EXHIBIT 3 

EXHIBIT 3 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 1 of 46
KNAPP & ROBERTS, P.C. 

8777 North Gainey Center Drive, Suite 165 

2 Scottsdale, Arizona 85258 

C' :, 

2.J i i JUL I I AM 11 : 4 9 

IY~-'-~.J..-.l___.~~~~ 

OEPUT Y 

3 (480)991-7677 

Craig A. Knapp, Esq. (013580) knapp@krattomeys.com 

4 David S. Friedman, Esq. ( 029943) friedman@krattomeys.com 

5 Attorneys for Plaintiffs 

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IN THE SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF PINAL 

9 DEAN MICHAEL WATT, a minor, by and 

through his natural parents; HAYLEY 

10 HOLLAND-HONEA and ALY AN WATT, 

l l individually, 

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Plaintiffs, 

v. 

15 BANNER HEAL TH, an Arizona 

corporation d/b/a BANNER CASA 

16 GRANDE MEDICAL CENTER; DANIEL 

17 ROWLAND, M.D., a Nebraska resident; 

SUN LIFE FAMILY HEAL TH CENTER, 

18 an Arizona corporation d/b/a SUN LIFE 

19 CENTER FOR WOMEN: CHARLOTTE 

SONO-PETTY, R.N., an Arizona resident; 

20 JUDY QUICK, R.N., an Arizona resident; 

DOES 1-X; CORPORATIONS 1-X; and 

PARTNERSHIPS 1-X, 21 

Defendants. 

Case No. eL~Zo l'if- 0 / 20 ~ 

COMPLAINT 

BFU:NOA E. OLDHAM 

{Tort: Non-Motor-Vehicle; 

Medical Malpractice) 

DEMAND FOR 

TRIAL BY JURY 

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For their Complaint against Defendants, and each of them, Plaintiff Dean Michael Watt, a 

minor, by and through his natural parents, Plaintiffs Hayley Holland-Honea and Alyan Watt, who 

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also assert claims on their individual behalf, allege as follows: 

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General Allegations 

This Court has jurisdiction over this pleading's subject matter. 

Defendants have done and continue to do business in Arizona, have committed 

tortious acts, in whole or in part, in Arizona, have continuous and systematic contacts with 

Arizona, and are thus amenable to jurisdiction by an Arizona court. Accordingly, this Court has 

personal jurisdiction ovi.:r all Defendants under substantive Arizona and federal law, and under 

the Arizona Rules of Ci Yi I Procedure. 

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Venue is proper in Maricopa County. 

The minimum jurisdictional amount is established for filing this action in Arizona 

Superior Court. 

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Plaintiffs 

Plaintiff Dean Michael Watt, a minor, was born on July 12, 2015. 

Plaintiff Dean Michael Watt brings his claims for relief by and through his natural 

14 parents, Plaintiffs Hayley Holland-Honea and Alyan Watt. 

15 7. At all times material to this action, Plaintiffs Hayley Holland-Honea and Alyan 

16 Watt have resided, and continue to reside, in Pinal County. 

17 8. In addition to the claims they assert on behalf of their minor son, Plaintiffs Hayley 

18 Holland-Honea and Alyan Watt assert claims on their own respective behalves, individually, as 

19 mother and father of Plaintiff Dean Michael Watt. 

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Defendant Banner Health 

("Banner") 

At all timi.:s material to this action, Defendant Banner Health ["Banner"] was an 

Arizona corporation authorized to conduct business, and regularly conducting business, in Pinal 

County, Arizona doing business as Banner Casa Grande Medical Center. 

10. At all times material tot his action, Defendant Banner was a "healthcare provider" 

as that term is used within the Arizona Medical Malpractice Act, A.R.S. §§ 12-561 to 12-573, 

authorized to engage in the business of providing healthcare and medical services to members of 

the public, including to its patients, Plaintiffs Dean Michael Watt and Hayley Holland-Honea. 

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11. At all times material to this action, a hospital/patient and healthcare-provider/patient 

2 relationship existed between Plaintiffs Dean Michael Watt and Hayley Holland-Honea, and 

3 Defendant Banner. 

4 12. At all times material to this action, Defendant Banner owned and operated, or 

5 participated in owning and operating, a hospital and retained, employed, and allowed the services 

6 of doctors, nurses, technicians, and other healthcare professionals, including, but not limited to, 

7 Defendants Daniel Rowland, M.D., Charlotte Sono-Petty, R.N., Judy Quick, R.N., and the other 

8 labor, delivery, and newborn healthcare professionals who provided care to and for Plaintiffs 

9 Dean Michael Watt and Hayley Holland-Honea. 

10 13. At all times material to this action, Defendant Banner acted directly and through its 

11 actual, apparent, inherent, and/or ostensible agents or employees, including, but not limited to, 

12 Defendants Daniel Rowland, M.D., Charlotte Sono-Petty, R.N., Judy Quick, R.N., and the 

13 various medical, labor, delivery, nursing and other healthcare professionals who provided care to 

14 Plaintiff Dean Michael Watt at Defendant Banner. 

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14. Defendant Banner held those doctors, nurses, technicians, and other healthcare 

professionals out to the public as being competent in the care of pregnant women and newborn 

children. 

15. Both directly, through hospital corporate liability or negligent hiring/training 

practices, and vicariously, through principles of respondeat superior, ostensible agency, apparent 

agency, nondelegable duty, joint venture, Defendant Banner is liable and responsible for the acts 

and omissions of the dodors, nurses, technicians, and other hospital and healthcare personnel 

who provided hospital, medical, and healthcare services to and for Plaintiffs Dean Michael Watt 

and Hayley Holland-Honea at Defendant Banner's hospital facilities. 

Defendant Daniel Rowland, M.D. 

("Dr. Rowland") 

16. At all times material to this action, Defendant Daniel Rowland, M.D. ["Dr. 

Rowland"] was an Arizona resident and a physician duly licensed by the State of Arizona. 

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17. At all times material to this action, Defendant Dr. Rowland was a healthcare 

2 provider regularly conducting business and engaging in the practice of obstetrical and 

3 gynecological medicine in Pinal County, Arizona including, but not limited to, at Defendant 

4 Banner. 

5 18. At all times material to this action, Defendant Dr. Rowland was a "healthcare 

6 provider" as that term is used within the Arizona Medical Malpractice Act, A.R.S. §§ 12-561 to 

7 12-573, and authorized to engage in the business of providing healthcare and medical services to 

8 members of the public. including to his patients, Plaintiffs Dean Michael Watt and Hayley 

9 Holland-Honea. 

10 19. At all times material to this action, a doctor-patient and healthcare-provider/patient 

11 relationship existed between Defendant Dr. Rowland and Plaintiffs Dean Michael Watt and 

12 Hayley Holland-Honea. 

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20. At all times material to this action, Defendant Dr. Rowland acted individually, on 

behalf of his medical practice, namely, Defendant Sun Life Family Health Center, an Arizona 

corporation doing business as Sun Life Center for Women. 

21. At all tim1.:s material to this action, Defendant Dr. Rowland acted individually, and 

as an actual, apparent, inherent, and ostensible agent of Defendant Banner. 

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Defendant Sun Life Family Health Center 

("Sun Life") 

Upon information and belief, at all times material to this action, Defendant Sun Life 

Family Health Center ['"Sun Life"] was an Arizona corporation authorized to conduct business, 

and regularly conducting business, in Pinal County, Arizona under the trade name of Sun Life 

Center for Women. 

23. At all times material to this action, Defendant Sun Life was a "healthcare 

provider(s)" as that term is used within the Arizona Medical Malpractice Act, A.R.S. §§ 12-561 

to 12-573, authorized to engage in the business of providing healthcare and medical services to 

members of the public, including to Plaintiffs Dean Michael Watt and Hayley Holland-Honea. 

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24. At all times material to this action, a doctor-patient or healthcare provider-patient 

2 relationship existed between Defendant Sun Life and Plaintiffs Dean Michael Watt and Hayley 

3 Holland-Honea. 

4 25. At all times material to this action, Defendant Sun Life acted directly and through 

5 its actual, apparent, inherent, and/or ostensible agents, principals, servants and/or employees, 

6 including, but not limited to Defendant Dr. Rowland, who acted within the scope of their agency 

7 and/or employment. 

8 26. Defendant Sun Life held those doctors, nurses, technicians, and other healthcare 

9 professionals out to the public as being competent in the care of pregnant women and newborn 

10 children. 

11 27. Both directly, through negligent hiring/training practices, and vicariously, through 

12 principles of respondeat superior, ostensible agency, apparent agency, nondelegable duty, joint 

13 venture, Defendant Sun Life is liable and responsible for the acts and omissions of the healthcare 

14 personnel and professionals who provided healthcare services to and for Plaintiffs Dean Michael 

15 Watt and Hayley Holland-Honea at Defendant Banner's hospital facilities. 

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Defendants Charlotte Sono-Petty, R.N. and Judy Quick, R.N. 

("Hospital Nurses") 

28. At all times material to this action, Defendants Charlotte Sono-Petty, R.N. and Judy 

Quick, R.N. ["Hospital Nurses"] were Arizona residents and licensed nurses providing medical, 

nursing, or healthcare services on behalf of Defendant Banner for Plaintiffs Dean Michael Watt 

and Hayley Holland-Honea. 

29. At all times material to this action, the Defendant Hospital Nurses were authorized 

to engage in, and were engaged in, the business of providing medical, nursing, or healthcare 

services to the public, including to Plaintiffs Dean Michael Watt and Hayley Holland-Honea. 

30. Each of the Defendant Hospital Nurses was a "nursing," "medical," or "healthcare 

provider," as those terms are used in the Arizona Medical Malpractice Act, A.R.S. §§ 12-561, et 

seq. 

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31. At all times material to this action, a healthcare provider/patient relationship existed 

2 between the Defendant Hospital Nurses and Plaintiffs Dean Michael Watt and Hayley Holland3 Honea. 

