or timely diagnostic testing; o. failure to order and/or perforin appropriate, necessary,proper, adequate, sufficient and/or timely radiology studies of the lower spine; p. failure to order and/or perform appropriate, necessary, proper, adequate, sufficient and/or timely magnetic resonance imaging (MRI) of the lower spine; q. failure to order, request and/or obtain appropriate, necessary, proper, adequate, sufficient and/or timely consultations with other specialists; r. failure to order, request and/or obtain appropriate, necessary,proper, adequate, sufficient and/or timely consultations with other specialists, including but not limited to internal medicine, hospitalist medicine, neurology, neurosurgery, and/or orthopedic surgery; s. failure to recognize and/or appreciate the severity of the patient's symptoms; t. failure to recognize and/or appreciate the significance of the patient's history of present illness; u. failure to recognize and/or appreciate the significance of the patient's history of present illness, including but not limited to his returning to healthcare providers for evaluation and treatment of same or worsening chief complaint and condition; v. failure to recognize and/or appreciate the significance of the patient's clinical signs and findings upon physical examination; w. failure to recognize and/or appreciate the significance of the patient's clinical signs and findings upon physical examination, including but not limited to neurologic and/or musculoskeletal examination; x. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings; y. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings; 28 z. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings of the lumbosacral spine; aa. failure to formulate an appropriate, necessary, proper, adequate, sufficient and/or timely differential diagnosis of the patient's clinical condition; bb. failure to investigate, work-up and/or evaluate life-altering conditions within the differential diagnosis; cc. failure to consider appropriate, necessary,proper, adequate, sufficient and/or timely continued observation in the emergency department; dd. failure to consider appropriate, necessary, proper, adequate, sufficient and/or timely continued observation in the emergency department continued and on-going monitoring and evaluation for response to treatment and/or progression of signs, symptoms and clinical findings despite treatment; ee. failure to consider appropriate, necessary,proper, adequate, sufficient and/or timely admission to the hospital for continued and on-going monitoring and evaluation; ff. failure to recognize and/or appreciate the necessity for response to treatment and/or progression of signs, symptoms and clinical findings despite treatment; gg. failure to recognize and/or appreciate signs, symptoms, clinical findings, and/or diagnostic test findings, including but not limited to radiology findings, suggestive of, consistent with, and/or concerning for cauda equina syndrome, conus medularis syndrome, spinal cord compression, nerve root compression and/or nerve compression; hh. failure to exclude and/or rule-out potential life altering conditions from the differential diagnosis; and ii. failure to exclude and/or rule-out potential life altering conditions from the differential diagnosis, including but not limited to cauda equina syndrome, conus medularis syndrome, spinal cord compression, nerve root compression and/or nerve compression; J. failure to communicate with other healthcare providers; kk. failure to communicate with other healthcare providers radiological findings requiring additional urgent evaluation; 11. failure to communicate with other healthcare providers radiological findings requiring additional urgent evaluation of the spine, including but not limited to magnetic resonance imaging; mm. failure to communicate with other healthcare providers the necessity for prompt and urgent imaging of the spine; 29 nn. failure to issue appropriate, proper and complete discharge instructions to the patient; and oo. failure to communicate the necessity for emergent, urgent and/or additional imaging. 84. At all relevant times, EMCARE defendants engaged defendant Dr. Paul as its agents, servants, and/or employees to provide medical care and treatment to Craig Stone while acting within the course and scope of his agency and/or employment with EMCARE defendants. Accordingly, EMCARE defendants are derivatively and vicariously liable for the negligent acts and omissions of Dr. Paul and other individuals who participated in and/or were responsible for the care of Craig Stone during his visitation at Holy Spirit Hospital on November 14, 2014 under principles of respondeat superior,master-servant, vicarious liability, agency and/or right of control. 85. As a result of the negligent acts and omissions of EMCARE defendants, Craig Stone was deprived of necessary, timely and appropriate evaluation, treatment, and management. 86. The negligence of EMCARE defendants, increased the risk of harm to Craig Stone. 87. As a direct and proximate result of the negligent acts and omission of EMCARE defendants, Craig Stone was deprived of necessary, timely and appropriate evaluation, diagnosis, treatment and management of his condition. 88. As a direct and proximate result of the negligence of EMCARE defendants, Craig Stone suffered catastrophic injuries and damages. WHEREFORE, plaintiffs demand of defendants,jointly and severally, damages in an amount in excess of Fifty Thousand Dollars ($50,000.00), and in excess of the prevailing arbitration limits, exclusive of pre judgment interest, post judgment interests and costs. 30 COUNT THREE- NEGLIGENCE Plaintiffs Craig Stone and Brenda Stone, h/w v. Defendant Cynthia Lynn Jackson, M.D. 89. The preceding paragraphs of this complaint are incorporated as though fully set forth herein. 90. The negligent acts and omissions of Cynthia Lynn Jackson, M.D, in the medical evaluation, treatment and management of Craig Stone, consisted of one or more of the following: a. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings; b. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings; c. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings of the lumbosacral spine; d. failure to formulate an appropriate, necessary, proper, adequate, sufficient and/or timely differential diagnosis of the patient's radiology findings; e. failure to exclude and/or rule-out potential life altering conditions from the differential diagnosis of the patient's radiological findings; f. failure to communicate with other healthcare providers; g. failure to communicate with other healthcare providers radiological findings requiring additional urgent evaluation; h. failure to communicate with other healthcare providers radiological findings requiring additional urgent evaluation of the spine, including but not limited to magnetic resonance imaging; i. failure to communicate with other healthcare providers the necessity for prompt and urgent imaging of the spine; j. failure to timely and properly recommend necessary follow up tests with appropriate urgency; and k. failure to communicate the necessity for emergent, urgent and/or additional imaging. 91. The negligence of defendant Cynthia Lynn Jackson, M.D. increased the risk of harm to Craig Stone. 92. As a direct and proximate result of the negligent acts and omissions of defendant 31 Cynthia Lynn Jackson, M.D, Craig Stone was deprived of necessary, timely and appropriate evaluation, treatment, and management of his condition. 93. As a direct and proximate result of the negligence of defendant Cynthia Lynn Jackson, M.D, Craig Stone suffered catastrophic injuries and damages. WHEREFORE, plaintiffs demand of defendants,jointly and severally, damages in an amount in excess of Fifty Thousand Dollars ($50,000.00), and in excess of the prevailing arbitration limits, exclusive of pre judgment interest, post judgment interests and costs. COUNT FOUR—NEGLIGENCE Plaintiffs Craig Stone and Brenda Stone, h/w v. Defendant Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging 94. The preceding paragraphs of this Complaint are incorporated as though fully set forth herein. 95. 'Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging is vicariously liable for the negligent acts and omissions of their actual, apparent and/or ostensible agents as set forth herein, including the acts and omissions of defendant Dr. Jackson and any other of their actual, apparent and/or ostensible agents who provided or were responsible for providing medical care and nursing care, treatment or services to Craig Stone during his visitation to Holy Spirit Hospital on November 14, 2012 who are known to defendants but unknown to plaintiffs after reasonable investigation. 96. The negligent acts and omissions of EMCARE defendants, included one or more of the following: a. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings; b. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings; 32 c. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings of the lumbosacral spine; d. failure to formulate an appropriate, necessary, proper, adequate, sufficient and/or timely differential diagnosis of the patient's radiology findings; e. failure to exclude and/or rule-out potential life altering conditions from the differential diagnosis of the patient's radiological findings; f. failure to communicate with other healthcare providers; g. failure to communicate with other healthcare providers radiological findings requiring additional urgent evaluation; h. failure to communicate with other healthcare providers radiological findings requiring additional urgent evaluation of the spine, including but not limited to magnetic resonance imaging; i. failure to communicate with other healthcare providers the necessity for prompt and urgent imaging of the spine; j. failure to timely and properly recommend necessary follow up tests with appropriate urgency; and k. failure to communicate the necessity for emergent, urgent and/or additional imaging. 97. At all relevant times, Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging engaged defendant Dr. Jackson as its agents, servants, and/or employees to provide medical care and treatment to Craig Stone while acting within the course and scope of his agency and/or employment with Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging. Accordingly, Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging are derivatively and vicariously liable for the negligent acts and omissions of Dr. Paul and other individuals who participated in and/or were responsible for the care of Craig Stone during his visitation at Holy Spirit Hospital on November 14, 2014 under principles of respondeat superior, master-servant, vicarious liability, agency and/or right of control. 