...IN THE COURT OF COMMON PLEAS, ABC COUNTY, PENNSYLVANIA CIVIL ACTION-LAW LUKE SPENCER & LAURA SPENCER : 100 Maple Street : Anywhere, PA 19100 : Plaintiff : v. : No. 04-1234 : GENERAL HOSPITAL : 200 City Avenue : Anywhere, PA 19100 : Defendant : PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT'S PRELIMINARY OBJECTIONS IN THE NATURE OF A DEMURRER Statement of Facts Laura Spencer was admitted to General Hospital on May 1, 2003. Lucky Spencer was delivered at 11:52 p.m. The following morning a nurse brought the baby into the plaintiff’s room in a rolling crib and then left. After about fifteen minutes of nursing, Laura feeling tired called the nurse to come and take the baby back to the nursery. When the nurse returned she was hurried and appeared tired. She picked up the baby to the transport him back to the nursery, but failed to put the baby into the rolling crib per hospital policy. Instead, she held the baby in one arm and attempted to open and close the door to plaintiff’s room. The nurse lost her grip and dropped the newborn on his head onto the floor. The plaintiff immediately heard...
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