January 14, 2025 Direct Line: 561-615-4309

VIA EMAIL: Mallory_K_Edel_2@progressive.com

Mallory K. Edel
Progressive American Insurance Company
901 N Lake Destiny Road Suite 200
Maitland, FL 32751

RE: Julie Diaz v. Jamelle Comfort and Singh Transport Corporation

Date of Loss: February 7, 2023
Claim No: 23-7615829
Our File No: 0188553
Mediation: January 29, 2025 – 9:30 am - Mediator Robert Molletteirre

PRE-MEDIATION REPORT

Dear Mallory:

This matter arises out of a moderate impact motor vehicle accident that occurred on February 7, 2023 in
Volusia County, Florida. My client, 44 year old, Jamelle Comfort (DOB: 6/28/1980), was driving for her
employer, Singh Transport Corporation, at the time of the accident. Plaintiff, 41 year old (DOB:
7/27/1983) Julie Diaz, was driving a 2015 Chevy Silverado truck which was owned by Monica Lorraine
Diaz. Plaintiff was traveling eastbound on Destination Daytona Lane in Ormond Beach, Florida. As the
Plaintiff was approaching the entrance of 1657 N US Hwy 1, Ms. Comfort is alleged to have failed to
yield and began to turn left onto Destination Daytona Lane. Plaintiff, who was traveling approximately
15 mph within a posted speed limit of 25 mph, attempted to stop, but ultimately stuck the driver’s side of
the trailer. According to the Florida Traffic Accident Report, no injuries were reported at the scene, thus,
Plaintiff was not transported from the scene of the accident. That same day, Plaintiff presented to AH
Centra Care with complaints of neck and back pain. On April 21, 2023, Plaintiff underwent a cervical 5/6
and 6/7 anterior cervical discectomy and disc replacement after which she had a complicated recovery
and continues to receive ongoing chiropractic treatment. She has received two cervical and two lumbar
injections post-surgery.

Plaintiff’s submitted a 30-day demand for the policy limits on March 25, 2024. We filed a proposal for
settlement for $271,000. On May 31, 2024, Plaintiff filed their Second Amended Complaint, moving to
bring Safeco (UM carrier) into the suit. On December 30, 2024, Plaintiff voluntarily dismissed Safeco.
Plaintiff indicated they were not pursuing a TBI claim and therefore he did not see this as a policy limits
case. Plaintiff is also not making a lost wage or earning capacity claim.

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We retained Radiologist Dr. Eric Pfeiffer to review the Plaintiff's diagnostic studies, and his findings are
notably negative in regard to her cervical spine (summarized below). We will schedule a CME with
Dr. Eric Gabriel should this claim not resolve at mediation. We have attempted multiple rounds of
surveillance without success.

Please allow the following to serve as our Pre-Mediation Report in preparation for the

A. General Background:

The subject accident occurred at approximately 7:59am on February 7, 2023. Plaintiff, 41 year old (DOB:
7/27/1983) Julie Diaz, has alleged that Defendant, Jamelle Comfort was negligent in the operation of the
2020 Volvo tractor trailer which allegedly failed to yield the right of way to oncoming traffic and began
turning left onto Destination Daytona Lane in Ormond Beach, Florida. At the time of the accident,
Plaintiff was traveling eastbound on Destination Daytona Lane and was approaching the entrance of 1657
N US Hwy. Plaintiff was travelling approximately 15 mph with a posted speed limit of 25 mph. Plaintiff
was unable to stop and or avoid colliding with my client’s vehicle. Subsequently, the impact occurred on
the driver’s side of the trailer. According to the Florida Traffic Accident Report, no injuries were reported
at the scene, thus, Plaintiff was not transported from the scene of the accident. The following is an aerial
view of the approximate location where the accident occurred for your reference:

Officer James E. Feeley of the Ormond Beach Police Department reported to the scene of the accident
and noted the following in the Traffic Crash Report regarding the occurrence of the accident:

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 “V-1(Client) was exiting the parking lot of 1657 N US Hwy 1 from the Commercial truck
entrance. V-2(Plaintiff) was traveling eastbound on Destination Daytona Lane approaching the
entrance of 1657 N US Hwy. D-1(Client) of V-1 failed to yield the right of way pulling out of the
parking lot into the path of V-2. D-2 (Plaintiff) of V-2 attempted to stop in time, but due to the
timing was unable. V-2 struck the trailer of V-1.

V-1 had no damage as the contact was made with the 53’ trailer that was being towed. V-1 had
minor damage to the front driver side headlight as well as the fender. Neither vehicle was towed
from the scene.

None of the parties involved claimed any injuries due to the crash.

D-1 of V-1 was determined to be at fault for the crash.”

Officer Feeley also prepared the following diagram in his report:

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Please see below photographs of Plaintiff’s vehicle following the Subject Accident.

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B. Injuries:

Brief Summary of Alleged Injuries/Treatment:

Plaintiff is alleging injuries to the neck and back. She reported and treated for neck and back pain on the
date of the accident. She subsequently treated with a chiropractor and underwent a cervical epidural
injection on March 9, 2023, before having a two-level cervical discectomy and disc replacement at C5-6
and C6-7 on April 21, 2023. Her cervical MRI, which was performed just three weeks post-accident,
shows a significant herniation at C5-6 with compression on the cord that would be symptomatic. The
herniation is large and is easy for a jury to see. Since the surgery she has continued to treat, receiving
ongoing chiropractic treatment, a cervical epidural, cervical trigger point injections, and two lumbar
epidural injections, most recently on April 3, 2024. She attended 69 chiropractic sessions from February
14, 2023 through September 4, 2024.

