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FILED
DALLAS COUNTY
AM
12/1 1/2019 8:25
FELICIA PITRE
DISTRICT CLERK
Debra Clark
N0. DC-18-16118
MICHAEL P. BURCH IN THE DISTRICT COURT
PLAINTIFF,
VS. mmmmmmm
DALLAS COUNTY, TEXAS
ELVIRA ZUBIRI ALCANTAR
DEFENDANT. 134TH JUDICIAL DISTRICT
DEFENDANT’S SECOND SUPPLEMENTAL RESPONSE T0 PLAINTIFF’S
REQUEST FOR DISCLOSURE AND DESIGNATION 0F EXPERTS
Pursuant t0 TeX R. CiV. P. 194, Defendant serves the following Second Supplemental
Response to Plaintiff s Request for Disclosure and Designation 0f Experts.
f. For any testifying expert:
1. The expert’s name, address, and telephone number;
2. The subj ect matter 0n Which the expert will testify;
3. The general substance 0f the expert’s mental impressions and opinions and
a brief summary of the basis for them, or if the expert is not retained by, employed by, 01‘
otherwise subject to the control 0f the responding party, documents reflecting such
information;
4. Ifthe expert is retained by, employed by, 0r otherwise subject t0 the control
0f the responding party:
A. A11 documents, tangible things, reports, models, 0r data
compilations that have been provided to, reviewed by, or prepared by or for the
expert in anticipation 0f the expert’s testimony; and
B. The expert’s current resume 0r bibliography.
Response: Defendant hereby designates and reserves the right t0 call any expert Witness(es)
designated by any other party to this case, as well as any experts later designated
by any party t0 this case 0n any subject relevant t0 this litigation 0n Which the
witness is qualified to testify. In the event that any party to this cause has
designated any experts but has been or is subsequently dismissed for any reason or
fails t0 call any designated expert at the time 0f trial, Defendant specifically
reserves the right to call any such expert previously designated by that party.
Defendant further reserves the right t0 withdraw 0r de-designate any expert prior
t0 testimony and t0 positively aver that such previously designated expert Will not
DEFENDANT’S SECOND SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -1-
be called as a witness at trial and to redesignate same as a consulting expert who
Will not be called by any party in this cause. Finally, Defendant reserves the right
to supplement this response as additional information concerning experts becomes
available.
Defendant further hereby designates as adverse expert Witnesses all expert
witnesses designated by Plaintiff. Defendant reserves the right to rely upon or to
offer, by direct examination or cross-examination, testimony obtained from those
experts and rebuttal experts, if any, designated by Plaintiff. By this designation,
Defendant does not necessarily agree with, nor vouch for, the credibility of any
such Witnesses 0r their opinions, or the reliability, materiality, or admissibility of
information and/or tangible things produced by these individuals in general; by this
designation Defendant is simply reserving the opportunity t0 rely upon 0r elicit
certain opinions and/or evidence from these witnesses t0 the extent that itdeems it
in its interest t0 d0 s0.
Such persons are expected to testify concerning Plaintiffs care and treatment. See
Plaintiffs Responses to Defendant’s Request for Disclosure for additional
information concerning such health—care providers including medical bills and
records relating to Plaintiff.
Second Supplemental Response:
Defendant hereby designates as an expert Witness the following individual:
Andrew Goodman, DC
2046 Forest Lane, Ste. 180
Garland, Texas 75042
972.265.8104
Dr. Goodman is chiropractor who has reviewed Michael Burch’s medical records and other
case materials provided t0 him and is expected t0 testify regarding the extent of the injuries
sustained by the Plaintiff in the subject motor vehicle accident, the appropriate care and
treatment for those injuries, and the fair and reasonable cost of that treatment, both in the
past and in the future, if applicable, as set out in the attached report.
DEFENDANT’S SECOND SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -2-
Respectfully submitted,
CQW
Chad Kimble, State Bar 24007483
Kyle Smith, State Bar 241025 12
LAW OFFICE 0F CHAD KIMBLE, P.C.
