Answer 1- affirmative defenses and counterclaim for declarative relief in med mal suit

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Defendant Gregory Nacopoulos, D.O.'s Answer, Affirmative Defenses and Counterclaim for Declaratory Relief

Donohue Brown Mathewson & Smyth LLC, Richard H. Donohue, One of the for defendant, Gregory Nacopoulos, D.O., I.D. 32878, Richard H. Donohue, Karen Kies DeGrand, Kristin M. Gruss, Edward E. Fu, Donohue Brown Mathewson & Smyth LLC, 140 South Dearborn Street, Suite 800, Chicago, IL 60603, (312) 422-0900.

Hon. Diane J. Larsen, Judge Presiding.

NOW COMES the defendant, GREGORY NACOPOULOS, D.O, by and through his attorneys in this regard, Richard H. Donohue, Kristin M. Gruss and Edward E. Fu of DONOHUE BROWN MATHEWSON & SMYTH LLC; and Saul J. Morse of BROWN, HAY & STEPHENS LLP, and hereby answers plaintiff's complaint at law as follows:

Count I (Negligence)

1. That at all times relevant, defendant GREGORY NACOPOULOS, D.O., was a physician licensed to practice medicine in the State of Illinois.

ANSWER, Defendant admits the allegations set forth in paragraph 1 of Count I of plaintiff's complaint at law.

2. That at all times relevant, defendant SWEDISH COVENANT HOSPITAL was a corporation authorized to do business in the State of Illinois.

ANSWER, The allegations in paragraph 2 of Count I of plaintiff's complaint at law are not directed to this defendant, and therefore no answer is required. To the extent that any of the allegations set forth in paragraph 2 of Count I of plaintiff's complaint at law are deemed to be directed to this defendant, this defendant lacks sufficient knowledge to form a belief as to the truth of those allegations and on that basis denies them.

3. That at all times relevant, defendant SWEDISH COVENANT HOSPITAL owned, operated, managed and maintained SWEDISH COVENANT HOSPITAL in Chicago, Cook County, Illinois, wherein it provided patients medical, surgical, nursing and other healthcare treatment by and through its duly authorized agents, employees and/or servants.

ANSWER, The allegations set forth in paragraph 3 of Count I of plaintiff's complaint at law are not directed to this defendant, therefore no answer is required. To the extent that any of the allegations set forth in paragraph 3 of Count I are deemed to be directed to this defendant, this defendant lacks sufficient knowledge to form a belief as to the truth of those allegations and on that basis denies them.

4. That at all times relevant, defendant GREGORY NACOPOULOS, D.O., was the agent, employee and/or servant of defendant SWEDISH COVENANT HOSPITAL.

ANSWER, This defendant denies the allegations set forth in paragraph 4 of Count I of plaintiff's complaint at law.

5. That at all times relevant, defendant GREGORY NACOPOULOS, D.O., was the apparent agent of defendant SWEDISH COVENANT HOSPITAL.

ANSWER, Defendant makes no answer to the allegations contained in paragraph 5 of Count I of plaintiff's complaint at law because the allegations contain a conclusion of law rather than an averment of fact so that no answer is required. To the extent that an answer maybe required, this defendant denies said allegations.

6. That on July 19,2006, plaintiff DUSTY ALEXANDER, age 33, was the victim of a crime wherein he was attacked and sustained a gunshot wound to his lower right leg which lacerated his popliteal artery.

ANSWER, This defendant admits that on July 19, 2006, plaintiff sustained a gunshot wound to his lower right leg. This defendant lacks sufficient knowledge to form a belief as to the truth of the remaining factual allegations set forth in paragraph 6 of Count I of plaintiff's complaint at law and on that basis denies them. Further, to the extent that paragraph 6 contains conclusions of law rather than averments of fact, no answer is required. To the extent that an answer may be required, this defendant denies said allegations.

7. That on July 19, 2006, plaintiff DUSTY ALEXANDER was taken by Chicago Fire Department paramedics to defendant SWEDISH COVENANT HOSPITAL.

ANSWER, On information and belief, this defendant admits the allegations set forth in paragraph 7 of Count I of plaintiff's complaint at law.

8. That from July 19, 2006 through August 4, 2006, plaintiff DUSTY ALEXANDER was an in-patient at SWEDISH COVENANT HOSPITAL wherein he received medical, surgical, nursing and other healthcare treatment by and through the duly authorized agents, employees, and/or servants of defendant SWEDISH COVENANT HOSPITAL, including but not limited to the agent named herein.

