Malpractice Lawsuit in Child's Death

Electronically Filed
2/17/2020 10:36 AM
Steven D. Grierson
CLERK OF THE COURT
1 COMP
ADAM J. BREEDEN, ESQ.
2 Nevada Bar No. 008768
BREEDEN & ASSOCIATES, PLLC
3 376 E. Warm Springs Road, Suite 120 CASE NO: A-20-810590-C
Las Vegas, Nevada 89119
4 Phone: (702) 819-7770 Department 24
Fax: (702) 819-7771
5 Adam@Breedenandassociates.com
Attorneys for Plaintiffs
6
7 EIGHTH JUDICIAL DISTRICT COURT
8 CLARK COUNTY, NEVADA
9 DIAMOND ROSE, individually and as CASE NO.

Special Administrator of the Estate of
10 BRIANA JA’NAE BRADFORD, a minor DEPT NO.
deceased; and BRIAN BRADFORD,
11 individually,
COMPLAINT
12 Plaintiffs,
Arbitration Exempt- Professional
13 v. Negligence/Medical Malpractice/Wrongful
Death Case Chapter 41A
14 SUMMERLIN HOSPITAL MEDICAL
CENTER, LLC, a foreign limited liability
15 company; MARTIN N. LEE, M.D., an
16 individual; MEADOWS HEALTHCARE,

LLC, a Nevada limited liability company;
17 GARY S. MCLAUGHLIN, M.D., an
individual; EMCARE PHYSICIANS
18 PROVIDERS, INC., a foreign corporation;
FARAZ M. NOROZIAN, M.D., an individual;
19 EDMUND R. GOROZA, M.D., an individual;
20 POKROY MEDICAL GROUP OF NEVADA,

LTD. d/b/a PEDIATRIX MEDICAL GROUP
21 OF NEVADA, a Nevada limited liability
company; DOES I through X; and ROE
22 CORPORATIONS I through X, inclusive,
23 Defendants.
24
25 COMES NOW Plaintiffs, DIAMOND ROSE and BRIAN BRADFORD, by and through
26 their counsel, Adam J. Breeden, Esq. of BREEDEN & ASSOCIATES, PLLC, and for their
27 Complaint against the Defendants allege as follows:
28
Case Number: A-20-810590-C

