Example Cerebral Palsy Complaint in Pennsylvania Part 2 of 8

71. On June 20, 2017, at approximately 1:48 p.m., Ms. Plaintiff arrived at the maternal-fetal medicine clinic at the Apple Hill Medical Campus. A non-stress test and ultrasound was performed by nurse/technician Elizabeth A. Koller.
72. The non-stress test fetal heart strip showed multiple variable decelerations in both twin A and twin B consistent with severe utero-placental insufficiency. The fetal heart rate for twin B was non-reactive.
73. Twin B on the June 20, 2017, non-stress test was Baby Plaintiff.
74. At approximately 2:06 p.m., the nurse/technician Elizabeth A. Koller ceased fetal heart monitoring and told Ms. Plaintiff to drive herself to Stoneleigh Hospital rather than arrange for an ambulance to transport Ms. Plaintiff to the hospital more quickly.
75. Nurse/technician Elizabeth A. Koller, who was also an employee/agent of Defendant GoodLife Medical Group, t/d/b/a GoodLife Maternal-Fetal Medicine, Defendant GoodLife Health, and Defendant Stoneleigh Hospital, called Resident C and the charge nurse at Stoneleigh hospital and notified them of the tracing findings and the potential need for delivery based upon the tracings.
76. Ms. Plaintiff arrived at Stoneleigh Hospital at 2:25 p.m. and was admitted to labor and delivery.
77. Ms. Plaintiff was placed on the fetal heart monitor at 2:31 p.m. by nurse M. Nurse M and the other employees/agents/ostensible agents of Stoneleigh Hospital failed to appreciate that the fetal heart strips showed a category III strip and that the twins were suffering from hypoxia requiring immediate delivery.
78. At approximately 2:38 p.m., resident physician Dr. C arrived in Ms. Plaintiff’s room. Dr. C was a resident at Stoneleigh Hospital and at all times relevant hereto was being supervised by Defendant obstetrician Dr. N.
79. Dr. C and the other employees/agents/ostensible agents of Stoneleigh Hospital failed to appreciate that the fetal heart strips showed a category III strip and that the twins were suffering from hypoxia requiring immediate delivery.
80. Instead, Dr. C attempted to perform a bedside ultrasound that showed twin A’s heart rate dropping to 40-50 beats per minute when this information was already available via the fetal heart strips.
81. For purposes of this Complaint, twin A on the ultrasound at Stoneleigh Hospital on June 20, 2017 was the same baby (Baby Plaintiff) as twin B experiencing decelerations earlier in the day at the maternal-fetal medicine clinic.
82. A stat cesarean section was ordered at 2:50pm.
83. Both twins were delivered by Dr. N at 2:57pm.
84. Upon delivery, Baby Plaintiff was noted to be limp, pale, with barely perceptible heart rate. She was suctioned and stimulated but there were no spontaneous breathing movements. As a result, she was resuscitated and intubated with a 2.5 endotracheal tube. She was immediately taken to the neonatal intensive care unit.
85. Baby Plaintiff was born with APGAR scores of 3, 5, and 6, at one, five, and ten minutes respectively. She weighed 1,696 grams, which was in the fourth percentile for gestational age.
86. Baby’s initial blood gases showed severe metabolic acidosis as a result of severe hypoxia. Her PH was 6.8 and her base excess was –
87. Baby was diagnosed with perinatal asphyxia with significant metabolic acidosis and hypoxic ischemic encephalopathy. Her initial EEG on June 26, 2018, show diffuse cortical suppression, which persisted on follow up EEG on July 5, 2017, which also showed rare sharp EEG transients over the right central temporal region. Her brain MRI on July 5, 2017, showed extensive injury representative of severe hypoxic ischemic encephalopathy and permanent brain injury.
88. Throughout her hospital course, Baby continued to have severe motor deficits in addition to no gag reflex and decreased tone. She ultimately ended up needing a feeding tube inserted because of the extent of her neurological injuries.
89. Baby was discharged form Stoneleigh Hospital on July 15, 20
90. Baby currently has a severe and permanent brain injury as a result of hypoxic ischemic encephalopathy. She has substantial motor deficits and cognitive impairment. She sees many doctors on a regular basis, including neurologists, physical therapists, occupational therapists, feeding specialists, and pediatricians, among many others. She will require extensive medical care and assistance for the rest of her life.
