i PATTERSON,
vs.
CATHOLIC HEALTHCARE WEST = ARIZONA, an Arimna corporation, dba 5 CHANDLER REGIONAL HOSPITAL 1 ‘ (fka EAST VALLEY REGIONAL ; HEALTH SYSTEM, dba CHANDLER
’ HEALTH CARE ASSOCIATES, LTD,
i 13.0., dba CHANDLER SURGERY : CENTER ASSOCIATES; WWI-ER.
, EAST VALLEY OFFICE ASSOCIATES, 1 a partnership; EAST VALLEY MEDICAL OFFICE ASSOCIATES II, a
OFFICE ASSOCIATION, a partnership;
‘» L. EASTON, DD. and JOHN DOE
LAW OFFICES
Hassle-r Pmumao Pomens a Cuuumennm Puc
PARK WHOM m 101 831 EAST cm POST OFFICE BOX 13388 PHOENIX. “EDNA anon-sun (cm 371-3544 FAX (502) m WBWOWHLWA’IT-HET
Frank 1. Powers (Bar No. 013369)
‘ Attorneys for Plaintifl’
By MI W: Demty Date 0351/2000 Time 12:54 PM Descriptim Qty meow: —-— GASES: W ———~ GIUIL BER 38mm? 901 1619.09
—-——~.—-—……___
IN THE SUPERIOR COURT OF THE STATE OF ARIZONA
IN AND FOR THE COUNTY OF MARICOPA I
RUSSELL FAT-mason, mm spouse ) ofGLORIA PATTERSON, deceased, ) and on behalfof JOSEPH )
‘i PATTERSON and LAWRENCE BROWN, )
mvingnatwalchfldrenofGiflRIA
P1. .3;
REGIONAL HOSPITAL); WOMEN’S
an Arizona oorporafion; H C. WATTERS,
MEDICAL ASSOCIATES, a parma’sbip;
partnership; EAST VALLEY MEDICAL
H. C. WATI‘ERS, 13.0., and JANE DOE WATTERS, husband and wife; DIANE
VVVVVVVVVVVVVVVVVVWVVVVVVVV
N“ omega-006138
COMPLAINT
(Medical Negligence)
2613-002«omummhmmé-
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N 00
. .
EASTON, wife and husband; EAST ) VAIJEY FMY MEDICAL, P.C., an ) Adzona corporation, aka EAST VALLEY ) FMY MEDICINE; CARDIAC ) DIAGNOSTIC INSTITUTE, L.L.C., an ) )
~ Afizona limited liability corporation; –
VICTOR BONELA, MD, dba CARDIAC ) INSTITUTE GENERAL PARTNERSHIP; ) CHANDLER DIAGNOSTIC m
a Wship; VICTOR R BONHLA, MD. and JANE DOE BONBLA,
husband and wife; BRUCE EICH, MD. and JANE DOE EICH,
husband and wife; OLE-GEORG TDRIUSEN, MD. and JANE DOE TORJUSEN, 1111is and wife;
BONNIE HARE, NP. and JOHN DOE HARE, wife and husband; MARY MAUDE WYER, NP. and JOHN DOE mm wife and husband; MARY MARGARET WYEK RN. and JOHN ROE MEYER, wife and husband; LINDA YESS, GNP. and JOHN DOE YESS, wife and lmsband; JOHN and JANE DOES I-V; BLACK
and WHITE CORPORATIONS I—V,
VVVVVWVUVWWWWVVVVVV
Defendants.
PlaintiffRussell Patterson, through counsel, for his claim against the Defendants,
alleges as follows:
I.
The Parties at all times relevant hereto were residents of andior doing business in
Maficopa County, State of An’zona.
All events complained of owned within Malicopa County, Arizona
11.III.
Plainfifi’Russell Patterson is the surviving spouse of Gloria Patterson, now He brings this claim on behalf of himself individually, as well as Ioseph Patterson and Lawrence Brown, surviving natural adult children of Gloria Patterson.
IV.
Defiandant Catholic Healthcare West Arizona, an Arizona corporation, dba Chandler Regional Hospital (formerly known as East Valley Regional Health System dba Chandler Regional Hospital) is a foreign corporation authorized to conduct business within the State of Arizona, with aprincipal place ofbusiness and/or agents andlor property within Mmicopa County, Arizona. Said Defendant is authorized to engage in the business of providing health care and medical services to memba’s ofthe public, and said Defendant and its employees and agents provided services to Gloria Patterson, deceased.
V.
Defendant Women ’s Health Care Associates, Ltd is an Anmna commotion organized and ezdslingunderthelaws ofthe State ofArizona, withitsprinoipalplamofbusiness andior agents andfor property within Maficopa County, Arizona. Said Defendant is authorized to engage in the husinessofprovldinghwlthcareandmedical servicestomembers ofthe public, and saidDefendant and its elnployees and agents provided services to Gloria Patterson, deceased.
V’L
Defendant Chandler Surgery Center Associates is a registered fictitious name for H. C. Wetters, D.O., organized and existing under the laws of the State of Arizona, with its principal place of business and/or agents andlor property within Marieopa County, Said Defendant
ismflrofizedtoengageinthebusinessofprovidinghealthcareandmedionl sewicestomembersof
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N MN MNNNHHHI—IHHHHHH
the public, and said Defendant and its employees and agents provided services to Gloria Patterson, deceased? VII.
Defmdant Warner Medical Associates is a partnership organized and under the laws of the State of Arizona, with its principal place of business and/bf agents and/or property within Maficopa County, Arizona. Said Defendant is authorized to engage in the business of providing health care and medical services to members of the public, and said Defendant and its employees and agents provided services to Gloria Patterson, deceased.
VIII.
Defendant East Valley Ofiice Associates is a partnership organized and existing under the laws of the State of Arizona, with its principal place of business and/or agents and/or property within Mp3 County, Arizona. Said Defendant is authorized to engage in the business ofprovidinghealthcare andmedical servicesto membersofthe public, and saidDefendarnandits employees and agents provided services to Gloria Patterson, deceased.
IX
Defendant East Valley Medical Office Associates II, is a permership organized and existing under the laws of the State of Arizona, with its principal place of business and/or agents andfor property within Maficopa County, Arizona. Said Defendant is authorized to engage in the business ofproviding health care and medical services to members ofthe public, and said Defendant and its employees and agents provided services to Gioria Patterson, deceased.
I X. Defendant East Valley Medical Ofice Association is a partnership organized and
existingunderthelawsofflieStateofArizona,withitspfincipalpiaoeofbusinessand/oragem
.4. ‘ 2613-002