Legal Document: WENCK, THOMAS vs. SOUTHERN CRANE AND TRACTOR SUPPLY, INC.

On June 22, 104 a was filed involving a dispute between Wenck, Thomas, and Southern Crane And Tractor Supply, Inc., for Auto Negligence in the District Court of Charlotte County.

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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND
FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION

THOMAS WENCK,

Plaintiff,

Case No. 2022- -000629

SOUTHERN CRANE AND TRACTOR
SUPPLY, INC.,

Defendant.
/

DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT AND/OR
IN LIMINE REGARDING PLAINTIFF'S PAST MEDICAL EXPENSES

Defendant, SOUTHERN CRANE AND TRACTOR SUPPLY, INC., by and

through the undersigned counsel and pursuant to Florida Rule of Civil Procedure

1.510, respectfully moves in limine to preclude Plaintiff, who became Medicare

eligible shortly after the subject incident, from mentioning or introducing into

evidence an amount of past medical expenses greater than the amount he would have

been responsible for had his bills been submitted to Medicare, and/or for a summary

judgment order limiting Plaintiff’s damages accordingly, and states as follows:

INTRODUCTION & SUMMARY

This is case involves a motor vehicle accident which occurred on November 5

2021. Plaintiff seeks compensatory damages for past medical expenses arising from

the aforementioned accident. Plaintiff is Medicare eligible, but h health care

providers did not submit h bills to Medicare as required by federal law and did not

comply with the Federal Medicare Program, 42 CF.R. § 405. et seq., to opt out of such

legal requirement. Had h bills been submitted to Medicare, as required by law, the
amount originally charged would have been reduced to the prevailing Medicare

reimbursement rate. That rate would be the highest amount Plaintiff could owe - and

by definition, recover - for h past medical expenses.

Based on noncompliance with federal law, Plaintiff’s medical providers are

prohibited from collecting the full amounts shown on Plaintiff’s medical bills, and

thus any amounts in excess of the Medicare reimbursement rate are not damages

Plaintiff actually suffered because they are not bill he has actually legally incurred.

It would follow that Plaintiff should be prohibited from introducing the full amount

of medical bills from these providers, and instead, Plaintiff must only be allowed to

introduce medical bills at the operative Medicare reimbursement rate.

FACTUAL AND PROCEDURAL BACKGROUND

This is a personal injury action arising out of an auto accident on

January 6, 2021. (See generally, Pl. Compl.)

Plaintiff seeks economic damages, including past medical expenses from

treatment with h medical providers.

Upon information and belief, Plaintiff signed Letters of Protection with

at the very least the following providers: Physicians Group, LLC, University

Orthopedic Care, Physician Partners of America CRNA, MRI Associates of Venice,

Sun City Ambulatory Surgery Center, Lakewood Ranch Surgical Suites, LLC, Office

Anesthesia Staffing, Quiescence Anesthesia, and Associates MD Medical Group.

Plaintiff is a Medicare recipient. (See Ex. A, Wenck dep. 49:2-3

Plaintiff did not submit his medical bills to Medicare.
Defendant, therefore, moves in limine to preclude Plaintiff from arguing

or offering into evidence any amount of h past medical expenses above the Medicare

allowed amounts.

MEMORANDUM OF LAW

EVIDENCE OF PAST MEDICAL EXPENSES IN EXCESS OF THE
MEDICARE REINBURSEMENT RATES SHOULD BE EXCLUDED.

To prevail cause of action for negligence, a plaintiff must ve (1) a duty,

(2) a breach (3) proximate causation and (4) actual loss or damage. Clay Elec. Coop.,

Inc. v Johnson, 873 So. 2d 1182, 1185 (Fla. 2003). As to the fourth element, a plaintiff

can recover compensatory or actual damages for loss (those signed to make the

plaintiff whole) but cannot ecover compensatory damage in xcess amount

that represents at actual lo sustained. MCI WorldCom Network Servs., v. Mastec,

995 So. 2d 22 223 (Fla 2008). Damages for past medical expenses are economic

and compensatory in nature Coop. Leasing. Inc. v. Johnson, 872 So 2d 956

(Fla. 2d DCA 2004); Garcia v Arraga, 872 So. 2d 266 272 (Fla 4th DCA 2004).

