I Am Working With Larry

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Hi Keri, I am working with Larry on this file and I would ask that you consider the following to be our status report on this matter. Pursuant to our presentation of our motion, we received an extension of time from the court to file our responsive pleadings to the Complaint by October 19, and we will file an Answer and Affirmative Defenses on a timely basis. Further, we had the opportunity to meet with Polly Hartman, the Executive Director, and Beth Sahuri, Director of Nursing, from Support Services. They were very cooperative and provided us with preliminary documentation regarding the incident and Polly indicated that she will forward additional documents regarding Elise Wasson’s residency at the group home in the near future. During our meeting, Polly and Beth reported that Elise lived in one of their group homes on Lynwood in Fairview Heights for a year before the occurrence. Elise had no prior difficulties with her balance while sitting, but had an unsteady gait, which required the use of a gait belt while walking. The plaintiff, who is Elise’s sister and guardian, was very involved in Elise’s care and visited her often. Polly and Beth described the plaintiff as “challenging” in that she regularly requested additional services for Elise. However, despite making several demands on our client, the plaintiff also insisted that she would provide Elise with many items that she required. Regarding the January 17, 2016 occurrence, Elise, who has Down syndrome and suffers from dementia, had no balance issues earlier that day. Further, she was not suffering from an acute medical condition, e.g., UTI, that previously affected her balance. At the time of the occurrence, Elise was sitting in a chair at the north end ... ... middle of paper ... ...ance issues while sitting and there are no medical orders requiring our client to stabilize her while sitting. We also anticipate that the plaintiff’s expert will criticize our client for failing to provide “one-on-one” care, which the plaintiff requested after Elise had a prior fall while walking. Our client did not make a request to the State of Illinois for the required funding to allow “one-on-one” care because, based on our client’s experience, one fall was not a sufficient basis to request the additional funding. However, our client did implement the use of a gait belt previously. As mentioned above, we will file our responsive pleadings shortly and serve the plaintiff with written discovery. In addition, we will keep you informed as developments occur. In the meantime, please do not hesitate to call Larry or me if you have any questions or concerns.
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