Kelly McCoy PLC – Extreme DUI – Phoenix Attorney Matthew Kelly

patterson_vs_east_valley

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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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

robinson_vs_desantis_east_valley_family_physicians

1

0501-wa

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

MICHAEL K. JERNES Clerk of the Superior Court

BY RUBERT HILL; Deputy

Date 08/27/2002 Time 02:27 Pfl J. Gregory Osborne (8.3. No. 006422) Damflpflm my fimmfi TOLMAN & OSBORNE, P . c. —-——- {3931511 WSW—01656.3 .4.– 1920 E. Southern Avenue, Suite 104 cmfi_mufimflfim1 m1 $300 Tempe, Arizona 85282 —————_—_—~_—m~__~i. ‘l__ (480) 897—1020 TUTHL 914011111 mm

fiaeip- r ‘r Attorneys for Plaintiffs Tfimmm£wmo

SUPERIOR COURT OF ARIZONA

MARICOPA COUNTY

CV2002-016663

STEVE AND SUSAN ROBINSON, Case NO. CV

husband and wife, Plaintiffs,

)

)

)

)

)

VS. ) COMPLAINT )

DONNA M. DESANTIS, M.D. and‘ ) JOHN DOE DESANTIS, wife and ) husband; EAST VALLEY FAMILY ) PHYSICIANS,P.L.C., an Arizona ) Corporation; JOHN AND JANE DOES ) I-V; BLACK AND WHITE CORPORA— ) TIONS VI—X; ABC PARTNERSHIPS ) XIvXV, ) )

)

)

(Tort: Non—Motor Vehicle; Medical Malpractice)

Defendants.

_____________————————————-—-—

For their complaint, plaintiffs allege as follows:

1. Plaintiffs are residents of Maricopa County,

Arizona.

2. Defendants Donna M. DeSantis, M.D. and John Doe DeSantis are now, and at all times material hereto were, residents of Maricopa County, Arizona; the true name of John Doe DeSantis is not presently known to plaintiffs but plaintiffs will seek leave of court to amend their complaint to reflect the true name at such

time as it becomes known. At all times material hereto defendantp—a

nomadic.”th

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Donna M. DeSantis, M.D. acted on behalf of and in furtherance of

her marital community. 3. East Valley Family Physicians, P.L.C. is an.Arizona

Corporation and licensed health care provider. At all times

material hereto, Dr. DeSantis was acting as the agent, servant and/or employee of East Valley Family Physicians, P.L.C.

4. Defendants John Does I—X, Jane Does 17X, Black Corporations I—X, and White Partnerships I—X are the officers,

and/or employees of defendants and their

directors, agents

spouses, who at all times material hereto acted within the course and scope of their employment and/or agency relationship with

defendants and on behalf of and in furtherance of their respective

marital communities; the true names and identities of these defendants are not presently known to plaintiffs, but plaintiffs will seek leave of court to amend their complaint to reflect the true names, together with the appropriate allegations concerning

the conduct of each defendant as it relates to their respective

negligence in rendering health care individually or collectively

as a principal, agent, employee, administrator, manager or director of defendants. 5. At all times material hereto, defendants held

themselves out to the public, and particularly to plaintiff Susan

Robinson, to be health care providers capable of treating

injuries, illnesses and conditions, including those of plaintiff

Susan Robinson, by and through their employees and agents

including the individual and corporate defendants; as such,

-2-1

0501-th

(I)

10 11 12 13 14 15 16 I7 18 19 20 21 22 23 24 25 26

defendants represented to the public and to plaintiffs that they were possessed of and exercised that degree of learning, skill, care, knowledge and diligence required of health care providers of

their respective specialties in the State of Arizona.

6. All acts complained of herein occurred in Maricopa County, Arizona. 7. The amount in controversy exceeds the ‘minimum

amount required for jurisdiction in this Court.

8. During 2001, plaintiff Susan Robinson presented

herself to defendants for examination, diagnosis and treatment of

her complaints.

