BEFORE THE OFFICE OF ADMINISTRATIVE HEARINGS ) ) ) ) ) ) ) ) ) ) Applicant ABC Ambulance ( ABC ), through counsel undersigned, hereby

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1 BURCH & CRACCHIOLO, P.A. 702 East Osborn Road Phoenix, Arizona Telephone ( Bryan F. Murphy, SBA # bmurphy@bcattorneys.com James M. Stipe, SBA # jstipe@bcattorneys.com Laura J. Meyer, SBA # lmeyer@bcattorneys.com Attorneys for Applicant, ABC Ambulance BEFORE THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE, Applicant. Case No. 2012A-EMS-0101-DHS SUPPLEMENT TO REQUEST OF APPLICANT ABC AMBULANCE FOR ISSUANCE OF SUBPOENAS (Assigned to the Honorable Thomas Shedden Applicant ABC Ambulance ( ABC, through counsel undersigned, hereby supplements its Request of Applicant ABC Ambulance for Issuance of Subpoenas filed on July 27, 2012, which pleading is incorporated herein by reference, by attaching ten subpoenas duces tecum to this supplement in accordance with the court s Minute Entry No. 2 dated July 30, th DATED this 30 day of July, BURCH & CRACCHIOLO, P.A. By /s/ Bryan F. Murphy Bryan F. Murphy James M. Stipe Laura J. Meyer 702 E. Osborn Road, Suite 200 Phoenix, Arizona Attorneys for ABC Ambulance

2 COPY of the foregoing electronically filed th this 30 day of July, 2012, with: Office of Administrative Hearings 1400 West Washington, Suite 101 Phoenix, Arizona With a copy of the foregoing ed through OAH Electronic Motion Submission System this th 30 day of July, 2012, to: Honorable Thomas Shedden Administrative Law Judge Office of Administrative Hearings 1400 W. Washington Street, Suite 101 Phoenix, Arizona William Humble, Director Arizona Department of Health Services Jan.Escoto@azdhs.gov Kevin Ray (DHS Office of the Attorney General kevin.ray@azag.gov Philip R. Wooten PMT Ambulance (PMT American Ambulance (AA Comtrans Ambulance (CA Canyon State Ambulance (CSA philip.wooten@azbar.org Lawrence J. Rosenfeld Southwest Ambulance (SWA rosenfeldl@gtlaw.com Paul J. McGoldrick (RM Rural/Metro Ambulance (Maricopa paulmcgoldrick@smbattorneys.com Paul J. Roberts Life Line Ambulance randc@cableone.net Cheryl A. Smith (LLASI Life Line Ambulance Service, Inc. CSMITH@LIFELINEAZ.COM

3 Ronna L. Fickbohm (BVA Buckeye Valley Ambulance rfickbohm@tucsontrusts.com Ronna L. Fickbohn (FDSCW Fire District Sun City West rfickbohm@tucsontrusts.com Harry Eth (DHS ADHS/Bureau of Emergency Medical Services ethh@azdhs.gov Charles M. Smith (AA American Ambulance csmith@lifestar.us ginorio@starwest.us Jim Roeder American Comtrans 1501 W. Fountainhead Pkwy, Suite 650 Tempe, Arizona Thomas A. Birch (BCFD Black Canyon Fire District d/b/a Black Canyon Fire Department chief@bcvfd.org Scott Benbow (BVVRU Buckeye Valley Rural Volunteer Fire District d/b/a Buckeye Valley Volunteer Rescue Unit markalexander@cox.net Mark Nichols (DMFD Daisy Mountain Fire District 515 E. Carefree Highway PMB 385 Phoenix, Arizona David Birchfield (GBRA Gila Bend Rescue/Ambulance jcarpenter@gilabendaz.org Ray Tempe (PFD City of Phoenix d/b/a Phoenix Fire Department ray.c.temple@phoenix.gov John Valentine (RMI River Medical, Inc. John.Valentine@emsc.net - 3 -

