Your Case. Matters. It has been a busy few months here at Wilkes & McHugh as our attorneys keep racking up the headlines with

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1 Your Case WILKES & McHUGH, P.A. Matters December 2010 It has been a busy few months here at Wilkes & McHugh as our attorneys keep racking up the headlines with multi-million dollar verdicts! They earned three major nursing home verdicts in three different states, including a $114 million record-setting award in Polk County, Florida. They also secured a $3.2 million verdict for a victim of professional negligence in California, and fought for a family injured in a tractor-trailer crash in Arkansas. That case resulted in a $10.3 million verdict and $20.5 million in pre-trial settlements. Of course, Wilkes & McHugh attorneys stay busy with more than just important trials and large verdicts. They also work to make sure our clients win significant appeals and fight for key court rulings that have changed law for the better. Read on in this latest issue of Your Case Matters to learn more about all of the amazing things our firm has accomplished since our last edition. Arkansas jury awards $10.3 million to family burned in truck accident Record $114 million verdict for nursing home victim Woman s family wanted her to regain strength so she could come home, but instead she received a fracture and bedsores that led to death. A Prairie County jury awarded $10.3 million to the family of an Iraq War veteran who was burned while rescuing his wife and two children after a devastating collision. On July 22, 2008, Mark Rogers and his On July 20, 2010, a Polk County jury handed down a $114 million verdict in a nursing home abuse case that resulted in an elderly woman s death. It is believed to be one of the largest verdicts ever in Polk County, Florida. The family of Juanita Jackson, a 76-year- Juanita Jackson Continued on page 3 Continued on page 2

2 R e c e n t V e r d i c t s Record verdict in Polk County, Florida case Continued from page 1 old homemaker and mother of four, had to place her in nursing home for rehabilitation in March Their plan was for Juanita to regain her strength at IHS of Florida at Auburndale (now known as Auburndale Oaks Healthcare Center) so they could resume caring for her at home. But that was not to be. The nursing home staff knew when Juanita Jackson was admitted that she was at risk for falls, but they did not put proper preventative measures in place. Within two weeks of her admission, they allowed her to fall. It was a catastrophic injury; Jackson suffered a closed head trauma and Blair Mendes Lance Reins least one that rotted to the bone. They didn t give her enough to eat and drink, causing her to become malnourished and dehydrated. Juanita was also overmedicated during her stay. She was left to lie in bed so long that she developed contractures, where the muscles shrivel up, making movement even more difficult. Jackson s family removed her from the nursing home on May 30, 2003, but it was too late. Her health continued to deteriorate, and she died July 6, We hope this verdict will send a message to nursing home operators, especially big corporations, that it is not acceptable to put profits before people, Blair Mendes said. Nursing home residents deserve attentive, dignified care. Trans Healthcare, Inc. and Trans Healthcare Management operated the nursing home at the time of Jackson s residency. During that period, the company also operated more than 200 nursing homes in 22 states and was the largest private nursing home chain in the United States. The jury heard from former caregivers, including a staffing coordinator, a certified nurse s assistant and a nurse, who all testified about the terrible conditions at the home. There was not enough staff or supplies, and the residents suffered as a result. They also heard testimony from a doctor and a We are proud that we fought for our mom, and we are glad that people recognized the suffering she went through. We hope this will help make sure no one else has to go through such a horrible experience. Statement from Juanita Jackson s family fractured her upper arm. She never fully recovered from her injuries and became more dependent on the nursing home staff than ever before. The nursing home also was chronically short-staffed with overworked employees. Patients suffered. Juanita Jackson suffered. They didn t turn her enough or elevate her heels to prevent the development of bedsores. She got multiple bedsores, including at medical expert about how Juanita Jackson s terrible injuries resulted from the poor treatment and led to her death. Blair N. Mendes and A. Lance Reins represented Jackson s family in the case. While a verdict like this will not bring Juanita Jackson back, we hope that it will make a difference for her family, as well as all nursing home residents in Polk County, said Lance Reins. 2

