Example Cerebral Palsy Complaint in Pennsylvania Part 3 of 8

Below is example birth injury lawsuit alleging the doctors and nurses negligence caused the child to have cerebral palsy.  It is broken up in 8 parts. This is the third part.    

COUNT IV: NEGLIGENCE – MEDICAL MALPRACTICE

Mother Plaintiff and Father Plaintiff, Individually, as Parents and
Natural Guardians of Baby Plaintiff, a Minor,
v.
Kelly L. Gesell, R.N.

133. Plaintiff incorporates paragraphs 1-131 above herein by reference and in additional avers:
134. Defendant Nurse Gesell 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.
135. That at all times relevant to the claims at bar, the standard of nursing care applicable to Nurse Gesell 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 17, 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 17, 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 17, 2017; 4) properly and timely recognizing that Mother Plaintiff’s twins were suffering from IUGR on June 17, 2017; 5) properly and timely recognizing that Mother Plaintiff’s twins were suffering from gestational hypertension on June 17, 2017; 6) identifying and documenting fetal heart strip abnormalities when she reviewed Ms. Plaintiff’s fetal heart strips on June 17, 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 17, 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 17, 2017.
136. Nurse Gesell 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 17, 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 17, 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 17, 2017; 4) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from IUGR on June 17, 2017; 5) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from gestational hypertension on June 17, 2017; 6) failing to identify and document fetal heart strip abnormalities when she reviewed Ms. Plaintiff’s fetal heart strips on June 17, 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 17, 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 17, 2017.
137. As a direct and proximate result of Nurse Gesell’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.
138. As a direct and proximate result of the negligence of the Defendant Nurse Gesell, 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.
139. 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.
140. 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.
141. 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.
142. 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).
143. 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.
144. The damages of the Plaintiff Baby Plaintiff exceed the amount requiring mandatory arbitration in Stoneleigh County.
145. 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 Gesell together with interests and costs of suit in an amount in excess of the arbitration limits.

COUNT V: NEGLIGENCE – MEDICAL MALPRACTICE

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

146. Plaintiff incorporates paragraphs 1-143 above herein by reference and in additional avers:
147. Defendant Nurse R 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.
148. That at all times relevant to the claims at bar, the standard of nursing care applicable to Nurse R 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 16, 2017 and June 17, 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 16, 2017 and June 17, 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 16, 2017 and June 17, 2017; 4) properly and timely recognizing that Mother Plaintiff’s twins were suffering from IUGR on June 16, 2017 and June 17, 2017; 5) properly and timely recognizing that Mother Plaintiff’s twins were suffering from gestational hypertension on June 16, 2017 and June 17, 2017; 6) identifying and documenting fetal heart strip abnormalities when she reviewed Ms. Plaintiff’s fetal heart strips on June 16, 2017 and June 17, 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 16, 2017 and June 17, 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 16, 2017 and June 17, 2017.
149. Nurse Gesell 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 16, 2017 and June 17, 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 16, 2017 and June 17, 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 16, 2017 and June 17, 2017; 4) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from IUGR on June 16, 2017 and June 17, 2017; 5) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from gestational hypertension on June 16, 2017 and June 17, 2017; 6) failing to identify and document fetal heart strip abnormalities when she reviewed Ms. Plaintiff’s fetal heart strips on June 16, 2017 and June 17, 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 16, 2017 and June 17, 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 16, 2017 and June 17, 2017.
150. As a direct and proximate result of Nurse R’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.
151. As a direct and proximate result of the negligence of the Defendant Nurse R, 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.
152. 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.
153. 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.
154. 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.
155. 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).
156. 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.
157. 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 R together with interests and costs of suit in an amount in excess of the arbitration limits.

COUNT VI: NEGLIGENCE – MEDICAL MALPRACTICE

Mother Plaintiff and Father Plaintiff, Individually, as Parents and
Natural Guardians of Baby Plaintiff, a Minor,
v.
Amy L. H, R.N.

