RETURN DATE: JUNE 5, 2018 JOHN P. GALLAGHER, ADMINISTRATOR OF THE ESTATE OF MAURA B. GALLAGHER, Plaintiff, v. STAMFORD HEALTH, INC. d/b/a STAMFORD HOSPITAL, THE STAMFORD HOSPITAL, THE HEALTH SYSTEM, INC., ASTRID M.D., KIGER, LAU, M.D., HEALTH CONNECTICUT, INC., PHYSICIANS FOR WOMENS HEALTH, LLC, OBSTETRICS GYNECOLOGY ASSOCIATES, OBSTETRICS GYNECOLOGY ASSOCIATES, P.C., MARIA MAZZEO, M.D., and STAMFORD ANESTHESIOLOGY SERVICES, P.C., PLA COUNT ONE: SUPERIOR COURT JUDICIAL DISTRICT OF STAMF LK MAY 8, 2018 (As to Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital, and The Stamford Health System, Inc. for Medical Malpractice/Wrongful Death) 1. On or about June 9, 2017, John P. Gallagher was appointed Administrator of the Estate of Maura B. Gallagher, deceased, by order of the Darien New Canaan Probate Court, District Number PD52. 2. John P. Gallagher, as Administrator of the Estate of Maura B. Gallagher (hereinafter ?Administrator?) brings this Medical Malpractice/Wrongful Death claim pursuant to Connecticut General Statutes 52-555 for the death of Plaintiff decedent, Maura B. Gallagher ?Maura?), to recover all damages to which the Estate of Maura B. Gallagher is legally entitled to recover under said statute, including, but not limited to, both economic and non-economic damages. 3. This Complaint for damages alleges the failures of Defendants, Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital, The Stamford Health System, Inc., Astrid Hoffmann?Olsen, M.D., Kiger Lau, M.D., Women's Health Connecticut, Inc., Physicians For Womens Health, LLC, Obstetrics Gynecology Associates, Obstetrics Gynecology Associates, P.C., Maria Mazzeo, M.D., and Stamford Anesthesiology Services, P.C., individually, and through their agents, apparent agents, servants, and/or employees, to provide proper medical care and treatment to Maura, and alleges that said failures were the proximate cause of Maura?s death. 4. At all relevant times hereto, Defendant, Stamford Health, Inc. d/b/a Stamford Hospital, was and is a hospital or other entity organized pursuant to the laws of the State of Connecticut with a place of business of One Hospital Plaza, Stamford, CT 06904. 5. At all relevant times hereto, Defendant, The Stamford Hospital, was and is a hospital or other entity organized pursuant to the laws of the State of Connecticut with a place of business of One Hospital Plaza, Stamford, CT 06904. 6. At all relevant times hereto, Defendant, The Stamford Health System, Inc., was and is a hospital or other entity organized pursuant to the laws of the State of Connecticut with a place of business of One Hospital Plaza, Stamford, CT 06904. 7. At all relevant times hereto, Defendant, Stamford Hospital was a medical facility, owned and operated by Stamford Health Inc. and/or The Stamford Health System, Inc., which operated a hospital in Stamford, Connecticut comprised of physicians specializing in obstetrics, gynecology, anesthesiology, in-house and attending physicians and surgeons and other health care professionals, that provided medical services to the general public and, more speci?cally herein, to the decedent, Maura B. Gallagher. 8. At all relevant times hereto, Defendant, Astrid Hoffmann-Olsen, M.D., was and is a physician, duly licensed to practice medicine in the State of Connecticut, that specialized in and was board-certi?ed in the area of Obstetrics and Gynecology. 9. At all relevant times hereto, Defendant, Kiger Lau, M.D., was and is a physician, duly licensed to practice medicine in the State of Connecticut, that specialized in the area of Obstetrics and Gynecology. 10. At all relevant times hereto, Defendant, Women's Health Connecticut, Inc., was and is a medical group with offices in Stamford, Connecticut, including at 29 Hospital Plaza, Suite 400, Stamford, CT 06902, specializing in the assessment, care and treatment of women in the areas of Obstetrics and Gynecology. 11. At all relevant times hereto, Defendant, Physicians For Womens Health, LLC, was and is a medical group with of?ces in Stamford, Connecticut, including at 29 Hospital Plaza, Suite 400, Stamford, CT 06902, specializing in the assessment, care and treatment of women in the areas of Obstetrics and Gynecology. 12. At all relevant times hereto, Defendant, Obstetrics Gynecology Associates, was and is a medical group with of?ces in Stamford, Connecticut, including at West Broad Street, Stamford, CT 06902, specializing in the assessment, care and treatment of women in the areas of Obstetrics and Gynecology. 13. At all relevant times hereto, Defendant, Obstetrics Gynecology Associates, P.C., was and is a medical group with offices in Stamford, Connecticut, including at 190 West Broad Street, Stamford, CT 06902, specializing in the assessment, care and treatment of women in the areas of Obstetrics and Gynecology. 14. At all relevant times hereto, Defendant, Maria Mazzeo, M.D., was and is a physician, duly licensed to practice medicine in the State of Connecticut, that specialized in and was board~ceitif1ed in the area of Anesthesia. 15. At all relevant times hereto, Defendant, Stamford Anesthesiology Services, P.C., was and is an Anesthesia group with of?ces in Stamford, Connecticut, including at 4 Hospital Plaza, Stamford, CT 06902, that provides Anesthesia services to pediatric and adult patients. 16. At all relevant times hereto, Defendant, Astrid Hof?nann-Olsen, M.D., Was a physician employed by, contracted to, and/or was a servant, agent, apparent agent and/or employee of Stamford Hospital (and/or Stamford Health, Inc. and/or The Stamford Health System, Inc., and/or Women's Health Connecticut, Inc., and/or Physicians For Womens Health, LLC, and/or Obstetrics Gynecology Associates, and/or Obstetrics Gynecology Associates, RC), and who in or about May 2017, was responsible for providing medical care to persons admitted as patients, including Maura. 17. At all relevant times hereto, Defendant, Kiger Lau, M.D., was a physician employed by, contracted to, and/or was a servant, agent, apparent agent and/or employee of Stamford Hospital (and/or Stamford Health, Inc. and/or The Stamford Health System, Inc., and/or Women?s Health Connecticut, Inc., and/or Physicians For Womens Health, LLC, and/or Obstetrics Gynecology Associates, and/or Obstetrics Gynecology Associates, PC), and who in or about May 2017, was responsible for providing medical care to persons admitted as patients, including Maura. 18. At all relevant times hereto, Defendant, Maria Mazzeo, M.D., was a physician employed by, contracted to, and/or was a servant, agent, apparent agent and/or employee of Stamford Hospital (and/or Stamford Health, Inc. and/or The Stamford Health System, Inc., and/or Stamford Anesthesiology Services, PO), and who in or about May 2017, was responsible for providing medical care to persons admitted as patients, including Maura. 19. On or about May 8, 2017, Maura was an admitted obstetrics and gynecology patient at Stamford HOSpital. 20. At all relevant times during this hospitalization, Maura was under the care and supervision of medical personnel employed by and/or contracted to Stamford Hospital, acting in the course and scope of their respective employment, including as servants, agents, apparent agents and/or employees. 21. At all relevant times mentioned herein, Defendants, Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital, The Stamford Health System, Inc., Astrid Hoffmann-Olsen, M.D., Kiger Lau, M.D., Women's Health Connecticut, Inc., Physicians For Womens Health, LLC, Obstetrics Gynecology Associates, Obstetrics Gynecology Associates, P.C., Maria Mazzeo, M.D., and Stamford Anesthesiology Services, PO, individually, and through their agents, apparent agents, servants, and/or employees, had concurrent control and acted in concert with each other herein as to the healthcare, treatment, monitoring, diagnosing and supervision of the plaintiff?s decedent, Maura. 22. At all relevant times mentioned herein, Maura had a laboratory work-up including a complete blood count with differential, at Defendants, Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital, The Stamford Health System, Inc., on May 5, 2017, at the request and direction of Defendants, Astrid Hof?nann?Olsen, M.D., Kiger Lau, M.D., Women's Health Connecticut, Inc., Physicians For Womens Health, LLC, Obstetrics Gynecology Associates, and/or Obstetrics Gynecology Associates, PC. 23. At all relevant times mentioned herein, the May 5, 2017 laboratory work- up including a complete blood count with differential, at Defendants, Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital, The Stamford Health System, Inc., on May 5, 2017, at the request and direction of Defendants, Astrid Hoffmann-Olsen, M.D., Kiger Lau, M.D., Women's Health Connecticut, Inc., Physicians For Womens Health, LLC, Obstetrics Gynecology Associates, and/or Obstetrics Gynecology Associates, PC. was not communicated to, or requested by, Defendants, Astrid Hoffmann?Olsen, M.D., Women's Health Connecticut, Inc., Physicians For Womens Health, LLC, Obstetrics Gynecology Associates, and/or Obstetrics Gynecology Associates, PC. at any time prior to the morning of May 8, 2017. 