IN THE COURT OF COMMONPLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`MARK MORTLAND,
`
`CIVIL DIVISION
`
`Plaintiff,
`
`Docket No. : GD-19-011711
`
`VS.
`
`ARIE. PRESSMAN,M.D., THE
`ORTHOPEDIC GROUP, UPMC MERCY,
`and UPMC,
`
`PLAINTIFF’S PRETRIAL STATEMENT
`
`Filed on behalf of Plaintiff:
`
`Defendants.
`
`Mark Mortland
`
`Counsel of Record forthis Party:
`
`Peter D. Friday, Esquire
`Pa LD. #48746
`pfriday @ fridaylaw.com
`
`Joshua S. Licata, Esquire
`Pa LD. #318783
`Jlicata @ fridaylaw.com
`
`Tan M. Watt, Esquire
`Pa ID. #324364
`iwatt @fridaylaw.com
`
`Friday & Cox LLC
`1405 McFarland Road
`Pittsburgh, Pennsylvania 15216
`Tele # (412) 561-4290
`Fax # (412) 561-4291
`
`JURY TRIAL DEMANDED
`
`

`

`IN THE COURT OF COMMONPLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`MARK MORTLAND,
`
`CIVIL DIVISION
`
`Plaintiff,
`
`Docket No. : GD-19-011711
`
`VS.
`
`ARIE. PRESSMAN,M.D., THE
`ORTHOPEDIC GROUP, UPMC MERCY,and
`UPMC
`
`Defendants.
`
`PLAINTIFEF’S PRETRIAL STATEMENT
`
`Plaintiff, Mark Mortland, by and through his attorneys, Peter D. Friday, Esquire, Joshua
`
`S. Licata, Esquire, Ian M. Watt, Esquire, and Friday & Cox LLC, and in accordance with
`
`Pennsylvania Rules of Civil Procedure 212.2, files the within Plaintiff’s Pretrial Statement:
`
`I.
`
`STATEMENT OF THE CASE
`
`This medical malpractice action stems from surgery performed by Defendant Ari E.
`
`Pressman, M.D. on August 6, 2016 at UPMC Mercy. On this day, Mark Mortland underwent a
`
`right hip resurfacing surgery involving the insertion of an acetabular cup and femoral head
`
`prosthesis. During this surgery, Dr. Pressman deviated from the standards of care in that he
`
`caused an intraoperative fracture of plaintiff’s acetabulum with extension downinto the ischium
`
`due to implanting an over-sized femoral head prosthesis, while also leaving a piece of his or his
`
`surgical staff’s surgical glove inside Mr. Mortland. Dr. Pressman also failed to pre-operatively
`
`perform a CT scan with 3D reconstruction and failed to appropriately secure the prosthetic
`
`components to Mr. Mortland’s hip joint.
`
`

`

`On September 28, 2016, Mr. Mortland sought a second opinion from Dr. Edward
`
`McClain, II with regard to the fracture and continued, persistent, and severe right hip pain he
`
`experienced since Dr. Pressman’s August 6, 2016 surgery. Dr. McClain ordered a CT scan of
`
`plaintiff's pelvis with 3D reconstruction, as Dr. Pressman failed to obtain one. Dr. McClain
`
`informed plaintiff that it would be a difficult reconstruction because it would involve removing
`
`the prosthetic hip socket and potentially cutting the femoral head off to do a total hip and plating
`
`the acetabulum. Dr. McClain noted that this was “not a good scenario.”
`
`Plaintiff underwent the pelvic CT scan on February 10, 2017 and returned to Dr. McClain
`
`on February 15, 2017. Dr. McClain noted that there was a fracture line visible on the ischium
`
`and there was a disruption of the anterior column with some lucency aroundtheanterior portion
`
`of the hip socket. Dr. McClain advised Mr. Mortland that he may needa total hip replacement.
`
`On April 12, 2017, Dr. McClain diagnosed plaintiff with a failed hip resurfacing as a
`
`result of the August 6, 2016 surgery with Dr. Pressman.
`
`It was noted in Dr. McClain’s records
`
`that plaintiff “had a blow out of his acetabulum when the cup was inserted and the femoral head
`
`was clearly oversized.” On June 1, 2017, Mr. Mortland underwentright total hip replacement
`
`surgery by Dr. McClain, where it was notedthat the acetabular cup inserted by Dr. Pressman was
`
`“grossly loose” and there was a fracture in the medial wall. Dr. McClain also removed was
`
`appearedto bethe fingertip of a surgeon’s glove.
`
`Dueto the medical negligence during the August 6, 2016 surgery, Mr. Mortlandsustained
`
`a medical acetabular pelvic fracture, severe infections requiring IV antibiotics and surgical
`
`intervention, a retained foreign body, hip dislocation requiring another surgical procedure to
`
`remove the hip hardware and insert antibiotic spacers, hematoma evacuation procedure with
`
`wound vac, surgical procedure to remove the antibiotic spacer and re-install total hip hardware,
`
`additional surgical interventions, chronic severe pain of the groin and hip, pain while sitting,
`
`