98. As a result of the negligent acts and omissions of Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging, Craig Stone was deprived of 33 necessary, timely and appropriate evaluation, treatment, and management. 99. The negligence of Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging, increased the risk of harm to Craig Stone. 100. As a direct and proximate result of the negligent acts and omission of Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging, Craig Stone was deprived of necessary, timely and appropriate evaluation, diagnosis, treatment and management of his condition. 101. Asa direct and proximate result of the negligence of Quantum Imaging & Therapeutic Associates, Inc., a/k/a and/or d/b/a Quantum Imaging, Craig Stone suffered catastrophic injuries and damages. WHEREFORE, plaintiffs demand of defendants,jointly and severally, damages in an amount in excess of Fifty Thousand Dollars ($50,000.00), and in excess of the prevailing arbitration limits, exclusive of pre judgment interest, post judgment interests and costs. COUNT FIVE—NEGLIGENCE Plaintiffs Craig Stone and Brenda Stone, h/w v. Defendants Holy Spirit Hospital of the Sisters of Christian Charity a/k/a and d/b/a Holy Spirit Hospital, Holy Spirit Health System, Holy Spirit Ventures, Inc.,West Shore Advanced Life Support Service, Comfort Care of Holy Spirit, Inc., Holy Spirit Corporation, Sisters of Christian Charity Health Care Corporation 102. The preceding paragraphs of this Complaint are incorporated as though fully set forth herein. 103. Holy Spirit defendants are vicariously liable for the negligent acts and omissions of their actual, apparent and/or ostensible agents as set forth herein, including the acts and omissions of defendant Dr. Paul and Dr. Jackson and any other of their actual, apparent and/or ostensible agents who provided or were responsible for providing medical care and nursing care, 34 treatment or services to Craig Stone during his visitation to Holy Spirit Hospital on November 14, 2012 who are known to defendants but unknown to plaintiffs after reasonable investigation. 104. The negligent acts and omissions of Holy Spirit defendants, included one or more of the following: a. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely history and/or history of present illness; b. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely review of systems; . c. failure to perform appropriate, necessary,proper, adequate, sufficient and/or timely physical examination; d. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely musculoskeletal examination; e. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely neurological examination; f. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely sensory examination; g. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely sensory examination of the perineum, rectum, genitals, and/or lower extremities; h. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely motor examination of the lower extremities; i. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely examination of gait and/or ambulation; j. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely examination of rectal tone; k. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely examination of reflexes; 1. failure to perform appropriate, necessary, proper, adequate, sufficient and/or timely of the reflexes of the lower extremities; in. failure to perform appropriate, necessary,proper, adequate, sufficient and/or timely examination of the anocutaneous reflex; n. failure to order and/or perform appropriate, necessary, proper, adequate, sufficient and/or timely diagnostic testing; o. failure to order and/or perform appropriate, necessary, proper, adequate, sufficient and/or timely radiology studies of the lower spine; 35 p. failure to order and/or perform appropriate, necessary, proper, adequate, sufficient and/or timely magnetic resonance imaging (MRI) of the lower spine; q. failure to order, request and/or obtain appropriate, necessary, proper, adequate, sufficient and/or timely consultations with other specialists; r. failure to order, request and/or obtain appropriate, necessary,proper, adequate, sufficient and/or timely consultations with other specialists, including but not limited to internal medicine, hospitalist medicine, neurology, neurosurgery, and/or orthopedic surgery; s. failure to recognize and/or appreciate the severity of the patient's symptoms; t. failure to recognize and/or appreciate the significance of the patient's history of present illness; u. failure to recognize and/or appreciate the significance of the patient's history of present illness, including but not limited to his returning to healthcare providers for evaluation and treatment of same or worsening chief complaint and condition: v. failure to recognize and/or appreciate the significance of the patient's clinical signs and findings upon physical examination; w. failure to recognize and/or appreciate the significance of the patient's clinical signs and findings upon physical examination, including but not limited to neurologic and/or musculoskeletal examination; x. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings; y. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings; z. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings of the lumbosacral spine; aa. failure to formulate an appropriate, necessary,proper, adequate, sufficient and/or timely differential diagnosis of the patient's clinical condition; bb. failure to investigate, work-up and/or evaluate life-altering conditions within the differential diagnosis; cc. failure to consider appropriate, necessary,proper, adequate, sufficient and/or timely continued observation in the emergency department; dd. failure to consider appropriate, necessary, proper, adequate, sufficient and/or timely continued observation in the emergency department continued and on-going monitoring and evaluation for response to treatment and/or progression of signs, symptoms and clinical findings despite treatment; 36 ee. failure to consider appropriate, necessary,proper, adequate, sufficient and/or timely admission to the hospital for continued and on-going monitoring and evaluation; ff. failure to recognize and/or appreciate the necessity for response to treatment and/or progression of signs, symptoms and clinical findings despite treatment; gg. failure to recognize and/or appreciate signs, symptoms, clinical findings, and/or diagnostic test findings, including but not limited to radiology findings, suggestive of consistent with, and/or concerning for cauda equina syndrome, conus medularis syndrome, spinal cord compression, nerve root compression and/or nerve compression; hh. failure to exclude and/or rule-out potential life altering conditions from the differential diagnosis; and ii. failure to exclude and/or rule-out potential life altering conditions from the differential diagnosis, including but not limited to cauda equina syndrome, conus medularis syndrome, spinal cord compression,nerve root compression and/or nerve compression; J. failure to issue appropriate,proper and complete discharge instructions to the patient; kk. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings; 11. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings; mm. failure to recognize and/or appreciate the significance of the patient's diagnostic test findings, including but not limited to radiology findings of the lumbosacral spine; nn. failure to formulate an appropriate, necessary, proper, adequate, sufficient and/or timely differential diagnosis of the patient's radiology findings; oo. failure to exclude and/or rule-out potential life altering conditions from the differential diagnosis of the patient's radiological findings; pp. failure to communicate with other healthcare providers; qq. failure to communicate with other healthcare providers radiological findings requiring additional urgent evaluation; rr. failure to communicate with other healthcare providers radiological findings requiring additional urgent evaluation of the spine, including but not limited to magnetic resonance imaging; ss. failure to communicate with other healthcare providers the necessity for prompt and urgent imaging of the spine; and tt. failure to communicate the necessity for emergent, urgent and/or additional imaging. 37 105. At all relevant times.-Holy Spirit defendants engaged defendant Dr. Paul and Dr. Jackson as their agent, servant, and/or employee to provide medical care and treatment to Craig Stone while acting within the course and scope of his agency and/or employment with Holy Spirit defendants. Accordingly, Holy Spirit defendants are derivatively and vicariously liable for the negligent acts and omissions of Dr. Paul and Dr. Jackson and other individuals who participated in and/or were responsible for the care of Craig Stone during his evaluation to Holy Spirit Hospital on November 14, 2012 under principles of respondeat superior, master-servant, vicarious liability, agency and/or right of control. 106. As a result of the negligent acts and omissions of Holy Spirit defendants, Craig Stone was deprived of necessary, timely and appropriate evaluation,treatment, and management. 107. The negligence of Holy Spirit defendants, increased the risk of harm to Craig Stone. 108. As a direct and proximate result of the negligent acts and omission of Holy Spirit defendants, Craig Stone was deprived of necessary, timely and appropriate evaluation, diagnosis, treatment and management of his condition. 109. As a direct and proximate result of the negligence of Holy Spirit defendants, Craig Stone suffered catastrophic injuries and damages. WHEREFORE,plaintiffs demands of defendants,jointly and severally, damages in an amount in excess of Fifty Thousand Dollars ($50,000.00), and in excess of the prevailing arbitration limits, exclusive of pre judgment interest, post judgment interests and costs. COUNT FOUR- CORPORATE NEGLIGENCE Plaintiffs Craig Stone and Brenda Stone, h/w v. Defendant Holy Spirit Hospital of the Sisters of Christian Charity a/k/a and/or d/b/a Holy Spirit Hospital, 110. The preceding paragraphs of this Complaint are incorporated as though fully set 38 forth herein. 111. In addition to the derivative and vicarious liability of Holy Spirit Hospital for the negligent acts and omissions of its agents, servants and employees who participated in and/or were responsible for the care of Craig Stone during his visitation at Holy Spirit Hospital on November 14, 2012, defendant Holy Spirit Hospital owed direct and non-delegable duties to Craig Stone under the tenets set forth in Thompson v. Nason, 591 A.2d 709 (Pa. 1991) and its progeny of case law, including Welsh v. Bulger, 698 A.2d 581 (Pa. 1997) and Whittington v. Woods, 768 A.2d 1144 (Pa. Super. Ct. 2001). 