Preview
EXHIBIT 3
EXH Ihe
Al : 5
ARNOLD & ITKIN
TRIAL LAWYERS
September 13, 2021
FIRST REQUEST
Via Email: tcrawford@lawla.com
Todd G. Crawford
Lugenbuhl, Wheaton, Peck, Rankin & Hubbard
801 Travis Street, Suite 1800
Houston, Texas 77002
Re: Christopher Pleasant v. Transocean Offshore Deepwater Drilling Inc. et al.
Dear Mr. Crawford:
Mr. Pleasant has a recommendation for the following surgery as part of his treatment
related to the injuries he sustained while employed by Transocean Offshore Deepwater Drilling
Inc.
1 ACDF C5/C6
Please see attached estimates and report from Dr. William Brennan. This procedure will
be scheduled in the near future.
Please contact Lafayette Surgical Hospital and Dr. William Brennan to make payment
arrangements for Mr. Pleasant’s surgery in accordance with your cure obligations to Mr. Pleasant.
Please advise me in writing by September 24, 2021 to let us know if your client does not
intend to honor its cure obligations to Mr. Pleasant. If we do not hear from you, we will assume
that you are refusing to pay for Mr. Pleasant’s treatment, and we will be seeking punitive damages
for your client's failure to pay its automatic obligation of cure.
Sincerely,
Caj Boatright
CB/lab
Enc.
t 866.222.2606 6009 Memorial Drive info@arnolditkin.com
f 713.222.3850 Houston, TX 77007 arnolditkin.com
Neurosurgical Solutions of Lafayette LLC March 15, 2021
105 Patriot Avenue Suite 101 Lafayette, LA 70508 Page 1
3379812125 Fax: 3379812174 Transcription
Christopher Pleasant
Male DOB: 01/18/1973 11307 Ins: Access Healthcare Management
03/08/2021 - Transcription: Brennan, William A - Consult
Provider: William A Brennan MD
Location of Care: Neurosurgical Solutions of Lafayette LLC
Status: UNSIGNED DOCUMENT
Brennan, William A - Consult
CHRISTOPHER PLEASANT DOS: 03/08/2021
CHIEF COMPLAINT: Neck pain left-sided more than right with radiation to left
shoulder more than right.
HISTORY OF PRESENT ILLNESS: The patient is a 48-year-old right-handed
offshore worker, who on 10/28/2020, was offshore off the coast of Louisiana
working as a senior Subsea, and during a hurricane was on a ship in tight
quarters in rough seas and he was banged around for approximately 10 minutes.
He recalls his head being jerked around multiple times for a period of
approximately 10 minutes. He had no loss of consciousness. He says it is
possible his head actually contacted nearby structures where he was
stationary. He continued to work on the ship after the hurricane passed with
no medical treatment. He did file a report about a sleep disturbance. When he
came to the Mainland, he was seen by Psychiatry for what sounds like PTSD
symptoms and revealed that he had these neck pains and headaches. He was
referred to Dr. Lane for Pain Management, who ordered MRI of the cervical
spine revealing abnormalities and the patient was referred for Neurosurgery
consultation. He at this point, has not done physical therapy.
MEDICATION ALLERGIES: None.
MEDICATIONS: Labetalol, carvedilol, olmesartan, aspirin, and spironolactone.
SOCIAL STATUS: He is married. He has children. He is a nonsmoker, nondrinker
of alcohol.
REVIEW OF SYSTEMS: Otherwise negative for chest pain, shortness of breath,
other radicular symptoms, memory loss, or syncope.
PAST MEDICAL HISTORY: A hypertensive stroke in 2018 affecting his right arm
and right leg.
PAST SURGICAL HISTORY: He denies any surgery.
FAMILY HISTORY: A mother with hypertension.
PHYSICAL EXAMINATION: He is awake and alert. His cranial nerves are intact.
He has 75% full range of motion of the head and neck in all directions limited
by pain. He has 5/5 motor strength in his deltoid, biceps, triceps, and
interossei, with the exception of the right interossei of 4/5. He has intact
sensation in the In the lower extremities, he has 5/5
upper extremities.
motor strength in all muscle groups of the lower extremities with 3+ DTRs on
the right, 2+ DTRs on the left. Positive Hoffmann's on the right, negative on
the left. His gait and station are normal. He ambulates unassisted.
