It is worth noting that situations similar to those described in this traumatic brain injury case could just as easily occur at any of the healthcare facilities in the area, such as Kaiser Permanente, UC Davis Medical Center, Mercy, Methodist, or Sutter.
(Please also note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this personal injury lawsuit and its proceedings.)
STATEMENT OF FACTS
FACTUAL ALLEGATIONS THAT SUPPORT PRAYER FOR PUNITIVE DAMAGES
On June 16, 2009, shortly before 1:00 p.m., David Hall, a pedestrian, was proceeding on the eastern sidewalk of University, near the intersection of Smith Road, in Sacramento. Dr. Brown was driving east on University. Dr. Brown fell asleep while driving and drove up and onto the raised sidewalk and struck David from behind. David flew violently onto the hood and smashed into the windshield, then up onto the roof. David was carried approximately 59 feet east before being thrown off the top of the vehicle. Dr. Brown, while still asleep, then dragged David approximately 38 feet where she ultimately ran over him.
On June 16, 2009, Dr. Brown was working as a medical resident at Universal Hospital in Sacramento, California, which is owned and operated by Defendant County Medical Center
(“CMC”). Plaintiff alleged that immediately prior to the incident, Dr. Brown worked excessive hours, including but not limited to an overnight shift after inadequate rest and without any rest. Dr. Brown acted recklessly and with a willful and conscious disregard of the rights or safety of others by driving a vehicle in a fatigued condition when she knew or should have known that she was not capable of safely driving home. (Id.) (See Part 3 of 9.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.