"i ICINAL IN THE SUPREME COURT OF OHIO STATE OF OHIO ex rel., CAMBRIDGE HOME HEALTH CARE, INC./PRIVATE CASE NO. 2008-1464 ORIGINAL ACTION IN MANDAMUS RELATOR, vs. THE INDUSTRIAL COMMISSION OF OHIO R E C E: and LAURA HORVAT RESPONDENTS. CLERK OF COURT SUPREME COURT OF OHIO PARTIES' STIPULATED PRESENTATION OF EVIDENCE MICHAEL J. REIDY ( 0012603) MILLISOR & NOBIL CO., L.P.A. 9150 South Hills Boulevard, Suite 300 Broadview Heights, OH 44147 (440) 838-8800 - Telephone (440) 838-8805 - Fax mreidy@millisor.com CHARISSA D. PAYER (0064452) ASSISTANT ATTORNEY GENERAL 150 East Gay St., 22"d FI. Columbus, OH 43215 (614) 728-3043 - Telephone (614) 728-9535 - Fax cpayer@ag.state.oh.us Counsel for Relator, Cambridge Home Health Care, Inc./Private Counsel for Respondent, Industrial Commission of Ohio MARK M. STURIK (0000377) THOMAS C. MAYS & ASSOCIATES 1370 Ontario Street, Suite 1520 Cleveland, OH 44113 (216) 475-0725 Counsel for Respondent-Claimant, Laura Horvat AUC 1$ 2009 CLERK OF COURT SUPREME COURT OF OHIO PARTIES' STIPULATED PRESENTATION OF EVIDENCE The parties, by and through counsel, and pursuant to S.Ct.Prac.R. X, §7, hereby stipulate that the attached documents, indexed as Exhibits A - N and paginated PAGE 1 - 111, are true copies of documents filed with and before the Ohio Bureau of Workers' Compensation with respect to the Respondent Laura Horvat's Claim No. 04-888455, and that these copies shall constitute the evidentiary record before the Court in this original mandamus action. The parties further stipulate that the record may be supplemented by written agreement of all parties, by submission of certified copies of documents from said claim file, or by order of this Honorable Court. STIPULATED AND AGREED TO: Micha J. Reidy (00 2603) MILLISOR & NOBIL CO., L.P.A. 9150 South Hills Boulevard, Suite 300 Cleveland, OH 44147-3599 (440) 838-8800 - Telephone (440) 838-8805 - Fax mreidy(a) millisor.com Counsel for Relator, Cambridge Home Health Care, lnc./Private /s/ Charissa D. Payer (per phone consent 8/14/2009) Charissa D. Payer (0064452) Assistant Attorney General 150 East Gay St., 22nd Floor Columbus, OH 43215 (614) 728-3043 - Telephone (614) 728-9535 - Fax cpayer(c)aq.state.oh.us Counsel for Respondent, Industrial Commission of Ohio /s/ Mark M. Sturik (per phone consent 8/14/2009) Mark M. Sturik (0000377) Thomas C. Mays & Associates 1370 Ontario St., Suite 1520 Cleveland, OH 44113 (216) 475-0725 - Telephone marksturik&sbcglobal.net Counsel for Respondent, Laura Horvat 2 t CERTIFICATE OF SERVICE Copies of the foregoing Parties Stipulated Presentation of Evidence, Index of Exhibits, and Exhibits A - N were mailed by regular U.S. mail, postage pre-paid, on this 17th day of August, 2009 to: Charissa D. Payer, Esq. Assistant Attorney General 150 East Gay St., 22"d Floor Columbus, OH 43215 Counsel for Respondent, Industrial Commission of Ohio and Mark M. Sturik, Esq. Thomas C. Mays & Associates 1370 Ontario St., Suite 1520 Cleveland, OH 44113 Counsel for Respondent, Laura Horvat Mich el J. Reidy 3 IN THE SUPREME COURT OF OHIO STATE OF OHIO ex rel., CAMBRIDGE HOME HEALTH CARE, INC./PRIVATE CASE NO. 2008-1464 ORIGINAL ACTION IN MANDAMUS RELATOR, vs. THE INDUSTRIAL COMMISSION OF OHIO and LAURA HORVAT RESPONDENTS. INDEX OF EXHIBITS FOR PARTIES' STIPULATED PRESENTATION OF EVIDENCE EXHIBIT DOCUMENT(S) PAGE S A Respondent-Claimant Laura Horvat's First Report of 1 Injury in Claim No. 04-888455 filed February 4, 2005 B Relator-Employer's correspondence dated January 25, 2 2005 accepting the claim for "sprains and strains of the right wrist and hand" C Respondent Industrial Commission of Ohio's Record 3-4 of Proceedings dated October 4, 2006 noting Relator's accepting the claim for the additional allowance of "aggravation of pre-existing arthritis of the right wrist" D Respondent Laura Horvat's C-86 application for 175 5 weeks of disability for loss of use of the right hand filed February 25, 2008, including: . Medical report of Dr. Todd Hochman dated February 14, 2008 6-7 E Respondent Industrial Commission of Ohio's Record 8-9 of Proceedings (DHO) dated May 15, 2008 denying the application for loss of use of the right hand 4 F Respondent Industrial Commission of Ohio's Record of Proceedings (SHO) dated June 13, 2008 granting the application for loss of use of the right hand 10-11 G Relator's Notice of Appeal of SHO Order with Brief in Support filed June 30, 2008, including: 12-24 • Correspondence from Dr. Michael Keith dated January 21, 2008 • VoCare Services, Inc. Status Update Report dated January 30, 2008 • MetroHealth therapy records • Functional Capacities Evaluation by Barbara Hornbeek, PT dated May 7, 2008 • Medical record review by Dr. Scott Singer dated June 30, 2008 • Copies of legal authorities attached to Brief in Support 25 26-29 30-42 43-48 49-50 51-91 H Respondent Industrial Commission of Ohio's Order dated July 5, 2008 refusing Relator's appeal 92-93 I Medical record of Dr. Michael Keith dated August 5, 2005 94 J Medical report of Dr. Rex Dinsmore dated October 23, 2005 95-96 K Medical report of Dr. R. Scott Krupkin dated December 14, 2005 97-99 L Medical report of Dr. Michael Magoline / Crystal Clinic 100-102 M Correspondence from Dr. Michael Keith dated October 5, 2007 103 N Medical record review by Dr. Donato Borrillo dated November 2, 2007 5 104-111 a WARNING: Any person who ob©^ns compensatlon from BWC or seN-msuring anploye» by. knowrngty misrepresenong or conceabng hca, na4mg faJse sraasnenqnr accepong corrQensacon to wh¢it heJshe ts no[ enudcd,is zubject tc felony criminal prosecuuon for ffiaud First Report of an Injury, Occupational Jeftd WcrlretY tempensatfan euilt with yov In mind, --' Disease or Death For fuscer serviee Complete as much of all four sections of this form as possible,Type or print in black or blue ink (ftC :913SE1 Last Name. Ftrvt Name, Middle Inmal Horvat Laura Sooal Secunr Nuniber Home MzrhngAddress 3880 Grafton Road ---.. ^ Srare ._ Cny 9-dgrt _7_P Codc -Brunswick 44212 OH J Ses . f7Malc ❑ Female Marital Stacus OSingle OMarried ODnorred Cououy dddfcrmt dvn USA O Scparaccd ❑ Wldawed Date ol &roh 12_^ 9-19 Number ot Depcndentz - Deparunmt Name Whac days of che week do you usually work Wage Rate U Hour O Month ❑ Week RegWxrwork l ♦ uurs USun OMon fJTues OWed OThur OFr. USx[ FromTu S Pcr OYear OOther Have you been offered or do you expect to receive payntenc lor sha claim from anyone Occupation or Job Tale other ^hxn thc Ohio Bureau of Workeri Compensanon or the employerr ❑ YES ONO Home Heal t h I um appiymg fur recugnn.on of my <Imm uoder rhe Onro m ekaua0medrd,prydrobg<d,mdlwqythwvc mfarmmron Workers Compensmmn Act fw work-.elored qunes Ihul I dN ihm u rtloted to nry eob.eri compensorron ciovn to rhe Ohio rms purpomH mT2c I requca prymenr fur cmipcreorm nndlnr 6urenu a(NUrku. Campensormn rhe fndusmal Gnmmnuon medcdr.pernesovNM.obkDrtttpoyment(i)mMeprovdrrs ofOhin.Ihtemployerktmdmthistlamr,NmemployerS ofony medcalsu, ves oreouthwrzed Iunderstondtharlum allowin any (3 3 0) 2 7 3- 61 3 . red kerSignature ^ morwgedcorenrgornropnni,ard onyaudiorrsedrepruenmtrrez ate ^/ ^ wrder whu vnerds ro tr.wts or c.amrnes me Time of In1,ury If faul.grve dam of death ll l ;-0-u_ OAM OPM Date o11n1urylDisease 1 Tclephone Number Work Nmnber Q - 15 - 2004 Datn Last Worked N.C.L.T. Dxre Remmed ;o Wo Dace Employer NavBed Accident Locamn ( street address) Dam H.red Sure Where Hired City Stare Wav plxce of xecidem or exposure Y D '-^ ES NO an em lo er's prenz¢es+ Type of Inlurylomease and Pzrt(s) oi BodyAHecsed ( For example sprznn of lower left back, erc ) Descnpuon olAccident ( De[crrbe the sequence of events ehat directly mlured the employee, or caused the ditease or death) Whi1alif-tiiLg-pa.tient,._ felL_snap__and_pairL_in __ Strain rnht wr; ^t _and_ See attached_letter _ frQm PhyziuanlHcalrh{are Providcr Name [ ltPhOONumber SveczAddress Fax Number ^q racc Oiagnoso(es) Incl.de ICO-9 Code(s) 9dign ZIP Code Will this inudent cause the inlured worker m miss ei ht or more days of workr OYES ONO Provuder Signaturc . Is this injury causally related (o the mduztnzlinadend ❑ YES ONO' Date BWC Pimada Numbrr Employer Name Policy Number Cambrid e H InivalTrczumenr Uzce Care MzihngAddress(NumberandSsreec- GryorTown.Ssate,andZlPCode) U Employer is Scif-Inrvr'og J O O O ri 3 7 9 _O , O Inprred Worker is Owner/PxrtncrlMember of F Coumy 4085 Em B^'^aL.$W3y .. Locauon, if diHerent from mailing addrest Telephone Number Fax Number CENTIFICATION-Theemploycr c eruries dut the facu m thn applicanon are correcc and valid Mmu.>I Numbcr Federal ID numbcr ^HEJECTION -Theemployer rejeces the validity of thrs daim tor the lollowing rea[on(s) below ^ CLARIFICATION -The employer clarifies and zllows the clalm for the condmon(v) below See-attached letter Employer Signamre andTtle EXHI BI"F` Jo( Com; :nes C-1, C-2. C 3, C-6, (-50, C-51, UD 1, 00 1 22) ate OSHA Case Nnmber B7lC-1]ul (3ev Apnl 3, 2000) This farm meets 05NA 101 reqtorements Page 1 '"N25.2C05 10:56AM CAMBRIDGE SUPPORT A NO. 185 P. ?/? bL amb7rid xcca^ Jy t^cv,^ ^ewa^ yarvx ✓ January 25, 2005 Mr. Mark Sturik 1520 Standard Building, 15`h Floor 1370 Ontario St. Gleveland, OH 44113 Sent via facsimile only (440) 475-5890 f2E: Laura Horvat , Dear Mr. Sturik: i am In receipt of your letter dated January 13, 2005, regarding your represBntation of Laura HQrvat for her workers' compensation claim. The allowed conditions'of her claim are as follows: 842.00 -- Sprains and strains of wrist and hand 842.10 - Hand, unspecified site Please send any further communication to my attention at the following address; Cambridge Home Health Care 4085 E.mbassy Parkway Akron, OH 44333 (330) 888-1922 (330) 988-1080, fax Thank you. rely, inda Percyhski, SPHR Director of Human Resources Self Insured Policy.Number#20005329-0 EXHIBIT B 'Do ^ mOFim-3GOf-1Wi E Joim Cwnmlaaioa m Aavn.^lM d Fkadr^re kpMntcru ^^hNwNq w t 99i,1999. gn0. 7901, 70 Vi ^ Page 2 The in(itistrial (:omntissiun of Ohio I2ECORI) OF PROCEEDINGS Claim Number: 04-888455 LT-ACC-SI-COV PCN: 2062541 Laura Horvat Claims Heard: 04-888455 LAURA HDRVAT 382 STABLE DRIVE LAGRANGE OH 44050 Date of Injury: 10/15/2004 Risk Number; 20005329-0 EX PARTE ORDER This claim has been previously WRIST AND HAND. allowed for: SPRAINS AND STRAINS OF RIGHT C-86 Motion filed by Injured Worker on 09/05/2006. Iss(je: 1) Additional Allowance - AGGRAVATION OF PRE-EXISTING ARTHRITIS OF THE RIGHT WRIST 2) Authorization Of Treatment/Appropriate Medication - SURGERY The 09/29/2006 hearing is cancelled as the self-insured employer (letter of 09/28/2006) has accepted claimant's C-86 request to additionally recognize AGGRAVATION OF PRE-EXISTING ARTHRITIS OF THE RIGHT WRIST. The Self-Insured employer is hereby ordered to comply with the above findings. Typed By: kjb Date Typed: 10/02/2006 Date Received: 09/06/2006 Findings Mailed: 10/04/20D6 Joseph Laszcz District Hearing Officer Electronically signed by Joseph S.I_aszcz The parties and representatives listed below have been sent this record of proceedings. If you are not an authorized representative of either the injured worker or employer, please notify the Industrial Commission. 04-888455 ID No: 14465--90 Laura Horvat Thomas C Mays 382 Stable Drive 1370 Ontario St Ste 1520 Lagrange OH 44050 Cleveland OH 44113-1708 EXHIBIT C Page 3 DHOINF Page 1 kjb/kjb '1'he lndustrial Conunission of Ohio RECORD OF PROCEEDINGS Clain Number: 04-888455 ID No: 1825-80 Risk No: 20005329-0 Cambridge Home Health Care, Inc/Pri Benefits 1 Group 4085 Embassy.Pkwy 250D1 Emery Rd Ste 340 Cleveland OH 44128-5627 Akron OH 44333-1781 ID No: 20785-91 Willacy Lo Presti & Marcovy 1468 W 9th St Ste 700 Cleveland OH 44113-1220 BWC, LAW DIRECTOR EXHIBIT C DHDINF Page 2 kjb/kjb Page 4 and sr.iv^r^ Pinvldnr MOTION Ohio'Bureau Of Workers' Compensation INSTRUCTtONS' • This fonn is to be used by the mtured worker or ernpfoyer andlor their authorized representatives to request a decision by the Bureau of Workers' Compensation or the Industrial Commission that cannot be accomplished through any other form or application This torm is NOT TO BE USED BY HEALTH CARE PROVIDERS OR MANAGED CARE ORGANIZATIONS Health Care Providers or Managed Care Organrzattons must use form C-9, Physician's ReportlTreatment Plan for N 7ndusVral or Occupatronal Disease ^ Proof must be submitted with this form ^ ntured Worker Name Address Laura Horvat clty , State, Zip 382 Stable Drive Claim Number 04-888455 Lagrange, Ohio 44050 This MOTION is a request to consider the following The Claimant respectfully requests she be awarded 175 weeks of permanent partial compensation (schedule B) for loss of use of the right hand pursuant to February 14, 2008 medical report of Dr. Hochman attached and further information contained in file. In support of this MOTION, the following evidence is tncluded (identtfy documents) February 14, 2008 report of Dr. Hochman Stamp THOMAS C. MAYS, ATTORNEY 1520 Standard Bidg.15th ftoor 1370 Ontarlo Street Clevetand, Ohio 44113 ID # 14465-90 Stgned T u^t^N aNOWHOtN ❑ Injured Worker EXHIBIT D Date Signed 2- BQOZ U^6^164ArZZ BLXIAuthortzed Representative ❑ CEO/BWC Admtnistrator t,i ^ /19 J ^ )34 C-86 Page 5 Ul 002/003 02/13J2006 10 27 FAX 12162528722 WESTPARK OCCUPATIONAL MEDICINE & THERAPY TODD S. HocHMAN, M.D. ]NT5RN.1L MEbICINL' & FYDLj712ICS 4367 Rocky River Dr., Suite 100 Cleveland, OH 44135 FAX 216-752-8722 Plwnc 216-252.8S7Z February 14, 2008 Mark Stunk, Esq Derby Professional Burlding 5706 Tumey Road, Suite 103 Garfield Heights, Ohio 44125 Fax: 216-475-5890 REGAROING: LAURA HORYAT CLAIM NO.. 04-888455 INJURY DATE: 10-15•2004 Exwnt DA'tE: 0244-2008 ALLOWANCE: RIGHT WRIBT ARTHROPATHY ( 716.93); RIGHT WRIST 8PRAINISTRA4N (842.00); RIGHT HAND SPRAtNlSTRAfN ( 842.10) History of Injury Ms Horvat is a 51-year-otd female who, on the above stated date of injury was working for Cambndge Home Health Care as a nursa's aid when, in the process of lifting a patlent with multtpte sclerosis, she developed severe pain throughout the nght wrist and hand Ms Horvat attempted ice without significant relief. She then followed up at On The Clock Care where she was treated conservatively wlth physical therapy and prescription medications Despite the conservative treatment, Ms. Horvat remained symptomatsc. Ms. Horvat eventuatly came under the care of Dr. Keith, a board certifled orthopedic hand surgeon Reportedly, Dr Keith ordered a bone scan, which revealed the arthopathy Ms. Horvat had an arthrodesis performed an October 26, 2008 A second right wrist surgery was perforrned on July 19, 2007 Ms Horvat completed post-operative rehabilitation but presents today continuing with significant nght wrist and hand symptomatology Presenting Complafnts Ms Horvat presents today complaining of a sharp stabbing pain as wetl as an aching dull discomfort throughout the dght wnst and hand. She describes weakness throughout the hand Her symptoms are such that she has difficulty lifting and carry+ng heavy tterns as welf as grasping and holdtng objects with the nght hand. She has difficulty sleeping undisturbed and performing routine dally activities She has had to curtad her recreatronai activities It is important to note that Ms Horvat is a nght-hand-0ominant individual Since the October 16, 2004 Injury and subsequent surgeries, Ms Horvat has been forced, for all intents and purposes, to use the left hand for all routine activiGes Spectflcally, Ms Horvat reports that she is unable to open a door wrth her rLght hand Ms Horvat currently utllizes her left hand to manipulate utensils while eating. Ms Horvat now uses her left hand for all personal hygiene. Ms. Horvat reports that she has to turn her oar key with her left hand Of note, paperwork for today's examination was completed by a friend of Ms Horvat's EXHIBIT D Page 6 ^ 003; 003 02/19/2008 10 28 f0.X 12162528122 Page 2 REGARDING; LAURA HORVAT CLAinl No.: 04-888455 10-15-2004 INJURY DATE: Physical Examination Examination of the right wrist and hand reveals that the skin overlytng the nght wrist and hand is intact There is a well-healed scar noted over the dorsal aspect of the right wrist and hand The right wrist and hand are extremely cool to the touch There Is significant tenderness noted throughout the nght wnst and hand There is a flex on conhadure noted throughout the PIP joint of the right fifth digit Handgrip is s gn i cantly diminished on the nght in companson to the left There is atrophy noted throughout the musculature of the right hand There is a sensory defic t noted throughout the right hand; tnoreso throughout the fourth and fifth digits. Capillary refill is intact Distal pulses are intact Range of motion throughout the nghtwrist is essenttatly zero Pincer-grasp was extrernely dtftlculty. Discussion I have had the opportuntty to obtain a history, review some medical records and perform a physical examination on Ms. Laura Horvat Based on the history of injury as reported by the pattent as well as the objective findings noted during today's physical examinatton, it is evident that Ms, Hon+at continues to be significantly symptomatic from the work Injury that occurred ori October 15, 2004 Despite two surgeries and post-operaUve rehabiiitatton, Ms Horvat utd¢es her left hand fot essenttally all routine daily acttvtties. Based on today's examination, I can state to a reasonable degreo of medical certainty that, for all intents and purposes, Ms Laura Horvat has lost functional uae of the nght wrist and hand lf you should have any questions, please do not hesitate to call Stncerely, TSH/ksw cc Thomas Mays, Esq EXHIBIT D Page 7 7'he ln(Justrial Cornmission of Ohiu RECORD Oh PROCEEDINGS Claim Number: 04-888455 LT-ACC-SI-COV PCN: 2081021 Laura Horvat Claims Heard: 04-888455 LAURA HORVAT 362 STABLE DR LAGRANGE OH 44050-9654 Date of Injury: 10/15/2004 Risk Number: 20005329-0 This claim has been previously allowed for: SPRAINS AND STRAINS OF RIGHT WRIST AND HAND; AGGRAVATIDN OF PRE-EXISTING ARTHRITIS OF THE RIGHT WRIST. This matter was heard on 05/08/2008 before District Hearing Officer Rhonda Patsouras pursuant to the provisions of Ohio Revised Code Section 4121.34 and 4123.511 on the following; C-86 Motion filed by Injured Worker on 02/25/2008. Issue: 1) Scheduled Loss/Loss Of Use - RIGHT HAND Notices were mailed to the injured worker, the employer, their respective representatives and the Administrator of the Bureau of Workers' Compensation not less than 14 days prior to this date, and the following were present for the hearing: APPEARANCE FOR THE INJURED WORKER: Sturik, Claimant APPEARANCE FOR THE EMPLOYER: Marcovy APPEARANCE FOR THE ADMINISTRATOR: N/A It is the order of the District Hearing Officer that the C-86 Motion, filed by Injured Worker on 02/25/2008, is denied. District Hearing Officer finds that Ohio Revised Code 4123.57 (B) provides compensation for claimant's who sustain a loss of an enumerated body part by amputation or loss of use. In State ex rel. Gould Inc. vs. Indus. Gomm., (1998), 4D Ohio St. 3d. 323, the Court held that a loss of use...means to the same extent as if by amputation. (District Hearing Officer also cites State ex rel Alcoa Buildiny Products v. Indus Comm., 102 Ohio St. 3d. 341(2004), State ex rel Gassman Y. Indus. Comm.(1975), 41 Ohio St. 2d. 64, and State ex relWalker v. Indus. Comm.(1979), 58 Ohio St. 2d. 402.) After review of all of the evidence on file and testimony at hearing, District Hearing Officer finds that claimant has failed to establish that she has sustained a total loss of use of the right hand and therefore the request for 175 weeks of compensation pursuant to Ohio Revised Code 4123.57 (B) is denied. District Hearing Officer further finds that the 02-14-2008 report of Dr. Hochman fails to establish total loss of use of the hand. District Hearing Officer finds that the records of Dr. Keith through 01-21-2008 document some, albeit limited use of the right hand, which has been confirmed at hearing through testimony of the claimant. District Hearing Officer finds the evidence and testimony at hearing revealed claimant could perform some tasks and/or activities of daily living and could also write her name with her right hand. EXHIBIT E DHOSI Page 1 jd/jd Page 8 lhclnduslrial Comroisxion oC Ohin RECORD OF PROCEEDINGS Claim Number: 04-888455 Based upon the totality of the evidence noted, District Hearing Officer denies the requested award for loss of use. The Self-Insured employer is hereby ordered to comply with the above findings. A POA, IS ON FILE FOR THE ABOVE LISTED INJURED WORKER. An Appeal from this order may be filed within 14 days of the receipt of the order. The Appeal may be filed online at www.ohioic.com or the Appeal (IC-12) may be sent to the Industrial Commission of Ohio, Cleveland Regional Office, 615 Superior Avenue, N.W. - 7th Floor Cleveland OH 44113-1898. Typed By: jd _ Date Typed: 05/09/2008 Rhonda Patsouras Date Received: 03/25/20D8 District Hearing Officer Notice of Contested Claim: 02/25/2008 Findings Mailed: 05/15/2008 Llectianicallysigned by Rhonda Patsouras The parties and representatives listed below have been sent this record of proceedings. If you are not an authorized representative of either the injured worker or employer, please notify the Industrial Commission. 04-888455 Laura Horvat 382 Stable Dr Lagrange OH 44050-9654 ID No: 14465-90 Thomas C Mays 1370 Ontario St Ste 152D Cleveland OH 44113-1708 Risk No: 20005329-0 Cambridge liome Health Care, Inc/Pri 4085 Embassy Pkwy Akron OH 44333-1781 ID No: 1825-80 Benefits 1 Group 25001 Emery Rd Ste 340 Cleveland OH 44128-5627 ID No: 20785-91 Willacy Lo Presti & Marcovy 1468 W 9th St Ste 700 Cleveland OH 44113-1220 BWC, LAW DIRECTOR NOTE: INJURED WORKERS, EMPLOYERS, AND THEIR AUTHORIZED REPRESENTATIVES MAY REVIEW THEIR ACTIVE CLAIMS INFORMATION THROUGH THE INDUSTRIAL COMMISSION WEB SITE AT www.ohioic.com. ONCE ON THE HOME PAGE OF THE WEB SITE, PLEASE CLICK I.C.O.N. ANO FOLLOW THE INSTRUCTIONS FOR OBTAINING A PASSWORD. ONCE YOU HAVE OBTAINED A PASSWORD, YOU SHOULD BE ABLE TO ACCESS YOUR ACTIVE CLAIM(S). EXHIBIT E DHOSI Page 2 id/id .,,1,1-, . , ,:,..,.^,,..,, Page 9 PCOVIa,^r and SCrv1L1, I fhe Industrial ('ouiniission of Ohio RECORD OF PROCEEDINGS Claiin Number: 04-888455 LT-ACC-SI-COV PCN: 20B1021 Laura Horvat Claims Heard: 04-888455 LAURA HORVAT 382 STABLE DR LAGRANGE OH 44050-9654 Date of Injury: 10/15/2004 Risk Number: 20005329-0 This claim has been previously allowed for: SPRAINS AND STRAINS OF RIGHT WRIST AFD HAND; AGGRAVATION OF PRE-EXISTING ARTHRITIS OF THE RIGHT WRIST, DISALLOWED FOR: LOSS OF USE OF RIGHT HAND. This matter was heard on 06/11/2008 before Staff Hearing Officer Robin Nash pursuant to the provisions of Ohio Revised Code Section 4121.35(B) and 4123.511(D) on the following: APPEAL of DHO order from the hearing dated 05/08/2008, filed by Injured Worker on 05/15/2008. Issue: 1) Scheduled Loss/Loss Of Use - RIGHT HAND Notices were mailed to the injured worker, the employer, their respective representatives and the Administrator of the Bureau of Workers' Compensation not less than 14 days prior to this date, and the following were present for the hearing: APPEARANCE FOR THE INJURED WORKER: Sturik, Injured Worker APPEARANCE FOR THE EMPLOYER: Marcovy APPEARANCE FOR THE ADMINISTRATOR: N/A The order of the District Hearing Officer, from the hearing dated 05/08/2008, is vacated. It is the order of the Staff Hearing Officer that the C-86 filed 2/25/2008, is granted. The injured worker is entitled to a scheduled loss of use award as she has proven that she has sustained a loss of use of the right hand. The evidence on file establishes that for all practical intents and purposes the injured worker has suffered the loss of use of her right hand. This finding is based on the results of a functional capacities evaluation that was conducted on 5/7/08. The evaluator found that the injured worker could not perform any finger or manual dexterity activities with her right hand. The injured worker had no measurable grip strength with the right hand. She could not complete fine motor skill testing as she was unable to grasp pegs with her right hand. The injured worker was unable to type or to write with her right hand. The injured worker testified that she did sign her name using a wide pen, but that she had to employ the left hand as an assistive device for the right hand. The evaluator noted that the signature was not legible. The injured worker was unable to complete any pinching or grasping functions of any weights when tested. The Staff Hearing Officer finds this is sufficient to establish that the injured worker has lost function of the right hand for all practical purposes. Payment of the award is to begin as of 5/7/2008. All proof on file was reviewed and considered. An Appeal from this order may be filed within 14 days of the receipt of the EXHIBIT F Page 10 SH01 Page 1 klp/klp The Induslrial Cummissiorn ol Oliio RECORD OF PROCEEDINGS Claim Number: 04-888455 order. The Appeal may be filed online at www.ohioic.com or the Appeal (IC-12) may be sent to the Industrial Commission of Ohio, Cleveland Regional Office, 615 Superior Avenue, N.W. - 7th Floor Cleveland OH 44113-1898. Typed By: klp Date Typed: 06/11/2008 Robin Nash Staff Hearing Officer Findings Mailed: 06/13/2008 Electronically signed by Robin Nash The parties and representatives listed below have been sent this record of proceedings. If you are not an authorized representative of either the injured worker or employer, please notify the Industrial Commission. 04-888455 Laura Horvat 382 Stable Dr Lagrange OH 44050-9654 ID No: 14465-90 Thomas C Mays 1370 Ontario St Ste 1520 Cleveland OH 44113-1708 Risk No: 20005329-0 Cambridge Home Health Care, Inc/Pri 4085 Embassy Pkwy Akron OH 44333-1781 ID No: 1825-80 Benefits 1 Group 25001 Emery Rd Ste 340 Cleveland OH 44128-5627 ID No: 20785-91 Willacy Lo Presti & Marcovy 1468 W 9th St Ste 700 Cleveland OH 44113-1220 BWC, LAW DIRECTOR NOTE: INJURED WORKERS, EMPLOYERS, AND THEIR AUTHORIZED REPRESENTATIVES MAY REVIEW THEIR ACTIVE CLAIMS INFORMATION THROUGH THE INDUSTRIAL COMMISSION WEB SITE AT www.ohioic.com. ONCE ON THE HOME PAGE OF THE WEB SITE, PLEASE CLICK I.C.O.N. AND FOLLOW Tt{E INSTRUCTIONS FOR OBTAINING A PASSWORD. ONCE YOU HAVE OBTAINED A PASSWORD, YOU SHOULD BE ABLE TO ACCESS YOUR ACTIVE CLAIM(S). EXHIBIT F SHOL Page 2 klp/klp „ ,. 3 .,,,I :> .,,,,,,I Page 11 =ua s. ,..,,.. rro.iacr T he Induissisto I (r'-012 U m 0^TCKEp ON CAS NOTICE OF APPEAL PI Com of Ohio 04-868455 This fonn should be delivered il,(TJAL ^ CLAIM NUMBER to the office where this decision took place. - -8190 SOCIAL SECURITY # ❑ Address on appeal is new DATE OF INJURY EmptoyersAddress Injured Worker's Address Phune ( i Namc Laura Horvat 10/15/2004 Name Cambridge Home Health Care Addiess Address 4085 Embassy Parkway 382 stable Drive City. SIa1e, Ztp Code IA{ County I ].aGran e OH 44050 Phone City, State. Zip Code kron, OH 44333 t Employer's Representative Injured Worker's Representative Name Name 1' Thomas C. P]a s Es . Appealed by Willacy, LoPresti & Marcovy ❑ Injured Worker QEmployer ❑ BWC Administrator = 0 c7 ^ Appealing Order of g c a Heard at (City) cl e v e lzn d z Oh. ❑ BWC Administrator Date of Hearing: 06/1170II ° j ❑ District Hearing Officer Date Order Received: 06^^ 1T %^ ❑ Staff Hearing Officer As a matter of law, SHO improperly and solely ReasonforAppeal: rPlied n;nn au ir9anra nnt pinor3 hy a phyGi.- i.an r., d°ternine a disability in a"los^ of use" claim Howwouldyouliketheorderchanged:Order vacated and remanded for furthar proceedings Have you or do you intend to file new evidence not available at the last hearing? ® Yes ❑ No To be completed by Self-Insured Employer. ❑ Compensation / benefts have or will be timely paid as mandated by R.C. 4123.511 'U Compensation 1 benefits will NOT be timely paid as mandated by R.C. 4123.511 Y NOTE: Failure to identify the necessary documents may result in a determination not to hear an appeal at theCommission tevel. Documents identified on attached Document List I hereby certify that I have mailed copies of this notice to the M injured worker's representative and / or D employer's d a copy to the representative (check one or both), on J i i 7 y 7 20 OB If there is no representative, I have m injured worker and/or employer. ❑ Bycheckingthisbox,Icertifythatlamanon-attorneyrepresent i who as eena thoriz Ir edtofi ❑ Employer. this appeal by the ❑ Injured Worker p0e1la ignalure) tC-52 EXHIBIT G An Equal Ooportunity Employer And Service Provider (Rev 9705) Page 12 NOTICE OF APPEAI. (IC-12) ATTACHMENT Necessary Bocument List as Required by R07-1-04 (1) Identification of all the underlying adrninistrative orders from which the notice of appeal is filed; On February 25, 2008, claimant filed a C-86 requesting 175 weeks compensation for loss of use of her right hand under R.C.4123.57(B). The BWC referred the request to the IC an March 24, 2008, by way of referral letter. DHO Patsouras, in an order mailed May 15, 2008, denied claimant's "loss of use" request. [See, Exhibit "A", DHO order of 05/15/2008, hereto attached.] Subsequently, claimant appealed the DHO's order. In an order mailed June 13, 2008, S11O Nash allowed claimant's "loss of use" request. (See, Exhibit "B", SHO order of 06/13l2008, hereto attached.] Pursuant to R.C. 4123.51 i(E), this is the employer's appeal of the SHO order mailed June 13, 2008, granting claimant's allowance of loss of use of her right hand. (2) Identification of all relevant documents that are within the claim file and where appropriate, citation to legal authority relied upon, to support the request that the notice of appeal be accepted for hearing under Section 4123.511(E); In support ofCambridge Home Health Care's Notice of Appeal are the following documents: Employer's Brief in Support Exhibit "A", DI IO order of 0S/15/2008 Exliibit "B", SI-10 order of 06/13/2008 Exhibit "C", Letter of Dr. Michael Keith Exhibit "D", Status Update Report prepared by VoCare Services Exhibit "E",Therapy Records from MetroHealth Exhibit "F', FCE performed by Barbara Hombeek Exhibit "G", Medical Review of Dr. Scott Singer % l n (those authorities noted as "attached" are attached to the brief in support): 'D 3 0 R.C.4123.57 R.C.4123.511 o Srnte ex rel. Noll v. Indus. Comm. (1991) 57 Ohio St.3d 203. Ohio Admin. Code 4123-6-01(D). Chapter 4755 of the Revised Code R.C.4731.34. K. C.4755.40. (Attached.) Zinn v. Leach (November 29, 1990), Champaign App. Nos. 90-CA-03, and 90-CA-08, unreported, 1990 WL 187466, citing, Burress v Park Cycle & Marine, Inc. (Nov. 7, 1988), Stark App.No. CA-7492, unreported. ( Attached.) -1- EXHIBIT G Page 13 R.C.4123.32 Ohio Admin. Code 4123-5-18. Ohio Adniin. Code 4123-3-15. aLhe Hearing Officers Manual, Memo E2, dated May 7, 200). Memo E2. (Attached.) R. C.4121.32. Cited in HN3, Stare ex rel. Stringer v. Hamilton Plastics (Franklin, June 25, 2002) 2002-Ohio-3255, No. Ol AP-1157. (Attached.) Cited inFN3, Sicklesmith v. Chesterhoist, et aL (2006), 169 Ohio App.3d 470, No. 05-CO-20 Stale ex rel. Miller v. bdus. Comm. (December 1, 2005), 2005 -Ohio- 6371, No. OSAP-214. (Attached.) State exreL HumilityHouse v. Indus. Comm. (Franklin, May 29, 2003), 2003-Ohio-5582, 03-LW4309 (Attached.) z 0 c W U EXHIBIT G Page 14 BEFORE THE INDUSTRIAL COMMISSION OF O1I1O LAURA HORVAT, CLAIM NO. 04 888455 Claimant, t^ -vs- EMPLOYER'S BRIEF IN SUTPOCT OF CAMBRIDGE HOME HEALTH CARE ITS APPEAL OF THE STAFF-I-IEnl> ING, = Employer. OFFICER'S ORDER, PURSU/SNT R. C.4123.511(E) BRIEF IN SUPPORT I. PROCEDURAL HISTORY On February 25, 2008, claimant filed a C-86 requesting 175 weeks compensation for loss of use of her right hand under R.C.4123.57(B). The BWC referred the request to the IC on March 24, 2008, by way of refer7al letter. DHO Patsouras, in an order mailed May 15, 2008, denied claimant's "loss ofuse" request. [See, Exhibit `A", DHO order ofoS/15/2008, hereto attached.) Subsequently, claimant appealed the DHO's order. In an order mailed June 13, 2008, SHO Nash allowed claimant's "loss of use" request. [See, Exhibit "B", SIiO order of 06/1312008, hereto attached.] Pursuant to R.C. 4123.51 1(E), this is the employer's appeal of the SHO order mailed June 13, 2008, granting claimant's allowance of loss of use of her right hand. H. STATEMENT OF FACTS This is a workers' compensation claim, numbered 04-888455, before the Industrial Commission of Oliio. On October 15, 2004, Mrs. Horvat suffered an injury to her right hand and wrist while attempting to lift a patient during the course of her employment with Cambridge 14ome Health Care (°Cambridge"). The three allowed conditions in this matter were: (1) Right Wrist Arthopathy (716.93), (2) Right Wrist Sprain/Strain (842.00), and (3) Right Hand Sprain/Strain -1- EXHIBIT G Page 15 (842.10). On February 25, 2008, claimant filed a C-86 requesting 175 weeks compensation for loss of use of her right hand. At the time of filing, Mrs. Horvat's treating physician was Dr. Michael Keith_ Dr. Keith never opined that Mrs. Horvat's hand was so disabled as to constitute a "loss." ln fact, in his January 21, 2008, letter to Mrs. Horvat, Dr Keith told claimant she could return to work, pending a vocational assessment, with a SIb lifting restriction. [See, Exhibit "C", Letter of Dr. Michael Keith, hereto attached.] Further, during the requested vocational assessment ofMrs. Horvat, the case manager found Mrs. Horvat could lift a can of soup with her right hand, sign her name (although slowly), and was capable of returning to work. [See, Exhibit "D", Status Update Report prepared by VoCare Services, hereto attached.] Other evidence on record did not indicate a loss of use either. In Mrs. Horvat's physical therapy records from MetroHealth, the occupational therapist notes claimant can make finger extension and flexion, can oppose thumb to index and middle fingers, and has a right hand lateral pinch strength of 7 pounds (norm is 12.0 poundaj. [Se,@, Ex m ^ "E",Therapy Records from MetroHealth, hereto attached.] The sole basis for claimant'o5equest?or V.) "loss" was the one time exam by Dr. Todd Hochman. _3 -J The BWC referred claimant's C-86 to the Industrial Commission. In an order dated May 15, 2008, DHO Patsouras properly denied the "loss of use" claim stating: ,- District Hearing Officer finds that the Ohio Revised Code 4123.57 (B) provides compensation for claimant's who sustain a loss of an enumerated body part by amputation or loss of use. In State ex rel. Gould Inc. vs. Indus. Comm., (1998), 40 Ohio St. 3d. 323, the Court held that a loss of use...means to the same extent as if by amputation. (District Hearing Officer also cites State ex rel Alcoa Buildin Products v. Indus. Comm., 102 Ohio St. 3d. 341 (2004), State ex re1 Gassman v. Indus. Comm. (1975), 41 Ohio St. 2d 64, and State ex rel Walker v. Indus. C,omm. (1979), 58 Ohio St. 2d 402.) EXHIBIT G Page 16 After review of ait of the evidence on file and testimony at hearing, District Hearing Officer finds that claimant has failed to establish that she has sustained a total loss of use of the tight hand and therefore the request for 175 weeks of compensation pursuant to Ohio Revised Code 412357(B) is denied. District Hearing Officer further fends that the 02-14-08 report of Dr. Hochman fuils to establish total loss of use of ihe hand Distnct Hearing Officer finds that the recordr of Dr. Keith lhrough 01-21-2008 docvment some, afbeit limited use of the right hand, which has been conftrmed at hearing through testimony of the claimant. District Hearing Officer finds the evidence and testimony at hearing revealed claimant could perform some tasks and/or activities of daily living and could also write her name with her right hand Based upon the totality of the evidence noted, District Hearing Officer denies the requested award for loss of use.' [See. Exhibit "A".] Upon the employee's appeal, an FCE was performed. [See, Fxhibit "F", FCE performed by Barbara Hornbeek, hereto attached.] This test was performed by Mrs. Barbara Hombeek, a physical therapist. [Id.] TheFCE explains the tests performed. [ld.] The concludes with Mrs. Hombeek rating the claimant's performance as "Medium" meaning the results were mostly substantiated, but "[p] erformance on some activities was somewhat inconsistent, self-limited or associated with increase symptom reporting in response to the exam." [Id. at 6.] Mrs. Hombeek also notes validity concems regarding "unusuaUexcessive symptoms reports," "inconsistent strength results," "abnormal function uninjured region," "refusal to attempt specific tests," and "increase symptoms following exam." [Id.] On some tests, Mrs. Hornbeek notes that "testing on the right hand was not done." [Id. at 1.] At no point does the FCE opine as to the extent of Mrs. Horvat's disability. No physician signed or reviewed Mrs. Hornbeek's FCE The FCE was filed with the commission and, in an order mailed June 13, 2008, SIIO Nash found: Emphasis added throughout, unless otherwise noted. EXHIBIT G Page 17 The injured worker is entitled to a scheduled loss of use award as she has proven that she has sustained a loss of use of the right hand. 