91. Her injuries will prevent her from ever seeking gainful employment. She will also never be able to live independently and will require extensive assistance for the rest of her life.
92. Had Ms. Plaintiff been kept and continuously monitored at Stoneleigh Hospital on June 18, 2017, the nurses and physicians would have discovered and responded to her twin’s (including Baby Plaintiff’) utero-placental insufficiency and other complications by delivering her twins in time to prevent any injury, including any permanent hypoxic injury.
93. Alternatively, had a cesarean section been performed on June 18, 2017, Ms. Plaintiff’s twins (including Baby Plaintiff) would not have suffered any injury, including any permanent hypoxic injury.
94. Had a cesarean section been timely performed on June 20, 2017, when Ms. Plaintiff’s twins were suffering hypoxia, the twins (including Baby Plaintiff) would not have suffered any injury, including any permanent hypoxic injury.

COUNT I: NEGLIGENCE – MEDICAL MALPRACTICE

Mother Plaintiff and Father Plaintiff, Individually, as Parents and
Natural Guardians of Baby Plaintiff, a Minor,
v.
James L. A, D.O.

95. Plaintiff incorporates paragraphs 1-93 above herein by reference and in additional avers:
96. Defendant Dr. A owed a duty imposed by the common law of the Commonwealth of Pennsylvania to skillfully, prudently, and properly diagnose, care, treat, advise, and observe Mother Plaintiff and her unborn twins in such a manner as would a reasonable and prudent physician specializing in obstetrics, gynecology, and maternal-fetal medicine confronted by similar conditions and circumstances treating patients with medical conditions similar to Mother Plaintiff.
97. That at all times relevant to the claims at bar, the standard of medical care applicable to Dr. A for the treatment of Mother Plaintiff and her unborn twins (including Baby Plaintiff)
    included, but was not limited to: 1) properly monitoring, assessing, interpreting, and documenting Ms. Plaintiff’s twins’ fetal heart rates when he saw her at Stoneleigh Hospital on June 16, 2017 until June 18, 2017; 2) properly assessing and evaluating the risk of pregnancy complications for a twin pregnancy with monochorionic diamniotic twins when he saw Ms. Plaintiff at Stoneleigh Hospital on June 16, 2017 until June 18, 2017; 3) properly monitoring, assessing, and evaluating Mother Plaintiff’s twin pregnancy for complications when he saw her on June 16, 2017 until June 18, 2017; 4) properly and timely recognizing that Mother Plaintiff and her twins were suffering from utero-placental insufficiency on June 16, 2017 until June 18, 2017; 5) properly and timely recognizing that Mother Plaintiff’s twins were suffering from IUGR on June 16, 2017 until June 18, 2017; 6) properly and timely recognizing that Mother Plaintiff’s twins were suffering from gestational hypertension on June 16, 2017 until June 18, 2017; 7) properly and timely assessing the risk of harm to Mother Plaintiff’s twins when she was approximately 34 weeks pregnant with monochorionic diamniotic twins and her twins were suffering from IUGR, gestational hypertension, utero-placental insufficiency on June 16, 2017 until June 18, 2017; 8) refraining from discharging Mother Plaintiff from Stoneleigh Hospital on June 18, 2017 when she was approximately 34 weeks pregnant with monochorionic diamniotic twins and when her twins were suffering from IUGR, gestational hypertension, and utero-placental insufficiency; 9) keeping Mother Plaintiff at Stoneleigh Hospital for continuous monitoring of her twins until their delivery rather than discharging her from the hospital on June 18, 2017; 10) alternatively, timely and appropriately delivering Mother Plaintiff’s twins on June 18, 2017 via cesarean section; 11) properly and timely recognizing, appreciating, and responding to the signs and symptoms of utero-placental insufficiency experienced by Mother Plaintiff’s twins, including abnormalities seen on a fetal heart strips such as late decelerations and periods of non-reactivity when Dr. A saw her on June 16, 2017 until June 18, 2017; 12) recognizing and appreciating the risk of permanent injury to Ms. Plaintiff’s twins if Ms. Plaintiff was discharged from Stoneleigh Hospital on June 18, 2017 while her twins were suffering from IUGR, gestation hypertension, and utero-placental insufficiency; and 13) properly administering to Ms. Plaintiff the correct and complete dosage of Betamethasone on June 18, 2017 in anticipation of early delivery and to assist with lung development and utero-placental insufficiency.
