Not For Profit Hospital Litigation: Filed Case

• Letter From The Court Re: Plaintiffs' Motion For Class Certification - Opinion Letter Allowing Motion Dated: October 4, 2005 (117 KB)
  0CT-04-2Q05 TUE 09:47 AM 4TH JUDICIAL DISTRICT FAX NO. 5039883425 P. 01 CIRCUIT COURT OF THE STATE OF OREGON FOURTH JUDICIAL DISTRICT RICHARD C. BALDWIN MULTNOMAH COUNTY COURTHOUSE PHONE (503) 988-3052 JUDGE 1021 S.W. FOURTH AVENUE FAX (503) 276-0983 PORTLAND, OR 97204-1123 October 4,2005 Michael L. Williams Via Fax : 503-295-3720 Brian S. Campf WILLIAMS LOVE O'LEARY CRAINE POWERS 1001 SW 5th Avenue, Suite 1900 Portland, OR 97204 John F. McGrory, Jr. Via Fax: 503-276-5704 DAVIS WRIGHT TREMALNE 1300 SW 5th Avenue, Suite 2300 Portland, OR 97201 Re: Turner. EtAI v. Legacy Health System. EtAl. Case No. 0412-12483 Plaintiffs' Motion For Class Certification - Opinion Letter Allowing Motion Dear Counsel: The Court has now had an opp
  
  
• Carle Foundation Hospital: Class Action Complaint (1.25 MB)
  IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT CHAMPAIGN COUNTY, ILLINOIS MONTY EVELAND CRISTIAN McCORMICK Plaintiffs, on behalf of themselves and other persons similarly situated, v. CARLE FOUNDATION HOSPITAL, an Illinois Not-for-Profit Corporation, Defendant Case No. 05-L- f
  
  
• Providence Health System: Class Action Complaint For Damages And Declaratory, Injunctive And Other Equitable Relief (1.55 MB)
  _ —- i nnfiFf) * SEP I 8 20W AT SEATTLE RECEIVED sv. UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE GORDON BLOCK and THERESA BLOCK, husband and wife, on behalf of themselves and all others similarly situated, Plaintiffs, PROVIDENCE HEALTH SYSTEM, a non-profit organization; and PROVIDENCE HEALTH SYSTEM -OREGON, a Washington non-profit corporation, Defendants. Case No. CLASS ACTION COMPLAINT FOR DAMAGES AND DECLARATORY, INJUNCTIVE AND OTHER EQUITABLE RELIEF JURY TRIAL DEMANDED Plaintiffs Gordon and Theresa Block, on behalf of themselves and all others similarly situated, file this class action complaint for damages and declaratory, injunctive and other equitable relief against Defendants. Plaintiffs allege upon personal knowledge as to themselves and their own acts, and on information and belief (based on the investigation of their counsel) as to all other matters, as to which allegations they believe substantial evidentiary support will exist after a reaso
  
  
• Legacy Health System: Class Action Allegation Complaint For Damages And Declaratory, Injunctive And Other Equitable Relief (1.00 MB)
  Michael L. Williams, OSB #78426 Mwilliams@wdolaw.com Brian S. Campf, OSB #92248 Bcampf(5).wdolaw. com Law Offices of Williams Love O'Leary Craine & Powers, P.C. 1001 S.W. 5th Avenue, Suite 1900 Portland, Oregon 97204-1135 (503) 295-2924 (503) 295-3720 (Facsimile) Of Attorneys for Plaintiffs ^msEPmsmmmp UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON HELEN TURNER and JOHN TURNER, husband and wife, on behalf of themselves and all others similarly situated, Plaintiffs, v. LEGACY HEALTH SYSTEM, an Oregon non-profit corporation; LEGACY GOOD SAMARITAN HOSPITAL AND MEDICAL CENTER, an Oregon non-profit corporation; and LEGACY MOUNT HOOD MEDICAL CENTER, an Oregon non-profit corporation, Defendants. CaseN^AR 139 5 CLASS ACTION ALLEGATION COMPLAINT FOR DAMAGES AND DECLARATORY, INJUNCTIVE AND OTHER EQUITABLE RELIEF (28 U.S.C. §§ 1331,1340, and 1367) JURY TRIAL DEMANDED Plaintiffs Helen and John Turner, on behalf of themselves and all others similarly situated, file this class action complain
  