'l-he evidence on file establishes that for all practical intents and purposes the injured worker has suffered the loss of use of her right hand. This finding is based on the results of a functional capacities evaluation that was conducted on 5/7/0S. The evaluator found that the injured worker could not perform any finger or manual dexterity activities with her tight hand. 'I'he injured worker had no measurable grip strength with the right hand. She could not complete fine motor skill testing as she was unabie to grasp pegs with her right hand. 'fhe injured worker was unable to type or to write her name with her right hand. The injured worker testified that she did sign her name using a wide pen, but that she had to employ the left hand as an assistive device for the right hand. The evaluator noted that the signature was not legible. The injured worker was unable to complete any pinching or grasping functions of any weights when tested. The Staff Heating Officer finds this is sufficient to establish that the injured worker has lost funetion of the right hand for all praclical purposes. Payment ofthe award is to begin as of 5/7/2008. [Exhibit "B".] Pursuant to R C 4123.511(E), Cambridge EIome Health Care appeals the abRve-aingici)f ^_ SHO Nash. ^, ^-^ <-, III. LAW AND AI2GUMElYT A. The Statf $earir^ Oifcer Made a Clear Mistake of Law: in Aivardine Partial Permanent Disability Based Solely on Evidence Not Opif-d by a Ph sician. i. The StafT Aearina OlTicer Solelv Itelied UQon the FCE Performed bv a Physical Therapist. The commission must specify in its orders what evidence ha.s been relied upon and briefly explain the reasoning for its decision. State ex ret Noll v Indus. Comm. (1991) 57 Ohio St.3d 203. In the instant case, SHO Nash specifically stated, "This finding is based on the results of a functional capacities evaluation that was conducted on 5/7/08." [Exhibit "B".J SHO Nash then explained [fs reasoning by citing the FCE performed by a physical therapist. [Id.] The SHO makes no references to any other evidence relied upon to make her determination. [Id. ) Pursuant to Nnll, SIIO Nash only EXHIBIT G Page 18 relied upon the physical therapist's FCE_ ii. A Phvsicat TheraQist is not a PhYsician. Under the Workers' Compensation Act, a"physician" is, [a]s defined in division (B) of section 4730.01 of the Revised Code, a doctor of medicine, doctor of osteopathic medicine or surgery, or doctor of podiatric medicine who holds a current, valid certificate of licensure to practice medicine or surgery, osteopathic medicine or surgery, or podiatry under Chapter 4731. of the Revised Code; as provided in section 4734.09 of the Revised Code, a doctor of chiropractic who holds a current, valid certificate of licensure to practice chiropractic under Chapter 4734. of the Revised Code; as provided in section 4731.151 of the Revised Code, a doctor of mechanotherapy who holds a current, valid certificate of licensure to practice mechanotherapy under Chapter 4731. of the Revised Code and who was lieensed prior to November 3, 1985; a psychologist who holds a current, valid certificate of licensure to practice psychology under Chapter 4732. of the Revised Code; or a dentist who holds a current, valid certificate of licensure to practice dentistry under Chapter 4715. of the Revised Code. A physician licensed pursuant to the equivalent law of another state shall qualify as a physician under this rule. Ohio Admin. Code 4123-6-01(D). A physical therapist does not qualify under the above definitions ofa°physician." See generally, Ohio Admin. Code 4123-6-01(D); Chapter4755 ofthe Revised Code. Further, any person who is not a licensed physician cannot legally make a medical diagnosis. See, R.C.4731.34. Pursuant to R.C.4755.40(A), the practice of "[pjhysical therapy does not include the meJical diagnosis of a patient's disability[.]" See also, Zinn v. Leach (November 29, 1990), Champaign App. Nos. 90-CA-03, and 90-CA-08, unreported, 1990 WL 187466, at 8(Court holds physical therapists are precluded &om giving diagnostic opinions in testimony as well as in the form of patient advice and communication.), citing, Burress v. Park Cycle & Marine, Inc. (Nov. 7, 1988), Stark App.No. CA-7492, unreported, at 4, (Court held R.C. 4755.40 precludes physical therapists from giving medical opinions by "wander[ing] outside the statute to give a medical opinion as to permanent injury[.]"); Ifonly licensed physicians can make a medical diagnosis as to a disability and physical therapists are prohibited from making that determination, then it stands to reason EXHIBIT G Page 19 physical therapists are not physicians. By statute, Mrs. Hornbeek is not a physician and could not (and didtot) opine as to the disability of the claimant_2 iii. Only Determinations as to the F;xtent of a Disability made by a Licensed PhXsician are Considered Evidence upon which a Hearing Otiicer may Rely As stated above, only a licensed physician may make a medical diagnosis. See, R.C.4731.34. Section 4123.32(E) of the Revised Code maintains that proposition through the workers' compensation act stating that [w)ithrespecttoanydeterminationofdisabilityunderChapter4123. ofthe Revised Code, when the physician nutkes a determination based upon statements or information furnished by the claimant or upon subjective evidence, he shall clearly indicate this fact in his report. The above requirement of a physician deterrnination is further supported by Ohio Admin. Code 4]235-18(A), which states that "no paynrent of eonrpensation shall be approved by the bureau in a claim unless supported by a report oL physician duly efcensed to render the treatment." "Medical evidence is required to substantiate the allowance of a disability or condition not previously considered" Ohio Admin. Code 4123-3-15(B)(2)(b). These statutes dictate that a 6nding of disability, and subsequent compensation, under any provision of the Workers' Compensation Act must be supported by a physician'.s determination. Not only is there a general requirement under the Act that a hearing officer support his findings of disability on a physician's detemunation, but the R.C. 4123.57 requires it as well. Under R.C.4123.57, when a request is filed with the BWC or upon referral to the commissjon, &--Mediclai' 4i U 2 Mrs. Hombeek makes no detersnination as to the extent of"loss".'nor o^nes a_s" to the disability of Mrs. Horvat. [Exhibit "F'.] The FCE merely explains the tests'she pefformed. -6- EXHIBIT G Page 20 examirwtion may be requested by the BWC or the employer.' This examination is to be perfonned by a physician. See, The HearinR Officers Manual, Memo E2, dated May 7, 2001. Memo E2, pursuant to R.C.4123.57, requires s#s [tjhe Hearing Officer ** * to note in the order that the determination is based upon the medical or clinic•al findings of a particutar doctor or doctors. Also Hearing Officers are to note the reports of additional physicians, if appropriate. It is the duty of the Hearing Officer to evaluate the physicians' ratings of impainnent and issue the determination as provided by O.R.C. 4123.57." a*s [Id] By statute, the EIearing Officer's Manual is controlling authority as "no employee may deviate from nranual procedures without autitorization of the section chief. " R.C.4121.32(A). DRO Patsouras properly applied Memo E2, stating she relied upon Dr. Keith's opinions, then briefly described his findings. [Exhibit "A".] DHO Patsouras also stated she did not rely upon Dr. Hochman's opinion as it was insufficient to establish "loss." [Id.] The StaffHearing Officer, however, wrongfully deviated from the requirement that his determination be based upon "medical or clinical findings of a particular doctor or doctors." In his order, the SHO only referenced and relied upon the report of a physical therapist, who is not a physician. As a physical therapist cannot diagnose a ' An FCE is not a medical examination, but "a series of tests used to assist the examining physician in his assessment" State ex reL Stringer v. Hamilton Plastics (Franklin, June 25, 2002) 2002-Ohio-3255, No. Ol AP-1157, 112, 34. "An FCE tests how well a person can do certain work-related activities such as li$ing walking, squatting, bending, and range of motion" Sicklesmith v. Chesterhoist, et aL (2006), 169 Ohio App.3d 470, No. 05-CO-20, ¶139. The FCE Horvat attended was a series of tests to assess her "current physical capabilities." [Exhibit "FCE", p. 1.] ` The Industrial Commission created the Heanng Officer's Manual pursuant to R.C.4721.32, to adopt procedures and criteria for decision making. The commission was specifically required by the legislature to adopt criteria for "award(s] under division (B) of section 4123.57 of the Revised ('_orle." R.C 4121.32(C)(8). Hence, Memo E2. EXHIBIT G Page 21 disability, the SI-IO committed a clear error in adopting an FCE report without a physician's re^dew. No precedent exists sttpporting the SHO's finding based solely on a physical therapist's FCE. ,Sta1e ex reL Miller v. /nche.s. Comm. (December 1, 2005), 2005 -Ohio- 6371, No. 05AP-214, a factually analogous case, provides persuasive evidence that an FCE is ordy reliable to the extent its views have been accepted by a physician. The claimant in Miller filed for'9oss of use" of his hand. In Miller, however, there were two physician's reports, one ofwhich reviewed an FCE. The physical therapist in Mller opined that the claimant's "hand is basically not useable for working activities." Id. at ¶36. As to the FCE, Miller states that a physical therapist's opinion is reliable only to the extent their view is accepted by the physician. Id. at ¶36 ("Moreover, physical therapist David Kazee's opinion (to the extent that it is viewed as accepted by Dr. Aitken) ***"). See also, Stringer, (In the determination of permanent total disability benefits, the SHO considered two physicians' exams and an FCE by a physical therapist; however, in his order only relied upon the physician reports to make the determination); State exrel. HumiliryHouse v. Indus. Comm. (Franklin, May 29, 2003), 2003-Ohio-5582, 03-LW-4309, at ¶21-30. (the commission relied upon a physician's assessment of a functional capacity evaluation.) Unlike the facts in Miller, SHO Nash had no physician's interpretation of Mrs. Horvat's FCE available; therefore, any findings contained within the FCE cannot be deemed reliable. The unreliability of the FCE has become more apparent since the commission's order dated June 13, 2008 Since the date of the SHO order, the employer has obtained a physician's review of medical records, including the FCE. [Exhibit "G", Medical Review of Dr. Scott Singer.] Dr. Scott Singer specifically states with a reasonable degree of medical certainty and probability ***[that] the results of the 5/7108 functional capacity evaluation do not appear to be a valid indicator of the -8- EXHIBIT G Page 22 claimant's current functional capabilities. The report document a "medium" validity rating and noted that the claimant was self-limited in many of the activities. In addition, she failed to demonstrate any grip strength capability at any of the five settings on the dynamometer despite showing the ability to grasp a pen. As such, the claimant appears to have made a less than full effort duiing the evaluation. (I& at response to question 3.1 In Dr. Singer's opinion, "the claimant's cunent level of function does not meet statutory definition for`9oss of use." [Id. at response to question 2.1 He further notes, based on her medical records, that Mrs. Horvat has funetional capabilities with her right hand that include her ability to move her fingers and to "grasp a wide pen." B. CONCLUSION By law, determinations ofdisability are solely within the province ofphysicians T'he workers' compensation act is no exception. Because the hearing officerrelied solely upon a physical therapist's report, not a physician's report, the hearing officer made a clear error of law in basing his order upon unreliable evidence. The unreliability of an FCE without a physician's review has been documented by case law and a subsequent review by Dr. Singer. Therefore, the July 16, 2008, must be vacated in favor of Cambridge Home Health Care, Inc./PRI and remanded for further proceedings. RespectfulLY Submi OTHY A. Iv1?.RCbVY, ESQ. ( 0006518) MICHAEL S. LEWIS, ESQ. (0079101) WILLACY, LOPRFSTI, & MARCOVY 700 Western Reserve Building 1468 West Ninth Street Suite 700 Cleveland, Ohio 441 13 T:(216)241-7740 F (216) 241-6031 Email: msl@wlmlaw.com Attorneys for Employer Cambridge ITome Health Care, Inc EXHIBIT G Page 23 CERTIFICATE OF SERVICE 1'he aforegoing notice of appeal, brief in support, and exhibits were mailed USPS first class, postage prepaid to: Mr. Sturik, Counsel for Claimant, Office of'Thomas C. Mays, 1370 Ontario St, Suite 1520, Cleveland, Ohio 441 13 on the 1° day of July, 2008. -10- EXHIBIT G Page 24 MetroHealtn CASE $Cllnnl nF MrOlCllaf RI10IAF.1. W. K(ITI7, M.t). Iland. $hnnldcr 8e t)ppcr Erircuiity Coinplcx Paralysis Disordcrs 1i06 Merrnllexllh Drive ClrvelauJ,Oli 34109-1994 Oifice(216)773-4399 FA X (21 6) 77R-.7690 7anuary? 1, 2008 Ms. LauraHorvat 3ZQ Stable Drive LaGrang" 0I-1 44050 Dear Ms. Horvat: At our last ottice visit we discussed the successful surgery in your wrist which nonetheless leaves eou with restrictions and job choices. At the present time we are working through a vocational plan so that you can do a job change into light clerical work. I can at tilis stage tell ynu that no further surgical management or treatment is : required. The current plan that 1 consider you qualify for is a nonworking wage loss CI40 program and that you should considerwork at the 5 Ib. ii;tine limit. Your MCD should assist you in obtainingjob placement. I hope that this is an appropriate summary for where we stand reearding your retunt to work Very Iruly yours, (N^/l^ .'-v/J Michael W. Keith, M.D. Olthopaedic & Hand Surgery MetroHcalth Medical Center Southwest General Medical Center MWl4'ca cc: Linda Hunt RN, CItRn, VoCare Serviccs Cambridge Home Health Care Attorney Tltomas Mays Exhibitc- EXHIBIT G Thc MctroHcalth System 2500 MevoHcaith Drivc, Clcvcland, Ohio '19109-1998 216 - 778 - 7800 Page 25 VoCare Services, Inc. 25001 Emery Rd. Ste. 320 Cleveland, OH 44128 (216) 514-1221 Fax: (216) 514-0706 .l anuary 10, 20(1R To: leannetta Cross/Benefits 1 25001 Emery Rd. Suite 320 Cleveland OH 44128 Re: Laura Ilorvat DOI: 10-15-04 (;]aim: Laura Horvat--8190/04-88845S (SI) RTW Goal: DJDE SS #: Allowed Injury: (842) Rt. Wrist Sprain, (842.10) Hand Sprain Status Update Report 1-30-08: Summary: Laura Horvat is 50-year-old rieht hand dominate female who sustained a rieht hand and wrist - on 10-15-04, during her employ with Cambridge Home Health Care, a self-insured iut^ employer, as a Home Health Care Aid. 71re claim has been allowed for (842) Rt. Wrist Sprain, (842.10) Hand Sprain. Ms. Horvat states she is not comfortable returning to the transitional work program at Cambridge and the physician of record has documented permanent restriction from return to work as a home health aid. As an altemative to transitional work program at Cambridge Home Health Care in the past, Ms. Horvat performed voluntary work for the United Way, a nonprofit agency. Specifically she worked for Faith in Action, an agency that cares for the Elderly in Medina, primarily answering phones, coordinating resources for the elderly. She did this for 1.5 years and was paid wage continuation for 20 hours/week by the employer of record. Ms. Horvat reports she loved this position and was valued at this agency. Jeannette Cross of Benefits 1, the Third Party Administrator for this self-insured employer, referred Ms. Horvat to VoCare Services, Inc. on 9/26/07 for medical case management and ultimately vocational rehabilitation case management pending medical stability and release to participate. She was initially contacted on 10/1/07 after obtaining correct phone number from the employer of record. Initially, Ms. Horvat declined services. This case manager faxed letters to the nhysician ofrecord, injua,-d worker a_*id attoraey of record eut!ining services and justification for services. Ultimately the physician of record, Dr. Keith, forwarded a lcttcr documenting recommendation for vocational rehabilitation services. An initial assessment with the injured worker was ultimately conducted on 11/12/07. Ms. Horvat was participating in occupational therapy (8-12 weeks @ 2X/week) for strengthening and range of motion with goal of maximizing motion to the extent the fusions will allow. 'fhis case manager attended a therapy session and consulted with the treating occupational therapist. Exhibiti;?^ EXHIBIT G Page 26 t.aura Horvat/_8190/04 Paee'_ •-155 (SI i ^cz JOoa4 Ms. liorvat indicated shc ltas, "no pain if I don't use rny hand"; occasional ache or tltrobbing at rest; however with activities the pain can reach a 6-8 on a scalc of 1-10 with 10 representing thc most severe pain imaginable. Functionally, Ms. Horvat reports she is now functionally lcfi hand dominate as she is verv limited in what she can do with the right hand. She reports she is unable to cut vcQetables or lilt more than a can of soup with her right hand. She signs her name with her right hand, very laboriously and slowly. She is now driving her car; however must get into the passenger side to r^rn the key to start 4- engine, then get out and reenter the car on the driver's side. She reports sitting, standing, walking, stair climbing are unimpaired- She hat difficulty sleeping- She is independent in self care activities with some difficulty; however requires assistance with cooking and household chores. She is unable to participate in her outdoor hobbies such as yard work. She eniovs swinunin_e and readin_e. She renorts financial strueeies since tne tnrurv and renucuon ir, income. 'Fhe employer of record has offered a permanent office position. Cambridge I-lome Health Care understands Ms. Horvat has functional restrictions and is willing to accommodate the functional limitations; however, Ms. Horvat has declined this position and during 12114107 office appointment (case manager in attendance) her physician of record supported this decision due to the stressful relationshin with the EUK. We further discussed that the treatinq OT opines Ms. Hotvat wili require a one-handed job and how difficult it will be to find employment for one-handed/non dominate job with different emplover. Dr. Keith aureed to FCE with uooer extremitv focus and aqreed to submit a C-9. While Dr. Keith disagreed with maximum medically improved status, he did encourage her to proceed with oermanent partial imoairment aaplication. Dr. Keith later submitted Medco statina mav lift up to 5# witti right upper extremity. Services Offered this Period: 1. Medical Case Management Services 2. Vocatioual rehabilitatiornplan development Activity since Last Report: This case manager discussed functional capacity evaluation with upper extremity focus with two providers and reviewed samples of their reports. (Approved C-9 pending) On 12/20/07 this case manager finally made telephonic contact with Doris K. at Faith in Action. We discussed arrangement of "volunteer work" (altemative to transitional work program with employer) wlth ihe hope Of mvving Laura into a po;ition urere. Doris indicated Ivis- iiorvat was very valued while she worked there and was, "gifted" in working with the clients. However with her understanding of Ms. T-lorvat's present limitations (as discussed with injured worker), she does not feel they could accommodate her present functional limitations. However; on further discussion agreed if Ms. Horvat could be trained on Voice Recognition Software and adaptive writing techniques, she could indeed use her in a volunteer position. Additionally she felt there is a good possibility of developing a work opportunity there with a Work Trial. EXHIBIT G Page 27 Laura Ttorvat/_8190/04 v455 (SI) Stz indarc Reoott Page 3 1- This was discussed in detaii with Ms. liorvat on 1-9-08; however Ms. Horvat was very ill with upper respiratory illncss. As agrecd w-ith injured worker, this case manager rcferred the iqjured worker to the Bureau oC Vocational Rehabilitation for collaborative plamting. (BVR could fmid the training and adaptive equipmcnt). On 1/28/08, Ms. Horvat contacted this case manager stating she was not going to the scheduled appointment at BVR on 1/29/08. She had discussed the potential benefit with her attorney of record, who suggested BVR would help her get an $8.O0H our job as a receptionist. She is adamant she can find ajob such as this on tier own, without any agency assistance. She further i.n.dicated she ap.d her significant other are down to only one vehicle due to financial difficulty and that she has no transportation as he works full time. After a lengthy discussion regarding possible plan (collaborative with BV R) for preparing for return to work such as work adjustment program with ergonomic specialist assisting to deterrnine necessary adaptive equipment and method needs (such as voice recognition software) and training, job seeking skills training and supported job search to optimize her return to work potential; she inquired if BVR could provide transportation. I suggested she contact the agency to inquire as I am not aware of anyone who provides this service for her situation. She again contends she can find a job on her own. After lengthy discussion, I acknowledged participation in vocational rehabilitation focused services is voluntary and she has the right to decline. She indicated, "That is where I think I am; however let me think about it and I will call you by the end of the week". Recommendations: • Continue medical case management as desired by seN insured employer; however case manager questions if there is value added at this point in the process, if injtued worker is not interested in pursuing assistance with retum to work. Occupational therapy has been discontinued according to Ms. Horvat. • Await injured worker' decision regarding interest/ability to participate in vocational rehabilitation focused services. As this service is voluntary, she has the right to decline. The physician of record has, according to Ms. Horvat, reinforced she needs to "work with MCO (tlris case manager) and return to work (different employer) to a job with lifting rcquirement of 5#. She states he wrote another letter to this case manager (not yet received). • Should Ms. Horvat decline the services outlincd, this case manager has nothing else to offer in the way of vocational rehabilitation services as participation is voluntary. • Should Ms. Florvat agree to proceed and is able to overcome the transportation barrier the following services are recommended: • Funciionai capacity evaluation wiih upper extremity focus. • Community Based Work Assessment, with ergonomic specialist input, at United Way/Faith in Action/office setting, which may lead to Work Trial and/or On The Job Training; or work adjustment program for clerical training with ergonomic input, adaptive equipment/methods. • Ms. Horvat will require assistance with placement into a different job and will benefit from job seeking skills training and job placement and development services to assist her in developing a resume and finding appropriate employment EXHIBIT G Page 28 t955 t^il ^ce J oaa:e •Lanra Horva^8190104 Paee 4 1-3o-08 with in her fwtctional abilities aitd skill sets if the placement at tlnitcd Way does noi result in a job offer. Opinion: It is the opinion of this case manager that Ms. Horvat remains an appropriate candidate for rnedicaUvocational case management services. 'Ihe physician of record has indicated readiness for vocational focus at this time and reconunended different jobldifferent employer. The employer of record is suppo:uve of this goal as well. `.'hile J:e functional barriers a:e signiflcant, Ms. Horvat has demonstrated skills in an office setting and has demonstrated good organizational skills and the softer skills required in a customer service/office setting. Therefore it is the recommendation of this case manager we proceed with vocationally directed services if/when Ms. Horvat is agreeable to do so; otherwise tlris case manager recommends consideration of closure of the referral as this case manager has nothing clse to offer. Thank you for this referral; I will keep you updated on status of Ms. Horvat's decision regarding vocational rehabilitation participation- Sincerely, / ' (?(,a-& ;qf.r. Zn, c'ReJ Linda Hunt, RN, CRRN MedicaURehabilitation Case Manager EXHIBIT G Page 29 The'vfetr-oIlealth System ^ 2500 troHealth Drive j Cleveland OH 4410' '? ] 6= 775-7800 15100003 P roce d ure Vi si t Laura L Horvat (MR# 5266472; D06: 1223011956) 1010812007 2:00 PM in ASC OCC THERAPY wlth Carol Presutto, OTR/L [Z521 F'ncqtlLterlnfarmation __ Encountsr A[Vizitf! De ertment 074860650 I23860829 IASC OCC THERAPY Flace of service ftaferrin jovidar MH OUTPATIENT SURGERY KEITH, MICHAEL W. [2006] CENTER previous Vl^lS Time 10:15 AM Date 70105/2007 DeparLnenk ' Asc Ph sician Offlces -- Provlder Dr, Michael W. Keith, MO RRRR^on_FoL isit Reason OT Evaiuation [1077] CommeM VV^ ' ns L.MP I Postmenopausali Progress Notes Carol Presutto, OTRIL Mon Oct 8, 2007 4:38 PM Signed Visit #: 1116 Referring Provider: Michael W. Keith, MD Diagnosis: Sprain right thumb and wrist with ligament injury during a lift of a patient at work 10/15/2004. Surgery: 7119107 Right wtist art.hrodesis 10/26/2006 Arthrodesis (four corner .i.nz:ercarpal fusion with scaphoid autograft) right wrist, carpectomy scaphoid (lunate fossa and lunate cartilage intact), EP?, released, PIN resected for pain control, repair dorsal ligaments from scaphoid to 1-.inate to capitate Payar: WORKER'S COMP - SELF INSURED Plan: SELF INSURED EMPLOYERS Product Type: Worker's Comp Patient seen for - Evaluation - 20 minutes of therapeutic exercises consisting of: NOV 0 5 2007 desensitization strengthening scar management finger Flexion place and holds precautions Identification was verified by patient verbalizing her name and date of birth. 50 year old right hand dominant female refened to Occupational Therapy for evaluation and treatment. PRECAUTIONS: No heavy lifting, NWB RUE Past Medical I Surgical History: EXStibit& EXHIBIT G zo a TICI 029 OCE H 3WOH 3J0188NV0 ^ E7TOT ^oo '^a^e 30 'Fhe MctroHealth System 1251 QctroHealth Drive t Cieveland pA 44' 216- 774-7300 15100003 Past Medical History (BWC) RT-WRIST SPRAIN NOS Comment: 10/15104 RT WRIST (BWC) RT-HAND SPRAIN NOS Comment: 10/15/04 RT WRIST Past Surgical History EXPLORE/TREAT ANKLE JOINT. Comment ruptured tendon (RIGHT) EXTENSIVE HAND SURGERY- 026250 Comment: RIGHT hand fusion ORIF VAGINAL DELIVERY 59612 Comment: x3 3/18Y2005 3/18/2006 1998 1112006 SUBJECTIVE: Patients Goals: "To get some motion to my tendons and use my arm better." Pain scale: 01 10 if not using right arm, 5 / 10 in right fingertips and wrist and is described as sore and hot. To manage symptoms, patient instructed to utilize heat and ice at home OBJECTIVE: Employment:Employed at Cambridge Home Health Care as a Nurses Aide. Off work due to injury Appearance: Healed longitudinal incision over dorsal right wrist. Mild edema rioted. Atrophy right UE. UPPER EXTREMITY STATUS ( Range of motion and strength): If not noted, joint range of motion and strength within functional limits. Right Forearm: supination: AROM 80 degrees. PROM 85 degrecs, strength 4/ 5 pronation: AROM 90 degrees, strength 4 / 5 Right Wrist: fused Right hand AROM abte to rnake about 112 composite finger flexion PROM able to make full fist. Full aetive finger extension. Smail finger flexion contracture from previous injury. Have tried splint small finger without success. Small finger at plateau. Patient opposes Right thumb to t ips of index and middle fingers. STRENGTH Grip Strength: Greenleaf Electrodynamometer: Position 2: Right 16 lbs., Left 51 lbs. EXHIBIT G ... . . ,.:w „,,.....,^ .... . . . ..........__ _. ^_ .. _ .........-^-en•,^ iTf.t 099 OEE H 9WOH 39QIy9WV0 E1_Ol LOoZ-904LL 31 "1'he iv2ctrofleatth System I 25C ietroHcaltl: Drive I Clevetand OH 447 1 i16778 ?800 15100003 Position 3: Right 19 lbs., Left 51 lbs. Norm for position 2: female age 50-54: Right 53 lbs., Left 48 Ibs. Pinch Strength: Greenleaf Electrodynamorneter Key... Right 7 lbs., Left 15 lbs. 3 Point... Right 6 lbs., Left 17 lbs. Norms for lateral pinch: female age 50-54: right 12.0 lbs. left 11.5 lbs. Norms for three-point pinch: female age 50-54: right 11.51bs. left'f0.5lbs. Sensation: Llght Touch: reports numbness in index and middte fingers Dexterity: Able to use right UE for brushing teeth, unable to use right for fine motor, i. e, putting on earrings, necklace. FUNCTION / ADL: Lives with boyfriend. Now able to use both hands for shampooing, can't write with right hand. Holds hair dryer with left. Unable to tum car key with right. ASSESSMENT: Laura L Horvat is a 50 year old female 11 weeks and 3 days s/p right wrist fusion surgery. Problems include: Decreased Range of Motion, Decreased Strength, Decreased Coordination I Dexterity, Hypersensitivity, Pain, Impaired Self Care Skills, Impaired Home Management Skills, Unable to perform Full Work Tasks, Scarring and Lack of Home Program Patient could benefit from occupationaf therapy for the following goals: GOALS Short Term Goals: achieve in 2 weeks: Demo home exercises of ROM Demo home exercises of strengthening Demo home exercises of scar management Demo home exercises of desensitization fdent'rfy precautions Identify pain management techniques Will achieve an increase of AROM Long Term Goals: achieve in 8 weeks Achieve functional AROM to perform self care, home management and leisure Achieve functional strength to perform self care, home management and leisure Hypersensitivity will not limit patient's performance in self care, home management and leisure Scarring will not limit joint motion in performance of self care, home management and EXHIBIT G .. /^.(ll L C/1<CR'19, _^ ., . ^^ i,n,, I [rt raaq nf,C ^H 3WOH 30QI83Wtl0 w - rc^ ET:OT LOOZ-era 32 The Mctrolicalfl System 12.5 rfetroHealth Drive I Cleveland DH 44 216-773-7300 J 5100003 leisure Incorporate pain management techniques in performance of self care, home rnanagement and leisure Return to work witn restrictions PLAN: Patient to foliow up with physician 12/1412007 Patient to be seen 2 times per week, for 8 weeks. Treatment / Home Program to include: AROM / Place and Holds right fingers Tendon Gliding Exercises Strengthening ( foam block, theraputty and PRE's as toleraled ) Desensitization ( massage, tapping and fabdcs ) Scar Management ( scar massage ) Pain management ( use of heat and cold ) Precautions Plan of care discussed with patient and agreed upon. Risks and benefits of Occupational Therapy discussed with patient Garol Presutto, OTRIL Previous Version SmartForms SIIrattEurmsF_i!ed,DudngthisViait INIERIJISCIPUNARV PATiELtT1FAMILY EDUCATION FII d For the "10115f04 RT WRIS7" E' de ' CBSrnartForms ... _. C9 SmartForm Tex( re ort f smadForrns Tded durino vM Reports CurrentMedication s9L14LQ9L2Qp.7 Instmctions Dis Refillsj MedtcaEon Start Sto PERCOCET 5•325 M(5 OR TABS fOral) 07/18/2007 10/17f2007 1-2 tab q4h prn for oain 60 0 I Medication Comments flled 90/Z7l2006 Pt. Reports she does not currently take medications. Medication Recon -^II{at1p1C1.J^Lf^Encounfer tn40ej A[lefpies as of 7 010 812 0 0 7: Nn Krtown AJ.tetgt_es Date Reviewed !10ros/2o07 Levol Of Level ot Se ice Service CONSULTATION FEE t977991 EXHIBIT G cna ttri H99 nF;c'^'•.~^• ^ .,..^^•.^^ ^ H WWOR 3JQ1218Wtl7 6i=01 LOnZ- 00^^ 33 Tl eMetto"flealth Systetn' 25( 4etroHeatth llrive I Cleveland OH 44' 1216-778-7800 1 S100003 ^n59S1ntBr. Dfagnoces ^ _-_- "- ^- _ --- - Comment Diaqnosls I (BWC) RT-WRJST SPRAIN NOS [842.00) 10115/04 RT WRIST !Pn) -"___ Problem Li^ JQ(0.6/2007 Prohlem •(BWC) RT-WRIST SPRAIN NOS 1842.01 1005104RTWRISi : (6WC) RT-HAND SPRAlN NOS ( 842.10] 10/15/04 RT 1p1RlST (BWC) RT ARTHROPATHY NOS, FOREARM [716.93] 10I15104 RT WRIST. Cl.k 04-888455SI/KHANH Priorl - Cless BWC Not®d Resotved Deleted, 03118/2005 BWC 03/18/ZDD5 BWC 10l15l2004 .. ^ . ., . ..- ._. . . . . Rati^nt, lns#^-uati^.n.s Admin istrative! nfotmation AdministraCtva Information Encounter Clas5flcali4n[5] Rofardn ProvIder Visit Indlcator None KEITH, MICHAEL W.