Free Other Notice - District Court of Arizona - Arizona

54 'IIIIS 1JOCIIMEN'I` IS §_Q;I_1N PROPER FORM ACCORDING
TO FEDERAI. AND/OR LOCAL RULES ANI) PRACTICES \
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T T (Rule Number/Section] — RECEIVED ——-- - VCPY
WYVONNA M BARNETT
506 EAST MCKAMEY DCT I 4
PAYSON ARIZONA 55541 eww 0 e D!STI—NC1 I;-Inear
DISTRICT CDF ARIZONA
I 928 474 5609 OR 1 928 978 3203 BY V ,_] ggpgw
REPRESENTING SELF
UNITED SATES DISTRICT COURT
DISTRICT OF ARIZONA
WYVONNA M BARNETT CASE NO. 03 2566 PHX ROS
PLAINTIFF SUPPLEMENTAL ALL DISCOVERY
VS MATERIAL DISCLOSURES ,EXIBITS
MESA GENERAL HOSPITAL (ADDITIONAL DEFENDANTS)
DEFENDANTS
AS PER HONORABLE EDWARDCVOSS” SCI-IEDULING ORDER DATED DEC 7, 2005
PAGE 2 ARTICLE G WHICH STATES:
THE PARTIES SHALL FINALLY SUPPLEMENT ( ALL) DISCOVERY , INCLUDING
MATERIAL CHANGES IN EXPERT WITNESS OPINIONS AND MATERIAL DISCLOSURES ,
PURSUANT TO FRCP 26(A}(3),OF ALL EXIBITS TO BE USED AND ALL WITNESSES
TO BE CALLED AT TRIAL
PLAINTIFFS CASE IS A (RES IPSA LOQUITUR CASE ) IT SPEAKS FOR ITSELF.
A THIRD SURGERY WOULD NOT HAVE BEEN NECESSARY HAD PLAINTIFF NOT
SUFFERED DAMAGE .... DUE TO GROSS NEGLIGENCES BY MESA GENERAL HOSPITAL S
PRESUMED (PROFESSIONAL ? ) CAREGIVERS ¤SEE DETAIL OF INTENSE SURGERY TO
REPAIR DAMAGE. PAGE 191 OF MEDICAL RECORDS ATTACHED HERETO.
FUTI-IER CASE FALLS UNDER ( NEGLIGENCE PER SE ) AND ( BREACH OF
STANDARD OF CARE.) SEE ATTACHED ( EX 1 (ZPAGES )
MATERIAL DISCLOSURES AND EXIBITS ....
( SUMMARY ) ATTACHED DEFINES MEDICAL MALPRACTICE SUITS AND OTHER
RELEVENT INFORMATION .
98,000 PEOPLE A YEAR LOSE THEIR LIVES DUE TO GROSS NEGLIGENCES BY THEIR
CAREGIVERS.
PLAINTIFFS CASE COINCIDES WITH ALL THE REQUIREMENTS NECESSARY FOR
FILING A MEDICAL MALPRACTICE SUIT.
PLAINTIFF SUFFERED SEVER AND IRREVERSIBLE DAMAGE FROM GROSS
NEGLIGENCES BY MESA GENERAL HOSPITAL AND CAREGIVERS.
Case 2:03—cv—02566—ROS Document 100 Filed 10/14/2005 Pege1 014

1 Y
EXIBITS AND MATERIAL DISCLOSURES
GROSS NEGLIGENCES.
SEE SUMARY .... 9 PAGES
SEE ALSO PAGES 139 , 159 , 101 , 140 , 191 , 113 AND 114 OF PLAINTIFFS
MEDICAL RECORDS( MESA GENERAL HOSPITAL.) ATTACHED I-IERETO .
SEE ALSO PAGES 1 THRU 10 OF EXIBIT (DIAGRAMS ) ..ATTACHED HERETO.
SEE ALSO PICTURES .. EXIBIT ( ONE )
VISUAL EVIDANCES BY VEWING LEFT HAND .. PROOF OF COLLESPED VEINS AND
LONG SURGERY INCISION IN GROIN TO REPAIR DAMAGED ARTERY AND VEIN ....
NOTE ALT]-IO PLAINTIFF WAS 60 YEARS OLD ATTI-IE TIME AND HADBORN 5
CHILDREN .. SHE HAD NO SCARS ON HER BODY , NOT EVEN STREACI-I MARKS..
