Example Cerebral Palsy Complaint in Pennsylvania Part 5 of 8

This is Part V of a example cerebral palsy case we filed in Pennsylvania. 

We broke up this sample complaint into 8 parts because he Internet apparently does not tolerate the long pages.  This is the 5th part.   

COUNT XIII: NEGLIGENCE/RESPONDEAT SUPERIOR – MEDICAL MALPRACTICE

Mother Plaintiff and Father Plaintiff, Individually, as Parents and
Natural Guardians of Baby Plaintiff, a Minor,
v.
Stoneleigh Hospital

  1. Plaintiff incorporates paragraphs 1-345 above herein by reference and in additional avers:
  2. At all times relevant hereto, the employees, agents, servants, including physicians, physician assistants, residents, fellows, nurses, nurse midwives, and technicians who provided care to Mother Plaintiff between June 16, 2017 and June 20, 2017, including, but not limited to, Dr. A, Dr. S, Dr. F, Dr. C, Dr. N, Nurse Hon, Nurse P, Nurse G, Nurse M, and Nurse R were under the control and were acting within the course and scope of their employment and/or ostensible agency and/or professional relationship with Defendant Stoneleigh Hospital.
  3. That Defendant Stoneleigh Hospital acting through its employees, agents, servants, and/or ostensible agents, including, but not limited to, Dr. A, Dr. S, Dr. F, Dr. C, Dr. N, Nurse Hon, Nurse P, Nurse G, Nurse M, and Nurse R had a duty to provide that degree of care and skill exercised by a similarly trained and skilled, reasonable and prudent health care provider in the same or similar circumstance treating patients with medical conditions similar to Mother Plaintiff from June 16, 2017 until June 18, 2017, and on June 20, 2017.
  4. That Defendant Stoneleigh Hospital, by and through its employees, agents, servants, and/or ostensible agents, including, but not limited to, Dr. A, Dr. S, Dr. F, Dr. C, Dr. N, Nurse Hon, Nurse P, Nurse G, Nurse M, and Nurse R, breached the applicable standard of medical and nursing care (as stated above) during the care and treatment of Mother Plaintiff and her unborn twins from June 16, 2017 until June 18, 2017, and on June 20, 2017.
  5. Stoneleigh Hospital negligence, by and through its employees, agents, servants, and/or ostensible agents, including, but not limited to, Elizabeth Koller, breached the applicable standard of medical and nursing care during the care and treatment of Mother Plaintiff (who was experiencing a medical emergency) on June 20, 2017 when Ms. Plaintiff was told to drive herself to Stoneleigh hospital by car as opposed to being transported via ambulance. As a result of the delay caused by Ms. Plaintiff driving herself to the hospital as opposed to taking an ambulance, her twins suffered additional hypoxic injury because of the additional time spent reaching the hospital and the additional time spent connecting Ms. Plaintiff to IVs and other equipment upon her arrival when she could have been immediately assessed for a cesarean section.
  6. Plaintiff Mother Plaintiff reasonably believed that the care provided by the said Defendants was being given by Defendant Stoneleigh Hospital or by Defendants Dr. A, Dr. S, Dr. F, Dr. C, Dr. N, Nurse Hon, Nurse P, Nurse G, Nurse M, and Nurse R as agents of Defendant Stoneleigh Hospital.
  7. As a direct and proximate result of Defendant Stoneleigh Hospital’s negligence and breaches of the applicable standards of care, by and through the actions of its employees, agents, servants, and/or ostensible agents, including, but not limit to, Dr. A, Dr. S, Dr. F, Dr. C, Dr. N, Nurse Hon, Nurse P, Nurse G, Nurse M, and Nurse R, 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.
  8. As a direct and proximate result of the negligence of Defendant Stoneleigh Hospital negligence and breaches of the applicable standards of care, by and through the actions of its employees, agents, servants, and/or ostensible agents, 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.
  9. 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.
  10. 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.
  11. 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.
  12. 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).
  13. 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.
  14. 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 Stoneleigh Hospital with interests and costs of suit in an amount in excess of the arbitration limits.
COUNT XIV: CORPORATE NEGLIGENCE – MEDICAL MALPRACTICE

Mother Plaintiff and Father Plaintiff, Individually, as Parents and
Natural Guardians of Baby Plaintiff, a Minor,
v.
