Preview
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------------------X Index No.: 522897/2020
PATRICK FORD,
NOTICE OF EXPERT
Plaintiff(s), WITNESS PURSUANT TO
CPLR 3101(d)
-against-
YSMAEL A. TORRES,
Defendant(s).
---------------------------------------------------------------------------X File No.: 1084880
PLEASE TAKE NOTICE, of Defendant(s), YSMAEL A. TORRES, response to Plaintiff(s)
request for expert disclosure pursuant to section 3101(d) of the Civil Practice Law and Rules.
Defendants expect to call DR. DANA A. MANNOR, M.D. as an expert witness at the trial in
the above matter.
The subject matter upon which the examining physician is presently expected to testify is set
forth in detail in report(s) dated OCTOBER 26, 2022, attached hereto and incorporated by
reference herein.
The facts and opinions upon which the examining physician is expected to testify are based on
his/her physical examination of the plaintiff and/or his/her review of the plaintiff’s medical
records and upon all matters in evidence.
The grounds of the physician’s opinion come from his/her physical examination of the plaintiff
on the above date and/or his/her review of the plaintiff’s medical records and is set forth in the
attached report.
The Curriculum Vitae for the examining physician is annexed to the report.
Dated: Brooklyn, New York
November 3, 2022
BAKER, MCEVOY & MOSKOVITS
TO: CASSISI & CASSISI, PC
155 FIRST STREET, STE. 101
MINEOLA, NY 11501
(516) 294-5050
________________________________
BY: RONIT Z. MOSKOVITS, ESQ.
ATTORNEY FOR DEFENDANT(s)
5 BROADWAY, SUITE 3
FREEPORT, NY 11520
(212) 857-8230
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-----------------------------------------------------------------------------X Index No.: 522897/2020
PATRICK FORD,
Plaintiff(s),
-against-
YSMAEL A. TORRES,
Defendant(s).
-----------------------------------------------------------------------------X File No.: 1084880
NOTICE OF EXPERT WITNESS PURSUANT TO CPLR 3101(d)
BAKER, MCEVOY & MOSKOVITS
Attorneys for Defendant(s)
YSMAEL A. TORRES
Office and Post Office Address, Telephone Number
5 Broadway, Suite 3
Freeport, NY 11520
(212) 857-8230
To: CASSISI & CASSISI, PC
Attorney(s) for: PATRICK FORD
Service of a copy of the within
is hereby admitted.
Dated,
Attorney(s) for
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023
Dana A. Mannor, M.D.
Diplomate American Board of Orthopedic Surgery
2044 Ocean Avenue
Brooklyn, NY 11230
10/26/2022
Baker, McEvoy & Moskovits, P.C.
One Metro Tech Center, 8th Floor
Brooklyn, NY, 11201
Claimant: Ford, Patrick
Claim#: 1084880
RMA#: 033983
DOB: 02/19/1980
DOA: 02/19/2020
To Whom It May Concern:
I am a Board Certified Orthopedic Surgeon and have been asked to perform an orthopedic examination on
09/28/2022 regarding Mr. Patrick Ford at the Brooklyn, New York office. He presented his New York State
Driver License prior to this examination. Alla, a chaperone was present during this examination. He took a
train to this examination.
My findings are as follows:
ACCIDENT HISTORY:
The history was obtained from Mr. Ford who reports a motor vehicle accident occurring on 02/19/2020. At that
time, he reports he was the restrained driver when the vehicle was rear-ended.
Mr. Ford denies any loss of consciousness following the accident.
Mr. Ford reports that immediately he injured his low back and right ankle.
Mr. Ford reports that he went to the Good Samaritan Hospital that same day on his own. He was seen in the
emergency room where he was evaluated. He reports that diagnostic tests including X-rays were performed.
Mr. Ford reports that he was later released that same day.
Mr. Ford reports that he did not sustain any fractures or lacerations.
TREATMENT HISTORY:
Following the accident, Mr. Ford came under the care of various physicians. He reports that he was initiated
on a course of physical therapy, acupuncture treatment, massage therapy, and heat/ice treatment. He was
also treated with a TENS unit. He reports that the treatment received has been helpful. He reports additional
MRIs of the neck and back were performed. He underwent lumbar spine surgery in November 2020.
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
Claimant:
NYSCEF DOC. NO. 29 Ford, Patrick IME NYSCEF:
RECEIVED Report 02/06/2023
Claim #: 1084880 Page 2
DOB: 02/19/1980
DOA: 02/19/2020
Mr. Ford reports that he required the use of a cane as a result of the accident.
PRIOR MEDICAL HISTORY:
Mr. Ford denies any prior accidents or injuries. He was involved in a subsequent accident in July 2020 and
sustained concussion and whiplash injuries.
Mr. Ford reports that he does not have diabetes, hypertension, or asthma.
