PRE-HEARING MEMORANDUM

This is a pre-hearing memorandum for AAA. The disability claim file presents strong evidence of
physical impairment, supported by detailed medical examination which bears preclusion to work.

INTRODUCTION

AAA is a 48 year old male who has undergone a left hip replacement in 2002 after he figured in a
vehicular accident in the 1990s.

Since the said surgical operation, AAA suffered from lower back pain radiating to his right leg. In June
2014, he was forced to quit his job as a construction worker (which he had since 2008) due to
persistent severe back pain despite seeking treatment and therapy.

The medical record contains evidence which shows severe physical impairment precluding AAA to
engage in his previous work and sustain a substantial gainful activity.

MEDICAL EVIDENCE

EXHIBIT B

AAA was examined for low back pain by Martha Pollock, M.D at Great Lakes Medical on November
18, 2014. The physician’s Consultative Examination Report indicated in Exhibit B, page 2 that the
straight leg raising test was positive on the right leg.

EXHIBIT C

The treatment record and notes of Sadiq Haque, D.O, a Sports Medicine Physician at Detroit Medical
Center are contained in Exhibits A and C.

Dr. Sadiq Haque’s extensive patient assessment on January 28, 2015 revealed that AAA has
lumbosacral spine degenerative disc disease and likely right L5 radiculopathy (Ex.C,p.2).

Exhibit C, page 1 includes a result of a CT Scan of the lumbosacral spine which demonstrated
moderate-to-severe bilateral neural foraminal stenosis at L5-S1 and at L4-5.

An X-ray Exam was also ordered and showed degenerative disc disease at L4-5 and L5-S1 (Ex.C,p.
2).

Dr. Haque’s medical notes in Exhibit C, page 2 showed moderate paraspinal tenderness on the right
as compared to the left and mild limitation in lumbar flexion and extension.The neurological exam
manifested slightly diminished sensation on the right as compared to the left. A special test conducted
showed positive straight leg test on the right as compared to the left.

The Final Report of the RIM (Ex.C,p.4) on the Spine-Lumbar (AP-Lateral view) performed and verified
by Cheryl Grigorian M.D on June 28 and 29, 2015, respectively, contained the following findings: “Disc
space narrowing at L3-L4-L4-L5 and L5-S1. Anterior listhesis of L5 01-01 likely on a degenerative
basis. Facet hyperthropic changes to the lower lumbar spine. Minimal scoliosis.”

On the other hand, Dr. Grigorian made the following impression on the RIM of the Hip: “Mild
degenerative changes to the right hip especially superiorly compatible with osteoarthritis.” (Ex.C page
6).

In a scheduled follow up on June 22, 2015, Dr. Haque carried out lumbar epidural steroid injections
(Ex. C,p.4) due to complains of low back pain despite physical therapy and intake of prescribed oral
medications.

Exhibit C, page 16 contains the patient evaluation made by Dr. Haque on March 25, 2015. AAA claims
he did not find much relief with the last epidural steroid injection. In his report, Dr. Haque made the
following observations: “Right-sided paraspinal tenderness” upon palpation; “Lumbar . . . extension is
limited”; and “Mildly positive straight-leg raise test.” Dr. Haque’s assessment showed “lumbar sacral
spine degenerative disc disease” and “right lumbar radiculopathy”.
EXHIBIT A

Dr. Sadiq Haque throughly completed a Lumbar Spine Medical Statement in an Attorney/
Representative Supplied Form. In Exhibit A, page 1, he made the diagnosis of “lumbar disc disease;
right LS radiculopathy”.

Dr. Haque further expects AAA’s impairments to have lasted or to last at least 12 months. He noted
that his patient’s symptoms include low back to right leg pain, that becomes worse with prolonged
walking and standing. (Ex.A, p.1) He also noted the following: positive sensory loss, tenderness,
muscle spasm, motor loss and muscle weakness. The positive supine straight leg raising test was 30
degrees at Right and the positive seated straight leg raising test was also 30 degrees at Right.
(Ex.A,p.2)

In Exhibit A, page 2, Dr. Haque’s made an estimation of AAA’s functional limitations if the latter were
placed in a competitive work situation. He noted that AAA can sit or stand at one time for around 30
minutes only.

For physical limitations, Dr. Haque indicated in Exhibit A, page 3, that in an 8-hour working day, AAA
can sit for about 2 hours and stand/walk for about 2 hours total with normal breaks. He assessed that
his patient needs to include periods of walking around every 30 minutes for about 5 minutes each time
during an 8-hour working day. He also estimates that unscheduled breaks during the working day may
happen every 2 hours. In addition, Dr. Haque noted that his patient must use a cane or other assistive
device during occasional standing or walking.

Dr. Haque assessed limitations of carrying 10 lbs. only occasionally (6%-33%), 20 lbs. rarely (1%-5%),
and 50 lbs. never. He noted that patient can rarely stoop and twist. (Ex.A,p.4).

Dr. Haque assessed in Exhibit A, page 5, that the patient’s impairments are reasonably consistent with
the symptoms and functional limitations described in the evaluation.

PREPARED BY:

ATTY. JACQUELINE LEONCIA M. ALIÑO

Telephone No.: (02) 771-2551
Mobile No.: 09054953663
Email: jacquelinealino@gmail.com