GoodLife Health

  1. Plaintiff incorporates paragraphs 1-359 above herein by reference and in additional avers:
  2. GoodLife Health is a non-profit corporation providing healthcare to the public and incorporated under the laws of Pennsylvania. GoodLife Health owns a vast and integrated healthcare system that includes a multitude of medical groups and healthcare facilities, including, but not limited to GoodLife Medical Group, t/d/b/a GoodLife Maternal-Fetal Medicine and Stoneleigh Hospital.
  3. As part of an integrative and collaborative network of providers operating under the umbrella of GoodLife Health, GoodLife Medical Group, t/d/b/a GoodLife Maternal-Fetal Medicine and Stoneleigh Hospital collaborate with each other in the following ways: a) sharing patients; b) sharing medical records through the same computer database; c) having equal access to the medical records, including the ability to make changes to the medical records; d) sharing pathways of communication, including the ability to immediately call other facilities; e) sharing policies, protocols, and procedures for nurses and physicians; f) sharing residents and fellows; g) sharing joint responsibility for the retaining, training, and supervision of residents and fellows; h) sharing joint responsibility for patients being seen at multiple GoodLife locations; and i) having the ability to direct and control healthcare providers at other GoodLife locations (for instance, maternal fetal medicine fellows having the ability to direct and control residents and nurses working at Stoneleigh Hospital).
  4. As part of an integrative and collaborative network of providers operating under the umbrella of GoodLife Health, GoodLife Medical Group, t/d/b/a GoodLife Maternal-Fetal Medicine and Stoneleigh Hospital share policies, procedures, and a common set of goals to ensure the safety of their shared patients.
  5. More specific to this case, GoodLife Health, GoodLife Medical Group, t/d/b/a GoodLife Maternal-Fetal Medicine, and Stoneleigh Hospital jointly advertise and offer a physician fellowship in maternal-fetal medicine. The program spans 3 years and offers fellows an opportunity to practice in an office setting at various GoodLife Medical Group, t/d/b/a GoodLife Maternal-Fetal Medicine locations as well as seeing patients who have been admitted to Stoneleigh Hospital. The training program is collaborative and designed to train fellows in maternal-fetal medicine to assess, diagnose, and treat patients in various clinic settings, including office and hospital settings. As a result, GoodLife Health, GoodLife Medical Group, t/d/b/a GoodLife Maternal-Fetal Medicine, and Stoneleigh Hospital share responsibility for their fellows and collectively hire, train, educate, reprimand, and supervise them in their assessment, diagnosis, and treatment of patients.
  6. In this case, Dr. A was a fellow with GoodLife Health, GoodLife Medical Group, t/d/b/a GoodLife Maternal-Fetal Medicine, and Stoneleigh Hospital when he saw and evaluated Mother Plaintiff at Stoneleigh Hospital from June 16, 2017 until June 18, 2017.
  7. Upon information and belief, Defendant GoodLife Health is a parent company of a health system that operated Defendant Stoneleigh Hospital.
  8. At all times relevant hereto, Defendant Stoneleigh Hospital and/or GoodLife Health was a medical facility subject to the corporate liability law that was holding itself out as having advanced and safe labor and delivery units with high quality nurses and physicians skilled at diagnosing and treating high-risk pregnancies, including Mother Plaintiff’s pregnancy when she was admitted to Stoneleigh Hospital on June 16, 2017 until June 18, 2017, and on June 20, 2017 for that purpose.
  9. Under the law of Pennsylvania, Defendant GoodLife Health had a duty to comply with the objective legal standard of care for hospitals which required Defendant Stoneleigh Hospital and/or GoodLife Health to ensure the safety and well-being of all patients being treating in its facilities including Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff).
  10. At all times relevant hereto, GoodLife Health had a duty and obligation under the law to have and enforce comprehensive policies and standards for ensure the safety of patients, employees, and visitors and for the protection from malpractice and negligence. 28 P.A. Code § 101.31(10)(xv).