4 Doe Defendants 

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32. Defendants DOES I-X are citizens or residents of the State of Arizona. 

33. Defendants PARTNERSHIPS I-X and CORPORATIONS I-X are authorized to 

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34. Defendants DOES I-X, PARTNERSHIPS I-X, and CORPORATIONS I-X are 

individuals, corporations, partnerships, and/or business entities that caused the events asserted 

herein to occur within the State of Arizona. Plaintiffs do not yet know the true identities of these 

Defendants and therefore name them in this pleading fictitiously. Plaintiffs will amend their 

pleading accordingly if and when the names of these Defendants and their respective roles in this 

matter become known. 

COUNTI 

(Medical Negligence/Malpractice) 

35. Plaintiffs incorporate by reference, and thereby re-allege, the foregoing allegations 

and paragraphs of this pleading as though fully set forth herein. 

36. This is a medical malpractice case arising from the negligent labor, delivery, and 

birth concerning Plaintiffs Hayley Holland-Honea and Plaintiff Dean Michael Watt. 

3 7. This claim for relief is brought under the provisions of the Arizona Medical 

Malpractice Act, A.R.S. §§ 12-561, et seq. 

38. Defendants. and each of them, provided healthcare services to Plaintiffs Dean 

Michael Watt and Hayley Holland-Honea. 

39. Plaintiffs Dean Michael Watt and Hayley Holland-Honea explicitly or implicitly 

agreed with Defendants that Plaintiffs would submit to Defendants' medical, nursing, or 

healthcare services. 

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40. Likewise, Defendants explicitly or implicitly agreed to examine, diagnose, and treat 

Plaintiffs Dean Michael Watt and Hayley Holland-Honea with the care, skill, and diligence 

consistent with their positions as healthcare providers. 

41. Plaintiff Dean Michael Watt was born on July 12, 2015, at which time Plaintiff 

Hayley Holland-Honea was 18 years of age, standing 4' 11 tall. 

42. During her pregnancy, Plaintiff Hayley Holland-Honea was under the care of 

Defendants Dr. Rowland and Sun Life for obstetrician and antepartum services. 

43. Prior to Plaintiff Dean Michael Watt's birth, upon information and belief, 

Defendants had not documented Plaintiff Hayley Holland-Honea's pregnancy as high-risk or as 

otherwise complicated. 

44. On July 8. 2015, Defendant Dr. Rowland documented his scheduling of Plaintiff 

Hayley Holland-Honea for an elective labor induction to take place on July 11, 2015. 

45. Upon information and belief, there was no medical indication or need for Plaintiff 

Hayley Holland-Honea to undergo this elective labor induction. 

46. As of July J 1, 2015, Plaintiff Hayley Holland-Honea was at 39 weeks and one day 

gestation. 

47. On July 11, 2015, Plaintiff Hayley Holland-Honea was admitted to Defendant 

Banner for the elective labor induction ordered by Defendant Dr. Rowland. 

48. At 10:03 a.m. on July 11, 2015, Defendant Dr. Rowland ordered the induction to be 

performed with Cytotec, 25 mcg. every four hours. 

49. Upon information and belief, a Bishop's score was not taken pnor to the 

administration of Cytotec. a strong inducifacient agent. 

50. Upon information and belief, prior to the administration of Cytotec, Plaintiff Dean 

Michael Watt's fetal weight was not estimated, his cephalic fetal position was not verified, and 

pelvic adequacy was not evaluated for relatively small, 4' 11 Plaintiff Hayley Holland-Honea. 

51. Upon information and belief, Defendant Judy Quick, R.N. administered the only 

recorded dose of Cytotcc at 10:38 a.m. on July 11, 2015. If accurate, this would have been in 

contradiction to Defendant Dr. Rowland's Order of 10:03 a.m. on July 11, 2015. 

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52. At or about 2:53 p.m. on July 11, 2015, Plaintiff Hayley Holland-Honea's 

membranes ruptured. 

53. At or about 5:45 p.m. on July 11, 2015, Defendant Judy Quick, R.N. noted variable 

Fetal Heart Rate Decelerations dropping to 60 beats per minute lasting for 30 seconds. 

54. At or about 6:15 p.m. on July 11, 2015, Defendant Judy Quick, R.N. noted variable 

Fetal Heart Rate Decelerations dropping to 20 beats per minute lasting for 20 seconds. 

55. Variable Fetal Heart Rate Decelerations continued to be noted in Defendant 

Banner's medical records over approximately the next eight hours of labor. 

56. Defendant Banner's medical records indicate that Plaintiff Dean Michael Watt was 

exhibiting signs of fetal labor intolerance. 

57. Nonetheless, upon information and belief, neither Defendant Hospital Nurses nor 

Defendant Dr. Rowland took available or appropriate action in response to these decelerations, 

such as resuscitation measures to improve fetal oxygenation. 

58. At 7:00 p.m. on July 11, 2015, "Tachysystole" is noted, e.g., that Plaintiff Hayley 

Holland-Honea was experiencing six uterine contractions every 10 minutes, thereby not 

permitting enough time between contractions for the fetus to adequately recover. 

59. Nonetheless, upon information and belief, neither Defendant Hospital Nurses nor 

Defendant Dr. Rowland took available or appropriate action to reduce the frequency of the uterine 

contractions or to improve blood delivery to the fetus. 

60. Likewise, Defendant Dr. Rowland's note of 8:06 p.m. on July 11, 2015 mentions 

nothing concerning variable or late decelerations, indeterminate Category II tracings, 

Tachysystole, or uterine hypestimulation. Instead, Defendant Dr. Rowland's note at this time 

indicates a "Reassuring fetal heart rate." 

61. In what, upon information and belief, is the only documented written order 

concerning Pitocin, entered by Defendant Dr. Rowland at 9:57 a.m. on July 11, 2015, the doctor 

indicates that it is only to be administered "AFTER DELIVERY OF PLACENTA. To control 

uterine bleeding. 2 doses max." [Emphasis in original]. 

62. Although Defendant Banner's medical records indicate that the placenta was not 

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delivered until 12:35 a.111. on July 12, 2015, and despite the fact that the fetus exhibited signs of 

labor intolerance, including but not limited to late and variable decelerations, Defendant Charlotte 

Sono-Petty, R.N. nonetheless administered Pitocin to Plaintiff Hayley Holland-Honea prior to 

placental delivery, e.g., at 8:21 p.m. on July 11, 2015. 

63. By 10:30 p.m. on July 11, 2015, while Plaintiff Hayley Holland-Honea had already 

been noted to be fully dilated, Defendant Charlotte Sono-Petty, R.N. documents that Plaintiff 

Dean Michael Watt was tachycardic with a heart rate in the 170s, with variable Fetal Heart Rate 

Decelerations down to 90 beats per minute. 

64. Upon information and belief, neither Defendant Hospital Nurses nor Defendant Dr. 

Rowland took available or appropriate action to address these variable decelerations. 

65. Rather, Defendants apparently permitted Plaintiff Hayley Holland-Honea to 

continue pushing for approximately the next two hours. 

66. A Caesarian section was not performed. 

67. Defendant Banner's medical records indicate that Plaintiff Dean Michael Watt was 

delivered at 12:27 a.m. on July 12, 2015, after enduring a shoulder dystocia. 

68. During this labor or delivery process, Plaintiff Dean Michael Watt sustained injuries 

including, but not limited to, a left parietal skull fracture, prominent posterior cephalohematoma, 

intracranial hematoma with intracranial hemmohage, a massive subgaleal hemorrhage, cerebral 

edema, periorbital edema, respiratory distress requiring oxygen, and significant right arm and 

back bruising. 

69. In the one, five, and ten-minute intervals post-birth, Defendant Banner's medical 

records indicate that Plaintiff Dean Michael Watt exhibited Apgar scores of two, four, and seven, 

respectively. 

70. Plaintiff Dean Michael Watt was transferred and admitted to Banner Desert Medical 

Center at 4:00 p.m. on July 12, 2015, where he underwent a course consistent with "birth 

depression, subgaleal and intracranial hemorrhages, seizures, [ disseminated intravascular 

coagulopathy], renal failure, hypoxic liver injury." 

71. Defendants negligently failed to provide full, systematic, competent, and proper 

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monitoring of the progress of Plaintiff Hayley Holland-Honea's labor. 

72. Defendants then negligently and traumatically executed the delivery of Plaintiff 

Dean Michael Watt, causing him to suffer acute skull and brain injuries. 

73. As a result of these severe and permanent injuries, Plaintiff Dean Michael Watt will 

continue to suffer lifelong physical, emotional, and developmental disabilities. 

74. Defendants. and each of them, owed a non-delegable duty to Plaintiffs Dean 

Michael Watt and Hayley Holland-Honea to exercise that degree of reasonable care and skill 

exercised by like healthcare professionals, hospitals, physicians, or nurses of good standing 

providing obstetrical, perinatal, or newborn care under the same or similar circumstances. 

75. Defendants. and each of them, acting directly and/or through their actual, apparent, 

inherent, or ostensible agents, servants, principals, and/or employees, were negligent and deviated 

from the generally accepted standards of medical and hospital care. 

76. Defendant Dr. Rowland's acts, errors, or omissions falling below the applicable 

standard of care include. but are not limited to, inducing labor in Plaintiff Hayley Holland-Honea 

without taking adequate preventative measures to ensure her fetus' safety. 

77. Defendant Dr. Rowland's acts, errors, or omissions falling below the applicable 

standard of care include. hut are not limited to, failing to communicate adequately with Defendant 

Hospital Nurses. 

78. Defendant Dr. Rowland's acts, errors, or omissions falling below the applicable 

standard of care include. but are not limited to, allowing Pitocin to be administered in a manner 

directly contrary to his Order. 

79. Defendant Dr. Rowland's acts, errors, or omissions falling below the applicable 

standard of care include. but are not limited to, allowing Pitocin to be administered when the fetus 

had already exhibited hours of Category II tracings with ongoing variable decelerations, late 

decelerations, and tachysystole. 

