Medical Malpractice Motion 22 - Motion to reconsider

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Plaintiffs' Memorandum of Law in Support of Motion to Reconsider

Lindner, Speers & Reuland, P.C., Terry W. Heady #11229, Attorney for Plaintiff, 54 West Downer Place, Po. Box 5055, Aurora, Il 60507, (630) 892-8109.

NOW COMES the Plaintiff, Joann Williams, individually and as mother and next friend of Robert Morales, Jr., a minor, by and through her attorneys, Lindner, Speers & Reuland, P.C., and respectfully submits the following Memorandum of Law in support of Plaintiff's Motion to Reconsider the Court's Order of November 2, 2005, granting Defendants' Motion to Transfer Venue and in support thereof, states as follows:

INTRODUCTION

On November 2, 2005, the Court granted Defendants' Forum Non Conveniens Motion to Transfer Venue from Cook to Kane County. Plaintiff asks that the Court reconsider its earlier ruling for three reasons. First, because Plaintiff has determined that the defense made incorrect material statements about two witnesses that were identified as likely trial witnesses. A nurse identified by the defense identified as a likely trial witness was in fact deceased long before Defendant's Motion was filed. A second witness, a doctor, identified by the defense now works for Defendant, Advocate Health Care, in Cook County. In addition, during the hearing on the Motion to Transfer, the Court advised the parties that copies of pertinent medical records had been omitted from the courtesy copy provided to the Court. Therefore, the Court was not fully able to appreciate the nature and extent of the treatment received by the minor Plaintiff, Robert Morales, Jr., at Lutheran General Hospital in Cook County. The Plaintiff has attached portions of the relevant records, as well as an affidavit that provides the Court with specific information as to nature and extent of the care rendered by the doctors and the reason that their testimony will be necessary. In addition, new medical records from Cook County that were not available at the time of the hearing on Defendants' Motion are now available and Plaintiff can identify additional witnesses who will testify at trial. Lastly, the Court erred by failing to consider the numerous delays caused by the Defendants in the instant cause. Because Defendants' Motion to Transfer is based in equity, the Court should consider the substantial delay caused by their failure to file the motion to transfer at an earlier date.

I. WITNESSES EXPECTED TO TESTIFY

a. Witnesses identified by Defendants

Attached as Exhibit “C “to Defendant Provena's Motion to Transfer Venue, is a “list of likely trial witnesses.” This Exhibit is attached hereto as Exhibit 1. Those witnesses included two doctors, the defendant, Dr. Judson Jones, who lives in Kendall County and works in Kane County, and a Dr. Rom M. Kopparthi, who is listed as working in Kane County but his county of residence was unknown. (Ex. 1) With regard to Dr. Kopparthi, according to the website maintained by Defendant, Advocate Health Care, he is now on staff at Advocate Lutheran General, located in Park Ridge, Cook County. A copy of the Dr. Kopparthi's listing on Defendant Advocate's webpage is attached hereto as Exhibit. 2. This listing indicates that Dr. Kopparthi is also a member of the Advocate Medical Group with offices in Park Ridge.

Plaintiff agrees that Dr. Kopparthi is a likely trial witness. Dr. Kopparthi is the doctor who made the decision to transfer the minor plaintiff to Advocate Lutheran General in Park Ridge six hours after his birth. Plaintiff attached a copy of Dr. Kopparthi's four page report to its response to the motion to transfer. A copy of the report is attached hereto as Exhibit 3. As this is a case involving alleged malpractice resulting in a brain injury, Dr. Kopparthi's testimony as the minor's condition at the time that he left the hospital will be important. Dr. Kopparthi performed a physical examination, reported the history of the pregnancy, the condition of the baby on birth, APGAR scores, cord gasses, neurological findings. He reports seven diagnoses and identifies the procedures performed on the baby. The fact that this doctor now practices in Cook County is another reason this case should not be transferred from Cook County.