It is plaintiff's burden present evi proving a definite amount of economic

damages, including those for pas medical treatment. The Fourth District has

explained:

It has long been accepted in lorida that a party claiming economic
sses must produce evidence justifying defini amount. Economic
damages may not founded on jury speculation or guesswork and must
rest on some sonable factual basis. Plaintiff has the burden of
presenting ence tifying a specific and definite amount of
economic damages. Where is no ence to justify any amount on
a claim for economic damages, defendant is entitled judgmen the
claim
Uni Auto. Ins. Co. v. Colon 990 So 2d 1246 1248 (Fla. 4th DCA 2008) (internal

citations omitted). See also Fla. Ventilated Awning Co Dickson, 67 So. 2d 215 (Fla.

1953) (insufficient predicate on which a definite sum could awarded); Rirnmeir v

Dickson 107 So. 2d 372 (Fla. 1958) (same).

FEDERAL MEDICARE PROGRAM REQUIREMENTS

Medicare was enac as Title XVIII of the Social Security and titled,

eal Insurance for Aged and Disabled." U.S.C. § 1395 The Social

Security Act and Section l 848(g)( 4 )(A) states in pertinent part:

For services furnished on or after September 1, 1990, within year
after date of providing a service for which payment is made under
this part on a reasonab charge or fee schedule basis a physician
supplier or other person (or an employer or facility in the cases
described in section 1842(b)(6)A)

sha comp ete and submit a claim for such service on a standard
claim form specified by the Secretary to carrier on behalf of a
beneficiary; and

may not impose a v charge re ing to completi
submitting such a form

42 U.S 1395w 4(g)(4)(A)(i ii) (emphasis added).

Under Act a health care provider mus ubmit the bill to Medicare within

one year of the service provided. "If the physician fails submit a claim to the

Medicare carrier on behalf of the beneficiary when is required to be submitted

Secretary may impose sanctions Stewart Sullivan, 816 Supp 281, 284

(D.N.J. 1992). See 42 U.S.C. 1395w 4(g)(4)(B)(i

The Centers for Medicare Medicaid Services (CMS) adminis ers

Medicare program See generally Centers for Medicare Medicaid Services,
ww.CMS.gov The CMS guidelines state as follows with regard medical

charges to beneficiaries for services covered by Medicare I]f the provider bills

Medicare, provider must accept the Medicar approved amount as payment in

and may charge beneficiaries only deductibles and coinsurance

Nevertheless, 1395a allows Medicare beneficiaries to enter into

private contracts with their health care providers under certain limited

circumstances, which allows the health care providers not to bill Medicare. See also

42 C.F.R. § 405-425. This is to ensure that beneficiaries have the free choice of care.

Specifically, Section 1395a(b)(l) states in pertinent part:

Subject to the provisions of this subsection, nothing in this title shall
prohibit a physician or practitioner from entering into a private contract
with a Medicare beneficiary for any item or service

For which no claim for payment is to be submitted under this
title, and

For which the physician or practitioner receives-

No reimbursement under this title directly or on a
capitated basis, and

Receives no amount for such item or service from an
organization which receives reimbursement for such
item or service under this title directly or on a capitated
basis.
42 U.S.C. §1395a(b).

urth private contracts authorized nly if the physician signs an

affidavit which states that h or she:

Medicare Secondary Payer (MSP) Manual, Chapter 2 MSP Provisions
https://www.ems.gov/Regulations-
Guidance/Guidance Manuals downloads/msp105c02.pdf.
Will not bmi claim under thi title for y item or service pro ded to any
dicare beneficiary (and will not rece any dica imbur nt for any
such of serv e) durin 2-year period beginning on the date affidavit is
signed

1395a(b)(3)(B)(ii). This eans tha a doctor who int a private

contract with a single patient is barred from submitting claim Medicare

half of any pat for a two year iod.

The e pri contracts are permitted :

A physician or practiti er may enter into one or more private contracts
with Medicare ficiaries for purpose f furnishing it or
serv that would otherwise be co d b Medicare, ded
conditions tills subpar are

A physician or practitioner who enters into at least one private contract
with a Medicare beneficiary under the conditions of this subpart, and
who submits one or more affidavits in accordance with this subpart, opts
out of Medicare for the opt-out period described in § 405.400 unless the
opt-out is terminated early according to§ 405.445.

