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Home My WebLink About02-0978IN RE: ESTATE OF MANDY GROVE, a minor, by and through her parents and natural guardians, CHARLES and DONNA GROVE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY- CIVIL DIVISION PETITION TO APPROVE MINOR'S COMPROMISF TO THE HONORABLE JUDGES OF SAID COURT: The Petition of Mandy Grove, a minor, by and through her parents and natural guardians, Charles and Donna Grove, seeks Court approval of a settlement in favor of their minor daughter, Mandy Grove, in support thereof, provides as follows: 1. Charles and Donna Grove are the parents and natural guardians of Mandy Grove, a minor, age 17 (DOB: 12/20/84) (SSN: 197-66-2130) who sustained injuries on or about February 16, 2001, as a result of being a passenger in a motor vehicle that was involved in an accident at or near the intersection of Airport and Gilbert Roads, Southampton Township, Cumberland County, Pennsylvania. 2. The minor resides with her parents and natural guardians, Chades and Donna Grove at 100 Enola Road, P.O. Box 144, Newburg, Pennsylvania 17240. 3. According to the Police Report completed by Trooper John Lutz of the Pennsylvania State Police Department, the minor was injured while riding as a passenger in a vehicle heading south on Airport Road that struck the driver's side of a vehicle being operated by Austin Myers traveling east on Gilbert Road. The vehicle being operated by Karen Lauver did not stop for a posted stop sign and as such proceeding into the intersection causing the accident. A true and correct copy of the Police Report is attached hereto and made a part hereof as Exhibit "A". 4. As a result of the above-mentioned accident, minor suffered injuries consisting of a concussion and fracturesof the pelvis, clavicle and first metatarsal bone. A copy of the York Hospital records pertaining to the evaluation, admission and discharge of the minor are attached hereto and made a part hereof as Exhibit "B". 5. No out-of-pocket expenses have been incurred by the minor or Petitioners with respect to the injuries sustained by Minor. There are presently no outstanding liens or claims on behalf of any medical supplier, Medicare or Department of Public Welfare, ERISA plan or other entity. 6. No attorney fees are being charged to Petitioner nor are the settlement proceeds as being offered to the minor subject to a reduction for payment of attorney fees. 7. Karen Lauver, who according to the Police reports is the party responsible for the accident, is covered as a resident relative insured under a policy of insurance issued by State Farm Mutual Automobile Insurance Company to Rose Lauver. Under the policy as issued by State Farm Mutual Automobile Insurance Company, the total coverage available for the payment to third parties for personal injury liability is $30,000. A true and correct copy of State Farm's Certificate of Coverage is attached hereto and made a part hereof as Exhibit "C". 8. In addition to the injuries sustained by the minor as set forth in this Petition, one (1) other individual who was a passenger occupant of the vehicle in which the minor was a passenger was also injured. Specifically, this individual is Casey Hippensteel (who sustained a concussion and facial lacerations). Additionally, the driver of the other vehicle, namely Austin Myers sustained a fractured sternum and fractured scapula. 9. Each of these other individuals has agreed to accept $10,000 in full and final settlement of their respective claims. Therefore, the providing of settlement proceeds in the amount of $10,000 each to the minor, Casey Hippensteel and Austin Myers has resulted in a complete exhaustion of the policy limits available under the policy of insurance issued by State Farm to Rose Lauver. 10. After discussions between the minor's parents, Charles and Donna Grove and State Farm Mutual Automobile Insurance Company, the insurance provider for Karen Lauver, a settlement has been reached for $10,000.00. Chades and Donna Grove as parents of minor, fully understand that the settlement of this claim releases and forever discharges Karen Lauver and State Farm Mutual Automobile Insurance Company, their heirs, executors, administrators, agents, assigns and all other persons, firms or corporations were liable or who may be claimed to be liable as a result of the accident of February 16, 2001. 11. Minor's parents, Charles and Donna Grove, agree to put the entire amount of the settlement proceeds into an interest bearing account with a federally insured financial institution until the minor turns 18 years of age. 12. Petitioners believe and therefore aver that considering the liability issues in this case and the fact that the minor's injuries were relatively minor and have since been resolved, the aforementioned settlement and resolution of this claim is in the best interest and welfare of the minor. 