Defendant Provena Hospital further listed, as a likely trial witness, Ms. Janice Walczak, a nurse from Will County. (Exhibit 1) The defense could not have possibly identified this witness in good faith as a likely trial witness because, based on records obtained through the Social Security Death Index, Ms. Walczak passed away on September 8, 2003. (A copy of the Death Record is attached hereto as Exhibit 4)

The remaining nurses Provena identifies as likely witness are from Will (1), Kane (5), Kendall (3), DeKalb (1) and Cook (1). The Will County nurse, Mojisola Ogunbuyide, is listed in public records as residing at 412 Bluebird Dr., in Bolingbrook, Will County, which is actually a couple of miles closer to the Cook County Courthouse than it is to the Kane County Courthouse in Geneva. (Attached as Exhibit 5 are Mapquest maps showing the mileage).

b. Defendants Provided no Information About the Witnesses

Defendant's Motion fails to provide any information as to why any or all of the nurses identified would be necessary trial witnesses. As Defendant name a nurse as a likely trial witness who had been deceased long before the motion was filed, it is evident that Defendant did not name these nurses in good faith. This is further evidenced by the fact that no information is given as to what the subject of their testimony will be and what their contact with the minor plaintiff, if any, was. The only information provided for nurse is: “Provena Nurse involved in the Plaintiff's care and treatment. (Ex.1)

Provena provides two affidavits from nurses. One affidavit is provided by Nurse Enoh, which states where she lives but no information is provided as to the subject of her testimony, what her contact with the minor plaintiff was, or why she is a necessary witness. (Def' s Ex. F) An affidavit was provided by a nurse Linda Lombard (Def's Ex. F), but this nurse is not included on the list of likely witnesses provided by the defense. (Ex 1) The affidavit says nothing about the subject of her anticipated testimony or what care she provided to Plaintiff. The only other affidavit provided by Provena is from a Christine Pike, a Quality/Risk management coordinator, who is also not listed as a likely trial witness, and who is not alleged to have provided any treatment to the minor plaintiff. No other affidavits were provided by Provena.

c. Cook County Witnesses Identified by Plaitnifff

The majority of medical treatment relating to the birth injury in this case occurred at Advocate Lutheran General in Cook. Six hours after his birth, the minor plaintiff was transferred to Advocate Lutheran General, in Park Ridge, Cook County, where he remained in the NICU for 23 days. Plaintiff identified numerous doctors and nurses at Advocate Lutheran General in Cook County who are potential witnesses in this case. (See Exhibit's D through F to Plaintiff's Response to the Motion to Transfer) During oral argument on Defendants' Motion, the Court expressed interest in knowing the extent of contact between the medical care providers and the minor plaintiff. Plaintiff pointed to numerous records that had been attached to Defendant's Motion but the Court stated that the attachments of the courtesy copies were missing and out of order. (See page 25 of transcript to Hearing on Motion to Transfer attached hereto as Exhibit 6). Those records included medical records of Dr. Priti Sing, who will likely be called by Plaintiff to testify as to both causation and damages, is Dr. Priti Singh, is identified on medical records as the Assistant Division Head, Pediatric Neurology and Director, Pediatric Electrophysiological services Hope Children's Hospital Advocate-Christ Hospital and Medical Center Clinical Assistant Professor/Department of Neurology University of Illinois at Chicago. (A copy of two of Dr. Priti Singh's records are attached hereto as Exhibits 7 & 8) Dr. Singh followed the treatment of Robert Morales from approximately January of 2002 through May 22, 2003. Dr. Singh provided medical diagnosis and treatment for the child's cerebral palsy and seizure disorder and will be an important witness in this case. Dr. Singh is listed on Defendant Advocate's Website as a doctor on staff at Advocate Christ located in Oak Lawn, Cook County. (Exhibit 9)

The minor plaintiff was transferred a second time from Provena to Advocate Lutheran General for two days in July of 2001. During those two visits, the plaintiff was treated by at least eight doctors, 39 nurses and seven other healthcare professionals. (A list of these health care providers is attached as Exhibit 10) Plaintiff expects that most of the doctors from this facility will be called to testify as will many of the other health care providers. Drs. Nisant Shaw, Rajan Raj, E. Phillip Ow, Bhagya Puppala, David Mittelman, Barry Rabin, and John Phillips, are identified as doctors on staff at Advocate Lutheran General as of November 2, 2005. (Copies of Defendant Advocate's web listings for these doctors is attached as Group Exhibit 11)

Dr. Bhagya Puppala, a neonatolgist at Lutheran General Hospital, was the admitting physican, and primary doctor who oversaw the treatment of the minor plaintiff on a daily basis while he was at the hospital during the first admission. A copy of Dr. Discharge Summary is attached as Exhibit 12. Dr. Puppala had contact with the minor Plaintiff on a regular basis during his initial stay at the hospital.

