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NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
ANSWER OF...
January 26,2024 08:34
By: MALORIE A. ALVERSON 0089279
Confirmation Nbr. 3071272
RAYMOND KAY. ADM. OF ESTATE OF MARY KAY. CV 23 990355
DECD.
Judge: NANCYA. FUERST
EMERGENCY PROFESSIONALS OF OHIO, INC., ET
AL.
Pages Filed: 9
Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH
IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
RAYMOND KAY, ADMINISTRATOR OF CASE NO. CV 23 990355
THE ESTATE OF MARY KAY, DECEASED
JUDGE NANCY A. FUERST
Plaintiff
v.
ANSWER OF DEFENDANT TEAM
EMERGENCY PROFESSIONALS OF OHIO, HEALTH HOLDINGS, INC.
ET AL.
(JURY DEMAND ENDORSED
Defendants HEREON)
****
NOW COMES Defendant Team Health Holdings, Inc. ("Defendant"), by and
through counsel, and for its Answer to Plaintiff Raymond Kay, Administrator of the Estate of Mary
Kay, Deceased's Complaint ("Plaintiff's Complaint") states as follows:
RESPONSE TO "PARTIES, JURISDICTION, AND VENUE"
1. Defendant is without sufficient knowledge or information to form a belief
as to the truth of the allegations contained in Paragraph 1 of Plaintiff's Complaint and, therefore,
denies the same.
2. Defendant is without sufficient knowledge or information to form a belief
as to the truth of the allegations contained in Paragraph 2 of Plaintiff's Complaint and, therefore,
denies the same.
3. Responding to Paragraph 3 of Plaintiff's Complaint, Defendant admits only
that Team Health, LLC is a defendant in Kay v. Southwest General Health Center, et al; Case No.
CV-23-976698, pending in the Cuyahoga County Court of Common Pleas.
4. Defendant denies the allegations contained in Paragraph 4 of Plaintiff's
Complaint.
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5. Defendant is without sufficient knowledge or information to form a belief
as to the truth of the allegations contained in Paragraph 5 of Plaintiff's Complaint and, therefore,
denies the same.
6. Defendant denies the allegations contained in Paragraph 6 of Plaintiff's
Complaint.
7. Defendant denies the allegations contained in Paragraph 7 of Plaintiff's
Complaint.
8. Responding to Paragraph 8 of Plaintiff's Complaint, Defendant admits only
that Emergency Professionals of Ohio, Inc. is an Ohio corporation.
9. Defendant denies the allegations contained in Paragraph 9 of Plaintiff's
Complaint.
10. Responding to Paragraph 10 of Plaintiff's Complaint, Defendant admits
only that Emergency Professional Services, Inc. is an Ohio corporation.
11. Defendant denies the allegations contained in Paragraph 11 of Plaintiff's
Complaint.
12. Defendant admits the allegations contained in Paragraph 12 of Plaintiff's
Complaint.
13. Defendant denies the allegations contained in Paragraph 13 of Plaintiff's
Complaint.
14. Defendant admits the allegations contained in Paragraph 14 of Plaintiff's
Complaint.
15. Defendant denies the allegations contained in Paragraph 15 of Plaintiff's
Complaint.
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16. Defendant denies the allegations contained in Paragraph 16 of Plaintiff's
Complaint.
17. Defendant denies the allegations contained in Paragraph 17 of Plaintiff's
Complaint.
18. Defendant denies the allegations contained in Paragraph 18 of Plaintiff's
Complaint.
19. Defendant denies the allegations contained in Paragraph 19 of Plaintiff's
Complaint.
20. Defendant denies the allegations contained in Paragraph 20 of Plaintiff's
Complaint.
21. Defendant denies the allegations contained in Paragraph 21 of Plaintiff's
Complaint.
22. Defendant denies the allegations contained in Paragraph 22 of Plaintiff's
Complaint.
23. Responding to Paragraph 23 of Plaintiff's Complaint, Defendant admits
only that a document titled Affidavit of Merit is attached to Plaintiff's Complaint.
RESPONSE TO "FIRST CAUSE OF ACTION – WRONGFUL DEATH"
24. Defendant restates and realleges each of the admissions and denials
contained in paragraphs 1 through 23 as if fully rewritten herein.