  11. Defendant GoodLife Health had a non-delegable duty imposed by the common law of the Commonwealth of Pennsylvania to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) while they were a patient at its facility Stoneleigh Hospital. This non-delegable duty included:
    1. A duty to use reasonable care in the maintenance of safe and adequate facilities and equipment;
    2. To select and retain only competent physicians;
    3. To oversee all persons who practice medicine within its walls as to patient care;
    4. To formulate, adopt, and enforce rules and policies to ensure quality care for patients.
  12. At all times relevant hereto, Defendant GoodLife Health knew or should have known of the published notice that it was required to have and enforce comprehensive policies and standards for ensuring the safety of patients for protection from malpractice and negligence (28 Pa. Code §101.31(10)(xv)) and to make certain through reasonable compliance with the corporate duties established by law to ensure the safety and well-being of Mother Plaintiff and her unborn twins (including Baby Plaintiff).
  13. At all times relevant hereto, Defendant GoodLife Health had published notice that Defendants were “required to make every effort to reduce and eliminate medical errors by identifying problems and implementing solutions to promote patient safety.” MCARE Act (Act of March 20, 2002 PL 154 No. 113 §102(5), 40 P.S. §1303.102(5).
  14. In ensuring the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) and removing needless dangers to them, Defendant GoodLife Health was required to be aware of the known and needless dangers involved in discharging from the hospital high-risk pregnancy patients, such as Mother Plaintiff who was approximately 34 weeks pregnant with twins on June 18, 2017 and suffering IUGR, gestational hypertension, and utero-placental insufficiency.
  15. At all times relevant hereto, Defendant GoodLife Health knew or should have known that the level of danger to Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) was established by the level of care that was needed to provide safe care to avoid risks and complications including hypoxic injury and permanent brain damage to Baby Plaintiff. The level of danger to Mother Plaintiff and her unborn twins (including Baby Plaintiff) was extraordinarily given Mother Plaintiff and her unborn twins’ (including Baby Plaintiff) pregnancy complications, including, but not limited to, IUGR, gestational hypertension, and utero-placental insufficiency from June 16, 2017 until June 20, 2017. The risks associated with these complications specifically included hypoxic injury to both twins and the risk of permanent brain damage. Given the high level of risk, Mother Plaintiff and her unborn twins (including Baby Plaintiff) required a high level of safety training, experience, and preparedness to avoid.
  16. At all times relevant hereto, Defendant GoodLife Health knew or should have known that Ms. Plaintiff was pregnant with monochorionic diamniotic twins and at high risk for pregnancy complications when she was sent to the hospital on June 16, 2017.
  17. At all times relevant hereto, Defendant GoodLife Health knew or should have known that Ms. Plaintiff was suffering from pregnancy complications such as gestation hypertension, IUGR, and utero-placental insufficiency while she was admitted to Stoneleigh Hospital from June 16, 2017 until June 18, 2017.
  18. At all times relevant hereto, Defendant GoodLife Health knew or should have known that, Ms. Plaintiff was experiencing signs and symptoms of utero-placental insufficiency, including, but not limited to, headaches, nausea, vomiting, hypertension, and IUGR while she was admitted to Stoneleigh Hospital from June 16, 2017 until June 18, 2017.
  19. At all times relevant hereto, Defendant GoodLife Health knew or should have known that utero-placental insufficiency, IUGR, and gestational hypertension could be fatal to Ms. Plaintiff’s twins (including Baby Plaintiff).
  20. At all times relevant hereto, Defendant GoodLife Health knew or should have known that utero-placental insufficiency, IUGR, and gestational hypertension could cause serious permanent injury, including, but not limited to, permanent organ damage and brain injury to Ms. Plaintiff’s twins (including Baby Plaintiff).
  21. At all times relevant hereto, Defendant GoodLife Health knew or should have known that high-risk pregnancy patients such as Ms. Plaintiff who are suffering from pregnancy complications such as utero-placental insufficiency, IUGR, and gestational hypertension require continuous monitoring and surveillance for worsening of their condition and signs and symptoms of fetal hypoxia and injury.
  22. At all times relevant hereto, Defendant GoodLife Health knew or should have known that high-risk pregnancy patients such as Ms. Plaintiff who are suffering from pregnancy complications such as utero-placental insufficiency, IUGR, and gestational hypertension require a competent nursing staff skilled at identifying, recognizing, documenting, and communicating to other healthcare providers when a high-risk patient pregnancy with twins is experiencing signs and symptoms of utero-placental insufficiency, IUGR, gestational hypertension, fetal hypoxia, and fetal injury.
  23. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it needed to select and retain competent nurses who were properly trained to identify, recognize, document, and communicate with other healthcare providers signs and symptoms of utero-placental insufficiency, IUGR, gestational hypertension, fetal hypoxia, and fetal injury.