ANSWER, This defendant admits that he provided medical care to plaintiff on July 19, 2006, at Swedish Covenant Hospital's emergency room and that he subsequently performed surgery on plaintiff on July 19, July 20, July 22, and August 1, 2006. Further, to the extent that paragraph 8 contains conclusions of law rather than averments of fact, no answer is required. To the extent that an answer may be required, this defendant denies said allegations to the extent to which they are inconsistent with the foregoing.

9. That on July 19,2006, plaintiff DUSTY ALEXANDER underwent surgery to address the wound in his right leg.

ANSWER, This defendant admits the allegations set forth in paragraph 9 of Count I of plaintiff's complaint at law.

10. That defendant GREGORY NACOPOULOS, D.O., was the attending surgeon during the plaintiffs surgery on July 19, 2006.

ANSWER, This defendant admits the allegations set forth in paragraph 10 of Count I of plaintiff's complaint at law.

11. That on July 20,2006, plaintiff DUSTY ALEXANDER underwent surgery to repair his occluded popliteal artery in his right leg.

ANSWER, This defendant admits that on July 20, 2006, plaintiff underwent a second surgery performed on his right leg. Further answering, this defendant denies that the allegations contained in paragraph 11 of Count I of plaintiff's complaint at law fully and accurately set forth the nature of the medical and surgical care rendered at that time.

12. That defendant GREGORY NACOPOULOS, D.O., was the attending surgeon during the plaintiff's surgery on July 20, 2006.

ANSWER, This defendant admits the allegations set forth in paragraph 12 of Count I of plaintiff's complaint at law.

13. That on July 22, 2006, plaintiff DUSTY ALEXANDER underwent surgery for the performance of fasciotomies on his right leg.

ANSWER, This defendant admits that on July 22, 2006, plaintiff underwent surgery to his right leg, including the performance of fasciotomies. Further answering, this defendant denies that the allegations contained in paragraph 13 of Count I of plaintiff's complaint at law fully and accurately set forth the nature of the medical and surgical care rendered at that time.

14. That defendant GREGORY NACOPOULOS, D.O., was the attending surgeon during the plaintiff's surgery on July 22, 2006.

ANSWER, This defendant admits the allegations set forth in paragraph 14 of Count I of plaintiff's complaint at law.

15. That the care and treatment by defendants GREGORY NACOPOULOS, D.O., SWEDISH COVENANT HOSPITAL, and each of them, was directed toward restoring necessary blood flow within and down plaintiff's right lower leg.

ANSWER, This defendant admits that attempting to restore blood flow to plaintiff's right lower leg was part of the care and treatment provided by defendant. Further answering, this defendant denies the remaining allegations set forth in paragraph 15 of Count I of plaintiff's complaint at law to the extent to which they are inconsistent with the foregoing

16. That given the nature of plaintiff DUSTY ALEXANDER'S injuries, with proper surgical, medical and nursing care and treatment, his right leg should have been repaired and healed with full function.

ANSWER, This defendant denies the allegations set forth in paragraph 16 of Count I of plaintiff's complaint at law.

17. That the care and treatment by defendants GREGORY NACOPOULOS, D.O., SWEDISH COVENANT HOSPITAL, and each of them, did not salvage plaintiff's right leg, rather, the negligence of the defendants allowed increased pressure and diminished blood flow below the injury to exist for days, causing the crushing of muscle and nerve tissue and, ultimately, tissue death and gangrene, which resulted in the putrefaction and liquification of lower leg tissue. See the operative report from August 14, 2006, attached hereto as Exhibit A.

ANSWER, This defendant denies the allegations set forth in paragraph 17 of Count I of plaintiff's complaint at law.

18. That on August 18,2006, plaintiff DUSTY ALEXANDER underwent amputation of his right leg.

ANSWER, On information and belief, this defendant understands that on August 18, 2006, plaintiff underwent a below the knee amputation of his right leg at Rush University Medical Center.

19. That plaintiff DUSTY ALEXANDER, age 33, will continue to endure pain and suffering, disability and disfigurement and loss of normal life for approximately the next 42 years. See the Life Table from the National Vital Statistics Report from the Department of Health and Human Services and the Center for Disease Control (June 28, 2006) attached hereto as Exhibit B.

ANSWER, This defendant lacks sufficient knowledge to form a belief as the truth of the allegations set forth in paragraph 19 of Count I of plaintiff's complaint at law and on that basis denies them.

