IN THE CIRCUIT COURT OF LEE COUNTY, MISSISSIPPI

_____________, a minor, PLAINTIFFS

by her Guardian ad litem,

_____________ and

_____________, individually

v. Cause No.:

DEFENDANTS

_____________, and

COMPLAINT

JURY TRIAL REQUESTED

Plaintiffs, _____________, a minor, by and through her Guardian ad litem, _____________, and _____________, individually, by and through their undersigned attorneys, file this Complaint against Defendants and for cause would show unto the Court the following:

A. THE PARTIES

1. Minor Plaintiff, _____________ (hereinafter “_____________”), a

citizen of the State of Mississippi, appears through her mother, natural guardian and duly appointed guardian ad litem, _____________.

2. Plaintiff, _____________, a citizen of the State of Mississippi,

appears individually and as the biological mother, natural guardian and duly appointed guardian ad litem of _____________.

3. Upon information and belief, Defendant, _____________ (hereinafter “______________________________________ corporation which, at all times relevant hereto, transacts and conducts business at ________________________________, Mississippi. _____________ may be served through its registered agent, _______________,

4. At all times relevant to this Complaint, Defendant _____________ held itself out to the public as a provider of health services, including obstetrical, nursing, neonatal care, pediatric, emergency, medical, surgical, and/or critical care services in Mississippi, and provided such services through its actual and/or apparent agents, servants and employees who, at all relevant times, acted within the scope of their agency or employment.

5. Defendant, _____________, is a resident citizen of the State of Mississippi, who may be served with process at _____________, , Mississippi 38801. At all relevant times hereto, Dr. _____________ was a duly licensed physician practicing under the laws of the State of Mississippi, who acted as the actual and/or apparent agent, servant or employee of Defendant, _____________, and/or Defendant, _____________, and did so within the scope of his agency/employment.

6. Upon information and belief, Defendant, _____________ (hereinafter “Associates”), is a professional corporation existing under the laws of the State of Mississippi with its principal place of business at, Mississippi 38801. Associates may be served through its registered agent,. _____________, at