PRIOR SURGICAL HISTORY:
Mr. Ford underwent prior laminectomy.
CURRENT MEDICATIONS:
Mr. Ford reports that he is taking medications at the present time; however, he has not provided the name of
any medications.
Mr. Ford denies taking any medications today prior to this examination.
EMPLOYMENT HISTORY:
Mr. Ford reports that he was employed as a pastor at the time of the accident. He reports missing six weeks
from work due to the accident. He reports that currently he is working at the new job performing duties with
limitations. He reports that standing, sitting and lifting.
CURRENT COMPLAINTS:
Mr. Ford reports that he has complaints of pain in his low back and right ankle.
REVIEW OF SUBMITTED MEDICAL RECORDS:
The following medical records were available for my review:
1. Verified Bill of Particulars Index# No: 522897/2020.
2. Motor vehicle accident report dated 02/19/2020.
3. Police accident report dated 02/19/2020.
I am advised that there are no legally authenticated medical records were available for review. If any
authenticated medical records are available at any later time. I would be pleased to review them and advice
whether they have any effect on my opinion, which is based on today’s examination.
PHYSICAL EXAMINATION:
Mr. Ford reports that he is a 42-year old right hand dominant male, weighing 240 pounds, height 5 feet 11
inches with hazel eyes and brown hair.
Mr. Ford ambulates with a normal gait. He is in no acute distress and is able to understand and cooperate
during the examination.
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
Claimant:
NYSCEF DOC. NO. 29 Ford, Patrick IME NYSCEF:
RECEIVED Report 02/06/2023
Claim #: 1084880 Page 3
DOB: 02/19/1980
DOA: 02/19/2020
RANGE OF MOTION MEASUREMENTS:
The range of motion of the examined body parts were performed by the claimant. This is a subjective
maneuver on the part of the claimant. Measurements of the ranges of motion were performed by the examiner
using a hand-held goniometer where applicable. The measurement itself is, therefore, an objective
measurement of the claimant’s subjective efforts. The values of all the measurements were compared to the
normal active range of motion values according to the publication, “Guidelines to the Evaluation of Permanent
Impairment,” 5th edition, published by the American Medical Association.
ORTHOPEDIC EXAMINATION:
Lumbar Spine: Examination reveals a multiple posterior and anterior surgical scars. There is no muscle
spasm noted. Non tender to palpation.
Active range of motion is in flexion to 40 degrees (60 degrees normal), extension to 15 degrees (25 degrees
normal), and right lateral bending to 15 degrees (25 degrees normal) and left lateral bending to 15 degrees
(25 degrees normal).
Passive range of motion is same as active consistent with surgery. There is no atrophy, deformity or soft
tissue swelling noted.
Straight leg raise is negative bilaterally.
Grossly neurovascularly intact. Motor strength is 5/5 in all muscle groups tested. Deep tendon reflexes are 2+
and symmetric in the bilateral lower extremities. Heel-toe-walk is normal.
Right Ankle/Foot: There is no heat, swelling, effusion, erythema, atrophy, deformity or crepitus
noted. Non tender to palpation.
Active range of motion is in dorsiflexion to 20 degrees (20 degrees normal), plantar flexion to 40
degrees (40 degrees normal), inversion to 30 degrees (30 degrees normal), and eversion to 20
degrees (20 degrees normal).
Passive range of motion is full. There is no instability.
• Drawer’s – negative.
• Tinel’s– negative.
Grossly neurovascularly intact. Muscle strength is 5/5 in all muscle groups tested.
Left Ankle/Foot: There is no heat, swelling, effusion, erythema, atrophy, deformity or crepitus noted.
Non tender to palpation.
Active range of motion is in dorsiflexion to 20 degrees (20 degrees normal), plantar flexion to 40
degrees (40 degrees normal), inversion to 30 degrees (30 degrees normal), and eversion to 20
degrees (20 degrees normal).
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
Claimant:
NYSCEF DOC. NO. 29 Ford, Patrick IME NYSCEF:
RECEIVED Report 02/06/2023
Claim #: 1084880 Page 4
DOB: 02/19/1980
DOA: 02/19/2020
Passive range of motion is full. There is no instability.
• Drawer’s – negative.
• Tinel’s– negative.
Grossly neurovascularly intact. Muscle strength is 5/5 in all muscle groups tested.
IMPRESSION:
1. Status post lumbar spine fusion surgery in November 2020 – healed by exam.
2. Alleged right ankle/foot sprain/strain – resolved.
CONCLUSIONS:
The Bill of Particulars alleges that as a result of the accident on 02/19/2020 the claimant sustained injuries to
lumbar spine and right ankle/foot.