20. That at all times relevant, defendants GREGORY NACOPOULOS, D.O., SWEDISH COVENANT HOSPITAL, and each of them, had the duty to possess and apply the knowledge and use the skill and care ordinarily used by reasonably careful medical providers in the same or similar circumstances in their care and treatment of the plaintiff, DUSTY ALEXANDER.

ANSWER, This defendant denies that the allegations set forth in paragraph 20 of Count I of plaintiff's complaint at law correctly set forth the nature of any legal duties owed to plaintiff by this defendant.

21. That notwithstanding the aforementioned duty, defendants GREGORY NACOPOULOS, D.O, SWEDISH COVENANT HOSPITAL, and each of them, breached their duty in by committing one or more of the following careless and/or negligent acts and/or omissions:

a. Failed to properly diagnose and treat plaintiff's right leg;

b. Failed to utilize correct and reasonable surgical techniques in addressing the damage to plaintiff's right leg during the July 19, 20 and 22,2006, surgeries;

c. Utilized incorrect and unreasonable surgical techniques in repairing the damage to plaintiff's right leg during the July 19,20, and 22,2006, surgeries;

d. Failed to timely and adequately repair the damage to plaintiff's leg during the surgeries on July 19, 20, and 22, 2006;

e. Failed to timely recognize and diagnose decreased blood flow in the plaintiff's right leg;

f. Failed to reasonably and timely assess complications with plaintiffs right leg;

g. Failed to timely perform surgery on plaintiff's right leg when his condition required it;

h. Utilized incorrect diagnostic measures in assessing plaintiff's condition;

i. Failed to utilize correct diagnostic measures in assessing plaintiff's condition

j. Failed to comply with and reasonably carry out orders for plaintiff's care;

k. Failed to timely recognize occlusion in plaintiff's right leg;

l. Failed to perform timely and adequate fasciotomies on plaintiff's right leg;

m. Failed to reasonably and correctly monitor patient's condition and care;

n. Failed to reasonably and correctly manage plaintiff's condition and care;

o. Plaintiffs treating healthcare providers failed to timely and adequately communicate among themselves concerning plaintiffs condition;

p. Were otherwise careless and negligent.

ANSWER, This defendant denies each and every allegation set forth in paragraph 21 of Count I of plaintiff's complaint at law, including subparagraphs (a) through (p) thereof.

22. That as a direct and proximate result of one or more of the aforementioned careless and/or negligent acts and/or omissions, plaintiff DUSTY ALEXANDER suffered permanent damage and injuries of a personal and pecuniary nature, and he will continue to suffer said damage and injuries in the future.

ANSWER, This defendant denies the allegations set forth in paragraph 22 of Count I of plaintiff's complaint at law.

23. That plaintiff attaches a physician's report and attorney's affidavit pursuant to 735 ILCS 5/2-622.

ANSWER, This defendant admits that plaintiff has attached to his complaint reports that purport to have been prepared by a physician but denies that said attachments comply with the statutory prerequisites set forth in section 2-622 of the Code of Civil Procedure, 735 ILCS 5/2-622 (West 2006).

WHEREFORE, for the foregoing reasons, this defendant, GREGORY NACOPOULOS, D.O., denies that plaintiff is entitled to judgment in a sum in excess of $50,000.00, or to any sum whatsoever, and prays for the entry of judgment in his favor, with costs assessed against the plaintiff.

Count II (Declaration of Unconstitutionality)

1-22. That the plaintiff reasserts and realleges paragraphs one through twenty-two of Count I as paragraphs one through twenty-two of Count II, as though fully set forth herein.

ANSWER, This defendant repeats and realleges his responses to the allegations set forth in paragraphs 1 through 22 of Count I of plaintiff's complaint at law as his answers to paragraphs 1 through 22 of Count II, as if fully set forth herein.

23. That plaintiff, DUSTY ALEXANDER, desires a judicial determination of his legal rights with respect to Public Law 94-677, as well as a judicial determination that provisions of Public Law 94-677 found applicable to this action violate the Illinois Constitution.

ANSWER, This defendant denies that plaintiff is entitled to the relief requested in paragraph 23 of Count II of plaintiff's complaint at law. Answering further, this defendant denies that any provision of Public Act 94-- 677, or the Act as a whole, violates the Illinois Constitution.

24. That plaintiff, DUSTY ALEXANDER, has sustained disability, disfigurement, pain and suffering to the extent that damages for those injuries will greatly exceed the applicable limitations on non-economic damages under Public Law 94-677, codified at 735 ILCS 5/21706.5.