80. Defendant Dr. Rowland's acts, errors, or omissions falling below the applicable 

standard of care include. but are not limited to, failing to take appropriate measures in preparation 

for or in response to signs of fetal labor intolerance. 

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1 81. Defendant Dr. Rowland's acts, errors, or omissions falling below the applicable 

2 standard of care include. but are not limited to, allowing Plaintiff Hayley Holland-Honea to push 

3 for hours while the fetus was exhibiting signs of labor intolerance. 

4 82. Defendant Dr. Rowland's acts, errors, or omissions falling below the applicable 

5 standard of care include, but are not limited to, failing to perform a Caesarian section in 

6 consideration of the circumstances, such as Plaintiff Hayley Holland-Honea's prolonged labor 

7 and signs of fetal labor intolerance. 

8 83. Defendant Dr. Rowland's acts, errors, or omissions falling below the applicable 

9 standard of care include. but are not limited to, performing the acutely traumatic delivery of 

10 Plaintiff Dean Michael Watt that caused him to sustain injuries as severe as a skull fracture with 

11 intracranial hemorrhages. 

12 84. Defendant I lospital Nurses' acts, errors, or omissions falling below the applicable 

13 standard of care include. but are not limited to, failing to communicate adequately with Defendant 

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85. Defendant I Iospital Nurses' acts, errors, or omissions falling below the applicable 

standard of care include. but are not limited to, administering Pitocin in a manner directly 

contrary to Dr. Rowland's Order. 

86. Defendant I Iospital Nurses' acts, errors, or omissions falling below the applicable 

standard of care include, but are not limited to, administering Pitocin when the fetus had already 

exhibited hours of Category II tracings with ongoing variable decelerations, late decelerations, 

and tachysystole. 

87. Defendant Hospital Nurses' acts, errors, or omissions falling below the applicable 

standard of care include. but are not limited to, failing to take appropriate measures in response to 

signs of fetal labor intolerance. 

88. Defendant I Iospital Nurses' acts, errors, or omissions falling below the applicable 

standard of care include. but are not limited to, allowing Plaintiff Hayley Holland-Honea to push 

for hours while the fetus was exhibiting signs of labor intolerance. 

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89. Defendant Hospital Nurses' acts, errors, or omissions falling below the applicable 

standard of care include, but are not limited to, the extent to which they negligently caused or 

contributed to the acutely traumatic delivery of Plaintiff Dean Michael Watt that caused him to 

sustain injuries as severe as a skull fracture with intracranial hemorrhages. 

90. Defendants· negligence directly and proximately caused, or contributed to causing, 

the harms, damages, and injuries that Plaintiffs suffered. 

91. Plaintiff Dean Michael Watt, by and through his natural parents, Plaintiffs Hayley 

Holland-Honea and Alyan Watt, seeks to recover reasonable damages for the permanent injuries 

he has sustained due to Ddendants' negligence. 

92. As a direct and proximate result of the Defendants' negligence, Plaintiff Dean 

Michael Watt has suffered, and will continue to suffer for the remainder of his natural life, pain, 

distress, discomfort, disfigurement, impairment, disability, anxiety, and inconvenience. 

93. As a direct and proximate result of the Defendants' negligence, Plaintiff Dean 

Michael Watt sustained. and will continue to sustain for the remainder of his natural life, a loss of 

enjoyment of life. 

94. As a direct and proximate result of the Defendants' negligence, Plaintiff Dean 

Michael Watt will sustain a loss of earning capacity. 

95. As a direct and proximate result of the Defendants' negligence Plaintiff Dean 

Michael Watt has undergone, and will continue to undergo for an indefinite period of time, 

reasonable and necessary medical treatment, rehabilitative care, special-needs attention and care, 

vocational education, and/or other treatment and therapy, in a total amount that will be proven at 

trial. 

96. As a direct and proximate result of the Defendants' negligence, Plaintiffs, and each 

of them, have incurred expenses, and will continue to incur expenses for an indefinite period of 

time, for reasonable and necessary medical treatment, rehabilitative care, special-needs attention 

and care, vocational education, and/or other treatment and therapy, in a total amount that will be 

proven at trial. 

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1 97. As a direct and proximate result of the Defendants' negligence, Plaintiffs, and each 

2 of them, have incurred expenses, and will continue to incur expenses for an indefinite period of 

3 time, for special adaptive living necessities, including but not limited to transportation and in the 

4 home. 

5 98. As a direct and proximate result of the Defendants' negligence, Plaintiffs Hayley 

6 Holland-Honea and Alyan Watt have suffered, and will continue to suffer for the remainder of 

7 their or their son's natural life, a loss of parental consortium, including but not limited to a loss of 

8 affection, companionship. and love. 

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10 WHEREFORE, Plaintiffs seek judgment against Defendants, and each of them, as 

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For reasonable actual, general, and compensatory damages, in an amount to be 

determined at trial; 

For reasonable special damages in an amount to be determined at trial; 

For costs of suit incurred herein and accruing; and 

For such other and further relief as the Court deems just and proper. 

Jury Demand 

Plaintiffs demand a trial by jury on all claims so triable in this action. 

DATED this 11th day of July, 2017. 

KNAPP & ROBERTS, P.C. 

! 

; 

1gA. Knapp 

David S. Friedman 

8777 North Gainey Center Drive, Suite 165 

Scottsdale, Arizona 85258 

Attorneys for Plaintiffs 

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In the Superior Court of the State of Arizona 

In and For the County of _P_i_n_al ____ _ 

Case Number G vZDl1 D f Z0 '-f 

CIVIL COVER SHEET-NEW FILING ONLY 

(Please Type or Print) 

Plaintiff's Attorney Craig A. Knapp, Esq. 

Attorney Bar Number 013580 

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Plaintiff's Name(s): (List all) 

Dean Michael Watt, a minor, by and 

through his natural parents, Hayley 

BRENDA E. OLOHAM 

Plaintiff's Address: 

c/a Craig A Knapp, Esq 

Knapp & Roberts 

Holland-Honea and Alyan Watt, Individually. 8777 N. Gainey Ctr Dr., Ste 165, Scottsdale, AZ 85258 

(List additional plaintiffs on page two and/or attach a separate sheet). 

Banner Health, dba Banner Casa Grande Medical Center; Daniel Rowland, M.D.; Defendant's Name(s): (List All) _____________________________ _ 

Sun Life Family Health Center dba Sun Life Center for Women; Charlotte Sono-Petty, R.N.; Judy Quick, R.N.; 

(List additional defendants on page two and/or attach a separate sheet) 

EMERGENCY ORDER SOUGHT: 0 Temporary Restraining Order D Provisional Remedy Dose 

0Election Challenge D Employer Sanction Oother -------------------- (Specify) 

0 RULE 8(h) COMPLEX LITIGATION APPLIES. Rule 8(i) of the Rules of Civil Procedure defines a "Complex Case" 

as civil actions that require continuous judicial management. A typical case involves a large number of witnesses, a 

substantial amount of documentary evidence, and a large number of separately represented parties. 

(Mark appropriate box on page two as to complexity, in addition to the Nature of Action case category). 

0JHIS CASE IS ELIGIBLE FOR THE COMMERCIAL COURT UNDER EXPERIMENTAL RULE 8.1. (Maricopa 

County only.) Rule 8.1 defines a commercial case and establishes eligibility criteria for the commercial court. Generally, a 

commercial case primarily involves issues arising from a business contract or business transaction. However, consumer 

transactions are not eligible. A consumer transaction is one that is primarily for personal, family or household purposes. 

Please review Rule 8.1 for a complete list of the criteria. See http://www.superiorcourt.maricopa.gov/commercialcourt/. You must check this box if this is an eligible commercial case. In addition, mark the appropriate box below in 

the "Nature of Action" case category. The words "eligible for commercial court" must appear in the caption of the 

original complaint. 

NATURE OF ACTION 

(Place an "X" next to the one case category that most accurately describes your primary case.) 

TORT MOTOR VEHICLE: 0Property Damage 

0Non-Death/Personal Injury 0Legal Malpractice 

0Property Damage 0Malpractice - Other professional 

Owrongful Death 0Premises Liability 

TORT NON-MOTOR VEHICLE: 0Slander/Libel/Defamation 

0Negligence Oother (Specify) _____ _ 

0Product Liability-Asbestos MEDICAL MALPRACTICE: 

0Product Liability - Tobacco 0Physician M.D. [i]Hospital 

0Product Liability - Toxic/Other 0Physician D.O Oother 

0Intentional Tort 

November 28, 2016 Page I 

SG 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 15 of 46
CONTRACTS: 

0Account (Open or Stated) 

0Promissory Note 

0Foreclosure 

0Buyer-Plaintiff 

0Fraud 

Oother Contract (i.e. Breach of Contract) 

0Excess Proceeds-Sale 

Oconstruction Defects (Residential/Commercial) 

Osix to Nineteen Structures 

0Twenty or More Structures 

OTHER CIVIL CASE TYPES: 

0Eminent Domain/Condemnation 

0Eviction Actions (Forcible and Special Detainers) 

Dchange of Name 

0Transcript of Judgment 

0Foreign Judgment 

OQuiet Title 

0Forfeiture 

0Election Challenge 

0NCC- Employer Sanction Action (A.R.S. §23-212) 

0Injunction against Workplace Harassment 

0Injunction against Harassment 

Ocivil Penalty 

Dwater Rights (Not General Stream Adjudication) 

0Real Property 

Dsexually Violent Person (A.R.S. §36-3704) 

(Except Maricopa County) 

0Minor Abortion (See Juvenile in Maricopa County) 

Ospecial Action against Lower Courts 

(See lower court appeal cover sheet in Maricopa) 

0Immigration Enforcement Challenge (§§1-501, 1-502, 

11-1051) 

UNCLASSIFIED CIVIL: 