1204 S. White Chapel Blvd.
Southlake, Texas 76092
eservice@chadkimblelaw.com
817.766.7488
817.423.7492 fax
ATTORNEY FOR DEFENDANT
CERTIFICATE 0F SERVICE
The undersigned certifies that 0n the 11th day 0f December, 2019, a true copy of the
foregoing has been served on all parties in accordance with Rule 21a, Texas Rules of Civil
Procedure.
Chad Kimble
DEFENDANT’S SECOND SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -3-
ANDREW GOODMAN, D.c. . 12001 N. CENTRAL EXPRESSWAY
DOCTOR OF CHIROPRACTIC j”
SUITE 800
DALLAS, Tx 75243
(214) 750-61 10
FAX - 750-5825
(21 4)
December 9, 201 9
Mr. Chad Kimble
Low Office of Chad Kimble, P.C.
1204 Sou’rh white Chapel Blvd.
Southlake, TX 76092
Fox: 81 7-423—7492
RE: Michael Burch
CLAIM #: 04751 67029
DATE OF lNJURY: 09/1 5/1 7
CASE #z 20984866
Dear Mr. Kimble:
I
l
lhove had ’rhe opportunity to review medical records 0n Mr. Michael Burch.
My name isAndrew Goodman, DC. | graduated Cum Loude from Parker. College of Chiropractic in 2008. I
hove had chiropractic practices in Plano, TX 0nd Dallas, TX seeing 0nd treating many patients who were
subject ’ro musculoskele’rol injuriesof The spine cmd ’rhe exTremities. Iwas also the Director of Rehabilitation for
Alpha Physical Medicine, The rehabilitation center for Alpha Orthopedics, seeing 0nd Treating hundreds of post—
operative 0nd non-opero’rive patients, many of whom were injured due To traumatic incidences of falls,motor
vehicle accidents, 0nd fractures. | hove had direct patient experience wi’rh Thousands of patients during my
time cs c1 Doctor of Chiropractic. Imaintain cm active license cmd work as cm independent contractor for cm ‘
occupational medicine clinic:performing pre-employmem physicals, Department of Transportation physicals.
0nd workers’ compensation injuries and independent medical evaluations 10 determine MMI 0nd assign
impairment ratings. l 0m c1 Nationally Registered Certified Medical Examiner for the Department of
Transportation and o certified Designated Doctor with ’rhe Texas Department of Insurance Division of Workers'
Compensation. I hove several years of experience setting fee schedules, billing third—porfy reimbursement cmd
discussing fhird-porfy reimbursement wi’rh patients.
OVERVIEW
On September 15, 2017, the patient presented to Parkland Emergency Departmenf with Chronic spine pain,
status postmotor vehicle collisionThat day, The patient was in c: fuII—sizeHon pickup cmd hiton the rightfrom.
There was no vehicle intrusion. No airbags deployed. The patient was restrained. No loss of consciousness. He
had immediate spine pain. No bowel or bladder concerns. The patient‘h‘gs c1history of surgery a’r T7-T9 0nd
now hos c: nerve stimulator installed. The initialplan of core from the emergency and diagnosis was chronic
low back pain with cm exacerbation of symptoms due to motor vehicle collision with possible acute
musculoskeletol injury. While 01 the emergency department, the patient had a CT scan of the cervical,
ihorocic, 0nd lumbar spine wi’rh The following impressions: No evidence of fracture or o’rher acute Traumatic
abnormality identified. There was multilevel cervical, thoracic, 0nd lumbqr spondylosis 0nd a spinal stimulator
dech.
Michael
Michael Burch
Burch
December
December 9, 9, 20199
201
CASE
CASE #: 20984866
#1 20984866
Page 22 of
Page of 66
On September
On September 28, 28, 2017,
201 7, the pofiem‘ presented
ihe patient presented to Lone Star
to Lone Star Radiology
Radiology for
for cervical
cefvicol spine
spine x-rays
x-roys with
with the
the following
following
impressions:
impressions: Postural
Postural alterations,
olferofions, mild
mild reduction
reduction inin flexion,
flexion, mild
mild reduction
reduction inin extension,
extension, spondylosis
spondylosis of C4 and
of C4 0nd C5.