Pre-Accident Medical Treatment:

On July 30, 2015, Plaintiff sustained right shoulder, forearm, and wrist pain after a workplace incident
where a tire rack fell on her arm while she was lifting tires. On October 17, 2020, the Plaintiff was struck
by a drunk driver, resulting in road rash and insomnia, which she began treating for on November 3,
2020. On March 18, 2021, she was involved in a boating accident, injuring her left wrist, which was
diagnosed as a sprain and treated with a sling and wrist brace. On April 13, 2021, she followed up with
complaints of wrist pain, photophobia, nausea, eye strain, and cycles of cramping and back pain.

This history highlights numerous prior injuries and treatments, including abdominal and musculoskeletal
issues; however, no specific cervical or lumbar injuries are documented in the records in our
possession.

Post-Accident Medical Treatment:

On the same day as the subject accident (February 7, 2023), Plaintiff presented to AH Centra Care with
complaints of neck and back pain and she was evaluated by Rebekah Buchanan, APRN (Nurse
practitioner). Plaintiff received the following x-rays: cervical, thoracic, and lumbar, which evidenced no
acute fractures or subluxation. Plaintiff was prescribed Methyl Prednisone (Medrol Dosepak) 4 mg and
Methocarbamol (Robaxin) 750 mg. No diagnostics of the head were performed.

On February 14, 2023, Plaintiff presented to Aligned Intergrative Health Care and was evaluated by Dr.
James Valcarcel, DC (Chiropractor). Plaintiff’s chief complaints were cervical pain 5-6/10, thoracic pain
5-6/10, and lumbar pain 8/10. Dr. Valcarcel ordered a cervical and lumbar MRI to be performed. Plaintiff
attended 69 sessions from February 14, 2023 through September 4, 2024.

On February 21, 2023, Plaintiff saw Dr. Yoon and Jennifer Kramer, APRN, at Medical FM Practice for
follow-up on labs, weight loss, and medication. She reported a 14-pound weight loss but continued neck,
back, and arm pain from the subject accident. Medical history included a grand mal seizure (2020),
diverticulosis, and anxiety managed with Valium and Trazodone. Her smoking was reduced to two
cigarettes daily with patch use. Treatment included Mounjaro 10 mg weekly and new B12 injections
every two weeks. Follow-up for weight management was advised.

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Plaintiff presented to Stand Up MRI on February 27, 2023 for a cervical and lumbar MRI. The reporting
radiologist, Dr. Ali Badday, MD opined as follows:

Radiologic Exam Impression

Cervical Spine MRI There is loss of the normal lordotic curvature of the cervical spine. In the
correct clinical settings, this may reflect injury.

At C5-6, there is 0.6 mm of retrolisthesis. There is a posterior central disc

herniation superimposed on a disc bulge. Vertebral osteophytes, effaces the
ventral thecal sac, and demonstrates impression on the spinal cord. There is
faint spinal cord edema at this level. Severe spinal canal stenosis. Mild
bilateral foraminal stenosis.

At C6-7, there is a posterior central disc herniation which indents the ventral
thecal sac. Moderate spinal canal stenosis. Mild bilateral foraminal stenosis.

Given the history, and the findings and appearance on this MRI, it is
medically probable that the C5-6 and C6-7 disc herniations are related to the
injuries sustained from the motor vehicle collision on 2/7/23.
Lumbar Spine MRI There is loss of the normal lordotic curvature of the lumbar spine. In the
correct clinical setting, this may reflect injury.

At L5-S1, there is a posterior central disc herniation superimposed on a disc

bulge. The disc herniation indents the ventral thecal sac.

Given the history, and the findings and appearance on this MRI, it is
medically probable that the L5-S1 disc herniation is related to the injuries
sustained from the motor vehicle collision on 2/7/23.

Additionally, on February 27, 2023, Plaintiff attended a telemedicine visit with Heather Morales, PA
(Physicians Assistant) at Associates MD. Plaintiff reported muscle aches/stiffness to her neck and back
which radiated to her arms bilaterally and right leg. Plaintiff was advised to continue chiropractic
treatment and to consider physical therapy.

On March 8, 2023, Plaintiff presented to Coastal Neurology and was evaluated and treated by Dr. Bojan
Pavlovic, MD (Pain Management). Plaintiff reported neck pain that radiated to her arms bilaterally but
primarily the right side as well as low back pain which radiated to the right leg. Dr. Pavlovic reviewed
Plaintiff’s diagnostics and thereafter, Plaintiff received a cervical interlaminar epidural injection (right
side). Later that day, she called the office with complaints of pain and being unable to get out of bed. She
began using Lidocaine patches and heat/ice but to no avail. She was told to take over the counter pain
medication if needed.

On March 9, 2023, Plaintiff presented to Coastal Neurology with unchanged chief complaints. Dr. Bojan
diagnosed the Plaintiff with Lumbosacral radiculopathy. The Plaintiff then underwent a lumbar sacral
interlaminar epidural injection.

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On April 13, 2023, Plaintiff followed up with Dr. Yoon for neck and back pain related to the subject
accident, increased arm pain and anxiety. She was refilled a prescription of Valium and Trazodone and
was recommended a follow-up with neurology.

On April 17, 2023, Plaintiff presented to Coastal Neurology for an initial visit with Dr. Frederico Carlos
Vinas, MD (Neurosurgeon). Dr. Vivas reviewed the MRIs of cervical spine which showed C5-C6 disc
herniation causing severe stenosis and possible edema as well as disc protrusion at C6-7 causing moderate
stenosis. Additionally, the lumbar MRI evidenced disc protrusion with stenosis at L5-S1. Dr. Vivas
explained advised that Plaintiff should consider all alternative treatment before considering surgery. Dr.
Vivas ordered a cervical x-ray to be performed.