0Administrative Review 

(See lower court appeal cover sheet in Maricopa) 

0Tax Appeal 

(All other tax matters must be filed in the AZ Tax Court) 

0Declaratory Judgment 

0Habeas Corpus 

0Landlord Tenant Dispute- Other 

0Restoration of Civil Rights (Federal) 

0Ciearance of Records (A.R.S. § 13-4051) 

0Declaration of Factual Innocence (A.R.S. §12-771) 

0Declaration of Factual Improper Party Status 

Dvulnerable Adult (A.R.S. §46-451) 

0Tribal Judgment 

Dstructured Settlement (A.R.S. § 12-2901) 

0Attomey Conservatorships (State Bar) 

Dunauthorized Practice of Law (State Bar) 

Oout-of-State Deposition for Foreign Jurisdiction 

Dsecure Attendance of Prisoner 

0Assurance of Discontinuance 

0In-State Deposition for Foreign Jurisdiction 

0Eminent Domain- Light Rail Only 

0Interpleader- Automobile Only 

0Delayed Birth Certificate (A.R.S. §36-333.03) 

0Employment Dispute- Discrimination 

0Employment Dispute-Other 

Oother (Specify) __________ _ 

COMPLEXITY OF THE CASE 

If you marked the box on page one indicating that Complex Litigation applies, place an "X" in the box of no 

less than one of the following: 

DAntitrust/Trade Regulation 

0Construction Defect with many parties or structures 

0Mass Tort 

0Securities Litigation with many parties 

0Environmental Toxic Tort with many parties 

0Class Action Claims 

Dinsurance Coverage Claims arising from the above-listed case types 

DA Complex Case as defined by Rule S(i) ARCP 

Additional Plaintiff(s) 

Additional Defendant(s) 

November 28, 2016 Page 2 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 16 of 46
KNAPP & ROBERTS, P.C. 

8777 North Gainey Center Drive, Suite 165 

2 Scottsdale, Arizona 85258 

(480) 991-7677 

20 U JUL I I Mi II : Li 9 

IY_ ~0 

3 Craig A. Knapp, Esq. (013580) knapp@krattorneys.com DEPUT'( 

4 David S. Friedman, Esq. (029943) friedman@krattorneys.com 

5 Attorneys for Plaintiffs 

6 

7 

8 

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF PINAL 

9 DEAN MICHAEL WATT, a minor, by and 

through his natural parents; HAYLEY 

10 HOLLAND-HONEA and AL YAN WATT, 

11 individually, 

12 

13 

14 

Plaintiffs, 

V. 

15 BANNER HEAL TH, an Arizona 

corporation d/b/a BANNER CASA 

16 GRANDE MEDICAL CENTER; DANIEL 

17 ROWLAND, M.D., a Nebraska resident; 

SUN LIFE FAMILY HEAL TH CENTER, 

18 an Arizona corporation d/b/a SUN LIFE 

19 CENTER FOR WOMEN; CHARLOTTE 

SONO-PETTY, R.N., an Arizona resident; 

20 JUDY QUICK, R.N., an Arizona resident; 

DOES I-X; CORPORATIONS 1-X; and 

PARTNERSHIPS I-X, 21 

Defendants. 

Case No. 

BRENDA E. OLDHAM 

CERTIFICATE OF COMPULSORY 

ARBITRATION 

22 

23 

24 

25 

26 

Pursuant to Rule 72( e ), Arizona Rules of Civil Procedure, the undersigned certifies that he 

27 or she knows the dollar limits and any other limitations set forth by the local rules of practice for 

28 the applicable superior court, and further certifies that this case IS NOT subject to compulsory 

8 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 17 of 46
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arbitration, as provided by Rules 72 to 77 of the Arizona Rules of Civil Procedure. 

DATED this 10th day of July, 2017. 

KNAPP & ROBERTS, P.C. 

David S. Friedman 

8777 North Gainey Center Drive, Suite 165 

Scottsdale, Arizona 85258 

Attorneys for Plaintiffs 

2 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 18 of 46
SUPERIOR COURT OF ARIZONA 

PINAL COUNTY 

ALEO 

AMANDA STANFORD 

CLERK • SUPERIOR COURT 

JUL I I 2017 

Time: II_: 4gAH By: --~::-:-.L....1-..L1..L:..L--

cAsE NUMBER: cv ~o I Jo /2--0 if 

NOTICE OF IMPENDING DISMISSAL FOR 

FAILURE TO SERVE 

f3&1J612~W ~ HONORABLE: BRENDA E. OLDHAM 

Defendant(s) c~\... 

NOTICE AND WARNING: 

Pursuant to Rule 4(i), Arizona Rules of Civil Procedure, the Court shall dismiss the action 

without prejudice unless service is made upon a defendant within 90 days after the filing of the 

complaint. 

This is notice that your case will be dismissed without further notice after January _la __ 2018 at 9:00 ~ am D pm if you do not take at least one of the steps listed below. 

A. SERVE THE OTHER PARTY WITH THE COURT PAPERS AND FILE THE PROOF 

OF SERVICE. If you have served the other party, you must file proof of service with the 

Clerk of the Court immediately. 

B. MOTION AND ORDER TO CONTINUE ON THE INACTIVE CALENDAR: You may file 

a motion requesting additional time to complete the service of the court papers before 

the court automatically dismisses your case. The order granting the continuance must 

be SIGNED by the judge BEFORE the dismissal date indicated above. 

C. VOLUNTARY DISMISSAL OF YOUR CASE. You may dismiss your case instead of 

waiting for the Court Order of Dismissal. 

You may obtain appropriate documents and instructions from the Pinal County Clerk of 

the Superior Court website: http://coscpinalcountyaz.gov 

WARNING: Failure to comply with this notice may result in THE COURT DISMISSING YOUR 

CASE without prejudice. 

If you have legal questions, consult an attorney who practices in this area of the law and has the 

expertise you need. 

SG 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 19 of 46
1 KNAPP & ROBERTS, P.C. 

8777 North Gainey Center Drive, Suite 165 

2 Scottsdale, Arizona 85258 

e 

3 (480) 991-7677 

Craig A. Knapp, Esq. (013580) knapp@krattomeys.com 

4 David S. Friedman, Esq. (029943) friedman@krattomeys.com 

5 Attorneys for Plaintiffs \ . _ 

6 IN THE SUPERIOR COURT OF THE STATE~IZONA-----

7 

8 

IN AND FOR THE COUNTY OF PINAL 

9 DEAN MICHAEL WATT, a minor, by and 

through his natural parents; HAYLEY 

10 HOLLAND-HONEA and AL YAN WATT, 

11 individually, 

12 

13 

14 

Plaintiffs, 

V. 

15 BANNER HEAL TH, an Arizona 

corporation d/b/a BANNER CASA 

16 GRANDE MEDICAL CENTER; DANIEL 

17 ROWLAND, M.D., a Nebraska resident; 

SUN LIFE FAMILY HEAL TH CENTER, 

18 an Arizona corporation d/b/a SUN LIFE 

19 CENTER FOR WOMEN; CHARLOTTE 

SONO-PETTY, R.N., an Arizona resident; 

20 JUDY QUICK, R.N., an Arizona resident; 

DOES 1-X; CORPORATIONS 1-X; and 

PARTNERSHIPS 1-X, 

21 

Defendants. 

Case No. ()J ~lr)D\1/3·~ 

CERTIFICATION OF 

EXPERT TESTIMONY 

PURSUANT TO A.R.S. § 12-2603 

BRENDA e. OLDHAM 

22 

23 

24 

25 

26 

The undersigned certifies, pursuant to A.R.S. § 12-2603, that expert opinion testimony is 

necessary to prove the licensed professionals' standard of care or liability for the claims asserted 27 

28 in the Complaint, filed concurrently with this Certification of Expert Testimony. 

RCP 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 20 of 46
' : ~"'T- . 

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DATED this 10th day of July, 2017. 

KNAPP & ROBERTS, P.C. 

~]2J,p~ 

David S. Friedman 

8777 North Gainey Center Drive, Suite 165 

Scottsdale, Arizona 85258 

Attorneys for Plaintiffs 

2 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 21 of 46
AFFIDAVIT OF SERVICE 

Case: Court: County: 

CV201701294 Superior Court, State of Arizona Pinal, AZ 

Plaintiff/ Petitioner: Defendant I Respondent: 

Dean Michael Watt, Hayley Holland-Honea and Alyan Watt Daniel Rowland, M.D. 

Received by: For: 

Advanced Process Service Knapp & Roberts 

To be served upon: 

Daniel Rowland, M.D. 

Job: 

1672658 

BY OEPUlY 

I, Alan Gustafson, being duly sworn, depose and say: I am over the age of 18 years and not a party to this action, and that within the 

boundaries of the state where service was effected, I was authorized by law to make service of the documents and informed said person of 

the contents herein 

Recipient Name I Address: Daniel Rowland, M.D., Company: 4021 B Ave, Scottsbluff, NE 69361 

Manner of Service: 

Documents: 

Additional Comments: 

Personal/Individual, Sep 18, 2017, 3:01 pm MDT 

Complaint, Certificate of Expert Testimony, Certificate of Compulsory Arbitration and Summons {Received Sep 

15, 2017 at 1:14pm MDn 

1) Successful Attempt: Sep 18, 2017, 3:01 pm MDT at Company: 4021 B Ave, Scottsbluff, NE 69361 received by Daniel Rowland, M.D .. Age: 45; 

Ethnicity: Caucasian; Gender: Male; Weight: 150; Height: 5'6"; Hair: Blond; Eyes: Brown; 

Personal service to Dr. Rowland at his place of employment of The Womens Center. 

Fees: $45.00 

/\ I 

; ' J. ' 

/()'.' J, 

),,) 

~J 1,.' 