112. The duties of defendant Holy Spirit Hospital, (1) a duty to use reasonable care in the maintenance of safe and adequate facilities and equipment; (2) a duty to select and retain only competent physicians; (3) a duty to oversee all persons who practice medicine within its walls as to patient care; and (4) a duty to formulate, adopt and enforce adequate rules and policies to ensure quality care for patients. 113. Defendant Holy Spirit Hospital had a duty to its patients, and to Craig Stone, in particular,to exercise reasonable care in the appointment and reappointment of physicians, physician assistants, interns, residents, fellows, nurse practitioners, nurses, therapists, aides and technicians. 114. Defendant Holy Spirit Hospital had a duty to supervise and monitor the medical care and treatment rendered to Craig Stone. 115. Defendant Holy Spirit Hospital had an obligation to formulate, adopt and enforce adequate policies and procedures to ensure safe and appropriate treatment to its patients such as Craig Stone. 116. It is believed and therefore averred that defendant Holy Spirit Hospital was 39 negligent in failing to properly determine the qualifications and proficiencies of those physicians, nurses and technicians involved in the care of Craig Stone on November 14, 2014. 117. It is believed and therefore averred that the physician, nursing, technical and ancillary staff who participated in or were responsible for the care of Craig Stone, as more particularly defined herein, did not possess the requisite training, experience, technical skills and judgment to render proper care and services to patients with his clinical history, presenting signs and symptoms and abnormalities demonstrated upon diagnostic testing. 118. It is believed and therefore averred that defendant Holy Spirit Hospital was negligent in failing to supervise and monitor the medical care and treatment rendered to Craig Stone when it knew or should have known that the physician, nursing,technical and ancillary staff who participated in or were responsible for the care of Craig Stone did not possess the requisite medical training, skill, knowledge and/or competency to properly care for Craig Stone. 119. Defendant Holy Spirit Hospital had a duty to its patients, and to Craig Stone in particular, to provide reasonable and competent medical care and services and to avoid conduct that would increase the risk of and/or in fact cause harm to its patients, including Craig Stone. 120. The corporate negligence of defendant Holy Spirit Hospital, arising out of the medical care and treatment provided and/or negligently not provided to Craig Stone on November 14, 2014, consisted of the following: a. failing to have physicians, interns, residents, fellows, technicians and nurses appropriate in number, training, and/or experience to make appropriate and timely decisions with respect to the evaluation, diagnosis, treatment and management of patients who present to the hospital with a clinical history, physical signs and symptoms such as those demonstrated by Craig Stone as more particularly described herein; b. failing to have physicians, interns, residents and fellows, technicians and nurses appropriate in number, training, and/or experience to make appropriate and timely decisions regarding the evaluation, diagnosis, 40 treatment and management of patients with findings such as those demonstrated by Craig Stone including, but not limited to, severe back pain that was ongoing, increasing in severity, progressive in nature, refractory to . medical treatment, and that progressed to include weakness and numbness of both the lower extremities and which was found to be associated with abnormal findings of the lumbosacral spine on contrast enhanced CT scan imaging; C. failing to ensure that Craig Stone received appropriate attention from fully trained and experienced physicians, interns, residents, fellows, nursing staff and technicians able to make appropriate and timely decisions regarding the evaluation, diagnosis, treatment and management of patients with findings such as those demonstrated by Craig Stone including, but not limited to, severe back pain that was ongoing, increasing in severity, progressive in nature, refractory to medical treatment, and that progressed to include weakness and numbness of both the lower extremities and which was found to be associated with abnormal findings of the lumbosacral spine on contrast enhanced CT scan imaging; (d. failing to select and retain physicians, nurses, physician assistants, nurse practitioners, technicians and other medical staff competent in the evaluation, diagnosis, treatment and management of patients with findings such as those demonstrated by Craig Stone including, but not limited to, severe back pain that was ongoing, increasing in severity, progressive in nature, refractory to medical treatment, and that progressed to include weakness and numbness of both the lower extremities and which was found to be associated with abnormal findings of the lumbosacral spine on contrast enhanced CT scan imaging; e. failing to formulate, adopt and enforce adequate policies and procedures to ensure quality patient care, including written policies and procedures regarding: (1) appropriate, proper, reasonable, necessary, sufficient and/or timely evaluation,treatment and management of the patient; (2) appropriate, proper, reasonable, necessary, sufficient and/or timely evaluation,treatment and management of the patient with findings of severe back pain, worsening back pain, back pain refractory to medical treatment, and/or back pain that progresses to include weakness and/or numbness of the lower extremities with abnormal findings of the lumbosacral spine on contrast enhanced CT scan imaging; (3) appropriate, proper, reasonable, necessary, sufficient and/or timely diagnostic studies; (4) appropriate, proper, reasonable, necessary, sufficient and/or timely diagnostic studies of the patient with findings of severe back pain, 41 worsening back pain, back pain refractory to medical treatment, and/or back pain that progresses to include weakness and/or numbness of the lower extremities with abnormal findings of the lumbosacral spine on contrast enhanced CT scan imaging, including but not limited to magnetic resonance imaging(MRI) of the lumbosacral spine; (5) appropriate, proper, reasonable, necessary, sufficient and/or timely consultations; (6) appropriate, proper, reasonable, necessary, sufficient and/or timely consultations to evaluate the patient with findings of severe back pain, worsening back pain, back pain refractory to medical treatment, and/or back pain that progresses to include weakness and/or numbness of the lower extremities with abnormal findings of the lumbosacral spine on contrast enhanced CT scan imaging; (7) appropriate, proper, reasonable, necessary, sufficient and/or timely consultations, including but not limited to internal medicine, hospitalist medicine,neurology, neurosurgery, and/or orthopedic surgery; (8) appropriate, proper, reasonable, necessary, sufficient and/or timely consultations, including but not limited to internal medicine, hospitalist medicine,neurology, neurosurgery, and/or orthopedic surgery, to evaluate the patient with findings of severe back pain, worsening back pain,back pain refractory to medical treatment, and/or back pain that progresses to include weakness and/or numbness of the lower extremities with abnormal findings of the lumbosacral spine on contrast enhanced CT scan imaging; (9) indications for appropriate, proper, reasonable and/or timely admission to the observation unit and/or hospital; (10) indications for appropriate, proper, reasonable and/or timely admission to the observation unit and/or hospital for the patient with findings of severe back pain, worsening back pain, back pain refractory to medical treatment, and/or back pain that progresses to include weakness and/or numbness of the lower extremities with abnormal findings of the lumbosacral spine on contrast enhanced CT scan imaging; (11) appropriate, necessary,proper, adequate, sufficient and/or timely communications between healthcare providers; (12) appropriate, necessary, proper, adequate, sufficient and/or timely communications between healthcare providers concerning signs, symptoms, test results, diagnostic imaging results and/or other clinical findings pertaining to patient care; (13) appropriate, necessary, proper, adequate, sufficient and/or timely communications between healthcare providers concerning the need for additional urgent testing and evaluation of the patient's clinical condition; 42 (14) appropriate, necessary,proper, adequate, sufficient and/or timely communications between healthcare providers concerning the need for additional urgent testing and evaluation of the patient's clinical condition, including the need for additional urgent spine imaging; (15) reporting recommendations for additional appropriate, necessary, proper, adequate, sufficient and/or timely testing and evaluation of the patient's clinical condition; and (16) reporting recommendations for additional appropriate, necessary, proper, adequate, sufficient and/or timely testing and evaluation of spine imaging. 121. In violation of the accepted standard of care, defendant Holy Spirit Hospital did not have adequate policies or procedures implemented in November 2012, as described above, and/or if such policies were in place, Holy Spirit defendants and failed to ensure that their medical, resident, fellow, nursing and technician staff were aware of, familiar with and followed such policies. 122. Defendant Holy Spirit Hospital knew or should have known that it did not have adequate written policies and procedures in place, as described above. 123. Defendant Holy Spirit Hospital knew or should have known that its medical, resident, fellow, nursing and technician staff were not familiar with and/or failed to follow the hospital's written policies and procedures with respect to the matters described above, to the extent that they existed. 124.- Defendant Holy Spirit Hospital knew or should have known that its medical, resident, fellow, nursing and technician staff did not possess the adequate training, skill or knowledge in the evaluation and management of patients presenting with signs, symptoms, and clinical findings of severe back pain that was ongoing, increasing in severity, progressive in nature, refractory to medical treatment, and that progressed to include weakness and numbness of both the lower extremities and which was found to be associated with abnormal findings of the lumbosacral spine on contrast enhanced CT scan imaging. 