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HomeMy WebLinkAbout0567 suf~ered mental pain and anguish as a result of their mother's un- timely'death, and will continue to suffer said losses and mental pain and anquish into the future. . WHEREFORE, the Plaintiff, ANDREW PRIDE, as Personal Repre- sentative of the Estate of BETTY JEAN PRIDE, deceased, 3emands judqment for damages against.the Defendants, JOHN J. WTLSON, M.D., and FORT~ ` - ~ PIERCE MEMORIAL HOSPITAL, toqether with costs of this matter and costs of the medical mediation liability claim number MLMC 77-249 , • i and MLMC 77-543, and further demands trial by jury. ~ ~ ~ ` CO[TNT IV _ ~ ~ 32. Plaintiff, ANDREW PRIDE, individually, realleges t3ie allegations of Paragraphs 1 through 31 of Count I, Count II, and Count III as if the same were set forth fully herein. 33. T~at as a result of the foregoing conduct of the De- fendants, the Plaintiff, ANDREW PRIDE, decedent's husband, has lost ~ t the support and services,~companionship, and has suffered mental pain ' . 3 and suffering as a result of ~the decedent's untimely death, and will ; continue to suffer said losses and mental pain and anguish into the future. ~ . ~ F ~ WgEREFORE, the Plaintiff, ANDREW PRIDE, as Personal Repre- ~ sentative of the Estate of BETTY JEAN PRIDE, deceased, demands judgment ~ ~ 1 for damages against the Defendants, JOAN J. WILSON, M.D., and FORT i j PI-ERCE MEMORIAL H4SPITAL, together with costs of this matter and costs of the medical mediation liability claim number MLMC 77-249 and MLMC 77-543, an~i further demands trial by jury. LIAYD & BROWN Post Office Box 4382 Fort Pierce, Florida 33450 ~ and itlEO ANO RECOROED CONE, OWEN, WAGNER, NUGENT, JOHNSON & McKEOWN, ~P.A. f St•LUC~~ ~O~KTY Ft~ 507 North Olive Avenue, Post Office Box 3466 ~ ROCE~i POITNI?S y ~~ERK CtRCUIt COURT West Palm Beach, Florida 33402 ` ~ ' n~r~p1 VFF fiEO (305j 6 5-8I00 ~ ; ~2 51 PN~~~ Atto s for Plaintiff ~ MaY IT - ' . . . - 4039'~3 By LOUIS M. SILBER -9- ~~287 ~ 5fi~ ~ _ ~ ~ ~ - " ~ ~ ~ ~ , ' ~ ' . ~ .~-'~~£:i~"x'' . .