On April 18, 2023, Plaintiff presented to Radiology Associates Twin Lakes and received a cervical x-ray
performed by Dr. Robert Levy, MD which evidenced reversal of normal cervical lordosis, mild cervical
spondylosis at C5-6 and C6-7 and to lesser extent at C4-5, and no acute fracture or prevertebral soft tissue
swelling.

Notably, at Plaintiff’s April 19, 2023 chiropractic visit, Plaintiff had to driven to her appointment where
she reported that she has had difficulty walking and that she fell on her way use the bathroom. Plaintiff
was instructed to go to the ER at Advent Hospital Daytona Beach where she underwent the following
diagnostic studies:

Radiologic Exam Impression

Cervical Spine MRI Multilevel degenerative changes without change, contributing to multilevel
neural foraminal narrowing, most pronounced on the left C6-7 mild canal
stenosis at C4-5, no cord compression.
Thoracic Spine MRI Mild degenerative changes without significant canal stenosis, cord
compression or nerve renal foraminal narrowing.

Lumbar Spine MRI No acute findings, minimal disc desiccation and disc bulging at L5-S1
without central or foraminal narrowing.
CT Head No acute intracranial hemorrhage, mass effect or midline shift.
Cervical X-Ray Limited 4 fluoroscopic spot images from 2 level disc replacements for
additional clinical details and possible additional findings and
recommendations see performing physicians note. Fluoroscopic time 1.9
minutes.

On April 21, 2023, Plaintiff underwent cervical 5/6 and 6/7 anterior cervical discectomy and a cervical
5/6 and C7 arthroplasty performed by Dr. Vinas. Upon discharge on April 22, 2023, Plaintiff was
instructed to follow up with Dr. David Yoon, MD (PCP) and Dr. Vinas. Notes indicate that the Plaintiff
could return to work on April 24, 2023 for four to six hours a day with no lifting, bending, or driving.

On April 28, 2023, Plaintiff presented to Dr. Yoon for a post-hospital follow up. Dr. Yoon prescribed
Mounjaro 10 mg. and instructed her to follow up in (1) one month.

On May 5, 2023, Plaintiff presented returned to Coastal Neurology for her initial post-operation visit and
was seen by Zoe Griffin, APRN (Nurse Practitioner). Plaintiff reported that her neck pain was currently

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5/10. Plaintiff was ordered a cervical x-ray. Additionally, records indicate that Plaintiff would be able to
return to work under light duty after May 15, 2023. Plaintiff was instructed to follow up in 4-6 weeks.

On June 5, 2023, Plaintiff returned for her 6 week post-operation follow up. Throughout the 6 weeks,
records note that Plaintiff complained of significant pain. Additionally, records note that Plaintiff went for
a cervical x-ray on May 30, 2023 which showed appropriate hardware placement without any evidence of
complication or hardware failure. Furthermore, at her June 5, 2023 appointment, Plaintiff reported that
she fell and hit her head on the floor after becoming lightheaded and dizzy. She was now complaining
of spasm, ringing in her ears, trouble swallowing, voice change, shortness of breath, gait problems and
difficulty with speech. Plaintiff was instructed to go to the ER at Advent Health Daytona Beach Hospital.

Upon arriving to Advent Health Daytona Beach Hospital ER, Plaintiff reported that she got out of bed and
felt lightheaded when she fell. She could not recall whether she hit her head or lost consciousness.
Additionally, she reported neck pain (left side) which radiated toward her left shoulder. She was later told
to return to work on June 12, 2023. Treatment consisted of the following diagnostic studies:

Radiologic Exam Impression

Shoulder X-ray No acute ossesous findings.
CT Head 1. No evidence of acute intracranial process.
2. No acute fracture or traumatic subluxation in the cervical spine.
3. Interbody disc spacers at C5-6 and C6-7 in appropriate positioning.

Cervical X-ray No acute appearing abnormality of the cervical spine is shown. Disc
prosthesis have been previously placed at C5-C6, C6-C7. There is
osteophytic encroachment upon the neural foramina at C6-C7 more severely
on the right.
Cervical MRI No evidence for acute fracture or static listhesis in the cervical spine.
Sequela of C5-6 and C6-7 interbody disc spacer placement. Susceptibility
artifact from the hardware limits optimal evaluation at these levels although
mild spinal canal stenosis is suspect at C5-6. Varying degrees of multilevel
neural foraminal narrowing.

On June 26, 2023, Plaintiff returned to Dr. Yoon and she received refill for her Mounjaro 10 mg.
prescription.

On July 10, 2023, Plaintiff returned to Zoe Griffin, APRN (Nurse Practitioner) for her 12 week post-
operation follow up visit. Plaintiff reported that she was doing well overall. Records indicate that Plaintiff
was seen without her cervical collar. Additionally, Plaintiff reported that she been going on the boat and
is back to work, although she was still experiencing some numbness and tingling in her left upper
extremity as well as some voice changes and difficulty swallowing. Plaintiff was given a referral to an
ENT and for chiropractic treatment. Additionally, Plaintiff requested a referral to Dr. Valcarcel for
physical therapy.

On July 21, 2023, Plaintiff returned to Dr. Yoon and she received refill for her Mounjaro 10 mg.
prescription. She was also given permission to return to work with no restrictions.

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On August 2, 2023, Plaintiff returned to Dr. Valcarcel for chiropractic treatment. Plaintiff reported left
arm, shoulder, and leg pain 9/10. Additionally, she reported that her neck overall felt okay but she had
been experiencing changes in her voice and difficulty speaking and swallowing. Plaintiff attended (6) six
visits from August 2, 2023 through September 18, 2023.

