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AMEN
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AMENDED COMPLAINT
TYPE: MEDICAL MALPRACTICE;
WRONGFUL DEATH
CV-2016-07-3112
AMEN
07/26/2016 14:29:23 PM
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and
TeamHealth
Attention: Risk Manager
265 Brookview Centre Way, Suite 400
Knoxville, TN 37919
Defendants
Now comes Martin Karl Schmidt, Individually and as Administrator of the Estate of
Jaen Anne Prell Schmidt, Deceased, by and through undersigned counsel, and for his
complaint states as follows:
FIRST CLAIM FOR RELIEF
1.
Schmidt, Deceased, by the Probate Court of Summit County, Ohio being Case Number
2015 ES 01837, The Plaintiff brings this wrongful death action as personal representative
for the exclusive benefit of the surviving next of kin of the Decedent, Jean Anne Prell
Schmidt.
2.
That during the period of January 23, 2015 through January 28, 2015, the
CV-2016-07-3112
3.
AMEN
07/26/2016 14:29:23 PM
That as a direct and proximate result of the joint, combined, and concurrent
negligence of the Defendants, their agents, servants and employees, the Decedent, Jean
Anne Prell Schmidt died on January 28, 2015. Jean Anne Prell Schmidt is survived by
Martin K. Schmidt and other next of kin, all whom are beneficiaries of this action.
4.
The beneficiaries and next of kin of Jean Anne Prell Schmidt have suffered
damages for the loss of services for the time that she was expected to live.
5.
The beneficiaries of Jean Anne Prell Schmidt have suffered damages for the
loss of society over her life expectancy, including the loss of companionship, care,
assistance, attention, advice, counsel, guidance, comfort, society, and consortium.
6.
The beneficiaries and next of kin of Jean Anne Prell Schmidt have suffered
damages for the mental anguish caused by her death and her pain and suffering.
7.
The beneficiaries and next of kin of Jean Anne Prell Schmidt have suffered
That Plaintiff, Martin Karl Schmidt, Administrator of the Estate of Jean Anne
Prell Schmidt, Deceased, brings this action for the injuries and damages sustained to Jean
Anne Prell Schmidt prior to her death for the benefit of the Estate of Jean Anne Prell
Schmidt.
10.
That as a direct and proximate result of the joint, combined and concurrent
negligence of the Defendants, their agents, employees and servants, Jean Anne Prell
Schmidt suffered pain and mental anguish prior to her death.
CV-2016-07-3112
11.
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That Jean Anne Prell Schmidt, deceased, incurred hospital and medical
expenses prior to her death and thereafter up to and including the time of her death.
THIRD CLAIM FOR RELIEF
12.
That the Estate of Jean Anne Prell Schmidt has incurred reasonable funeral
That as a direct and proximate result of the joint, combined and concurrent
negligence of the Defendants, their agents, employees and servants, Jean Anne Prell
Schmidt suffered a delay in her diagnosis; serious personal injuries; unnecessary pain and
suffering; loss of chance of cure; suffered great pain, mental anguish, emotional distress
and further claims that because of the medical negligence that occurred, that she
sustained an increased risk of harm.
16.
Plaintiff further states that as a direct and proximate result of the joint,
combined and concurrent negligence of the Defendants, their agents, employees and
servants, Jean Anne Prell Schmidt required the care of physicians and other health care
providers and that said care and treatment was more extensive because of the medical
negligence that occurred.
CV-2016-07-3112
AMEN
07/26/2016 14:29:23 PM
Respectfully submitted,
PERANTINIDES & NOLAN CO., L.P.A.
/s/Paul G. Perantinides
______________
PAUL G. PERANTINIDES (0006618)
Attorney for Plaintiff
300 Courtyard Square
80 South Summit Street
Akron, OH 44308-1736
(330) 253-5454
(330) 253-6524 Fax
Email: paul@perantinides.com
JURY DEMAND
Plaintiff hereby demands a trial by jury on all issues contained in Plaintiffs
Complaint.