1064. SYLVIA left surviving as his next of kin her husband, Plaintiff Dr. Ladien and daughter, Fawn Doucette. Because of Defendants’ negligence, said next of kin had less time to spend in the company of SYLVIA than they would otherwise have had. 1065. By reason of the wrongful death of SYLVIA, said next of kin has: sustained substantial pecuniary loss; been deprived of valuable services that the decedent, SYLVIA, was accustomed to performing for her and would have continued to perform but for his death; been deprived of the affection, society, companionship, and guidance of the decedent, SYLVIA, to their great detriment; and, suffered and will continue to suffer from grief, sorrow, and mental suffering due to the death of the decedent, SYLVIA. WHEREFORE, the Plaintiff, DR. KIMBALL LADIEN, pro se and as Independent Administrator of the Estate of SYLVIA, Deceased, prays for damages against Defendant COHEN, SJH and PRESENCE, in a sum in excess of Fifty Thousand Dollars ($50,000), plus costs. COUNT FOURTEEN SURVIVAL ACT (KIMBALL LADIEN, MD, PRO SE AND AS THE INDEPENDENT ADMINISTRATOR OF THE ESTATE OF SYLVIA DOUCETTE-LADIEN v. HARRY COHEN. PRESENCE AND PRESENCE/SJH including SJH employees and agents) 1066. Plaintiff incorporates by reference herein Paragraphs 1 through 986 as if fully set forth herein. This Count refers to all Parties listed above in the discussion below. 1067. From September 2, 2009 through October 2011, and at all times relevant to this Complaint, Defendant DR. COHEN, owed SYLVIA a duty to act as a reasonably careful doctor in similar circumstances would act. On and after September 2, 2009 through September 2011, and at all relevant times hereto, Defendant DR. COHEN was negligent for one or more of the following reasons: failed to monitor and prevent over-radiation of SYLVIA; failed to give informed consent to both SYLVIA and Dr. Ladien concerning both the possibility - and risks associated with over radiation; failed to prevent and treat wrongful DVT leading to iatrogenic CVA;
1064. SYLVIA left surviving as his next of kin her husband, Plaintiff Dr. Ladien and daughter, Fawn Doucette. Because of Defendants’ negligence, said next of kin had less time to spend in the company of SYLVIA than they would otherwise have had. 1065. By reason of the wrongful death of SYLVIA, said next of kin has: sustained substantial pecuniary loss; been deprived of valuable services that the decedent, SYLVIA, was accustomed to performing for her and would have continued to perform but for his death; been deprived of the affection, society, companionship, and guidance of the decedent, SYLVIA, to their great detriment; and, suffered and will continue to suffer from grief, sorrow, and mental suffering due to the death of the decedent, SYLVIA. WHEREFORE, the Plaintiff, DR. KIMBALL LADIEN, pro se and as Independent Administrator of the Estate of SYLVIA, Deceased, prays for damages against Defendant COHEN, SJH and PRESENCE, in a sum in excess of Fifty Thousand Dollars ($50,000), plus costs. COUNT FOURTEEN SURVIVAL ACT (KIMBALL LADIEN, MD, PRO SE AND AS THE INDEPENDENT ADMINISTRATOR OF THE ESTATE OF SYLVIA DOUCETTE-LADIEN v. HARRY COHEN. PRESENCE AND PRESENCE/SJH including SJH employees and agents) 1066. Plaintiff incorporates by reference herein Paragraphs 1 through 986 as if fully set forth herein. This Count refers to all Parties listed above in the discussion below. 1067. From September 2, 2009 through October 2011, and at all times relevant to this Complaint, Defendant DR. COHEN, owed SYLVIA a duty to act as a reasonably careful doctor in similar circumstances would act. On and after September 2, 2009 through September 2011, and at all relevant times hereto, Defendant DR. COHEN was negligent for one or more of the following reasons: failed to monitor and prevent over-radiation of SYLVIA; failed to give informed consent to both SYLVIA and Dr. Ladien concerning both the possibility - and risks associated with over radiation; failed to prevent and treat wrongful DVT leading to iatrogenic CVA;