24. At all relevant times mentioned herein, Maura presented to Defendants, Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford HOSpital, The Stamford Health System, Inc., on the morning of May 8, 2017 with thrombocytOpenia and elevated urine protein, indicative of Preeclampsia. 25. At all relevant times mentioned herein, Defendants, Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital, and/or The Stamford Health System, Inc., are vicariously liable and responsible for the negligent acts and/or omissions of their respective agents, apparent agents, servants, and/or employees, inclusive of physician, nurse and physician assistant personnel, such as: Astrid Hoffmann-Olsen, M.D. Kiger Lau, M.D. Maria Mazzeo, M.D. (Anesthesiology); Dr. Rakos (?rst name currently unknown); Karen L. Brown, Princess Johns, Ahem, RN (?rst name currently unknown); Sco?eld, RN (first name currently unknown); and Sharpe, RN (?rst name currently unknown); Praveen Reddy, MD. (Internal Medicine); Michael Bernstein, MD. (Pulmonary/Critical Care); and Daniel Brooks, M.D. (Neurology). 26. At all relevant times mentioned herein, Defendants, Women's Health Connecticut, Inc., Physicians For Womens Health, LLC, Obstetrics Gynecology Associates, and/or Obstetrics Gynecology Associates, P.C., are vicariously liable and responsible for the negligent acts and/or omissions of their respective agents, apparent agents, servants, and/or employees, inclusive of physician, nurse and physician assistant personnel, such as: Astrid Hoffmann-Olsen, M.D. and Kiger Lau, MD. 27. At all relevant times mentioned herein, Defendant, Stamford Anesthesiology Services, RC, is vicariously liable and responsible for the negligent acts and/or omissions of its respective agents, apparent agents, servants, and/or employees, inclusive of physician, nurse and physician assistant personnel, such as: Maria Mazzeo, M.D. (Anesthesiology). 28. At all relevant times mentioned herein, Maura was preeclamptic on May 5, 2017, in need of delivery of her twins on that day, the following day, May 6, 2017, and the following day May 7, 2017. 29. All of the pertinent events, at Defendants, Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital, The Stamford Health System, Inc., with regards to the claimed negligent acts and/or omissions of these Defendants occurred on May 8, 2017. 30. At or about Maura was admitted to Stamford Hospital at 37+4 weeks, for a primary Cesarean section, of fraternal twins. 31. At or about Maura complained of some difficulty breathing, with a history of low platelet count (98,000) from three days prior. 32. At or about 8: 15AM, a repeat platelet count (84,000) came back even lower. 33. At or about the Anesthesia pre-op was completed. 34. At or about Maura?s Urine Chemistry showed a high total protein of 15.3. 35. At or about Maura began receiving anesthesia in prep for her Cesarean section twin delivery, with a pre-induction blood pressure of 170/76mmHg. 36. At or about Maura was given Phenylephrine 200 for nausea and blood pressure drop post-spinal anesthesia. 37. At or about the first incision was made as part of the Cesarean section surgery for delivery. 38. At or about a male baby (Thomas) was delivered. 39. At or about a female baby (Layla) was delivered. 40. Between at or about to 11AM, Maura experienced decrease in blood pressure with resulting nausea, vomiting, and headache. 41. Also, between at or about and 1 1AM to 1 Maura received a total of 40mg or 50mg of Ephedrine, to raise her blood pressure. There is no indication in the record why this drug was used, at that time, in that close. 42. Between 1 1AM and 1 Maura received 30mg of Ketorolac (Toradol). 43. At or about Maura suffered a seizure, that was erroneously listed in the medical record as ?an anxiety attack and ?a panic attack?, despite Maura showing clinical of headache, vomiting, shaking/shivering, and shortness of breath. 44. At or about Maura received Midazolam 3mg IV and Labetalol 20mg IV in response to the underdiagnosed seizure. 45. At or about the Cesarean section surgery ended. 46. At or about anesthesia ended. 47. At or about 1 1:3 8AM, upon entry to the Post Anesthesia Care Unit, Maura?s blood pressure was 152/76mmHg. 48. Dr. Hoffmann-Olsen?s Operative report indicates that ?intraoperatively? Maura ?developed severe range blood pressures and a headache?. 49. Dr. Lau?s Delivery Summary indicates that ?In the operating room, [Maura] deve10ped severe range blood pressures and a headache.? 50. At all times during the Cesarean section surgery, Maura?s systolic blood pressure was above 140mmHg. 51. From the post-delivery time period of approximately through approximately Maura made consistent complaints of nausea, vomiting, and headache. 52. Maura?s postoperative complaints of nausea, vomiting, and headache, once out of the operating room, were being treated with Tylenol, Zofran, and Reglan. 53. At or about and Maura received multiple doses of Magnesium Sulfate. 54. At or about Maura had a blood pressure of 162/85. 55. At or about Maura had a blood pressure of 169/87. 56. At or about a call was placed for a Rapid Response Team to Maura?s room, #1404, due to Maura having suffered from acute loss of consciousness, unresponsiveness, and agonal breathing. Maura was rushed to radiology for a CT of her brain. 57. At no time prior to was Maura ever evaluated by any physician or consult in the ?elds of radiology, neurology, neuroradiology, or neurosurgery. 58. At or about Maura?s Magnesium Sulfate level was elevated to 4.5. 59. At or a about Maura was given Calcium Gluconate 1,000 mg IV to attempt to address Magnesium Sulfate toxicity. 60. At or about 3PM, Dr. Mazzeo was called to Maura?s room to assist with airway management. 61. By 3: 15PM, the brain CT con?rmed a massive intracerebral hemorrhage that was non-survivable. Maura was brain dead, with no chance of recovery. 62. The Anesthesia Record, as edited by Dr. Maria Mazzeo at indicates: ?Addended notes, deleted it, re-entered it.? 63. The Anesthesia Record, as edited by Dr. Maria Mazzeo at indicates: ?Pre-op was deleted by computer system upon unlocking chart to addend notes, pre-op re- entered.? 64. The Anesthesia Record, as edited by Dr. Maria Mazzeo at indicates: ?Toradol for pain management was cleared by the OB team, was removed from Pyxis, and chatted, but was set aside and not given. On further thought, administration was deferred for patient?s low platelet count. In my haste to care for patient, the medication record was not updated to re?ect the deferral of Toradol administration.? 65. At or about Maura underwent a ?rst brain death exam. 66. Maura was pronounced dead at on May 9, 2017. 67. The Stamford Hospital autopsy report, as authored by Dr. Robert C. Babkowski, purports to be unable to ?de?nitively? determine the cause of the brain bleed, which was undoubtedly the cause of death. However, Dr. Babkowski relies on incorrect and incomplete information regarding the extent of hypertension and the closeness of the monitoring of the patient, in arriving at his conclusion. 68. While under the care, treatment, monitoring, and supervision of the Defendants, Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital, The Stamford Health System, Inc., Astrid Hoffmann-Olsen, M.D., Kiger Lau, M.D., Women's Health Connecticut, Inc., Physicians For Womens Health, LLC, Obstetrics Gynecology Associates, Obstetrics Gynecology Associates, P.C., Maria Mazzeo, M.D., and Stamford Anesthesiology Services, P.C., Maura suffered severe, painful injuries and sickness which continued over a number of hours as set forth herein, ending in death. 69. The aforementioned injuries and death suffered by Maura B. Gallagher were caused by the failure of Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital and the Stamford Health System, Inc. and/or its servants, agents, apparent agents and/or employees, to exercise reasonable care under all of the facts and circumstances then and there existing, by engaging in conduct that was negligent and below the applicable standard of care, in that they: a) Failed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; b) Underdiagnosed the extent and severity of Maura?s preeclampsia; c) Undertreated the extent and severity of Maura?s preeclampsia; d) Improperly managed Maura?s preeclampsia; e) Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford HOSpital on May 8, 2017; f) Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; g) Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; h) Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; i) Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; j) Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; k) Failed to prOperly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; 1) Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; m) Failed to properly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; n) Failed to properly manage Maura?s fluid levels, at any and all times prior to her brain bleed; . 0) Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; p) Failed to deliver Maura?s twins in a tirnelier manner; q) Failed to place Maura in a scheme of care designed to deliver Maura?s twins on May 5th, 6th or 7th of 2017 based on the laboratory data available on May 5, 2017; and r) Improperly deferred Maura?s postpartum medical management to non-physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 70. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent, suffered injuries, sickness and death as a result of the defendants? failure to exercise that degree of care and skill ordinarily and customarily used by Medical Doctors, Registered Nurses, Licensed Practical Nurses, under all the circumstances then and there present in that they failed to timely and properly recognize and treat the signs and of a preeclampsia that was improperly permitted to continue into the postpartum period, resulting in an eclampsia with subsequent hypertensive intracerebral hemorrhage and death. 71. As a direct and proximate result of the aforementioned medical negligence the plaintiff?s decedent suffered extreme emotional distress, mental and physical pain, and her untimely death from failure to diagnose and treat her illness. 72. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent lost her life and her ability to enjoy and engage in life?s activities. At the time of her death, Maura was a 38-year-old woman who had prior to May 2017, been in relative good health. Her death destroyed her ability to carry out life's activities, including the ability to earn income and enjoy her family and friends, including her newborn children, resulting in substantial loss and damage to her estate. 73. Maura?s untimely death also destroyed her ability to pursue life's activities and enjoy the usual pleasures of life all to her loss and detriment. 74. As a result of her death, Maura?s estate incurred expenses for ?meral and related expenses. 75. As a direct and proximate result of the aforementioned medical negligence, the plaintiff? decedent suffered conscious pain and suffering. 76. At all relevant times mentioned herein, Defendants Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital, and The Stamford Health System, Inc., demonstrated great insensitivity and callousness by forcing Maura?s family to be subjected to unnecessary administrative procedures before relinquishing Maura?s newborns to the family, all within hours of Maura?s tragic and unexpected passing. COUNT TWO: (As to Women?s Health Connecticut, Inc., Physicians for Womens Health, LLC, Obstetrics Gynecology Associates, and Obstetrics Gynecology Associates, P.C. for Medical Malpractice/Wrongful Death) 1-67. Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 67 of COUNT TWO as if more fully set forth herein. 68. During the course of said hospitalization, the defendants, Women?s Health Connecticut, Inc., Physicians for Womens Health, LLC, Obstetrics Gynecology Associates, and Obstetrics Gynecology Associates, PC. and their agents, servants, apparent agents and/or employees, deviated from applicable standards of care in one or more of the following ways, in that they: a) Failed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of prOper care, treatment and management in a timely and appropriate manner; b) Underdiagnosed the extent and severity of Maura?s preeclampsia; c) Undertreated the extent and severity of Maura?s preeclampsia; d) Improperly managed Maura?s preeclampsia; e) Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; t) Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; g) Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; h) Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; j) k) 1) p) q) Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; Failed to deliver Maura?s twins in a timelier manner; Failed to place Maura in a scheme of care designed to deliver Maura?s twins on May 5th, 6th or 7th of 2017 based on the laboratory data available on May 5, 2017; and Improperly deferred Maura?s postpartum medical management to non-physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, the plaintiff? decedent, suffered injuries, sickness and death as a result of the defendants? failure to exercise that degree of care and skill ordinarily and customarily used by Medical Doctors, Registered Nurses, Licensed Practical Nurses, under all the circumstances then and there present in that they failed to timely and properly recognize and treat the signs and of a preeclampsia that was improperly permitted to continue into the postpartum period, resulting in an eclampsia with subsequent hypertensive intracerebral hemorrhage and death. 70. As a direct and proximate result of the aforementioned medical negligence the plaintiff?s decedent suffered extreme emotional distress, mental and physical pain, and her untimely death from failure to diagnose and treat her illness. 71. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent lost her life and her ability to enjoy and engage in life?s activities. At the time of her death, Maura was a 38-year-old woman who had prior to May 2017, been in relative good health. Her death destroyed her ability to carry out life's activities, including the ability to earn income and enjoy her family and friends, including her newborn children, resulting in substantial loss and damage to her estate. 72. Maura?s untimely death also destroyed her ability to pursue life's activities and enjoy the usual pleasures of life all to her loss and detriment. 73. As a result of her death, Maura?s estate incurred expenses for funeral and related expenses. 74. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent suffered conscious pain and suffering. COUNT THREE: (As to Astrid Hoffmann-Olsen, MD. for Medical Malpractice/Wrongful Death) 1-67. Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 67 of COUNT THREE as if more fully set forth herein. 68. During the course of said hospitalization, the defendant, Astrid Hoffmarm-Olsen, M.D., deviated from applicable standards of care in one or more of the following ways, in that she: a) Failed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; b) Underdiagnosed the extent and severity of Maura?s preeclampsia; c) Undertreated the extent and severity of Maura?s preeclampsia; d) Improperly managed Maura?s preeclampsia; e) Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; 1) Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; g) Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; h) Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; i) Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; j) Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; k) Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; 1) Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; m) Failed to properly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; n) Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; 0) Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; p) Failed to deliver Maura?s twins in a timelier manner; q) Failed to place Maura in a scheme of care designed to deliver Maura?s twins on May 5th, 6th or 7th of 2017 based on the laboratory data available on May 5, 2017; and r) Improperly deferred Maura?s postpartum medical management to non- physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent, suffered injuries, sickness and death as a result of the defendant?s failure to exercise that degree of care and skill ordinarily and customarily used by Medical Doctors, Registered Nurses, Licensed Practical Nurses, under all the circumstances then and there present in that they failed to timely and properly recognize and treat the signs and of a preeclampsia that was improperly permitted to continue into the postpartum period, resulting in an eclampsia with subsequent hypertensive intracerebral hemorrhage and death. 70. As a direct and proximate result of the aforementioned medical negligence the plaintiff?s decedent suffered extreme emotional distress, mental and physical pain, and her untimely death from failure to diagnose and treat her illness. 71. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent lost her life and her ability to enjoy and engage in life?s activities. At the time of her death, Maura was a 38?year-old woman who had prior to May 2017, been in relative good health. Her death destroyed her ability to carry out life's activities, including the ability to earn income and enjoy her family and friends, including her newborn children, resulting in substantial loss and damage to her estate. 72. Maura?s untimely death also destroyed her ability to pursue life's activities and enjoy the usual pleasures of life all to her loss and detriment. 73. As a result of her death, Maura?s estate incurred expenses for funeral and related expenses. 74. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent suffered conscious pain and suffering. COUNT FOUR: (As to Kiger Lau, MD. for Medical Malpractice/Wrongful Death) 1-67. Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 67 of COUNT OUR as if more ?illy set forth herein. 