`

`limited and painful range of motion, inability to stand for extended periods of time, inability to
`
`walk withoutthe assistance of crutches, bilateral carpal tunnel syndrome dueto prolonged use of
`
`crutches over the course of two (2) years,
`
`in addition to nervousness, emotional tension, anxiety
`
`and depression.
`
`Mr. Mortland has had to endure three (3) total hip replacements, as well as a left carpal
`
`tunnel release and flexor synovectomy on December 4, 2018 and a right carpal tunnel release and
`
`flexor synovectomy on December3, 2019.
`
`Mr. Mortland continuesto suffer from persistent right hip pain and limitations, which has
`
`made every dayofhis life, including his work as a physical therapist, difficult for him. He can
`
`no longer run, jump, or move about as easily as he once could. He may require mobility
`
`assistance in the future, and there may be additional surgery required.
`
`Il. WITNESSES
`
`1.
`
`2.
`
`3.
`
`Mark Mortland (Plaintiff)
`c/o Peter D. Friday, Esquire
`Joshua S. Licata, Esquire
`Ian M. Watt, Esquire
`Friday & Cox, LLC
`1405 McFarland Road
`Pittsburgh, PA 15216
`
`Ari E. Pressman, M.D. (Defendant)
`c/o Alan S. Baum, Esquire
`Michael J. Wiesemann, Esquire
`Matis Baum O’Connor
`912 Fort Duquesne Blvd.
`Pittsburgh, PA 15222
`
`Mark Gindlesperger, PA-C
`c/o Alan $. Baum, Esquire
`Michael J. Wiesemann, Esquire
`Matis Baum O’Connor
`912 Fort Duquesne Blvd.
`Pittsburgh, PA 15222
`
`

`

`WendyPatronas, PA-C
`c/o Alan S. Baum, Esquire
`Michael J. Wiesemann, Esquire
`Matis Baum O’Connor
`912 Fort Duquesne Blvd.
`Pittsburgh, PA 15222
`
`Kristal McFeely
`c/o Richard J. Federowicz, Esquire
`Dickie, McCamey & Chilcote, P.C.
`Two PPGPlace, Suite 400
`Pittsburgh, PA 15222-5402
`
`Derek Kucharski
`c/o Richard J. Federowicz, Esquire
`Dickie, McCamey & Chilcote, P.C.
`Two PPGPlace, Suite 400
`Pittsburgh, PA 15222-5402
`
`Jennifer Buterbaugh
`c/o Richard J. Federowicz, Esquire
`Dickie, McCamey & Chilcote, P.C.
`Two PPG Place, Suite 400
`Pittsburgh, PA 15222-5402
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`The Orthopedic Group
`1145 BowerHill Road, Suite 301
`Pittsburgh, PA 15243
`
`Records Custodian,corporate representative, officers, agents, and/or designees of
`Three Rivers Orthopedic Associates
`200 Delafield Road, Suite 1040
`Pittsburgh, PA 15215
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`St. Clair Hospital
`1000 Bower Hill Road
`Pittsburgh, PA 15243
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`UPMCSt. Margaret
`815 Freeport Rd.
`Pittsburgh, PA 15215
`
`10.
`
`11.
`
`

`

`12.
`
`13.
`
`14.
`
`15.
`
`16.
`
`17.
`
`18.
`
`19.
`
`20.
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`UPMCMercy
`1400 LocustSt.
`Pittsburgh, PA 15219
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`Burke and Bradley Orthopedics
`200 Delafield Road, Suite 4010
`Pittsburgh, PA 15215
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`Campbell & Philbin Medical Associates
`1400 Locust Street, Suite 5109
`Pittsburgh, PA 15219
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`Dr. Barry Levine
`393 Vanadium Rd., Suite 309,
`Pittsburgh, PA 15243
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`Gateway Rehab Center
`100 Moffett Run Rd.
`Aliquippa, PA 15001
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`Los Robles Hospital and Medical Center
`215 W Janss Rd.
`Thousand Oaks, CA 91360
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`HCR ManorCare- Peters Township
`113 W. McMurray Road
`McMurray, PA 15317
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`Patricia Howarth Korb, LCSW
`501 Valleybrook Road, Suite 206
`McMurray, PA 15317
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`Seasons Recovery Center- Malibu
`31739 Pacific Coast Highway
`Malibu, CA 90265
`
`

