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STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF INGHAM JAMES ST. CLAIR, Plaintiff, Case No. 19-153-NI Hon, Clinton Canady III 3 JOHN LAURAIN, individually, EDWARD W. SPARROW HOSPITAL ASSOCIATION, a domestic nonprofit Corporation d/b/a SMG LANSING INTERNAL MEDICINE, and EDWARD W. SPARROW HOSPITAL ASSOCIATION, a domestic nonprofit corporation, Defendants. MANVIR S. GREWAL, SR. (P48082) RANDALL A. JUIP (P58538) NOLAN L. ERICKSON (P72661) MITCHELL C. JACKSON (P76385) GREWAL LAW, PLLC FOLEY, BARON, METZGER & JUIP, PLLC Attorney for Plaintiff Attorneys for Defendant John Laurain 2290 Science Parkway 38777 Six Mile Road, Suite 300 Okemos, Ml 48864 Livonia, MI.48152 (517) 393-3000 (734) 742-1800 / (734) 521-2379 ~ Fax rajuip@fomjlaw.com mjackson@fbmjaw.com MARCY MATSON (P49758) HALL MATSON, PLC Attorney for Def. Sparrow Hospital Assoc. 1500 Watertower Place, Suite 200 East Lansing, Ml 48823-8052 (617) 853-2929 mmatson@hallmatson.com ANSWER TO COMPLAINT, FURTHER ANSWERS, AFF ES ANI RELIANCE UPON JURY DEMAND ON BEHALF OF DR. JOHN LAURAIN ~ SOLEVIGRR: Allama fc ARCY MATSU L. MATSO , PL NOW COMES the Defendant, JOHN LAURAIN'M.D:, by and through his attorneys, FOLEY, BARON, METZGER AND JUIP, PLLC, and for his Answer to Comptaint, Further Answers, Atfimative Defendants and Reliance Upon Jury Demand, states as follows: GENERAL ALLEGATIONS AND VENUE 1, Inanswer to Paragraph #1, Defendant denies this allegation ‘in the manner and form alleged. * 2. In answer to Paragraph #2, Defendant states that he was an employee of Sparrow Medical Group and a resident of Ingham County. et ‘admits nor denies the 3. In answer to Paragraph #3, Defén ant allegations contained therein for lack of roveioe oF s\fcient information upon which to form a belief thereto and leaves Plaintiff to his strict proofs thereof. 4, In answer to Paragraph #4, Defendant acknowledges that his care and treatment of James St. Clair ocourred in Lansing, Michigan, Ingham County. 5. In answer to Paragraph #5, Defeadant neither admits nor denies the allegation contained therein becayse they, call for Jegal conclusions, and Defendant lacks knowledge or sufficient information upon which to form a belief thereto and leaves Plaintiff to his strict proofs thereof. 6. In answer to Paragraph #6,,Defendaft;nelther admits nor denies the allegation contained therein begaue, they galferongalifanusions. and Defendant lacks knowledge or sufficient information, uf whieh ym a belief thereto and leaves matan gp Mah We Plaintiff to his strict proofs thereof. 7. In answer to Paragraph #7, Defendant admits that there is an amount in controversy but denies any and all allegations ofinegligence and denies that the amount in controversy exceeds $25,000:c 9-3, thay gall Ju tage! SPECIFIC FACTUALALLEGATIONS 8. In answer to Paragraph #8, Defendant repeats and realleges all answers set forth in paragraphs 1 through 7 of this Answer as if set forth in full herein, and the same are adopted by reference. 9. In answer to Paragraph #9, Defendant neither admits nor denies the allegations regarding agency because they call for legal conclusions and thus no response is required. 10. In answer to Paragraph #10, Defendant denies these allegations in the manner and form alleged. siangrohewadiaee 11. In answer to. Paragraph #14, Defendant acknowledges that he provided care and treatment to James..St.,.Clalj, from, February, 201%.to November 2018. Defendant denies the remaining allegations in the manner and form alleged. 12. In answer to Paragraph #12, Defendant acknowledges that there was a disciplinary action through the Michigan Department of Licensing and Regulatory Affairs that was closed in July 2011 f 13. In answer to Paragraph #13, Defendant neither agrees nor disagreés with the summary of medical information as presented, and leaves Plaintiff to his strict proofs thereof, except where there are inconsistencieg,with the medical records, in which case, this Defendant denies the same for the reason that they are untrue. 14, _ In answer to Paragraph #14, Defendant neither agrees nor disagrees with nec a the summary of medical information as I ns Plaintiff to his strict proofs hy eee