68. During the course of said hospitalization, the defendant, Kiger Lau, M.D., deviated ?'om applicable standards of care in one or more of the following ways, in that she: a) Failed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; b) Underdiagnosed the extent and severity of Maura?s preeclampsia; c) Undertreated the extent and severity of Maura?s preeclampsia; d) Improperly managed Maura?s preeclampsia; e) Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; f) Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; g) Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; h) Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; i) Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; j) Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; k) Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; 1) Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; m) Failed to prOperly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; n) Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; 0) Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; p) Failed to deliver Maura?s twins in a timelier manner; q) Failed to place Maura in a scheme of care designed to deliver Maura?s twins on May 5th, 6th or 7th of 2017 based on the laboratory data available on May 5, 2017; and r) Improperly deferred Maura?s postpartum medical management to non- physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent, suffered injuries, sickness and death as a result of the defendant?s failure to exercise that degree of care and skill ordinarily and customarily used by Medical Doctors, Registered Nurses, Licensed Practical Nurses, under all the circumstances then and there present in that they failed to timely and properly recognize and treat the signs and of a preeclampsia that was improperly permitted to continue into the postpartum period, resulting in an eclampsia with subsequent hypertensive intracerebral hemorrhage and death. 70. As a direct and proximate result of the aforementioned medical negligence the plaintiff?s decedent suffered extreme emotional distress, mental and physical pain, and her untimely death ?'om failure to diagnose and treat her illness. 71. As a direct and proximate result of the aforementioned medical negligence, the plaintiff decedent lost her life and her ability to enjoy and engage in life?s activities. At the time of her death, Maura was a 38-year?old woman who had prior to May 2017, been in relative good health. Her death destroyed her ability to carry out life's activities, including the ability to earn income and enjoy her family and friends, including her newborn children, resulting in substantial loss and damage to her estate. 72. Maura?s untimely death also destroyed her ability to pursue life's activities and enjoy the usual pleasures of life all to her loss and detriment. 73. As a result of her death, Maura?s estate incurred expenses for funeral and related expenses. 74. the plaintiffs de COUNT FIVE: 1-67. As a direct and proximate result of the aforementioned medical negligence cedent suffered conscious pain and suffering. (As to Stamford Anesthesiology Services, PC. for Medical Malpractice/Wrongful Death) Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 67 of COUNT FIVE as if more fully set forth herein. 68. During the course of said hospitalization, the defendant, Stamford Anesthesiology Services, RC. and their agents, servants, apparent agents and/or employees, do viated from applicable standards of care in one or more of the following ways, in that theyFailed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; Underdiagnosed the extent and severity of Maura?s preeclampsia; Undertreated the extent and severity of Maura?s preeclampsia; Improperly managed Maura?s preeclampsia; Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; Failed to prOperly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; 1) Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; m) Failed to properly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; n) Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; 0) Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; p) Failed to deliver Maura?s twins in a timelier manner; and q) Improperly deferred Maura?s postpartum medical management to non- physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent, suffered injuries, sickness and death as a result of the defendants? failure to exercise that degree of care and skill ordinarily and customarily used by Medical Doctors, Registered Nurses, Licensed Practical Nurses, under all the circumstances then and there present in that they failed to timely and properly recognize and treat the signs and of a preeclampsia that was improperly permitted to continue into the postpartum period, resulting in an eclampsia with subsequent hypertensive intracerebral hemorrhage and death. 70. As a direct and proximate result of the aforementioned medical negligence the plaintiff?s decedent suffered extreme emotional distress, mental and physical pain, and her untimely death from failure to diagnose and treat her illness. 71. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent lost her life and her ability to enjoy and engage in life?s activities. At the time of her death, Maura was a 38-year-old woman who had prior to May 2017, been in relative good health. Her death destroyed her ability to carry out life's activities, including the ability to earn income and enjoy her family and friends, including her newborn children, resulting in substantial loss and damage to her estate. 72. Maura?s untimely death also destroyed her ability to pursue life's activities and enjoy the usual pleasures of life all to her loss and detriment. 73. As a result of her death, Maura?s estate incurred expenses for funeral and related expenses. 74. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent suffered conscious pain and suffering. COUNT SIX: (As to Maria Mazzeo, MD. for Medical Malpractice/Wrongful Death) 1-67. Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 67 of COUNT SIX as if more fully set forth herein. 68. During the course of said hospitalization, the defendant, Maria Mazzeo, M.D. deviated from applicable standards of care in one or more of the. following ways, in that sheFailed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; Underdiagnosed the extent and severity of Maura?s preeclampsia; Undertreated the extent and severity of Maura?s preeclampsia; Improperly managed Maura?s preeclampsia; Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; m) Failed to properly correlate Maura?s abnormal blood values, at any and n) all times prior to her brain bleed; Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; 0) Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; p) Failed to deliver Maura?s twins in a timelier manner; and q) Improperly deferred Maura?s postpartum medical management to non- physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent, suffered injuries, sickness and death as a result of the defendant?s failure to exercise that degree of care and skill ordinarily and customarily used by Medical Doctors, Registered Nurses, Licensed Practical Nurses, under all the circumstances then and there present in that they failed to timely and properly recognize and treat the signs and of a preeclampsia that was improperly permitted to continue into the postpartum period, resulting in an eclampsia with subsequent hypertensive intracerebral hemorrhage and death. 70. As a direct and proximate result of the aforementioned medical negligence the plaintiff?s decedent suffered extreme emotional distress, mental and physical pain, and her untimely death from failure to diagnose and treat her illness. 71. As a direct and proximate result of the aforementioned medical negligence, the plaintiff?s decedent lost her life and her ability to enjoy and engage in life?s activities. At the time of her death, Maura was a 38-year-old woman who had prior to May 2017, been in relative good health. Her death destroyed her ability to carry out life's activities, including the ability to earn income and enjoy her family and friends, including her newborn children, resulting in substantial loss and damage to her estate. 72. Maura?s untimely death also destroyed her ability to pursue life's activities and enjoy the usual pleasures of life all to her loss and detriment. 73. As a result of her death, Maura?s estate incurred expenses for funeral and related expenses. 74. As a direct and proximate result of the aforementioned medical negligence, the plaintiff decedent suffered conscious pain and suffering. COUNT SEVEN: (As to Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital and The Stamford Health System, Inc. for Loss of Chance) 1-67. Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 67 of COUNT SEVEN as if more fully set forth herein. 