Dr. Shah, a pediatric neurologist, also provided frequent consultations and performed at least three EEG exams on the minor Plaintiff. (Copies of four of Dr. Shah's reports are attached as Group Exhibit 13). Dr. Shah also provided a physical exam, provided medical treatment, ordered an MRI and made a diagnosis, during the second admission to Advocate Lutheran General. Dr. Shah's discharge summary of the second admission is included with Group Exhibit 13. According to the attached reports, the EEGs were abnormal and a diagnosis of severe hypoxic ischemic encephalopathy was made. Because one of the issues presented in this case will be whether the deprivation of oxygen to the minor plaintiff during delivery caused cerebral palsy, Dr. Shah will be a key witness in this case.

Other doctors who will certainly be called to testify are doctors John Phillips and Dr. Barry Rabin, radiologists who performted CT scans of the Brain and an MRI of the brain. (Copies of their reports are attached as Group Exhibit 14) The actual CT and MRI films are located at Lutheran General Hospital. These doctors will need to consult with these MRI films when they testify. As this is a case involving a brain injury, the MRI taken of the child the day after his birth will be critical, and thus, both Drs. Phillips and Rabin will be key witnesses in this case.

In addition to the treatment received at Advocate Lutheran General, the minor Plaintiff has also treated at the University of Illinois Medical Center at Chicago. Because of medications that the minor Plaintiff takes, he sustained serious injuries to his teeth and had to have numerous root canals performed under general anesthesia on November 4, 2005. Dr. Fadavi Shar, from UIC, Department of Pediatric Dentistry, will likely be called to testify regarding his examinations and the oral surgery performed. Copies of these medical records are attached as Exhibit 15. These medical records were not available at the time that Plaintiff filed a Response to the Motion to Transfer because he had not yet undergone the treatment.

Another witness who will testify at trial is Scott Beckman who is the vice-president of risk management for Advocate. When Defendants filed their original Motion to Transfer Venue, Scott Beckman's affidavit was attached in support of the motion. A copy of that affidavit is attached as Exhibit 16. At the hearing on the Motion to Transfer, the Court asked whether the Court could draw an inference of convenience based on the fact that he is located in Oak Brook. (Ex. 6, p. 40) Counsel for Advocate admitted that the Court could draw this inference, but then informed the Court that “no one has indicated that he is going to be a witness that is likely to testify at trial regarding the agency issue. I mean, he hasn't addressed it.” (Ex. 6, p. 50, 1.11) Nevertheless, on page 2, paragraph 5 of the affidavit, Mr. Beckman did in fact represent that “AHCN is not the actual or apparent principal of the Defendants, Judson Jones, M.D., or Dreyer Medical Group, Ltd.” Thus, defense counsel's representation regarding Scott Beckman was not accurate. Based on the affidavit, Plaintiff deposed Scott Beckman where he testified about the agency issue. Because of information learned at that deposition regarding the corporate structure of Advocate, Plaintiff anticipates on calling Mr. Beckman as a witness even if the defense does not. According to public records, Scott Beckman is a resident of Willow Springs, located in Cook County. (Exhibit 17) Thus, only after Defendant's original motion to transfer, alleging that Advocate was not joined in good faith, was denied, did Defendants decide that Mr. Beckman was not a key witness.