25. Defendant is without sufficient knowledge or information to form a belief
as to the truth of the allegations contained in Paragraph 25 of Plaintiff's Complaint and, therefore,
denies the same.
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26. Defendant is without sufficient knowledge or information to form a belief
as to the truth of the allegations contained in Paragraph 26 of Plaintiff's Complaint and, therefore,
denies the same.
27. Defendant is without sufficient knowledge or information to form a belief
as to the truth of the allegations contained in Paragraph 27 of Plaintiff's Complaint and, therefore,
denies the same.
28. Defendant is without sufficient knowledge or information to form a belief
as to the truth of the allegations contained in Paragraph 28 of Plaintiff's Complaint and, therefore,
denies the same.
29. Defendant is without sufficient knowledge or information to form a belief
as to the truth of the allegations contained in Paragraph 29 of Plaintiff's Complaint and, therefore,
denies the same.
30. Defendant is without sufficient knowledge or information to form a belief
as to the truth of the allegations contained in Paragraph 30 of Plaintiff's Complaint and, therefore,
denies the same.
31. Defendant is without sufficient knowledge or information to form a belief
as to the truth of the allegations contained in Paragraph 31 of Plaintiff's Complaint and, therefore,
denies the same.
32. Defendant denies the allegations contained in Paragraph 32 of Plaintiff's
Complaint.
33. Defendant denies the allegations contained in Paragraph 33 of Plaintiff's
Complaint.
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34. Defendant denies the allegations contained in Paragraph 34 of Plaintiff's
Complaint.
35. Defendant denies the allegations contained in Paragraph 35 of Plaintiff's
Complaint.
36. Defendant denies any and all remaining allegations not specifically
admitted herein.
AFFIRMATIVE DEFENSES
Plaintiff's Complaint fails for one or more of the following affirmative defenses:
37. Plaintiff's claims are in whole or in part barred by the applicable statute of
limitations.
38. Plaintiff's Complaint fails to state a claim against Defendant on which relief
may be granted.
39. Plaintiff's Complaint is barred by failure of service of process.
40. Plaintiff's Complaint is barred for insufficiency of service.
41. Plaintiff's Complaint is brought in an improper venue.
42. The Court lacks personal jurisdiction over Defendant.
43. The Court lacks subject matter jurisdiction over Defendant.
44. Plaintiff failed to join a necessary party under Rule 19 or 19.1.
45. Plaintiff's injuries and damages, if any, were caused by persons, firms,
corporations or entities over whom Defendant had no control and no duty to control.
46. No basis in law exists to assert alter-ego liability and/or piercing the
corporate veil.
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47. Plaintiff expressly and/or impliedly assumed the risk of injuries and
damages, if any.
48. Plaintiff's claims against Defendant are barred by the doctrines of
superseding and/or intervening causes.
49. Plaintiff's claims are barred and/or limited by Ohio Tort Reform
Legislation.
50. Plaintiff's Complaint should be dismissed for failure to comply with the
Affidavit of Merit requirements of Ohio Rule of Civil Procedure 10(D).
51. Plaintiff's damages, if any, were caused by or contributed to, in full or in
part, by actions of persons or parties other than Defendant.
52. Plaintiff's damages, if any, were a result of their own contributing
negligence.
53. Plaintiff's claims are barred by the doctrine of unclean hands.
54. One or more of Plaintiff's claims for damages are subject to limitation and
this Court is without jurisdiction to enter judgment for Plaintiff beyond the limits set forth in Ohio
Revised Code 2323.43.
55. Plaintiff released, settled, entered into an accord and satisfaction, or
otherwise compromised Plaintiff's claims herein and accordingly, said claims are barred by
operation of law; or alternatively, Plaintiff has accepted compensation or partial settlement of those
claims, for which Defendant is entitled to set off.
56. Plaintiff lacks a reasonable good faith basis to bring this medical claim
against Defendant, thereby entitling Defendant to an award of attorneys' fees and costs against
Plaintiffs as provided in Ohio Revised Code 2323.42.
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57. No physician/patient relationship existed or exists between Defendant and
Plaintiff.
Defendant Team Health Holdings, Inc. reserves the right to assert additional
defenses which the evidence and discovery in this matter reveal as applicable.