 

158. Plaintiff incorporates paragraphs 1-155 above herein by reference and in additional avers:
159. Defendant Nurse H 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 ma
     nner 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.
160. That at all times relevant to the claims at bar, the standard of nursing care applicable to Nurse H 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 17, 2017 and 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 17, 2017 and 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 17, 2017 and June 18, 2017; 4) properly and timely recognizing that Mother Plaintiff’s twins were suffering from IUGR on June 17, 2017 and June 18, 2017; 5) properly and timely recognizing that Mother Plaintiff’s twins were suffering from gestational hypertension on June 17, 2017 and June 18, 2017; 6) identifying and documenting fetal heart strip abnormalities when she reviewed Ms. Plaintiff’s fetal heart strips on June 17, 2017 and 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 17, 2017 and June 18, 2017; 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 17, 2017 and June 18, 2017; and 9) administering to Ms. Plaintiff the second dose of betamethasone that was ordered for June 17, 2017 and June 18, 2017.
161. Nurse H 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 17, 2017 and 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 17, 2017 and 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 17, 2017 and June 18, 2017; 4) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from IUGR on June 17, 2017 and June 18, 2017; 5) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from gestational hypertension on June 17, 2017 and June 18, 2017; 6) failing to identify and document fetal heart strip abnormalities when she reviewed Ms. Plaintiff’s fetal heart strips on June 17, 2017 and 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 17, 2017 and June 18, 2017; 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 17, 2017 and June 19, 2017; and 9) failing to administer to Ms. Plaintiff the second dose of betamethasone that was ordered for June 17, 2017 and June 18, 2017.
162. As a direct and proximate result of Nurse H’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.
163. As a direct and proximate result of the negligence of the Defendant Nurse H, 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.
164. 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.
165. 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.
166. 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.
167. 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).
168. 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.
169. 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 H together with interests and costs of suit in an amount in excess of the arbitration limits.

COUNT VII: NEGLIGENCE – MEDICAL MALPRACTICE

Mother Plaintiff and Father Plaintiff, Individually, as Parents and
Natural Guardians of Baby Plaintiff, a Minor,
v.
Megan E. F, M.D.

170. Plaintiff incorporates paragraphs 1-167 above herein by reference and in additional avers:
171. Defendant Dr. F 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.
172. That at all times relevant to the claims at bar, the standard of medical care applicable to Dr. F 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 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 18, 2017; 3) properly monitoring, assessing, and evaluating Mother Plaintiff’s twin pregnancy for complications when he saw her on June 18, 2017; 4) properly and timely recognizing that Mother Plaintiff and her twins were suffering from utero-placental insufficiency on June 18, 2017; 5) properly and timely recognizing that Mother Plaintiff’s twins were suffering from IUGR on June 18, 2017; 6) properly and timely recognizing that Mother Plaintiff’s twins were suffering from gestational hypertension on 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 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 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 her 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 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.
173. Dr. F breached the applicable standard of medical 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 Ms. Plaintiff’s twins’ fetal heart rates when he saw her at Stoneleigh Hospital on 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 18, 2017; 3) failing to properly monitor, assess, and evaluate Mother Plaintiff’s twin pregnancy for complications when he saw her on June 18, 2017; 4) failing to properly and timely recognize that Mother Plaintiff and her twins were suffering from utero-placental insufficiency on June 18, 2017; 5) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from IUGR on June 18, 2017; 6) failing to properly and timely recognize that Mother Plaintiff’s twins were suffering from gestational hypertension on 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 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 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 her 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 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.
174. As a direct and proximate result of Dr. F’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.
175. As a direct and proximate result of the negligence of the Defendant Dr. F, 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.
176. 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.
177. 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.
178. 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.
179. 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).
180. 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.
181. 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. F together with interests and costs of suit in an amount in excess of the arbitration limits.