Preview
By: Danyelle Yondura, Esquire
Identification No. 317071 ATTORNEY FOR DEFENDANT:
Law Offices of Mezzanotte, Hasson & Sichok
PO Box 6835 Kristin Prettyman
Scranton, PA 18505-6835
215-627-3087
RONALD MAYER COURT OF COMMON PLEAS
Plaintiff, DELAWARE COUNTY
CIVIL ACTION — LAW
V.
KRISTEN PRETTYMAN and ARMANI BROWN NO. CV-2021-001895
Defendants.
DEFENDANT, KRISTIN PRETTYMAN’S,
PRE-TRIAL MEMORANDUM
(A) NATURE OF CASE:
This is an Arbitration appeal filed by Plaintiff where a panel of Arbitrators found Defendant
not liable for the subject accident and Co-Defendant, Armani Brown 100% liable. (See Arbitration
award attached as Exhibit A.) Plaintiff settled with Co-Defendant for $5,000.
This matter arises from a motor vehicle accident that took place on May 12, 2019 on Route
252/Providence Road, Wallingford, PA. A witness reported to the police that she observed a vehicle,
identified as being operated by Armani Brown, turned left into Manor Care and was taking it’s time at
entrance when the vehicle operated by Defendant, Kristen Prettyman (hereinafter “Defendant’”) didn’t
have enough time to react. (See Police report attached Exhibit B.) Defendant testified at her
deposition that she was driving up to 35 mph, glanced down for a second to put her tea in cupholder
and when she looked up there was a car horizontal to her in her lane. She slammed on the brakes and
swerved to avoid collision but struck the back of Brown’s vehicle and then struck Plaintiff, Ronald
Mayer’s (hereinafter “Plaintiff’) vehicle head on. The police report also noted that EMS arrived at the
scene and evaluated each occupant involved in accident; all parties refused to go to the hospital.
Plaintiff alleged injuries to his right-side ribs, neck, back, chest and dominate left hand as well as
damages to his musculoskeletal system. It should be noted that Plaintiff was involved in a prior
motor vehicle accident approximately 16 years ago in 2006, wherein he injured his back and neck.
Defendant contests liability in addition to the etiology and extent of Plaintiffs alleged injuries.
Plaintiff is subject to Limited Tort due to not having insurance coverage of his vehicle that was
involved in the said accident. (See The Carrier History Report, attached as Exhibit C.) As such, he is
precluded from recovery of non-economic damages unless his injuries rise to the level of “serious
injury.” Neither death nor permanent disfigurement are applicable in the instant matter, Thus, in order
to recover non-economic damages in the present case, the Plaintiff must establish the existence of a
“serious impairment of body function.”
(B) DAMAGES CLAIMED:
Following the accident of May 12, 2019, Plaintiff treated later that evening at the emergency
department of Bryn Mawr Hospital where a CT scan of his chest found a questionable non-displaced
fracture of the anterior right second rib. An x-ray of his left hand proved negative for fracture or
dislocation. A head CT was unremarkable and cervical CT showed degenerative changes with “no acute
injury.”
Plaintiff followed up with his primary care physician who referred him for physical therapy for
“rib fracture” and “boxer’s fracture” despite the lack of diagnostic supports. On June 4, 2019, Plaintiff
was evaluated at Philadelphia Hand to Shoulder by Dr. Meredith Osterman. In-office x-rays were
negative for any fracture(s). In light of his ongoing pain complaints, despite the lack of objective injury,
Plaintiff was referred for occupational therapy. However, Plaintiff never returned for treatment for his
alleged injury(ies). In fact, Plaintiff did not provide any records of medical services received for his
alleged injuries after June 4, 2019 visit.
To date, Plaintiff has had no injections or surgeries recommended or received for said related
injuries. Plaintiff has since been discharged and testified that he has no plans of continuing treatment.
As such, no setious injury was sustained by Plaintiff relating to the motor vehicle accident of May 12,
2019.
An orthopaedic Independent Medical Examination (IME) of Plaintiff was performed on May
17, 2023 by Dr. Jeffrey Malumed. Plaintiff stated to Dr. Malumed that he injured his left hand, neck,
and had a questionable fracture of a right rib. He also communicated that he did not seek out any
additional treatment following the one visit on 06/04/2019. (See IME report attached as Exhibit
D,) Plaintiff also confirmed that he works in the home improvement field, including roofing and
siding, and that he returned to work after being out for approximately 2-3 months and returned to
playing guitar and bass with his band after subject accident.
Upon examination, Dr. Malumed found Plaintiff's left hand and wrist demonstrated full and
complete range of motion of all fingers and the wrist without any limitations. He has no complaints
of left hand or left wrist pain in addition to no weakness of the wrist or fingers. Dr. Malumed found
no evidence of thenar wasting or atrophy. There was no indication for any further medical treatment
for Plaintiffs left hand as Dr. Malumed his left hand pain to be completely resolved. With regard to
the questionable right rib fracture, Dr. Malumed found no diagnostic testing demonstrating a rib
fracture and any alleged right rib pain had resolved. Examination of Plaintiff's cervical spine showed
a full and complete range of motion of the cervical spine with mild pain and Plaintiff had returned
to his normal work and recreational activities without any restrictions. Examination of Plaintiff's
lumbar spine is completely normal with no complaints of pain or tenderness on palpation. With
regard to Plaintiffs cervical spine, Dr. Malumed found that, by history, Plaintiff may have had a
cervical strain or sprain but he did not seek any treatment for his neck following subject motor
vehicle accident other that the visit to emergency department on May 12, 2019.
Dr. Malumed opined that,
“He has had no treatment, other than the one emergency room visit and the one evaluation
by Dr. Osterman. In the last four years, he has had no treatment to any body parts injured in
this motor vehicle accident of 05/12/2019.”
{]
“Mr. Mayer has not sustained any serious impairment of bodily function as a result of this
motor vehicle accident. Any alleged injuries he may have sustained certainly were self-limited
and would not have resulted in any significant problems limiting his ability to return to his
preinjury work activities or recreational activities within two to four weeks.”
Plaintiff testified that he still experiences pain in his wrist, lower back and neck. However, he
has not provided any records of additional medical treatment for his alleged pain after his June 4,
2019 visit. Plaintiff further claims that he missed about 2-3 months of work because of his alleged
left-hand injury. However, he is self-employed and has no proof of his income admitting that as he
has not filed tax returns for at least 4 years.
As yet, Plaintiff has not provided any proof of motor vehicle insurance coverage for the said
May 12, 2019 accident. A Carrier Discovery Report shows that Plaintiff, the owner of the vehicle
involved in the accident, did not have motor vehicle insurance coverage on May 12, 2019. (See
Exhibit C.) According to Title 75 of the Pennsylvania General Assembly, Election of Tort Options, in
Section 1705(a)(5), “An owner of a currently registered private passenger motor vehicle who does not
have financial responsibility shall be deemed to have chosen the limited tort alternative.” Unless
Plaintiff can provide proof of motor vehicle insurance on the date of the accident, he will be bound by
limited tort as he was the owner of an uninsured vehicle that was involved in the accident. Even if
Plaintiff had broken his rib from this accident, it does not rise to the level of “serious bodily injury
protracted loss or permanent impairment” and thus does not breach the limited tort threshold.
No serious injury was sustained by Plaintiff, Ronald Mayer in the minor May 12, 2019 motor
vehicle collision. No body function was seriously impaired. There has been no major impact on his
daily for life for an extended period of time. In fact, Plaintiff was able to function and perform all
activities of daily living, including his home improvement work consisting of roofing and siding, and
playing guitar and bass with his band. He functions primarily as he did before the accident. No
serious injury was sustained.