[2006] None Advance Advanne pireetives DlrectlVes an File? Yes Data Askea: 514/07 Power of AKotney On File? Yes Date Asked: 5/4/07 QrS1flr 3 Date 10l08/2007 10/08/2007 r[ ^ ^.ther Orders ^OT INITIAL EVALUATION19"10031 THERAPEUTIC EXERClSES [9711003"591 Encounter Status Order Report Order#35197916 Order #35197917 Eleceunicaliy signed by PRESUTTO. CAROL on 10/8107 at 4:38 PM RyRerltnfcs Re rt: UserAcces R_e ort Re ort: Bar Codes Re ott: Plain te enoounter-summa Re on: After yisit sum_m^ revlew ReooA^Encounler9owsbeetdata ^ EXHIBIT G 1---. . 90'^i liE1 8°9 OEE H 3NOH aUQI`18WV7 fiT:OT L00Z-Pa)91^ 34 T[te Nlctrol3eald i Systern j 250 r.etroHcalUt Dtive I Cleve]and OH 441 Procedure Visit 216-778-78oo 15100003 Laura L Hoivar (MR# 5266472; DOB: 1213011956) 1011512007 1:00 PM in ASC OCC THERAPY with Carol Presutto, OTRIL [2521 Encogftter inform_ation Encounter q I074860610 Visit p ne artment 23860831 ASC OCC THERAPY L. ftavilo.SIB Klsit 9ate 'fime 1a/o8r2oo7 2:00 PM Place of serviee Referrin"rovider MH OUTPATIENT SURGFRY KEITH, MICHAEL W. [2006)^ CEI CENTER Leparttnent. Asc Occ TherapY Provlder -1 Carol Presuflo, OTWL, OT Vital Sians i.MP Postmeno aus al Progress Not es Carol Presutto, OTR/L Mon Oct 22, 2007 1:40 PM Addended VISIT NUMBER: 2 of 16 Diagnosis: Sprain right thumb and wdst with ligament injury during a lift of a patient at work 10115/2004. Surgery: 7/19/07 Right wrist arthrodesis 10/26/2006 Arthrodesis (four corner intercarpal fusion with scaphoid autograft) right wrist, carpectomy scaphoid (lunate fossa and lunate cartilage intact), EPL released, PIN resected for pain control, repair dorsal ligaments from scaphoid to lunate to capitate Referring Provider. Michael W. Keith, MD Payor: WORKER'S COMP - SELF INSURED Plan: SELF INSURED EMPLOYERS Product Type: Worker"s Comp SUBJECTIVE: "My hand is feeling sore from using it more." Pain scale: 4 or 5/ 10 in dorsal palm and is described as aching. Pain addressed with therapeutic exercise OBJECTIVE, Patient participated in 30 minutes of therapeutic exercises consisting of: - Desen.sitizatiori=.partictes (unco.oked rice) - Stretching/mobilization - right digits and forearm - Strengthening - active use of vadous sized nuts and bolts removal and placement, simulating key turning with yellow (light) Rosedale web. Elbow curls and shoulder flexion to 90 with 1 lb. weight, 10 reps. - Tendon glides - Patient education - precautions, emphasis on not overdoing, pain management with i ieat and cold - Scar management ASSESSMENT: Patient progressing well. Needs to continue to increase strength of right hand and wrist. Home program upgraded. PLAN: Continue plan of care. Emphasis to be placed on ROM, strengthening, desensitization. Carol Presutto, OTRJL EXHIBIT G i aaa nrr H 3WOH 300I88Wtlo vt:ot iooz-Rage 35 "1'hc MclroHealth System I 25C SctroHCal[h Drive I Clevclarld OH 44' i 216-776-7800 15100003 Previous Version SmartForms S!narLFqII115_E11Cd For tha 'Vl15/D4 RT W RIST_Episede OD C.9 -- Curre nt Opf[,catko.ns ag of 101 j2Qt17 Medication )Start IStop Instructlons PERCOCET 5-325 MG OR TABS Oral) 107/19/200711011712DO711-2 tab q4h prn for pain IMedicatfon Comments filed 10l23/2006) ^Pt. Repons she does noi currently teke medications. AIs ^ ReKlle'^^ 60 l0 I M®dtcasj20_$er.m>sIllatton This_E,ftunter fnoneJ A11er°fegas of 10/1SI2007• No (( town Allerdies E)ate Reviewed 10/05/2007 Level Of ev I f Cmice Service CONSULTATION FEE 1977991 Encoun$g^plagnoses Comment 10/15/04 RT WRIST Dia nosls (BWC RT-WRIST SPRAIN NOS [842.00] Po) Qr0]21em List as of 10115f^f g,7 Problem Prio ' -(BWC) RT-WRIST SPRAIN N05 [842.00] 10/15104 RT WRIST -(BWC) RT-HANA SPRAIN NOS [B42.10] 10118/04 RT WRIST -(BWC) RT ARTHROPATHY NOS, FOREARM [716.93] 10I15104 RT WRIST. CIJi 048884555I/KHNJH Class Noted BWC 0311812005 BWC 03/18/2005 BWC 10/15/2004 Resolved 0eieted Pit,iaht^ I n 8tr0 Gt^o n s Adiniqistr.atiue infoicination Administrative Information Advance plrcctivae Encounte Clas None 6on(s) ReferrtnnPt4Kider Yfs4tlp.Qical or KEITH, MICHAEL W.R006J None Advance Dlrective5 Powerof Anornev On File? Yas On Fite? Yes Dale Asked: 5/4107 Date Asked: 514107 Q[Stq l^ Other Orders Date ^THERAPEUTC EXERGISES [97110D3] (qty=2) 10115/2007 Encounter Status Order Report Order #35316359 Elecnonically signed by PRESUTTO. CAROL on 10/15/07 at 1:38 PM Hyperlinks EXHIBIT G Rn + ttei a59 B aWOH 390laawvD st:ot I ODZ-Go age 36 The Metrollnilth System 1215( 4etrOliealth hrive j Clcveland OEI 44: 216-775-7500 15 100003 RepQrt: Usef, Acc,ess Report Re ort: Bar Codes Repod: Plaui text encountor sunmal'y Reoort Ah_^r ^isit sum_mary re^iew Re ort: Encountertlowshee^data EXHIBIT G ...I ....., .. r._- -- . I - - .., Gn',7 i lET 899OGE ^^!^ H BWOH 3oOIN9WtlJ DloOl 1,00Z-P„@6 37 T(ie MctroI-IGalth System 1 25r 'fietraFlealin Drive j Cleveland OIt 44 23 G-773-7800 JS 7 00003 Procedure Visit Laura L};orvat ( MR# 5266472; DO6: 1213611956) 1 0122J2007 1:00 PM in ASC OCC THFRAPY with Carol Presutto, OTRIL [2521 E4counter. In9rm pn Encounfer^ V^sit# 074860610 23860833 Do artrnent _ place pf serv]cs : 'Referring provider ASC OCC THERAPY MH OUTPATIENT SURGERYJKETH, MICHAEL W. 120061 CENTER Prg.yjp^^ Ylsit Dafo ionsr20o7 Tima 1:00 PM Department TPrwider -Asc Occ Therapy iCarol Presutlo, OTWL, OT Vitat_$Igns. lMP Poslmeno ausal Progress Notes Carol Presutto, OTR/L Mon Oct 22, 2007 1:38 PM Signed VISIT NUMBER: 3 of 16 Diagnosis: Sprain right thumb and wrist with ligament injury during a lifl of a patient at work 10/15/2004. Surgery: 7/19107 Right wrist arthrodesis 10/2612006 Arthrodesis (four comer iniercarpal fusion with scaphoid autograft) dght wrist, carpectomy scaphoid (lunate fossa and lunate cartilage intact), EPL released, PIN resected for pain control, repair dorsal ligarnents from scaphoid to lunate to capitate Referring Provider: Micltael W. Keith, MD Payor: WORKER'S COMP- SELF INSURED Plan: SELF INSURED EMPLOYERS Product Type: Worker's Comp SUBJECTIVE: "My hand hurt after therapy (ast week." Pain scale: 6 / 10 in dorsal palm and is described as aching. Pain addressed with therapeutic exercise OBJECTIVE: Patient participated in 30 minutes of therapeutic exercises consisting of: - Desensitization - particles ( uncooked rice) - Stretching/mobilization - right digits and forearm - Strengthening - Elbow curls and shoulder Flexion to 90 with 1 lb. weight, 10 reps. with foreann in neutral. Rolling with light theraputty. Pinch into putty for small pegs - Finger flexion and extension isometrics - Patient education - precautions, emphasis on not overdoing, pain management using cold - Scar management ASSESSMENT: Patient progressing well. Doesn't tolerated any resistance to wrist in forearm supination or pronation. Has to be positioned in midposition. Possibly simulating key turning causing increased symptoms last week. PLAN: Continue pian of care. Emphasis to be placed on ROM, strengthening, desensitization. EXHIBIT G 01 -d liEt 899 DL'E^•••^_•1 . ._._-.__ __ H flWuH 3`1r1IHflW1+C Vl=OT LDOZ-PaM1H 38 Tl;e ,1Retrollealth System 125C /eh o)Ieaiih Drive ! Cleveland OH 44 i 216-778-7800 j S 100003 Carol Presutto, OTR'L SmartForms SmB[7Form5Fle.d For thv."10715l04 RT I+yRrcT^ EpisoJn C,8 C9 Current Me ic?itlQps_as., of10 22/20 j(NONE) Medfca5on Start lstop lnstrucfions Medication Comments (Hled ]0I2372005) ___ _ Ft. Re orts she does not currenU take medications. ^__- Olsp [ReflIls mQ9icat1vuJ3econsili^tfon.T>,i=. Fn^ot!rd^^,(nenel MIergies as o00722I2067: No Known_Alferaies Date Reviewed 10ros72007 Level Of 1..evet af Servicg Service CONSULTATION FEE [97799[ Enenunter Diagny§;g.g ^ Dla nosis -- 11 (BWC) RT-WRIST SPRAIN NOS [842.00) qAn) I _ Comrrtent 10115704 RT WRIST Pro4lem List as of 7Qf221Z007 Ptiorl Pro6lem •(BWC) RT-WRIST SPRAIN NOS [842.00] Clase BWC Noted Resolved Oaletsd 0311812005 BWC 0371B12005 BWC 10N 5/2004 10115704 RT WRIST •(BWC) RT-HAND SPRAIN NOS [842,101 70115/04 RT WRIST ^16.93] ROCL# 04-884551 KH/WH 1 0181 04 RT WR ST P4ttient [ngtiuctiiins Administxative Ittformation Administrative F„p^o untar Classlf4aioMsl R gferdng Proyider Vlalt Indtcator Information Nonr KEITH, MICHAEL w r2ppF) None Pow r y Advance Advanca Olrectivrs Oirective5 On File7 Yes On Eile7 Yes Date Asked: 5l4I07 Dats Asked: 514707 Orders Other Orders 7HERAPEUTI C EXERCISES [971100J (qry=2) Date 10/2212007 Order Report Order#35442352 EXHIBIT G [1 d r 11£i 899^OEE^('•^^`T , -^__^_- -H 3WOH 3rJQI89Wtl0 5t=0i LOOZ-Ptig-6 39 The P✓IetroHealth Systenl 1 250 tctroHe•aftlt brivc I Cleveland OH V T ^ 216 -773-7800 15100003 Encountor c-lectronically s qne•d by PRE SU 7C, .,n RD L on }0/2207 nl . ao E ^d i Hyperlinks Report: User Access Re ort Repod: 8ar Cqdes -_-` Re ort; Plain texi encounier suinmgv_ Re nrtt After visit summa review _`_ I "-_J1 Re ort;Encounter tlowsheet data EXHIBIT G ,.^„ .. ^,«....,...-----... .. .__. zt ^ :ec © ee oec n swoh aoataawv:^ si:ot ouz-^a^^ 40 T be h4etroHealth System I ::5 Metroflealth Dtive I Clevcl.uid O3i 44 ) 1216-775-7800 15100003 Laura L Horvat (MR# 52664(2; DOB: 12/3011956) 10/0512007 10:15 AM {n ASC PHYSICIAN OFFICES with Dr. Michaol W. Keith 1002006] Office Visit Fa<rounter_ Informatip 0 Encounter# tsit # De rtment Place offservice 074801150 23466749 i Refortinq provSder ASC PHYSICIAN OFFICES MH OUTPATIENT SURGERY CENTER Previous V1^JY Trme Date D8124l2007 atfinent 10:OD AM .Asc Physmian Offices Proyider ' I Dr. Michael W Keith, MD R€o.OttFoC-ktstt Comment Reason Lirnlted or partial axam (323) Vital ' s ern LMP 98.1 Postmenopausal ,(Tympanic axtetfded Vitals Pain Date Tlme 0110 10/05l2007 0912 AM ProBrass Notes Dr. Michaol W. Keith Fri Oct 5, 2007 4:58 PM Signed CHRISTINE M ANIELSKI Wed Oct 17,2007 4:11 PM Addended See letter to Linda Hunt vocational case manager Lettevs KEITH MIGHBEL W,,(M0) on t01i7l2097 Sent SmartForms SmaISE4Sm.s_File4Durtn thisV"s"t VITAL.SIGNS INTERDISCIPLINARY PATIENTIFAMJ.LY EDUCATION SmartForms Filed Fq( the " t0/15lOa RT WRISILF gnde C9 C9 SmartForm T xt r rmrt of SmartForms filed durina vsil Reports Curr @dicoitions as of 1010512p07 Inatruc Medioation St9rt 6tn tions Dis PERCOCET 5325 MG OR TABS (Orap on1912007 10l17l20071-2 tab q4h pm for pain Medlcation Comments (Fled 10I23/2006) Pt. Reports she does not cunently take medications. Refills 60 0 Mgs1rc 1pn RecopFlttatiqn Thig Encounte^(non A]1@[gt.frs as of 1014$LZQQZ: No. Knywn Allerales Date Reviewed EXHIBIT G f,f'i 11EI 89° DEC^!!^-` N BWOH 39n1H8WV0 51:0i LOOZ-ppaG!)kI 41 ^Ilte MetroIleaIt11 Systeni f^.5( netro)-?ealth Drive I C[eveiand OH 14' i 2) 6-77S-7S00 1 S) 00003 (10/0512007 Levet Of LCyef pl Servicg Servtce LEVEL 3 EXPANDED, ESTABL!SHED 199213) Encognte_r Dia°npsss comment _ 70115/04 RT WRIST Dia nosts _ 1 (BWC) R7-WRIST SPRAIN NOS t842.001 (PO) Problem L't5t as of 10/OS/2QQZ Prlorl Probtem •(BWC) RT-WRIST SPRAIN NOS (842.00) 10115/04 RT WRIST Class BW Noted •(BWCj RT-HANO SPRAIN NOS [842.10) BW#U31 '1 10155/D4 RT WRIST •(BWC) RT ARTHROPATHY NOS, FOREARM (716.93) 10/15/04 RT WRIST. CL# 04-888455SI/KH/WH BW ResoWed De)ated Patle{Yt InSt1•uGt19f1S Administrative, information AcfvanCe Advance Dlrecty^s Dinactives On File? Yes Date Asked: 514/07 pSDNer of-AttorneV On Fi7e? Ye6 Date Asked: 514107 Orders (NON<EOUNDf Enc o untar Electronically signed by KEITH, MICHPEL W. (MD) on 10l5107 at 4:58 PM Staf 'Re ortUserAccess_Re ort_ RetH1tt Bar Cop^es Re rt Plain texl encoun^t summnn>n t3g ort: ASer vlstt summa. preview Report Encourt[erflowshet deta EXHIBIT G vi a'- iiel e^3 oee' H 3WDH aeulaewvD at:ot t0ozFikfix 42 330 SE0 1311 P.03 P1A'f--22-2008 12:1'7 CAMBRIDGE HOME H Jawarski P&ysical Therapy, Inc ® 137 Winckles SGeet Elyria, Ohio 44035 Ph: 440-366-5993 Fax: 440-366-5313 Excellence in Outpatient Rehabilitatioti JPTREHAB. COM ❑ 6150 Enerald Street North Ridgeville, Ohio 44039 Ph: 440-327-1602 Fax: 440-327-1656 Patient: LauraFtorvat Medical Record Number 201731 Date: 05/07/08 Physician: pr. Ivfichael Kei.th Diagnosis: Right wtist sprainlstrain Surgery. Right wrist arthrodesis Date of Sunaery: 10J26106, 07119/07 Purpose of Assessment: To detennine subject's cUment physical capabilities ------Surnmary-oFResntfsThiSS'tyaartiid-riglri tl8tfd2Si an em e presen e o e dimc on time, was appropnately dressed and was cooperative. Range of Motion & Strength: Subject presents with no focal ROM of the lower extremfies. She is moderately limited in bilateral corvical and trunk lateral tlexion. She has moderate limitation in left shoulder movements. She has signif-icant limitations in right shoulder, wrist and hand movements. Right shoulder Flwdon is 95 dgs., ER 50 dgs., and IR 30 dgs. Due to the arthrodesis, there is no movement for wrist f3ebon/extension, lateral and ulnar devialion. She is able to oppose her right thumb and index finger and unable to oppose any other finger. The right fifth finger PIP remains in 90 dgs. of flexion at all times and cannot passively be straightened. She has enough finger movement to grasp a wide pen. There are no foral strength deficits of the lower extremitiPs. The right shoulder movements could not be tested with the Micmfet dynamometer due to placement of the device on the foreann. Her left shoulder strength showed no focal deficits. She was unable to record a n:suft with the right hand on the grip dynamometer as she was unable to grip. Her left hand strength is 39-49% of nonnative data. Fine Motor Skills: Subject was unable to grasp 2 different types of pegs with her right hand, therefore testing was not done on the tighL She completed the tests with the left hand and was signiftcunUy below normative standards. Cardi❑vascuiar Status: Subjeci completed I mile on the stationary bike for8 minutes, requested to slop due to general fatlgue. She exhibited no shortness of breath. Her head rate recovered to pretest level wlthin S minutes. Consistency of Effort Eight tests for her left hand were administered to determine her consistency of effort. She was observed trying to grip the hand held dynamometer. She needed her left hand to assist and she did not register a reading with the rigM hand. Testing on the right hand was not done. If the co-etflclent of variance is 15% or less, elfort is considered to be consistent and valid. Of the eight tests, 2 had a co-efficient of vadance over 15% (range: 28.93'/=30.48%). Six had a co-ef8cient of vadance below 15% (range 2 84°.6-13.47%). Twenty five peivent of the left handed grip testing was inconsistent. Litt/Carry Abilities worklhomelleBgubF Floor Lift Strength (0-15") Knee Lift Strength (16-291 Worker Sa4e Load 0 lbs. 0 lbs- Job Match Demand 25 lbs. 25 lbs. Waist tJft Strenglh (30-36°) Physical Aptitudes woridttomelfeisure Agdityldynamic balance Finger Dexteri[y Worker Aptitude Low Never Job Match Demand Low Low Never Low Worker Tolerance Frequent Job Match Demand Frequent Sit Constant Frequent Altemate Sit or stand Frequent Frequent Reach above shoulder leval Never Occasional TwistAurn head Bend over/ stoop Climb- legs only (steps) Climb arrnsAegs Qadders) Kneel/squat down Frequent Occasional Occasional Never Occasional Frequent Frequent Occasional Never Occasional 0 Ibs. 100 lbs. Manual Dexterity Chest Lift Strength (37-48') Shnulder Lift Strength (49-60') Overhead Lift Strengih Carry Strength 50' or less Horizontal Push/Pull Strength 0 lbs. 0 lbs. 0 Ibs. 0 lbs. 35 lbs. 251bs. 25 Ibs. 15 Ibs. 25 Ibs. 175 lbs- Kay; Never-o%'va.y Low= 1-39% • Low= 40-79% Mecgum=80 rfg%"Hien=120%olindustnarstanda.d Frequent Lift(>12 reps/hour) 0 lbs. 15 lbs. constant Lift (>30 reps/hour) 0 lbs. 5 lbs. Posture Tolerances work/horne/teisure Stand/Walk Key.'Newr- 0% -OCCSSfonaf= 1-33%' PRoquenr=34=86%' C.onstarA= 87•100%'Exha hme=>8 hours perday Job Match: Subject met the job requirements in standfwalk, sit, aRemate sit or stand, twist/tum head, climbing steps, climbing ladders and kneeUsquat down. She is unable to perform two handed lifts. She cannot perfomi any finger or manual dexterify activities with the right hand and is well below normative standards on her left hartd. She is unable to perform repebtive activity with the right hand and has diffiailty with the left. YTorvat, Lam FCE 5-7-08-2 Page 1 of 7 EXHIBIT G ExhibirFPage 43 33U 6bH 1;t11 t'.U4 MAY-22-200n t2:17 CAMBRIDGE HOME !i Recommendations: The subject will not be able to return to her job as a home health aide mainly due to lier inability to tiit/perform transfers, difficulty io reaching, i_e. bathing and dressing the patient and very poor manual dexferity. Any employment opportunity would require edensive use of her left hand/upper extremity with minlmal assistance of her right. She does not have the finger dexterity to type orwritewith the right hand. She has a moderately positive unpingement sign of the lett shoulderwhich could also limitthe use of her left UE. As she has had extensiva rehabilitation, it is questionable if she would benefit from further rehab. These limitaGons would be permanent. 0 Barbara Hombeek, PT #2404 05107108 wEstu^,.This^1 ` _aexCAd-.d9hf«andsio«ina',-:2 aleTc shaaln^aide•farGamGidgaH ,,, , eatfh aerr^ywas _._...._ assisting a multiple sclerosis patient by lifting and transferting him to a commode on 10f15104 when she feft pain in the right thumb/wrisi area. She called her office and related the inddent to them. She continued to work and went to her next client. As symptoms wonsened, sha called the otTice and stopped for the day. She was referred to an Occupational Medicine Specialist, diagnosed as a sprain right thumbfvmst and was refened to Occupaiional Therapy. Subject stated she received no X-rays. She received 32 sessions of O.T. She was then referred to "a specialist at Crystal Clinic" and O.T. was stopped. She received further evaluations from differsnt physicians, She was casted on and off for several monttts. She conGnued to work for 6 months in the office with no patient care. She sought a medical opinion from Dr. Michael Keith. She received X-rays and a bone scan which, according to the subject, showed a"chipped bone compressing a netve and artery." On October 26, 2006, she had an arthrodesis of the right wrist, carpectomy of the scaphoid, EPL release, PIN resection for pain co0trot, and repair dorsal ligements. As the pain conttnued, she had a secontl wrist arthrodesis on 07119/07. She has not had any further treatment. She currently uses ice and X-tra strength Tylenol for pain conboL Her current pain lavei is 5-8/10 of the right wrist/hand. Other pertinent medical history inGudes arthritis and occasional hypertension. Job Descriptinn: The subtect is a home heaHh aide for Cambridge Home Health Agency. She is required to drive to her Gients' homes, assist in bathing, dressing. ADLs, transferring clieMs, toileting, making beds and assisting with household activities. LiftlCarry ABili6es work/homelieisure Floor Lift Shength (0-1 5') Knee Lift Strength (16-29") Waist Lift Strength (30-36^ Chest Lift Strength (37-48") Shoulder I..i¢ Strength (4&-60") Overhead Lift Strength Carry Strength 50' or less Horizontal Push/Pull Strength Frequent Lift(^12 reps/hour) Constant Lift (>30 reps/hour) Job Match Demand 25 lbs. 25 lbs. 100 Ibs. 25 lbs. 25 !bs. 15 lbs. 25 lbs. 175 lbs. 15 Ibs_ 5 Ibs_ Job Matsh: El Sedentary ❑ Ught ® Medium ❑ Heavy [] Very Heavy Physical Aptitudes work/homelleisure Agility/dynamic balance Finger Dederity Manual Dextertty Job Match Demand Low Low Low Key: Never-0%'Very Lon^1-39%' Lar 40-79% MednNm= 84179%•High=720% oflndusbial standard Posture Tolerances Job Match work/home/leisure Stand(Walk Sit ARemate sit or stand Demand Frequent Frequent Frequent Reach above shoulder level Occasional Twist/tum head Bend over/ stoop Climb- legs only (steps) Climb annsAegs (ladders) KneeVsquat down Frequent Frequent Occasional Never Occasional Key: Never= 0%'OCtasronal= 1-33%'Tiequent-34=68%' Constanh 87-700%' 6rLa 6me=>8 hours pef day Horvat, faura FCJ= 5-7-08-2 Page 2 of 7 EXHIBIT G Page 44 330 668 1311 P.05 PSAY-213-200n i2:18 CAM[,'RI ➢GE I1OML' H Range ot Motion Limitations: WNL min Mod Cervical Flexion ❑ ❑ U Cervical Extension ❑ ❑ M Cervicat Left Sidebending ❑ ❑ N Cervical R(ght Sidebending Cervical Left Rotatian Cervical Right Rotation ❑ ❑ ® Lurnbar Flexion ❑ ❑ 0 Lumbar Extension ❑ ® [.7 o ^ n Severe Lumbar Left Sidebending ❑ Lumbar f2ight Sidebenriing ❑ Lumbar Left Rotatfon ❑ Lumbar Rlght Rotation ❑ Upper Ectremily (left) ❑ [,J Upper Extremity (right) Lower Extremity ( right) ❑ ❑ Lower F^dremity (left) WNL Min Mod Severe n ❑ m ❑ rA ❑ ❑ ❑ ❑ ® ❑ ❑ m ❑ ❑ ❑ ^ ^ 0 ❑ a ® o a Comments: Subject has 80-85 dgs. of MP flexion, 95-10D dgs. PIP flexion right hand. Right fifth finger PIP does not extend past 90 dgs_ ., RighL _^ Left ( Active Range of Motion -o ouroerTlexron 125' 95* Shoulder ER ShoWqerIR Wrist tfexion Wrist extensine 9090° 25' 50' 50" 30° 0° _ D" Deficits' Strenntil: WNL Upperextremit e X ft Uppor extrem'_ ri hq Lower extrem' left) X Lower extremi (righ X WFL Defidts Knee Extension Knee Flexton Hip Ftexion Shoulder Intemal Rotation Shoulder Fxtemal Rotation Shoulder Flexion Cardiovascular Assessment: Resting Hean Rate ^ Resting Blood Pressure Hean rate immediately after completion of staiionary bike test Heart Rate after 3 minute rest 88 Gpm _^ 1571111 mm/Hq 12tt bpm ^ 90 b m Heart Rate after 5 minute r e s t 84 b Left 37 Ibs. 37 Ibs. 23 lbs. 15 Ibs. 15 1bs, 11 Ilxs. Right 41 Ibs. 35 Ibs. 26 lbs. unable unable unable Comments_ Completed one mile, 8 minutes requesting to stoRdue to fatigue. Neurological Findings: Subject exhibits hypersensitivity to touch along the dorsal and ventral aspect otthe right lower foreamt and wrist, unable to tolerate light touch or pressure given by the therapist. Soft Tissue Assessment: Subject's right lower foreamVwrist is redder, slightly more swollen in the fingers and has a shiny glean when compared to the left She is able to tolerate palpation of ibe right shoulder and upper arm, but pulls away with palpation of the wrist extensor and flexor groups. Stie has a surgical scar, approximately 6 inches long along the ventral surface of the foreann that is healed_ Musculoskeletal Screen: Subject stantls wlth the right shoulder and scapufa elevated. The humeral heads are elevated and anterior. She exhibits a moderately posifive impingement sign on the left and rigttt shoulders. She has a forward head and shoulder poslure with an increased thoracic kyphosis noted. She exhibits a decreased lumbar loniosis. Her pelvis is tevet. Gait Pattern: Subjeot ambukates without focal deficits. She uses no devlr,es. Other. Subject was able to sit for 45 minutes during the interview and initial testing without distress. She was able to standlambulate 25 minutes durtng non-material handling before requesting to sit due to faUgue. She was observed writing her name and the date with a wKte width pen using her right hand. Her signature had very poor legibility. Hornt, Laure FCE 5-7-08-2 Page 3 of 7 EXHIBIT G Page 45 3t 1 P. 06 330 660 1 C?.i'IBRf DGE i{ONE It 19AY-22-2000 12.16 Test 5.5 Unable 6 Unable 5, Left Pinch Lateral Riglit Pjnch Laterul Left 3 Jaw Pinch Right 3 Jaw Pinch I_ett lip Pinch Right Tip Pinch Grip Strength Left Hand 43 Grip Sttength Right Hand #3 Grip Strength Left Hand tf4 Grip Strength Right Hand #4 Grip Strength Left Hand #2 ^7 ,^I1hl^nzf ^ Grip Strength Left I{and #5 Grip Strength Right Hand #5 Grip Strength Left Hand #1 Grip Strength Riqht Hand #1 Unable 21 Unable 20 Unable 17 7 Unable 6 Unable 5.5 Unable 22 Unable 21 Unable 20 6.5 Unable 7 Unable 05 Unable 20 Unable 20 Unable 30 na te Un^ t^ ble 18 Unable 1B Unable 18 Unahle 11 (J nable 14 Unable 20 Unable Co-efficient of Vatiance 12.1% 8.33 ^;tandarrl Deviation 76 6.33 .58 9.12% 5.67 76 13.47% Average l :(pounds offorce) 1 -= ^ 4.76% 21 20 33 .58 2.84% 22.33 asked to stand due to pa i n _ ^ 15.33 6.S 30.48% 1.15 7.53% 16.33 4.72 28.93% ---^--------- --% Co-el&leni ofVenance bntwexn 0-15% /s consfdared ConSistenr in edorr. 1. Grip shength was tested in the following position order 3-4-2-5-1 2. Six tests were completed with a co-etficient of varianea of 15% or less. Therefore siK tests are assumed to demonstrate consistent effon by the olient 3 The pain level of the right foreamnMnist and hand at the initia8on of the FOE was reported at 5-6I10 and upon the completion ot pinch and grip tesGng this was reported as 9/10, Five position testing for grip strength showed a normal bell-shaped curve on the left. 1 2 3 4 5 Right Gdp Strength Unable Unable Unable Unable Unable LeftGripStrength . 16.33 lbs 22.331bs 21 lbs 20.33lbs 15.33 lbs Grip strength compared to nonnative data for 51 year old, right dominant, female- Grip strength position!#2 Lateral Pinch 3 Jaw dluck Tip Pinch Right Unable lbs Unable Ibs Unable lbs Unable lbs Normal (tight) 65.7lbs 16.5lbs 17.1 lbs 12.5 lbs Left 22.33 lbs 6,33 lbs 6.33lbs 5.67 lbs Normal (left) 57.2 lbs 16 lbs 16.21bs 11.4 lbs Horvat, ianra FCE 5-7-08-2 Page 4 of 7 EXHIBIT G Page 46 330 668 1311 ?.07 11AY-22-2000 12: L3 CAI;63IJGE HOME H Material Handling- Lifting Chest Lift Strength- Both Arms: ® Standard (48') [] other Safe Limit: Ibs Time: sec HR min End point: ❑ Subjed Umited ^ Coordinatfon ❑ Job Limit [] More Symptoms ❑ Other Reason ❑ Target HR Comments: Unable to grip the box with the dght hand. Could not complete the test. Chest lift Frequent- Both AmiS: 0 Standard (as-) El Other Safe LImR: lbs Time: sec HR rnin End point: ❑ Subject Limfled N Coontination ❑ Job Limit __ _ I^More --- ^ Target HR ❑ Other Reason Coniments: Could not complete single lift Carrying Strength- Both Arms: n Standard (50") (] Other Safe Limit: Ebs Time: sec HR min ❑ Coordina5on End point: ❑ Subject Limited ❑ Job Limit ❑ More Symptoms [] Target HR [] Other Reasori Comments: Unable to gripthe box with the right hand. Could not complete the test. Overhead Lift Strength- Both Arms ® Standard [] Other Safe Limit: ibs Time: sec HR rnin End point: 0 Subject Limited N Coordination ❑ Job Limit ❑ More Symptoms ❑ Target HR Q Other Reason Comments: Subject attempted, txrt had 95 dgs. of ftexion without lifiing box. Unable to pertorm test, Pallet Litt Strength- Both Arrns: 9 Standard (o )[] o8,er Safe Limft: It.s Time: sec HR niin End point: L1 Subject Limited ® CoordinaGon F] Job Limit ❑ More Symptoms ❑ Other Reason 0 Target HR Comments: Unable to grip the box with the tight hand. Could not complete test. Pallet Lift Frequent- Both Arms: 0 Standard (6') ❑ Other Safe Limit: lbs T9me: sec HR min End point: ❑ Subject Limited ® Coordination _.^-Joti-Limit-----8•'+6er^^mptems--❑ Other Reason 0 Target HR Comments, Could not complete single litt Unilateral Carry Strength: ® Standard (50'") i_j Other Right Arm Carry Left Arm Carry Safe Limit: 7 ib. Safe Limit: lb. Carry Time: sec. Carry Time: sec. bpm Heart Rate: bprn Heart Rate: Endpoint: Endpoint: ❑ Subject Limded ❑ Subject Limited ❑ More Synrptoms ® Mon: Symptoms ❑ Coordination Coordination ❑ Job Limit ❑ Job Limit ❑ Target Heart Rate ❑ Target Heart Rate ❑ Other Reason ❑ Other fteason Comments: Subject did not pertorm right arm cany per iherapist due to high pain level. Able to carry 7 lb, empty boxwith left hand but noted moderately increased left shoulder pain. Non Material Handiing: Activdy Trial 1 (reps/sessions) Climbing Trunk t3ending (1 miriute episode) Overhead Reach (1 minute episode) Crawling 10 feet squatting Repetrtive (Five ttmes) Kneeling (1 minute) Stooping repetitive (five times) Crouching (sustained squat for I minute) Ladder Climb (3- rungs, 3 times) Trunk Twisting (5 times) Fonvard Reaching (1 minute) Push/Pull (repetftive, weight 35 Ibs) RadiaUUlnar Deviation (repetitive I minute) Supinate/Pronate (repetitive 1 min.) Wrist flexiordextension (repetitive I rnin) Able to ascendldescend steps reciprocally 16x Trial 2 (reps/sess:oas Unable righf, left 5x/20 secs. stnpped left shoulder pain Unable due to right wdst fusion 5x X - needed to hold onto chair to get in and out of position 2x with ann, 3x using legs only 14 sees. holding on, stopped at 20 secs. due to UE fahgue (answer subject gave when asked) Not tested duc to safety reasons pertherapist x 5x/21.62 secs. stopped right UE. left shoulder pain X-pushed with body/left hand (no right hand), pulls with left hand anly 19 secs./12x IeR only, stopped left shoulder pain 20 secsJ4x left than right, stopped due to dght and left shoulder pain 16.41 secs./5 reps. left only, stopped due to left shoulder pain Horvat, t.awa FCE 5-7-08-2 page 5 of 7 EXHIBIT G Page 47 M.4Y-Za-2008 330 6Ge 1311 P.08 12:15 CAMSRIDGE HC)ME It Comments: Last 3 acGvities of tl1 nz-material handfing sections were instruc . tu be done standing. Subject requested that she be seated forthat part due to generalized faGgue and increasing pain of the right UE. Subject 5tarted non matenal handling ;edion at 8/10 pain of the left shoutder, iight wrist; 511 D right stioutder. Upon completion of this section, She noted rigtd hand/wrist pain 10110 with throbbing/aching and swelling; rigttt shoulder 9110 with right UE fatigued and "heavy", left shoulder a-g/io with left UE'Yimd". Coordinationldexterity testinq Nine tiole pegboard test: The score for each hand is the 6rne nequired to place and remove 9 pegs in a 5 inch square board. Right Unable to pick up pegs sec Left 35 sec Norm for age/sex Norrn for agc/sex 13-23 sec 14-26 sec Grooved Pegboard Tests __ Ptac^ng e 6T.3' - Right Retum Test f19 4)- Rioht Drop errots ( 1.4 s): -# Drop errors (- 1.4 s): -# Retum errors (-1.2s): -# Miss errors (-0.&s): -7k Placing Time ;- s Placing Time :- s Comments Subject observed attempting to pick up pegs. Could not grasp with fingers, Plaang Test (61.31-Leff Retum Test (19.4)- Left Drop errors (-1.4 s): 1# Drop errors (-1.4 s): 1# Return errors t-1.2s): 0 # Miss errors (-0.6s): 1# Placing Time : 153.5 s Placing Time : 29.39 s Comments: Subject noted increased left shoulder pain. Pertormance Validity Rating; 0 Very High- Subject was fully cooperative and pmvides a good, consistent effort. No signtficant probiems or physical limitations were identified before, during or in response to the exam. ❑ Htgtr The subject was fully cooperative and provided a good, consistent effort. Probiems and physical limitations identified during the exam were MOSTLY SUBSTANTIATED by objective findings. Reported severity of symptoms did not increasa significarrity in response to the exam. ® Mediam-The subjectwasfully ceoperative and provided a cansistentetforton mostactivi6es. Problems reporled and demonstrated functional abilities were MOSTLY SUBSTANTIATED by objedive findings. Performanr^ on some activfties was somewhat inconsistent, self-limifed or associated with inerease symptom reporting in response to the exam. ❑ Low^ The subject's performanoe was inconsistent or more limited than expected on activifies that stressed recent problem areas_ Degree of reported ore demonstrated functional limitations was NOT SUBSTANTiATED by objective frndings. Subject was cooperative and provided a good effort on requested activities that dtd not significanUy stress recent problem areas. L] i/ery Low- The subject's perforrnance was very self-limited and ineonsistent. The subject's demonsbsted performance was NOT SU9STANTIATEO by objecOve findings_ The subject was NOT COOPERATIVE and appeared to exaggerate the degree of reported problems and functionat limRaBons throughout the exam_ Validity Concems 1. UnusuaUexcessive symptoms raports 2. Unusuallexcessive pain behaviors ® Yes ❑ Yes 3. Inconsistent movement pattems ❑ Yes No 4. Inconsistent strength tests results 5. Abnormal function uninjured region 6. Poorsafetyjudgmenl exhibited 7. Refusal to attempt speciryc test(s) Yes Yes ❑ Yes ® Yes ❑ No ❑ No 0 No ❑ No 8. Increase symptoms following exam Comments: Reasons for "yes" answers: 0 Yes ❑ No ❑ No ® No 1. Subject reported levels of 8-9110 pain of the left shoulder which had no history of injury or previous condition. 4. Subjed completed 8 grip strerigth tests with the unaffected hand. Two out of 8(25q,) were inconsistent. 5. Suqect reported high pain levels and frequently stopped tasks due to left sThoulder pain and decreased movement Left shoulder/upper extremity was not injured. Subject reports left shoulder pain is from increased use of the left UE, 7. Subject appmpriately refused ladder and crawling tasks due to safety, 8. Subject started evaluation at level 5-6/10 forthe rigM hand and left shoulder. She ended the evaluation al level 10110 ng t wnstlhand t nd 9/10 right and left shoulder. ! ,^^,LuL fitm+lt-r^.(z^t3^fa/ 'S Barbam Hombeek, PT #2404 05/07108 t-Ioryat, Lauia FCE 5-7-08-2 Page 6 of 7 EXHIBIT G TOTAL P.DO Page 48 -t^ _I.^.^i^^ +^ ^ Uccupatia^slMedicine b ulguit Cara 8555 Sweet Valley Drive VaVVey View, OH 44125 1 Phone: 216.328.2240 Fax: 216.642.7900 / www.medsource-one.com June 30, 2008 Timothy A. Marcovy Willacy, LoPresti & Marcovi Re: Claimant: Employer. Claim #: DOI: Allowed Condition(s): File Review Laura Horvat Cambridge Home Health Care 04888455 10/15/04 Right wrist sprain/strain; aggravation pre-existing arthritis right wrist As per your request, f have reviewed all of the documents provided relative to the above-captioned claimant and claim. I am now writing for the purpose of providing my opinion regarding the prevailing issue of extent of disability in this case. For the purpose of my analysis, the following medical records were reviewed: • BWC FROI dated 10/18/04. • Records from On the Clock Care dating from 10/18/04 to 1/13/05. • Consultation report from Dr. Engles dated 1216/04. • Office notes from Dr. Keith dating from 3/18/05 to 12114107. • Correspondence from Dr. Keith dated 10/5/07. • Operative reports dated 10/26/06, 1/25/07 and 7119/07. • Occupational therapy records dating from 10/8/07 to 12/3/07. • Functional capacity evaluation report dated 5/7/08. • IME report from Dr. Randt dated 2/14/05. • Impairment examination report from Dr. Dinsmore dated 10/23/05. • IME report from Dr. Krupkin dated 17J14/05. • IME report from Dr. Magoline. • Report from Dr. Hochman dated 2/14/08. With full consideration given to the information contained within the above described medical records, I submit the following, wi ^h a reasonable degree of medical certainty and probability: 1. What is the current status of Ms. Horvat's disabillty directly and proximately resulting from the allowed conditions in this claim? The records in the file indicate that the claimant is still experiencing a significant loss of function of her dght hand. As such, she does not appear to be capable of performing the full scope of her previous work activities as a home health caregiver. However, she does appear to be capable of performing appropriately restricted work activities that would place her in a light physical demand category. This opinion is based primarily upon the clinical findings documented in her serial occupational therapy records. EXHIBIT G Page 49 2 lias Pdis. Horvat's use of her right hand reached a level of function below that of the legal standard for loss of use, which is defined as being to the same effect and extznt as if the hand have been aniputat:ed; that for all practical iritents and purposes she has no use of the hand? Please state the basis for your opinion. The records that were reviewed indicate that the claimant's current level of function does not meet statutory definition for "loss of use". This opinion is based upon the fact that her occupational thetapy records and for recent functional capacity evaluation document the fact that she has some residual functional capabilities with her right hand that include the ability to move her fingers and to "grasp a wide pen". 