On August 16, 2023, Plaintiff presented to Coastal Neurology, Inc. with Dr. Alyn Benezette. Her
complaints included neck and back pain, muscle spasms, and tremors. She reported worsening symptoms
following cervical spine surgery with Dr. Vinas and a subsequent fall out of bed. The plan included
initiating Baclofen and scheduling follow-ups with Dr. Pavlovic for pain management and Dr. Beg for
EMG and nerve conduction testing. Diagnoses included cervical and lumbar disc disorders,
radiculopathy, spinal cord injury at C5-7, and diabetes insipidus secondary to vasopressin deficiency.

On August 21, 2023, Plaintiff presented to Dr. Pavlovic and she received an IM Toradol 60 mg
Dexamethasone 10 mg injection. She rated her pain radiating from her lower back to her left leg a 9/10.
It was noted, that the Plaintiff was functioning worse after previously improving. Plaintiff returned on
August 24, 2023 and she received a C7-T1 interlaminar epidural injection.

On Plaintiff’s September 11, 2023 chiropractic visit, Plaintiff reported that she has experienced 40% relief
from the cervical epidural injection. The records indicate the Plaintiff reported going to a local bar and
drinking heavily to the point where she needed to get a lyft to get home and that when she woke up the
next day she had a mental breakdown in regard to her health condition.

The next day, on September 12, 2023, Plaintiff returned to Dr. Pavlovic and received a cervical trigger
point injection (left side).

On September 21, 2023, Plaintiff presented to Dr. Alyn Benezette, DO (Neurologist) and underwent an
NCV and EMG which was read as showing distal fibular motor neuropathy of the left lower extremity.

On September 25, 2023, Plaintiff returned at which time it was noted she continued to experience left-
sided motor and sensory impairment. Records indicate she had trouble reaching, pushing, pulling,
lifting, and carrying involving the left extremity. It was also noted she was unable to write with her
left hand, which is her dominant hand. It was also noted she was dragging her left leg. She denied any
cognitive impairments or headaches. She agreed to undergo a brain MRI.

From October 2, 2023, to December 22, 2023, Plaintiff underwent Chiropractic treatment with Dr.
Valcarcel with chief complaints of left sided radiating arm and leg pain, tingling, and numbness.

On October 5, 2023, Plaintiff followed up at Jena Medical FM Practice with Dr. James Brown, reporting
ongoing issues including loss of strength and muscle mass on the left side, difficulty walking, and
inability to use her left hand effectively. She noted she has not been able to engage in prior activities, such
as boating or motorcycling, since the accident and has missed nine weeks of work managing a service
department. Despite undergoing her epidural steroid injections (ESI), she reported persistent pain and was
working with physical therapy. Medications were adjusted due to issues with Trazodone and Tizanidine.

On October 9, 2023, Plaintiff had an EMG/NCV of the upper extremity which was read as being within
normal limits.

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That same day, Plaintiff presented to Stand Up MRI and received the following MRIs: brain, cervical, and
lumbar. The reporting radiologist, Dr. Shahin J. Korangy, MD opined as follows:

Radiologic Exam Impression

Brain MRI There is a right frontal subcortical focus T2 hyperintensity, given the
patient’s history this is suspect for post traumatic brain injury. Differential
consideration include/stroke/small vessel ischemic change and demyelinating
condition since as MS or other causes.
Cervical MRI There is a loss of the normal lordotic curvature of the cervical spine. At C4-5
there is stable bulging of the disc. This results in an anterior impression on
the thecal sac. At C5-6 in the interval, there are post-operative changes with
disc replacements susceptibility artifacts limits evaluation.
Lumbar MRI At L4-5 there is stabling bulging disc. This result in an anterior impression
on the thecal sac. Mild facet osteoarthritis with trace facet effusion.
L5-S1 there is a stable posterior disc herniation measuring 3.5 mm in AP
dimension abutting the descending S1 nerve roots.

On October 12, 2023, Plaintiff returned to Dr. Pavlovic and received a Sacral 1 transforaminal epidural
injection (left side).

On November 6, 2023, Plaintiff returned to Dr. Benezette for follow-up and reported improved
function/mobility. However, she continued to report pain, weakness, numbness and tingling, left-sided
motor and sensory impairment, muscles spasms and mood swings. Dr. Benezette referred Plaintiff to
ETHOS Health Group for additional testing in regards to her traumatic brain injury.

From January 2, 2024, to July 8, 2024, Plaintiff received chiropractic care from Dr. James Valcarcel at
Aligned Integrative Healthcare. She reported improvement in her left arm and leg but ongoing neck, back,
and leg pain. Notably, she experienced increased pain after a 1.5-mile hike in April 2024 and continued
with physical therapy and medication adjustments. By June 2024, she reported significant improvement in
her lower back but still experienced neck pain and tingling in her left hand. In July 2024, she noted 90%
relief from radiculopathy using compression, but her lower back pain persisted at 3-4/10, flaring to 8/10.

On January 5, 2024, Plaintiff presented to Dr. James Brown, MD (Family Medicine). Plaintiff reported
that she had better range of motion of her left shoulder. Additionally, Plaintiff reported that she had a 5-
day fishing trip scheduled in March of 2024 and a possible trip to Costa Rica afterward.
On February 14, 2024, Plaintiff returned for a follow-up and medication refills. Plaintiff reported ongoing
left-sided weakness and tingling as well as spasms.