(© WITNESSES:
Ronald Miller, Plaintiff
Defendant, Kristen Prettyman
Armani Brown, Co-Defendant
Anne Hollyer, Witness
6. Jeffrey Malumed, M.D., defense expert
Plaintiff's treating medical providers, including but.not limited to: Bryn Mawr
Hospital, Philadelphia Hand to Shoulder, Dr. Meredith Osterman.
Any person named, mentioned or otherwise identified in Answers to Interrogatories,
Request for Production of Documents, ot depositions taken by any party in connection
with this case.
Any person named, mentioned or otherwise identified in any paper filed of record in
this case.
10. Any petson necessary for impeachment or rebuttal purposes based upon testimony
introduced at trial.
11 Any person named, mentioned, or otherwise identified in any Pretrial Statement filed by
any party to this action and all supplements thereto filed; and
12. Defendants reserve the right to call as additional liability witnesses any or all other
witnesses discovered or named in depositions, interrogatories or any other pleadings
filed by any party to this action. Further, Defendants reserve the right to call any and all
witnesses necessary for rebuttal. Defendants also reserve the right to supplement this
witness list at any time up to and including the time of trial.
@) EXHIBITS:
Plaintiffs Answers to Interrogatories and Responses to Request for Production;
Defendant’s Answers to Interrogatories and Responses to Request for Production;
Co-Defendant’s Answers to Interrogatories and Responses to Request for Production;
Deposition transcript of Plaintiff, Ronald Miller;
Deposition transcript of Co-Defendant, Armani Brown;
6. Deposition transcript of Defendant, Kristen Prettyman;
Any exhibit previously marked in any deposition taken in relationship to this matter.
IME report and CV of defense medical expert, Jeffrey Malumed, M.D.;
All photographs exchanged in discovery;
10. All of Plaintiff's medical records exchanged in discovery;
11 All records obtained via subpoena;
12. Any exhibit listed in the Pretrial Statement or any amendment filed thereto of any
party to this litigation.
13. Any exhibit necessary for impeachment or rebuttal proposed based on testimony
introduced at trial.
14. Any photographs, diagrams, sketches and/or other illustrations exchanged during
discovery.
15. Any statement obtained from any person called as a witness.
16. Any and all documents produced in discovery.
17. All health insurance records, along with social security disability, Medicare, short
term disability, and long-term disability records reflecting benefits provided to
Plaintiff.
18. Any and all internet or social media postings made by the Plaintiff, including
photographs.
19. Defendants reserve the right to introduce any and all documentary evidence in its
possession at the trial of the within captioned matter including but not limited to any
and all documents, photographs, maps, diagrams or physical evidence whatsoever,
named or indicated in the pre-trial statement of any party to this action or in any
deposition, answers to interrogatories, response to. request for production of
documents or any other pleading filed in the instant case.
) EXPERT REPORT:
Jeffrey Malumed, M.D., defense expert, who will testify that Plaintiff has not sustained any
serious impairment of bodily function as a result of motor vehicle accident of May 12, 2019 and he
has had no treatment for his alleged injuties since the last June 4, 2019 office visit.
@) REQUESTED STIPULATIONS:
None at this time.
© LIABILITY DEFENSE:
The exhibits listed in the Pretrial Statement or copies thereof, shall be made available
by the party filing the statement.
All records listed should have been disclosed previously in discovery. Expert report
attached.
@) TRIAL LENGTH:
Defendant estimates this matter may requite 2-3 days to try.
® LEGAL ISSUES IN THIS CASE:
None at this time.
Law Offices of Mezzanotte, Hasson & Sichok
Danyelle Yondtra, Esquire
Attorney for Defendant,
Kristin Prettyman
EXHIBIT
COURT OF COMMON PLEAS
DELAWARE COUNTY, PENNSYLVANIA
CASE CAPTION DOCKET NO!
IST S- 2OoA)
Ron ald Ma Cr TAX FOLIO NO
ARBITRATION
(Please indicate type of act)
Kvister Petty man SY Motor Vehicle
() Contract
MU Vvy\ ( ) Assessment of Damages
Armani () Other
( ) Delay Damages
(Prime Rate + 1%)
REPORT AND AWARD OF ARBITRATORS
NOW, this day of Jan. 20 a3, we the undersigned Arbitrators having
£%
been duly appointed and sworn. ake the folla 2, Award:
yt IW) Yow A Wolbers dent Prcthy man
Dire | finds Defer dctot Arn, ny Brow 4
1Oo0%% respousi ble fee The lls oy awn a
any damages A Fe Pls DAE
That may be Owe'’s | ee
Please name the parties if there are more than one Plaintiff and/or Defendant, address all counterclaims
and cross-claims, and complete percentage of negligence, if applicable.
din A-Rellinzerss Job
Arbitrator (Pleage
boegey
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Ly Le. Sem el gal
cator (Pleaseint)
C erson Signatare Arbjtfator Sigucture bitrafor ature
COUNSEL FOR PARTIES
Griéin Evens, ES® SIYNGI3
Attomey Ay D Pre Txuann Attorney ID#
Lener Sb a B, ES YOICS
Attorney ar S hroury ID# Attormmey ID#
Ret [A Deluca, Esse 494947 FILED
Attorney Rp , ID# Attorney Ties or sunln evrponr
ELAWARE COUNT
EXHIBIT
Incident Report
NETHER PROVIDENCE TOWNSHIP POLICE
99TH DISTRICT
214 SYKES LA
WALLINGFORD, PA 19086
Phone: (610)892-2875 Fax: (610)566-6496
Municipality NETHER PROVIDENCE (105)
Report Type ACCIDENT
Incident # Reference #
Location 115 S PROVIDENCE RD - WALLINGFORD
20190512M0008 19086
Landmark
Premise HIGHWAY/ROAD/STREET, ETC.
