Professional Documents
Culture Documents
March 1
Description Amount
Consulting Fee for June $5640.00
Supplies 200.00
Travel Expenses 550.00
TOTAL $6390.00
Maddy Ott
Salt Lake Community College - 4600 3483 Made Up Drive
South Redwood Road - Salt Lake City, Taylorsville, Utah, 84124
Utah 84123 (801) 343-6584
(801) 957-SLCC (957-7522)
www.slcc.edu
Objective To obtain a position utilizing leadership and communication skills
focusing on marketing, consulting, and/or public relations.
Professional October 2008 – present
Biomat Usa
Phlebotomy
Payroll Report
Hours Hourly
Employee Name Worked Wage Salary
Larson, Kaia 20 9.00 180.00
Mulgroni, Shayla 29 10.00 290.00
Barnes, Fredrick 35 10.00 350%.00
Allen, Shawna 38 9.00 342.00
Eliff, Edward 39 11.00 429.00
Pinner, Derek 40 12.00 480.00
West, Shandra 40 15.00 1724.5.00
Johnson, LeBrock 40 12.00 480.00
Sing, Chang 40 11.00 440.00
McFarland, Ian 41 15.00 615.00
TOTAL PAYROLL EXPENSE 4984.00
Maddy Ott 4/12/2009
A revision mark (a vertical line outside the left or right margin) signifies a change has
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Maddy Ott 04/14/2009
Sidewalk Café
Where trendy-conscious people dine!
Sidewalk Café is an avant-garde that has recently opened on Main Street in Carmel.
Sidewalk Café offers a diverse and eclectic menu that will appeal to a diverse and eclectic
clientele.
Following is a list of lunch items available on a daily basis:
Fresh Seafood
Homemade Soup
Italian Cuisine
Gourmet Sandwiches
The décor in the Sidewalk Café is homey and inviting, yet surprisingly sophisticated.
Original artwork is displayed on every wall, adding a charming feeling to the already warm
environment. A large fireplace takes up the back wall, while the front windows provide a frame
for the activity on the street outside.
The owner, Sue McCrory, is a newcomer to the restaurant scene. Previously, she operated a
folk-art gallery. Sue has vowed to maintain the integrity of the Sidewalk Café vision. She makes
herself available to her customers, and she can usually be found table-hopping through the dining
room.
The chef, Ken McCrory, is the owner's brother. His love of food, and his willingness to
experiment are evident in the interesting specials he prepares daily. Ken’s talents are numerous:
in addition to the daily specials, he is responsible for the fresh baked breads and pastries that
grace the tables.
The Sidewalk Café is open from 11:30 a.m. to 10:00 p.m. Tuesday through Saturday. On
Sundays, the hours are 9:30 a.m. to 10:00 p.m. The Sunday brunch is charming, and not to be
missed.
The Sidewalk Café also has a private room that can be reserved for parties and functions.
The room has a fireplace, and accommodates up to 25 people.
Stop by and find out why the Sidewalk Café is where trendy-conscious people come to
dine!
Maddy Ott 4/12/2009
Cases
Florida Physician's Ins. Reciprocal v. Stanley, 452 So.2d 514, 515-16 (Fla. 1984) .....................................................4
Florida Physician's Insurance Reciprocal v. Stanley ....................................................................................................4
Washington v. Barnes Hosp., 897 S.W.2d 611, 619-21 (Mo. banc 1995) .................................................................2, 4
Washington v. Barnes Hosp., 897 S.W.2d at 621 ..........................................................................................................6
Washington v. Barnes Hospital .............................................................................................................................3, 4, 5
1
Maddy Ott 4/12/2009
In point 3 of his first motion in limine, plaintiff seeks to preclude evidence of collateral
source payments. Plaintiff attempts to categorize the evidence into two groups:
Group 1: Medicaid
Plaintiff claims that evidence of Medicaid is subject to the rule, while the Missouri Supreme
Court in Washington v. Barnes Hosp., 897 S.W.2d 611, 619-21 (Mo. banc 1995) has held that
evidence of programs and therapies available through the public schools are not subject to the
While defendant does not agree that any Missouri appellate court has directly held that
Medicaid is subject to the collateral source rule, defendant does not plan to introduce evidence
that Medicaid has paid for certain medical expenses in this case.1
1
The only case cited by plaintiff concerning Medicaid payments is Cornelius v. Gipe, 625
S.W.2d 880, 882 (Mo. App. 1981). In that case, the court expressly said: "Even assuming
without deciding that the argument [that mentioned the availability of Social Security,
Medicare, and Medicaid] violated the collateral source rule, the argument clearly bore on
damages, and by reason of the defendant's verdict, Cornelius was not prejudiced." In
Washington v. Barnes Hosp., 897 S.W.2d 611, 620 (Mo. banc 1995) the court specifically noted
this was dicta.
