COURT OF COMMON PLEAS HAMILTON COUNTY, OHIO THEODORE DOYLE PLAINTIFF, V. MOUNT VERNON MEDICAL CENTER, ET AL. DEFENDANTS.

MOTION INDEPENDENT MEDICAL EXAM OF PLAINTIFF THEODORE DOYLE JUDGE: JEFF RUBEL CASE: A-147507

COMES NOW Defendant, Mount Vernon Medical Center, asks this Court to order Plaintiff, Theodore Doyle, to submit to a physical examination and provides the following in support of its motion: 1. This is a case in which the Plaintiff, Theodore Doyle, alleges that he suffered an allergic reaction to a specific type of contrast medium dye that was inserted in his body to visualize Plaintiff Doyles internal organs. As a result of that procedure, don e by Defendant Abigail Roosevelt, Plaintiff Theodore Doyle had suffered cardiac arrest. 2. Defendant, Mount Vernon Medical Center, denies that Plaintiff, Theodore Doyle, was injured as a result of the alleged incident of the contrast medium being entered into the body. Therefore the physical condition of Plaintiff, Theodore Doyle, is in controversy. 3. A physical examination of Plaintiff, Theodore Doyle, present condition is relevant and essential for Defendant, Mount Vernon Medical Center, to properly prepare a defense of the action brought against it.

4. Defendant, Mount Vernon Medical Center, desires Plaintiff, Theodore Doyle, to be examined by Dr. Greg Patton a Cardiologist specializing in the area of the diagnosis of the heart and blood vessels. Defendant, Mount Vernon Medical Center, would like to ask Dr. Greg Patton to examine the heart of Plaintiff, Theodore Doyle, and check to see if a pre-existing condition affected the procedure.

WHEREFORE, Defendant, Mount Vernon Medical Center, respectfully requests the Court to enter an order directing the Plaintiff, Theodore Doyle, to attend and undergo a physical examination by Dr. Greg Patton at his offices on April 1, 2014 at 1:00 PM at the address 666 Doctor's Blvd. Cincinnati, OH 45202.

Respectfully Submitted, ___________________ Bruce Davis, (12345) Bruce Davis LLC Trial Attorney for Defendant 123 Main Street Batavia, OH 45103 513-867-6367 Fax: 513-263-4377 Brucedavis@uc.edu

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the Motion to take the Physical Examination of Plaintiff, Theodore Doyle, has been furnished to A. Page Beetem and the Plaintiff of record on this nineteenth day of February 2014. Physical Examination shall be sent to 123 Batavia, OH 45103. Main Street

___________________ Bruce Davis, (12345) Trial Attorney for Defendant