Documente Academic
Documente Profesional
Documente Cultură
for the
District of Vermont
Civil Division
Plaintiff, :
:
v.
:
LASSITER CENTRAL CLINIC OF
VERMONT, a corporation : COMPLAINT FOR DAMAGES
DR. BETHANY RANDALL, an
individual :
Defendants. :
____________________________
Count 1
2. Plaintiff is domiciled in and a citizen of the state of Rhode Island. Defendant, Dr.
the laws of the State of Vermont, with its principal place of business in the state
of Vermont. Every issue of law and fact in this action is fully between citizens of
different states.
Count 2
3. Defendant Dr. Beth Randall was the agent and employee of Lassiter Central
Clinic of Vermont, and in doing the things hereinafter alleged, was acting within
4. Defendant Dr. Beth Randall, on or about September 11, 2017 in the state of
Vermont, did not properly receive consent for the medical procedure conducted
on Plaintiff.
5. Defendant Dr. Beth Randall, on or about September 11, 2017 in the state of
anaphylactic shock.
6. Plaintiff had a cardiac arrest and almost expired due to the actions of Defendant.
8. As a result, the plaintiff suffered physical and mental injuries, and incurred
Wherefore plaintiff for judgment against defendants for medical bills, pain and
suffering, and any other damages that the Court finds proper.