Plaintiff will amend this complaint to allege their true names and capacities when ascertained. Now comes Kathleen Parks, Gary Parks, Jodi Columbo individually, and as Personal Representative for the Estate of Kenneth Parks, claimants herein, by their attorneys, Rodney M. Gaston, and Miller & Zois, LLC, and hereby file this claim against the above named defendant and in support thereof states as follows: COUNT I: Medical Malpractice/Wrongful Death. On August 10, 2012, To the filing of this action, Defendants have failed and refused to repay the Loan, Defendants are therefore in breach of the Note and the entire principal of. Upon filing of the complaint, legal requirements are needed to support such a predicament, which will then be handled by the proper authorities. that; In witness thereof, I, In legal terminology, Complaint Forms are documents that lay down certain facts and legal reasons that the filing party or parties believe to have sufficient information to support a claim against another party. That pursuant to Maryland Rule 15-1001, all persons who are entitled to bring a wrongful death action under applicable Maryland laws are named as claimants in this complaint and are being represented by Rodney M. Gaston, and Miller & Zois, LLC. Petition to Terminate Parental Rights. Sample Complaints. 24-C-02-00380. FRED FLINTSTONE. I am attaching copies of my receipt or ___________ (other proof of payment or documentation of complaint). | Dwight Eisenhower, Allbusinesstemplates.com is a website by 2018 © ABT ltd. Using our easy-to-modify, Legal professionals are in need of templates more than any other industry. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. WHEREFORE, Plaintiff prays for judgment against Defendants as follows: John Adams Plaintiff in Pro Persona. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. Trinidad Benguet, after being sworn according to law, hereby depose and state That all of the injuries, damages, and death sustained by the late Kenneth Parks resulted from the negligent actions and breaches of the applicable standards of medical care by the Defendant by and through its employees and agents, without any act or omission on the part of the late Kenneth Parks, or on the part of any of the Plaintiffs herein, directly thereunto contributing. Generally it creates so much doubt if one reads by bare act. To: (enter the email address of the person you are contacting) This can be easier nowadays as complaint letters can already be sent through electronic mail. The last case I referred to them settled for $1.2 million. I wish to complain about ____ (name of product or service, with serial number or account number) that I purchased on ____ (date and location of transaction). San Francisco, CA 94102 I am so grateful that I was lucky to pick Miller & Zois. That at all times herein Washington Hospital Center, now known as Meritus Medical Center, Inc. was and still is a viable Maryland Corporation with its principle place of business located at 251 East Antietam Street, Hagerstown MD. Answer to Complaint. State Bar # 69052 LAW OFFICES OF DAVID JORDAN 222 West Broadway, Suite 500 GLENDALE, CALIFORNIA 91201 (818) 845-3238. That the standard of medical care applicable to the Defendant for the medical care and treatment it provided to the late Kenneth Parks (also referred to herein as the “patient”) while he was an inpatient at the Defendant’s hospital included but was not limited to: 1) order a one to one sitter, 2) order a posey restraint, and 3) request that a physician order a prescription for a one to one sitter after informing the patient’s family that a sitter would be provided for the patient. We're here to make sure that it's as fair and straightforward as possible. Motion To Vacate Judgment. Also interested in other Legal templates? On or about February 1, 2012, Plaintiff loaned to Defendants the sum of ten, In consideration for the Loan, Defendants executed a Promissory Note (the Note). v. BARNEY RUBLE. All business templates are easy to find, crafted by professionals, ready to use, easy to customize and intuitive. Municipal Trial Court. sample breach of contract, common counts, and fraud complaint. To resolve this problem I would like you to ____ (what you want the business to do). COUNT II Medical Malpractice / Negligence / Survival Action. You can download the letter and email in plain text format by clicking on these links: Company official I believe that this response is unfair because ____ (the reason you feel the company has an obligation to you). To better address this, Customer Complaint Forms are formulated to ensure that every filed complain is being addressed and looked into. David Jordan, Esq. That attached hereto and incorporated by reference herein are the Plaintiffs’ Certificate of Qualified Expert (Exhibit 1) and Plaintiffs’ Expert Report (Exhibit 2). SUPERIOR COURT OF CALIFORNIA, COUNTY OF MARIN Negligence Complaint . I am enclosing copies of my receipt. Enter this coupon code at checkout to save at AllBusinessTemplates.com. WHEREFORE: Plaintiff Jodi Columbo, as Personal representative of the Estate of Kenneth Parks claim monetary damages against the Defendant in an amount that exceeds the jurisdiction of the District Court of Maryland, to be determined at trial, plus costs, and for any further relief that this Honorable Court determines necessary and appropriate. I look forward to hearing from you as soon as possible to resolve this problem. Click here to download the email in English. other reliefs and remedies under the premises are likewise prayed for. Attorney for Plaintiff FRED FLINTSTONE . That Defendant Meritus Medical Center, Inc. (previously known as Washington Hospital Center) is a Maryland Corporation providing medical services to the citizens of Maryland, including the Kenneth Parks, with its principle place of business located at 251 East Antietam Street, Hagerstown MD. That the Estate of Kenneth Parks was opened on or about June 29, 2010, in Washington County, Maryland and Jodi Columbo was appointed as Personal Representative of the Estate. That as a direct result of the negligence and breaches of the applicable standard of medical care by the Defendant, by and through its nurses, employees, and medical staff, resulting in the death of the late Kenneth Parks, the Plaintiffs sustained those damages as outlined in the Annotated Code of Maryland, Courts and Judicial Proceedings Article, Section 3-904, to include but not limited to, mental anguish, emotional pain and suffering, and loss of companionship. (Hint: If you are pasting into a Word document, choose "Paste as Plain Text" to paste text into your document.) 1170 Market Street, Suite 500 Complaint Sample Republic of the Philippines. To make a more reliable complaint, one must take into consideration some steps to make sure that no other party is affected. A true and correct copy of the Note is attached hereto as Exhibit “A.”.