`

`21.
`
`22.
`
`23.
`
`24.
`
`25.
`
`26.
`
`27.
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`TJN Ortho: Dr. Gregory Tchejeyan
`250 Lombard St., Suite 1
`Thousand Oaks, CA 91360
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`UPMCPresbyterian South Hills
`1300 Oxford Drive
`Bethel Park, PA 15102
`
`Records Custodian, corporate representative, officers, agents, and/or designees of
`Hand & Shoulder Center
`6001 Stonewood Drive
`Wexford, PA 15090
`
`Anyand all individuals identified in any deposition testimony taken to date and
`future depositions that may be takenfor useattrial.
`
`Any andall individuals mentioned in Plaintiff’s medical records.
`
`Plaintiff may also call as a liability witness any individual(s) identified in
`Defendants’ Pretrial Statements, or identified in pleadings and/or discovery
`responses.
`
`Plaintiff may also call as a damage witness any individual(s) identified in
`Defendants’ Pretrial Statement, or identified in pleadings and/or discovery
`responses.
`
`Plaintiff reserves the right
`
`to call as witnesses any person or entity named and/or
`
`identified in all other parties’ respective Pretrial Statements.
`
`Ill. EXHIBITS
`
`Plaintiff reserves the right to use any ofthe following documentsattrial:
`
`1.
`
`Medical Records and Billing Statements for Plaintiff Mark Mortland:
`
`a) The Orthopedic Group
`b) Three Rivers Orthopedic Associates
`c) St. Clair Hospital
`d) UPMCSt. Margaret
`e) UPMC Mercy
`f) Burke and Bradley Orthopedics
`g) Campbell & Philbin Medical Associates
`h) Dr. Barry Levine
`i) Gateway Rehab Center
`
`

`

`Jj) Los Robles Hospital and Medical Center
`k) HCR ManorCare- Peters Township
`1) Patricia Howarth Korb, LCSW
`m) Seasons Recovery Center- Malibu
`n) TJN Ortho: Dr. Gregory Tchejeyan
`o) UPMCPresbyterian South Hills
`p) Hand & Shoulder Center
`
`Plaintiff's radiographic/diagnostic images and reports from any ofthe above
`providers.
`
`Medical illustrations depicting plaintiff's injuries.
`
`Anyandall photographs takenof plaintiff’s various wounds andsurgical scars.
`
`Transcripts and videos ofall depositions taken in this case.
`
`Any deposition exhibits attached to any deposition taken in this case.
`
`Anypleadings or portions thereof by Plaintiff or Defendantsin this case.
`
`Anyof the parties’ answers and responsesto discovery requests.
`
`Any and all documents and/or materials producedby the parties in this case.
`
`Any textbooks, notes, summaries, reports, tables, date or other documents used,
`relied upon,ortestified from byplaintiff's or defendant’s expertsattrial.
`
`Any exhibit, which subsequently becomes known, and information with regard to
`whichis disclosed to defendants in a reasonable timebeforetrial.
`
`Resumesor curriculum vitas for any of plaintiff's and/or defendants’ expert
`witnesses.
`
`Visualaids used to explain and highlight testimonyattrial.
`
`Medical diagrams and/or demonstrative exhibits to be used during any physician’s
`testimony.
`
`Demonstrative exhibits summarizing the treatmentofplaintiff and his medical
`expenses and/or damages.
`
`Anatomical charts and/or models.
`
`Any photographs, including enlargements of any photographs, diagrams, sketches,
`and/or anyillustrations.
`
`10.
`
`11.
`
`12.
`
`13.
`
`14.
`
`15.
`
`16.
`
`17.
`
`

`

`18.
`
`19,
`
`20.
`
`Any statement obtained from anyperson called as a witness.
`
`Any exhibit necessary for impeachmentorrebuttal purposes.
`
`Anyandall exhibits identified in Defendants’ Pretrial Statements.
`
`Plaintiff reserves the right
`
`to supplement
`
`this exhibit
`
`list at any time prior to the
`
`commencementoftrial.
`
`IV. EXPERT WITNESSES
`
`Edward J. McClain, I, M.D.
`Three Rivers Orthopedic Associates
`200 Delafield Road, Suite 1040
`Pittsburgh, PA 15215
`(Report and curriculum vitae attached as Exhibit A)
`
`Glenn A. Buterbaugh, M.D.
`Hand & Shoulder Center
`6001 Stonewood Drive
`Wexford, PA 15090
`(Report and curriculum vitae attached as Exhibit B)
`
`Standard of care expert to be identified uponreceipt of report.
`
`Economicloss expert to be identified upon receipt of report.
`
`Plaintiff reserves the right to call as expert witnesses any andall persons identified in
`
`1.
`
`2.
`
`3.
`
`4,
`
`the parties’ respective Pretrial Statements.
`
`V. ADMISSIONS/ STIPULATIONS
`
`None.
`
`None.
`
`VI. PARTIES UNNECESSARY TO THE CASE
`
`VI. SPECIAL DAMAGES
`
`Plaintiff claims non-economic damages including but not limited to scarring, discomfort,
`
`pain, suffering, inconvenience, emotionaldistress, and loss of enjoymentoflife.
`
`