3 R e c e n t V e r d i c t s Courtesy of Arkansas State Police The Rogers vehicle (the charred mass at center) was pinned among a caravan of tractor-trailers and caught fire. Mark Rogers, a 34-year-old staff sergeant in the U.S. Army Reserves, had to kick in the windshield to rescue his wife and two young children. Three of the four family members were severely burned. W&M attorneys negotiate $20.5 million in settlements Continued from page 1 Jim Freeman Jim Wilkes family were traveling through Arkansas while on vacation when their car was corralled by several tractor-trailers. One of the rigs ignited, and the fire spread, setting Rogers car on fire. His was the only door that would open, so the 34 year old escaped and kicked in the windshield to rescue his wife, daughter and son. In total, six tractor-trailers were involved in the catastrophic accident that left three of the four Rogers family members severely burned. Jim Wilkes and Jim Freeman represented the Rogers family. Five of the companies settled before the trial for a total of $20.5 million. U.S. Xpress, Inc. denied liability and the case went to trial on Sept. 23, Wilkes argued that U.S. Express Inc. driver Charles Daniels was following too closely and rear-ended a tractor-trailer owned by Triad Transport Inc., causing it to trap the Rogers family in their burning Pontiac. Daniels failed to maintain appropriate speed and distance, and violated other safety regulations, according to the lawsuit. It took a Prairie County jury only two hours to deliberate. At the time of the accident, Mark Rogers was a staff sergeant in the U.S. Army Reserves. He had recently returned from his second tour in Iraq, where he served as a combat engineer. In an ironic twist of fate, Staff Sgt. Rogers was a K-9 handler who searched for explosives in Iraq with the goal of maintaining safe highways. 3

4 R e c e n t V e r d i c t s $42 million in nursing home death case The cause of the Kentucky nursing home death was painfully simple: Joseph Clint Offutt became lethally dehydrated despite having a feeding tube, said Lisa Circeo. The nursing home simply failed to ensure he got enough water to live. Offutt was abused, neglected and ultimately died in a Madisonville nursing home. As a result, a Hopkins County jury saw fit to award a $42.75 million verdict to Offutt s family. Offutt was one of seven children who grew up on a farm and served in World War II. He was married for 58 years and was still planting crops at age 88. A stroke weakened him in 2007, and his devoted wife, Pearline, cared for him at home for eight months before the family realized he needed professional care. The 92-year-old man was in Harborside of Madisonville from March 25, 2008, until April 3, Just nine days. He was transferred to Regional Lance Reins Lisa Circeo Medical Center and died on April 5, Offutt s family filed a wrongful death lawsuit in 2009 against Harborside Healthcare Madisonville This jury sent a clear message to nursing home operators in Kentucky and elsewhere that you cannot profit at the expense of the people you are responsible for caring for. Lance Reins and Sunbridge Healthcare Corp. Circeo, along with Lance Reins, represented the Offutt family in the case. The trial lasted three weeks and ended on Nov. 16, In the complaint, the family alleged that the defendants neglected Mr. Offutt, causing him to suffer many injuries, including severe dehydration, malnutrition, bedsores, infections, and ultimately death. The Adult Protective Service Department of the Commonwealth of Kentucky substantiated the allegations of neglect, according to the lawsuit. Circeo and Reins presented evidence at trial that the nursing home was part of one of the largest for-profit nursing home companies in America. It generated $1.8 billion in revenue in the year that Mr. Offutt resided there and ultimately put profits over people. The jury awarded $1 million for Mr. Offutt s pain and suffering, $1.75 million for Mrs. Offutt s loss, and $40 million for punitive damages. 4

5 R e c e n t V e r d i c t s Morphine overdose causes brain injury in woman Jury awards $3.2 million in damages; Doc and rehab center liable A California woman underwent surgery for a torn tendon and ended up with a brain injury because she was given too much morphine. In August, an Orange County jury awarded her a $3.2 million verdict in the case. Kim Valentine and Jennifer Turner represented the victim, Barbara Lefforge. Lefforge, 55 at the time of the incident, underwent a surgery to repair a torn tendon. She was admitted to Covenant Care of California, LLC (doing business as St. Edna s Subacute and Rehabilitation Center) that same day for a one-week stay for rehabilitation. The surgeon, Dr. Wesley Kobayashi, wrote a prescription for 50 milligrams of morphine for pain, and the staff at St. Edna s had the prescription filled. The pharmacy notified St. Edna s staff that the morphine order was unusually high. Although procedure requires that the resident s attending physician approve medication orders, staff of the facility did not obtain the attending physician s approval to administer the morphine injection. The nurse who administered Kim Valentine Jennifer Turner the injection testified that he knew that the dose was too high and that a morphine overdose could lead to respiratory depression, yet he did not monitor Ms. Lefforge more closely. She began to have trouble breathing and was transferred by ambulance to Garden Grove Emergency Room. She was later seen at UCLA Medical Center, where the neurology team concluded that she had suffered brain damage as a result of the morphine overdose at St. Edna s. This resulted in problems with coordination, severely reduced thinking abilities, and impaired judgment. She spent more than six months after her discharge relearning how to walk, talk, eat, and groom herself. Since then, she has required 24-hour supervision to assist her with daily activities. St. Edna s claimed at trial that the nurses had done nothing wrong. No nurse involved in Ms. Lefforge s care was disciplined or fired. Following eight weeks of trial, the jury deliberated for more than two days and rendered a unanimous verdict that Covenant Care of California LLC, d/b/a St. Edna s Subacute and Rehabilitation Center, was liable for neglect of a dependent adult. The jury also found that Covenant Care of California, LLC and Dr. Wesley Kobayashi were liable for negligence. After the jury reached its verdict and prior to the punitive damages phase of trial, the parties reached a confidential settlement. The doctor prescribed too much morphine. The pharmacy notified the hospital staff that the dose was too high, and the nurse admitted he knew it was too high, but the woman still got an overdose and suffered a brain injury. 5