9. Defendants, including their agents and servants,

were negligent in consulting on, examining, diagnosing and treating plaintiff Susan Robinson.during the above—mentioned times in that they failed to exercise the degree of care and skill

ordinarily exercised by competent physicians, health care

providers, and medical supplier/consultants in similar cases under

similar circumstances.

10. As a direct and proximate result of said

negligence, plaintiff Susan Robinson sustained. permanent and

grievous physical injuries to his person which have caused her pain and substantial discomfort and which will continue in the future to cause pain and discomfort.

11. As a direct and proximate result of the negligence plaintiff Robinson has required the

of defendants, ‘Susan

attendance of physicians and will require further medical care and

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attention in the future; the cost of such future medical care and treatment is not presently known or ascertainable but will be proven at the trial of this matter.

12. As a direct and proximate result of the negligence of defendants, and the injuries suffered thereby, plaintiff Susan Robinson has undergone and will continue to undergo severe physical and mental pain and suffering.

13. As a direct and proximate result of the negligence of defendants, and the injuries suffered thereby, plaintiff Susan Robinson has suffered a loss of earnings.

14. As a direct and proximate result of the negligence of defendants, and each of them, and the injuries suffered by his wife, Susan Robinson, plaintiff Steve Robinson has been deprived

of the care, comfort, consortium and advice of his wife and is

entitled to damages therefore. WHEREFORE, for judgment against

plaintiffs pray

defendants as follows:

1. For reasonable damages for medical expenses incurred by plaintiff Susan Robinson as of the date of the Complaint, plus an amount to be determined as and for the reasonable future medical expenses to be incurred by plaintiff Susan Robinson.

2. For reasonable damages as and for the past and future physical and mental pain and suffering, and embarrassment

caused by the injury sustained by plaintiff Susan Robinson.

3. For reasonable damages for lost wages and loss of

earning capacity sustained by plaintiff Susan Robinson.

-4-0‘01th

\1

10 11 12 13 14 15 16 17 18 19 20 21 22 23

24 25

26

4. For reasonable loss of consortium damages to Steve

Robinson for the loss of care, comfort, consortium and advice of

Susan Robinson. 5. For plaintiffs“ costs incurred and expended in this

lawsuit.

6. For such other and further relief as this Court may

deem just and appropriate.

. Gr ry Osborne 920 Southern, Suite 104 Temp , Arizona 85282

Attorneys for Plaintiffs

timothy_baker_vs_mindy_baker_maricopa

,—

Thomas J. Griggs (LD. No.006690)

LAW OFFICES Killian, Nicholas, Fischer,

Wirken, Cook & Pew, P.L.C.

SUITE 200 40 NORTH CENTER STREET no. BOX 1467 MESA, ARIZONA 85211 (602) 461-4600

Attomeysfor Petitioner

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA

In re the marriage of TIMOTHY P. BAKER

Petitioner, PETITION FOR DISSOLUTION OF MARRIAGE With Children)

and

MINDY K. BAKER

Respondent.

Petitioner, TIMOTHY P. BAKER, by his undersigned attorneys, for his Petition

for Dissolution of Marriage, alleges as follows:

I That the petitioner’s true name is TIMOTHY P. BAKER, that petitioner’s birthdate is June 6, 1963, that petitioner’s address is 11625 South Appaloosa, Phoenix, Arizona 85044; that petitioner’s occupation is medical doctor; that the respondent’s true name is MINDY K. BAKER, that respondent’s birthdate is September 20, 1963, that respondent’s address is 3935 East Park Avenue, Phoenix, Arizona 85044; that Respondent is presently

unemployed, but is employable. Respondent is not pregnant at this time.