98. Dr. A breached the applicable standard of medical care owed to Mother Plaintiff and her unborn twins from June 16, 2017 until June 18, 20 These breaches included, but were not limited to: 1) failing to properly monitor, assess, interpret, and document Ms. Plaintiff’s twins’ fetal heart rates when he saw her at Stoneleigh Hospital on June 16, 2017 until June 18, 2017; 2) failing to properly assess and evaluate the risk of pregnancy complications for a twin pregnancy with monochorionic diamniotic twins when he saw Ms. Plaintiff at Stoneleigh Hospital on June 16, 2017 until June 18, 2017; 3) failing to properly monitor, assess, and evaluate Mother Plaintiff’s twin pregnancy for complications when he saw her on June 16, 2017 until June 18, 2017; 4) failing to properly and timely recognize that Mother Plaintiff and her twins were suffering from utero-placental insufficiency on June 16, 2017 until June 18, 2017; 5) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from IUGR on June 16, 2017 until June 18, 2017; 6) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from gestational hypertension on June 16, 2017 until June 18, 2017; 7) failing to properly and timely assess the risk of harm to Mother Plaintiff’s twins when she was approximately 34 weeks pregnant with monochorionic diamniotic twins and her twins were suffering from IUGR, gestational hypertension, utero-placental insufficiency on June 16, 2017 until June 18, 2017; 8) discharging Mother Plaintiff from Stoneleigh Hospital on June 18, 2017 when she was approximately 34 weeks pregnant with monochorionic diamniotic twins and when her twins were suffering from IUGR, gestational hypertension, and utero-placental insufficiency; 9) failing to keep Mother Plaintiff at Stoneleigh Hospital for continuous monitoring of her twins until their delivery rather than discharging her from the hospital on June 18, 2017; 10) alternatively, failing to timely and appropriately deliver Mother Plaintiff’s twins on June 18, 2017 via cesarean section; 11) failing to properly and timely recognize, appreciate, and respond to the signs and symptoms of utero-placental insufficiency experienced by Mother Plaintiff’s twins, including abnormalities seen on a fetal heart strips such as late decelerations and periods of non-reactivity when Dr. A saw her on June 16, 2017 until June 18, 2017; 12) failing to recognize and appreciate the risk of permanent injury to Ms. Plaintiff’s twins if Ms. Plaintiff was discharged from Stoneleigh Hospital on June 18, 2017 while her twins were suffering from IUGR, gestation hypertension, and utero-placental insufficiency; and 13) failing to properly administer to Ms. Plaintiff the correct and complete dosage of Betamethasone on June 18, 2017 in anticipation of early delivery and to assist with lung development and utero-placental insufficiency.
99. As a direct and proximate result of Dr. A’s negligence and breaches of the applicable standards of medical care, Baby Plaintiff suffered a severe and permanent physical injury, including but not limited to, oxygen deprivation, severe hypoxia, severe metabolic acidosis, permanent brain injury, respiratory distress, neurological impairment, gastrointestinal impairment, and multi-system organ failure.
100. As a direct and proximate result of the negligence of the Defendant Dr. A, Baby Plaintiff suffered mental and physical pain and suffering, inconvenience, humiliation, embarrassment, loss of life’s enjoyment and pleasures, and the damages that discovery will show are appropriate under the laws of the Commonwealth of Pennsylvania.
101. Baby Plaintiff’ medical expenses to date total approximately $100, Baby Plaintiff has incurred and will incur past medical expenses; past pain and suffering; future costs and medical expenses; future lost wages; future loss of earning capacity; and future pain, suffering, and inconvenience.
102. As the parents and next friend of Baby Plaintiff, a minor, Mother Plaintiff and Father Plaintiff are legally responsible for paying these past and future medical expenses.
