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. STEFANON &: GLACE
407A~~~~~1rr ORIGtNAl'
POST OPFlCE BOX 12027
HARRISBURG. PENNSYLVANIA 17108-2027
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TRUDELL V. MAGNELLI and LINO A. : IN THE COURT OF COMMON PLEAS
MAGNELLI, her husband, : CUMBERLAND COUNTY PENNSYLVANIA
Plaintiffs .
.
: CIVIL ACTION LAW
v. . Cu..J Je.(,~
. q5 - /~OD
. NO.
.
RICHARD J. PATTERSON, M.D., .
.
Defendant . JURY TRIAL DEMANDED
.
PRAECIPE FOR ISSUANCE OF WRIT OF SUMMONS
TO THE PROTHONOTARY:
Issue a Writ of Summons in the above captioned action against
Defendant Richard J. Patterson, M.D., and deliver that Writ to the
Sheriff for service at the address set forth below:
RICHARD J. PATTERSON, M.D.
875 Poplar Church Road
Camp Bill, PA 17011
By
Street
17108-2027
DATE:
~-l9 .~S
407
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TRUDELL V. MAGNELLI and LINO A. . IN THE COURT OF COMMON PLEAS
.
MAGNELLI, her husband, I CUMBERLAND COUNTY PENNSYLVANIA
Plaintiffs .
.
. CIVIL ACTION LAW
.
v. .
.
. NO. 95-1600
.
RICHARD J. PATTERSON, M.D. , .
.
Defendant . JURY TRIAL DEMANDED
.
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint is served, by entering
a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims
set forth against you. You are warned that if you fail to do so
the case may proceed without you and a judgment may be entered
againsL you by the Court without furt11er notice for any money
claime" ir. the Complaint or for any othet:" claim or relief requested
by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT ImVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CM GET LEGl\L HELP.
COURT ADMINISTRATOR
CUMDER~lD COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
4TH FLOOR
CARLISLE, FA 17013
(717) 240-6200
'!'RUDELL V. MAGNELLI and LINO A. : IN THE COURT OF COMMON PLEAS
MAGNELLI, her husband, : CUMBERLAND COUNTY PENNSYLVANIA
Plaintiffs :
: CIVIL AC'rION J,AW
v. :
: NO. 95-1600
RICHARD J. PATTERSON, ~I.D. , .
.
Defendant . JURY TRIAL DEMANDED
.
COMPLAINT
1. Plaintiffs TRUDELL V. MAGNELLI and LINO A. MAGNELLI, are
adult individuals, husband and wife, who reside in the city of
lIarrisburg, Dauphin County, Pennsylvania.
2. Defendant RICHARD J. PATTERSOlf, M. D. , (hereinafter Dr.
Patterson) is an adult individual; a licensed practitioner of the
healing arts; a medical doctor speciali:dng in the field of
orthopedic surgery; with officen or principal place of business
located at 875 poplar Church Hoad, Camp lIill, Cumberland County,
Pennsylvania 17011.
3. On or about February 4, 1993 Plaintiff Trudell V. Magnelli
(hereinafter Mrs. Magnelli) came under the care and treatment of
Ur. Patterson fo~ a painful condition of her right foot.
4. Mrs. tlagnelli had injured her right foot \'lhen she twisted
her foot: while dt!occnding a stairway in ,1anuary of 1993, cllusing a
dislocation of the second metatarsophalangeal joint: of the right
foot.
1
5. Prior to this traumatic dislocation of the second toe of
the right foot, Mrs. Magnelli had not experienced pain, difficulty
in walking, abnormality of gait, inability to wear standard shoes,
or any other symptom or complaint.
6. In addition to the dislocation of the second toe of the
right foot, Mrs. Magnelli suffered from a severe hallux abducto
valgus deformity of the great toe of the right foot.
7. On April 2, 1993, Dr. Patterson performed surgery upon the
right foot of Mrs. Magnelli in the nature of a "Mann procedure" for
correction of the deformity of the great toe and a fusion with K-
wire fixation to correct the dislocation of the second toe.
8. Dr. Patterson was negligent in his care and treatment of
Mrs. Magnelli in each of the following respects:
(a) He failed to advise Mrs. Magnelli that the
dislocation of her second toe was the source of the
painful condition of her right foot from which she
suffered; and
(b) He failed to advise Mrs. Magnelli that the
dislocation of the second toe could be repaired
surgically or non-surgically without intervention
or repair of the deformity of the great toe; and
(c) He failed to properly perform the reduction of the
dislocation of the second toe in that he attempted
to immobilize the surgical correction using a K-
wire which was improperly placed in the second toe;
and
(d) He elected to correct the deformity of the great
toe utilizing the "Mann procedure", which surgical
procedure was contraindicated for a patient with
the degree of deformity suffered by Mrs. Magnelli;
and
(e) He failed to make an accurate diagnosis of the
deformities present in the right foot of Mrs.