Title
Criminal Section Point of Entry
Code Sub-Section Meth. of Entry
Description Patrol Zone Grid
Reported 05/12/2019 ane (Sun)
Discovered
2| 6006 TRAFFIC ACCIDENT INVOLVING INJURY
Last Secure @
Received Dispatched
Arrived Cleared 15:59
Status CLOSED/CLEARED
Disposition
Clear Date 05/12/2019
Badge 9928 - PTLM MICHAEL WORRELL
[= ——= == —
_ Additional Officers
Officers Date Activity
9931 PTLM ROBERT BRAKE if ASSISTS/OFFICER
9944 SGT. ROBERT ELMORE ff ASSISTS/OFFICER
SS — =
Vehicles
Year, Make, Model Style Color License-State VIN/Serial#t Owner
2016, HONDA, HARDTOP Gray KFX3987-PA 5FNRL5H30GB155119 KRISTEN M PRETTYMAN
ODYSSEY (MINIVA 12 W POSSUM HOLLOW RD
ROSE VALLEY, PA 19086
Vehicle towed by LUONGOS TOWING to LUONGOS TOWING Insurance Co. LIBERTY MUTUAL - 36447
Policy No. AOS-288-160973-40-9 0
Title 77023416801
2006, HONDA, CivIC SEDAN, 4 DOOR Gray KWDS5586-PA 1HGFA16586L017363 ARMANI C BROWN
(AND CRX) 1247 EDGEHILL RD
DARBY, PA 19023
Vehicle towed by LUONGOS to LUONGOS Insurance Co. PROGRESSIVE - 32786
Policy No. 912367941
Title 62606096
Investigating Officer Date Approving Officer
Sonate
NETHER PROVIDENCE TOWNSHIP POLICE Page 1 of 6
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6006 - TRAFFIC ACCIDENT INVOLVING INJURY}
Year, Make, Model Style Color License-State VIN/Serial# Owner
2006, CHEVROLET, PICKUP Gray ZGT8280-PA 1GCHK29U46E210840 RON DEAN MAYER
309 FIRST AV
NEWTOWN SQUARE, PA 19073}
Vehicle towed by LUONGOS TOWING to LUONGOS TOWING Insurance Co. PROGRESSIVE - 11770
Policy No. 01698418-7
Title 62893126
NETHER PROVIDENCE TOWNSHIP POLICE Page 2 of 6
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6006 - TRAFFIC ACCIDENT INVOLVING INJURY]
ree = So SSS —
“Persons Involved
BROWN, ARMANI C Arrest Date : Disposition Date
Rok Incident Classificatio! How Charged ispositior
DRIVER 6006 TRAFFIC ACCIDENT INVOLVING INJURY
Age DOB 22- Height
[
Race BLACK Weight 0 Home Addr 1247 EDGEHILL RD
Sex MALE Hair DARBY, PA 19023
Ethnicity UNKNOWN Eyes
Marital Stat Build Home Ph #
Residency Non-Resident Compiex. Work Ph #
SSN Cell Ph #
Gang Other Ph # No Photo
Tattoo E-Mail
Clothing Employer
GBM Id
-Entered tt
-Released // Occupation
OLN/State Addl Addr None
Injury
HOLLYER, ANNE Arrest Date : Disposition Date
Ingic nt Classifi ion How Charged Dis
Witess 6006 TRAFFIC ACCIDENT INVOLVING INJURY
i
Age-DOB 55- Height
[
Race WHITE Weight 0 Home Addr 103 BLACKTHORN RD
Sex FEMALE Hair WALLINGFORD, PA 19086
Ethnicity NON-HISPANIC Eyes
Marital Stat Build Home Ph #
Residency Resident Complex. Work Ph #
SSN Cell Ph#
Gang Other Ph # No Photo
Tattoo E-Mail
Clothing Employer
GBM Id
-Entered Vw
Released // Occupation
OLN/State Addl Addr None
Injury
NETHER PROVIDENCE TOWNSHIP POLICE Page 3 of 6
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6006 - TRAFFIC ACCIDENT INVOLVING INJURY]
MAYER, RON DEAN Arrest Date : Disposition Date :
Role Incident Classification How Charger Disposition
DRIVER/VEHICLE OWN | 6006 TRAFFIC ACCIDENT INVOLVING INJURY
Alias
Age-DOB 54- Height
[
Race WHITE Weight 0 Home Addr 309 FIRST AV
Sex MALE Hair NEWTOWN SQUARE, PA 19073
Ethnicity UNKNOWN Eyes
Marital Stat Build Home Ph #
Residency Non-Resident Complex. Work Ph #
SSN Celt Ph#
Gang Other Ph # No Photo
Tattoo E-Mail
Clothing Employer
GBM Id
-Entered tt
-Released it Occupation
OLN/State Addl Addr None
Injury
XXXXXXXXXKXXX Arrest Date : Disposition Date :
Incident Classificatior How Charged Dispositior
PASSENGER 6006 TRAFFIC ACCIDENT INVOLVING INJURY
Alias [Pouvenite Disp: 17 UNDEFINED
Age-DOB - Height
Race WHITE Weight 0 Home Addr
Sex MALE Hair
Ethnicity Eyes
Marital Stat Build Home Ph #
Residency Non-Resident Complex. Work Ph #
SSN Cell Ph#
Gang Other Ph # No Photo
Tattoo E-Mail
Clothing School
GBM Id
-Entered it
-Released i Occupation
OLN/State Addl Addr None
Injury
Juvenile!
NETHER PROVIDENCE TOWNSHIP POLICE Page 4 of 6
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[ 6006 - TRAFFIC ACCIDENT INVOLVING INJURY|
PRETTYMAN, KRISTEN M Arrest Date : Disposition Date :
Incident ssifical How Chargex Dispositior
BRIVERIVEHICLE OWN 6006 TRAFFIC ACCIDENT INVOLVING INJURY
Alias
Age-DOB 41- Height
l
Race WHITE Weight 0 Home Addr 12 W POSSUM HOLLOW RD
Sex FEMALE Hair ROSE VALLEY, PA 19086
Ethnicity UNKNOWN Eyes
Marital Stat Build Home Ph #
Residency Non-Resident Complex. Work Ph #
SSN Cell Ph#
Gang Other Ph # No Photo
Tattoo E-Mail
Clothing Employer
GBM Id
-Entered tt
-Released i Occupation
OLN/State Addl Addr None
Injury
SELLETTI JR., ANTHONY Arrest Date : Disposition Date :
Incident Classification How Charger Disposition
PASSENGER 6006 TRAFFIC ACCIDENT INVOLVING INJURY
Age DOB 42 - Height 6'01" [
Race WHITE Weight Q Home Addr 127 W LAUGHEAD AV
Sex MALE Hair LINWOOD, PA 19061
Ethnicity NON-HISPANIC Eyes
Marital Stat Build Home Ph #
Residency Non-Resident Complex. MEDIUM Work Ph #
SSN Cell Ph#
Gang Other Ph # No Photo
Tattoo E-Mail
Clothing Employer
GBM Id
-Entered i
-Released Vt Occupation
OLN/State Addl Addr None
Injury
NETHER PROVIDENCE TOWNSHIP POLICE Page 5 of 6
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[ 6006 - TRAFFIC ACCIDENT INVOLVING INJURY]
Main Narrative
PTLM MICHAEL WORRELL (9928)
05/12/2019 14:52 - 9928 PTLM MICHAEL WORRELL
On May 12th, 2019 at 1452 hours, Nether Providence Police were dispatched to 205 S. Providence Rd. and 115 S. Providence
Rd. for repert of a 3 vehicle accident with injuries reported. Upon arrival, | observed ail vehicles in front of 115 S. Providence Rd. |
immediately asked each of the occupants if they were in need of medical attention. All parties stated they were just a little shaken
up but did not need immediate attention. EMS came to the scene and began evaluating each of the occupants. All occupants
refused to go to the hospital at this time.
| met with the driver of Unit 1, identified as Kristen Prettyman, driver of the 2016 Honda Odyssey, who stated she was traveling
south bound on the 100 block of S. Providence Rd. when she observed Unit 2 making a left turn into Manor Care Nursing Home.
She continued going straight, but Unit 2 stopped with it's rear still blocking S. Providence Rd. causing Unit 1 to swerve left, first
striking Unit 2, then Striking Unit 3 in the opposite lane of traffic. Unit 1 sustained severe damage to the 12 0 clock position of the
vehicle. This vehicle was towed to Luongo's towing
1 met with the driver of Unit 2, identified as Armani Brown, driver of the 2006 Honda Civic, who stated he was traveling north
bound on the 100 block of S. Providence Rd. when began turning into the Manor Care Nursing Home, before being struck by
Unit 1. Unit 2 sustained severe damage to the 5 0 clock position of the vehicle. This vehicle was towed to Luongo’s towing.
| met with the driver of Unit 3, identified as Ron Mayer, driver of the 2006 Chevrolet Pick Up, who stated he was traveling north
bound behind Unit 2, when he observed Unit 2 turn left into the entrance of Manor Care and then stop, leaving the rear end of the
vehicle in tre roadway, causing Unit 1 to strike Unit 2 then swerve head on into Unit 3. Unit 3 sustained severe damage to the 12
0 clock position. This vehicle was towed to Luongo’s towing.
[A witness identified as Anne Hollyer stated he observed Unit 2 turn left into the Manor Care entrance and she doesn't believe he
cut off Unit 1 but stated Unit2 did take it's time getting into the entrance and Unit 1 didn’t have enough time to react. Anne
Hollyer was traveling south bound behind Unit 4
Notice of accident forms, car fax cards, and Luongo's business cards were given to each of the drivers and | explained how to
get a copy of the report.
