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of Xanax withdrawal.                                           

3. No claim is made for the failure of the defendant to

administer a diagnostic test.

4. The defendant failed to administer Xanax to treat the

withdrawal symptoms. Defendant also failed to timely begin

treatment with Ativan; failed to timely begin to administer the

drug intravenously and failed to raise the dosage on a timely basis

to treat decedent's agitation, hallucinations and other withdrawal

symptoms; defendant also failed to adequately sedate the decedent

which would nave obviated or at least limited, the need for

restraints.

5. It will be claimed that the defendant, through its agents,

servants and/or employees were negligent, careless and reckless in

the care and treatment rendered to the decedent while he was a

psychiatric patient under their care, control and supervision; in

failing to properly monitor, observe and supervise the decedent who

was delusional and delirious; in causing, allowing and permitting

the decedent, who was medicated, to be permitted to use the

lavatory unattended; in failing to order one on one coverage for

the supervision and care of the decedent; in causing,and permitting the

decedent to fall and strike his head while in the

lavatory; in failing to order, monitor and observe proper

protective and immobilizing devices and restraints; in failing to

properly monitor, observe and act upon the decedent's reactions and

experiences to his withdrawal and/or administration of medications

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