1 PARTIES, JURISDICTION AND VENUE
2 1. Plaintiff, DIAMOND ROSE (hereinafter collectively referred to as “Plaintiff” and/or
3 “Ms. Rose”) is a resident and citizen of the State of Nevada, County of Clark, and was at all times
4 relevant to this Complaint.
5 2. Plaintiff ROSE also brings this action in her capacity as the Special Administrator of
6 the Estate of Briana J. Bradford, deceased.
7 3. Plaintiff, BRIAN BRADFORD (hereinafter collectively referred to as “Plaintiff”
8 and/or “Mr. Bradford”) is a resident and citizen of the State of Nevada, County of Clark, and was at
9 all times relevant to this Complaint.
10 4. Defendant, SUMMERLIN HOSPITAL MEDICAL CENTER, LLC (hereinafter
11 collectively referred to as “Defendant” and/or “Summerlin”) is and was a foreign limited-liability
12 company duly authorized to do and doing business in the County of Clark, State of Nevada at all
13 times relevant to this Complaint.
14 5. Defendant, MARTIN NICHOLAS LEE, M.D. (hereinafter referred to as “Dr. Lee”)
15 is and was a physician, with a specialty in pediatrics, and provider of health care licensed to practice
16 medicine within the State of Nevada as defined by NRS § 630.014, NRS § 630.020 and NRS §
17 41A.017, and was a medical care provider to Briana at all times relevant to this Complaint.
18 6. Defendant, MEADOWS HEALTHCARE, LLC (hereinafter collectively referred to
19 as “Defendant” and/or “Meadows Healthcare”) is and was a Nevada limited-liability company duly
20 authorized to do and doing business in the County of Clark, State of Nevada at all times relevant to
21 this Complaint.
22 7. Defendant, GARY MCLAUGHLIN, M.D. (hereinafter referred to as
23 “Dr. McLaughlin”) is and was a physician, with a specialty in emergency medicine, and provider of
24 health care licensed to practice medicine within the State of Nevada as defined by NRS § 630.014,
25 NRS § 630.020 and NRS § 41A.017, and was a medical care provider to Briana at all times relevant
26 to this Complaint.
27 8. Defendant, EMCARE PHYSICIANS PROVIDERS, INC. (hereinafter collectively
28 referred to as “Defendant” and/or “Emcare”) is and was a foreign limited-liability company duly
2
1 authorized to do and doing business in the County of Clark, State of Nevada at all times relevant to
2 this Complaint.
3 9. Defendant, FARAZ NOROZIAN, M.D. (hereinafter referred to as “Dr. Norozian”)
4 is and was a physician, with specialties in pediatrics and critical care, and provider of health care
5 licensed to practice medicine within the State of Nevada as defined by NRS § 630.014, NRS §
6 630.020 and NRS § 41A.017, and was a medical care provider to Briana at all times relevant to this
7 Complaint.
8 10. Defendant, EDMUND GOROZA, M.D. (hereinafter referred to as “Dr. Goroza”) is
9 and was a physician, with specialties in pediatrics and critical care, and provider of health care
10 licensed to practice medicine within the State of Nevada as defined by NRS § 630.014, NRS §
11 630.020 and NRS § 41A.017, and was a medical care provider to Briana at all times relevant to this
12 Complaint.
13 11. Defendant, POKROY MEDICAL GROUP OF NEVADA, LTD. d/b/a PEDIATRIX
14 MEDICAL GROUP OF NEVADA (hereinafter collectively referred to as “Defendant” and/or
15 “Pediatrix”) is and was a Nevada limited-liability company duly authorized to do and doing business
16 in the County of Clark, State of Nevada at all times relevant to this Complaint.
17 12. The true names and capacities, whether individual, corporate, associate, or otherwise,
18 of Defendants DOES I through X and ROE CORPORATIONS I through X, inclusive, are unknown
19 to the Plaintiff, who therefore sues these defendants by such fictitious names. Plaintiff is informed
20 and believes and thereon alleges that each of the Defendants designated herein as a Does I through
21 X, inclusive, and/or Roe Corporations I through X, inclusive, is responsible in some manner for the
22 events and happenings referred to herein, and caused injury and damages proximately thereby to
23 Plaintiff as herein alleged, and Plaintiff will ask leave of this Court to amend this Complaint to insert
24 the true names and capacities of Defendants, DOES and/or ROE CORPORATIONS, when the same
25 have been ascertained by Plaintiff, together with appropriate charging allegations, and adjoin such
26 Defendants in this action.