Magnelli and failed to select appropriate operative
2
procedures intended to correct those deformities;
and
(f)
He failed to provide for post-operative bandaging
and support of the right foot which bandaging and
support may have maintained the degree of
correction which was achieved during the surgery;
and
He failed to obtain intra-operative and post-
operative x-ray examinations to determine whether
the K-wire pin in the second toe had been properly
placed; and
He undertook to repair the deformity of the great
toe which repair was unnecessary to relieve the
pain suffered by Mrs. Magnelli.
(g)
(h)
9. As the result of the aforesaid negligence of Dr.
Patterson, Mrs. Magnelli has suffered a recurrence of the deformity
of the great toe of her right foot, and a recurrence of the
dislocation of the second toe of her right foot, which has left her
foot in a condition as bad as, if not worse than, the condition in
which it was prior to Dr. Patterson's surgery.
10. As the result of the aforesaid negligence of Dr.
Patterson, Mrs. Magnelli underwent surgery on April 2, 1993 which
surgery was unnecessary, inappropriate, and destined to failure,
and which surgery caused her to suffer pain, aggravation,
inconvenience, temporary and permanent disability, and the loss of
life's pleasures, and to incur expenses for the surgery itself, and
for her post-operative care.
11. As the result of the recurrence of the deformities to her
right great toe and second toe, Mrs. Magnelli has suffered pain,
suffering, aggravation, inconvenience, temporary and permanent
disability, the loss of life's pleasures, and had incurred and will
3
continue to incur expenses for the care and treatment of those
deformities.
12. Since the time of the surgery performed by Dr. Patterson,
Mrs. Magnelli has constantly suffered and swelling of her right
foot accompanied by anxiety, mental and physical anguish, and
deterioration of the quality of her life in general.
13. As the result of the negligent surgery performed by Dr.
Patterson, Mrs. Magnelli will require extensive reconstructive
surgery to repair the deformities of her right foot, and the
likelihood of success of that reconstructive surgery is
significantly diminished because of the damage to the bones and
tissues involved in the joints, caused by the inappropriate and
negligent performance of Dr. Patterson's original surgery.
14. Mrs. Magnelli has incurred, and will continue to incur in
the future, medical expenses; loss of earnings; and loss of earning
capacity as the result of the injuries and damages suffered as
aforesaid.
15. The injuries and damages about which Plaintiffs complain
herein were caused by the aforesaid negligent acts and omissions of
Dr. Patterson.
16. Dr. Patterson was negligent in the care and treatment of
Mrs. Magnelli in that he failed to have and use the same knowledge
and skill, and to exercise the same care as that which is usually
had and exercised by practitioners in his field, in each of the
particulars set forth in the foregoing paragraphs.
17. Plaintiff Lino A. Magnelli has suffered the loss of the
4
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services, society, comfort, and companionship of his wife, which
damages will continue to occur in the future.
WHEREFORE, Plaintiffs demand judgment against Dr. Patterson
for damages in an amount in excess of $20,000.00, which amount
exceeds the limit for compulsory arbitration under the Local Rules
of the Court of Common Pleas of Cumberland County Pennsylvania,
plus interest and costs of suit.
DATE:
7,-~/-c;C;--
Street
17108-2027
5
VERIFICATION
The undersigned hereby verifies that the facts averred in the
foregoing Complaint are true and correct to the best of her
knowledge, information and belief.
This Verification is made subject to the penalties of 18 Pa
C.S.A. S 4904 relating to unsworn falsification to authorities.
crc"hJJ v, h~LliL.'
TRUDELL V. MA ELLI
DATE:
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MICHAEL W. McGUCKIN & ASSOCIATES,
BY: Michael W. MCGuckin
Identification No. 49464
Leigh A. J. Ellis
Identification No. 53229
1850 William Penn Way
suite 209
P.O. Box 10696
Lancaster, PA 17605-0696
(717) 390-3020
P.C. 60,336
Attorneys for Defendant:
Richard Patterson, M.D.
TRUDELL V. MAGNELLI and LINO A.
MAGNELLI, her husband
.
.
.
.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No. 95-1600 Civil Term
v.