It is likely that there will be other witness from Advocate who will testify at trial and these witnesses either maintain their offices in Cook County or in Oak Brook. One likely witnesses from Advocate is Daniel Schmidt, the chief executive of the Physician Services Group. According to Scott Beckman's His office is located in Chicago. (Exhibit 18 at p. 44-45) Mr. Schmidt gave a statement in an interview that differed significantly from Mr. Beckman's testimony concerning the relationship between Advocate and Dreyer Clinic. A copy of the interview is attached hereto as Exhibit 17. Mr. Schmidt explains in the interview the relationship between Advocate and Dreyer, such as their standardization of billings, the fact that they use the same billing system, that they are under the same management system, financial reporting, risk management, purchasing and human resources. (Ex. 17, pg. 3) Because the control by Advocate over Dreyer is a critical and disputed issue in this case, Daniel Schmidt will certainly be a key witness in this case.

II. ARGUMENT

A. This Court Should Deny Defendant's Motion To Transfer Venue For Forum Non Conveniens, Because Defendant Has Failed To Present Exceptional Circumstances Which Would Strongly Favor Transfer To Another Venue.

A case should be transferred on intrastate forum non conveniens grounds only in exceptional circumstances where it has been shown that the interests of justice require a trial in a more convenient forum. Paglia v. Goodman, 194 Ill.App.3d 543, 546, 551 N.E.2d 810 (5th Dist. 1990) (citing Torres v. Walsh, 98 I11.2d 338, 346 (1983). In this case, Defendants failed to provide any “exceptional circumstances” which would warrant transfer of this case from Cook County to Kane.

The party seeking transfer of venue on forum non conveniens grounds has the heavy burden of proving that the Plaintiffs chosen forum is inconvenient or unduly burdensome to him and another forum is more convenient to all parties. First National Bank v. Guerine, 198 Ill.2d 511, 518, 764 N.E.2d 54 (2002). However, deference to the Plaintiffs choice of forum should rarely be disturbed unless the balance is strongly in favor of the Defendant. Guerine, at 511

Plaintiff has identified thirteen medical doctors and a dentist from Cook County who are likely to testify in this case. The twelve doctors are part of Advocate Healthcare, a defendant in this suit. The corporate witnesses from Advocate, Scott Beckman and Daniel Schmidt, work and/or reside in Cook County. Thus, Advocate cannot rationally argue that a Kane County venue would be more convenient to Advocate than a Cook County forum. Because the forum is more convenient to one of the parties, Advocate, Defendants cannot meet the required burden of proving that another forum is more convenient to all parties.

Defendant Provena identified one doctor, Dr. Rom Kopparthi, in addition to the defendant who would likely be a trial witness. Since this doctor now practices for Advocate in Cook County, Provena cannot claim that its doctor will be inconvenienced in this case. As to the nurses identified by Provena, the Court cannot give these supposed witnesses any weight when the defense did not provide any information as to the substance of their testimony.

In a forum non conveniens motion the defendants must identify witnesses that will testify and indicate what the substance of their testimony will be. See Elling v. State Farm Mutual Automobile Insurance Co., 291 Ill.App.3d 311, 683 N.E.2d 629 (1st Dist. 1997) ; Schoon v. Hill, 207 Ill.App.3d 601, 566 N.E.2d 718 (1st Dist. 1991) (both cases affirming trial court's denial of defendants forum non conveniens where defendants failed to identity the court's substance and necessity” of any witnesses or how they would be inconvenienced if required to testify in Cook County.Defendants completely failed to provide the identity of likely trial witnesses. The defendants did not state why any of the witnesses would be necessary and what the substance of their testimony would be, and whether they would likely be trial witnesses. By naming a nurse that was deceased before the motion was filed, it is evident that Defendant made no genuine effort to identify which nurses would likely be called. In addition, there were far more nurses who treated the minor plaintiff during his 23 day stay at Advocate Lutheran than treated him at Provena. It is far more likely that the doctors, identified by the plaintiff will be actual trial witnesses.

B. The Private and Public Interest Factors Set Forth By The Illinois Supreme Court Weigh in Favor of Giving Deference to Plaintiffs Choice of Forum.

In resolving a forum non conveniens question, this Court must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts. Griffith v. Mitsubishi Aircraft, Int'l, Inc., 136 I11.2d 101, 105 (1990); citing Bland v. Norfolk & W R.Co., 116 I1.2d 217, 223 (1987). Defendant bears a heavy burden of proof, because the relevant factors must not only weigh in favor transfer, they must strongly favor transfer before a transfer is to be ordered. Griffith, 136 Il.2d at 107. The fact that some other forum might also be appropriate does not diminish the propriety of the chosen forum.