3. Is the May 7, 2008 FCE report a valid indicafor of Ms. Horvai s level of abi7i y to use "er right hand? Why or why not? Does the report support the complete "loss of use" of the right hand, in accordance with a standard set out above? Please state the basis for your opinion on this point', also. Unforlunately, the results of the 5I7/08 functional capacity evaluation do not appear to be a valid indicator of the claimanYs current functional capabilities. The report documented a"medium" validity rating and noted that the claimant was self-limited in many of the activities. In addition, she failed to demonstrate any grip strength capability at any of the five settings on the dynamometer despite showing the capability to grasp a pen. As such, the claimant appears to have made less than a full effort during the evaluation. I trust this information will be helpful in providing some additional insight into the claim in question. If you have any further questions, please do not hesitate to contact my office. Respectfully, Scott E. Singer, MD, MPH Board Certified, Occupational Medicine EXHIBIT G Page 50 Ntay 7, 2001 iVtemo E2 State of Ohio Industrial Commission Policy Statements and Guidelines Permanent Partial - Hearing Officer Discretion Hearing Officers shall be limited in their determinations of disabilities under O.R.C. 4123.57 to the percentage of permanent partial impairment based on the medical or Ginical findings specifically expressed in a physician's report. Hearing Officers are to adopt one of the impairment ratings. However, when a Hearing Officer determines that the medical or clinical findings reasonably demonstrable support a percentage of permanent partial disability other than an impairment rating as found by one of the physicians, the Hearing Officer may adopt a percentage of permanent partial disability which is within the range of impairment ratings as given by the physicians even though such percentage of permanent partial disability is not the same as any of the physicians impairment ratings. The Hearing Officer is to note in the order that the determination is based upon the medical or clinical findings of a particular doctor or doctors. Also Hearing Otficers are to note the reports of additional physicians, if appropriate. It is the duty of the Hearing Officer to evaluate the physicians' ratings of impairment and issue the determination as provided by O.R.C. 4123.57. The parties may agree subject to the approval of the Hearing Officer to a compromise rating of permanent partial disability, which is within the range of impairment ratings where medical evaluations are in conflict. NOTE: Industrial Commission Resolution. No. R81-7-30 (June 3, 1981) EXHIBIT G Page 51 LttpJ/66.161.141.1 cgi-bi;dtexis/wdde,,ticlnw/+ynic+73Scoxbnrne-h... 2005-Ghio-6377; Siafe ex rei. Miller v. Indus. Comm; 2005-Obio-6371 [Cite as State ex rel. Miller v. Indus. Comm., 2005-Ohio-63711 State of Ohio ex rel. Gary A. Miller, Relator, V. Ohio Industrial Cornmission and Fluor Constructors Intelnational, Respondents. No. 05AP-214 10th District Court of Appeals of Ohio, Franklin County Decided on December 1, 2005 J. B. Marshall, Jr., for relator. Jim Petro, Attorney General, and Dennis L. Hufstader, for respondent Industrial Commission of Ohio. IN MANDAMUS DECISION TRAVIS, J. {tft1} Jn this original action, relator, G1ry A. Miller, seeks a writ of mandamus compelling respondent, the Industrial Comnvssion of Ohio, to vacate its order denying relator's application for the alleged loss of use of his left hand, R.C. 4123.57(B), and enter a new order that grants relators application. {112} The matter was referred to a magistrate of this court pursuant to Civ.R. 53(C), and Loc.R. 12(M) of the Tenth District Court of Appeals. The magistrate issued a decision that includes findings of fact and conclusions of law and recommended that this court deny the requested writ of mandamus. (Attached as Appendix A.) No objection has been filed to the magistrate's decision. {J3} Pursuant to Civ.R. 53(E)(4), the court conducted a full review of the magistrate's decision. The court finds that there is no error of law or other defect upon the face of the decision. Therefore, the court adopts the magistrate's decision as its own and the requested writ of mandamus is denied. Writ of mandamus denied. EXHIBIT G 1 of 13 6127/Ndb48 52 bnp:!/66.1(i 1.141.1 ib/cgi, bin/Lex i s/web/cvicelaw/ r ycne t-13Scoxbmt:e_h... SADLER and McGRATH, JJ_, concur. {qJ4} In this original action, relator, Gary R. Miller, requests a writ of niandamus ordering respondent Industrial Commission of Ohio ("commission") to vacate its order denying his motion for an R.C. 4123.57(B) scheduled-loss award for an alleged loss of use of his left hand, and to enter an award for a total loss of use of his left hand. Findings of Fact: {151 1. On August 22, 2004, relator sustained an industrial injury while employed as a pipe fitter for respondent Fluor Constructors Intemational, a state-fund employer. The injury occurred when relator was getting up from a lunch table and fell onto his outstretched left hand. The industrial claim is allowed for "fracture left carpal bone, closed; other postoperative infection, left; fracture left distal radius," and is assigned claim number 02-416290_ {$6} 2. On August 28, 2002, relator underwent an "[o]pen reduction intemal fixation bone graft, application of external fixation device left radius." The surgery was perfot7ned by George K. Aitken, M.D. According to Dr. Aitken's operative report, the preoperative and postoperative diagnoses were "[c]omminuted fracture left distal radius." {$7} 3_ On May 20, 2003, physical therapist David Kazee conducted a "Functional Capacity Evaluation" ("FCE"). Mr. Kazee reported: The patient's Physical Demand Classification is light-medium: Light-Medium Occasional 35 lbs. Frequent 15 lbs. Constant 51bs. Stand/walk * * * Restriction use by the patient is basically any significant left upper extremity use. The patient can do no reaching overhead with the left upper extremity, no crawling and no pulling or pushing with the left upper extremity. He is basically restricted from any occupation that requires left upper extremity use. The patient can drive a farnily type vehicle but I doubt he can drive a commercial vehicle requiring a lot of heavy tuming. At this point, the patient has difficulty getting hand in position that he can tum a steering wheel safely. The patient is not to do any overhead reaching or crawling or pulling with the left upper extreniity. *** His left upper extremity is probably at maximum improvement. It should also be noted that the patient's job as a pipe fitter is [in] the heavy EXHIBIT G 2 of 13 6/21/P2fgLk48 58 http://E5. 15 t. 141. i 76/cgi-bin/[exic/w0/caselaw/+ymro-73scoxhmnc" h... classification: Heavy Occasional 100 lbs. Fre;quent 50 lbs. Constant 20 lbs. He cannot meet these demands. * * * ASSESSMENT: From the Musculoskeletal Evaluation the patient is status post fusion of left wrist_ He is now presenting with a permanent loss of extension. His wrist is in a flexed position, which is probably not the best position to have a fusion. He has lost significant range of motion of his left hand and fingers and left upper extremity in general, still has significant weakness throughout the left upper extremity. I feel like these deficits are probably permanent and will not improve over what they currently are. There was no symptom magnification or symptom exaggeration demonstrated by this patient during the Musculoskeletal Evaluation. Comments: The patient's left hand is basically not useable for working activities" He has to compensate with his trunk and shoulder to get into positions to be able to use his hands. We allowed the patient to be tested in comfortable positions, which are not really functional positions_ In short, due to his wrist being in a permanent flexed position and lacking supination and pronation he has to compensate with his shoulder and trunk, which is eventually going to lead to other musculoskeletal problems. His inability to manipulate fine objects rules him out for being good on any type of assembly. The patient had significant increase in hand discomfort, but considering his pathology, this would be considered normal. *** *** The patient's job demand as a pipe fitter is in the heavy category to very heavy category for Physical Demand Classification. He is unable to do this and it is the personal opinion of this evaluator that he will never [be] able to do this again. It is also the opinion of this evaluator that the lightmedium category this patient is currently in is probably his maximum classification achievement. It also must be noted that this patient is limited to minimal to no use with the left upper extremity. Light-medium category is what his body and right upper extreniity are capable of doing [at] this time. EXHIBIT G 3 n! 13 6/2"llt"61:454M )11p_//66.161.741.)761cy hird7cxis/wcb/oascfaw/^,v^n:^473Scoxbnmc_h... {l[S} On July 30, 2003, relator moved for K.C. 4123.57(B) scheduled-loss compensation for an alleged loss of use of his left hand. In support, relator submitted a report, dated June 3, 2003, frotn Dr. Aitken: * * * I-Ie continues to have problems with his wrist. It's uncomfortable most of the time but if he uses it to any significant degree then it will becoane quite painful. His range of motion has not significantly cliwrged. He's not having any significant numbness or tingling and he's had no evidence of recurrent infection. He had his FCE which rates him as able to do light to medium activity. Xrays were obtained today and these show severe arthritic change within the wrist, no evidence of recurrent infection. In spite of his FCE, I don't believe he has any significant realistic chance to rejoin the work force. This is based upon the severity of his injury, his inability to use his left hand for any significant activity, his age and training. I believe he is at MMI. I do believe he will likely come to a wrist fusion in the future. Because this is all related to his original injury and treatment thereof, I do believe this would also [be] considered to be compensable. 5ince he has in essence a wrist fusion with angleosis [sic] of the wrist at 20 degrees of flexion, 10 degrees of radial deviation. Using the AMA Guide to Permanent Impairment, 5th Edition, Figure 16-28, 16-31 and Table 16-3, he has a 35% upper extremity impairment which is equivalent to a 21% whole person impairment. I believe this is solely related to his injury and does not have any element of previous problems or part of a normal aging process. {19} On October 2, 2003, at the request of the Ohio Bureau of Workers' Compensation ("bureau"), Robert Brown, M.D., reviewed the conunission's file and reported: Allowed conditions are accepted as [a] result of [a] fall that fractured [the left] wrist. Had surgical fixation of fracture and developed an infection requiring 6 week[sJ of intravenous antibiotics [and] surgical debridements. 1W [injured worker] had physical therapy ***. [N]oted to have stiffness in wrist [and] fingers. 2/21/03 has a 25# grip; 6/3/03 xrays shows fracture healed with slight dorsal angulation. Dr. Aitken found a 21% IWP [impairment whole person]. *** Based on information in file, IW has a 21% IWP-this is not consistent EXHIBIT G 4 or 13 6/27I2H0}r J.,1d48 lgM1- hup:7/66.161.141.1"76/cgi-hinhexislvwclJcasetaw/+yme+73Seoxbnme_h... with total loss of use of hand. {$10} On October 30, 2003, relator was exa>:nined, at the enlployer's request, by Nelen M. O'Donnell, M.D. Dr. O'Donnell reported: * * * The force of the fall was associated with a closed fracture of the left wrist. The x-ray report on the day after injury described a comminuted intra-articular fracture involving the distal radius with mild impaction and dorsal tilt of the articular surface of the distal radius. Noted at that time was moderate to severe osteoarthritis involving the f^irst trapeziometacarpal joint. The patient underwent ORIF [open reduction intemal fixation] 08/28102, which involved pin insertion, bone grafting and application of EF [external fixation] at King's Daughters' Medical Center. Postoperative filal showed osteoarthritic change in the first digit from the trapezium to the distal phalanx, including significant osteophyte formation at the IP joint of the thumb. The procedure was complicated by wound infection with S. Aureus; readmission for IV [intravenous] antibiotics, wound debridement, removal of bone graft, and insertion of antibiotic beads was required. After discharge, Mr. Miller continued treatment with IV antibiotics administered at home under supervision of ID, by his estimate, 6 weeks. This was followed by oral antibiotic therapy. At 7 weeks post op, EF was removed and PT [physical therapy] intiated. Current complaints include pain in the left wrist and hand increased with use, numbness around the scars, over the thumb and in the fingers, index and ring fingers. In spite of numbness, he has pain dysesthesia to touch and to heat, as with hot water on the hand. Other complaints include decreased grasp, decreased dexterity. The pain is "excruciating" with use, brings him to tears. At rest, there is a dull ache_ Intensity is graded from 2/10 to 10/10 with pulling, for instance. All these signs and symptoms affect function; Mr. Miller reports he is independent in dressing and grooming with loose clothing with his right hand. He helps with light housekeeping using one hand; this includes loading the dishwasher, folding clothes, loading the washer from hampers in the room. He cannot carry loads. The patient is independent in use of the riding lawnmower, but cannot trim with a "weedeater". Medication use is OTC pain medication; although he has [been] prescribed narcotic analgesia, he does not like side effects and only uses for severe exacerbation of pain_ EXHIBIT G 5 of 13 6127^g1q:48_Rf'j1 h tt p:f/66- I6;.14 L 176/cgi-bin/lcxis/wcb/cascl aw/+ymc+73 Scoxbnfne_h... Review of therapy notes suggests this patient gave good effort and was an active p<uticipant in his own therapy program. In spite of extensive treatment and good effort, wrist range never reached goaLs set, but, in fact, decreased over time with fusion into flexion and ulnar deviation. Maximum wrist extension was 12 degrees passively 11/22/02. Dr. Aitken's notes document a flare of pain and inflatrnnation in March 2003. At the time of functional capacity evaluation, May 20, 2003, the left wrist was described as fused into flexion of 20 degrees. The assessment was that Mr. Miller had significant impairment of the left arm involving primarily range of the wrist, but also affecting range of forearm pronation, supination, strength of hand grip, pincti and sensation. It was offered that the impairments documented would be associated with disabilities in 2 handed tasks such as material lifting, material handling, even crawling. Right upper extremity, trunk and lower extremities were normal. Mr. Miller reports his surgeon advised him that a wrist fusion might be considered in the future. The Comprehensive Vocational Assessment suggested Mr. Miller had the intellectual and academic abilities to function in entry-level clerical positions, counter clerk, and sales occupations at the sedentary to light-medium level. It was suggested that earning a GED and improving math skills would help him to participate in technical college level training. *** PIiYSICAL EXAM: * * * On the left, the wrist was fixed in 30 degrees flexion; there was no passive or active range elicited. Attempts at passive range were painful. At rest the left wrist was also in a posture of ulnar deviation 20 degrees; no active range could be demonstrated_ Attempts at passive range were painful and did not move the wrist. On the left MCP [metacarpophalangeal] extension was full; maximum MCP flexion was 40 at the thumb and 80 at digits 2-5. Left thumb IP [interphalangeal] flexion was quite limited at 10 degrees; this could not be increased passively. Left finger PIP [proximal interphalangealj f7exion was 70 degrees active and passive_ DIP [distal interphalangeal] flexion was limited to less than 40 degrees. Because of these flexion limits and abnormal wrist posture, the thumb could not be brought into apposition to the finger pads_ The thumb could be adducted against the index finger to produce a pinch. EXHIBIT G fi of 13 6/27ft8gIQ:485(7i1 hltpl/66.161.141_ l76/cgi-bin/texis/web/eacelaw/ r yine+73Seoxhnme_h... Xrays provided by the patient were rcviewed. There is complete loss of the wrist joint space. {111} Following a January 21, 2004 hearing, a district hearing officer ("DHO") issued an order denying relator's motion for a loss of use award- The DHO's order states: The District Hearing Officer finds the injured worker had not established that he sustained a total loss of use of his left hand, pursuant to O.R.C. 4123.57(B). Accordingly, his request for a total loss of use award is denied. The medical evidence does not establish that the injured worker suffers from contractures and/or ankylosis to such an extent as to render his left hand as useless as if it were amputated. ln fact, the reports of Drs. O'Donnell, 10/30/2003, Aitken, 06/30/2003, Brown, 10/02/2003 and the Functional Capacity Evaluation of 05/20/2003 all indicate the injured worker still has some use of the hand{112} Relator administratively appealed the DHO order of January 21, 2004. 19[13} 9. Following a March 2, 2004 hearing, a staff hearing officer ("SHO") issued an order stating: The order of the District Hearing Officer, from the hearing dated 01 /21/2004, is Affirmed with additional reasoning_ After reviewing all of the evidence on file, it is the order of the Staff Hearing Officer that the injured worker's motion, filed 07/30/2003 is denied. The injured worker has failed to show that he has total loss of use of his hand. Functionally used does not equal total loss of use of the hands [sic]. The injured worker demonstrated that he has movements in his hand. He is able to move his fingers. Staff Hearing Officer also notes [in] Dr. Aitken['s] report where he noted "thumb could be adducted against the index finger to produce a pinch" (08/28/2002). EXHIBIT G 7 of 13 6/2714POgp48 W Illtp:1/66.161.14 I.176/cbi -hin/te xis/web/caaa aw/+ylne+73$eox bn me_h... {114} On March 2`1, 2004, another SHO mailed an order refusing relator's administrative appeal from the SHO's order of March 2, 2004. {9115} 11. On March 3, 2004, relator, Gary R. Miller, filed this mandamus action. Conclusions of Law: {9[16} It is the magistrate's decision that this court deny relator's request for a writ of mandamus, as more fully explained below. {117} R.C_ 4123.57(B) provides for compensation for scheduled losses: If the claimant has suffered the loss of two or more fingers by amputation or ankylosis and the nature of the claimant's employment in the course of which the claimant was working at the time of the injury or occupational disease is such that the handicap or disability resulting from the loss of fingers, or loss of use of fingers, exceeds the normal handicap or disability resulting from the loss of fingers, or loss of use of fingers, the administrator may take that fact into consideration and increase the award of compensation accordingly, but the award made shall not exceed the amount of compensation for loss of a hand_ For the loss of a hand, one hundred seventy-five weeks. {(118} Two cases cited by relator are instructive. Both cases will be extensively discussed here_ {T19} In State ex rel. Alcoa Building Products v. Indus. Comm., 102 Ohio St.3d 341, 342-343, 2004-Ohio-3166, atq10, the court succinctly set forth the historical development of scheduled awards for loss of use under R.C_ 4123.57(B). The Alcoa court states: Scheduled awards pursuant to R.C. 4123.57(B) compensate for the "loss" of a body member and were originally confined to amputations, with the obvious exceptions of hearing and sight. In the 1970's, two cases--State ex rel. Gassmann v. Indus. Comm. (1975), 41 Ohio St.2d 64, * * * and State ex rel. Walker v. Indus. Comm. (1979), 58 Ohio St.2d 402, * * * - construed "loss," as similarly used in R.C. 4123.58, to include loss of use without severance. Gassmann and Walker both involved paraplegics_ In sustaining each of their scheduled loss awards, we reasoned that "[f]or all practical purposes, relator has lost his legs to the same effect and extent as if they had been amputated or otherwise physically removed." Gassmann, 41 Ohio St.2d at 67 * * *; Walker, 58 Ohio St.2d at 403-404[.] * * * {%19} In Alcoa, the claimant sustained a left arm amputation just below the elbow. EXHIBIT G 8 of 13 6/27(PArI,W8 gg hup://66.16 L l R I.176/cgi-hinAexiJweb/c:,.velaw/+yme+73Seoxhmne_h... Continuing hypersensitivity at the amputation site prevented the claimant frorn ever wearing a prosthesis. Consequently, the claimant moved for a scheduled-loss award for loss of use of his left arrn. (1201 Alcoa established through a videotape that the clailnant could use his remaining left arm to push open a car door and to tuck paper under the ann. Nevertheless, the commission granted the claimant an award for the loss of use of his left ann. {121} This court denied Alcoa's complaint for a writ of mandamus and Alcoa appealed as of right to the Supreme Court of Ohio. {gJ22} Affirming this court's judgment and upholding the commission's award, the Alcoa court explained, at J10-15: * * * Alcoa urges the most literal interpretation of this rationale and argues that because claimant's arm possesses some residual utility, the standard has not been met. The court of appeals, on the other hand, focused on the opening four words, "for all practical purposes." Using this interpretation, the court of appeals found that some evidence supported the commission's award and upheld it. For the reasons to follow, we affirm that judgment. Alcoa's interpretation is unworkable because it is impossible to satisfy. Walker and Gassmann are unequivocal in their desire to extend scheduled loss benefits beyond amputation, yet under Alcoas interpretation, neither of those claimants would have prevailed. As the court of appeals observed, the ability to use lifeless legs as a lap upon which to rest a book is a function unavailable to one who has had both legs removed, and under an absolute equivalency standard would preclude an award. And this will always be the case in a nonseverance situation. If nothing else, the presence of an otherwise useless limb still acts as a counterweight--and hence an aid to balance--that an amputee lacks. Alcoa's interpretation would foreclose benefits to the claimant who can raise a mangled arm sufficiently to gesture or point. It would preclude an award to someone with the hand strength to hold a pack of cards or a can of soda, and it would bar--as here--scheduled loss compensation to one with a limb segment of sufficient length to push a car door or tuck a newspaper. Surely, this could not have been the intent of the General Assembly in promulgating R.C. 4123.57(B) or of Gassmann and Walker. Pennsylvania defines "loss of use" much as the court of appeals did in the present case, and the observations of its judiciary assist use here. In that state, a scheduled loss award requires the claimant to demonstrate either EXHIBIT G 9 of 13 6/27/.pCAoLpM1S 4" http:N£5.16 J . 141.17(,Jcgi-biNtcxixlwcblcasclawl+ymo+73 Scoxhnme_h... that the specific bodily member was amputated or that the clairnant suffered the pennanent loss of use of the injured bodily ;.nember for all practical intents and purposes. Discussing that standard, one court has written: "Generally, the'all practical intents and purpose' test requires a more crippling injury than the'industrial use' test in order to bring the case under section 306(c), supra. However, it is not necessary that the injured member of the claimant be of absolutely no use in order for him to have lost the use of it for all practical intents and purposes." Curran v. Walter E. Knipe & Sons, Inc. (1958), 185 Pa.Super. 540, 547, 138 A.2d 251. This approach is preferable to Alcoa's absolute equivalency standard. Having so concluded, we further find that some evidence indeect support.s the commission's decision. Again, Dr_ Perkins stated: "It is my belief that given the claimant's residual hypersensitivity, pain, and tenderness about his left distal forearrn, that he is unable to use his left upper limb at all and he should be awarded for the loss of use of the entire left upper limb given his symptoms. He has been given in the past loss of use of the hand, but really he is unable to use a prosthesis since he has had the amputation, so virtually he is without the use of his left upper limb ***." 19123} In State ex rel. Tirnmerman Truss, Inc. v. indus. Comm., 102 Ohio St.3d 244, 2004-Ohio-2589, the court granted a writ of mandamus in favor of the employer when the commission had granted a loss of use award in reliance upon doctors' reports that did not consider the claimant's actual physical abilities with respect to the body part for which loss of use was being sought. {y(24} In Timmerman, the commission award for loss of use of the right hand was based upon the March 11, 2002 medical file review of Dr. Gibson and Dr_ Bamberger's April 22, 2002 letter. ($25} The Timmerman court found that the reports of both doctors were seriously flawed. Dr. Bamberger's report was held to be flawed because it raised questions as to the author's awareness of "(1) the Walker standard of loss and (2) claimant's postrecovery activities."(fn 1) Tirnmerman, at 125. The Timmerman court explains: * * * Nothing in Dr. Bamberger's report indicates that the claimant's degree of loss is the functional equivalent of an amputation. He instead recites the claimant's history without discussing his current functional residuals and bases his loss-of-use assessment on claimant's employment history and the EXHIBIT G J P of J 3 6/27/p§J646 el h11p:/lE5.161, 141.176/cgi 6inhcxislcieC;"Cusul:rx/syaicr 73swxbnnic_h.. fact that the dorninant hand is involved. Id. {g{26} With respect to Dr. Gibson's file review, the Timmerman court, at 1)(29, states that Dr. Gibson "appears to be more cognizant of the Walker loss standard," `I'he Timtnerman court, at 130, concludes: Under most circumstances, therefore, Dr. Gibson's report alone would support the commission's award. Here, however, [State ex ret. Schultz v. Indus_ Comm., 96 Ohio St.3d 27, 2002-Ohio-3316} demands that the medical assessment be viewed in the context of claimant's postrecovery physical and work activities. * * * {%27} Whether we use the so-called Walker standard of loss, i.e., that "for all practical purposes" the claimant has lost the hand to the same effect and extent as if it had been amputated or otherwise physically removed, or we use the Alcoa standard of loss, i.e., that "for all practical intents and purpose" the claimant has suffered the permanent loss of use of the hand, the result is the same. In either case, this magistrate must conclude that there is no evidence in the record upon which the contmission could have based an award for loss of use of the hand. {128} Analysis here begins with the DHO's finding: "The medical evidence does not establish that the injured worker suffers from contractures and/or ankylosis to such an extent as to render his left hand as useless as if it were amputated." {$29} In Timmerman, the court notes that loss of a hand under R.C. 4123.57(B) can be shown under a "flat loss" theory or a "two fingers plus" theory. T'immerman, at 124. {%30} Apparently, the above finding of the DHO is a rejection of a "two fingers plus" theory that relator perhaps presented to the hearing officer. {131} While it is unclear whether relator argued the "two fingers plus" theory before the commission's hearing officers, relator does not seem to posit the theory here in mandamus. In any event, none of the doctors who issued reports in regard to relator's motion opined that relator had lost the use of any of the digits of the left hand due to ankylosis. For example, while Dr. O'Donnell found "left thumb IP flexion was quite limited at 10 degrees" and that "maximum MCP flexion was 40 at the thumb," she did not opine that the left thumb wa.s considered a loss due to ankylosis. {9132} Dr. Aitken, relator's surgeon, did not evaluate left digit impairment as did Dr. O'Donnell. Dr. Aitken based his 35 percent impairment rating for the left upper EXHIBIT G 11 <rf 13 6/2PA6QI:402M htupl,166 .161-141.175icgi-bin/tcxis!wcblcxudaw7-rytnc+73Scuxbmru: h... extremity entirely upon the "wrist fusion," noting that the left wrist was "fixed in 30 degrees flexion" and that "attempts at passive range of lnotion were painful and did not move the wrist." {$33} In short, there is no evidence in the record to support a so-called "two fingers plus" theory for a loss of hand award. {134} There is also no evidence in the record to support a "flat loss" theory for loss of a left hand. {1#35} While Dr. Aitken, in his June 3, 2003 report, referred to relator's "inability to use his left hand for any significant activity," he failed to indicate his awareness of the Walker standard of loss or the Alcoa standard of loss. Thus, under the reasoning set forth in 1'immerman regarding Dr. Bamberger's report, Dr. Aitken's report must be viewed as similarly flawed. There is simply no indication in Dr. Aitken's report that Dr. Aitken understood the standard for determining loss of use. {136} Moreover, physical therapist David Kaze&s opinion (to the extent that it is viewed as accepted by Dr. Aitken) that relator's "left hand is basically not usable for working activities" does not meet the Walker or Alcoa standard for loss of use. As the Alcoa court notes, the "all practical intents and purpose" test used by the Pennsylvania courts requires a more crippling injury than the "industrial use" test. Kazee's opinion that relator's "left hand is basically not useable for working activities" applies an "industrial use" test that is not appropriate here. {137} Dr. O'Donnell, who evaluated the industrial injury for the Pmployer, does not opine that relator has suffered the loss of use of the left hand. She, in fact, renders no statement whatsoever that could be viewed as an opinion that relator has lost the use of his left hand. Accordingly, Dr_ O'Donnell's report provides no evidence to support relator's motion. {138) Dr. Brown, who conducted a file review for the bureau, opines that the 21 percent impairment rating given by Dr. Aitken is "not consistent with total loss of use of band_" Obviously, Dr. Brown's report provides no evidence supporting an award for loss of use of the left hand. {T39} Based upon the above analysis, the magistrate concludes that there is no evidence in the record to support relator's motion for an R.C. 4123.57(B) award for loss of use of his left hand under either the "flat loss" or the "two fingers plus" theory. {140} Accordingly, for all the above reasons, it is the magistrate's decision that this EXHIBIT G 12of 13 6727I1.%ge:443n1 itp://G6.161.14L176Jcgibiidlcxisfweblcatict:,w/^ymc+"13Scoxbuwc. h... court deny relator s request for a writ of mandamus. KENNE'CH W. MACKE MAGISTRATE Footnotes: 1. State ex rel. Walker v. Indus. Comm. (1979), 58 Ohio St.2d 402. OH OH Unpublished App. Lawriter Corporation. All rights reserved. The Casemaker Online database is a compilation exclusively owned by Lawriter Corporation. The database is provided for use under the terms, notices and conditions as expressly stated under the online end user license agreement to which all users assent in order to access the database. EXHIBIT G 13 c,r ) 3 6/27m$.,b Aa6w Westlaw. Page I Not Reported in N.E.2d Not Reported in N.E.2d, 2IX)2 WL 1377869 (Ohio App. 10 Dist.), 2002 -Ohio- 3255 (Cite as: Not Reported in N.E.2d, 2002 WL 1377869 (Ohio App. 10 Dist.)) HState ex ret. Stringer v. Hamilton Plastics Ohio App. 10 Dist.,2002. t11 Workera' Compensation 413 C^1306 413 Workers' Compcnsation CHECK OH7O SUPREME COURT RULFS FOR REPOR77NG OF OPINIONS AND WEIGHT OF LEGAL AUTHORITY. Court of Appcals of Ohio,Tenih District, Franklin Cot nly. STATE of Ohio ex rel. Laura STRINGER, Relator, V. IiAlvtit.TON PLASTICS, C. James Conrad, Administrator, Ohio Bureau of Workers' Compensation and The Industrial Commission of Ohio, Respondents. No. OIAP-1157- 413XVi Proceedings to Secure Competisation 413XVI(G) Medical Examination 4] 3k1306 k. Right to Examination in Gcneral. Most Cited Cases Employer could require workcr s cotnpensation claimant to submit to functional capacity examination, after she had bocn examined by employer's physician, although claimant asserted that she could be compelled to submit to only one examination; functional capacity exami nat i on was not second medical examination, but a series of tests used to assist examining physician in his assessment, and functional capacity examination was neccssary to enable employer to defend against claim. R.C. S 3123.651; OAC 4123-34)9a. b Dccided June 25, 2002. )2j Workers' Compensation 413 C^1686 Workers' compensation claimant sought mandamus revicw of a decision by the Indnstrial Commission that denied her permanent total disability (PTD) benefits. The Court of Appeals adopted the decision of StephanieBisca Brooks, Magistrate, which held thal: (1) employer could require claimant to undergo functionalcapacityevaluatioo; (2) claimant was not entitled to depose vocationa) expeil; and (3) Commission was not rcqnired to discuss notunedical factors already discussed in vocation reports. 413 Wodcers' Compensation 413XV1 Proccedings to Secure Compensation 413XVi(O) Affidavits and Depositions 413k1(,86 k. Discovery and Depositions. Most C.itcd Cascs Worker's compensation claimant was not entilled to take deposition of vordtional expen, where claimant merely stated her disagreement with experi's opinions, but did not point ont substantial disparity bctween this opinion R.C. $ 4123.09; and others' opinions. 