IN THE COURT OF COMMON PLEAS

MARION COUNTY, OHIO

_________________________, a minor*

by his mother and next friend,

_________________________ * COMPLAINT

_________________________

_________________________ *

Plaintiff * CASE NO.

v. *

(Jury Demand Endorsed –

_________________________ * Attached)

_________________________

_________________________ *

_________________________

*

and

*

_________________________

Serve on Resident Agent: *

________________________

________________________ *

________________________

*

Defendants

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

Plaintiff, _________________________, a minor, by and through his mother and next friend, _________________________, complaining of the Defendants, avers as follows:

1. The minor Plaintiff, _________________________, was born on _____________, at ____________________________________ in , Ohio.

2. _________________________ is the natural mother of _________________________ and is a resident of Franklin County, Ohio.

3. Defendant, _________________________, M.D., is, and at all times pertinent to this action was, a licensed physician in the State of Ohio holding himself out to the public,

including the Plaintiff, as being a physician trained and able, competent and qualified to provide safe and proper obstetrical care and treatment to his patients.

4. At all times pertinent to this action, Defendant, _________________________, was the actual and/or apparent agent, servant or employee of the _________________________ acting within the scope of his employment or agency when he provided care to Plaintiff.

5. Defendant, _________________________, is liable for all damages proximately caused by his acts or omissions during the course of his care and treatment to the Plaintiff.

6. At all times pertinent to this action, Defendant, _________________________ held itself out to the public as a health care organization providing obstetrical medical and nursing services, whose actual and/or apparent agents, servants and/or employees possessed that degree of skill, expertise, knowledge and ability ordinarily possessed by reasonably prudent and competent like health care providers and who were acting within the scope of their agency and/or employment when providing care and treatment to the Plaintiff.