68. The defendants, Stamford Health, Inc. d/b/a Stamford Hospital, The Stamford Hospital and The Stamford Health System, 1110., through its agents, apparent agents, employees and servants, deviated from applicable standards of care in one or more of the following ways, in that theyFailed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; Underdiagnosed the extent and severity of Maura?s preeclampsia; Undertreated the extent and severity of Maura?s preeclampsia; Improperly managed Maura?s preeclampsia; Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; p) Failed to deliver Maura?s twins in a timelier manner; q) Failed to place Maura in a scheme of care designed to deliver Maura?s twins on May 5th, 6th or 7th of 2017 based on the laboratory data available on May 5, 2017; and r) Improperly deferred Maura?s postpartum medical management to non-physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive a prompt and proper evaluation and/or treatment and, as a result she: (I) was deprived of a chance for successful treatment; (2) lost a substantial or signi?cant chance of survival; (3) suffered a decreased chance to save her life. 70. Maura?s decreased chance for successful treatment and survival more likely than not resulted from the aforementioned medical negligence. 71. As a direct and proximate result of the foregoing, Maura suffered great pain and extreme mental anguish before her death, experienced a signi?cant and material decrease in her life expectancy, lost any opportunity and/or chance of achieving a favorable medial recovery, lost the opportunity to experience the signi?cant palliative bene?t of available medical treatment, and lost the opportunity to carry out all of life?s activities. 72. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive proper evaluation and treatment which resulted in her death. 73. As a direct and proximate result of the aforementioned medical negligence, Maura lost her life and her ability to enjoy and engage in life?s activities. 74. As a direct and proximate result of the aforementioned medical negligence, Maura lost her earning capacity. 75. As a direct and proximate result of the aforementioned medical negligence, the Estate of Maura B. Gallagher incurred medical bills, funeral and burial expenses. COUNT EIGHT: (As to Women?s Health Connecticut, Inc., Physicians for Womens Health, LLC, Obstetrics Gynecology Associates, and Obstetrics Gynecology Associates, P.C. for Loss of Chance) 1-67. Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 67 of COUNT EIGHT as if more fully set forth herein. 68. The defendants, Women?s Health Connecticut, Inc., Physicians for Womens Health, LLC. Obstetrics Gynecology Associates, and Obstetrics Gynecology Associates, P.C., through its agents, apparent agents, employees and servants, deviated from applicable standards of care in one or more of the following ways, in that they: a) Failed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; b) Underdiagnosed the extent and severity of Maura?s preeclampsia; c) Undertreated the extent and severity of Maura?s preeclampsia; d) Improperly managed Maura?s preeclampsia; e) Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; 0 Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; g) Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; h) Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; i) Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; j) Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; k) Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; 1) Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; m) Failed to properly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; n) Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; 0) Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; p) Failed to deliver Maura?s twins in a timelier manner; q) Failed to place Maura in a scheme of care designed to deliver Maura?s twins on May 5thbased on the laboratory data available on May 5, 2017; and r) Improperly deferred Maura?s postpartum medical management to non-physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive a prompt and proper evaluation and/or treatment and, as a result she: (1) was deprived of a chance for successful treatment; (2) lost a substantial or signi?cant chance of survival; (3) suffered a decreased chance to save her life. 70. Maura?s decreased chance for successful treatment and survival more likely than not resulted ?om the aforementioned medical negligence. 71. As a direct and proximate result of the foregoing, Maura suffered great pain and extreme mental anguish before her death, experienced a signi?cant and material decrease in her life expectancy, lost any opportunity and/or chance of achieving a favorable medial recovery, lost the opportunity to experience the signi?cant palliative bene?t of available medical treatment, and lost the opportunity to carry out all of life?s activities. 72. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive proper evaluation and treatment which resulted in her death. 73. As a direct and proximate result of the aforementioned medical negligence, Maura lost her life and her ability to enjoy and engage in life?s activities. 74. As a direct and proximate result of the aforementioned medical negligence, Maura lost her earning capacity. 75. As a direct and proximate result of the aforementioned medical negligence, the Estate of Maura B. Gallagher incurred medical bills, funeral and burial expenses. COUNT NINE: (As to Astrid Hoffmann-Olsen, MD. for Loss of Chance) 1-67. Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 67 of COUNT NINE as if more fully set fOrth herein. 68. The defendant, Astrid Hoffmann-Olsen, M.D. deviated from applicable standards of care in one or more of the following ways, in that sheFailed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; Underdiagnosed the extent and severity of Maura?s preeclampsia; Undertreated the extent and severity of Maura?s preeclampsia; Improperly managed Maura?s preeclampsia; Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; Failed to prOperly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; Failed to deliver Maura?s twins in a timelier manner; Failed to place Maura in a scheme of care designed to deliver Maura?s twins on May 5th, 6th or 7th of 2017 based on the laboratory data available on May 5, 2017; and r) ImprOperly deferred Maura?s postpartum medical management to non-physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive a prompt and prOper evaluation and/or treatment and, as a result she: (I) was deprived of a chance for successful treatment; (2) lost a substantial or signi?cant chance of survival; (3) suffered a decreased chance to save her life. 70. Maura?s decreased chance for successful treatment and survival more likely than not resulted from the aforementioned medical negligence. 71. As a direct and proximate result of the foregoing, Maura suffered great pain and extreme mental anguish before her death, experienced a signi?cant and material decrease in her life expectancy, lost any opportunity and/or chance of achieving a favorable medial recovery, lost the opportunity to experience the signi?cant palliative bene?t of available medical treatment, and lost the opportunity to carry out all of life?s activities. 72. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive proper evaluation and treatment which resulted in her death. 73. As a direct and proximate result of the aforementioned medical negligence, Maura lost her life and her ability to enjoy and engage in life?s activities. 74. As a direct and proximate result of the aforementioned medical negligence, Maura lost her earning capacity. 75. As a direct and proximate result of the aforementioned medical negligence, the Estate of Maura B. Gallagher incurred medical bills, funeral and burial expenses. COUNT TEN: (As to Kiger Lau, MD. for Loss of Chance) 1-67. Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 67 of COUNT TEN as if more fully set forth herein. 68. The defendant, Kiger Lau, M.D. deviated from applicable standards of care in one or more of the following ways, in that she: a) Failed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; Underdiagnosed the extent and severity of Maura?s preeclampsia; Undertreated the extent and severity of Maura?s preeclampsia; Improperly managed Maura?s preeclampsia; Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; Failed to deliver Maura?s twins in a timelier manner; Failed to place Maura in a scheme of care designed to deliver Maura?s twins on May 5th, 6th or 7th of 2017 based on the laboratory data available on May 5, 2017; and Improperly deferred Maura?s postpartum medical management to non-physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive a prompt and proper evaluation and/or treatment and, as a result she: (I) was deprived of a chance for successful treatment; (2) lost a substantial or signi?cant chance of survival; (3) suffered a decreased chance to save her life. 70. Maura?s decreased chance for successful treatment and survival more likely than not resulted from the aforementioned medical negligence. 71. As a direct and proximate result of the foregoing, Maura suffered great pain and extreme mental anguish before her death, experienced a significant and material decrease in her life expectancy, lost any Opportunity and/or chance of achieving a favorable medial recovery, lost the Opportunity to experience the signi?cant palliative bene?t of available medical treatment, and lost the opportunity to carry out all of life?s activities. 72. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive proper evaluation and treatment which resulted in her death. 