43 125. Defendant Holy Spirit Hospital knew or should have known that it failed to provide its medical, resident, fellow, nursing and technician staff with the proper training, skill or knowledge to care for patients with findings of severe back pain that was ongoing, increasing in severity, progressive in nature, refractory to medical treatment, and that progressed to include weakness and numbness of both the lower extremities and which was found to be associated with abnormal findings of the lumbosacral spine on contrast enhanced CT scan imaging. 126. As a direct and proximate result of the corporate negligence of Defendant Holy Spirit Hospitals, as described herein, Craig Stone was deprived of necessary, timely and appropriate evaluation, diagnosis, treatment and management of his condition. 127. As a direct and proximate result of the corporate negligence of Defendant Holy Spirit Hospitals, as described herein, Craig Stone suffered catastrophic injuries and damages as described herein. WHEREFORE, plaintiffs demand of defendants,jointly and severally, damages in an amount in excess of Fifty Thousand Dollars ($50,000.00), and in excess of the prevailing arbitration limits, exclusive of pre judgment interest, post judgment interests and costs. COUNT FIVE - LOSS OF CONSORTIUM (Plaintiffs v. All Defendants) 128. The previous paragraphs are incorporated herein as if set forth in full. 129. At all times relevant hereto, plaintiff Brenda Stone was the lawful wife of plaintiff, Craig Stone. 130. As a direct and proximate result of defendants' liability producing conduct, causing injury to Craig Stone, Brenda Stone has been obliged to spend various and diverse sums of money for medical treatment in an attempt to cure and rehabilitate her husband from the ills and injuries he has suffered to her great detriment and loss. 44 131. Asa further direct and proximate result of the defendants' liability, causing injury to Craig Stone, plaintiff Brenda Stone has been caused to suffer the loss of services, society and companionship of her husband, which will continue in the future. WHEREFORE, plaintiffs demand damages against defendants,jointly and severally, in an amount in excess of Fifty Thousand ($50,000.00) Dollars, and in excess of prevailing arbitration limits, exclusive of pre judgment interest,post judgment interest, and costs. jROSSFELASEY, LLP Dated: November 11, 2014 By: ESQUIRE SHANON S. LEVIN, ESQUIRE 1650 Market Street, Suite 3450 Philadelphia, PA 19103 Attorneys for Plaintiffs 45 VERIFICATION Plaintiffs, Craig and Brenda Stone, hereby verify that the within Civil Action Complaint is based on first-hand information and on information furnished to her counsel and obtained by counsel in the course of this lawsuit. The language of the document is that of counsel and not of the affiant. To the extent that the contents of the document are based on information furnished to counsel and obtained by counsel during the course of this lawsuit, the affiant has relied upon counsel in taking this verification. All statements are founded upon reasonable belief. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. G Craig Stone Brenda Stone EXHIBIT A ROSS FELLER CASEY,LLP By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL, M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: LAURENCE H. PAUL, M.D. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, 1 hereby certify that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant, his agents, servants, and/or employees in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a substantial contributing factor in bringing about harm to plaintiff, Craig Stone. Dated: November 11, 2014 XANONS. , ESQUIRE EXHIBIT B ROSS FELLER CASEY,LLP By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL, M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: EMCARE I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 ZSZHANON S. LEVIN, ESQUIRE EXHIBIT C ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL, M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: EMCARE MEDICAL SERVICES OF PENNSYLVANIA, P.C. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare Medical Services of Pennsylvania, P.C., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE EXHIBIT D ROSS FELLER CASEY, LLP By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL, M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: EMCARE OF PENNSYLVANIA INC. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare of Pennsylvania, Inc., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE EXHIBIT E ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL, M.D., et.al. JURY TRIAL DEMANDED Defendants. : CERTIFICATE OF MERIT PERTAINING TO: EMCARE PHYSICIANS PROVIDERS. INC. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare Physician Providers, Inc., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 Z�WANTnXTV. N, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, : NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL,M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: EMCARE PHYSICIAN SERVICES. INC. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare Physician Services, Inc., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 HANON S. LEVIN, ESQUIRE EXHIBIT G ROSS FELLER CASEY, LLP By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN,ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL,M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: EMCARE INC. 1, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare Inc., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE I 1 t R EXHIBIT H ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia,PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL, M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: CYNTHIA LYNN JACKSON, M.D. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant, his agents, servants, and/or employees in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a substantial contributing factor in bringing about harm to plaintiff, Craig Stone. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE EXHIBIT I ROSS FELLER CASEY, LLP By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL, M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF,MERIT PERTAINING_TO: OUANTUM IMAGING& THERAPEUTIC ASSOCIATES,INC. A/K/A OR D/B/ A/QUANTUM IMAGING I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, 1 hereby certify that the claims Quantum Imaging & Therapeutic Associates, Inc. a/k/a or d/b/a Quantum Imaging., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 HANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia,PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL,M.D., et.al. JURY TRIAL DEMANDED Defendants. : CERTIFICATE OF MERIT PERTAINING TO: HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHRISTIAN CHARITY A/K/A AND/OR D/B/A HOLY SPIRIT HOSPITAL I, Shanon S. Levin,Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, 1 hereby certify that the claims against Holy Spirit Hospital of the Sisters of Christian Charity a/k/a and/or d/b/a Holy Spirit Hospital,which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 ANON S. LEVIN, ESQUIRE i �I I I i I i I EXHIBIT K ROSS FELLER CASEY,LLP By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs; NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL, M.D.,,et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: HOLY SPIRIT HEALTH SYSTEM I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. l 042.3,I;hereby certify that the claims against Holy Spirit Health System, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint,fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 ffTANON S. LEVIN, ESQUIRE i I EXHIBIT L ROSS FELLER CASEY,LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN,ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia,PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE,h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL, M.D.,et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: HOLY SPIRIT VENTURES, INC. I, Shanon S.Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Holy Spirit Ventures, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint,fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 HANON S. LEVIN, ESQUIRE it it EXHIBIT M ROSS FELLER CASEY,LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN,ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia,PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL,M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: WEST SHORE ADVANCED LIFE SUPPORT I, Shanon S. Levin,Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against West Shore Advanced Life Support,which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone'. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE i 1 I, �I I� EXHIBIT ROSS FELLER CASEY,LLP'. By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia,PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs,, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL,M.D.,iet.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: COMFORT CARE OF HOLY SPIRIT,INC. I, Shanon S. Levin,Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa.R. Civ.P. 1042.3, 1 hereby certify that the claims against Comfort Care of Holy Spirit, Inc.,which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard,and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment,practice or work that is the subject of the Complaint,fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. i Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE Ili I ' I I I II �I I Ili I i I I I I EXHIBIT 0 ROSS FELLER CASEY LLP, By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL, M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: HOLY SPIRIT CORPORATION I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, T hereby certify that the claims against Holy Spirit Corporation, i which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the I undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint,fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 ZSHANONS. , ESQUIRE I EXHIBIT P ROSS FELLER CASEY, LLP By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia,PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: LAURENCE H. PAUL,M.D., et.al. JURY TRIAL DEMANDED Defendants. CERTIFICATE OF MERIT PERTAINING TO: SISTER OF CHRISTIAN CHARITY HEALTH CARE CORPORATION 1, Shanon S.Levin,Esquire, am an attorney for the plaintiffs in the above-captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Sister of Christian Charity Health Care Corporation, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard,and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 HANON S. LEVIN, ESQUIRE 2366827.doc DICKIE, MCCAMEY & CHILCOTE, P.C. BY: Thomas M. Chairs, Esquire ATTORNEY I.D. NO. 78565 BY: Aaron S. Jayman, Esquire ATTORNEY I.D. NO. 85651 Plaza 21, Suite 302 425 North 21st Street Camp Hill, PA 17011 717-731-4800 (Tele) 888-811-7144 (Fax) ATTORNEY FOR: DEFENDANT HOLY SPIRIT HOSPITAL; HOLY SPIRIT HEALTH SYSTEM; HOLY SPIRIT VENTURES, INC.; WEST SHORE ADVANCED LIFE SUPPORT SERVICES; COMFORT CARE OF HOLY SPIRIT, INC.; HOLY SPIRIT CORPORATION; SISTERS OF CHRISTIAN CHARITY HEALTH CARE CORPORATION CRAIG STONE and BRENDA STONE, h/w, PlaintiffS, v. LAURENCE H. PAUL, M.D.; JOHN R DIETZ EMERGENCY CENTER; EMCARE; EMCARE MEDICAL SERVICES OF PENNSYLVANIA PC; EMCARE OF PENNSYLVANIA INC; EMCARE PHYSICIAN PROVIDERS INC.; EMCARE PHYSICIAN SERVICES INC.; EMCARE INC; CYNTHIA LYNN JACKSON, MD; QUANTUM IMAGING & THERAPEUTIC ASSOCIATES INC., a/k/a and/or d/b/a QUANTUM IMAGING; HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHRISTIAN CHARITY A/K/A AND/OR D/B/A HOLY SPIRIT HOSPITAL; HOLY SPIRIT HEALTH SYSTEM; HOLY SPIRIT VENTURES INC; WEST SHORE ADVANCED LIFE SUPPORT SERVICE; COMFORT CARE OF HOLY SPIRIT INC; HOLY SPIRIT CORPORATION; SISTERS OF CHRISTIAN CHARITY HEALTH CARE CORPORATION, Defendants. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 14-6592 MEDICAL MALPRACTICE ACTION JURY TRIAL DEMANDED CD c N ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned as counsel for Defendants, Holy Spirit Hospital, Holy Spirit Health System, Holy Spirit Ventures, Inc., West Shore Advanced Life Support Services, Comfort Care of Holy Spirit, Inc., Holy Spirit Corporation, and Sisters of Christian Charity Health Care Corporation, in the above -captioned matter. Respectfully submitted, DICKIE, MCCAMEY & CHILTE, P.C. Date: December 8. 2014 By: Thomas M. C 'irs, Esquire Attorney I.D. No. 78565 Aaron S. layman, Esquire Attorney I.D. No. 85651 Plaza 21, Suite 302 425 North 21st Street Camp Hill, PA 17011-2223 717-731-4800 Attorney for Defendants, Holy Spirit Hospital, Holy Spirit Health System, Holy Spirit Ventures, Inc., West Shore Advanced Life Support Services, Comfort Care of Holy Spirit, Inc., Holy Spirit Corporation, and Sisters of Christian Charity Health Care Corporation CERTIFICATE OF SERVICE AND NOW, December 8, 2014, I, Thomas M. Chairs, Esquire, hereby certify that I did serve a true and correct copy of the foregoing ENTRY OF APPEARANCE upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: By First -Class Mail: Robert Ross, Esquire Shanon S. Levin, Esquire Ross Feller Casey, LLP 1650 Market St., Suite 3450 Philadelphia, PA 19103 Thom hairs, Esquire ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE I.D. NOS: 47152/86040 One Liberty Place, Suite 3450 1650 Market Street Philadelphia, Pennsylvania 19103 (215) 574-2000 Attorneys for Plaintiffs CRAIG STONE and BRENDA STONE, h/w Plaintiff, v. LAURENCE H. PAUL, M.D., et al. Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-6592 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned action. ROSS FELLER CASEY, LLP By: Dated: December 9, 2014 ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorneys for Plaintiff ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 1,1 F`iL CiF I HE E O I1C,i �. 23 I ti BEC 18 Fri : 25 CUMBERLAND COUNTY PEN?6YLVANIY. Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, v. LAURENCE H. PAUL, M.D., et.al. Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 No: 14-6592 JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: COMFORT CARE OF HOLY SPIRIT, INC. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Comfort Care of Holy Spirit, Inc., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 HANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 )LL �C 0Q- -44-€_Pnen,a doly bee_ ie ?m 3.S" aterti, Co :PA - Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, v. LAURENCE H. PAUL, M.D., et.al. Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 No: 14-6592 JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: WEST SHORE ADVANCED LIFE SUPPORT I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against West Shore Advanced Life Support, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 ANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 sorWILE_. CJS- aa1y ii. is Pin 3:.1s• Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, v. LAURENCE H. PAUL, M.D., et.al. Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 No: 14-6592 JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: SISTER OF CHRISTIAN CHARITY HEALTH CARE CORPORATION I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Sister of Christian Charity Health Care Corporation, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 HANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 )71_qa_4!)-e-QL. o-� -EL,s_ Piustl,eAJa-LAy aow J� re kr, � •as Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, v. LAURENCE H. PAUL, M.D., et.al. Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 No: 14-6592 JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: QUANTUM IMAGING & THERAPEUTIC ASSOCIATES, INC. A/K/A OR D/B/A/ QUANTUM IMAGING I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims Quantum Imaging & Therapeutic Associates, Inc. a/k/a or d/b/a Quantum Imaging., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 aoJL( c_ ie ?ir) a: aS eu,t,t. P19- Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 v. No: 14-6592 LAURENCE H. PAUL, M.D., et.al. Defendants. JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: HOLY SPIRIT VENTURES, INC. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Holy Spirit Ventures, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 aot q -b /8 Pin c?. C. . 66. 1'/ Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, v. LAURENCE H. PAUL, M.D., et.al. Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 No: 14-6592 JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHRISTIAN CHARITY A/K/A AND/OR D/B/A HOLY SPIRIT HOSPITAL I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Holy Spirit Hospital of the Sisters of Christian Charity a/k/a and/or d/b/a Holy Spirit Hospital, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about ha o plaintiff Craig Stone. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 v. No: 14-6592 LAURENCE H. PAUL, M.D., et.al. Defendants. JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: HOLY SPIRIT HEALTH SYSTEM I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Holy Spirit Health System, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 11# H SON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 aoILi -bet_ l0 kip? :as 4, . a• Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 v. No: 14-6592 LAURENCE H. PAUL, M.D., et.al. Defendants. JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: HOLY SPIRIT CORPORATION I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Holy Spirit Corporation, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 HANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 a©IL 18 ism 4.,; eu,n 6. eo PA .71 Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, v. LAURENCE H. PAUL, M.D., et.al. Defendants. NOVEMBER TERM 2014 No: 14-6592 JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: EMCARE I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare, which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 Tt �4 C ►Gc_., o 4L,,c__ L lq ie Pm a &c.13(,. e. Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, v. LAURENCE H. PAUL, M.D., et.al. Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 No: 14-6592 JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: EMCARE PHYSICIAN SERVICES, INC. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare Physician Services, Inc., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 -.c_?, as/Lt ie Pm :As ett-r1, . eo . 7 4 { Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, v. LAURENCE H. PAUL, M.D., et.al. Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 No: 14-6592 JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: EMCARE PHYSICIANS PROVIDERS, INC. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare Physician Providers, Inc., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 HANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 XlcLoCeiec_ ?in �: s" aQl�{ !g � �£L � Q,b. Pi Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 v. No: 14-6592 LAURENCE H. PAUL, M.D., et.al. Defendants. JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: EMCARE OF PENNSYLVANIA, INC. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare of Pennsylvania, Inc., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 NON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 ) Li lac aalc.{ ler__ iB PM 3:2S Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, v. LAURENCE H. PAUL, M.D., et.al. Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 No: 14-6592 JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: EMCARE MEDICAL SERVICES OF PENNSYLVANIA, P.C. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare Medical Services of Pennsylvania, P.C., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 ANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 a t q (s »-7 3:2S 0...dA.'% .& 714 `-r Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS Plaintiffs, v. LAURENCE H. PAUL, M.D., et.al. Defendants. CUMBERLAND COUNTY NOVEMBER TERM 2014 No: 14-6592 JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: CYNTHIA LYNN JACKSON, M.D. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant, his agents, servants, and/or employees in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a substantial contributing factor in bringing about harm to plaintiff, Craig Stone. Dated: November 11, 2014 ANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 ALL; 041 .4 oc ly �( £c__ l8 PM 2:as Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 v. No: 14-6592 LAURENCE H. PAUL, M.D., et.al. Defendants. JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: LAURENCE H. PAUL, M.D. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant, his agents, servants, and/or employees in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a substantial contributing factor in bringing about harm to plaintiff, Craig Stone. Dated: November 11, 2014 ANON S. LEVIN, ESQUIRE ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia, PA 19103 (215) 574-2000 ✓ ` (.LL- c e am► wort .€0.__ is P17? 2.'.25 c • C•?At Attorneys for Plaintiff CRAIG STONE AND BRENDA STONE, h/w Plaintiffs, COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2014 v. No: 14-6592 LAURENCE H. PAUL, M.D., et.al. Defendants. JURY TRIAL DEMANDED CERTIFICATE OF MERIT PERTAINING TO: EMCARE INC. I, Shanon S. Levin, Esquire, am an attorney for the plaintiffs in the above -captioned matter. Pursuant to Pa. R. Civ. P. 1042.3, I hereby certify that the claims against Emcare Inc., which allege that this entity deviated from an acceptable professional standard, are based upon allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard, and that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about harm to plaintiff Craig Stone. Dated: November 11, 2014 SHANON S. LEVIN, ESQUIRE FOULKROD ELLIS Professional Corporation 4000 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 909-7006 Fax: (717) 909-6955 Attorney for Defendants: Cynthia L. Jackson, M.D. and Quantum Imaging & Therapeutic Associates, Inc. CRAIG STONE AND BRENDA STONE, husband and wife, Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA r: is r- - --, .x-- ..r NO. 14-6592.:::u' r, `n LAURENCE H. PAUL, M.D., EMCARE, =- r `r. =: EMCARE MEDICAL SERVICES OF CIVIL ACTION `r). 