`

`
`
`
`
`
`
`
`
`Total economic loss will be supplemented upon receipt of expert report.
`
`VIII. VOIR DIRE STATEMENT
`
`
`
`On August 6, 2016, Mark Mortland underwent a right hip resurfacing procedure with Dr.
`
`
`
`
`
`
`
`
`
`
`
`Pressman. Dr. Pressman deviated from the standard of care by causing an intraoperative pelvic
`
`
`
`
`
`
`
`fracture and inappropriately securing the prosthetic components to Mark's hip joint. Dr.
`
`
`
`
`
`
`
`Pressman also left a piece of surgical glove inside Mark's body.
`
`
`
`
`
`
`
`
`
`Mark suffered the intraoperative fracture and severe infections requiring IV antibiotics
`
`
`
`to suffer severe pain in his groin and over six (6) additional right hip procedures. He continues
`
`
`
`
`
`
`
`and right hip and has lost range of motion. All aspects of his life have been made more
`
`
`
`
`
`difficult, including his job as a physical therapist. Mark required the use of crutches for over two
`
`
`
`years, which caused bilateral car
`
`pal tunnel syndrome requiring surgery.
`
`Dr. Pressman
`Mark was forced to take time off work and has lost income as a result.
`
`
`
`
`
`owed a duty to Mark to exercise reasonable skill, care, and diligence, ordinarily exercised by
`
`
`
`
`
`physicians in the profession. Dr. Pressman's negligence
`
`
`directly impacted the surgery and
`
`
`
`Mark's recovery. The Orthopedic Group, Dr. Pressman's employer in August 2016, is
`
`
`
`
`
`
`
`vicariously liable for Mark Mortland's severe injuries caused by Dr. Pressman's negligence.
`
`
`
`
`
`
`
`UPMC Mercy and its operating room personnel caused and contributed to the surgical glove
`
`
`
`
`
`
`
`being left in Mark's right hip during the August 2016 surgery by Dr. Pressman.
`
`IX. PROPOSED VOIR DIRE QUESTIONS
`
`
`
`
`1. Have you or has anyone close to you ever been injured as the result of a healthcare
`
`
`
`
`
`provider's mistake?
`
`
`
`2. Should a surgeon and a hospital be responsible for the safety of a patient during a
`
`
`
`
`
`
`
`
`
`
`
`surgical procedure?
`
`

`

`3.
`
`Would you have any problem awarding money to an injured patient for pain and
`
`suffering caused by the negligence of a healthcare provider?
`
`4.
`
`Do you think that healthcare providers should be held accountable in a court
`
`of law whentheir medical negligence injuresa patient?
`
`5.
`
`Do you have any belief that a person should not be fully compensated forinjuries
`
`caused by negligent healthcare providers?
`
`X. RESERVATION TO AMEND AND/OR SUPPLEMENT
`
`Plaintiff reserves the right to supplement and amendthis Pretrial Statement and present
`
`impeachmentand rebuttal witnesses.
`
`Respectfully Submitted
`
`/s/ Peter D. Friday
`Peter D. Friday, Esquire
`Pa LD. # 48746
`Joshua S. Licata, Esquire
`Pa LD. #318783
`Ian M. Watt, Esquire
`Pa LD. #324364
`Attorneys for Plaintiff
`
`Friday & Cox LLC
`1405 McFarland Road
`Pittsburgh, PA 15216
`Phone: (412) 561-4290
`
`

`

`
`
`CERTIFICATE OF SERVICE
`
`
`
`
`
`I hereby certify that on January 18, 2022, a true and correct copy of the foregoing
`
`
`
`
`
`nd/or First Class U.S. Mail, posta
`
`
`ge Plaintiff's Pretrial Statement was served by email a
`
`
`
`prepaid, upon the following:
`
`Alan S. Baum, Esquire
`
`Michael J. Wiesemann, Esquire
`Matis Baum O'Connor
`
`912 Fort Duquesne Blvd.
`
`Pittsburgh, PA 15222
`
`
`Counsel for Defendants Ari E. Pressman, M.D. and The Orthopedic Group
`
`
`
`Richard J. Federowicz, Esquire
`
`
`
`
`Jeffrey Hantz, Esquire
`
`
`Dickie, McCamey & Chilcote, P.C.
`
`Two PPG Place, Suite 400
`
`Pittsburgh, PA 15222-5402
`
`
`Counsel for Defendants UPMC Mercy, and UPMC
`
`
`
`Friday & Cox LLC
`
`By: Isl Peter D. Friday
`
`Peter D. Friday, Esquire
`
`Pa I.D. # 48746
`
`
`Joshua S. Licata, Esquire
`Pa I.D. #318783
`Ian M. Watt, Esquire
`Pa I.D. #324364
`
`Attorneys for Plaintiff
`
`