103. Therefore, as the direct and proximate result of these breaches of the applicable standard of medical care, Mother Plaintiff and Father Plaintiff incurred past medical expenses on behalf of Baby Plaintiff. They will incur future medical expenses on behalf of Baby Plaintiff; future cost and expenses for the care of Baby Plaintiff; and the loss of services, labor, assistance, etc. from their child, Baby Plaintiff.
104. All of the allegations of negligence and wrongful conduct set forth herein increased the risk of harm to Plaintiff Mother Plaintiff and her unborn twins (in particular Baby Plaintiff).
105. The harm suffered by Mother Plaintiff and in particular Baby Plaintiff from discharging Mother Plaintiff from the hospital rather than keeping her in the hospital and/or delivering her via cesarean section was of a kind that ordinarily does not occur in the absence of negligence.
106. The damages of the Plaintiff Baby Plaintiff exceed the amount requiring mandatory arbitration in Stoneleigh County.
     WHEREFORE: The Plaintiffs, Mother Plaintiff and Father Plaintiff, individually, and as parents and natural guardians of Baby Plaintiff, a minor, claim mone
     tary damages on her behalf against Dr. A together with interests and costs of suit in an amount in excess of the arbitration limits.

COUNT II: NEGLIGENCE – MEDICAL MALPRACTICE

Mother Plaintiff and Father Plaintiff, Individually, as Parents and
Natural Guardians of Baby Plaintiff, a Minor,
v.
Erik J. S, D.O.

107. Plaintiff incorporates paragraphs 1-105 above herein by reference and in additional avers:
108. Defendant Dr. S owed a duty imposed by the common law of the Commonwealth of Pennsylvania to skillfully, prudently, and properly diagnose, care, treat, advise, and observe Mother Plaintiff and her unborn twins in such a manner as would a reasonable and prudent physician specializing in obstetrics, gynecology, and maternal-fetal medicine confronted by similar conditions and circumstances treating patients with medical conditions similar to Mother Plaintiff.
109. That at all times relevant to the claims at bar, the standard of medical care applicable to Dr. S for the treatment of Mother Plaintiff and her unborn twins included, but was not limited to: 1) properly monitoring, assessing, interpreting, and documenting Ms. Plaintiff’s twins’ fetal heart rates when he saw her at Stoneleigh Hospital on June 16, 2017 until June 18, 2017; 2) properly assessing and evaluating the risk of pregnancy complications for a twin pregnancy with monochorionic diamniotic twins when he saw Ms. Plaintiff at Stoneleigh Hospital on June 16, 2017 until June 18, 2017; 3) properly monitoring, assessing, and evaluating Mother Plaintiff’s twin pregnancy for complications when he saw her on June 16, 2017 until June 18, 2017; 4) properly and timely recognizing that Mother Plaintiff and her twins were suffering from utero-placental insufficiency on June 16, 2017 until June 18, 2017; 5) properly and timely recognizing that Mother Plaintiff’s twins were suffering from IUGR on June 16, 2017 until June 18, 2017; 6) properly and timely recognizing that Mother Plaintiff’s twins were suffering from gestational hypertension on June 16, 2017 until June 18, 2017; 7) properly and timely assessing the risk of harm to Mother Plaintiff’s twins when she was approximately 34 weeks pregnant with monochorionic diamniotic twins and her twins were suffering from IUGR, gestational hypertension, utero-placental insufficiency on June 16, 2017 until June 18, 2017; 8) refraining from discharging Mother Plaintiff from Stoneleigh Hospital on June 18, 2017 when she was approximately 34 weeks pregnant with monochorionic diamniotic twins and when her twins were suffering from IUGR, gestational hypertension, and utero-placental insufficiency; 9) keeping Mother Plaintiff at Stoneleigh Hospital for continuous monitoring of her twins until their delivery rather than discharging her from the hospital on June 18, 2017; 10) alternatively, timely and appropriately delivering Mother Plaintiff’s twins on June 18, 2017 via cesarean section; 11) properly and timely recognizing, appreciating, and responding to the signs and symptoms of utero-placental insufficiency experienced by Mother Plaintiff’s twins, including abnormalities seen on a fetal heart strips such as late decelerations and periods of non-reactivity when Dr. A saw her on June 16, 2017 until June 18, 2017; 12) recognizing and appreciating the risk of permanent injury to Ms. Plaintiff’s twins if Ms. Plaintiff was discharged from Stoneleigh Hospital on June 18, 2017 while her twins were suffering from IUGR, gestation hypertension, and utero-placental insufficiency; and 13) properly administering to Ms. Plaintiff the correct and complete dosage of Betamethasone on June 18, 2017 in anticipation of early delivery and to assist with lung development and utero-placental insufficiency.
