HomeMy WebLinkAbout0565 , 21. That as a proximate result of the foregoing conduct,
the decedent left as survivors the following: Andrew Pride, Husband;.
Priscilla Prid~, daughter= Andrew Pride, Jr., son; Anqelene Pride, .
daughter; Phillip Pride, sonf Dexter Pride, son. -
22. That as a result of the foregoinq conduct, the ;
decedent's husband and children have lost the support, services, .
wifely and parental companionship, instruction and guidance of
their deceased wife and mother, and have suffered mental pain, ;
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sufferinq and anguish as a result of their wife and mother's untimely-
death and will continue to suffer said losses and mental pain and
anguish into the future.
23. That as a result of the foregoing conduct, there has
been a loss of the net accwnulations of the decedent's estate.
WHEREFORE, the Plaintiff, ANDREW PRIDE, as Personal Repre- k
sentative oE the Estate of BBTTY JEAN PRZDE, deceased, demands judg- ~
ment for both compensatory and punitive damaqes aqainst the Defendant ~
Hospital and JOHN J. WILSON, M.D., toqether with costs of thisJmatter
and the~medical mediation liability claim number I~ff.MC 77-249 and
~iLMC 77-543, and further demands trial by jury. ~ ~
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CUUNT III [
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~4. ~The Plaintiff,-ANDREW PRIDE, as Personal Representative ~
for the Estate of BETTY JEAN PRIDE, reall~ges the allegations of Para-
graphs 1 through 15 of Count I and Paragraphs 17 throuqh 23 of Count II,
as if the same was set forth fully herein. -
25. That the Defendant, JOHN J. WILSON, M.D., and Defendant
Hospital failed to procure and recommend the admission of Plaintiff's
decedent as a patient in the FORT PIERCE MEMORIAL HOSPITAL despite the ~
numerous visits to such hospital by Plaintiff's decedent on June 25,
July 4, July 6,-July and July 8, 1976, where she displayed symptoms
of acute toxic metabolic encephalopathy, or other serious illness, and
where on July 8, 1976,.she was'diagnosed by Dr. Emanuel H. Winocur,
Indian River Hental Health Center, 800 Avenue "H", Fort Pierce, Florida,
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