Both the private contracts described in paragraph (a) of this section and
the physician's or practitioner's opt-out described in paragraph (b) of
this section are null and void if the physician or practitioner fails to
properly opt-out in accordance with the conditions of this subpart.

Both the private contracts described in paragraph (a) of this section and
the physician's or practitioner's opt-out described in paragraph (b) of
this section are null and void for the remainder of the opt-out period if
the physician or practitioner fails to remain in compliance with the
conditions of this subpart during the opt-out period.

Services furnished under private contracts meeting the requirements of
this subpart a.re not covered services under Medicare, and no Medicare
payment will be made for such services either directly or indirectly,
except as permitted in accordance with§ 405.435(c).

42 C.F.R. § 405.405.
The following conditions must be met for a health care der properly opt-

out of Medicare:

Each private contract between a physician or a practitioner and a
Medicare beneficiary that is entered into prior to the submission of the
affidavit described in paragraph (b) of this section must meet the
specifications of§ 405.415.

The physician or practitioner must submit an affidavit that meets the
specifications of§ 405. 420 to each Medicare Administrative Contractor
with which he or she would file claims absent the opt-out.

A nonparticipating physician or a practitioner may opt-out of Medicare
at any time in accordance with the following:

(1)(c)(1) The initial 2-year opt-out period begins the date the
affidavit meeting the requirements of § 405.420 is signed,
provided the affidavit is filed within 10 days after he or she signs
his or her first private contract with a Medicare beneficiary.

(2)(c)(2) If the physician or practitioner does not timely file the
opt-out affidavit(s) as specified in the previous paragraph, the
initial 2-year opt-out period begins when the last such affidavit is
filed. Any private contract entered into before the last required
affidavit is filed becomes effective upon the filing of the last
required affidavit, and the furnishing of any items or services to
a Medicare beneficiary under such contract before the last
required affidavit is filed is subject to standard Medicare rules.

A participating physician may properly opt-out of Medicare at the
beginning of any calendar quarter, provided that the affidavit described
in § 405.420 is submitted to the participating physician's Medicare
Administrative Contractors at least 30 days before the beginning of the
selected calendar quarter. A private contract entered into before the
beginning of the selected calendar quarter becomes effective at the
beginning of the selected calendar quarter, and the furnishing of any
items or services to a Medicare beneficiary under such contract before
the beginning of the selected calendar quarter is subject to standard
Medicare rules.

42 C.F.R. 405.410.
The many requirements for private contrac and the opt-out Affida it are

specified in 405.415 and 405.420 respectively. 42 C.F §§ 405.415 405.420.

Critically private contracts are null and void absent strict compliance with these

numerous requirements. 42 C.F.R. § 405.405(c) (d) 42 C.F.R. § 405.430. such

circumstances the health care provider has not effectively opted-out of Medicare

program as it concerns a particular patient. Id.

The DC Circuit Court of Appeals held that this provision and the restriction it

imposes on doctors applies only to contracts made for services which Medicare would

not pay. The Court also notes than only 300 doctors nationwide have ered into

these types of private contracts and thus been sub ct to the two-year restriction

United Seniors Ass 'n v. Shala 182 .3d Cir. 1999).

There is no evidence that any of Plaintiffs health care providers properly opted-

out of their requirement to submit Plaintiffs bills to Medicare.

PLAINTIFF'S HEALTH CARE PROVIDERS DID NOT SUBMIT
PLAINTIFF'S BILLS TO MEDICARE, DID OT EFFECTIVELY
OPTOUT MEDICARE, AND ARE, THEREFORE, NOT ENTITLED
TO COLLECT ANY AMOUNTS IN MEDICAL EXPENSES OVER
MEDICARE REIMBURSEMENT RATE.

Plaintiff was and is Medicare eligible. Plaintiff did provide h Medicare card

lth care der related bject accident. No Medicare claims

made on Plaintiff’s b half.