110. Dr. S breached the applicable standard of medical care owed to Mother Plaintiff and her unborn twins from June 16, 2017 until June 18, 2 These breaches included, but were not limited to: 1) failing to properly monitor, assess, interpret, and document Ms. Plaintiff’s twins’ fetal heart rates when he saw her at Stoneleigh Hospital on June 16, 2017 until June 18, 2017; 2) failing to properly assess and evaluate the risk of pregnancy complications for a twin pregnancy with monochorionic diamniotic twins when he saw Ms. Plaintiff at Stoneleigh Hospital on June 16, 2017 until June 18, 2017; 3) failing to properly monitor, assess, and evaluate Mother Plaintiff’s twin pregnancy for complications when he saw her on June 16, 2017 until June 18, 2017; 4) failing to properly and timely recognize that Mother Plaintiff and her twins were suffering from utero-placental insufficiency on June 16, 2017 until June 18, 2017; 5) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from IUGR on June 16, 2017 until June 18, 2017; 6) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from gestational hypertension on June 16, 2017 until June 18, 2017; 7) failing to properly and timely assess the risk of harm to Mother Plaintiff’s twins when she was approximately 34 weeks pregnant with monochorionic diamniotic twins and her twins were suffering from IUGR, gestational hypertension, utero-placental insufficiency on June 16, 2017 until June 18, 2017; 8) discharging Mother Plaintiff from Stoneleigh Hospital on June 18, 2017 when she was approximately 34 weeks pregnant with monochorionic diamniotic twins and when her twins were suffering from IUGR, gestational hypertension, and utero-placental insufficiency; 9) failing to keep Mother Plaintiff at Stoneleigh Hospital for continuous monitoring of her twins until their delivery rather than discharging her from the hospital on June 18, 2017; 10) alternatively, failing to timely and appropriately deliver Mother Plaintiff’s twins on June 18, 2017 via cesarean section; 11) failing to properly and timely recognize, appreciate, and respond to the signs and symptoms of utero-placental insufficiency experienced by Mother Plaintiff’s twins, including abnormalities seen on a fetal heart strips such as late decelerations and periods of non-reactivity when Dr. A saw her on June 16, 2017 until June 18, 2017; 12) failing to recognize and appreciate the risk of permanent injury to Ms. Plaintiff’s twins if Ms. Plaintiff was discharged from Stoneleigh Hospital on June 18, 2017 while her twins were suffering from IUGR, gestation hypertension, and utero-placental insufficiency; and 13) failing to properly administer to Ms. Plaintiff the correct and complete dosage of Betamethasone on June 18, 2017 in anticipation of early delivery and to assist with lung development and utero-placental insufficiency.
111. In addition, as part of the maternal-fetal medicine fellowship program, the standard of care required Dr. S to properly supervise and communicate with fellows in the program, including, but not limited to, Dr. A.
112. From June 16, 2017 until June 18, 2017, Dr. S breached the standard of care and was negligent in failing to properly supervise and communicate with his fellow, Dr. A, regarding Mother Plaintiff and her unborn twin’s medical condition. As a result, Dr. S and Dr. A had a dispute on June 18, 2017, regarding whether it was appropriate for Ms. Plaintiff to be discharged from Stoneleigh Hospital given her current medical condition and complications. This dispute and lack of communication led to Ms. Plaintiff being inappropriately discharged from Stoneleigh Hospital on June 18, 2 Had Dr. A been properly supervised by and communicated with Dr. S, Ms. Plaintiff would not have been discharged from the hospital on June 18, 2 Dr. S was negligent and breached the standard of care by failing to gather sufficient information regarding Ms. Plaintiff’s medical condition and by
     allowing her to be discharged from the hospital.