27 13. Using due diligence, Plaintiffs have identified what they believe are the legal entities
28 for which the Defendant physicians were agents for at the time of the events alleged herein.
3
1 However, there may be legal entities, business relationships, contracts or agencies unknown to
2 Plaintiffs at present, who thereby designate ROES I, II, III and IV as the unknown legal entities who
3 are responsible for the acts of doctors Lee, McLaughlin, Goroza and Norozian, respectively.
4 14. This Court has personal jurisdiction over the Defendants because they are residents
5 of the State of Nevada or have minimum contacts with the state of Nevada under NRS § 14.065.
6 15. This Court has subject matter jurisdiction over this matter pursuant to Nev. Const.
7 Art. VI, § 6 and NRS § 4.370(1), as this Court has original jurisdiction in all cases not assigned to
8 the justices’ courts and the amount in controversy exceeds $15,000, exclusive of attorney’s fees,
9 interest, and costs.
10 16. All the facts and circumstances that give rise to this dispute and lawsuit occurred in
11 Clark County, Nevada, making venue in the Eighth Judicial District the appropriate venue.
12 17. This is an action for professional negligence as defined by NRS § 41A.015. This
13 action falls under the scope of NRS Chapter 41A and pursuant to NRS § 41A.071 is supported by
14 the attached affidavits of Dr. Alan Nager, Dr. Nicholas Saenz and Dr. H. Michael Worthen,
15 physicians in the same or substantially similar area of practice as the Defendants. A copy of
16 Dr. Nager’s supporting declaration and report is attached as Exhibit “1” to this Complaint. A copy
17 of Dr. Saenz’ supporting declaration and report is attached as Exhibit “2” to this Complaint. A
18 copy of Dr. Worthen’s supporting declaration and report is attached as Exhibit “3” to this
19 Complaint.
20 ALLEGATIONS COMMON TO ALL COUNTS
21 18. Plaintiffs Diamond Rose and Brian Branford are the natural parents of Briana
22 Bradford, deceased.
23 19. On February 9, 2019, Briana Bradford celebrated her seventh (7th) birthday with
24 family and friends as a happy, healthy young girl with her whole life ahead of her. Incredibly, she
25 would be dead within 10 days.
26 20. On February 16, 2019, Briana was taken to the Summerlin Hospital Emergency
27 Department with pain in the lower right quadrant, nausea and vomiting.
28
4
1 21. On further evaluation at Summerlin Hospital, Briana’s condition should have been
2 interpreted as very serious as she had clear signs of an ongoing abdominal infection and dehydration
3 secondary to infection, including abdominal pain and tenderness, nausea, vomiting, tachycardia
4 (high heart rate), hypotension (low blood pressure), hematocrit 59%, BUN 39, Creatinine 1.04,
5 TCO2 17, WBC 24,230 and urine specific gravity 1.045.
6 22. Despite these incredibly serious symptoms, vital signs and laboratory results, her
7 care can be described as “too little, too late” with Briana’s care showing no urgency and being
8 insufficient to address her condition regardless.
9 23. Although fluid resuscitation treatment is critical and the standard of care for
10 treatment of abdominal infection or sepsis requires such treatment, Briana received insufficient fluid
11 therapy, her weight and fluid intake/output was not properly recorded to even begin to allow for
12 sufficient fluid therapy, and her fluid therapy was not titrated to effect to control her vital signs.
13 24. Although adequate antibiotic treatment is critical and the standard of care for
14 treatment of abdominal infection or sepsis requires such treatment, Briana was only administered
15 ceftriaxone which by itself done not address all abdominal infections. The first documented
16 administration of ceftriaxone is 22 hours after presentation, well beyond the 1-2 hour standard of
17 care, and despite having no reaction to ceftriaxone an infectious diseases doctor was not consulted
18 nor were alternate antibiotics considered or administered.
19 25. Although adequate source control is critical and the standard of care for treatment of
20 abdominal infection or sepsis requires such treatment, no pediatric surgeon was consulted and no
21 surgery to explore the abdomen and find the source of the infection or irrigate the abdomen, which
22 had ascites, occurred during Briana’s lifetime.
23 26. As other examples of the type of insufficient care she received, Briana sat for hours
24 in the ER and hospital without care. Just as one of many examples of this, while Briana sat dying
25 of infection in Summerlin Hospital, no care of any kind for her is recorded for four hours after her
26 hospital admission. There is no record that the ER doctor spoke to the intensivist about this critical
27 patient upon admission to the hospital. Despite serious symptoms, vitals and lab results in this child,
28 there was no urgency to Briana’s care and her case does not appear to have been taken seriously.
5
1 Vitals were infrequently recorded with little response to her serious tachycardia and hypotension
2 which persisted throughout her hospital course. Although Briana should have been admitted directly
3 into the PICU, she was instead sent to the hospital floor and received less attention. There is no
4 record of any order for an antibiotic for twenty hours after presentation and, despite the fact that
5 Briana was dying of an infection, it took staff two hours past the time the antibiotic was ordered to
6 actually administer it. It took 10 hours to get a CT of a child who clearly had a serious abdominal
