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…)