2
Maddy Ott 4/12/2009
Defendant also agrees that goods and services provided by the public schools is not subject to the rule.
However, to the extent plaintiff is attempting to recast Washington v. Barnes Hospital as holding that
the availability of free public school programs is the only exception to the collateral source rule,
defendant disagrees. There are other free public programs and therapies that are available outside the
public school programs that will be available to Marcel that should also not be considered collateral
sources. Programs that will likely be at issue in this case are those provided through the Missouri
The State of Missouri has an extensive system of care and treatment options for individuals with
developmental disabilities. The only criteria for eligibility is they have a developmental disability
In this case, Marcel will meet this criteria. He has already been documented as having cerebral
palsy prior to the age of twenty-two. Plaintiff's own experts state this is likely to continue indefinitely,
and results in substantial functional limitations in more than two of the six areas of major life.
Evidence that these public programs are available as an alternative to Dr. Elam's private one-on-one
attendant care projections in his life care plan are relevant and admissible.
2
If the recipient has annual adjusted gross income exceeding one hundred thousand dollars ($100,000)
he shall be assessed a charge for case management services, and the charge shall be the lesser of actual
cost or one-fourth (1/4) their monthly ability to pay. 9 CSR 10-31.011(3). This has no application in
this case as plaintiff's experts state Chavon will be permanently unemployable.
3
Maddy Ott 4/12/2009
In Washington v. Barnes Hosp., 897 S.W.2d 611, 619-21 (Mo. banc 1995), the Missouri
Supreme Court extensively re-examined the collateral source rule. The court began its analysis with
the statement that "the collateral source rule is not a single rule but rather, a combination of rationales
should be precluded from admission." Id. In analyzing the rationales that supported the rules
application, the court reviewed decisions from other states. In reaching its decision that public school
benefits where not subject to the collateral source rule, the court rejected contrary views from other
states, and adopted the reasoning of the Florida Supreme Court in Florida Physician's Ins. Reciprocal
Id. at 620-21 (Emphasis added). The Missouri Supreme Court also stated: "[w]e reject the concept that
the collateral source rule should be utilized solely to punish the defendant. Id. at 621.
While the specific issue addressed in Washington v. Barnes Hospital was evidence relating to
the availability of public special education services, the issue in Florida Physician's Insurance
Reciprocal v. Stanley, the Florida case adopted by the Missouri Supreme Court, also included the
"availability and effectiveness of free or low-cost charitable and governmental programs available in
the community." 452 So.2d at 515. In the Florida case, the plaintiff "brought a medical malpractice
action against the [defendants] for the retardation and cerebral palsy [plaintiff] has suffered from birth."
Id. Defendant cross-examined plaintiff's damage experts on the availability of free or low cost services
from governmental and charitable organizations that were available to people that had mental
4
Maddy Ott 4/12/2009
retardation and cerebral palsy as children. Id. These are the same benefits that are at issue in the
Id. at 515. As the Missouri Supreme Court adopted the Florida court's reasoning in Washington v.
Barnes Hospital, it is apparent it would reach the same result with regard to the admissibility of
evidence of other public programs, in addition to the public school special education programs,
The public programs available through MRDD are, in effect, an extension of those available
through the public schools. They replace those provided by the public school after the child turns 18.
Just as in the case of public school benefits, the plaintiff did not purchase the benefits available through
MRDD, nor work for them as an employment benefit, nor contract for them. Hence, the "benefit of the
bargain" rationale does not apply. Just as in the case of public school benefits, the MRDD programs
are funded by tax dollars. As the Missouri Supreme Court stated in Washington v. Barnes Hospital,
"[w]hile to some extent public schools are funded by plaintiffs' tax dollars, they are also funded by
defendants' tax dollars and no windfall results to either." Id. at 621. The same is true for MRDD
benefits. As the court emphasized in Washington v. Barnes Hospital: "[a]s the injured party [Marcel]
incurs no expense, obligation, or liability, we see no justification for applying the Collateral Source
rule." Moreover, these free public programs are available to any child that has been documented to
have a developmental disability before age 22, and is not contingent on indigent status (as in Medicaid
benefits) or having been earned through military service (as for veteran's benefits), or through work
Accordingly, these free public benefits available to people, like Marcel, after they turn eighteen
and have cerebral palsy can be considered by the jury as alternatives to Dr. Elam's private one-on-one
attendant care projections in his life care plan. Plaintiff's motion in limine to this extent should be
5
Maddy Ott 4/12/2009
denied. "Plaintiffs, of course, may respond to this evidence with arguments of its inadequacy, the risk
of its continued availability, etc." Washington v. Barnes Hosp., 897 S.W.2d at 621.