6 R e c e n t V e r d i c t s $5 million judgment awarded for assault, abuse A 77-year-old woman was allegedly sexually assaulted in nursing home On Aug. 12, 2010, a Fayette County judge issued a $5 million judgment in a nursing home case where an elderly woman was abused including sexually assaulted and eventually died. While no amount of money will ever bring Ms. Biehl back or undo the wrongs that were Cameron Jehl done to her, her family hopes that this judgment will send a message, said Cameron Jehl. Families will not stand for their loved ones being neglected and abused. Pauline Biehl was a resident at Gallaway Healthcare Center in Fayette County, Tennessee, from April 6, 2002, to Feb. 4, While there, she suffered catastrophic injuries including: dehydration, weight loss, malnutrition, two sexual assaults, six falls, skin tears, pressure sores, urinary tract infections, urosepsis, and more. The defendants also failed to properly monitor the 77-year-old s medications, which caused her neck to become hyper extended a painful condition that made it hard for her to swallow. As a result of these injuries, Biehl endured extreme pain, disfigurement and embarrassment. She required medical attention and hospitalization. Her overall health deteriorated, and she eventually died on March 1, Before Biehl entered the nursing home, she lived with her daughter Wendy Elliott for 10 years. After her mother died, Elliott sued the nursing home for negligence, gross negligence, negligence pursuant to the Tennessee Medical Malpractice Act, violation of the Tennessee Nursing Home Residents Rights Act, violation of the Tennessee Adult Protection Act, and wrongful death. After six years of litigation, the defendants attorneys withdrew from the case, and they never bothered to hire new counsel. Judge Weber Mc- Craw issued a default judgment against the defendants for $2.5 million in compensatory damages and $2.5 million in punitive damages. The hearings on damages occurred over two days: July 26, 2010, and Aug. 12, Witnesses called to testify included Wendy Elliot, as well as a former nurse, certified nurse s assistant, and assistant director of nursing for the home. Expert testimony from Dr. David Sparks and the other witnesses revealed the nursing home was understaffed to increase its profits, which created dangerous conditions for the residents. A state survey of the nursing home from Oct. 3, 2002, found that the residents were in immediate jeopardy. Memphis attorney Cameron Jehl represented the family in the case. From medical expert Dr. David Sparks report: 6