Plaintiff presented to Stand Up MRI on February 19, 2024and an DTI 3D Tractography of the brain was
performed which evidenced the following:

Radiologic Exam Impression

DTI 3D Tractography of 1. There is a stable right frontal subcortical focus of T2 hyperintensity.
the Brain See figure 1, image 25, and series 16 with the arrow pointing to the
focus of T2 hyperintensity. Given the patient’s history, this finding is
suspicious for post-traumatic brain injury. Differential
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 considerations include stroke/small vessel ischemic change and
demyelinating condition, such as multiple sclerosis, amongst other
causes. Correlate clinically to confirm the diagnosis of traumatic
brain injury in this patient.
2. Whole brain analysis demonstrates visible reductions in fractional
anisotropy which correspond with areas of abnormal signal seen on
the standard MRI images. This finding is seen in groups of patients
that are diagnosed with white matter injury; therefore, clinical
correlation is recommended to confirm the diagnosis of traumatic
brain injury in this patient. Quantitative regional analysis through the
corpus callosum was performed. FA value within the genu of the
corpus callosum is 0.71 which is more than two standard deviations
below the mean of 0.853 (SD 0.04). FA value within the selenium of
corpus callosum is 0.765 which is more than two standard deviations
below the mean of 0.868 (SD 0.05). These are abnormal and
indicative of axonal injury. Evaluate clinically.
3. Analysis of brain volumes was performed. There is volume loss
involving the right entorhinal cortex. Given the patient’s history, the
finding is suspicious for post-traumatic atrophy. If there is further
concern for developing post-traumatic atrophy, a follow-up MRI of
the brain with NeuroQuant in six months would be helpful for
evaluation of interval changes.

On April 3, 2024, Plaintiff presented to Coastal Neurology, Inc., where she underwent a sacral
transforaminal epidural steroid injection for lumbosacral radiculopathy. She rated her pain as 10/10
and reported persistent symptoms radiating down her lower extremities.

On April 16, 2024, Plaintiff visited Complete Health – FL for her monthly checkup and medication refill.
She required scopolamine patches for an upcoming offshore trip. Plaintiff reported severe lower back pain
and sciatica, noting difficulty sitting for extended periods and requiring frequent rest. Stress related to her
ongoing divorce and work schedule of 60 hours per week was also noted. She described easy bruising and
continued challenges maintaining a positive outlook. An annual physical revealed elevated cardiovascular
risk, anxiety, insomnia, UTI’s, fibro adenoma of the breast, hyperlipidemia, and hypothyroidism.

On May 2, 2024, Plaintiff presented to Dr. Whitney Shoemaker at The Gynecology Center with
complaints of persistent breast pain and a lump in her right breast. Her history included prior benign
biopsies. Dr. Shoemaker recommended a mammogram and breast ultrasound. She also advised lifestyle
changes, including avoiding caffeine and taking Vitamin E supplements. Plaintiff’s reported medical
history included domestic violence, fibromyalgia, anxiety, depression, migraines, and the loss of a child
to a motorcycle accident.

On May 21, 2024, Plaintiff returned to Dr. Shoemaker for abnormal uterine bleeding with large clots. A
pelvic ultrasound and lab work were ordered to investigate potential underlying causes, including
menorrhagia.

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On June 6, 2024, Plaintiff followed up with Dr. Shoemaker regarding her lab and ultrasound results.
Imaging revealed fibroids, multiple ovarian cysts, and cervical abnormalities. Plaintiff reported severe
abdominal pain and lower back pain associated with heavy bleeding. A PAP smear confirmed HPV+16
with atypical squamous cells of undetermined significance (ASCUS). Recommendations included further
evaluation and treatment of the identified conditions.

On June 11, 2024, Plaintiff attended her monthly checkup at Complete Health – FL, reporting moderate
improvement in her lower back pain and sciatica due to consistent physical therapy sessions twice a week.
She mentioned resuming walking 14,000 steps a day, however before the subject accident, she walked
16,000 steps a day. Additionally, she expressed relief at reducing alcohol consumption to improve her
health. However, she still experienced significant soreness and occasional flare-ups of lower back pain.
On July 12th, she returned and noted that her lower back feels strong and is feeling better.
.
On July 31, 2024, Plaintiff underwent a colposcopy with Dr. Shoemaker, revealing CIN3 with HPV+16.
Abnormal bleeding persisted, and she was scheduled for a follow-up procedure.

On August 2, 2024, Plaintiff returned to Complete Health – FL, reporting continued physical therapy for
lower back and leg pain. She discussed ongoing financial and emotional stress related to her divorce and
stated she had drained her investment account and sold her motorcycles. She described recurring
nightmares linked to a traumatic gunshot incident involving her ex-wife in June 2024 and was actively
engaging in therapy to address these issues.

On August 15, 2024, Plaintiff underwent a LEEP procedure with Dr. Shoemaker to address cervical
intraepithelial neoplasia (CIN3). The preoperative diagnoses included HPV+16 and cervical dysplasia.

On September 9, 2024, Plaintiff returned to Dr. Shoemaker for a post-LEEP follow-up, reporting heavy
menstrual bleeding and significant abdominal discomfort. She requested a referral to a breast surgeon due
to a recurrent right breast mass. Menorrhagia, cervical dysplasia, and HPV were noted, along with the
need for ongoing management of her conditions. 15 days later, she retuned with additional complaints of
abdominal pain and discharge.

On October 4, 2024, Plaintiff presented to Dr. Tara Wilson at North Florida Surgeons for an evaluation of
persistent breast pain and a lump in her right breast. Her history of multiple benign biopsies was noted.
Dr. Wilson recommended further right breast imaging. Plaintiff also reported ongoing back pain, muscle
weakness, fatigue, and restless sleep attributed to the subject accident. Psychological counseling was
encouraged.