C5.
The patient
The potieni also had thoracic
oiso had thoracic spine
spine x-rays
x-roys with
with the
the following
following impressions:
impressions: Postural
Postural alterations 0nd intraspinal
ol’rerafions and Introspinol
electrodes
electrodes are
ore present
presen’r at
CIT T9
T9 through
through Til.
TI 1. The po’n’en’r
The patient had lumbar
had lumbar spine
spine x-rays
x—roys with
with the
The following
following impressions:
impressions:
Postural alterations, opophyseol degeneration of L4 0nd
Postural alterations, apophyseal degeneration at L4 and L5 and LS-S I
L5 and L5—S] on the right, spondylosis
on The,_rjghf,spondyiosis L2L2 to
to L4.
L4.
On September
On SepTember 28, 28, 2017,
2017, the
The patient
patient presented
presented to Accident && Injury
to Accident Injury Chiropractic
Chiropractic for on initial
for an initial evaluation
evoluofion with
with
the following
The following findings.
findings. Neuro exam
Neuro exam was
was normal.
normal, Cervical
Cervical range
rcmge of motion was
of motion W03 mildly decreased with
mildly decreased with mild-to-
mild-fo-
moderofe pain.
moderate pain. Thorocolumbor range
Thoracolumbar range ofof motion was decreased.
motion was decreased. Foramina!
Forominol compression
compression test was positive
test was positive for
for
localized
localized pain
pain onon the
the left.
left. Shoulder
Shoulder depression
depression test was positive
test was positive bilaterally.
bilaterally. Cervical
Cervical distraction
distraction test was
test was
negofive bilaterally.
negative bilaterally. Straight
Straight leg
leg raise was positive
raise was positive for
for low bock pain
low back on the
pain on The left
left at
of 75
75 degrees 0nd positive
degrees and positive for
for
low bock pain
low back on the
pain on the right
right at
of 50
50 degrees.
degrees. Ely's
Ely‘s test was positive
Test was positive for
for localized
localized pain
pain on the right.
on the right. Treatment
Treatment that
’fhoT
day consisted
day consisTed of intersegmemol traction,
of intersegmental Traction, electrical
electrical muscle
muscle stimulation, 0nd ice
stimulation, and 0nd heat
ice and heat therapy.
Therapy.
On September
On September 30,2017,
30, 201 7, the
The patient
patient presented
presented to Accident && Injury
To Accident Injury Chiropractic
Chiropractic for
for treatment,
treatment, which
which consisted
consisted
of manipulation, intersegmental traction,
of manipulation, iniersegmem‘o! traction, electrical
elecTricol muscle
muscle stimulation, 0nd ice
sfimulofion, and 0nd heat
ice and heat therapy.
Therapy.
On October
On October 4, 4. 2017,
2017, the pofienf presented
The patient presented to Accident && Injury
to Accident Injury Chiropractic
Chiropractic for
for treatment,
freonenT, which
which consisted
consisted ofof
manipulation, iniersegmem‘ol fraction, electrical muscle stimulofion, 0nd
manipulation, intersegmental traction, electrical muscle stimulation, and ice:and ic_e‘,ond heat therapy.
heat therapy.
On October
On October 5,5, 2017,
201 7, the
the patient presem‘ed to
patient presented 1‘0Accident && Injury
Accident Injury ChiropraCtic
Chiroprocfiéfor for treatment,
treatment, which
which consisted
consisTed ofof
manipulation, intersegmemol traction,
manipulation, intersegmental traction, electrical muscle stimulation,
electrical muscle and ice.'and
s1imulofion, and icefo‘nd heat
heat therapy.
therapy.