`

`Dee/2172021 8:53:57 AM
`
`UPMC 4127847941
`
`ay
`
`Three Rivers Orthapedic
`Associates-UPMC
`Spire N, Papas, MD
`Edward J. McClain tl, MD
`VincentJ, Silvaggia, MD
`Cart. Heacelman, MD
`Patrick N, Smith, MO
`Michad! 5. Gafiney, MD
`Frad P. Heidenreich Jr, MD
`Alex J, Kline, MD
`Franklin 8. Chow, Mo
`Lee M. Sasala, Mp
`
`F 412-782-3993
`
`Heights Shopping Plaza
`1624 Pacifle Avenium, Sulte 4,
`Natrona Heights, PA 18065
`T 724-226-199
`F 724-226-1479
`
`UPMC me
`
`December 20, 2021
`
`Mr. Peter D. Friday, Esquire
`Friday & Cox, LLC
`Attorneys at Law
`1405 McFarland Road
`Pittsburgh, PA 15216
`
`RE: Mark Mortiand
`DOB: 01/27/1963
`
`Dear Mr. Friday:
`
`| first met Mr. Mark Mortland on September 28, 2016, He presented to our office
`with right hip pain and presented for a second opinion, He stated earlierin
`August that he had had a hip resurfacing done using a Birmingham hip
`performed by Dr. Ari Pressman. He suffered a complication at the surgery of a
`fracture of his acetabulum with extension of the fracture down into the ischium
`and he had been on crutches at the time that | saw him. On this Initial
`presentation he was complaining of significant pain.
`In addition when he sat the
`pain in his hip joint that he had prior to surgery waslargely improved. He had no
`pain with passive range of motion of his hip. At this point | .ordered a CT scan to
`better evaluate the fracture of his acetabulum.
`
`The GT.scan was done with 3-dimensional reconstruction, andit clearly showed
`that the acetabularcomponent had penetrated the medial wall of the acetabulum
`and a portion of it was intrapelvic. He had extensive comminution of the anterior
`column and posterior column of the acetabulum with comminution of the medial
`wail as well and with a large fracture line extended downinto the ischium.
`
`Myfeeling at the time wasthat it was best to allow the columns to heal and then
`
`bring himbackata later date and revise him toatotal hip. | also felt at the time
`that the size ofthe cup and the. size of the femoral head resurfacing was larger
`than his native acetabulum and native femoral head.
`
`| had Mr, Mortland get another CT scan in February of 2017 to assess the
`healing of his acetabulum and it showed some healing of the anterior column.
`He still had a nonunion of his ischial fracture and it also looked as if his cup was
`still protruding intrapelvic, The Judet views at that time as weil showed some
`lucency around the socketin the anterior column which made me suspiciousfor
`loosening of the socket.
`
`AffillatedwiththeUniversityofPittsburgh
`
`EXHIBIT
`
`i
`
`Af
`
`

`

`Dee/21/2021 8:53:57 AM
`
`UPMC 4127847941
`
`ar
`
`Page 2
`December 20, 2021
`RE: Mark Mortland
`
`| saw Mr. Mortland again on April 12, 2017, and | repeated x-rays. He appeared
`to have healed his anterior column fracture but there was stil! a nonunion of the
`ischium. The cup appeared to be loosening and he wasfeeling some clicking or
`crepitus in his groin when he walked.
`
`Wehad a discussion at that time about converting him to a total hip and he was
`then scheduled forthat procedure.
`
`On June 1, 2017, Mr. Mortland underwentrevision of his resurfacing to a total
`hip, Prior to his surgery we did have his hip aspirated and he did have
`inflammatory markers doneall ofwhich were negative. At that surgery it was
`noted that the cup was grossly loose. There was no evidence of any ingrowth of
`the cup. There was a rather thick membrane that developed between the cup
`and the bone which was curetted in order to get downto the native hip bone. As
`a result of curetting, it we did obtain a foreign object that appeared to be a
`fingertip portion of a surgeon's glove that was trapped within the membrane
`behind the socket. The remainder of the revision surgery went uneventfully, We
`obtained very good purchasewith the socket and stem.
`
`His initial rehabilitation upon the revision surgery on June 1, 2017, was
`uneventful.
`
`He followed up with mein the office on June 21, 2017 and was noted to have
`some rednessabout his wound where it looked like a superficial stitch had spit
`out.
`| did some debridement of his woundin the office and put him on some
`antibiotics orally and asked him to return fo the office in one week for a wound
`check with the plan thatif there was no improvementin the wound, we would do
`a debridementof the woundin the operating room.
`His office assistant called and cancelled his follow up appointmentstating that
`Mr. Mortland had a family emergency on June 26, 2017.
`
`| received a text message from Mr. Mortland witha picture of his hip showing
`redness and wound drainage from his hip and the text message stated that he
`was in Los Angeles and that he was going to an Emergency Room in Los
`Angelas to be seen by another orthopedic surgeon.
`
`He wastreated by a surgeon in Los Angeles who performeda debridement and
`retention of his implants, and he was started ¢onantibiotics via a PICCline for a
`gram-negative infection.
`
`He subsequently came back to Pittsburgh where he was seen bythe Infectious
`Disease doctors in our hospital, Drs, Pontzer and Jacobs.
`
`