Today's examination indicates that the injured body parts alleged in the Bill of Particulars have resolved. The
claimant did not sustain any significant or permanent injury as a result of the motor vehicle accident on
02/19/2020. There are no objective clinical findings indicative of a present disability, and functional
impairment, which prevents the examinee from engaging in ADL, and usual activities including work, school,
and hobbies. The claimant is able to return to full duty work without restrictions.
Upon completion of the examination, Mr. Patrick Ford offers no complaints as a result of this examination and
left the examining area stable and unchanged.
If you have any further questions regarding Mr. Patrick Ford, please do not hesitate to contact me.
ATTESTATION:
I, Dana A. Mannor, M.D., being an Orthopedic Surgeon, duly licensed to practice medicine in the State of New
York, am not a party to this lawsuit, pursuant to the applicable provisions of the Civil Practice Law and Rules
section 2106, hereby affirm under the penalties of perjury that the statements contained herein are true and
accurate.
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
Claimant:
NYSCEF DOC. NO. 29 Ford, Patrick IME NYSCEF:
RECEIVED Report 02/06/2023
Claim #: 1084880 Page 5
DOB: 02/19/1980
DOA: 02/19/2020
I further certify that the signature appearing below is an electronic signature, and that term is defined by New
York State technology law 302(3) and 15 USA section 7001 ET. Seq.: that I have personally placed the within
electronic signature on this report; and that facsimiles and copies of this report shall be deemed originals.
Sincerely,
Dana A. Mannor, M.D.
Board Certified Orthopedic Surgeon
License No: 197496-1
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023
Dana A. Mannor, M.D.
Certryied Orthopedic Surgeon
Board
Curriculum Vitae
- _ .
Education:
Orthopaedic Center, Cincinnati, Ohio
Cincinnati Sportsmedicine and
1996 - 1998
- Director: Frank R. Noyes, M.D.
Sports Medicine Fellowship
at Brooklyn, Brooklynx New York
- 1996 State University of New York
1992
Department of Orthopaedic Surgery
Resident,
at Brooklyn, Bmoklyn, New York
- 1992 State University of New York
1991
Intern, Department of General Surgery
Medical Chicago, Illinois.
- 1991 Northwestern University School,
1987
M.D.
Program in Medicine,.Evanston, Illinois
Northwestern Uni versity Honors
1984 - 1987
B.S.
Honors:
Sportsmedicine Medicine Education and Reseamh
Foundation for
1997
Bundle Posterior Cruciate
Grant for "Blomechanics of Two
(FSMER)
Reconstruction"
Ligament Oraft
Spine Research Award, Scoliosis R.esearch
Russel A. Hibbs Clinical
1994
Society
Medical School, Baxter Research Scholarship
1987 Northwestern University
Northwestern University, Dean's List
1986
Appointments:
American of Orthopaedic Surgeons
2007- Board of Specialties Member, Academy
2009
State of Orthopaedic Surgeons
2006- Present Board Member, Ne w York Society
New York State Society of
2006- Present Chairwoman, Diversity Committee,
Orthopaedic Surgeons
Ruth Jackson Orthopaedic Society
2007- Board of Specialities Representative,
2009
1
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023
Ruth Jackson Orthopaedic Society
2007- 2009 Member at Large,
Ruth Jackson Orthopaedic Society
2004- Present Scientific Committee,
2007- Present Member at Large, FORUM
2000- Bylaws Committee, FORUM
2007 Chairwoman,
2000- 2004 Reviewer, Joumal of Arthroscopy
Management Committee, Lenox Hill Hospital
2001- 2002 Assurance/Risk
Quality
Selection Committee, Lenox Hill Hospital
2000- 2002 Orthopedic Surgery Residency
Northwestern University Medical School
- 1991 Executive Curricuhan Committee,
1988
Northwestem University Medical
- Assistant in Microanatomy,
1987 1988 Teaching
School
Research:
with Stuart L. Weinstein, M.D.
Spring, Summer Preceptorship
Ignacio V. Ponseti Professor of Orthopaedic Surgery, University ofIowa,
1990
Iowa City, Iowa
Research with Gerhard Rannann, M.D.
1987 - 1988 Baxter Preceptorship
Metabolism and Nutrition, Northwestern
Center for Endocrinology,
Medical School, Chicago, Illinois
University
with Rosalyn S. Yalow, Ph.D.
Summer Preceptorship
and Senior Investigator
1987 Nobel Laureate 1977-Medicine/Physiology
1986,
Solomon Berson Research Laboratory, Banx Veterans AdministratioA
Bronx, New York
Fublications:.
MS: Two-Bundle Posterior Cruciate
Mannor Shearn JT, Grood ES, Noyes FR, Levy
DA,
Ligament
Josenal 28(6):833-845, 2000.
Reconstruction. American of Sports Medicine,
Pmcess Apophysitis.Mimics Spondylolysis.
Mannor Lidenfeld TN: Spinal
DA,
23(2):257-260, 2000.
