case: 4:15-cv-00076-dmb doc #: 96-1 filed: 03/02/18 1 of...

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI

GREENVILLE DIVISION

DANNY DYKES, INDIVIDUALLY, AND ON BEHALF OF THE ESTATE AND WRONGFUL DEATH BENEFICIARIES OF JAMES A. DYKES, DECEASED PLAINTIFF

vs. CIVIL ACTION NO.: 4:15-CV-00076-DMB-JMV

CLEVELAND NURSING & REHABILITATION CENTER and JOHN AND JANE DOES 1-X DEFENDANTS

PLAINTIFFS' EXPERT DESIGNATION

COMES NOW, the Plaintiff, Danny Dykes, Individually, and on behalf of the Estate and

Wrongful Death Beneficiaries of James A. Dykes ("Plaintiff'), by and through counsel, and

pursuant to FED. R. C1v. P. 26(a)(2) and L.U. CIV. R. 26(a)(2), and submits this, his Designation

of Expert Witnesses as follows:

This Plaintiff reserves the right to designate additional experts and additional opinions of

experts listed herein on the following grounds, to wit:

A. Plaintiff has not yet had the opportunity to depose Defendants nor Defendants' witnesses;

B. The parties anticipate deposing other key healthcare providers and their testimony regarding the specific details of what happened during the care and treatment of Mr. Dykes h:!s net been perpetuated in this litigation.

C. Upon transcription of these depositions, the Plaintiffs expert will need a reasonable period of time to analyze same and potentially clarify and/or designate additional opinions.

D. To avoid prolixity, the opinions of experts set forth below are tendered in similar areas of overlapping clinical and research expertise, categorized by expert; but will necessarily overlap for the sake of completion and jury edification and each such expert adopts by reference the opinions contained herein, to the extent that said opinion falls within his or her proffered area of expertise at trial.

Case: 4:15-cv-00076-DMB Doc #: 96-1 Filed: 03/02/18 1 of 15 PageID #: 661

kee

Typewritten Text

Exhibit A

E. The following opinions must be disclaimed by the following statement: There are a number of documents still outstanding. Once said documents (along with any further documents) are reviewed, Plaintiff's Expert Opinions will be supplemented.

Without waiver of the objections and reservations set forth herein, the Plaintiff may call

the following expert witnesses to testify at a trial of this cause, who, in addition to the specific

disclosures of opinions will disagree substantially with those of Defendants' experts designated:

1. KATHLEEN A. HILL-O'NEILL 7 VALLEY VIEW DRIVE UPPER MAKEFIELD, PA Hl943

1.1 Please see the attached report signed by Ms. Hill O'Neill in accordance with FED.

R. C1v. P. 26(a)(2) and L.U.C1v.R.26(a)(2), attached as Exhibit "A.''

1.2 A copy of Ms. Hill-O'Neill's CV is attached as Exhibit "B."

1.3 A copy of Ms. Hill-O'Neill's Trial and Deposition Testimony over the past four

(4) years is attached as Exhibit "C."

1.4 A copy of Ms. Hill-O'Neill's Fee Schedule is attached as Exhibit "D."

2. JAMES A. SEXSON,M.D. 3875 AUSTELL ROAD SUITE 303 AUSTELL, GA 30106

2.1 Please see the attached report signed by Dr. Sexson in accordance with FED. R.

CI\'. P. 26(a)(2) and L.U.CI\'.R.26(a)(2), at+..ached as Exhibit "E."

2.2 A copy of Dr. Sexson's CV is attached as Exhibit F."

2.3 A copy of Dr. Sexson's Trial and Deposition Testimony over the past four (4)

years is attached as Exhibit "G."

2.4 A copy of Dr. Sexson's Fee Schedule is attached as Exhibit "H."

3. ALL OF MR. DYKES' TREATING PHYSICIANS

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3.1 Plaintiff may call any and all of the treating physicians who provided

examination, care, treatment, or services to Mr. Dykes from 2012 through 2014 and who may be

identified in the hospital records, physician records, psychiatric and/or psychological records,

and other documents produced or identified by the parties in fonnal or informal discovery

responses, depositions or correspondence. None of these persons are retained experts pursuant to

the Federal Rules of Civil Procedure. If called, these persons will testify regarding their

exaruinations, diagnoses, car0, treatment, opinions, and observations vf ~1r. Dykes as revealed in

the referenced in their respective records/documents. Such treating physicians might also offer

testimony as to Mr. Dykes' pain.