Alan Gustafson 

Advanced Process Service 

PO Box 1616 

Scottsbluff, NE 69363 

3086418116 

Date 

n GENERAL NOTARY -State of Nebraska 

8

1 JOAN M LASHLEY 

· 

1 

., My Conm Exp. April 24, 2018 

c- t •• ,·•·.' ~I,' ., i 1' 

Subscribed and sworn to before me by the affiant who is 

personally known to me. 

C\ o l'.4-"iv~ 

Notary Public 

~/q,J.0(7 

Date Commission Expires 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 22 of 46
- - IN THE SUPERIOR COURT OF THE STA TE OF ARIZONA /\M&1.N6~\1~~[SJ~t:n 

IN AND FOR THE COUNTY OF MAlMIDRA PINA1cLERK Of suer: R,,./' · 

DEAN MICHAEL WATT, 

Plaintiff __ , 

VS. 

BANNER HEALTH, et al., 

Defendant 

] 

] 

No. CV 2017-01294 2011 SEP 28 AH 10: 33 

MM 

] 

] 

ev-------:o:::-:E~P:-;':UT~Y-;-------

] AFFIDAVIT OF SERVICE OF 

] PROCESS BY PRIVATE PERSON 

] 

] 

] _____________ ] 

ST A TE OF ARIZONA ) 

COUNTY OF MARICOPA ) ss. 

Ray E. Currie, being sworn, states: That he is fully qualified to serve process 

in this cause, having been so appointed by the Court; that he received the _______ _ Summons & Complaint & Cert of Comp ARb., Expert Testimony 

in this action from Craig Knapp #013580 , Attorney. That he 

personally served the same on those names below, in the manner and at the time and place 

shown: 

SERVED: 

BANNER HEALTH dba BANNER CASA GRANDE MEDICAL CENTER, by service upon 

Statutory Agent, DAVID M. BIXBY, ACCEPTED BY GAIL HYDE, duly authorized to 

accept at her usual place of business at 2901 N. Central Ave., Phoenix, 

Arizona 85012, at 1:46 P.M. on September 18, 2017. 

~ Ray . urri 

Subscribed and sworn to before me on this 22 day of September , 20 17 

Service: $ ---- Miles: $ ---- Additional Mileage:_$ ___ _ 

Witness Fees: $ ---- Notary: $ ___ _ 

TOTAL: $ 50.00 ----

Ray E. Currie Investigations 

P.O. Box 33131, Phoenix, Az. 85067 

(602) 573-6135 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 23 of 46
- FILED 

IN THE SUPERIOR COURT OF THE STA TE OF ARIZ~Ot ,iIA~A2~R •psr 

IN AND FOR THE COUNTY Ofx~Jsl~fiRi,Lt:i±~lr:1"' tR,, ... 

DEAN MICHAEL WATT, 

Plaintiff __ , 

vs. 

BANNER HEALTH, et al., 

Defendant 

] No. CV 2017-01294 

20i1 SEP 28 AH t0: 32 

] 

] 

] 

ev--------~o~E~Ptt'UT~V;------- ~~ 

] AFFIDAVIT OF SERVICE OF 

] PROCESS BY PRIVATE PERSON 

] 

] 

] _________ ] 

ST A TE OF ARIZONA ) 

COUNTY OF MARICOPA ) ss. 

Ray E. Currie, being sworn, states: That he is fully qualified to serve process 

in this cause, having been so appointed by the Court; that he received the -~------ Summons & Complaint & Cert of Comp ARb. & Expert Testimony 

in this action from Craig Knapp #013580 , Attorney. That he 

personally served the same on those names below, in the manner and at the time and place 

shown: 

SERVED: 

JUDY QUICK, R.N., in person, at her usual place of business at Banner 

Casa GRande Medical Center, 1800 E. Florence Blvd. Casa GRande, Arizona 

85122, at 12:30 P.M. on September 21, 2017. 

Subscribed and sworn to before me on this _11 day of September , 20 11_. 

Service: $ 30. 00 

Miles: 58 $ 145 . 00 

Additional Mileage:_$ ___ _ 

Witness Fees: $ ---- Notary: & Aff. $ 10.00 

TOTAL: $ J ss an 

Ray E. Currie Investigations 

P.O. Box 33131, Phoenix, Az. 85067 

(602) 573-6135 

l , ·~ .~~""'· ',

··ii'.'"-·; ..,... 

\. .. ) ~-_-./~ 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 24 of 46
- - IN TIIE 1tu:~~l~tRC~~g0iJ~ ii ~~~~\16i,~~~rt?~t, 1 

DEAN MICHAEL WATT, ] 

] 

] 

] 

No.Cv 2017-01294 2011 SEP 28 AM IQ: 32 

Li\JV\J 

ev-------o=-=E:::Po:-:UT;";Y~-------

Plaintiff __ , 

vs. 

BANNER HEALTH, et al., 

Defendant 

] AFFIDAVIT OF SERVICE OF 

] PROCESS BY PRIVATE PERSON 

] 

] 

] _____________ ] 

ST A TE OF ARIZONA ) 

COUNTY OF MARI COP A ) ss. 

Ray E. Currie, being sworn, states: That he is fully qualified to serve process 

in this cause, having been so appointed by the Court; that he received the 

Summons & Complaint & Expert Testimony & Cert of co=m=p--.>-'AR-b~.------

in this action from Craig Knapp #013580 , Attorney. That he 

personally served the same on those names below, in the manner and at the time and place 

shown: 

SERVED: SUN LIFE FAMILY HEALTH CENTER dba SUN LIFE CENTER FOR WOMEN, by 

service upon Statutory Agent, STEPHEN R. COOPER, in person, at his 

usual place of business at 221 N. Florence St. Casa Granqe, Arizona 

85122, at 11:12 A.M. on September 21, 2017. 

Service: $ ----- Miles: $ ----- Additional Mileage:_$ ___ _ 

Witness Fees: $ ---- Notary: $ ___ _ 

TOTAL: $ 50.00 -----

~ 

Ray E. Currie Investigations 

P.O. Box 33131, Phoenix, Az. 85067 

(602) 573-6135 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 25 of 46
OFFICE OF THE CLERK OF THE SUPERIOR COURT 

AMANDA STANFORD 

PO BOX 2730 

FLORENCE, ARIZONA 85132 

Oct 6, 2017 

CLERK OF THE SUPERIOR COURT, PINAL COUNTY 

JURY COMMISSIONER/PROBATE REGISTRAR 

To SLATTERY PETERSEN PLLC 

Address 

5981 E GRANT ROAD SUITE 101 

TUCSON, AZ 85712 

Case CV201701294 

The Clerk of the Court is returning the following document(s): 

TELEPHONE: 520-866-5300 

FAX: 520-866-5320 

DEFENDANTS BANNER HEAL TH OBA BANNER CASA GRANDE MEDICAL CENTER CHARLOTTE 

SONO-PEIIY, RN AND JUDY QUICK RN'S ANSWER TO COMPLAINT AND DEMAND FOR JURY TRIAL 

Also enclosed is your ~ Check or D Money Order Number ~44=6~6 ______ in the amount of $_22_4_.o_o __ _ 

Received by our office on: ----~O-C~T=O~BE~R_6~------' 2017. 

For the following reason(s): 

::::J $ __ filing fee is due for the pleadings attached. If the filing fee is a hardship, you may print the deferral 

instructions and application at \vww.coscpinalcountyaz.gov/forms.html and submit the deferral as per instructions 

to the Clerk of the Court along with the Original pleadings. 

D The Clerk has researched the attached document(s) and the case number and/or party name(s) do not match any of 

those in our system. 

No originals provided. The Clerk must be in receipt of the Original document(s) for filing. The above 

mentioned document(s): 

Zl Do not have an original signature 

D Need to be notarized 

::::J Other: -----------

::::J The document(s) you have submitted do not comply with 16 A.R.S. Rules of Civil Procedure, Rule 5.2 (Formerly 

cited as AZ ST RCP Rule IO(d)) as to format: 

Revised 06.27.17 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 26 of 46
OFFICE OF THE CLERK OF THE SUPERIOR COURT 

AMANDA STANFORD 

PO BOX 2730 

FLORENCE, ARIZONA 85132 

[] Other: 

CLERK OF THE SUPERIOR COURT, PINAL COUNTY 

JURY COMMISSIONER/PROBATE REGISTRAR 

TELEPHONE: 520-866-5300 

FAX: 520-866-5320 

Please note that the Clerk of the Superior Court's Office cannot give any legal advice. For additional assistance 

please contact an attorney or paralegal. 

AMANDA ST P._NfORD 

Clerk of the Superior Court 

cc: AJACS x __ 

Return Letter File x 

Revised 06.27.17 

How are we doing? Your feedback is very important to us. Please take a moment to complete a very brief survey regarding your experience 

with Pinal County Clerk of the Superior Court. Thank you. https://www.surveymonkey.com/r/COSCFC 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 27 of 46
1 

2 

KNAPP & ROBERTS, P.C. 

8777 North Gainey Center Drive, Suite 165 

Scottsdale, Arizona 85258 

(480) 991-7677 

- ;: ! ! :-:- !"'"· 

f ; :_, - • 

:- \," 

3 Craig A. Knapp, Esq. (013580) knapp@krattomeys.com 

4 David S. Friedman, Esq. (029943) friedman@krattomeys.com 

5 Attorneys for Plaintiffs 

6 

7 

8 

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF PINAL 

9 DEAN MICHAEL WATT, a minor, by and 

through his natural parents; HAYLEY 

10 HOLLAND-HONEA and AL YAN WATT, 

11 individually, 

12 

13 

14 

Plaintiffs, 

V. 

15 BANNER HEAL TH, an Arizona 

corporation d/b/a BANNER CASA 

16 GRANDE MEDICAL CENTER; DANIEL 

17 ROWLAND, M.D., a Nebraska resident; 

SUN LIFE FAMILY HEAL TH CENTER, 

18 an Arizona corporation d/b/a SUN LIFE 

19 CENTER FOR WOMEN; CHARLOTTE 

SONO-PETTY, R.N., an Arizona resident; 

20 JUDY QUICK, R.N., an Arizona resident; 

DOES I-X; CORPORATIONS 1-X; and 

PARTNERSHIPS I-X, 21 

Defendants. 