American Journal of Sports Medicine,
J: Meta-analysis of surgical
Haber Merola A, Zipnick RI, Gorup J, Mannor D, Orchowski
TR,
scoliosis. A 35-year English literature review of 11,000
outcome in adolescent idiopathic
patients. 200(14):1575-1584, 1995.
Spine,
FR· of chiari pelvic osteotomy in
Mannor Weinstein SL, Deitz L ong-term follow-up
DA,
16: 769-773, 1996.
myelomeningocele. Journal of Pediatric Orthopaedics,
Baumann O: Plasma growth hormone (GH)-binding
Mannor DA, WinerLM, Shaw MA,
proteins: Effect on GH binding to receptors and on GH action. Journal of Clinical
and Metabolism, 73(1):30-34, 1991.
Endocrinology
2
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023
Baumann. bormone-binding protein
Circulating growth
Shaw MA, Winer LM,
Mannor DA, GH action. Clinical
but not in vivo
hormone binding to GH receptors
inhibits growth (OH)
36(6):870, 1988.
Research,
Presentations:
Ligament Reconstruction. Intemational Society
Bundle Posterior Cruciate
Biomechanics of Two Washington,
Orthopaedic Sports Medicine Biennial Congress,
Knee Surgery and
of Arthroscopy,
June, 1999.
D.C., Reconstruction: An In Vitro Analysis of Graft
Posterior Cruciate Ligament
Two Bundle
Surgeons Annual Meeting,
Tension. American Academy of Orthopaedic
Placernent and
Febmary, 1999.
Anaheim,
American Orthopaedic
pelvic in myelomeningocele.
Long-term follow-up of chiari osteotomy
Atlanta, March, 1994.
Association's 27th Annual Residents Conference,
inhibits growth hormone (GH)binding to OH
honnone-·binding protein
Cimulating growth
March, 1988.
GH action. Chicago Endocrinology Society,
receptors but not in vivo
3
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023
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FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 29 RECEIVED
. NYSCEF: 02/06/2023
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FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023
STATE OF NEW YORK
WORKERS' COMPENSATION BOARD
RoSERT E. BELOTEN
CHAIR
ANDREW M. cUoMo
Govemor
CERTIFICATION OF AUTHORIZATION
to render treatment to injured employees
THAT the physician named below is authorized
181S IS TO CERTBY Workers'
medical exams under the Compensation Law,
and perfbrm independent
Authorization No: 197496-3B
Date of Issue: 5/18/2011
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FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023
PHYSICIANS & SURGEONS PROFE SSIONAL LIABILITY INSURANCE POLICY
Medicot Liabtitt y Mutuni Insurance Company
2 Park Ave nue, New York, NY 10016
Declarations Page
|NY-PZ-PO-3349þZ4-ND Policy Period: |07/01/2014 | 07/01/2015
Number:
Policy
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Account Number:
Polley Adm nistrator:
Name Dana A Mannor, MD
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Name &
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and subject to all the terms of this policy, we agree with you to provide the insurance .
T.6return fbt the payment of tle Premium,
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WEO IS INSURED
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5urcharge(s)
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Total Premium:
FORMS AND ENDORSEMENTS
Þ$20002 0102 MIL0002 0112, PSE0065 0711, PSE005'f 120B, PSE0006 0303, PSB0010 0102, PSE0049 1105, PSE0035 0102
2 Park Avenue, New Yorl NY 100.1.6 Phonor 212-576-9670
tssuing Offlec:
Signed by:
Initials/Date: LO/July 09, 2014
Authorized C any Representative
Pnge 1 of 1
Medical Liability Mutual Insurance Company
Flat-774534504 6/15." 168,291
P5E0001-030s NY-PZ-PO4349938-ND Folicy Administrator Copy 60
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020
IME EXPERT
NYSCEF EXCH-INDEX#522897/2020
DOC. NO. 29 FILE#1084880 PATRICK FORD
RECEIVED NYSCEF: 02/06/2023
From: Marilyn Ortiz
Received: 11/3/2022 11:23:47 AM
To: EFILINGDOCS
Attachments: Attachment.pdf
Sincerely,
Marilyn Ortiz Montalvo,
Legal Assistant
Baker, McEvoy & Moskovits
5 Broadway, Ste. 3
Freeport, NY 11520
MOrtiz@bm3law.com
Preview
FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------------------------------------------------X Index No.: 522897/2020 PATRICK FORD, NOTICE OF EXPERT Plaintiff(s), WITNESS PURSUANT TO CPLR 3101(d) -against- YSMAEL A. TORRES, Defendant(s). ---------------------------------------------------------------------------X File No.: 1084880 PLEASE TAKE NOTICE, of Defendant(s), YSMAEL A. TORRES, response to Plaintiff(s) request for expert disclosure pursuant to section 3101(d) of the Civil Practice Law and Rules. Defendants expect to call DR. DANA A. MANNOR, M.D. as an expert witness at the trial in the above matter. The subject matter upon which the examining physician is presently expected to testify is set forth in detail in report(s) dated OCTOBER 26, 2022, attached hereto and incorporated by reference herein. The facts and opinions upon which the examining physician is expected to testify are based on his/her physical examination of the plaintiff and/or his/her review of the plaintiff’s medical records and upon all matters in evidence. The grounds of the physician’s opinion come from his/her physical examination of the plaintiff on the above date and/or his/her review of the plaintiff’s medical records and is set forth in the attached report. The Curriculum Vitae for the examining physician is annexed to the report. Dated: Brooklyn, New York November 3, 2022 BAKER, MCEVOY & MOSKOVITS TO: CASSISI & CASSISI, PC 155 FIRST STREET, STE. 101 MINEOLA, NY 11501 (516) 294-5050 ________________________________ BY: RONIT Z. MOSKOVITS, ESQ. ATTORNEY FOR DEFENDANT(s) 5 BROADWAY, SUITE 3 FREEPORT, NY 11520 (212) 857-8230 FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -----------------------------------------------------------------------------X Index No.: 522897/2020 PATRICK FORD, Plaintiff(s), -against- YSMAEL A. TORRES, Defendant(s). -----------------------------------------------------------------------------X File No.: 1084880 NOTICE OF EXPERT WITNESS PURSUANT TO CPLR 3101(d) BAKER, MCEVOY & MOSKOVITS Attorneys for Defendant(s) YSMAEL A. TORRES Office and Post Office Address, Telephone Number 5 Broadway, Suite 3 Freeport, NY 11520 (212) 857-8230 To: CASSISI & CASSISI, PC Attorney(s) for: PATRICK FORD Service of a copy of the within is hereby admitted. Dated, Attorney(s) for FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023 Dana A. Mannor, M.D. Diplomate American Board of Orthopedic Surgery 2044 Ocean Avenue Brooklyn, NY 11230 10/26/2022 Baker, McEvoy & Moskovits, P.C. One Metro Tech Center, 8th Floor Brooklyn, NY, 11201 Claimant: Ford, Patrick Claim#: 1084880 RMA#: 033983 DOB: 02/19/1980 DOA: 02/19/2020 To Whom It May Concern: I am a Board Certified Orthopedic Surgeon and have been asked to perform an orthopedic examination on 09/28/2022 regarding Mr. Patrick Ford at the Brooklyn, New York office. He presented his New York State Driver License prior to this examination. Alla, a chaperone was present during this examination. He took a train to this examination. My findings are as follows: ACCIDENT HISTORY: The history was obtained from Mr. Ford who reports a motor vehicle accident occurring on 02/19/2020. At that time, he reports he was the restrained driver when the vehicle was rear-ended. Mr. Ford denies any loss of consciousness following the accident. Mr. Ford reports that immediately he injured his low back and right ankle. Mr. Ford reports that he went to the Good Samaritan Hospital that same day on his own. He was seen in the emergency room where he was evaluated. He reports that diagnostic tests including X-rays were performed. Mr. Ford reports that he was later released that same day. Mr. Ford reports that he did not sustain any fractures or lacerations. TREATMENT HISTORY: Following the accident, Mr. Ford came under the care of various physicians. He reports that he was initiated on a course of physical therapy, acupuncture treatment, massage therapy, and heat/ice treatment. He was also treated with a TENS unit. He reports that the treatment received has been helpful. He reports additional MRIs of the neck and back were performed. He underwent lumbar spine surgery in November 2020. FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 Claimant: NYSCEF DOC. NO. 29 Ford, Patrick IME NYSCEF: RECEIVED Report 02/06/2023 Claim #: 1084880 Page 2 DOB: 02/19/1980 DOA: 02/19/2020 Mr. Ford reports that he required the use of a cane as a result of the accident. PRIOR MEDICAL HISTORY: Mr. Ford denies any prior accidents or injuries. He was involved in a subsequent accident in July 2020 and sustained concussion and whiplash injuries. Mr. Ford reports that he does not have diabetes, hypertension, or asthma. PRIOR SURGICAL HISTORY: Mr. Ford underwent prior laminectomy. CURRENT MEDICATIONS: Mr. Ford reports that he is taking medications at the present time; however, he has not provided the name of any medications. Mr. Ford denies taking any medications today prior to this examination. EMPLOYMENT HISTORY: Mr. Ford reports that he was employed as a pastor at the time of the accident. He reports missing six weeks from work due to the accident. He reports that currently he is working at the new job performing duties with limitations. He reports that standing, sitting and lifting. CURRENT COMPLAINTS: Mr. Ford reports that he has complaints of pain in his low back and right ankle. REVIEW OF SUBMITTED MEDICAL RECORDS: The following medical records were available for my review: 1. Verified Bill of Particulars Index# No: 522897/2020. 