Personal Injury Lawyer Blog
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this medical malpractice case and its proceedings.)
COMPLAINT FOR DAMAGES (1) Negligence/ Medical Malpractice; (2) Willful Misconduct and Battery
[Brought by Plaintiff Sura Bhandi as against all Defendants]
COUNT ONE: NEGLIGENCE/ MEDICAL MALPRACTICE
1. Plaintiff Sura Bhandi is, and at all times relevant to the matters resident of Sacramento County.
2. Defendant Wellness Center (WELLNESS) is a California corporation, which does business in Sacramento County, and which is engaged, among other things. in the business of rendering chiropractic and other health care and services to the general public for compensation, and which held itself out to the general public and to Plaintiff Sura Bhandi to be competent in rendering chiropractic and other care and services.
3. Defendant Tim Jones, D.C., is a chiropractor, licensed to practice in the State of California, who held himself out to the general public and to Plaintiff Sura Bhandi to be competent and skilled in rendering chiropractic and health care, and to render such chiropractic and health care with the same skill, prudence, and diligence as other members of his profession commonly possess and exercise.
4. The true names and capacities, whether individual, corporate, associate, or otherwise, of Defendants DOES 1 through 100, inclusive, are unknown to Plaintiff who therefore sues said DOE Defendants by fictitious names.
Plaintiff is informed and believes and thereon alleges, that each of the Defendants sued herein as a DOE is legally responsible in some manner for the events and happenings referred to herein, and Plaintiff will ask leave of this Court to amend this complaint to insert their true names and capacities in place and instead of the fictitious names when the same becomes known to Plaintiff. (See Part 2 of 4.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.