El contexto institucional de la investigación sobre comunicación en España

(a) failed to provide [decedent] necessary services to attain and maintain the highest practicable physical, mental, and psychosocial well-being in accordance with a comprehensive assessment and plan of care;

(b) failed to develop, implement, and alter as necessary a care plan to meet [decedent]’s needs.

(c) failed to report changes in [decedent]’s condition to [his] [her] physician(s); (d) failed to protect [decedent] from abuse and neglect;

(e) failed to administer treatments and procedures to [decedent] as ordered by [his] [her] physician;

(g) failed to provide [decedent] restorative and rehabilitative measures to meet [his] [her] individual needs, total nursing needs, and personal care needs;

(h) failed to provide appropriate medical care to [decedent] when it was known or should have been known that such care was needed;

(i) failed to maintain an active medical record;

(j) failed to properly train individuals who provided care and treatment to [decedent]; (k) failed to provide necessary treatment and services to promote healing of pressure

sores and prevent infection and development of new pressure sores;

(l) failed to identify and treat changes in [decedent]’s skin and texture before the onset of pressure sores;

(m) failed to properly reposition and turn [decedent] to relieve existing pressure sores and prevent future pressure sores;

(n) failed to anticipate, recognize, and provide appropriate infection control measures for [decedent]’s open wounds;

(o) failed to implement daily skin checks as required according to [decedent]’s care plan;

(p) failed to properly implement vitamin C and zinc therapy pursuant to wound and skin care protocol;

(q) failed to correctly implement the registered dietician’s recommendations for increased calories for one month;

(r) failed to measure and document weekly weights; (s) failed to accurately monitor intakes and outputs;

(t) failed to provide appropriate services for receiving feedings per gastrostomy tube; (u) failed to address [decedent]’s weight loss;

(v) failed to provide [decedent] with sufficient fluid intake to maintain proper hydration and health;

(w) failed to make a comprehensive assessment of [decedent]’s clinical condition as it related to [his] [her] risk for dehydration and physical and psychosocial decline; (x) failed to identify and treat changes in [decedent]’s mentation, cognition, and

(y) failed to provide necessary treatment and services to avoid the development of specific nutritional and hydration issues;

(z) failed to appropriately assess, prevent, and ultimately treat dehydration;

(aa) failed to ensure that [decedent] maintained acceptable parameters of nutritional status;

(bb) failed to institute a regular program for [decedent] to prevent and treat malnutrition;

(cc) in violation of §483.25 of the OBRA Regulations, failed to provide necessary care and services to attain or maintain [decedent] at the highest practicable level of physical, mental, and psychosocial well-being in accordance with a comprehensive assessment and plan of care;

(dd) in violation of §483.13(c) of the OBRA Regulations, failed to protect [decedent] from neglect;

(ee) in violation of §483.10(b)(11) of the OBRA Regulations, failed to inform [decedent]’s physician and family of significant changes in [decedent]’s physical, mental, or psychosocial status;

(ff) in violation of §483.25(a) of the OBRA Regulations, failed to provide [decedent] the necessary care and services to prevent a decline in his abilities to perform activities of daily living;

(gg) in violation of §483.20(k) of the OBRA Regulations, failed to develop a comprehensive plan of care to address [decedent]’s medical, nursing, mental, and psychosocial needs;

(hh) in violation of §483.15(g)(1) of the OBRA Regulations, failed to provide [decedent] medically related social services to attain or maintain the highest practicable physical, mental, and psychosocial well-being;

(ii) in violation of §483.75(l) of the OBRA Regulations, failed to maintain the clinical record and document changes in [decedent]’s condition, including, but not limited to, changes in the condition of [decedent]’s pressure ulcers;

(jj) in violation of §483.20(b) of the OBRA Regulations, failed to make a comprehensive assessment of [decedent]’s needs;

(ll) in violation of §483.75(b) of the OBRA Regulations, failed to administer the facility in compliance with federal, state, and local laws and professional standards and in a manner that enables it to use their resources effectively and efficiently to attain or maintain the highest practicable physical, mental and psychosocial well-being of each resident;

(mm) in violation of §§483.25(c)(1) and 483.25(c)(2) of the OBRA Regulations, failed to provide necessary treatment and services to avoid the development of pressure sores, promote healing of pressure sores, and to prevent infection and development of new pressure sores;

(nn) in violation of §483.25(j) of the OBRA Regulations, failed to provide [decedent] with sufficient fluid intake to maintain proper hydration and health and failed to provide necessary treatment and services to avoid the development of specific hydration issues;

(oo) in violation of §483.25(i)(1) of the OBRA Regulations, failed to ensure that [decedent] maintained acceptable parameters of nutritional status;

(pp) in violation §483.25(i)(2) of the OBRA Regulations, failed to ensure that [decedent] received a therapeutic diet after nutritional problems developed;