`

`Deo/21/2021 6:53:57 AM
`
`UPMC 4127847941
`
`a
`
`Page 3
`December 20, 2021
`RE: Mark Mortland
`
`| saw Mr. Mortland again on August 2, 2017, at which time his wound looked
`good. He wasbeing treated with IV daptomycin and his inflammatory markers
`had returned to normal.
`-
`
`He subsequently suffered a hip dislocation on August 3, 2017 and cameinto to
`see me on August 4, 2017. He underwent a closed reduction at St, Clair Hospital
`on August 3, 2017.
`
`On August 11, 2017, he presented with.fever and chills and subsequently had a
`gram-negative bacteremia. He had his PICCline removed, and they cultured the
`tip which was positive for a gram-negative organism. At that point he was taken
`to the operating room for removal of his right total hip and insertion of an
`antibiotic spacer.
`
`On August 30, 2017, Mr. Mortland presented to the office having had the hip
`removed with a gross, dark, bloody drainage from his wound.
`
`On August 31, 2017, we took him to the operating room and evacuated a large
`hematoma and applied a wound VAC,
`
`[ saw him on September27, 2017, after the evacuation of the hematoma and
`application of the wound VAC and his wound was granulating nicely.
`
`He followed up again on October 27, 2017, and the wound continued to heal
`nicely. We continued the wound VACat that time.
`
`He was again seen on November27, 2017, with further healing of the wound
`noted.
`
`On January 3, 2018, he fallowed up with me in the office at which time | thought
`his wound was healed enough to stop the wound VAC and wedid wat to dry
`dressings.
`
`He was again seen on January 31, 2018, and his wound looked very good.
`
`He was seen again on February 14, 2018, andthis time with someirritation of his .
`wound and | asked him to see the plastic surgeons to get an opinion.
`
`He saw Dr. Wang from Plastic Surgery severaltimes.
`
`| thought that his wound
`He subsequently followed up with me on May 1, 2018.
`looked good at that point, and we elected to do an aspiration of his hip for a
`culture and also to have him get inflammatory markers drawn,
`
`

`

`Deo/21/2021 €:53:57 AM
`
`UPMC 4127847941
`
`Si?
`
`Page 4
`December20, 2021
`RE: Mark Mortland
`
`On May 31, 2018, we brought him back to the operating room and Inserted a.
`total hip.
`
`He followed up on June 8; 2018, for a wound check and also on June 15, 2018.
`
`He had x-rays done on June 15, 2018, which showed the components to be in
`good position. He had an area at the midpoint of his wound where he had some
`old hematoma drainage through the skin. He wasto follow up again in one week.
`
`He was seen again on June 22, 2018, At that point his wound washealed nicely.
`
`He was next seen on August3, 2018, where his wound appeared to be healed
`and his hip appeared to be stable clinically.
`
`On October 23, 2018, he developed an area of fluctuance in the distal end of his
`wound.
`| performed a debridement in the office making a small incision in the
`area and obtained some old blood. He was onoral antibiotics per the !nfectious
`Disease people at that time and we did same packingin the wound.
`
`Hefollowed up again on October 30, 2018, for a wound check and on November
`14, 2018, for a wound check.
`:
`
`The wound gradually healed over and on February 15, 2019, he presented to the
`office with some complaints of buttock pain and soft tissue swelling lateralto his
`hip.
`
`We subsequently ordered an MRI ofhis hip where.it was noted to have a soft
`tissue mass in the right buttock area. The area was aspirated by CT guidance by
`Radiology and fluid was sent for cultures. Subsequently it turned out to be an
`abscessthat grew diphtheroids.
`
`He subsequently had an aspiration done ofhis hip joint. The joint aspirate
`subsequently grew diphtheroids indicating communication with the abscessin his
`. buttock.
`
`| saw him again in. the office on March 20, 2019, andat this point we decided that
`we had to take the hip out,
`
`On April 4, 2019, Mr. Mortland underwent another excision of ari infected total hip
`on the right side with an insertion of an antibiotic spacer.
`
`He followed up with me on April 24, 2019 and presented me with the information
`that he had developed a pulmonary embolism. This was diagnosed at St. Clair
`Hospital. He was started on Eliquis.
`
`