It should be noted, the driver of Unit 2 came up to me while Unit 2 was on the tow truck and asked if he could have a private tow
truck come out to get the vehicle. | advised him that it was already too late for that. He then put me on the phone with someone
who stated they were the owner of the vehicle. The caller was irate and stated | was breaking the law by not letting him tow the
vehicle to his own tow yard. | advised the cailer that the vehicle was already traveling down the road to Luongo's towing and
advised him to contact his insurance company. Clear.
State Crash Report#: W0735219 will be compieted next shift.
NETHER PROVIDENCE TOWNSHIP POLICE Page 6 of 6
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EXHIBIT
Carrier Discovery Report Page of
Claim #: 039903179
Carrier Discovery Report Date Ordered: 7/11/2019
Report Status: Complete with Results
Order ID: 129315522734
Date of Report: 7/11/2019
Important: The Public Records and commercially available data sources used on reports have errors. Data is sometimes entered poorly, processed incorrectly
and is generally not free from defect. This system should not be relied upon as definitively accurate. Before relying on any data this system supplies, it should be
independ fenly vere For Secretary of State documents, the following data is for information purposes only and is not an official record. Certified copies may be
rom that individual state's Department of State, The criminal record data in this product ar service may include records that have sxpunged, sealed,
or otherwise have become inaccessible to the public since the date on which the data was last updated or collected.
Accurint does not constitu cor report as that term is defined in ral Fait Credit Reporting Act, 15 USC 1681 et seq. (FCRA). Accordingly, Accurint
‘may not be used in whole or in part as afactor in determining eligibility for cre insurance, employment or another permissible purpose under the FCF
Your DPPA Perr iss je Use: Insurance
Your GLBA Pert iss le Us Fraud Prevention or Detection
Your DMF Permissible U : Legitimate Fraud Prevention Interest
Search Request.
VIN Date of Loss” Recap Information
4GCHK29U46E210840 Carrier overy Auto Reference
#:19193020601865
Carrier Discovery Current Policy Found: # of Prior Possible
Search: 2 Record(s) Policies Lapse:
Found Found:
Current Policy
CARRIER: ERIE ‘AMB: 00348 POL:0041806586 TYPE:AU NAIC:26271
INSURANCE EXCH
INCEPTIO! ‘STATUS: IN- POL STATE: LAST CANCEL
04/18/1995 EFFECT PA REASON:
POLICY: 04/18/2019 -
04/18/2020,
Policy Holders
POLICY HOLDER NAME STATUS SUBJECT EFFECTIVE DATES
CASPER, CHARLES Jj III (PRIMARY) os 04/18/2019 - 04/18/2020
CASPER, BETH ANN (LISTED) os 04/18/2019 - 04/18/2020
CASPER, JAMIE N (LISTED) os 04/18/2019 - 04/18/2020
CASPER, JACOB CHARLES (LISTED) os 04/18/2019 - 04/18/2020
CASPER, JESSICA L (LISTED) os 04/18/2019 - 04/18/2019
Vehicles
VEHICLE VEHICLE
MAKE: YEAR VIN NUMBER: COVERAGE EFFECTIVE DATES NOTIFICATION
GMC 15 1GT22YEG6FZ558348 BI PD NB UB CO CP 04/18/2019 04/18/2016
04/18/2020
ToYO 15 2T1BURHE1FC272539 BI PD NB UB CO CP 04/18/2019 12/08/2016
oT 04/18/2020
TOYO 14 STDBKRFH6ES016849 BI PD NB UB CO CP 04/18/2019 04/18/2018
oT 04/18/2020
SUBA 12 JF2SHADC6CH461352 BI PD NB UB CO CP 04/18/2019 08/02/2018
oT 04/18/2019
NISS 13 {N4AL3AP3DC112293 BI PD NB UB CO CP 04/18/2018 04/18/2016
OTRR 04/18/2018
HYUN 13 KMHDH4AE3DU637695 BI PD NB UB CO CP 04/18/2017 04/18/2016
oT RR 01/19/2018
https://secure.accurint.com/app/bps/report 7/12/2019
Carrier Discovery Report Page of
VEHICLE VEHICLE
MAKE: YEAR VIN NUMBER: COVERAGE EFFECTIVE DATES NOTIFICATION
TOYO 08 2T1BR32E98C933647 BI PD NB UB CO CP 04/18/2016 04/18/2016
oT 12/08/2016
ToYO 02 STDBT44A82S074759 BIPD NB UB CP OT 04/18/2015 02/29/2008
11/09/2015
CHEV 06 1GCHK29U46E210840 BIPD NB UB CO CP 04/18/2015 02/29/2008
oT 10/27/2015
Policy History
CARRIER: STATE AMB: 88381 POL:0695381 TYPE: AU NAIC:25178
FARM INSURANCE,
INCEPTION: STATUS: POL STATE: LAST CANCEL
04/24/2005 EXPIRED PA REASON:
POLICY: 10/24/2018 -
04/24/2019
Policy Holders
POLICY HOLDER NAME STATUS SUBJECT EFFECTIVE DATES
RYAN, THOMAS J (PRIMARY) os 10/24/2018 - 04/24/2019
RYAN, MARYLOU (LISTED) os 10/24/2018 - 04/24/2019
Vehicles
VEHICLE VEHICLE
MAKE: YEAR VIN NUMBER: COVERAGE EFFECTIVE DATES NOTIFICATION
TOYT 18 STDDZRFH1JS495669 BI PD NB UB CO CP 10/24/2018 12/21/2017
04/24/2019
TOYT 16 STDDK3DC5GS139808 BI PD NB UB CO CP 10/24/2017 08/01/2016
MP 12/21/2017
VOL 16 YV4612RKXG2868123 BI PD NB UB CO CP 04/24/2016 03/14/2016
08/01/2016
TOYT 13 STDDK3DC6DS070140 BI PD NB UB CO CP 10/24/2015 08/27/2013
MP 03/14/2016
TOYT 12 STDDK3DCXCS040363 BI PD NB UB CO CP 04/24/2013 03/28/2012
MP 08/27/2013
JEEP "1 1J4RR4GT4BC596214 BI PD NB UB CO CP 10/24/2011 02/23/2011
03/28/2012
TOYT 10 4T3BK3BB4AU039769 BI PD NB UB CO CP 11/02/2010 07/14/2010
MP 02/23/2011
SUBA o7 4S4WX85D774406808 BI PD NB UB CO CP 04/24/2010 10/24/2006
07/14/2010
CHEV 06 1GCHK29U46E210840 BI PD NB UB CO CP 04/24/2006 04/24/2006
MP 08/21/2006
- -
THIS REPORT IS THE RESULT OF SEARCHING FOR POLICY HISTORY ON THE INDIVIDUALS OR VINS IN THE HOUSEHOLD VIA CARRIER D:
CLAIMS DISCOVERY AND ACCIDENT DATA. THE INFORMATION SHOULD BE INDEPENDENTLY VERIFIED PRIOR TO USE.SUBSCRIBER SHOULI
INDEPENDENTLY DETERMINE WHAT ACTION, IF ANY, TO TAKE.
CARRIER DISCOVERY AND CLAIMS DISCOVERY ARE SERVICE MARKS OF LEXISNEXIS RISK SOLUTIONS.
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https://secure.accurint.com/app/bps/report 7/12/2019
EXHIBIT
A Premier’
ORTHOPAEDICS
Jeffrey Malumed, M.D.
Richard Zamarin, M.D,
Priscilla Cavanaugh, M.D.
Armando Mendez, M.D.
Joseph Stellabotte, M.D.
David Yucha, M.D.
