ANGELA CAMPBELL VS ROYAL VISTA CARE CENTER LLC, A CALIFORNIA LIMITED LIABILITY COMPANY

virtue of the laws of the State of California with its principal place of business in the County of Los Angeles, California.

3. Defendants DOES 1 through 25, inclusive, and each of them, are sued herein under such fictitious names for the reason that the true names and capacities of said Defendants are unknown to Plaintiff at this time. When the true names and capacities of said Defendants are ascertained, Plaintiff will ask leave of court to amend this Complaint to insert the true names and capacities of said fictitiously-named Defendants, together with any additional allegations that may be necessary in regard thereto. Plaintiff is informed and believes and thereon alleges that each of said fictitiously-named Defendants is in some manner legally responsible for the acts and occurrences hereinafter alleged, which said acts and occurrences caused Plaintiff's injuries and damages.

4. At all times herein mentioned, each Defendants, and each of them, were the agents and employees of the remaining Defendants, and each of them, and in doing the things hereinafter mentioned, each Defendant was acting within the course and scope of his/her employment and authority as such agent and employee with the consent and ratification of his co-defendants.

5. At all times herein mentioned, Defendants ROYAL VISTA CARE CENTER LLC, a California Limited Liability Company; and Does 1 to 25, inclusive, and each them, were health care providers, medical practitioners, medical doctors, medical specialists, physicians, surgeons, physician's assistants, nurses, technicians, aides, radiologists, anesthetists, laboratory assistants, x-ray assistants and/or medical facilities. Defendants, each, held themselves out to Plaintiff as possessing that degree of skill, ability and learning common to health care providers in the community, specializing and possessing expertise in the examination, diagnosis, advice, care and treatment of the medical condition or conditions afflicting Plaintiff.

6. Each and all of the acts, events and injuries alleged hereinafter, took place and were sustained on or about February 2, .

MEDICAL NEGLIGENCE

7. The preceding paragraphs of this Complaint are incorporated by reference.

8. On or about February 2, 2023 , and continuing thereafter, Plaintiff consulted, retained and/or employed Defendants, and each of them, as a health care providers, medical practitioners, medical doctors, medical specialists, physicians, surgeons, physician's assistants, nurses, technicians, aides, radiologists, anesthetists, laboratory assistants, x-ray assistants and/or medical facilities, to examine, diagnose, advise, care, treat and administer to Plaintiff's medical needs.

9. On or about February 2, 2023 , Plaintiff was a patient at Defendants' facility and was being transferred from the shower to a shower chair and/or shower bench by Defendants' employee. As Defendants' employee transferred Plaintiff, he improperly performed the transfer, and the shower chair and/or shower bench broke and/or collapsed causing Plaintiff to fall to the ground. At all times and places herein mentioned, a confidential relationship of physician and patient existed between Plaintiff and Defendants.

10. Plaintiff consulted with Defendants, and each of them, specifically for the purpose of obtaining Defendants' professional advice regarding Plaintiff's symptoms and medical care. Defendants recommended and carried out treatment. Plaintiff relied upon the advice and representations of Defendants, and each of them, all to Plaintiff's ultimate detriment.

11. At all times herein mentioned, Defendants, each, did negligently and carelessly examine, diagnose, advise, care, treat and administer to Plaintiff. In their examination, diagnosis, advice, care, treatment and administration of medical care to Plaintiff, defendants, each, failed to exercise that degree of skill and care commonly possessed and exercised by