The relevant private interest factors to be considered in a intrastate forum non conveniens motion are: 1) the availability of another forum and the relative capacities of the two courts to provide a fair trial (Adkins v. Chicago. Rock Island and Pacific Railroad Company. 54 I11.2d 511, 514 (1973)); 2) the convenience of the forums to the parties; 3) the relative ease of access to the sources of proof in each forum; 4) the accessibility to the forum for witnesses; 5) the possibility of viewing the premises, if such would be appropriate to the action ( Meyers v. Bridgeport Machines Division of Textron, Inc., 113 Ill.2d 112, 118 (1986) ; citing Foster v. Chicago & North Western Transp.Co.,102 I11.2d 378, 382 (1984); Gulf Oil Corp., 330 U.S. at 508; Griffith, 136 I11.2d at 106-107; Torres, 98 I11.2d at 351).

In addition, relevant public interest factors include: 6) the interest of a forum in having localized controversies decided locally; 7) the fairness of imposing jury duty upon residents of each county; 8) the administrative difficulties caused when litigation is handled in congested venues; and 9) “all other practical problems that make trial of a case easy, expeditious and inexpensive.” Griffith 136 111.2d at 105, citing Gulf Oil Corp., 330 U.S. at 507; Torres, 98 L11.2d at 351; McClain v. Illinois Central Gulf RB. Co., 121 Ill.2d 278, 289 (1988). The trial court must evaluate the total circumstances, and no single factor should be given under weight. Guerine, 198 Il1.2d at 518.

A consideration of these factors favors keeping the case in Cook County. As the majority of witnesses who will be testifying in this case are from Cook County, it will be more convenient to all parties to have the case heard in Cook County. The only treating physician employed by Provena, who was identified as a likely trial witness by both Plaintiff and Provena, is now employed in Cook at Advocate. All of Advocate's witnesses either work or reside in Cook County. Although Defendant has argued that Advocate Lutheran General is not a party to this case, Advocate Healthcare, for whom these doctors work, is a party to the case and the presence of these doctors in Cook County makes trying the case in Cook more convenient for Advocate.

Provena argued in its motion that the location of the treating doctors should be given little weight. In making this argument, the First District's decision in Prouty v. Advocate Health and Hospitals Corp., 348 Ill.App.3d 490, 810 N.E.2d 173 (1st Dist. 2004). Prouty recognized that generally, the location of treating doctors is not given overdue weight because of the potential that a plaintiff may obtain medical treatment in a forum solely for the purpose of trying to fix venue. However, in Prouty, the Appellate Court held that this concern was not present where the the minor came into contact by these doctors because the defendant transferred the child to the Cook County facility. Id. at 179. Therefore, the Appellate Court held that the Trial Court properly considered the care provided by these doctors. Id.Here too, the minor plaintiff had no choice in where he received treatment. In Prouty, the child stayed a total of two weeks at Advocate Lutheran General in Chicago, where as in the present case, the minor plaintiff spent initially 23 days in Cook County, followed by numerous follow up visits for MRI's and other treatment and a second admission for several days. As in Prouty, the malpractice did not take place in Cook County nor does the plaintiff reside in Cook County. However, in Prouty, the court found that because substantial treatment was provided in Cook County, and because the numerous witnesses were spread out over several counties, the trial court did not error in denying the motion to transfer venue on the basis of forum non conveniens. Id. at 180.

In the present case, as in Prouty, Cook County has a substantial interest in this case. In Prouty, on interest the Court identified that the child had spend two weeks in a Cook County hospital. Id. at 179. Here, the minor plaintiff spent even longer in the same Cook County hospital. Prouty also held that any county to which Advocate provides service has an interest in the outcome of the case. Id. The same defendant in this case, Advocate, provides services in Cook County as thus, Cook County has an interest in the litigation.