WHEREFORE, having fully answered, Defendant Team Health Holdings, Inc.
prays that the instant Complaint be dismissed against it, with prejudice, at Plaintiff's costs, and that
an order be entered awarding Defendant its costs expended herein, and all other relief this Court
deems equitable, just and proper.
Respectfully submitted,
/s/ Malorie A. Alverson
Matthew W. Nakon (No. 0040497)
E-mail MNakon@WickensLaw.com
Malorie A. Alverson (No. 0089279)
E-mail MAlverson@WickensLaw.com
Michael R. Nakon (No. 0097003)
E-mail MRNakon@WickensLaw.com
Docket E-mail Docket@WickensLaw.com
WICKENS HERZER PANZA
35765 Chester Road
Avon, OH 44011-1262
(440) 695-8000 (Main)
(440) 695-8098 (Fax)
ATTORNEYS FOR DEFENDANTS, TEAM
FINANCE, LLC AND TEAM HEALTH
HOLDINGS, INC.
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JURY DEMAND
Pursuant to Rule 38(B) of the Ohio Rules of Civil Procedure, Defendant Team
Health Holdings, Inc. hereby demands a trial by jury on all issues presented herein.
/s/ Malorie A. Alverson
Matthew W. Nakon
Malorie A. Alverson
Michael R. Nakon
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PROOF OF SERVICE
This is to certify that a copy of the foregoing Answer of Defendant Team Health
Holdings, Inc. (Jury Demand Endorsed Hereon) has been sent via the Court's electronic filing
system, on this 26th day of January, 2024, to:
Stuart E. Scott, Esq. Susan Blasik-Miller, Esq.
Dustin B. Herman, Esq. Michael D. Rice, Esq.
Spangenberg Shibley & Liber LLP Reminger Co., L.P.A.
1001 Lakeside Avenue East, Suite 1700 Fifth Third Center
Cleveland, OH 44114-1149 1 S. Main Street, Suite 1800
E-mail: sscott@spanglaw.com Dayton, OH 44308-1857
dherman@spanglaw.com E-mail: sbmiller@reminger.com
mrice@reminger.com
Michael F. Lyon, Esq.
Paul J. Vollman, Esq.
Cullen P. Rooney, Esq.
Zachary R. Rigg, Esq.
Lindhorst & Dreidame Co., L.P.A.
312 Walnut St., Suite 3100
Cincinnati, OH 45202-4048
E-mail: mlyon@lindhorstlaw.com
pvollman@lindhorstlaw.com
crooney@lindhorstlaw.com
zrigg@lindhorstlaw.com
/s/ Malorie A. Alverson
Matthew W. Nakon
Malorie A. Alverson
Michael R. Nakon
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NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas ANSWER OF... January 26,2024 08:34 By: MALORIE A. ALVERSON 0089279 Confirmation Nbr. 3071272 RAYMOND KAY. ADM. OF ESTATE OF MARY KAY. CV 23 990355 DECD. Judge: NANCYA. FUERST EMERGENCY PROFESSIONALS OF OHIO, INC., ET AL. Pages Filed: 9 Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO RAYMOND KAY, ADMINISTRATOR OF CASE NO. CV 23 990355 THE ESTATE OF MARY KAY, DECEASED JUDGE NANCY A. FUERST Plaintiff v. ANSWER OF DEFENDANT TEAM EMERGENCY PROFESSIONALS OF OHIO, HEALTH HOLDINGS, INC. ET AL. (JURY DEMAND ENDORSED Defendants HEREON) **** NOW COMES Defendant Team Health Holdings, Inc. ("Defendant"), by and through counsel, and for its Answer to Plaintiff Raymond Kay, Administrator of the Estate of Mary Kay, Deceased's Complaint ("Plaintiff's Complaint") states as follows: RESPONSE TO "PARTIES, JURISDICTION, AND VENUE" 1. Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 1 of Plaintiff's Complaint and, therefore, denies the same. 2. Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 2 of Plaintiff's Complaint and, therefore, denies the same. 3. Responding to Paragraph 3 of Plaintiff's Complaint, Defendant admits only that Team Health, LLC is a defendant in Kay v. Southwest General Health Center, et al; Case No. CV-23-976698, pending in the Cuyahoga County Court of Common Pleas. 4. Defendant denies the allegations contained in Paragraph 4 of Plaintiff's Complaint. Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH 11695-378\2840781.docx 1 5. Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 5 of Plaintiff's Complaint and, therefore, denies the same. 6. Defendant denies the allegations contained in Paragraph 6 of Plaintiff's Complaint. 7. Defendant denies the allegations contained in Paragraph 7 of Plaintiff's Complaint. 8. Responding to Paragraph 8 of Plaintiff's Complaint, Defendant admits only that Emergency Professionals of Ohio, Inc. is an Ohio corporation. 