Describe each injury for which a claim is being made on behalf of the Plaintiff, specifying the part of the body that was injured, the nature of the injury and any emotional or psychological impairment or injury which it is claimed she suffered, as well as a description and itemization of any other losses for any other individuals which are claimed as a result of the Incidents identified in the Complaint.
Plaintiff was admitted to the Defendant’s facility on May 6, 2006. At the time of admission, she had no pressure ulcers. The lack of any pressure ulcers was documented on her hospital transfer sheet dated 5/6/06, as well as in Defendant’s MDS, Pressure Ulcer RAP, and Nutritional Status RAP, all dated 5/17/06. Plaintiff’s diagnoses on admission to Defendant’s facility included a prior heart attack; congestive heart failure; hypertension; and dementia. She did not have diabetes, nor peripheral vascular disease, so she was not predisposed to developing pressure ulcers. Further, Plaintiff did not develop any bedsores during the time her family cared for her at home prior to her admission to the Defendant’s facility.