Free Response to Motion - District Court of Arizona - Arizona

v *1
I FHA?] ..__ I<<;i~:·;1;I
W .___ EECJEVED ____ @51-w {
Wl-IYVONNA M BARNETT 0 5
506 E- MCKAMEY i {r}LE.?`I!·{ · I S {WET +‘7w_;·"<“ gm Im I
PAYSON AZ. 85541 A a.1·re11-Instr I.I<‘.:·.I-;1.‘*<_i·a I I
I Y*¥E1'_____ rr _) ‘·;;_»L. gw! I
1928 474 5609 OR 1928978 3203 (CELL) "_`“ ``'`` M ` ’ `““"“··”
REPRESENTING SELF.
UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
WYVONNAM BARNETT CASE NO. 03 2566 PHX ROS
PLAINTIFF REGARDING :
VS. PLAINTIFPS RESPONSE TO:
MESA GENERAL HOSPITAL I ) MESA GEN. HOSP. FIRST SET OF
DEFENDANTS NON — UNIFORM IN TERROGATORIES
2 ) MOTION TO STRIKE PLAINTIFFS
AMENDED COMPLAINT
3 ) AND PLAINTIFFS RESPONSE T0
DEFENDANTS MGH . S ANSWER TO
FIRST AMENDED COMPLAINT
PORTIONS OF ARTICLE 1 ONE ABOVE WILL BE COVERED IN PLAINTIFFS NEXT
MOTION ENTITLED ( MOTION TO SETTLE .)
ANSWER AND RESPONSE TO ARTICLES 2 AND 3 ABOVE WILL ALSO BE COVERED IN
PLAINTIFFS MOTION TO SETTLE NOW BEING COMPLIED".
REGARDING # I ABOVE...
THIS INTERROGATION IS IN DIRECT VIOLATION OF HONORABLE JUDGE C VOSS’
ORDER THAT STATED ALL DISCOVERY MUST BE IN BY SEPT.. 30, 2005 WHOWEVER
IT APPEARS THAT HONORABLE SILVERS OVER RULED HONORABLE VOSS AND
ALLOWED AN EXTENSION EVEN THO DEFENDANTS ALREADY HAD 22 MONTHS TO
GET THEIR DISCOVERY IN.
REGARDING ARTICLE A PAGE ONE OF INTERROGATION :
ALL INFORMATION (HAS BEEN DIVULGED ) THAT IS RELEVENT TO THIS CASE
PLAINTIFF SIGNED RELEASE FORMS FROM MESA GENERAL HOSPITAL RELEASING
HER MEDICAL RECORDS APP. 2 YEARS AGO , .WI-IIC]-I DEFENDANTS HAVE COPYS
WHICH CONTAIN 250 PAGES AND WHICH ARE PRESUMED TO BE COMPLETE
I-IOWBEIT THESE RECORDS ARE VERY MIXED UP AND VERY CONFUSING.
ONE THING STANDS OUT IN PLAINTIFFS RECORDS , HOWEVER, AND THAT IS THE
FACT GROSS NEGLIGENCE OCCURRED WHEN MGH MIXED THE RECORDS OF MR.
RONALD BIESECKER A FELLOW PATIENT WITH PLAINTIFFS RECORDS SEE PAGES 139
AND 159 OF PLAINTIFFS MED. RECORDS.
MIXED RECORDS ALONE SHOULD BE SUFFIENT EVIDANCE TO PROVE GROSS
NEGLIGENCES AND GRANT PLAINTIFF HER RELIEF ....
· C : — - - é -
asc 2 03 cv 02566 ROS D0 ument 107 Fnled 12/05/2005 Page 1 of 4