4 Roy Royals, Director of EMS (SWA Southwest Ambulance (Maricopa Southwest Ambulance (Casa Grande, Inc. Southwest Ambulance and Rescue of Arizona roy_royals@rmetro.com Robert Biscoe (FDSC Fire District of Sun City West d/b/a Fire District of Sun City West Ambulance Service rbiscoe@scwfire.org Paul S. Wilson (SLFD Sun Lakes Fire District pwilson@slfd.org Steve Hold (TBFD Tonto Basin Fire District tbfdchief@netscape.net Neal Thomas (ABC ABC Ambulance neal@goabca.com By: /s/ Betty Bement

5 IN THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE APPELLANT. Docket No. 2012A-EMS-0101-DHS SUBPOENA (Duces Tecum Under the Authority of Arizona Revised Statutes C To: Name: Emergency Medical Transport, Inc. d/b/a/ American Ambulance Address: Philip R. Wooten Charles M. Smith (AA American Ambulance American Ambulance You are commanded to PRODUCE documents or other tangible items for the above entitled matter, specifically: SEE EXHIBIT A ATTACHED HERETO on or before August 14, 10:00 a.m. at: Burch & Cracchiolo, P.A. 702 E. Osborn Road, Suite 200 Phoenix, Arizona The Office of Administrative Hearings endeavors to ensure the accessibility of its hearings to all persons with disabilities. Should you need special accommodations please contact the Office of Administrative Hearing at ( at least three working days prior to the hearing. DATED this day of. Thomas Shedden, Administrative Law Judge AT THE REQUEST OF: Bryan F. Murphy, Esq., Attorneys for Applicant TELEPHONE NUMBER: (

6 Exhibit A 1. For all 2010 and 2011 Convalescent and Interfacility transports, as defined in R definitions 17, 35 and 52, a breakdown for each CON including the: a. Certificate of Necessity ( CON number and/or name; b. Run Number a.k.a. PMT run number; c. Vehicle Number a.k.a. Unit Shop#; d. Transport Date; e. All time fields, including but not limited to Received, Scheduled, Dispatched, Responding, and On Scene; f. ALS or BLS; g. Patient Age h. Pickup City; i. Pickup Zip Code; and j. Beginning and Ending mileage, and/or Total Mileage. This data can be transmitted on CD to save paper and printing time. Producing the data should not require any expense because the report can run from computer records in no more than an hour and with no printing expense. No HIPPA protected data is requested.

7 IN THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE APPELLANT. Docket No. 2012A-EMS-0101-DHS SUBPOENA (Duces Tecum Under the Authority of Arizona Revised Statutes C To: Name: Buckeye Valley Rural Volunteer First District d/b/a/ Buckeye Valley Volunteer Rescue Unit Address: Ronna L. Fickbohn Buckeye Valley Volunteer Rescue Unit (BVVRU You are commanded to PRODUCE documents or other tangible items for the above entitled matter, specifically: SEE EXHIBIT A ATTACHED HERETO on or before August 14, 2:00 p.m. at: Burch & Cracchiolo, P.A. 702 E. Osborn Road, Suite 200 Phoenix, Arizona The Office of Administrative Hearings endeavors to ensure the accessibility of its hearings to all persons with disabilities. Should you need special accommodations please contact the Office of Administrative Hearing at ( at least three working days prior to the hearing. DATED this day of. Thomas Shedden, Administrative Law Judge AT THE REQUEST OF: Bryan F. Murphy, Esq., Attorneys for Applicant TELEPHONE NUMBER: (

8 Exhibit A 1. For all 2010 and 2011 Convalescent and Interfacility transports, as defined in R definitions 17, 35 and 52, a breakdown for each CON including the: a. Certificate of Necessity ( CON number and/or name; b. Run number; c. Vehicle Number; d. Transport Date; e. All time fields, including but not limited to Received, Scheduled, Dispatched, Responding, and On Scene; f. ALS or BLS; g. Patient Age h. Pickup City; i. Pickup Zip Code; and j. Beginning and Ending mileage, and/or Total Mileage. This data can be transmitted on CD to save paper and printing time. Producing the data should not require any expense because the report can run from computer records in no more than an hour and with no printing expense. No HIPPA protected data is requested.

