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Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 May 11 1:32 PM-22CV003269
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IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO
JEMILATU BANGURA, Administrator of the :
Estate of Dominion Bangura, deceased, et al., : CASE NO. 22-CV-3269
PLAINTIFFS,
JUDGE K. PHIPPS
vs.
OHIOHEALTH RIVERSIDE
METHODIST HOSPITAL, et al.,
DEFENDANTS.
REPLY IN SUPPORT OF MOTION TO RECONSIDER
COURT’S APRIL 25, 2023 ORDER GRANTING PLAINTIFF’S EMERGENCY
MOTION TO EXTEND CASE MANAGEMENT SCHEDULE OF DEFENDANTS
OHIOHEALTH RIVERSIDE METHODIST HOSPITAL, OHIOHEALTH
CORPORATION, MEAGAN SCHNEIDERMAN, M.D., VALERIE SCHOTT,
M.D., EMILY MISBRENER, D.O., MAHIMA PRASAD, M.D., AMBERN.
FERRARO, RN, MADDALYNN HUFFMAN, RN, KATELYN MEISTER, RN,
AND MARYBETH D’AMICO, RN
This medical negligence case was filed by Plaintiffs Jemilatu Bangura,
Administrator of the Estate of Dominion Bangura, deceased, Jemilatu Bangura,
Individually, and Paul Bangura, Individually (hereinafter collectively “Plaintiff”) on May
13, 2022. Thereafter, the parties jointly prepared a Rule 26(F) Conference Report setting
case deadlines, and the Court entered an Agreed Amended Case Management Schedule
with those very deadlines on August 25, 2022. The Plaintiffs then did nothing thereafter,
even as discovery disclosure deadlines came and went.
As such, on April 3, 2023, Defendants Avina Women’s Care dba MaternOhio
Clinical Associates, Inc., MaternOhio Clinical Associates, Inc., Carl Krantz, M.D., and
Amber Murphy Mack, M.D. (hereinafter collectively “MaternOhio Defendants”) filed a
Motion for Summary Judgment on the basis that because the Plaintiff failed to make any
disclosures in the 11 months of the case’s pendency, which included a failure to identify
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the expert witnesses necessary to meet the Plaintiff's evidentiary burden at trial, the
Defendants were entitled to judgment as a matter of law. Thereafter, on April 17, 2023,
Defendants OhioHealth Riverside Methodist Hospital, OhioHealth Corporation, Meagan
Schneiderman, M.D., Valerie Schott, M.D., Emily Misbrener, D.O., Mahima Prasad, M.D.,
Amber N. Ferraro, RN, Maddalynn Huffman, RN, Katelyn Meister, RN, and Marybeth
D’Amico, RN (hereinafter collectively “OhioHealth Defendants”) filed a Motion for
Summary Judgment on the same grounds (hereinafter collectively “Motions for Summary
Judgment”).
Rather than replying to those dispositive motions, the Plaintiff then filed Plaintiff's
Emergency Motion to Extend Case Management Schedule and Motion for Telephone
Pretrial (“Plaintiff's “Emergency” Motion”) on April 24, 2023, in which the Plaintiff
couched the dispositive issue of the missed deadlines as a scheduling concern resulting
from an exchange of counsel. The Court granted the Plaintiff's “Emergency” Motion the
following day, on April 25, 2023, without first hearing the opposition of the Defendants
to the extension. As such, on April 27, 2023, the OhioHealth Defendants filed Motion to
Reconsider Court’s April 25, 2023 Order Granting Plaintiff's Emergency Motion to
Extend Case Management Schedule of Defendants OhioHealth Riverside Methodist
Hospital, OhioHealth Corporation, Meagan Schneiderman, M.D., Valerie Schott, M.D.,
Emily Misbrener, D.O., Mahima Prasad, M.D., Amber N. Ferraro, RN, Maddalynn
Huffman, RN, Katelyn Meister, RN, and Marybeth D’Amico, RN (“OhioHealth
Defendants’ Motion for Reconsideration”) to reconsider that decision and instead exclude
the Plaintiff's undisclosed experts, and the MaternOhio Defendants did the same on May
2, 2023 in Motion of Defendants MaternOhio Clinical Associates, Inc. dba Avina
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Women’s Care, Carl Krantz, M.D. and Amber Murphy Mack, M.D. for Reconsideration
of the Court’ April 25, 2023 Order Granting Plaintiffs’ Emergency’ Motion to Extend
Case Management Schedule (hereinafter collectively “Motions to Reconsider”).
