# Sample Medical Summary for Attorneys

## What is an EvenUp Medical Summary?

A template within the AI Drafts Suite that compiles 
synced treatment records into a structured summary 
of care, diagnoses, and impairment findings. Powered 
by Piai™, it offers line-level detail to support case 
valuation and strategy. Intended for attorney review, 
not final use.

## May 31, 2025

## VIA CERTIFIED MAIL

**VIA FAX**
<u>VIA EMAIL</u>: [[adjusteremail]]
[[insurancecarrier]]
[[adjusterfirstname]] [[adjusterlastname]]
[[insuranceaddress]]

| RE: | [[Defendant/At-Fault Party Reference]]： |
| --- | --- |
| [[defendantfirstname]] [[defendantlastname]] |  |
| My Client: | Ryan Calder |
| Date of Loss: | September 15,2024 |
| Claim No.: | [[claimnumber]] |
| Policy No.: | [[policynumber]] |

## 1.1. Medical Treatment Summary

09/15/2024  -**Miami-Dade Fire Rescue  - Paramedic  Elliott Ramirez**: Paramedic Ramirez 
responded to a motor vehicle collision in which Mr. Calder, the restrained driver, was rear-ended 
while stopped at a traffic light. Mr. Calder reported neck and lower back pain, stating "My neck 
and lower back are really hurting. I felt a sharp pain right after the impact.". The physical 
assessment revealed pain on palpation of the back of the neck with limited range of motion and 
tenderness along the mid and lower back. Treatment included applying a cervical collar, securing 
Mr. Calder to a long backboard with head blocks, establishing an intravenous line in the left arm, 
and administering Ketorolac for pain management. Mr. Calder was transported to Mercy Hospital 
Miami with an assessment of cervical and lumbar strain/sprain following the collision.

09/15/2024  -**Mercy Hospital Miami  - Dr. Eliza Marquez, M.D.**: Dr. Marquez evaluated Mr. 
Calder in the Emergency Department after the motor vehicle collision. Her physical examination 
revealed tenderness in the back of the neck, limited movement due to pain, and tenderness in the 
thoracic and lumbar regions. X-rays  of the cervical, thoracic, and lumbar spine showed 
straightening of the normal curves, likely due to muscle spasm, and mild degenerative changes. 
Dr. Marquez diagnosed Mr. Calder with acute strain/sprain in the cervical, thoracic, and lumbar 
regions. Her treatment included Cyclobenzaprine and Naprosyn, which improved his symptoms, 
reducing  pain  from  5/10  to  3/10.  She  provided  discharge  prescriptions  of  Naproxen,

Cyclobenzaprine, and instructions to continue using a cervical collar as needed. Mr. Calder was 
referred to Miami Spine & Rehabilitation Center for chiropractic evaluation.

11/01/2024  -**Miami Spine & Rehabilitation Center  - Dr. Marcus Wilson, D.C.**: Dr.  Wilson 
performed an initial chiropractic evaluation of Mr. Calder, who presented with neck, upper back, 
and lower back pain following the 09/15/2024 collision. Mr. Calder rated his neck pain as 6/10 
and his back pain as 5/10 at rest, increasing to 8/10 with movement. The examination revealed 
moderate to severe tenderness in the neck, mid back, and lower back, along with subluxation at 
various spinal levels and the right sacroiliac joint. Dr. Wilson diagnosed multiple issues including 
sprain/strain, segmental dysfunction, and early degenerative changes. He outlined a treatment plan 
of chiropractic adjustments, soft tissue mobilization, therapeutic exercises, heat and cold therapy, 
and electrical muscle stimulation for several weeks.

11/02/2024  - 11/05/2024  -**Miami Spine & Rehabilitation Center  - Dr. Wilson**: Mr. Calder 
reported continued neck pain (5-6/10) and back pain (5/10) with slight improvement in his neck. 
Dr. Wilson provided additional chiropractic adjustments, interferential current therapy, therapeutic 
exercises, moist heat, and soft tissue mobilization.

11/07/2024  -**South Florida Orthopedic Specialists  - Dr. Jennifer Patel, M.D.**: Dr. Patel 
evaluated Mr. Calder and diagnosed a rotator cuff tear in his right shoulder. She recommended 
starting with conservative care and then considering injection therapy if needed.