113. As a direct and proximate result of Dr. S’s negligence and breaches of the applicable standards of medical care, Baby Plaintiff suffered a severe and permanent physical injury, including but not limited to, oxygen deprivation, severe hypoxia, severe metabolic acidosis, permanent brain injury, respiratory distress, neurological impairment, gastrointestinal impairment, and multi-system organ failure.
114. As a direct and proximate result of the negligence of the Defendant Dr. S, Baby Plaintiff suffered mental and physical pain and suffering, inconvenience, humiliation, embarrassment, loss of life’s enjoyment and pleasures, and the damages that discovery will show are appropriate under the laws of the Commonwealth of Pennsylvania.
115. Baby Plaintiff’ medical expenses to date total approximately $100, Baby Plaintiff has incurred and will incur past medical expenses; past pain and suffering; future costs and medical expenses; future lost wages; future loss of earning capacity; and future pain, suffering, and inconvenience.
116. As the parents and next friend of Baby Plaintiff, a minor, Mother Plaintiff and Father Plaintiff are legally responsible for paying these past and future medical expenses.
117. Therefore, as the direct and proximate result of these breaches of the applicable standard of medical care, Mother Plaintiff and Father Plaintiff incurred past medical expenses on behalf of Baby Plaintiff. They will incur future medical expenses on behalf of Baby Plaintiff; future cost and expenses for the care of Baby Plaintiff; and the loss of services, labor, assistance, etc. from their child, Baby Plaintiff.
118. All of the allegations of negligence and wrongful conduct set forth herein increased the risk of harm to Plaintiff Mother Plaintiff and her unborn twins (in particular Baby Plaintiff).
119. The harm suffered by Mother Plaintiff and in particular Baby Plaintiff from discharging Mother Plaintiff from the hospital rather than keeping her in the hospital and/or delivering her via cesarean section was of a kind that ordinarily does not occur in the absence of negligence.
120. The damages of the Plaintiff Baby Plaintiff exceed the amount requiring mandatory arbitration in Stoneleigh County.
     WHEREFORE: The Plaintiffs, Mother Plaintiff and Father Plaintiff, individually, and as parents and natural guardians of Baby Plaintiff, a minor, claim monetary damages on her behalf against Dr. S together with interests and costs of suit in an amount in excess of the arbitration limits.

COUNT III: NEGLIGENCE – MEDICAL MALPRACTICE

Mother Plaintiff and Father Plaintiff, Individually, as Parents and
Natural Guardians of Baby Plaintiff, a Minor,
v.
Lindsey S. P, R.N.

121. Plaintiff incorporates paragraphs 1-119 above herein by reference and in additional avers:
122. Defendant Nurse P owed a duty imposed by the common law of the Commonwealth of Pennsylvania to skillfully, prudently, and properly diagnose, care, treat, advise, and observe Mother Plaintiff and her unborn twins in such a manner as would a reasonable and prudent nurse specializing in obstetrics, gynecology, and maternal-fetal medicine confronted by similar conditions and circumstances treating patients with medical conditions similar to Mother Plaintiff.
123. That at all times relevant to the claims at bar, the standard of nursing care applicable to Nurse P for the treatment of Mother Plaintiff and her unborn twins included, but was not limited to: 1) properly monitoring, assessing, interpreting, and documenting Mother Plaintiff’s twins’ fetal heart rates when she saw her on June 18, 2017 in accordance with the standard of care and hospital policies and protocols; 2) properly monitoring, assessing, and evaluating Mother Plaintiff’s twin pregnancy for complications on June 18, 2017 in accordance with the standard of care and hospital policies and protocols; 3) properly and timely recognizing that Mother Plaintiff and her twins were suffering from utero-placental insufficiency on June 18, 2017; 4) properly and timely recognizing that Mother Plaintiff’s twins were suffering from IUGR on June 18, 2017; 5) properly and timely recognizing that Mother Plaintiff’s twins were suffering from gestational hypertension on June 18, 2017; 6) identifying and documenting fetal heart strip abnormalities when she reviewed Ms. Plaintiff’s fetal heart strips on June 18, 2017, including decelerations and periods of non-reactivity; 7) communicating with other physicians, including, but not limited to, Dr. A, Dr. S, and Dr. F regarding fetal heart strip abnormalities when she reviewed Ms. Plaintiff’s fetal heart strips on June 18, 2017; and 8) recognizing, documenting, and communicating with other physicians, including, but not limited to, Dr. A, Dr. S, and Dr. F that Ms. Plaintiff was experiencing signs of utero-placental insufficiency and hypoxia on fetal heart strips when she saw her on June 18, 2017.