7 infection. Concerning vitals such as an extremely high heart rate but extremely low blood pressure
8 was recorded and then not monitored further for hours at a time despite a lack of improvement. Her
9 fluid intake and output were not carefully monitored, and her weight is not even recorded, which
10 would make it impossible to properly treat her with fluids. This is a girl who was left to die, despite
11 all warning signs. No one seemed to take her case seriously, the ultimate insult being Dr. Lee’s note
12 when Briana was discharged from the ER that her condition had “improved.” Perhaps nothing better
13 exemplifies the type of substandard care Briana received than writing in the chart of a seven year
14 old girl--who would die in approximately 8 hours who you have failed to properly diagnose,
15 properly administer treatment, or address her serious vitals and lab results--that she has “improved.”
16 27. Briana sat in Summerlin Hospital being left uncared for and unmonitored for hours
17 at a time while she bravely fought for her life despite being in a hospital full of doctors, nurses and
18 modern medical care that could have easily saved her had proper treatment been administered.
19 28. After approximately 35 hours at Summerlin Hospital, Briana Bradford died of her
20 abdominal infection at 3:45 a.m. on February 18, 2019.
21 FIRST CAUSE OF ACTION
22 (Corporate Negligence – Summerlin Hospital Medical Center, LLC)
23 29. Plaintiffs hereby re-state and re-allege each and every preceding paragraph of the
24 Complaint as if fully restated herein.
25 30. As a hospital, Summerlin Hospital owed a duty of care to Plaintiffs and the decedent
26 to use reasonable care to properly staff, credential and hire at its hospital, provide education and
27 training, and properly supervise those working out of its hospital, regardless of whether those
28 persons were direct employees of the hospital, independent contractors or some other form of agent.
6
1 31. Summerlin Hospital breached its duty to properly hire, educate, train and supervise
2 those working at its hospital.
3 32. As a result of said breach, Briana Bradford received improper care and died.
4 33. As a direct and proximate cause of the acts of the Defendants, Plaintiffs have
5 sustained damages in an amount to be determined at trial but exceeding $15,000.
6 34. That Plaintiffs have been required to retain an attorney to prosecute their case and
7 Defendants are liable for all attorney’s fees, costs and interest incurred.
8 SECOND CAUSE OF ACTION
9 (Professional Negligence – Summerlin Hospital Medical Center, LLC)
12 36. While at Summerlin Hospital and leading up to her death, Briana Bradford was
13 provided medical care by various nurses and staff who were direct employees of Summerlin
14 Hospital, including but not limited to: Marizel Yukee, RN, Jonathon Berkabile, RN, Amy
15 Bergstrom, RN, Karla Welch, RN, Dana Ernsberger, RN, Alicia Garcia, RN, Alicia Garcia, RN,
16 Melissa Benkovich, RN, Ashley Escuriex, RN, Traci Dufour, RN, and Isabel Gonzales, RN.
17 37. These nurses and staff failed, in rendering health care services, to use the reasonable
18 care, skill or knowledge ordinarily used under similar circumstances by similarly trained and
19 experienced providers of health care.
20 38. More specifically but without limitation, the staff/nurses at Summerlin Hospital fell
21 below the standard of care in at least the following ways: (a) record keeping was insufficient, (b)
22 the patient’s weight was not recorded to allow proper fluid administration, (c) the patient’s fluid
23 input and output was not recorded to allow proper fluid administration, (d) the patient was admitted
24 to the pediatric floor as opposed to the PICU, as ordered, when transferred from the Emergency
25 Department, (e) there are long periods of time or “gaps” in the medical records where no care or
26 vital signs are being taken of the patient by nurses, (f) failing to timely administer the treatment that
27 was ordered by the physicians, and (g) there was no nurse advocacy for this patient despite
28 prolonged, serious vital signs and a lack of improvement.
7
1 39. In addition to or in alternative to professional negligence, the actions of the staff and
2 nurses were undertaken knowingly, wantonly, willfully, maliciously and/or with extreme conscious
3 disregard.
4 40. In addition to or in alternative to professional negligence, the conduct was despicable
5 and so contemptable that it would be looked down upon and despised by ordinary decent people and
6 was carried on with willful and conscious disregard for the safety of Briana Bradford.
7 41. In addition to or in alternative to professional negligence, the outrageous and
8 unconscionable conduct warrants an award of exemplary and punitive damages under NRS § 42.005
9 in an amount appropriate to punish and make an example of the Defendant and to deter similar
10 conduct in the future.
11 42. As a result of said acts or omissions of the staff and nurses and breaches of the
12 standard of care, Briana Bradford died.
13 43. At the time the staff and nurses administered care to Briana Bradford, they were the
14 actual, apparent, implied or ostensible agent of Defendant Summerlin Hospital Medical Center,
15 LLC. Therefore, Defendant Summerlin Hospital Medical Center, LLC is responsible for the
16 injuries, pain, suffering and death of Briana Bradford under the theory of respondeat superior, NRS
17 § 41.130 and to the extent applicable NRS § 42.007.
22 THIRD CAUSE OF ACTION
23 (Professional Negligence – Martin N. Lee, M.D., Meadows Healthcare, LLC & Summerlin
Hospital Medical Center, LLC)
24