•-·· \
SECONDLY PLAINTIFF SIGNED RELEASE FORMS WITH ADVANCED CARDIAC
SPECIALISTS ...( IF DEFENDANTS DO NOT HAVE THE INFORMATION FROM ACS IT
IS NOT PLAINTIFFS FAULT.
PLAINTIFFS ANSWER TO INTERROGATORIES
ART, I, PG 2 REGARDING HEALTH CARE GIVERS SINCE AUG. 2003.
MOLLY MOORE , JAYSON COOL , JENNIFER COOL 112 W CEDAR LANE PAYSON,
AZ. 85541
URGENT CARE , LAYTON STREET , IN SAN JACINTO, CALIFORNIA .92583 DR. THAT
WAS ON CALL .
HEMET GLOBAL URGENT CARE , 1545 W. FLORIDA, I-IEMET CALIFORNIA. DR. ON
CALL.
ARTICLE 2 PAGE 2
NO I HAVE NOT BEEN I-IOSPITALIZED ( NOT BECAUSE I DIDN’T NEED EMERGENCY
CARE BUT BECAUSE MY ACCESS HAD BEEN CANCELLEDN OV. 2003 AND MY
MEDICARE DID NOT BECOME ACTIVE UNTIL NOV. I .2005 . I COULD NOT
FINANCIALLY AFFORD TO SEEK PROFESSIONAL CARE EVEN WHEN I SUFFERED
THE SYMPTOMS OF OTHER HEART ATTACKS .. )
ARTICLE 3. PAGE NEGLIGENT ACTS CATHY STEVENS COMMITTED.
COVERED IN MOTION TO SETTLE BY PLAINTIFF.
ACCORDING TO MOTION FILED BY DEFENDANTS OCT 27, 2005 ...ARTICLE 4 STATES
THAT CATHY STEVENS w/as ( FORMALLY ) EM1>1.0Y12D FOR MESA GENERAL
HOSPITAL AS THE ( DIRECTOR OF RISK AND MANAGEMENT CONTROL ) SHE IS
NO LONGER WITH MESA GENERAL HOSPITAL .
CIRCUMSTANTIAL EVIDANCE ALONE IN THIS CASE WOULD BE SUFFIENT FOR THE .
COURT TO MAKE A FAVORABLE DECISION ON BEIIALF OF PLAINTIFF AND SETTLE
TI-IIS CASE AS CATHY STEVENS WAS A PRIMARY PARTY TO NEGLIGENCES BY
CAREGIVERS AS IT WAS HER RESPONSIBILITY TO KEEP PATIENTS SAFE AS HER
TITLE INPLYS.
ALTI-IO HIGHLY ILLEGAL , DEFENDANTS COUNSEL NOR CATHY STEVENS THOUGHT
IT NECESSARY TO NOTIFY THE COURT AND PLAINTIFF THAT CATHY STEVENS
WAS NO LONGER EMPLOYED FOR MESA GENERAL HOSPITAL OR SUPPLY TI·IE
I COURT AND PLAINTIFFS WITH CATHY STEVENS (NEW ) ADDRESS.
NOTE .PLAINTIFF WILL FILE A SEPARATE MOTION WITH THE COURT REGARDING
CATHY STEVENS DISAPPEAREN CE AND NEGLIGENCES AND ASK FOR A RULING
BASED ON CIRCUMSTANCIAL EVIDANCE AND NON COMPLIANCE.
ARTICLES A , B , C , AND D WILL BE COVERED IN THE ABOVE NOTED MOTION.
Case 2:03—cv—02566—ROS D0'€:%ment 107 Filed 12/05/2005 Page 2 of 4

