(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/elder abuse case and its proceedings.)
Memorandum of Points and Authorities in Support of Defendant TMC, Inc.’s, dba Universal Medical Center’s Motion for Summary Adjudication
INTRODUCTION AND PROCEDURAL BACKGROUND
This motion for summary adjudication is brought on behalf of defendant TMC, Inc., dba Universal Medical Center (hereinafter collectively referred to as “Universal”) against plaintiffs’ first cause of action for wrongful death. Plaintiffs Sean Ryan, Jr. and Nancy Smith (hereinafter collectively referred to as “plaintiffs”) have alleged several additional causes of action against defendants, all of which they claim arose out of the death of their father, Sean Ryan, Sr. (hereinafter “Mr. Ryan”) on June 1, 2008.
Background Facts and Issues Presented
Mr. Ryan was a 61-year-old man weighing over 400 pounds. A neighbor called 911 after Mr. Ryan, had collapsed and was non-responsive for about 15 minutes. Emergency personnel arrived at approximately 2251 and found Mr. Ryan in full arrest with fixed and dilated pupils and cold to the touch. Mr. Ryan was intubated, and the paramedics attempted resuscitation for about 31 minutes, both at his home and en-route to the emergency room. During this time, Mr. Ryan remained non-responsive and had no pulse. The paramedics attempted to insert an intravenous line on-scene, but they were unable to gain access to a vein. Mr. Ryan was brought into the emergency room at Universal Medical Center at approximately 2322, still unresponsive.
Further resuscitation efforts were performed for approximately 23 minutes in the emergency room, to no avail. Mr. Ryan could not be revived, and he was pronounced dead at 2345. (See Part 2 of 10.)
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