IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHRN DISTRICT OF ILLINOIS

EASTERN DIVISION

K.G., a Minor, by and through )

his Parents and Next Friends, CELESTINA )

COLEMAN and ANTHONY GILBERT; and )

CELESTINA COLEMAN, Individually, and )

ANTHONY GILBERT, Individually; )

)

)

Plaintiffs, )

) Case No.

v. )

) 

THE UNITED STATES OF AMERICA; )

LAWNDALE CHRISTIAN HEALTH CENTER, )

an Illinois Corporation; LINDSAY )

MCCRACKEN, PA-C; BLUE ISLAND )

HOSPITAL COMPANY d/b/a )

METROSOUTH MEDICAL CENTER, an Illinois )

corporation; AURORA EMERGENCY )

ASSOCIATES, LTD., an Illinois corporation; )

KATIE THOMPSON, D.O.; US ACUTE CARE )

SOLUTIONS, an Ohio corporation; )

MELISSA O’KEEFE, PA-C; and )

MONICA A. BESZKA, M.D.; )

)

Defendants. )

COMPLAINT

NOW COME the Plaintiffs, K.G., a Minor, by and through CELESTINA COLEMAN and 

ANTHONY GILBERT, as Parents and Next Friends; and CELESTINA COLEMAN, Individually;

and ANTHONY GILBERT, Individually; by and through their attorneys, SALVI, SCHOSTOK & 

PRITCHARD P.C., and complaining of the Defendants, state as follows: 

JURISDICTION AND VENUE

1. This action arises under the Federal Tort Claims Act, 28 U.S.C. §§ 2671, et seq. 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 1 of 23 PageID #:1
2. The Plaintiffs, K.G., a Minor, by and through his Parents and Next Friends, 

Celestina Coleman and Anthony Gilbert, and Celestina Coleman, Individually, and Anthony 

Gilbert, Individually, have complied with Section 2675(a) of the Federal Tort Claims Act, and 

have exhausted their administrative remedies before filing this suit.

3. On July 23, 2019, the Plaintiffs filed an administrative claim with the United States 

Department of Health & Human Services (“HHS”) for medical care that resulted in significant 

injuries to K.G. 

4. On August 6, 2019, HHS acknowledged the Plaintiffs’ claim and requested 

supplemental documentation of the claim. (See Acknowledgement Letter, attached as Exhibit A.)

5. On September 10, 2019, Plaintiffs provided HHS with the requested 

documentation.

6. Plaintiffs have not received denial of the administrative claim from HHS; however, 

the six month time period for investigation of the claim has expired. 

7. The Plaintiffs have elected to file suit against the USA and its affiliatesin the United 

States District Court for the Northern District of Illinois pursuant to 28 U.S.C. § 2401(b). 

8. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. § 1346(b), in which the 

District Court shall have exclusive jurisdiction of civil actions on claims against the United States 

for money damages for personal injury by the negligent or wrongful act or omission of any 

employee of the Government while acting within the scope of her office or employment, under 

circumstances where the United States, if a private person, would be liable to the claimant in 

accordance with the laws of the State of Illinois.

9. Venue is proper under 28 U.S.C. § 1391(b) because all of the acts and omissions 

forming the basis of the claim occurred in the Northern District of Illinois. 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 2 of 23 PageID #:2
10. On or about November 26, 2018, and at all times material, Lawndale Christian 

Health Center (“LCHC”) was a healthcare facility located in the City of Chicago, County of Cook, 

State of Illinois, receiving grant money from the United States Public Healthcare Service, pursuant 

to 42 U.S.C. § 233, as well as being the employer of various physicians, physician assistants, and 

healthcare workers. 

11. On or about November 26, 2018, and at all times material, Lindsay McCracken, 

PA-C (“McCracken”) was an agent, servant, and/or employee of LCHC and USA. 

12. Defendant, USA, has been deemed the employer of LCHC and McCracken, 

pursuant to 42 U.S.C. § 233, for FTCA purposes only. 

GENERAL ALLEGATIONS

13. On or around November 24, 2018 through November 26, 2018, and at all times 

material, Celestina Coleman and Anthony Gilbert lived in Blue Island, Cook County, Illinois. 

