samantha haggerty accident

ANSWER TO INTERROGATORY NO. Interrogatory No. 12: Identify all your employers for the past five (5) years and the dates and nature of such employment. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. 2: Mr. Kevin McGinnis, (443) 848-4303, (410) 446-8519 was a witness to the occurrence. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. ANSWER TO INTERROGATORY NO. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. She was occasionally admitted to various emergency rooms for dehydration, pain from the accident, and pneumonia. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Advanced Radiology; Joe Kennedy, M.D. Indiana Area School District © 2021. Rakesh K. Mathur, M.D., is an expert in the field of internal medicine, anesthesiology, and critical care; he is expected to testify at trial as to the care and treatment rendered to the Plaintiff following the auto accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. 9: See Answer to Interrogatory No. Plaintiff was not running late at the time of the accident. ANSWER TO INTERROGATORY NO. If so, state the details, including date, place of such accidents or accident, nature of injuries sustained, and identify the parties involved, stating the identities of attending physicians and other health care providers, and dates of all examinations or treatments for such injuries. ANSWER TO INTERROGATORY NO. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. Secretary to the Business Manager and Accounts Payable, Mathematics Teacher and Technology Innovator, Speech-Language Pathologist - Ben Franklin Elementary, Secretary to the Superintendent & Right-to-Know Officer, Learning Support Teacher - East Pike Elementary, School Counselor - Horace Mann & Eisenhower, Administrative Assistant- Jr. High School Counseling Office, Principal - Horace Mann Elementary School, Mathematics Teacher, Senior Class Advisor, Administrative Assistant - Sr. High School Counseling Office, Principal - Ben Franklin Elementary School, MTSS Facilitator - Horace Mann Elementary & Eisenhower Elementary, Assistant to the Supervisor of Buildings and Grounds, Children Services Booklet for Indiana County, Tutoring - Ark of Learning - Salvation Army, Voluntary Student Accident Insurance Form, The High Arrow - Sr. High School Newspaper. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. 20: DOB: 1/20/67; SSN: 215-88-8720; Height: 5' 7" and Weight: 163 lbs. 26: All individuals identified within these answers to interrogatories have personal knowledge of the facts in this case. I do solemnly declare and affirm under the penalties of perjury that the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information and belief. 10. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. The doctors' opinions are based upon their review of Ms. Powers’ medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Avraam Karas, M.D., is an expert in the field of orthopaedics and thoracic and outlet surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Plaintiff was a little sore from the accident and had a couple of physical therapy visits and was back to baseline shortly thereafter. Interrogatory No. They quite literally worked as hard as if not harder than the doctors to save our lives. Interrogatory No. 1: Give a concise statement of facts as to how you contend the accident took place. ANSWER TO INTERROGATORY NO. Representatives and doctors from Rosen-Hoffberg Rehabilitation and Pain Management Associates are experts in the field of medical rehabilitation, physical therapy, and pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. $ 140.00 Rafiq K. Patel, M.D. ANSWER TO INTERROGATORY NO. This is the OLD TIME MOVIE section. Gary was a two tour Vietnam Veteran. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. We start off on this page with OLD TIME MOVIES WORLDWIDE then at the top, above the great Lucille Balls head you will see the grey header with the sub categories, just click on the title you want to view ie: OLD TIME CLIFFHANGER MOVIE SERIALS and it will take you to that page OR Just click below on the Movie section below you … She does have pain in her legs on occasion. See repair records already produced. $ 2,400.00 Good Samaritan Hospital $60,100.00 Henry A. Spindler, M.D. At the time of the accident, Plaintiff was earning $36.00 an hour and worked an average of 32 hours a week. ANSWER TO INTERROGATORY NO. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. + de 10 000 célébrités, stars et personnalités du monde entier avec leur biographie, des photos, des questions/réponses sur leur vie, des commentaires d'internautes ainsi que leurs avis sur … 1: On May 22, 2003 Plaintiff was operating her vehicle on Maryland Route 152 near its intersection with Reckord Road. If so, state when, describe the complaints or symptoms, and identify all doctors and other health care providers who treated or provided examinations or treatments. Mid-Atlantic Neurosurgical Associates, P.A., Agha S. Khan, M.D., and their representatives are experts in the field of orthopedics and neurosurgery; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Interrogatory No. $ 8,875.00 Rosen-Hoffberg Rehabilitation $ 3,600.85 And Pain Management Assoc., P.A. ANSWER TO INTERROGATORY NO. ANSWER TO INTERROGATORY NO. If so, state the date, the subject matter, the identity of the person recording said testimony, and the identity of the person who has present possession of each said transcript of testimony. 19: State whether you ever had, before the accident, complaints of pain or symptoms of disease or injury in those parts of your body which were injured in the accident. 16: If you, since reaching the age of majority, have ever been convicted of any crimes, other than minor traffic violations, state the nature of the crimes, the dates of conviction, and the names and locations of the courts. If the vehicle is unrepaired, state the address and the hours at which time it may be seen. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. Tous les décès depuis 1970, évolution de l'espérance de vie en France, par département, commune, prénom et nom de famille ! Plaintiff was expected to be at the doctor's office around 4:30 p.m. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. These was another individual at the scene as identified above. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. $ 1,045.00 Wayne Sodano, D.C. Harford County Ambulatory $ 3,768.00 Chesapeake Medcare Services $ 3,095.00 Avraam Karas, M.D. Plaintiff may have been seen for other unrelated issues; however, she was never checked for neck pain before the accident. Interrogatory No. ANSWER TO INTERROGATORY NO. ANSWER TO INTERROGATORY NO. Interrogatory No. If a married woman, state your full maiden name. Plaintiff was a passenger in a car drive by her friend, Trudy Schacor. Plaintiff does not recall doing anything unusual the night before the accident. 17: State whether you have within your control, or have knowledge of any transcripts of testimony in any proceeding arising out of the accident. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Brady opened his own studio in New York in 1844, and photographed Andrew Jackson, John Quincy … $ 1,065.00 (MS DOCTORS: $ 8,409.00) Steven A. Romener, M.D. Henry A. Spindler, M.D., is an expert in the field of rehabilitation medicine and electromyography; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Interrogatory No. Interrogatory No. The American television series The Love Boat (Love Boat in its final season), set on a cruise ship, was aired on ABC from September 24, 1977 until May 24, 1987. Representatives and doctors from Harford County Ambulatory Surgical Center are experts in the field of pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Michele T. Cerino, M.D., is an expert in the field of thoracic surgery; she is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. Lewiston-Gary A. 4: Identify all persons who arrived at the scene within two (2) hours after the accident. ANSWER TO INTERROGATORY NO. 21: At the time of the accident, Plaintiff was on her way to take her son to see his doctor and was coming from home. Nothwithstanding this objection, Plaintiff has not been convicted of a crime. The contact form sends information by non-encrypted email, which is not secure. Gray, 6o, of Bryant Pond died April 1, 2009 after a brief illness. 24: Outline in detail the work schedule, physical and other activities for the Plaintiff(s), for the 24-hour period immediately before the accident. 7: As a direct and proximate result of the Defendant's negligence, Plaintiff sustained injuries to her neck, back, knees, head, thoracic outlet syndrome, radiating numbness, tingling and pain into her upper and lower extremities, a herniated cervical discs requiring a discectomy and fusion at three levels. 22: State whether you consumed any alcoholic beverages, medications, or drugs within eight (8) hours prior to the accident, places where such alcoholic beverages, medications, or drugs were obtained, and the nature and amount thereof. We serve the following localities: Baltimore; Prince George's County including Bowie, Laurel, Landover, Hyattsville; Anne Arundel County including Glen Burnie; Baltimore County including Cockeysville, Glyndon, Hunt Valley, Jacksonville, Lutherville-Timonium, Owings Mills, Parkville, Reisterstown, Plaintiff Attorney Legal Information Center, Example Pretrial Documents for Plaintiff's Lawyers. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. $ 1,515.00 John Cardero, D.O. Kevin Strauss or some other individual will be called as an expert in the field of vocational rehabilitation; they are expected to testify as to the extent of the Plaintiff's ability to be re-trained in a career suitable to her skills and ability to learn a new trade, and the costs associated with such retraining, loss of earnings capacity and any losses she may incur. Abdallah J. Helou, M.D., is an expert in the field of orthopedics and thoracic outlet surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. 27: As to any document, object, or other item produced by you in this case which has been altered prior to or as a part of the production process, state its identity with sufficient specificity to identify it, the nature of each alteration (i.e., the material or condition prior to alteration and the material or condition after the alteration), the date of each alteration, the name and address of each person who made each alteration and the reason or purpose of each alteration. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. 12: 2004 Riverview Nursing Center 2005 Riverview Nursing Center 2006 Riverview Nursing Center 2017 Canton Harbor Healthcare Center. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Plaintiff earned $87,000 in 2006 and $91,000 in 2007. Dr. Johnson's opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. 11: If you have any present complaints on account of the injuries received in the accident, state in detail the nature of the present complaints, and what injuries, if any, are alleged to be permanent. Plaintiff is unaware of any other eyewitnesses to the occurrence other than the parties and her son who was a passenger in her vehicle. + de 10 000 célébrités, stars et personnalités du monde entier avec leur biographie, des photos, des questions/réponses sur leur vie, des commentaires d'internautes ainsi que leurs … $ 1,475.00 Agha S. Khan, M.D. Each episode has multiple titles, referencing the simultaneous storylines contained within. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Richard Trinkes, M.D., is an expert in the field of orthopaedics; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. ANSWER TO INTERROGATORY NO. Interrogatory No. At the time of the accident, I was not taking any medication. 22: Within (8) hours prior to the accident I did not consume any alcoholic beverages. 5: Identify all persons who have given you statements, or from whom you have statements reduced to written or recorded form, the dates of such statements, the identity of persons who procured such statements, and the identities of the persons who have custody or possession of such statements. Legacy.com enhances online obituaries with Guest Books, funeral home information, and florist links. 7: State in detail the nature of all bodily injuries sustained by you as a result of the accident, and state which injuries, if any, are claimed to be an aggravation to any condition that existed before the accident. She contends that all of these injuries and ongoing problems are permanent. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. 19: See Answers to Interrogatories 9,10, and 18. Combien de temps vous reste-t …

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