May 17, 2023
Ms. Jessica Morales
Certified Medical Consultants
1401 NW 136th Avenue
Suite 203
Sunrise, FT. 33323
INDEPENDENT MEDICAL EVALUATION
RE: RONALD MAYER
DOL: 05/12/2019
Claim: 399031790004
Dear Ms. Morales,
This is the Independent Medical Examination you requested on Ronald
Mayer. This
examination was conducted after performing a thorough history
and physical
examinatio
Preview
By: Danyelle Yondura, Esquire Identification No. 317071 ATTORNEY FOR DEFENDANT: Law Offices of Mezzanotte, Hasson & Sichok PO Box 6835 Kristin Prettyman Scranton, PA 18505-6835 215-627-3087 RONALD MAYER COURT OF COMMON PLEAS Plaintiff, DELAWARE COUNTY CIVIL ACTION — LAW V. KRISTEN PRETTYMAN and ARMANI BROWN NO. CV-2021-001895 Defendants. DEFENDANT, KRISTIN PRETTYMAN’S, PRE-TRIAL MEMORANDUM (A) NATURE OF CASE: This is an Arbitration appeal filed by Plaintiff where a panel of Arbitrators found Defendant not liable for the subject accident and Co-Defendant, Armani Brown 100% liable. (See Arbitration award attached as Exhibit A.) Plaintiff settled with Co-Defendant for $5,000. This matter arises from a motor vehicle accident that took place on May 12, 2019 on Route 252/Providence Road, Wallingford, PA. A witness reported to the police that she observed a vehicle, identified as being operated by Armani Brown, turned left into Manor Care and was taking it’s time at entrance when the vehicle operated by Defendant, Kristen Prettyman (hereinafter “Defendant’”) didn’t have enough time to react. (See Police report attached Exhibit B.) Defendant testified at her deposition that she was driving up to 35 mph, glanced down for a second to put her tea in cupholder and when she looked up there was a car horizontal to her in her lane. She slammed on the brakes and swerved to avoid collision but struck the back of Brown’s vehicle and then struck Plaintiff, Ronald Mayer’s (hereinafter “Plaintiff’) vehicle head on. The police report also noted that EMS arrived at the scene and evaluated each occupant involved in accident; all parties refused to go to the hospital. Plaintiff alleged injuries to his right-side ribs, neck, back, chest and dominate left hand as well as damages to his musculoskeletal system. It should be noted that Plaintiff was involved in a prior motor vehicle accident approximately 16 years ago in 2006, wherein he injured his back and neck. Defendant contests liability in addition to the etiology and extent of Plaintiffs alleged injuries. Plaintiff is subject to Limited Tort due to not having insurance coverage of his vehicle that was involved in the said accident. (See The Carrier History Report, attached as Exhibit C.) As such, he is precluded from recovery of non-economic damages unless his injuries rise to the level of “serious injury.” Neither death nor permanent disfigurement are applicable in the instant matter, Thus, in order to recover non-economic damages in the present case, the Plaintiff must establish the existence of a “serious impairment of body function.” (B) DAMAGES CLAIMED: Following the accident of May 12, 2019, Plaintiff treated later that evening at the emergency department of Bryn Mawr Hospital where a CT scan of his chest found a questionable non-displaced fracture of the anterior right second rib. An x-ray of his left hand proved negative for fracture or dislocation. A head CT was unremarkable and cervical CT showed degenerative changes with “no acute injury.” Plaintiff followed up with his primary care physician who referred him for physical therapy for “rib fracture” and “boxer’s fracture” despite the lack of diagnostic supports. On June 4, 2019, Plaintiff was evaluated at Philadelphia Hand to Shoulder by Dr. Meredith Osterman. In-office x-rays were negative for any fracture(s). In light of his ongoing pain complaints, despite the lack of objective injury, Plaintiff was referred for occupational therapy. However, Plaintiff never returned for treatment for his alleged injury(ies). In fact, Plaintiff did not provide any records of medical services received for his alleged injuries after June 4, 2019 visit. To date, Plaintiff has had no injections or surgeries recommended or received for said related injuries. Plaintiff has since been discharged and testified that he has no plans of continuing treatment. As such, no setious injury was sustained by Plaintiff relating to the motor vehicle accident of May 12, 2019. An orthopaedic Independent Medical Examination (IME) of Plaintiff was performed on May 17, 2023 by Dr. Jeffrey Malumed. Plaintiff stated to Dr. Malumed that he injured his left hand, neck, and had a questionable fracture of a right rib. He also communicated that he did not seek out any additional treatment following the one visit on 06/04/2019. (See IME report attached as Exhibit D,) Plaintiff also confirmed that he works in the home improvement field, including roofing and siding, and that he returned to work after being out for approximately 2-3 months and returned to playing guitar and bass with his band after subject accident. Upon examination, Dr. Malumed found Plaintiff's left hand and wrist demonstrated full and complete range of motion of all fingers and the wrist without any limitations. He has no complaints of left hand or left wrist pain in addition to no weakness of the wrist or fingers. Dr. Malumed found no evidence of thenar wasting or atrophy. There was no indication for any further medical treatment for Plaintiffs left hand as Dr. Malumed his left hand pain to be completely resolved. With regard to the questionable right rib fracture, Dr. Malumed found no diagnostic testing demonstrating a rib fracture and any alleged right rib pain had resolved. Examination of Plaintiff's cervical spine showed a full and complete range of motion of the cervical spine with mild pain and Plaintiff had returned to his normal work and recreational activities without any restrictions. Examination of Plaintiff's lumbar spine is completely normal with no complaints of pain or tenderness on palpation. With regard to Plaintiffs cervical spine, Dr. Malumed found that, by history, Plaintiff may have had a cervical strain or sprain but he did not seek any treatment for his neck following subject motor vehicle accident other that the visit to emergency department on May 12, 2019. Dr. Malumed opined that, “He has had no treatment, other than the one emergency room visit and the one evaluation by Dr. Osterman. In the last four years, he has had no treatment to any body parts injured in this motor vehicle accident of 05/12/2019.” {] “Mr. Mayer has not sustained any serious impairment of bodily function as a result of this motor vehicle accident. Any alleged injuries he may have sustained certainly were self-limited and would not have resulted in any significant problems limiting his ability to return to his preinjury work activities or recreational activities within two to four weeks.” Plaintiff testified that he still experiences pain in his wrist, lower