Cerebral Palsy Complants (3/3)

June 24th, 2008

31. Defendants, _____________, directly and through its

actual and apparent agents, servants and/or employees, including, but not limited to the nurses and house officer who cared for the minor Plaintiff, violated their duty and were negligent in the following ways, among others:

A. They failed to properly assess the condition of the infant; B. They failed to recognize and appreciate the signs and Read the rest of this entry »

Cerebral Palsy Complant (2/3)

June 24th, 2008

rate was in the 160’s and his respiratory rate was in the 80’s. _____________’s extremities were rigid and he was grunting on respiration. Despite these findings, no physician was called to evaluate _____________ at this time, thus no medical evaluation was done and no diagnostic studies were ordered.

16. At 9:00 a.m., _____________ was noted to continue to cry inconsolably.

Defendant Dr. _____________ was updated concerning _____________’s condition but simply ordered saline drops for congestion instead of any diagnostic studies.

17. Dr. _____________ circumcised _____________ at about 9:30 a.m. Thereafter, Dr.

_____________ performed a discharge examination of _____________, determined he had a normal exam and wrote orders for _____________ to be discharged at 48 hours of age. Read the rest of this entry »

Cerebral Palsy Complant (1/3)

June 24th, 2008

IN THE COURT OF COMMON PLEAS

MIAMI COUNTY, OHIO

_____________ a minor *

by his parents and next friends

_____________ *

* COMPLAINT

and *

_____________ *

*

and *

_____________, Individually * JURY DEMAND ENDORSED

* Read the rest of this entry »

Cerebral Palsy Mississippi Complaint (4/4)

March 7th, 2008

D. NEGLIGENCE

(ON BEHALF OF _____________)

28. Plaintiffs incorporate herein by reference thereto the averments contained in paragraphs 1-27 as though same were fully set forth herein. Read the rest of this entry »

Cerebral Palsy Mississippi Complaint (3/4)

March 7th, 2008

C. NEGLIGENCE

(ON BEHALF OF _____________)

20. Plaintiffs incorporate herein by reference thereto the averments contained in paragraphs 1-19 as though same were fully set forth herein. Read the rest of this entry »

Cerebral Palsy Mississippi complaint (2/4)

March 7th, 2008

B. STATEMENT OF FACTS GIVING RISE

TO PLAINTIFFS’ CAUSE OF ACTION

8. Sometime during the month of September and/or October _____________ became pregnant with her first child, _____________, with an estimated delivery date of ___________________ Read the rest of this entry »

Cerebral Palsy Mississippi complaint (1/4)

March 7th, 2008

IN THE CIRCUIT COURT OF LEE COUNTY, MISSISSIPPI

_____________, a minor, PLAINTIFFS

by her Guardian ad litem,

_____________ and

_____________, individually

v. Cause No.:

DEFENDANTS

_____________, and

Read the rest of this entry »

CP complaint from Ohio (4/4)

February 21st, 2008

COUNT TWO - UNCONSTITUTIONALITY OF CIVIL RULE 10

31. Plaintiff incorporates the allegations set forth in paragraphs one through 30 of this Complaint as though fully set forth herein, and states further that the requirements of Civil Rule 10, as amended, effective July 5, 2005, are unconstitutional and are in violation of the Ohio and Federal Constitutions on the basis of equal protection under the law and due process, and impose an undue burden on the class of plaintiffs bringing medical claims in the State of Ohio. Read the rest of this entry »

CP complaint from Ohio (3/4)

February 21st, 2008

COUNT ONE - NEGLIGENCE

24. Plaintiff incorporates by reference herein all of the facts and

allegations contained in paragraphs one through 23 of the Complaint as if fully set forth herein and further allege as follows: Read the rest of this entry »

CP complaint from Ohio (2/4)

February 21st, 2008

FACTUAL BACKGROUND

8. On or about _________________________ presented to the _________________________ when she was approximately eight weeks pregnant. Blood taken for testing that visit indicated that _________________________’s blood was type O, Rh negative. The significance of this finding was that if her baby’s blood was Rh positive, she would be making antibodies to her own baby, which could be problematic for the baby and for any future pregnancies. Read the rest of this entry »