ANSWER, This defendant denies the allegations set forth in paragraph 24 of Count I of plaintiff's complaint at law.

25. That the limitation on non-economic damages codified at 735 ILCS 5/2-1706.5 violates the separation of powers mandated by Article II, § 1 of the Illinois Constitution by permitting the General Assembly to supplant the judiciary in determining whether a remittitur is appropriate under the facts and verdict of this case. The Illinois Constitution denies the Legislature such authority by granting it only legislative, rather than judicial, authority. Ill. Const, art. II, § 1 ; Best v. Taylor Machine Works, Inc., 179 I11.2d 367, 689 N.E.2d 1057 (1997).

ANSWER, Paragraph 25 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 25 of Count II of plaintiff's complaint at law.

26. That the limitation on non-economic damages codified at 735 ILCS 5/2-1706.5 constitutes special legislation in violation of Article IV, § 13 of the Illinois Constitution because, to the substantial detriment of plaintiff DUSTY ALEXANDER, the restrictions on non-economic damages grant limited liability specially and without just cause to a select group of health care provider defendants. No other defendants receive such special consideration, and no other injured plaintiffs suffer under such a special legal disability. Further, there are no reasonable differences in kind or situation that would justify the disparate treatment.

ANSWER, Paragraph 26 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 26 of Count II of plaintiffs complaint at law.

27. That the limitation on non-economic damages codified at 735 ILCS 5/2-1706.5 violates plaintiff DUSTY ALEXANDER'S “inviolate” right to trial by jury, guaranteed in Article I, § 13 of the Illinois Constitution, by supplanting the jury's determination of facts proven a trial, namely, proper compensation, and substituting a legislative determination that overrides the facts proven at trial or the jury's determination of those facts, thereby denying Plaintiff's right to trial by jury.

ANSWER, Paragraph 27 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 27 of Count II of plaintiff's complaint at law.

28. That the limitation on non-economic damages codified at 735 ILCS 5/2-1706.5 violates due process as guaranteed in Article I, § 2 of the Illinois Constitution because the limitations do not further a compelling state interest in the least restrictive manner nor bear a rational relationship to a legitimate public purpose.

ANSWER, Paragraph 28 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 28, Count II of plaintiff's complaint at law.

29. That the limitation on non-economic damages codified at 735 ILCS 5/2-1706.5 violates equal protection as guaranteed by Article I, § 2 of the Illinois Constitution by treating plaintiff DUSTY ALEXANDER differently from less seriously injured victims of medical negligence or similarly situated victims of other forms of negligence. Those individuals receive full compensation for their non-economic damages whereas plaintiff DUSTY ALEXANDER will not under 735 ILCS 5/2-1706.5.

ANSWER, Paragraph 29 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 29 of Count II of plaintiff's complaint at law.

30. That the limitation on non-economic damages codified at 735 ILCS 5/2-1706.5 violates the right to a certain and complete remedy guaranteed by Article I, § 12 of the Illinois Constitution by limiting the remedy of plaintiff DUSTY ALEXANDER without providing a reasonably just substitute for that more limited remedy.

ANSWER, Paragraph 30 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 30 of Count II of plaintiff's complaint at law.

31. That once this matter is reduced to final judgment, Public Law 94-677, codified at 735 ILCS 5/2-1704.5, will prevent plaintiff DUSTY ALEXANDER from realizing the full amount of that judgment immediately by enabling Defendants to elect to pay those damages periodically over a lengthy period of time. Enactment of the periodic payment provision exceeded the Legislature's authority as an invasion of judicial authority over the procedural mechanisms that operate in court in violation of the separation of powers established in Article II, § 1 of the Illinois Constitution.

ANSWER, Paragraph 31 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 31 of Count II of plaintiff's complaint at law.

32. That defendant's option to elect periodic payments under 735 ILCS 5/2-1704.5 results in a double reduction of the plaintiff DUSTY ALEXANDER'S judgment because future damages for medical expenses and lost earnings are already required to be discounted to present value. See Schaffher v. Chi. & N. W. Transp. Co., 129 Ill.2d 1,25,541 N.E.2d 643 (1989). If a defendant can choose to pay such future damages over a period of time and purchase an annuity to pay damages already reduced to present value, there would be an arbitrary additional reduction of that judgment that lacks any rational basis; treats plaintiffs in tort cases differently, without rational basis, from plaintiffs obtaining similar compensation in non-tort cases; and arbitrarily and without commensurate benefit to plaintiffs effects a reduction in their appropriate compensation. In addition, the periodic payment scheme forces the plaintiff to accept the risks of insolvency or liquidation of the insurance company holding the annuity. As such, the provision violates Plaintiff's due process and equal protection rights under Article I, § 2 and the guarantee against a taking of private property without just compensation under Article I, § 15 of the Illinois Constitution.