14. Celestina Coleman and Anthony Gilbert are the parents of K.G.

15. K.G. was born on October 15, 2015.

16. On November 24, 2018, and at all times material, Blue Island Hospital Company 

was an Illinois corporation, licensed to do business in Illinois, operating a hospital as MetroSouth 

Medical Center (“MetroSouth”), located at 12935 South Gregory Street, Blue Island, Illinois,

60406. 

17. On or around November 24, 2018, and at all times material, MetroSouth provided 

certain facilities, including but not limited to, an emergency department that treated pediatric 

patients, including K.G.

18. On or around November 24, 2018, and at all times material, MetroSouth held itself 

out to the general public to be a provider of medical and hospital services. 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 3 of 23 PageID #:3
19. On or around November 24, 2018, and at all times material, MetroSouth employed 

certain personnel, including but not limited to, physicians, physician assistants, nurses, and other 

hospital personnel, who provided emergency medical services to patients, including K.G.

20. On or around November 24, 2018, and at all times material, Melissa O’Keefe. was 

a physician assistant, licensed in the State of Illinois.

21. On or around November 24, 2018, O’Keefe held herself out to K.G. and the general 

public to be a physician assistant, treating patients in the emergency department of MetroSouth,

under the supervision of a physician. 

22. On or around November 24, 2018, and at all times material, O’Keefe provided 

treatment to K.G. while in the emergency department of MetroSouth. 

23. On or around November 24, 2018, O’Keefe was an employee and agent of Blue 

Island Hospital Center, and treating patients at MetroSouth. 

24. On or around November 24, 2018, and at all times material, O’Keefe was an 

employee and agent of Blue Island Hospital Center d/b/a MetroSouth acting within the scope of 

her employment during the treatment of K.G.

25. On or around November 24, 2018, and at all times material, O’Keefe was an 

apparent agent of MetroSouth. 

26. On or around November 24, 2018, and at all times material, US Acute Care 

Solutions (“USACS”) was an Ohio corporation, licensed to do business in Illinois, with a primary 

place of business located at 4535 Dressler Road NW, Canton, Ohio, 44718.

27. On or around November 24, 2018, and at all times material, USACS held itself out 

to the general public to be a provider of emergency medicine and hospital services. 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 4 of 23 PageID #:4
28. On or around November 24, 2018, and at all times material, USACS employed 

certain personnel, including physician assistants, who provided emergency medicine and hospital

services to patients, including K.G.

29. On or around November 24, 2018, and at all times material, O’Keefe was an 

employee and agent of USACS. 

30. On or around November 24, 2018, and at all times material, O’Keefe was an 

employee and agent of USACS acting within the scope of her employment.

31. On or around November 24, 2018, and at all times material, Katie Thompson, D.O. 

was a physician licensed to practice medicine in the State of Illinois.

32. On or around November 24, 2018, Dr. Thompson held herself out to K.G. and the 

general public to be a specialist in emergency medicine. 

33. On or around November 24, 2018, Dr. Thompson was an employee and agent of 

Blue Island Hospital Center, and treating patients at MetroSouth. 

34. On or around November 24, 2018, and at all times material, Dr. Thompson was an 

employee and agent of Blue Island Hospital Center d/b/a MetroSouth acting within the scope of 

her employment.

35. On or around November 24, 2018, and at all times material, Dr. Thompson was an 

apparent agent of MetroSouth. 

36. On or around November 24, 2018, and at all times material, Aurora Emergency 

Associates, Ltd. (“AEA”) was an Illinois corporation, licensed to do business in Illinois, with its 

registered address located at 801 Adlai Stevenson Drive, Springfield, Illinois, 62703.

37. On or around November 24, 2018, and at all times material, AEA held itself out to 

the general public to be a provider of emergency medicine and hospital services. 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 5 of 23 PageID #:5
38. On or around November 24, 2018, and at all times material, AEA employed certain 

personnel, including physicians, who provided emergency medicine and hospital services to

patients, including K.G.

39. On or around November 24, 2018, and at all times material, Dr. Thompson was an 

employee and agent of AEA. 

40. On or around November 24, 2018, and at all times material, Dr. Thompson was an 

employee and agent of AEA acting within the scope of her employment.

41. On or around November 24, 2018, and at all times material, Dr. Thompson was the 

attending physician overseeing the care of K.G. while in the emergency department of MetroSouth. 

42. On or around November 24, 2018, and at all times material, Dr. Thompson provided 

medical care and treatment to K.G. while in the emergency department of MetroSouth. 

