HomeMy WebLinkAbout0563 12. As a result of the carelessness and negligence of
the Defendants, decedent continued to deteriorate and she died on
July 14, 1976.
13. That as a result of the carelessness and negligence ;
of the Defendants, the decedent's estate incurred medical expenses ;
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and funeral expenses. ;
14. That as a proximate result of the~carelessness and
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neqlfgence of the .Defendants~, the decedent left as survivors the ~ ~
followinq: Andrew Pride, Husband; Priscilla Pride, daughter;
Andrew Pride, Jr., so~; Angelene Pride, daughter; Phillip Pride,
son; Dexter Pride, son. _ ~
15. That as-a result of the carelessness and-negligence
of.th~ Defendants, the decedent's husband and children have lost ;
the support, services, wifely and parental~companionship, instruction ~
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and guidance of their deceased wife and mother, ~and have suffered ~
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mental pain, sufferinq and anguish as a result of_their wife and '
raother's untimely death and will continue to suffer said losses- '
. and mental pain and anguish in the future. ?
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16. That as a result of the carelessness and negligence ~
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of the Defendants, there has been a loss of the net accumulations ~ ;
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of the decedent's estate.
WHEREFORE, the Plaintiff, ANDREW PRIDE, as Personal Repre--
sentative of the Estate of BETTY JEAN PRIDE, deceased, demands judg-
ment for damages aqainst the Defendant hospital and JOHN J. WILSO*i, ~
M.D., together with costs of trii.s matter and costs of the medical
mediation liability claim nwnber MLMC 77-249 and MLMC 77-543; and
further demands trial by jury. ~
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COUNT II - ~
17. The Plaintiff, ANDREW PRIDE, as ~Personal Representative ~
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for the Estate of BETTY JEAN PRIDE, realleges the allegations of Para- }
graphs 1 throuqh 15 of Count I, as if the same was set forth fully
herein.
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