The Plaintiff responded to the Motions to Reconsider on May 4, 2023 in Plaintiff's
Brief in Opposition to Defendants’ Motions for Reconsideration Filed on April 27, 2023
and May 2, 2023 (“Plaintiff's Brief in Opposition”), and therein stated that she believed
that the Defendants should have reminded Plaintiffs counsel to advance their client’s case
and that the Defendants had no basis for their Motions for Reconsideration. This is not
so. As such, the MaternOhio Defendants filed a Reply Brief of Defendants MaternOhio
Clinical Associates, Inc. dba Avina Women’s Care, Carl Krantz, M.D. and Amber
Murphy Mack, M.D. in Support of Motion for Reconsideration (“MaternOhio Reply
Brief”) on May 5, 2023 and therein asserted that the Defendants have no duty to advance
the Plaintiff’s case, and that not only are motions to reconsider permitted under the Ohio
Rules of Civil Procedure, but they were necessary here because the Plaintiff had the
Plaintiff's “Emergency” Motion granted before the Defendants could respond. As the
OhioHealth Defendants concur on the arguments that the MaternOhio Defendants
advanced therein, the MaternOhio Reply Brief is incorporated herein by reference.
A. Plaintiffs Counsel’s Statements that the Defendants Should Have
Reminded Them of Their Obligations to Their Clients Is Not a Legal
Argument.
The MaternOhio Defendants advance a number of valuable arguments in response
to the Plaintiff's “disappointment” that defense counsel did not remind them to fulfill
their obligations to their clients, as expressed in the Plaintiff’s Brief in Opposition, all of
which are incorporated herein by reference. The only additional point that the
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OhioHealth Defendants would add is that the Plaintiff's belief that the Defendants should
not move for summary judgment where the Plaintiff fails to meet the Plaintiffs
evidentiary burden is not a legal argument. As such, the Plaintiffs assertions that the
Defendants should have reminded Plaintiff's counsel of their obligations and not moved
for summary judgment when it became clear that the Plaintiff could not meet that burden
at trial is unavailing.
B. The Motions for Reconsideration Are Allowed by the Rules of Civil
Procedure and Are Appropriate Given the Immediate Granting of the
Plaintiff's “Emergency” Motion Before the Defendants Could Oppose
It.
In addition to the Plaintiffs argument that the Defendants should have reminded
Plaintiffs counsel to advance the Plaintiff’s claims while concurrently defending against
those very same claims, the Plaintiff argues that there is no basis for a motion for
reconsideration. However, as the MaternOhio Defendants clearly argue, there not only is
a valid basis for such a motion, but that type of motion was necessary here to allow the
Defendants to oppose the Plaintiff's “Emergency” Motion. As such, any argument to the
contrary is without merit.
C. The Plaintiff Contests Neither that the Plaintiff Has Not Provided a
Basis to Excuse Her Neglect Nor that the Extension of Deadlines Will
Prejudice the Defendants and Burden the Court.
Finally, in the OhioHealth Defendants’ Motion to Reconsider, the OhioHealth
Defendants argue that because (a) the Plaintiff has not provided the Court with any basis
to excuse her/her counsel’s neglect, (b) the extension granted will prejudice the
Defendants, and (c) the extension granted will burden the Court’s schedule, the Court
should reconsider that extension pursuant to Price v. Cleveland Clinic Found., 33 Ohio
App.3d 301, 306, 515 N.E.2d 931, 936 (8th Dist.1986) (holding that when considering
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whether to use its discretion to permit or exclude undisclosed or belatedly-disclosed
expert testimony, a trial court may contemplate “(1) the proponent's justification for the
delayed disclosure of the expert's identity or the expert's report, (2) the opponent's
prejudice from that delay, and (3) the burden on the court’s schedule to accommodate the
respective parties’ interests.”) Indeed, because of the lack of excusable neglect, the
prejudice to the Defendants, and the burden to the Court, the OhioHealth Defendants
argued that instead of extending the discovery deadlines and maintaining the trial date,
which would force fifteen months of discovery to occur in eight months, the Plaintiff's
undisclosed expert witnesses should instead be excluded, and the Plaintiff should either
defend her claims on summary judgment or dismiss the case and refile without prejudice
pursuant to Civ.R. 41(A), which would put the case in the more appropriate position: the
start of a 24-month case schedule.