9 IN THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE APPELLANT. Docket No. 2012A-EMS-0101-DHS SUBPOENA (Duces Tecum Under the Authority of Arizona Revised Statutes C To: Name: Lifestar, L.L.C. d/b/a/ Canyon State Ambulance, d/b/a Payson Medical Transport, d/b/a/ Lifestar EMS Address: Philip R. Wooten Canyon State Ambulance (CSA You are commanded to PRODUCE documents or other tangible items for the above entitled matter, specifically: SEE EXHIBIT A ATTACHED HERETO on or before August 14, 11:00 a.m. at: Burch & Cracchiolo, P.A. 702 E. Osborn Road, Suite 200 Phoenix, Arizona The Office of Administrative Hearings endeavors to ensure the accessibility of its hearings to all persons with disabilities. Should you need special accommodations please contact the Office of Administrative Hearing at ( at least three working days prior to the hearing. DATED this day of. Thomas Shedden, Administrative Law Judge AT THE REQUEST OF: Bryan F. Murphy, Esq., Attorneys for Applicant TELEPHONE NUMBER: (

10 Exhibit A 1. For all 2010 and 2011 Convalescent and Interfacility transports, as defined in R definitions 17, 35 and 52, a breakdown for each CON including the: a. Certificate of Necessity ( CON number and/or name; b. Run number; c. Vehicle Number; d. Transport Date; e. All time fields, including but not limited to Received, Scheduled, Dispatched, Responding, and On Scene; f. ALS or BLS; g. Patient Age h. Pickup City; i. Pickup Zip Code; and j. Beginning and Ending mileage, and/or Total Mileage. This data can be transmitted on CD to save paper and printing time. Producing the data should not require any expense because the report can run from computer records in no more than an hour and with no printing expense. No HIPPA protected data is requested.

11 IN THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE APPELLANT. Docket No. 2012A-EMS-0101-DHS SUBPOENA (Duces Tecum Under the Authority of Arizona Revised Statutes C To: Name: ComTrams Ambulance Service, Inc., d/b/a/ ComTrans Ambulance Service, d/b/a/ ProMed Transport, d/b/a American ComTrans Ambulance Address: Philip R. Wooten Comtrans Ambulance (CA You are commanded to PRODUCE documents or other tangible items for the above entitled matter, specifically: SEE EXHIBIT A ATTACHED HERETO on or before August 14, 10:30 a.m. at: Burch & Cracchiolo, P.A. 702 E. Osborn Road, Suite 200 Phoenix, Arizona The Office of Administrative Hearings endeavors to ensure the accessibility of its hearings to all persons with disabilities. Should you need special accommodations please contact the Office of Administrative Hearing at ( at least three working days prior to the hearing. DATED this day of. Thomas Shedden, Administrative Law Judge AT THE REQUEST OF: Bryan F. Murphy, Esq., Attorneys for Applicant TELEPHONE NUMBER: (

12 Exhibit A 1. For all 2010 and 2011 Convalescent and Interfacility transports, as defined in R definitions 17, 35 and 52, a breakdown for each CON including the: a. Certificate of Necessity ( CON number and/or name; b. Run Number a.k.a. PMT run number; c. Vehicle Number a.k.a. Unit Shop#; d. Transport Date; e. All time fields, including but not limited to Received, Scheduled, Dispatched, Responding, and On Scene; f. ALS or BLS; g. Patient Age h. Pickup City; i. Pickup Zip Code; and j. Beginning and Ending mileage, and/or Total Mileage. This data can be transmitted on CD to save paper and printing time. Producing the data should not require any expense because the report can run from computer records in no more than an hour and with no printing expense. No HIPPA protected data is requested.

