Atty. No, 34560 ‘HE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION JULIEN FLOREZ, a minor, by his parents and next friends, AIMEE FLOREZ and DAVID FLOREZ; and AIMEE FLOREZ. and DAVID FLOREZ, Individually, Plaintiffs, vs, No, NORTHSHORE UNIVERSITY HEALTH SYSTEM /bla EVANSTON HOSPITAL; ARMIN MICHAEL DRACHLER, M.D. NORTHSHORE PHYSICIANS GROUP, LLC /b/a/ NORTHSHORE MEDICAL GROUP ; ELIZA MEADE, M.D.; JENNIFER LESKO, M.D.; and LISA WEGRZYN, R.N., Defendants, COMPLAINT AT LAW NOW COME the Plaintiffs, JULIEN FLOREZ, a minor, by his parents and next friends, AIMEE FLOREZ and DAVID FLOREZ; and AIMEE FLOREZ and DAVID FLORE; Individually, by and through their attorneys, SALVI, SCHOSTOK & PRITCHARD P.C. and complaining of Defendants, NORTHSHORE UNIVERSITY HEALTH SYSTEM d/bia EVANSTON HOSPITAL; ARMIN MICHAEL DRACHLER, M.D.; NORTHSHORE, PHYSICIANS GROUP, LLC d/b/a’ NORTHSHORE MEDICAL GROUP; ELIZA MEADE, M.D.; JENNIFER LESKO, M.D.; and LISA WEGRZYN, R.N,, state the following:(Medical Negligence — NORTHSHORE UNIVERSITY, NORTHSHORE PHYSICIANS, and DR. DRACHLER) 1. On March 22, 2009, and at all times material, NORTHSHORE UNIVERSITY HEALTH SYSTEM d/b/a EVANSTON HOSPITAL (hereinafter; “NORTHSHORE, UNIVERSITY”), was an Illinois corporation, licensed to do business in Illinois, operating a hospital as Evanston Hospital. 2. On or before March 22, 2009, and at all times material, NORTHSHORE UNIVERSITY provided certain facilities, including but not limited to labor and delivery rooms, for patients including AIMEE FLOREZ and JULIEN FLOREZ. 3. On or before March 22, 2009, and at all times material, NORTHSHORE UNIVERSITY held itself out to the general public, including AIMEE FLOREZ, to be a provider of medial, nursing, and hospital services. 4. On or before March 22, 2009, and at all times material, NORTHSHORE UNIVERSITY employed certain personnel, including but not limited to, physicians, residents, nurses, and other hospital personnel, who provided medical, hospital, and nursing services to AIMEE FLOREZ during her pregnancy, labor, and delivery of JULIEN FLOREZ. 5. On or before March 22, 2009, and at all times material, NORTHSHORE PHYSICIANS GROUP, LLC d/b/a’ NORTHSHORE MEDICAL GROUP (hereinafter; “NORTHSHORE PHYSICIANS”), was an Ilinois Corporation, doing business as a medical services provider in Cook County, Illinois. 6. On or before March 22, 2009, and at all times material, ARMIN MICHAEL DRACHLER, M.D. (“DR. DRACHLER”) was a physician licensed to practice medicine in the State of Llinois.7. Onoor before March 22, 2009, and at all times material, DR. DRACHLER held himself out to AIMEE FLOREZ and the general public to be a specialist in obstetrics, 8. Onor before March 22, 2009, and at all times material, DR. DRACHLER was the physician who was responsible for managing the labor of AIMEE FLOREZ and delivery of JULIEN FLOREZ, 9. Onor before March 22, 2009, and at all times material, as an obstetrical patient at NORTHSHORE UNIVERSITY, AIMEE FLOREZ delivered JULIEN FLOREZ afier a period of labor. 10. On or before March 22, 2009, and at all times material, DR. DRACHLER was employed by NORTHSHORE UNIVERSITY, and treating patients at Evanston Hospital. 11. Onor before March 22, 2009, and at all times material, DR. DRACHLER was an employee and agent of NORTHSHORE UNIVERSITY acting within the scope of his employment during the labor of AIMEE FLOREZ and delivery of JULIEN FLOREZ. 12. Onor before March 22, 2009, and at all times material, DR. DRACHLER was an apparent agent of NORTHSHORE UNIVERSITY, 13. Ono before March 22, 2009, and at all times material, DR. DRACHLER was employed by NORTHSHORE PHYSICIANS, and treating patients at Evanston Hospital. 14. Onor before March 22, 2009, and at all times material, DR. DRACHLER was an employee and agent of NORTHSHORE PHYSICIANS, acting within the scope of his employment during the labor of AIMEE FLOREZ and delivery of JULIEN FLOREZ. 15. While providing obstetrical services to AIMEE FLOREZ and JULIEN FLOREZ, Defendant, DR. DRACHLER, had a duty to possess and use the knowledge, skill, and care of a reasonably careful physician under the same or similar circumstances.