On October
On October 6, 6, 2017,
201 7, the
The patient
patienf presented
presented to Accident && Injury
to Accident Injury Chiropractic
Chiropractic forfér treatment,
Treatment, which
which consisted
consisted ofof
manipulation,
manipulation, intersegmental
intersegmenfol traction,
Traction, electrical
electrical muscle
muscle stimulation, 0nd ice
stimulcufion, and ,and heat
Iceland heof therapy.
Therapy.
'
On October
On October 7,7. 2017,
2037, the
the patient presenied to
patient presented Accident && Injury
to Accident Injury Chiropractic
Chiroprocfic forfor treatment,
Treatment, which
which consisted
consisted ofof
manipulation,
manipulation, intersegmental
intersegmenfol traction,
traction, electrical
electrical muscle
muscle stimulation, 0nd ice
stimulation, and 0nd heat
ice and heat therapy.
fheropy.
On October
On October 9, 9, 2017,
2017, the
the patient
patient presented
presented to Accident && Injury
to Accident Injury Chiropractic
Chiropractic for
for treatment,
Treatment, which
which consisted
consisted of
of
manipulation, intersegmental traction, electrical muscle
manipulation, intersegmentol Troca‘ion,etec’rricol muscle stimulation, 0nd ice
stimuiofion, and 0nd heat
ice and hecfi therapy.
therapy.
On October
On October 10,2017,
10, 2017, the
The patient
patient presented
presented to Accident && Injury
to Accident Injury Chiropractic
Chiropractic for
for treatment,
treatment, which
which consisted
consisted of
of
manipulation, elecfricol muscle stimulation, Traction, 0nd ice 0nd
manipulation, electrical muscle stimulation, intersegmental traction, and ice and heal therapy.
infersegmental heoi therapy.
On October
On October II,H, 2017,
2017, the
The patient
potiem presented
presented to Accident && Injury
To Accident Injury Chiropractic
Chiropractic for
for treatment,
Treatment which
which consisted
consisted of
of
manipulation,
manipulation, intersegmental
infersegmentol traction,
Trocfion, electrical muscle stimulation,
electrical muscle 0nd ic.Ei,and
stimulation, and iceiond heat
heot therapy.
therapy.
On October
On October 12,12, 2017,
2017, the
the patient
patient presented
presented to10 Accident
Accident && Injury
Injury ChiropraCtic
Chiroproéfic for for ac1 re-examination.
re-exomino’rion. Cervical
Cervical
range
range of
of motion
motion was
was very
very mildly
mildly decreased
decreased with
with mild
mild pom
pain. Thorocolumbor range
Thoracolur)!bar range of
of motion
motion wos
was mildly
mildly
decreased with
decreased with mild pom.
mild pain.
On October
On October 13,l3, 2017,
2017, the poh’enf presented
the patient presented to ’roAccident && Injury
Accident Injury Chiropract(c
Chiropractic for
for treatment, which consisted
Treatment, which consis’red of
of
manipulation,
monipulofion, electrical
eiecfricol muscle stimulation,
muscle stimulation, and ice 0nd
0nd ice and heat
heat therapy.
Therapy. ·
On October
On October 16,16, 2017,
201 7, the
The patient
patient presented
presented to Accident && Injury
to Accident Injury Chiropractic
Chiropractic for
for treatment, which consisted
treatment, which consisted of
of
manipulation, electrical muscle sfimulofion, 0nd ice 0nd
manipulation, electrical muscle stimulation, and ice and heat therapy.
heat Therapy.
On October
On October 17,17, 2017,
2017. the
the patient
patient presented
presented to Accident && Injury
to Accident Injury ChiropraCtic
ChiropraCTic for
for treatment, which consisted
Treatment, which consisted of
of
manipulation, electrical muscle stimulation, ice 0nd heat therapy, 0nd
manipulation, electrical muscle stimulation, ice and heat therapy, and therapeutic exercise .
therapeutic exercise.
.,_·
..
( ..
