28. _________________’ Apgar scores were 2, 4, and 6 at 1, 5, and 10 minutes respectively (a zero to ten scale of fetal well being). He was acidotic at birth, developed seizures, and required a gastostomy tube for feeding. _________________ suffered an anoxic injury shortly before birth as a result of the delay in timely accomplishing his delivery.

29. The damages and injuries to Plaintiff _________________ were directly caused or were directly contributed to be caused as a result of the carelessness and negligence, faults, and omission of Defendant _________________, in one, more, or all of the following particulars, to wit:

(a) Defendant negligently and carelessly failed to properly manage Mrs. _________________’ pre-eclampsia;

(b) Defendant negligently and carelessly failed to properly manage Mrs. _________________’ elevated blood pressure;

(c) Defendant negligently and carelessly failed to perform adequate antenatal testing on Mrs. _________________ and her unborn child;

(d) Defendant negligently and carelessly failed to properly monitor Mrs. _________________ and her unborn child;

(e) Defendant negligently and carelessly failed to perform a timely biophysical profile;

(f) Defendant negligently and carelessly failed to timely and adequately respond to the abnormal findings observed on January 30, 2005;

(g) Defendant negligently and carelessly failed to timely and appropriately delivery _________________;

(h) Defendant negligently and carelessly failed to perform a timely cesarean section;

(i) Defendant negligently and carelessly failed to accurately and adequately respond to abnormalities in the fetal heart tracings;

(j) Defendant negligently and carelessly failed to perform adequate fetal monitoring;

(k) Defendant negligently and carelessly failed to perform and measure up to the requisite standard of due care and skill required and observed by licensed physicians and in further particulars presently unknown to Plaintiffs, but which is verily believed and alleged will be disclosed upon proper discovery procedures in the course of this litigation.

30. The damages and injuries to Plaintiff _________________ were directly caused or were directly contributed to be caused as a result of the carelessness and negligence, faults, and omission of Defendant _________________, in one, more, or all of the following particulars, to wit:

(a) Defendant negligently and carelessly failed to properly manage Mrs. _________________’ pre-eclampsia;

(b) Defendant negligently and carelessly failed to properly manage Mrs. _________________’ elevated blood pressure;

(c) Defendant negligently and carelessly failed to perform adequate antenatal testing on Mrs. _________________ and her unborn child;

(d) Defendant negligently and carelessly failed to properly monitor Mrs. _________________ and her unborn child;

(e) Defendant negligently and carelessly failed to perform a timely biophysical profile;

(f) Defendant negligently and carelessly failed to timely and adequately respond to the abnormal findings observed on January 30, 2005;

(g) Defendant negligently and carelessly failed to timely and appropriately delivery _________________;

(h) Defendant negligently and carelessly failed to perform a timely caesarean section;

(i) Defendant negligently and carelessly failed to accurately and adequately respond to abnormalities in the fetal heart tracings;

(j) Defendant negligently and carelessly failed to perform adequate fetal monitoring;

(k) Defendant negligently and carelessly failed to perform and measure up to the requisite standard of due care and skill required and observed by licensed physicians and in further particulars presently unknown to Plaintiffs, but which is verily believed and alleged will be disclosed upon proper discovery procedures in the course of this litigation.

31. The damages and injuries to Plaintiff _________________ were directly caused or were directly contributed to be caused as a result of the carelessness and negligence, faults, and omission of Defendant _________________, in one, more, or all of the following particulars, to wit:

(a) Defendant negligently and carelessly failed to properly manage Mrs. _________________’ pre-eclampsia;

(b) Defendant negligently and carelessly failed to properly manage Mrs. _________________’ elevated blood pressure;

(c) Defendant negligently and carelessly failed to perform adequate antenatal testing on Mrs. _________________ and her unborn child;

(d) Defendant negligently and carelessly failed to properly monitor Mrs. _________________ and her unborn child;

(e) Defendant negligently and carelessly failed to perform a timely biophysical profile;

(f) Defendant negligently and carelessly failed to timely and adequately respond to the abnormal findings observed on January 30, 2005;

(g) Defendant negligently and carelessly failed to timely and appropriately delivery _________________;

(h) Defendant negligently and carelessly failed to perform a timely caesarean section;

(i) Defendant negligently and carelessly failed to accurately and adequately respond to abnormalities in the fetal heart tracings;

(j) Defendant negligently and carelessly failed to perform adequate fetal monitoring;

(k) Defendant negligently and carelessly failed to perform and measure up to the requisite standard of due care and skill required and observed by licensed physicians and in further particulars presently unknown to Plaintiffs, but which is verily believed and alleged will be disclosed upon proper discovery procedures in the course of this litigation.

