SUPERIOR COURT FOR THE STATE OF CALIFORNIA IN THE COUNTY OF ORANGE. Plaintiffs, Defendants

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1 BRODIE & FLOCKHART MICHAEL A. BRODIE (State Bar No. 0) MONICA M. FLOCKHART (State Bar No. 1001) Chardonnay Irvine, California Telephone No. () - / Facsimile No. () 1- Attorneys for Plaintiffs, TAYLEE BLISCHKE, a Minor, by and through her Guardian Ad Litem, JESSICA BLISCHKE; JEESICA BLISCHKE, individually; and TODD BLISCHKE SUPERIOR COURT FOR THE STATE OF CALIFORNIA IN THE COUNTY OF ORANGE TAYLEE BLISCHKE, a Minor, by and through her Guardian Ad Litem, JESSICA BLISCHKE; JEESICA BLISCHKE, individually; and TODD BLISCHKE vs. Plaintiffs, MISSION HOSPITAL REGIONAL MEDICAL CENTER; CHILDREN'S HOSPITAL AT MISSION; and DOES 1 through 0, inclusive CASE NO. COMPLAINT FOR (1) MEDICAL MALPRACTICE; () INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; () NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS 1 1 Defendants FIRST CAUSE OF ACTION (Medical Malpractice on behalf of Plaintiff, TAYLEE BLISCHKE, a Minor, by and through her Guardian Ad Litem, JESSICA BLISCHKE Against all Defendants) Plaintiffs, TAYLEE BLISCHKE, a Minor, by and through her Guardian Ad Litem, JESSICA BLISCHKE; JEESICA BLISCHKE, individually; and TODD BLISCHKE, allege: 1. Plaintiff, TAYLEE BLISCHKE, is a minor (DOB: 0/0/0) and therefore brings this Complaint for Damages through his mother and Guardian Ad Litem, JESSICA 1 C:\DOCUMENTS AND SETTINGS\JHOROWITZ.USA\DESKTOP\BLISCHKE COMPLAINT FOR MEDICAL MALPRACTICE.WPDCOMPLAINT FOR DA

2 BLISCHKE. Plaintiffs, JESSICA BLISCHKE and TODD BLISCHKE are the parents of Plaintiff, TAYLEE BLISCHKE.. The true names, identities, or capacities, whether individual, associate, corporate or otherwise, of Defendants, DOES 1 through 0, inclusive, are unknown to Plaintiffs who, therefore, sue said Defendants by such fictitious names. When the true names, identities or capacities of said fictitiously designated Defendants are ascertained, Plaintiffs will ask leave of Court to amend the Complaint to insert said true names, identities or capacities together with proper charging allegations.. Plaintiffs are informed and believe and, therefore, allege that each Defendant sued herein as a DOE is responsible in some manner for the events and happenings herein referred to, thereby proximately causing the injuries and damages to the Plaintiffs.. All facts, acts, events, and circumstances herein mentioned with reference to Defendants occurred in the County of Orange, State of California.. Within one (1) year prior to the service upon Defendants of Notice required by California Code of Civil Procedure, Plaintiffs discovered the Defendants negligence.. Defendants, MISSION HOSPITAL REGIONAL MEDICAL CENTER and CHILDREN'S HOSPITAL AT MISSION and DOES 1 through 0, inclusive, are healthcare facilities licensed by the State of California to provide medical care and other ancillary services and whose business organization are unknown. Said Defendants held out to the public at large and to Plaintiffs, as properly equipped, fully accredited, competently staffed and qualified with prudent physicians, nurses and other medical care personnel and that all said personnel were operating within the standard of care.. At all times herein mentioned, Defendants were acting as agents, employees and/or servants of some or all of the other Defendants, within the course and scope of their agency or employment.. At all times herein mentioned, the Defendants, and each of them, were the C:\DOCUMENTS AND SETTINGS\JHOROWITZ.USA\DESKTOP\BLISCHKE COMPLAINT FOR MEDICAL MALPRACTICE.WPDCOMPLAINT FOR DA

