Complaint,Petition: ALEXANDER PENN VS LOUISE COOLEY DAVIS MD ET AL

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                                ALEXANDER PENN
     843 Hauser Blvd.
     Los Angeles, CA 90036
                                                                                  meg tical
     Phone Number (323) 387 0925                                                        MAY 18 2018
                                                                                                             lerk
                                                                                                         Deputy
     ALEXANDER PENN, IN PRO PER




                               SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                   IN AND FOR THE COUNTY OF LOS ANGELES

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                                                                                           BC7o S728
i    ALEXANDER PENN, In pro per                               ) Case No.:

12                                     Plaintiff,             ) COMPLAINT FOR:
                                                              )    1) DAMAGES FOR PROFESSIONAL
                                                                      NEGLIGENCE (Medical Malpractice),
13              vs.                                           )       and
                                                                  2)  DIRECT CORPORATE
14   LOUISE COOLEY DAVIS, MD, and                             )       NEGLIGENCE.
15   SPECIALTY SURGICAL CENTER OF                             )
     BEVERLY HILLS, L.P.,                                          JURY TRIAL DEMANDED
16                                                            )
                                                              )
17                                    Defendants.

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                Plaintiff ALEXANDER PENN alleges and complains against Defendants LOUISE COOLEY
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     DAVIS,           M.D   (hereinafter “DAVIS”)   and SPECIALTY      SURGICAL     CENTER     OF BEVERLY
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     HILLS, L.P (hereinafter “SSCBH”) as follows:
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                                                GENERAL ALLEGATIONS
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                1           Plaintiff, Alexander Penn underwent surgical procedures, at least one of which was
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     negligently performed by Davis at SSCBH, which have resulted in permanent damage and injury to
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     his eye.
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                2.          Venue is proper because the place of injury and loss occurred in the County of Los
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     Angeles where both Defendants conduct business and this Court has jurisdiction over the Complaint
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     pursuant to California Code of Civil Procedure § 410.10.
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