The Plaintiff did enter into letters of protection with ders mentioned

These letters of protection/assignment of benefits seek make Plaintiff liabl for
charges in great excess over what Medicare have reimbursed for Plaintiffs

medical services had her bills been properly bmitted Medicare

However, letters of tection do not comply with the requirements for such

private contracts er C.F.R. § 405.415. Indeed, none of the letters of protection

for examp (a) indicate ether the practitioner is cluded from Medicare; (b) state

that e beneficiary understands that Medicare limi do not apply; (c) state t th

beneficiary agrees not submit a claim to Medicare; (d) state that e beneficiar

understands that Medicare yments will mad for services provides; state

that beneficiary knowns that s had th right to obtain Medicare covered

mention an effective or xcepte expiration date of the current 2 year opt-out

period (f) Medigap plans or (g) are even s gned by th physician or

practitioner. C.F.R. 405.415(b) (d), (e), (f), (g), (h), (m). Therefore, letters of

protection are null and void. 42 C.F.R. § 405.430 (reflecting that private contracts

between practitioners and the Medicare beneficiary patient "are deemed null and

void" if they fail to comply with the requirements under§§ 405.415 and 405.420).

Furthermore, no opt-out Affidavits accompanied these Letters of Protection.

Again, the practitioner can only enter into a private contract with a Medicare eligible

patient if the practitioner properly opts-out of Medicare. 42 C.F.R. § 405.410. There

are ten requirements for a proper opt-out affidavit, the most obvious of which is that

it be in writing and signed by the practitioner. 42 C.F.R. § 405-410.

Therefore, Plaintiff’s health care providers (1) did not legally opt-out of

Medicare, (2) were required to submit Plaintiff's bills to Medicare as an eligible
patient; and (3) were not entitled to collect anything greater than the Medicare rates

for the services provided to the Plaintiff in full satisfaction of the original charges.

See Thyssenkrupp Elevator Corp. v. Lasky, 868 So. 2d 547, 549 (Fla. 4th DCA 2003)

("[P]ayment by Medicare requires the provider to whom payment is made to accept

such amount in full satisfaction of the total charge even though the amount charged

exceeds the amount paid by Medicare.") Neither the medical providers, nor Plaintiff

and h attorneys, should be permitted to benefit from circumventing the plain

requirements of federal statutory and regulatory law.

PLAINTIFF CAN ONLY PRESENT TO THE JURY THE AMOUNT
THAT MEDICARE WOULD HAVE CHARGED HAD HIS BILLS BEEN
SUBMITTED TO MEDICARE AS REQUIRED BY LAW.

Original charges by health care providers are irrelevant and inadmissible

when the provider accepts payment from Medicare in full satisfaction of the charge.

See Thyssenkrupp Elevator Corp. v. Lasky, 868 So. 2d 547 (Fla 4th DCA 2003);

Cooperative Leasing, Inc. v. Johnson, 872 So. 2d 956 (Fla. 2d DCA 2004) (holding it

was error to allow plaintiff to admit into evidence bills for medical expenses for which

she never incurred liability and in allowing her to recover damages in excess of

payments made by Medicare); Miami-Dade Cty v. Laureiro, 894 So. 2d 268 (Fla 3d

DCA 2005); Boyd v. National Mut. Fire Ins. Co., 890 So. 2d 1240 (Fla 4th DCA 2005)

(trial court properly limited evidence regarding medical bills paid by Medicare to the

amounts actually paid to the medical providers pursuant to the Medicare fee

schedule).
The undiscounted excess medical charges cannot be admitted in to evidence

because it would result in a windfall to Plaintiff by permitting recovery for pa

medical expenses for which he was never and will never be liable for. Thyssenkrupp

868 So. 2d at 550 (charges in excess to the amount discharged by Medicare is

irrelevant and inadmissible on the issue of damages suffered by a plaintiff because

the plaintiff is never liable for the difference). A Cooperative Leasing, Inc. succinctly

stated:

The issue in this case is the appropriate measure of compensatory
damages for past medical expenses. "The objective of compensatory
damages is to make the injured party whole to the extent that it is
possible to measure his injury in terms of money." Mercury Motors
Express. Inc. v. Smith, 393 So. 2d 545, 547 (Fla. 1981). "The primary
basis for an award of damages is compensation." Fisher v. City of Miami
172 So. 2d 455, 457 (Fla. 1965). In this case, Johnson sought to collect
the "additional value of medical services reasonably made necessary" by
the appellants. We conclude, however, that Johnson was not entitled to
recover for medical expenses beyond those paid by Medicare because she
never had any liability for those expenses and would have been made
whole by an award limited to the amount that Medicare paid to her
medical providers.