13. In order to reduce the mutual exchange promises referred to in Paragraphs 10 and 11 hereof to writing, Petitioners request authority to execute a release in the form identical to that attached hereto as Exhibit "D". WHEREFORE, Petitioners, Chades and Donna Grove, individually and on behalf of their minor daughter, Mandy Grove, request this Honorable Court to approve the Minor's Settlement. Chades Grove, as parent and natural guardian of Mandy Grove, a minor Respectfully submitted: Dgml~'G('~e, a~ par'~ent ~(] ~atural guardian of Mandy Grove, a minor VERIFICATION We, Chades a_nd Donna Grove, Petitioners in this action hereby verify that the statements made in the foregoing Petition to Settle or Compromise Minor's action are true and correct to the best of our information, knowledge and belief. We understand that the statements in said Petition are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Charles Gro~e, parent and natural guardian of Mandy Grove, a minor /,..-O'onna (~r°ve, ~aren~ and n~tural · guardian of Mandy Grove, a minor EXHIBIT "A" POLICE ACCIDENT REPORT 31 ST&TIQ~ _-,:~ OATF. ACCIDENT INFORMATION H2.1177196 ' ~-'--------- 21 PRINCIPAL ROADWA~ -r'~C'-'-5~'--~'120 ~ - -- T 3171 .~;.--~ Rd. : .... · ~-#~ · ~ ~ I ;l I ....... ~---~___L INTeRSeCTING ROA : ~ I ~ ~ SR30021GilbertRd. Friday Rose Ann t. auvr 1168 Means Hollow Rd. : ,, r~~(. 1168 Means Hcdlow Rd. ~ c,~ S,AT~ Shq:~)anSbufg. PA 17257 ' F I IF NOT AT INTERSECTION: --------'-'--- - --'~ ~'-- UNIT · Z 100 High Rd. eo c,TY. STAVE ShippanM~rg. PA 17257 CiTY STA~ ,,AGE 01 PennDOT - BH~, Unit # 1 cell phone not present Unit # 2 cell phone present not in use. This accident occurred as unit # 1 travelled SB on Airport Rd. and failed to stop at a propedy posted stop sign. Initial impact occurred as Unit # 1 entered the intersection with SR3002 and struck Unit # 2, which was travelling EB. on the left side driver's door with its front end. The force of the collision spun unit # 1 into a counterclockwise rotation and forced Unit # 2 off the roadway where it landed in an adjacent field and rolled over as the vehicle turned sideways. Unit # 1 came to a final rest facing WB partially on the EB berm of High Rd. Unit # 2 came to a final rest facing NB and on its right side. Physical evidence: debris field at point of impact, heavy front end damage of Unit # 1, heavy left side damage of Unit # 2. On 02119101 at approx 1500 hrs. this R.O. interviewed Oper # 1 via telephone, she related that she did not ~emember anything about the accident and didn't know how it happened. Continued.. ~,u~wc~' cc;--::.":. Ede ..su-_-~, i ¢c.~__ Sra. Farm Insu~'ance .--~o~ I ~uc ~Fow~t)~. UNfl' Y ~_,~,~_~_~1_ _ 116 poL,c~, 6853-~SEJ05--38V Glenn Ee'~ard Halter 940 FMest Cou~ Ca,isle, PA 17013 ',MTNESSES Stop s~gns & Yield Signs t I None i ' '-------'~ i ~ NO ~EST ,~,, · 0 , i 0__% I-I El,c*, tc mc ~i~oo'r. BHSTE ~' headed east bound to return the vehicle I,~was drivi.ng to the.. __d~.._h. lp .that owned, it..! where I was going so I wasnl going very fast, mayl3e around 3,~ MPI'I. I ~ Up m N irl[ersecm~n an<] I ~.~ saw the other car coming at me aS I Ioo,k~d out my window and then I got hit. On 02/21/01 at approx 1030 hfs this R.O interviewed the right front seat passenger, Man:.ty N. Grove, via telephone. Sh~, .r.~. ~ ~.~,~,m.~o~h~._ ~ ..................... to the stol:) -r-n it wea iosertotbestoPsigfl:l'~tomyse~ffsnewasgmngmsmP.~aw~..~'~ . . .'~'.?' ___ ,otc ~ ..... ...__. _. . . sure she didn.'t st6i~.-:.;' :'::.--. ' ...... On 02/1~/01 this R.O. interviewed the witrtess on scene. He related, I was right behind tfll~erGcaMr.C~l~e my, :.~ he was going around 35 to 40 MPH and he got hit from the side by the girl driving the ot . completely ran the stop sign. Both vehicles removed from scene by Chuck's Auto Repair, Shippansburg, PA SP7-0015 Mailed to owners of Units I & 2. n 0 0 0..__~ 0 u~ ,. ~ .o 0 EXHIBIT "B" ATTENDING PHYSICIAN: RHOADS JR, JONATHAN Discharge Diagnosis: 1. Concussion. 2. Severely comminuted fracture of the pelvis involving the left acetabulum. 3. Fracture of the left clavicle. 4. Fracture of the left first metatarsal bone. History of Present Illness: This 16-year-old girl was allegedly a restrained front seat passenger in a motor vehicle which crashed. She was seen initially at Chambersburg Hospital where her cervical spine was evaluated and cleared, and then transferred to York Hospital for continuing management of her multiple injuries. She appeared to be amnestic for the event and was considered to have a concussion. Radiographic evaluation showed the injuries enumerated above. She was admitted to the Intensive Care Unit and placed in traction. Consulting orthopedists quickly concluded that the pelvis needed operative management and that she was not a candidate to have that done at York. Arrangements were made to send her to Spence Reid, M.D. at Hershey Medical Center for definitive management of this injury, and she was transferred on the day after admission to York Hospital. Her continuing management including medications, diet, activity and follow-up will be with the doctors at Hershey. Jonathan E. Rhoads Jr., M.D. D: T: R: 04/02/2001 12:00:50 JER 04/04/2001 13:45:31 crw CC: Noelle A. Rotondo, D.O. ' ~ ' TRAUMA NAME: GROVE, MANDY MRN: 000744757 DOB: 12/20/1984 ADMITTED: 02/16/2001 