`

`Deo/21/2021 8:53:57 AM
`
`UPMC 4127847941
`
`Gi?
`
`Page 5
`December20, 2021
`RE: Mark Mortland
`
`He was seen again on May 21, 2019, and his wound looked good. He was
`tolerating the spacer. At this visit! set him up for an aspiration of his hip under
`fluorascopy by Radiology to see if we adequately treated the infection.
`
`The aspirate proved negative, and he was taken back to the operating room on
`July 18, 2019, for removalof the retained cement spacer andinsertion of a total
`hip. Surgery went weil and all intraoperative cultures were negative.
`
`Mr. Moriland was seenin the office on August 2, 2019,for follow up. X-rays
`showed the components to be well aligned and well fixed.
`
`He was seen on September 24, 2019,for follow up at which point we got him
`measured for a shoelift.
`
`He attended outpatient physical therapy and was subsequently seen again in the
`office on December 18, 2019, where he showed continued progress and it was
`feit that he needed to work more on his strength. He stillrequired a lift in his
`shoe.
`
`On June. 17, 2020, he was seen in the office and was feeling very comfortable
`and had minimal pain, He thought that he had a leg length discrepancy and
`again we had him get measuredfora lift.
`
`He waslast seen on September 7, 2021, at which time his x-rays showed the
`osteotomysites had all healed and that the acetabulum had healed. The
`components were all stable. He was having somehip flexor pain, but no pain
`with weightbearing on his hip.
`
`Asofhis last visit Mr. Mortland was functioning very well. He still had some miid
`groin pain which | felt was muscular in nature. He is left with a permanentleg
`length discrepancy which is due to the multiple surgeries and the loss of bone as
`a rasult of thesesurgeries.
`
`His short-term prognosis is good. As for a long-term prognosis in a gentleman
`whois still in his fifties,it is very likely that he may require surgery in the futureif
`the bearing surface wears outor if the mechanical implants fail.
`
`As far as future treatment recommendations, pain management should beleft to
`the Pain Management Service. He should maintain the strength and range of
`motion of his hip.
`
`He clearly suffered pain as a result of the fracture of the acetabulum due to the
`surgery performed by Dr, Ari Pressman. He clearly suffered pain with ail of the
`other surgeries that he had to underge In order te treat his multiply infected hip.
`
`

`

`Dee/21/2021 8:83:57 AM
`
`UPMC 4127847941
`
`Te
`
`Page 6
`December 20, 2021
`RE: Mark Mortland
`
`The question of whetherhewill require mobility assistance in the future Is really
`not pertinentto this particular person.
`| think that anybody approaching their
`sixties ara concerned about mobility needs in the future.
`| cannot assign anyof
`these mobility needs directly to the acetabular fracture he suffered from theinitial
`surgery.
`
`As far as his hip is concerned in his current condition it appears to be stable,
`radiographically andclinically.
`| do not anticipate any majorfailure ofthis
`implant.
`
`| place no physical or functional restrictions on Mr. Mortland, but | would
`recommend that he avoid running and jumping activities.
`
`| have no knowledge as to whether he has anybilateral hand or upper extremity
`injuries,
`
`As to whetherthe patient will be free from pain orlimitations from his injuries,|
`am not sure exactly what your question is here. He had a hip problem, and it
`appears stable radiographically and clinically.
`It should be less painful thanit
`was before surgery. Other than that, | cannot comment as to whether he would
`have any pain or functionallimitations in the future,
`
`All of these statementsin this narrative are stated within a reasonable degree of
`medical certainty.
`.
`
`Please do not hesitate to contact me if you hava any other questions.
`
`Sincerely,
`4
`
`A
`
`af
`re i at rhe’ a oNee h|)
`eo, : s
`é Inetft Mt ((auFI; ii
`if
`!
`iN ;
`HP
`:
`:
`&
`
`f
`
`4
`
`Edward J. McClain, I, M.D.
`
`EJM/kme
`
`

