Complaint 1 - Med Mal Suit against Doctor, Hospital for Negligent Care and Wrongful Death

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Complaint

Cook, Ysursa, Bartholomew, Brauer & Shevlin, Ltd., Bruce N. Cook, Ill. Reg. No. 507660.

Cook, Ysursa, Bartholomew, Brauer & Shevlin, Ltd., 12 West Lincoln Street, Belleville, IL 62220, (618) 235-3500, (618) 235-7286 Fax.

COUNT I

Comes now plaintiff, Lee Lindemann, as Special Administrator of the Estate of Sue Ann Lindemann, deceased, by and through his attorneys, Cook, Ysursa, Bartholomew, Brauer & Shevlin, Ltd., and for Count I of his Complaint against defendant, Charles Dumontier, M.D., states as follows:

1. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Charles DuMontier, M.D., was a licensed physician in the State of Illinois on the staff of St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, and defendant provided medical services to decedent.

2. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Radiology Consultants of Mid-America, P.C., was a company organized under the laws of the State of Illinois and duly authorized to engage in the practice of medicine in the State of Illinois, and more particularly, in St. Clair County, Illinois and defendant provided medical services to decedent.

3. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, was an Illinois corporation duly authorized under the laws of the State of Illinois, doing business in the County of St. Clair, and said defendant provided medical services to decedent.

4. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Erick Falconer, M.D., was a licensed physician in the State of Illinois, and on the staff of St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, who engaged in his practice in St. Clair County, Illinois, and defendant provided medical services to decedent.

5. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Midwest Emergency Department Services, Inc., was a company organized under the laws of the State of Illinois and duly authorized to engage in the practice of medicine in the State of Illinois, and more particularly, in St. Clair County, Illinois and defendant provided medical services to decedent.

6. That at all times relevant hereto, it was the duty of the defendants to use reasonable and ordinary care of physician and healthcare facility in their care and treatment of plaintiff's decedent herein.

7. That defendant, Charles Dumontier, M.D., breached the aforementioned duty in the following respects:

a) negligently and carelessly failed to timely evaluate and treat decedent's herniated bowel on or about January 21, 2012, and thereafter;

b) negligently and carelessly failed to properly evaluate CT scans which showed decedent's herniated bowel on or about January 21, 2012, and thereafter;

c) negligently and carelessly failed to timely transfer decedent after her condition became critical.

8. That as a direct and proximate result of one or more of the foregoing negligent acts or omissions on the part of defendants, plaintiffs decedent was caused to suffer injuries resulting in her death on January 22, 2012.

9. That decedent left surviving as her next of kin, her spouse, Lee Lindemann, and her son, Brandon Lindemann.

10. That the aforementioned next of kin have been damaged as a result of the wrongful death of decedent, in that they have been deprived of the reasonable value of her services, companionship, comfort, instruction, guidance, counsel, training, love, affection and support of wife and mother, and further have sustained direct economic loss as a result of decedent's demise.

11. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “A” and incorporated herein indicating that there is a reasonable cause for filing a medical malpractice action against Charles Dumontier, M.D.

12. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “B” and incorporated herein indicating that there is a reasonable cause for filing a medical malpractice action against Radiology Consultants of Mid-America, P.C.

13. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “C” and incorporated herein indicating that there is a reasonable cause for filing a medical malpractice action against St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis.

14. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “D” and incorporated herein indicating that there is a reasonable cause for filing a medical malpractice action against Erick Falconer, M.D.

15. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “E” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Midwest Emergency Department Services, Inc.

16. That this action is brought pursuant to Wrongful Death Act, 740 ILCS 180/1 et. seq.

17. That plaintiff, Lee Lindemann, was duly appointed Special Administrator of the Estate of Sue Ann Lindemann.

WHEREFORE, the plaintiff, Lee Lindemann, Special Administrator of the Estate of Sue Ann Lindemann, deceased, prays judgment against the defendant, Charles Dumontier, M.D., in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), plus costs herein expended.

COOK, YSURSA, BARTHOLOMEW,

BRAUER & SHEVLIN, LTD.

Bruce N. Cook

Ill. Reg. No. 507660

COOK, YSURSA, BARTHOLOMEW,

BRAUER & SHEVLIN, LTD.

12 West Lincoln Street

Belleville, IL 62220

(618) 235-3500

(618) 235-7286 FAX

COUNT II

Comes now plaintiff, Lee Lindemann, as Special Administrator of the Estate of Sue Ann Lindemann, deceased, by and through his attorneys, Cook, Ysursa, Bartholomew, Brauer & Shevlin, Ltd., and for Count II of his Complaint against defendant, Radiology Consultants of Mid-America, P.C., states as follows:

1. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Charles DuMontier, M.D., was a licensed physician in the State of Illinois on the staff of St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, and defendant provided medical services to decedent.

2. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Radiology Consultants of Mid-America, P.C., was a company organized under the laws of the State of Illinois and duly authorized to engage in the practice of medicine in the State of Illinois, and more particularly, in St. Clair County, Illinois and defendant provided medical services to decedent.

3. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, was an Illinois corporation duly authorized under the laws of the State of Illinois, doing business in the County of St. Clair, and said defendant provided medical services to decedent.

4. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Erick Falconer, M.D., was a licensed physician in the State of Illinois, and on the staff of St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, who engaged in his practice in St. Clair County, Illinois, and defendant provided medical services to decedent.

5. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Midwest Emergency Department Services, Inc., was a company organized under the laws of the State of Illinois and duly authorized to engage in the practice of medicine in the State of Illinois, and more particularly, in St. Clair County, Illinois and defendant provided medical services to decedent.

6. That at all times relevant hereto, it was the duty of the defendants to use reasonable and ordinary care of physician and healthcare facility in their care and treatment of plaintiffs decedent herein.

7. That defendant, Radiology Consultants of Mid-America, P.C., by and through the act of its agents, servants and employees, breached the aforementioned duty in the following respects:

a) negligently and carelessly failed to timely evaluate and treat decedent's herniated bowel on or about January 21, 2012, and thereafter;

b) negligently and carelessly failed to properly evaluate CT scans which showed decedent's herniated bowel on or about January 21, 2012, and thereafter;

c) negligently and carelessly failed to timely transfer decedent after her condition became critical.

8. That as a direct and proximate result of one or more of the foregoing negligent acts or omissions on the part of defendants, plaintiffs decedent was caused to suffer injuries resulting in her death on January 22, 2012.

9. That decedent left surviving as her next of kin, her spouse, Lee Lindemann, and her son, Brandon Lindemann.

10. That the aforementioned next of kin have been damaged as a result of the wrongful death of decedent, in that they have been deprived of the reasonable value of her services, companionship, comfort, instruction, guidance, counsel, training, love, affection and support of wife and mother, and further have sustained direct economic loss as a result of decedent's demise.

11. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “A” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Charles Dumontier, M.D.

12. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “B” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Radiology Consultants of Mid-America, P.C.

13. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “C” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis.

14. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “D” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Erick Falconer, M.D.

15. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “E” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Midwest Emergency Department Services, Inc.

16. That this action is brought pursuant to Wrongful Death Act, 740 ILCS 180/1 et. seq.

17. That plaintiff, Lee Lindemann, was duly appointed Special Administrator of the Estate of Sue Ann Lindemann.

WHEREFORE, the plaintiff, Lee Lindemann, Special Administrator of the Estate of Sue Ann Lindemann, deceased, prays judgment against the defendant, Radiology Consultants of Mid-America, P.C., in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), plus costs herein expended.

COOK, YSURSA, BARTHOLOMEW,

BRAUER & SHEVLIN, LTD.

Bruce N. Cook

Ill. Reg. No. 507660

COOK, YSURSA, BARTHOLOMEW,

BRAUER & SHEVLIN, LTD.

12 West Lincoln Street

Belleville, IL 62220

(618) 235-3500

(618) 235-7286 FAX

COUNT III

Comes now plaintiff, Lee Lindemann, as Special Administrator of the Estate of Sue Ann Lindemann, deceased, by and through his attorneys, Cook, Ysursa, Bartholomew, Brauer & Shevlin, Ltd., and for Count III of his Complaint against defendant, St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, states as follows:

1. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Charles DuMontier, M.D., was a licensed physician in the State of Illinois on the staff of St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, and defendant provided medical services to decedent.

2. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Radiology Consultants of Mid-America, P.C., was a company organized under the laws of the State of Illinois and duly authorized to engage in the practice of medicine in the State of Illinois, and more particularly, in St. Clair County, Illinois and defendant provided medical services to decedent.

3. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, was an Illinois corporation duly authorized under the laws of the State of Illinois, doing business in the County of St. Clair, and said defendant provided medical services to decedent.

4. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Erick Falconer, M.D., was a licensed physician in the State of Illinois, and on the staff of St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, who engaged in his practice in St. Clair County, Illinois, and defendant provided medical services to decedent.

5. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Midwest Emergency Department Services, Inc., was a company organized under the laws of the State of Illinois and duly authorized to engage in the practice of medicine in the State of Illinois, and more particularly, in St. Clair County, Illinois and defendant provided medical services to decedent.

6. That at all times relevant hereto, it was the duty of the defendants to use reasonable and ordinary care of physician and healthcare facility in their care and treatment of plaintiffs decedent herein.