In the Plaintiffs Brief in Opposition, the Plaintiff does not contest any of those
three points, and instead again provides no basis to find the neglect excusable outside of
onclusory statements, does not contest the prejudice to the Defendants of cutting the
time for discovery in half, and does not challenge the assertion that this impossible
discovery timeline will burden the Court’s schedule. Indeed, as those points remain
unrebutted, the Motions to Reconsider should be granted.
D. Conclusion
For the foregoing reasons, Defendants OhioHealth Riverside Methodist Hospital,
OhioHealth Corporation, Meagan Schneiderman, M.D., Valerie Schott, M.D., Emily
Misbrener, D.O., Mahima Prasad, M.D., Amber N. Ferraro, RN, Maddalynn Huffman,
RN, Katelyn Meister, RN, and Marybeth D’Amico, RN respectfully request that this Court
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reconsider its April 25, 2023 Order and impose the discovery sanction of excluding the
Plaintiff's expert witnesses at trial due to lack of disclosure instead of extending the case
deadlines.
Respectfully submitted,
s/ Karin M. Long
Bobbie S. Sprader (0064015)
bsprader@brickergraydon.com
Karen L. Clouse (0037294)
kelouse@brick aydon.com
Karin M. Long (0101480)
kmlong @brickereraydon.com
Bricker Graydon LLP
100 South Third Street
Columbus, Ohio 43215-4291
Phone: (614) 227-2300
Fax: (614) 227-2390
Counsel for Defendants,
OhioHealth Riverside Methodist Hospital,
OhioHealth Corporation,
Meagan Schneiderman, M.D.,
Valerie Schott, M.D.,
Emily Misbrener, D.O.,
Mahima Prasad, M.D.,
Amber N. Ferraro, RN,
Maddalynn Huffman, RN,
Katelyn Meister, RN, and
Marybeth D’Amico, RN
Of Counsel:
Chester P. Porembski, Esq. (0000754)
OhioHealth Corporation
David P. Blom Administrative Campus
3430 OhioHealth Parkway, 5‘ Floor
Columbus, OH 43202
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true copy of the foregoing Reply in Support
of Motion to Reconsider Court’s April 25, 2023 Order Granting Plaintiffs Emergency
Motion to Extend Case Management Schedule of Defendants OhioHealth Riverside
Methodist Hospital, OhioHealth Corporation, Meagan Schneiderman, M.D., Valerie
Schott, M.D., Emily Misbrener, D.O., Mahima Prasad, M.D., Amber N. Ferraro, RN,
Maddalynn Huffman, RN, Katelyn Meister, RN, and Marybeth D’Amico, RN was served
via the Court’s electronic filing system, and/or regular U.S. mail, postage prepaid, this
11th day of May, 2023
Meghan P. Connolly, Esq.
Lowe, Scott, Fisher, Co., LPA
1660 West 24 Street
610 Skylight Office Tower
Cleveland, OH 44113
mconnoll sflayv OR
Counsel for Plaintiffs
Craig S. Tuttle, Esq.
LEESEBERG TUTTLE
175 S. Third Street:
Penthouse One
Columbus, Ohio 43215
chuttle@) sebergla LOM
Counsel for Plaintiffs
FrederickA. Sewards, Esq.
Arnold, Todaro, Welch & Foliano, Co., LPA
2075 Marble Cliff Office Park
Columbus, OH 43215
Counsel for Defendants,
Avina Women’s Care dba MaternOhio Clinical Associates, Inc.,
MaternOhio Clinical Associates, Inc., Carl Krantz, M.D., and
Amber Murphy Mack, M.D.