IMAGING: His cervical MRI scan performed at Southwest Louisiana Imaging in
Lake Charles on 02/03/2021 shows a large C5-C6 disk herniation with
attenuation and flattening of the anterior profile of the cord.
Neurosurgical Solutions of Lafayette LLC March 15, 2021
105 Patriot Avenue Suite 101 Lafayette, LA 70508 Page 2
3379812125 Fax: 3379812174 Transcription
Christopher Pleasant
Male DOB: 01/18/1973 11307 Ins: Access Healthcare Management
His thoracic MRI scan done on the same day is normal for age.
IMPRESSION: Offshore accident-induced cervical disk herniation at C5-C6.
PLAN: The patient is going to undergo physical therapy and return once he has
exhausted nonsurgical management with Dr. Lane and physical therapy. I am
joing to construct a surgical quote for an anterior cervical diskectomy and
fusion at C5-Cé. I am going to order cervical flexion and extension x-rays to
be used if the patient is not successful in controlling his neck pain symptoms
described above in any nonsurgical fashion.
William A. Brennan, M.D., F.A.C.S.
WAB/mkw
i
Wg roerceuraica Solutions
of Lafayetta.LLC
Wiliam A. Brennan, MD FACS
Board Certified by The American Board
cf Neurological Surgery April, 2021
Access Healthcare Management
Patient: Christopher Pleasant (DOB: 01/18/1973)
Mr. Pleasant has been under our care and we have recommended the following surgical procedure to him to
help with his radiating neck pain if the patient is unable to achieve pain relief through non-surgical means. I feel
it is more likely than not that this patient will need the following procedure as a result of the injury for which we
have evaluated the patient. The timing of the surgery, of course, will be left up to the patient.
Anterior Cervical Discectomy and Fusion C5/C6 22551 $ 6,600.00
PEEK/Titanium Cervical Cage Placement C5/C6 22853 $ 2,400.00
Titanium Cervical Plate Placement C5-C6 22845 $ 7,440.00
Titanium Cervical Plate, Screws $ 12,342.00
PEEK Cervical Cage C5/C6 $3,150.00
Cadaveric Bone Graft (1 cc) $ 1,050.00
Cervical Collar $ 500.00
Surgery Total $ 33,482.00
For a quotation on hospital charges, please contact either the Business Office at Lafayette Surgical Specialty
Hospital 769-4100.Services not covered by the above charges are pre-operative laboratory work and any
required radiology studies prior to or after surgery.
Intraoperative neuromonitoring will be utilized for this surgery. Please contact our office with any questions.
All surgical quotes are valid for 1 year from date of quote.
Sincerely, Les
William A. Brennan MD FACS
{05 Patriot Avenue, Suite (01
SANT dackson Street, Suite D Lafayette, LA 70508 ‘BIBD Parkins Raed, Suite 120
Arondria,LA 71203 Fhone: 337.981.2125 Fax: 337.981.2174 Baten Rouge, LA 70808
Web Site: Lafayetteneuro.com
S
LAFAYETTE SURGICAL
SPECIALTY HOSPITAL
— PROUDLY PHYSICIAN OWNED —
1101 Kaliste Saloom Road - Lafayette, LA, 70508 - (337) 769-4100 - (337) 769-4199 - www. lafayettesurgical.com
April 6, 2021
Access Healthcare Mgmt.
Attorney at Law
751 E Bayou Pines
Lake Charles, LA 70601
Via Fax: 337-494-0086
Attn: Brandy Rogers
Please note the estimate of charges is in no way a guarantee of total charges for
CHRISTOPHER PLEASANT.
We require a deposit in the amount of the estimated charges prior to admission to the
hospital for the procedure listed below. If the deposit is not received, the procedure could
be postponed or cancelled. The balance of the actual charges for this procedure will be
billed to the patient’s attorney and must be paid within 30 days.
This estimate is for the facility charges for Lafayette Surgical Specialty Hospital, only.
There may be additional charges from the anesthesiologist (APC) 337-706-1520, pathologist
and/or any additional implants or hardware that may not have been covered in the
estimate.
This estimate is valid for six months from the date of this letter.
Procedure: Estimate of Charges:
ACDF C5-6 $30,600.00
This estimate does not include implants. If LSSH provides implants you will be billed
accordingly.
Please contact Shalyn Livings at 337-769-4279 or Joy Simmons at 337-769-4296 if you
have any questions regarding this matter.