43. On or around November 24, 2018, and at all times material, Dr. Thompson was the 

attending physician responsible for supervising physician assistants who cared for K.G. while in 

the emergency department of MetroSouth. 

44. On or around November 24, 2018, and at all times material, Dr. Thompson was the 

attending physician responsible for supervising O’Keefe in her care of K.G. while in the 

emergency department of MetroSouth. 

45. On or around November 24, 2018, and at all times material, Monica Beszka, M.D. 

(“Dr. Beszka”) was a physician licensed to practice medicine in the State of Illinois.

46. On or around November 24, 2018, Dr. Beszka held herself out to K.G. and the 

general public to be a specialist in emergency medicine. 

47. On or around November 24, 2018, Dr. Beszka was an employee and agent of Blue 

Island Hospital Center, and treating patients at MetroSouth. 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 6 of 23 PageID #:6
48. On or around November 24, 2018, and at all times material, Dr. Beszka was an 

employee and agent of Blue Island Hospital Center d/b/a MetroSouth acting within the scope of 

her employment.

49. On or around November 24, 2018, and at all times material, Dr. Beszka was an 

apparent agent of MetroSouth. 

50. On or around November 24, 2018, and at all times material, Dr. Beszka was 

overseeing the care of K.G. while in the emergency department of MetroSouth. 

51. On or around November 24, 2018, and at all times material, Dr. Beszka provided 

medical care and treatment to K.G. while in the emergency department of MetroSouth. 

52. On or around November 24, 2018, and at all times material, Dr. Beszka was the 

physician responsible for supervising physician assistants who cared for K.G. while in the 

emergency department of MetroSouth. 

53. On or around November 24, 2018, and at all times material, Dr. Beszka was the 

physician responsible for supervising O’Keefe in her care of K.G. while in the emergency 

department of MetroSouth. 

54. On or around November 24, 2018, K.G. was brought to the emergency department 

of MetroSouth by his mother, Celestina Coleman.

55. On or around November 24, 2018, K.G. was treated by O’Keefe at MetroSouth.

56. On or around November 24, 2018, K.G. was treated by Dr. Thompson at 

MetroSouth.

57. On or around November 24, 2018, K.G. was treated by Dr. Beszka at MetroSouth.

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 7 of 23 PageID #:7
58. On or around November 24, 2018, K.G. presented to the emergency department of 

MetroSouth with reports of a fever, onset of three days prior; headache; and eye signs and 

symptoms, onset of three days prior.

59. On or around November 24, 2018, while in the emergency department of 

MetroSouth, K.G.’s measured heart rate was 150 bpm.

60. On or around November 24, 2018, while in the emergency department of 

MetroSouth, K.G.’s measured blood pressure was 134/72.

61. Repeat testing was not done to assess K.G.’s blood pressure before discharge.

62. No testing was done in the emergency room of MetroSouth to address K.G.’s eye 

signs and symptoms.

63. O’Keefe, Dr. Beszka, and Dr. Thompson did not chart regarding K.G.’s behavior 

or mental status. 

64. A neurological exam was not performed on K.G. while in the emergency room of 

MetroSouth. 

65. On or around November 24, 2018, while in the emergency department of 

MetroSouth, no further neurological or other testing of K.G. was ordered. 

66. On or around November 24, 2018, O’Keefe, Dr. Beszka, and Dr. Thompson 

discharged K.G. to home, with diagnoses of ringworm and fever, and instructions to follow up 

with pediatrician.

67. On or around November 26, 2018, K.G. was brought to LCHC by his mother, 

Celestina Coleman.

68. On or around November 26, 2018, K.G. was treated by McCracken at LCHC.

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 8 of 23 PageID #:8
69. On or around November 26, 2018, K.G. presented to LCHC with a history of having 

been seen in the ER at MetroSouth for fever and headache; fever for 4-5 days; increased fussiness; 

slight cough and cold; and increased swelling to right eye, worsening on that day, with no evidence 

of eye trauma or discharge.

70. On or around November 26, 2018, McCracken charted that K.G.’s visit was a wellchild exam.

71. McCracken did not perform a full eye exam to assess extra-ocular movement of the 

eye.