back and neck. However, he has not provided any records of additional medical treatment for his alleged pain after his June 4, 2019 visit. Plaintiff further claims that he missed about 2-3 months of work because of his alleged left-hand injury. However, he is self-employed and has no proof of his income admitting that as he has not filed tax returns for at least 4 years. As yet, Plaintiff has not provided any proof of motor vehicle insurance coverage for the said May 12, 2019 accident. A Carrier Discovery Report shows that Plaintiff, the owner of the vehicle involved in the accident, did not have motor vehicle insurance coverage on May 12, 2019. (See Exhibit C.) According to Title 75 of the Pennsylvania General Assembly, Election of Tort Options, in Section 1705(a)(5), “An owner of a currently registered private passenger motor vehicle who does not have financial responsibility shall be deemed to have chosen the limited tort alternative.” Unless Plaintiff can provide proof of motor vehicle insurance on the date of the accident, he will be bound by limited tort as he was the owner of an uninsured vehicle that was involved in the accident. Even if Plaintiff had broken his rib from this accident, it does not rise to the level of “serious bodily injury protracted loss or permanent impairment” and thus does not breach the limited tort threshold. No serious injury was sustained by Plaintiff, Ronald Mayer in the minor May 12, 2019 motor vehicle collision. No body function was seriously impaired. There has been no major impact on his daily for life for an extended period of time. In fact, Plaintiff was able to function and perform all activities of daily living, including his home improvement work consisting of roofing and siding, and playing guitar and bass with his band. He functions primarily as he did before the accident. No serious injury was sustained. (© WITNESSES: Ronald Miller, Plaintiff Defendant, Kristen Prettyman Armani Brown, Co-Defendant Anne Hollyer, Witness 6. Jeffrey Malumed, M.D., defense expert Plaintiff's treating medical providers, including but.not limited to: Bryn Mawr Hospital, Philadelphia Hand to Shoulder, Dr. Meredith Osterman. Any person named, mentioned or otherwise identified in Answers to Interrogatories, Request for Production of Documents, ot depositions taken by any party in connection with this case. Any person named, mentioned or otherwise identified in any paper filed of record in this case. 10. Any petson necessary for impeachment or rebuttal purposes based upon testimony introduced at trial. 11 Any person named, mentioned, or otherwise identified in any Pretrial Statement filed by any party to this action and all supplements thereto filed; and 12. Defendants reserve the right to call as additional liability witnesses any or all other witnesses discovered or named in depositions, interrogatories or any other pleadings filed by any party to this action. Further, Defendants reserve the right to call any and all witnesses necessary for rebuttal. Defendants also reserve the right to supplement this witness list at any time up to and including the time of trial. @) EXHIBITS: Plaintiffs Answers to Interrogatories and Responses to Request for Production; Defendant’s Answers to Interrogatories and Responses to Request for Production; Co-Defendant’s Answers to Interrogatories and Responses to Request for Production; Deposition transcript of Plaintiff, Ronald Miller; Deposition transcript of Co-Defendant, Armani Brown; 6. Deposition transcript of Defendant, Kristen Prettyman; Any exhibit previously marked in any deposition taken in relationship to this matter. IME report and CV of defense medical expert, Jeffrey Malumed, M.D.; All photographs exchanged in discovery; 10. All of Plaintiff's medical records exchanged in discovery; 11 All records obtained via subpoena; 12. Any exhibit listed in the Pretrial Statement or any amendment filed thereto of any party to this litigation. 13. Any exhibit necessary for impeachment or rebuttal proposed based on testimony introduced at trial. 14. Any photographs, diagrams, sketches and/or other illustrations exchanged during discovery. 15. Any statement obtained from any person called as a witness. 16. Any and all documents produced in discovery. 17. All health insurance records, along with social security disability, Medicare, short term disability, and long-term disability records reflecting benefits provided to Plaintiff. 18. Any and all internet or social media postings made by the Plaintiff, including photographs. 19. Defendants reserve the right to introduce any and all documentary evidence in its possession at the trial of the within captioned matter including but not limited to any and all documents, photographs, maps, diagrams or physical evidence whatsoever, named or indicated in the pre-trial statement of any party to this action or in any deposition, answers to interrogatories, response to. request for production of documents or any other pleading filed in the instant case. ) EXPERT REPORT: Jeffrey Malumed, M.D., defense expert, who will testify that Plaintiff has not sustained any serious impairment of bodily function as a result of motor vehicle accident of May 12, 2019 and he has had no treatment for his alleged injuties since the last June 4, 2019 office visit. @) REQUESTED STIPULATIONS: None at this time. © LIABILITY DEFENSE: The exhibits listed in the Pretrial Statement or copies thereof, shall be made available by the party filing the statement. All records listed should have been disclosed previously in discovery. Expert report attached. @) TRIAL LENGTH: Defendant estimates this matter may requite 2-3 days to try. ® LEGAL ISSUES IN THIS CASE: None at this time. Law Offices of Mezzanotte, Hasson & Sichok Danyelle Yondtra, Esquire Attorney for Defendant, Kristin Prettyman EXHIBIT COURT OF COMMON PLEAS DELAWARE COUNTY, PENNSYLVANIA CASE CAPTION DOCKET NO! IST S- 2OoA) Ron ald Ma Cr TAX FOLIO NO ARBITRATION (Please indicate type of act) Kvister Petty man SY Motor Vehicle () Contract MU Vvy\ ( ) Assessment of Damages Armani () Other ( ) Delay Damages (Prime Rate + 1%) REPORT AND AWARD OF ARBITRATORS NOW, this day of Jan. 20 a3, we the undersigned Arbitrators having £% been duly appointed and sworn. ake the folla 2, Award: yt IW) Yow A Wolbers dent Prcthy man Dire | finds Defer dctot Arn, ny Brow 4 1Oo0%% respousi ble fee The lls oy awn a any damages A Fe Pls DAE That may be Owe'’s | ee Please name the parties if there are more than one Plaintiff and/or Defendant, address all counterclaims and cross-claims, and complete percentage of negligence, if applicable. din A-Rellinzerss Job Arbitrator (Pleage boegey print) Ly Le. Sem el gal cator (Pleaseint) C erson Signatare Arbjtfator Sigucture bitrafor ature COUNSEL FOR PARTIES Griéin Evens, ES® SIYNGI3 Attomey Ay D Pre Txuann Attorney ID# Lener Sb a B, ES YOICS Attorney ar S hroury ID# Attormmey ID# Ret [A Deluca, Esse 494947 FILED