ANSWER, Paragraph 32 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 32 of Count II of plaintiff's complaint at law.

33. That enactment of the periodic payment provision constitutes unconstitutional special legislation under Article IV, § 13 of the Illinois Constitution by providing a select group of health-care defendants, specially and without just cause, the authority to elect to pay certain damages in the future, while other defendants do not have that right, and conversely burdening only victims of malpractice with that limitation on their ability to collect their full judgment.

ANSWER, Paragraph 33 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 33 of Count II of plaintiff's complaint at law.

34. That enactment of the periodic payment provision conflicts with the right to trial by jury guaranteed by the Illinois Constitution, Art. I, § 13, by denying plaintiff DUSTY ALEXANDER the right to collect the full amount of the judgment when it becomes final, thereby revising the import and effect of the jury's verdict.

ANSWER, Paragraph 34 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 34 of Count II of plaintiff's complaint at law.

35. That enactment of the periodic payment provision violates plaintiff DUSTY ALEXANDER'S rights to due process and equal protection under Article I, § 2 of the Illinois Constitution by arbitrarily imposing delayed payment of judgment on the Plaintiff at the Defendant's option and without rational basis, while treating plaintiffs injured by medical negligence differently from similarly situated plaintiffs injured by other types of negligence.

ANSWER, Paragraph 35 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 35 of Count II of plaintiff's complaint at law.

36. That to prove departures from the standard of care in this case, the plaintiff DUSTY ALEXANDER will require expert evidence, and that the limitation under Public Law 94-677, codified at 735 ILCS 5/8-2501, on the types of experts whose testimony may be used by Plaintiffs to establish liability exceeds the Legislature's authority, invades the judiciary's authority to set rules of practice and violates separation of powers as guaranteed in Article II, § 1 of the Illinois Constitution.

ANSWER, Paragraph 36 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 36 of Count II of plaintiff's complaint at law.

37. That the limitations on eligible experts to testify under 735 ILCS 5/8-2501 constitute a form of impermissible favoritism for certain defendants, namely, a select group of health care providers, as well as an impermissible form of discrimination against certain plaintiffs, namely, plaintiffs in medical malpractice cases, and thereby violate the special legislation provision of Article IV, § 13 of the Illinois Constitution.

ANSWER, Paragraph 37 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 37 of Count II of plaintiff's complaint at law.

38. That the limitations on eligible experts further violate the due process and equal protection guarantees of Art. I, § 2 of the Illinois Constitution because they prohibit credible and medically sound testimony that would be helpful to the fact finder in ascertaining the truth of the allegations, as well as treat plaintiffs in medical malpractice cases differently and more adversely than other victims of negligence.

ANSWER, Paragraph 38 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 38 of Count II of plaintiff's complaint at law.

39. That the “certificate of merit” requirement, codified at 735 ILCS 5/2-622, invades the judiciary's authority to set rules of practice and thus violates separation of powers as guaranteed by Article II, § 1 of the Illinois Constitution, as well as the constitutional guarantees of due process and equal protection found in Article I, § 2 and the guarantee of a complete remedy found in Article I, § 12 of the Illinois Constitution.

ANSWER, Paragraph 39 of Count II of plaintiff's complaint at law contains conclusions of law rather than averments of fact; therefore no answer is required. To the extent that an answer may be required, this defendant denies the allegations set forth in paragraph 39 of Count II of plaintiff's complaint at law.

40. That the requirement in 735 ILCS 5/2-622 that a reviewing health care professional's name, address, current license number, and state licensure be attached to certificate of merit affidavit unconstitutionally usurps the judiciary's authority to establish the rules of Illinois courts and creates an irreconcilable conflict with the protection provided to consultants under Illinois Supreme Court Rule 201 (b)(3) (“A consultant is a person who has been retained or specially employed in anticipation of litigation or preparation for trial but who is not to be called at trial. The identity, opinions, and work product of a consultant are discoverable only upon a showing of exceptional circumstances under which it is impracticable for the party seeking discovery to obtain facts or opinions on the same subject matter by other means.” (emphasis added).)

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