Fill and Sign the Medical Malpractice Form

- 1 - IN THE _____________ COURT OF _____________ COUNTY, _____________ ______________________ PLAINTIFF VS. NO._____ ______________________ DEFENDANT COMPLAINT COMES NOW _____________, Plaintiff, by and through counsel, and files this Complaint against _____________ and for cause of same would state the following: 1. That Plaintiff is an adult resident citizen of _____________ County, _____________. 2. That the Defendant, _____________, is a non-profit corporation existing and doing business pursuant to the laws of the State of _____________. That the Defendant may be served with the process of this Court by service of process upon its registered agent, _____________, __________________________, _____________(city), _____________(state) or upon such other persons authorized to be served by the _____________ Rules of Civil Procedure at its business address, _______________________________________. 3. That between _____________ and _____________, Plaintiff sought and received medical treatment at the Defendant's facility in _____________, under the primary care of Dr. _____________, a physician employee of the Defendant. That at all times related hereto, Dr. _____________ was the employee of the Defendant and Defendant was and is liable for the actions, omissions and negligence of said employee. 4. That Plaintiff's primary complaints related to severe abdominal pain, swelling, and nausea. That these symptoms persisted throughout her treatment without a diagnosis of the particular cause of the symptoms, physical illness or condition that afflicted the Pla intiff, notwithstanding Defendant's treatment, by and through its' employee, Dr. _____________, medical tests and medications. 5. That on or about _____________, Plaintiff was treated by physicians who immediately diagnosed, Cholecystitis with stones and common duct stones, hospitalized Plaintiff, performed surgery and removed 12 gall stones, the largest of which measures 1 x 2 cm. Following the cholecystectomy and common duct exploration, Plaintiff made a normal rec overy and returned to full normal health. - 2 - 6. That the Defendant, by and through its' employee physician _____________, was negligent in failing to diagnose Plaintiff's medical condition and render treatment c onsistent with a proper diagnosis. 7. That Defendant's negligence directly and proximately resulted in unnecessary severe physical, mental and emotional pain and suffering and unnecessary medical trea tment, tests and expense over a period of twenty months and Plaintiff is entitled to recover da mages of from and against the Defendant for said negligence. WHEREFORE, Plaintiff files this Complaint and demands judgment of, from and against the Defendant in the sum of $_____________ actual damages together with prejudgment interest and all costs of court accrued herein. Respectfully submitted, _________________________