27 47. While at Summerlin Hospital ED and leading up to her death, Briana Bradford was
28 provided medical care by Dr. Martin Lee.
8
1 48. Dr. Lee failed, in rendering health care services, to use the reasonable care, skill or
2 knowledge ordinarily used under similar circumstances by similarly trained and experienced
3 providers of health care.
4 49. More specifically but without limitation, Dr. Lee (a) failed to promptly administer
5 adequate antibiotic therapy, (b) failed to administer adequate fluid therapy, (c) failed throughout the
6 ED stay to properly monitor and interpret vital signs, (d) failed to properly diagnoses the patient
7 and/or adjust his differential diagnosis despite the patient’s failure to improve, (e) failed to assure
8 the patient’s transfer to the PICU or discuss her case with the hospital physicians assuming the
9 patient’s care, and (f) generally failed to urgently recognize and treat the serious abdominal infection
10 and/or related conditions of the patient.
11 50. In addition to or in alternative to professional negligence, the actions of Dr. Lee were
12 undertaken knowingly, wantonly, willfully, maliciously and/or with extreme conscious disregard.
13 51. In addition to or in alternative to professional negligence, Dr. Lee’s conduct was
14 despicable and so contemptable that it would be looked down upon and despised by ordinary decent
15 people and was carried on with willful and conscious disregard for the safety of Briana Bradford.
16 52. In addition to or in alternative to professional negligence, Dr. Lee’s outrageous and
17 unconscionable conduct warrants an award of exemplary and punitive damages under NRS § 42.005
18 in an amount appropriate to punish and make an example of the Defendant and to deter similar
19 conduct in the future.
20 53. As a result of said acts or omissions of Dr. Lee and breaches of the standard of care,
21 Briana Bradford died.
22 54. At the time Dr. Lee administered care to Briana Bradford, he was the actual,
23 apparent, implied or ostensible agent of Defendant Meadows Healthcare, LLC and/or ROE I.
24 Therefore, Defendant Meadows Healthcare, LLC and/or ROE I is responsible for the injuries, pain,
25 suffering and death of Briana Bradford under the theory of respondeat superior, NRS § 41.130 and
26 to the extent applicable NRS § 42.007.