124. Nurse P breached the applicable standard of nursing care owed to Mother Plaintiff and her unborn twins from June 16, 2017 until June 18, 2017. These breaches included, but were not limited to: 1) failing to properly monitor, assess, interpret, and document Mother Plaintiff’s twins’ fetal heart rates when she saw her on June 18, 2017 in accordance with the standard of care and hospital policies and protocols; 2) failing to properly monitor, assess, and evaluate Mother Plaintiff’s twin pregnancy for complications on June 18, 2017 in accordance with the standard of care and hospital policies and protocols; 3) failing to properly and timely recognize that Mother Plaintiff and her twins were suffering from utero-placental insufficiency on June 18, 2017; 4) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from IUGR on June 18, 2017; 5) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from gestational hypertension on June 18, 2017; 6) failing to identify and document fetal heart strip abnormalities when she reviewed Ms. Plaintiff’s fetal heart strips on June 18, 2017, including decelerations and periods of non-reactivity; 7) failing to communicate with other physicians, including, but not limited to, Dr. A, Dr. S, and Dr. F regarding fetal heart strip abnormalities when she reviewed Ms. Plaintiff’s fetal heart strips on June 18, 2017; and 8) failing to recognize, document, and communicate with other physicians, including, but not limited to, Dr. A, Dr. S, and Dr. F that Ms. Plaintiff was experiencing signs of utero-placental insufficiency and hypoxia on fetal heart strips when she saw her on June 18, 2017.
125. As a direct and proximate result of Nurse P’s negligence and breaches of the applicable standards of nursing care, Baby Plaintiff suffered a severe and permanent physical injury, including but not limited to, oxygen deprivation, severe hypoxia, severe metabolic acidosis, permanent brain injury, respiratory distress, neurological impairment, gastrointestinal impairment, and multi-system organ failure.
126. As a direct and proximate result of the negligence of the Defendant Nurse P, Baby Plaintiff suffered mental and physical pain and suffering, inconvenience, humiliation, embarrassment, loss of life’s enjoyment and pleasures, and the damages that discovery will show are appropriate under the laws of the Commonwealth of Pennsylvania.
127. Baby Plaintiff’ medical expenses to date total approximately $100,089.25. Baby Plaintiff has incurred and will incur past medical expenses; past pain and suffering; future costs and medical expenses; future lost wages; future loss of earning capacity; and future pain, suffering, and inconvenience.
128. As the parents and next friend of Baby Plaintiff, a minor, Mother Plaintiff and Father Plaintiff are legally responsible for paying these past and futu
     re medical expenses.
129. Therefore, as the direct and proximate result of these breaches of the applicable standard of medical care, Mother Plaintiff and Father Plaintiff incurred past medical expenses on behalf of Baby Plaintiff. They will incur future medical expenses on behalf of Baby Plaintiff; future cost and expenses for the care of Baby Plaintiff; and the loss of services, labor, assistance, etc. from their child, Baby Plaintiff.
130. All of the allegations of negligence and wrongful conduct set forth herein increased the risk of harm to Plaintiff Mother Plaintiff and her unborn twins (in particular Baby Plaintiff).
131. The harm suffered by Mother Plaintiff and in particular Baby Plaintiff from discharging Mother Plaintiff from the hospital rather than keeping her in the hospital and/or delivering her via cesarean section was of a kind that ordinarily does not occur in the absence of negligence.
132. The damages of the Plaintiff Baby Plaintiff exceed the amount requiring mandatory arbitration in Stoneleigh County.
     WHEREFORE: The Plaintiffs, Mother Plaintiff and Father Plaintiff, individually, and as parents and natural guardians of Baby Plaintiff, a minor, claim monetary damages on her behalf against Nurse P together with interests and costs of suit in an amount in excess of the arbitration limits.