DISCHARGED: 02/17/2001 YORK HOSPITAL YORK, PA 17405 DISCHARGE SUMMARY PAGE 1 CONFIDENTIAL This information is furnished on the condition that it wfll be used only for the purpose for which it was requested. Any other use o~ disclosure of this information requires the express authorization of York Health System. CHART COPY ATTENDING PHYSICIAN: RHOADSJR, JONATHAN INFORMANT Patient and prehospital personnel. CHIEF COMPLAINT Status post motor vehicle collision. HISTORY OF PRESENT ILLNESS This is a 16-year-old Caucasian female, seatbelted, front seated passenger involved in a motor vehicle collision. She states that she may have lost consciousness. She complains of left shoulder, left hip, and left lower quadrant abdominal pain. She was brought in as a class 2 transfer from Chambersburg Hospital. PRIMARY SURVEY Airway was patent. Cervical spine was cleared at Chambersburg. The patient has no cervical collar on. Breathing spontaneously and unlabored. There is no exsanguinating hemorrhage. Bilateral femoral pulses are strong. Glasgow Coma Scale is ~ 15. Moving all extremities. The patient was disrobed, examined, and re-covered with warm blankets. PAST MEDICAL HISTORY Negative. FAMILY HISTORY Negative· SOCIAL HISTORY Negative for smoking or alcohol use. REVIEW OF SYSTEMS As in History Of Present Illness. All systems are ~egative. PHYSICAL EXAMINATION Glas,qow Coma Score is 15. Vital signs - blood pressure 126/82, heart rate 82, temperature 99.3, respirations 22, saturating 100%. Head, Ears, Eyes, Nose, and Throat - normocephalic, atraumatic. There is a small abrasion on the left temporal area. There is no mass, facial tenderness, or crepitus. Pupils equal, round, reactive · t~'light~'-'E~[t~oc~Lilai--m~isciesare int~ct;'Ther~-~-tt'0-h~rn0t~/~n~i~Qm*.-NO~'[S'hOnt~nder~-- Oropharynx is pink and moist. Neck - nontender. NAME: MRN: DOB: ROOM #: ADMITTED: YORK HOSPITAL YORK, PA 17405 GROVE, MANDY 000744757 12/20/1984 2405A HISTORY AND PHYSICAL EXAMINATION 02/16/2001 PAGE 1 CONFIDENTIAL This information is furnished on the condition that it will be used only for the purpose for which it was requested, Any other use or disclosure of this information requires the express authorization of Yo~ Health System. CHART COPY Chest - no chest wall tenderness. There is left-sided shoulder tenderness. Lungs - clear to auscultation bilaterally. Cardiac'- rate and rhythm is regular, S1 and S2 presen[. Breasts -within normal limits. Back - nontender. No stepoff deformities. Abdomen - soft, nondistended. There is left lower quadrant tenderness. Rectal and Genitalia - examination deferred. Extremities - patient has left hip tenderness. Pulses right and left were symmetric, radial, femoral, · lorsalis pedis. Neurologic - the patient is completely intact. TRAUMA BAY COURSE The patient's resuscitation was per advanced trauma life support guidelines. X-ray of the chest was performed. Ancef and fentanyl were administered. Contrast was given. The patient was taken to the CT scanner and then to x-ray. LABORATORY DATA X-rays - lateral cervical spine, AP cervical spine, odontoid, oblique cervical spine all negative. AP chest, CT head all negative. AP pelvis demonstrates three fractures, 1) of the acetabulum, 2) of the inferior ramus on the left side and 3) of the symphysis pubis of the left side. White blood cell count 20.4, hemoglobin 12.4, hematocrit 35~, platelets 249. Pro-time 12.4, amylase 43, AST 55, ALT 34. ETOH is 0. Magnesium 1 IMPRESSION This is a 16-year-old Caucasian female status post motor vehicle collision who has the following injuries. 1. Left pelvic fracture of the acetabulum, inferior ramus, and symphysis pubis. 2. Concussion with brief loss of consciousness. 3. Left clavicle fracture. 4. Left first proximal metatarsal fracture. PLAN 1. The patient will be admitted to Trauma Surgical Intensive Care Unit and ~rthopedic consultation has been placed. Kap~e, M.D. NAME: .;ROVE, MANDY HISTOF{'~ ,AND PHYSICAL EXAMINATION MRN: 000744757 ADMITTED: 02/16/2001 PAGE 2 CONFIDENTIAL This information is furnished on the condition that it will be used only for the purpose for which itwas requested. Any other use or disclosure of this information requires the express authorization of York Health System. o CHART COPY D; T~ R~ CC: 02/1612001 20:10:50 K S 02/1712001 12:21:54 sks I NAME: GROVE, MANDY HISTORY AND PHYSICAL EXAMINATION M RN: 000744757 ADMITTED: 02/16/2001 PAGE 3 CONFIDENTIAL This information is furnished on the condition that it will be used only for the purpose for which it was requested. Any other use or disclosure of this information requires the express authorization of York Health System. CHART COPY Print(~d: 02/22/01 0903 ~ROVE, MANDY YORK HOSPITAL CLINICAL LABORATORY -- FINAL CHART - DO NOT DISCARD -- (00000)000744757 16 YRS F 2405A TSIC Date: 02/16/01 02/17/01 Time: 1820 0144 RHOADS JR, JONATHAN E. Reference Units WBC 20.9H 12.3H (4.0-11.0) RBC 4.14 3.86 (3.80-5.34) M/ChUn HGB 12.4 11.6 (11.5-15.5) g/dL HCT 35.3 32.9L (34.5-47.0) MCV 85 85 (83-99) fL MCH 30.0 30.1 (27.0-33.0) pg MCHC 35.1H 35.3H (31.0-35.0) g/dL PLAT CT '249 233 (140-400) ABS NEUT CT 19.02H (1.70-7.80) K/cmm ABS LYMPH CT 1.05 (1.00-4.80) K/chun ABS MONOCYTE CT .84 (.00-1.00) K/chun ABS EOS CT .00 (.00-.45) K/ChUn ABS BASO CT .00 (.00-.20) K/extra MATURE NEUT 91 % LYMPH,NORMAL 5 % MONO 4 f % RDW-SD 39.6 39.5 (37.0-51.0) fL RDW-CV 12.6 12.7 (11.0-16.0) % RBC MORPH Normal Normal INC BANDS Present* Date: 02/16/01 02/17/01 Time: 1820 0144 Reference Units -- COA~'ULATION -- PROTHROMBIN 12.4 12.7 (10.5-13.5) sec INR 1.1 1.1 (1.0-1.2) PTT 22.2 24.4 (21.0-36.0) sec FIBRINOGEN 195 (170-440) mg/dL Legend: L = Low, H = High, * = Abnormal GROVE, MANDY FN # 065066151 (00000)000744757 16 YRS F 2405A TSIC RMOADS JR, JONATHAN E. AdmiSsion date: 02/16/01 Discharge date: 02/17/01 Do Not Discard If Initialed Printed: 02/22/01 0903 ~f,x.