27 55. At the time Dr. Lee administered care to Briana Bradford, he was the actual,
28 apparent, implied or ostensible agent of Defendant Summerlin Hospital Medical Center, LLC.
9
1 Therefore, Defendant Summerlin Hospital Medical Center, LLC is responsible for the injuries, pain,
8 FOURTH CAUSE OF ACTION
9 (Professional Negligence – Gary McLaughlin, M.D., Emcare Physicians Providers, Inc. &
Summerlin Hospital Medical Center, LLC)
10
13 59. While at Summerlin Hospital ED and leading up to her death, Briana Bradford was
14 provided medical care by Dr. Gary McLaughlin.
15 60. Dr. McLaughlin failed, in rendering health care services, to use the reasonable care,
16 skill or knowledge ordinarily used under similar circumstances by similarly trained and experienced
18 61. More specifically but without limitation, Dr. McLaughlin (a) failed to promptly
19 administer adequate antibiotic therapy, (b) failed to administer adequate fluid therapy, (c) failed
20 throughout the ED stay to properly monitor and interpret vital signs, (d) failed to properly diagnoses
21 the patient and/or adjust his differential diagnosis despite the patient’s failure to improve, (e) failed
22 to assure the patient’s transfer to the PICU or discuss her case with the hospital physicians assuming
23 the patient’s care, and (f) generally failed to urgently recognize and treat the serious abdominal
24 infection and/or related conditions of the patient.
25 62. In addition to or in alternative to professional negligence, the actions of
26 Dr. McLaughlin were undertaken knowingly, wantonly, willfully, maliciously and/or with extreme
27 conscious disregard.
28 63. In addition to or in alternative to professional negligence, Dr. McLaughlin’s conduct
10
1 was despicable and so contemptable that it would be looked down upon and despised by ordinary
2 decent people and was carried on with willful and conscious disregard for the safety of Briana
3 Bradford.
4 64. In addition to or in alternative to professional negligence, Dr. McLaughlin’s
5 outrageous and unconscionable conduct warrants an award of exemplary and punitive damages
6 under NRS § 42.005 in an amount appropriate to punish and make an example of the Defendant and
7 to deter similar conduct in the future.
8 65. As a result of said acts or omissions of Dr. McLaughlin and breaches of the standard
9 of care, Briana Bradford died.
10 66. At the time Dr. McLaughlin administered care to Briana Bradford, he was the actual,
11 apparent, implied or ostensible agent of Defendant Emcare Physicians Providers, Inc. and/or ROE
12 II. Therefore, Defendant Emcare Physicians Providers, Inc. and/or ROE II is responsible for the
15 67. At the time Dr. McLaughlin administered care to Briana Bradford, he was the actual,
24 FIFTH CAUSE OF ACTION
25 (Professional Negligence – Edmund Goroza, M.D., Pokroy Medical Group of Nevada, Ltd. &
26
11
2 provided medical care by Dr. Edmund Goroza.
3 72. Dr. Goroza failed, in rendering health care services, to use the reasonable care, skill
4 or knowledge ordinarily used under similar circumstances by similarly trained and experienced
6 73. More specifically but without limitation, Dr. Goroza (a) failed to promptly
8 throughout the hospital stay to properly monitor and interpret vital signs, (d) failed to properly
9 diagnoses the patient and/or adjust his differential diagnosis despite the patient’s failure to improve,
10 (e) failed to assure the patient’s transfer to the PICU or discuss her case with other hospital
11 physicians, and (f) generally failed to urgently recognize and treat the serious abdominal infection
13 74. In addition to or in alternative to professional negligence, the actions of Dr. Goroza
14 were undertaken knowingly, wantonly, willfully, maliciously and/or with extreme conscious
15 disregard.
16 75. In addition to or in alternative to professional negligence, Dr. Goroza’s conduct was
17 despicable and so contemptable that it would be looked down upon and despised by ordinary decent
18 people and was carried on with willful and conscious disregard for the safety of Briana Bradford.
19 76. In addition to or in alternative to professional negligence, Dr. Goroza’s outrageous
20 and unconscionable conduct warrants an award of exemplary and punitive damages under NRS
21 § 42.005 in an amount appropriate to punish and make an example of the Defendant and to deter
22 similar conduct in the future.
23 77. As a result of said acts or omissions of Dr. Goroza and breaches of the standard of
24 care, Briana Bradford died.
25 78. At the time Dr. Goroza administered care to Briana Bradford, he was the actual,
26 apparent, implied or ostensible agent of Defendant Pokroy Medical Group of Nevada, Ltd. d/b/a
27 Pediatrix Medical Group of Nevada and/or ROE III. Therefore, Defendant Pokroy Medical Group
28 of Nevada, Ltd. d/b/a Pediatrix Medical Group of Nevada and/or ROE III is responsible for the
12
3 79. At the time Dr. Goroza administered care to Briana Bradford, he was the actual,
12 SIXTH CAUSE OF ACTION
13 (Professional Negligence – Faraz Norozian, M.D., Pokroy Medical Group of Nevada, Ltd. &
14
18 provided medical care by Dr. Faraz Norozian.
19 84. Dr. Norozian failed, in rendering health care services, to use the reasonable care, skill
20 or knowledge ordinarily used under similar circumstances by similarly trained and experienced
22 85. More specifically but without limitation, Dr. Norozian (a) failed to promptly
24 throughout the hospital stay to properly monitor and interpret vital signs, (d) failed to properly
25 diagnoses the patient and/or adjust his differential diagnosis despite the patient’s failure to improve,
26 (e) failed to assure the patient’s transfer to the PICU or discuss her case with other hospital
27 physicians, and (f) generally failed to urgently recognize and treat the serious abdominal infection
13
1 86. In addition to or in alternative to professional negligence, the actions of Dr. Norozian
2 were undertaken knowingly, wantonly, willfully, maliciously and/or with extreme conscious
3 disregard.
4 87. In addition to or in alternative to professional negligence, Dr. Norozian’s conduct
5 was despicable and so contemptable that it would be looked down upon and despised by ordinary
6 decent people and was carried on with willful and conscious disregard for the safety of Briana
7 Bradford.
8 88. In addition to or in alternative to professional negligence, Dr. Norozian’s outrageous
9 and unconscionable conduct warrants an award of exemplary and punitive damages under NRS §
10 42.005 in an amount appropriate to punish and make an example of the Defendant and to deter
11 similar conduct in the future.
12 89. As a result of said acts or omissions of Dr. Norozian and breaches of the standard of
13 care, Briana Bradford died.
14 90. At the time Dr. Norozian administered care to Briana Bradford, he was the actual,
15 apparent, implied or ostensible agent of Defendant Pokroy Medical Group of Nevada, Ltd. d/b/a
16 Pediatrix Medical Group of Nevada and/or ROE IV. Therefore, Defendant Pokroy Medical Group
17 of Nevada, Ltd. d/b/a Pediatrix Medical Group of Nevada and/or ROE IV is responsible for the
20 91. At the time Dr. Norozian administered care to Briana Bradford, he was the actual,