NOW EVERYTIME PLAINTIFF SHOWERS SI-IE IS REMINDED OF ALL THE
UNNECESSARY PAIN AND SUFFERING SHE I-IAD TO ENDURE AND HOW CLOSE SHE
CAME TO DEATH MORE 'I`I-IAN ONCE BY THESE NEGLIGENT CAREGIVERS.
EXIBITS REGARDING GROSS NEGLIGENCES
A ) PAGE 139 OF MEDICAL RECORDS VARIFY GROSS NEGLIGENCE
( ANOTHER PATIENTS RECORDS WERE MIXED IN PLAINTIFFS FILES.)
B ) PAGE 159 OF MEDICAL RECORDS VARIFY GROSS NEGLIGENCE
( MORE MEDICAL RECORDS OF SAME PATIENTS RECORDS MIXED IN PLAINTIFFS
FILES )...
C ) PAGE 101 OF MEDICAL RECORDS BY DR CHARLES JOST , HEART SURGERON.
VARIFY RESULT GROSS NEGLIGENCES ( ARTERVENOUS SHUNT)
PAGE 101 VARIFYS ARTERVENOUS SHUNT, ( INCISION IN PLAINTIFFS LARGE
FEMORAL ( VEIN) THAT HAD NOTHING TODO WITH REQUIRED SURGERY.
BUT RATHER
THIS DAMAGE WAS CAUSED WHEN PLAINTIFFS BODY LURCHED UPWARDS OFF TI-[E
OPERATING TABLE WHEN INCISION WAS MADE INTO THE GROIN .....
C22
Case 2:03—cv—02566—F1OS Document 100 Filed 10/14/2005 Page 2 014

DUE TO THE FACT( PLAIN'I"IFI·` WAS NOT SEDATED) ..DUE TO TI-IE FACT SI-IE WAS
ASSIGNED TWO CAREGIVERS ( NURSES ) WH0 FAILED TO USE REQUIRED
[STANDARD OF CARE) AND WERE UNSKILLED TO DO THE PROCEDURES THAT
THEY WERE ASSIGNED TO DO ..DUE ALSO TO THE FACT THAT THESE CAREGIVERS
WERE ( UNSUPERVISED) AND ( IT WAS THEIR FIRST DAY OF EMPLOYMENT)
.... BY MESA GENERAL HOSPITAL. FOR BOTH OF THEM.
D ) PAGE 140 OF MEDICAL RECORDS ...VARIFY MORE GROSS NEGLIGENCES
ARTERIAL EXAMINATION OF THE RIGHT GROIN VARIFY S :
I ) I-IEMATOMA IN RIGHT GROIN. - POOLING OF BLOOD INTERNALLY .
2 ) COMMUNICATION OF BLOOD BETWEEN THE RIGHT FEMORAL ARTERY AND TI-IE
LARGE FEMORAL VEIN AT THE SEPI-INOFEMORAL IUNCTION. DIAGNOSED AS AN
ARTERVENOUS FISTULA ...BY ULTERSOUND TECH., .....
3 ) NECK MBASURED I. 7 .X-4.8 MILIMETERS WITH A JET ( BLOOD STREAM) OF
220 CENTIMETERS PER SECOND.
NOTE GROSS NEGLIGENCES
BY N”URSE(CAREGIVER) NO. 4 WI-IO DID NOT SIGN THE DOCUMENT AS
TNSTRUCTED SEE PAGE 159 OF MEDICAL RECORDS WI-IEREIN THIS CAREGIVER
PULLED THE SI-IEATH .... THE SHEATH IS THE INSTRUMENT PLACED IN TI-IE GROIN,
( RIGHT FEMORAL ARTERY ) WI-IEREIN TI-IE TUBES ECT AREUSED T0 TRANSPORT
STENTS TO REPAIR HEART.
IT WAS AT THIS TIME ( 2231 AM ) ON 7/ 8/ 03 TILAT PLAINTIFF ALMOST BLED TO
DEATH DUE TO THE NEGLIGENCE OF THIS NURSE. AND TO COMPLICATE THE
ALREADY SERIOUS CONDITION CREATED BY THREE OTHER NEGLIGENT
CAREGIVERS".
