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COMPLAINT - American Association for Justice

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a corporation organized and existing under the laws of the State of Tennessee <strong>for</strong> the<br />

purpose of providing hospital care to patients. At all material times, defendant St.<br />

Thomas acted by and through its agents, servants and/or employees, who in turn were<br />

acting within the course and/or scope of their employment.<br />

5. Marissa Creager presented to defendants Oldfield and Growdon and was<br />

followed in their office <strong>for</strong> obstetrical care during her pregnancy. Her initial pre-natal<br />

examination was in mid-1996.<br />

6. During her pregnancy genetic tests were done on the baby which revealed<br />

no evidence of genetic defects.<br />

7. Marissa Creager was admitted to St. Thomas Hospital on or about March<br />

31, 1997 <strong>for</strong> induction of labor.<br />

8. The membranes were artificially ruptured and induction started in the<br />

morning hours of March 31, 1997. The induction was done with Pitocin.<br />

9. After the start of the induction an epidural was placed.<br />

10. Sometime in the early afternoon, the fetal monitor revealed a deceleration<br />

associated with a tetanic contraction. At that point the Pitocin was discontinued but was<br />

restarted shortly afterward.<br />

11. Throughout the day, while her labor was augmented with Pitocin, Marissa<br />

Creager’s cervix dilated slower than expected.<br />

12. Sometime in the afternoon of March 31, 1997 the fetal monitor strip<br />

exhibited signs of fetal distress.<br />

13. These signs generally became more significant through the later afternoon<br />

and early evening hours.<br />

14. Repetitive late decelerations developed on the monitor strip, but the nurses<br />

and agents of defendant St. Thomas never in<strong>for</strong>med defendant Oldfield of their presence.<br />

15. Sometime around 8:15 p.m. defendant Oldfield became concerned about<br />

the tracings.<br />

16. Around 8:15 p.m., defendant Oldfield noted that Marissa Creager had a<br />

high station which needed to be advanced be<strong>for</strong>e delivery could be accomplished.<br />

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