Michael
Michael Burch
Burch ;‘
December 9,
December 9, 2019
201 9
CASE
CASE #:#2 20984866
20984866
Page
Page 33 of
of 66
On October
On October 19,19, 2017,
2017, the pofiem presented
The patient presented to to Accident
Accident & & Injury
Injury Chiropractic
Chiropractic for
for treatment,
treatment which
which consisted
consisted of
of
manipulation,
manipulation, electrical
electrical muscle
muscle stimulation,
stimulation, ice
ice and
0nd heat
heat therapy,
Therapy, and
0nd therapeutic
therapeutic exercise.
exercise.
On October
On OcTOber 20,
20, 2017,
2017, the
’rhe patient
patient presented
presented to ’ro
Accident
Accident && Injury
Injury Chiropractic
Chiropractic for
for treatment,
freOTmem‘, which
Preview
FILED DALLAS COUNTY AM 12/1 1/2019 8:25 FELICIA PITRE DISTRICT CLERK Debra Clark N0. DC-18-16118 MICHAEL P. BURCH IN THE DISTRICT COURT PLAINTIFF, VS. mmmmmmm DALLAS COUNTY, TEXAS ELVIRA ZUBIRI ALCANTAR DEFENDANT. 134TH JUDICIAL DISTRICT DEFENDANT’S SECOND SUPPLEMENTAL RESPONSE T0 PLAINTIFF’S REQUEST FOR DISCLOSURE AND DESIGNATION 0F EXPERTS Pursuant t0 TeX R. CiV. P. 194, Defendant serves the following Second Supplemental Response to Plaintiff s Request for Disclosure and Designation 0f Experts. f. For any testifying expert: 1. The expert’s name, address, and telephone number; 2. The subj ect matter 0n Which the expert will testify; 3. The general substance 0f the expert’s mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, employed by, 01‘ otherwise subject to the control 0f the responding party, documents reflecting such information; 4. Ifthe expert is retained by, employed by, 0r otherwise subject t0 the control 0f the responding party: A. A11 documents, tangible things, reports, models, 0r data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation 0f the expert’s testimony; and B. The expert’s current resume 0r bibliography. Response: Defendant hereby designates and reserves the right t0 call any expert Witness(es) designated by any other party to this case, as well as any experts later designated by any party t0 this case 0n any subject relevant t0 this litigation 0n Which the witness is qualified to testify. In the event that any party to this cause has designated any experts but has been or is subsequently dismissed for any reason or fails t0 call any designated expert at the time 0f trial, Defendant specifically reserves the right to call any such expert previously designated by that party. Defendant further reserves the right t0 withdraw 0r de-designate any expert prior t0 testimony and t0 positively aver that such previously designated expert Will not DEFENDANT’S SECOND SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -1- be called as a witness at trial and to redesignate same as a consulting expert who Will not be called by any party in this cause. Finally, Defendant reserves the right to supplement this response as additional information concerning experts becomes available. Defendant further hereby designates as adverse expert Witnesses all expert witnesses designated by Plaintiff. Defendant reserves the right to rely upon or to offer, by direct examination or cross-examination, testimony obtained from those experts and rebuttal experts, if any, designated by Plaintiff. By this designation, Defendant does not necessarily agree with, nor vouch for, the credibility of any such Witnesses 0r their opinions, or the reliability, materiality, or admissibility of information and/or tangible things produced by these individuals in general; by this designation Defendant is simply reserving the opportunity t0 rely upon 0r elicit certain opinions and/or evidence from these witnesses t0 the extent that itdeems it in its interest t0 d0 s0. Such persons are expected to testify concerning Plaintiffs care and treatment. See Plaintiffs Responses to Defendant’s Request for Disclosure for additional information concerning such health—care providers including medical bills and records relating to Plaintiff. Second Supplemental Response: Defendant hereby designates as an expert Witness the following