‘s/ KarinM. Long
Karin M. Long, Esq
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Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 May 11 1:32 PM-22CV003269 0G383 - Y2 IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO JEMILATU BANGURA, Administrator of the : Estate of Dominion Bangura, deceased, et al., : CASE NO. 22-CV-3269 PLAINTIFFS, JUDGE K. PHIPPS vs. OHIOHEALTH RIVERSIDE METHODIST HOSPITAL, et al., DEFENDANTS. REPLY IN SUPPORT OF MOTION TO RECONSIDER COURT’S APRIL 25, 2023 ORDER GRANTING PLAINTIFF’S EMERGENCY MOTION TO EXTEND CASE MANAGEMENT SCHEDULE OF DEFENDANTS OHIOHEALTH RIVERSIDE METHODIST HOSPITAL, OHIOHEALTH CORPORATION, MEAGAN SCHNEIDERMAN, M.D., VALERIE SCHOTT, M.D., EMILY MISBRENER, D.O., MAHIMA PRASAD, M.D., AMBERN. FERRARO, RN, MADDALYNN HUFFMAN, RN, KATELYN MEISTER, RN, AND MARYBETH D’AMICO, RN This medical negligence case was filed by Plaintiffs Jemilatu Bangura, Administrator of the Estate of Dominion Bangura, deceased, Jemilatu Bangura, Individually, and Paul Bangura, Individually (hereinafter collectively “Plaintiff”) on May 13, 2022. Thereafter, the parties jointly prepared a Rule 26(F) Conference Report setting case deadlines, and the Court entered an Agreed Amended Case Management Schedule with those very deadlines on August 25, 2022. The Plaintiffs then did nothing thereafter, even as discovery disclosure deadlines came and went. As such, on April 3, 2023, Defendants Avina Women’s Care dba MaternOhio Clinical Associates, Inc., MaternOhio Clinical Associates, Inc., Carl Krantz, M.D., and Amber Murphy Mack, M.D. (hereinafter collectively “MaternOhio Defendants”) filed a Motion for Summary Judgment on the basis that because the Plaintiff failed to make any disclosures in the 11 months of the case’s pendency, which included a failure to identify 18615485v1 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 May 11 1:32 PM-22CV003269 0G383 - Y¥3 the expert witnesses necessary to meet the Plaintiff's evidentiary burden at trial, the Defendants were entitled to judgment as a matter of law. Thereafter, on April 17, 2023, Defendants OhioHealth Riverside Methodist Hospital, OhioHealth Corporation, Meagan Schneiderman, M.D., Valerie Schott, M.D., Emily Misbrener, D.O., Mahima Prasad, M.D., Amber N. Ferraro, RN, Maddalynn Huffman, RN, Katelyn Meister, RN, and Marybeth D’Amico, RN (hereinafter collectively “OhioHealth Defendants”) filed a Motion for Summary Judgment on the same grounds (hereinafter collectively “Motions for Summary Judgment”). Rather than replying to those dispositive motions, the Plaintiff then filed Plaintiff's Emergency Motion to Extend Case Management Schedule and Motion for Telephone Pretrial (“Plaintiff's “Emergency” Motion”) on April 24, 2023, in which the Plaintiff couched the dispositive issue of the missed deadlines as a scheduling concern resulting from an exchange of counsel. The Court granted the Plaintiff's “Emergency” Motion the following day, on April 25, 2023, without first hearing the opposition of the Defendants to the extension. As such, on April 27, 2023, the OhioHealth Defendants filed Motion to Reconsider Court’s April 25, 2023 Order Granting Plaintiff's Emergency Motion to Extend Case Management Schedule of Defendants OhioHealth Riverside Methodist Hospital, OhioHealth Corporation, Meagan Schneiderman, M.D., Valerie Schott, M.D., Emily Misbrener, D.O., Mahima Prasad, M.D., Amber N. Ferraro, RN, Maddalynn Huffman, RN, Katelyn Meister, RN, and Marybeth D’Amico, RN (“OhioHealth Defendants’ Motion for Reconsideration”) to reconsider that decision and instead exclude the Plaintiff's undisclosed experts, and the MaternOhio Defendants did the same on May 2, 2023 in Motion of Defendants MaternOhio Clinical Associates, Inc. dba Avina 2 18615485v1 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 May 11 1:32 PM-22CV003269 0G383 - Y4 Women’s Care, Carl Krantz, M.D. and Amber Murphy Mack, M.D. for Reconsideration of the Court’ April 25, 2023 Order Granting Plaintiffs’ Emergency’ Motion to Extend