WIOSQ 01II That the petitioner and respondent have been domiciled in the State of Arizona for period of ninety (90) days prior to the filing of this Petition. III That the petitioner and respondent were married on or about the 11th day of June, 1983 in Phoenix, Arizona, and ever since that time have been and now are husband and wife. IV That the marriage between the petitioner and respondent is irretrievably broken and there is no reasonable prospect of reconciliation. V That the conciliation provisions ofA.R.S. § 25-38109 either do not apply or have been met. VI That there have been born as issue of this marriage two children, both of whom are minors, namely: GARRETT R. date of birth October 19, 1991; and EMILY S. date of birth April 30 1993; and within the last five years have lived with both Petitioner and Respondent at the 11625 South Appaloosa, Phoenix, Arizona address and prior to that at 4831 East Boston Street, Chandler, Arizona 85226. That there shall be a sole custody order issued in this case with Respondent/Wife as the custodial parent for the parties’ minor children. Petitioner has not participated as a party, witness, or in any other capacity, in any other litigation, concerning the custody of the minor children in this or any other State, has no information of any custody proceedings concerning the minor children pending in a court of this or any other state, and knows of no person not a party to these proceedings who has physical custody of the minor children or claims to have

custody or visitation rights with respect to the minor children.

00105620] ‘2’In

VII That the Petitioner is an able-bodied man currently employed and capable of paying a reasonable amount as and for child support both pendente lite and permanently; that the petitioner lacks sufficient funds and property to provide for these matters and is

unable to support herself and the minor children of the parties. Therefore, Petitioner

alleges that he has committed to the Respondent that he should also pay Spousal

maintenance. VIII

That there are no written agreements between the parties as to support, custody and visitation of the children and maintenance of either spouse. The parties have had

discussions which Petitioner believes will result in written agreements.

IX That the parties hereto have acquired community, joint and common property, and

joint, common and community debt. There should be an equitable division of joint,

common and community property and debt. X

That each party shall be. responsible to pay his or her own attorneys fees and costs

incurred in this matter. WHEREFORE, the petitioner requests as follows: 1. That the Court order a Decree of Dissolution of Marriage, dissolving the

marriage existing between the parties and that the parties be restored to the status of

single persons; 2. That there be a sole custody order issued in this case with regard to the

custody of the minor children with Respondent/Wife being the custodial parent in this

case, subject to guideline access for the Father as a minimum;

ODWSGZDI3. That the Petitioner be ordered and required to pay to the petitioner a reasonable amount to be determined by the Court as and for child support for the benefit of the parties’ minor children;

4. That Petitioner shall pay to the Respondent spousal maintenance to be allocated in this matter;

5. That the Court fix its order equitably ordering the payment and discharge of the community obligations of the parties;

6. That the Court fix its order equitably dividing the property acquired by the parties during their marriage;

7. That the Court affirm to the parties their sole and separate property, if any;

8. For such other and further relief as the Court may deem just and proper in

the law.

9. That each party be responsible to pay his or her attorneys fees and costs

incurred in this matter.

DATED this [2: day of . , 1994.

KILLIAN, NICHOLAS, FISCHER, WIRKEN, COOK & FEW, P.L.C.

Attorneys For Petitioner

omosazm ’4’STATE OF ARIZONA ) County of Maricopa SS-

TIMOTHY P. BAKER, being first duly sworn upon his oath, deposes and says that he is the Petitioner in the foregoing Petition for Dissolution of Marriage; that he has read the foregoing instrument and knows the contents thereof; that the facts alleged therein are

true except those alleged upon information and belief and as to those, he believes them to be true. % . B R

SUBSCRIBED AND SWORN to before me this [,2 day of

m m, [M 1 , 1994, by TIMOTHY P. BAKER.