13 IN THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE APPELLANT. Docket No. 2012A-EMS-0101-DHS SUBPOENA (Duces Tecum Under the Authority of Arizona Revised Statutes C To: Name: Fire District of Sun City West d/b/a Fire District of Sun City West Ambulance Address: Ronna L. Fickbohn Fire District Sun City West (FDSCW You are commanded to PRODUCE documents or other tangible items for the above entitled matter, specifically: SEE EXHIBIT A ATTACHED HERETO on or before August 14, 2:00 p.m. at: Burch & Cracchiolo, P.A. 702 E. Osborn Road, Suite 200 Phoenix, Arizona The Office of Administrative Hearings endeavors to ensure the accessibility of its hearings to all persons with disabilities. Should you need special accommodations please contact the Office of Administrative Hearing at ( at least three working days prior to the hearing. DATED this day of. Thomas Shedden, Administrative Law Judge AT THE REQUEST OF: Bryan F. Murphy, Esq., Attorneys for Applicant TELEPHONE NUMBER: (

14 Exhibit A 1. For all 2010 and 2011 Convalescent and Interfacility transports, as defined in R definitions 17, 35 and 52, a breakdown for each CON including the: a. Certificate of Necessity ( CON number and/or name; b. Run number; c. Vehicle Number; d. Transport Date; e. All time fields, including but not limited to Received, Scheduled, Dispatched, Responding, and On Scene; f. ALS or BLS; g. Patient Age h. Pickup City; i. Pickup Zip Code; and j. Beginning and Ending mileage, and/or Total Mileage. This data can be transmitted on CD to save paper and printing time. Producing the data should not require any expense because the report can run from computer records in no more than an hour and with no printing expense. No HIPPA protected data is requested.

15 IN THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE APPELLANT. Docket No. 2012A-EMS-0101-DHS SUBPOENA (Duces Tecum Under the Authority of Arizona Revised Statutes C To: Name: Life Line Ambulance Service, Inc. Address: Paul J. Roberts Life Line Ambulance You are commanded to PRODUCE documents or other tangible items for the above entitled matter, specifically: SEE EXHIBIT A ATTACHED HERETO on or before August 14, 3:00 p.m. at: Burch & Cracchiolo, P.A. 702 E. Osborn Road, Suite 200 Phoenix, Arizona The Office of Administrative Hearings endeavors to ensure the accessibility of its hearings to all persons with disabilities. Should you need special accommodations please contact the Office of Administrative Hearing at ( at least three working days prior to the hearing. DATED this day of. Thomas Shedden, Administrative Law Judge AT THE REQUEST OF: Bryan F. Murphy, Esq., Attorneys for Applicant TELEPHONE NUMBER: (

16 Exhibit A 1. For all 2010 and 2011 Convalescent and Interfacility transports, as defined in R definitions 17, 35 and 52, a breakdown for each CON including the: a. Certificate of Necessity ( CON number and/or name; b. Run number; c. Vehicle Number; d. Transport Date; e. All time fields, including but not limited to Received, Scheduled, Dispatched, Responding, and On Scene; f. ALS or BLS; g. Patient Age h. Pickup City; i. Pickup Zip Code; and j. Beginning and Ending mileage, and/or Total Mileage. This data can be transmitted on CD to save paper and printing time. Producing the data should not require any expense because the report can run from computer records in no more than an hour and with no printing expense. No HIPPA protected data is requested.

17 IN THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE APPELLANT. Docket No. 2012A-EMS-0101-DHS SUBPOENA (Duces Tecum Under the Authority of Arizona Revised Statutes C To: Name: Professional Medical Transport, Inc. d/b/a PMT Ambulance Address: Philip R. Wooten PMT Ambulance (PMT You are commanded to PRODUCE documents or other tangible items for the above entitled matter, specifically: SEE EXHIBIT A ATTACHED HERETO on or before August 14, 9:30 a.m. at: Burch & Cracchiolo, P.A. 702 E. Osborn Road, Suite 200 Phoenix, Arizona The Office of Administrative Hearings endeavors to ensure the accessibility of its hearings to all persons with disabilities. Should you need special accommodations please contact the Office of Administrative Hearing at ( at least three working days prior to the hearing. DATED this day of. Thomas Shedden, Administrative Law Judge AT THE REQUEST OF: Bryan F. Murphy, Esq., Attorneys for Applicant TELEPHONE NUMBER: (

18 Exhibit A 1. For all 2010 and 2011 Convalescent and Interfacility transports, as defined in R definitions 17, 35 and 52, a breakdown for each CON including the: a. Certificate of Necessity ( CON number and/or name; b. Run Number a.k.a. PMT run number; c. Vehicle Number a.k.a. Unit Shop#; d. Transport Date; e. All time fields, including but not limited to Received, Scheduled, Dispatched, Responding, and On Scene; f. ALS or BLS; g. Patient Age h. Pickup City; i. Pickup Zip Code; and j. Beginning and Ending mileage, and/or Total Mileage. This data can be transmitted on CD to save paper and printing time. Producing the data should not require any expense because the report can run from computer records in no more than an hour and with no printing expense. No HIPPA protected data is requested.