As in Prouty, the majority of pertinent medical records, and diagnostic films will be located in Cook County along with the majority of witnesses. One factor that favored the defense, that is not present here, is Court congestion. As the Trial Court noted during oral argument on the rest of the motion, cases on this Court call on the individual Court calendar are disposed of far more rapidly than cases on then the general court calendar. Transferring this case back to Kane County will result in a significant delay as this process generally takes several months before the case is transferred and placed on the new court docket.

In addition, Cook adjoins Kane, and DuPage Counties. It is difficult to demonstrate that a trial in Cook County would be inconvenient or unduly burdensome where it adjoins the counties the Defendant advocates. See Meyers, 113 I11.2d at 121; Griffith 136 I11.2d at 113 (stating that the distance between adjacent counties makes it unlikely that trial in one county would be more costly or inconvenient than trial in the other); Diaber v. Montgomery County Mut. Fire Ins. Co., 191 Ill.App.3d 566, 568 (5th Dist. 1989) (“it is most difficult to demonstrate inconvenience when the alternative forum adjoins the county in which venue otherwise property was laid.”); Lint v. Missouri P. R. Co., 200 Ill.App.3d 1047, 1050 (5th Dist. 1990). Furthermore, due to the proximity of the Daley Center to metropolitan airports, mass transit systems, and interstate highways defendant's claim as to inconvenience is groundless.

Both Defendants have also retained counsels that are within walking distance of this Court. As defendants' counsels will be attending the Court calls and depositions, and they have chosen counsel in Cook County, Defendants certainly will not be inconvenienced by a Cook County Venue.

Lastly, the Court erred in failing to consider the numerous delays caused by the Defendants in failing to timely respond to pleadings, filing multiple motions to dismiss that were denied by the Court, and then waiting two years to bring a forum motion. Because Defendants seek equity, the Court erred in refusing to consider this significant factor in its decision. Transferring this case to Kane County, after the Court has decided multiple motions, and after limited discovery has been conducted, will cause considerable delay and additional expense to Plaintiff. There is no just reason why Defendants could not have brought their motion at an earlier date.

The doctrine of forum non conveniens is an equitable doctrine based upon considerations of fundamental fairness and sensible and effective judicial administration, and that equity aids the vigilant and not those who sleep on their rights. Terrill v. St. Louis Southwestern Ry. Co. 154 Ill.App.3d 983, 507 N.E.2d 1282, 1283 (5th Dist. 1987). A defendant who believes that the forum chosen by the plaintiff is inconvenient should not allow the lengthy periods of time which were involved in these cases to pass without asking the court to decline jurisdiction and dismiss the case. Bell v. Louisville & Nashville R. Co., 106 I11.2d 135, 478 N.E.2d 384, 389 (1985). Before the enactment of Illinois Supreme Court Rule 187, the Illinois Supreme Court held in Bell that a defendant's delay in asking the court to decline jurisdiction on the basis of forum non conveniens should be one of the factors weighed in considering the motion Id. at 389. While Bell was decided before the enactment of Rule 187, Bell has not been overruled. The First District recently held: “The supreme court's decisions in Bell, Kemner and McClain have not been reversed; therefore, the 90-day limitations period prescribed by Supreme Court Rule 187 must be applied and harmonized with those decisions. Ellis v. AAR Parts Trading, Inc., 357 Ill App.3d 723, 828 N.E.2d 726, 738 (1st Dist. 2005). A concern of the Supreme Court in Bell, which resulted in Supreme Court Rule 187 one year later, was that a defendant should be vigilant in seeking a change of venue. While the defendant's motion may not technically violate Supreme Court Rule 187, by repeatedly failing to meet Court deadlines, and by filing duplicative motions to transfer, and waiting over two years to file the current motion, Defendant has violated the spirit of the rule and the problem that Supreme Court rule was designed to address. Defendants should not be rewarded for their failure to act diligently in bringing this motion

WHEREFORE, the Plaintiff, Joann Williams, individually and as mother and next friend of Robert Morales, Jr., a minor, prays that this Honorable Court enter an Order Reversing its November 2, 2005 Order granting Defendants' Motion to Transfer, and that this matter be allowed to remain in Cook County, and for whatever other relief this Honorable Court deems just.

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