6
Maddy Ott 4/12/2009
Table of Figures
Cancer Overview
Cancer is one of the scariest words in the English language. When you hear the word as
part of a diagnosis, it’s natural to feel many emotions, especially fear.
A cancer diagnosis can cause you and your family a great deal of stress, but you have
many resources to help you. You owe it to yourself to learn as much as possible about
your diagnosis and how it can be treated. Knowledge is power, and it can help you deal
with this disease.
What is cancer?
Cancer is a disease that occurs when cells in the body begin to divide at a faster rate than
the body requires. These rapidly dividing cells grow into a lump that is known as a tumor.
The tumor can be benign (non-cancerous) or malignant (cancerous).
For instance, the use of tobacco is one of the main causes of cancer, especially lung
cancer. Tobacco use, whether in the form of smoking, chewing, or exposure to second-
hand smoke (smoking by others), can also cause cancer of the mouth and larynx,
esophagus, throat, and many other parts of the body.
What is staging?
One of the biggest concerns about a cancer diagnosis is whether the cancer has spread
(metastasized) beyond its original location. To determine this, the doctor assigns a
number (I through IV) to your diagnosis. The higher the number, the more the cancer has
spread throughout your body. This is called "staging." The doctor needs this information
in order to plan your treatment.
Chemotherapy — This treatment uses powerful drugs that destroy the cancer cells.
Chemotherapy is delivered orally (pills) or through an intravenous (IV) line.
Radiation — This is a treatment that kills cancerous cells with radiation (high-energy
rays). Radiation therapy can either be internal (placed within the body) or external
(delivered by a machine outside the body).
Maddy Ott 4/12/2009
NOTE: In some cases, radiation therapy and chemotherapy are given to a patient at the
same time.
Surgery — A surgeon removes the tumor, along with the surrounding area (in some
cases).
Hormone therapy — Hormones (substances produced by the glands to regulate organ
functions) might be given to the patient to block other hormones that might cause cancer.
For example, men with prostate cancer might be given hormones to keep testosterone
(which contributes to prostate cancer) at bay.
Biological response modifier therapy — Biological response modifier therapy uses
natural or artificial (created in a laboratory) materials to reconstruct the body's natural
defenses against disease. Biological therapy includes monoclonal antibody therapy and
vaccines. (Monoclonal antibodies are created in a laboratory to work like natural
antibodies, which are produced by the body’s immune system to fight disease.)
Stem cell transplantation — Stem cells (immature cells from which all blood cells
develop) are removed from the patient's circulating blood or bone marrow and then
returned after chemotherapy treatment.
In addition, your doctor can refer you to a social worker or a mental health professional,
both of whom can help you deal with the emotional aspects of your diagnosis. The social
worker can also help you with the practical and financial issues related to the disease.
The most consistent finding, over decades of research, is the strong association between
tobacco use and cancers of many sites. Hundreds of epidemiologic studies have
Maddy Ott 4/12/2009
confirmed this association. Further support comes from the fact that lung cancer death
rates in the United States have mirrored smoking patterns, with increases in smoking
followed by dramatic increases in lung cancer death rates and, more recently, decreases
in smoking followed by decreases in lung cancer death rates in men.
Food and nutrient intake have been examined in relation to many types of cancer. Case-
control epidemiological studies have suggested an association between high fruit and
vegetable consumption and reduced risk of various cancers. The quality of this evidence,
however, has been questioned, and prospective cohort studies exploring this question
have shown inadequate evidence to conclude that such an association truly exists.
Contrary to expectation, randomized trials found no benefit of beta-carotene
supplementation in reducing lung cancer incidence and mortality; risk of lung cancer was
statistically significantly increased in smokers in the beta-carotene arms of 2 of the trials.