Leasing, Inc. 872 So. 2d at 957-58.

Accordingly, maximum amount Plaintiff d ever be responsible for if

medical providers submitted medical bills to Medicare as required by law

should have Medicare rates. Any amounts ded for above Medicare

rates cannot legally constitute past medical expenses of Plaintiff and he must not be

allowed to mention or introduce evi ence as to thos higher amounts.
PLAINTIFF HAD THE ABILITY TO SUBMIT H MEDICAL
EXPENSES TO MEDICARE TO MITIGATE H DAMAGES

ilure to bmit Plaintiff's medical expenses Medicare not fall solely

on h medical providers. Plaintiff knew he Medicare eligible at the time he

eated for e subjec accident that providers never asked for Medicare

card, and still chose not to submit h ills to Medicare.

A Medicare beneficiary can submit his/her bills to Medicare if his/her

physicians do not. Plaintiff admitted that he did not submit his claims for past

medical expenses to Medicare. This represents a failure to mitigate damages as a

matter of law - an affirmative defense raised by Defendant.

term "mitigation damages has no single meaning and is used
y the courts to describe ral diff problems in law of
damages rn as used herein encompasses those fac s which
show that th conceded or assumed cause of action does not entitle the
plaintiff to as large an amoun damage as would otherwise be
recoverable. Specifically, type of problem tigated herein involves
doctrin of avoidable consequences or orts to minimize damag
where the plaintiff easonab uld have avoided a part or al of the
conseq ences defenda 's wrongful act.

Parker v Montgomery 529 2d 1147 (F a. 988). Had Plaintiff

properly submitted his medical bills to Medicare, he would only be able to submit the

lesser amount actually paid by Medicare, to the jury. Matrisciani v. Garrison Prop. &

Cas. Ins. Co., 298 So. 3d 53, 59 (Fla. 4th DCA 2020). Original charges by health care

providers, therefore, are irrelevant and inadmissible when the provider accepts

https://www_medicare_gov/claims- -appeals/file-a-claim/file-a-claim_html; See
https://www cms gov/Medicare/CMS-Forms/CMS-Forms/ Downloads/CMS1490S
ENGLISH Instructions PartB pdf.
payment from Medicare in full satisfaction of the charge. See Thyssenkrup , 868 So.

2d at 551.

“[I]t is error to permit a plaintiff to introduce into evidence (and to request from

the jury) the gross amount of medical bills rather than the lesser amount actually

paid as a governmental or charitable benefit in full settlement of those bills.”

Matrisciani, 298 So. 3d at 59; (citing Thyssenkrupp Boyd, and Coop. Leasing, Inc.);

see also Gulfstream Park Racing Ass’n v. Volin, 326 So. 3d 1124 (Fla. 4th DCA 2021)

(holding the circuit court erred in allowing Plaintiff to introduce evidence of the

amount billed by medical providers (“phantom damages”) instead of the discounted

amount Medicare paid for past medical expenses).

"Accordingly if of the damages incurred could have reasonably bee

avoided by plaintiff [this] doctrine vents those damag from being added

amoun f damages recoverable." Id. See also S Components Corp. Fla.

967, 982 (Fla 2009).

TENTH, THIRTEENTH, FIFTEENTH AND NINETEE JUDICIAL
CIRCUITS HAVE ALREADY RULED ON THIS ISSUE

The Florida appellate courts have not written on the precise issue raised in

this Motion. However, the Honorable Thomas H. Barkdull, III of the 15th Judicial

Circuit ruled on this issue in Richardson v. Wal-Mart Stores, Inc., Case No. 2014-

015197 (Fla. 15th Jud. Cir.).

Wal-Mart filed a motion in limine that was based on a nearly identical

situation as in this case. The plaintiff, Jannie Richardson, sued for personal injuries
when a box of merchandise allegedly fell on her at Wal-Mart. She sought past medical

expenses in the amount of $362,153.42.

She had been a Medicare recipient since before the accident. She treated with

various providers, none of which properly opted-out of Medicare, and none of which

submitted her bills to Medicare even though she was Medicare eligible. The Court

found that, based on the providers’ noncompliance with federal law on opting-out of

Medicare, Plaintiff was prohibited from introducing the full amount of her medical

bills at trial. (See Exhibit B, Order dated December 13, 2017.)