:
.
.
RICHARD J. PATTERSON, M.D.
.
.
TWELVE JURORS DEMANDED
RULE TO FILE COMPLAINT
AND NOW, this 3/ ,l day of )1t /. d' , 1995, a Rule is
hereby granted upon Plaintiffs to file a Complaint against
defendant, Richard Patterson, M.D., herein within twenty (20)
days after service hereof or suffer the entry of a JUdgment of
Non Pros.
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MICHAEL W. McGUCKIN & ASSOCIATES,
BY: Michael W. McGuckIn
Identification No. 49464
Leigh A. J. Ellis
Identification No. 53229
1850 William Penn Way
suite 209
P.O. Box 10696
Lancaster, PA 17605-0696
(717) 390-3020
TRUDELL V. MAGNELLI and LINO A.
MAGNELLI, her husband
P.C. 60,336
Attorneys for Defendant:
Richard Patterson, M.D.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
No. 95-1600 civil Term
RICHARD J. PATTERSON, M.D.
TWELVE JURORS DEMANDED
ANSWER AND NEW MATTER OF DEFENDANT,
RICHARD J. PATTERSON, M.D. TO
PLAINTIFFS' COMPLAINT
1.
Denied.
After reasonable investigation, Defendant is
without knowledge or information sufficient to form a belief as to
the truth of the averments in paragraph one (1), and therefore,
demands strict proof thereof at trial, if relevant.
2. Admitted.
3. Denied as stated. It is admitted that on February 4,
1993, Plaintiff, Trudell V. Magnelli, presented to Dr. Patterson's
office with a chief complaint of right foot pain. The history
taken, the physical examination performed and the impression are
contained in a letter to Greg R. Ehgartner, D.O., dated February 5,
1993, which speaks for itself and is incorporated in its entirety
as an answer to the corresponding paragraph of the plaintiffs I
Complaint.
4. Denied as stated. See the history taken by Dr. Patterson
and documented in his letter to Dr. Ehgartner, dated February 5,
1993.
It is admitted that plaintiff-Wife related a history of
twisting her right foot coming down steps about a month prior to
that visit.
Dr. Patterson's physical examination showed a
metatarsus primus varus with a significant bunion deformity and
marked hallux valgus as well as a second metatarsophalangeal joint
dislocation.
5.
Denied.
After reasonable investigation, Defendant is
without knowledge or information sufficient to form a belief as to
the truth of the averments in paragraph five (5), and therefore,
demands strict proof thereof at trial, if relevant.
6. Admitted. It is also noted that the great toe underlapped
the second toe with clawing of the second toe which produced a
dislocation of the second MTP joint.
7. Admitted.
8(a-h). It is specifically denied that Defendant, Richard J.
Patterson, M.D., was negligent and careless in any manner in the
care and treatment of Plaintiff. All other allegations are denied
as conclusions of law. It is specifically denied that Richard J.
Patterson, M.D. was negligent in the following respects:
"(a) He failed to advise Mrs. Magnelli that the
dislocation of her second toe was the source of the
painful condition of her right foot from which she
suffered; and
(b) He failed to advise Mrs. Magnelli that the
dislocation of the second toe could be repaired
surgically or non-surgically without intervention
or repair of the deformity of the great toe; and
. (c) He failed to properly perform the reduction of the
dislocation of the second toe in that he attempted
to immobilize the surgical correction using a K-
wire which was improperly placed in the second toe;
and
2
(d)
He elected to correct the deformity of the great
toe utilizing the "Mann procedure", which surgical
procedure was contraindicated for a patient with
the degree of deformity suffered by Mrs. Magnelli;
and
(e)
He failed to make an accurate diagnosis of the
deformities present in the right foot of Mrs.
Magnelli and failed to select appropriate operative
procedures intended to correct these deformities;
and
He failed to provide for post-operative bandaging
and support of the right foot which bandaging and
support may have maintained the degree of
correction which was achieved during the surgery;
and
(f)
(g)
He failed to obtain intra-operative and post-
operative x-ray examinations to determine
whether the K-wire pin in the second toe had
been properly placed; and
He undertook to repair the deformity of the
great toe which repair was unnecessary to relieve
the pain suffered by Mrs. MagnellL II
(h)
9-10.
Denied.
It is specificallY denied that Defendant,
Richard J. Patterson, M.D., was negligent and careless in his care
and treatment of Plaintiff-Wife.
