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006866-0000IlM.,,'h ~8, 19931DWDIMIlI4~680
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HOLBERT G, MYERS and LYNDA R,
MYERS, in their own right and as parents
and natural guardians of ALLISON E.
MYERS, a minor,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
1'5 - 17j';; (It-U-I.-W~I.-
NO. (J
Petitioners
CIVil ACTION. LAW
vs.
LUCAS M. MilLER and JOHN W. MILLER,
Respondents
ORDER OF COURT
AND NOW. this .lS' dey of ~ ,,; I , 1995, upon consideration of the
foregoing Petition, it is hereby ordered that Petitioners be authorized to settle the claim of Allison E. Myers
against the Respondents for tha sum of $2,500,00 and execute a Release in favor of the Respondents
and their insurer.
The proceeds of settlement shall be deposited in a restricted bank account pursuant to the
requirements of Pa.R,C.P. No. 2039(b)(2), with no withdrawal to be made therefrom until Allison E. Myers
attains her maturity, except as authorized by prior Order of Court.
BY THE COURT,
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J.
APR 25 IllS AH '95
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006866-0000IlM.",h 28. 1995IDWD/M1l/42680
VERIFICA TION
The undersigned verify that the facts set forth in the foregoing Petition are true and correct, This
verification is made subject to the penalties of 18 Pa,C.S,A. ~ 4904 relating to unsworn falsification to
authorities.
Date:)f-'~~ :Pv/ Iff)
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Exhibit A
NllHE: HYERS, Jlr.r,T~
JIR I: 705844
DM'E: 11/08/93
DIDlGEH:Y 1llXH R!XXIlD
aI:IEI' CXJI1ILlUN1': M:lt:cr vehicle acx:ident.
'@JBIB'l'lEY ag l'RESENr ILUml8: 'lhis lS-year-old fBllllle was the lI'iM1e t.rcnt seat
~ passeJ'XJer in II mct:cr vehicle that was involved in II fairly signiricant: llCCi-
dent:. 'Ihe patient was net wearinq a seat belt. She did strike her fareheac1
against: the windshield. She did net lose canscicusness. She p1. sently is
taJdnq Erythrauycin. She has no known allergies.
PHmI:CAL EIl\KINl\TIaf: Physical examination reveals a well developed, well
nourishecl female M10 is fully ilIItlobilizecl on a lorq spine boarc1 and has cervi-
cal i""""'''i1 ha1:ion in place. VITAL SIGNS: Terrperature 36.4. C, p.l1se 100,
respiratory rate 20, blood pressure 140/80. HEENl': J:Y>.,"i1'llltion of the fore-
head reveals III.1ltiple abrasions with -""'""at1 pieces of glass in the fareheac1.
'Ibere is also a total of a~tely 6 an of laceration on the right lateral
forehead. Pupils are equal and reactive to light. Elct:ra.1'Y"I""'" lII.ISCles are
int.act. ~c membranes are clear without hemorrhage behin:i the tyupanic
membranes. ND:K: CaJpletely 5Ig;lle. 'Ibere is no ten:1erne.ss alOll:] the cervi-
cal spinal colUllU'1. 'Ihe trachea is in the midline. CHEST: Clear. CARDIAC:
U1remarkable, there is a ncrmal SI and Sz without 1IIlIrIDUl:S, gallops, or rubs.
AI!IXmN: Soft and ncnterx!er. '1here is no rellound or guardinq. 'Ibere is no
"hi""inal distention. ElcrREMITIES:J:Y>.,"h'lation of the extremities reve.ais
slight ten:1erne.ss at the I:Iase of the left thumb mt there is excellent ran;re
of mJt:ion, no swel.J.inq, and no deformity.
l'R(> .... -.IRE: 'Ihe forehead was thoroughly cleanse:! and. several pieces of glass
as large as Jon in length were remavecl fran the wcuncls. 'Ihe Io'OUnds were thor-
cughly irrigatec1 and 'n"'''1''ecl to have no residual foreign body. '!he lateral
laceration on the forehead was closed u1:ilizinq a total of 10 interrupted 5-0
Nylon sutures. 'Ihe patient was anesthetizecl with n xyloc:aine with epineph_
rine.
DD\GlnlIS: 1. M.1ltiple -""'""<>d foreign Ixxiies in the forehead.
2. Closure of approximately 6 an forehead laceration.
3. Evaluation for motor vehicle accident:.
4. Contusion of the left thumb.
~/PLl\N: 'Ihe patient was advised to have the sutures removed in 5 to 7
clays and was given a WalI'Xi care and head sheet.