73. As a direct and proximate result of the aforementioned medical negligence, Maura lost her life and her ability to enjoy and engage in life?s activities. 74. As a direct and proximate result of the aforementioned medical negligence, Maura lost her earning capacity. 75. As a direct and proximate result of the aforementioned medical negligence, the Estate of Maura B. Gallagher incurred medical bills, ?meral and burial expenses. COUNT ELEVEN: (As to Stamford Anesthesiology Services, P.C. for Loss of Chance) 1-67. Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragaphs 1 through 67 of COUNT ELEVEN as if more fully set forth herein. 68. The defendant, Stamford Anesthesiology Services, P.C. deviated from applicable standards of care in one or more of the following ways, in that it/they: a) Failed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; b) Underdiagnosed the extent and severity of Maura?s preeclampsia; c) Undertreated the extent and severity of Maura?s preeclampsia; d) Improperly managed Maura?s preeclampsia; e) Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; Failed to recognize or otherwise appreciate that Maura suffered an intracperative seizure; Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; Failed to properly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior . to her brain bleed; Failed to deliver Maura?s twins in a timelier manner; and Improperly deferred Maura?s postpartum medical management to non-physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive a prompt and proper evaluation and/or treatment and, as a result she: (I) was deprived of a chance for successful treatment; (2) lost a substantial or signi?cant chance of survival; (3) suffered a decreased chance to save her life. 70. Maura?s decreased chance for successful treatment and survival more likely than not resulted from the aforementioned medical negligence. 71. As a direct and proximate result of the foregoing, Maura suffered great pain and extreme mental anguish before her death, experienced a signi?cant and material decrease in her life expectancy, lost any opportunity and/0r chance of achieving a favorable medial recovery, lost the Opportunity to experience the signi?cant palliative bene?t of available medical treatment, and lost the opportunity to carry out all of life?s activities. 72. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive proper evaluation and treatment which resulted in her death. 73. As a direct and proximate result of the aforementioned medical negligence, Maura lost her life and her ability to enjoy and engage in life?s activities. 74. As a direct and proximate result of the aforementioned medical negligence, Maura lost her earning capacity. 75. As a direct and proximate result of the aforementioned medical negligence, the Estate of Maura B. Gallagher incurred medical bills, ?meral and burial expenses. COUNT TWELVE: (As to Maria Mazzeo, MD. for Loss of Chance) 1-67. Paragraphs 1 through 67 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 67 of COUNT TWELVE as if more ?illy set forth herein. 68. The defendant, Maria Mazzeo, M.D. deviated from applicable standards of care in one or more of the following ways, in that she: a) Failed to properly diagnose, monitor, supervise, or otherwise appreciate the signs and indicative of an ongoing Preeclampsia condition in need of proper care, treatment and management in a timely and appropriate manner; b) Underdiagnosed the extent and severity of Maura?s preeclampsia; c) Undertreated the extent and severity of Maura?s preeclampsia; d) Improperly managed Maura?s preeclampsia; e) Failed to maintain Preeclampsia protocol at all times while Maura was on premises at Stamford Hospital on May 8, 2017; 1) Failed to recognize or otherwise appreciate that Maura suffered an intraoperative seizure; g) Failed to recognize or otherwise appreciate the signi?cance of Maura?s signs, and complaints of nausea, vomiting, and headache, at any and all times prior to her brain bleed; h) Failed to properly correlate Maura?s signs, and complaints of nausea, vomiting, and headache, with her Preeclampsia, at any and all times prior to her brain bleed; i) Failed to properly correlate Maura?s intraoperative seizure with her Preeclampsia, at any and all times prior to her brain bleed; j) Failed to properly monitor Maura?s blood pressures, at any and all times prior to her brain bleed; k) Failed to properly monitor Maura?s platelet levels, at any and all times prior to her brain bleed; 1) Failed to properly monitor Maura?s urine protein levels, at any and all times prior to her brain bleed; m) Failed to properly correlate Maura?s abnormal blood values, at any and all times prior to her brain bleed; n) Failed to properly manage Maura?s ?uid levels, at any and all times prior to her brain bleed; 0) Failed to properly manage or otherwise control Maura?s prolonged and persistent hypertension, at any and all times prior to her brain bleed; p) Failed to deliver Maura?s twins in a tirnelier manner; and r) Improperly deferred Maura?s postpartum medical management to non-physicians, and medical personnel who lacked the skill, knowledge, experience and training, to recognize that Maura?s postpartum complaints of nausea, vomiting, and headache were indications of an ongoing and progressive deterioration of her condition due to improperly managed Preeclampsia. 69. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive a prompt and proper evaluation and/or treatment and, as a result she: (I) was deprived of a chance for successful treatment; (2) lost a substantial or signi?cant chance of survival; (3) suffered a decreased chance to save her life. 70. Maura?s decreased chance for successful treatment and survival more likely than not resulted from the aforementioned medical negligence. 71. As a direct and proximate result of the foregoing, Maura suffered great pain and extreme mental anguish before her death, experienced a signi?cant and material decrease in her life expectancy, lost any opportunity and/or chance of achieving a favorable medial recovery, lost the opportunity to experience the signi?cant palliative bene?t of available medical treatment, and lost the opportunity to carry out all of life?s activities. 72. As a direct and proximate result of the aforementioned medical negligence, Maura did not receive proper evaluation and treatment which resulted in her death. 73. As a direct and proximate result of the aforementioned medical negligence, Maura lost her life and her ability to enjoy and engage in life?s activities. 74. As a direct and proximate result of the aforementioned medical negligence, Maura lost her earning capacity. 75. As a direct and proximate result of the aforementioned medical negligence, the Estate of Maura B. Gallagher incurred medical bills, funeral and burial expenses. WHEREFORE, the Plaintiff prays for relief as follows: 1. Damages pursuant to C.G.S. 52-555 2 3. Fair, just and reasonable compensatory monetary damages; and 4. Such further relief as the Court deems just and proper. THE PLAINTIFF John P. Gallagher, Administrator of the Estate of Maura B. Gallagher BY: Daniel A. Thomas, Esq. LAW OFFICES OF DANIEL A. THOMAS, RC. 333 East 53rd Street Suite 3A New York, New York 10022 Tel. 212-307-0200 Fax 212-307-0200 E-mail: danielathomaslaw??ginail.com Juris No. 408150 AND- Steven J. Errante, Esq. Marisa A. Bellair, Esq. TRAUB, KEEFE, ERRANTE, RC. 52 Trumbull Street New Haven, CT 06510 Tel. 203-787-0275 Fax 203-782-0278 Juris #34876 RETURN DATE: JUNE 5, 2018 JOHN P. GALLAGHER, ADMINISTRATOR OF THE ESTATE OF MAURA B. GALLAGHER, Plaintiff, v. STAMFORD HEALTH, INC. d/b/a STAIVIFORD HOSPITAL, THE STANIFORD HOSPITAL, THE STAIVIFORD HEALTH SYSTEM, INC., ASTRID HOFFMANN-OLSEN, M.D., KIGER LAU, M.D., HEALTH CONNECTICUT, INC., PHYSICIANS FOR WOMEN HEALTH, LLC, OBSTETRICS GYNECOLOGY ASSOCIATES, OBSTETRICS GYNECOLOGY ASSOCIATES, P.C., MARIA MAZZEO, M.D., and STAMFORD ANESTHESIOLOGY SERVICES, P.C., IEF SUPERIOR COURT JUDICIAL DISTRICT OF MAY 8, 2018 WHEREFORE, THE PLAINTIFF ADMINISTRATOR OF THE ESTATE OF MAURA B. GALLAGHER HEREBY CLAIMS MONETARY DAMAGES IN EXCESS OF FIFTEEN THOUSAND DOLLARS AND 0/100 CENTS AND THIS MATTER IS WITHIN THE JURISDICTION OF THIS COURT. THE PLAINTIFF John P. Gallagher, Administrator of the Estate of Maura B. Gallagher BY: Daniel A. Thomas, Esq. LAW OFFICES OF DANIEL A. THOMAS, RC. 333 East 53rd Street Suite 3A New York, New York 10022 Tel. 212-307-0200 Fax 212-307-0200 E-mail: danielathomaslaw??gmaileom Juris No. 408150 - AND - Steven J. Errante, Esq. Marisa A. Bellair, Esq. TRAUB, KEEFE, ERRANTE, RC. 52 Trumbull Street New Haven, CT 06510 Tel. 203-787-0275 Fax 203-782-0278 Juris #34876 RETURN DATE: JUNE 5, 2018 JOHN P. GALLAGHER, ADMINISTRATOR OF THE SUPERIOR COURT ESTATE OF MAURA B. GALLAGHER, JUDICIAL DISTRICT OF Plaintiff, V. STAMFORD HEALTH, INC. d/b/a STAMFORD HOSPITAL, THE STAMFORD HOSPITAL, THE STAMFORD HEALTH SYSTEM, INC., ASTRID M.D., KIGER LAU, M.D., HEALTH CONNECTICUT, INC., PHYSICIANS FOR WOMENs HEALTH, LLC, OBSTETRICS GYNECOLOGY ASSOCIATES, OBSTETRICS GYNECOLOGY ASSOCIATES, P.C., MARIA MAZZEO, M.D., and STAMFORD ANESTHESIOLOGY SERVICES, MAY 8, 2018 RC, A BLE I hereby certify that I have made reasonable inquiry, as permitted by the circumstances, to determine whether there are grounds for a good faith belief that there has been negligence in the form of medical malpractice in the diagnosis, care and/or treatment of the plaintiffs decedent, Maura B. Gallagher. This inquiry has given rise to a good faith belief on my part that grounds exist for an action against each named defendant. I hereby further certify that the attached written opinion is from a similar healthcare provider in compliance with Connecticut General Statute 52-190a. THE PLAINTIFF John P. Gallagher, Administrator of the Estate of Maura B. Gallagher BY: Daniel A. Thomas, Esq. LAW OFFICES OF DANIEL A. THOMAS, PC. 333 East 53rd Street Suite 3A New York, New York 10022 Tel. 212-307-0200 Fax 212-307-0200 E-mail: danielathomaslaw@gmail.com Juris No. 408150 - AND- Steven J. Errante, Esq. Marisa A. Bellair, Esq. TRAUB, KEEFE, ERRANTE, RC. 52 Trumbull Street New Haven, CT 06510 Tel. 203-787-0275 Fax 203-782-0278 Juris #34876 13.