Meritorious Basis Affidavit 1
RE: Wendy Bums/Your File #4A0762-01
Dear Mr. Donald J. Mock,
I have had an opportunity to review the provided medical records related to the treatment and care of Ms. Bums.
It is my opinion, as a physician qualified to render same, being in a medical practice for more than six  years and qualified in this area of the Healing Arts, that there is a reasonable meritorious basis for bringing action against Drs. William Seneca, Steven Seneca and Kimberly Bruneau on behalf of Ms. Bums for  not obtaining appropriate testing before prescribing oral contraceptives to a women at risk for complications from same,  failure to monitor appropriate lab tests as well as blood pressure monitoring for a woman known to be hypertensive,  for continuing a medication longer than needed to control a clinical symptom,  for failure to provide informed consent about the risks versus benefits of continued oral contraceptives in a women with known hypertension and with no need for contraception.
That as a consequence, Ms. Burns suffered an acute stroke on 09/18/03.
That the standard of care would have required  that a lipid profile be obtained prior to or at the time of initiation of oral contraceptives in a woman of similar age,  that said lipid profile, if abnormal, would be addressed and treated appropriately and/or monitored as indicated along with blood pressure monitoring of a more frequent nature [and treatment and/or referral of any abnormality of same],  once a medication is successful in resolving a clinical situation, said medication should be reviewed for appropriate continuance, if needed, as well as alternative medications as appropriate, as well as consideration to discontinuance of said medication,  prescribed oral contraceptive is a known agent in increasing the risk of developing as well as aggravating hypertension as well as stroke - no indication that said review of risks versus benefits of continued medication was given to the patient, as well as failure to treat this patient's hypertension or to refer her to another physician specifically for this problem.