Fill and Sign the State of Maryland Hereinafter Referred to as the Trustor and the Trustee Form

- 1 - IN THE CIRCUIT COURT OF_________ COUNTY, ____________ NAME OF PLAINTIFF ) )) V. ) NO. )) NAME OF DEFENDANT ) )) COMPLAINT I. Plaintiff, _____________________, is an adult resident citizen of _________________,____________ County, ________________. Defendant, __________________ , M.D., is an adult resident citizen of ____________ County, ________________ who may be served with process of this Court at his office located at __________________, _______________________, ________________. Defendant, ____________________, M.D., is an adult resident citizen of ____________ County, ________________ who may be served with process of this Court at his office located at _____________________, ________________________, ________________. II. On or about _________________ _________, 20_____, Plaintiff came under the treatment and care of Defendant ___________________. On or about _____________ ____________, 20____, Defendant __________ performed a surgical procedure upon Plaintiff during the course of which he was injured. III. The Defendants were guilty of negligence and deviated from the standard of care in their examination, treatment, and care of Plaintiff. IV.
Defendants' conduct constituted a gross violation of the law and the negligent act resulted in plaintiff's injury. Ix. Plaintiff,, claims compensable damages to ( name of plaintiff) ( name of defendant ) . 1 , (name of plaintiff), claims an appropriate remedy of . (name of defendant ), claims an appropriate remedy of . The complaint was filed by john j. Murphy on behalf of himself and his son, daniel j. Murphy. Murphy did not include his wife, linda i. Murphy in her complaint. The complaint alleges that the defendant Daniel murphy performed surgery on his father on January 29, 2005. The complaint states that Daniel murphy is a physician and is in his family practice office in. A copy of the medical record is attached. The complaint states that Daniel murphy performed medical tests on his father and performed a surgical procedure. The complaint asserts that these tests were to be a routine test performed on all the patients of the doctor. The complaint alleges that an assistant performed the surgical procedure on Daniel murphy. Both the surgery on daniel Murphy and the surgical procedure on his father were performed by the doctor himself. Murphy says he was the doctor and was not present during the course of the process. He says that his father had surgery to his stomach, that was not a normal procedure with his father, and he is a doctor himself and knew the risks of anesthesia. Daniel Murphy said that he was very scared of his father the whole time. He says he did not feel the need to do an examination during the time his father was in the surgical room at that hospital. Daniel Murphy stated that after surgery he told his father that he wanted to go home. He asked his father if he wanted him to accompany him home. Daniel Murphy says he never received this request. He says he received it the next day. Daniel Murphy has an attorney , edward p. Foscarinis. Murphy states that he has never been interviewed with the state attorney regarding the investigation. Murphy claims that Toscanini gave the statement to them without his knowledge that these things were not true and said that he wanted to get the matter to a judge. Murphy states that he is afraid of the government and says that he will not cooperate with the government and claims that he is a doctor. He states that Daniel murphy has a history of mental illness and that Murphy had been advised by his own doctor that Daniel murphy's conduct was medically unnecessary