4121-3-09(A)(6)(d). Objections overtuled; writ denied. J7j Workers' Compensation 413 p1756 West Headnotes cQ 2008 Thomson/West. No Claim to Orig. U.S. Govt. Works. EXHIBIT G Page 65 Not Reported in N.E.2d Not Rcported in N.F.2d, 2002 WL 1377869 (Ohio App. ll) Dist.), 2002 -Ohio- 3255 (Cite as: Not Rcported in N.E.2d, 2002 WL 1377869 (Ohio App. 10 Dist)) 413 Workers' Compensation J13XV1 Proceedings to Secure Compensation 413XVt(P) Hearing or Trial 41 3XV1(P)G Findings of Fact and Conclusions of Law by Board, Commission, or Court 4 13k1751 Particular Facts and C.onclusions 413k176 k. Eamings and Impairmeut of Earning Capacity. Most Cited Cases Industrial Cvmmission was not required to specify and explain the combined impact of nomnedieal and vocation factors considered in denying claaim for pemrenent toL•d distbility (P'1'D) benefits, whcre vocational n7wrLS fully discussed nonmedical factors. ln ivlandamus on Objections to theMagislrate'SJlecision Kearns Company, LPA, and Michael A. Kearns, for relator. Vorys, Sater, Seymour & Pcasc, LLP, and Richard L. Moore, for respondent Hamilton Plaslics. Be^tr;omerti; Attorney GeneraL, and Janinc 1lancock Jones, for respondent Industrial Commission of Ohic. Pagc 2 r(xlucstat writ. tj 3) Relator has ftled objoctions to the magistrnte's decision, and the matter is now before this court for a fidl, independent review. ('¶ 4) Relator's objections to the contraiy, this court agrees with the magistrates analysis of the pertinent issues. Accordingly, for the reasons sel forth in the magistrate's decision, this court overrutes rclator's objections and adopts the magistrate's decision as its own, including the findings of fact (with a corrected date of May 16, 1988 in the first paragraph of the findings of fact and a correction from TTD to FTD in the tlurteen0i paragraph ofthe findings of fact) and c,onclusions of law contained therein. In accordance with the tnagistrate's decision, this oourt hereby denics the requesled writ of mandamus. OBjections ovemJed,• writ denied PETREE, J. *1 {Sl 1) Relator, Laura S1rYnger, has filed this original action requesting that this court issue a writof ntattdamus ordering respondent Industrfal Comrnission of Ohio ("commission') to vacate its order which denied her application for pemtattcnt total disability ("PTD') compeosation and to issae an order finding that she is entitled to PTD compensation purxuant to Slnfe ez rel. Gayr 91ihui(1994) 6SOhioSt.3d315.626N.E.2d666. (¶ 2) PAusuant to Civ.R 53C and Loc.R. 12(M) of the Tenth Dislrict Court of Appeals, this matter was referred to a magistmte of this court, who examiced the evidence and issued a decision, including findings of facf and conclusions of law. (Attached as Appendix A.) Therein, the magistrate concluded thal the commission did not abuse its discretion in denying her application for PTD compensation and recommeMed that this court deny the TYACY P.J., and DESHL.ER J., concur. APPENDIX A MAGIS"PRATE'S DFCISION Rendered on March 11, 2002 tN [vfANDAMUS (9 5) Relator, Lauta Stringer, has filed this original action requesting that this court issue a writ of mandamus ® 2008 ThomsoNWest. No Claim to Orig. U.S. Govt. Works. EXHIBIT G Page 66 Not Reported in N.E.2d Page 3 Not Reported in N.E.2d, 2002 WL 1377869 ( Ohio App. 10 Dist.), 2002 -0bio- 3255 (Cite as: Not Reported in N.E.2d, 2002 WL 1377869 ( Oltio App. 10 Dist.)) ordering respondent Indusuial t:ommission of Ohio ("commission") to vacate its order which denied her application for permaucnt total disability ("YS'D") compcnsation and asked this court to order the commission to find that she is entitled to PTD compensation pursuant to .Stare ex reL Gac r. tJihrn (1994)68 Ohio St 3d 315. 626 N E.2d 606. Ihindings QfYact: {U 6) 1. Relator has sustained two work-related injuries. The first injury occurred on August 6,1997, and has been allowed for nonspecific conditions involving the left ann and liand, but specifically disallowed for left and right c•uoal tonttel s-ndrome and aggravation of preexisting carpal tunnel svndrorne le8 and right The second injury occurred on May 16, 1998, and has been allowed for: "Hcmiated disc L4-5 and L5-S l; right foraminal stenosis at L5-Sl •, failed back syndrome." {N 7) 2. Relator has bad two surgeries perfortned on her back, the first in 1990. Relator reinjured her back in 1992, and tlte second surgery was performed in 1993. (¶ 8) 3. Relator last worked in I996. *2 (1 9) 4. On March 23, 2000, relator frled the application seeking PTD cvmpcnsation. At the time of the application, relator was sixty-eight years old, had completed the sixth grade, had workcd as a school bus driver, a real estate agent, and a barmaidlwaitrtss. {¶ 10) 5. Relator was examined by Dr. David C. Randolph who issued a report dated May 23, 2000. Dr. Randolph concluded that relatorwas capable of returning to sedentary work activities; however, he reconnnended tlwt a functional capacity examination was necessary in order to fully address this issuc. Dr. Randolph listed the following functional litnitations: {¶ 1 I}Based solely on subjective infonnation and the objective physical exanrination, it is nty opinion she should be capable of work related activities in a sedentary physical demand characteristic only. She should avoid prolonged work in a single position but be permitted frequent position changes as needed. Bending, twisting and s(ooping may be performed on a rninimal basis. Stte shoutd avoid lifting or carrying objects weighing in excess of 10 pounds. {¶ 12) 6. Because Dr. Randolph indicated that a functional capacity examination was necessary, relator was dvected to report to Richard J. W ickslrom, PT, CPE. Relator contested the issue of attending this exam; however, the hearing administntor issued an order finding that the examination is not a "second" examination but that it was a serics of tests used to assist the examining physician in his assessment and that rclator was nstuired to attend and participate unless she couldshow good cause preventing her front p:rrticipating. {1l3} 7. Mr. Wickstrom examined relator and issued a report dated August 10, 2000. Mr. Wickstrom concluded that rciatoes liHing abilities werc in the sedealary to sedentary-light range. He indicatod Ihat relator could lift, carry, push, pull up to fiftecn pounds with the exeeption of her upper lifting and pushing being confined to 6ve pounds. Retator was trmestrieted in her ability to sit and could oeeasionally stand and walk; occasionally drive but never use foot controls witlr both feet; however, could occasionally use foot controls with one foot; hand use with both bands was restricted to freqnently; hand use with one hand was unrestricted; reaching with both arms was restricted to ocpsionally; reaching with one ann was restricted frequently, stooping andbending was restricted 0 2008 Thamson/West. No Claim to Orig. U.S. Govt. Works. EXHIBIT G Page 67 Not Reported in N.F.2d Not Rcponcd in N Y.2d, 2002 WL 1377869 (Ohio App. 10 Disl.), 2002 -0hio- 3255 (Cite as: Not Reported in N.E.2d, 2002 WL 1377869 (Ohio App. 10 Dist.)) to frequeutly; and relator was precluded from crouching, crawling, and clintbing. Mr. Wicksunm concluded thal, based solely upon the allowed conditions, relator is capable of performing the full range of jobs requiring sedentary physical demands and a limited range of jobs that requirc light physical detnands. He indicated further tIL1t tLe employer had previously created ajob which was consistent with her limilations but that relator had stopped performing that job due to 417tertension and problems with her hands. He opined that relator had reached rttaximum medical improvement and rhal it was unliketythatshewouldachieveany hs*ant' lfunctional improvement with any frulher skilled thempy. x3 (¶ 14) 8. Relator was also examined by Dr. Kennefh R. Hanington on October 19, 2000. Dr. Hanington opitted that she had fcached maximtmt medical itnprovement, assessed a twenty-five percent whole petson impairment, concluded that she was unable to rehun to ber formcr position of employment bnt that she would be capable of performing other work in a sedentary capacity. Dr. Hanington completed an occupational activity assessntent wherein he indicated that relator could sit, sland, and walk for tbnc to five hours; was unrestricted in her ability to carry, push, pull or otherwise ntove up to ten pound.c; could occasionally climb stairs and reach overhead; was unrestricted in her ability to handle objects as well as lift at waist and knee level; was preclnded from climbing laddcm, using foot controls with her right foot, cronching, stooping, bending, and kneeting as well as rcaching at floor level. (¶ 15 ) 9. An employability assessment was prepared by Mark A. Anderson, MS, LPC, CDMS, dated September 28, 2000. Parsuant to the medical teports of Drs. Hanington and Randolph, Mr. Anderson concluded that relator could perform the following jobs: (¶ 16)Telemarke(er, Information Clerk, Appointment Page 4 Clerk, Patcher, Security Camera Monitor, Docuntent Prepttrc:r-Microfilm, Order Clerk-Food & Beverage, Film Touch-Up Inspcctor, Touch-Up Scrccncr Printed Circuits, Sorter, Credit Authorizer, Bonder, Taper, Ampoulc Sealer, Preparer. {}l 17) Mr. Anderson opined that, at age sixty-eight, relator would have more difficulty than her younger counterparts in learning new skills but that the occupations he listed were entry level occupations that did not rrquire complex tasks. He noted that the highest level of scbooling she completed was the sixth grade and that she had no diplorna or GED. However, he noted that she had obtained a real eslate license whicb ltad lapsed because she had not complied with the continuing education requirentents. With regard to her wurk history, Mr. Anderson noted that relator has worked in skilled and semi-skiltcd jobs and that her work as a real estate agent, being skilled, would have required the ability to read, write and perform basic mathematical fnnctions. He concluded that it was unlikely that rclator would benefit from a remediation program but restated thal she was capable of entry level sedentary occupations. He concluded that if relator wen: to actively seek employmeut she would benefit from job placement assistartce to learn how to market herself to prospeciirc cmploycrs. (118) 10. An employability asse.ssmentwaspreparedby Craig Johtutnn, MRC, CRC, and daled January 20, 2001. Mr. Johnston noted that rclator's past work history required her to demonstratc seventh to eighth grade reasoning and languageproficiencies as well as fourth to sixth grade levels of mathematical proficiency. Based upon the reslrictions identified by Drs. Randolph and Hanington, Mr. Johnston indicated thal relator could return to work in light assembly, or work unrelated to her past employmcnt but within her basic vocational capacities. Ele listed the following positions: "Parking-Lot Boolh Attendant, Surveillance-System Monitor, and Cci 2008 ThomsonlWest. No Claim to Orig. U.S. Govt. Works. EXHIBIT G Page 68 Pagc 5 Not Rcporled in N.E.2d Not Rc}xntcd in N.E2d, 2002 WL 1377869 (Ohio App. l0 DisL), 2002 -0hio- 3255 (Cite as: Not Rcported in N.E.2d, 2002 WL 1377969 (Ohio App. 10 Dist.)) Bonder."Relator's age was seen as a pMcntial barrier but, Mr. Johnston indicated that it would not be, by ils.elf, work protribitive. He noted that relator had last worked in 1996 when she was sixty-four years old. lie saw telatods cducation as a potential barrier to employnmenL Her prior work historv indicated that she has demonstrated temperaments for perforrning repetitive activities and dealing with people. He noted hnther Utat her semi-skilled work hi slory reflectedan ability to overcorne lier marginal cducation and to obtain employment despile not possessing a lugh school diplorna •4 {¶ 19) 11. On November l, 2001, naator filed a motion asking to depose the vocational expert, Mr. Anderson. In her motion, relator sought clarification as to several issues pertai ning to conclusions reachedby Mr. Anderson. Nowhere in her motion did n;lator indirate that there was a substantial disparity bctw•een the n.•pon of Mr. Anderson and the reports of any other vocational expcrts. {¶ 20} 12. By order dated lanuary 18, 2001, a staff hearing officer (" SHO") denied relatols request as follows: (¶ 21)Following review of the claim frle and all rclcvant evidence, it is the finding of the Staff Hearing Officer that the claimant's motion is anreasonable because the reasons set forth by the ctaimant's motion tnerely state ttte opinions and conclusions of Mr. Anderson with which the claimant disagrr:es. The claimant has not provided any other evidence which would contradict the conclusions of Mr. Anderson and detnonstmte any type of snbstantial disparity. Therefore, it is the order of the Staff Hearing Officer that the claitnant's motion is deniotL The processing of all pending issues is to resume. (122) 13. Relator's application for P71) compensation was heard before an SHO on March 20, 2001, and resulted in an order denying relator's request for 771) compensation. The SHO relied upon the reporis of Drs. RandolphandHanington,andMr. Wickstrom,Anderson, and Johnston. Based upon the reports of Drs. Randolph and Hanington. the SHO concluded that mlator retained the physical functional capacity to perfonn employment activities wMch are sedentary in nature. After srmtmarizing the vocalional evidence provided in the reporis which were submitted, the SHO concluded as follows: {I 23}Thc Staff Hearing Officer finds that ihe claimant's age of 69 years is a barrier to the claimant with regard to her ability to return to and compete in the workforce. The Staff Hearing O@icer further finds, however, that age alone is rwt a factor which would prevent the claitnant from returning to work. The Staff Hearing Officer Curther finds that the claimant's nwrginal educalion would be a barrier to the claimant with n:gard to her ability to retrun to work. The Staff Hearing Oflicer further finds, however, that the claimant has never had more than a marginal education and il has not prevented her from working in the past The Staff Hearing Officer further finds that not only has it not prevented the claimant from working in the past, it has nat prevented the claimant from performing skilled employment activities in the past. The Staff Hearing Officer further finds that conflicting evidence exists concetning the claimant's ability to read, write and performbasic math. The Staff Hearing Otficer notes, however, that the claimant's academic skills did not prevent her fmm obtaining a n^_l eslale license. The Staff Hearing Offrcer further finds that the fact that the claimant has performed skilled employntent activities in the past is evidence that the claimant pos.sesses the intellectual capacity to learn to perform at least unskillyd employment activities in the future. Based upon the report of Mr. Anderson, the Staff Hearing OfScer finds that the claimant posses [sic ] academic skills tbat are suffrcient for the performance of many entry level sedentary jobs. 0 2008 Thom.sou/West. No Claim to Orig. U.S. Govt. Works. EXHIBIT G Page 69 Not Rcported in Nfi.2d Not Reported in N. E.2d, 2(x)2 WL 1377869 ( Ohio App. 10 Dist ), 2002 -Ohitr 3255 (Cite as: Not Reponcd in N.E.2d, 2002 WL 1377869 (Ohio App. 10 Dist)) The Staff Hearing Officer further finds that although the claimanl, at the age of 69 years, would not be a good candidale for mhabilitation ur mmediation, claimant is capable presently of entry level sedentary occupations. The Staff Hearing Officer further finds tbat the claimant has demonstratcd tlre following temper.unems in her work ltisiory which might be heipfui to hcr in the performance of futum employment: perfonning mpelitive, or short cycle work; dealing with people; making judgments and dccisions and itilluencing people in their opiniont, attitudes, and judgments. The Staff Hearing Otficer accepts the residnal funetioual capacitits opinions of Dr. llanington and Dr. Randolph. Based upon the opinion of Mr. Anderson, the Staff Hearing Offic,cr finds that the claimant would be capable ofperforming the following jobs immediatcly: Seauity Camera Monitor; Document preparer-Microfihn; Order Clerk-Food and Beveragc;Film Touch-Up Inspector Touch-Up Screener-Printer Circuits; Sorter', Bonder, Taper; Amponle Sealer, and Prepater. 'The Staff Hcaring Officer therefore finds tbat the claimant is capable of sustiined remunerative employnnvt and is not pcrmancntly and totafly disabled. Claimant's Application for Permanent and Total Disability filed 3/23/2000 is"therefote dcnied Page 6 the mmmissionahused its discn:tion by entering an order which is not supported by any evidence in the record. Stare ecr rel. F_(Iiort v. Indus. Cnnnn. (19R6). 26 Ohio St3d 76 497 N.E.2d 70. On the other hand, where the record contains some evidence to support the commission's findings, there has been no abuse of discrelion and rnandamus is not appropriate. ,Stnte ex re1. I.euisv. DirnnondFoundrvCa (1987), 29Ohio S1.3d56. 505 N.E.2d 962. Furtbermore, questions of credibility and the weigbt lobe given evidence areclearly within the discretlon of the commission as fact finder. .S(r,re ex rel. Teece v. Indu.c. Comm. (1981 L fiR Ohio St2d 165. d29 N.E.2d 433. Conclusions ojl,aw: (1 26) The relevant inquiry in a detenmination of perrnancnt total d'rsabitity is claintant's ability to do any sLstained remuncrative employment. State ex rel. Dnrn/ancic v. Indus. Camm. (199J1. 69 Ohio St.3d 693. 635 N.E.2d 372. Generally, in making this determination, the commission must consider not only n>edical impairrnents but, also, the claimant's age, education, wark recard and other relevant nonmedical fadors..Slateexrei Stenhensonv Indus.C'nnmr.(1987) 31 Ohio St3d 167. 509 N.E.2d 946. Thus, a claimant's nrodital capacity to work is uot dispositivc if the claimaul's nomnedical factors foreclose employability. Srnle e.r rel. Gm• v. ,IfiLm (19941. 68 Ohio St.3d .i 15,626 N.E.2d 666. The commission must also specify in its order what evidence has been relied upon and briefly explain the reasoning Por its decision. State ex re1. Vofl v Indus. Cnmm. 1991 57 Ohio St. 3d 203. 567 N.E.2d Z45. 1125) In ordcr for this court to issue a writ of nwndamus as a remedy from a determination of the commis.sion, relator must show a clear legal right to the relief sought and that the conunission has a clear legal duty to provide such rel ief..Stnre ec ref.1're.cslev v. Indus. Cornm. (1967). 11 Ohio St.2d 141. 228 N.E.2d 631. A clear legal right to a writ of mandamus exists where the relator shows that (127} Relator raises the following thrce argnments in this mandamus action: (f) the commission abused its discretion by finding that relator was obligated to undergo a ffimetional capacity examination requested by Dr.l2andolph who examined relator at the request of the self-insured employer, (2) the commission abused ils discretion by finding that relator was not entitled to take '5 {¶ 24) 14. Therealier, rei•uor filed thc instant mandamtvs action in this court. ® 2()08 ThomcotilWest No Claim to Orig. U.S. Govt. Works. EXHIBIT G Page 70 Not Reponcd in N.E.2d Not Reported in N.E.2d, 2002 WL 1377869 (Ohio App. 10 Dist), 2002 -0ltio- 3255 (Cite as: Not Reported in N.E.2d, 2002 WL 1377869 (Ohio App. 10 Dist.)) the deposition of vocational expert Mark Anderson when the report was unclear and contradictory on its face; aad (3) the comtnission abused its disctetion by failing to adeqmtlely specify and explain the combined impact of all of the nonmedical vocational factors as requirai in Stephenson, suprn.Eor the reasons that follow, this magistrate finds that mlator s arguments lack merit. J 1}(¶ 28) R.C. 4123.651 prmrides for the examination of a claimant by a physician of the employets choice and providcs in pertincnt parl as follows: (¶ 29) (A) The employer of a claimant who is injured or disabled in the conrse of his employment nray require, without the approvat of the administrator or the industrial commission, that the claimant be examined by a physician of the employer's choice one time upon any issue asserted by ttte eniployce ***. Any further mquests for medical examinations shall be inade to ihe commission which shall consider and rute on the request. 'fhe employer sball pay the cost of any examinations initiated by ihe employer. *6 {1 30}0hio Adm.Code 4123-3-09(a) and ta) provide additionally, in relevant part, as follows: (131)(a) In no event will the claimant bc examined tnore than one titne at the requcst of the employer on any issue that is assetted by the claimantor which is to be considered by the commission, during the time Ihat the specific matter asserted or that is in controversy remains pending final adjudication before thebureau or commission. {¶ 32) (b) If after a medical exaroinatian of the claimant undcr pamgmph (A)(5)(a) of this nilc on an issue tltat mmains in controversy and has not been finally adjudicated, an employer asseRs that an additional medical examiruttion by a doctor of the Page 7 employer's choice is essential in the defense of the claim by thc employer, writtcn request for such an cxarnination shalt be suburlticd to the hearing adnrinistretor oniy in cases where there is a dispute as to the rcxtuest for additional examination. *** (133) All nemnable expenses of such examination, including any travel expense shall be paid by the employer inrnrediately upon the receipt of the billing. s*: (134) Relator ditects this coun's attention to (A)(5)(a) and not (b). Obviously, pursuant to (5)(a) the enrployer is only entitled to have relator examined one timc on any issue that is asserted by relator. In the present case, the employer requircd that relator be seen by Dr. Randolph. However, within the body of Dr. Randolph's report, he sper,tifically noted that a functionalcapacitiesevaluation was necessary in order to fully address the issue of whether relator could reehrrn to sedexdary work activities. The relator challenged this ret(uest and the matler was heard before an SHO. The SHO specifically concluded thal thc upcoming examination with Mr. Wickstrom was not a second examinationbut was part of a series of lests uscd to assist an examining physician in his assessment, rdered telator to attend unless she could show good and on cause preventing her from participating in the Icsting. Relator did not appeal this order nor does she present any persuasive reasons evidencing good cause. tj 35) The SHO concluded that the employer wa.s not requiring relator to submit to a second exandnation. In looking at (5)(b), it is apparent that there is a certain atoomttofdiscretion whereby thecomrnission can require a claimant to submit to a second medical examination at thc employer's request. As sucil there is no absolute right as relalor contends thal she would only be forced to wbmit to one medical exarnination at the employer's request instead, it is apparent that a second examination ® 2008 ThonrsonlWest. No Claim to Orig. U.S. Govt. Works. EXHIBIT G Page 71 Not Reported in N.E.2d Not Reported in N.E.2d, 2002 WL 1377969 (Ohio App. 10 Dist.), 2002 -Ohio- 3255 (Cite as: Not Reported in N.E.2d, 2002 WL 1377869 (Ohio App. 10 Dist)) may be requircd if the employer asscrts that the additional medical exa mination is essential in the deferese of the claim by theemployer. Given the foregoing, rclator ltas not demonslrated an abuse of discretion in Ihis regard. [2{{¶ 36) Relator also contends that the commission abused its discretion by denying her the opportunity to depose vocational expert, Mark Anderson.RC. 4123D9 vests the commission with the authority to allow the taking of depusitions and provides as follows: *7 (¶ 37)In claims filed before the industrial commission * * * by injured cmployees *•' on account of injury * *' sustained by such employees in the coursc of their employment, the commission * * * may cause depositinns of witnesses tesiding within or without the state to be taken in the manner prescribed by law for the taking of depositions in civil actions in the court of common plcas. {¶ 38}Ohio Adm.Codc 4121-1-09(A)(G) provides a procedure for obtaining the oral deposiUion of an industrial commission physician. OMo Adm.Code 1123-3-09(A)L6)LdJ enumerates the faetors to be considered in determining the reasonableness ora request for a deposition and provides, in pertinent part: (¶ 39)* **[W)hether a substantial disparity exists between various medical repotts on the is,atc that is under contest, whether one oredical report was rclied upon to the exctn.sion of others, and whether the request is for harassment or delay. * * * (9 40) Relator filcd a nrotion seeking to depose Mr. Anderson and (he rnatter was hcard bcfotc an SHO who denied the motion aHcr dctermining that it was mueasonable becausc relator's only basis was that she disagrced with the expert's opinion. The S}IO concluded Page 8 that them was no evidence presented to show that Ihere was a substantial disparity between the report of Mr. Anderson and the repons of the others. {9 4 t) The decision whetber to grant or deny a party the right to depose a witness in connection with a workes' compensation case is discmtionary. 1,7V Sree! Co. v. Indus. Convn. (20M), 140 Oho App.3d 680. R.C. 4123.09 is a pennisaive statute giving the cmnmission discretion and indicated the cornmission nray cause depositions to be taken. There is no right, as relator asserts, nequiring the commission to grant a party's request to take a deposition under any circurnstancct In the present case, relator did not indicate in her motion that a substantial dfsparity existed betwcen the rcpon of Mr. Anderson and a report of others. I nstead, shc merely listed opinions stated by Mr. Anderson and indicated that she wanted to scek clarification as to those issues. Based on the record, it cannot be said that the comrnission abused its discretion by denying relator's request to depose Mr. Anderson. }3l{142} Lastly, relator contends that the comnrission did not adequately specify and explain the combined impact of all the noumedical vocational or factors as required by Stephenson, supra. Relator contends that the commission merely noted the nonmedical vocational nuxlical fac7ors witbout explaining them. This magistrate disagrees. {143} In the prtsenl crse, the comrnission determined, that from a medical standpoint, relator could physically engage in scdentary work. 'fhereaRer, the commission summarized the conclusionsbasedby the three vocational expens upon which the commission specifically relied in denying re.lators application for PTD compensation. The comnrission has the discretion to accept one vocational neport while rejecting another vocational report. Or, the cormttission can reject all the vocational reports and rO 2008 Thomson/West. No Claim to Orig. U.S. Govt. Works. EXHIBIT G Page 72 Not Reportcd in N.E.2d Not Reported in N E 2d, 2(H)2 WL 1377869 ( Ohio App. I l) Dist.). 2002 -0hio- 325i (Cile as: Not Reported in N.E.2d, 2002 WL 1377869 (Ohio App. 10 Dist.)) conduct its own analysis of the nonmedical fadors. See Stafe ex reI.In<:kcnn v. Indtr.c. Comm (1997j, 79 Ohio St.:d 266 680 N.E.2d 1233. Furthcr, if tlre vocational reports extensively discuss and analyze all the relevant nonmedical factors, the comrnission does not nced to repeat tlat analysis in ils order. State ex ret. Hunt v. Indus. Comm. (Sept. 28, 1995), Frenklin App. No. 94AP-1659, unrcported (Memorandum Daision); State ex rel. Freeman v. Inrlus. Comm. (Mar. 17, 1998), Franklin App. No. 97AP-251, tuucported(Mcrnorandum Decision). *8 (¶ 44) In the present case, the vocational experts did provide extensive explanations of lheir analysis of We norunedical factors. The commission relied upon three vocational repons.In addition, thecommissionconducted its own analysis and again cited the vocational report of Mr. Anderson. '1'he commission found that relators age of sixty-nine years is a barrier with n:gard to her ability lo relurn to compele in lhe workforce; however, the comntission concluded that age alone is not a factor which would prevent this relator from retuming to work. The record indicates that relator had worked up until she was sixty-four years old- With regard to relator's education, the SHO noted thst her marginal education would be a barrier with regards to her ability to return to work. However, the SHO noted that relator had never had ntore than a marginal education in the past and thal she had not been prevented from working. Further, the SHO noted that rclator had obtaincd a mat estate license, despite her alleging that she was not able to read, write or perform basic math well. The SHO notod that them was conflicting evidence in the record conceming retatois ability lo read, write and perfonn basic math. The SHO notcd further that relator has performed skilled employment and that she possesses the intellectual capacity to learn and perform skilled employment activities in the futttre. Based upon the report of Mr. Atrdersnn, the SHO found that rclator possessed academic skills which are sufficient for the pcrformarrce of many entry level sedentary jobs. The SHO notcd that relatoe s Pagc 9 priorwork history indicates certain tempcr.tntenls wfticlt would be helpful for her in the perfonnancc of futurc cmployinent: performing repetitive or short-cycle Nvork; dealing with people, making judgmcnts and decisions and influencing people in thcir opinioas, attitudes, ancl judgrncnts. (¶ 45) Relalor directs this caurt's atlention to the vorational evidence she submitted; however, Ihe commission clrose not to rely on that vocational expert and that faci does not constitute an abuse of discretion. {146} Based on the foregoing, this magistrate concludes that relator has not demonstrated that Ihe comtnission abused its discrciion in denying her application for PTD compensation and retator's requcst for a writ of mandamus should be denied. /S/Stephanic Bisca Brooks STEPHANfE BiSCA BROOKS MAGISTRA"[E Ohio App. 10 Dist.,2002. State cx reL Stringer v. Hanulton Plastics Not Rcported in N.E.2d, 2002 WL 1377869 (Ohio App. 10 Dist.), 2002 -0hio- 3255 FND OF DOCUMENT ® 2008 Thornson/West. No Claim to Orig. U.S. Govt. Works. EXHIBIT G Page 73 N;estlaw. Not Reported inN.E.Zd Page I Not Reported in N.E?d, 1990 WL 187466 (Ohio Aop. 2 Dist.) (Cite as: Not Reporied in N-E.2d, 1990 Wl, 187466 (Ohio App. 2 Dist.)) err in nllowing a physic-el therapist to offer inedical C Zinn v. L.cach Ohio App-, 1990. causation testimony; and (4) did the trial court erz in overruling a motion for new trial. Only the Westtaw citation is currently available. CHECK 01410 SUPREMF- COURT RULES FOR REPORTING OF OPINIONS AND WEIGHT OF LEGAL AUTHORITY. Court of Appcats of Ohio, Sccond Disuict, Champaign County. Everett O. Z1NN, et al., Plaintill-Appel I ee/Cross-Appel lant, V. Billie N. LEACH, et al-, Dcfcndant-Appel- lant/Cross-Appel l ce. Nos. 90-CA-03, 90-CA-08. Nov. 29, 1990. John A. Smalley, Young & Alexander Co., L.P.A., Dayton, for piaintiff-appelleclcross-appellant Francis S. McDaniel & David F. Beitzel, Freund, Freeze & Arnold, Dayton, for defendant-appelIanUcross-appellcc. Karl F- Paufig, Urbana, for defendant. William L. Haventann, Pickrcl, Schacffer & Ebeling, Dayton, for dcfcndant Nationwide Insurance Co. In his cross-appeal, Zinn presents two issues for our consideration: (1) did the trial court crr in overruling a mution for prejudgment interest; and (2), did the trial court err in defening a decision on a supplemental pleading to recover insnrance proceeds pursuant R.C. 3929.06 pending the outcome of Leach's appeal to this cottn. For the reasons stated below we overrule Leach's four assignments of error. We likewise overrule Zinn's assignment of errw regarding the Irial court's decision to defer consideration of his snpplemental petition pending the outcome of a direct appeal tn this court. The trial court's decision on these matters will be alfirmed. However, we reverse the trial court's judgment as it concerns Zinn's claim for prejudgment interesL Accordingly, the malter will be remandcd for entry of judgment for prejudgtnent interest. Factc OPINION On March 25, 1985, Everett Zinn was injured when GRADY, ludge. the vehicle he was driving was struck broadside at *'1 This is a ctmsolidated appeal from the trial an intersection by a vehicle driven by Billie Leach. court's judgment awarding Plaintiff-Appellee Ever- Zirtn, a timberman and recording studio owner, re- ett O. Zinn $400,000 in compensatory damages for ceived a C-shaped laceration of the scalp which left injuries suffered in an automobile accident $oth permanent scarring, tightness and numbness of the parties have 6ted appeals challenging various parts scalp. Ile also sustained injury to his inner car res- or the proceedings below. ulting in permanent hearing loss in one ear, per- In his appeal, Leach presents four issues for our consideration: (1) did the trial court crr in ovcrruling various motions conceming discovery mattets; (2) did the trial court err in overruliug an objection to Zinn's closing argument; (3) did the trial court EXHIBIT G manent damage to the scmi-circular canal with resulting disequilibrium or vertigo, and pennanent tinnitus or ringing in the ear. Zinn notified Lcach's insurer, Nationwide Insurance ® 2008 ThomsorJWest. No Claim to Orig. U.,S- Govt. Works. Page 74 Page 2 Nut Reported in N.E.2d Not Reported in N.fi.2d, 1990 WL 187466 (Oldo App. 2 Dist.) (Cite as_ Not Reported in N-E.2d, 1990 WL 187466 (Ohio App. 2 Dist.)) Company, of his injuries two days after the accident On Februaty 24, 1986, Wingfield transferrcd Zinu`s on March 27, 1985. Nationwide assigned the claim claim to Jarnes Suttcr, another Nationwidc adjusn:r. to William Wingfield, onc of its adjustcrs James Sutter testified that although the value of the claim Sacco was WingGcld's supervisor. Wingfield ob- was probably discussed, he could not recall the tained a copy of the police report and took recorded value placed on the claim. Sutter admitted that he statements from Leach and Zinn (Wingfield Dcp.'fr. 15, 16). Zinn stated that he had reccived ncver communicated to Zinn's attomey, Michael Grnoscr, a settlcment offer (Sutter Dcp.Tr. 9). treatment for his injuries at two hospitals and from On June 16, 1986, Nationwide received from Zinn's three physicians (Wingfield Dep.Tr. 17). On April 8, 1985, at Nationwide's request, Zinn exccuted an authorization enabling Nationwide to obtain medical and employment records. That same day Wingfield concludnd that Nationwide owed "property damage and bodily injury." (Sacco Dep.Tr. 8). Wingfield itnmediatcly requested infonnation from