To the contrary, Defendant,
Richard J. Patterson, M.D., was at no time negligent and tended to
the plaintiff competently in accordance with accepted standards of
care consistent with the standards of the medical profession within
the community. Moreover, the allegations contained in paragraphs
nine (9) and ten (10) are conclusions of law to which the
pennsylvania Rules of civil procedure require no responsive
pleading, are therefore denied, and strict proof is demanded at
trial, if relevant. Additionally, all allegations of causation and
consequential injury are specificallY denied as improper legal
3
conclusions and strict proof is demanded at trial. with respect to
plaintiff's allegations of injury, after reasonable investigation,
Defendant is without knowledge or information sufficient to form a
belief as to the truth of the averments in paragraphs nine (9) and
ten (10) and therefore, demands strict proof thereof at trial, if
relevant.
11-12. Denied. After reasonable investigation, Defendant is
without knowledge or information sufficient to form a belief as to
the truth of the averments in paragraphs eleven (11) and twelve
(12), and therefore, demands strict proof thereof at trial, if
relevant.
13-14. Denied. It is specifically denied that Defendant,
Richard J. Patterson, M.D., was negligent and careless in his care
and treatment of Plaintiff-wife. To the contrary, Defendant,
Richard J. Patterson, M.D., was at no time negligent and tended to
the plaintiff competently in accordance with accepted standards of
care consistent with the standards of the medical profession within
the community. Moreover, the allegations contained in paragraphs
thirteen (13) and fourteen (14) are conclusions of law to which the
Pennsylvania Rules of civil Procedure require no responsive
pleading, are therefore denied, and strict proof is demanded at
trial, if relevant. Additionally, all allegations of causation and
consequential injury are specifically denied as improper legal
conclusions and strict proof is demanded at trial. With respect to
plaintiff's allegations of injury, after reasonable investigation,
Defendant is without knowledge or information sufficient to form a
4
belief as to the truth of the averments in paragraph thirteen (13)
and fourteen (14) and therefore, demands strict proof thereof at
trial, if relevant.
15-16. Denied. The allegations contained in paragraphs
fifteen (15) and sixteen (16) of the Complaint are conclusions of
law to which the Pennsylvania Rules of civil Procedure require no
responsive pleading, are therefore denied, and strict proof thereof
is demanded at trial, if relevant.
17. Denied. After reasonable investigation, Defendant is
without knowledge or information sufficient to form a belief as to
the truth of the averments in paragraph seventeen (17), and
therefore, demands strict proof thereof at trial, if relevant.
WHEREFORE, Defendant, Richard J. Patterson, M.D., respectfully
requests that this Court grant judgment in his favor and against
the Plaintiffs on the Complaint, together with costs, expenses and
attorney's fees.
NEW MATTER
18. Defendant, Richard J. Patterson, M.D., incorporates
herein by reference the averments contained in paragraphs one (1)
through seventeen (17) of the foregoing Answer as if fully set
forth herein.
19. The Plaintiffs' complaint fails to state a claim upon
which relief can be granted.
20. plaintiffs' claims are barred in whole or in part by the
doctrines of contributory/comparative negligence and assumption of
risk.
5
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21. Plaintiffs have not sustained any injuries cognizable
under Pennsylvania law as a consequence of answering Defendant's
alleged action.
22. Plaintiffs' claims are barred in whole or in part because
Plaintiffs' alleged injuries, if any, were not caused by the
actions of Defendant, Richard J. Patterson, M.D..
23. Plaintiffs' claims are barred because the Plaintiffs have
sustained no injuries in fact.
24. Plaintiffs' claims are barred by the applicable statute
of limitations.
25. Plaintiffs have not alleged facts sufficient to support
their allegations of negligence.
26. Plaintiffs' allegations are vague and insufficiently
pleaded under Pennsylvania law.
WHEREFORE, Defendant, RichardJ. Patterson, M.D., respectfully
requests that this Court grant judgment in his favor and against
the Plaintiffs on the Complaint, together with costs, expenses and
attorneys' fees.
Respectfully submitted,
--.-.-.-.".---
MICHAEL W. McGUCKIN & ASSOCIATES, P.C.
MICHAEL
LEIGH A.
Attorne
Richard
By:
6
60,336
VERIFICATION
Richard J. Patterson, M.D., hereby states that he is a
Defendant in this action and verifies that the statements made in
the foregoing Answer and New Matter to Plaintiffs' Complaint are
true and correct to the best of his knowledge, information and
belief. The undersigned understands that the statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
Dat.d, ~~ I' /11"
BY:
RICHARD J. PA.