19 IN THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE APPELLANT. Docket No. 2012A-EMS-0101-DHS SUBPOENA (Duces Tecum Under the Authority of Arizona Revised Statutes C To: Name: Rural/Metro (Maricopa d/b/a Rural/Metro Ambulance Service d/b/a Arizona Medical Transport d/b/a AMT Address: Paul J. McGoldrick (RM Rural/Metro Ambulance (Maricopa You are commanded to PRODUCE documents or other tangible items for the above entitled matter, specifically: SEE EXHIBIT A ATTACHED HERETO on or before August 14, 11:30 a.m. at: Burch & Cracchiolo, P.A. 702 E. Osborn Road, Suite 200 Phoenix, Arizona The Office of Administrative Hearings endeavors to ensure the accessibility of its hearings to all persons with disabilities. Should you need special accommodations please contact the Office of Administrative Hearing at ( at least three working days prior to the hearing. DATED this day of. Thomas Shedden, Administrative Law Judge AT THE REQUEST OF: Bryan F. Murphy, Esq., Attorneys for Applicant TELEPHONE NUMBER: (

20 Exhibit A 1. For all 2010 and 2011 Convalescent and Interfacility transports, as defined in R definitions 17, 35 and 52, a breakdown for each CON including the: a. Certificate of Necessity ( CON number and/or name; b. Run number; c. Vehicle Number; d. Transport Date; e. All time fields, including but not limited to Received, Scheduled, Dispatched, Responding, and On Scene; f. ALS or BLS; g. Patient Age h. Pickup City; i. Pickup Zip Code; and j. Beginning and Ending mileage, and/or Total Mileage. This data can be transmitted on CD to save paper and printing time. Producing the data should not require any expense because the report can run from computer records in no more than an hour and with no printing expense. No HIPPA protected data is requested. 2. Any and all documents, written communications, and/or records of oral communications reflecting the Arizona Department of Health Services approval or disapproval of Ambulance Revenue and Cost Reports ( ARCRs filed in the last 5 years on behalf of the aforementioned intervenors. 3. Any and all documents, written communications, and/or records of oral communications reflecting the Arizona Department of Health Services approval or disapproval of the manner and/or format in which the aforementioned intervenors completed and submitted ARCRs.

21 IN THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE APPELLANT. Docket No. 2012A-EMS-0101-DHS SUBPOENA (Duces Tecum Under the Authority of Arizona Revised Statutes C To: Name: Southwest Ambulance of Casa Grande, Inc. d/b/a Southwest Ambulance and Rescue of Arizona Address: Lawrence J. Rosenfeld Roy Ryals, Director of EMS (SWA Southwest Ambulance (SWA Southwest Ambulance (Maricopa Southwest Ambulance and Southwest Ambulance and Rescue of Arizona Rescue of Arizona You are commanded to PRODUCE documents or other tangible items for the above entitled matter, specifically: SEE EXHIBIT A ATTACHED HERETO on or before August 14, 1:30 p.m. at: Burch & Cracchiolo, P.A. 702 E. Osborn Road, Suite 200 Phoenix, Arizona The Office of Administrative Hearings endeavors to ensure the accessibility of its hearings to all persons with disabilities. Should you need special accommodations please contact the Office of Administrative Hearing at ( at least three working days prior to the hearing. DATED this day of. Thomas Shedden, Administrative Law Judge AT THE REQUEST OF: Bryan F. Murphy, Esq., Attorneys for Applicant TELEPHONE NUMBER: (