MSL/vfj 0-11/08/93--1035
T-11/09/93
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CARLISLE HOSPITAL
EMERGENCY ROOM RECORD
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HIOil\EL 0--" M.D.
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AESTHETIC AND
RECONSTRUCTIVE SURGERY
OF CENTRAL PENNSYLVANIA, P.C.
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818 Belvlldere Slfeel
Carlisle, Pennsylvania 17013
717.249.0100
WILLIAM P. GRAHAM, III, M.D.
JOHN p, STAATIS, M.D.
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May 31, 1994
Allison Myers
1804 Walnut Bottom Road
Newville, Pa. 17241
Dear Miss Myers:
'I'his letter is in fo11owup to your recent consultation with me
regarding scars which you suffered during an automobile accident.
'!'he automobile accident occurred on 11/8/93. Apparently your
forehead hit the dashboard and you sustained multiple lacerations
of the forehead. '!'hese were repaired in the Emergency Room and a
fair amount of glass was removed. On examining you today, you have
scars which are in a variety of stage of healing. You have multiple
linear scars running in oblique direction of the forehead, near the
hairline, in the mid to left side of the forehead. 'I'here is a
noticeable scar just down and to the right and about a em. wide
which you tell feels like it has glass in it. 'I'here is an
additional scar which is L-shaped in fashion and is widened on the
right near the hairline. We discussed that it is best to determine
whether or not a scar revision is appropriate only after the scars
have completely matured. Right now the two scars which have not
matured are the ones on the right side of the forehead. Should
these require scar revision, it would be best done by cutting out
the scar on the right forehead near the scalp and reclosing that.
'I'he other scar would also be best attended to by cutting it out and
reclosing it. 'I'he other small scars would best be attended to by
dermabrasion.
'I'hese procedures can be done in the office under local anesthesia
in our Ambulatory Surgical Facility. 'I'hey would involve
dermabrasion of most of the forehead and excision and reclosure of
scars measuring approximately 4 em. total. 'I'he fees for this
procedure would be in two parts. 'I'he first part is the facility fee
which is $450.00. 'I'he surgeons fee would be approximately
$1,500.00.
As with any scar, there will be at least one year healing time
before you can determine exactly what the scars will look like.
During that time you should wear sunblock and moisturizers on these
scars.
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JUl 2 S 1994
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Sincerely,
~fS!cJ
~n-p. Stratis, M.D.
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Allison Myers
May 31, 1994
Page 2
nhould you have any questions after receiving this letter, please
feel free to contact me.
JPS/klp
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AESTHETIC AND
RECONSTRUCTIVE SURGERY
OF CENTRAL PENNSYLVANIA, PoCo
. .
WILLIAM P. GAAHAM, III, M,O.
JOHN P. STAATIS, M,O.
LAWRENCE K, THOMPSON, III, M,O.
4700 Union Oeposn Road, Sulle 240
Harrisburg, Pennsylvania 17111
7170541 04303
816 BelVedere SIree1
Carlisle, Pennsylvania 17013
717.249.0100
January 16, 1995
Russell Orlando
Claims Representative
susquehanna Claims Department
P. O. Box 6237
Harrisburg, Pa. 17112-0237
RE; Allison Myers
Claim No. A44l86032 U D4
Policy ~ BABAl157
Insured; John Miller Carpentry
Date of Loss; 11-8-94
Dear Mr. Orlando:
This letter is in followup to your request for information and
photographs of Allison Myers. As you know, I saw Ms. Myers in my
office initially in May of 1994 and subsequently in November of
1994. She was involved in a motor vehicle accident in which she hit
her forehead on the dash board and sustained laceratons of the
forehead from glass. She apparently had a repair of these
lacerations. It appears that most of her lace~ations are currently
stable. She has extensive scarring of the forehead which can be
appreciatp.d in her photographs, but specifically a noticable scar
on the right side approximately a em. long, L-shaped scar on the
right near the hairline and multiple small scars. I discussed with
the patient options for treatment and I suspect that a scar
revision would give the patient a significant chance for
improvement of her scars. They are currently stable and I do not
expect any changes in the scars in the future. The estimated cost
of the surgical fee would be $1,500.00 and a facility fee of
$450.00. This is if the procedure is done under local anesthesia.
If you require any additional information, please let me know.
JPS/klp
roc: Allison Myers
1804 Walnut Bottom Road
Newville, Pat 17241
sinceref:S~
lJf-. Stratis, -',D.-
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