1/410 PENNSYLVANIA, P.C., EMCARE OF MEDICAL PROFESSIONAL LIAB1LIT PENNSYLVANIA, INC., EMCARE ACTION-- '. PHYSICIAN PROVIDERS, INC., EMCARE t- t PHYSICIAN SERVICES, INC., EMCARE, ,:4 c' INC., CYNTHIA LYNN JACKSON, M.D., JURY TRIAL DEMANDED QUANTUM IMAGING & THERAPETJTIC ASSOCIATES, INC., HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHRISTIAN CHARITY, HOLY SPIRIT HEALTH SYSTEM, HOLY SPIRIT VENTURES, INC., WEST SHORE ADVANCED LIFE SUPPORT SERVICE, COMFORT CARE OF HOLY SPIRIT, INC., HOLY SPIRIT CORPORATION, SISTERS OF CHRISTIAN CHARITY HEALTH CARE CORPORATION, Defendants PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of Defendants, Cynthia Lynn Jackson, M.D. and Quantum Imaging & Therapeutic Associates, Inc., in the above -captioned action. Respectfully submitted, FOULKROD ELLIS PROFESSIONAL CORPORATION 1. r Date: 0 By: Leigh A.J. llis, Esquire Attorney .D. No. 53229 leigh@fo lkrod.com Cindy N. Ellis, Esquire Foulkrod Ellis, P.C. Attorney I.D. No. 83823 cindy@foulkrod.com r CERTIFICATE OF SERVICE I HEREBY CERTIFY that true and correct copies of the foregoing were served upon all counsel of record this 17th day of December, 2014, by depositing said copy in the United States Mail at Camp Hill, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Robert Ross, Esquire Shanon S. Levin, Esquire Ross Feller Casey, LLP One Liberty Place 1650 Market Street, Suite 3450 Philadelphia, PA 19103 (Counsel to Plaintiffs) PERSONAL AND CONFIDENTIAL Laurence H. Paul, M.D. John R. Dietz Emergency Center Holy Spirit Hospital 503 North 21st Street Camp Hill, PA 17011 PERSONAL AND CONFIDENTIAL EMCARE, Attn: Risk Management 503 North 21st Street Camp Hill, PA 17011 PERSONAL AND CONFIDENTIAL Attn: Risk Management EMCARE Medical Services of Pennsylvania, P.C., EMCARE of Pennsylvania, Inc., EMCARE Physician Providers, Inc., EMCARE Physician Services, Inc., and EMCARE, Inc. c/o Corporation Service Company 2595 Interstate Drive Suite 103 Harrisburg, PA 17110 Thomas M. Chairs, Esquire Aaron Jayman, Esquire Dickie McCamey & Chilcote, PC 425 N. 21St St., Suite 302 Camp Hill, PA 17011 (Counsel to Defendants, Holy Spirit Hospital, Holy Spirit Health System, Holy Spirit Ventures, West Shore Advanced Life Support Services, Comfort Care of Holy Spirit, Inc., Holy Spirit Corporation, and Sisters of Christian Charity Health Care Corp.) By: FOULKROD ELLIS PROFESSIONAL CORPORATION Stacy L. Breon; Paralegal Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r , t 201[1 DC 19 PH0.2<< CUMBERLAND COUNTY Y PENNSYLVANIA Craig Gilbert Stone vs. Laurence H Paul, MD (et al.) Case Number 2014-6592 SHERIFF'S RETURN OF SERVICE 11/24/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: EMcare Medical Servies of Pennsylvania, P.C., but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint & Notice according to law. 11/24/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Emcare of Pennsylvania, Inc., but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint & Notice according to law. 11/24/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Emcare Physician Providers, Inc., but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint & Notice according to law. 11/24/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Emcare Physician Services, Inc., but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint & Notice according to law. 11/24/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Emcare, Inc., but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint & Notice according to law. 11/24/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Cynthia L Jackson, MD, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint & Notice according to law. 11/24/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Quantum Imaging & Therapueutic Associates, Inc. a/k/a and or d/b/a, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint & Notice according to law. 11/24/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Sisters of Christian Chairty Health Care Corporation, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Lycoming, Pennsylvania to serve the within Complaint & Notice according to law. 12/01/2014 02:34 PM - The requested Complaint & Notice served by the Sheriff of Dauphin County upon Jennifer Smith, Customer Service Associate, who accepted for Emcare, Inc., at 2995 Interstate Drive, Suite 103, Harrisburg, PA 17110. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 12/01/2014 02:34 PM - The requested Complaint & Notice served by the Sheriff of Dauphin County upon Jennifer Smith, Customer Service Associate, who accepted for Emcare Physician Services, Inc., at 2595 Interstate Drive, Suite 103, Harrisburg, PA 17110. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. (c) CourtySuite Shonft, Te!e osoft, Inc. 12/01/2014 02:34 PM - The requested Complaint & Notice served by the Sheriff of Dauphin County upon Jennifer Smith, Customer Service Associate, who accepted for Emcare Physician Providers, Inc., at 2595 Interstate Drive, Suite 103, Harrisburg, PA 17110. Jack Lotwick, Sheriff, Return of Service attached to. and made part of the within record. 12/01/2014 02:34 PM - The requested Complaint & Notice served by the Sheriff of Dauphin County upon Jennifer Smith, Customer Service Associate, who accepted for Emcare of Pennsylvania, Inc., at 2595 Interstate Drive, Suite 103, Harrisburg, PA 17110. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 12/01/2014 02:34 PM - The requested Complaint & Notice served by the Sheriff of Dauphin County upon Jennifer Smith, Customer Service Associate, who accepted for EMcare Medical Servies of Pennsylvania, P.C., at 2595 Interstate Drive, Suite 103, Harrisburg, PA 17110. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 12/01/2014 04:19 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Kay Tipton, Legal Cordinator, Risk Managment Department, who accepted as "Adult Person in Charge" for Holy Spirit Health System at 503 North 21st Street, East Pennsboro Township, Camp Hill, PA 17011. SON KINSLER, DEPUTY 12/01/2014 04:19 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Kay Tipton, Legal Cordinator, Risk Managment Department, who accepted as "Adult Person in Charge" for Holy Spirit Corporation at 503 North 21st Street, East Pennsboro Township, Camp Hill, PA 17011. JASON KINSLER, DEPUTY 12/01/2014 04:19 PM - Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Emcare, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at 503 N. 21St Street, East Pennsboro Township, Camp Hill, PA 17011. Kay Tipton, Legal Coordinator stated that Holy Spirit has no affiliation with Emcare, she infomed deputies that that Emcare was based out of Texas. 12/01/2014 04:19 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Kay Tipton, Legal Cordinator, Risk Managment Department, who accepted as "Adult Person in Charge" for Holy Spirit Hospital of the Sisters of Christian Charity a/k/a and/or at 503 North 21st Street, East Pennsboro Township, Camp Hill, PA 17011. /Lv J ON KINSLER, DEPUTY 12/01/2014 04:19 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Kay Tipton, Legal Cordinator, Risk Managment Department, who accepted as "Adult Person in Charge" for Holy Spirit Health Ventures, Inc. at 503 North 21st Street, East Pennsboro Township, Camp Hill, PA 17011. , N KINSLER DEPUTY UTY 12/01/2014 04:19 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Kay Tipton, Legal Cordinator, Risk Managment Department, who accepted as "Adult Person in Charge" for West Shore Advanced Life Support Services at 503 North 21st Street, East Pennsboro Township, Camp Hill, PA 17011. SON KINSLER, DEPUTY (c) CountySuito Sheriff, TeInosoft, Inc. 12/01/2014 04:19 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Kay Tipton, Legal Cordinator, Risk Managment Department, who accepted as "Adult Person in Charge" for Comfort Care of Holy Spirit, Inc. at 503 North 21st Street, East Pennsboro Township, Camp, PA 17011. Z-7 N KINSLER, DEPUTY 12/02/2014 08:08 AM - The requested Complaint & Notice served by the Sheriff of York County upon Chris Lawrence, Manager, who accepted for Cynthia L Jackson, MD, at 629-D Lowther Road, Lewisberry, PA 17339. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 12/02/2014 08:08 AM - The requested Complaint & Notice served by the Sheriff of York County upon Chris Lawrence, Manager, who accepted for Quantum Imaging & Therapueutic Associates, Inc. a/k/a and or d/b/a, at 629-D Lowther Road, Lewisberry, PA 17339. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 12/02/2014 02:45 PM - The requested Complaint & Notice served by the Sheriff of Lycoming County upon Lisa English, Secretary to the President, who accepted for Sisters of Christian Chairty Health Care Corporation, at 1100 Grampian Boulevard, Williamsport, PA 17101. R. Mark Lusk, Sheriff, Return of Service attached to and made part of the within record. 12/09/2014 02:12 PM - Deputy Brian Barrick, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Laurence H Paul, MD at 503 North 21st Street, East Pennsboro Township, Cam ill, PA 17011. BRIAN BARRICK, DEPUTY SHERIFF COST: $328.90 SO ANSWERS, December 10, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft is:c. HERIF F`I'_`S_ RETURN-= REGULAR ` J CASE NO: 2014-06592 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF Lycoming CRAIG STONE & BRENDA STONE VS LAURENCE H. PAUL, M.D. & ET AL BRYANN BINGAMAN ,Sheriff or Deputy Sheriff of Lycoming County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE & COMPLAINT was served upon SISTERS OF CHRISTIAN CHARITY the DEFENDANT , at 1445:00 Hour, on the 2nd day of December , 2014 at 1100 GRAMPIAN BLVD. WILLIAMSPORT, PA 17701 by handing to LISA ENGLISH, SECRETARY TO THE PRESIDENT & ADULT IN CHARGE a true and attested copy of NOTICE & COMPLAINT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 9.00 Service 9.00 Affidavit 2.50 Surcharge .00 Mileage 4.52 25.02 Sworn and subscribed to before me this day of A.D. Notary So Answers: Lusk, Sheriff By 12/03/2014 y Sheriff SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber $�ar.5 0 � PETER J. MANGAN, ESQ. Sheriff Solicitor Michael S. Hose Richard E Rice, II Chief Deputy, Operations "?