Plaintiff’s Decedent, Linda Brown, presented herself to Union Hospital under the attending physician care of Defendants, Doe and/or Doe, Inc.

Upon her admission to Defendant Hospital, Defendant Doe was “covering” for Defendant Roe who was absent from the hospital and had requested that Defendant Doe oversee Decedent’s care and treatment. On said date, Linda Brown was a 30-year old wife and mother of three, who was admitted for a late term pregnancy and delivery.

Linda Brown was admitted to labor room “3” at approximately 7:00 a.m. At approximately 1:24 p.m., Linda Brown delivered a viable female. Following the delivery, Linda Brown began to experience heavy vaginal bleeding. This bleeding continued and at approximately 2:00 p.m., Defendant Doe took Linda Brown to the operating room in order “to find where the bleeding is originating from”. Thereafter, Defendants undertook a “vaginal exploration under general anesthesia, exploratory laparatomy and supracervical hysterectomy”. Despite the fact that Linda Brown’s bleeding was uncontrollable and “oozing from almost everywhere”, Defendants made the decision to perform a closure at the abdominal incision and transfer Linda Brown to the intensive care unit.

Upon being transferred to the intensive care unit, Linda Brown went into cardiac and respiratory arrest and was declared dead at approximately 6:30 p.m.