~ATOLO~Y COAGULATION (Continued) Page: Prin~d: 02/22/01 0903 GROVE, MANDY Test: BUN Units: mg/dL Low Normal: 4 High Normal: 27 02/16/01 1820 02/17/01 0144 9 Test: GLUCOSE Units: mg/dL Low Normal: 72 High Normal: 02/17/01 0144 126 H YORK HosPrEAL CLINICAL LABORATORY -- PINAL CHART - DO NOT DISCARD ~ (00000)000744757 16 FRS F 2405A TSIC RROADS JR, JONATHAN E. CREATININE TOTAL C02 CHLORIDE SODIUM POTASSIUM mg/dL mmol/L n~ol/L mmol/L n~nol/L 0.8 21 96 133 3.4 1.~ 32 110 145 5.3 0.? L 26 0.6 L 25 101 132 L 3.7 Date: 02/16/01 02/17/01 Time: _~ 0144 -- ROUTINE __ . Reference Units BILIRUBIN, TOTAL 0.8 0.7 (0.3-1.2) mg/dL ALK PHOS 78 68 (40-110) U/L ALT 34 29 (13-46) U/L AST 55H 38H (14-37) U/L CK 775H 673H (21-215) U/L AMYLASE 43 28 (25-115) U/L ALBUMIN 3.39L (3.40-5.00) g/dL CALCIUM 9.3 (8.4-10.2) mg/dL IONIZED CALCIUM 1.17 (1.12-1.30) mmol/L PHOSPHORUS 3.9 4.3 (2.4-4.7) mg/dL MAGNESIUM 1.7L 1.?L (1.8-2.5) mg/dL Legend: L = Low, H = High GROVE, MANDY FN # 065066151 Do Not Discard If Initialed Printed: 02/22/01 0903 (00000)000744757 16 YRS F 2405A TSIC RHOADS JR, JONATHAN E. Admission date: 02/16/01 Discharge date: 02/17/01 (Continued) Page: 2 ELECTROLYTES CHEMISTRY C~4ISTRY Printed: 02/22/01 0~0~ ~ROVE, M~NDY Date: 02/16/01 Time: 1820 -- ENDOCRINOLOGY -- PREGNANCY SCRN Negative YORK HOSPrFAL CLINICAL LABORATORY -- ~AL CHART - DO NOT DISCARD -- (00000)000744757 16 YRS F 2405A TSIC Date: 02/17/01 Time: 0144 PREALBUMIN ~ 22.4f 02/17/01 0144 Note: Reference range change effective 12/27/00. Date: Time: 02/16/01 1820 -- ALCOHOL T~BTI~ -- ALCOHOL SCREEN I~ROADS JR, JONATHAN E. Date: 02/16/01 Time: 1820 -- MOLECULAR DIAgNOSTICS -- FACT V MbT GENO WILDTYPEf Reference Units Reference Units (18.0-35.7) mg/dL Reference Units 0 (0-0) mg/dL 02/16/01 1820 The Factor V Leiden allele was not detected. Reference Units Legend: f = Footnote ~ = PREALBUMIN Performed at GROVE, 14ANDY FN % 065066151 Do Not Discard If Initialed Printed: 02;22/01 0903 C~STRY Central Pennsylvania Alliance LaboratoryYork, PA 17403 (00000)000744757 16 YRS F 2405A TSIC P, HOADS JR, JONATHAN E. Admission date: 02/16/01 Discharge date: 02/17/01 (Continued) Page: ELECTROPHORESIS TOXICOLOGY GENETIC TESTING Printed: 02/22/01 O903 YORK HOSPITAL CLINICAL LABORATORY -~ FINAL CHART - DO NOT DISCARD ~ Page: 4 (00000)000744757 16 YRS F 2405A TSIC PJi0ADS JR, JONATHAN E. FACT V MUT GENO (06/14/99 ........... ., ............. Interpretation: The Factor V Leiden allele (R506Q mutation) is represented by a single nucleotide change in the normal DNA sequence of either one or both copies (alleles} of the factor V gene. This mutation renders the factor V protein resistant to cleavage by activated protein C. Heterozygotes for the Factor V Leiden allele are at 7 fold increased relative risk for thrombosis, homozygotes are at 90-100 fold increased relative risk. The test employs enzymatic digestion of polymerase chain reaction (PCR) amplified DNA to detect the RS06Q mutation and is highly accurate. Rare diagnostic errors may occur due to the presence of DNA po lymorphi sins. This test result or one or more of its components was developed and its performance characteristics determined by the Molecular Diagnostics Laboratory at York Hospital. It has not been cleared or approved by the U.S. Food and Drug Administration (FDA). The FDA has determined that such clearance or approval is not necessary. Date: 02/16/01 Time: 1831 -- C.~.(iSTRY -_ pH 7.52H pCO2 27L NA 139 K 4.2 CL 104 BUN 12 GLUCOSE 116H HCT 39 Reference Units (7.35-7.45) (35-45) mmHg (138-146) mmol/L (3.5-4.9) maol/L (98-109) mmol/L (8-26) mg/dL (70-105) mmol/L (38-51) % Legend: L = Low, H = High GROVE, MANDY FN # 065066151 DO Not Discard If Initialed Prin=ed: 02/22/01 0903 (00000)000744757 16 YRS F 2405A TSIC RROADS JR, JONATHAN E. Admission date: 02/16/01 Discharge date: 02/17/01 (Continued) Page: POINT OF CARE Print&l: 02/22/01 0903 (- YORK HOSPITAL CLINICAL LABORATORY --- FINAL CHART - DO NOT DISCARD., ~'IAY (i ~. 