3 .2 Mr. Dykes' treating physicians will testify regarding their treatment, care,

examination, or services rendered to Mr. Dykes. These physicians may be identified in the

hospital records, physician records, and other documents produced or identified by the parties in

formal or informal discovery responses, depositions, or correspondence, including all medical

records. Said physicians are qualified to give expert testimony based upon their extensive

knowledge and experience as physicians.

3.3 Mr. Dykes' treating physicians are anticipated and/or expected to testify regarding

their treatment of Mr. Dykes during Mr. Dykes' residency at Cleveland Nursing & Rehabilitation

Center, prior and subsequent to. Mr. Dykes' treating physicians are anticipated and/or expected

to testify to the dates of treatment, actual treatments and evaluations, the Plaintiffs history of

pain, the extent of the Plaintiffs injuries, Mr. Dykes' severe pain and suffering, any procedures

performed, their diagnosis, their prognosis, and that Mr. Dykes' medical conditions were caused

by Defendant's actions. Mr. Dykes' treating physicians are anticipated and/or expected to testify

as to \Vhat is set out in the medical records. The subject matter of their testimony is the care and

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treatment provided to Mr. Dykes, including the care and treatment by the nursing home facility.

The subject matter of their testimony will also concern Mr. Dykes' presentation at the hospital,

his falls, his decubitus ulcers, his infections, and death.

3 .4 The grounds for the treating physician's opinions are based upon their

examination, evaluation, and treatment of Mr. Dykes, the medical records and/or reports they

have studied and their past expertise, training and experiences in handling this type of injury.

~1r. Dykes' treating physicians are ~nticipated and/or expected to testify to all of the abovl! based

upon a reasonable degree of medical probability.

3.5 Additionally, Mr. Dykes' treating physicians are anticipated and/or expected to

testify to the total amount of his medical bills. Mr. Dykes' treating physicians are anticipated

and/or expected to testify that these charges are both reasonable and customary for this area and

are directly related to the Defendant's actions.

3.6 As discovery is ongoing, the Plaintiff reserves the right to supplement this

response in accordance with the Federal Rules of Civil Procedure and Plaintiff would otherwise

refer Defendants to Mr. Dykes' medical records regarding the Plaintiffs treatment.

4. Plaintiffs reserve the right to call any necessary experts in rebuttal.

5. Plaintiffs reserve the right to supplement these opinions and expert

designations in keeping with the Federal Rules of Civil Procedure. Plaintiffs also reserve the

right to supplement these opinions upon receipt and review of any additional medical records,

depositions, or discovery, including the Defendants' Designation of Experts and responses to

interrogatories and the opinions included therein.

6. Plaintiff's experts will use various demonstrative exhibits, including those

produced in discovery.

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RESPECTFULLY SUBMITTED, this the i 51h day of July, 2016.

R n"u' "'1· 11·1"m" 'II E·q ("SD# 102°'5' '\. • .1. a 1 Vf ll i.t l~, .i , ;:, , !Vl .L J'+ }

PLAINTIFF, DANNY DYKES, INDIVIDUALLY, AND ON BEHALF OF THE ESTATE AND WRONGFUL DEATH BENEFICIARIES OF JAMES A. DYKES, DECEASED

BY: s/ R. Paul Williams III R. PAUL WILLIAMS, Ill

Courtney M. Williams, Esq. (MSB# 102347) WILLIAMS NEWMAN WILLIAMS, PLLC 129B South President Street Post Office Box 23 785 Jackson, Mississippi 39225 Tel: (601) 949-5080 Fax: (601) 949-3358 Email: [email protected]

· [email protected]

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CERTIFICATE OF SERVICE

I, R. Paul Williams, III, attorney for Plaintiff, hereby certify that I have provided a true and correct copy of the above and foregoing instrument via US Mail and electronic mail to:

Bradley W. Smith, Esq. Clay Gunn, Esq. BAKER, DONELSON, BEARMAN CALDWELL & BERKOWITZ, PC 4268 I-55 North Meadowbrook Office Park Jackson, MS 39211

John F. Hawkins, Esq. HAWKINS GIBSON, PLLC 628 North State Street (39202) Post Office Drawer 24627 Jackson, Mississippi 39225-4627