Drs. Lawrence Mervis and Aftab attorney a packet of material containing the following: photographs of Zinns automobile and injurics, a letter from Dr. Mark Roberto to Attorncy Gmuscr dated May 27, 1986 describing Zinn's truatment, a letter from Mark Maiu, L.P.T., to Dr. Roberto dated May 29, 1986 describing Zinn's treatment, and a letter from Rose Palermo, Zinn's Nashville attor ney, dcscribing his numerous recording awards. Butt, and Mercy Medical Center. Nationwide also souglu a report froni Dr. Mark Roberto. Nationwide received Mervis's report on May 10, 1985, Butt's report ou May 22, 1985, and Roberto's repwt on Sutter testified that he reviewed the packct and requested the adjuster to obrain an independent medical evaluation ( IME), IRS records, a current photograph and wage veriGcation ( Sutter Dep.Tr. 16, 27). September 4, 1985. The lME was eventually conducted by Dr. Paulson. *2 At the end of the 60 day "pricing period," Wing- Paulson was not called to testify at trial, a fact freld evaluated Zinn's claim at $6,500 (Winglield noted by Zinn during his closing argument. Sutter Dep.Tr. 18). This was latter increased to $60,000, rcviewed the packet but did not keep notes on the although neither Wingfield nor Sacco could recall tnaterial and could not recall what the packet con- how they arrived at tbis figure (See, Memorandurn tainod ( Sutter Dep.Tr. 16). Sutter stated that numer- from Sacco to Wingheld, January 25, 1986, Wing- ous documents not then containod in his files would field Dcp: fr. 38). Notwithstanding the deterrrtina- have been transfnrred to the attorneys representing tion of liability, no settlement offer was made by Leach and Nationwide (Sutter Dep.Tr. 9). Nationwide (Wingfield Dep.Tr. 26). Sacco testified that while the generat documentation supported S60,000 in compensation, he did not feel such an urfer was justifiel absent additional infonnation on wage loss (Sacco Dep.Tr. 20). Saccu statr.d that no scttlement was offered because he "did not want to insult the individual with an offer that would not be in line with what the injuries were (Sacco Dep.Tr. 24). In a mcmorandum dared February 6, 1987, Sutter stated that "this might be a limits case but as we discussed we don't have enough information." (Sutter Dcp.Tr. 28). A settlement offer of $40,000 was discussed at Nationwide on Febmary 5, 1987, but never presentcd to Zino (Sutter Dep.Tr. 29). Sutter admitted that while it was practice to make a scttlement offer m let the "PlaintifFs artomey know if he wants to get more money than he is asking he On January 27, 1986, Wingfield formally asked has to come up with more prooP or come down in Zinn by lettor to transmit all medieal and wage in- with his demand, no offer was made in this case. formation concerning his claim to Nationwide. This (Sutter Dep.Tr. 28, 29). was the rirst and only formal request for records sent by Nationwide to Zinn ( Sacco Dep.Tr. 21, 22). *3 On March 6, 1987, Nationwide reccived a dc EXHIBIT G Page 75 Not Rcpnrtetl in N.E.2d Page 3 Not Rrpurted inN.E.2d, 1990 WL 187466 (Ohio App. 2 Dist) (Cite as: Not Reported in N.E.2d, 1990 WL 187466 (Ohio App. 2 Dist.)) rn.md for setqement frorn Zinn's attome,v, accontpanied by another packet of information containing records from Mercy Medical Centr:r, reports from On June 16, 1987, Nicholas Subashi, the first :rttor- Drs. Butt, DuVall, Farrell and Roberto, consultar.ion and update reports from Mark Main, L.l'.T., and numerous letters from various parties conceming the value of various timber and recording assets Seguin. Both Subashi and Scguin were employces owned by Zinn. The accompanying letter reiterated Zinn's demand for settlement and warned Nationwide that a complaint would be filed shortly because the statute of limitation was close to expiring ney to represent Leach and Nationwide, withdraw as counsel of record and was rcplaccd by James P. of Nationwide. Seguin withdrew as counsel on Octobcr 27, 1987, and was rcplacod by Robert A. Burke. Finally, Burke was replaced by David Beitzel on lanuary 20, 1989. The trial court specifcally stated in the substitution entry that the uial schedule would remain in effect. (Letter from Attomcy (imoser to Wingfield, March 6, 1987). Nationwide made no response. On April 25, 1988, Zinn submitted a pretrial staternent in which he listed [he names of witnesses he expected to call for trial. Included on this list were Zinn and his wife filed a complaint against Leach on March 11, 1987, seeking $1,000,000 in com- Drs. Butt, DuVall and Roberto and Mark Main, L.P T. Zinn also listai the exhibits he expected to pen.catory damages. use at trial. On March 30, 1987, Leach filed separately an answer to Zinn's complaint and a thirteen branch request for production of documents. The Request for judgment which sought, in part, judgment on the is- Production sought "any and all" documents conceming statements by Leach, photos or diagrarrts of the accident, medical or hospital reports conccming the injuries produced by thu accident and any other On July 25, 1998, Zinn Gled a motion for summary sue of negligence. On August 15, 1988, the court found Leach negligenr in causing the automobile accident and judgment was entered accordingly. Lc.ach did not offer to settle the case. confinement or treatment for ten years past, medicat opinion and expense, lost income or earning capacity, tax records for three yctrs past, impairrnent '4 In addition to bling a claim with Nationwide, Zinn also filed a claim with his insurer, Buckeye Union Insurance Company, for damages under thc of daily routines, special damages of any kind, benefiLs From collai.eral sources, investigators reports, and any evidence intended to be inuoduced at uial underin.sured motorist provision of his policy. 13uckeye evaluatcd the claim and in December 1988, settled with Zinn for $300,000. "and any and all documentary evidence whatsoever". The Request was signed by Nicholas E. Subashi, an attorncy in the employ of Nationwide. Subsequent to filing his complaint, Zinn made additional demands for settlcment from Nationwide. On March 17, 1987, Attomey Gmoser wrote WingGeld supplying him with mcdical and economic documentation. Gmoser also demanded settlement for the policy limits. Similar letters were sent to Nationwide's attomey, Rnbert 13urke, on April 14, 1988, November 14, 1988, and December 6, 1988. "fhese demands went unanswered. Burke did, however, acknowledge on September IS, 1988, re- On January 19, 1989, Zinn notified Leach that he iotcnded to take depositions from Drs. Aftab Butt and Michael DuVall, and Mark Main, L.P.T., for use at trial. On January 23, 1989, Leach's fourth counsel since institution of the action filed a motion to compel discovery and also sought a pmter:tive order cancelling the depositions. The court overruled the motions. On March I, 1989, Gve days before trial, Nationwide fmally offered to settle Zinn's claim at policy limits of $100,000. The offer was rejected and the matter proceeded to trial. ceipt of Zinn's income tax returns. EXHIBIT G © 2008 Thornson/West. No Claim to Orig. U.S. Govt. Works. Page 76 Not Reported in N.E.2d Page 4 Not Rcported 'ur N. E.2d, 1990 WL 187466 (Ohio App. 2 DisL) (Cite as: Not Reported in N.E-2d, 1990 WL 187466 (Ohio App. 2 Di.ct.)) On the first day of trial, Leach filcd threc motions in limine seeking to exclude from the jury the de- Uefendan6Appellunt/Cros.s-Appellee Leach:r i1.s.signmen ts of Error position testimony by Dr. Aftab Butt and two pages of exihibits allegedly requested From but withheld by Zinn. The trial court overruled the motions at an A. Failure to Compel Discovery in-charrtbers confuence conditioned on Zinn providing defense counsel with the requested docu- I-cach statcs in his Srat assignmcnt of crror: ments by Gve o'clock that day. In addition to other wimesses at trial, Zitm presentcd the deposition tcstimony of Aftab Butt, M.D., Michael DuVall, M.D., and Mark Main, L.P.T. Leach objected to t}te testimony of Main arguing that only a medical doctor could offer medical causation testimony. During closing arguments, Leach also objected to TIIE TRIAL COURT ERRED TO TIiE PRESUDICE OF DEFENDANT-APPELLANT IN OVERRULING APPELLANT'S MOTION TO COMPEL DISCOVERY, AND MOTIONS IN LIMINE, AND IN ALLOWP.JG EVIDENCE BY MEDICAL EXPERTS AND OF MEDICAL EXPENSE UPON THE SUBJECTS CONCERNING WIiICIi I'LAINTIFFS-APPELLEES I-IAD NOT RESPONDED TO DISCO V ERY UPON. Zimi s reference to Dr. Paulson's absence. The court overruled the objection. Following deliberations, *5 Discovery provides a mcans to narrow and the jury awarded Zinn R400,W0 io compeasatory sharpen the scope of the issues to be litigated damages. betwean parties to a dispute. Stare, ex rel. Daggev, On March 20, 1989, Zinn tilod a motion secking Ohio has adopted a liberal discovery policy which, prejudgment interest alleging that Leach and Na- subject to privilege, enables opposing parties to ob- tionwide had not acted in good faith in attempting tain all evidence that is material, rclevant and com- v. Ge.r,vaman (1973). 34 Ohio St.2d 55. To this end, to settle the case. Shortly thereafter, Leach 6ied a petent notwithstanding its admissibility at trial. See, motion for new trial alleging various trial irregular- Civ.R. 26(B)(1). See, genemlly, 36 Ohio Jurispru- ities, rnisconduct by Zinn in discovery matters and dence 3d ([982), Discovery and Dcpositions, Sec- an excessive damage award. Following a hearing, tion 2S. Management of the discovery prncess lies the court orciruled the motions finding that Zinn sulely within the sound discretion of the trial court. had failed to show that Leach did not make a good See State, ei rel. Doggett, supra, at syllabus 1; faith effort to setde the case and Leach had failud to Sregawski v. Cleveland Aneslhe.via cstablisb any irregularities warranting a new trial. (1987). 37 Ohio App.3d 78: Smith v. Klien (1985), Zinn then filed a motion pursuant to Civ.R. 15 for leave to file a supplemental petition to recover insurance proceeds to satisfy his judgment against Zinn. Shortly thereafter, Leach filed his appeal to this court. The trial court tteferred ruling on Zinn's supplemental petition pending the outcome of the appeal. Zinn then filed his appeal and cross-appeal. The mattcr is now before us on a variety of alleged errors. 11 Group. Inc. 23 Ohio App.3d 146. Absent a palpabie abuse of that discretion, a decision granting or denying a discovery request will not be disturbed by tlre revicwing cotut. State, ez ret. Daggett, .supra, at syllabus 1; Smith, supra. See, also, Aos.smmt v. Roanrnnn (19751, 47 Ohio App.2d 103; Cri.s.s v. Kenl (C-A. 6, 1988), 876 F.2d 259. The record before us indicates that before instituting an action, Zinn sent Nationwide on June 6, 1986, a packet of infonnation containing photographs, medieal reports and cconomie loss documents. Zinn sent Nationwide another packet of doc- EXHIBIT G tfJ 2008 Thomson/West. No Claim to Orig. U.S. (iovt. Works. Page 77 Page S Not Reported in N.E.2d Not Reported in N.E.2d, 1990 WL 187466 (Ohio App. 2 Dist. ) (Cite asr Not Repuried in N.E.2d, i 99(I WL 187466 (Ohio App- 2 Dist.)) uments on March 6, 1987. This packet contained mand fur production placed on Zinn the burden of medical reports from Drs. Buu, Roberto and providing all documents relevant to Leach's evalu- DuVall, progress reports from Mark Main, L.P.T., ation and preparation of his defense. Yet, Lcach and a wide variety of econutrtic loss documentation. could have avoided this quandary by pursuing other Further, on Septetnber 15, 1988, Nationwide's attor avenues of discovery that would narrow and idenii- ney acknowledged, by Ictter, receipt of Zintis in- fy the issues involved, i.e., deposing Zinn and his come rnx returns. Leach nevertheless argues Ihat witnesses, or rnoving to compel production of docu- Zinn refused to comply fully with his discovery re- ments sooner than six weeks before trial. This he quest. He alleges that the trial court's refusal to did not do. If Leach was prejudiced by a lack of cornpel discovery, issue a protective order, and sus- diccovery, it was do more to his own conducl rhan tain his motions in limine, was crror. any obstruction of the thscovery process by his oppunent Although attomeys have a duty to cooperate in the counsel. Civ.R. 34 is subject to the constraintt of We conclude that the trial court did not abuse its discretion in overruling the motion to compel discovery, the protective ordcr, or the motions in limine. Leach's first assignment of error is over- C'iv.It. 26, which speaks of avoiding undue burden. ruled. discovery process, cf., Royal Indemnity Companv v. J.C. Penny, et al ( 1986), 26 Ohio St.3d 31, tbey are not required to act as investigamrs for opposing Broad form discovery requests are not favored becausc they frequentty burden the opposing patty B. Zinn's Closing Argument with an obtigation to engage in an inquiry beyond facts known to him. Thus, one party is compelled to Leach states in his second assignment of error: act as an investigator for the other, with the party seeking discovery possibly "taking undue advantage of his adversary's industry or efforts." C iv.R. 16(A). This distorts the discovery proce.ss by relieving the movant for discovery of the burden to pursue diligently those avenues whieh will narrow the issues and provide use6rl inrotmatian. Here, Leach 9led a broad and categorical discovery rcquest on March 30, 1987. No discovery order was MISCONDUCT OF COUNSEL FOR PLAINTIFFS-APPF.LLEES OCCURRED IN FL NAL ARGUMENT TO THE JURY THAT DEFENDANT-APPELLANT DID NOT CALL DR. PAULSON OF COLUMBUS, AS A WITNESS AND DID NOT PRODUCF MEDICAL RECORDS, AND THE COURT ERRED IN OVERRULING THE OBJECTION OF COUNSEL FOR DEFENDANTTO SUCH ARGUMENT. sought until Lcach ntovcd to compel production on January 23, 1989-atmost two years after the filing Attomeys have broad latitude in fashioning closing of the complaint or a mere six weeks before trial. In arguments. However, that latimde has limits. It is the two years between answering the complaint and fundamental that a closing argument bc confined to Gling his motion to compel, Leach did not depose the questions at issue, the evidence presented, and Zinn or any other witness and did not pursue any the deductions and inferences to be reasonably othcr avenues of discovery. Meanwhile, Zinn sup- drawn from the evidence. Sce, Denv. Reud ( 1895). plied Leach with many of the documents requcsted 52 Ohio St. 519: Cvfley v. Slrenk (1974), 39 Ohio and provided authorization tn obtain such addition- App.2d 156, at syllabu.s I; Cu.rnmano v. Pepsi-Cola al medical records as Leach might want to have BottRng Cn. ( 1967), 9 Ohio App.2d 105. A closing from those who provided care to Zinn, who were argument is improper if it argues facts outside the known to Leach. record, or makes assertions or attempts to draw inferences not supported by the evidence. Hertnan v. *6 Leach's mliance on a broad and categorical de- EXHIBIT G 0 2008 Thomson/West. No Claim to Orig. U.S. Govt. Works. Page 78 Not Rcponed in N.E.2d Not Reponed iu N.F.2d, 1990 WL 187466 (Ohio App.2 Dist.) Page 6 (Cite as: Not Etepot-tcd in N.E-2d, 1990 WL 197464 (Ohio App. 2 Dist.)) 7'ep1iL ( 1925), 1 13 Ohio Si 164- encc wa.c a singular occurrence which took placc During rebu[tal argurnent, counsel for Zinn stated: circumstances and the substantial evidence support- MR. SMALLEY: Thatilc you, your Honor. Ladies and gentlemen, the defendant has suggested what judiced by the reference. evidence we didn't produce. Let me suggest wc produced virtually all the cvidence in this case. The defendant wifl huve (vic) (he npporlunily ro look for overruled. during rcbuual argument. Given thc totality of thc ing Zinn's claim, we cannot say that Leach was pre- Leaeh's second assignment of error is, accordingly, and get any prior medical records and had four year.c to have plaintiff esamined hv lheir poctor, Dr. Paul.von in Cblumbu.c. They didn't ca!! Dr. Paul.son. Why nol7 They didn't prnduce any prior rnedical records froni 1953 to the present time. C. Medical Causation Testimony by a Physical Therapist Zinn states in his third assignmcnt of crror: THE TR]AL COURT ERRED IN PERMITTING THE TESTIMONY OF A PHYSICAL THERAP]ST Tl"IAT IN 'rHE OPIN)0N OF 111E PHYSIC- MR. BEITZEL: Objection. TIIE COURT: The objection is overruled. The comment is permitted to stay. You may proceed. (Emphasis added) (Tr. 476-477). At no tirne during the trial did either party refer to Dr. Paulson or present any report he may have compiled for the defense. AL THERAPIST, AND BASED ON "REASONABLE DEGREE OF CERTAINTY;' "fHAT THE ACCIDENT WAS THF DIRECT AND PROXIMATE CAUSE "OF THE PROBLEMS FOR WIIICH (HE HAfI) BEEN TREATING MR. ZINN." At the deposition of Mark Main, L.P.T., the follow- Zinn's reference to Dr. Paulson's abscnce was im- ing colloquy took place: proper as it sought to draw an iuference not supportcd by evidence in the record. While Zinn correctly Q. '*• I want to ask you to assume certain things. states that counsel could refer to the opposing party's failure iu call a modical cxpert wbo examined a plaintiff for the defense, see, Pennr v. Tlrurrnnn (1972), 34 Ohio App.2d 190, it is equally correct that the record must cstablish, as condition precedent to suctt a reference, that the medical expert in fact exatnined lhe plaintiff for the defense. ld. at 191. Therc was no such evidence in the record. Thus, it was improper for counsel to comment on lhe absence of Dr. Paulson. Cf., Knnn.c v. Vnlorclri (1963), 2 Ohio App.2d 198. -7 Ilowever, we eannot say that Zinn's comment was prejudicial. Notwithstanding error in allowing the reference, Leach fails to show prejudice; that is, that but For the enor the outcome of the trial would, in all probability, have bcen different. Cf., Smir/r e. Assuming this accident, that subsequeut history, and the history that I'm asking you to assume to be vue, that the man had no neck and back problems before this accident, then considering upon thosc things your cxpertisc, experience and skill as a therapist and your fmdings and objective evidence of on-going injury or injtuy to the date of this last exarnination in 1989, do you have an opinion, Mr. Main, within a reasonable degree of certainty as to the direct and proximate cause of the problems for which you have becn treating Mr. Zinn. MR. McDANIEL:Objcction. THE WITNESS: Yes, I would say it's as a result of the accident. Fle.dier (19671. 12 Ohio St.2d 107. Here the refcr- EXHIBIT G 0 7009 IhomsonlWest. No Claim to Orig. U.S. Govt. Works. Page 79 Page 7 Not Reported in N.E.Zd Not Reported in N.E.2d, 1990 WL 187466 (Ohio App. 2 Dist) (Cite as: Not Reported in N.E.2d, 1990 WL 187466 (Ohio App. 2 Dist.)) MR. McDANIEL: **' Well, okay, I will try to discuss thc subject. Numbcr I, I objcct to this witness, the physical therapist giving upinion evidence on maGcal causation. ( Deposition of Mark Main, L.P.T., at 49-50). R.C. 4755.40 pruvides, in pan: (A) "Physical therapy" means the evaluation and trcatment of a person by physical measures and the use of therapeutic exercises and rehabilitative procedures, with or with out assistive devises, for the purpose of preventing, correcting, or alleviating any disability. *'' Physical therapy does not include the diagnosis of a patient's disability the use of Roentgen ray.c nr radium for diagnn.ctic or (hera- caused by the coliision. Dr. Aftab Butt testiGcd that the penxtanent scarring, numbness and tightness of Zinn's scalp resulted from the accident ( Deposition of Af)ab Butt, M.D., at 24). Dr. Michael DuVall testilSed that Zinn's pcrmanent hearing and coordination problems resulted from the accident (Deposilion of Michael DuVall, M.D., at 66). Dr. Mark Roberto testified that many of Zinn's injuries and later complaints resulted, either primarily or secondarily, from the accident. Leach presented no evidenee to contradict these conclusions. We concluded that Leach was not prejudiced by the medical causation testimony of Main. Absent such a showing of prejudice, we will not disturb the decision of lhe trial cuun. See, ,Smith, supra. Leach's third assigoment of error is overruled. peutic purpo.se.c, or the use of electricityjor caulerizatinn orother.surgical purpo.ses. Yhy.sical therapy D. Motion for a New Trial includes physiotherapy. (B) "Physical therapist" rneans a person who prac- Leach's founh assignment of error states: tices physical ther-apy as dcfines in this section, and includes physiothcrapist. (Emphasis added) In Burrevs v. Park Cycle & Marine, lnc. (Nov. 7, 1988), StarkApp.No. CA-7492, unreported, the Court of Appeals for Stadc County concluded tbat R.C. 4755.40 precludes physical therapists from giving medical opinions. The Stark County Court of Appeals found that a physical therapist could not "wander outside the statute to give a medical opinion as to perrnanent injury t.]" Id. at 4. THE TRIAL COURT ERRFD IN OVERRULING MOTION OF DEFENDANT-API'ELLANT FOR (A] NEW TRIAL. Gmnting or denying a motion for a new trial lies within the sound discretion of the trial court. See, Ludlo+v'.r Fleir.v v. CGdherLvon (1829), 4 Ohio 5; Beatrr• v. Harcher (1861), 13 Ohio St. 115; Steiner c. Custer (1940), 137 Ohiu St. 448; Krcici v. 1/alak (1986). 34 Ohio App.3d 1. Thus, whether the trial court errod in disposing of such a motion is deteern- '8 Though R.C. 4755.40 does not speci6ca(ty apply ined under the traditional abuse of discretion stand- to issues of witness competency, we agrce with the ard; that is, was the coun's attitude unreasonahle, view of Bnrress, cupra, that the statute prooludes arbitraty or unconscionable. Steiner, supra. See, physical therapists from giving diagnostic opinions also, Ear.con v. Clevelnnd Acceptance Cnrp. (1969). in testimony as well as in the form of patient advice 17 Ohio App2d 239. and communication. Therefore, we must conclude that the trial court errcd in admitting that testimony. IIowevcr, the enor does not merit reversal unfess it was prejudicial. The record here indicates that sutbcient credible evidence was presented beyond Main's tcstimony m support the conclusion that Zinn's injuries were EXHIBIT G Leach filed a six branch motion for a new trial. The grotmds offered in support of the motion included Zinn's failure to comply with the discovery requests (Civ.R. 59(A)(l)), misconduct by Zinn during discovery (Civ.R. 59(A)(2)), excessive damages (Civ.R. 59(A)(4)), a judgment unsupported by the wcight of the evidence (CivR. 59(A)(6)), and vari- (D 2008 Thomson/Wcsl. No Claim to Orig. U.S. Govt. Works. Page 80 Pxgc 8 Not Reported in N.F.2d Not Reponed in N.fi.2d, 1990 WI_ 187466 (Ohio App. 2 Dist.) (Cite as: Not Reported in N.E-2d, 1990 WL 187466 (Ohio App. 2 Dist.)) ous errors of law by Ihc trial cnurt conccming discovery rclated matters (Civ.R. 59(A)(9)). In the alternativc, Leach sought in branch six of his motiun a seventy-five per cent remittitur of damages. Upou the recovery of a Final judgment against any ISaving revieweci the record, we conclude the biai of action arose, the judgment creditor or the suc- court did not abuse its discretion in overmling the cutsor in inrere.st iv entitled fo have the insurmrce motion forr a new trial- Nothing in the record sug- money provided fOr in the insurance contract t** f;mr, person, or corporation by any person *'' for loss of damage on account of bodily injury or death •*• if the defeadant in such action was insured against loss or damages at the time when the rights gests dtat the trial court's disprnition of this tnattcr applied to the .cati.rjaction of the judgment. If the or unconscionable- judgment is not satiafied within thirty day-r after it was uureasonable, arbitrary Steiner, supra. As we noted above, any alleged dis- is rendered, the judgment creditor * * * to reach covery failures resulted as tnuch from Leach's con- and apply the insurance money to the satisfaction duct as from Zinn's alleged refusal to comply with of the judgment, may file a.supplemental petition in the discovery request. Further, givcn the extent of the action in which said judgment wa.c renderer( in Zinn's injuries, his loss of income, aud his future which the in.curer is made a new purry defendant * medical expenses, we cannot say the damage award ` * (Emphasis added) was eacessive or the result of passion or prejudice. R.C. 3929.06 provides a mcans to satisfy an exist- See, Civ.R. 59(A)(4). ing judgment against a tortfeasor from funds gener- '9 We eoncluded that the uial cuurt did not abuse its discretion in overruling Lcach's Civ.R. 59 ntotiort for a new trial or Iris alternative request for remittitur- Leach's fourth assignmcnt of error is, ac- ated by his insurence contract with his own insurer. corrlingly, overruled. is properly brought by the judgment creditor by Because the funds are held by the insurer, a separate legal proceeding is required to determine the contract and its coveragc. That separwte procecding way of a supplemental complaint. Il. When the trial court deferred a decision on the supplemental complaint brought pursuaot to R.C Appellant/Cros.c-Appellant Zinn'.r A.csignment ojEr- 3929.06, it did not stay any right of execution rorx arising fmm the judgment held by Zinn. Thatjudgment ran only to Leach, not to ihe insurer Nation- A. Supplemental Pctition wide. Therefore, the court was not required to order a supersedeas bond in connection with its order of postponement, which deferred a decision on the The assignment of enor raised in Zinn's appeal supplemental complaint until the merits of this ap- states: peal are decided. We see no error. TIiF. TR]AI. COURT ERRFD BY STAYiNCi APPELLANT(S]-l'LAINTIFFS' ATTEMPTS TO EXFCUTE ON ITS JUDGMENT, VIA A SUPPLEMENTAL PETITION, WHEN NO SUPERSEDFAS BOND WAS FILED BY OR ON BFIiALF OF 'fHE APPFLLFFS-DEFENDANTS- The assignment of crror will be overruled- 7.inn Bled a supplemental petition pursuant to R.C. 3929.06. This provision states, in part: EXHIBIT G B. Prejudgrnent lnterest Zinn statcs in his cross-appeal: THE LOWER COURT ERRED IN FAILING TO GRANT PRF,-JUDGMENT INTEREST 'f0 THE PLAINTIFF WFIFN DFFFNDANT-APPFLLANT ® 2008 ThomsorJWest. No Claim to Orig. IJ S. Govt Works. Page 81 Not Reported in N.1?.2d Not Reported in N.E1d, 1990 WL 187466 (Ohio App. 2 Dist) (Cite as: Not Neported in N-E.2d, 1990 WL 197466 (Ohio App. 2 Diei.)) WAS DETERM)NED I3Y SUMMARY IUDGMGNT TO BE NEGLIGRNT, TtIE PLAINTIFF IIAD TEIIRTF.GN 'I'IIOtJSAND FNE BUNDRED DOLLARS ($13,500.00) IN MEDICAI_ EXPENSES WI'fH PERMANENT INJURIES AND NO OFFER WAS MADE IN SETTLEMENT UNTIL ONL• I-IUNDREI) THOUSAND DOLLARS ($100,000.00) WAS OFFERED TO TIIE PLAINTIFF FIVE DAYS BEFORE TRIAL. I'age 9 evaluated hi.c ri.ckc and potential liahility, (3) not attempted to unnecessarily delav anv of tlte proceedings. and (4) made a good faith monetary settlement offer or responded in goodfaith tn an offer from the other party. If a party has a good faith, objectively reasonable belief that he has no liability, he necd not make a monetary setttement offer. (Emphasis added) See, also, Holman v. Grmrrhietv Hasp. d- .14et1. Clr. R.C. 1343.03(C) provides; (1987), 37 Ohio App.3d 151, 158. Whether the movant bas met this burden is a factual issue. A tri(C) Interest on a judgment, decree, or order for the al court's decision awarding or denying prejudg- paytnent. of money rcnde.red in a civil action based ment interest under R.C. on tortious conduct and not settled by agreement of disturbed if supported by competent evidence in the the parties, shall be computed from the date the record cause of action accmed to the dateon which Lhe (1985). 28 Ohio App.3d 14. 1343.03(C) will not be Edger.snn r. Cleveland Fle. 11hunt. Cn. ntoncy is paid, j upon motion of any party to the action, the court determines at a hearing held sub- We note that R.C. 1343.03(C) does not require a sequent to the verdict or decision in the action that showing of "bad faith" by the defendant. Rather, as the party required to pay the money failed to make observed in a good faith effort to .settle the rare and that the perbc, 1nr. (1984). 18 Ohio App.3d 39, 41: Doilev v. ;Vatinnwide Demolition party to whom the money is to he paid did rwt fail m make a good faith effort to settle the cave. '10 As a condition precedent to receiving prejudgment interest, the movant must make a two-part showing. First, the movant must establish, ( I) a valid judgment or decree ordering the payment of An "effort to settle" can be something less than °good faith efTort" and still not be "bad faith effort:" The mere failure to do anything towards settlement '•• would be a failure to make a "good faith effott to settle" but might well be short oC a "bad faith e(fort" to settle. inoney as compensation for tortious conduct, and (2) a civil action not settled by the parties. Sce, Vanrlerhoo(v. Generat rtcc. Ins. Group (1)87), 39 Ohio App.3d 91. Thus, the party secking prejudgment interesL need only establish a lack of good faith, not bad faith. Whether a party has not acted in good Caith to settle Sccond, the movant must then establish that the a case is a ract-sensitive inquiry that must address party subjeU to a civil judgment for tortious con- the circumstances of each case as well as the relev- duct failed to make a good faith effort to settle the ant faetors set out in Kalain v. Smith, supra. De- dispute. In Kalain v. 5'mitb (1986). 25 Ohio St.3d terminations may vary according to the nature of 157, the Ohio Supreme Court provided severnl the claim, the adversary role of the party concemed, facton relevam to assessing whether a party failed and the means available to the party to determine to make a good faith effort to settle the dispute. The his position in the litigation. Court stated in the syllabus: A party has not "Failed to make a good faith effort to settle" under R.C. 1343.03(C)ifhe has (1) fuRy cooperated in di.ccovery proceedings, (2) rationallv EXHIBIT G In this case the negiigence and liability of Leach was clear from the date of the accident on March 25, 1985. Leach collided with Zinn's vehicle at an intersection at which Zinn had the right-of-way. © 2008Thornson/West, No Claim to Orig. U.S. Govt. Work.s. Page 82 Not Reportcd inN.E.2d Not Rcportcxl in N.E.2d, 1990 WL 187466 (Ohio App. 2 Dist.) (Cile as: Not Reported in N-E-2d, 1990 WI. 187464 ( Ohio App. 2 Dist.)) Page 10 Zinn and his wife gavc full suttcments about the ac- effort to obtain discovery, athcr than a latc motion cidcnt. I_each claimed ttmt he could not rcmernber to compel production of the documents. Yet, by wltether he ignored a b-affic control device, though that time Nationwide had thc information many he did enter a plea of no contest tu that charge. times over. In truth, thc demand for production was etnployed less as a toul for discovery thnn as a 11I As early as April 8, 1985, two weeks after the me-ans to finestall settletnent. accident, Nationwide's adjuster concluded tbat the company would owe damages. In Febmary 1987, an adjuster conciuded that the company had a policy limits exposure, but declined to settle because the company lacked "information" on the claitn. 'rhe trial court t:ntered summary judgmeut lirc Zinn on liability on August 15, 1988, and in December 1981T, Zinns own insurcT paid him $300,000 in underinsured coverage. Yet, Leech and Nationwide made no offer to settle the case urrtil March 1, 1989, a mere five days before trial and altnns-t four years from the date of the accident. The record also reflects a failure of Leach and Nationwide to address the progress of the litigation. Four difTerent attorneys were assigned, in succession, to represent Leach. Two of thuse were salaried employees of Nationwidc. Two different adjusters wcrc assigned. As the matter moved from person to pcrson, past demands were renewed and evaluations repeated. Documents werc lost or nrisplaeed. Communication broke down. No cffort was made to reply to Zinn's demands for seulement, and no responsibility wa.c taken to move the matter to closFN• urc. Zinn made every cffort to settle the case by providing Leach and Nationwide extensive information Leach and Nationwide hnally made an offer to and documentation. Numerous reports were settle the claim fox "policy limits" only five days befom triat Yet, the information then bcfore thcm conceming their risks and liability had been available to thcm or in their hands for months or years. The record re[]ects no reason to support that delay. Rather, it compels a conclusion that Leach and Nationwide wished to rctain their capital for as long as provided from Zinn's physicians, and the substance of their opinions conceming their diagnosis of Zinn's injuries, their treatment of him, and his prognosis for recovery, did not change through the course of the claim. Complete medical expense information was provided. 