Justin King Answer

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IN AND FOR FORD COUNTY, ILLINOIS

PAXTON MEDICAL CENTER AND ITS DOCTORS, SURGEONS AND NURSES

Defendant

VS.
JUSTIN WILLIAM KING
Plaintiff)
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Case No. 7417410 (05)

Judge Stephen R. Pacey

DEFENDANT ANSWER
TO
PLAINTIFF COMPLAINT
COMES NOW, DEFENDANT, Paxon Hospital and for their complaint alleges as follows:

1. Plaintiff, for all times mentioned herein, was and is a resident of the County of

Jackson, State of Missouri. Plaintiff is informed and believes and thereon alleges that defendants, Answer to Paragraph 1, Defendants admits that plaintiff, was and is a resident of the County of Jackson, State of Missouri and denies the rest of the paragraph.

2. The cause of action took place in Ford County, Illinois.

Answer to Paragraph 2. Defendants do not have sufficient information or belief to enable them to answer said Paragraph and, on that ground, deny each and every allegation contained therein.
3. This is an action for damages in excess of the minimal jurisdictional limits

of this court.

Answer to paragraph 3. Defendants deny allegations that’s this court has proper jurisdiction to hear diversity cases as cited by Article III, §2 of the United States Constitution. The proper United States District is Northern District of Illinois. 4. Plaintiff is informed and believes and thereon alleges that defendants, Paxton Medical Center and medical staff including doctors, surgeons, and nurses was and is located in the County of Ford, State of Illinois. Answer to paragraph 4, Defendant agrees to allegation.

5. The cause of action took place in Ford County, Illinois. Answer to Paragraph 5, Defendants does not have sufficient information or belief to enable them to answer said Paragraph and, on that ground, denies each and every allegation contained therein. 6. This is an action for damages in excess of the minimal jurisdictional limits of this court.

Answer to paragraph 6, Defendants do not have sufficient information or belief to enable them to answer said Paragraph and, on that ground, denies each and every allegation contained therein 7. At all times herein mentioned, plaintiff was a patient in Paxton Medical Center and was treated by the medical staff of Paxton Medical Center, including doctors, surgeons, and nurses. Answer to paragraph 7, Defendants admits plaintiff allegations. 8. At all times herein mentioned, Paxton Medical Center, including doctors, surgeons and nurses is a county hospital located in Paxton, Illinois in the County of Ford, State of Illinois. Answer to paragraph 8, Defendants admit that Paxon Medical Center is an entity located in Illinois in the County of Ford, State of Illinois. 9. On or about April 5, 2001, at about the hour of 6:00 p.m., the plaintiff was

brought unconscious to Paxton Medical Center by ambulance and admitted to the

Hospital with nine fractured bones in his face. “The doctors at Paxton Medical Center

use a newly accepted technique to ‘secure’ and reset plaintiff’s facial bones. To allow

his facial bones to heal in place, the Doctors wire plaintiff’s jaws shut with metal wires.”

The plaintiff becomes upset and agitated with the wires that are holding his mouth shut

and a doctor at Paxton “administers a strong sedative to plaintiff and the hospital staff

handcuffs plaintiff’s wrists to his hospital bed.”

Answer to paragraph 9, Defendant agrees to allegation.

10. The defendants’ gross negligence and wanton disregard for the safety and care

of others with regard to the careless medical care given to plaintiff while in the care

of Paxton Medical Center, including doctors, surgeons, and nurses caused a considerable

amount of harm to plaintiff’s facial appearance, medical condition, and mental health.

Answer to Paragraph 10, Defendants do not have sufficient information or belief to enable them to...
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