(qq) in violation of 77 Ill.Admin. Code §300.1210(a), failed to provide the necessary care and services to attain or maintain the highest practicable physical, mental, and psychosocial well-being in accordance with [decedent]’s comprehensive assessment and plan of care;

(rr) in violation of 77 Ill.Admin. Code §300.1210(a)(1), failed to provide [decedent] restorative and rehabilitative measures to meet [his] [her] individual needs;

(ss) in violation of 77 Ill.Admin. Code §300.1210(a)(4), failed to assist and encourage [decedent] so that [decedent]’s abilities in daily living did not diminish;

(tt) in violation of 77 Ill.Admin. Code §300.1210(b)(2), failed to administer treatments and procedures to [decedent] as ordered by [his] [her] physician;

(uu) in violation of 77 Ill.Admin. Code §300.1210(b)(3), failed to objectively observe, assess, and evaluate changes in [decedent]’s condition;

(vv) in violation of 77 Ill.Admin. Code §300.1220(b)(3), failed to develop an up-to-date care plan for [decedent] based on [his] [her] comprehensive assessment, individual needs and goals to be accomplished, physician’s orders, and personal care and nursing needs;

(ww) in violation of 77 Ill.Admin. Code §300.1810(b), failed to maintain an active medical record for [decedent].

(xx) in violation of 77 Ill.Admin. Code §§300.3210(n) and 300.3210(o), failed to notify [decedent]’s family, representative, and physician of changes in [decedent]’s condition;

(yy) in violation of 77 Ill.Admin. Code §300.3240, failed to protect [decedent] from abuse and/or neglect;

(zz) in violation of 77 Ill.Admin. Code §§300.1210(b)(4)(A) and 300.1210(b)(4)(B), failed to ensure that [decedent] received proper daily personal attention to maintain personal hygiene;

(aaa) in violation of 77 Ill.Admin. Code §300.1210(b)(5), failed to provide [decedent] with the necessary treatment and services to promote healing, prevent infection, and prevent pressure sores from developing;

(bbb) in violation of 77 Ill.Admin. Code §300.2050, failed to provide [decedent] with an adequate diet in order to attain and maintain appropriate nutritional levels; (ccc) otherwise failed to provide adequate medical care, personal care, maintenance,

and treatment to [decedent]. 9. [Decedent] died on [date].

10. As a direct and proximate result of one or more of the Defendants’ negligent acts or omissions, [decedent] sustained injuries including, but not limited to, multiple pressure ulcers, dehydration, malnutrition, weight loss, sepsis with multiple organ dysfunction, hypoxia, emaciation, and pneumonia, all of which caused or contributed to [his] [her] death. 11. [Decedent] left surviving [him] [her] various persons who were his next of kin, including, but not limited to:

[list]

12. [Decedent]’s next of kin suffered injuries as a result of [his] [her] death, including the loss of companionship and society.

13. The Plaintiffs, ____________, bring this action pursuant to 740 ILCS 180/1, et seq., commonly known as the Wrongful Death Act of the State of Illinois.

14. Attached to this Complaint are an Attorney Affidavit (see Exhibit B) and Health Professional Report (see Exhibit C), filed pursuant to 735 ILCS 5/2-622.

WHEREFORE, the Plaintiffs, ____________, ask that judgment be entered against the Defendants, ____________, in a fair and just amount in excess ____________.

COUNT IV

(Plaintiffs v. ____________) (Negligence — Survival Statute)

1. – 9. Plaintiffs reallege paragraphs 1 – 9 of Count III of this Complaint as and for paragraphs 1 - 9 of this Count IV.

10. As a direct and proximate result of one or more of the Defendants’ negligent acts or omissions, [decedent] sustained injuries including, but not limited to, multiple pressure ulcers, dehydration, malnutrition, weight loss, sepsis with multiple organ dysfunction, hypoxia, emaciation, and pneumonia, all of which caused and contributed to [decedent]’s death, and [decedent] would have been entitled to recover from the Defendants for these injuries, had [he] [she] survived.

11. As a direct and proximate result of one or more of the Defendants’ negligent acts or omissions, [decedent] sustained substantial personal and pecuniary injuries, past, present and future, including, but not limited to, disability and disfigurement, pain and suffering, and expenses for hospital and related medical care, and [decedent] would have been entitled to receive compensation from the Defendants for these injuries, had [he] [she] survived. Further, [decedent]’s estate was diminished by virtue of the medical, hospital, and funeral expenses that were incurred.

12. [Plaintiffs] bring this action on behalf of [decedent] under provisions of 755 ILCS 5/27-6, known as the Illinois Survival Statute.

13. Attached to this Complaint are an Attorney Affidavit (see Exhibit B) and Health Professional Report (see Exhibit C), filed pursuant to 735 ILCS 5/2-622.

WHEREFORE, the Plaintiffs, ____________, ask that judgment be entered against Defendants, ____________, in a fair and just amount in excess of ____________.

PLAINTIFFS DEMAND TRIAL BY JURY.