Attorney Rp , ID# Attorney Ties or sunln evrponr ELAWARE COUNT EXHIBIT Incident Report NETHER PROVIDENCE TOWNSHIP POLICE 99TH DISTRICT 214 SYKES LA WALLINGFORD, PA 19086 Phone: (610)892-2875 Fax: (610)566-6496 Municipality NETHER PROVIDENCE (105) Report Type ACCIDENT Incident # Reference # Location 115 S PROVIDENCE RD - WALLINGFORD 20190512M0008 19086 Landmark Premise HIGHWAY/ROAD/STREET, ETC. Title Criminal Section Point of Entry Code Sub-Section Meth. of Entry Description Patrol Zone Grid Reported 05/12/2019 ane (Sun) Discovered 2| 6006 TRAFFIC ACCIDENT INVOLVING INJURY Last Secure @ Received Dispatched Arrived Cleared 15:59 Status CLOSED/CLEARED Disposition Clear Date 05/12/2019 Badge 9928 - PTLM MICHAEL WORRELL [= ——= == — _ Additional Officers Officers Date Activity 9931 PTLM ROBERT BRAKE if ASSISTS/OFFICER 9944 SGT. ROBERT ELMORE ff ASSISTS/OFFICER SS — = Vehicles Year, Make, Model Style Color License-State VIN/Serial#t Owner 2016, HONDA, HARDTOP Gray KFX3987-PA 5FNRL5H30GB155119 KRISTEN M PRETTYMAN ODYSSEY (MINIVA 12 W POSSUM HOLLOW RD ROSE VALLEY, PA 19086 Vehicle towed by LUONGOS TOWING to LUONGOS TOWING Insurance Co. LIBERTY MUTUAL - 36447 Policy No. AOS-288-160973-40-9 0 Title 77023416801 2006, HONDA, CivIC SEDAN, 4 DOOR Gray KWDS5586-PA 1HGFA16586L017363 ARMANI C BROWN (AND CRX) 1247 EDGEHILL RD DARBY, PA 19023 Vehicle towed by LUONGOS to LUONGOS Insurance Co. PROGRESSIVE - 32786 Policy No. 912367941 Title 62606096 Investigating Officer Date Approving Officer Sonate NETHER PROVIDENCE TOWNSHIP POLICE Page 1 of 6 Printed by: KIM DANIEL (05/20/2019 03:10:27 PM) 6006 - TRAFFIC ACCIDENT INVOLVING INJURY} Year, Make, Model Style Color License-State VIN/Serial# Owner 2006, CHEVROLET, PICKUP Gray ZGT8280-PA 1GCHK29U46E210840 RON DEAN MAYER 309 FIRST AV NEWTOWN SQUARE, PA 19073} Vehicle towed by LUONGOS TOWING to LUONGOS TOWING Insurance Co. PROGRESSIVE - 11770 Policy No. 01698418-7 Title 62893126 NETHER PROVIDENCE TOWNSHIP POLICE Page 2 of 6 Printed by: KIM DANIEL (05/20/2019 03:10:27 PM) 6006 - TRAFFIC ACCIDENT INVOLVING INJURY] ree = So SSS — “Persons Involved BROWN, ARMANI C Arrest Date : Disposition Date Rok Incident Classificatio! How Charged ispositior DRIVER 6006 TRAFFIC ACCIDENT INVOLVING INJURY Age DOB 22- Height [ Race BLACK Weight 0 Home Addr 1247 EDGEHILL RD Sex MALE Hair DARBY, PA 19023 Ethnicity UNKNOWN Eyes Marital Stat Build Home Ph # Residency Non-Resident Compiex. Work Ph # SSN Cell Ph # Gang Other Ph # No Photo Tattoo E-Mail Clothing Employer GBM Id -Entered tt -Released // Occupation OLN/State Addl Addr None Injury HOLLYER, ANNE Arrest Date : Disposition Date Ingic nt Classifi ion How Charged Dis Witess 6006 TRAFFIC ACCIDENT INVOLVING INJURY i Age-DOB 55- Height [ Race WHITE Weight 0 Home Addr 103 BLACKTHORN RD Sex FEMALE Hair WALLINGFORD, PA 19086 Ethnicity NON-HISPANIC Eyes Marital Stat Build Home Ph # Residency Resident Complex. Work Ph # SSN Cell Ph# Gang Other Ph # No Photo Tattoo E-Mail Clothing Employer GBM Id -Entered Vw Released // Occupation OLN/State Addl Addr None Injury NETHER PROVIDENCE TOWNSHIP POLICE Page 3 of 6 Printed by: KIM DANIEL (05/20/2029 03:10:27 PM) sees 6006 - TRAFFIC ACCIDENT INVOLVING INJURY] MAYER, RON DEAN Arrest Date : Disposition Date : Role Incident Classification How Charger Disposition DRIVER/VEHICLE OWN | 6006 TRAFFIC ACCIDENT INVOLVING INJURY Alias Age-DOB 54- Height [ Race WHITE Weight 0 Home Addr 309 FIRST AV Sex MALE Hair NEWTOWN SQUARE, PA 19073 Ethnicity UNKNOWN Eyes Marital Stat Build Home Ph # Residency Non-Resident Complex. Work Ph # SSN Celt Ph# Gang Other Ph # No Photo Tattoo E-Mail Clothing Employer GBM Id -Entered tt -Released it Occupation OLN/State Addl Addr None Injury XXXXXXXXXKXXX Arrest Date : Disposition Date : Incident Classificatior How Charged Dispositior PASSENGER 6006 TRAFFIC ACCIDENT INVOLVING INJURY Alias [Pouvenite Disp: 17 UNDEFINED Age-DOB - Height Race WHITE Weight 0 Home Addr Sex MALE Hair Ethnicity Eyes Marital Stat Build Home Ph # Residency Non-Resident Complex. Work Ph # SSN Cell Ph# Gang Other Ph # No Photo Tattoo E-Mail Clothing School GBM Id -Entered it -Released i Occupation OLN/State Addl Addr None Injury Juvenile! NETHER PROVIDENCE TOWNSHIP POLICE Page 4 of 6 Printed by: KIM DANIEL (05/20/2019 03:10:27 PM) [ 6006 - TRAFFIC ACCIDENT INVOLVING INJURY| PRETTYMAN, KRISTEN M Arrest Date : Disposition Date : Incident ssifical How Chargex Dispositior BRIVERIVEHICLE OWN 6006 TRAFFIC ACCIDENT INVOLVING INJURY Alias Age-DOB 41- Height l Race WHITE Weight 0 Home Addr 12 W POSSUM HOLLOW RD Sex FEMALE Hair ROSE VALLEY, PA 19086 Ethnicity UNKNOWN Eyes Marital Stat Build Home Ph # Residency Non-Resident Complex. Work Ph # SSN Cell Ph# Gang Other Ph # No Photo Tattoo E-Mail Clothing Employer GBM Id -Entered tt -Released i Occupation OLN/State Addl Addr None Injury SELLETTI JR., ANTHONY Arrest Date : Disposition Date : Incident Classification How Charger Disposition PASSENGER 6006 TRAFFIC ACCIDENT INVOLVING INJURY Age DOB 42 - Height 6'01" [ Race WHITE Weight Q Home Addr 127 W LAUGHEAD AV Sex MALE Hair LINWOOD, PA 19061 Ethnicity NON-HISPANIC Eyes Marital Stat Build Home Ph # Residency Non-Resident Complex. MEDIUM Work Ph # SSN Cell Ph# Gang Other Ph # No Photo Tattoo E-Mail Clothing Employer GBM Id -Entered i -Released Vt Occupation OLN/State Addl Addr None Injury NETHER PROVIDENCE TOWNSHIP POLICE Page 5 of 6 Printed by: KIM DANIEL (05/20/2019 03:10:27 PM) [ 6006 - TRAFFIC ACCIDENT INVOLVING INJURY] Main Narrative PTLM MICHAEL WORRELL (9928) 05/12/2019 14:52 - 9928 PTLM MICHAEL WORRELL On May 12th, 2019 at 1452 hours, Nether Providence Police were dispatched to 205 S. Providence Rd. and 115 S. Providence Rd. for repert of a 3 vehicle accident with injuries reported. Upon arrival, | observed ail vehicles in front of 115 S. Providence Rd. | immediately asked each of the occupants if they were in need of medical attention. All parties stated they were just a little shaken up but did not need immediate attention. EMS came to the scene and began evaluating each of the occupants. All occupants refused to go to the hospital at this time. | met with the driver of Unit 1, identified as Kristen Prettyman, driver of the 2016 Honda Odyssey, who stated she was traveling south bound on the 100 block of S. Providence Rd. when she observed Unit 2 making a left turn into Manor Care Nursing Home. She continued going straight, but Unit 2 stopped with it's rear still blocking S. Providence Rd. causing Unit 1 to swerve left, first striking Unit 2, then Striking Unit 3 in the opposite lane of traffic. Unit 1 sustained severe damage to the 12 0 clock position of the vehicle. This vehicle was towed to Luongo's towing 1 met with the driver of Unit 2, identified as Armani Brown, driver of the 2006 Honda Civic, who stated he was traveling north bound on the 100 block of S. Providence Rd. when began turning into the Manor Care Nursing Home, before being struck by Unit 1. Unit 2 sustained