7 P r o f e s s i o n a l A w a r d s a n d A c t i v i t i e s 4 named Tampa Bay s Top Lawyers W&M attorneys impart their expertise around the country Jim Wilkes Tim McHugh Jim Freeman Bennie Lazzara Jeff Priebe Jeff Priebe spoke at the Arkansas Trial Lawyers Association s Personal Injury continuing legal education seminar in Little Rock on the topic It s Free, so use it! Arkansas Freedom of Information Act & Your Personal Injury Case. Four W&M attorneys were named Tampa Bay s Top Lawyers in the July/August edition of Tampa Bay Magazine. The magazine composed its list based on a study conducted by LexisNexis Martindale-Hubbell. The Martindale-Hubbell Peer Review Ratings identifies lawyers who have been rated by their peers to be AV Preeminent the highest rating available. LexisNexis Martindale-Hubbell invites lawyers and members of the judiciary to provide confidential reviews of lawyers of whom they have professional knowledge. These opinions are the basis for the ratings. The attorneys who make the list have reached the highest level of ethical standards and professional excellence, according to Tampa Bay Magazine. Jim Freeman was featured under Health Care litigation; Bennie Lazzara Jr. was featured under Medical Malpractice litigation; and firm founding partners Jim Wilkes and Tim McHugh were featured under Nursing Home Rights litigation. Their names can be found online at Lawyers.com, martindale.com, and Lexis.com, or in print in the Martindale-Hubbell Law Directory. Lisa Circeo Bob Edwards Lexington attorney Lisa Circeo and Little Rock attorney Bob Edwards spoke at the Kentuckians for Nursing Home Reform s educational seminar in Lexington. The topic was: Nursing Home Abuse or Neglect... You May Need a Lawyer, and they were part of a panel of experts explaining to families what they should look for in terms of abuse and neglect of their loved ones in nursing homes. PA attorney elected to justice association board Michael Collis Pittsburgh attorney Michael Collis has been elected to the Pennsylvania Association for Justice Board of Governors. The mission of the PAJ is to promote a fair and effective justice system, as well as support attorneys as they work to ensure that any individual injured by the misconduct or negligence of others can obtain justice. As a member of the Board of Governors, Michael will participate in the PAJ s legislative program, attend quarterly board meetings and also evaluate current judicial, legislative and political developments as they relate to the civil justice system in Pennsylvania. Wilkes & McHugh, P.A Bennie Lazzara D Army Bailey Bennie Lazzara Jr. recently spoke at an American Association for Justice convention on the topic of using depositions of certified nursing assistants to develop a nursing home case. D Army Bailey spoke at the W. Harold Flowers Law Society luncheon at the University of Arkansas at Little Rock William H. Bowen School of Law. He also spoke at the National Bar Association convention in New Orleans, and the American Bar Association s fall conference, More to Overcome: Civil Rights in the 21st Century, which the firm also sponsored. 7

8 C o u r t R u l i n g s, A p p e a l s a n d M o r e Pennsylvania Superior Court ruling puts nursing homes on hook for neglect, abuse In a landmark appeals opinion published July 15, the Pennsylvania Superior Court held that Pennsylvania nursing homes, as well as their owners and operators, could be held directly liable under a corporate negligence theory. Before this case, only hospitals and HMOs could be sued under such a theory. Also, nursing home corporate owners and management companies in Pennsylvania now could face direct punitive damages liability when they understaff their nursing homes, allow records to be falsified, deceive state surveyors, recklessly fail to oversee that quality care is provided, etc. This is the first case in Pennsylvania to have such a holding, said Pete Giglione. Prior to it, we were usually required to seek punitive damages through vicarious liability, i.e., by proving that the conduct of the employees was reckless, intentional, willful, wanton, etcetera, and to meet that burden, we had to show that the employer/owner was aware of what the employees were doing and allowed it to occur. Now, [owners and operators] are directly on the hook. Implicit in this ruling: Evidence of understaffing by state and federal minimum staffing standards, failures of corporate oversight, records falsification, deceiving state surveyors, and other offensive behavior is relevant and admissible at trial in a nursing home case. Typically, the defendants usually Peter Giglione Bennie Lazzara Stephen Trzcinski Joe Ficarrotta try to have such evidence excluded from trial and/or have it struck from lawsuits, Giglione said. This Superior Court ruling stems from a case that began in 2005 when Richard Scampone filed a lawsuit against Highland Park Care Center and Grane Healthcare on behalf of his mother, Madeline Scampone. At the 2007 trial, his attorneys proved that Madeline Scampone, a resident at Highland Park Care Center, died on Feb. 9, 2004, from complications related to severe dehydration and a urinary tract infection. Nurses notes show that before being taken to the hospital where she died, Madeline Scampone had been crying for water and hadn t consumed fluid in several days. Former employees testified that the nursing home was chronically understaffed, medical records were falsified, water was not given to the residents because staff did not have time, and administration would deceive state surveyors by increasing staffing levels during inspections. The jury found that the defendants were negligent, had caused harm to and killed Madeline Scampone. They awarded $193,500 in compensatory damages. However, the court would not allow plaintiffs to seek punitive damages from the jury against the nursing home and dismissed its parent company, Grane Healthcare, from the lawsuit. But the new Superior Court ruling reverses those decisions. The Superior Court found that Grane was approving the budget, oversaw the quality of patient care, had nurse consultants visiting the building, was placed on notice of problems with staffing, and was actively engaged in records falsification. The appeals court sent the case back to the trial court for a new trial, this time including Grane Healthcare and giving a jury the chance to assess punitive damages. A new trial has not yet been scheduled, but in the meantime, the Superior Court s opinion is now binding Pennsylvania law. Wilkes & McHugh, P.A. attorneys Bennie Lazzara Jr., Pete Giglione, and Joe Ficarrotta served as trial counsel for the plaintiff, and Stephen Trzcinski and Pete Giglione handled the appeal. 8