9uppurt for prospective income loss was also provided. This information substantiated Zinn's fau sepamte dernands for settle- possible while causing Zion and his counsel to incur more expense and grcater inconvenience. _ ment. Leach and Nationwide ignored those de*12 R.C. 1343.03(C) has two purposes. It is inten- mands. ded to relieve the courts of the burden of litigating Nationwide failed to utilize thc tools of discovery cases that should be settled by requiring litigants to availablc to it to Icam the additional information it address their sculemcnt obligations realistically and complaincd that it lacked. No deposition was conducted of Zinn or his wife. No depositions were in good faith. It is atso intended to deny a recalcitmnt litigant the benefits he has realized in retaining takcn of Zinn's physicians. No consistent effort was funds long after he knows he must ultimately pay made to use the releases obtained from Zinn to get medical or oconornic data. These measures could them over, and to give his adversary who has acted have been used to narrow and focus the issues in- on tbe funds he would have realized had they been volved in Leach's potential liability. Instead, Nationwidc presented Zinn only with a broad fortn, paid out when the obligation was clear. categorical demand for production of documenls which was so openended that it might never be satisficd. Leach and Nationwide made no additional EXHIBIT G in good faith compensation in the form of interest No party is required to settle a claim against his better judgment. Howevcr, R.C. 1343.03(C) penalizes a party who fails to act in good faith to bring U 2008 Thomson/Wcst. No Claim to Orig. iJ.S. Govt. Works. Page 83 Page 11 Not Rcported itn N.F..2d Not Reported inN.F.:?d, 1990 WL 187466 (Ohio App. 2 Dist.) (Cite as: Not Reported in N.E.2d, 199i1 Wl. 137466 (Ohio App. 2 Uist.)) the maue.r to closure. We conclude t}tal Lcach and 15, 1988. Nmlonwidc failed to wake that good faith cffort. Ohio App.,1990. "ihcir conducl did not meet the obligations of co- Zinn v. Leach operation and rational evaluation of risks and po- Not Rcported in N.F,.2d, 1990 WL 187466 (Ohio tcn(ial liabilily sct out in Katain v. Smirh, supra. App. 2 Dist.) The record is clear that Ihey purposely delaycd the procccdings through unproductive discovcry calcu- END OF DOCUMENT lated to protect them from their settlement obligations. llieir last-minute offer to settle thc case on information known to them for umnths or years lacked good faith. Lastly, Leach and Nationwidc cannnt point to an objectively reasonable belicf that they lacked liability, and they could have had no such belicf from the time of the summary judgment on liability in August, 1988. Wc find that the trial court acted unreasonably in denying Zinn's motion for prejudgment interest. We hold ihat the triat court thus abused its discretion and crred thereby to the prejudice of Zinn. 111 Canclusion Tbe judgment of the trial court will be af6rmed on all assignments of error of Appellant and CrossAppellant, exccpt as to Cross-Appellant's assign" atent conceming prcjudgment interest, on which the judgment af the trial court will be reversed. The mattcr will he remanded to the trial court for entry of a judgment for prejudgment interest as provided by R.C. 1343.03(C) in favor of Appellee/ Cross-Appellant Zinn against Appellant Leach. W OL F F, P.J., and 13 R(1G AN, J. , concur. FN* Leach and his wife advised the court by motion and affidavit 6led March 27, 1989, that until early 1989 they had no contact with any attorney providaA them by their insurer, Nationwide, and that they were ttnaware of the sumrnary judgment on liability rendered against them on August EXHIBIT G 92008 ITomson/Wcst, NoClaim W orig. U.S. Govt. Works. Page 84 V\Te_q1aK Not Rcpurted in N.E:Ld Page I Not Reported in N.E.2d, 2003 WL 22390095 (Ohio App. 10 Dist.), 2003 -Ohio- 5582 (('ite as: Not Reported in N.E.2d, 2003 WL 22390095 ( Ohio App. 10 Dist)) GI Surte ex reL Hmnilityl{onse v. Indtutrial Cum'n of Ohio Ohio App. 10 Dist.,2003. CHECK 0I110 SUPREME COURT RULES FOR REPORTING OF OPINIONS AND WEIGHT OF LEGAL AULIIORITY. Court of Appeals of Ohio;Centh District, Franklin County. STATE ex rel. IIUMILI7YIIOUSE, Rclator, v. die tiolland, Respondents. No. 03AP-t. Decided Oct. 21, 2003. Employer sought writ of mandamus ordczing lndustrial Cuinmission to vacate its order awarding perdisability ( PTD) compensation to 72-year-old workers' componsation claimant Magistrate issued'a decision, and cmployer filed objections. The Court of Appeals, Sadlcr, I., held that: (1) rcport of claimant's treating physician constitutcd "somc evidence" of claimant's physical inability to engage in suslained, remunerauve employment; ( 2) valuation of tton-medical/vocational factors was not necessary, as claimant was medically unable to perform any sustained, remunerative employmnnt; and (3) magistratc was not required to address employer's contention that claimant's advanced age was sole cause of her inability to work. Objeetions overruled; writ of mandamus denied. West Ilcadnotes 111 Workers' Compensation 413 4D^1639 413 Workers' Compensation 413X V I Proceedings to Secure Compensation 41 } X V l('.J ) Weight and Suffrciency of Fvidcnce EXHIBIT G pcnsation 413k 1615 Compensatiort for Tntal Disability in General 413k1639 k. Permanent Disability. Most Cited Cascs Report of workeri compensation claimant's treating physician, which conlained both objective and subjective physical findings and an opinion that, medically, claimant was permanently and totally dis, abled, constituted "some evidenec" of claimant's pbysical inability m engage in sustained, remunerative employment, as was required to award per- INDUSTRIAL COMMISSION OF OIIIO and Gol- mancnt total 413XV1(N)9 Amount and Period of Com- manent total disability ( PTD) compensation, even though physician had opined just three montlrs carlier that claimant could remm to work within restrictions outlined by occupatiotul therapist. 121 Workers' Compensation 413 C^847 413 Workers Compensation 4131X Amount and Period of Compensation 4131X(B) Compensation for Disability 4137X(II)2 Total Incapacity 413k847 k. Incapacity for Work or Employment Generally. Most C ited Cases Fvaluation of non-medical/vocational factors was not necessary to award permanent total disability (PTD) compensation to workers' compensation claimant who was medically unable to perform any sustained, remunerative employment, even though this inability wvc occasioned by only one allowed condition. 131 Workers' Compensation 413 C^1756 413 Workers'Compensation 413XVI Proceedings to Sccure Compensation 413XVI(P) Hearing orTrial 413XV1(P)6 Findings of Fact and Conclusions of Law by Board, Commission, or Court 413k 1751 Particular Facts and Conclusions 413k1756 k. Famings and Impair- 0 2M8 Thomson/Wcst. No Claim to Orig. U.S. Govt. Works. Page 85 Page 2 Not Rcported in N.1:.2d Not Reported in N.E.2d, 2003 WL 22390095 (Ohio App. 10 Dist.), 2003 -Ohto- S5g2 (Cite as: Not Reported in N.JE.2d, 2003 WL 22390095 (Ohio App- 10 Dist)) ment of Eanting Capacity. Most Citcd Cascs Magistrate was not rcquired to address employcr's contention, in opposing award of permanent tntal disability (PTD) compensation, that 72-year-old workers' compensation claimanis advanced age was sole cause of her inability to work, where uothing in the record demonstrated that cla(mant's age was the sole cause or primary obsrxle serving as a significant impe(iment to rcemployment. trate recommended dtat thc roquestcd writ of ntantlamus be denied. [1]{1 4) Relator filed objections to the magistrate's decision. Therein, rclator argues that the magistrate erred in finding that the January 21, 2002 repon of Holland's treating physician, Dr Williams, constimted "some evidence" of Holland's physical inability to engage in sustained, remunerative employment. Relator argues that, because Dr. Williams Hanna, Campbell & Powell, LLP, and Lori A. had opined just three months earlier, in a report Fricke, for relator. Jim Petro, A0.orney General, and Janine Ifancock dated September 14, 2001, that Holland could re- Jones, for respondent Jndustrial Commission of O}), Law Offices of Dennis E. Ujczn, and Dennis E. occupational Ujczo, for respondent Goldic Holland. sion's order. We disagree. SADLER, J. *1 11 I) Relator, Humility7louse, commenced this original action requesting a writ of mandamus ordering respondent, Industrial Commission of Ohio ("commission"), to vacate its order awarding perrnanent total disability ("PTD") compensation to respondent, Goldie Holland ("ITolland"). turn to work within the restrictions oullined by the therapist, the January 2002 report should not have been relied upon and does not constitute "some evidcnce" supporting the contmis- (15) The January 2002 rcport cuntains both objective and subjective physical findings and an opinion that, medically, Holland is petmanently and totally disabled. Therefore, it constitutes "some evidence" supporting the commissiun's order. That the same physician opined differently several months earlier goes ottly to the weight of the evidence. The com- {12{ Pursuant to Civ.R. 53(C), and Loc.R. 12(M) tnission ascribed sufHcient weight to the January of the Tenth District Court of Appeals, this matter was referred to a magistrate wbo issued a decision 2002 report to rely un it in ordcring PTD compensation, and this was within its discretion. This objec- including findings of fact and conclusions of law. tion is overruled. (Attached as Appendix A.) In her decision, the magistrate found that there was "some evidcucc' to support the cotnmission's detcrmination tbat Holland was incapable of performing sastained, remunerative employment. She detcrmined that though the evidence was susceptible to interpretation wi(h respect to whether or not Holland was capable of sedentary or light work, the commission's interpretation was within its discretion. (j 3) The magistrate also found that because the evidence established that medical factors alone render Holland incapable of sustained, remunerative employment, the commission was not required to evaluate non-medical factors pursuant to Slare e.r rel. Slephen.ron i. Jnnca. Comm. (1987), 31 Ohio St.3d 167. 509 q.E.2d 946. Tberefore, the magis- EXHIBIT G [2](1 b) Relator also argues that the magistrate erred when she concludcd that the commission was not required to discuss non-medical factors pursuant to Srephen.ron, supra, and that the commission was correct in relying on the case of Srole e.x rel. Galion Afrg. Div. Dresser Jndnarrie.a, Jnc. v. Hargood (1991). 60 Ohio St.3d 38, 573 >I.E.2d 60 in failing to do so. Aa evaluation of the non-medical/vocational factors is not necessary when the claimant is medically unable to perform any sustained, remunerative employment, even if this inability is occasioned by only one allowed condition. Store e.r rel. Speelrnan v. lnrLrr. Cnnun. (1992), 73 Ohio App.3d 757, 598 N.F,.2d 192. Accordingly, this objection is overmled. © 2008 Thomson/West. No Claim to Orig. U.S. Govt. Works. Page 86 Not Reported in N.E.2d Not Reported in N.E.2d, 2W3 WI. 22390095 (Ohio App. I0 Dist.), 2003 -0hiu5592 (Cite as: Not Reported in N.F..2d, 2003 WL 22390095 (Ohio App. 10 Dist)) Page 3 Findings ofFacr *2 [3]11 7) Finally, relator argucs tbal the ntagistrate erred in not addressing relator's contention that Holland's advanced age was the sole cause of her inability to work. Finding nothing in the record to demonstrate that Holland's age was the sole cause or primary obstacle serving as a siguificant impediment to reemployment, we find no error in the magistrate's failure to specifically address this argn- (, 10) 1. In March 2001, Guldie llolland ("claimant") was lifting a resident of ilumilityAouse from the floor when she sustaincd an injury to her back. licr workcrs' cutnpcnsatiori claim was allowed for a c(impression fracture of the lumbar spine at L3. Claimant was 72 years otd on the date of injury. ment. {¶ R) Following an indepe:ndent review of this matter, wc find that the tnagistrate has properly determined the pertinent facts and applicd the appropriatc law. Therefore, we ovetrule relator's objections and adopt the magistrate's decision as our own, including the Ilndings of fact and conclusions of law contained therein. in accordance with the magistrates decision, we deny the requested writ of mandamus. Objections overruled; writ of mandamus dettied. LAZARUS and W A'iSON, JJ., concur. 1' 11) 2. In April 2001, K. Brian Williams, D.O., an orthopedic surgeon, reported as follows: (T 12)"Thcee is apparently a question as to the relationship of Mrs. Ilolland's fracture and her work related activiries. There is no history to suggest any other relationship and the activity of record is certainly consistent and is felt to bc the cause of her compression Fracmre of L3 vertebral body." tJ 13) 3. On September 6, 2001, claimant was evaluated in regard to her functional capacity at Keystone Rehabiliiatiun Systems, at which time she APPENDIX A felt that she could perform many of the tasks that she used to campiete prior to her injury. 'fhe occu- MAGISTRATE'S DECISION pationat thetapist opined that claimant retained the capacity to carry ten pounds occasionally, sit frequently ( although she had to change her position as Rendcred on May 29, 2003 pain in her low back began to increase), drive a car for transportation to appointments, etc., perform fine motor skills and fingering frequently, stoopt IN MANDAMUS bend occasionally, and kneel one to two times per day. ClaimanC was able to perform a variety of lim- fj 9; In this original action, relator, IIM Health ited lifting and reaching activities. The therapist Services, known as 1lumilityHouse, asks this court made the following recommendations: to issue a writ of mandamus compelling respondent Industrial Commission of Ohio ("commission") to vacate its order awarding compensation for permanent total disability ("PTD") to respondent Goldie Holland and to deny the requestcd compensation or, in the alternative, to give further consideration to the PTD application under Slure es rel. Srephen.son v. /ndu.s. Cornrn. (1937). 31 Ohio St )d 167. 509 N.E.2d 946. •3 (J 141°Sascd upon the results of this evatuation, Mrs. Holland should wurk at a position in the Sedentary level of Physical Demands, (I to 10 N Occasinnally, Negligible weight on a Frequent or Coastant basis.) She did have greater strength in the lif) that used her leg strength, being in the Light level when lifting 15 inches above floor level (1I to ?0M Occasionally, bnt no Frcqncnt lifts from this level.) She sbould be given the opportunity to change her postures every 30 minutes, as she can be EXH IBIT G Q 200R Tlromstnr/Wcst. No Claim to Orig. U.S. Govt. Works. Page 87 Not Rcponcd in N.L-.2d Pagc: 4 Not Reportu] in N.F..2d, 2003 WL 22390095 (Ohio App. 10 Dist.), 2003 -0hio- 5S82 (Cite as: Not Reported in N.E.2d, 2003 WL 22}90095 (Ohio App. 10 Dist.)) on her fecl or sit 30 minute intcrvals, and lben pain ated with simple activities of daily living. becomes intense if she does not change her pusture. She is limited to 10 minute intervals of Standing ll 20) "X-rays taken 5/21/01 showed improved stationary. She would benefit from kecping taeks density through the L3 venebral body with appczr- within Near Reach (within 16" of her body) to min- ance of a stable hcaling fracture. IIrace was contin- imize discomforl from reaching and allow her to ued at that point as wcll. Therapy was initiated at use her hands on a Frequent basis. She could usc that time at Rebab Network with slow progression Hend/Stoop or Rarely a 1/2 Kneel to perfonn low related to the injury itself, patient's age and also symptums. Thcrapy was progresscd in light of the or floor level tasks.` apparently hcaled fracture, though the patient con- {¶ 15) The occupational therapist furYher opincd tinued tn complain of low back pain and restrictions tltat, if claimant could be taken back at a modified duty, lifting more than ten pounds occasionally and gtven the opportunity ut sit occasionally, while also following all the other reconrmendalions, claimant "may be able to participate in a Gradual Return to of activities inctuding difficulty even sitting because of associated back pain. *4 11 21) 'Functional capacity evaluation was recommended and obtained, repnrt dated 916/01. Significant impairments were listed here as weil as Work progrnm, bcgituting at 4 hours per day and slowly increas[ing] to a full 8 haurs pcr day as her mther prohibited outline of recommendations for tolermrce improves " limitatinns. t'♦I 161 4. On September 14, 2001, claimant's orthopedist, Dr. Williams, released her to return tu work within the restrictions outlined in the occupational The patient was hurting a lot in her low back sub- 11 22) "'fhe latest follow up date was 12/12/01. jectively at that time with actually an increased intensity. Clinically observed was a slow, careful evaluntion. gait, pain on palpation of the lurnbosacral and sac{l 17) 5. In December 2001, claimant visited Dr. roiliae areas, increased lwnbar tone with some ten- Williams, rcpoRing increased intensity of pain. On demess, and signi6cant limitation of back mobility. January 21, 2002, Dr. Williams reported, in part: )9 1 R)" •`* Mrs. Holland's injury of 3/23/0l is recalled lifting a resident from the floor at f7umilityNouse. * * * X-rays of 3/26/01, Medical Imagining Network, showed a eompression fracture {1 23) "Based upon this evaluation and all the information previously outlined, it is my feeling that Mrs. Holland is permanently and totally disabled due to allowed conditions which are felt to be directly related to Ihe injury of record." of the L3 vertebral body. Bone scan dated 4/9/01 showed increased activity of L3 vertebra, corresponding to compression defonnity seen on plain 11 24) 6. In February 2002, claimant filed a PTD application stating among other things tJtat she was bom in May 1929 and 6nishe(i eight years of films. school in West Virginia, leaving school in about (1 19) "The patient was subsequently referted to 1945 to wnrk to help support her family. She wa.c Al3l Orthotics fur placement of a back brace, A certified as a nurses aide in 1990. Freeman corset was fit 4/19/01. Patient waa inslructed to continue to wear this and was follow up on a .serial basis with follow up X-rays of the tumbar spine to assess the status of the vericbral fracmre. The brace alleviated some of the patient's discomfort, however, not all of it, which was even associ- EXHIBIT G {125) 7. Additional medical and vncational reports were submitted. (9 26) 8. In September 2002, a hearing was held before a staff hearing oHicer ("SHO"), who found the January 2001 report of Dr. Williarns to be per- <> 2008'fhomson/West. No Claim to Orig. U.S. Govt. Works. Page 88 Not Reported in N.F..2d Not Reported in N.E.2d, 2003 W L 22390095 (Ohio App. 10 Dist), ?003 -Ohio- 5582 Pagc 5 (Cite as: Not Reported in N-E.2d, 2003 WI. 2239669_S (Ohio App. 10 Dist.)) suasive. Thc SHO found that claimant was medically unable to perfonn any sustained remuncratlvc rcnder the claimant any morc. or less ... able to work.(') employment, based solely on the industrial injury and allowed condition in the claim. Accordirrgly, the S{10 did not procct.^d to an analysis of nonmed '5 (133) "The paymcnt of petmanent and total disability bene6Ls is to commeucc on 1/21/2002, based on the ctaimant's request th-at dte permanent and ical factors: total disability bene6ts commence on sai(i date, and {¶ 27)"It is the finding of the Slaff Hearing Offrcer that this claim has been allowed for: CDMPRF.SSION FRACTURF. L3. (T.1 281 "ARar full consideration of the issue it is the the opinion of Dr. Williams, cited above. (l 34} "it is hrrther ordered that the above award be allocated as follows: 100% ofthc award is to be paid under Claim Number 01-832131. order of the Staff Hearing Oflicer that the Applicalion 61et1 01/31/2002, for Pennanent andTutal Disability Compensation, is GRANTED 'rO TH6 {135} "rhe allocatimt of this award is predicated upon thc said opinion of Dr. Wikliams who attributes all of claimant's inability to work soleiy to the FOLLOWING EXTENT. injury and allowed condition in this claim. Said {¶ 29) "Parm:utent and mtal disability compensa- opinion is found persuasive. tion is heteby awardcd from 1/21/2002 `' *. 1130) "This Staff Hearing Officer finds that it is {l 36) "All relevant evidence has been reviewed, and considered, in rendcring this de- not nccessary to consider the claimant's disability cision."(Emphasis sic.) factors since [he claimanl has reached rnaximttm medical improvement and is medically unable to perform any sustained remunerative cmployment {J 37) 9. The employees request Cor reconsideration was denied. based upon the 1/21/2002 opinion by Dr. Williams, D.O., an orthopedic surgeon. 1131) "This Hearing Officer relies upon the case of Sta1c ex rc1L Calinn Mfg. Uiv., Dresser bulusIries, Inc. v. Hat^goot! ( 1991), 60 Ohio St.3d 38. 573 :V.F.'.d 60, wherein the coutt stated as follows: {¶ 32) °[')A claimant who has mulliple allowed conditions is not required to shaw that each condition standing alone, is work-prohibitive ... While permanent total disability benefits may never be denied sofely on the basis of medical evidence without consideration of Stephenson factors contained in the record, thcre are some situations where an award of such benefits may properly be based on medical factors alone. It would serve no practical purpose for the commission to consider non-medical Cactors in extreme situalions wbcre medical factors alone preciude sustained ¢munerative employment, since non-medical factors will not EXHIBIT G Conclusions ojLaw {l 38) The relevant inquiry in a PTD determination by the commission is whether the injurerl worker is capable of pcrforming any sustained remunerafive cntployment. Stale ex rel. DornJancir v. /rrrhrs. Comm. ( 1994), 69 Ohio St.3d 693, 695, 635 N.F.2d 372;Srme er rel. ;Na.r.s r. Luhec Co.ron. (1996), 75 Ohio St.3d 414, 662 N.E.2d 364. In mandamus, the issue before the court is whether the commission's order was supported by "some evidence" in the rccnrd and the commission provided an adequate explanation of iLs tationale. Srure ex rel, A'oll r. Indrer. Comm. (1991), 57 Ohio St.3(1203, 567 N.F.'d 245. An order supported by "some evidence" must be upheld regardless of whether the record includes other evidence, greater in quantity and/or quality, that supports the contrary decision. S7ute c.r rrcl. I'asr cCS'.T. Exnartion Co. t 1996). 74 Ohio St.3d 373, 376, 658 N.E.2d 1055. d 2008 Thomson/West. No Claim ut Orig. U.S. Govt. Work.s. Page 89 Not Rcpurted in N.E.2d Not Reported in N.F.2d, 2003 WL 2239tyJ95 (Ohio App- 10 Dist.), 2003 -Ohio- 5582 Pagc 6 (Cite as: Not Reported in N.£.2d, 2003 WL 22390095 (Ohio App. 10 Disr-)) (¶ 39} In cases whcre the injured worker rctains a functional capacity). residual fuuctiotmllmcdical capacity for work activities, the commissiun rnust consider not only the claimant:s medical restrictions but must also consider nonmcdical factors such as agc, education and work hislory.Srephen,son,- -Stare ex rel. Gav Y. '6 11 421 The entployer also argues that all thc cvideuce indicates that thc claimant was and is capable of sedentary if not light work. Again, the rnagistrate disagrees. The evidence was susceptible to V1ihm ( 1994). 68 Ohio St.3d 315, 626 N.E.2d 666. interpretation, and the commission's interpretation Ilowever, an explorntion of thc nonmedical/voca- was within its discretion. It is true that, as of tinnal factors is not necessary when the claimant is September 2001, Dr. Williams opined that claimant medically unable tq perform any sustained remu- was able to perfonn limited work within ttte restric- nerative employment. E.g., Stmre ex reL Golinn tions oudined by the occupational therapist. Mfg. Div. Dres.cer lndreNrie.C Jnc. r. Hargond (1991), 60 Ohio St.3d 38. 573 N.G.2d 60'srare ex rel. Snrelmnn v. btdn.s. Comne. ( 1992). 73 Ohio App.?d 757, 598 N. E.2d 192. tlowever, when Dr. Williarns cxamined the claimant in December 2001, she reported that her pain was morc intense. In his report of January 2002, Dr. Williams descrilted claimant's slow, careful gait, and pain and (enderncss on examination. {¶ 401 Here, the commission found that claimant was medically unable to perform any sustained remuneretive employment due to the industrial injury, and the issue before this court is a narrow onewhether that finding was supported by "some evidence" in thu record. The magistrate cuneludes that He also found significant limitation of back mobil- it was- The report on which the commission relied, the January 2001 report of Dr. Williams, constituted "some evidence" to support the commissions decision. Accordingly, a writ of mandamus is not opinion but simply a revision of his opinion bascd warranted. er the patient's increased symptoms were sufficient 1141) The employer argues the decision in Galion opinion was "some evidence" on which the com- Mfg. cited by the commission was inapplicable. The mission could choose to rely. Thc magistrate finds magistrate disagrees, concluding that the principle no basis for removing the report from evidentiary for which the decision was cited has application consideration as a matter of law. Dr. Williams fo- beyond those situations in which the injured worker cused snlely on the industrial injury and the al- ity. Dr. Williatns explained why he believed a t that timc that claimant was unahlc to work. {j 43} Dr. Williams' opinion of January 2002 does not show a contradiction of his September 2001 on a change in the patient's presentation during a subsequent examination. Although reasonable persons could disagree with Dr. Williams as to whethto remove her from the workforce, his medical has multiple allowed conditions. Where a claimant lowed fracmre at L3: there is no mention of any is medically unable to perform sustained remuner- other condition causing disability. The doctoi s gen- ative employment, an evaluation of the vncational ernl rcfcrence to "allowed conditions" in the last ability is pointless, regardless of whether there is sentence does not outweigh his clear focus one allowed condition or ten- A consideration of the throughout the report on a single injurious event claimant's vrxational facmrs is prcmisod on the ex- and a single condition of fmctured vertebra at L3. istence of a residual medicaUfunctional capacity for In sum, the commission as the finder of fact was sustained remunerativc cmployment. See, gener- within its discretion to accept Dr. Williams' opinion ally, Stephen.son; Speelman,supra; see, also, Stare in awarding PTD cumpensation. ex re1. Cnrnna v. Indue Comm. (1998). 81 Ohio St.3d 587, 589, 692 N.E.2d 1017 (indicating that the nonmedical analysis depends on the claimant's EXHIBIT G (1 44) The employer has not met its burden of proving en abuse of discretion by the commission. Accordingly, the magistrate recommends that the ® 2008 Thomson/West. No Claim to Orig. U.S. Govt. Warks. Page 90 Nol Reported in N.E.2d Nol Relwrtcd icr N E.2d, 2{H)3 Wt. 22390095 (Ohio App. 10 DisL). 2003 -Ohio 5582 (Cite as: Not Reported in N.E_2d, 2003 WL 22390095 (Ohio App. 10 Dist)) Page 7 court deay thc rroqurated writ. Ohio App. 10 Dist.,2003 State cx rel. Humility Ilouse v. Industrial Cotn'n of Ohiu Not Reporled iu N.E.2d 2003 WL 22390095 (Ohio App. 10 Dist.), 2003 -Ohio- 5582 END OF DOCUMENT EXHIBIT G (0 2008 fhomsonlWcst. No Claim to Orig. O.S. Govt. Works. Page 91 'I'he IndusLri:d Cornniission of Ohio RECORI) OF PROCEEDINGS Claims Heard: 04-888455 04-888455 LT-ACC-SI-COV PCN: 2081021 Laura Horvat Claim Number: LAURA HORVAT 382 STABLE DR LAGRANGE OH 44050-9654 Risk Number: Date of Injury: 10/15/2004 20005329-0 IC-12 Notice Of Appeal filed by Employer on 06130/2008. Issue: 1) Scheduled Loss/Loss Of Use - RIGHT HAND Pursuant to the authority of the Industrial Commission under Ohio Revised Code 4123.511(E), it is ordered that the Appeal filed 06/30/2008 by the Employer from the order issued 06/13/2008 by the Staff Hearing Officer be refused and that copies of this order be mailed to all interested parties. ANY PARTY MAY APPEAL AN ORDER OF THE COMMISSION, OTHER THAN A DECISION AS TO EXTENT OF DISABILITY, TO THE COURT OF COMMON PLEAS WITHIN 60 DAYS AFTER RECEIPT OF THE ORDER, SUBJECT TO THE LIMITATIONS CONTAINED IN OHIO REVISED CODE 4123.512. Date Reviewed: 07/02/2008 Typed By: tjc John L. Havener Date Typed: Staff Hearing Officer 07/02/2008 Findings Mailed: 07/05/2008 Electronically signed by John L.Iiavener The parties and representatives listed below have been sent this record of proceedings. If you are not an authorized representative of either the injured worker or employer, please notify the Industrial Commission. 04-888455 Laura Horvat 382 Stable Dr Lagrange OH 4050-9654 ID No: 14465-90 Thomas C Mays 1370 Ontario St Ste 1520 Cleveland OH 44113-1708 Risk No: 20005329-0 ID No: 1825-80 Benefits 1 Group 25001 Emery Rd Ste 340 Cleveland OH 44128-5627 Cambridge Home Health Care, Inc/Pri 4085 Embassy Pkwy Akron OH 44333-1781 EXHIBIT H Page 92 SHREFUSE Page 1 tjc/tjc Thc Industrial Conunission of Ol,io RI:CORD OF PROCEEDINGS Claim Number: 04-888455 ID No: 2D785-91 Willacy Lo Presti & Marcovy 1468 W 9th St Ste 700 Cleveland OH 44113-1220 BWC, LAW DIRECTOR NOTE: INJURED WORKERS, EMPLOYERS, AND THEIR AUTHORIZED REPRESENTATIVES MAY REVIEW THEIR ACTIVE CLAIMS INFORMATION THROUGH THE INDUSTRIAL COMMISSION WEB SITE AT www.ohioic.com. ONCE ON THEHOME PAGE OF THE WEB SITE, PLEASE CLICK I.C.O.N. AND FOLLOW THE INSTRUCTIONS FOR OBTAINING A PASSWDRD. ONCE YOU HAVE OBTAINED A PASSWORD, YOU SHOULD BE ABLE TO ACCESS YOUR ACTIVE CLAIM(S). EXHIBIT H SHREFUSE Page ,,,,,,. .t,,,,,,> and Sc^]cc Pn,vide[ 2 tjc/tjc Page 93 M[CIEA.EL W. KETI7i, M.t). ssao Mrtroualta Ortre Oevebud t1H 14109-1998 MebuNenlf>, MeAlnt Csnnr p.p"bNeet of OriboPo*mo O1vo R16j TT6.q9p Hrnd, Bhenldv A Upprr Cttr®17 FAX (216) TTB {690 Coprpkx Paralyds Dhneden Laura Horvat 915105 Unit #5266472 SSN_CC: Follow-up righf wtin XR: I roviewed het bono scaa and oa the tight side it shows evidence of increased lplalce hl the tadlocarpal joint eroa. This repcavrnta objective evidatce that the pa}n emminadng &om this erca Is 6om bones and joints. This is strong evidence that she would not recuver itam any tneatment onless it is directed tnward resotving her inswbility. R'hat is nut known at thi.s stage ero which caltilages atefaces ara twethl for reconstruction wd wbw opvone we will use to recommtmd a specifie surgical procedare. I believe that the next stage in her managalnent Is consideration for surgery. Spectfiwliy I racommend an intucmpet at9lTodests or reseetton of bones lf our etlteria 1s nor met tor succeasflil carVlege stvtacc to bcncfit from, for iavtanw an STT ftlsion or fourcorner erHuodesis and scqhoid reseeainn, radiooacpel pimeimal row arthtodosis or proxhnal raw oarpcctoany. She stiU has 30 degfeos of ftexion-exfension. I believe that the wrist arthrodesis is not neussary at thLs stegc. tt couid be resuved for a seivago proceduro. In cifhor caee a faihac of the rnon ccroservativc opeaation or the necessity of a total wrist arthrodesis would 117cely remove her fi+om ths beavy tabor wark foree. I have indicatal to her that we will aubmit a C9 fat intereetpat anbrodests or proximal tow cacpeetomy dependmg upon the sltrgical findtng9, t wflt await adecision ffom her selLInsunxi uoaywny bcfurc ptt>Va.71inK wItb Ircn4nmt. The patient has retained an attnmey at this stagq,'ILotnas Mays to tepraseat hef In all negotiations with her ernployer. MWKeith 1rtDR:a cc: Linda Pencynski, Cambridge f{ome tteahh Cate (C9) EXHIBIT I Page 94 FAX 'J(,, ;30 438 0597 P. 0DG '- AU5-T'u[i (i^:: 0 :4'r+1 B41'C Rex Dinsmore, D.Q. P.O. Box 879 Brunswick, OH 44212 (330) 225-2554 I Permanent Pattial Impairment Evaluation October 23, 2005 Laura Horvat 3880 Grafton Rd_ Brunswick, OH 44212 Claim # 04-888455 SI DATE OF INJURY: ' DATE OF EXAMINATION: DATE OF REPORT: ` DATE OP BIRTH: 10/15/04 10/20/05 10/23/05 12/30/52 ALLOWED CONDITION(S): 842.00 SPRAIN Of WRIST NOS RIGHT; 842,10 SPRAIN OF HAND NOS RIGHT HAND HISTqRY: The patient is a 52 year old female who states that she was Injured while employed as a Caregiver for Cambridge Home Health Care, Inc_ The Injuly occurred as the claimantwas lifting a patient and she developed pain In her right hand and wrist. She was initialiyevaluated af Medina General Hospital where x-rays and a bone scan revealed no fractures or dislocations. She was diagnosed with a sprain of the right wrist and hand, treated conservatively and released. She continued to experience pain and was evaluated by Dr. Michael Keith, MD. A bone scan was performed however no records of this procedure were provided to me for today's examination. Dr. Ke'ith's notes repeatedly mention the necessity of surgical intervention, however I understand that nothing has been performed to dafe. Injections have been administered and the use of pain medication for pain management. Ms. Horvat missed three days of work due to this Injury and she is currently employed. She is not taking any medications at this time and is presently under the care of Dr_ Keith. No follow-up freahnent was required. PRESENT COMPLAINTS: Presently the patient complains of pain. EXAMINATION: Examination of the Sprain ot the Right Hand/Wrist finds the flexion to be 30 degrees, which is equal to 5% UE. EXHIBIT J PAGE6125"RCVDAT 11f3120051;52:23AMlEasternSfandardTime)`SUR;fMGfXPD3128"DNIS;144564752'CSID,330d38059i'DURATION(mm•ss):04-28 Page 95 1)011` f"J?005-7, H; [18: i0 AM B44C FAX ldo, 330 438 0597 P. Ofi? Laura Horvat Ciaim # 04-888455 Page 2 The extension is 40 degrees, whlch is equal to 4% UE. The radial deviation is 10 degrees, which is equal to 2% UE. The ulnar deviation is 15 degrees, which is equal to 4% UE. Further examination finds there to be moderate tenderness present. No scarring or deformity is noted. Tinel's and Phalen's signs are negative. Using the AMA Guidelines. Fiffh Edltlon, Page 466-471, Figure 16-26 to 16-31, and Page 439, Table 16-3, the Total UE Impairment is equai to 15% UE, which is equal to 9% WPI. PERCENTAGE OF IMPAIRMENT: Based upon the AMA Guidelines Fifth Edition Revised, the total WPI for this claimant is 9% WPI. I have not provided care for this patient I have seen this potient one time, on the above date, for the purpose of evaluating medical impairment. Evaluation was focused to the allowed condiHons listed above.. The patient declined to have an assistant present during the exarninatlon.: i Respectfully submitted, Rex Dinsmore, D.O. EXHIBIT J PAGE 7I25"RCVD AT 11f3f200S 7:52;23 AM (Easfern Standard Time)"SVR:IfAGFKPD3128' DNIS:144564752' CSID,330 432 0597' DURATION (mm•ssj;04•26 Page 96 fC^. i. 2005 5.46^h1CAAhkKl7Gt SuYYUKi . ._ r.l:^ . - R. 'cott 1^ruPkin, M.I). 400 St. ClalrAvenue Cieveland, dhio 44103 ]Phone (216) 426-2555 Pax (216) 426-2554 Deacrnbcr 14, 2005 Linda Percyneki, 3PHR, CWCP Director of Human Resources Cambridge Homa Honlth Care 4085 Ymbasgy Yatkway Akron; OH 44333 RE; Clairn Number: Employer: I3ste of Injury: Date of);xamination: Purpose of Eacanoination: Allowed Cor,dieions: f1(11 Laura Horvat i p^^ 2 0 2005 04-888455 Cambridge Home Healtkt Care 10/151200a t:t/14/2005 Bxtent of Disability and Permanent Pattial Disability 842.00 $prain/9train Right Wrist 842.10 5prain/Strain Rigbt Hand H 48-yeezwtd rigttt-hsnded tbmale who wee warbng as a caregiver with: Carnbridge• llome Health 8ervicWS whmti she reported a snap and pain in the tight wrist while lifting a patient. She.was . ..... secn initially at Medina Hospital, where she was examined and then followed-up wi+3t I3r. '..'. Branstein. Sbe says no x-rays vvere done at that time. She was pre8oribed medioatioHs and physical therapy. She thea cam,e under the oare of a Dr. Erngles, who diacondnued her pbysical for a periad of ^w^:Fd .:••" therapy beeause of persiateaR paln. He apparently oastod recvmtuandcd. surgory. She then oame under tha carcrn of a paut management ptogtatn where sha ., received what sound9 3ike laser traatmants and contrast baths. She then sougirt oare at Wg4bore =. .' 