2001 Page: 5 GROVE, I~ANDY Date: 02/16/01 Time: 1833 (00000)000744757 16 YRS F 2405A TSIC BROADS JR, JONATHAN ~.. -- Blood Group and Type -- ABO and Rh 0 POS -- A~til~d~ ~creen an~ Identi~ication -- ANTIBODY scREEN Negative CBC WITHOUT DIFF 02/17/01 Duplicate order received GROVE, MANDY FN # 065066151 (00000)000744757 16 YRS F 2405A TSIC BROADS JR, JONATHAN E. Admission date: 02/16/01 Discharge date: 02/17/01 Do Not Discard If Initialed Printed: 02/22/01 0903 BLOOD BANK ** End of Report ** Page: CANCELLED ORDER Patient Location: 2405A Status: I MFID: S197662130 TSIC MRN: 000744757 GROVE,MANDY DOB: 12-20-1984 SEX: F Phone: (717)423-6118 York Health System Imaging Services York, Pennsylvania 17405 IMAGING REPORT 2872203 02-16-2001 2033 Requested by: PELVIS COMPLETE, MIN 3 VIEWS Diagnosis: TRAU~ MVA PELVIC FX CLAVICLE 7X SIMLOTE KAPIL MD H1scory: TRAUMA Final Report PELVIS, TWO VIEWS: CLINICAL HISTORY: TRAUMA. Contrast material was injected through a Foley catheter into the bladder. Two images were taken. It showed no evidence of abnormal contrast extravasation. The bladder was displaced to the right side of the pelvis. The comminuted fracture involving the left iliac, ischium, and pubic bones are again noted. IMPRESSION: 1. Comminuted fracture involving the left iliac, ischium and pubic bones. wail. There is no evidence of bladder lacerauion. END OF IMPRESSION Dictated by: Shi Cynthia MD /electronically signed Finalized on: 02-17-2001 This copy printed: 02-17-2001 14:24 [U: TSIC] PELVIS COMPLETE, MIN 3 VIEWS Patient Location: 2405A Status: I MFID: S197662130 TSIC MR/g: 000744757 GROVE,MANDY DOB: 12-20-1984 SEX: Phone: (717)423-6118 York Health System Imaging Services York, Pennsylvania 17405 IMAGING REPORT 2872176 02-16-2001 1815 Requested by: TOMAN JEFFREY R CHEST FRONTAL VIEW/PORTABLE/ MD Diagnosis: TRAUMA MVA PELVIC FX CLAVICLE FX History: TRAUMA,MVA Final Report CHEST, ONE VIEW PORTABLE: CLINICAL HISTORY: Trauma, MVA. A single portable AP view of the chest was obtained. No prior study is available for comparison. There is a comminuted fracture involving the mid third of the left clavicle. The lungs are clear. No rib fractures are seen. The mediastinum and the cardiac silhouette are normal. IMPRESSION: A comminuted fracture involving the mid third of ~he left clavicle. Dictated_by:. ~hJ~Cy~i~ ~D~e~e~p.n.~q~!_~y__s!g~~ ......... Finalized on: 02-16-2001 This copy printed: 02-16-2001 23:45 [U: TSIC] CHEST FRONTAL VIEW/PORTABLE/ Patient Location: 2405A Status: I MFID: S197662130 TSIC MRN: 000744757 GROVE,MANDY DOB: 12-20-1984 SEX: F Phone: (717)423-6118 York Health System Imaging Services York, Pennsylvania 17405 IMAGING REPORT 2872200 02-16-2001 2033 Requested by: THORACIC SP AP/LAT/SWIMMERS 2872202 02-16-2001 2033 Requested by: LUMBAR SPINE AP/LAT SIMLOTE KAPIL MD SIMLOTE KAPIL MD Diagnosis: TRAUMA MVA PELVIC FX CLAVICLE FX History: TRAUMA Final Report THORACIC SPINE, THREE VIEWS AND LUMBAR SPI~C.E, TWO VIEWS: CLINICAL HISTORY: MVA. There is mild irregularity of the superior end plate of Tll, suspicious for mild compression fracture. The vertebral height is slightly decreased. The lumbar spine is normal. Mild scoliosis is noted in the superior aspect of the thoracic spine. No bony abnormality is seen. There is no evidence of spondylolisthesis or spondylolysis. IMPRESSION: I ........ lu,,~bar --~ AP ~d ....... - ....... 2. Irregularity of the superior end plate of Tll is suspicious for mild compression fracture. END OF IMPRESSION E, lc5ated by: Shi Cynthia MD /electronically signed Finalized on: 02-17-2001 This copy printed: 02-17-2001 14:24 [U: TSIC] LUMBAR SPINE AP/LAT Patient Location: 2405A Status: I MFID: S197662130 TSIC MRN: 000744757 ~vl~ ~f. GROVE, MANDY ' ~; '~ ~00; DOB: 12-20-1984 SEX: F Phone: (717) 423-6118 York Health System Imaging Services York, Pennsylvania 17405 IMAGING REPORT 2872196 02-16-2001 1949 Requested by: CT ENHANCED ABDOMEN 2872199 02-16-2001 1949 Requested by: CT ENHANCED PELVIS WITH ABD RHOADS JR JONATHAN E MD RHOADS JR JONATHAN E MD Diagnosis: TRAUMA MVA PELVIC FX CLAVICLE FX History: trauma multiple injuries Final Report CT ENHANCED ABDOMEN AND PELVIS: CLINICAL HISTORY: MVA. Helical CT of the abdomen and pelvis was obtained after IV administration of 150 cc of Omnipaque. Oral contrast was given to opacify the bowel. Evaluation of lung bases demonstrates no evidence of pneumothorax or contusion. The liver, spleen, pancreas, adrenals, and kidneys are intact with a normal appearance. The small and the large bowel are unremarkable. The:-e i= a commip~,ted fracture in~ro]~r~n~ the left iliac bone wi-~h bone fragment displacement mediallv~ ~g left pubic rami and symphysis pubis are also fractured. There is a moderate-to-large sized hematoma involving the Retzius space. The urinary bladder is There is a nondisplaced fracture involving the right sacral ale. Increased presacral soft tissue density indicates possible hemorrhage. CT ENI4ANCED PELVIS WITH AJBD Patient Location: 2405A Status: I MFID: S197662130 TSIC MR/g: 000744757 GROVE,MANDY DOB: 12-20-1984 SEX: F Phone: (717)423-6118 York Health System Imaging Services York, Pennsylvania 17405 IMAGING REPORT 287219~. 02-16-2001 1949 Requested by: RHOADS JR JONATHAN E CT E~IHANCED PELVIS WITH ABD MD The left iliac artery and vein enhance in a normal fashion. There is no evidence of abnormal contrast extravasation in the left pelvic hematoma. A Foley catheter is in place. IMPRESSION: 1. No evidence of visceral laceration. 