Sacer Dean oe
Joy Simmons
Business Office Manager
Lafayette Surgical Specialty Hospital
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EXHIBIT 3 EXH Ihe Al : 5 ARNOLD & ITKIN TRIAL LAWYERS September 13, 2021 FIRST REQUEST Via Email: tcrawford@lawla.com Todd G. Crawford Lugenbuhl, Wheaton, Peck, Rankin & Hubbard 801 Travis Street, Suite 1800 Houston, Texas 77002 Re: Christopher Pleasant v. Transocean Offshore Deepwater Drilling Inc. et al. Dear Mr. Crawford: Mr. Pleasant has a recommendation for the following surgery as part of his treatment related to the injuries he sustained while employed by Transocean Offshore Deepwater Drilling Inc. 1 ACDF C5/C6 Please see attached estimates and report from Dr. William Brennan. This procedure will be scheduled in the near future. Please contact Lafayette Surgical Hospital and Dr. William Brennan to make payment arrangements for Mr. Pleasant’s surgery in accordance with your cure obligations to Mr. Pleasant. Please advise me in writing by September 24, 2021 to let us know if your client does not intend to honor its cure obligations to Mr. Pleasant. If we do not hear from you, we will assume that you are refusing to pay for Mr. Pleasant’s treatment, and we will be seeking punitive damages for your client's failure to pay its automatic obligation of cure. Sincerely, Caj Boatright CB/lab Enc. t 866.222.2606 6009 Memorial Drive info@arnolditkin.com f 713.222.3850 Houston, TX 77007 arnolditkin.com Neurosurgical Solutions of Lafayette LLC March 15, 2021 105 Patriot Avenue Suite 101 Lafayette, LA 70508 Page 1 3379812125 Fax: 3379812174 Transcription Christopher Pleasant Male DOB: 01/18/1973 11307 Ins: Access Healthcare Management 03/08/2021 - Transcription: Brennan, William A - Consult Provider: William A Brennan MD Location of Care: Neurosurgical Solutions of Lafayette LLC Status: UNSIGNED DOCUMENT Brennan, William A - Consult CHRISTOPHER PLEASANT DOS: 03/08/2021 CHIEF COMPLAINT: Neck pain left-sided more than right with radiation to left shoulder more than right. HISTORY OF PRESENT ILLNESS: The patient is a 48-year-old right-handed offshore worker, who on 10/28/2020, was offshore off the coast of Louisiana working as a senior Subsea, and during a hurricane was on a ship in tight quarters in rough seas and he was banged around for approximately 10 minutes. He recalls his head being jerked around multiple times for a period of approximately 10 minutes. He had no loss of consciousness. He says it is possible his head actually contacted nearby structures where he was stationary. He continued to work on the ship after the hurricane passed with no medical treatment. He did file a report about a sleep disturbance. When he came to the Mainland, he was seen by Psychiatry for what sounds like PTSD symptoms and revealed that he had these neck pains and headaches. He was referred to Dr. Lane for Pain Management, who ordered MRI of the cervical spine revealing abnormalities and the patient was referred for Neurosurgery consultation. He at this point, has not done physical therapy. MEDICATION ALLERGIES: None. MEDICATIONS: Labetalol, carvedilol, olmesartan, aspirin, and spironolactone. SOCIAL STATUS: He is married. He has children. He is a nonsmoker, nondrinker of alcohol. REVIEW OF SYSTEMS: Otherwise negative for chest pain, shortness of breath, other radicular symptoms, memory loss, or syncope. PAST MEDICAL HISTORY: A hypertensive stroke in 2018 affecting his right arm and right leg. PAST SURGICAL HISTORY: He denies any surgery. FAMILY HISTORY: A mother with hypertension. PHYSICAL EXAMINATION: He is awake and alert. His cranial nerves are intact. He has 75% full range of motion of the head and neck in all directions limited by pain. He has 5/5 motor strength in his deltoid, biceps, triceps, and interossei, with the exception of the right interossei of 4/5. He has intact sensation in the In the lower extremities, he has 5/5 upper extremities. motor strength in all muscle groups of the lower extremities with 3+ DTRs on the right, 2+ DTRs on the left. Positive Hoffmann's on the right, negative on the left. His gait and station are normal. He ambulates unassisted. IMAGING: His cervical MRI