Case No. CV201701294 

ACCEPTANCE OF SERVICE OF 

PROCESS 

(Assigned to the Hon. Brenda E. Oldham) 

22 

23 

24 

25 

26 

Pursuant to Rule 4(f)(2), Ariz.R.Civ.P., GinaMarie Slattery, Esq. of Slattery Petersen, 

PLLC. hereby acknowledges acceptance of service of the Complaint, Summons, Certificate on 

27 

28 Expert Testimony Pursuant to A.R.S. § 12-2603, and Certificate of Compulsory Arbitration in 

s 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 28 of 46
- - 1 

2 

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the above-captioned matter on behalf of Decedent Defendant Charlotte Sono-Petty, R.N. 

DATED this 4th day of October, 2017. 

ORIGINAL of the foregoing 9 mailed for filing with the Court 

IO this 4th day of October, 2017, to: 

11 

12 

13 

14 

Clerk of Court 

Pinal County Superior Court 

971 N. Jason Lopez Circle, Bldg. A 

Florence, Arizona 85232 

:: By:~ vy'~ 

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SLATTERY PETERSEN, PLLC 

GinaMarie Slattery, Esq. J 

Attorneys for Defendants Banner Health, Charlotte SonoPetty, R.N., and Judy Quick, R.N. 

2 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 29 of 46
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2 

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~ 12 --.....;o 

o..,- \0 

~ 0 ~ "Z,,.~N ,_ 13 ~;:},_I 

[/') C/l t-- \0 ;:i2 "on N 

·~~ ~ :io ~ 14 e- ~ ~ 0 -~ N 

'·' ::,: V) 

s::: § ;:::" Q 

>- 15 .';:; § § c:c:v ;:;..C:: 

~;:j~~ 

~ - 0 16 l-"' 00 E-' 

< °' ' V) - 17 [/') 

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GinaMarie Slattery (#012867) 

SLATTERY PETERSEN PLLC 

5981 E. Grant Road, Suite 101 

Tucson, AZ 85712 

Telephone: (520) 326-1866 

Facsimile: (866) 323-9593 

gslattery@slatterypetersen.com 

Attorney for Banner Health dba 

Banner Casa Grande Medical Center, 

Charlotte Sona-Petty, RN, and Judy 

Quick, RN 

17 OCT 23 PM 12: i 0 

BY ~~TY 

IN THE SUPERIOR COURT FOR THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF PINAL 

DEAN MICHAEL WATT, a minor, by and 

through his natural parents; HALEY 

HOLLAND-HONEA and ALY AN WATT, 

individually, 

Plaintiffs, 

VS. 

BANNER HEALTH, an Arizona corporation 

d/b/a BANNER CASA GRANDE 

MEDICAL CENTER; DANIEL 

ROWLAND, M.D., a Nebraska resident; 

SUN LIFE FAMILY HEALTH CENTER, an 

Arizona corporation d/b/a SUN LIFE 

CENTER FOR WOMEN; CHARI~OTTE 

SONO-PETTY, RN., an Arizona resident; 

JUDY QUICK, RN., an Arizona Resident; 

DOES 1-X; CORPORATIONS 1-X; and 

PARTNERSHIPS 1-X, 

Defendants. 

No. CV201701294 

,,.,--

DEFEND ANTS BANNER HEALTH 

DBA BANNER CASA GRANDE 

MEDICAL CENTER, CHARLOTTE 

SONO-PETTY, RN, AND JUDY 

QUICK, RN'S ANSWER TO 

PLAINTIFFS' COMPLAINT 

(Assigned to Hon. Brenda E. Oldham) 

Defendants Banner Health dba Banner Casa Grande Medical Center, Charlotte 

Sono-Petty, RN, and Judy Quick, RN (collectively, "Banner Health"), through 

undersigned counsel, admit, deny, and aver as follows: 

-1-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 30 of 46
1 

2 

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~ ~~ 12 ~o 

"' ;:i.,~ 

C) "' 

z.<;::N ~ 13 ~ ;:::1 .- I 

{./Jrl)r--,\C 

~ .v; N "O 00 ("') 

~g~~ 14 

.• , a:: "' ~ § c· .. 15 0 0 

~ r~ V, § ~ '--: _g "E. 

C;..:.:: ~ ..3 ~ ....... CJ 16 ,... 00 i-

< '<r) °' - 17 VJ 

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General Allegations 

1. Answering Paragraph 1, Banner Health avers, upon information and belief, 

that this Court has jurisdiction over this pleading's subject matter, but Banner Health denies 

that any such events form the basis of liability against Banner Health. 

2. Answering Paragraph 2, Banner Health avers, upon information and belief, 

that this Court has jurisdiction over all Defendants but until such time as the specific 

provisions of Arizona law, federal law or the Arizona Rules of Civil Procedure are 

identified by Plaintiffs, Banner Health lacks sufficient information to respond as to their 

applicability to this matter. 

3. Answering Paragraph 3, Banner Health avers, upon information and belief, 

that venue is proper in Pinal County, 1 based upon Plaintiffs' allegations. 

4. Answering Paragraph 4, Banner Health avers, upon information and belief, 

that the minimal jurisdictional amount has been established for filing the action in Arizona 

Superior Court, but Banner Health denies that any such events form the basis of liability 

against Banner Health. 

Plaintiffs 

5. Answering Paragraph 5, Banner Health avers, upon information and belief, 

that Dean Michael Watt's date of birth is as alleged in Paragraph 5. 

6. Banner Health lacks knowledge or information sufficient to form a belief as 

to the truth of the allegations contained in Paragraph 6 and 7 concerning the relationship, 

residence, status or conduct of parties other than this Answering Defendant and therefore 

denies them. Further answering, Banner Health avers that Plaintiffs' pleadings speak for 

themselves. 

7. Banner Health lacks knowledge or information sufficient to form a belief as 

to the truth of the allegations contained in Paragraph 8 concerning Plaintiffs' relationship 

1 Banner Health assumes that Plaintiffs' reference to Maricopa County in Paragraph 3 of their Complaint was a 

clerical error, as they chose to file this action in Pinal County. 

-2-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 31 of 46
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and therefore denies them. Further answenng, Banner Health avers that Plaintiffs' 

pleadings speak for themselves. 

Defendant Banner Health 

8. Answering Paragraph 9, Banner Health avers that it is an Arizona 

corporation and at the time of the events in question was doing business as Banner Casa 

Grande Medical Center in Pinal County, Arizona. 

9. Answering Paragraph 10, Banner Health avers that it is a healthcare provider 

as that term is used in Arizona Medical Malpractice Act, A.RS. § 12-561, et seq., and was 

authorized to provide healthcare and did provide healthcare to Dean Michael Watt and 

Hayley Holland-Honea. All remaining allegations are denied. 

10. Answering Paragraph 11, Banner Health avers that at all times relevant to 

this action, Dean Michael Watt and Hayley Holland-Honea were patients of Banner 

Health. 

11. Answering Paragraph 12, Banner Health avers that, at all times relevant, it 

owned and operated Banner Casa Grande Medical Center. Further answering, Banner 

Health avers only that Charlotte Sono-Petty, RN and Judy Quick, RN were employees of 

Banner Health at the time of the events in question in this case and were working in the 

course and scope of their employment such that Banner Health is responsible for any 

proven acts of negligence committed by the aforementioned employees in the course and 

scope of their employment. Banner Health denies the remaining allegations contained in 

Paragraph 12, as Plaintiffs have failed to state, with specificity, the identities of "the 

doctors, nurses, technicians, and other healthcare professionals" and the "other labor, 

delivery, and newborn healthcare professionals who provided care to and for Plaintiffs 

Dean Michael Watt and Hayley Holland-Honea." The allegations with regard to these 

unnamed individuals are vague in that they fail to provide sufficient information 

concerning what role, if any, they played in the care and treatment rendered to Plaintiffs or 

-3-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 32 of 46
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their relationship, if any to Banner Health or to other named defendants. Banner Health 

denies that any of its employees were negligent. Further answering, Banner Health avers 

only that it is liable for any proven acts of negligent of its employees, acting within the 

course and scope of their employment. All remaining allegations contained in Paragraph 

12 are denied. 

12. Answering Paragraph 13, Banner Health avers only that Charlotte SonoPetty, RN and Judy Quick, RN were employees of Banner Health at the time of the events 

in question in this case and were working in the course and scope of their employment 

such that Banner Health is responsible for any proven acts of negligence committed by the 

aforementioned employees in the course and scope of their employment. Banner Health 

denies the remaining allegations contained in Paragraph 13, as Plaintiffs have failed to 

state, with specificity, the identities of "the various medical, labor, delivery, nursing and 

other healthcare professionals who provided care to Plaintiff Dean Michael Watt at 

Defendant Banner." The allegations with regard to these unnamed individuals are vague in 

that they fail to provide sufficient information concerning what role, if any, they played in 

the care and treatment rendered to Plaintiffs or their relationship, if any to Banner Health 

or to other named defendants. Banner Health denies that any of its employees were 

negligent. Further answering, Banner Health avers only that it is liable for any proven acts 

of negligent of its employees, acting within the course and scope of their employment. 

Banner Health denies that any of the Co-Defendants, including Dr. Rowland and Sun Life 

Family Health Center, are employees or agents of Banner Health under an actual agency, 

ostensible agency, respondeat superior, nondclcgablc duty or any other theory. All 

remaining allegations contained in Paragraph 13 are denied. 

13. Banner Health denies the allegations contained in Paragraph 14, as Plaintiffs 

have failed to state, with specificity, the identities of "those doctors, nurses, technicians, 

and other healthcare professionals" referred to therein. The allegations with regard to 

-4-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 33 of 46
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these unnamed individuals arc vague in that they fail to provide sufficient information 

concerning what role, if any, they played in the care and treatment rendered to Plaintiffs or 

their relationship, if any to Banner Health or to other named defendants. 

