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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