9. Defendant denies the allegations contained in Paragraph 9 of Plaintiff's Complaint. 10. Responding to Paragraph 10 of Plaintiff's Complaint, Defendant admits only that Emergency Professional Services, Inc. is an Ohio corporation. 11. Defendant denies the allegations contained in Paragraph 11 of Plaintiff's Complaint. 12. Defendant admits the allegations contained in Paragraph 12 of Plaintiff's Complaint. 13. Defendant denies the allegations contained in Paragraph 13 of Plaintiff's Complaint. 14. Defendant admits the allegations contained in Paragraph 14 of Plaintiff's Complaint. 15. Defendant denies the allegations contained in Paragraph 15 of Plaintiff's Complaint. Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH 11695-378\2840781.docx 2 16. Defendant denies the allegations contained in Paragraph 16 of Plaintiff's Complaint. 17. Defendant denies the allegations contained in Paragraph 17 of Plaintiff's Complaint. 18. Defendant denies the allegations contained in Paragraph 18 of Plaintiff's Complaint. 19. Defendant denies the allegations contained in Paragraph 19 of Plaintiff's Complaint. 20. Defendant denies the allegations contained in Paragraph 20 of Plaintiff's Complaint. 21. Defendant denies the allegations contained in Paragraph 21 of Plaintiff's Complaint. 22. Defendant denies the allegations contained in Paragraph 22 of Plaintiff's Complaint. 23. Responding to Paragraph 23 of Plaintiff's Complaint, Defendant admits only that a document titled Affidavit of Merit is attached to Plaintiff's Complaint. RESPONSE TO "FIRST CAUSE OF ACTION – WRONGFUL DEATH" 24. Defendant restates and realleges each of the admissions and denials contained in paragraphs 1 through 23 as if fully rewritten herein. 25. Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 25 of Plaintiff's Complaint and, therefore, denies the same. Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH 11695-378\2840781.docx 3 26. Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 26 of Plaintiff's Complaint and, therefore, denies the same. 27. Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 27 of Plaintiff's Complaint and, therefore, denies the same. 28. Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 28 of Plaintiff's Complaint and, therefore, denies the same. 29. Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 29 of Plaintiff's Complaint and, therefore, denies the same. 30. Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 30 of Plaintiff's Complaint and, therefore, denies the same. 31. Defendant is without sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 31 of Plaintiff's Complaint and, therefore, denies the same. 32. Defendant denies the allegations contained in Paragraph 32 of Plaintiff's Complaint. 33. Defendant denies the allegations contained in Paragraph 33 of Plaintiff's Complaint. Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH 11695-378\2840781.docx 4 34. Defendant denies the allegations contained in Paragraph 34 of Plaintiff's Complaint. 35. Defendant denies the allegations contained in Paragraph 35 of Plaintiff's Complaint. 36. Defendant denies any and all remaining allegations not specifically admitted herein. AFFIRMATIVE DEFENSES Plaintiff's Complaint fails for one or more of the following affirmative defenses: 37. Plaintiff's claims are in whole or in part barred by the applicable statute of limitations. 38. Plaintiff's Complaint fails to state a claim against Defendant on which relief may be granted. 39. Plaintiff's Complaint is barred by failure of service of process. 40. Plaintiff's Complaint is barred for insufficiency of service. 41. Plaintiff's Complaint is brought in an improper venue. 42. The Court lacks personal jurisdiction over Defendant. 43. The Court lacks subject matter jurisdiction over Defendant. 44. Plaintiff failed to join a necessary party under Rule 19 or 19.1. 45. Plaintiff's injuries and damages, if any, were caused by persons, firms, corporations or entities over whom Defendant had no control and no duty to control. 46. No basis in law exists to assert alter-ego liability and/or piercing the corporate veil. Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH 11695-378\2840781.docx 5 47. Plaintiff expressly and/or impliedly assumed the risk of injuries and damages, if any. 48. Plaintiff's claims against Defendant are barred by the doctrines of superseding and/or intervening causes. 49. Plaintiff's claims are barred and/or limited by Ohio Tort Reform Legislation. 50. Plaintiff's Complaint should be dismissed for failure to comply with the Affidavit of Merit requirements of Ohio Rule of Civil Procedure 10(D). 51. Plaintiff's damages, if any, were caused by or contributed to, in full or in part, by actions of persons or parties other than Defendant. 52. Plaintiff's damages, if any, were a result of their own contributing negligence. 53. Plaintiff's claims are barred by the doctrine of unclean hands. 54. One or more of Plaintiff's claims for damages are subject to limitation and this Court is without jurisdiction to enter judgment for Plaintiff beyond the limits set forth in Ohio Revised Code 2323.43. 55. Plaintiff released, settled, entered into an accord and satisfaction, or otherwise compromised Plaintiff's claims herein and accordingly, said claims are barred by operation of law; or alternatively, Plaintiff has accepted compensation or partial settlement of those claims, for which Defendant is entitled to set off. 56. Plaintiff lacks a reasonable good faith basis to bring this medical claim against Defendant, thereby entitling Defendant to an award of attorneys' fees and costs against Plaintiffs as provided in Ohio Revised Code 2323.42. Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH 11695-378\2840781.docx 6 57. No physician/patient relationship existed or exists between Defendant and Plaintiff. Defendant Team Health Holdings, Inc. reserves the right to assert additional defenses which the evidence and discovery in this matter reveal as applicable. WHEREFORE, having fully answered, Defendant Team Health Holdings, Inc. prays that the instant Complaint be dismissed against it, with prejudice, at Plaintiff's costs, and that an order be entered awarding Defendant its costs expended herein, and all other relief this Court deems equitable, just and proper. Respectfully submitted, /s/ Malorie A. Alverson Matthew W. Nakon (No. 0040497) E-mail MNakon@WickensLaw.com Malorie A. Alverson (No. 0089279) E-mail MAlverson@WickensLaw.com Michael R. Nakon (No. 0097003) E-mail MRNakon@WickensLaw.com Docket E-mail Docket@WickensLaw.com WICKENS HERZER PANZA 35765 Chester Road Avon, OH 44011-1262 (440) 695-8000 (Main) (440) 695-8098 (Fax) ATTORNEYS FOR DEFENDANTS, TEAM FINANCE, LLC AND TEAM HEALTH HOLDINGS, INC. Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH 11695-378\2840781.docx 7 JURY DEMAND Pursuant to Rule 38(B) of the Ohio Rules of Civil Procedure, Defendant Team Health Holdings, Inc. hereby demands a trial by jury on all issues presented herein. /s/ Malorie A. Alverson Matthew W. Nakon Malorie A. Alverson Michael R. Nakon Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH 11695-378\2840781.docx 8 PROOF OF SERVICE This is to certify that a copy of the foregoing Answer of Defendant Team Health Holdings, Inc. (Jury Demand Endorsed Hereon) has been sent via the Court's electronic filing system, on this 26th day of January, 2024, to: Stuart E. Scott, Esq. Susan Blasik-Miller, Esq. Dustin B. Herman, Esq. Michael D. Rice, Esq. Spangenberg Shibley & Liber LLP Reminger Co., L.P.A. 1001 Lakeside Avenue East, Suite 1700 Fifth Third Center Cleveland, OH 44114-1149 1 S. Main Street, Suite 1800 E-mail: sscott@spanglaw.com Dayton, OH 44308-1857 dherman@spanglaw.com E-mail: sbmiller@reminger.com mrice@reminger.com Michael F. Lyon, Esq. Paul J. Vollman, Esq. Cullen P. Rooney, Esq. Zachary R. Rigg, Esq. Lindhorst & Dreidame Co., L.P.A. 312 Walnut St., Suite 3100 Cincinnati, OH 45202-4048 E-mail: mlyon@lindhorstlaw.com pvollman@lindhorstlaw.com crooney@lindhorstlaw.com zrigg@lindhorstlaw.com /s/ Malorie A. Alverson Matthew W. Nakon Malorie A. Alverson Michael R. Nakon Electronically Filed 01/26/2024 08:34 / ANSWERS / CV 23 990355 / Confirmation Nbr. 3071272 / BATCH 11695-378\2840781.docx 9