Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 Report of Mr Abdul Jalil Dated: 150820220 Specialist field: Emergency Medicine On behalf of the Claimant: Mrs Pauline Hennessy(Deceased) DOB: 05061953 Address: C/o 14 Stadium Close, Willenhall, WV13, 1EG Subject matter: Clinical Negligence? Instructing Party: Emsleys Solicitors Defendants: Care home Expert: NA Title of the Action; Clinical Negligence at the care home Reference Number: PH/2020/CN/AJ I examined Mr Burma Fox on 01st of January 2000, at 9.45 am in Consultation Rooms, Spalding, PE11 1QQ. He was unaccompanied during the examination. I used his passport to confirm his identity. Name Dr. Abdul Jalil Address 123 Justice Road, Peace Court, Fondon, L23 45M Telephone 0123-456789 Fax 0123-456788 Email medicolegal123@kmail.com Contents Page Numbers 1 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 1. Introduction 3 2. Interview and investigations of the facts 4 3. Losses consequential to injury 5 4. Examination 5 5. Review of medical records 6 6. Opinion 7 7. Prognosis 7 8. Recommendations 7 9. Prospects in the open labour mark 7 13. Statement of Compliance 8 Appendices 1. List of documents examined 2. Literature reviewed 3. Glossary of technical terms 4. Other 1. Introduction: 2 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 I am Abdul Jalil. I am a Consultant in Emergency Medicine (EM). My qualifications are BSc, MBBS, FRCS and FRCEM. As an EM Consultant, I deal daily with the entire spectrum of acute injuries ranging from the treatment of minor injuries to the resuscitation of patients with severe, life-threatening injuries. I report over 200 cases yearly for personal injury claims for over six years now. 1.01 Summary of the case: The claimant told me that he works for a vegetable packing firm, and his job involves travelling from factory to field every day. The claimant stated that on 01/12/1999 when the driver of the company’s van had to apply emergency brakes to avoid an accident, his back suffered a jolt, and the next morning the claimant developed severe lower back pain. 1.02. The instructions: I have been instructed by The Best Solicitors to assess the severity of the injury, the effect of the injury on claimant’s ability to work and expected time required for recovery as stated in their letter of instruction, November 1999. 1.03 Summary of my professional opinion: 1.03 (a) The claimant sustained a sprain of his lower back in the index accident. 1.03 (b). The claimant told me that he is still unable to carry his duties at work and this is consistent with the findings of my examination. 1.03 (c) It would be reasonable to attribute a period of up to four months’ worth of symptoms to the injury sustained in the index accident and any symptoms beyond that period should be considered constitutional in origin. 2. My interview with the Claimant and medical examination on 01st Jan 2000. 3 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 2.1. Past Medical History: There was no relevant past medical history. 2.2. Accident details: The claimant informed me that he works for a vegetable packing firm and his job involves travelling from a factory to the farm every day. The claimant stated that on 01/12/1999 when the driver of the company’s van was driving at the speed of 60mph, the driver had to apply emergency brakes to avoid an accident, which caused a jolt and the claimants back suffered a severe jolt. 2.3. Injuries sustained: The claimant felt a pop in his back, and he developed sudden severe lower back pain. The claimant has not been able to work since the injury. There was no other complaint. 2.4. Present Complaints: a) Physical: The claimant reported ongoing pain in his lower back. b) Psychological: The claimant reported no psychological symptoms. 2.5. Psychological symptoms: The claimant did not report having any psychological symptoms. 2.6. Treatment, past, present and future: The claimant told me that he stopped working, went home and started taking Paracetamol for pain. He consulted his GP next morning who examined him and referred him to the Accident and Emergency Department where initial treatment comprised of analgesia and X-Rays of his lower back was taken, which showed an undisplaced fracture of the transverse process of his fourth lumbar vertebra. 2.7. Current treatment: The claimant is regularly taking Tablet Co-Codamol for pain and Tablet Naproxen for pain and inflammation. 2.8. Future Treatment: I am not aware of any future treatment planned for the injuries sustained in the indexed accident. Review of medical records. 3 Losses consequential to injury: 4 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 3.01 Employment. The claimant is still off work 3.02 Living Circumstances & Daily Living. The claimant lives with his wife. The claimant reported ongoing moderate to severe restriction in performing daily chores like cooking, washing and hovering. He has not been able to do gardening. His sleep is also affected and wakes up at night on changing position in bed. He is getting help from his wife. 4 Physical Examination: 4.01 General observation. The claimant was able to walk into the Examination Room unaided and but appeared to have a stiffened back and used the back of the chair to get support while sitting in the chair. There were no signs of the psychological overlay. The claimant is right hand dominant. 4.02 Examination of the Neck Full range of pain-free Forward flexion. Full range of pain-free Extension. Full range of pain-free Right rotation. Full range of pain-free Left rotation. Full range of pain-free Right lateral flexion. Full range of pain-free Left lateral flexion. 4.02 Examination of the Upper Limbs Full range of pain-free movements in both shoulder joints. Full range of pain-free movements in both elbow joints. Full range of pain-free movements in both wrists. Full range of pain-free movements in hand with normal grip. 5 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 4.03 Examination of the Lower Limbs: Full range of movements in both hip joints associated with pain in the lower back. Full range of pain-free movements in both knee joints. Full range of pain-free movements in both ankle joints. Squat and rise was not possible because of the pain in the lower back. 4.03 Examination of the Back: The Paraspinal muscles were tight on palpation, and there was significant tenderness along the right side of L4 L5, which was marked around the transverse process of L4. The claimant was unable to flex his back more than 30 degrees. Right straight leg raise test was around 20 degrees. Left straight leg raise test was around 50 degrees. 