22 Exhibit A 1. For all 2010 and 2011 Convalescent and Interfacility transports, as defined in R definitions 17, 35 and 52, a breakdown for each CON including the: a. Certificate of Necessity ( CON number and/or name; b. Run number; c. Vehicle Number; d. Transport Date; e. All time fields, including but not limited to Received, Scheduled, Dispatched, Responding, and On Scene; f. ALS or BLS; g. Patient Age h. Pickup City; i. Pickup Zip Code; and j. Beginning and Ending mileage, and/or Total Mileage. This data can be transmitted on CD to save paper and printing time. Producing the data should not require any expense because the report can run from computer records in no more than an hour and with no printing expense. No HIPPA protected data is requested. 2. Any and all documents, written communications, and/or records of oral communications reflecting the Arizona Department of Health Services approval or disapproval of Ambulance Revenue and Cost Reports ( ARCRs filed in the last 5 years on behalf of the aforementioned intervenors. 3. Any and all documents, written communications, and/or records of oral communications reflecting the Arizona Department of Health Services approval or disapproval of the manner and/or format in which the aforementioned intervenors completed and submitted ARCRs.

23 IN THE OFFICE OF ADMINISTRATIVE HEARINGS IN THE MATTER OF: ABC AMBULANCE APPELLANT. Docket No. 2012A-EMS-0101-DHS SUBPOENA (Duces Tecum Under the Authority of Arizona Revised Statutes C To: Name: SW General, Inc. d/b/a Southwest Ambulance Address: Lawrence J. Rosenfeld Southwest Ambulance (SWA You are commanded to PRODUCE documents or other tangible items for the above entitled matter, specifically: SEE EXHIBIT A ATTACHED HERETO on or before August 14, 1:00 p.m. at: Burch & Cracchiolo, P.A. 702 E. Osborn Road, Suite 200 Phoenix, Arizona The Office of Administrative Hearings endeavors to ensure the accessibility of its hearings to all persons with disabilities. Should you need special accommodations please contact the Office of Administrative Hearing at ( at least three working days prior to the hearing. DATED this day of. Thomas Shedden, Administrative Law Judge AT THE REQUEST OF: Bryan F. Murphy, Esq., Attorneys for Applicant TELEPHONE NUMBER: (

24 Exhibit A 1. For all 2010 and 2011 Convalescent and Interfacility transports, as defined in R definitions 17, 35 and 52, a breakdown for each CON including the: a. Certificate of Necessity ( CON number and/or name; b. Run number; c. Vehicle Number; d. Transport Date; e. All time fields, including but not limited to Received, Scheduled, Dispatched, Responding, and On Scene; f. ALS or BLS; g. Patient Age h. Pickup City; i. Pickup Zip Code; and j. Beginning and Ending mileage, and/or Total Mileage. This data can be transmitted on CD to save paper and printing time. Producing the data should not require any expense because the report can run from computer records in no more than an hour and with no printing expense. No HIPPA protected data is requested. 2. Any and all documents, written communications, and/or records of oral communications reflecting the Arizona Department of Health Services approval or disapproval of Ambulance Revenue and Cost Reports ( ARCRs filed in the last 5 years on behalf of the aforementioned intervenors. 3. Any and all documents, written communications, and/or records of oral communications reflecting the Arizona Department of Health Services approval or disapproval of the manner and/or format in which the aforementioned intervenors completed and submitted ARCRs.

BEFORE THE OFFICE OF ADMINISTRATIVE HEARINGS ) ) ) ) ) ) ) ) ) ) ) ) ) Professional Medical Transport, Inc., dba PMT Ambulance ( PMT ), R/M Arizona

BEFORE THE OFFICE OF ADMINISTRATIVE HEARINGS ) ) ) ) ) ) ) ) ) ) ) ) ) Professional Medical Transport, Inc., dba PMT Ambulance ( PMT ), R/M Arizona Philip R. Wooten (0000 PHILIP R. WOOTEN, P.C. 1 East Equestrian Trail Phoenix, Arizona 0-0 (0-0 (0-1 (Fax Email: philip.wooten@azbar.org Attorney for PMT Ambulance, American Ambulance, Comtrans Ambulance