From October 14, 2024 through November 19, 2024, Plaintiff received chiropractic care from Dr. James
Valcarcel at Aligned Integrative Healthcare. She reported ongoing lower back pain with intermittent
radiating symptoms to the left glute, leg, and foot. Initially, she experienced minimal difficulties with
activities such as walking stairs and the beach, but her pain increased, particularly following prolonged
lumbar flexion while working on an RV at her job. Despite occasional soreness in the glute and
hamstring, notes indicate that her symptoms gradually improved, with back pain reducing to 2-3/10 and
leg pain becoming localized to the glute. Treatment included addressing thoracolumbar paraspinal tone,
an assessed spinal restriction at L4/5 and L5-S1, and poor balance through thoracic and lumbar
manipulation.

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The above summary accounts for all medical records received to date. Enclosed please find a detailed
medical summary of the records currently on file. We will of course supplement this report upon receipt
of additional medical records as well as provide an updated Medical Chronology.

Defense Neuroradiologist, Dr. Eric Pfeiffer’s Film Review:

Dr. Pfeiffer’s opinions as it pertains to the cervical spine are negative. A review of Plaintiff’s post-
accident cervical MRI films (from 2/27/23) reveals a very large protrusion at C5-6 with moderate
narrowing of the spinal canal. There is also a bulge at C6-7. Dr. Pfeiffer explained these findings will be
easy for a jury to see. He also noted that Plaintiff likely experienced symptoms. Dr. Pfeiffer agreed the
disc-replacement surgery at C5-6 and C6-7 would be a reasonable treatment for these findings.

Dr. Pfeiffer further opined that there was no indication that the cervical findings were the result of an
acute or recent injury (there was no soft-tissue swelling) and the spinal canal seems to have re-modeled
around the protrusion at C5-6, which would take years to develop. Dr. Pfeiffer also noted that C5-6 is the
most common area for early degenerative changes (here chronic spurring) to develop. However, even if
these findings at C5-6 pre-dated the subject accident, it would not have taken much of an impact to make
them become symptomatic. He characterized Plaintiff as a classic “egg-shell Plaintiff.”

As is pertains to the lumbar spine, Dr. Pfeiffer did not see anything but normal age-related degenerative
changes for a 40 year-old woman. There is no herniation. There is a tiny bulge at L5-S1.

Dr. Pfeiffer opined that the 10/9/23 and 2/19/24 brain MRIs were normal. No signs of swelling, no
bleeding (or history of bleeding), no tissue volume loss, and no atrophy.

C. Damages:

The records on file demonstrate total medical bills of $261,775.50. Safeco/Liberty Mutual has paid
$10,000.00 in PIP benefits, and MedPay payments total $1,406.14, including $1,000.00 from Wilbur
Insurance and $406.14 paid to Stand Up MRI. Plaintiff’s health insurance provider, Florida Blue, has paid
$77,036.82 toward the total charges and has asserted a lien of $74,680.96. After adjustments, the
remaining balance is $75,108.48.

Plaintiff is no longer claiming lost wages or loss of earning capacity. Additionally, she is not attributing
her recent divorce to the subject accident.

Attached please find a medical bill summary.

D. Investigation/Liability:

Deposition of the Plaintiff:

A. General Background

In general, the Plaintiff was well-spoken and had a normal appearance. Throughout the deposition, she
would have to continuously stand up to relieve the pain she was feeling from sitting down for an extended
time.

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The now 41-year-old Plaintiff, Julie Diaz (D.O.B.: 7/27/1983) was born in San Antonio, Texas, but
moved to Florida in 2012. She has two adult sons, Demetri Eliza Diaz (25) and Aramif Gaza (25).
Plaintiff currently lives in Ormond Beach, Florida. She lives with a roommate, Ellie Reed, and her son,
Demetri Eliza Diaz. At the time of the subject accident, the Plaintiff lived at 10 Heather Lane, Ormond
Beach, Florida. She lived there with her wife, Monica Diaz. Plaintiff and Monica Diaz are currently in the
process of getting divorced. The subject accident has no bearing on their decision to separate.

Plaintiff’s highest level of education is high school. She did not complete high school but has obtained
her GED. Additionally, the Plaintiff attended WyoTech and became certified as a Motorcycle Technician.

In the early 2000s, the Plaintiff was convicted of Possession of Controlled Substance, a felony, in San
Antonio, Texas. She did not receive any prison time for that conviction. Although the Plaintiff alleges she
doesn’t recall, she also was convicted of Theft of Property in 2001 in Texas. Additionally, she was
convicted of giving false information to a police officer during the investigation of possession of
marijuana in 2008.

Presently and at the time of the subject accident, the Plaintiff worked at Giant Recreation World. At Giant
Recreational, she works as a Senior Service Advisor primarily supervising technicians and conducting
customer service. Plaintiff works full-time from Tuesday to Saturday. Previously, the Plaintiff worked as
a manager at Tire Outlet, Ormond Outpost, and Just Brakes. Her employment with Ormond Outpost and
Just Brakes was terminated due to the company losing business. At Tire Outlet, her employment was
furloughed due to COVID-19.

The Plaintiff is not claiming lost wages or an impairment of earning capacity.

B. Prior Accidents

Plaintiff alleges she has never been injured on the job or filed a workers’ compensation claim. She doesn’t
recall that in 2015, she was treated at Advent Health in Daytona Beach, Florida, after she attempted to
grab a tire from a rack and the rack fell on her right forearm and right shoulder. Plaintiff admitted that she
treated Advent Health in Daytona Beach Florida after suffering abdominal pain while moving a
motorcycle in 2019. The abdominal pain was a result of gas from intestinal issues.

While in her early 20s, the Plaintiff had surgery to remove breast tumors.

