(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 3) Dr. X. testified that it took only 2 minutes to provide a surgical level of analgesia with a spinal anesthesia (between 11:08 am and 11:10 am). Plaintiff’s expert anesthesiologist will…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Exposing governmental inefficiency and misconduct is a matter of considerable significance. As the Court noted in Connick, public employers should, as a matter of good judgment, be receptive to constructive criticism…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) THIRD CAUSE OF ACTION (Unlawful Retaliation in Violation of Gov’t. Code §12900 et seq. By All PLAINTIFFS Against All Defendants) 39. PLAINTIFFS repeat and reallege the allegations contained in paragraphs 1…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) The mother in Wilks was not present at the exact moment of the specific act of negligence In Wilks, the child was injured; but the mother could claim emotional distress because…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Dr. Stuart X. 1) Although Dr. X. testified that he didn’t recall ever seeing Ms. Cruz in L&D on October 5, the L&D nursing notes clearly place him there at 10:32…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Foundation argues that Smith was terminated for legitimate reasons, cannot prove otherwise by showing that the reasons were pretext for retaliatory animus, and therefore it should prevail on summary judgment. As…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) SECOND CAUSE OF ACTION (Employment Discrimination on Account of Sex in Violation of Gov’t. Code §12900 et seq. By All PLAINTIFFS against all DEFENDANTS) 30. PLAINTIFFS repeat and reallege the allegations…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) While working at Foundation North Side, Ms. Lane made frequent complaints to upper management, including officers and managing agents such as Oliver Browne and Ethan Jones, regarding the failure of Foundation…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) STATEMENT OF FACTS On or about January 8, 2003, at about 1:30 p.m., JAMES PATEL was present in the emergency room when Sundari Patel bled excessively so that Sundari’s bed, arms…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 6) Substandard care to have given Terbutaline at 10:20 am, whether ordered by Dr. U. or not, given the likelihood that the placenta was abrupting (based on irritable uterus, abdominal pain…