David Norquist DA YID NORQUIST LAW OFFICE, PLLC Post Office Box 1379 301C West Sunflower Road Cleveland, Mississippi 38732-1209

This the 151h day ofJuly, 2016.

s/ R. Paul Williams III R. PAUL WILLIAMS, III

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Kathleen A. Hill-O'Neill, RN, MSN, CRNP, NHA 7 Valley View Drive

7115116

Williams Newman William Paul Williams, III P.O. Box 23785 Jackson, MS 39225

Upper Makefield, PA 18940

Re: James Dykes v Cleveland Nursing & Rehabilitation Center

Dear Mr. Williams:

Dykes I

I am Kathleen A. Hill-O'Neill MSN, Ri"\f, NHA, a registered nurse, gerontological nurse practitioner and licensed nursing home administrator. I hold a master's degree specializing in gerontological nursing and am certified as a gerontological nurse practitioner. I have more than 25 years of experience in the field of gerontology and have held various positions in continuing care retirement communities, nursing homes and hospitals. I am currently employed by Family Practice of~Je\vto\vn in Ne\vt0\Vn, Pennsy!vania. I have taught in both undergraduate and graduate nursing programs at the University of Pennsylvania and Gwynedd Mercy College. I have worked as a nursing instructor in the undergraduate nursing program at Gwynedd Mercy College as a clinical instructor in a hospital setting. I have taught in the undergraduate nursing and currently teach in the graduate program at the University of Pennsylvania's school of nursing and aiso precept nurse practiiioner students from the graduate program.

I have worked as a consultant to the United States Department of Justice and the Centers for Medicare and Medicaid and as a federal monitor. I have also worked as an independent consultant. My role has included touring nursing homes located in multiple states observing and assisting with care to assess for quality. In addition, my consulting work includes reviewing facility records to give my opinion as an expert on the quality of resident care and support services. Upon completion of these assessments, I have written reports to address areas of concern and formulated strategies and recommendations for improvement. I have also provided training for staff.

I have reviewed the following records regarding the care of Mildred Dykes: Cleveland Nursing & Rehabilitation Center- entire chart (11/12/12 - 09/03/14) Bolivar ~v1edical Center- (12/06/12- 09/03/14) North Sunflower Medical Center- all records (10/10/12-09/03/12)

Mr. Dykes, an 89 year old patient, was re-admitted to Cleveland Nursing & Rehabilitation Center on July 22, 2013. At the time of his admission, the nursing staff documented that his skin was intact. He had a past medical history of a Left Below the Knee Amputation, Peripheral Vascular Disease, Type II Diabetes and Coronary Artery Disease. He


Dykes 2

was completely dependent on the staff for assistance with mobility, incontinence care and obtaining food and fluids.

Early in his stay, the nursing staff failed to comply with the standard of care and the nursi11g process and complete and adequate and appropriate assessment and then develop a plan of nursing interventions.

On July 22, 2013, the nurses completed an evaluation of Mr. Dyke's risk of pressure sore development that noted he had the following risk factors:

• bed mobility is a problem

• bowel incontinence

• previous ulcer

• peripheral vascular disease

Despite noting these risk factors, no plan of care was developed by the staff at Cleveland Nursing & Rehabilitation Center to address his risk of skin breakdown and to maintain his skin integrity. It is no surprise that Mr. Dyke developed skin breakdown soon after his admission. The nursing staff wrote an entry on an interim plan of care on July 30, 2014, 8 days after Mr. Dykes was admitted that he had actual skin issues and wrote the following:

clean decubitus to sacral area with wound cleanser, pat dry using 4x4, gauze and apply duoderm ....

Mr. Dykes was hospitalized at North Sunflower Medical Center on September 30, 2013 due to gangrenous right leg and foot requiring amputation below the knee. He returned to Cleveland Nursing & Rehabilitation Center and remained there until he developed blood in his urine requiring hospitalization and treatment for benign prostatic hypertrophy and subsequent intermittent hospitalizations for related complications.

