NEGLIGENCE

34. Defendants, directly and through their actual and apparent agents, servants and employees, are guilty of the following acts of omission, each of the acts alone or in combination were the proximate cause of _________________’s severe and permanent neurological impairment and damages resulting therefrom. Specifically, Defendant _________________’s, negligent acts are as follows: (more…)

15. _________________ was then notified of the variables at 1343. The nurses administered oxygen and repositioned _________________ on her left side apparently in an effort to improve the tracing.

16. Nonetheless, the variable decelerations reoccurred until 1507 when _________________ labor had progressed to 9cm and zero station. (more…)

CAUSE NO.

_________________ and * IN THE DISTRICT COURT OF

____________________

Individually, and as next friends of * LUBBOCK COUNTY, TEXAS

_________________, a minor child

* 99^th JUDICIAL DISTRICT

Plaintiffs

*

v.

*

_________________

*

and

*

_________________

and

_________________

d/b/a __________________

_______________________ *

Defendants *

* * * * * * * * * * * * * (more…)

DAMAGES

29. As a direct and proximate result of the Defendants’ negligence, directly and through its actual and apparent agents, servants and employees, Plaintiffs have suffered serious, severe, and permanent damage. ___________ has experienced physical pain, mental anguish, physical impairment, physical disfigurement and will, in reasonable probability, suffer from the same in the future. (more…)

15. Upon information and belief, initially, Twin B (Baby ____), demonstrated a few variable decelerations on the fetal heart monitor. Thereafter, the tracing was non reassuring with recurrent decelerations, decreased variability and tachycardia which the nurses apparently did not recognize.

16. Despite the medications, Ms. ___________ continued to contract every 3-4 minutes. (more…)

CAUSE NO. ________

____________ and * IN THE DISTRICT COURT OF

___________

Individually, and as next friends of *

___________, a minor child

* ________ COUNTY, TEXAS

Plaintiffs

*

v.

* JUDICIAL DISTRICT ____

*

_____________

*

*

Defendants

* * * * * * * * * * * * *

PLAINTIFFS’ AMENDED PETITION

COME NOW Plaintiffs, ___________ and ___________, Individually, and as next friends of ___________, a minor child, herein referred to as Plaintiffs, complaining of __________________and__________________ Defendants, and file this Amended Petition under Texas Rules of Civil Procedure 190.4 (Level 3), and for cause of action would respectfully show the Court as follows: (more…)