72. McCracken did not refer K.G. for neurological testing.

73. McCracken did not refer K.G. for further ophthalmological testing.

74. McCracken did not refer K.G. for a CT scan.

75. McCracken did not refer K.G. to any other medical provider.

76. McCracken did not consult with a physician relative to her examination and 

diagnoses of K.G.

77. On or around November 26, 2018, McCracken diagnosed K.G. with preorbital 

cellulitis and prescribed antibiotics and cool compresses for his eye complaints, with instructions 

to return in 2-3 weeks for exam.

78. On November 28, 2018, Celestina Coleman found K.G. unresponsive at their home.

79. On November 28, 2018, K.G. was rushed to Advocate Christ Hospital.

80. On November 28, 2018, K.G. was diagnosed with septic shock, subdural abscess, 

subdural and epidural empyema, and sinusitis, requiring emergent, life-saving neurosurgery. 

COUNT I

(Medical Negligence)

(K.G. v. USA, LCHC, and McCracken) 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 9 of 23 PageID #:9
NOW COME the Plaintiffs, K.G., a Minor, by and through his Parents and Next Friends, 

Celestina Coleman and Anthony Gilbert, and Celestina Coleman, Individually, and Anthony 

Gilbert, Individually; by and through their attorneys, Salvi, Schostok & Pritchard, P.C., and 

complaining of the Defendants, USA, LCHC and McCracken, state as follows: 

1-80. Plaintiffs restate, reallege, and incorporate all prior paragraphs as paragraphs 1-80 

of Count I. 

81. On November 26, 2018, and at all times material, McCracken provided medical 

treatment as a physician assistant to K.G. at LCHC.

82. On November 26, 2018, and at all times material, while providing medical care to 

the Plaintiff, McCracken was doing so as an employee, servant, agent and/or apparent agent of 

LCHC and the USA. 

83. On November 26, 2018, and at all times material, while providing medical care to 

the Plaintiff, McCracken had a duty to possess and apply the knowledge and skill that other 

physician assistants would exercise in the same or similar circumstances. 

84. On November 26, 2018, and at all times material, in derogation of her 

aforementioned duty, McCracken, individually, and as an employee, servant, agent and/or 

apparent agent of LCHC and the USA, breached that duty and was negligent in one or more of the 

following respects: 

a. Failed to recognize K.G.’s history and complaints of fever and headache, paired 

with a swollen eye, as signs and symptoms of an emergent intracranial infection;

b. Failed to adequately assess K.G.’s extra-ocular eye movements to determine if his 

condition was pre-septal or post-septal;

c. Failed to timely order labs, including CBC and C-reactive protein;

d. Failed to consult with a physician concerning her treatment and diagnoses of K.G.;

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 10 of 23 PageID #:10
e. Failed to refer K.G. for additional radiological testing, such as a CT scan of the 

sinuses and brain; and/or

f. Failed to refer K.G. to a higher level of care.

85. As a direct and proximate result of one or more of the aforementioned negligent 

acts and/or omissions of the Defendants, USA, LCHC, and McCracken, K.G., a minor, suffered 

severe, permanent, and irreversible physical damages; is permanently disabled and disfigured; has 

experienced and will permanently experience untold pain and suffering; has incurred and in the 

future, will incur, obligations for substantial sums of money for hospital, medical, nursing, 

caretaking, custodial bills, and has an impaired or no earning capacity. 

86. The Plaintiffs, K.G., a minor, through Celestina Coleman and Anthony Gilbert, as 

Parents and Next Friends, attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B). 

WHEREFORE, the Plaintiff, K.G., a minor, through Celestina Coleman and Anthony 

Gilbert, as Parents and Next Friends, demands judgment against the Defendants, USA, LCHC, and 

McCracken.

COUNT II

(Family Expense Act)

(Coleman and Gilbert v. USA, LCHC, and McCracken)

1-86. The Plaintiffs, Celestina Coleman and Anthony Gilbert, Individually, re-state, reallege, and incorporate by reference all prior paragraphs as 1-86 of Count II. 

87. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of Defendants, USA, LCHC, and McCracken, the Plaintiffs, Celeste Coleman 

and Anthony Gilbert, as parents of the minor Plaintiff, K.G., incurred and in the future will incur 

obligations for substantial sums of money for hospital, medical, nursing, and other medical and 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 11 of 23 PageID #:11
family expenses of the minor Plaintiff, pursuant to the Illinois Family Expense Act, 750 ILCS 

65/14.

88. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

WHEREFORE, the Plaintiffs, Celestina Coleman and Anthony Gilbert, Individually, 

demand judgment against the Defendants, USA, LCHC, and McCracken.

COUNT III

(Medical Negligence)

(K.G. v. MetroSouth and Dr. Thompson)

NOW COME the Plaintiffs, K.G., a Minor, by and through his Parents and Next Friends, 

Celestina Coleman and Anthony Gilbert, and Celestina Coleman, Individually, and Anthony 

Gilbert, Individually; by and through their attorneys, Salvi, Schostok & Pritchard, P.C., and 

complaining of the Defendants, MetroSouth and Dr. Thompson, state as follows: 

1-88. Plaintiffs restate, reallege, and incorporate all prior paragraphs as paragraphs 1-88

of Count III. 

89. While providing emergency medical services to K.G., Dr. Thompson had a duty to 

possess and apply the knowledge, skill, and care of a reasonably careful emergency medicine 

physician under the same or similar circumstances. 

90. Dr. Thompson, individually and as an agent, apparent agent and/or employee of 

MetroSouth, breached her duty and was negligent in treating K.G. in one or more of the following 

respects:

a. Failed to appropriately chart K.G.’s signs and symptoms;

b. Failed to adequately assess K.G.’s behavior and mental status;

c. Failed to perform a full neurological exam;

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 12 of 23 PageID #:12
d. Failed to recognize the seriousness of K.G.’s elevated heart rate and elevated blood 

pressure;

e. Failed to ask for details regarding eye concerns;

f. Failed to recognize K.G.’s history and complaints of fever and headache, paired 

with eye symptoms, as signs and symptoms of an emergent neurological condition;

g. Failed to order further testing, such as a CT scan;

h. Failed to consult with a more specialized level of care, such as a neurologist;

i. Failed to admit K.G. to the hospital; and/or

j. Failed to supervise a physician assistant.

91. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of Dr. Thompson, individually, and as an agent, apparent agent and/or employee 

of MetroSouth, K.G., a minor, suffered severe, permanent, and irreversible physical damages; is 

permanently disabled and disfigured; has experienced and will permanently experience untold pain 

and suffering; has incurred and in the future, will incur, obligations for substantial sums of money 

for hospital, medical, nursing, caretaking, custodial bills, and has an impaired or no earning 

capacity.

92. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

WHEREFORE, the Plaintiff, K.G., a minor, through Celestina Coleman and Anthony 

Gilbert, as Parents and Next Friends, demands judgment against the Defendants, MetroSouth and 

Dr. Thompson . 

COUNT IV

(Family Expense Act)

(Coleman and Gilbert v. MetroSouth and Dr. Thompson)

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 13 of 23 PageID #:13
1-92. Plaintiffs re-state, re-allege, and incorporate by reference all prior paragraphs as 

paragraphs 1-92 of Count IV.

93. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of Defendants, MetroSouth and Dr. Thompson, the Plaintiffs, Celeste Coleman 

and Anthony Gilbert, as parents of the minor Plaintiff, K.G., incurred and in the future will incur 

obligations for substantial sums of money for hospital, medical, nursing, and other medical and 

family expenses of the minor Plaintiff, pursuant to the Illinois Family Expense Act, 750 ILCS 

65/14.

94. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

WHEREFORE, the Plaintiffs, Celestina Coleman and Anthony Gilbert, Individually, 

demand judgment against the Defendants, MetroSouth and Dr. Thompson.

COUNT V

(Medical Negligence)

(K.G. v. AEA and Dr. Thompson)

NOW COME the Plaintiffs, K.G., a Minor, by and through his Parents and Next Friends, 

Celestina Coleman and Anthony Gilbert, and Celestina Coleman, Individually, and Anthony 

Gilbert, Individually; by and through their attorneys, Salvi, Schostok & Pritchard, P.C., and 

complaining of the Defendants, AEA and Dr. Thompson, state as follows: 

1-94. Plaintiffs restate, reallege, and incorporate all prior paragraphs as paragraphs 1-94

of Count V. 