THIS NEGLIGENT INEXPERIANCED NURSE WAS UNABLE TO PERFORM THE DUTIES
SHE EITHER TOOK UPON HERSELF OR WHICH WERE ASSIGNED TO HER
THEREBY LEAVING PLAINTIFFS RIGHT ARTERY OPEN ( INSIDE) CAUSING PLAINTIFF
T0 CONTINUE TO BLED INTERNALLY AND ADDING MORE COMPLICATIONS WHEN
BLOOD CROSSED OVER PERIPHERIAL NERVES AND INTO THE LARGE FEMORAL VEIN
WHICH I-IAD BEEN CUT AT TIME OF SURGERY DUE TO OTHER NEGLIGENT PERSONAL
WHO FAILED TO PROPERLY SEDATE PLAINTIFF( PRIOR TO SURGERY)
PLAINTIFFS BLOOD WAS THEN RECYCLING THRU HER BODY, LITTERLY
POISONING PLAINTIFFS ENTIRE BODY AND SETTING OFF A CHAIN OF INFECTIONS
AND COMPLICATIONS THAT MAY YET LEAVE PLAINTIFF PARALYSEDWSEE EXIBITS
( DIAGRAMS) PAGES I TI-[RU 8.
Case 2:03—cv—02566—FIOS @ment 100 Filed 10/14/2005 Page 3 of 4

NEGLIGENT NURSE " BILLY " ( NICKNAME) PUT IV IN TOP OF PLAIN] IFFS
LEFT HAND CONTRARY TO FACT THAT PLAINTIFF SPECIFICALLY REQUESTED I-[ER TO
USE ANOTHER VEIN .. AS PLAINTIFFS HAD ONLY TWO LARGE VEINS ON TOP OF
THAT HAND AND ONE OF THEM HAD ALREADY COLLESPEDS
IN ADDITION TO THIS NURSE FAILING TO DO AS PLAINTIFF REQUESTED SHE MADE
A VERY RUDE AND ARROGANT REMARK TO PLAINTIFF QUOTE " MY NAME IS
BILLY , IVE BEEN HERE THIRTY YEARS AND I KNOW WHAT I"M DOING.
WELL OBVIOUSLY SHE DID NOT DUE TO THE FACT SHE DID CAUSE THAT VEIN TO
COLLESPE AND NOW ALL OF THE BLOOD THAT ORIGINALLY WOULD HAVE BEEN
PUMPED THRU THE TWO LARGE VEINS HAVE TO BE PUMPED THRU THE VERY
SMALL VEIN UNDER PLAINTIFFS LEFT WRIST....(VISUAL EVIDANCE.)
CAUSING MUCH MORE PRESSURE AND STRESS ON PLAINTIFFS DAMAGED HEART.
PLAINTIFF NOT SEDATED PRIOR TO SURGERY
# 2 AND # 3 NEGLIGENT CAREGIVERS , MESA GENERAL HOSPITAL.
PLAINTIFF DOES NOT KNOW TI-IE. NAMES OF THESE CAREGIVERS ,EITI-IER AND HAS
SUBPOENED THEIR NAMES FROM CATHY STEVENS AS WELL.
THESE TWO NURSES WERE ACTING FRUSTRATEDJIURRIED AND CONFUSED WHILE
ATTEMPTING TO PREPARE PLAINTIFF FOR SURGERY .
ONE OF THEM HAD ALREADY GIVEN PLAINTIFF MEDICATION SHE WAS ALLERGIC
TO ,
WHICH CAUSED PLAINTIFF TROUBLE BREATHING AND STARTED HER TI-IROAT TO
SWELL, BEFORE PLAINTIFF WAS ABLE TO MAKE HER AWARE OF THE PROBLEM".
BOTH OF THEM INFORMED PLAINTIFF AT THAT TIME " NOT PAY ANY ATTENTION
TO THEM AS IT WAS THE FIRST DAY FOR BOTH OF TI~IEM..." UNQUOTE
CAN YOU IMAGINE THE FEAR AND ANXIETY THAT PLAINTIFF WENT THRU
KNOWING SHE WAS GOING IN FOR HEART SURGERY AND]-IAD BEEN ASSIGNED
( TWO} CARE GIVERS WHO HAD ALREADY SHOWN THEIR INABILITY TO PERFORM
THEIR PROFESSIONAL DUTIES AND BREACHED THE STANDARD OF CARE AND YET
THEY WERE ( UNSUPERVISED)
THIS CONFIRMS THE REASON FOR THIS LAWSUIT ON MEDICAL MALPRACTICE .. AND
THIS WAS ONLY THE BEGINNING OF NEGLIGENCES.
SI-IEATH SUTURED IN RIGHT FEMORAL ARTERY
ONE OR BOTH OF THE ABOVE MENTIONED NURSES HAVING NOT PROPERLY
SEDATED PLAINTIFF .... AND PLAINTIFFS BODY LURCI-IING UPWARD WHEN
PLAINTIFFS FEMORAI., ARTERY WAS CUT INTO INTI-IE GROIN AREA , CAUSING
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