He was readmitted to Cleveland Nursing & Rehabilitation Center on January 15, 2014. On May 24, 2014, Mr. Dykes was admitted to North Sunflower Medical Center. The discharge summary notes:

90 year old male admitted 1.vith dei;reased !evel of consciousness. He had been 'veak ., lethargic and barely arousable for the past 3 days . He was unresponsive to verbal stimuli on admission minimally responsive to painful stimuli. He had a histCI}' of chills and fever \Vith temperature up to 103. He was found to have a Urinary Tract Infection with most likely Sepsis (a systemic life threatening infection). His bladder was distended to the level of the umbilicus

(the belly button) with his supra pubic cathcfar being stopped up. His supra pubic catheter was removed and a large amount of urine just flowed out followed by lOOOcc in the Foley

bag. On the third day he woke up and was conversive and by the time of discharge he was oriented, coherent and mnch improved. His urine was clear. His Azotemia proved to be reversible with a BUN and Creatinine of 31 and 1.1. Initially not taking food and fluids well enough to get by without IV fluids but by discharge this had improved. He had a sacral decubitus

Stage III on admission and this was treated and will continue under treatment on discharge back to the nursing home.


Dykes 3

The pattern of neglectful care by the staff at Cleveland Nursing & Rehabilitation Center continued. Although the hospital stabilized Mr. Dyke and returned him on May 24, 2014 in a much improved condition, he did not receive adequate and appropriate care and his condition declined again within a month of his return to Cleveland Nursing & Rehabilitation Center. Despite the hospital's discharge plan for him to receive care and treatment of his stage III sacral ulcer, the Cleveland Nursing & Rehabilitation Center staff failed to adequately assess and treat his skin condition. The sacra/coccyx decubitus became larger and infected necessitating another hospitalization. The failure to provide adequate care and treatment for a pressure sore includes:

assessment, treatment, documentation and care planning including assuring adequate pressure relief, hydration and nutrition with ongoing monitoring and evaluation of the progress and notification of the physician and timely revisions in care and treatment as needed.

This is not only the standard of care but also a requirement of state and federal regulations that govern nursing homes. However the staff at Cleveland Nursing & Rehabilitation Center failed to provide adequate and appropriate care and in doing so fell below the standard of care.

Mr. Dykes was once again admitted to the hospital on May 31, 2014. He was treated at the hospital, stabilized and returned to Cleveland Nursing & Rehabilitation Center to receive antibiotics and ongoing care at the Wound Center. His condition continued to decline due to worsening of his pressure ulcer and subsequent infections and related complications requiring subsequent hospitalization on June 14, 2014 where he received a PEG tube for feeding.

Once again he was returned to Cleveland Nursing & Rehabilitation Center on June 20, 2014 and despite having a feeding tube where nursing staff can administer feeding and fluids, Mr. Dykes developed severe dehydration, another infection which was exacerbated by dehydration, pneumonia and sepsis requiring hospitalization yet again on July 6, 2014. During this hospitalization, Mr. Dykes was noted to be so severely neglected that the family was approached about him being infected with fecal matter. Mr. Dykes family then made the decision to never let him return to Cleveland Nursing & Rehabilitation Center. Mr. Dykes condition was at such a deteriorated state at this point that he was never able to fully recover and he died on September 3, 2014.

The staff at Cleveland Nursing & Rehabilitation Center failed to provide adequate care to James Dykes by:

• Failing to adequately assess and provide individual care to maintain and or promote skin integrity.

• Failing to provide adequate and appropriate care and treatment to prevent malnutrition, dehydration and infections.

• Faiiing to put adequate and timely measures in place to improve his skin condiiion when he developed new areas or existing areas were declining.

• Failed to provide adequate and appropriate care to maintain adequate urinary function and prevent complications of BPH.


Dykes 4

• Failing to assess and recognize the severity of his decline in condition, alert the physician and send him to the hospital.

• Failing to develop and update and adequate plan of care to meet his needs and promote his well-being.

• Failing to keep him clean and dry even of his own feces which would knowingly contribute to the development of infection and a violation of his right to dignity.

Based on my education and extensive experience in the long-term care industry as a clinician, administrator and consultant, it is my opinion, to a reasonable degree of nursing certainty that the care provided to Mr. Dykes by the Cleveland Nursing & Rehabilitation Center staff fell below acceptable standards of care and said failure to adhere to accepted standards of care were the proximate cause of Mr. Dykes' s worsening skin condition, infections and related injury, pain and suffering. All opinions expressed throughout this report are stated within a reasonable degree of nursing certainty.

