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Marshall Dennehey Announces 2026 Shareholder Class and Special Counsel Promotions

December 15, 2025

Marshall Dennehey is pleased to announce that 16 attorneys have been elected shareholders of the firm effective Jan. 1, 2026. Additionally, two attorneys have been promoted from associate to special counsel. These new shareholders and special counsel represent the firm’s four core departments – Casualty, Professional Liability, Health Care and Workers’ Compensation – and come from 11 of the firm’s 19 offices. 

“We are delighted to welcome this outstanding class of newly elected shareholders,” said G. Mark Thompson, President & CEO of Marshall Dennehey. “Each of them has demonstrated exceptional skill, dedication, and leadership in advancing the interests of our clients and strengthening our firm. We look forward to the impact these individuals will make as leaders in our profession and contributors to our collective success.”

Promoted to Shareholder

PHILADELPHIA, PENNSYLVANIA
Holli K. Archer, Health Care Department (former Associate)
Holli defends health care practitioners, medical providers, and dental providers, against all manner of medical and dental malpractice suits. She also handles licensure matters before State Boards of Medicine, Dentistry and Nursing. She is a member of the Pennsylvania and Philadelphia Bar Associations and is recognized as a Pennsylvania Super Lawyer Rising Star and a Best Lawyers: Ones to Watch. She is a graduate of the University of Scranton and Loyola University New Orleans School of Law. Holli is admitted to practice in Pennsylvania.

Jack A. Bennardo, Jr., Casualty Department (former Associate)
Jack primarily focuses his practice on construction injury and construction defect litigation, and trucking and transportation litigation. He provides legal counsel to construction companies and contractors, commercial property owners/managers, trucking companies, amusement parks and recreational facilities, and insurance companies in Pennsylvania. Jack also handles a wide array of serious loss cases where there is often catastrophic injury or death in the areas of premises liability, product liability, construction accident, construction defect, commercial trucking, insurance coverage, and sports, amusement and entertainment litigation. He is a graduate of Fordham University and Villanova University Charles Widger School of Law and is admitted to practice in Pennsylvania and New York. 

Julianne M. Curry, Casualty Department (former Special Counsel)
Julianne has over 20 years of experience representing clients in a wide variety of high-exposure trucking, motor vehicle, construction accident, premises liability and construction defect litigation. She frequently litigates multiparty matters and has served as a certified arbitrator for the Philadelphia Court of Common Pleas. She is a graduate of Rutgers, the State University of New Jersey, and Rutgers Law School. Julianne is admitted to practice in Pennsylvania. 

KING OF PRUSSIA, PENNSYLVANIA
Michael R. Duffy, Workers’ Compensation Department (former Associate)
Michael focuses his practice on defending employers and insurance carriers in matters related to workers’ compensation. He represents employers across numerous industries including trucking, construction, landscaping, manufacturing, hospitality and long-term care. Michael is a member of the Pennsylvania Workers’ Compensation Coalition, Brehon Law Society, Philadelphia Bar Association and Judge Alexander F. Barbieri Workers’ Compensation Inn of Court. He earned his Bachelor of Arts in Political Science from Pennsylvania State University and his juris doctor from Widener University Delaware Law School. He is admitted to practice in Pennsylvania and New Jersey.

Robert A. Morton, IV, Casualty Department (former Associate)
Rob concentrates his practice in the areas of construction accident and construction defect litigation, premises liability, trucking and commercial motor carrier liability, and veterinary malpractice and licensure defense. He regularly provides legal counsel to developers, general contractors, subcontractors, and hotel operators, as well as trucking companies and a national bus company. He is a graduate of Saint Joseph’s University and Widener University School of Law and is admitted to practice in Pennsylvania and New Jersey.

PITTSBURGH, PENNSYLVANIA
Nicholas A. Cerimele, Health Care Department (former Associate)
Nicholas devotes the entirety of his practice to the defense of physicians, nurses, hospitals, physicians assistants and physician practice groups in professional liability litigation. He has more than 20 years of experience representing health care providers in medical malpractice cases. Nicholas is a graduate of Pennsylvania State University and the Thomas R. Kline School of Law of Duquesne University. He is admitted to practice in Pennsylvania. 