individual: Andrew Goodman, DC 2046 Forest Lane, Ste. 180 Garland, Texas 75042 972.265.8104 Dr. Goodman is chiropractor who has reviewed Michael Burch’s medical records and other case materials provided t0 him and is expected t0 testify regarding the extent of the injuries sustained by the Plaintiff in the subject motor vehicle accident, the appropriate care and treatment for those injuries, and the fair and reasonable cost of that treatment, both in the past and in the future, if applicable, as set out in the attached report. DEFENDANT’S SECOND SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -2- Respectfully submitted, CQW Chad Kimble, State Bar 24007483 Kyle Smith, State Bar 241025 12 LAW OFFICE 0F CHAD KIMBLE, P.C. 1204 S. White Chapel Blvd. Southlake, Texas 76092 eservice@chadkimblelaw.com 817.766.7488 817.423.7492 fax ATTORNEY FOR DEFENDANT CERTIFICATE 0F SERVICE The undersigned certifies that 0n the 11th day 0f December, 2019, a true copy of the foregoing has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure. Chad Kimble DEFENDANT’S SECOND SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -3- ANDREW GOODMAN, D.c. . 12001 N. CENTRAL EXPRESSWAY DOCTOR OF CHIROPRACTIC j” SUITE 800 DALLAS, Tx 75243 (214) 750-61 10 FAX - 750-5825 (21 4) December 9, 201 9 Mr. Chad Kimble Low Office of Chad Kimble, P.C. 1204 Sou’rh white Chapel Blvd. Southlake, TX 76092 Fox: 81 7-423—7492 RE: Michael Burch CLAIM #: 04751 67029 DATE OF lNJURY: 09/1 5/1 7 CASE #z 20984866 Dear Mr. Kimble: I l lhove had ’rhe opportunity to review medical records 0n Mr. Michael Burch. My name isAndrew Goodman, DC. | graduated Cum Loude from Parker. College of Chiropractic in 2008. I hove had chiropractic practices in Plano, TX 0nd Dallas, TX seeing 0nd treating many patients who were subject ’ro musculoskele’rol injuriesof The spine cmd ’rhe exTremities. Iwas also the Director of Rehabilitation for Alpha Physical Medicine, The rehabilitation center for Alpha Orthopedics, seeing 0nd Treating hundreds of post— operative 0nd non-opero’rive patients, many of whom were injured due To traumatic incidences of falls,motor vehicle accidents, 0nd fractures. | hove had direct patient experience wi’rh Thousands of patients during my time cs c1 Doctor of Chiropractic. Imaintain cm active license cmd work as cm independent contractor for cm ‘ occupational medicine clinic:performing pre-employmem physicals, Department of Transportation physicals. 0nd workers’ compensation injuries and independent medical evaluations 10 determine MMI 0nd assign impairment ratings. l 0m c1 Nationally Registered Certified Medical Examiner for the Department of Transportation and o certified Designated Doctor with ’rhe Texas Department of Insurance Division of Workers' Compensation. I hove several years of experience setting fee schedules, billing third—porfy reimbursement cmd discussing fhird-porfy reimbursement wi’rh patients. OVERVIEW On September 15, 2017, the patient presented to Parkland Emergency Departmenf with Chronic spine pain, status postmotor vehicle collisionThat day, The patient was in c: fuII—sizeHon pickup cmd hiton the rightfrom. There was no vehicle intrusion. No airbags deployed. The patient was restrained. No loss of consciousness. He had immediate spine pain. No bowel or bladder concerns. The patient‘h‘gs c1history of surgery a’r T7-T9 0nd now hos c: nerve stimulator installed. The initialplan of core from the emergency and diagnosis was chronic low back pain with cm exacerbation of symptoms due to motor vehicle collision with possible acute musculoskeletol injury. While 01 the emergency department, the patient had a CT scan of the cervical, ihorocic, 0nd lumbar spine wi’rh The following impressions: No evidence of fracture or o’rher acute Traumatic abnormality identified. There was multilevel cervical, thoracic, 0nd lumbqr spondylosis 0nd a spinal stimulator dech. Michael Michael Burch Burch December December 9, 9, 20199 201 CASE CASE #: 20984866 #1 20984866 Page 22 of Page of 66 On September On September 28, 28, 2017, 201 7, the pofiem‘ presented ihe