`

`Jans 18/2022 2:51:02 PM
`
`UPMC 4127847941
`
`ate
`
`BIOGRAPHICAL
`
`Name:
`Citizenship:
`Office Address:
`Office Telaphone:
`
`Edward J, McClain Ill, M.D,
`USA
`200 Delafield Road, Suite 1040, Pittsburgh, PA 15215
`(412) 782-3990
`
`EDUCATION AND TRAINING
`
`B.S,
`
`M.S.
`
`M.D.
`
`PGY-1
`General Surgery
`
`PGY-1 — PGY-5
`Orthopaedic Surgery
`
`PGY-6
`Adult Reconstructive
`Surgery
`
`Undergraduate
`
`1974-1978
`
`Graduate
`
`1978-1981
`
`1982-1986
`
`Post Graduate
`
`7/86-6/87
`
`7/87-6/91
`
`8/91-7/92
`
`2/85
`
`4/91
`
`4/91
`
`5/91
`
`Allegheny College
`Meadville, PA
`
`West Virginia University
`Morgantown, WV
`
`West Virginia University
`Morgantown, WV
`
`Mercy Hospital
`Pittsburgh, PA
`
`University of Pittsburgh
`Pittsburgh, PA
`
`Fellowship
`Indiana University
`Indiariapolis, IN
`Willlam N. Capello, M.D.
`
`AO/ASIF Basic Course
`Los Angeles, CA
`
`AO/ASIF Advance Course
`MarcoIsland, FL
`
`The Pelvic and Acetabular
`Fracture Management Course
`Toronto, Ontario, Canada
`
`West Coast Orthopaedic Review Course
`Santa Monica, CA
`
`

`

`Janf1a/2022 2:51:02 PM
`
`UPMC 4127847944
`
`we
`
`Edward J, McClain II, MD
`Page 2
`
`3/92
`
`5/92
`
`8/93
`
`10/94
`
`4/95
`
`12/01
`
`12/06
`
`2/08
`
`9/10
`
`Instructor
`
`Table Instructor
`
`Moderator
`
`State of the Art in Hip
`and Knee Replacement: 1992
`Breckenridge, CO
`
`Reviston Total Hip Replacement
`Complex Total Knee Replacement
`Anderson Clinic
`Arlington, VA
`
`AO/ASIF Osteotomy Course
`Detroit, Ml
`
`Surgery of the Pelvis and Acetabulum:
`The Second International Consensus
`Pittsburgh, PA
`
`Revision Total Hip Replacements
`American Orthopaedic Association
`28" Annual Residents Conference
`Pittsburgh, PA
`
`AO Masters Trauma Course
`Davos, Switzerland
`
`AO MIS 1 CAS Fracture Course
`Davos, Switzerland
`
`AO Caribbean Trauma Update
`Cancun, Mexico
`
`AO Co-Managed Geriatric Fracture Care Course
`Phoenix, Arizona
`
`APPOINTMENTS AND POSITIONS
`
`7/13 - Present
`
`Three Rivers Orthopedic Associates — UPMC
`Pittsburgh, PA
`
`Medical Director
`
`11/93
`
`University of Pittsburgh
`Pittsburgh, PA
`
`11/94-12/97 |
`
`Mercy Hospital
`Pittsburgh, PA
`
`Clinical Instructor
`Orthopaedic Surgery
`
`Trauma Coordinator
`Orthopaedic Surgery
`Division
`
`

`

`Jan/18/2022 2:51:02 PM
`
`UPMG 4177847941
`
`46
`
`Edward J. McClain itl, MD
`Page 3
`
`Specialty Certification
`
`CERTIFICATION AND LICENSURE
`
`7/94
`
`American Board of Orthopaedic Surgeons
`
`Board Certified
`
`Medical Licensure
`
`4/88
`
`10/91
`
`1992
`1992
`1993
`1993
`1996
`1996
`1997
`1997
`
`Pennsylvania
`
`Indiana
`
`MEMBERSHIPS IN PROFESSIONAL AND SCIENTIFIC SOCIETIES
`
`Allegheny County Medical Society
`Pennsylvania Medical Society
`Pennsylvania Orthopedic Society
`Interstate Orthopedic Society
`American Academy of Orthopaedic Surgeons
`American College of Surgeons
`Eastern Orthopedic Association
`Society for Arthritic Joint Surgery
`
`PROFESSIONAL ACTIVITIES
`
`Current Hospital Affiliations
`
`Active Staff
`
`St. Margaret Memorial Hospital - UPMC
`Pittsburgh, PA
`
`Affiliate Staff
`
`University of Pittsburgh Medical Center
`Pittsburgh, PA
`
`Prior Hospital Affiliations
`
`2016-2020
`
`Children’s Hospital of Pittsburgh of UPMC
`Pittsburgh, PA
`
`Invited Lectureships
`
`1992
`
`State of the Art in Hip and Knee Replacement: 1992
`Osteonics Winter Meeting: “Cementiless Total Hip Replacement In Young Adults”
`Brackenridge, CO
`
`

`

`Jan/18/2022 2:51:02 PM
`
`UPMC 4127847941
`
`5/6
`
`Edward J. McClain Ill, MD
`Page 4
`
`1992
`
`1994
`
`1994
`
`1995
`
`1996
`
`1997
`
`Little Orthopaedic Club
`“The Five Year Average Results of the Omnifit Stem”
`Indianapolis, IN
`
`Pennsylvania Orthopedic Society Spring Meeting
`“Patellar Failure and Total Knee Arthroplasty”
`
`Mercy Hospital, Division