severe damage to the 5 0 clock position of the vehicle. This vehicle was towed to Luongo’s towing. | met with the driver of Unit 3, identified as Ron Mayer, driver of the 2006 Chevrolet Pick Up, who stated he was traveling north bound behind Unit 2, when he observed Unit 2 turn left into the entrance of Manor Care and then stop, leaving the rear end of the vehicle in tre roadway, causing Unit 1 to strike Unit 2 then swerve head on into Unit 3. Unit 3 sustained severe damage to the 12 0 clock position. This vehicle was towed to Luongo’s towing. [A witness identified as Anne Hollyer stated he observed Unit 2 turn left into the Manor Care entrance and she doesn't believe he cut off Unit 1 but stated Unit2 did take it's time getting into the entrance and Unit 1 didn’t have enough time to react. Anne Hollyer was traveling south bound behind Unit 4 Notice of accident forms, car fax cards, and Luongo's business cards were given to each of the drivers and | explained how to get a copy of the report. It should be noted, the driver of Unit 2 came up to me while Unit 2 was on the tow truck and asked if he could have a private tow truck come out to get the vehicle. | advised him that it was already too late for that. He then put me on the phone with someone who stated they were the owner of the vehicle. The caller was irate and stated | was breaking the law by not letting him tow the vehicle to his own tow yard. | advised the cailer that the vehicle was already traveling down the road to Luongo's towing and advised him to contact his insurance company. Clear. State Crash Report#: W0735219 will be compieted next shift. NETHER PROVIDENCE TOWNSHIP POLICE Page 6 of 6 Printed by: KIM DANIEL (05/20/2019 03:10:27 PM) EXHIBIT Carrier Discovery Report Page of Claim #: 039903179 Carrier Discovery Report Date Ordered: 7/11/2019 Report Status: Complete with Results Order ID: 129315522734 Date of Report: 7/11/2019 Important: The Public Records and commercially available data sources used on reports have errors. Data is sometimes entered poorly, processed incorrectly and is generally not free from defect. This system should not be relied upon as definitively accurate. Before relying on any data this system supplies, it should be independ fenly vere For Secretary of State documents, the following data is for information purposes only and is not an official record. Certified copies may be rom that individual state's Department of State, The criminal record data in this product ar service may include records that have sxpunged, sealed, or otherwise have become inaccessible to the public since the date on which the data was last updated or collected. Accurint does not constitu cor report as that term is defined in ral Fait Credit Reporting Act, 15 USC 1681 et seq. (FCRA). Accordingly, Accurint ‘may not be used in whole or in part as afactor in determining eligibility for cre insurance, employment or another permissible purpose under the FCF Your DPPA Perr iss je Use: Insurance Your GLBA Pert iss le Us Fraud Prevention or Detection Your DMF Permissible U : Legitimate Fraud Prevention Interest Search Request. VIN Date of Loss” Recap Information 4GCHK29U46E210840 Carrier overy Auto Reference #:19193020601865 Carrier Discovery Current Policy Found: # of Prior Possible Search: 2 Record(s) Policies Lapse: Found Found: Current Policy CARRIER: ERIE ‘AMB: 00348 POL:0041806586 TYPE:AU NAIC:26271 INSURANCE EXCH INCEPTIO! ‘STATUS: IN- POL STATE: LAST CANCEL 04/18/1995 EFFECT PA REASON: POLICY: 04/18/2019 - 04/18/2020, Policy Holders POLICY HOLDER NAME STATUS SUBJECT EFFECTIVE DATES CASPER, CHARLES Jj III (PRIMARY) os 04/18/2019 - 04/18/2020 CASPER, BETH ANN (LISTED) os 04/18/2019 - 04/18/2020 CASPER, JAMIE N (LISTED) os 04/18/2019 - 04/18/2020 CASPER, JACOB CHARLES (LISTED) os 04/18/2019 - 04/18/2020 CASPER, JESSICA L (LISTED) os 04/18/2019 - 04/18/2019 Vehicles VEHICLE VEHICLE MAKE: YEAR VIN NUMBER: COVERAGE EFFECTIVE DATES NOTIFICATION GMC 15 1GT22YEG6FZ558348 BI PD NB UB CO CP 04/18/2019 04/18/2016 04/18/2020 ToYO 15 2T1BURHE1FC272539 BI PD NB UB CO CP 04/18/2019 12/08/2016 oT 04/18/2020 TOYO 14 STDBKRFH6ES016849 BI PD NB UB CO CP 04/18/2019 04/18/2018 oT 04/18/2020 SUBA 12 JF2SHADC6CH461352 BI PD NB UB CO CP 04/18/2019 08/02/2018 oT 04/18/2019 NISS 13 {N4AL3AP3DC112293 BI PD NB UB CO CP 04/18/2018 04/18/2016 OTRR 04/18/2018 HYUN 13 KMHDH4AE3DU637695 BI PD NB UB CO CP 04/18/2017 04/18/2016 oT RR 01/19/2018 https://secure.accurint.com/app/bps/report 7/12/2019 Carrier Discovery Report Page of VEHICLE VEHICLE MAKE: YEAR VIN NUMBER: COVERAGE EFFECTIVE DATES NOTIFICATION TOYO 08 2T1BR32E98C933647 BI PD NB UB CO CP 04/18/2016 04/18/2016 oT 12/08/2016 ToYO 02 STDBT44A82S074759 BIPD NB UB CP OT 04/18/2015 02/29/2008 11/09/2015 CHEV 06 1GCHK29U46E210840 BIPD NB UB CO CP 04/18/2015 02/29/2008 oT 10/27/2015 Policy History CARRIER: STATE AMB: 88381 POL:0695381 TYPE: AU NAIC:25178 FARM INSURANCE, INCEPTION: STATUS: POL STATE: LAST CANCEL 04/24/2005 EXPIRED PA REASON: POLICY: 10/24/2018 - 04/24/2019 Policy Holders POLICY HOLDER NAME STATUS SUBJECT EFFECTIVE DATES RYAN, THOMAS J (PRIMARY) os 10/24/2018 - 04/24/2019 RYAN, MARYLOU (LISTED) os 10/24/2018 - 04/24/2019 Vehicles VEHICLE VEHICLE MAKE: YEAR VIN NUMBER: COVERAGE EFFECTIVE DATES NOTIFICATION TOYT 18 STDDZRFH1JS495669 BI PD NB UB CO CP 10/24/2018 12/21/2017 04/24/2019 TOYT 16 STDDK3DC5GS139808 BI PD NB UB CO CP 10/24/2017 08/01/2016 MP 12/21/2017 VOL 16 YV4612RKXG2868123 BI PD NB UB CO CP 04/24/2016 03/14/2016 08/01/2016 TOYT 13 STDDK3DC6DS070140 BI PD NB UB CO CP 10/24/2015 08/27/2013 MP 03/14/2016 TOYT 12 STDDK3DCXCS040363 BI PD NB UB CO CP 04/24/2013 03/28/2012 MP 08/27/2013 JEEP "1 1J4RR4GT4BC596214 BI PD NB UB CO CP 10/24/2011 02/23/2011 03/28/2012 TOYT 10 4T3BK3BB4AU039769 BI PD NB UB CO CP 11/02/2010 07/14/2010 MP 02/23/2011 SUBA o7 4S4WX85D774406808 BI PD NB UB CO CP 04/24/2010 10/24/2006 07/14/2010 CHEV 06 1GCHK29U46E210840 BI PD NB UB CO CP 04/24/2006 04/24/2006 MP 08/21/2006 - - THIS REPORT IS THE RESULT OF SEARCHING FOR POLICY HISTORY ON THE INDIVIDUALS OR VINS IN THE HOUSEHOLD VIA CARRIER D: CLAIMS DISCOVERY AND ACCIDENT DATA. THE INFORMATION SHOULD BE INDEPENDENTLY VERIFIED PRIOR TO USE.SUBSCRIBER SHOULI INDEPENDENTLY DETERMINE WHAT ACTION, IF ANY, TO TAKE. CARRIER DISCOVERY AND CLAIMS DISCOVERY ARE SERVICE MARKS OF LEXISNEXIS RISK SOLUTIONS. - https://secure.accurint.com/app/bps/report 7/12/2019 EXHIBIT A Premier’ ORTHOPAEDICS Jeffrey Malumed, M.D. Richard Zamarin, M.D, Priscilla Cavanaugh, M.D. Armando Mendez, M.D. Joseph Stellabotte, M.D. David Yucha, M.D. May 17, 2023 Ms. Jessica Morales Certified Medical Consultants 1401 NW 136th Avenue Suite 203 Sunrise, FT. 33323 INDEPENDENT MEDICAL EVALUATION RE: RONALD MAYER DOL: 05/12/2019 Claim: 399031790004 Dear Ms. Morales, This is the Independent Medical Examination you requested on Ronald Mayer. This examination was conducted after performing a thorough history and physical examinatio