2. Motor vehicle accident report dated 02/19/2020. 3. Police accident report dated 02/19/2020. I am advised that there are no legally authenticated medical records were available for review. If any authenticated medical records are available at any later time. I would be pleased to review them and advice whether they have any effect on my opinion, which is based on today’s examination. PHYSICAL EXAMINATION: Mr. Ford reports that he is a 42-year old right hand dominant male, weighing 240 pounds, height 5 feet 11 inches with hazel eyes and brown hair. Mr. Ford ambulates with a normal gait. He is in no acute distress and is able to understand and cooperate during the examination. FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 Claimant: NYSCEF DOC. NO. 29 Ford, Patrick IME NYSCEF: RECEIVED Report 02/06/2023 Claim #: 1084880 Page 3 DOB: 02/19/1980 DOA: 02/19/2020 RANGE OF MOTION MEASUREMENTS: The range of motion of the examined body parts were performed by the claimant. This is a subjective maneuver on the part of the claimant. Measurements of the ranges of motion were performed by the examiner using a hand-held goniometer where applicable. The measurement itself is, therefore, an objective measurement of the claimant’s subjective efforts. The values of all the measurements were compared to the normal active range of motion values according to the publication, “Guidelines to the Evaluation of Permanent Impairment,” 5th edition, published by the American Medical Association. ORTHOPEDIC EXAMINATION: Lumbar Spine: Examination reveals a multiple posterior and anterior surgical scars. There is no muscle spasm noted. Non tender to palpation. Active range of motion is in flexion to 40 degrees (60 degrees normal), extension to 15 degrees (25 degrees normal), and right lateral bending to 15 degrees (25 degrees normal) and left lateral bending to 15 degrees (25 degrees normal). Passive range of motion is same as active consistent with surgery. There is no atrophy, deformity or soft tissue swelling noted. Straight leg raise is negative bilaterally. Grossly neurovascularly intact. Motor strength is 5/5 in all muscle groups tested. Deep tendon reflexes are 2+ and symmetric in the bilateral lower extremities. Heel-toe-walk is normal. Right Ankle/Foot: There is no heat, swelling, effusion, erythema, atrophy, deformity or crepitus noted. Non tender to palpation. Active range of motion is in dorsiflexion to 20 degrees (20 degrees normal), plantar flexion to 40 degrees (40 degrees normal), inversion to 30 degrees (30 degrees normal), and eversion to 20 degrees (20 degrees normal). Passive range of motion is full. There is no instability. • Drawer’s – negative. • Tinel’s– negative. Grossly neurovascularly intact. Muscle strength is 5/5 in all muscle groups tested. Left Ankle/Foot: There is no heat, swelling, effusion, erythema, atrophy, deformity or crepitus noted. Non tender to palpation. Active range of motion is in dorsiflexion to 20 degrees (20 degrees normal), plantar flexion to 40 degrees (40 degrees normal), inversion to 30 degrees (30 degrees normal), and eversion to 20 degrees (20 degrees normal). FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 Claimant: NYSCEF DOC. NO. 29 Ford, Patrick IME NYSCEF: RECEIVED Report 02/06/2023 Claim #: 1084880 Page 4 DOB: 02/19/1980 DOA: 02/19/2020 Passive range of motion is full. There is no instability. • Drawer’s – negative. • Tinel’s– negative. Grossly neurovascularly intact. Muscle strength is 5/5 in all muscle groups tested. IMPRESSION: 1. Status post lumbar spine fusion surgery in November 2020 – healed by exam. 2. Alleged right ankle/foot sprain/strain – resolved. CONCLUSIONS: The Bill of Particulars alleges that as a result of the accident on 02/19/2020 the claimant sustained injuries to lumbar spine and right ankle/foot. Today's examination indicates that the injured body parts alleged in the Bill of Particulars have resolved. The claimant did not sustain any significant or permanent injury as a result of the motor vehicle accident on 02/19/2020. There are no objective clinical findings