MOUNT LAUREL, NEW JERSEY
Brielle K. Winkler, Casualty Department (former Associate)
Brielle provides legal counsel and representation in the areas of automobile liability, underinsured/uninsured motorists claims, premises liability and condominium/community association law. Her clients include small businesses, condominium associations, large public companies and insurance carriers. Brielle also handles personal injury matters related to auto liability on behalf of retail establishments, building owners, homeowners, drivers and businesses. She is a graduate of Towson University and Rutgers Law School, and she is admitted to practice in New Jersey and Pennsylvania. 

ROSELAND, NEW JERSEY
Nataliana A. Guida, Health Care Department (former Associate)
Nataliana (Talia) devotes her practice to medical malpractice litigation, defending the interests of physicians, dentists, nurses, hospitals, and other healthcare providers and institutions. Talia is also experienced in handling licensing and disciplinary board matters. She is a graduate of Quinnipiac University and New York Law School, and is admitted to practice in New Jersey. 

PURCHASE, NEW YORK
Sanford G. Jacobs, Casualty Department (former Special Counsel)
Sanford has over 30 years of experience in trucking and transportation liability, general liability, premises liability, motor vehicle liability, construction injury litigation, product liability and toxic torts. His extensive experience includes handling cases from inception through jury trial throughout the New York Metropolitan area, upstate New York and the state of Florida. He is a graduate of the State University of New York at Oneonta and Western Michigan University Thomas M. Cooley Law School. He is admitted to practice in New York, the District of Columbia and Florida.

FORT LAUDERDALE, FLORIDA
Seth B. Altman, Professional Liability Department (former Associate)
Seth focuses his practice on representing and defending clients in insurance coverage and first-party property matters. Prior to joining Marshall Dennehey, Seth served as in-house counsel for two insurance companies where he litigated first-party property cases and was a member of the assignment of benefits and catastrophe (hurricane) divisions. Seth is also experienced in investigation, and he counseled and instructed his former claims departments in pre-suit matters. He is a graduate of the University of Florida and Albany Law School and is admitted to practice in Florida and New York. 

Holly M. Hamilton, Professional Liability Department (former Associate)
Holly focuses on a wide variety of professional liability litigation matters in state and federal court. A significant portion of her practice includes the defense of a variety of employment matters, including discrimination, harassment, and retaliation claims from the administrative (i.e., EEOC) stage through litigation. Another significant part of her practice consists of director and officer disputes in not-for-profit condominium and other community associations. She is a graduate of Florida International University and the Maurice A. Dean School of Law at Hofstra University. Holly is admitted to practice in Florida, New Jersey and New York. 

Matthew J. Wildner, Professional Liability Department (former Associate)
Matthew focuses his practice on commercial litigation, construction defect litigation and a wide variety of professional liability litigation matters. Litigating in both state and federal courts, he defends design and construction professionals independently as well as through their insurance carriers in complex construction defect suits involving a variety of claims, such as building and design-related deficiencies, code violations, negligence, breach of contract and fraud, as well as insurance coverage claims under GL policies. Matthew additionally represents condominium associations, directors, officers, and property managers in matters involving breach of fiduciary duty, violations of governing documents, and construction and maintenance obligations. He is a graduate of the University of Florida and Stetson University College of Law and is admitted to practice in Florida. 

JACKSONVILLE, FLORIDA
Kathleen A. Carlson, Casualty Department (former Associate)
Kathleen focuses her practice on automobile liability matters with an emphasis on uninsured/underinsured motorist claims. She also represents a wide array of clients in general liability matters. She is a graduate of the University of Florida and the University of Florida Levin College of Law. She is admitted to practice in Florida. 

Taylor A. Naughton, Professional Liability Department (former Associate)
Taylor focuses his practice on construction defect litigation, representing contractors, subcontractors, material suppliers, developers and design professionals when claims are made against them. He routinely counsels clients in construction disputes, handling pre-suit investigations, multi-party claims, code violations, negligence and breach of contract claims. He is a graduate of Jacksonville University and Florida Coastal School of Law. Taylor is admitted to practice in Florida. 

ORLANDO
Carolin A. Pacheco, Professional Liability (former Associate)
Carolin defends insurance carriers in first-party insurance coverage claims and complex matters pertaining to coverage and bad faith claims. She also represents condominium association boards in directors and officers suits, as well as real estate agents, brokers, and appraisers in errors and omissions claims. She also litigates FDCPA claims and suits brought by debtors against the collection services assigned to recover the debt. Carolin is a graduate of the University of Central Florida and Stetson University College of Law. She is admitted to practice in Florida. 