2. A comminuted, displaced fracture involving the left iliac, ischium, and left pubic bones. It is associated with a left pelvic wall hematoma. 3. A nondisplaced fracture involving the right iliac ala. END OF IMPRESSION Dictated by: Shi Cynthia MD /electronically signed Finalized on: 02-16-2001 This copy printed: 02-16-2001 23:46 [U: TSIC] CT ENHANCED PELVIS WITH ABD Patient Location: 2405A Status: I MFID: S197662130 TSIC MR_N: 000744757 GROVE,MANDY DOB: 12-20-1984 SEX: F Phone: (717)423-6118 York Health System Imaging Services York, Pennsylvania 17405 IMAGING REPORT CT U~ENFIANCED HEAD ~ciLtes ~ed b'z i~£{ODES JOSHUA T MD Diagnosis: TRAUMA MVA PELVIC FX CLAVICLE FX History: trauma mrs Final Report CT SCAN OF BP, AIN: CODE: 70450 INDICATION: MVA. Multiple CT images of the brain were performed without intravenous contrast enhancement. There is no evidence of acute hemorrhage, infarction, or mass effect. No unusual calcifications are noted. The ventricular system appears normal. IMPRESSION: Ncrmal unenhanced cranial CT scan. END OF IMPRESSION Dictated by: Shi Cynthia MD /electronically signed ......... Fi~i~.~d-~.v--0-2~-I7r.200i This copy printed: 02-17-2001 11:29 [U: TSIC] CT UNENHANCED HEAD REQUESTING PHYSICIAN: CONSULTING PHYSICIAN: Steven K. Groff, M.D. REASON FOR CONSULTATION: Chief Complaint: Left clavicle fracture, left acetabular fracture. The patient is a teenage female who was involved in a high speed motor vehicle accident. The patient was a restrained passenger in a vehicle which was involved in a high energy collision. She was brought to the York Hospital Emergency Room as a Trauma patient secondary to orthopedic injuries. The patient was admitted to the Trauma Service and found to have a left clavicle fracture and a left acetabular fracture. Orthopedic consultation was recommended. The patient is examined in the hospital Intensive Care Unit. She is awake and responsive and responds to commands appropriately. She is complaining of pain in her left shoulder. Examination of the upper extremities revealed tenderness and pain as well as swelling about the left clavicle. She has normal neurovascular of the upper extremities including intact distal pulse and normal strength. The pelvis is stable except for pain about the left hip. Lower extremities reveal intact distal pulses, she has normal strength in the toes with dorsiflexion and plantar flexion. She is able to maintain extension of both knees to gravity. She has pain with any range of motion of the left hip. Sensation is intact to light touch throughout. Radiographs - AP radiographs reveal a displaced left acetabular fracture involving both anterior and posterior columns. There is a coronal fracture through the dome of the acetabulum. IMPRERSIONS: 1. 16-year-old white female with displaced acetabular fracture, left clavicle fracture. 1. I had an extensive discussion with the patient and her family regarding her findings. I have reviewed the radiographs and discussed with them in detail. I have recommended that the YORK HOSPITAL YORK, PA 17405 NAME: GROVE, MANDY MRN: 000744757 DOB: 12/20/1984 ROOM #: 2405A ORTHOPEDIC CONSULTATION REPORT CONSULT DATE: 02/17/2001 PAGE 1 CONFIDENTIAL This information is fumished on the condition that it will be used only for the purpose for which it was requested. Any other use or disclosure of this information requires the express authod_~_~on of York Health System. CHARTCOPY patient be transferred to Dr. Spence Reid's service at Hershey Medical Center. He will perform definitive open reduction, internal fixation of the patient's displaced acetabular fracture. The patient will be placed in Buck's traction over night and will be transferred to Hershey Medical Center. D: 02/17/2001 17:24:26 SKG T: 02/19/2001 09:14:09 msm R: CC: Steven K. Gruff, M.D. NAME: GROVE, MANDY ORTHOPEDIC CONSULTATION 'REPORT MRN: 000744757 CONSULT DATE: 02/17/2001 PAGE 2 CONFIDENTIAL This information is f~mished on the condition that it will be used only for the purpose for which it was requested. Any other use or disclosure of this information requires the express authorization of York Health System. CHART COPY I;l~, ~e744'~7 248~-A PO~ ~44 lillliiiii DR. ~ J'/"~*'" REQUESTS DR. ~o.~o. co.~.~ ~ .~-~/~ ~ ?/AY O ,j 2001 YORK HOSPITAL YORK, PENNSYLVANIA 17405 CONSULTATION REPORT Date & Time ~.Rec.~.ested: Routine consult to be completed within 24 hours of physician notification. Consultaltons requiring more immediate attention require personal conversation between requestor and consultant, [] If checked, do not change or initiate therapy. [] If checked, do not order testing. [] Call me when consult completed: Phone REPORT: Pager # Date & lfme consultant notified: Consultant Signature ~o.u NO. s=46 (.EV. Date & Time Completed EMERGENCY DEPARTMENT GROVE~ PO BOX 144 ~s I ~o 1.°/S0/84 EMPtOYER YORK HOSPITAL 065066 YORK, PA 17405 FINANCIAL NO. 1197_66_:=,130 'NOMOUAL~TH.^~EN~ soc. s~c. NO. WEST SHORE ~E~ I ~UP~ C~P~ ~S~C~ I~E I~0. AUTO-ALL OTHERS CHIEF COMP~INT: MVA PELVIC FX CLAVICLE FX ~ ,,.