- GALLAGHER . mama?; OF V. STAMFORD. HEALTH, INC, . STAMFORD HOS.RITAI., HIE. STAMFORD HOSPITAL, HIE STAMFORD INC, M11, HEALTH. Icoumsmcur; mu, PHYSICIANS FOR WOMENS- up; GYNECOLOGX: GYNECOLQGY 2018' MARJA and sum-+0110 .D?fcndanw- - pig .3. l?am?a dulyf licensed and-practicing physiciani: ofeAnestheeia; tam-board certi?ediin A?pgthe?ologyggand'l. have been-board ofz?ti993;agdf Mvczatsomaintained all requirements. Upon ?beli'el?fmy .5p'ecizilty same aasma: .helii:_by. named. defendant; Maria ng?MD: and'the Same Sewi?ccs, RC. I elm-familiar with the professibnal standa?td?iif a. physician, ih the 137, for" treatment of apath?t ?undergoing'the. procedure in :quc?tion; namer ?m.clmtivez Ciseetio?ilnathe' cb?lifs?g?f my'tt?ai?ing? and experience, 1.11m attended over 5,000 obstetrical caSesiof 'wbi?hmotegthan'i l;000 Wereiicleetive C?se'C?ons', and continue tos'er?easan An?mhesidlbgimiih Vsarneand similar at present. I am Quali?ed to commenter) the. matters herein and :englerfopinims as lathe nature and degree of the. anesthetic care} arid :tre?tmerjit- in this e'gsebyv'irtue: ofthenationat standard which gchr'ns the :pcrfomtanqe '?f'bb?t?tri?al deliveries, ihcludin'gj elective- 0 sections in the facc'ofHELLP. I have reviexa'red allofthc ahd hoSpilal chafLS'fOrWardcd to me regarding this: patient. Maura Gallagher, including: Stamford-Hospital chart forfpvaticnt, Maura'GaHagheerr admission May-8. 2017 torMay 9, 2017, inclusive of lab w?ork dated?May the Rewnds?for the subjectsurgery on: May 8; 2017; Stamford Hospital chanjror admission/visit Apr? 24,_ 2017; Stamford Hospitalchartfor admission/Visit?pf? 14,2017; Stamfmd Hospitalp'hm for ?dmigjpn/Visiti?p?lb, 2017.; 0 Stamfor?Hospitalj {Or admissi'on/viSit' January. 2017-; . smrordgnospnal-gsha? foggdmiss'ion?ti'sit Fa;in 2013'; - Antop$y 10,2011 7i'?oi? WhiCh State's ihatthc bruit) id 'th?z-Mayd? Clinic review, 9 Surgical?Pamologleeg?dndaled inchich and '0 Dr.- from Obstetrics-I Gynecglog'y Assopidt?, A DiyiSipn?f Phygip?ians'?f?br' Whinbn?s of thcr?cbrak for the'subjec?t'pre'g'nancy. Based onmy?rc?cw dither _mcoris,"1 bc?gveih?te-is the Liam'- that. ms prolifi'd?cdiitd Galiiaghe'r: bx? Dr- -?j~?iazzc6fstudford Anesthaialb?yiscrviceg Hospitalii?spg'gi?ml 1y; thet?i?c?p?rpyid? 8,2201 before. daring, ahd afl?i the; Electix'cT'Q-scc'tEOn surgery l??n ?beloxi?Ei-th?? il??'eUst?nd?rd - Of and treatment Which-in light offal]; the}. fcl?vzim surrdundipgfcirqumsiances-is asap?r?pri'a'ic for patients. these ckcuf?stanc?s; Based Gummy review of?ghqmedich?31jacorgdg and .rbelieve: _th?at__10_; fa. (gasona?lc of-medical probability ?it: "sta'??dard 'wgs not met in (my: {or-mgre of? the TN THAT Dr; ?Mm?O/Stam Tc?mffailgdito anqifoqnnlatc aipropcr pl?a?niof; zin?sthefiu for {he patient-?8? ?bas?dimxhd pini'em's prpnatal history; in. particular. her prenatalgbasding blood pressures; THAT Team failgjd to a proper pl?hitd?ameslth?tidmhnagemqm for the pa?ticnt?s elective - C-S?tlion' bas?df'ph ?the; .Sign'sfand- on May 8, 2017,5111 pafticul?r age;- gestationil'diabct'e's gcsta?'on, and recent- platelet count) and??lcvaitcd un'he? prOte?in; C) IN- Dr. MMco/ Sgamford- Anestha?iqlogy' Services, Team .135in to properly appreciatc: cxtg?t? ands of the before andduringthe May 8. 2017; d) IN Dr. Mazzeo/ Stamford Angs?th?siology Services, Team failed to monitor (hepaticnt?s imraopcrative blood 'in a shorter, consistent, and mute rcgular interval of time: c) THATDIQ Mazzoo/ 'Stau?brq P;C;lAnc?thcsia Team failing-19 change-her play of'mahaggrhemrror thwati?nifin ?d?livery- pe?qd: (once -'3ccond - was {Helivcred- a: l-OE32?Mvn Sikh that the heed not?eCCSSaryfg Ll) 'l?eam. contra! a?c; followingrd?livenjy of'thc R?thouti'?i?d?nhix i'tlic: (patient to rewm'rtolregaib'? unzmiiSt?d? mark)13mm:E pressures; 3" Stanford Team administered a 'iconti?aindita'ted .?icldib?tiorii? 1hi??lgpatien?duripg 31116;- electivc-C-s'cction; .11) n9. Mango! Stamford 'I'ca'm administ?crcd, contraindicated patienidbring . the elective Team. failed 'to recoghiz: that picky??g :a's morqu 5i_n ihjt?j Anesthesia 'Record._.. dining-?ute Soto-s45. minutes Ephedrine was ad failed :tp= warrant j?r?justif?y; nae-pr Ephedrine-asadministered-'10 lhc' paticnt4ih'lraopcratively; 5) . 1N S?irviccSi Team administered. co_ the. 'ofihe '?iMiyc?Cj?seclion; k) admi?nistci'cd . medications. within -a[timc od Lof3'0 10' 545: this 1.116 ?i'ntr'a'o pcratii'?spcriOd? of the emotive C,7Section; 1) IN THATDL :Mazz?co; Team 'administe'rcgl; a. contraindicated." . icali'on ilhis patieht?dming? :the intraop'erat'ivc period of . m) 'l'emn failed-to recognize "ahd properly halftime described as an ?'arixiely anack?"or af'panic unack??li? medical-recurds; 11) IN 'l?HAT'DrLMazzeol Stamford: Anesthesiology Team ?ordergany .bminfirnagjng ofth?c patient lec, ?anxietyattack? 6r tbaf'any surgical interventiOn optionsow d?nicd to the paticm such??ilure; o) apt/Anesthesia ?l'cam' failed can I?m" timelyr?onsultations i'rgrneurollogy, and/or- mi any time prior 'to the" p'a'tie?t?s 'I'Iizi?ss?ive hyp?rtenSiV? intracerebrul p) Mazzoo/ Stamford S?rvic?s, RCJAn?Sth?sia Team delivery, 1hd--' patie'nt?tb' pCri'ods .of spikcsf?ingblood meninteggityt-of .5lodd"Ych?l??in brain which . caused; .cre?led, ?bernjiit'te'd the (if-bike "Of m?pe'ihypertensbc intracetebgal hgmorrbagcg-With' the lasf such at-oi:fabont2:50PM 2017 resulting in maSsivc,xfnonrsuryivabie, 1' of S?ameFd gnd. h?qr {3'11ch gzubsglanth?il?gfaCtonrin- causing Ms; Gallagths-urifo?unme bfdin? May a?nd?umit??lfdei?i??go? 20;: . The,inibmiafi?n s9th 5h9r?in~is ba?ciis 011- available to all?? time- Should?n?thcr infdrihation?rid. cvi?d'?ncc' 1b: right-ts) amend these opinions. .Gen?ral Statutes '??52i-190m b?c by any'iparly ceni?catc?? *1 uhders?tand??copy bf??s-bpi?i?mmiihmy naian will} be??tta?hed'Zm the good ?fth-certi?cate :?led. 'thc. COmpIaint andloi?i Claim, ,ists'?led ag?ihst. any-defe?dant 1n redditibn to my. mv-icw odili?n?diiabos?; arci?bas?d upo?? my: andStudy'in this specialty. ESTATE OF MAURA B. GALLAGHER, SUPERIOR COURT Plaintiff, JUDICIAL DISTRICT OF V. STAMFORD HEALTH, INC. d/b/a STAMFORD HOSPITAL, THE STAMFORD HOSPITAL, THE STAMFORD HEALTH SYSTEM, INC., ASTRID HOFFMANN-OLSEN, M.D., KIGER LAU, M.D., HEALTH CONNECTICUT, INC., MAY 8, 2018 PHYSICIANS FOR WOMENS HEALTH, LLC, OBSTETRICS GYNECOLOGY ASSOCIATES, OBSTETRICS GYNECOLOGY ASSOCIATES, P.C., MARIA MAZZEO, M.D., and STAMFORD SERVICES, P.C., Defendants. OPINION PURSUANT TO C.G.S. 6 52-190a I am a duly licensed and practicing physician, specializing in the area of Obstetrics and Gynecology. . I am board certi?ed in Obstetrics and Gynecology by the American Board of Obstetrics and Gynecology, and I have been board certi?ed since 1998, and have also maintained all my CME requirements. Upon information and belief, my specialty and certi?cation are the same as that held by named defendant, Astrid Hoffman-Olsen, the same specialty as Stamford Hospital resident physician, Kiger Lau, and the same area of practice as Women's Health Connecticut, Inc., Physicians For Womens Health, LLC, Obstetrics Gynecology Associates, and Obstetrics Gynecology Associates, P.C. I am familiar with the prevailing professional standard of care in the year 2017 required of a physician, Obstetrician/Gynecologist (hereinafter in the care and treatment of an obstetrical patient undergoing the procedure in question, namely an elective C-section. In the course of my training and experience, I have attended over 5,000 obstetrical cases, and continue to serve as an in same and similar cases at present. I am quali?ed to comment on the matters stated herein and render Opinions as to the nature and degree of the obstetrical care and treatment in this case by virtue of the national standard which governs in the performance of obstetrical deliveries, including elective C-sections in the face of HELLP and/or Preeclampsia. I have reviewed all of the medical treatment records and hospital charts forwarded to me regarding this patient. Maura Gallagher, including: - Stamford HOSpital chart for patient, Maura Gallagher for admission May 8, 2017 to May 9, 2017, inclusive of lab work dated May