11/09/2024  -**Miami Spine & Rehabilitation Center  -Dr. Wilson**: Mr. Calder reported 
improvement in his neck pain to 4/10 but noted new discomfort in his right shoulder when reaching 
overhead. Examination showed pain during shoulder abduction above 100° and internal rotation, 
with mild tenderness over the right rotator cuff and a positive Hawkins-Kennedy test. Dr. Wilson 
assessed the shoulder as having a possible rotator cuff strain/impingement and adjusted his 
treatment to focus more on the right shoulder.

11/12/2024  - 11/16/2024  -**Miami Spine & Rehabilitation Center  - Dr. Wilson**: Mr. Calder 
reported gradual improvement in neck and back pain (both 4/10) but an increase in right shoulder 
pain (5-6/10). Examination of his right shoulder revealed limited active range of motion, positive 
impingement tests, and noticeable tenderness over the supraspinatus tendon and bicipital groove. 
His treatment continued with chiropractic adjustments, interferential current therapy, therapeutic 
exercises focusing on the shoulder, and soft tissue mobilization.

11/15/2024 -**South Florida Imaging Center - Dr. Patel** (ordering): An MRI of the right shoulder 
was performed. The imaging showed a full-thickness tear of the supraspinatus tendon measuring 
approximately 1.5 cm with mild retraction, moderate subacromial bursitis, mild acromioclavicular joint arthropathy, a Type II acromion, mild glenohumeral joint effusion, and mild degenerative 
changes of the glenoid labrum.

11/19/2024 -**Miami Spine & Rehabilitation Center - Dr. Wilson**: Mr. Calder reported that his 
neck pain had improved to 3/10 and his back pain to 3/10. However, his right shoulder pain 
persisted at 6/10 with only limited improvement. The examination indicated that shoulder 
abduction was limited to 110° with pain, positive impingement signs, and pain with resisted 
external rotation. Dr. Wilson assessed the shoulder as having rotator cuff tendinitis/impingement 
and referred Mr. Calder to Dr. Patel for further evaluation.

11/23/2024 -**Miami Spine & Rehabilitation Center - Dr. Wilson**: Mr. Calder reported that his 
neck pain had decreased to 2/10 and his back pain to 2/10. Dr. Wilson continued his chiropractic 
care once per week for an additional four weeks and recommended coordinating care with an 
orthopedic specialist for his shoulder.

11/25/2024 -**Miami Pain Specialists - Dr. Carlos Rivera, M.D.**: Dr. Rivera evaluated Mr. Calder, 
who presented with right shoulder pain following the collision. After reviewing the MRI that 
showed a full-thickness supraspinatus tear, Dr. Rivera diagnosed a right shoulder rotator cuff tear, 
impingement syndrome, subacromial bursitis, glenohumeral joint effusion, and pain related to the 
collision. He treated Mr. Calder with a subacromial corticosteroid injection using a mixture of 
Kenalog and lidocaine.

11/26/2024  - 11/30/2024  -**Miami Spine & Rehabilitation Center  - Dr. Wilson**: Mr. Calder 
reported that his neck and back pain had further improved to between 2/10 and 1/10, but his right 
shoulder pain remained at 5-6/10. He received additional treatments including chiropractic 
adjustments, interferential current therapy, therapeutic exercises, and soft tissue mobilization.

12/03/2024 -**Miami Spine & Rehabilitation Center - Dr. Wilson**: Mr. Calder reported minimal 
neck pain (1/10) and back pain (1/10) with his right shoulder pain at 4/10 after a steroid injection 
from Dr. Rivera. His treatment included targeted chiropractic adjustments to C5 and L5, 
interferential current therapy, therapeutic exercises, soft tissue mobilization, and a modified 
exercise program to improve shoulder mobility.

12/10/2024 -**Miami Spine & Rehabilitation Center - Dr. Wilson**: Mr. Calder reported no neck 
pain (0/10) and only intermittent low back pain (1/10). His right shoulder pain remained at 4/10 
but his range of motion had improved following the injection. Treatment included a chiropractic 
adjustment to L5, interferential current therapy, advanced therapeutic exercises, and soft tissue 
mobilization.

12/13/2024 -**Miami Pain Specialists - Dr. Rivera, M.D.**: Mr. Calder returned for a follow-up and 
reported that his shoulder pain had improved for about a week after the first corticosteroid injection 
but then returned. He stated that his pain had decreased from 6/10 to 2/10 for 7-10 days after the 
injection, but over the past week it progressively increased to 5/10 at rest and 7/10 with activity. 
Dr. Rivera administered a second corticosteroid injection to the right shoulder and discussed 
surgical options, including arthroscopic rotator cuff repair if conservative management failed.