9 C o u r t R u l i n g s, A p p e a l s a n d M o r e Appeals court upholds $65 million verdict In August, the Florida Second District Court of Appeal upheld a $65 million verdict in a case where a 19-year-old woman was catastrophically injured by a tractor-trailer. This is the largest pain and suffering award affirmed by an appellate court in Florida, said Isaac Ruiz-Carus, a Tampa attorney who handled the appeal. In 2007, Kendra Lymon s life was shattered when an 18-wheeler, owned by Bynum Transport Inc. and driven by Robert Bohn, T-boned her Dodge Neon at the intersection of State Roads 35 and State Road 64. She had no Isaac Ruiz-Carus pulse when emergency personnel arrived at the scene. She was in a coma and hospitalized at Tampa General Hospital for months and still needs aroundthe-clock care. Bohn did not have the 10 hours of off-duty time before driving that day a rest period the Federal Motor Carrier Safety Rules require. Bynum Transport had no system in place to monitor its drivers hours of rest. On March 20, 2009, a Polk County jury found the defendants were 100 percent at fault and awarded Lymon $65 million. The defendants filed a motion for a new trial, which the judge denied. They then appealed that judgment and the verdict to the Second District Court of Appeals. Ruiz-Carus made oral arguments on Aug. 4, 2010, and on Aug. 13, the three-judge panel upheld the trial court s decision. Bennie Lazzara Jr. and Jim Freeman were the trial lawyers for the case. How can Wilkes & McHugh, P.A. help you? Our experience is diverse. Our practice areas include: Nursing home abuse and neglect Automobile and trucking accidents Catastrophic injuries Wrongful death Product liability Corporate misconduct and consumer protection Medical malpractice and other professional negligence Current product liability issues we are following include: DEFECTIVE HIPS -- Johnson & Johnson s DePuy Orthopaedics recalled its ASR XL Acetabular System and ASR Hip Resurfacing System, and Zimmer Inc. removed its Durom Cup (or Durom Acetabular Component) from the market because of high failure rates that caused pain and led to additional surgeries. OVERPRICED DRUGS -- Pfizer tried to prevent Americans from having access to generic forms of its popular cholesterol-lowering drug, Lipitor. Some consumers might have paid too much for their medication. DANGEROUS DRUGS -- The Food & Drug Administration acknowledged that the popular diabetes drug, Avandia, poses greater cardiovascular risks and has since increased the warnings on the label. People who suffered heart attacks or heart failure while taking the drug might be entitled to compensation. The birth control pill, Yaz, has been linked to serious problems, including stroke, blood clots, DVT and pulmonary embolism, that could be caused by the type of synthetic progestin in Yaz birth control called drospirenone. 9

10 N e w A t t o r n e y s a t W & M W&M welcomes 8 new faces to our nationwide team! Adrienne Wilson, Arizona Adrienne Wilson earned her law degree from William Mitchell College of Law in St. Paul, Minnesota, in In her nearly 20 years of practice, she has represented victims of personal injury, medical malpractice, and nursing home neglect. She also has experience in civil matters and employment law. Deena Knopf, Tennessee Deena Knopf received her law degree, cum laude, from the University of Memphis Cecil C. Humphreys School of Law in Before joining Wilkes & McHugh, P.A., Ms. Knopf was with Cordts & Gulley, PLLC, where she practiced criminal defense. Donna Oh, Arizona Donna Oh received her bachelor s degree in Business and Psychology from Lewis & Clark College, and her law degree from Baylor Law School. Before joining Wilkes & McHugh, P.A., Ms. Oh practiced in the areas of personal injury, product liability, and insurance defense. Ryan J. Duty, Pennsylvania Ryan J. Duty received his law degree, cum laude, from Duquesne University School of Law in Pittsburgh in He received the CALI Award of Future Excellence, among other honors. Before joining Wilkes & McHugh, P.A. as an attorney, Mr. Duty worked for the firm as a law clerk. Richard Murphy, Arizona Richard Murphy received his law degree from the University of Notre Dame Law School in Mr. Murphy has represented workers and their families injured or killed by exposure to asbestos. In addition, he has also represented victims of medical malpractice, construction negligence, and automobile accidents. Rob Salyer, Kentucky Rob Salyer received his law degree from The Ohio State University in Mr. Salyer has practiced commercial litigation, intellectual property litigation, and criminal defense. He has had a particular focus in appellate law, both civil and criminal, with several cases reported in West s Reporter Series. Mary Perry, Florida Mary J. Perry earned her law degree from Harvard Law School. She spent eight years with Wilkes & McHugh before leaving to start a solo practice focused on serious personal injury, wrongful death, medical neglect and more. Ms. Perry recently rejoined W&M to tackle fraudulent corporate transactions and transfers. Sandra Sutter, Kentucky Sandra D. Sutter earned her law degree, graduating magna cum laude from the University of Florida Levin College of Law. Last year, Ms. Sutter managed a solo practice that focused on small business, employment, creditor-debtor and family law matters, as well as provided family mediation and guardian ad litem services. You can read more about all of our new attorneys at 10