Case Management Schedule (hereinafter collectively “Motions to Reconsider”). The Plaintiff responded to the Motions to Reconsider on May 4, 2023 in Plaintiff's Brief in Opposition to Defendants’ Motions for Reconsideration Filed on April 27, 2023 and May 2, 2023 (“Plaintiff's Brief in Opposition”), and therein stated that she believed that the Defendants should have reminded Plaintiffs counsel to advance their client’s case and that the Defendants had no basis for their Motions for Reconsideration. This is not so. As such, the MaternOhio Defendants filed a Reply Brief of Defendants MaternOhio Clinical Associates, Inc. dba Avina Women’s Care, Carl Krantz, M.D. and Amber Murphy Mack, M.D. in Support of Motion for Reconsideration (“MaternOhio Reply Brief”) on May 5, 2023 and therein asserted that the Defendants have no duty to advance the Plaintiff’s case, and that not only are motions to reconsider permitted under the Ohio Rules of Civil Procedure, but they were necessary here because the Plaintiff had the Plaintiff's “Emergency” Motion granted before the Defendants could respond. As the OhioHealth Defendants concur on the arguments that the MaternOhio Defendants advanced therein, the MaternOhio Reply Brief is incorporated herein by reference. A. Plaintiffs Counsel’s Statements that the Defendants Should Have Reminded Them of Their Obligations to Their Clients Is Not a Legal Argument. The MaternOhio Defendants advance a number of valuable arguments in response to the Plaintiff's “disappointment” that defense counsel did not remind them to fulfill their obligations to their clients, as expressed in the Plaintiff’s Brief in Opposition, all of which are incorporated herein by reference. The only additional point that the 3 18615485v1 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 May 11 1:32 PM-22CV003269 0G383 - Y5 OhioHealth Defendants would add is that the Plaintiff's belief that the Defendants should not move for summary judgment where the Plaintiff fails to meet the Plaintiffs evidentiary burden is not a legal argument. As such, the Plaintiffs assertions that the Defendants should have reminded Plaintiff's counsel of their obligations and not moved for summary judgment when it became clear that the Plaintiff could not meet that burden at trial is unavailing. B. The Motions for Reconsideration Are Allowed by the Rules of Civil Procedure and Are Appropriate Given the Immediate Granting of the Plaintiff's “Emergency” Motion Before the Defendants Could Oppose It. In addition to the Plaintiffs argument that the Defendants should have reminded Plaintiffs counsel to advance the Plaintiff’s claims while concurrently defending against those very same claims, the Plaintiff argues that there is no basis for a motion for reconsideration. However, as the MaternOhio Defendants clearly argue, there not only is a valid basis for such a motion, but that type of motion was necessary here to allow the Defendants to oppose the Plaintiff's “Emergency” Motion. As such, any argument to the contrary is without merit. C. The Plaintiff Contests Neither that the Plaintiff Has Not Provided a Basis to Excuse Her Neglect Nor that the Extension of Deadlines Will Prejudice the Defendants and Burden the Court. Finally, in the OhioHealth Defendants’ Motion to Reconsider, the OhioHealth Defendants argue that because (a) the Plaintiff has not provided the Court with any basis to excuse her/her counsel’s neglect, (b) the extension granted will prejudice the Defendants, and (c) the extension granted will burden the Court’s schedule, the Court should reconsider that extension pursuant to Price v. Cleveland Clinic Found., 33 Ohio App.3d 301, 306, 515 N.E.2d 931, 936 (8th Dist.1986) (holding that when considering 4 18615485v1 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 May 11 1:32 PM-22CV003269 0G383 - Y6é whether to use its discretion to permit or exclude undisclosed or belatedly-disclosed expert testimony, a trial court may contemplate “(1) the proponent's justification for the