  24. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to select and retain competent nurses that could identify, recognize, document, and communicate to other healthcare providers fetal heart strip abnormalities, including, but not limited to, late decelerations and periods of non-reactivity.
  25. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to develop policies, procedures, protocols, guidelines, order sets, and training materials regarding the interpretation of fetal heart strips and fetal heart strip abnormalities, including, but not limited to late decelerations and periods of non-reactivity.
  26. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to develop policies, procedures, protocols, guidelines, order sets, and training materials for nurses and physicians regarding identifying and communicating to other healthcare providers when a high-risk twin patient pregnancy with twins is experiencing signs and symptoms of pregnancy complications such as IUGR, gestational hypertension, and utero-placental insufficiency.
  27. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to develop policies, procedures, protocols, guidelines, order sets, and training materials regarding treating high-risk twin pregnancy patients when they are experiencing signs and symptoms of pregnancy complications such as IUGR, gestational hypertension, and utero-placental insufficiency.
  28. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to develop policies, procedures, protocols, guidelines, order sets, and training materials regarding nurses going up the chain of command if a physician or another healthcare provider fails to adequately respond to a high-risk patient pregnant with twins who is experiencing pregnancy complications such as IUGR, gestational hypertension, and utero-placental insufficiency.
  29. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to develop policies, procedures, protocols, guidelines, order sets, and training materials regarding the supervision and training of physician residents and fellows who are caring for high-risk patients pregnant with twins who are suffering from complications such as IUGR, gestational hypertension, and utero-placental insufficiency.
  30. At all times relevant hereto, Defendant GoodLife Health knew or should have known that the steroid betamethasone is required to be administered prior to birth in high-risk pregnancies to premature fetuses to develop the fetuses’ lungs and to prevent utero-placental insufficiency.
  31. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to develop policies, procedures, protocols, guidelines, order sets, and training materials to ensure that medications such as betamethasone, which are ordered for high-risk twin pregnancy patients, are actually administered to the patient to develop the baby’s lungs and prevent complications, such as utero-placental insufficiency.
  32. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it needed to select and retain competent physicians, residents, and fellows who were properly trained to identify, recognize, document, treat, and to communicate with other healthcare providers that a high risk pregnancy patient is experiencing signs and symptoms of utero-placental insufficiency, IUGR, gestational hypertension, fetal hypoxia, and fetal injury.
  33. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to select and retain competent physicians, residents, and fellows that could identify, document, and communicate to other healthcare providers fetal heart strip abnormalities, including, but not limited to, late decelerations and periods of non-reactivity.
  34. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to select and retain competent physicians, residents, and fellows that could properly treat a high-risk pregnancy patient such as Mother Plaintiff who has fetal heart strip abnormalities, including, but not limited to, late decelerations and periods of non-reactivity.
  35. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to select and retain competent physicians, residents, and fellows that could identify the risk of harm to high risk twin pregnancy patients such as Mother Plaintiff if they were prematurely discharged from the hospital when they were suffering from IUGR, gestational hypertension, and utero-placental insufficiency.
  36. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to select and retain competent physicians to train and supervise physician residents and fellows in the performance of their duties in caring for high-risk pregnancy patients such as Mother Plaintiff on June 16, 2017 until June 20, 2017.
  37. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to develop policies, procedures, protocols, guidelines, order sets, and training materials to ensure that physician residents and fellows were properly trained and supervised by attending physicians in the care and treatment of high-risk pregnancy patients such as Mother Plaintiff on June 16, 2017 until June 20, 2017.
  38. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to develop policies, procedures, protocols, guidelines, order sets, and training materials for the resolution of disputes between attending physicians and fellows regarding the care and treatment of high-risk pregnancy patients, such as Mother Plaintiff, and for the resolutions of such disputes in a manner that is safe for the patient.
  39. At all times relevant hereto, Defendant GoodLife Health knew or should have known that if Ms. Plaintiff was discharged from Stoneleigh Hospital on June 18, 2017 with her twins at approximately 34 weeks gestation, she would suffer a medical emergency necessitating an emergency delivery of her twins in the next week, which would result in one or both of her twins suffering death or hypoxic injury, including, but not limited to, a permanent brain injury and organ damage.