patient presented to Lone Star to Lone Star Radiology Radiology for for cervical cefvicol spine spine x-rays x-roys with with the the following following impressions: impressions: Postural Postural alterations, olferofions, mild mild reduction reduction inin flexion, flexion, mild mild reduction reduction inin extension, extension, spondylosis spondylosis of C4 and of C4 0nd C5. C5. The patient The potieni also had thoracic oiso had thoracic spine spine x-rays x-roys with with the the following following impressions: impressions: Postural Postural alterations 0nd intraspinal ol’rerafions and Introspinol electrodes electrodes are ore present presen’r at CIT T9 T9 through through Til. TI 1. The po’n’en’r The patient had lumbar had lumbar spine spine x-rays x—roys with with the The following following impressions: impressions: Postural alterations, opophyseol degeneration of L4 0nd Postural alterations, apophyseal degeneration at L4 and L5 and LS-S I L5 and L5—S] on the right, spondylosis on The,_rjghf,spondyiosis L2L2 to to L4. L4. On September On SepTember 28, 28, 2017, 2017, the The patient patient presented presented to Accident && Injury to Accident Injury Chiropractic Chiropractic for on initial for an initial evaluation evoluofion with with the following The following findings. findings. Neuro exam Neuro exam was was normal. normal, Cervical Cervical range rcmge of motion was of motion W03 mildly decreased with mildly decreased with mild-to- mild-fo- moderofe pain. moderate pain. Thorocolumbor range Thoracolumbar range ofof motion was decreased. motion was decreased. Foramina! Forominol compression compression test was positive test was positive for for localized localized pain pain onon the the left. left. Shoulder Shoulder depression depression test was positive test was positive bilaterally. bilaterally. Cervical Cervical distraction distraction test was test was negofive bilaterally. negative bilaterally. Straight Straight leg leg raise was positive raise was positive for for low bock pain low back on the pain on The left left at of 75 75 degrees 0nd positive degrees and positive for for low bock pain low back on the pain on the right right at of 50 50 degrees. degrees. Ely's Ely‘s test was positive Test was positive for for localized localized pain pain on the right. on the right. Treatment Treatment that ’fhoT day consisted day consisTed of intersegmemol traction, of intersegmental Traction, electrical electrical muscle muscle stimulation, 0nd ice stimulation, and 0nd heat ice and heat therapy. Therapy. On September On September 30,2017, 30, 201 7, the The patient patient presented presented to Accident && Injury To Accident Injury Chiropractic Chiropractic for for treatment, treatment, which which consisted consisted of manipulation, intersegmental traction, of manipulation, iniersegmem‘o! traction, electrical elecTricol muscle muscle stimulation, 0nd ice sfimulofion, and 0nd heat ice and heat therapy. Therapy. On October On October 4, 4. 2017, 2017, the pofienf presented The patient presented to Accident && Injury to Accident Injury Chiropractic Chiropractic for for treatment, freonenT, which which consisted consisted ofof manipulation, iniersegmem‘ol fraction, electrical muscle stimulofion, 0nd manipulation, intersegmental traction, electrical muscle stimulation, and ice:and ic_e‘,ond heat therapy. heat therapy. On October On October 5,5, 2017, 201 7, the the patient presem‘ed to patient presented 1‘0Accident && Injury Accident Injury ChiropraCtic Chiroprocfiéfor for treatment, treatment, which which consisted consisTed ofof manipulation, intersegmemol traction, manipulation, intersegmental traction, electrical muscle stimulation, electrical muscle and ice.'and s1imulofion, and icefo‘nd heat heat therapy. therapy. On October On October 6, 6, 2017, 201 7, the The patient patienf presented presented to Accident && Injury to Accident Injury Chiropractic Chiropractic forfér treatment, Treatment, which which consisted consisted ofof manipulation, manipulation, intersegmental intersegmenfol traction, Traction, electrical electrical muscle muscle stimulation, 0nd ice stimulcufion, and ,and heat Iceland heof therapy. Therapy. ' On October On October 7,7. 