4.04 Injuries, Wounds, and Scars: No wounds or scars were seen. Opinion The injuries are consistent with the accident and are attributable to the accident on 01/12/1999. The claimed problems with the claimant’s home life are consistent and reasonable. The treatment has not been sufficient, and the claimant should have had physiotherapy to facilitate recovery from symptoms. 6 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 Prognosis: The pain in the lower back is due to the musculoskeletal injury due to the trauma sustained in the accident. It is currently causing moderate to severe disability. I recommend that physiotherapy treatment and anticipate that on the balance of probability, with appropriate treatment, the pain in the lower back will resolve over the period of four months since the indexed accident. Future Treatment: I recommend seven sessions of physiotherapy treatment in total. Prospects on the open labour market: The claimant is restricted at work. In my opinion, on the balance of probability, the claimant is expected to have recovered to resume his normal duties within a period of four months from the indexed accident. Statement of compliance I understand my duty as an expert witness is to the court. I have complied with that duty and will continue to comply with it. This report includes all matters relevant to the issues on which my expert evidence is given. I have given details in this report of any matters which might affect the validity of this report. I have addressed this report to the court. I further understand that my duty to the court overrides any obligation to the party from whom I received instructions. Declaration of Awareness I confirm that I am aware of the requirements of Part 35 and Practice Direction 35, and the Guidance for the Instruction of Experts in Civil Claims 2014. Statement of truth I confirm that have made clear which facts and matters referred to in this report are within my knowledge and which are not. Those that are within my knowledge 7 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 I confirm to be true. The opinions I have expressed represent my true and complete professional opinions on the matters to which they refer. Statement of conflicts I confirm that I have no conflict of interest of any kind, other than any which I have already set out in this report. I do not consider that any interest which I have disclosed affects my suitability to give expert evidence on any issue on which I have given evidence, and I will advise the part by whom I am instructed if, between the date of this report and the trial, there is any change in circumstances which affects this statement. Signed Mr Abdul Jalil Date: 01012000 MBBS, BSc, FRCS, FCEM GMC: 4596950 8 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 Appendix 1 Curriculum Vitae Name: Mr Abdul Jalil Date of Birth: 19.04.1962 Year first appointed as a consultant: December 2008 Medico-legal experience (including % for Plaintiff and Defendant): I report over 200 cases yearly for personal injury claims for over six years. The majority of the cases are on behalf of the plaintiff. The Bond Solon Civil Procedures Rules course for an Expert witness on 09012012. Special skills: I have been working in A & E as a Consultant since December 2008. I have over five years’ Experience in General Surgery, four years in Orthopaedics, a year in General Medicine and over 17 years in Emergency Medicine. I am a human factor trainer. I manage claims made against the trust for Clinical Negligence. 9 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 I answer complaints and attend Coroner’s court. Education & Qualifications: MBBS University of Peshawar, Pakistan, 1986. BSc, University of Peshawar, Pakistan, 1989. FRCS, Royal College of Surgeons of Edinburgh, 1998. FCEM, College of Emergency Medicine, 2010. Pg. Cert in Health Care Education July 2017. Training: General Medical Training 1986-1988). Specialist Training in General Surgery (1989-1995) Specialist training in Orthopaedics. (1996-1999) Associate Specialist in A & E, (2000-2008). Consultant in Accident and Emergency (2008- to date). Publications Posters presented in EuSEM 2016 #1919- The appropriateness of requests for Chest X-Rays from the Department of Emergency Medicine. Abdul Jalil, Faisal Fasih, Juan Ballesteros (UK). #1922-Significance of a post-manipulation radiograph in a shoulder dislocation. Abdul Jalil, Juan Ballesteros (UK). #1899- An audit of the “Failsafe Mechanism” to identify and manage missed diagnosis on Radiographs in the Department of Emergency Medicine. Abdul Jalil, Muhammad Islam (UK). 10 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 Professional affiliations: General Medical Council. Medical Defence Union. Fellow of the Royal College of Emergency Medicine. Member British Medical Association. Last five years appointments in reverse chronological order. Consultant in EM at Alexandra Hospital Redditch since Aug 2015 to date. Consultant in EM, Doncaster Royal Infirmary from Dec 2008 until Aug 2015. Additional Posts currently held: Medical Director Angelique Health Services and Supplies Limited. Contact For enquiries about medico-legal work, please contact me by email at medicolegal19@gmail.com Mobile; 07725999530 Postal address; 305-Evesham Road Redditch Worcestershire B97 5HL 11 Mr. Abdul Jalil, Expert Emergency Physician On behalf of The Emsleys Solicitors Client’s name: Mrs. Pauline Hennessey(Deceased) Date: 15082022 Date of the incident:18072020 Appendix 2. References; 1. https://www.sciencedirect.com/science/article/pii/S0002961027904401 2. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2776377/ 3. https://academic.oup.com/omcr/article/2015/5/288/1500395 4. GP Records. 5. Hospital notes. 12