TAMPA, FLORIDA
Sean P. Greenwalt, Casualty Department (former Associate)
Sean focuses his practice on amusement, sports, and recreation matters as well as fraud and personal injury protection (PIP) disputes. He litigates a variety of complex matters on behalf of corporations involving premises liability, commercial auto liability, catastrophic loss, wrongful death and commercial contract disputes. He also has experience defending first-party auto coverage suits and conducting examinations under oath. Sean is a member of the Florida Defense Lawyers Association and Claims Litigation Management Alliance. A graduate of Old Dominion University and Ave Maria School of Law, he is admitted to practice in Florida. 

Associates Promoted to Special Counsel

MELVILLE, NEW YORK
Ian L. Glick, Casualty Department
Ian handles cases from inception through resolution involving New York State Labor Law, construction accidents, premises liability, product liability, auto liability, general liability and subrogation claims. He is a graduate of the University of Wisconsin and St. John’s University School of Law. Ian is admitted to practice in New York and New Jersey. 

Noriel L. Sta. Maria, M.D., Casualty Department
Noriel concentrates his practice in the areas of asbestos and toxic tort litigation. As both a physician and an attorney, he leverages his deep medical expertise to strengthen legal defenses, offering a distinct advantage in cases where medicine plays a critical role. Noriel is a graduate of the SUNY Downstate College of Medicine and obtained his juris doctor from Fordham University School of Law. He is admitted to practice in New York. 

2026 Shareholder Class

Firm Highlights

Result

No-Cause Jury Verdict Secured in Wrongful Death Trial

We successfully obtained a no-cause jury verdict in a 13-day wrongful death trial. The decedent, a 59-year-old man, was admitted to the emergency room on February 15, 2019, with complaints of abdominal pain, decreased appetite, and constipation, despite the use of laxatives. The patient did not complain of any nausea, vomiting, or diarrhea. He had a significant medical history including diabetes, hypertension, prior coronary artery stenting, morbid obesity (with past gastric bypass surgery), longstanding ventral hernia, and back pain. A CT scan revealed multiple hernias and a potential closed-loop bowel obstruction, leading to a surgery consultation. Our client, an emergency general surgeon, interpreted that the patient did not have a closed loop or any significant obstruction and recommended non-surgical management. The patient was approved to have clear liquids, and had a vomiting incident shortly after, but our client was not notified. The patient was returned to NPO status, and after improving overnight, he was returned to “clears” and additional medical and renal consults were ordered. Our client did not receive any communications from the residents/nurses of any changes in the patient’s condition. On February 18, 2019, two rapid responses were called due to increased heart rate and vomiting. It is believed that the vomiting resulted in aspiration, causing sepsis, ultimately leading to the patient’s death. During the trial, the plaintiff’s sole medical expert highlighted imaging on the wrong hernia, which called into question all of his opinions in the case. We made key objections related to the expert testimony, limiting what the allegations were, and preventing new allegations from being made. After approximately two and a half hours of deliberating, the jury returned a no-cause verdict. 

Portrait of Thomas Glassman. Text: Joining our Cincinnati Office as a Shareholder in the Casualty Department

News

Marshall Dennehey Adds Shareholder Thomas F. Glassman in Cincinnati, Expands Casualty Practice in Ohio and Kentucky

blue facade of a hospital sign against blue sky

Result

Defense Verdict in Complex Medical Malpractice Trial

News

Marshall Dennehey’s John J. Hare Brings Home Attorney of the Year Honors; Firm Named Litigation Department of the Year in Two Categories