95. While providing emergency medical services to K.G., Dr. Thompson had a duty to 

possess and apply the knowledge, skill, and care of a reasonably careful emergency medicine 

physician under the same or similar circumstances. 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 14 of 23 PageID #:14
96. Dr. Thompson, individually and as an agent, apparent agent and/or employee of 

AEA, breached her duty and was negligent in treating K.G. in one or more of the following 

respects:

a. Failed to appropriately chart K.G.’s signs and symptoms;

b. Failed to adequately assess K.G.’s behavior and mental status;

c. Failed to perform a full neurological exam;

d. Failed to recognize the seriousness of K.G.’s elevated heart rate and elevated blood 

pressure;

e. Failed to ask for details regarding eye concerns;

f. Failed to recognize K.G.’s history and complaints of fever and headache, paired 

with eye symptoms, as signs and symptoms of an emergent neurological condition;

g. Failed to order further testing, such as a CT scan;

h. Failed to consult with a more specialized level of care, such as a neurologist;

i. Failed to admit K.G. to the hospital; and/or

j. Failed to supervise a physician assistant.

97. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of Dr. Thompson, individually, and as an agent, apparent agent and/or employee 

of AEA, K.G., a minor, suffered severe, permanent, and irreversible physical damages; is 

permanently disabled and disfigured; has experienced and will permanently experience untold pain 

and suffering; has incurred and in the future, will incur, obligations for substantial sums of money 

for hospital, medical, nursing, caretaking, custodial bills, and has an impaired or no earning 

capacity.

98. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 15 of 23 PageID #:15
WHEREFORE, the Plaintiff, K.G., a minor, through Celestina Coleman and Anthony 

Gilbert, as Parents and Next Friends, demands judgment against the Defendants, AEA and Dr. 

Thompson. 

COUNT VI

(Family Expense Act)

(Coleman and Gilbert v. AEA and Dr. Thompson)

1-98. Plaintiff re-states, re-alleges, and incorporates by reference all prior paragraphs as 

paragraphs 1-98 of Count VI.

99. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of Defendants, AEA and Dr. Thompson, the Plaintiffs, Celeste Coleman and 

Anthony Gilbert, as parents of the minor Plaintiff, K.G., incurred and in the future will incur 

obligations for substantial sums of money for hospital, medical, nursing, and other medical and 

family expenses of the minor Plaintiff, pursuant to the Illinois Family Expense Act, 750 ILCS 

65/14.

100. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

WHEREFORE, the Plaintiffs, Celestina Coleman and Anthony Gilbert, Individually, 

demand judgment against the Defendants, AEA and Dr. Thompson.

COUNT VII

(Medical Negligence)

(K.G. v. MetroSouth and O’Keefe)

NOW COME the Plaintiffs, K.G., a Minor, by and through his Parents and Next Friends, 

Celestina Coleman and Anthony Gilbert, and Celestina Coleman, Individually, and Anthony 

Gilbert, Individually; by and through their attorneys, Salvi, Schostok & Pritchard, P.C., and 

complaining of the Defendants, MetroSouth and O’Keefe, state as follows: 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 16 of 23 PageID #:16
1-100. Plaintiffs restate, reallege, and incorporate all prior paragraphs as paragraphs 1-100

of Count VII. 

101. While providing medical services to K.G., O’Keefe had a duty to possess and apply 

the knowledge, skill, and care of a reasonably careful physician assistant under the same or similar 

circumstances. 

102. O’Keefe, individually and as an agent, apparent agent and/or employee of 

MetroSouth, breached her duty and was negligent in treating K.G. in one or more of the following 

respects:

a. Failed to appropriately chart K.G.’s signs and symptoms;

b. Failed to adequately assess K.G.’s behavior and mental status;

c. Failed to perform a full neurological exam;

d. Failed to recognize the seriousness of K.G.’s elevated heart rate and elevated blood 

pressure;

e. Failed to ask for details regarding eye concerns;

f. Failed to recognize K.G.’s history and complaints of fever and headache, paired 

with eye symptoms, as signs and symptoms of an emergent neurological condition;

g. Failed to recommend further testing, such as a CT scan;

h. Failed to consult with a physician regarding her examination and diagnoses; and/or

i. Failed to consult with a more specialized level of care, such as a neurologist.

103. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of O’Keefe, individually, and as an agent, apparent agent and/or employee of 

MetroSouth, K.G., a minor, suffered severe, permanent, and irreversible physical damages; is 

permanently disabled and disfigured; has experienced and will permanently experience untold pain 

and suffering; has incurred and in the future, will incur, obligations for substantial sums of money 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 17 of 23 PageID #:17
for hospital, medical, nursing, caretaking, custodial bills, and has an impaired or no earning 

capacity.

104. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

WHEREFORE, the Plaintiff, K.G., a minor, through Celestina Coleman and Anthony 

Gilbert, as Parents and Next Friends, demand judgment against the Defendants, MetroSouth and 

O’Keefe. . 

COUNT VIII

(Family Expense Act)

(Coleman and Gilbert v. MetroSouth and O’Keefe)

1-104. Plaintiffs re-state, re-allege, and incorporate by reference all prior paragraphs as 

paragraphs 1-104 of Count VIII.

105. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of Defendants, MetroSouth and O’Keefe, the Plaintiffs, Celeste Coleman and 

Anthony Gilbert, as parents of the minor Plaintiff, K.G., incurred and in the future will incur 

obligations for substantial sums of money for hospital, medical, nursing, and other medical and 

family expenses of the minor Plaintiff, pursuant to the Illinois Family Expense Act, 750 ILCS 

65/14.

106. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

WHEREFORE, the Plaintiffs, Celestina Coleman and Anthony Gilbert, Individually, 

demand judgment against the Defendants, MetroSouth and O’Keefe.

COUNT IX

(Medical Negligence)

(K.G. v. USACS and O’Keefe)

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 18 of 23 PageID #:18
NOW COME the Plaintiffs, K.G., a Minor, by and through his Parents and Next Friends, 

Celestina Coleman and Anthony Gilbert, and Celestina Coleman, Individually, and Anthony 

Gilbert, Individually; by and through their attorneys, Salvi, Schostok & Pritchard, P.C., and 

complaining of the Defendants, USACS and O’Keefe, state as follows: 

1-106. Plaintiffs restate, reallege, and incorporate all prior paragraphs as paragraphs 1-106

of Count IX. 

107. While providing medical services to K.G., O’Keefe had a duty to possess and apply 

the knowledge, skill, and care of a reasonably careful physician assistant under the same or similar 

circumstances. 

108. O’Keefe, individually and as an agent, apparent agent and/or employee of USACS, 

breached her duty and was negligent in treating K.G. in one or more of the following respects:

a. Failed to appropriately chart K.G.’s signs and symptoms;

b. Failed to adequately assess K.G.’s behavior and mental status;

c. Failed to perform a full neurological exam;

d. Failed to recognize the seriousness of K.G.’s elevated heart rate and elevated blood 

pressure;

e. Failed to ask for details regarding eye concerns;

f. Failed to recognize K.G.’s history and complaints of fever and headache, paired 

with eye symptoms, as signs and symptoms of an emergent neurological problem;

g. Failed to recommend further testing, such as a CT scan;

h. Failed to consult with a physician regarding her examination and diagnoses; and/or

i. Failed to consult with a more specialized level of care, such as a neurologist.

109. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of O’Keefe, individually, and as an agent, apparent agent and/or employee of 

USACS, K.G., a minor, suffered severe, permanent, and irreversible physical damages; is 

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 19 of 23 PageID #:19
permanently disabled and disfigured; has experienced and will permanently experience untold pain 

and suffering; has incurred and in the future, will incur, obligations for substantial sums of money 

for hospital, medical, nursing, caretaking, custodial bills, and has an impaired or no earning 

capacity.

110. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

WHEREFORE, the Plaintiff, K.G., a minor, through Celestina Coleman and Anthony 

Gilbert, as Parents and Next Friends, demand judgment against the Defendants, USACS and 

O’Keefe. . 

COUNT X

(Family Expense Act)

(Coleman and Gilbert v. USACS and O’Keefe)

1-110. Plaintiffs re-state, re-allege, and incorporate by reference all prior paragraphs as 

paragraphs 1-110 of Count X.

111. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of Defendants, USACS and O’Keefe, the Plaintiffs, Celeste Coleman and 

Anthony Gilbert, as parents of the minor Plaintiff, K.G., incurred and in the future will incur 

obligations for substantial sums of money for hospital, medical, nursing, and other medical and 

family expenses of the minor Plaintiff, pursuant to the Illinois Family Expense Act, 750 ILCS 

65/14.

112. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

WHEREFORE, the Plaintiffs, Celestina Coleman and Anthony Gilbert, Individually, 

demand judgment against the Defendants, USACS and O’Keefe.

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 20 of 23 PageID #:20
COUNT XI

(Medical Negligence)

(K.G. v. MetroSouth and Dr. Beszka)

NOW COME the Plaintiffs, K.G., a Minor, by and through his Parents and Next Friends, 

Celestina Coleman and Anthony Gilbert, and Celestina Coleman, Individually, and Anthony 

Gilbert, Individually; by and through their attorneys, Salvi, Schostok & Pritchard, P.C., and 

complaining of the Defendants, MetroSouth and Dr. Beszka, state as follows: 

1-112. Plaintiffs restate, reallege, and incorporate all prior paragraphs as paragraphs 1-112

of Count XI. 

113. While providing emergency medical services to K.G., Dr. Beszka had a duty to 

possess and apply the knowledge, skill, and care of a reasonably careful emergency medicine 

physician under the same or similar circumstances. 

114. Dr. Beszka, individually and as an agent, apparent agent and/or employee of 

MetroSouth, breached her duty and was negligent in treating K.G. in one or more of the following 

respects:

a. Failed to appropriately chart K.G.’s signs and symptoms;

b. Failed to adequately assess K.G.’s behavior and mental status;

c. Failed to perform a full neurological exam;

d. Failed to recognize the seriousness of K.G.’s elevated heart rate and elevated blood 

pressure;

e. Failed to ask for details regarding eye concerns;

f. Failed to recognize K.G.’s history and complaints of fever and headache, paired with 

eye symptoms, as signs and symptoms of an emergent neurological problem;

g. Failed to order further testing, such as a CT scan;

h. Failed to consult with a more specialized level of care, such as a neurologist;

i. Failed to admit K.G. to the hospital; and/or

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 21 of 23 PageID #:21
j. Failed to supervise a physician assistant.

115. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of Dr. Beszka, individually, and as an agent, apparent agent and/or employee of 

MetroSouth, K.G., a minor, suffered severe, permanent, and irreversible physical damages; is 

permanently disabled and disfigured; has experienced and will permanently experience untold pain

and suffering; has incurred and in the future, will incur, obligations for substantial sums of money 

for hospital, medical, nursing, caretaking, custodial bills, and has an impaired or no earning 

capacity.

116. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

WHEREFORE, the Plaintiff, K.G., a minor, through Celestina Coleman and Anthony 

Gilbert, as Parents and Next Friends, demands judgment against the Defendants, MetroSouth and 

Dr. Beszka. . 

COUNT XII

(Family Expense Act)

(Coleman and Gilbert v. MetroSouth and Dr. Beszka)

1-116. Plaintiffs re-state, re-allege, and incorporate by reference all prior paragraphs as 

paragraphs 1-116 of Count XII.

117. As a direct and proximate result of one or more of the foregoing negligent acts 

and/or omissions of Defendants, MetroSouth and Dr. Beszka, the Plaintiffs, Celeste Coleman and 

Anthony Gilbert, as parents of the minor Plaintiff, K.G., incurred and in the future will incur 

obligations for substantial sums of money for hospital, medical, nursing, and other medical and 

family expenses of the minor Plaintiff, pursuant to the Illinois Family Expense Act, 750 ILCS 

65/14.

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 22 of 23 PageID #:22
118. The Plaintiffs attach affidavits and reports in compliance with 735 ILCS 5/2-622 

(Exhibit B).

WHEREFORE, the Plaintiffs, Celestina Coleman and Anthony Gilbert, Individually, 

demand judgment against the Defendants, MetroSouth and Dr. Beszka.

Respectfully submitted, 

SALVI, SCHOSTOK & PRITCHARD P.C.

s/Heidi L. Wickstrom

One of the Attorneys for the Plaintiffs

Matthew L. Williams (ARDC# 6256858)

Heidi L. Wickstrom (ARDC #6328082)

SALVI, SCHOSTOK & PRITCHARD P.C.

161 N. Clark Street, Suite 4700

Chicago, IL 60601

(312) 372-1227

(312) 372-3720 - fax

mwilliams@salvilaw.com

hwickstrom@salvilaw.com

Case: 1:20-cv-02872 Document #: 1 Filed: 05/13/20 Page 23 of 23 PageID #:23