3 agents, servants, employees, and joint ventures of each other and of their said Co-Defendants, and were acting within the purpose and scope of their employment, agency, or joint venture.. Plaintiffs name Defendants herein, and each of them, because Plaintiffs are in doubt and do not know exactly from which of the Defendants Plaintiffs are entitled to redress and whether the injuries and damages herein alleged were caused by the combined negligence of all the Defendants or by the concurrent or successive and separate negligence of the Defendants and/or one or more of them. For that reason, Plaintiffs name all of said Defendants and ask that the court determine the liability of each and all of the Defendants in this action and to what extent and what responsibility falls upon each of the said Defendants and that the court award judgment to Plaintiffs as against such or all of the Defendants, either jointly or severally, as may be found liable.. In holding themselves out as experts and specialists in their field of medicine, possessing skill, learning and expertise in said fields, Defendants herein represented themselves to Plaintiffs that they would at all times exercise and use skill, prudence, learning, knowledge and expertise in the care and treatment of Plaintiff, TAYLEE BLISCHKE, in accordance with the standard of practice among competent, reputable, and prudent physicians and medical facilities and/or medical groups undertaking the diagnosis and treatment of patients such as Plaintiff, TAYLEE BLISCHKE.. On April,, at approximately 01 hours, Plaintiff, JESSICA BLISCHKE, for valuable consideration and remuneration, presented herself to the aforesaid Defendants, for the purpose of primary cesarean delivery of her triplets at weeks gestation by Scott Capobianco, M.D. Upon admission to the hospital, Plaintiff, JESSICA BLISCHKE, specifically provided a history of no alcohol use, no cigarette use, no marijuana use, no cocaine

4 use, no meth use and no other illicit drug use.. At 000 hours on April, 0, Plaintiff, TAYLEE BLISCHKE, was delivered. She was the smallest of the triplets and weighed 1 grams (lbs. oz.) and had APGAR scores of at 1 minute and at minutes. Tasha Blischke was delivered at 001 hours on April, 0, weighing 0 grams ( lbs. oz.) and with APGAR scores of at 1 minute and at minutes. Tessa Blischke was delivered at 00 hours on April, 0, weighing 1 grams ( lbs. oz.) and with APGAR scores of at 1 minute and at minutes. The neonatologist in the operating room assessed all three babies as physically normal, but transferred them to the Neonatal Intensive Care Unit (NICU) at 0 hours because of their prematurity. 1. Following delivery, Plaintiff, JESSICA BLISCHKE, received orders for numerous medications. In particular, on April, 0, Dr. Capobianco ordered - mg of Morphine IV Push to be administered by Defendants every two hours, as needed for pain. There was no physician order for Morphine for any of the babies, including Plaintiff, TAYLEE BLISCHKE. 1. According to the medical records, on April, 0, Defendants administered Morphine IV Push to Plaintiff, JESSICA BLISCHKE,.0 mg at 0 hrs and at 100 hours and.0 mg at 1 hours. On April, 0, she received.0 mg at 0 hours. 1. Notwithstanding the above, and despite the fact that Morphine had only been ordered for Plaintiff, JESSICA BLISCHKE, on or about April, 0, Defendants negligently administered to Plaintiff, TAYLEE BLISCHKE, Morphine via IV Push. On that date, when Plaintiff, TAYLEE BLISCHKE, was in the arms of her mother, JESSICA BLISCHKE, she stopped breathing, tuned limp and became dusky. 1. At 00 hours on April, 0, the physicians diagnosed Plaintiff, TAYLEE BLISCHKE, with several seizures that required intubation and ventilator support. They performed several tests to try to determine the cause of those seizures, including a urine drug

5 screen. On April, 0, that urine drug screen was positive for Morphine, which was determined to be the cause of Plaintiff, TAYLEE BLISCHKE S symptoms, including, but not limited to, stopping breathing, limpness and duskiness. 1. As a result of the carelessness, recklessness, negligence, lack of due care, prudence reasonable judgment, and concern for the welfare of Plaintiff, TAYLEE BLISCHKE, she has suffered and continues to suffer pain, anxiety, and mental anguish as hereinafter alleged. As a result of the aforesaid negligence, Plaintiff, TAYLEE BLISCHKE, has suffered and continues to suffer from severe and permanent disabling injuries and damages. 1. As a further result of the negligence of Defendants, and each of them, Plaintiff TAYLEE BLISCHKE, has incurred, and will continue to incur medical expenses. The full amount of such expense is not known to Plaintiffs at this time, but will br provided at the time of trial. 1. The negligent acts or omissions of Defendants, and each of them, in the care given to Plaintiff, TAYLEE BLISCHKE, were a legal cause of the damages heretofore alleged. SECOND CAUSE OF ACTION (Intentional Infliction of Emotional Distress on behalf of Plaintiffs, JESSICA BLISCHKE, individually and TODD BLISCHKE against all Defendants). Plaintiffs incorporate by reference as if fully set forth herein, the allegations set forth in Paragraphs 1 through 1 above.. On or about April, 0, when the Defendants diagnosed that Plaintiff, TAYLEE BLISCHKE, had Morphine in her system and despite the fact that Plaintiff, JESSICA BLISCHKE, had clearly indicated in her pre-admission history that she did not use cocaine, meth or any other illicit drugs, they intentionally and wrongfully accused Plaintiff, JESSICA

