Nursing Home Decubtitus Ulcer Complaint at Law

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Complaint at Law

Adam S. Goldfarb, One of Plaintiff's, Attorneys, Nemeroff Law Offices, Ltd., 180 North Lasalle St., Suite 3112, Chicago, IL 60601, (312) 629-8800, Atty. No. 34371.

NOW COMES the Plaintiff, LILLIE STEVENSON, as Plenary Guardian of the person of LEONARD NEAL and of the person of CORRINE LASLIE, by and through her attorneys, NEMEROFF LAW OFFICES, LTD., and complains of Defendant, CHEVY CHASE CORP., an Illinois corporation, doing business as BRONZEVILLE PARK SKILLED NURSING & LIVING CENTER, as follows:

COUNT I - NURSING HOME ACT

(LILLIE STEVENSON, as Plenary Guardian of the person of LEONARD NEAL VS. CHEVY CHASE CORP.)

1. At all times relevant, Plaintiff, LILLIE STEVENSON resides in Chicago, Cook County, Illinois.

2. On February 22, 2010, Plaintiff LILLIE STEVENSON was appointed plenary guardian of the person of LEONARD NEAL.

3. On February 22, 2010, Plaintiff LILLIE STEVENSON was appointed plenary guardian of the person of CORRINE LASLIE

4. At all times relevant, Defendant CHEVY CHASE CORP., (“DEFENDANT”) is an Illinois corporation, doing business as BRONZEVILLE PARK SKILLED NURSING & LIVING CENTER in Cook County, Illinois in providing rehabilitation and nursing home services to patients, including LEONARD NEAL who resided on the Premises located at 3400 S. Indiana Avenue, Chicago, Cook County, Illinois (herein referred to as the “PREMISES”).

5. At all times relevant, Defendant is a facility subject to the duties imposed under the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/1-101, et. seq.

6. Since on or about August 27, 2010 to the present date, LEONARD NEAL has been a patient residing at Defendant's Premises.

7. On or about August 27, 2010, LEONARD NEAL was admitted as a resident at the Defendant's Premises for rehabilitation and nursing home care as he is disabled and wheelchair bound.

8. During his time at Defendant's Premises, starting in approximately October 2010 to present, LEONARD NEAL developed bed sores/ pressure ulcers throughout his body.

9. At all relevant times, the persons responsible for attending to LEONARD NEAL were acting as employees, agents, employee and/or servants of Defendant.

10. It then and there became the duty of defendant to provide assistance to LEONARD NEAL consistent with that provided by a reasonably well-qualified nursing home in the care of LEONARD NEAL.

11. Since August 27, 2010 to present date, Defendant breached their aforesaid duties under the Illinois Nursing Home Care Act, through one or more of the following acts and/or omissions:

(a) Violated the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/1-117 in neglecting to provide adequate medical or personal care or maintenance, which failure resulted in Leonard Neal's physical or mental injury or deterioration of his physical or mental condition, including developing bed sores/pressure ulcers;

(b) Violated the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/1-120 in neglecting to provide adequate assistance to Leonard Neal in his “personal care”, including tending to his personal needs or maintenance or general supervision and oversight of his physical and mental well-being;

(c) Violated the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/2-107 in neglecting Leonard Neal by failing to appropriately turn him over in his bed, resulting in bed sores/pressure ulcers forming on his body; and

(d) Violated the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/2-107 in neglecting to properly provide adequate nursing home care, treatment and services to Leonard Neal in preventing the development of bed sores/ulcer ulcers forming on his body.

12. As a direct and proximate result of one or more of the negligent acts and/or omissions of the defendant, in violating the Illinois Nursing Home Act, LEONARD NEAL was caused to suffer illnesses, including developing bedsores/pressure ulcers throughout his body.

13. That on the aforesaid date and prior thereto, the Defendant, is a duly licensed nursing home facility under the provisions of the Illinois Nursing Home Care Reform Act pursuant to 210 ILCS 45/1-101, et. seq. and violated the aforementioned provisions of said act.

14. That under the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/3-602, the defendant shall pay the actual damages and costs and attorney's fees for the violations in Part 1 of Article II of the Illinois Nursing Home Care Act.

