Trial Court of Massachusetts SUPERIOR COURT DEPARTMENT Ge ag CIVIL ACTION COVER SHEET | ——_NORFOLK __ Division I ra ee Catherine Clark Boris I. Orkin, M.D. ee ARR Wii eRce eS ees 301 victory oad, Harina Bay Quincy, MA 02171 617-773-7111 Board of Bar Overseers # (Required) 431860 ORIGIN CODE AND TRACK DESIGNATION 2 4 Place an [Xi in one box only: & 1. FO1 Original Complaint C1 4, Fos District Ct. Appeal 231, 5.970) Ex 0 2, Fo2 Removal to Sup. Ct. ¢231, s, 104 (F) O 5. FOS Reactivated after Rescript; Relief from! C0 3. F03 Retransfer to Sup. Ct. ¢231, s. 102C (X) judgmentforder (Mass. R Civ. P. 60 ( O 6. £10 Summary process appeal (x) TYPE OF ACTION AND TRACK DESIGNATION (See Reverse Side) CODE NO. TYPE OF ACTION (specity) TRACK 1S THIS A JURY CASE? B06 Malpractice - Medical (A) ® Yes No 1. PLEASE GIVE A CONCISE STATEMENT OF THE FACTS: (Required in ALL Types of Actions) In the present instance, the defendant performed an abortion upon the plantiff. Subsequent to the procedure as performed upon the plaintiff, the said plaintiff developed severe and debilitating complications which were made known to the defendant, his agents, servants and employees. In spite of this, the defendant did nothing and as a result of his negligence, the plaintiff developed a serious infection (sepsis) which eventually lead to the plaintiff having a stroke rendering her totally paralyzed on her right side. 2. IN A CONTRACT ACTION (CODE A) OR A TORT ACTION (CODE 8) STATE, WITH PARTICULARITY, MONEY DAMAGES WHICH WOULD WARRANT A REASONABLE LIKELIHOOD THAT RECOVERY WOULD EXCEED $25,004 As a result of the defendant's alleged negligence and failure to follow and monitor the plaintiff's post-surgical condition, the plaintiff has been left totally paralyzed on her right side for the remainder of her life and, as such, is totally unable to care for herself and/or undertake or resume any of her normal activities and/or gainful employment. 3. PLEASE IDENTIFY, BY CASE NUMBER, NAME AND DIVISION, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT. None. ‘SONATURE OF ATTORNEY OF PEDORD OF PLANTIEF Larim—N, Corre = Caan PR eS DISPOSITION EOENED ‘A. Judgment Entered B. No Judgment Entered e g 1. Before jury trial or nonjury hearing (6 Transferred to District | ire 2. During jury trial or nonjury hearing Court under G.L. ¢.231, 1.3. after jury verdict SiGe TISPOSTION ENTERED 0 4. After court finding Disposition Date__________| sv: 15. After post trial motion one (OCI emt 005.01DATE FILED tom mat ou) ‘DOCKET NONGER treme moos ow | Trlal Court oF Messachusetts 37 ‘STATEMENT OF DAMAGES St, 1996, ¢, 358, 9. 8 PLAINTIFFIS) Catherine Clark DEFENDANTIS) Boris I. Orkin, M.D. COUNTY: ‘GMiddesex BS Norfolk SUPERIOR COURT: 9 Cambridge Lowell 8 Dedham DISTRICT COURT: Based on the facts set forth above (and attached) Plaintiff avers as follows: INSTRUCTIONS: TO GE FILED WITH THE COMPLAINT IN ALL cIViL ACTIONS. SEEKING MONETARY DAMAGES COMMENCED IN DISTRICT ‘AND SUPERIOR COURTS IN MIDDLESEX AND NORFOLK COUNTIES. Division O damages are not likely to exceed $25,000 CO Damages are not ely to be less than or equal to $25,000 "TORT CLAIMS, A. Documented medical expenses to date: 8. Total hospital expenst 3150,000* ». Total doctor expenses: 3 -50,000* ¢. Total chiropractic expenses: NONE 4. Total physical therapy expenses: 3150, 000* ¢@. Total other expenses (Describel: +10,000* *Exact amount unknown, but vastly in excess of * amount. 5 360,000 SUBTOTAL: 8. Documented lost wages and compensation to date: .LOE arning capacity... ¢ 30,000 C. Documented property damages to date: 7; D. ocumentad tans a damaoe peserbey, “Exact _amount_of medical 5,000 pred seers “ae eae se, Bea and other related 1tens : or a person who haS been paralyzed,precise amount unknown, €. Reasonably anticipated future medical and hospital expenses: auites nee + 300,000 F. Reasonably anticipated lost wages: HOSt, earning capacity. 25,000/year, a eum ood) 24 years (41 y/o to 65 y/o) G. Extent of injury (chect ail that apply): rota disability partial disabiry 50% permanent injury 0 temporary injury __ months Wescrite); AS_a_xesult of the alleged negligence of the defendant, the plaintiff suffered a stroke which rendered her totally paralyzed on her right side and also caused Ter to sutter brain aear Toss_oF memory and aphasia- Furthermore, the plaintiff r equired months of physicalrora,. herapy to reaai of almost all of her bodil 1,315, 000.00 CONTRACT CLAMS functions. ’ ‘ : ToraL: | "ATTORNEY FOR PLAINTIFF [OR PRO SE PLAINTIFAT DEFENDANT'S NAME AND ADDRESS? Nibbana Aorectnale OE __.27-93 eet a Sonate cE eGMiiam H. Rowerdink, 11 1842 Beacon Street PingyAPRESry Road, Marina Bay Brookline, MA 02146 Address Quincy, MA 02171COMMONWEALTH OF MASSACHUSETTS Norfolk, SS. SUPERIOR COURT DEPARTMENT CATHERINE CLARK, Plaintiff, vs. BORIS I. ORKIN, M.D., Defendant . OF THE TRIAL COURT CIVIL ACTION DOCKET NO. 97-367 AMENDED ANSWERS TO DEFENDANT'S INTERROGATORIES TO THE PLAINTIFF, CATHERINE CLARK hs Please state your full name, date of birth, residence, business address and occupation, and, if married, the name of your spouse. ANSWER Catherine Ann Clark; 6/8/55; 43 Richdale Avenue, Somerville, Massachusetts; Presently unemployed, however, I was previously trained and received my license in the Commonwealth of Massachusetts as a hairdresser/beautician. (Also, please refer to the plaintiff's response to interrogatory number 14.) However, due to the nature and extent of my injury since the date that constitutes the basis of my complaint, I have been unable to become engaged in any gainful employment or occupation whatsoever. It is also anticipated that my condition, to wit, hemiparesis (almost total paralysis of my right side) is permanent in nature and that, concurrent therewith, it is projected that I have no potential for gainful employment for the remainder of my life. 2. Please describe fully and in complete detail all illnesses, injuries, diseases, or operations which you had: (a) (b) within fifteen years prior to the date of the occurrence or events alleged in your Complaint; and at any time since the date of the occurrence or events set forth in the Complaint, including the dates upon which each was experienced; and the treatment received for any such illnesses, injuries, or diseases and the dates thereof; CWPWINGORPDOCSICLIENTSICLARR 32 pd