12/17/2024 -**Miami Spine & Rehabilitation Center - Dr. Wilson**: Mr. Calder reported no neck 
pain (0/10) and occasional low back discomfort (1/10) when sitting for prolonged periods. His 
right shoulder pain improved to 3/10 following the second injection. Dr. Wilson reduced the 
treatment plan to maintenance adjustments, therapeutic exercises, and recommended a home 
exercise program with ergonomic practices. Treatment frequency was reduced to every other week.

12/30/2024 -**Miami Pain Specialists - Dr. Rivera, M.D.**: Mr. Calder returned for follow-up with 
concerns about long-term solutions for his shoulder. He reported significant improvement in pain 
since the second injection, rating his pain as 2/10 at rest and 4/10 with activity. Examination 
showed significant improvement in his range of motion. Dr. Rivera administered a third and final 
corticosteroid injection to the right shoulder and discussed surgical intervention. He recommended 
arthroscopic rotator cuff repair based on the MRI findings and scheduled a surgical consultation 
with Dr. Patel for February 2025.

01/07/2025 -**Miami Spine & Rehabilitation Center - Dr. Wilson**: Mr. Calder reported that his 
neck symptoms had resolved and his low back discomfort was minimal. His right shoulder function 
improved, although he still experienced pain at 2/10 with certain movements. Dr. Wilson provided 
a maintenance adjustment, a final home exercise program, and discharged Mr. Calder from active 
care for his spinal conditions while supporting his decision regarding shoulder treatment.

01/07/2025 -**South Florida Orthopedic Specialists - Dr. Patel, M.D.**: Dr. Patel conducted a new 
patient office visit with a comprehensive evaluation and obtained X-rays (2 views) of the right 
shoulder.

01/28/2025  -**South Florida Orthopedic Specialists  -Dr. Patel**: Dr. Patel conducted an 
established patient office visit with a detailed evaluation and provided therapeutic exercise 
instruction.

01/28/2025 -**Miami Pain Specialists - Dr. Rivera, M.D.**: Dr. Rivera evaluated Mr. Calder during 
a follow-up regarding next steps for his shoulder. Mr. Calder reported continued improvement after 
the third injection, rating his pain as 1-2/10 at rest and 3-4/10 with strenuous activity. He indicated 
that he had consulted with Dr. Patel about surgical intervention and was leaning toward 
arthroscopic rotator cuff repair. Dr. Rivera strongly recommended arthroscopic rotator cuff repair 
as the definitive treatment based on the MRI findings and clinical presentation. He outlined a 
postsurgical pain management plan and advised coordinating with Dr. Patel for scheduling the surgery. 
Dr. Rivera certified that the shoulder injury was directly related to the 09/15/2024 collision and 
that the recommended surgery was medically necessary.

02/05/2025 -**Miami Spine & Rehabilitation Center - Dr. Wilson**: Dr. Wilson conducted a final 
evaluation of Mr. Calder, who reported resolution of his neck and low back symptoms with only 
minor discomfort after prolonged activities. Mr. Calder noted that his right shoulder, though 
improved, still had limitations with pain rated at 2/10. He confirmed his decision to proceed with 
arthroscopic surgery scheduled for 02/20/2025 with Dr. Patel. Dr. Wilson assessed that the cervical, 
thoracic, and lumbar conditions had resolved while the right shoulder tear had improved with 
conservative management but required surgery. He recommended monthly maintenance visits for 
three months and provided a home exercise program for spinal maintenance. The prognosis was 
favorable for the spine and guarded for the shoulder pending surgical outcome.

02/20/2025 (Scheduled) -**South Florida Orthopedic Specialists - Dr. Patel, M.D.**: Arthroscopic 
surgery for the right shoulder was scheduled.

## Exhibit List

| No. | Description |
| --- | --- |
| 1 | Police Report |
| 2 | Mercy Hospital-Bills |
| 3 | Miami-Dade Fire Rescue-Bills |
| 4 | Mercy Hospital-Records |
| 5 | Miami-Dade Fire Rescue-Records |
| 6 | Miami Spine&amp;Rehabilitation Center-Bills |
| 7 | Miami Spine&amp;Rehabilitation Center-Records |
| 8 | Biscayne Physical Therapy&amp;Rehabilitation-Bills |
| 9 | Miami Pain Specialists-Records |
| 10 | Miami Pain Specialists-Bills |
| 11 | Carlos Rivera,MD-Records |
| 12 | South Florida Orthopedic Specialists-Bills |
| 13 | South Florida Orthopedic-Bills |
