UNITED STATES DISTRICT COURT

for the
District of Vermont
Civil Division

SPENCER FLANNIGAN : Civil Action No.

Plaintiff, :

:
v.
:
LASSITER CENTRAL CLINIC OF
VERMONT, a corporation : COMPLAINT FOR DAMAGES
DR. BETHANY RANDALL, an
individual :

Defendants. :
____________________________

Plaintiff allege against each and every defendant:

Count 1

1. Jurisdiction is founded on diversity of citizenship and his amount of damages.

2. Plaintiff is domiciled in and a citizen of the state of Rhode Island. Defendant, Dr.

Bethany Randall is domiciled in and citizens of the state of Vermont. Defendant,

Lassiter Central Clinic of Vermont is a corporation organized and existing under

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

the scope of said agency.

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

Vermont, negligently injected Plaintiff with contrast medium causing

anaphylactic shock.

6. Plaintiff had a cardiac arrest and almost expired due to the actions of Defendant.

7. Defendant negligently did not have intravenous epinephrine in the operating

room at the time of the procedure.

8. As a result, the plaintiff suffered physical and mental injuries, and incurred

medical bills in excess of $5,000.

Wherefore plaintiff for judgment against defendants for medical bills, pain and

suffering, and any other damages that the Court finds proper.

Dated: November 6, 2017 __________________________

Roger Hutchinson, Esq.
Bradford, Miller, and Hutchinson
124 Sue Rd.
Berlin, Vermont 05602
rhutchinson@attorney.com
(802) 772-2340