  40. At all times relevant hereto, Defendant GoodLife Health knew or should have known that if one or both of Ms. Plaintiff’s twins suffered a hypoxic injury prior to 35 weeks of gestation, the twins could not receive head and/or body cooling to prevent permanent neurological injury and/or permanent organ damage per Stoneleigh Hospital protocol.
  41. At all times relevant hereto, Defendant GoodLife Health knew or should have known that head and/or body cooling could prevent permanent neurological injury and organ damage to a child suffering from hypoxic injury, such as Baby Plaintiff on June 20, 2017.
  42. At all times relevant hereto, Defendant GoodLife Health knew or should have known that if Ms. Plaintiff was discharged from Stoneleigh Hospital on June 18, 2017, she and her twins would not be continuously monitored for worsening of her pregnancy complications, such as IUGR, gestational hypertension, and utero-placental insufficiency.
  43. At all times relevant hereto, Defendant GoodLife Health knew or should have known that as of June 18, 2017, it was dangerous to discharge Ms. Plaintiff from Stoneleigh Hospital and to not continuously monitor her because of her pregnancy complications that created a high-risk for fetal death and/or permanent fetal neurological and physical injury.
  44. At all times relevant hereto, Defendant GoodLife Health knew or should have known that if Ms. Plaintiff was discharged from Stoneleigh Hospital on June 18, 2017, she would suffer a medical emergency in the next week requiring the immediate delivery of her twins while not admitted to the hospital, and that there would be a substantial delay in responding to this medical emergency because she not admitted to the hospital. As a result of this delay in delivery, Defendant GoodLife Health knew or should have known that Ms. Plaintiff’s twins would suffer hypoxia, permanent injury, or fetal death.
  45. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it was required to develop policies, procedures, protocols, guidelines, order sets, and training materials to ensure that high-risk pregnancy patients such as Mother Plaintiff who are approximately 34 weeks pregnant and suffering from pregnancy complications such as IUGR, gestational hypertension, and utero-placental insufficiency are not discharged from the hospital when there is a substantial danger that one or both twins will suffer fetal death or neurological damage and physical injury.
  46. At all times relevant hereto, Defendant GoodLife Health knew or should have known that Ms. Plaintiff twins were suffering hypoxia on June 20, 2017 and required an emergency cesarean section immediately upon her arrival to Stoneleigh Hospital in order to prevent fetal death, neurological damage, or organ damage.
  47. At all times relevant hereto, Defendant GoodLife Health knew or should have known that to comply with its obligation to ensure the safety and welfare of Plaintiff Mother Plaintiff and her unborn twins (including Baby Plaintiff) that it needed to select and retain competent physicians who were properly trained in obstetrics, gynecology, and maternal-fetal medicine and to supervise all persons such as the Defendants Dr. A and Dr. S who practice obstetrics, gynecology, and maternal-fetal medicine at GoodLife Medical Group, t/d/b/a GoodLife Maternal-Fetal Medicine locations and at Stoneleigh Hospital.
  48. At all times relevant hereto, Defendant GoodLife Health had a duty to supervise the competence of its staff members through the use of safety supervisory tools such as clinical practice guidelines, rules, protocols, checklists, and standing orders that were designed to provide safe and appropriate planning for pregnant women, including assessing and identifying women that are safe to be discharged from the hospital and those that should be delivered and/or admitted for continuous monitoring.
  49. At all times relevant hereto, Defendant GoodLife Health had the non-delegable duty and Plaintiff Mother Plaintiff and Baby Plaintiff, had the right of patient safety supervision so as to ensure her and her twin’s safety and well-being while be treated at Stoneleigh Hospital on June 16, 2017 until June 18, 2017, and on June 20, 2017.
  50. Proper patient safety supervision by Defendant GoodLife Health was not performed because GoodLife health had deliberately and intentionally decided to violate the known legal duty to supervise all persons practicing medicine within the hospital to appease the licensed and trained professional including those charged with preventing hypoxic and permanent injury to high-risk pregnancy patients and their unborn twins. However, Defendant GoodLife Health knew or should have known that the need for patient safety supervision of the medical staff charged with preventing hypoxic and permanent injury to high-risk pregnancy patients and their unborn twins was necessary to ensure the safety and wellbeing of high-risk pregnancy patients such as Mother Plaintiff who is suffering pregnancy complications.

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