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
, PLNOW 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
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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
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