~.q,~ TIME REG~T-m~=O ROOM~EM~ TIME 18:05 PM T P RR BP WT ALLERGIES: 02 SAT LMP 6 506 6 I 5 1 PEDS CRITICAL U 141Y 07/17/01 £M£EGEHCY 00074475? -p PMH: MEDS: TRIAGE CLASS: INITIAL LAB ORDERS: [] CBC [] ELECTROLY; =-S [] GLUCOSE [] LIVER PROFILE [] ABGS I--I SERUM PREG ADDITIONAL ORDERS: [] CREATININE[] EKG [ [] AMYLASE [] LIPASE [] U/A [] CCMS [] CATH [] PROCEDURES: [] YES [3 NO [] NOTE DICTATED n ATTENDING NOTE NURSING NOTE [] REVIEWED BED ORDER BED ASSIGNED TIME NOTIFIED TI.~ME TMEBED READY PRIMARY RN SIC3NATURE;~_,ti~ i~ ~J~ ~/-'7IDATE 4003-1 {0~/00) ~ i [] MRSA [] VRE ADMIT: .~'~PATIENT [] TRANSFER CARE TO: ED JR RESIDENT/ STUDENT: ED SR RESIDENT: ATTENDING: CONSULTANT: TO FLOOR ROOM TIME , INO. \ /I TIME DISCHAR_GI~D [] LATEX SENSmVITY [] EOC [] EPS /~'~"J~--~' CONDITION MEDICAL RECORD CHIEF COMPLAINT: HISTORY OF PRESENT ILLNESS: DIAGNOSIS: Trauma transfer. A 16-year-old female, who is a trauma transfer from Chambersburg, who presents to the Emergency Department. She has a pelvic fracture and a clavicle fracture. Trauma was called when the patient arrived to the Emergency Department. Please refer to the Resident's dictation. Trauma, motor vehicle accident, pelvic fracture, clavicle fracture. D: 02/1712001 00:02:58 NAR T: 02/20/2001 11:36:05 map R: CC: Noelle A. Rotondo, D.O. NAME: GROVE, MANDY MRN: 000744757 DOB: 12/20/1984 ED VISIT DATE: 02/16/2001 ROOM #: 2405A YORK HOSPITAL YORK, PA 17405 EMERGENCY DEPARTMENT ATTENDING NOTE PAGE 1 CONFIDENTIAL This information is furnished on the condition that it will be used only for the purpose for which it was requested. Any other use or disclosure of this information requires the express authorization of York Health System. CHARTCOPY EXHIBIT "C" CERTIFICATE OF ',OOVE GE The undersigned is a Claim 1 [] State Farm County [] State Farm Lloyds, Inc. [] State Farm Indemnity Company [] State Farm Florida Insurance Company This certifies that policy number 1984 Dodge Charger and was in effect on the accident date of 6853-448-38W (002) , covering a , was issued to February 16, 2001 Rose Lauver · The coverages and limits of liability for this policy on that date were A 15/30/25,C2 10~000~U-BI "The effective policy period was 2-5-01 to 8-5-01." State of County of 15/30,F Pennsylvani(! ) )ss. Frank l i n .) 1500,W 15/30,Z Subscribed and sworn to before me this 7th day of June ,(Year) 2001 Notary Public My Commission Expires: Carol D. H~l)augh. Nolary Public Chambersl~rg Boro~ Franklin County Member. Pen'rmylvanla Association of Notarlel 180-5276.~ Rev. 03-1999 Printed in U.S.A. EXHIBIT "D" RELEASE AND SETTLEMENT AGREEMENT The undersigned, CHARLES GROVE and DONNA GROVE, individually, and as the parents and full legal guardians of the minor MANDY GROVE (hereinafter referred to as "Releasors"), declare that, for and in consideration ofTEN THOUSAND and NO/100 DOLLARS ($10,000.00), the receipt of which is hereby acknowledged, for themselves, their heirs, administrators, successors and assigns, and for Mandy Grove, her heirs, administrators, successors and assigns do forever release, acquit and discharge ROSE LAUVER, KAREN LAUVER and STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, their predecessors, heirs, successors and assigns, their officers, directors, owners, employees and agents, and all other persons, firms, corporations, associations, partnerships, affiliates, subsidiaries and entities whatsoever (hereinafter collectively referred to as "Releasees"), of and from any and all actions, causes of actions, claims, demands, damages, costs, loss of services or use, expenses and compensation of whatever kind or nature on account of or in any way growing out of any and all personal injury and property damage and consequences thereof, and for any damages which may develop at some time in the future, and for any and all unforeseen developments arising from known or unknown injuries or property damage, including all claims resulting or to result from an accident which occurred on or about February 16, 2001, while traveling on Gilbert Road at or near the intersection of Airport Road in Southampton Township, Cumberland County, Pennsylvania. It is expressly understood and agreed that this Release and Settlement Agreement is intended to apply to and does apply to not only all known injuries, losses and damages, but further operates to release, acquit and forever discharge any and all claims or actions for any further injuries, losses and damages which arise from or may be related to the occurrence set forth in the lawsuit noted hereinabove, even if said injuries, losses, and damages are unknown at the this time and develop in the future. Page 1 of 3 It is understood and agreed that this settlement is a compromise of a doubtful and disputed claim, and that payment made is not to be construed as an admission of liability on the part of the parties hereby released, and that said Releasees deny liability and intend merely to finalize and avoid litigation and buy their peace It is further understood and agreed that this is the complete Release and Settlement Agreement, and that there are no written or oral understandings, or agreements, directly or indirectly connected with this Release and Settlement that are not incorporated herein. It