3/8

and immobilizing devices; in causing, allowing and permitting the  

decedent to be injured while restrained with immobilizing and/or

protective devices; in failing to properly order specific time

limits for the use of protective /immobilizing devices; in failing

to properly and adequately observe and re-examine the decedent in

order to determine the propriety of continued the use of

restraints; in failing to properly observe, chart and assess the

decedent's condition every 30 minutes; in improperly restraining

the decedent ,with wrist restraints and ankle restraints; in failing

to properly train, supervise and instruct the hospital staff in the

use and application of restraining devices; in failing to provide

for the decedent's safety; in failing to take proper care and

adequate and necessary safeguards and supervision to prevent the

occurrence herein set forth; in failing to use accepted modes,

practices, procedures and standards made, set and provided for the

use of such restraints within the medical and hospital community;

in failing to comply with the standards of medical and hospital

care and treatment practiced by physicians and/or medical

institutions and their personnel; in failing to use the accepted,

correct and established modes and procedures in connection with the

treatment of the conditions from which the decedent was suffering;

in treating the decedent in a manner contrary to the accepted rules

and standards of the community wherein the treatment was utilized

upon decedent; in failing to use and exercise the required degree

of care, skill, judgment and diligence; in failing to possess and

Click here for Next Page
Click here for Previous Page
Click here for Start of Bill of Particulars