THE FOUR CAREGIVERS NAMES(WAS TO BE SUPPLIED BY CATHY STEVENS).
AS NOTED IN HER DECLARATION FOR SUPPORT OF SUMMARY JUDGEMENT CATHY
STATES , QUOTE :
“ IN MY CAPICITY AS DIRECTOR OF QUILITY AND RISK MANAGEMENT , (I HAVE
ACCESS TO DOCUMENTS ) (WHICH ALLOW ME TO DETERMINE THE IDENTIES OF
PERSONS ENTPLOYED BY MESA GENERAL HOSPITAL.)
HOWEVER IN NUMEROUS DOCUMENDATION PLAINTIFF MADE IT CLEAR THE APP.
TIME THESE FOUR CAREGIVERS WAS PROVIDING CARE , CATHY DID NOT OBLIGE
THE COURT OR PLAINTIFF WITH THE NAMES OR OTHER RELEVENT INFORMATION
REGARDING THESE CAREGIVERS. EVEN THO ACCORDING TO HER ABOVE
STATEMENT ( SHE) HAD EASY ACCESS TO THAT INFORMATION.
CATHY STEVENS ( WAS ) OBLIGATED TO Tl-IE COURT, PLAINTIFF AND ALL
INTERESTED PARTIES TO PROVIDE THE NAMES OF THOSE PERSONS THAT PROVIDED
THE CARE TO PLAINTIFF. (.AT THE TIME THE NEGLIGENCES OCCURRED.)
INSTEAD HOWEVER CATHY CHOSE TO ( DISAPPEAR ) WITHOUT A TRACE BETWEEN
THE TIME SI-IE FILED HER DECLARATION IN SUPPORT OF DEFENDANTS SUMMARY
JUDGEMENT , THE TIME PLAINTIFF FILED AN AMENDED COMPLAINT THAT
INCLUDED I—IER,CATHY , AS A DEFENDANT. AND THE DATE OF DEFENDANTS
LAST MOTION DATED 10/ 27 I 05 ( LESS THAN THREE MONTHS. )
THEREFORE WHEN PLAINTIFF ATTEMPTED TO HAVE CATHY STEVENS SERVED WITH
A SUPEONA IN ORDER TO SUPPLY THE COURT WITH THE NAMES AND SCI-IEDUALS
AND OTHER DATA REGARDING THOSE FOUR CAREGIVERS , CATHY HAD
DISAPPEARED WITHOUT A TRACE. THE PROCESS SERVERS , SERVED WHOEVER
SUPPOSEDLY TOOK CATHYS PLACE
IT IS HARD TO BELIEVE THAT A PERSON WOULD ( WILLINGLY ) GIVE UP A JOB
THAT HAD SO MUCH CLOUT, SUPERIORITY AND POSSIBLE VERY GOOD MONEY IT
( APPEARS ) CATHY STEVENS BECAME A ( FORMER ) EMPLOYEE FOR MESA
GENERAL HOSPITAL (BECAUSE OF HER NEGLIGENCES ) , SOMEIM BEI WEEN
JULY OF 2005 AND OCT. 2005.
FUTHER THE ONE CAREGIVER THAT NEGLIGENTLY YANKED THE SHEATH OUT OF
PLAINTIFFS GROIN AT 2231 - (TIME) PAGE 158 MEDICAL RECORDS. (NEVER )
( SlGNED)THE DOCUMENT ALTHO REQUIRED .. THIS NEGLIGENT ACT ALMOST
CAUSED PLAINTIFF TO BLEED TO DEATH BEFORE THE BLOOD WAS STOPPED BY
ANOTHER CAREGIVER ...( EVIDANCED BY REGULAR NURSE AND TI-IE CAREGIVER
THAT ADMINSTERED AID. NAMES OF THESE CAREGIVERS ARE RELEVENT.
FACTS AND EVERY OTHER ISSUE REFERRED T0 IN DEFENDANTS
INTERROGATION MOTION WILL BE COVERED IN PLATNTIFF MOTION TO SETTLE ......
Case 2:03—cv—02566—FIOS D<§ument 107 Filed 12/05/2005 Page 3 of 4

COPYS MAILED TI-HS DAY NOV 30 2005 TO:
UNITED STATES DISSRSICT COURT
DISTRICT OF ARIZONA 401
W. WASH. PHX. AZ. 85003
HENDHAMMER AND COLBURN
394 N. THIRD AVE
PHX. AZ. 85003
•__r_ _,.-·""“'} ,3 G 5-" ff r {
l e’ fr
\ _/ ny I- J.,
Case 2:03—cv—02566—ROS Dgément 107 Filed 12/05/2005 Page 4 of 4

Case 2:03-cv-02566-ROS

Document 107

Filed 12/05/2005

Page 1 of 4

Case 2:03-cv-02566-ROS

Document 107

Filed 12/05/2005

Page 2 of 4

Case 2:03-cv-02566-ROS

Document 107

Filed 12/05/2005

Page 3 of 4

Case 2:03-cv-02566-ROS

Document 107

Filed 12/05/2005

Page 4 of 4