is expressly understood and agreed that this Agreement and Release shall be binding upon and inure to the benefit of the successors, assigns, heirs, executors, administrators, and legal representatives of both Charles and Donna Grove, individually, and as the parents and full legal guardians of the minor, Mandy Grove and Mandy Grove, individually, and the Releasees. CHARLES and DONNA GROVE, INDIVIDUALLY, AS THE PARENTS AND FULL LEGAL GUARDIANS OF THE MINOR, MANDY GROVE, HEREBY DECLARE THAT THE TERMS OF THIS RELEASE AND SETTLEMENT AGREEMENT HAVE BEEN COMPLETELY READ; THAT THEY HAVE HAD THE OPPORTUNITY TO DISCUSS THE TERMS OF THIS SETTLEMENT WITH LEGAL COUNSEL OF THEIR CHOICE; AND THAT SAID TERMS ARE FULLY UNDERSTOOD AND VOLUNTARILY ACCEPTED FOR THE PURPOSE OF MAKING A FULL AND FINAL COMPROMISE OF ANY AND ALL CLAIMS ON ACCOUNT OF THE DAMAGES AND LOSSES MENTIONED ABOVE AND FURTHER FOR THE EXPRESS PURPOSE OF PRECLUDING FOREVER AND FURTHER OR ADDITIONAL SUITS BY THEMSELVES OR THE MINOR, MANDY GROVE, ARISING OUT OF THE AFORESAID CLAIMS. [Remainder of page intentionally left blank] Page 2 of 3 of IN WITNESS WHEREOF, we have hereunto set our hands and seals this 2002. day CAUTION, READ BEFORE SIGNING Charles Grove, individually and as the parent and full legal guardian of the minor, Mandy Grove On this day of 2002, before me personally appeared Chades Grove, known to me as the person who executed the foregoing Release, and who acknowledged to me that he voluntarily executed same. NOTARY PUBLIC Donna Grove, individually and as the parent and full legal guardian of the minor, Mandy Grove On this day of 2002, before me personally appeared Donna Grove, known to me as the person who executed the foregoing Release, and who acknowledged to me that she voluntarily executed same. NOTARY PUBLIC Page 3 of 3 IN RE: ESTATE OF MANDY GROVE, a minor, by and through her parents and natural guardians, CHARLES and DONNA GROVE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - CIVIL DIVISION ENTRY OF APPEARANCE Please enter my appearance in the above-captioned action. Date: Respectfully submitted, McKissock & Hoffman, P.C. Attorney I.D. No. 36818 Edwin A.D. Schwartz Attorney I.D. No. 75902 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 IN RE: ESTATE OF MANDY GROVE, a minor, by and through her parents and natural guardians, CHARLES and DONNA GROVE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY - CIVIL DIVISION No. 02-0978 (Civil Term) ORDER AND NOVV, this t~, day of !~2002~upon consideration of the Petition to Approve Minor's Compromise, it is hereby ORDERED and DECREED that Petitioners are authorized to enter into settlement with Rose Lauver, Karen Lauver and State Farm Mutual Automobile Insurance Company in the gross sum of Ten Thousand Dollars ($10,000.00). State Farm Mutual Automobile Insurance Company shall forward all settlement drafts to Petitioners for proper deposit as set forth below. IT IS FURTHER ORDERED and DECREED that the settlement proceeds shall, in their entirety, be placed in an FDIC insured institution and protected from withdrawal until the minor reaches the age of majority or until further approval of Court is obtained by Petitioners. Petitioners are hereby authorized to execute any and all documentation necessary for the purchase of a savings certificate of deposit from a federally insured bank or savings institution in the sum of Ten Thousand Dollars ($10,000.00), with the funds payable to the minor upon reaching age of majority. The certificate shall be titled and restricted as follows: "Mandy Grove, a minor, not to be redeemed except for renewal in its entirety, not to be withdrawn, assigned, negotiated or, otherwise alienated before the minor attains the age majority except upon prior Order of this Court." In the Alternative, Petitioners are authorized to execute any and all documentation necessary to open a savings account in a federally insured bank or saving institution in the amount of Ten Thousand Dollars ($10,000.00) which shall be titled and restricted as follows: "Mandy Grove, a minor, not to be withdrawn before the minor attains the age of majority, except for the payment of city, state and/or federal income taxes on the interest earned by the savings account, or upon prior Order of Court." IN RE: ESTATE OF MANDY GROVE, a minor, by and through her parents and natural guardians, CHARLES and DONNA GROVE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - CIVIL DIVISION No. 02-978 Civil Term PRAECIPE Please mark the above captioned matter as settled and satisfied and dismissed with prejudice. Respectfully submitted, Charles Grove, as the parent and legal guardian of the minor, Mandy Grove Donna (~r(~ve, a"s the parent~nd legal guardian of the minor, Mandy Grove On this A~, day of G/~002, before me personally appeared Charles Grove and Donna Grove, known to me as the persons who executed the foregoing Praecipe, and who acknowledged to me that they voluntarily executed same. I Township of Susquehanna, Dauph n Count/I NOTARY PUBLIC I My Commission Expires May 9, 2005 I Member, Pennsylvania Association of Notaries