Similarly, randomized controlled trials have found no reduction in risk of subsequent
adenomatous polyps of the colon in individuals who have had polyps previously resected
taking dietary fiber supplements compared with those receiving much lower amounts of
supplemental wheat bran fiber. Ecologic, cohort, and case-control studies have found that
increased consumption of fat and red meat is associated with increased risk of colon
cancer. A randomized controlled trial of dietary modification to lower fat consumption in
postmenopausal women, however, showed no reduction in colon cancer. Likewise, there
was no benefit of the low-fat diet on all cancer mortality, overall mortality, or
cardiovascular disease. A large randomized trial is currently underway to investigate
whether men taking daily selenium or vitamin E or both experience a reduced incidence
of prostate cancer in comparison with men taking placebo pills.
Diagnosis
The rates of newly diagnosed cancer cases (incidence) are one way to measure progress
against cancer. The lower the rates, the better.
Another important measure is the proportion of cancers diagnosed at a late stage. The
stage of a cancer shows how far the disease has progressed. The earlier the stage at
diagnosis, the better the chances for cure. Downward trends in the proportion of late
Maddy Ott 4/12/2009
cancer diagnoses are a sign that screening is working for the cancers for which early
detection methods are available.
This section of the Cancer Trends Progress Report - 2005 Update provides data on the
rates of new cancers, based on the NCI Surveillance, Epidemiology, and End-Results
(SEER) Program, by cancer site and by racial and ethnic group. Also included are data on
the proportion of cancers diagnosed at a late stage for five of the major cancer sites where
cancer screening has been shown or has been evaluated to make a difference in outcomes.
Cancer sites include: female breast, colon, rectum, cervix, and prostate.
Source: www.cancer.gov (www.cancer.gov)1
Surgery can be very successful in treating some kinds of cancer, but it isn't an option for
all people. If the cancer is in the form of a malignant tumor and the tumor is in one place
(localized), it may be possible to safely "cut out" the tumor and any surrounding affected
tissue. Surgery may not be possible if the cancer has spread to other areas of the body or
if the tumor cannot be removed without damaging vital organs, such as the liver or brain.
Radiotherapy uses radiation — in the form of a special kind of x-ray, gamma rays or
electrons — to damage cancer cells so that they can't multiply. There is usually no pain
during therapy. Radiotherapy may sometimes be the only treatment needed, or it may be
used with other therapies, such as surgery. A combination of surgery and radiotherapy
may be used for tumors that grow in one place.
Chemotherapy uses medicines to attack the cancer cells. Just the word "chemotherapy"
can cause a lot of fear because the side effects can be severe. However, not all people
experience severe side effects. The side effects of chemotherapy can often be reduced
with other medicines.
Chemotherapy is usually used when the cancer has spread to other areas in the body.
Chemotherapy can also be used in combination with surgery and radiation. Sometimes
the tumor is surgically removed and then chemotherapy is used to make sure all the
cancer cells are killed.
Another kind of treatment is biological therapy. This treatment uses proteins to trigger the
body's immune system to produce more white blood cells (or lymphocytes). Two
lymphocytes that can attack and kill cancer cells are the T-cell and the B-cell. The
proteins boost the ability of the T-cell and B-cell lymphocytes to kill cancer. Biological
therapy can also be used in combination with surgery, radiation therapy or chemotherapy.
1
Source: www.cancer.gov
Maddy Ott 4/12/2009
Hormone therapy is sometimes used to treat breast or prostate cancer. The hormone
estrogen can make breast cancer tumors grow faster. Similarly, the hormone testosterone
can make cancerous tumors in the prostate grow faster. Drugs that contain other
hormones may be used to block the effects of estrogen and testosterone. In other cases,
surgery to remove the ovaries or the testicles may be used. Removing these organs
reduces the amount of estrogen or testosterone in the body.
Other specialized treatments may be available. Your doctor may talk to you about these
treatments if they are an option.
Source: http://familydoctor.org (http://familydoctor.org)2
Statistics
2
Source: http://familydoctor.org
Maddy Ott 4/12/2009
Sun Safety
A sunburn will fade, but damage to deeper layers of skin remains and can eventually
cause cancer. That's why sun-safe habits should begin in childhood and last a lifetime.
Eating right, being active, and maintaining a healthy weight are important ways to reduce
your risk of cancer—as well as heart disease and diabetes. Learn the American Cancer
Society's guidelines for diet and activity and find tips for a healthy lifestyle and
community.
Early Detection
If you can't prevent cancer, the next best thing you can do to protect your health is to
detect it early. Recognizing symptoms, getting regular check-ups, and performing self-
exams are just a few ways you can do this.
3
Source: www.cancer.org
Maddy Ott 4/12/2009
Bibliography
http://familydoctor.org. (n.d.).
www.cancer.gov. (n.d.).
www.cancer.org. (n.d.).
www.cancer.org. (n.d.).