indicative of a present disability, and functional impairment, which prevents the examinee from engaging in ADL, and usual activities including work, school, and hobbies. The claimant is able to return to full duty work without restrictions. Upon completion of the examination, Mr. Patrick Ford offers no complaints as a result of this examination and left the examining area stable and unchanged. If you have any further questions regarding Mr. Patrick Ford, please do not hesitate to contact me. ATTESTATION: I, Dana A. Mannor, M.D., being an Orthopedic Surgeon, duly licensed to practice medicine in the State of New York, am not a party to this lawsuit, pursuant to the applicable provisions of the Civil Practice Law and Rules section 2106, hereby affirm under the penalties of perjury that the statements contained herein are true and accurate. FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 Claimant: NYSCEF DOC. NO. 29 Ford, Patrick IME NYSCEF: RECEIVED Report 02/06/2023 Claim #: 1084880 Page 5 DOB: 02/19/1980 DOA: 02/19/2020 I further certify that the signature appearing below is an electronic signature, and that term is defined by New York State technology law 302(3) and 15 USA section 7001 ET. Seq.: that I have personally placed the within electronic signature on this report; and that facsimiles and copies of this report shall be deemed originals. Sincerely, Dana A. Mannor, M.D. Board Certified Orthopedic Surgeon License No: 197496-1 FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023 Dana A. Mannor, M.D. Certryied Orthopedic Surgeon Board Curriculum Vitae - _ . Education: Orthopaedic Center, Cincinnati, Ohio Cincinnati Sportsmedicine and 1996 - 1998 - Director: Frank R. Noyes, M.D. Sports Medicine Fellowship at Brooklyn, Brooklynx New York - 1996 State University of New York 1992 Department of Orthopaedic Surgery Resident, at Brooklyn, Bmoklyn, New York - 1992 State University of New York 1991 Intern, Department of General Surgery Medical Chicago, Illinois. - 1991 Northwestern University School, 1987 M.D. Program in Medicine,.Evanston, Illinois Northwestern Uni versity Honors 1984 - 1987 B.S. Honors: Sportsmedicine Medicine Education and Reseamh Foundation for 1997 Bundle Posterior Cruciate Grant for "Blomechanics of Two (FSMER) Reconstruction" Ligament Oraft Spine Research Award, Scoliosis R.esearch Russel A. Hibbs Clinical 1994 Society Medical School, Baxter Research Scholarship 1987 Northwestern University Northwestern University, Dean's List 1986 Appointments: American of Orthopaedic Surgeons 2007- Board of Specialties Member, Academy 2009 State of Orthopaedic Surgeons 2006- Present Board Member, Ne w York Society New York State Society of 2006- Present Chairwoman, Diversity Committee, Orthopaedic Surgeons Ruth Jackson Orthopaedic Society 2007- Board of Specialities Representative, 2009 1 FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023 Ruth Jackson Orthopaedic Society 2007- 2009 Member at Large, Ruth Jackson Orthopaedic Society 2004- Present Scientific Committee, 2007- Present Member at Large, FORUM 2000- Bylaws Committee, FORUM 2007 Chairwoman, 2000- 2004 Reviewer, Joumal of Arthroscopy Management Committee, Lenox Hill Hospital 2001- 2002 Assurance/Risk Quality Selection Committee, Lenox Hill Hospital 2000- 2002 Orthopedic Surgery Residency Northwestern University Medical School - 1991 Executive Curricuhan Committee, 1988 Northwestem University Medical - Assistant in Microanatomy, 1987 1988 Teaching School Research: with Stuart L. Weinstein, M.D. Spring, Summer Preceptorship Ignacio V. Ponseti Professor of Orthopaedic Surgery, University ofIowa, 1990 Iowa City, Iowa Research with Gerhard Rannann, M.D. 1987 - 1988 Baxter Preceptorship Metabolism and Nutrition, Northwestern Center for Endocrinology, Medical School, Chicago, Illinois University with Rosalyn S. Yalow, Ph.D. Summer Preceptorship and Senior Investigator 1987 Nobel Laureate 1977-Medicine/Physiology 1986, Solomon Berson Research Laboratory, Banx Veterans AdministratioA Bronx, New York Fublications:. MS: Two-Bundle Posterior Cruciate Mannor Shearn JT, Grood ES, Noyes FR, Levy DA, Ligament Josenal 28(6):833-845, 2000. Reconstruction. American of Sports Medicine, Pmcess Apophysitis.Mimics Spondylolysis. Mannor Lidenfeld TN: Spinal DA, 23(2):257-260, 2000. American Journal of Sports Medicine, J: Meta-analysis of surgical Haber Merola A, Zipnick RI, Gorup J, Mannor D, Orchowski TR, scoliosis. A 35-year English literature review of 11,000 outcome in adolescent idiopathic patients. 