2017, 2037, the the patient presenied to patient presented Accident && Injury to Accident Injury Chiropractic Chiroprocfic forfor treatment, Treatment, which which consisted consisted ofof manipulation, manipulation, intersegmental intersegmenfol traction, traction, electrical electrical muscle muscle stimulation, 0nd ice stimulation, and 0nd heat ice and heat therapy. fheropy. On October On October 9, 9, 2017, 2017, the the patient patient presented presented to Accident && Injury to Accident Injury Chiropractic Chiropractic for for treatment, Treatment, which which consisted consisted of of manipulation, intersegmental traction, electrical muscle manipulation, intersegmentol Troca‘ion,etec’rricol muscle stimulation, 0nd ice stimuiofion, and 0nd heat ice and hecfi therapy. therapy. On October On October 10,2017, 10, 2017, the The patient patient presented presented to Accident && Injury to Accident Injury Chiropractic Chiropractic for for treatment, treatment, which which consisted consisted of of manipulation, elecfricol muscle stimulation, Traction, 0nd ice 0nd manipulation, electrical muscle stimulation, intersegmental traction, and ice and heal therapy. infersegmental heoi therapy. On October On October II,H, 2017, 2017, the The patient potiem presented presented to Accident && Injury To Accident Injury Chiropractic Chiropractic for for treatment, Treatment which which consisted consisted of of manipulation, manipulation, intersegmental infersegmentol traction, Trocfion, electrical muscle stimulation, electrical muscle 0nd ic.Ei,and stimulation, and iceiond heat heot therapy. therapy. On October On October 12,12, 2017, 2017, the the patient patient presented presented to10 Accident Accident && Injury Injury ChiropraCtic Chiroproéfic for for ac1 re-examination. re-exomino’rion. Cervical Cervical range range of of motion motion was was very very mildly mildly decreased decreased with with mild mild pom pain. Thorocolumbor range Thoracolur)!bar range of of motion motion wos was mildly mildly decreased with decreased with mild pom. mild pain. On October On October 13,l3, 2017, 2017, the poh’enf presented the patient presented to ’roAccident && Injury Accident Injury Chiropract(c Chiropractic for for treatment, which consisted Treatment, which consis’red of of manipulation, monipulofion, electrical eiecfricol muscle stimulation, muscle stimulation, and ice 0nd 0nd ice and heat heat therapy. Therapy. · On October On October 16,16, 2017, 201 7, the The patient patient presented presented to Accident && Injury to Accident Injury Chiropractic Chiropractic for for treatment, which consisted treatment, which consisted of of manipulation, electrical muscle sfimulofion, 0nd ice 0nd manipulation, electrical muscle stimulation, and ice and heat therapy. heat Therapy. On October On October 17,17, 2017, 2017. the the patient patient presented presented to Accident && Injury to Accident Injury ChiropraCtic ChiropraCTic for for treatment, which consisted Treatment, which consisted of of manipulation, electrical muscle stimulation, ice 0nd heat therapy, 0nd manipulation, electrical muscle stimulation, ice and heat therapy, and therapeutic exercise . therapeutic exercise. .,_· .. ( .. Michael Michael Burch Burch ;‘ December 9, December 9, 2019 201 9 CASE CASE #:#2 20984866 20984866 Page Page 33 of of 66 On October On October 19,19, 2017, 2017, the pofiem presented The patient presented to to Accident Accident & & Injury Injury Chiropractic Chiropractic for for treatment, treatment which which consisted consisted of of manipulation, manipulation, electrical electrical muscle muscle stimulation, stimulation, ice ice and 0nd heat heat therapy, Therapy, and 0nd therapeutic therapeutic exercise. exercise. On October On OcTOber 20, 20, 2017, 2017, the ’rhe patient patient presented presented to ’ro Accident Accident && Injury Injury Chiropractic Chiropractic for for treatment, freOTmem‘, which