11 C o m m u n i t y A c t i v i t i e s a n d E v e n t s W&M employee walked 60 miles in 3 days to raise money for cancer W&M attorneys meet with Memphis Baptist Ministerial Association The firm cosponsored Peggy Tyre, a registered nurse in the Tampa office, in the Susan G. Komen 3-Day for the Cure walk. She raised $2,855 and made the 60- mile trek in Washington, D.C., in honor of friends and loved ones, including those of other W&M employees. Pictured is Peggy (center) with her daughter, Kristin Kreizenbeck (right) and friend Meghan Byrne. We are so proud of Peggy and her amazing accomplishment! The walk raised $5.3 million for breast cancer research. The firm hosted a luncheon for the Memphis Baptist Ministerial Association, which is an organization of more than 400 pastors and ministers and includes some of the most respected leaders in the community. Besides enhancing their own personal ministries, the association often tackles issues that affect the health of the community, such as infant mortality and HIV/AIDS. W&M attorney D Army Bailey spoke at the event. Pictured, from left: the Rev. Willie Jamison, D Army Bailey, the Rev. DeMarcus Smith, and the Rev. Dontarius Tate. Firm partners with MDA to raise money for research, services Tampa community and business leaders meet and mingle Photo by MDA Coordinator Paula Orandash. W&M sponsored a team for the inaugural Tampa Bay Muscle Walk 2010, which was a fundraiser for the Muscular Dystrophy Association. MDA is a nonprofit agency dedicated to curing muscular dystrophy and related diseases. The Wilkes & McHugh Wayfarers raised $1,428, which the firm matched for a total of $3,000. Pictured here is team captain Jim Freeman (center), his wife, Carla Jimenez (left) and legal assistant Jennifer Walchok. Thanks to all W&M employees who participated! Tampa attorney Lydia Wardell, center in white, regularly represents Wilkes & McHugh, P.A. at luncheons at The Columbia in Ybor City. The events offer business and community leaders a chance to meet and share ideas. Next to Lydia is Tampa Police Chief Jane Castor. Newsletter editor and designer: Ashley McKnight-Taylor 11

12 F i r m L o c a t i o n s WILKES & McHUGH, P.A. One North Dale Mabry Highway Suite 800 Tampa, FL / FIRST-CLASS MAIL U.S. POSTAGE PAID MAILED FROM ZIP CODE????? PERMIT NO. xxx Florida main office Toll-free: 800/ n. dale Mabry highway SUITE 800 Tampa, FL Arizona Toll-free: 866/ East camelback road suite 910 Phoenix, AZ Toll-free: 866/ N. Wilmont Road Suite 340 Tucson, AZ Wilkes & McHugh, P.A. Office Locations Arkansas Toll-free: 888/ information way Suite 300 Little rock, AR WTennessee M Toll-free: 888/ South main street Suite 101 Memphis, TN Kentucky Toll-free: 800/ north Broadway Lexington, KY Pennsylvania Toll-free: 800/ market street Suite 1250 Philadelphia, pa Toll-free: 800/ William penn place suite 3110 Pittsburgh, pa California Toll-free: 877/ Kilroy Airport Way Suite 220 Long beach, CA This newsletter is a periodic publication of Wilkes & McHugh, P.A. and should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult a lawyer concerning your own situation with any specific legal question you may have. Each case is different and similar results may not be obtained in your case. Past performance is no guarantee of future outcomes. Results obtained depend on the facts in each case. No representation is made that the quality of the legal service to be performed is greater than the quality of legal service performed by other lawyers. The choice of a lawyer is an important decision and should not be based solely upon advertisements. Services may be performed by other lawyers in the practice instead of the ones mentioned in this publication. 12