14. Answering Paragraph 15, Banner Health avers only that it is liable for any 

proven acts of negligence of its employees, acting within the course and scope of their 

employment. All remaining allegations arc denied. Banner Health denies that any of the 

Co-Defendants, including Dr. Rowland and Sun Life Family Health Center, are employees 

or agents of Banner Health under an actual agency, ostensible agency, respondeat 

superior, nondclcgable duty or any other theory, or that it is liable for negligent 

hiring/training practices or any other hospital corporate liability theory. All remaining 

allegations set forth in Paragraph 15 arc denied. 

Defendant Daniel Rowland, M.D. 

15. Answering Paragraphs 16-21, Banner Health lacks knowledge and 

information regarding the truth of the allegations pertaining to other defendants, other than 

to aver upon information and belief, that defendant Daniel Rowland, :MD, was a physician 

licensed by the State of Arizona at the time of the events alleged in this Complaint. To the 

extent the allegations in Paragraphs 16-21 are intended to apply to this Answering 

Defendant, Banner Health denies them. 

Defendant Sun Life Family Health Center 

16. Answering Paragraphs 22-27, Banner Health Jacks knowledge and 

information regarding the truth of the allegations pertaining to other defendants. To the 

extent the allegations in Paragraphs 22-27 arc intended to apply to this Answering 

Defendant, Banner Health denies them. 

Defendants Charlotte Sono-Petty, RN and Judy Quick, RN 

17. Answering Paragraph 28, Banner Health avers that Defendants Charlotte 

Sono-Petty, RN and Judy Quick, RN ("Hospital Nurses") were Arizona residents and 

-5-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 34 of 46
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licensed registered nurses providing healthcare services on behalf of Banner Health for 

Dean Michael Watt and Hayley Holland-Honea. 

18. Answering Paragraph 29, Banner Health avers that the Hospital Nurses were 

authorized to and did provide healthcare services to Dean Michael Watt and Hayley 

Holland-Honea, as more fully set forth in the medical records. 

19. Answering Paragraph 30, Banner Health avers that at all times relevant, the 

Hospital Nurses were healthcare providers within the meaning of A.RS. § 12-561 and 

were authorized to provide healthcare pursuant to the scope of their licenses as registered 

nurses. 

20. Answering Paragraph 31, Banner Health avers that a healthcare 

provider/patient relationship existed between the Hospital Nurses and Dean Michael Watt 

and Hayley Holland-Honea within the scope of the Hospital Nurses' licenses. 

Doe Defendants 

21. Answering Paragraphs 32-34, Banner Health lacks knowledge and 

information regarding the truth of the allegations pertaining to other defendants. To the 

extent the allegations in Paragraphs 32-34 are intended to apply to this Answering 

Defendant, Banner Health denies them. 

COUNTI 

(Medical Ncgligence/l\1alpractice) 

22. Answering Paragraph 35, Banner Health incorporates by reference each 

admission, denial, and avcrment to Paragraphs 1-34 of Plaintiffs' Complaint, as if set forth 

fully herein. 

23. Answering Paragraphs 36-37, Banner Health avers that this medicalmalpractice claim is brought under the Arizona Medical Malpractice Act, A.RS. § 12-561, 

et seq. but denies the remaining allegations. 

-6-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 35 of 46
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24. Answering Paragraph 38, Banner Health avers that at all times relevant to 

this pleading, Banner Health provided medical care and treatment to Dean Michael Watt 

and Hayley Holland-Honea. Banner Health denies the remaining allegations. 

25. Answering Paragraph 39, Banner Health avers that Dean Michael Watt and 

Hayley Holland-Honea were patients who were provided healthcare services at Banner 

Casa Grande Medical Center. Banner Health denies the remaining allegations contained in 

Paragraph 39. 

26. Answering Paragraph 40, Banner Health avers that Dean Michael Watt and 

Hayley Holland-Honea were patients who were provided healthcare services at Banner 

Casa Grande Medical Center and that Banner Health was required to exercise that degree of 

care, skill, and learning of a reasonably prudent healthcare provider in accordance with 

A.RS. § 12-563(1). Banner Health denies that it, or any of its employees or agents, were 

negligent or breached any legal duty to Plaintiffs, as alleged or at all. 

27. Answering Paragraphs 41-70, Banner Health avers that the medical records 

more accurately and completely reflect events that took place concerning Dean Michael 

Watt's and Hayley Holland-Honea's medical care that is the subject matter of this 

Complaint. To the extent that Plaintiffs' factual allegations suggest that Banner Health or 

anyone for whom Banner is legally responsible fell below the standard of care, it is denied. 

Banner Health lacks knowledge and information regarding the truth of any allegations 

pertaining to other defendants. All remaining allegations are denied. 

28. Answering Paragraphs 71-72, Banner Health denies the allegations set forth 

therein to the extent the allegations arc intended to apply to this Answering Defendant. 

29. Answering Paragraph 73, Banner Health is without knowledge or 

information sufficient to form a belief concerning Plaintiffs' injuries or damages, if any, 

but denies that Plaintiffs were injured or damaged, as alleged or at all, by reason of any 

breach on the part of this Answering Defendant, or anyone over whom this Answering 

-7-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 36 of 46
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Defendant is responsible. 

30. Answering Paragraphs 74 and 75, Banner Health denies that any of the CoDefcndants, including Dr. Rowland and Sun Life Family Health Center, are employees or 

agents of Banner Health under an actual agency, ostensible agency, respondeat superior, 

nondclegablc duty or any other theory. Banner Health denies that it, or any of its 

employees or agents, were negligent or breached any legal duty to Plaintiffs, as alleged or 

at all. 

31. Answering Paragraphs 76-83, Banner Health lacks knowledge or 

information sufficient to form a belief as to the truth of the allegations contained therein 

pertaining to other defendants. To the extent the allegations in Paragraphs 76-83 are 

intended to apply to this Answering Defendant, Banner Health denies them. 

32. Answering Paragraphs 84-89, Banner Health denies the allegations set forth 

therein. 

33. Answering Paragraphs 90-98, Banner Health is without knowledge or 

information sufficient to form a belief concerning Plaintiffs' injuries or damages, if any, 

but denies that Plaintiffs were injured or damaged, as alleged or at all, by reason of any 

breach on the part of this Answering Defendant, or anyone over whom this Answering 

Defendant is responsible. 

General Denial 

1. Banner Health denies any and all allegations of Plaintiffs' Complaint not 

expressly admitted herein. Banner Health denies that it was negligent or guilty of any 

conduct, of any kind or nature whatsoever that warrants the imposition of damages as 

alleged, or at all. As to Plaintiffs' prayer for judgment, Banner Health denies that Plaintiffs 

arc entitled to any actual, general, and/or compensatory damages, special damages, costs, 

expenses, fees, or any other relief. 

-8-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 37 of 46
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Aflirmative Defenses 

1. Plaintiffs' Complaint fails to state a claim against Banner Health upon which 

relief can be granted. 

2. Plaintiffs' claims, if any, may be barred or reduced because of Plaintiffs' 

assumption of the risk or comparative fault and/or the natural progression of Plaintiffs' 

condition. 

3. Plaintiffs' claims may be barred by the applicable statute of limitations. 

4. Plaintiffs' injuries and damages, if any, did not occur as a result of any 

conduct, action, or inaction by Banner Health. Rather, the damages suffered by Plaintiffs, 

if any, may be the result of acts of Plaintiffs, third persons, or conditions beyond the control 

of Banner Health as yet to be revealed through discovery. Accordingly, the trier of fact 

must allocate fault among all individuals or entities, including Plaintiffs, whether parties or 

non-parties, in accordance with A.RS. § 12-2501, et seq., including A.RS. § 12-2505 and 

§ 12-2506. 

5. Plaintiffs may have failed to mitigate any alleged damages. If there was such 

failure to mitigate, Plaintiffs' damages, if any, must be reduced accordingly. 

6. Plaintiffs may have failed to join indispensable parties. 

7. Expert opinion testimony will be required in this case to prove all allegations 

of negligence by Banner Health. Plaintiffs are required to disclose a preliminary expert 

affidavit with their Initial Rule 26.1 Disclosure Statement pursuant to A.RS. §§ 12-2603 

and 12-2604. 

8. Plaintiffs' injuries, losses or damages, if any, were not caused or contributed 

to by any failure of Banner Health to comply with the applicable standard of care. 

Plaintiffs are required to prove that Banner Health failed to exercise that degree of care, 

skill and learning expected of a reasonable, prudent healthcare provider in the profession or 

class to which the healthcare providers belong within the State acting in the same or similar 

-9-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 38 of 46
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circumstances, and that failure to do so was the proximate cause of the injuries or damages 

sustained by Plaintiffs, pursuant to A.RS.§ 12-563. 

9. Banner Health asserts that if Plaintiffs received any collateral source benefits 

or payments as defined by A.RS. § 12-565 as a result of alleged injuries, Banner Health 

will introduce evidence of such payments or benefits at trial. The extent of such collateral 

sources is not yet known and is presumably in the possession of Plaintiffs. 

10. Banner Health affirmatively alleges that Plaintiffs' alleged injuries may be 

the result of pre-existing injuries or medical conditions or the natural progression of 

medical conditions unrelated to those alleged to have occurred in the subject incident, 

which may bar recovery or reduce recovery to Plaintiffs. 

11. Banner Health has not knowingly or intentionally waived any applicable 

affirmative defense. If it appears that any affirmative defense is or may be applicable after 

Banner Health has had the opportunity to conduct reasonable discovery in this matter, it 

will assert such affirmative defense in accordance \Vith the Arizona Rules of Civil 

Procedure. Banner Health reserves the right to assert any and all affirmative defenses 

including those set forth in Rules 8( c) and l 2(b) of the Arizona Rules of Civil Procedure. 