Thank you for the opportunity to review these records. I reserve the right to revise my opinion should additional records or testimony be provided to me. If you have any questions, please do not hesitate to contact me.

Sincerely,

Kathleen A. Hiil-O"Neiil RL'-1, MSN, CRNP, NHA


REPORT OF JAMES A. SEXSON. M.D.

I am James A. Sexson, M.D. I am board certified in internal medicine. l received a B.S.

in Biology in 1983 from Birmingham-Southern College, a Doctor of Medicine from the

University of Alabama at Birmingham School of Medicine, and completed a residency in

internal medicine at Carraway Methodist Medical Center in Birmingham, Alabama. I am in

active practice at a clinic in Austell, Georgia and rouncl at nursing homes in Georgia. I am also

employed as a staff hospitalist at Dorminy Medical Center. I have served the position as

medical director and am a certified medical director.

I have reviewed the report completed by Kathleen Hill-O'Neill, att~.ched as Exhibit

"A" and incorporate by reference her report, including her factual findings and breaches in the

standard of care.

I reviewed the medical records in this case relating to Mr. Dykes, including but not

limited to, records from Cleveland Nursing & Rehab, Bolivar Medical Center, and North

Sunflower Medical Center; the death certificate of Mr. Dykes; pleadings filed in this case, and

am familiar with the Omnibus Budget Reeonciliation Act of 1987 and related regulation; and

will rdy upon my education, training, and experience as a physician.

The following opinions must be di.sclaimed by the following statement: There are a

numb1jr of documents still outstanding, including policies and procedures. Once said documents

(along with any further documents) are reviewed, this report may be supplemented. Also, upon

the depositions of the healthcare providers, including the Director of Nursing, and any

caregivers, in which the specific details of what happened during the care and treatment of Mr.

Dykes, this report wlll be supplemented.

The Nursing Home Facility breached the standard of care which was applicable to the

EXHIBIT

I e-


treatment of Mr. Dyk•~s durir1g bis residency. The overall issue in this case is just veiy, very poor

care in the nursing home, and specifically with regard tc> assessments of Mr. Dykes by the

facility. What brought aboutthis gentletmm' s death on September 3, 2014, according to the

death certificate, was bronchopneumonia, aspiration, dysphagia, and cva. On or aoout July 6,

2014 Mr. Dykes was admitted to the hospital with sepsi:s, aspiration .Pneumol'lia, severe

dehydration, a urinary tract infection, and a Stage IV necrotic coccyx pressure ulcer. These

conditions re.~ulted in a decline in Mr. Dykes' overall health causing his death on September 3,

2014. The medical oonditions which wert1 present on Mr. Dykes' admission to Notth Sunfluwer

Medical Center on .luly 6, 2014 resulted from the facili1y's breaches in the st.andarcl of care. Mr.

Dykes' death was caused by the facility's breaches in the standard of care.

During Mr. Dykes' residency period with Clevdand Nursing & Rehab, which began

November 12, 2012 and con.eluded July 6, 2014, Mr. Dykes was hospitalized on numerous

occasions. Mr. Dykes was admitted to tl:m hospital on at least the following occasions: July J. 8,

2013 for pneumonia:; September 3, 2013 for treatment related to a gangrenous righl leg/foot and

a pres:;ure ulceno his coccyx; September 28, 2013 related. to a fall atthc facility; Decembel' 17,

2013 related to a fall at the facility; January 7, 2014 with urinary tract infection, dehydration, and

further treatment ofl1is coccyx pressure u,Jcer; .lanuary 14 .• 2014 where Mr. Dykes was noted to

have a sacral skin tear; May 18, 2014 with a diagnosis of urinary tract infection, sepsis,

dehydration, and his coccyx pressure ulcer had progrei•sed to Stage 3; May 31, 2014 with sepsis

ftom Mr. Dykes infected coccyx pressure ulcer; June 14, 2014 with malnutrition, dehydration,

septicemia, and a lm:ge, necrotic un..'ltageable coccyx pressure ulcer - Mr. Dykes also had a PEG

tube placed during t!lis hospitalization; July 6, 2014 with sepsis, aspiration pneumonia, sevt<lre

dehydration, urinary tract i11.fuction, and a necrotic and infected Stage 4 coccyx pressure uh:er;

2


July 20, 201.4 with.a large decubitus coccyx ulcer with transfusion and debridement; August 6,

2014 with a Stag1: 4 coccyx pressure ulcer; and September 1, 201.4 with a Stage 4 coccyx

pressure ulcer. Each of these hospitalizations, and accompanying medical treatment and

expenses, were causally related to the Facility's breaches in the standard of cure related to Mr.

