Ronald Johnson v. V. James Makker 1/25/2011

3 4.
1 18, 2007; and April 29, 2008. Defendant was paid for some or all of the fees and
2 servces for which he biled plaintiff for these surgical procedures.
4 Plaintiff was permanently injured as a result of the surgical procedures performed
5 by and through the negligence of defendant. Plaintiff sustained permanent weakening of
6 his cervcal and lumbar spines, pain and suffering associated with the surgeries, recovery
7 therefrom, and from the instabilty caused by the surgical procedures. Plaintiffs injuries
8 include pain and loss of neurological function in his neck, low back and his upper
11
9 extremities, as well as
5.
a permanent loss of neurological function and movement of his
10 lower left leg and foot caused by the surgery of August 13, 2007.
12 Defendant Makker was negligent in one or more of the following particulars:
13 (a) In performing unnecessary surgeries on plaintiff herein;
14 (b) In performing surgeries on plaintiff without clinical or radiographic
15
16
17
(c)
indications to do so;
In prescribing excessive amounts of pain medications to plaintiff following
the above-alleged surgical procedures;
18 (d) In purporting to perform surgical procedures that were not, in fact, done;
19 and
20 (e) In positioning plaintiff and/or retracting plaintiffs tissues in such a way as
23
21 to cause permanent
6.
neurologic injury to plaintiffs lower left leg and foot in
22 the surgery of August 13, 2007.
24 Plaintiff did not know and could not reasonably have known or discovered his
25 claims against defendant until a time within two years of the date this case was
26 commenced.
Page 2 - SECOND AMENDED COMPLAINT MILLER & WAGNER lJ
Trial Lawyers
2210 NW. Flanders Street
Portland, Oregon 97210-3408
(503) 299.6116