.IIY D-
TRUDELL V. MAGNELLI and LINO A.
MAGNELLI, her husband,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
v.
CIVIL ACTION LAW
NO. 95-1600
RICHARD J. PATTERSON, M.D.,
Defendant
JURY TRIAL DEMANDED
PLAINTIFFS' REPLY TO NBK MATTER
AND NOW come Plaintiffs above named, by their Attorney,
Anthony Stefanon, and reply to the New Matter of Defendant as set
forth in the following paragraphs:
18. This paragraph contains no averments of fact to which
Plaintiffs may reply.
19. Denied. The averments of this paragraph are conclusions
of law requiring no answer by Plaintiffs.
20. Denied. The averments of this paragraph ar.e conclusions
of law requiring no answer by Plaintiffs.
By way of further
answer, Plaintiffs specifically deny any contributory or
comparative negligence and any voluntary assumption of any known
risk whatsoever.
21. Denied. The averments of this paragraph are conclusions
of law requiring no answer by Plaintiffs.
1
22. Denied. To the contrary, Plaintiffs' injuries were caused
by the acts and omissions of Defendant as set forth in Plaintiffs'
Complaint.
23. Denied. To the contrary, Plaintiffs suffered injuries as
set forth in Plaintiffs' Complaint.
24. Denied. The averments of this paragraph are conclusions
of law requiring no answer by Plaintiffs.
25. Denied. The averments of this paragraph are conclusions
of law requiring no answer by Plaintiffs.
26. Denied. The averments of this paragraph are conclusions
of law requiring no answer by Plaintiffs.
WHBREFORE, Plaintiffs demand judgment in accordance with the
prayer for relief set forth in their
By
Front Street
17108-2027
DATE:
7# 12 -75
2
VERIFICATION
The undersigned hereby verifies that the facts averred in the
foregoing Plaintiffs' Reply to New Matter are true and correct to
the best of her knowledge, information and belief.
This Verification is made subject to the penalties of 18 pa
C.S.A. S 4904 relating to unsworn falsification to authorities.
-'(~WII/\\,~~ .
TRUDELL V. MAGNE
DATE:
b-6 c> ~Cl.~
CERTIFICATB OF SERVICE
The undersigned hereby certifies that, on the date below he
served a true copy of Plaintiffs' Reply to New Matter, on each of
the persons listed below, at the addresses set forth, by First
Class united States Mail:
LEIGH A.J. ELLIS, Esquire
MICHAEL McGUCKIN, Bsquire
Michael McGuckin & Associates, P.C.
lS50 William Penn Way, Suite 209
P.O. Box 10696
Lancaster, PA 17605-0696
By
17108-2027
DATE:
7-(""t -9~
3
ELLIS & ASSOCIATES, P.C.
BY: Leigh A.J. Ellis
Identification No. 53229
1850 William Penn Way
suite 209
P.O. Box 10696
Lancaster, PA 17605-0696
(717) 390-3020
60,336
Attorneys for Defendant:
Richard Patterson, M.D.
TRUDELL V. MAGNELLI and LINO A.
MAGNELLI, her husband
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No. 95-1600 civil Term
v.
:
RICHARD J. PATTERSON, M.D.
TWELVE JURORS DEMANDED
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Defendant, Richard
J. Patterson, M.D., in reference to the above-captioned action.
ELLIS & ASSOCIATES, P.C,
;- VVL
LEIGW A.J. ELLIS
I
Atto ey for Defendant,
Rich rd J. Patterson, M.D.
DATED:
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TRUDELL V. MAGNELLI and LINO A.
MAGNELLI, her husband,
Plaintiffs
v.
RICHARD J. PATTERSON, M.D.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
CIVIL ACTION LAW
NO. 95-1600
.
: JURY TRIAL DEMANDED
PRAECIPE FOR SETTLEMENT AND DISCONTINUANCB
TO THB PROTHONOTARY I
Mark the above-captioned matter settled and discontinued.
DATE:
lo'Z,~ - 'J~
.
Street
17108-2027
CERTIFICATE OF SERVICE
;v. *'
- ~._.' .
The undersigned hereby certifies that, on the date below he
served a true copy of the Praecipe for Settlement and
Discontinuance on the person listed below, at the address set
forth, by First Class Mail:
Leigh A. J. Ellis, Esquire
Barley, Snyder, Senft & Cohen, LLC
126 East King Street
Lancaster, PA 17605-2893
1125497
407 No Street
P.O.
Harris urg, PA 17108-2027
(717) 232-0511
DATE:
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