Dykes.

The fac.ility's failure to properly prevent and treat Mr. Dykes' coccyx pressure ulcer

caused the pressi1re ulcer to develop and then progress ftom Stage 1 to Stage 4, become necrotic,

and become infected. Had the facility provided adequate care in the prevention of pressure sores

related to Mr. Dykes, Mr. Dykes would not have developed his coccyx pres.~ure ulc:er. Had the

facility provided adequate care in the trcal:ment of Mr. Dykes' coccyx pressw:e ulct!f upon iuitial

presentation Mr. Dykes' coc.cyx pressure ulcer would not have progressed from St.age 1 to Stage

4 and would not ltave become necrotic or infected. Mr. Dykes had the ability to heal as

evidenced by the medical records, and had proper treatment been ,provided to Mr. Dykes reL-ited

to the coccyx ulc~. Mt. Dykes' coccyx ulcer would haYe healed.

The facility failed to ensure that Mr. Dykes rect:ived adequate hydration as evidenced by

the dehydration diagnoses and lab results. The failure of the facility to ensure adequate

hydration with Mr. Dykes nisulted in Mr. Dykes beco.ming severely dehydrated and being

hospitalized.

The facili.ty continuously failed to properly assess Mr. Dykes in numi:rous areas related to

.his care. The failure of the facility to properly assess Mr. Dykes resulted in worsening of his

conditions, development of pneumonia, a:ipiration, urinary tract infections, and hospitalizations.

Mr. Dykes also experienced falls due to the faCJlity' s breaches in the standlll'd of care.

Mr. Dykes fell on September 27, 2013 where he hit his head, was bleedi.ng from hi.s head, and

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had a hematoma. Mr. Dykeg was hospitalized related to this fall around September ~!8, 2013.

Mr. Dykes fell agt~in on December 17, 201'.:l where he fell backwards ontO the floor !llld hit his

head. Mr. Dykes was hospits.lized around :December 17, 2013 related to this fall. Mr. Dykes fell

again on May 16, 2014 where he was found on the floor. Mr. Dykes was hospitalized on Ma;y

18, 2014 due to a change in his behaviors following this fa.11. The falls experfonced by Mr.

Dykes were preventable and the facility was not implementing appropriate fall prevention

interventions with Mi·. Dykes. As a result of the facility's breaches in the standard ·'Jf care in this

regard,. Mr. Dykes feU, suffered injury, and was hospitalized related to these falls.

As a result of breaches in the standard of care identified herein, and iricorporated herllin

by reference to Ms. Hill·O'Neill's report, Mr. Dykes' suffered in,iurics, damages, dehydraticin,

infections, pneumonia, sepsis, aspiration, decubitus ulcers, corres,pondi11g pain, and death.

Mr. Dyk1is' development of dehydration, UTl's, infections, decubitus ulcers, pneumonia,

aspiration, sepsis, and injur.ies from falls, were the fault of the facility and a:ffected his continued

decline.

Mr. Dykes e.1tperienced severe pai11 as a result of the Facility's breaches in the standard of

care. Mr. Dykes exµerienced pain and suffering related to the pressure ulcers, urinary tract

infections, wou11d infectioos, injudes from falls, aspiration and pneumonia, dehydration, arid

death.

Ultimately, the Fa.cility and its staff failed to deli.ver care and servico:s that a reasonably

careful service provider W1)uld have provided under similar circumstances which ca.used injury to

Mr. Dykes. Accordingly, Mr. Dykes suffered severe injuries and damages as a result oftbe

improper care ()f the Facility. I will also testify in this matter as to the total amount of medical

bills incurred by Mr. Dykies causally related to the breaches in the standard of care by the I

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Facility. The care and treatment by the named parties to Mr. Dykes was inad~quate,

inappropriate, and failed to conform to the standard of i:.are and these actions -::aused the inju1'ies

to, and death of, Mr. Dykes. All of the opinions contained herein are stated to a rea.sonable

degree of medical probability.

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case: 4:15-cv-00076-dmb doc #: 96-1 filed: 03/02/18 1 of...

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