PENNSYLVANIA RECORD

PHILADELPHIA - A Delaware County hospital worker says that the failure by the providers of a mobile

medical vehicle to keep the trailer properly maintained was directly responsible for the injuries she sustained when she fell from the trailer, according to a personal injury lawsuit filed at the U.S. District Court for the Eastern District of Pennsylvania.

Tracie Levin, of Williamstown, N.J., seeks punitive and compensatory damages in excess of $150,000 for one count of negligence against Medicoach Transportation, headquartered in Massachusetts. Levin's husband, Michael, also seeks damages for loss of consortium with his wife.

According to the complaint, Levin was working in the trailer parked at Delaware County Memorial Hospital in Drexel Hill on March 26 when she attempted to leave the vehicle. She attempted several times to push open the jammed door before it suddenly opened, causing Levin to slip on steps outside the door and fall to the ground.

The claim says that Levin sustained serious injuries from the fall, especially to her back and left shoulder. She also experienced lingering aches, mental anxiety and anguish and ongoing pain and suffering that has limited her ability to perform her daily duties, he complaint says.

The plaintiff says her earning capacity has been significantly reduced while medical expenses have climber during her rehabilitation process.

Levin holds Medicoach responsible for the incident, saying the company's employees failed to regularly inspect the trailer and ensure that it was free from potentially dangerous defects that could harm third party users, such as door jams. The complaint says that Medicoach was also responsible for keeping the stairs clear of ice and snow and should have pre-treated the steps before snow fell.

The plaintiffs are represented by Brandon Swartz of Swartz Culleton, PC in Newtown, Pa.

The federal case ID is 2:15-cv-00029-SD.