5. At all times relevant hereto, defendant COLUMBIA PRESBYTERIAN
MEDICAL CENTER, held itself out as a medical hospital duly qualified and
capable of rendering competent medical care, treatment, advice and surgery to
the general public, including plaintiffs’ decedent, Seth B. Speken.
6. At all times relevant hereto, defendant COLUMBIA PRESBYTERIAN
MEDICAL CENTER, furnished and/or provided physicians, surgeons, residents,
interns, nurses and other medical personnel at said hospital to afford medical
care, advice, referral, recommendations, management and treatment to the general
public, including plaintiffs’ decedent, Seth B. Speken.
7. At all times relevant hereto, defendant COLUMBIA PRESBYTERIAN
MEDICAL CENTER, represented that its employees, servants, agents, affiliated
physicians, surgeons, residents, interns, nurses, aides and medical personnel at
said medical hospital were capable, competent and qualified to properly and
adequately order, recommend, request, advise, perform, render or provide all of
the professional examinations, evaluations, consultations, care, treatments,
procedures, tests, studies, services and advice ordered, recommended, requested,
required and advised for, performed upon, rendered and/or provided to plaintiffs’
decedent, Seth B. Speken.