delayed disclosure of the expert's identity or the expert's report, (2) the opponent's prejudice from that delay, and (3) the burden on the court’s schedule to accommodate the respective parties’ interests.”) Indeed, because of the lack of excusable neglect, the prejudice to the Defendants, and the burden to the Court, the OhioHealth Defendants argued that instead of extending the discovery deadlines and maintaining the trial date, which would force fifteen months of discovery to occur in eight months, the Plaintiff's undisclosed expert witnesses should instead be excluded, and the Plaintiff should either defend her claims on summary judgment or dismiss the case and refile without prejudice pursuant to Civ.R. 41(A), which would put the case in the more appropriate position: the start of a 24-month case schedule. In the Plaintiffs Brief in Opposition, the Plaintiff does not contest any of those three points, and instead again provides no basis to find the neglect excusable outside of onclusory statements, does not contest the prejudice to the Defendants of cutting the time for discovery in half, and does not challenge the assertion that this impossible discovery timeline will burden the Court’s schedule. Indeed, as those points remain unrebutted, the Motions to Reconsider should be granted. D. Conclusion For the foregoing reasons, Defendants OhioHealth Riverside Methodist Hospital, OhioHealth Corporation, Meagan Schneiderman, M.D., Valerie Schott, M.D., Emily Misbrener, D.O., Mahima Prasad, M.D., Amber N. Ferraro, RN, Maddalynn Huffman, RN, Katelyn Meister, RN, and Marybeth D’Amico, RN respectfully request that this Court 5 18615485v1 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 May 11 1:32 PM-22CV003269 0G383 - Y7 reconsider its April 25, 2023 Order and impose the discovery sanction of excluding the Plaintiff's expert witnesses at trial due to lack of disclosure instead of extending the case deadlines. Respectfully submitted, s/ Karin M. Long Bobbie S. Sprader (0064015) bsprader@brickergraydon.com Karen L. Clouse (0037294) kelouse@brick aydon.com Karin M. Long (0101480) kmlong @brickereraydon.com Bricker Graydon LLP 100 South Third Street Columbus, Ohio 43215-4291 Phone: (614) 227-2300 Fax: (614) 227-2390 Counsel for Defendants, OhioHealth Riverside Methodist Hospital, OhioHealth Corporation, Meagan Schneiderman, M.D., Valerie Schott, M.D., Emily Misbrener, D.O., Mahima Prasad, M.D., Amber N. Ferraro, RN, Maddalynn Huffman, RN, Katelyn Meister, RN, and Marybeth D’Amico, RN Of Counsel: Chester P. Porembski, Esq. (0000754) OhioHealth Corporation David P. Blom Administrative Campus 3430 OhioHealth Parkway, 5‘ Floor Columbus, OH 43202 18615485v1 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 May 11 1:32 PM-22CV003269 0G383 - Y8 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true copy of the foregoing Reply in Support of Motion to Reconsider Court’s April 25, 2023 Order Granting Plaintiffs Emergency Motion to Extend Case Management Schedule of Defendants OhioHealth Riverside Methodist Hospital, OhioHealth Corporation, Meagan Schneiderman, M.D., Valerie Schott, M.D., Emily Misbrener, D.O., Mahima Prasad, M.D., Amber N. Ferraro, RN, Maddalynn Huffman, RN, Katelyn Meister, RN, and Marybeth D’Amico, RN was served via the Court’s electronic filing system, and/or regular U.S. mail, postage prepaid, this 11th day of May, 2023 Meghan P. Connolly, Esq. Lowe, Scott, Fisher, Co., LPA 1660 West 24 Street 610 Skylight Office Tower Cleveland, OH 44113 mconnoll sflayv OR Counsel for Plaintiffs Craig S. Tuttle, Esq. LEESEBERG TUTTLE 175 S. Third Street: Penthouse One Columbus, Ohio 43215 chuttle@) sebergla LOM Counsel for Plaintiffs FrederickA. Sewards, Esq. Arnold, Todaro, Welch & Foliano, Co., LPA 2075 Marble Cliff Office Park Columbus, OH 43215 Counsel for Defendants, Avina Women’s Care dba MaternOhio Clinical Associates, Inc., MaternOhio Clinical Associates, Inc., Carl Krantz, M.D., and Amber Murphy Mack, M.D. ‘s/ KarinM. Long Karin M. Long, Esq 7 18615485v1