7. That defendant, St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, by and through the act of its agents, servants and employees, breached the aforementioned duty in the following respects:

a) negligently and carelessly failed to timely evaluate and treat decedent's herniated bowel on or about January 21, 2012, and thereafter;

b) negligently and carelessly failed to properly evaluate CT scans which showed decedent's herniated bowel on or about January 21, 2012, and thereafter;

c) negligently and carelessly failed to timely transfer decedent after her condition became critical.

8. That as a direct and proximate result of one or more of the foregoing negligent acts or omissions on the part of defendants, plaintiffs decedent was caused to suffer injuries resulting in her death on January 22, 2012.

9. That decedent left surviving as her next of kin, her spouse, Lee Lindemann, and her son, Brandon Lindemann.

10. That the aforementioned next of kin have been damaged as a result of the wrongful death of decedent, in that they have been deprived of the reasonable value of her services, companionship, comfort, instruction, guidance, counsel, training, love, affection and support of wife and mother, and further have sustained direct economic loss as a result of decedent's demise.

11. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “A” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Charles Dumontier, M.D.

12. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “B” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Radiology Consultants of Mid-America, P.C.

13. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “C” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis.

14. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “D” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Erick Falconer, M.D.

15. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “E” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Midwest Emergency Department Services, Inc.

16. That this action is brought pursuant to Wrongful Death Act, 740 ILCS 180/1 et. seq.

17. That plaintiff, Lee Lindemann, was duly appointed Special Administrator of the Estate of Sue Ann Lindemann.

WHEREFORE, the plaintiff, Lee Lindemann, Special Administrator of the Estate of Sue Ann Lindemann, deceased, prays judgment against the defendant, St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), plus costs herein expended.

COOK, YSURSA, BARTHOLOMEW,

BRAUER & SHEVLIN, LTD.

Bruce N. Cook

Ill. Reg. No. 507660

COOK, YSURSA, BARTHOLOMEW,

BRAUER & SHEVLIN, LTD.

12 West Lincoln Street

Belleville, IL 62220

(618) 235-3500

(618) 235-7286 FAX

COUNT IV

Comes now plaintiff, Lee Lindemann, as Special Administrator of the Estate of Sue Ann Lindemann, deceased, by and through his attorneys, Cook, Ysursa, Bartholomew, Brauer & Shevlin, Ltd., and for Count IV of his Complaint against defendant, Erick Falconer, M.D., states as follows:

1. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Charles DuMontier, M.D., was a licensed physician in the State of Illinois on the staff of St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, and defendant provided medical services to decedent.

2. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Radiology Consultants of Mid-America, P.C., was a company organized under the laws of the State of Illinois and duly authorized to engage in the practice of medicine in the State of Illinois, and more particularly, in St. Clair County, Illinois and defendant provided medical services to decedent.

3. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, was an Illinois corporation duly authorized under the laws of the State of Illinois, doing business in the County of St. Clair, and said defendant provided medical services to decedent.

4. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Erick Falconer, M.D., was a licensed physician in the State of Illinois, and on the staff of St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, who engaged in his practice in St. Clair County, Illinois, and defendant provided medical services to decedent.

5. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Midwest Emergency Department Services, Inc., was a company organized under the laws of the State of Illinois and duly authorized to engage in the practice of medicine in the State of Illinois, and more particularly, in St. Clair County, Illinois and defendant provided medical services to decedent.

6. That at all times relevant hereto, it was the duty of the defendants to use reasonable and ordinary care of physician and healthcare facility in their care and treatment of plaintiffs decedent herein.

7. That defendant, Erick Falconer, M.D., breached the aforementioned duty in the following respects:

a) negligently and carelessly failed to timely evaluate and treat decedent's herniated bowel on or about January 21, 2012, and thereafter;

b) negligently and carelessly failed to properly evaluate CT scans which showed decedent's herniated bowel on or about January 21, 2012, and thereafter;

c) negligently and carelessly failed to timely transfer decedent after her condition became critical.

8. That as a direct and proximate result of one or more of the foregoing negligent acts or omissions on the part of defendants, plaintiffs decedent was caused to suffer injuries resulting in her death on January 22, 2012.

9. That decedent left surviving as her next of kin, her spouse, Lee Lindemann, and her son, Brandon Lindemann.

10. That the aforementioned next of kin have been damaged as a result of the wrongful death of decedent, in that they have been deprived of the reasonable value of her services, companionship, comfort, instruction, guidance, counsel, training, love, affection and support of wife and mother, and further have sustained direct economic loss as a result of decedent's demise.

11. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “A” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Charles Dumontier, M.D.

12. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “B” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Radiology Consultants of Mid-America, P.C.

13. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “C” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis.

14. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “D” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Erick Falconer, M.D.

15. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “E” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Midwest Emergency Department Services, Inc.

16. That this action is brought pursuant to Wrongful Death Act, 740 ILCS 180/1 et. seq.

17. That plaintiff, Lee Lindemann, was duly appointed Special Administrator of the Estate of Sue Ann Lindemann.

WHEREFORE, the plaintiff, Lee Lindemann, Special Administrator of the Estate of Sue Ann Lindemann, deceased, prays judgment against the defendant, Erick Falconer, M.D., in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), plus costs herein expended.

COOK, YSURSA, BARTHOLOMEW,

BRAUER & SHEVLIN, LTD.

Bruce N. Cook

Ill. Reg. No. 507660

COOK, YSURSA, BARTHOLOMEW,

BRAUER & SHEVLIN, LTD.

12 West Lincoln Street

Belleville, IL 62220

(618) 235-3500

(618) 235-7286 FAX

COUNT V

Comes now plaintiff, Lee Lindemann, as Special Administrator of the Estate of Sue Ann Lindemann, deceased, by and through his attorneys, Cook, Ysursa, Bartholomew, Brauer & Shevlin, Ltd., and for Count V of his Complaint against defendant, Midwest Emergency Department Services, Inc.,, states as follows:

1. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Charles DuMontier, M.D., was a licensed physician in the State of Illinois on the staff of St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, and defendant provided medical services to decedent.

2. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Radiology Consultants of Mid-America, P.C., was a company organized under the laws of the State of Illinois and duly authorized to engage in the practice of medicine in the State of Illinois, and more particularly, in St. Clair County, Illinois and defendant provided medical services to decedent.

3. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, was an Illinois corporation duly authorized under the laws of the State of Illinois, doing business in the County of St. Clair, and said defendant provided medical services to decedent.

4. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Erick Falconer, M.D., was a licensed physician in the State of Illinois, and on the staff of St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis, who engaged in his practice in St. Clair County, Illinois, and defendant provided medical services to decedent.

5. That on or about January 21, 2012, and continuing through January 22, 2012, and at all times mentioned herein, defendant, Midwest Emergency Department Services, Inc., was a company organized under the laws of the State of Illinois and duly authorized to engage in the practice of medicine in the State of Illinois, and more particularly, in St. Clair County, Illinois and defendant provided medical services to decedent.

6. That at all times relevant hereto, it was the duty of the defendants to use reasonable and ordinary care of physician and healthcare facility in their care and treatment of plaintiff's decedent herein.

7. That defendant, Midwest Emergency Department Services, Inc., by and through the act of its agents, servants and employees, breached the aforementioned duty in the following respects:

a) negligently and carelessly failed to timely evaluate and treat decedent's herniated bowel on or about January 21, 2012, and thereafter;

b) negligently and carelessly failed to properly evaluate CT scans which showed decedent's herniated bowel on or about January 21, 2012, and thereafter;

c) negligently and carelessly failed to timely transfer decedent after her condition became critical.

8. That as a direct and proximate result of one or more of the foregoing negligent acts or omissions on the part of defendants, plaintiffs decedent was caused to suffer injuries resulting in her death on January 22, 2012.

9. That decedent left surviving as her next of kin, her spouse, Lee Lindemann, and her son, Brandon Lindemann.

10. That the aforementioned next of kin have been damaged as a result of the wrongful death of decedent, in that they have been deprived of the reasonable value of her services, companionship, comfort, instruction, guidance, counsel, training, love, affection and support of wife and mother, and further have sustained direct economic loss as a result of decedent's demise.

11. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “A” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Charles Dumontier, M.D.

12. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “B” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Radiology Consultants of Mid-America, P.C.

13. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “C” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against St. Elizabeth's Hospital of the Hospital Sisters of the Third Order of St. Francis.

14. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “D” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Erick Falconer, M.D.

15. That plaintiff has received a Certificate of Merit from a consulting physician, a copy of which is attached and marked as Exhibit “E” and incorporated herein indicating that there is a reasonable cause for filing a medicalmalpractice action against Midwest Emergency Department Services, Inc.

16. That this action is brought pursuant to Wrongful Death Act, 740 ILCS 180/1 et. seq.

17. That plaintiff, Lee Lindemann, was duly appointed Special Administrator of the Estate of Sue Ann Lindemann.

WHEREFORE, the plaintiff, Lee Lindemann, Special Administrator of the Estate of Sue Ann Lindemann, deceased, prays judgment against the defendant, Midwest Emergency Department Services, Inc., in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), plus costs herein expended.

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