scan performed at Southwest Louisiana Imaging in Lake Charles on 02/03/2021 shows a large C5-C6 disk herniation with attenuation and flattening of the anterior profile of the cord. Neurosurgical Solutions of Lafayette LLC March 15, 2021 105 Patriot Avenue Suite 101 Lafayette, LA 70508 Page 2 3379812125 Fax: 3379812174 Transcription Christopher Pleasant Male DOB: 01/18/1973 11307 Ins: Access Healthcare Management His thoracic MRI scan done on the same day is normal for age. IMPRESSION: Offshore accident-induced cervical disk herniation at C5-C6. PLAN: The patient is going to undergo physical therapy and return once he has exhausted nonsurgical management with Dr. Lane and physical therapy. I am joing to construct a surgical quote for an anterior cervical diskectomy and fusion at C5-Cé. I am going to order cervical flexion and extension x-rays to be used if the patient is not successful in controlling his neck pain symptoms described above in any nonsurgical fashion. William A. Brennan, M.D., F.A.C.S. WAB/mkw i Wg roerceuraica Solutions of Lafayetta.LLC Wiliam A. Brennan, MD FACS Board Certified by The American Board cf Neurological Surgery April, 2021 Access Healthcare Management Patient: Christopher Pleasant (DOB: 01/18/1973) Mr. Pleasant has been under our care and we have recommended the following surgical procedure to him to help with his radiating neck pain if the patient is unable to achieve pain relief through non-surgical means. I feel it is more likely than not that this patient will need the following procedure as a result of the injury for which we have evaluated the patient. The timing of the surgery, of course, will be left up to the patient. Anterior Cervical Discectomy and Fusion C5/C6 22551 $ 6,600.00 PEEK/Titanium Cervical Cage Placement C5/C6 22853 $ 2,400.00 Titanium Cervical Plate Placement C5-C6 22845 $ 7,440.00 Titanium Cervical Plate, Screws $ 12,342.00 PEEK Cervical Cage C5/C6 $3,150.00 Cadaveric Bone Graft (1 cc) $ 1,050.00 Cervical Collar $ 500.00 Surgery Total $ 33,482.00 For a quotation on hospital charges, please contact either the Business Office at Lafayette Surgical Specialty Hospital 769-4100.Services not covered by the above charges are pre-operative laboratory work and any required radiology studies prior to or after surgery. Intraoperative neuromonitoring will be utilized for this surgery. Please contact our office with any questions. All surgical quotes are valid for 1 year from date of quote. Sincerely, Les William A. Brennan MD FACS {05 Patriot Avenue, Suite (01 SANT dackson Street, Suite D Lafayette, LA 70508 ‘BIBD Parkins Raed, Suite 120 Arondria,LA 71203 Fhone: 337.981.2125 Fax: 337.981.2174 Baten Rouge, LA 70808 Web Site: Lafayetteneuro.com S LAFAYETTE SURGICAL SPECIALTY HOSPITAL — PROUDLY PHYSICIAN OWNED — 1101 Kaliste Saloom Road - Lafayette, LA, 70508 - (337) 769-4100 - (337) 769-4199 - www. lafayettesurgical.com April 6, 2021 Access Healthcare Mgmt. Attorney at Law 751 E Bayou Pines Lake Charles, LA 70601 Via Fax: 337-494-0086 Attn: Brandy Rogers Please note the estimate of charges is in no way a guarantee of total charges for CHRISTOPHER PLEASANT. We require a deposit in the amount of the estimated charges prior to admission to the hospital for the procedure listed below. If the deposit is not received, the procedure could be postponed or cancelled. The balance of the actual charges for this procedure will be billed to the patient’s attorney and must be paid within 30 days. This estimate is for the facility charges for Lafayette Surgical Specialty Hospital, only. There may be additional charges from the anesthesiologist (APC) 337-706-1520, pathologist and/or any additional implants or hardware that may not have been covered in the estimate. This estimate is valid for six months from the date of this letter. Procedure: Estimate of Charges: ACDF C5-6 $30,600.00 This estimate does not include implants. If LSSH provides implants you will be billed accordingly. Please contact Shalyn Livings at 337-769-4279 or Joy Simmons at 337-769-4296 if you have any questions regarding this matter. Sacer Dean oe Joy Simmons Business Office Manager Lafayette Surgical Specialty Hospital