Plaintiff was only "allowed to attempt to introduce medical bills at the

Medicare reimbursement rate then existing at the time those services were provided.''

The decision was based on Plaintiffs physicians' failure to comply with applicable

Medicare laws under 42 U.S.C. § 1395 and regulations 42 C.F.R. § 405, et seq., the

same federal laws and regulations violated by the health care providers in the present

case.

The Court also detailed why public policy considerations supported its decision:

Medicare is a federal health insurance program for people who are 65 or
older certain younger people with disabilities, and people with End-
Stage Renal Disease. Medicare is funded by various sources including
payroll taxes, income tax paid Social Security fits funds
authorized by Congress and premiums from people enrolle in Medicare
Part B among sources. The United tat government has
genuine interest in protecting community of elderly Americans and
isabled patients from being overcharged for medical ervices for ch
they are otherwise covered.

The particular danger that is sought be avoided are situations where
patients/plaintiffs, are Medicare beneficia and have filed
suit against an alleged tortfeasor eceive m dical treatment from
providers who would otherwise accept Medicare reimbursement rates
but ecline bmit th bills for eatme through Medicare in these
tigation cases so that they may charge and claim full value for eir
treatment. All frequently, these plaintiffs, who, by virtue of eing
Medicare recipients are recognized as being at-risk popula ion due
ith seniority or sability are with exorbitant medical bills when
they are unsuccessful in litigation.

Based on this long standing established public policy, this Court finds
that in addition to the federal regulations which govern how
participating physicians and practitioners are permitted to charge and
contracted with beneficiaries, there is a legitimate government interest
in protecting the elderly community and other beneficiaries from being
charged in excess of Medicare reimbursement rates and in properly and
thoroughly advising plaintiff-patients of the perils of permitting their
providers to bill outside of the Medicare reimbursement schedules.
These public policy concerns support this Court's ruling.

The facts in the present matter are nearly identical to those in the Richardson

case. As such, Plaintiff should not be able to mention or introduce into evidence past

medical expenses over the amount he would be responsible for had h medical

providers submitted h bills to Medicare as required by law. Similar Motions were

filed in the 13th, 10th and 9th circuits and the corresponding orders granting said

motions are attached hereto as Exhibit “C”.

WHEREFORE, Defendant, SOUTHERN CRANE AND TRACTOR

SUPPLY, INC., respectfully requests this Court enter partial summary judgment

limiting any amount of damages for past medical expenses to the Medicare allowable

amounts and/or an Order in Limine precluding Plaintiff from entering any such

evidence at the trial of this matter.
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 31st day of July 2023, I electronically filed

the foregoing with the Clerk of Court using the E-Filing Portal System which will

send a notice of electronic filing to the following:

Nicholas J. Castellano, II, Esquire
Drake Buckman, Esquire
Buckman & Buckman, P.A.
2023 Constitution Boulevard
Sarasota, FL 34231
Telephone (941) 923-7700
Facsimile (941) 923-7736
nick@buckmanandbuckman.com
PL1@buckmanandbuckman.com
Attorney for Plaintiff

By: /s/ Robert V. White
Monica Schmucker, Esquire
Florida Bar No. 120579
monica.schmucker@henlaw.com
susan.nahra@henlaw.com
Steven C. Gendreau, Esquire
Florida Bar No. 1028115
steven.gendreau@henlaw.com
susan.peters@henlaw.com
Robert V. White, Esquire
Florida Bar No. 88882
Robert.white@henlaw.com
Tania.obregon@henlaw.com
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Case Info

Judge

GENTILE, GEOFFREY H Track Judge’s New Case

Case No.

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Document Filed Date

November 15, 2032

Case Filing Date

June 22, 104

County

Parties

BUCKMAN, AMIEE Attorney
GENTILE, GEOFFREY H Judge
SOUTHERN CRANE AND TRACTOR SUPPLY, INC. Defendant
WENCK, THOMAS Plaintiff
Yardley Buckman Attorneys for Plaintiffs
Nicholas Castellano Attorney
Michael Versnik Attorneys for Defendants
Steven Gendreau Attorneys for Plaintiffs
Robert White Attorneys for Defendants
Monica Schmucker Attorneys for Defendants
David Henry Attorney
Heather Stover Attorney

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