200(14):1575-1584, 1995. Spine, FR· of chiari pelvic osteotomy in Mannor Weinstein SL, Deitz L ong-term follow-up DA, 16: 769-773, 1996. myelomeningocele. Journal of Pediatric Orthopaedics, Baumann O: Plasma growth hormone (GH)-binding Mannor DA, WinerLM, Shaw MA, proteins: Effect on GH binding to receptors and on GH action. Journal of Clinical and Metabolism, 73(1):30-34, 1991. Endocrinology 2 FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023 Baumann. bormone-binding protein Circulating growth Shaw MA, Winer LM, Mannor DA, GH action. Clinical but not in vivo hormone binding to GH receptors inhibits growth (OH) 36(6):870, 1988. Research, Presentations: Ligament Reconstruction. Intemational Society Bundle Posterior Cruciate Biomechanics of Two Washington, Orthopaedic Sports Medicine Biennial Congress, Knee Surgery and of Arthroscopy, June, 1999. D.C., Reconstruction: An In Vitro Analysis of Graft Posterior Cruciate Ligament Two Bundle Surgeons Annual Meeting, Tension. American Academy of Orthopaedic Placernent and Febmary, 1999. Anaheim, American Orthopaedic pelvic in myelomeningocele. Long-term follow-up of chiari osteotomy Atlanta, March, 1994. Association's 27th Annual Residents Conference, inhibits growth hormone (GH)binding to OH honnone-·binding protein Cimulating growth March, 1988. GH action. Chicago Endocrinology Society, receptors but not in vivo 3 FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023 . an OF HAVING THE MET THE BOARD THE Bana AND VALID CONTINUING HEREBY HAVING PRACTICE THROUGH OF Annabel JANUARY BEEN 1, THE ORTHOPAEDIC INCORPORATED EDUCATION CERTIFIES 2012 IGee 1934 DECEMBER AND EXAMINED 31, THAT SPECIALTY IS 2021 OF SURGERY PRACTICEganner RECERTIFIED FOR REQUIREMENTS FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 29 RECEIVED . NYSCEF: 02/06/2023 · . . as..a60 wisa 8527884 please 03/31/2016 inforspton York Number certificate CERTIFICATE nee New Certificate- arfor Professions through of seM this is State State carqfeate of argwIAN coPy ork the ondim ihe REGISTRATMN of a ew of accept . i s sity ce in drai ed..to..Practim UDív.e 2) not 197496 py.Toarfy Ro THe Mumbed a èeau · . F . q. . . . FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023 STATE OF NEW YORK WORKERS' COMPENSATION BOARD RoSERT E. BELOTEN CHAIR ANDREW M. cUoMo Govemor CERTIFICATION OF AUTHORIZATION to render treatment to injured employees THAT the physician named below is authorized 181S IS TO CERTBY Workers' medical exams under the Compensation Law, and perfbrm independent Authorization No: 197496-3B Date of Issue: 5/18/2011 Treatment Authorization code(s): COS Date: 10/25/1999 IME Authorization Date: 5/18/2011 9,, g NE Rating Mannor Dana Annabelee, MD PENS o.ton..so incot FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/06/2023 PHYSICIANS & SURGEONS PROFE SSIONAL LIABILITY INSURANCE POLICY Medicot Liabtitt y Mutuni Insurance Company 2 Park Ave nue, New York, NY 10016 Declarations Page |NY-PZ-PO-3349þZ4-ND Policy Period: |07/01/2014 | 07/01/2015 Number: Policy gectine D:01ru.,brandardrime at the PONGy dministf ator's Ad&t.rs 3349934PR Policy type: Occurrence Account Number: Polley Adm nistrator: Name Dana A Mannor, MD & Address Not Applicable aced Name & . . Address Phone .. and subject to all the terms of this policy, we agree with you to provide the insurance . T.6return fbt the payment of tle Premium, as acted in this policy. WEO IS INSURED Retroactive Named Indlyldualorganization Limits of Llability Date Coverage Code/Specialty Descriptión Each Person/rntal (15appueÆç) Premian T1001-31-48.2B¬00000000 19-10145-NVD s t,300,000/$3,900,000 . iDana A Mannor. MD--MP0517336--H50420 5urcharge(s) Defense Coverage Premium Total Premium: FORMS AND ENDORSEMENTS Þ$20002 0102 MIL0002 0112, PSE0065 0711, PSE005'f 120B, PSE0006 0303, PSB0010 0102, PSE0049 1105, PSE0035 0102 2 Park Avenue, New Yorl NY 100.1.6 Phonor 212-576-9670 tssuing Offlec: Signed by: Initials/Date: LO/July 09, 2014 Authorized C any Representative Pnge 1 of 1 Medical Liability Mutual Insurance Company Flat-774534504 6/15." 168,291 P5E0001-030s NY-PZ-PO4349938-ND Folicy Administrator Copy 60 FILED: KINGS COUNTY CLERK 02/06/2023 03:59 PM INDEX NO. 522897/2020 IME EXPERT NYSCEF EXCH-INDEX#522897/2020 DOC. NO. 29 FILE#1084880 PATRICK FORD RECEIVED NYSCEF: 02/06/2023 From: Marilyn Ortiz Received: 11/3/2022 11:23:47 AM To: EFILINGDOCS Attachments: Attachment.pdf Sincerely, Marilyn Ortiz Montalvo, Legal Assistant Baker, McEvoy & Moskovits 5 Broadway, Ste. 3 Freeport, NY 11520 MOrtiz@bm3law.com