Inga Robertson 10/31/2018 12:58 PM WAYNE COUNTY CLERK 18-014152-NO FILED INMY OFFICE Cathy M. Garrett STATE OF MICHIGAN THIRD CIRCUIT COURT COUNTY OF WAYNE CIVIL DIVISION WHITNEY MORRIS and AJ JOHNSON, as Parents and Next of Kin of BABY BOY MORRIS, Case No: 18 -NO Hon, Plaintiffs, vs. VHS HARPER-HUTZEL HOSPITAL, INC., d/b/a HARPER-HUTZEL HOSPITAL, and, d/b/a HUTZEL WOMEN'S HOSPITAL, and CANTRELL FUNERAL HOME, INC.. a Michigan Domestic For Profit Corporation, and RAYMOND E. CANTRELL II, and ANNETTA CANTRELL Defendants. COLOVOS LAW FIRM BILL COLOVOS (P38434) Attorney for Plaintifis 13305 Reeck Road, Ste. 140 Southgate, Michigan 48195 (734) 282-2900 (phone) (734) 281-7332 (facsimile) bcolovos@sheglobal.net (email) COMPLAIN JURY DEMAND ‘There is a prior civil action pending with this Court arising out of the ‘occurrences and actions of Defendants as alleged in this Complaint bearing Case No.: 18-006481-NZ, assigned to Circuit Court Judge David A. Groner NOW COMES Plaintiffs, Whitney Morris and AJ Johnson, by and through their Attorney, Bill Colovos, and in support of their Complaint against the Defendants, state the following: JURISDICTIONAL ALLEGATIONS 1 Plaintiffs, Whitney Morris and AJ Johnson, are residents of the County of Wayne,Inga Robertson 10/31/2018 12:58 PM WAYNE COUNTY CLERK 18-014152-NO FILED INMY OFFICE Cathy M. Garrett State of Michigan. 2. Plaintiffs are the parents and Next of Kin of the decedent, Baby Boy Morris. 3. Defendant, VHS Harper-Hutzel Hospital, is a Foreign Corporation that does busin in the County of Wayne, State of Michigan under the assumed names of Harper-Hutzel Hospital and Hutzel Women’s Hospital 4. Defendant, Cantrell Funeral Home, is a domestic for profit corporation which has conducted regular business in the County of Wayne, State of Michigan, during all relevant times. 5. Defendant, Raymond E. Cantrell II, has been a Resident of the County of Wayne, State of Michigan during all relevant times. 6. Defendant, Annetta Cantrell, is a resident of the County of Wayne, State of Michigan, 7. The wrongful actions of Defendants were committed in the County of Wayne, State of Michigan. 8. The County of Wayne is the proper venue for this cause of action. 9. ‘The amount in controversy is in excess of $25,000.00, exclusive of costs, inte and attorney fees. DEFENDANTS' NEGLIGENT AND VRONGFUL HANDLING OF HUMAN REMAIN! 10. Plaintiffs hereby adopt and incorporate by reference each and every allegation as set forth above as though fully set forth herein 11. On or about September 13, 2011, the Plaintiff, Whitney Morris, was approximately 5 months pregnant and began experiencing bleeding and abdominal pain. 12, The Plaintiff immediately went to the emergency department at VHS Harper- Hutzel Hospital, doing business as Hutzel Women’s HospitalInga Robertson 10/31/2018 12:58 PM WAYNE COUNTY CLERK 18-014152-NO FILED INMY OFFICE Cathy M. Garrett 13, The Plaintiff’ was informed that she was a high risk pregnancy and due to hospi policy she would have to be admitted if 14, After being admitted into Defendant, Hutzel Women's Hospital, the Plai received both a vaginal and abdominal ultrasound along with various other tests. 15, After reviewing the ultrasounds and receiving the results of the tests the doctor on staff informed the Plaintiff, Mrs. Morris, that her baby was alive. 16, The doctor then told Mrs. Morris that the ultrasound looked cloudy which was a sign of infection. He then informed her that it would be in her best interest to induce labor at this point to guarantee the infection would not spread into her heart causing her to die, ae The Plaintiff, Mrs. Morris, had received an ultrasound mere weeks ago that was clear and indicated no sign of any infection 18. The Plaintiff told the doctor she did not think it was in the best interest of her baby or herself and she was not going to allow him to induce her labor. 19, The Defendant, Hutzel Women's Hospital's staff doctor, then, unethically and cruelly took it upon himself to tell the Plaintiff's family horror stories of other women dying painfully due to their refusing to have their labor induced as a scare tactic to force the Plaintiff to allow him to have his way and have her baby prematurely. 20, Plaintiff was coerced into having her labor induced and was prepared for delivery with all of the usual IV's and medications, including medication for pain which never had a regulator/stopper attached to the TV tube. 21. Upon feeling labor pains, Plaintiff notified her nurse who passed her off to someone else to be transported to labor and delivery.