1-Cospitai in the Occupational Medicine Depattment, and was referred to Dr. Michael Kruth, a local orthopaedic and upper extremity apeu'ialistr Office notes xrom Ar_ Keith, dated 03(}8f2Q05 :.. througlt 0810513005 were reviewed. X-tays at that timo reportadiy showed dagenarative Cp.fa of ,,, the eeaphoid with some widenittg. Dr. Koith also performed diagnostic and theQfetlRic ..:.. • injections of the elbow and band/wrist. On tbDow-up 04/15/2005, Dr. Keith desedbes that her conditiouwas aomewhat ittVroved, however, she aterted to use hei right haod and wrist with inc;east:d pain. 13ccauae of the inopathutce ot rest, ihe: was casted. at that viait to maintain immobiiity of the right hand and wriat. Ha also zetluested a bone sm at that time and, althougb denied initially, was subsequently perfomted. Bone acan frorit 07/1512005 showed incroased uptake in tho right radial earyel joint region 7t-raya frotn 03/18/2005 were negative for any eigttitleant pathology of the right elbow or hand, although a"flexion contracture" was noted in the fift p_roximal 'interphs ➢augeal jo'nt on tha right. X-ray ofthe right wsist is noted above. Follow-up..wdth.Dr:- Keith on 05/1t<2005 ttotet that tlie clairnant bad incre++€ed comfort when fully irnunot:iilzedl. Dr. Keitb notes that thla is consiatent with intercarpai inetability with seaphohanata uidaning. He provided her^vith f4 wrist brace to iaaintain imutobility. He began EXHIBIT K Page 97 ). - CF!NtlK!USt SurruK^ RE: Page 2 of 3 Claim 13umber: 04-459 discussioti ofpo9sible surgical alternetives, #oliow•up note from 08105C1005 indicates that Dr. Keith reviewed the bone scan results with the claimant and pmvides supporting informapion for aurgical indieations. Although he would like to pteserve joint.motion, arthrodeais of tbe wrist may have to be considered, depending on the degree of degenetative changes:seen at surgery, CUNMT 95'dTU$ At this time, the claimant has diaoorttinued pain meditations and aleeping medications. She is using Tylenol and ice for aymptonmtie relief. She is otherwise healthy with sosgery to the right ankle 12 years ago,. history of kidney stones, and childbirth timea.three. She denies any food or drug.allergies.: She roporte she has.no pritnarycaze physieian. She contdnues to report pain in the right wriat with occasionai numbness. She_drope objects at times,and reports that she caanot lift a gallon of, milk or bruah her teeth/heis with the right upper extremity. She was apparently unable to contplete the intake form. Other problems include sleep disturbance. She has returned to work in another division of Cambridge Home Heaith and ie perfornvng clerical activities 20 hours per week: She is independent with driving and aotivities of daily living. She says that her fiance and son help with hom,e tasks. YHYg'iICAL.^^(A . T[OlY Alert and oriented, in no acute distrCss. Siie is somewhat aoxious with subdued affect but cooperativo and comtttunicaCive during the ezamusation. She was wearing a lace-up wrist brace with a ntetal stay. She was able to remove'and replace the' brace independsntly. Gen®tal strength in the right upper limb ia withln' norcnal limita proxintal ta the wrist; bowevcr, she exhibits grip weakness and incomplete aodve:range of tnotion with hand flexion, Althoµgb.she tends to hold lter.little 5nger in a conhaated poaitien, it is reduCible manually. She waA.able'to axtend her fingera:fully, with encouragement . Mostly, she holds her hand in a loasc o=•limp position, There is slight active tange of rnotion at the wri®t, Range of motion in the xight W4st is flexion:2o degreas; extension 20 degrees, radial deviatiori 10 degreer, ulnar deviation 10 derrees, Distal pulses araIntact. Light toueh sensation is intaot and symtnctric t'htoughout the liai ^d and arm. Deep tendon reflexes ane 2t and rymmetric at the biceps and triceps. There is aolattDaffi repponse to touch ;and palpation. There is ditTace tendernees even to light palpation of ths g;st and lateral forearm. There is a soft taass or lump atopg the proximal ulnnr aspect of the.aght forearm. Passive range of !motion is better iit the hand but painAzl and limited due 1o•^tin inhibition. There le no evidence of changes in color, swalling; defortnity, sce=rtilBr'qr temperamro changes of the right hand or wrist. OpYNION3 .. ogc CS `iJ ^^. rr In response to your spocifie quostions; 2 0 2005 :.^ i, WRat, in your opinion, ate some poseible causee for her pr ^-I Based on claimant history and review of=rt±edieal records, it appears that Ms. Horvat austained injury to her right wrist and hand while engaged in employntent as a aaregiver for Cambridge Home Health Catc. An underlying ligamentoud injury may be alao a result of EXHIBIT K Page 98 ;. iL Caf+iN^luG SOrPUB IVV. 71L r. i 9; 9 ' RE: . Lao%;t;,.Mat .:rw Page 3 of 3 Claim Number: 04-888455 that claim, resultiog in degenezativc changes that becarne apparent both by x-zay and bone scan five to nine months post injury. Whether there was any prior injury or pre exisdng degenerative change in the wrist is unknown, a. Has the t.pe>ato^ ent to date bean medically aecessaryT Why or why not? it is my opinion that medioal treatmcnt te dats bas been appropriate and targated for the recovety. from a simple sprain or atrain injury of the wrist andlor hand: Further diagtosric testing by x-ray in 03/2005 and bone scaa in 07/3005, along with clinical correlation by Dr. Keitlt, suggests that appropriate treahnent for her ourrent ooadi4ion would be surgicsl. 3. Are there any objeogve lndicatlaus. of .symptom tapgnilteRtloa of maifngersng, and what tests or observation did you perforim, if aay, to determine the aame? As ndted above, the claimant was somewhat anxious with a subdued sffect durksg today's enantination, however, this would be entirely appropriate, givcn ber stat® ef chmnic pain and discornfort. Althougb ex8mination was sotnewbat linited due u+ guarding and pain inhibition^ again I found no patt'scular aspeat of ber psyohologieal prasenffition to reflect matingering, although there may be symptom raagnification related to pain. These comments rsgarding symptom ^ tnagaifioatlon and maling0ring a:e based on visual inspection; phyaical exarniaat9on, and veifial history wit'h the claimant. 4. Please detexntine s.ay partial, perroutentiwpalrmeat. At this point in time, it is my opinion.that the olaimaat has some degree of periment partia3 itnpairment due to reatricWd rsngc of motion in the:wrisx Based on range ofAptiba measuremaats, thia would be eat9tnated at a 20% upper extremity irapairment, or 147°Yo whole peraoa impairmant. I do not fecl, however; that the blainaettthas achieved mwdtnum tnedioal improvernent (MMI): Basedon cumntdiagnostlo fiadings, it wotft bemv reconunendation that the phreician of recoxd appl^f^additional allc^n^ AF I2r'Ktith points out, ligamentous itljury of the right wrist would be coded identically ta aprain/e!r$in • : _'i'iy^ ' of the right wrist Since there appears -^^ntous injury as weB as scaph6ttGfate do eaeration, the phyeiotan of record znay also want to apply for dagenecative arthtitig of the wrtst,. It is m inion that it would be reaeonable'to mvve ... .. . .... •. . ^. . ..' inmrvenrio , baE d aa r CaitLs optntem. seo opmton consultatton may ^SlO•be consideredwith an orthopaedic upper sxtramity surgical epecialist. I have not provided care for Laura Flor.vat on thia date or at any time in the past. I have gean her on this viait for the sole ptupoao of evaluating taedioal t' mpaitment. T his assassmei<t was focusad to the allowed conditions listed above. 7(^ s(^ R 1^^..^ ^s 1 DEC 2 0 2005 ii By EXHIBIT K Page 99 N^NN.. 1U0b`' 9:d9HK4"" CAMIiYIUG[ 5UYYUKPVLiIIE nu, u-uul1 Y. 13 CRYSTAI. CUNIC, INC Stow / HUdaon cR'litaf•,CUMC imMa4CamNiCF7nw OG1HOPANICdYR6FaH AYMaeI R. MngdFv MA (,'a121b11fp Ha1AC .HCA;ti1 CHfe &$: Letir$13G2vat Claim# 04•6B84S5 DOI; Oatober 15, 2004 Allowed Conditions: 842.00-9pcaldetrain of aviiat, sFght 842.10•sptain/straln ofhand,right She in a 49 year old xbmale h.are today for orfFwpedio ovaluatlon. Mr- liorvet hms a hiatory of psoblang wlth heQ right wniat, gha rolatos this to mn ityttty ahe avfYe:vd while at ;r.. work tbr Cembridgo liome Health Cere as ahome health aid. Sha waa ^g a^ ; pationS on. October 15, 2004 when she natad insrosdng pain in 3w rlght wrist atd harii^ 6ho wos initiall,y evaluated on tiw 18lb of Ootober 2004 when she preeented to Llfe on t€ie ; rlook aere medieal ^erviao. 93>e wat initiolly disgnoAed ae having a tigi^t. wr,lat Ipraia. 6ho contlnacd to oomp]ain of right wriet pain ®ad was aefare8 to Dr. Bagle', a liand pnrg®oh at the Cryrtal Cllaio, 8Lo was sxn oa Deconaba 6°i 2004, At the thnm, ^3r, 8agle's fek tt+at M^. Horvet euffored arigbtwriat spral,n whichwes supaimposedon prer exisfing arthtitts of the right wriat 8pecifloalIy Ms. FloxVat had evidence of pxo'^stingvF arthrit3a due to aaaplwlunata ad9anoed oo1{ap4o (S7.AC). 8hc was placed into a sp11.4it imcwbllizlag hcr hand aad wrist She vvae then zatsztad ia ooaupatioael tha,cepy. With thin Ms. Sorvat noted eome relief of h4r right'wrlst pala 8ha was eventually eeaa by Dr, 1Cafth in lufemh of 2005 who noted deganotativo uthr[tts oytho rig6t wriat Dx, Koith tb,an Sicnama the physioian of teoord. She was snbsoquently followed up in April of ?A05. Sho was aivaa an injecdon in her ri@fu wript and thea plsoed into a oast. Bubcey,>ont follow up visits by Dr. Koith ware eho pertbtmed. In each af4heaa visita Dr. Y.nitltnotod e+vidonoe of atthrltia in t'h,o tfsht wrist. Due to ongning aamplainte of pain in fler rlgkt wtiet, Dr. ICeitL moammonded n four cornor wrlst 8uion with exoiaiaai of tha scaphoid, A bollow up bona saam wu obtained !n fuEy of 2005 wbiah dem.ur--tmtsd inoreaaod uptake in the radiocatpal joiurt ooutiaoart wfth degeriototivo srtiutHs. Tn Auguat of 2005, she waa agsln sem by Dr. Kelth and ttn.goty reoommanded et that tirtuo was a limited fusion varrane a pinximn! raww cerpoc6omy. I1n diaoussiag hat cmo with Ms. atatea dset ber wrist is to the pa8nt whexo it Is giving hox constant paia unless She says any type of movemd<rt ia ex,]remnly painful forhor. 4A861MflRd.Y RD. I EiCNd OH ddM / 9la-075-1631 / FAX, 38ad76-1684 NhAtl W^ye Web; t'Atpd/www.crydalc&Ve.cam Page 100 NAR. ;.2006 9:50ANI CAMBRIDGE SUPPURILIN[ ...^... - N(1. J8C P. Pago 2 RA: Ls:xcaIi.orvat Claim: 04-868455 Sha is ccmr,ntly not taldng eny madicines. PRIOR SURGICAI.IiISTOItY: 3argory ouher right ankle in 1994. SOCIAL IiISTdRY: 8ingle 71m Cktldren She ernakos apaok of oSgarettom a waolc. She oooMonnily drinks alcohol, PHYSICAL BXAMINATION: I-ieight: 5'7 Wolpbtt 155 Ibe. She bas no kaown drng allorgieR. She formally vriulo ar a bonu hoalth ald, EXkM: Sbe is in no acute diatress. Sbo ie acvAiro, oiart and oricuted X3, Ccardei nerves 2-12 are grossly irdaot. She wa1k8 vvith a nooanal galk Hxernfuadon of the rlgbt uppez axkemity; she was waarlug a rnw splint Wltloh I smuavcd, ehe oomplained of axquisite pa[n with aay type af patpstlon of b=rig*wrlat Bxatalneaon of:tha wrlat itself was 13mited ;aaeandnry t}m qaYiaat'r cr^plamta of e^cqui^ peia with aaq typa of maatpu3at3on oftbe right wrist ehe had ii^l1 ra^sgo of motfon of s)1 ofl^ Sagee9. She had good radist aud nlnec pulroi. 8he had onmfg08 tandcma+ ^ aad maTkod.l,y llmited rango olmotion of the wrist woondary to cmmplaints of paim. She had i411 pmnatlodsulunation at t5m elbow aod wrist but again oomp]n4ned of pain with r=ge of motion. I'h'R'KESSIOI+F: This is a 49year old fcmale with pceaxist3ng oettaartluitie of the zlght wrtst. It is quite obvious 8nnt tb,a uotas reviewed by taysolf t6at Ms. kIoivet hsd degeaocative oheages in heQ wtlst prior to har isliury ia Oato6er of 2004. I". MAR Q $ 200G ^ L EXHIBIT L Page 101 'd..°;. [Oi6' 9:^DAMir GAMBRIDGE 5l1FPU&Tv^uue hU.08Gh1 N• ='S Pugo 3 FtB: Laura Horvat Cia^in i/ 04-888455 Tn respqnea to speaifio queadonsc 1.) In your opinion, is W. Hrnvat's ourreat complaini a direct snd cauFal reaolt of the aocidentel in,yury ID/15l047 No. Ms, liorvat puPPered $om pra-exlsting oeteoattbridR of the right wcisG 8he wa3 eaon by two hand speoirxliets, both of whom noted degenerative ohaugea in b.ar ii$ht rn'iat which obviously praF•existed hor lr♦jury on the 15d' of Ovtobe.r 2004. 5pecifxoally Dr. fingle's noted that she had avidcrloa of acapholtmato advande collapse whioh ie caused by an injucy to the naspholunate ligamant oauaing diactaaeo betwcen the two banes which oventually resultr in arthritlo ahangos withfn the wrist. C#iven tha timo ftWme involvcd with this injury. .#t is obviow that she suffexed from tho <ttlttitia prior to the iq}ury oa 10/15/04. Tbe iqpry on 10/15/04 cameitred of e sprain of the rlght wr.tet snd aggrsvation of pto-exieting artbritis of the right wriet Zypienl treatment for dst 8 typa of i^iury ia conservative with itnmobilizetion attdaati•fuflammatory rmedidne. R 2) Aro tbe tervitoes rnquastcd by Dr. 8oith reesonably neecosary for tho ttcatmant oftho ellowei conditlons4 Tho current allowed condltiona ere 842.00 spraf.a/afre3n of wrict, rlght divan the allowed condittone in this a1altp, the treatmentroc3ueated by Dr. Raith is not medi.cally neoessary. Dr. Keith is requesting to iraat Ma. IiorvaA'a right wrlat arduitis whictx is cunentty not allowod in this claim, 3.) Arc thoro otty objaative indiarxttona of ey,mptom , iaa,gaiflaadon or malittgering and what teatg or obrorva@ona did you perPortn, if any, to determine the eame7 Ma. T.-Iorvat compleinad of extreme painvrih3s any typo o^Ppalpation of the rlght wrist or aqy type of rnaipulstlon of the right wriC Some degreo of cymptom. tnagniflontion wutdbe a9cortatngd $om tlu qpe ofpudn complained which she ddmeaekYted £rom such tnfnicnat inenip^ilation af l^ec wtict iiaweaer, itwould be difficult for mo to mahe a fum detarminatiun on whetha or not tha repre:etned hua symptam magnifloatlon or ttue pain ee pnia itsaif is svary subjeative eutlty. Sincruely, EXHIBIT L PaBe 1 ^^ 2 Page 102 "0 ;j07!21) 0 5 14 :20 FAX 210 241 6031 MetroHealth ti•ILLAC:Y LoPRESTI & h{ARCIa RC^-^A^^V ac12 2 iDa7 MtctT,+Ft. w. tcL11.13, M.D. 19ann, Slwnidcr & Upper Extren,hy Contplex Pnrnlysis Diemdcrs 2500 M0ro17enlth Drive Cievelanu,OH 44109-1998 Office (316) 778-4399 FAX (:16) 778-4690 /ti n.w• CASE SCHOOL or MFuKINE AD4rtINC October 5,2007 Linda Hunt RN, CRRN VoCare Services Inc. 2S001 Hmery Road 9320 Clevcland DII 44125 Dear Ms. Hunt: RE: Laura Horvat Date of exam: 10f5l07 Unit 95266472 SSN:^ Thank you vety mud't for the kind letter regarding Iter vocational pragram. Ms. Horvat's current x-rays are satisfactoiy. Her cast is off. She is starting therapy to build strength am1 range of motion in her hand. She still has tenderness around the Incision and the plate. It is likely that she will have tllat plate removed in a ycar or so but not anything at [he present time. The next hurdles are vocational rehabilitution. She is now app'opriatc for assessment of transferable skilis. She lias done some diligence here and has looked into othm' work opportunities. She will discuss them with you. She is going to statt inaking contacts oow for what I would consider light duty positions, clerical, adrninistratlve, uonweight bearing and nonweitht lifting. The vocational plan at this stage should include assistanco wittt thosc job searchcs and resumes. I havo no intention of rcturning het• to heavy manual labor. Her pain relief is good onough that it shouldn't interfere in participation in any appropriate rehab activitics. lf the rightjob comes up she should be able to close her rehab cuse in a couple of inonths. I axpect a platcau I strength for light clerical assignments within probably 3-12 woeks. Very truly yours, Michael W. Keith, M.D. Orthopacdia & Fland Surgery MetroHealth Medical Centu Southwest General Medical Center MWK/ca EXHIBIT M The Metrol.iealth System 2500 MectoHealrh Lhive, Cleveland, Ohio 44109.1998 216 - 778 - 7800 PAGE20f20"RCVDATSITI20082;10:47PM[EasternDaylightTime] "SVR;IMGfXPD4129"DNIS;944564166'C51D,2962416031'DURATIDN(mm•ss),03,26 Page 103 , HOV-0^-2e07 12 :36 -- OH I 0 SPEC 1 nLTY PE-rtJORK 216 ^26 25`S4 r.02i10 Ohio Specialty Network, LLC P.O. Box 603787 Cleveland, Ohio 44103-0787 Phone: (216) 426-2555 - Fax: (216) 426-2554 November 2, 2007 Ms. Heidi McCune Workers' Compensation Admtnistratlve Assist. Cambrldge Home Health Care 4085 Embassy Parkway Akron Ohlo 44333 NOV 0 5 2607 RE: LAURA HORVAT Claim #f• 04-888455 Date of Injury: 10/15/2004 Allowed CondRions Right Hand Sprain/Strain; Right Wnst Sprain/Strain; Right Wrist Arihropathy Dear Ms. McCune; Thank you for the opportunity to revlew the med+cal claim file of Ms. Laura Horvat' 1. Issue: Have Ms Laura Horvat's allowed conditions reached maximum medical improvement (MMI) in the present claim? ll. Conclusion: Yes Pursuant to the Official Disability Guidelines Treatment of Workers' Compensation, further treatment is not reasonably necessary and appropnate Ill. Facts derived frum the medical record: I accept the following findings and reporis of examining physlcians Z Ms. Laura Horvat is a 50-year-old' home health caregiver with Cambridge Home Health On October 15, 2004, she was caring for a patient with (multipte sclerosis) MS patient who required five Irfts, and her right hand became swollen with discomfort as she was moving the patient to the potiy chalr to the wheelchatr and back to bed 3 oate of blrnh ts ' In accordance wfth standards for fi1e revlew State ex rel. Wallace v lndustr al Commission (1979), 57 Ohio St 2d 55, 59 and also State ex rel Bovne v, Greater Cleveland Reglonal Transit Authordy (1996) 75 Ohio St,3d 45B, 460 and State ex rel Dobb ins v industrlal Comm, 109 Ohio St 3d 235, 2006-Oh1o-2286 3 See FftOI of 10/15/04 EXHIBIT N 9t d ti£t 899 oc6 B 3woH H`JataeWVO 9t:01 LOOZ ^age" 104 ,NOV-9G-26r07 12'36 .UH10 SPECIPLTi NETWORK 216 426 2"54 P.F3i16 RE: LAURA HORVAT Page 2 NOV 0 5 2007 She was initially seen at Medina General Hospital on October- 18; 2004 by Dr Brustein in conjunction with Nurse Practitioner Watterson 4 It was noted that Ms. Horvat is right-hand dominant. Again, the same mechanism of injury was referenced, and assessment was rlght hand sprain/stratn 8nd right wrist sprainlstratn. The employee was placed on restrictions6 and was assigned to light duty.b In addition, she was sent to occupational tharapy 7 She attended occupational therapy through the end of Oclober.8 She did not appear to have any progress whde in occupational therapy during this time. She continued at the Occupational Health Clln c with Dr Brustein 9 The employee remained on restrictions during this time period, including a splinti0 Whlle in rehabilitation, it was noted that her wrist flexion improved to 50 degrees, extension was to 60 degrees, and grip strength was 20 pounds. She continued to perform light duty." On November 8, 2004, she was seen once again at the Occupational Health Clinic with Dr Brustetn'2 She had a shght de0rease in her pain rating; however, she continued to have a positive Ftnkelstein test Assessment was right hand and wrist strain with slow tmprovement13 Additional occupabonal therapy was requested.14 By November 29, 2004, Dc Brusteln arranged for evatuatton and consultatton with Dr. Engles, orthopaedic hand spectalist'b Dr Engles saw Ms Horvat on December 6, 200418 X-rays demonstrated a narrowing of the radtoscaphold interface with marKed spur formation. There was also a gap at the scapholunate interval. On lateral proiection, she had dorslflexion of the lunate conststent with a DI51 deformtty. Additional x-rays demonstrated irregularities of both the distal radius and on the radial border of the scaphoid consistent with an SLAC wrisL Bilateral clench fist views demonstrated diastasis on the right as compared to the left with respect to the scapholunate interval. There were no degenerative changes at the left radial styloid. Overall assessment was sprain of the nght wrist superimposed on SLAC wrist; arthritis, right upper extremlty; and history of hypertension. Dr Engles Informed the employee that ". while she may have been completely asymptomatlc, there is radiographic evidence of underlying wrist arthntis, specifically, scapholunate advanced collapsed wrist arthntis. I discussed, fortunately, this is in its early stages as she appears to have ° See 10/18/040ccupauonal Heahh Chnic note See MEDCO•14 of same date `See 10/20/04 RTW program light duty 7 See OPT notes of 10125/04 See 10/25/04 thru 11/30104, 10 vistts inclusive ° See 10125/04 Clinic Note te See MEDCO-14 " See 11/04/01 rehabdttation servlces notes tz See 11/08/04 Occupational Health Clinic nole "See also 11/08104 MEDCO-14 14 See 11/16/04 evaluation and C-9 of 09/08104 and 11117/04 i5 See Ocoupational Heahh Clinic nole of 11/29/04 "See Dr Engles consultation of 12/06/04 EXHIBIT N 91 d tTel 899 066 H BWOH 30012fawV0 9t:01 dooz-ade 105 . i 12' 37 - OHIO .SPEC IAI.: rr NETwoFZC =15=Cco 25-`.4 P. F+4i10 RE' LALfRA HORVAT Page 3 NOV 0 5 2007 disease only at the radioscaphold interface and/or surgical IntervenUon was discussed "" The posslbility of'steroid injection Ms Horvat returned to Dr. Bn.tstetn and was seen on December 13, 2004's He kept the employee sphntedi9 and saw her back in 2005_20 After being Immoblllzer for four weeks, she had no significant Improvement. She was doing mainly phone work, as per her restrictions She was again referred to occupational therapy with the possibility of Injectlon and follow up. Ms. Horvat was seen in occupational therapy once again on January 3, 2005 z' She remained on restrictlons22 and did not have any significant improvement. As such, she was referred back to Dr Engles 23 On February 14, 2005, an Independent Medical Examination was performed by Dr Randt 2" Dr. Randt opined that treatment to date was reasonably necessary and appropriate and that the employee should follow up wlth Dr. Engles.Zs X-ray of the rtght elbow was then obtained, which was unremarkable .26 Stmilariy, x-rays of the right wrist were performed, A flexion contracture of the fifth digit was noted and was otherwise a negative x-ray of the hand The right wnst demonstrated degenerative disc disease involving the rad{onavlcular joint Intraartlcular calcrfication or avulsion was suspected There was an irregularity of the cortical surface of the navicular with degenerattve cyst or other radiolucent abnormallty noted There was a widening of the radiolunate joint space consistent wrth radiolunate subluxation There was also an abnormal posrtion of the hook of the hamate with follow-up examination recommended 27 Ms Hprvat was then seen in the Ambulatory Surgical Center on March 18, 2005ZB by Dr Keith. He also obtained x-rays, which demonstrated right hand degenerative cysts of the scaphotd with some widening. He recommended reevaluating the employee in four weeks. Dr. Keith prescribed tramadol, carlsoprodol, diclofenac, and amitriptyllne 29 See recommendatlons, page 3, 12/06/04 report of Dr. Engles 1A See 12/13/04 Clinic Note of Dr. Bruslein See also MEDCO-14 See 01/03/05 Chnrc Note Z' See 01/03/05 PT note See MEDCO-14 01/03/05 n See 01/13/D5 Cllnic Note, also MEDCO•14 and rehabditation servIces and 01/14/05 C-g See 02114105 IME report Z5 See also C-9 of 02/17/05 See Dr. Blackburn x-ray report of 0311 BJ05 ''' See Dr Blackbum repott of D3118/05 29 See 03/18/05 Chnlc Note 29 See 03127105 Workers' Compensation rn7orce for modicatrons EXHIBIT N LT d SIGT 899 OSc H 9WOH flO0IN8WV0 9T:0i LOOZ-ftAAN 106 . 140Ri-U2-2007 12-37 CIHiD `_-PECIPLTY 17ETtdUrh: _'15 426 2Sl-d P.(iS/30 RE: LAURA HORVAT Page 4 Dr Keith saw the employee back on April 15, 2005.'0 He noted improvement after 0 5 2001 in]ectton of the elbow and hand, although the elbow remained painful. The thumb returned to hurttng again after the injection. Injections were again recommended - A- ^ request for clarification was made of Dr. Keith regardtrig medicattons." Ms. Horvat was seen by Dr. Moran, psychologist, on April 22, 2005. 2 Dr. Moran opined that there was an element of somatization and that it also appeared that Ms Horvat was dependent, insecure, and somewhat htstrionic. Supportive psychological counseling was recommended33 A bone scan was requested.34 On April 28, 2005, Dr Keith responded and recommended that he be allowed to prescribe the medications. On May 9, 2005, in response to Dr. Keith's letter, the bone scan was denied and the amitriptyline was processed and paid,35 X-rays were again obtained on May 16, 2005. There was free tntraarLcular osseous fragment most likely representing an old avulsion with a cortical irregularity of the navicular bone and also mild widening of the scapholunate joint. The right hand was negattve 36 Ms. Horv2t retumed to Dr. Kerth on May 20, 2005 37 A four-comer fuston ptus scaphoid excision was recommended. A bone scan was performed on July 15, 2005 This demonstrated no stgnificant uptake, although on the delayed images there was uptake within the region of the radtocarpal joint. Underlying degenerative process of a fracture was considered,313 Dr. Keith reviewed the hone scan and opined the employee should be considered for surgery, specifically an tntercarpal arthrodests or resection of bones 39 Outpatient surgery was requested 4D On October 23. 2005, a Permanent Partial Impairment Examination was performed by Dr Dtnsmore."' The employee was found to have a whofe person impairment of nine percent (9%). Ms Horvat was then seen by Dr. Krupkin on December 14, 2005 for an Independent Medical Examinatton.°2 Dr. Krupkin opined that treatment to date was appropnate. '0 See 04/15/05 Cl n c Note of Dr Ke th see 04/20/05 correspondence 72 See Dr Moran 04/22/05 [ME See 04/22105 psychological assessment See 04/22/05 C-9 35 See 05/09106 letter 96 See Dr Blackburn report ot 05116/D5 37 See 05/20/05 Clinic Note '8 See 07/15105 bone scan as read by Dr. Banker '9 See 08/05/05 note of Dr Keith "o see C-9 of Ofi/0e/0s , 4' See 10/23105 PPI exam report EXHIBIT N er d 1I£i 999 0££ H 3WOH 3001N0WY0 31 OI LODZ-60-AON Page 107 tIOV-6?-2Ei07 1? 37 OHIO SPEC[riL.Tr NETLIDRK ?1E 426 c 54 P C^_i16 RE LAURA HORVAT Page 5 NOV U 5 2001 A twelve percent (12%) whole person impatrment rating was noted; however, Dr Krupktn opined that the employee had not reached maximum medical improvement Ms. Horvat was then seen by Dr Magohne for an independent Medical Examination on or about February 7, 2006 43 Dr Magoitne opined that the requested surgtcal intervention was not medlcally necessary and appropriate for the allowed condit[ons. Outpatient surgery was subsequently approved "° On October 16, 2006. Dr. Keith recommended intercarpal fusion or a proxtmal row carpectomy depending upon the ligament instability encountered at the time of surgery 45 X-rays obtained on the same date of October 16, 200646 demonstrated degenerative joint disease of the radionavicular joint with cortical remodehng irregularity of the scaphoid and adjacent intraarttcular free osteochondral body with mild widening of the scapholunate joint Ms. Horvat was taken to the Operative Theater on October 26, 2006. An arthrodesis of the wrist with autograft and carpectomy one bone on the right was performed by Dr Keith a' The emplo^ee was Immobilizer with a short-arm cast and followed up with Dr Keith into 2007 8 Postoperatively, the first row carpectomy with removal of a significant portion of the scaphoid was noted on x-ray There was an interoarpat fuston with three oblique nalls stabilizing the first and second row through the capttate_ Free osseous fragments were also noted wrthln the vacatad carpal space. This appeared to be a satisfactory postoperative appearance.45 No significant Interval changes were noted on follow-up x-ray of January 15, 2007.50 Pin removal was requested by Dr. Keith.5' Ms. Horvat was taken to the Operative Theater on January 25, 2007 for removal of implant of the rigllt wrist where pins were removed 52 On February 2, 2007, Dr Keith noted that the wounds had heaied. Stability of the mtdcarpal spaces was noted iniraoperatNely with pin removat_ Therapy to regain strength and range of mot[on was scheduled, this in addipon to nonweightbearing °2 See 12114/05 IME report "' See 01126106 letter noting the appointment for 02/0i/06 with Dr. tvlagofine whose undated report was recetved 03/03/06 " See 10/04/06 C-9 and 10119106 script of Dr Keith °' See 10116/06 Clinic Note of Dr Keith °D See Dr Blackbum report of 10/16106 °' 8ee 10126I06 Operatr,e Report '" See 11106/06, 12111/06, and 01/15/07 repons of Dr. KeM A0 See 11/06/06 report of Dr 6lackburn ° See Dr Blackburn report of 01/15107 See 01/18/07 C-9 request 52 See operattve Report of 01125/07, also Pathology Report of 01/25/07 EXHIBIT N 61 d TIEI B99 oc6 B flWOH 3OOI88Wv0 91;OT tooz^age' 108 .ND^^O^-?G67 12 --n nN10 SPECIFLT'! IlETLJOf'.K 216 426 25:>4 P. 0'7i10 RE: LAURA HORVAT Page 6 and splinting 53 The employee started occupational therapy and had swelling around the wrist with not much progress in range of motion, accordirlg to Dr. Keith He recommended that she focus only on strengthentng A C-84 for three months was also scripted 6° By March 5, 2007, the occupational therapist also noted that the employee was instructed to be less aggresstve with exercises and to conltnue use of the splint mainly at night and during stressful activi6es during the day Emphasis on pain management, desensitization, and edema control was planned for bv the occupattonal theraplst.s5 The employee remained off works6 In occupational therapy on April 13, 2007, Ms Horvat participated in therapeutic activrttes and had Improvement in hypersensitivity over the dorsal inciston of the right wrist However, the utnar pin stte was still sensitive $7 Similarly, on April 16, 2007, the employee continued to have discomfort and had difficulV lifting a glass of milk or turnng a key in her car. She reported a pain scale of 7/10 5 She was dependent on the splint and using her left arm for activities of daily living On May 4, 2007, having completed 11 of 16 occupational therapy visits, occupational therapy was contlnued.59 On May 4, 2007, Dr, Keith noted the employee conttnued to have pain in her wrist wtth 20 degrees ot extension and 30 to 40 degrees of flexion, stdl wearing her rigid brace aimost all the time•60 Dr. Keith recommended that she discontinue therapy, functioning at about a 5-pound lifting level. A wrist arthrodests was considered A trtel of an tmrnobilizer was recommended after options were discussed.61 By June 8, 2007, Ms Horvai wished to proceed with an arthrodesis after the cast for four weeks improved her functton.82 Presurgical evatuatron and planning by anestheslology was conducted s3 On July 19, 2007, Ms. Hofvat was taken to the Operative Theater by Dr. Keith who performed an arthrodesis of the right wrist with autograft for a right arthropathy NOS of the forearm ed See 02/02/07 Clinic Note of Dr Keith also Nurse Practtuoner Chohaney See 03156/08 report of Or Keith, atso 02/13/07 occupational therapy note of Preustto u See 03/05107 report .% See C-84 03/16/07 17 See 04/13/07 raport sa See 04/16/D7 occupattonal therapy follow-up note sa See 05/16/07 OT request NOV D 5 2007 6D See 05104/07 report of Dr Keith See 05104107 Clinic Note of Dr Kerth See 06/08/07 Clinic Note, also 06/13/07 entry 63 See presurgical 07113l07 notes for planned surgery of 07119/07 - • °' See 07/19107 OperaUve Report of Dr Keith EXHIBIT N oZ d TTES 899 OEE B 314011 890I88Wv0 91 01 L003-60-AON Page 109 NJ!^-El^-2i-JN7 i<' "_'ti - C1HIO Si'ECIR'_T'e NtTIJORK 216 e2F -`.`n P. c+Bi10 RE. LAURA HORVAT Page 7 On July 27, 2007, x-rays demonstrated surgical revis i on of partial carpectomy and intercarpal fuslon.65 Dr Keith saw the employee postoperatively. No infection was noted, and a short-arm cast was appiied.66 By August 24, 2007, Ms Horvat's wrist pain was gone with x-rays showing good position and alignment A new cast was provided ' On August 24, 2007, the employee had x-rays perfomied, which noted a plate and screw device traversing the wrist with anchoring screws into the distal radius and third metacarpal, this with narrowing of the radtocarpal and intercarpal spaces with partial resection of the proximal pole of the scaphoid There was no acute fracture or dislocation, and alignment appeared to be maintained. Impression was status post arthrodesis and plate and screw device with alignment reasonably maintained 68 Most recently, Ms. Horvat had her cast removed and was capable of driving. As of October 18, 2007 occupabonal therapy continued.69 IV. Dlscussion: Application of the Miller Griteria requires a reasonableness standard for relatedness, necessity, and cost 70 In specific response to your question. I Have Ms. Laura Horvat's allowed conditions reached maximum medical improvement (MMI) in the present ciaim? Yes. On October 15, 2D04, Ms. Horvat sustained a hand and wnst sprain/strain. She subsequently developed nght wrist arthropathy Pursuant to the Official Disabllrty Guldelrnes Treatment of Workers' Compensation, further treatment is not reasonably necessary and appropriate The spraln/strain of some three years ago, to a reasonable degree of medical certainty has resolved. What remains is residual impairment from the allowed condition of arthropathy 71 On July 19, 2007, Ms. Horvat was taken to the Operative Theater by Dr. Keith who performed an arthrodesls of the right wrist with autograft for a right arthropathy NOS of the forearm72 By August 24, 2007, Ms. Horvat's wrist pain was gone with x-rays showing good position and alignment. A new cast was provlded" On August 24, 2007, the fis See 07127/07 report of Dr. 8latkbum " see 07127107 report 61 See 06l24/07 report of Dr. KeRh °g See Dr Amson report of 08124/07 b9 See Vocare email nots of 10/1812007 '° State ex rei Miller v industrial Comrnission 71 Ohio St 3d. 229 (1994) " Loosely defined as "disease oi the joint' 7z See 07/19107 Operai4ve Reporl of Dr Keith '' See 08I24/07 report of Or Keith NOV t) 5 2007 EXHIBIT N '.Z d t1E1 899 0Ce H 3WOH 8DG1218Wtla 91 01 L06Z-60-AON Page 110 zz a ivio.t ^;^Fn aoo 12 sE: OHIO sPtcIFUrr r+ETwow< 216 42c, 2554 P,99i10 RE- LAURA 1-1ORVAT Page 8 employee had x-rays performed, which noted a plate and screw device traversing the wrist wlth anchoring screws into the distal radius and third metacarpal, this with narrowing of the radrocarpal and intercarpal spaces with partial resection of the proximal pole of the scaphoid There was no acute fracture or dislocation, and alignment appeared to be maintained Impression was status post arthrodesis and plate and screw device with alignment reasonably malntained.7" Ms. Harvat's cast was recently removed. No doubt, she will have persistent impairment (PPl), however, further treatment is not reasonably nacessary end appropriate solely for the allowed condition of arthropathy. Dr. Keith notes good alignment and Ms. Horvat reported'5 her pain as gone. I thank you very much for allowing me to participate in the evaluation of this employee If I can be of further assistance to you, please do not hesitate to contact me to J. BorriUo, M.D., J.D., M.S. DJB:tmm NOV 0 5 2007 " See Dr. Arnson report of 08l24107 'S See 08124/07 repon of Dr Keith EXHIBIT N zz a 1161 899 oss li flWOH 3oa1a8Wtlo Ll:Iot Looz-Ngts 111