6 BLISCHKE, that she was the source of such Morphine. Plaintiff, TODD BLISCHKE, was present at the time of said accusations.. Defendants continued to accuse Plaintiff, JESSICA BLISCHKE, of being the source of the Morphine in Plaintiff, TAYLEE BLISCHKE S system, refusing to believe that she took no drugs during the course of her pregnancy with the triplets and trying to coverup their own misconduct. It was not until after the other two triplets, Tasha Blischke and Tessa Blischke tested negative for Morphine, did Defendant reluctantly admit that it was their negligent conduct, and not any conduct on the part of Plaintiff, JESSICA BLISCHKE, that was the source of Plaintiff, TAYLEE BLISCHKE S Morphine.. Plaintiffs herein, and each of them, are informed and believe and upon information and belief allege that Defendants, and each of them, knew, or should have known that their conduct as herein alleged, would reasonably expose persons, including Plaintiffs to probable serious harm and resultant emotional distress and in fact did cause to Plaintiffs such serious harm and emotional distress. Based thereon, Plaintiffs are informed and believe and upon such information and belief allege said injuries were foreseeable and the direct result of the acts, omissions and conduct of the Defendants and each of them.. As a result of said conduct by Defendants, and each of them, Plaintiffs have suffered the injuries and damages herein outlined. THIRD CAUSE OF ACTION (Negligent Infliction of Emotional Distress on behalf of Plaintiffs, JESSICA BLISCHKE, individually and TODD BLISCHKE, against all Defendants). Plaintiffs incorporate by reference as if fully set forth herein, the allegations set

7 forth in Paragraphs 1 through above. 1. On or about April, 0, when the Defendants diagnosed that Plaintiff, TAYLEE BLISCHKE, had Morphine in her system and despite the fact that Plaintiff, JESSICA BLISCHKE, had clearly indicated in her pre-admission history that she did not use cocaine, meth or any other illicit drugs, they negligently and wrongfully accused Plaintiff, JESSICA BLISCHKE, that she was the source of such Morphine. Plaintiff, TODD BLISCHKE, was present at the time of said accusations.. Defendants continued to accuse Plaintiff, JESSICA BLISCHKE, of being the source of the Morphine in Plaintiff, TAYLEE BLISCHKE S system, refusing to believe that she took no drugs during the course of her pregnancy with the triplets and trying to coverup their own misconduct. It was not until after the other two triplets, Tasha Blischke and Tessa Blischke 1 tested negative for Morphine, did Defendants reluctantly admit that it was their negligent 1 conduct, and not any conduct on the part of Plaintiff, JESSICA BLISCHKE, that was the 1 source of Plaintiff, TAYLEE BLISCHKE S Morphine. 1. Plaintiffs herein, and each of them, are informed and believe and upon 1 information 1 and belief allege that Defendants, and each of them, knew, or should have known that their 1 conduct as herein alleged, would reasonably expose persons, including Plaintiffs to probable serious harm and resultant emotional distress and in fact did cause to Plaintiffs such serious harm and emotional distress. Based thereon, Plaintiffs are informed and believe and upon such information and belief allege said injuries were foreseeable and the direct result of the acts, omissions and conduct of the Defendants and each of them.. As a result of said conduct by Defendants, and each of them, Plaintiffs have suffered the injuries and damages herein outlined.

8 WHEREFORE, Plaintiffs pray judgment against the Defendants, and each of them, as follows: On the First Cause of Action: 1. For general damages;. For special damages according to proof at the time of trial;. For prejudgment interest according to proof at the time of trial;. For costs of suit incurred herein; and. For such other and further relief as may seem proper to this Court. On the Second Cause of Action: 1. For general damages;. For special damages according to proof at the time of trial;. For prejudgment interest according to proof at the time of trial;. For costs of suit incurred herein; and. For such other and further relief as may seem proper to this Court. On the Third Cause of Action: 1. For general damages;. For special damages according to proof at the time of trial;. For prejudgment interest according to proof at the time of trial;. For costs of suit incurred herein; and. For such other and further relief as may seem proper to this Court. DATED: May, BRODIE & FLOCKHART By: MICHAEL A. BRODIE MONICA M. FLOCKHART Attorneys for Plaintiffs, TAYLEE BLISCHKE, a Minor, by and through her Guradian Ad Litem JESSICA BLISCHKE; JESSICA BLISCHKE, individually; and

9 TODD BLISCHKE

10

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