°' Chief Deputy, Administration CRAIG GILBERT STONE vs. Case Number CYNTHIA L JACKSON, MD (et al.) 2014-6592 SHERIFF'S RETURN OF SERVICE 12/02/2014 08:08 AM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT IN CIVIL ACTION (CICA) BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE CHRIS LAWRENCE, MANAGER, WHO ACCEPTED AS "ADULT PERSON IN CHARGE" FOR CYNTHIA L JACKSON, MD AT 629-D LOWTHER ROAD, LEWISBERRY, PA 17339. MICHAEL f • NOVAN, DEPUTY 12/02/2014 08:08 AM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT IN CIVIL ACTION (CICA) BY HANDING ATRUE COPY TOA PERSON REPRESENTING THEMSELVES TO BE CHRIS LAWRENCE, MANAGER, WHO ACCEPTED AS "ADULT PERSON IN CHARGE" FOR QUANTUM IMAGING & THERAPEUTIC ASSOCIATES, INC AT 629-D LOWTHER ROAD, LEWISBERRY, PA 17339. SHERIFF COST: $51.40 MICHAEL NOVAN DEPUTY December 03, 2014 RICHARD P KEU ' LEBER, SHERIFF COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sheila E. Cook, Notary Public City of York, York County My Commission Expires Feb. 1, 2017 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES Affirmed and subscribed to before me this 3RD day of DECEMBER NOTARY 2014 (c) Cuuni.ySu ,e Sheriff; Tefecso t; Inc. Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin AAA - 0111411. -11 Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff • f. Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy CRAIG STONE AND BRENDA STONE, H/W VS EMCARE MEDICAL SERVICES OF PENNSYLVANIA, P.C. Sheriffs Return No. 2014-T-3082 OTHER COUNTY NO. 2014-6592 And now: DECEMBER 1, 2014 at 2:34:00 PM served the within NOTICE & COMPLAINT upon EMCARE MEDICAL SERVICES OF PENNSYLVANIA, P.C. by personally handing to JENNIFER SMITH * 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at C/O CSC, 2595 INTERSTATE DRIVE, SUITE 103 HARRISBURG PA 17110 * CUSTOMER SERVICE ASSOCIATE Sworn and subscribed to before me this 3RD day of December, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, AV/aC___ Sheriff of 11.04• By D-puty Sheriff Deputy: W CONWAY Sheriffs Costs: $124.25 11/28/201 Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin f e ,SlIvrrft Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy CRAIG STONE AND BRENDA STONE, H/W VS EMCARE MEDICAL SERVICES OF PENNSYLVANIA, P.C. Sheriffs Return No. 2014-T-3082 OTHER COUNTY NO. 2014-6592 And now: DECEMBER 1, 2014 at 2:34:00 PM served the within NOTICE & COMPLAINT upon EMCARE OF PENNSYLVANIA, INC. by personally handing to JENNIFER SMITH * 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at C/O CSC, 2595 INTERSTATE DRIVE, SUITE 103 HARRISBURG PA 17110 * CUSTOMER SERVICE ASSOCIATE Sworn and subscribed to before me this 3RD day of December, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, Sheriff of D By D- suty Sheriff Deputy: W CONWAY Sheriffs Costs: $124.25 11/28/201 Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy CRAIG STONE AND BRENDA STONE, H/W VS EMCARE MEDICAL SERVICES OF PENNSYLVANIA, P.C. Sheriffs Return No. 2014-T-3082 OTHER COUNTY NO. 2014-6592 And now: DECEMBER 1, 2014 at 2:34:00 PM served the within NOTICE & COMPLAINT upon EMCARE PHYSICIAN PROVIDERS, INC. by personally handing to SABRA DUDDING * 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at CIO CSC, 2595 INTERSTATE DRIVE, SUITE 103 HARRISBURG PA 17110 * CUSTOMER SERVICE ASSOCIATE • Sworn and subscribed to before me this 3RD day of December, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, Sheriff of By D-puty Sheriff Deputy: W CONWAY Sheriffs Costs: $124.25 11/28/2014 Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor fpm .1.110 Commonwealth of Pennsylvania County of Dauphin Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff • Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy CRAIG STONE AND BRENDA STONE, H/W VS EMCARE MEDICAL SERVICES OF PENNSYLVANIA, P.C. Sheriffs Return No. 2014-T-3082 OTHER COUNTY NO. 2014-6592 And now: DECEMBER 1, 2014 at 2:34:00 PM served the within NOTICE & COMPLAINT upon EMCARE PHYSICIAN SERVICES, INC. by personally handing to JENNIFER SMITH * 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at C/O CSC, 2595 INTERSTATE DRIVE, SUITE 103 HARRISBURG PA 17110 * CUSTOMER SERVICE ASSOCIATE Sworn and subscribed to before me this 3RD day of December, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, ieg mac___ Sheriff of D By DSheriff Deputy: W CONWAY Sheriff's Costs: $124.25 11/28/201 Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin rt of fF:1. Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff • Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy CRAIG STONE AND BRENDA STONE, H/W VS EMCARE MEDICAL SERVICES OF PENNSYLVANIA, P.C. Sheriffs Return No. 2014-T-3082 OTHER COUNTY NO. 2014-6592 And now: DECEMBER 1, 2014 at 2:34:00 PM served the within NOTICE & COMPLAINT upon EMCARE, INC. by personally handing to JENNIFER SMITH * 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at C/O CSC, 2595 INTERSTATE DRIVE, SUITE 103 HARRISBURG PA 17110 * CUSTOMER SERVICE ASSOCIATE Sworn and subscribed to before me this 3RD day of December, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, Sheriff of By D-.uty Sheriff Deputy: W CONWAY Sheriffs Costs: $124.25 11/28/2014 FOULKROD ELLIS Professional Corporation 4000 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 909-7006 Fax: (717) 909-6955 Attorney for Defendants: Cynthia L. Jackson, MD. and Quantum Imaging & Therapeutic Associates, Inc. CRAIG STONE AND BRENDA STONE, husband and wife, Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 14-6592 LAURENCE H. PAUL, M.D., EMCARE, EMCARE MEDICAL SERVICES OF CIVIL ACTION - PENNSYLVANIA, P.C., EMCARE OF MEDICAL PROFESSIONAL LIABILITY PENNSYLVANIA, INC., EMCARE ACTION PHYSICIAN PROVIDERS, INC., EMCARE PHYSICIAN SERVICES, INC., EMCARE; INC., CYNTHIA LYNN JACKSON, M.D., JURY TRIAL DEMANDED c; r q QUANTUM IMAGING & THERAPEUTIC�. ASSOCIATES, INC., HOLY SPIRIT r= ;ice;- HOSPITAL OF THE SISTERS OF CHRISTIAN CHARITY, HOLY SPIRIT -._, `- f ` r HEALTH SYSTEM, HOLY SPIRITc -,, VENTURES, INC., WEST SHOREo �'"' ADVANCED LIFE SUPPORT SERVICE, COMFORT CARE OF HOLY SPIRIT, INC., .. -� HOLY SPIRIT CORPORATION, SISTERS OF CHRISTIAN CHARITY HEALTH CARE CORPORATION, Defendants PRELIMINARY OBJECTIONS OF DEFENDANTS, CYNTHIA LYNN JACKSON, M.D. and QUANTUM IMAGING & THERAPEUTIC ASSOCIATES, INC. TO PLAINTIFFS' COMPLAINT AND NOW come Defendants, Cynthia Lynn Jackson, M.D. and Quantum Imaging & Therapeutic Associates, Inc., by and through their attorneys, Foulkrod Ellis, P.C., to file the within Preliminary Objections to Plaintiffs' Complaint as follows: 1 The within medical malpractice action was initiated b'y Complaint filed on or about November 13, 2014. -r; 9. Plaintiffs' lack of specificity as to identification of agents and their specific involvement in Decedent's care, is violative of Pa. R.C.P. 1019(a). 10. Plaintiffs' lack of specificity regarding agency, deprives Defendants of their ability to comply with Pa. R.C.P. 1029(e)(1) relating to specific denials relating to agency averments. 11. Furthermore, if these unidentified individuals are licensed professionals, Plaintiffs are required to file Certificates of Merit as to those individuals pursuant to Pa. R.C.P. 1042.3 and has thus far failed to do so. WHEREFORE, Defendants respectfully request that Plaintiffs specifically identify individuals upon whom their negligence claims rest or be precluded from pursuing claims against any individual other that those specifically named and identified within the Complaint. Preliminary Objection - Motion to Strike — Lack of Specificity 12. Paragraphs 90 and 96 of the Complaint purport to set forth the specific acts of negligence alleged as to Dr. Jackson and Quantum Imaging. 13. Pursuant to Pa. R.C.P. 1019(a), "the material facts on which a cause of action or defense is based shall be stated in concise and summary form." 14. The only factual allegations as to Objecting Defendants relate to Dr. Jackson's interpretations and recommendations as to a CT Scan performed on November 14, 2012. See ¶¶ 46 and 49 of Plaintiffs' Complaint. 15. Despite this very limited and specific involvement, paragraphs 90 and 96 allege failures as to general "diagnostic test findings" and/or "radiology findings." See subparagraphs (a), (b), (c), (d), (e), (g) and (h). 3 16. Moreover, subparagraph (j) is critical of Dr. Jackson and/or Quantum Imaging relating to the general failure to recommend "necessary follow up tests." 17. From the information obtained so far by undersigned, there were multiple radiology studies performed on November 14 and November 15, 2012. 18. As these paragraphs currently read, Plaintiffs could be referencing any of the radiology studies performed upon Plaintiff at any time and read by any number of radiologists at Quantum Imaging. 19. The vague nature of the allegation of negligence as it now reads affords Plaintiffs the opportunity to introduce new theories of recovery at any time prior to the commencement of trial and after the expiration of the statute of limitations in violation of Connor v. Allegheny General Hospital, 461 A.2d 600 (Pa. 1983). 20. Defendants are prejudiced by these allegations, because a defense to these vague and conclusory allegations cannot be prepared. 21. Moreover, the vague nature of the allegations is completely unnecessary in this case. 22. Pursuant to Pa. R.C.P. 1028, this Court is empowered to strike from Plaintiffs' Complaint any allegations that fail to conform to law or rule of court. 4 WHEREFORE, Defendants respectfully request that subparagraphs (a), (b), (c), (d), (e), (g), (h) and (j) of Paragraphs 90 and 96 be stricken from the Complaint. In the alternative, Plaintiffs should be required to amend these subparagraphs to relate to the specific factual allegations of the Complaint. Respectfully submitted, FOULKROD ELLIS PROFESSIONAL CORPORATION Date: ` Ii fic( By: V ,� Leigh`A.J. Ellis, Esquire Attorney I.D. No. 53229 leigh@foulkrod.com Cindy N. Ellis, Esquire Foulkrod Ellis, P.C. Attorney I.D. No. 83823 cindy@foulkrod.com 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that true and correct copies of the foregoing were served upon all counsel of record this day of Aeoe„.,,,j/j.„€,----, 2014, by depositing said copy in the United States Mail at Camp Hill, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Robert Ross, Esquire Shanon S. Levin, Esquire Ross Feller Casey, LLP One Liberty Place 1650 Market Street, Suite 3450 Philadelphia, PA 19103 (Counsel to Plaintiffs) PERSONAL AND CONFIDENTIAL Laurence H. Paul, M.D. John R. Dietz Emergency Center Holy Spirit Hospital 503 North 21St Street Camp Hill, PA 17011 PERSONAL AND CONFIDENTIAL EMCARE, Attn: Risk Management 503 North 20 Street Camp Hill, PA 17011 PERSONAL AND CONFIDENTIAL Attn: Risk Management EMCARE Medical Services of Pennsylvania, P.C., EMCARE of Pennsylvania, Inc., EMCARE Physician Providers, Inc., EMCARE Physician Services, Inc., and EMCARE, Inc. c/o Corporation Service Company 2595 Interstate Drive Suite 103 Harrisburg, PA 17110 Thomas M. Chairs, Esquire Aaron Jayman, Esquire Dickie McCamey & Chilcote, PC 425 N. 21st St., Suite 302 Camp Hill, PA 17011 (Counsel to Defendants, Holy Spirit Hospital, Holy Spirit Health System, Holy Spirit Ventures, West Shore Advanced Life Support Services, Comfort Care of Holy Spirit, Inc., Holy Spirit Corporation, and Sisters of Christian Charity Health Care Corp.) By: FOULKROD ELLIS PROFESSIONAL CORPORATION Cryst L. Nemetz, Secretary ROSS FELLER CASEY, LLP By: ROBERT ROSS,ESQUIRE SHANON S. LEVIN,ESQUIRE Attorney ID Nos. 47152/86040 One Liberty Place 1650 Market Street Suite 3450 Philadelphia,PA 19103 (215) 574-2000 Attorneys for Plaintiffs CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: 14-6592 LAURENCE H. PAUL, M.D., et.al. JURY TRIAL DEMANDED Defendants. . PLAINTIFFS' RESPONSE IN OPPOSITION TO PRELIMINARY OBJECTIONS OF DEFENDANTS CYNTHIA LYNN JACKSON,M.D. AND QUANTUM IMAGING AND THERAPEUTIC ASSOCIATES, INC. TO PLAINTIFFS' COMPLAINT Plaintiffs Craig Stone and Brenda Stone, h/w, hereby oppose the preliminary objections of defendants Cynthia Lynn Jackson, M.D. and Quantum Imaging and Therapeutic Associates, Inc. ("Objecting Defendants") to plaintiff's Complaint and in support thereof states as follows: 1. Admitted. 