Marshall Dennehey took home top honors in three categories at the The Legal Intelligencer’s 2026 Pennsylvania Legal Awards, held June 11 in Philadelphia. The first place awards include: Attorney of the Year: John J. Hare, Chair of the firm’s Appellate Advocacy & Post-Trial Practice Group and Executive Committee member, together with Charles “Chip” Becker of Kline & Specter Litigation Department of the Year, Appellate – Third Win in a Row! Litigation Department of the Year, Product Liability/Mass Torts “There is no one more deserving of Attorney of the Year honors than John. This award is a testament to his exceptional skill, dedication, and leadership—qualities that truly exemplify the very best of our firm,” said G. Mark Thompson, Marshall Dennehey’s President & CEO. “These honors also reflect the strength and depth of our product liability, mass torts, and appellate practices across Pennsylvania and beyond, underscoring our ongoing commitment to delivering outstanding results for our clients.” Attorney of the Year – John J. Hare, Marshall Dennehey, together with Charles “Chip” Becker, Kline & Specter Over the past year, John and Charles were opposing counsel in many of the highest-profile civil appeals in Pennsylvania. John is renowned as a preeminent appellate lawyer on the defense side, and Chip on the plaintiff's side. They have opposed each other repeatedly, exhibiting peerless professionalism and exceptional civility, while zealously litigating under the unremitting pressure of high-profile litigation and record-setting verdicts totaling more than $3.5 billion. They have also collaborated, outside of litigation, on many commissions, committees, and projects of importance to the Pennsylvania judiciary and legal community. Litigation Department of the Year – Appellate Law, Winner (previous winner, 2025 and 2024) 2025 was another standout year for the firm’s Appellate Advocacy & Post‑Trial Practice Group, led by John J. Hare, which was retained to challenge many of Pennsylvania’s “nuclear” verdicts—awards exceeding $10 million. Notably, the department persuaded the Pennsylvania Superior Court to reverse a Philadelphia judgment of $1.09 billion, the largest judgment ever overturned by a Pennsylvania appellate court. The group’s 11 full‑time Pennsylvania‑based appellate lawyers are at the center of Pennsylvania’s most high-profile matters, bringing more than 150 years of combined appellate experience. They routinely handle post‑trial and appellate matters and are frequently engaged to participate in and monitor trials in high‑exposure cases to ensure that critical legal issues are properly raised and preserved for appeal. Litigation Department of the Year – Product Liability/Mass Torts, Winner This marks the first win for the firm’s Pennsylvania Product Liability and Mass Torts practices, which operate within our Casualty Department, managed by Matthew Schorr and Jeff Rapattoni. For almost five decades, Fortune 500 product manufacturers/distributors and their insurers have turned to these groups to defend their litigation. Led by Bradley D. Remick and Vlada Tasich, our Product Liability group’s success can be attributed to its commitment to keeping abreast of ever-changing legal theories, judicial viewpoints, and evolving technology impacting the product liability landscape. Our attorneys have successfully handled thousands of product liability matters in all jurisdictions across the state. Likewise, our mass tort litigation practice – divided into Asbestos & Mass Tort, and Environmental & Toxic Tort Litigation –  has defended manufacturers, distributors, contractors, and premises owners in thousands of personal injury and other claims. Led by Kevin E. Hexstall and Patrick T. Reilly, most attorneys in these groups have more than 20 years of experience, and our seasoned trial team has tried hundreds of cases to verdict, consistently achieving strong results through both trials and settlements. In addition to these awards, Marshall Dennehey was a Litigation Department of the Year finalist for Professional Liability.

Thought Leadership

Unanimous New Jersey Supreme Court Holds That Personal Emails of Public Employees and Officials are Subject to OPRA

In Rosetti v. Ramapo-Indian Hills Regional High School Board of Education, the New Jersey Supreme Court unanimously held that government-related emails, which are contained within personal email accounts, are government records under the Open Public Records Act (OPRA), and a log of those emails must be produced when requested. In reaching this decision, the court conducted an analysis of the OPRA and cited previous cases that held that emails do in fact fall within OPRA’s definition of a record and must be produced when requested pursuant to the Act. The court in Rosetti then had to answer the question as to whether public officials’ personal email accounts that are used for government purposes are subject to OPRA, and found that they are. Rosetti made an OPRA request to the Board of Education seeking email logs from Board members’ personal email accounts. The Board refused to produce the logs and indicated that it was not under any obligation to produce personal email account logs, only from government-related email accounts. The issue was whether a log had to be produced for Board members’ personal email accounts, which they used to conduct Board business. The Board argued that while it was possible to create a log for government-related email accounts through its IT Department, it was not possible to do so for personal email accounts. The court rejected this argument and ruled that Board members are required to search their personal email accounts and create a log of government-related emails housed in those accounts. Once completed, each Board member then must submit a certification detailing the searches that were conducted. The court went one step further with a suggestion to government employees and officials, stating, “[g]overnment agencies should strongly advise their employees, elected officials, and others engaged in government-related business to refrain from using their personal email accounts when conducting government-related business.”  Please do not hesitate to contact me with any questions regarding this case and others pertaining to the OPRA. 