Aside from the subject accident, the Plaintiff has not been in any motor vehicle accidents.

C. Subject Accident

On February 7, 2023, the Plaintiff was traveling to work on Destination Daytona Lane at approximately
15-20 mph and was approximately a few minutes away from arriving. She attempted to drive past Love’s
Travel Shop (including a gas station for semi-trucks), she noticed Defendant Driver stopped at the
entrance. The Plaintiff alleges that the Defendant Driver attempted to make a left-hand turn out of the
entrance instead of the exit, blocking the Plaintiff’s right of way. As a result, the Plaintiff attempted to
brake but allegedly had little to no time to do so. Plaintiff’s 2015 Chevy Silverado collided with the
container on the semi-truck. Her vehicle’s front panel area was damaged; while the Defendant Driver’s
semi-truck front trailer portion was damaged. Plaintiff described the impact as mild. Her body jolted upon
the collision but did not come into contact with the interior of her vehicle. The airbags did not deploy.

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Directly after the collision, the Plaintiff initially stated that both vehicles didn’t move until police arrived.
After further questioning, Plaintiff testified that her co-workers, Christopher Burdi, and others, were
driving directly behind her and that Defendant Driver continued to drive on. Her co-workers had to
inform the Defendant Driver that he needed to stop. After both vehicles came to a stop, the Defendant
Driver allegedly exited the semi-truck and began yelling at the Plaintiff. After a few exchanges, Plaintiff’s
co-workers also exited their vehicle in case of further escalation. Upon seeing Plaintiff’s co-workers come
to her defense, the Defendant Driver returned to his vehicle.

Law enforcement officers arrived approximately 15 minutes after the subject accident. The Plaintiff did
not complain to the officer of any injuries and did not request paramedics. The officer on the scene
determined that the Defendant Driver was at fault for the subject accident. While at the scene, the Plaintiff
called her wife and informed her of the accident. Eventually, after the officer conducted his investigation,
the Plaintiff left the scene in her vehicle and drove to work.

After a few hours at work, the Plaintiff eventually left after she began feeling pain and discomfort. Upon
arriving at her home, Plaintiff and her now ex-wife agreed that she should get evaluated at a hospital
because she had a headache, stiffness in her neck, and soreness in her lower back.

D. Post-Accident Medical Treatment

Plaintiff is alleging that she suffered injuries to her neck and lower back.

On February 7, 2023, the Plaintiff began treating at Advent Health Center Care in Ormond Beach,
Florida. Her chief complaint consisted of pain in her neck and lower back. Rebekah Lorraine Buchanan,
APRN, conducted a scan of her neck and lower back but doesn’t recall what the scans revealed. She
believes that Ms. Buchanan recommended that she take ibuprofen and get some rest.

On February 14, 2024, the Plaintiff began treating at Align Integrated Health Care with James Valcarcel,
DC, a reputable chiropractor, in the motorcycle community in and around Ormond Beach, Florida. She
complained of pain in her neck and lower back, along with intense muscle spasms in her left arm, left leg,
and left buttocks. The Plaintiff received chiropractic treatment, and Mr. Valcarcel recommended Dr.
Bojan Pavlovic, a neurologist.

On February 27, 2023, an MRI of the Plaintiff’s cervical spine at Stand Up MRI by Dr. Ali Badday
revealed: (1) At C5-6, there is 0.6 mm of retrolisthesis, posterior central disc herniation (2) At C6-7, there
is posterior central disc herniation which indents the ventral thecal sac. Dr. Badday concluded that it is
medically probable that the C5-6 and C6-7 disc herniations were related to the injuries sustained from the
subject accident. Additionally, an MRI of Plaintiff’s lumbar spine revealed: (1) At L5-S1, there is a
posterior central disc herniation superimposed on a disc bulge, which indents the ventral thecal sac.
Again, Dr. Badday concluded that it is medically probable that the L5-S1 disc herniation is related to the
injuries sustained from the subject accident.

On March 8, 2023, at Coastal Pain and Neurology, Dr. Pavlovic treated the Plaintiff for neck and lower
back pain. Dr. Pavlovic performed a series of injections on Plaintiff’s neck in March 2023. The injections
included a Cervical Interlaminar epidural injection and a Lumbar Interlaminar epidural injection.

In April 2023, the Plaintiff arrived at work and in a couple of hours, started to feel that something wasn’t
right. She called her wife and informed her of the discomfort she was feeling. At some time that morning,
the Plaintiff suffered from a severe spasm at work. She was unable to drive herself to the hospital and had
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one of her co-workers drive. The Plaintiff arrived at Advent Health Med Group Neurosurgery, where Dr.
Federico Valcarcel conducted a reflex test on her legs. She described that she couldn’t feel her legs and
that they were really cold. The Plaintiff testified that immediately after the test, she didn’t recall anything
and allegedly blacked out. Medical staff informed her that she had a spasm and collapsed on the floor.
Her next recollection was waking up with a neck brace after Dr. Vinas performed an Anterior Cervical
Discectomy and Arthroplasty on Plaintiff’s Cervical Spine at C5-6 and C6-7. After a couple of days, the
Plaintiff was discharged. The Plaintiff wore the neck brace for approximately one to two months after.
The operation almost completely relieved the Plaintiff of her muscle spasms. In comparison, before the
surgery, the Plaintiff was in intense and intolerable pain.

The Plaintiff is being treated at Aligned Integrative Healthcare with Dr. Valcarcel at least once a week.
Her ability to receive treatment depends on her work schedule, but she attempts to treat twice a week.
Lately, the Plaintiff has been receiving treatment for her neck and lower back. The treatment is helping
her regain muscle mass on the left side of her body.