2. Admitted. 3. Denied. The allegations of the Complaint are contained in a document that speaks for itself. Objecting Defendants' characterization of those allegations are, therefore, denied. 4. Denied. The allegations of the Complaint are contained in a document that speaks for itself. Objecting Defendants' characterization of those allegations are, therefore, denied. 5. Denied. By way of further answer, the averments of paragraph 5 constitute conclusions of law to which no response is required. To the extent the averments of this paragraph constitute allegations of fact,they are denied. Preliminary Objection - Motion to Strike 6. Denied. The allegations of the Complaint are contained in a document that speaks for itself. Objecting Defendants' characterization of those allegations are, therefore, denied. 7. Denied. By way of further answer, the averments of paragraph 7 constitute conclusions of law to which no response is required. To the extent the averments of this paragraph constitute allegations of fact, they are denied. 8. Denied. By way of further answer, the averments of paragraph 8 constitute conclusions of law to which no response is required. To the extent the averments of this paragraph constitute allegations of fact,they are denied. By way of further answer, Objecting Defendants have misstated the legal standard. 9. Denied. By way of further answer, the averments of paragraph 9 constitute conclusions of law to which no response is required. To the extent the averments of this paragraph constitute allegations of fact, they are denied. 10. Denied. By way of further answer, the averments of paragraph 10 constitute conclusions of law to which no response is required. To the extent the averments of this paragraph constitute allegations of fact,they are denied. 11. Denied. By way of further answer, the averments of paragraph 11 constitute conclusions of law to which no response is required. To the extent the averments of this paragraph constitute allegations of fact,they are denied. Preliminary Obiection - Motion to Strike 12. Denied. The allegations of the Complaint are contained in a document that speaks for itself. Objecting Defendants' characterization of those allegations are, therefore, denied. 2 13. Denied. By way of further answer,the averments of paragraph 13 constitute conclusions of law to which no response is required. To the extent the averments of this paragraph constitute allegations of fact, they are denied. 14. Denied. The allegations of the Complaint are contained in a document that speaks for itself. Objecting Defendants' characterization of those allegations are, therefore, denied. 15. Denied. The allegations of the Complaint are contained in a document that speaks for itself. Objecting Defendants' characterization of those allegations are, therefore, denied. 16. Denied. The allegations of the Complaint are contained in a document that speaks for itself. Objecting Defendants' characterization of those allegations are, therefore, denied. 17. Denied. By way of further answer,plaintiff has no information regarding the truth or falsity of allegations relating to Objecting Defendants' "investigation." 18. Denied. The allegations of the Complaint are contained in a document that speaks for itself. Objecting Defendants' characterization of those allegations are, therefore, denied. 19. Denied. By way of further answer,the averments of paragraph 19 constitute conclusions of law to which no response is required. To the extent the averments of this paragraph constitute allegations of fact, they are denied. 20. Denied. By way of further answer, the averments of paragraph 20 constitute conclusions of law to which no response is required. To the extent the averments of this paragraph constitute allegations of fact, they are denied. 21. Denied. By way of further answer,the averments of paragraph 21 constitute conclusions of law to which no response is required. To the extent the averments of this paragraph constitute allegations of fact, they are denied. 3 22. Admitted in part and denied in part. It is admitted only that Objecting Defendant seeks certain relief. It is denied that Objecting Defendant is entitled to any relief. The remaining allegations, if any, are denied. WHEREFORE, plaintiff respectfully requests that the Court enter an Order in the form attached overruling Objecting Defendant's preliminary objections. ROSS FELLER CAS LLP Dated: January 6, 2015 By: E T ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE 1650 Market Street, Suite 3450 Philadelphia, PA 19103 Attorneys for Plaintiffs CERTIFICATE OF SERVICE I, Donna Schreck, Paralegal to SHANON S. LEVIN, ESQUIRE, hereby certify that on January 6, 2015, 1 caused a true and correct copy of the foregoing Plaintiffs' Response to Preliminary Objections of Cynthia Lynn Jackson, M.D. and Quantum Imaging& Therapeutic Associates, Inc. to Plaintiffs' complaint upon counsel and defendants listed below by methods stated: VIA Regular Mail Thomas M. Chairs, Esquire Aaron S. Jayman, Esquire Dickie, McCamey& Chilcote, P.C. 425 North 21St Street Plaza 21, Suite 302 Camp Hill, PA 17011 Attorneys for Defendants -Holy Spirit Hospital, Holy Spirit Health System, Holy Spirit Ventures, Inc., West Shore Advanced Life Support Services, Comfort Care of Holy Spirit, Inc., Holy Spirit Corporation, Sisters of Christian Charity Health Care Corporation Leigh A.J. Ellis, Esquire Cindy N. Ellis, Esquire Foulkrod Ellis, P.0 Professional Corporation 4000 Market Street Camp Hill, PA 17011 Attorneys for Defendants: Cynthia L. Jackson, M.D. and Quantum Imaging&Therapeutic Associates, Inc. Laurence H. Paul, M.D. John R. Dietz Emergency Center Holy Spirit Hospital 503 North 21St Street Camp Hill, PA 17011 EMCARE 600 Six Flags Drive Suite 300 Arlington, TX 76011 r ' EMCARE Medical Services of Pennsylvania, P.C. EMCARE of Pennsylvania, Inc. EMCARE Physician Providers, Inc. EMCARE Physician Services, Inc. EMCARE, Inc. c/o Corporation Service Company 2595 Interstate Drive Suite 103 Harrisburg, PA 17110 nk Donna Schreck, Paralegal to, SHANON S. LEVIN, ESQUIRE CRAIG STONE AND BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, NOVEMBER TERM 2014 V. No: 14-6592 LAURENCE H. PAUL,M.D., et.al. JURY TRIAL DEMANDED Defendants. ORDER AND NOW, this _day of , 2015, upon consideration of the Preliminary Objections of Defendants Cynthia Lynn Jackson, M.D. and Quantum Imaging and Therapeutic Associates, Inc. to Plaintiffs Complaint and plaintiffs opposition thereto, it is hereby ORDERED that said preliminary objections are OVERRULED. Defendants Cynthia Lynn Jackson, M.D. and Quantum Imaging and Therapeutic Associates, Inc. are directed to file an Answer to Plaintiffs Complaint within 20 days of the date of this Order or suffer entry of a default judgment against them. BY THE COURT: , J. ROSS FELLER CASEY, LLP By: ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE I.D. NOS: 47152/86040 One Liberty Place, Suite 3450 1650 Market Street Philadelphia, Pennsylvania 19103 (215) 574-2000 Attorneys for Plaintiffs CRAIG STONE and BRENDA STONE, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, No. 14-6592 v. LAURENCE H. PAUL, M.D., et al. Defendants PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned action. ROSS FELLER CASEY, LLP By: Dated: January 9, 2015 ROBERT ROSS, ESQUIRE SHANON S. LEVIN, ESQUIRE Attorneys for Plaintiff PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next r, Argument Court.) c c .-4 ra CAPTION OF CASE (entire caption must be stated in full) Craig Stone and Brenda Stone, husband & wife vs. Cynthia L. Jackson, M.D. & Quantum, et. al. No. 14-6592 µ y CP Term - 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Preliminary Objections of Defs Cynthia L. Jackson, MD and Quantum Imaging & Therapeutic Assoc., Inc. to Plaintiffs' Complaint 2. Identify all counsel who will argue cases: (a) for plaintiffs: Robert Ross, Esquire, Shanon S. Levin, Esquire, Ross Feller Casey, LLP One Liberty Place, (Name and Address) 1650 Market Street, Ste 3450, Philadelphia, PA 19103 (b) for defendants: Cindy N. Ellis, Foulkrod Ellis, 4000 Market Street, (Name and Address) Camp Hill, PA 17011 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: February 6, 2015 Date: 1/7/15 0:w Signature Ora/ N r ij(J Print your name CK/► r.l iq G U uU�6ovl D an Attorney for INSTRUCTIONS: 1. Original and two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 14 days prior to argument. 3. The responding party shall file their brief 7 days prior to argument. 4. If argument is continued new briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) after the case is relisted. 0'1111/9 4g6, CL#Ywv G Rfr 3I sl1ia a CERTIFICATE OF SERVICE I HEREBY CERTIFY that true and correct copies of the foregoing were served upon all counsel of record this n " ! day of / , 2015, by depositing said copy in the United States Mail at Camp Hill, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: Robert Ross, Esquire Shanon S. Levin, Esquire Ross Feller Casey, LLP One Liberty Place 1650 Market Street, Suite 3450 Philadelphia, PA 19103 (Counsel to Plaintiffs) PERSONAL AND CONFIDENTIAL Laurence H. Paul, M.D. John R. Dietz Emergency Center Holy Spirit Hospital 503 North 21st Street Camp Hill, PA 17011 PERSONAL AND CONFIDENTIAL Attn: Risk Management EMCARE Medical Services of Pennsylvania, P.C., EMCARE of Pennsylvania, Inc., EMCARE Physician Providers, Inc., EMCARE Physician Services, Inc., and EMCARE, Inc. c/o Corporation Service Company 2595 Interstate Drive Suite 103 Harrisburg, PA 17110 Thomas M. Chairs, Esquire Aaron Jayman, Esquire Dickie McCamey & Chilcote, PC 425 N. 21st St., Suite 302 Camp Hill, PA 17011 (Counsel to Defendants, Holy Spirit Hospital, Holy Spirit Health System, Holy Spirit Ventures, West Shore Advanced Life Support Services, Comfort Care of Holy Spirit, Inc., Holy Spirit Corporation, and Sisters of Christian Charity Health Care Corp.) By: FOULKROD ELLIS PROFESSIONAL CORPORATION /()e Crystal L. Nemetz, Secr ry