GEORGE L. MALLORY, JR. ASSOCIATES 1925 Century Park East, Suite 2000 Los Angeies, CA 90067~2701 (310) 783-5555 15mGEORGEL MALLORY, JR ESQ. (SBN 86311) . it GEORGE L. MALLORY, JR. 1925 Century Pa1k East, Suite 2000 1.931113 Los Angeles, California 90067?2701 Telephone: (310) 7886555 acsimile: (310) 78 8-5 5 70 Attorneys for Plaintiff E: MEGHAN YOUNG ruf?wmmw i APR i 3 2005 1101-1111 BQE: DE 11W SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 1Q0507E3 MEGHAN YOUNG, an individual; - CASE NO.: COMPLAINT FOR MEDICAL NEGLIGENCE AND DAMAGES Plaintiff, VS. 3 RIFAAT D. SALEM, M.D., PH.D., an individual, PACIFIC COAST REPRODUCTIVE CENTER MEDICAL CLINIC, INC., a California ceiporation; PACIFIC COAST SURGICAL CENTER, a Califomia co1p01ation; and DOES I through) 100, Inclusive, Defendants. Plaintiff, MEGHAN YOUNG, hereby alleges against Defendants, and each of them, as follows: FIRST CAUSE oF ACTION $1 171 (Medical Negligence) $3 a; :13" ?135; 1. The true names or capacities of the Defendants, DOES 1 tin ough I00, whef?eii?f air? :31? individual, 001 porate associate or otherwise, are unknown to Plaintiff at the time of filing ti-h Earl 1 a n4 5,3 :1 1:33: thin: E?k} L61: ANGELES COURT 3:1?ng fig? 1.434COMPLAINT FOR MEDICAL NEGLIGENCE AND DAMAGES Los Angeles, CA 90067-2701 GEORGE L. MALLORY, JR. ASSOCIATES 1925 Century Park East, Suite 2000 (310) 7885555 (Th Complaint and Plaintiff therefore, sues said Defendants by such ?ctitious names and will seek leave of Court to amend this Complaint to show their true names or capacities when the same have been ascertained. Plaintiff is informed and believes, and thereon alleges, that each of the DOE Defendants is, in some manner, reSponsible for the events and happenings herein set forth which proximately caused injury and damages to the Plaintiff as hereinafter alleged. 2. That at all times herein mentioned, Defendants, RIFAAT D. SALEM, M.D., and DOES 1 through 20, inclusive, and each of them, were doctors, nurses, attendants, employees, assistants, and consultants, and the like of Defendants, PACIFIC COAST REPRODUCTIVE CENTER MEDICAL CLINIC, INC. and PACIFIC COAST SURGICAL CENTER, and DOES 1 through 100, inclusive. 3. Defendants, PACIFIC COAST REPRODUCTIVE CENTER MEDICAL CLINIC, INC., and DOES 21 through 40, are and were at all times herein, hospitals, clinics and/0r health care facilities duly organized, existing and licensed under and by Virtue of the laws of the State of California and/or authorized to do business and doing business in the County of Los Angeles, State of California. 4. Defendants, PACIFIC COAST SURGICAL CENTER, and DOES 41 through 60, are and were at all times herein, hospitals, clinics andf or health care facilities duly organized, existing and licensed under and by virtue of the laws of the State of California and/or authorized to do business and. doing business in the County of Los Angeles, State of California. 5. That at all times herein mentioned, Defendants, RIFAAT D. SALEM, M.D., PACIFIC COAST REPRODUCTIVE CENTER MEDICAL CLINIC, INC, PACIFIC COAST SURGICAL CENTER, and DOES 1 through 100, and each of them, were the agents, servants, and employees, assistants and consultants of their co-defendants and were, as such, acting within the course, scope and authority of said agency and employment, and that each and every Defendant, as -2- COMPLAINT FOR MEDICAL NEGLIGENCE AND DAMAGES GEORGE L. MALLORY, JR. ASSOCIATES 1925 Century Park East, Suite 2000 Los Angeles, CA 90067-2701 (310) 788-5555 aforesaid, when acting as a principal, was negligent in the selection and hiring of each and every other Defendant as an agent, servant, employee, assistant, consultant or hospital staff member. 