Filing # 78681081 E-Filed 10/01/2018 03:58:24 PM - Hospital Watchdog

Filing # 78681081 E-Filed 10/01/2018 03:58:24 PM

87328-9

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT

IN AND FOR PALM BEACH COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION

BARBARA DZIEDZIC; PAUL

DZIEDZIC, SR.; STACEY WILSON;

AND PAUL DZIEDZIC, JR.; each in

their individual capacities; and

BARBARA DZIEDZIC, as Personal

Representative of the Estate of

Joshua Dziedzic,

CASE NO. 502018CA007015XXXXMB

Div. AK

Plaintiffs,

v.

PALMS WEST HOSPITAL LIMITED

PARTNERSHIP, a Florida limited

partnership doing business as

PALMS WEST HOSPITAL;

COLUMBIA PALM BEACH GP, LLC,

a Delaware limited liability company;

and LINDA TRUEMPY, R.N.,

Defendants.

____________________________/

DEFENDANTS¡¯ ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFFS¡¯ FIRST

AMENDED COMPLAINT

COME

NOW

the

Defendants,

PALMS

WEST

HOSPITAL

LIMITED

PARTNERSHIP d/b/a PALMS WEST HOSPITAL; COLUMBIA PALM BEACH GP, LLC;

and LINDA TRUEMPY, R.N., by and through the undersigned counsel, and hereby file

their Answer and Affirmative Defenses to Plaintiffs¡¯ First Amended Complaint, and

hereby state as follows:

Introduction

1.

These Defendants deny the allegations as to malpractice that caused the death

of Joshua Dziedzic, set forth in this paragraph of Plaintiffs¡¯ First Amended Complaint,

and demand strict proof thereof.

CASE NO. 502018CA007015XXXXMB Div. AK

2.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint and demand strict proof thereof.

3.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

4.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

5.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

6.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

7.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

8.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint, and demand strict proof thereof.

The Defendants

9.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

10.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

11.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

-2-

CASE NO. 502018CA007015XXXXMB Div. AK

12.

These Defendants admit the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint.

13.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

Common Facts

14.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

15.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint as to the ¡°malpractice which caused¡± Joshua¡¯s death, and are

without knowledge as to the remaining allegations set forth in this paragraph of

Plaintiffs¡¯ First Amended Complaint.

16.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

17.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

18.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

19.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

20.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

-3-

CASE NO. 502018CA007015XXXXMB Div. AK

21.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

22.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

23.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

24.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

25.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

26.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

27.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

28.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

29.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

30.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

31.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

-4-

CASE NO. 502018CA007015XXXXMB Div. AK

32.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint and demand strict proof thereof.

33.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

34.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

35.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint and demand strict proof thereof.

36.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint and demand strict proof thereof.

37.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint and demand strict proof thereof.

38.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint and demand strict proof thereof.

39.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint and demand strict proof thereof.

40.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint and demand strict proof thereof.

41.

These Defendants deny the allegations set forth in this paragraph of Plaintiffs¡¯

First Amended Complaint and demand strict proof thereof.

42.

These Defendants are without knowledge as to the allegations set forth in this

paragraph of Plaintiffs¡¯ First Amended Complaint.

-5-

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