Although she has not scheduled future medical appointments, she plans to follow up with Dr. Venus and
Dr. Benedict.

E. Subsequent Accidents

In June 2023, the Plaintiff was at home when she tripped over her dog’s bed, resulting in a trip to Advent
Health in Daytona, Florida. After being examined, Dr. Justin Thomas informed her that everything was
okay and sent her home

F. Current Condition

The Plaintiff is not on any pain management medication besides over-the-counter Ibuprofen. She takes
Ibuprofen every other day. Her reasoning for not taking any pain-management medication is that she
wants to take a holistic/natural approach.

Regarding current pain levels, the Plaintiff still suffers from neck and lower back pain. She rated her neck
pain a 10 out of 10 in intensity on its worst day and a 3-4 out of 10 on a good day. Additionally, she rated
her lower back pain a 10 out of 20 in intensity on its worst day and a 2-3 out of 10 on a good day. Her
pain increases in intensity after sitting down for a long period. The pain radiates from the left side of her
neck down to her left shoulder, down to her left buttocks and left hip, and further down to her left toes.

As a result of the subject accident, the Plaintiff suffers from physiological/emotional conditions. Several
months ago, she started treatment with a therapist for anxiety as a result of the subject accident. As of
now, the Plaintiff has attended approximately 2-3 sessions for an hour each. She stated she feels like a
prisoner in her own body due to her inability to do certain activities. She plans on revisiting her therapist.

Before the subject accident, the Plaintiff enjoyed the following hobbies: offshore fishing, rollerblading,
archery, riding motorcycles, ATVs, bicycles, and dirt bikes. Currently, the Plaintiff can’t partake in any of
those activities. Regarding tasks that have become more difficult, she has trouble bending over, using
physical strength with her left hand, and writing with her left hand.

Since the subject accident, the Plaintiff has traveled to Nashville, Tennessee, and Texas. She traveled by
airplane to both destinations. She testified that during her April 2024 trip to Nashville, she didn’t partake
in many activities. The Plaintiff would go back to her hotel once she began to experience pain. Regarding
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Texas, she traveled there a few months ago for a funeral. Additionally, she traveled to Sea Rim State Park
in Texas.

Investigation and Surveillance:

As discussed earlier, our investigator attempted surveillance on 12/15/23, 12/16/23 and 12/21/23. He was
only able to document the Plaintiff’s wife (now ex-wife).

We conducted an additional round of surveillance on June 3, 2024, June 4, 2024, and June 23, 2024. The
good news is that our investigator located the Plaintiff, identified her vehicle, and confirmed the Giant
Recreation World location where she is employed. However, the surveillance efforts faced some
challenges. On the first Sunday, the Plaintiff did not leave her home. On the second Sunday, she
displayed suspicious behavior, taking a short drive but never exiting her truck. The investigator noted that
the setup at her residence is particularly difficult to monitor. It was also observed that the Plaintiff is now
divorced and living in a large house with several other individuals, including a male coworker. The
coworker drives a Giant Recreation World van, which initially made it challenging to determine whether
it was the Plaintiff or someone else leaving the property. The house has 3-4 vehicles in addition to the
Plaintiff's pickup truck and the work van. While the investigator found the Plaintiff's vehicle at her
workplace, it was parked approximately 800 feet away from the Giant Recreation World location, in a
plaza shared with other businesses. It remains unclear whether she works directly at Giant Recreation
World or at another business within the neighboring plaza, which is also owned by the same company.
The investigator recommends conducting surveillance at her workplace parking lot in the morning to
observe where she walks to begin her workday. Based on her history as a motorcycle mechanic, it is
believed she may still be working in a mechanical role.

Our investigator is in the process of conducting an additional round of surveillance. Thus far, he observed
the Plaintiff arriving at work in office attire, suggesting she is no longer working as a mechanic. A
weekend day of observation yielded no activity, and one weekend day remains.

E. Litigation Strategy/Evaluation:

This case involves a moderate front-drivers side impact collision with a 41-year-old Plaintiff who
reported and treated for neck and back pain on the date of the accident. She then treated with a
chiropractor and pain management, who provided a cervical epidural injection on March 9, 2023, before
having a two-level cervical discectomy and disc replacement at C5-6 and C6-7 on April 21, 2023. Her
cervical MRI, which was performed just three weeks post-accident, shows a significant herniation at C5-6
with compression on the cord that would be symptomatic. The herniation is large and is easy for a jury to
see. Since the surgery she has continued to treat, receiving ongoing chiropractic treatment, a cervical
epidural, cervical trigger point injections, and two lumbar epidural injections, most recently on April 3,
2024. She attended 69 chiropractic sessions from February 14, 2023 through September 4, 2024. We
have no record of prior injuries or treatment to the cervical or lumbar spine.

With $261,775 in boardable medical bills, considering the Plaintiff’s relatively young age, the fact that
she began treatment on the date of accident, the large/obvious cervical herniation, the lack of any priors,
the moderate impact with a tractor-trailer, and that fact that she has continued to treat with a chiropractor
and has received 4 post-surgical injections, it seem this case has a potential verdict value in the range of
$750,000 - $950,000 with a settlement value in the range of $650,000 - $850,000.

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We will keep you updated as additional information is received. As always, feel free to contact us with
any questions or comments.

Very truly yours,

David Drahos

DAVID M. DRAHOS
VICTOR J. GENCHI
DMD/VJG/MM

Enclosures: Updated Medical Record Summary

Updated Medical Bill Summary

cc: Client – Jamelle Comfort and Singh Transport Corporation

1700 Palm Beach Lakes Blvd, Suite 800, West Palm Beach, Florida 33401 • T: (561) 640-0303 • F: (561) 640-0524
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