WHEREFORE, having fully answered Plaintiffs' Complaint, Banner Health prays 

that Plaintiffs take nothing thereby, and for such other and further relief as the Court deems 

just and proper. 

J urv Trial Demand 

Banner Health demands a jury trial. 

Ill 

Ill 

Ill 

-10-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 39 of 46
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DATED this 5th day of October, 2017. 

SLATTERY PETERSEN PLLC 

By ~-t~{~;~~i'_~~_h_~_~_~_,(_.~_:~,'~z_?_;,.P_·:'C:l.71~·v11~·-

GinaMarie Slattery ( j 

V 

5981 E. Grant Road, Suite 101 

Tucson, AZ 85712 

Attorney for Banner Health dba 

Banner Casa Grande Medical Center, 

Charlotte Sono-Petty, RN, and Judy 

Quick, RN 

ORIGINAL of the foregoing sent for filing via 

overnight delivery this 5th of October, 2017, 

and served via first-class U.S. Mail on the following: 

Craig A. Knapp 

David S. Friedman 

KNAPP & ROBERTS, P.C. 

8777 North Gainey Center Drive, Suite 165 

Scottsdale, Arizona 85258 

knapp@krattorneys.com 

friedman@krattorneys.com 

Attorneys for Plaintiffs , 

By .tj,111 \\CJiAf* 

-2-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 40 of 46
• 

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::.) 12 --l- -lo 

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GinaMarie Slattery (#012867) 

SLATTERY PETERSEN PLLC 

5981 E. Grant Road, Suite 101 

Tucson, AZ 85712 

Telephone: (520) 326-1866 

Facsimile: (866) 323-9593 

gslattery@slatterypetersen.com 

Attorney for Banner Health dba 

Banner Casa Grande Medical Center, 

Charlotte Sono-Petty, RN, and Judy 

Quick, RN 

FILED 

AMANDA STMIFORO 

CLER!< OF <'!::,:~;~•C-'1 COURT 

17 OCT 2 3 PM 12: I 0 

BY,,.~ 

~ -

IN THE SUPERIOR COURT FOR THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF PINAL 

DEAN MICHAEL WATT, a minor, by and 

through his natural parents; HALEY 

HOLLAND-HONEA and AL YAN WATT, 

individually, 

Plaintiffs, 

vs. 

BANNER HEAL TH, an Arizona corporation 

d/b/a BANNER CASA GRANDE MEDICAL 

CENTER; DANIEL ROWLAND, M.D., a 

Nebraska resident; SUN LIFE FAMILY 

HEAL TH CENTER, an Arizona corporation 

d/b/a SUN LIFE CENTER FOR WOMEN; 

CHARLOTTE SONO-PETTY, R.N., an 

Arizona resident; JUDY QUICK, R.N., an 

Arizona Resident; DOES 1-X; 

CORPORATIONS 1-X; and PARTNERSHIPS 

1-X, 

Defendants. 

No. C20171294 

DEFENDANTS BANNER 

HEALTH OBA BANNER CASA 

GRANDE MEDICAL CENTER, 

CHARLOTTESONO~ETT~ 

RN, AND JUDY QUICK, RN'S 

CERTIFICATE OF 

COMPULSORY ARBITRATION 

(Assigned to Hon. Brenda E. 

Oldham) 

.... 

Defendants Banner Health dba Banner Casa Grande Medical Center, Charlotte 

Sono-Petty, RN, and Judy Quick, RN, through undersigned counsel, hereby certify that the 

largest award sought by the complainant, including punitive damages, but excluding 

interest, attorneys' fee, and costs DOES exceed limits set by Local Rule for compulsory 

arbitration. 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 41 of 46
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This case IS NOT subject to the Uniform Rules of Procedures for Arbitration. 

DATED this 5th day of October, 2017. 

SLATTERY PETERSEN PLLC 

r.'.A L11. ( .- By ~vvl.Ai./~ c:t~~- .. GinaMarie Slattery {J 

5981 E. Grant Road, Suite 101 

Tucson, AZ 85712 

Attorney for Banner Health dba 

Banner Casa Grande Medical Center, 

Charlotte Sono-Petty, RN, and Judy 

Quick, RN 

ORIGINAL of the foregoing sent for filing via 

overnight delivery this 5th of October, 2017, 

and served via first-class U.S. Mail on the following: 

Craig A. Knapp 

David S. Friedman 

KNAPP & ROBERTS, P.C. 

8777 North Gainey Center Drive, Suite 165 

Scottsdale, Arizona 85258 

knapp@krattorneys.com 

friedman@krattorneys.com 

Attorne s for Plaintiffs. 

B ' 1M WJ 

-2-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 42 of 46
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GinaMarie Slattery (#012867) 

SLATTERY PETERSEN PLLC 

5981 E. Grant Road, Suite 101 

Tucson, AZ 85712 

Telephone: (520) 326-1866 

Facsimile: (866) 323-9593 

gslattery@slatterypctcrsen.com 

Attorney for Banner Health dba 

Banner Casa Grande Medical Center, 

Charlotte Sano-Petty, RN, and Judy 

Quick, RN 

.. FILED 

AMANDA STANFORD 

CLERK OF ~:·,:,c·R 1CR COURT 

17 OCT 2 3 PH 12: I 0 

BY /\A\]\) 

DEPUTY 

IN THE SUPERIOR COURT FOR THE STATE OF ARIZONA 

IN AND FOR THE COUNTY OF PINAL 

DEAN MICHAEL WATT, a minor, by and 

through his natural parents; HALEY 

HOLLAND-HONEA and ALYAN WATT, 

individually, 

Plaintiffs, 

vs. 

BANNER HEALTH, an Arizona corporation 

d/b/a BANNER CASA GRANDE MEDICAL 

CENTER; DANIEL RUWLAND, M.D., a 

Nebraska resident; SUN Lllli FAMILY 

HEAL TH CENTER, an Arizona corporation 

d/b/a SUN LIFE CENTER FOR WOMEN; 

CHARLOTTE SONO-PETTY, RN., an 

Arizona resident; JUDY QUICK, RN., an 

Arizona Resident; DOES I-X; 

CORPORATIONS I-X; and PARTNERSHIPS 

I-X, 

Defendants. 

No. C20171294 

DEFENDANTS BANNER 

HEAL TH OBA BANNER CASA 

GRANDE :MEDICAL CENTER, 

CHARLOTTE SONO-PETTY, 

RN, AND JUDY QUICK, Rt~'S 

DE1\1AND FOR JURY TRIAL 

(Assigned to Hon. Brenda E. 

Oldham) 

Defendants Banner Health dba Banner Casa Grande Medical Center, Charlotte 

Sono-Petty, RN, and Judy Quick, RN, through undersigned counsel, hereby requests a trial 

by jury as to all triable issues in the above-captioned matter. 

-1-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 43 of 46
" 

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DATED this 5th day of October, 2017. 

SLATTERY PETERSEN PLLC 

By ~ ~ VV'-lv'--L.2 .' .c' ~ ""' 

Gin_itMarie Slattery ._j 

5981 E. Grant Road, Suite 101 

Tucson, AZ 85712 

Attorney for Banner Health dba 

Banner Casa Grande Medical Center, 

Charlotte Sono-Petty, RN, and Judy 

Quick, RN 

ORIGINAL of the foregoing sent for filing via 

overnight delivery this 5th of October, 2017, 

and served via first-class U.S. Mail on the following: 

Craig A. Knapp 

David S. Friedman 

KNAPP & ROBERTS, P.C. 

8777 North Gainey Center Drive, Suite 165 

Scottsdale, Arizona 85258 

knapp@krattorneys.com 

friedman@krattorneys.com 

Attorneys for Plaintiffs ¥rm w'~ 

-11-

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 44 of 46
Filed on 1/22/2018 1:10:12 PM 

Page 1 of 2

IN THE SUPERIOR COURT 

9:14 a.m. Hearing starts 

9:14 a.m. Hearing ends 

PINAL COUNTY, STATE OF ARIZONA

 

Date: 01/19/2018

THE HON BRENDA E OLDHAM, AMANDA STANFORD, CLERK 

Courtroom: 2C

Court Reporter: JACQUELIN ALLEN By Deputy Clerk: B.LOHR 

DEAN MICHAEL WATT, a minor, by and through 

his natural parents; HALEY HOLLAND-HONEA 

and ALYAN WATT, individually, 

 Plaintiff(s), 

vs. 

 

BANNER HEALTH, an Arizona corporation d/b/a 

BANNER CASA GRANDE MEDICAL CENTER; 

DANIEL ROWLAND M.D., a Nebraska Resident; 

SUN LIFE FAMILY HEALTH CENTER an Arizona 

corporation d/b/a SUN LIFE CENTER FOR 

WOMEN; CHARLOTTE SONO-PETTY, R.N., an 

Arizona resident; JUDY QUICK, R.N., an Arizona 

resident; DOES I-X; CORPORATIONS I-X; and 

PARTNERSHIPS I-X, 

 Defendant(s).

) 

) 

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) 

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) 

) 

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) 

S1100CV201701294 

MINUTE ENTRY ACTION: 

INACTIVE DISMISSAL 

PRESENT: 

 No parties appearing. 

The Court announces that this is the time set for a Hearing on Inactive Dismissal. 

The Court FINDS that service has been completed on defendant and that an answer 

has been filed; therefore, 

IT IS HEREBY ORDERED vacating the Inactive Dismissal hearing this date. 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 45 of 46
Filed on 1/22/2018 1:10:12 PM 

Page 2 of 2

Mailed/distributed copy: 01/19/2018

GINAMARIE SLATTERY 

CRAIG KNAPP 

DAVID FRIEDMAN 

Office Distribution: 

JUDGE/OLDHAM 

Case 2:18-cv-00448-GMS Document 1-4 Filed 02/08/18 Page 46 of 46