Complaint for Medical Negligence

COMPLAINT

COMES NOW the Plaintiff, by and through the undersigned counsel, and files this his Complaint against the Defendant, and would show unto the Court the following, to-wit:

1. Plaintiff is an adult resident citizen of County, residing at

2. Defendant, is an adult resident citizen of County, and may be served with process of this Court at his business address,

3. On or about the Plaintiff, sought and received treatment from the Defendant, for an infected tooth at Defendant's office in

4. Defendant, was negligent and deviated from the standard of care during his examination, treatment and care of the Plaintiff. Defendant deviated from the standard of care and was negligent, including but not limited to, as follows:

a. In failing to obtain an adequate history on the plaintiff prior to treating him;

b. In extracting a tooth without properly determining the extent of an infection;

c. In failing to maintain and follow-up the condition of the Plaintiff following the extraction;

d. In leaving on an extensive vacation without making necessary arrangements for follow-up treatment in the event Plaintiff required additional medical treatment.

5. As a direct and proximate result of the Defendant's negligence, Plaintiff developed a metastatic liver abscess and endocarditis. Plaintiff was required to undergo lengthy hospitalization and has incurred hospital, doctor, drug and other medical expenses. As a result of Defendant's negligence, Plaintiff received permanent injuries and will continue to incur hospital, doctor, drug and other medical related expenses in the future.

WHEREFORE, PREMISES CONSIDERED, Plaintiff demands judgment of and from the Defendant in the sum to compensate plaintiff for damages incurred, attorney fees and all costs accruing in this action.

RESPECTFULLY SUBMITTED,