S, 2017, and the Anesthesia Records for the subject surgery on May 8, 2017; 0 Stamford Hospital chart for admission/visit April 24, 2017; 0 Stamford Hospital chart for admission/visit April 14, 2017; 0 Stamford Hospital chart for admission/visit April 6, 2017; 0 Stamford Hospital chart for admission/visit January 9, 2017; 0 Stamford Hospital chart for admission/visit February 4, 2013; Autopsy Report dated May 10, 2017 from Stamford Hospital, which states that the brain was sent to the Mayo Clinic for neuropathology review; 0 Surgical Pathology Report dated July 12, 2017 from Stamford Hospital, inclusive of Neuropathology ?ndings from the Mayo Clinic (plus brain aut0psy photos); and 0 Dr. Astrid Hoffman-Olsen records from Obstetrics Gynecology Associates, A Division of Physicians for Women?s Health from August 2009 to May 2017, inclusive of the prenatal records for the subject pregnancy. Based on my review of the records, I believe there is evidence of medical negligence in the care that was provided to Maura Gallagher by Dr. Hoffman-Olsen (and the entire Obstetrical/Surgical Team) at Stamford HOSpital from May 5, 2017 through May 8, 2017. Speci?cally, the care provided by Dr. Hoffman-Olsen (and the entire Obstetrical/Surgical Team) at Stamford Hospital from May 5, 2017 through May 8, 2017, fell below the level/standard of care, skill, and treatment which in light of all the relevant surrounding circumstances is recognized as appropriate for patients under these circumstances. Based on my review of the medical records and documentation, I believe that to a reasonable degree of medical probability the standard of care was not met in one or more of the following respects: a) IN THAT Dr. Hoffman-Olsen/Dr. Lau/Women's Health Connecticut, Inc/Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. failed to and timely diagnose and treat the patient?s HELLP or Preeclampsia on May 5, 2017 following the blood work results of low platelet count, which required more testing (including urine protein levels) and closer monitoring such that delivery of the patient?s twins could be accomplished without exposing mother or babies to additiona1 and unnecessary risk of any untoward events associated with HELLP and Preeclampsia; b) IN THAT Dr. Hoffman-Olsen/Dr. Lau/Women's Health Connecticut, Inc./Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. failed to and timely diagnose and treat the patient?s progressive and evolving HELLP or Preeclampsia on May 6, 2017 following the blood work results of low platelet count on may 5, 2017, which required more testing (including urine protein levels) and closer monitoring such that delivery of the patient?s twins could be accomplished without exposing mother or babies to additional and unnecessary risk of any untoward events associated with HELLP and Preeclampsia; 0) IN THAT Dr. Lau/Women's Health Connecticut, Inc./Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. failed to and timely diagnose and treat the patient?s progressive and evolving HELLP or Preeclampsia on May 7, 2017 following the blood work results of low platelet count on may 5, 2017, which required more testing (including urine protein levels) and closer monitoring such that delivery of the patient?s twins could be accomplished without exposing mother or babies to additional and unnecessary risk of any untoward events associated with HELLP and Preeclampsia; (1) IN THAT Dr. Hof?nan?Olsen/Dr. Lau/Women's Health Connecticut, Inc/Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. (and the entire Obstetrical/Surgical Team) failed to properly appreciate and formulate a proper plan of obstetric management for the patient?s elective C-section based on the patient?s presenting history, signs and between May 5-8, 2017, and in particular the risk factors as of May 8, 2017 which include advanced maternal age (just shy of 39lh birthday), gestational diabetes mellitus, twin gestation, recent onset of thrombocytopenia (low platelet count), with a drop in platelet count from 98,000 to 84,000 over the 3 days prior to presentation for delivery and elevated urine protein; e) IN THAT Dr. Hoffman-Olsen/Dr. Lau/Women's Health Connecticut, Inc./Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. failed to ascertain or review the lab results of the May 5, 2017 blood work, in particular the platelet count at any time prior to the morning of May 8, 2017 when the patient presented to Stamford Hospital for her elective C-section; t) IN THAT Dr. Hoffman-Olsen/Dr. Lau/Women's Health Connecticut, Inc/Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. failed to ascertain the lab results of the May 5, 2017 blood work, in particular the platelet count at any time prior to the morning of May 8, 2017 when the patient presented to Stamford Hospital for her elective C-section; g) IN THAT Dr. Hoffman-Olsen/Dr. Lau/Women's Health Connecticut, Inc./Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. failed to rule out the indication for emergent admission to the hospital for close observation, if not emergent delivery, in light of the patient?s thrombocytopenia as recognized by the Stamford Hospital blood work data on May 5, 2017, timed at h) IN THAT Dr. Hoffman-Olsen/Dr. Lau/Women's Health Connecticut, Inc/Physicians For Womens Health, LLC/Obstetn'cs Gynecology Associates/Obstetrics Gynecology Associates, PC. (and the entire Obstetrical/Surgical Team) failed to evaluate the patient to change the plan of management for the patient in the immediate post-delivery period (once the second twin was delivered at on May 8, 2017) such that the need to maintain elevated maternal blood pressures was not necessary; i) 1N THAT Dr. Lau/Women's Health Connecticut, Inc./Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. (and the entire Obstetrical/Surgical Team) failed to call or order timely consults in neurology, radiology, neuroradiology, and/or neurosurgery at any time prior to the patient?s massive hypertensive intracerebral hemorrhage, despite indication for same by virtue of the Operative Reports? reference to ?intraoperatively, she developed severe range blood pressures and a headache?, which was reiterated in the Delivery Summary which states: ?In the operating room, she developed severe range blood pressures and a headache?; j) IN THAT Dr. Hoffman-Olsen/Dr. Lau/Women's Health Connecticut, Inc./Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. (and the entire Obstetrical/Surgical Team) failed to recognize and properly treat the patient?s post-delivery seizure-like episode, described as an ?anxiety attack? or a ?panic attack? in the various medical records; k) IN THAT Dr. Hoffman-Olsen/Dr. Lau/Women's Health Connecticut, Inc./Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. (and the entire Obstetrical/Surgical Team) failed to order any brain imaging of the patient as soon as possible following the ?anxiety attack? or a ?panic attack? such that any surgical intervention options were denied to the patient by such failure; I) IN THAT Dr. Hof?nan?Olsen/Dr. Lau/Women's Health Connecticut, Inc/Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. failed to recognize, consider, or treat the patient?s evolving and progressing eclampsia in a timely manner such that the patient?s signs and of vomiting, nausea, and headache were all underdiagnosed, undertreated, and caused, allowed, and permitted the patient to get more ill in the face of improper treatment and delay in diagnosis of a cerebral vascular accident that was wholly avoidable by the exercise of accepted care as to differential diagnosis, index of suspicion, and scheme of care; and m) IN THAT Dr. Hoffman-Olsen/Dr. Lau/Women's Health Connecticut, Inc/Physicians For Womens Health, LLC/Obstetrics Gynecology Associates/Obstetrics Gynecology Associates, PC. (and the entire Obstetrical/Surgical Team) improperly allowed, caused, created, and/or permitted, intraoperatively and post-delivery, the patient to sustain unreasonable periods of sustained hypertension, and/or spikes in blood pressure, that compromised the integrity of blood vessels in brain which allowed, caused, created, and/or permitted the occurrence of one or more hypertensive intracerebral hemorrhages, with the last such occurrence at or about on May 8, 2017 resulting in a massive, non-survivable, brain bleed. .I. believe: that thin reasonable. degree. of medical ppobability that Dr. Lav/Women's Health rCoqnecti?ut,; gFOfr?TW?mcn's Health; "Asslo?giat?lebStICIricai .Gynec?logy? Associath P13..- .(and: .Lh'g- optima rjn??t: pjrf??ailing of. cm.-qnd Ithat?her failuxc' wasa substantial factqr ?in 201:7- and'untiz??ly; d?niiscic'mf May 'i'ipifqrma?og styled hcpcin'is based 7on4?h? idfofinati an: gm; 111151;: 10.. me. 81.: 15.391 at'ailalilc, rpse?cyc. these opinions. ms is- a [in .thi?i? faith- .rcquijxemept of the "Gen?'rgi 'S'lamtqs ?i~52?1903g ?le-stain: prOvid?cs?v-Jlihiig be subject to: "discach by f0; gucStiOni?zithc"Yalidily 9f" understand-f a copy-0131113; ppii?bn.? with namc'a?d good faith/cedi?c??e i?lcd ?led ?a'gainst any defendant'- herein. 11.1 addition ?32m!Iieki?W9flh?P?1?Yant are based upon my experience Smdyiih? this specialty?