Thought Leadership

Perlmutter Provides Predictability for Punitive Damages Claims in Florida

In a much anticipated decision, the Florida Supreme Court provided clarity for the standards of proof for punitive damages claims in Perlmutter v. Federal Insurance Company, SC2024-0058 (Fla. June 11, 2026). Litigants and trial judges must be mindful of the standards laid out by the Court. And, defense practitioners must be prepared to alter their strategies to defend against such claims. Perlmutter came to the Court from the Fourth District, based on conflict jurisdiction with decisions from the Second and Fifth District and on certification of a question of great public importance as to the standard of proof for punitive damages claims at the pleading stage. Fed. Ins. Co. v. Perlmutter, 376 So. 3d 24, 29 (Fla. 4th DCA 2023). In the underlying case, the Fourth District made two conclusions. First, it held that a “trial court must consider the evidentiary showing by all parties at the hearing on the motion to amend, that is, evidence ‘in the record’ and evidence ‘proffered by the claimant.’”  376 So. 3d at 33. Second, the Fourth held that it “interpreted section 768.72(1) and (2) to require the trial court to make a preliminary determination of whether a reasonable jury, viewing the totality of proffered evidence in the light most favorable to the movant, could find by clear and convincing evidence that punitive damages are warranted.  Id. at 34 (underscoring in the original). In making these conclusions, the court cautioned trial courts that the “preliminary determination” analysis did not entitle the trial court to decide whether the evidence is clear and convincing and noted that the trial court should not weigh evidence and should not determine witness credibility. Id. The Florida Supreme Court accepted jurisdiction and answered the certified question in the negative. It quashed the decision below and remanded the case for application of the following standards: The trial court should consider only the evidence identified or proffered by the claimant; it should not entertain an evidentiary counter-submission from the opponent. The trial court should consider whether a reasonable person could conclude based on the claimant’s evidence, that the defendant committed “intentional misconduct” or “gross negligence” as defined in section 768.72(2) or section 768.72(3). The trial court must review the request for punitive damages in the context of the underlying claims. The trial court should not apply the clear and convincing standard of proof in reviewing the sufficiency of the evidence at the pleading stage. The trial court does not act as a fact-finder; the trial court must not weigh the claimant’s evidence—it cannot decide the truth of the matter. The trial court must consider the record evidence and the proffered evidence in the light most favorable to the plaintiff, but the allegations in the proposed amended complaint are not themselves evidence. Perlmutter, SC2024-0058 at 13-15 (emphasis added). In explaining these standards, the Court interpreted the text of the statute and compared it to a related statute which governs punitive damages in the nursing home context. The nursing home statute expressly calls for evidentiary submissions by “the parties” and expressly tells the trial court to determine whether there is a reasonable basis to believe the claimant could satisfy the “clear and convincing evidence” standard at trial. Id. at 17-18 (comparing the text of section 768.72(1), Florida Statutes, with section 400.0237, Florida Statutes). Without that express language in section 768.72, the statute could not be applied in the same manner. With these standards specially delineated for the trial courts, the Court is “confident that its interpretation of section 768.72(1) will not frustrate the effectiveness of the statute in accomplishing the Legislature’s textually evident purposes.” Id.  at 22 (cleaned up). This remains to be seen. While Perlmutter provides predictability and clarity for trial courts when reviewing the evidentiary submissions in support of a punitive damages claim, the decision will not likely impact the numbers of punitive damages motions filed. Rather, these new parameters will change the way claims are defended, reminiscent of a time when rulings on punitive damages were only subject to certiorari review and appellate courts were limited in reviewing procedural errors. This decision will likely deflate the level-playing field that Florida Rule of Appellate Procedure 9.130(a)(3)(G) addressed by allowing appeals of orders granting and denying punitive damages amendments. Further, Perlmutter may have impliedly created a call to action for the Legislature to amend section 768.72(1) in the same manner it amended section 400.0237 to allow the courts to analyze “admissible evidence submitted by the parties” and determine at a hearing whether there is a reasonable basis to believe the claimant at trial would be able to demonstrate by “clear and convincing evidence” that the recovery of punitive damages is warranted. Until then, defendants must adjust their strategies. To adapt to these new standards, defense practitioners will need to tailor their strategy for defending punitive damages claims since they can no longer submit a counter-proffer or urge a court to apply the clear and convincing standard at the pleading phase. Instead, defendants will need to attack the deficiencies in the claimant’s pleadings and proffer. If the trial court fails to serve as a gatekeeper, and does not apply the above standards, then defendants can pursue an interlocutory appeal under Rule 9.130(a)(3)(G). If a nonfinal appeal is taken, then defendants should move to stay any intrusive financial discovery while the appellate court analyzes the issues on appeal. Finally, defendants should utilize Florida Rule of Civil Procedure 1.510 to serve as a screening device to allow the trial court to analyze all evidence and prevent nonmeritorious punitive damages claims from proceeding to a jury.

