(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) LIABILITY: Regional Medical Center: Hospital nursing personnel fell below the standard of care in the following areas: 1) Regardless whether Ms. Cruz or the breech patient arrived at the hospital first,…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Nursing notes picked up again in the OR. The first reference after 10:52 am was at 11:05, with Ms. Cruz in the OR. The anesthesia record of Dr. X. referred to…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) After her second call to the main OR, charge Nurse E. went to the main OR herself to see what could be done to expedite the delivery for Ms. Cruz, who…
IN AN ACTION TO RECOVER FOR PERSONAL INJURIES TO A CHILD, SPECIAL DAMAGES INCLUDE THE REASONABLE VALUE OF HOME ATTENDANT CARE PROVIDED BY THE CHILD’S PARENTS The defense cannot bring up the quality of the care given to the minor by the parents in order to reduce the damages. The…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) According to the deposition testimony of nurses E. and F., the breech patient arrived after Ms. Cruz in L&D. Nurse E. did a physical examination and found the patient to be…
THE PARENTS’ QUALITY OF CARE FOR THE CHILD IS IRRELEVANT The defense has no admissible testimony that the quality of care given to the minor child by his parents has in any manner contributed to the condition from which the child suffers. The child’s suffering and severe brain damage has…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) On arrival at Regional Medical Center, the systolic pressure on Ms. Cruz was 138. Her blood sugar was relatively low. Nursing personnel were aware of a history of pregnancy-induced hypertension (PIH)…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Plaintiffs’ Trial Brief on the Quality of Parents’ Care (Hanif) MEMORANDUM OF POINTS AND AUTHORITIES INTRODUCTION This is a medical negligence action wherein the minor Plaintiff, DANIEL YAMAMOTO, a Roseville resident,…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) FACTS: Due to absence of comprehensive nursing notes on Ms. Cruz while she was in L&D, exceedingly poor memories of the witnesses whose depositions have been taken to date, and a…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) At 10:20 am, Dr. U. was informed by L&D personnel (while operating on the breech patient) that the FHR on Ms. Cruz had fallen further. As a result, Dr. U. called…