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.

29. As a further direct and proximate cause of the negligence of the Defendants, Plaintiff, _____________, has expended and will continue to expend in the future, tremendous effort and large sums of money for the extraordinary medical and

hospital care, treatment, therapies, equipment, nursing care, rehabilitative care, custodial, attendant and other care for her child.

30. As a further direct and proximate result of the negligence of the Defendants, Plaintiff, _____________, sustained and will continue to sustain great emotional pain and suffering, mental anguish, and loss of services, filial love, companionship, comfort, protection, advice, counseling, guidance and other pecuniary loss damages.

WHEREFORE, Plaintiff, _____________ S. _____________, a minor, by and through her Guardian ad litem, _____________, sues and demands judgment against Defendants, _____________, _____________, and_______ jointly and severally, on the above and foregoing grounds, for compensatory damages in an amount in excess of $75,000.00, exclusive of interest and costs, which will be sufficient to compensate Plaintiff for her damages as described herein, all to be determined by a jury; and Plaintiff sues for punitive damages in such amount as the jury determines to be sufficient to punish Defendants for their reckless and wanton conduct described herein, to deter them from engaging in such conduct in the future, to make examples of Defendants for such conduct and deter others from engaging in the same or similar activities, and to reward Plaintiff for public service in bringing wrongdoers to justice; and for all costs of this action, together with prejudgment interest from the date of occurrence and post judgment interest.