14
1 SEVENTH CAUSE OF ACTION
2 (Negligent Infliction of Emotional Distress – All Defendants)
3 94. Plaintiffs hereby re-state and re-allege each and every paragraph of the Complaint as
4 if fully restated herein.
5 95. As set forth herein previously in the Complaint, the Defendants negligently caused
6 the death of Briana J. Bradford.
7 96. As a result of the Defendants’ acts and omissions, Plaintiffs Diamond Rose and Brian
8 Bradford personally witnessed the extreme pain and suffering, medical emergency care, the last
9 sounds of their child, the last breath of their child, and the death of their child.
10 97. As a result, Plaintiffs were subjected to extreme emotional shock, trauma and distress
11 due to the Defendants’ negligence.
16 EIGHTH CAUSE OF ACTION
17 (Breach of Contract – All Defendants)
18 100. Plaintiffs hereby re-state and re-allege each and every paragraph of the Complaint as
19 if fully restated herein.
20 101. The Defendants, and each of them, entered into a contract under which they were to
21 provide medical care to Briana Bradford.
22 102. The contract included a covenant of good faith and fair dealing, and an express or
23 implied agreement that medical services would be provided at a professional level within the
24 standard of care.
25 103. Defendants breached their duty under said contract.
27 sustained damages in an amount to be determined at trial but exceeding $15,000 and are entitled to
28 recover the reasonable amount of medical services incurred for Briana prior to and after her death.
15
3 WHEREFORE, Plaintiffs pray for judgment against the Defendants and each of them
4 jointly and severally as follows:
5 1. For special and general damages in an amount to exceed $15,000;
6 2. For punitive damages in an amount to exceed $15,000;
7 3. For attorney’s fees, expenses, and costs of suit;
8 4. For all pre-judgment and post-judgment interest awardable by law;
9 5. For such further relief as the Court may deem just and proper.
10 DATED this 17th day of February, 2020.
11 BREEDEN & ASSOCIATES, PLLC
12
13 ADAM J. BREEDEN, ESQ.