32. The damages and injuries to Plaintiff _________________ were directly caused or were directly contributed to be caused as a result of the carelessness and negligence, faults, and omission of Defendant _________________, in one, more, or all of the following particulars, to wit:

(a) Defendant negligently and carelessly failed to properly manage Mrs. _________________’ pre-eclampsia;

(b) Defendant negligently and carelessly failed to properly manage Mrs. _________________’ elevated blood pressure;

(c) Defendant negligently and carelessly failed to perform adequate antenatal testing on Mrs. _________________ and her unborn child;

(d) Defendant negligently and carelessly failed to properly monitor Mrs. _________________ and her unborn child;

(e) Defendant negligently and carelessly failed to perform a timely biophysical profile;

(f) Defendant negligently and carelessly failed to timely and adequately respond to the abnormal findings observed on January 30, 2005;

(g) Defendant negligently and carelessly failed to timely and appropriately delivery _________________;

(h) Defendant negligently and carelessly failed to perform a timely caesarean section;

(i) Defendant negligently and carelessly failed to accurately and adequately respond to abnormalities in the fetal heart tracings;

(j) Defendant negligently and carelessly failed to perform adequate fetal monitoring;

(k) Defendant negligently and carelessly failed to perform and measure up to the requisite standard of due care and skill required and observed by licensed physicians and in further particulars presently unknown to Plaintiffs, but which is verily believed and alleged will be disclosed upon proper discovery procedures in the course of this litigation.

COUNT I

COME NOW _________________ and _________________, parents and next friends of Plaintiff _________________, and state and aver as follows:

33. Plaintiffs reassert and reallege paragraphs 1 through 32 above as fully set forth herein.

34. As a direct and proximate result of the negligence and carelessness of one, more or all of Defendants as stated herein, Plaintiff _________________ is permanently brain damaged and will forever need rehabilitation, therapies, nursing, attendant and other care, and substantial amounts of future medical care from age 18 onward.

35. Plaintiff _________________ has incurred substantial pain and suffering in the past and will continue to do so in the future.

36. Plaintiff _________________ has lost enjoyment of life in the past and will continue to do so in the future.

37. Plaintiff _________________ will lose a lifetime’s worth of wages due to his brain damage and incapacity.

WHEREFORE, _________________ and _________________, as parents and next friends of Plaintiff _________________, request judgment against Defendants, and each of them jointly and severally, in such sums as will reasonably and fairly compensate _________________ for his damages incurred, with his costs incurred herein, in excess of Twenty Five Thousand Dollars ($25,000.00), and for such other and further relief as the Court deems just and proper.

COUNT II

COME NOW, Plaintiffs _________________ and _________________, Individually, and state and aver as follows:

38. Plaintiffs _________________ and _________________ were at all times concerned herein the guardians and parents of _________________.

39. Plaintiffs reassert and reallege paragraphs 1 through 37 above as fully set forth herein.

40. As a direct and proximate result of the negligence of one, more or all of Defendants as aforesaid, Plaintiffs have lost consortium, companionship, and services of their child, _________________, in the past and will continue to do so in the future.

41. As a direct and proximate result of the brain damage of their son, Plaintiffs _________________ and _________________ are responsible from birth up and until age 18 for the medical bills for physicians, hospitals, therapies, nursing and attendant care, and other medical bills in the past, and will continue to do so until their son’s 18^th birthday.

WHEREFORE, Plaintiffs _________________ and _________________, Individually, request judgment against Defendants, and each of them, jointly and severally, in such sum which will reasonably and fairly compensate them for their damages incurred, with their costs incurred herein, in excess of Twenty-Five Thousand Dollars ($25,000.00), and for such other and further relief as the Court deems just and proper.

BLEY & PFEIFFER, P.C.

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