WHEREFORE, Plaintiff, LILLIE STEVENSON, as Plenary Guardian of the person of LEONARD NEAL, prays for judgment against Defendant CHEVY CHASE CORP., an Illinois corporation, doing business as BRONZEVILLE PARK SKILLED NURSING & LIVING CENTER, in the amount in excess of FIFTY THOUSAND DOLLARS ($50,000.00), the minimal jurisdictional amount of this Court, plus attorney's fees under the Nursing Home Care Reform Act and costs.

COUNT II - NURSING HOME ACT

(LILLIE STEVENSON, as Plenary Guardian of the person of CORRINE LASLIE VS. CHEVY CHASE CORP.)

1. At all times relevant, Plaintiff, LILLIE STEVENSON resides in Chicago, Cook County, Illinois.

2. On February 22, 2010, Plaintiff LILLIE STEVENSON was appointed plenary guardian of the person of LEONARD NEAL.

3. On February 22, 2010, Plaintiff LILLIE STEVENSON was appointed plenary guardian of the person of CORRINE LASLIE

4. At all times relevant, Defendant CHEVY CHASE CORP., (“DEFENDANT”) is an Illinois corporation, doing business as BRONZEVILLE PARK SKILLED NURSING & LIVING CENTER in Cook County, Illinois in providing rehabilitation and nursing home services to patients, including CORRINE LASLIE who resided on the Premises located at 3400 S. Indiana Avenue, Chicago, Cook County, Illinois (herein referred to as the “PREMISES”).

5. At all times relevant. Defendant is a facility subject to the duties imposed under the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/1-101, et. seq.

6. Since on or about August 27, 2010 to the present, CORRINE LASLIE has been a patient residing at Defendant's Premises.

7. On or about August 27, 2010, CORRINE LASLIE was admitted as a resident at the Defendant's Premises for rehabilitation and nursing home care as she is disabled and wheelchair bound.

8. During her time at Defendant's Premises, starting in approximately October 2010 to present, CORRINE LASLIE developed bed sores/ pressure ulcers throughout her body, including to her back and buttocks.

9. At all relevant times, the persons responsible for attending to CORRINE LASLIE were acting as employees, agents, employee and/or servants of Defendant.

10. It then and there became the duty of defendant to provide assistance to CORRINE LASLIE consistent with that provided by a reasonably well-qualified nursing home in the care of CORRINE LASLIE.

11. Since August 27, 2010 to present date, Defendant breached their aforesaid duties under the Illinois NursingHome Care Act, through one or more of the following acts and/or omissions:

(a) Violated the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/1-117 in neglecting to provide adequate medical or personal care or maintenance, which failure resulted in Corrine Laslie's physical or mental injury or deterioration of his physical or mental condition, including developing bed sores/pressure ulcers;

(b) Violated the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/1-120 in neglecting to provide adequate assistance to Corrine Laslie in her “personal care”, including tending to her personal needs or maintenance or general supervision and oversight of her physical and mental well-being;

(c) Violated the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/2-107 in neglecting Corrine Laslie by failing to appropriately turn her over in his bed, resulting in bed sores/pressure ulcers forming on her body; and

(d) Violated the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/2-107 in neglecting to properly provide adequate nursing home care, treatment and services to Corrine Laslie in preventing the development of bedsores/ulcer ulcers forming on her body.

12. As a direct and proximate result of one or more of the negligent acts and/or omissions of the defendant, in violating the IllinoisNursing Home Act, CORRINE LASLIE was caused to suffer illnesses, including developing bedsores/ pressure ulcers throughout her body.

13. That on the aforesaid date and prior thereto, the Defendant, is a duly licensed rehabilitation facility under the provisions of the Illinois Nursing Home Care Reform Act pursuant to 210 ILCS 45/1-101, et. seq. and violated the aforementioned provisions of said act.

14. That under the Illinois Nursing Home Care Act pursuant to 210 ILCS 45/3-602, the defendant shall pay the actual damages and costs and attorney's fees for the violations in Part 1 of Article II of the Illinois Nursing Home Care Act.

WHEREFORE, Plaintiff, LILLIE STEVENSON, as Plenary Guardian of the person of CORRINE LASLIE, prays for judgment against Defendant CHEVY CHASE CORP., an Illinois corporation, doing business as BRONZEVILLE PARK SKILLED NURSING & LIVING CENTER, in the amount in excess of FIFTY THOUSAND DOLLARS ($50,000.00), the minimal jurisdictional amount of this Court, plus attorney's fees under the Nursing Home Care Reform Act and costs.

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