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    • Heart surgery is an extremely dangerous procedure.
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      6) Defendants Ray Jennings and the Lakeview Regional Medical Center failed to perform their duties as described in Lakeview Regional Medical Center's Patient Guide in a safe and effective manner leading to the injuries sustained by the Plaintiff. Resulting in patient seclusion and isolation from family members. Plaintiff was intentionally denied access to family members during a critical time period of his recovery process.

      7) Defendants Ray Jennings and the Lakeview Regional Medical Center failed to perform their duties as described in Lakeview Regional Medical Center's Patient Guide in a safe and effective manner leading to the injuries sustained by the Plaintiff. Resulting in elder abuse. The Plaintiff, a fifty-eight year old man, with a long history of mental and physical health problems including type II diabetes, heart disease, high blood pressure, high cholesterol, a bipolar disorder, and a sleep disturbance, should never have been subjected to ridicule, humiliation or torture.

      XIII.

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