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My Commission Expires:

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0010562131 ‘5‘

ronald_sell_vs_sandee_sell_maricopa

K. JEfifiES

‘:.L he Super’mr {hurt

sxnesmmsflmssw;

Law offices of _. fl , – I …. + s A amt

1811 5. Alma School Road, Suite 225 BESE’rELpiL an ‘89:“ “—.—_’— 1′ L”. 4‘ E Mesa, Arizona 85210 L’ “4} ““ ’unu

DIVERSE fig SHELB £02 081 i£§.efi Salmig駥¥§fiY ISTAL éfifififii iéfieflc

(480) 345-8404 State Bar #005525 Attorneys for

Petitioner

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

IN AND FOR THE COUNTY OF HARICOPA

In re the marriage of ) – -‘ ) DR2000-092975 RONALD J. SELL, ) no, ) Petitioner. ) PETITION FOR DISSOLUTION ) OF MARRIAGE and ) ) SANDER BERRY SELL, ) ) Respondent; )

)

_______________—————-————

COMES NOW the Petitioner, RONALD J. SELL, by and through his undersigned counsel, and for his Petition for Dissolution of Marriage herein states and alleges as follows:

I That Petitioner’s name is RONALD J. SELL; he is presently forty-three (43) years of age, being born on July 30, 1956; he is presently employed as a physician; he has been domiciled within the State of Arizona for more than ninety (90) days prior to the commencement of this action.

Petitioner’s residence address is 4280 West Dublin Street,

Chandler, Arizona 85226.John R. Zarzynski 1811 5. Alma School Road, Suite 225 Mesa. Arizona 85210 (480) 345-8404

II Respondent’s name is SANDEE BERRY SELL; she is presently fifty (50) years of age, being born on December 16, 1949; she is employed as a census worker/craft maker and she has been domiciled within the State of Arizona for more than

ninety (90) days prior to the filing of the Petition for

Dissolution of Marriage herein. Respondent’s residence

address is 4280 West Dublin Street, Chandler, Arizona 85226. III The parties were married on or about June 19, 1999 in Mesa, Arizona. IV That the marriage of the parties is irretrievably

broken and that there is no reasonable prospect of

reconciliation. The conciliation provisions of A.R.S. 525—

381.09 either do not apply or have been met.

V

There are no minor children common to the parties of the marriage and Petitioner/Wife is not now pregnant. VI The parties entered into a written Prenuptial Agreement, a copy of which is attached hereto as Exhibit A. Said Prenuptial Agreement meets the general qualifications of

A.R.S. 525-201 et. seq. and defines the rights andAlma School Road, Suite 225 (480) 345-8404

John R. Zarzynski Mesa, Arizona 85210

S.

responsibilities of the parties in the event of a dissolution

of marriage.

VII That during coverture, to the extent that the parties have acquired certain joint, common or community property and incurred certain debts and obligations, this

Court should divide them equitably. VIII

Neither party is entitled to an award of spousal

maintenance.

WHEREFORE, the Petitioner/Husband requests the

following relief:

1. That the Court enter a Decree of Dissolution of Marriage and restore each of the parties to the status of

single persons.

2. That neither party be ordered to pay spousal

maintenance.

3. That the separate property of the parties as

defined by law and pursuant to their Prenuptial Agreement be

confirmed to each of them.

4. That to the extent that the parties have acquired joint, common or community property and obligations,

that said property and obligations should be divided equitably

between them.John R. Zarzynski 1811 S. Alma School Road, Suite 225

Mesa, Arizona 85210 (480) 345-8404

5. For such other and further relief as the Court

deems just and proper under the circumstances.

DATED this 1t) day of

LAW OFFICES OF JOHN R.

, 2000.

ZARZYNSKI

Joh R. Zarzy Attorney for PetitionerJohn R. Zarzynski

1811 5. Alma School Road,

Suite 225

Mesa, Arizona 85210 (480) 345-8404

EEBLELQéElQE

STATE OF ARIZONA ) ) ss. )

County of Haricopa

RONALD J. SELL, being first duly sworn, upon his

oath deposes and says:

1. That he is the Petitioner in the above matter;

2. That he has read the foregoing Petition for

Dissolution of Marriage and knows the contents thereof,

and

that the matters and things stated therein are true to t e

best of his knowledge, information and belief.

SUBSCRIBED AND SWORN to before me, the undersigned

Notary Public, this SC) day of §x>§3 54 , 2000.

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