News

Veteran Trial Attorney Joseph M. Toddy Joins Marshall Dennehey’s Casualty Department in Philadelphia

Result

Summary Judgment Secured, Preserving $750,000 in Coverage for Insured in Major Trucking Liability Dispute

Ray Freudiger and Michael A. Roberts (both of Cincinnati) successfully obtained summary judgment on behalf of their client in a coverage dispute arising from a May 19, 2022, motor vehicle accident. A permissive driver operated a box truck for an interstate trucking company and caused severe injuries to two tort victims. Prior to the accident, the insured had procured a commercial auto policy for the trucking company with stated limits of $1,000,000. Following the accident, the insurer initiated a declaratory judgment action asserting that only reduced bodily injury limits of $25,000/$50,000 applied and later counterclaimed, alleging it would not have insured the driver had he been properly submitted for approval under the policy. After extensive discovery, briefing, and oral argument, the court rejected the insurer’s attempt to shift responsibility for the $750,000 in coverage it was legally required to provide for permissive drivers under Ohio law, granting summary judgment in favor of the insured and preserving $750,000 in liability exposure.

Result

Unanimous Verdict Obtained in a Medical Malpractice Matter in Bergen County, New Jersey

Thought Leadership

Pennsylvania Supreme Court Holds Self-Referral Prohibition Does Not Cover Prescriptions Written by Physicians with Ownership Interests in Dispensing Pharmacies

700 Pharmacy v. Bureau of Workers’ Compensation Fee Review Hearing Office (State Workers’ Insurance Fund); Nos. 97, 98, 99, 100, 101 MAP 2024; decided June 16, 2026; by Justice Mundy.   In this case, Drs. Miteswar Purewal and Shailen Jalali, treating physicians for workers’ compensation claimants, wrote prescriptions for various medications that were filled by 700 Pharmacy. The worker’s compensation insurer refused to pay for the prescriptions on the basis that they were illegal self-referrals under the Act. 700 Pharmacy subsequently filed fee review applications with The Bureau of Workers’ Compensation Medical Fee Review Office. At a fee review hearing, both physicians stipulated they had a financial interest in the pharmacy.  The physicians argued that the Anti-Referral Provision of the Act does not bar self-referrals on prescription drugs and pharmaceutical services, since the provision does not specifically identify prescription drugs. The Fee Review Hearing Officer rejected this argument and found that prescriptions for medications are prohibited under the “goods or services” language included in the provision. 700 Pharmacy appealed to the Commonwealth Court, and the court affirmed, agreeing with the Hearing Officer’s interpretation of “goods and services” as encompassing prescriptions. 700 Pharmacy appealed to the Supreme Court.  The Supreme Court reversed the decisions of the Hearing Officer and the Commonwealth Court, holding that the term “goods and services” in the Anti-Referral Provision of the Act did not include prescriptions. According to the Court, “goods and services” was not a catch-all, but simply explanatory as to the eight enumerated categories in the provision. The provision (Section 306(f.1)(3)(iii)) reads, in pertinent part: Notwithstanding any other provision of law, it is unlawful for a provider to refer a person for laboratory, physical therapy, rehabilitation, chiropractic, radiation oncology, psychometric, home infusion therapy  or diagnostic imaging, goods or services pursuant to this section if the provider has a financial interest with the person or in the entity that receives the referral. The Court said that if the General Assembly wanted to specifically include prescription drugs and pharmaceutical services in the Anti-Referral Provision, they would have done so. They pointed out that prescription drugs and pharmaceutical services were included by the legislature in Section 306 (f.1)(3)(vi) of the Act as to reimbursement, and claimed that their omission from the Anti-Referral Provision supports the conclusion that those services are not included in the Anti-Referral Provision’s self-referral prohibition.