6. That on or about January 5, 2004, and thereafter, Plaintiff, MEGHAN YOUNG consulted and engaged for compensation, the services of Defendants, RIFAAT SALEM, M.D., PACIFIC COAST REPRODUCTIVE CENTER MEDICAL CLINIC, INC., PACIFIC COAST SURGICAL CENTER, and DOES 1 through 100, inclusive, and each of them, to examine, diagnose, care for and treat Plaintiff Within the medical/surgical standard of care for injuries and problems involving her well?being. 7. That on or about I y52004 eieafter Defendants RIFAAT D. SALEM, M.D., PACIFIC COAST-REPRODUCTIVE CENTER MEDICAL CLINIC, IN C., PACIFIC COAST SURGICAL CENTER, and DOES 1 through 100, and each of them, undertook to perform a surgical treatment of Plaintiff. 8. That during the aforesaid surgical procedure the care and treatment of Plaintiff was below the standard of care in that Defendants, and each of them, negligently failed to possess and to exercise that degree of knowledge and skill ordinarily possessed and exercised by other doctors, medical facilities, hospitals, nurses, attendants, and the like, engaged in said profession in the same or similar locality as the said Defendants, and each of them. 9. . 10. On January 20, 2005, Plaintiff sent a Notice of Intent to Sue letter pursuant to Code of Civil Procedure 364, to Defendants, RIFAAT D. SALEM, M.D., PACIFIC COAST REPRODUCTIVE CENTER MEDICAL CLINIC, IN C., PACIFIC COAST SURGICAL CENTER, and DOES 1 through 100, inclusive. -3- COMPLAINT FOR MEDICAL NEGLIGENCE AND DAMAGES Los Angeles, CA 90067-2701 GEORGE L. MALLORY, JR. ASSOCIATES 1925 Century Park East Suite 2000 (310) 733-5555 10direct and proximate result of the negligence, carelessness, recklessness, wantonness, and unlawfulness of the Defendants and each of them, Plaintiff MEGHAN YOUNG sustained severe and serious injury and permanent dis?guration to her person, all to Plaintiff damage in a sum Within the jurisdiction of this Court and to be shown according to proof. 12. By reason of the foregoing, Plaintiff MEGHAN YOUNG has been required to employ the services of hospitals, physicians, surgeons, nurses and other professional services, and Plaintiff has been compelled to incur expenses for ambulance service, medicines, X-rays, and other medical supplies and services. Plaintiff is infOrmed and believes, and thereon alleges, that further services of said nature will be required by Plaintiff in an amount to be shown according to proof. 13. By reason of the foregoing, Plaintiff MEGHAN YOUNG is informed and believes, and upon such information and belief, alleges that she will be unable to work at any gainful employment for an inde?nite period in the future, all to Plaintiff?s damage in an amount to be shown according to proof. PRAYER WHEREFORE Plaintiff MEGHAN YOUNG prays for judgment against the Defendants, and each of them, as follows: A. General damages in a sum according to proof; B. Sums incurred and to be incurred for services of hospitals, physicians, surgeons, nurses and other medical supplies and services; I C. Loss of income incurred and to be incurred according to proof; I I -4- COMPLAINT FOR MEDICAL NEGLIGENCE AND DAMAGES GEORGE L. MALLORY, JR. ASSOCIATES 1925 Century Park East, Suite 2000 Los Angeles, CA 90067-2701 (310) 788-5555 Interest provided by law including, but not limited to, California Civil Code 3291; and E. Costs of suit and for such other and further relief as the Court deems proper. DATED: April 8, 2005 GEORGE L. MALLORY, JR. ASSOCIATES By: GE . ALLORY, JR. Attorn 0r Plaintiff MEGHAN YOUNG -5- COMPLAINT FOR MEDICAL NEGLIGENCE AND DAMAGES