Nevada Bar No. 008768
14 376 E. Warm Springs Road, Suite 120
Las Vegas, Nevada 89119
15 Phone: (702) 819-7770
Fax: (702 819-7771
16 Adam@Breedenandassociates.com
Attorneys for Plaintiffs
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Electronically Filed

7 EIGHTH JUDICIAL DISTRICT COURT

8 CLARK COUNTY, NEVADA

9 DIAMOND ROSE, individually and as CASE NO.

16 individual; MEADOWS HEALTHCARE,

20 POKROY MEDICAL GROUP OF NEVADA,

Case Number: A-20-810590-C

2 1. Plaintiff, DIAMOND ROSE (hereinafter collectively referred to as “Plaintiff” and/or

4 relevant to this Complaint.

6 the Estate of Briana J. Bradford, deceased.

7 3. Plaintiff, BRIAN BRADFORD (hereinafter collectively referred to as “Plaintiff”

9 all times relevant to this Complaint.

10 4. Defendant, SUMMERLIN HOSPITAL MEDICAL CENTER, LLC (hereinafter

11 collectively referred to as “Defendant” and/or “Summerlin”) is and was a foreign limited-liability

13 times relevant to this Complaint.

14 5. Defendant, MARTIN NICHOLAS LEE, M.D. (hereinafter referred to as “Dr. Lee”)

18 6. Defendant, MEADOWS HEALTHCARE, LLC (hereinafter collectively referred to

22 7. Defendant, GARY MCLAUGHLIN, M.D. (hereinafter referred to as

3 9. Defendant, FARAZ NOROZIAN, M.D. (hereinafter referred to as “Dr. Norozian”)

8 10. Defendant, EDMUND GOROZA, M.D. (hereinafter referred to as “Dr. Goroza”) is

13 11. Defendant, POKROY MEDICAL GROUP OF NEVADA, LTD. d/b/a PEDIATRIX

14 MEDICAL GROUP OF NEVADA (hereinafter collectively referred to as “Defendant” and/or

26 Defendants in this action.

9 interest, and costs.

20 ALLEGATIONS COMMON TO ALL COUNTS

25 would be dead within 10 days.

5 TCO2 17, WBC 24,230 and urine specific gravity 1.045.

8 insufficient to address her condition regardless.

18 nor were alternate antibiotics considered or administered.

22 had ascites, occurred during Briana’s lifetime.

20 abdominal infection at 3:45 a.m. on February 18, 2019.

21 FIRST CAUSE OF ACTION

22 (Corporate Negligence – Summerlin Hospital Medical Center, LLC)

24 Complaint as if fully restated herein.

2 those working at its hospital.

5 sustained damages in an amount to be determined at trial but exceeding $15,000.

8 SECOND CAUSE OF ACTION

9 (Professional Negligence – Summerlin Hospital Medical Center, LLC)

11 Complaint as if fully restated herein.

19 experienced providers of health care.

28 prolonged, serious vital signs and a lack of improvement.

4 40. In addition to or in alternative to professional negligence, the conduct was despicable

7 41. In addition to or in alternative to professional negligence, the outrageous and

10 conduct in the future.

12 standard of care, Briana Bradford died.

17 § 41.130 and to the extent applicable NRS § 42.007.

19 sustained damages in an amount to be determined at trial but exceeding $15,000.

22 THIRD CAUSE OF ACTION

26 Complaint as if fully restated herein.

28 provided medical care by Dr. Martin Lee.

3 providers of health care.

10 and/or related conditions of the patient.

13 51. In addition to or in alternative to professional negligence, Dr. Lee’s conduct was

16 52. In addition to or in alternative to professional negligence, Dr. Lee’s outrageous and

19 conduct in the future.

21 Briana Bradford died.

26 to the extent applicable NRS § 42.007.

3 to the extent applicable NRS § 42.007.

5 sustained damages in an amount to be determined at trial but exceeding $15,000.

8 FOURTH CAUSE OF ACTION

12 Complaint as if fully restated herein.

14 provided medical care by Dr. Gary McLaughlin.

17 providers of health care.