  
• Yale New Haven Hospital, Inc.: Class Action Complaint (3.03 MB)
  UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT * L> PABLO RIVERA, on Behalf of himself and All Others Similarly Situated, Plaintiff, YALE NEW HAVEN HOSPITAL, INC., YALE NEW HAVEN HEALTH SERVICES CORP., d/b/a YALE-NEW HAVEN HEALTH SYSTEM, AMERICAN HOSPITAL ASSOCIATION and JOHN DOES 1-10, Defendants. CIVIL ACTION NO. JURY TRIAL DEMANDED SEPTEMBER 13, 2004 CLASS ACTION COMPLAINT Plaintiff Pablo Rivera, by his attorneys, brings this action on behalf of himself and all other persons similarly situated for their claims under The Fair Debt Collection Practices Act, (15 U.S.C. § 1692 et seq.), Connecticut General Statutes §19a-673, claims under Section 501(c)(3), violations of the Emergency Medical Treatment and Active Labor Act, Connecticut Unfair Trade Practices Act ("CUTPA")(C.G.S. §42-110b) and for claims of breach of contract, breach of duty of good faith and fair dealing, unjust enrichment, constructive trust, injunctive and declaratory relief, breach of charitable trust, civil conspiracy/con
  
  
• The Hospital Of The University Of Pennsylvania: Complaint (0.63 MB)
  IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA SARAIMALDONADO, individually and on behalf of herself and all others similarly situated 79 Claudia Drive, Apt. 458 West Haven, CT 06513 Plaintiffs, v. THE HOSPITAL OF THE UNIVERSITY OF PENNSYLVANIA 3400 Spruce Street Philadelphia, PA 19104 Defendant. COMPLAINT The Plaintiff files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendant and alleges the following: I. Introduction Defendant, The Hospital of the University of Pennsylvania (hereinafter referred to as "HUP") holds itself out as a charitable non-profit entity. In exchange for its promise to operate as a charitable, non-profit entity, HUP receives millions of dollars each year in Federal, State and local tax exemptions. In reality, HUP is anything but charitable. While it promises to provide affordable care to the uninsured poor, HUP has and continues to engage in a pattern and practice of charging inordi
  
  
• Children's Hospital Of Philadelphia: Complaint (0.64 MB)
  IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA SARAI MALDONADO, as parent and natural guardian on behalf of minor, JOANETSY ROBLES and on behalf of herself and all others similarly situated 19 Claudia Drive, Apt. 458 West Haven, CT 06513 Plaintiffs, v. CHILDREN'S HOSPITAL OF PHILADELPHIA 34th Street and Civic Center Boulevard Philadelphia, PA 19104 Defendant. COMPLAINT The Plaintiff files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendant and alleges the following: I. Introduction Defendant, Children's Hospital of Philadelphia (hereinafter referred to as "CHOP") holds itself out as a charitable non-profit entity. In exchange for its promise to operate as a charitable, non-profit entity, CHOP receives millions of dollars each year in Federal, State and local tax exemptions. In reality, CHOP is anything but charitable. While it promises to provide affordable care to the uninsured poor, CHOP has and continues to engage
  
  
• Mississippi Baptist Medical Center, Inc.: Class Action Complaint (Jury Trial Demanded) And Notice Of Plaintiffs' Intent To Seek The Following Discover; Plaintiffs' First Set Of Interrogatories And Plaintiffs' First Request For Production Of Documents And (0.53 MB)
  IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI JACKSON DIVISION MELISSA MICHELLE VALENCIA AND SHEKETAR CREAR, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED PLAINTIFFS -mjsvmi VS. Civil Action No.:_^ MISSISSIPPI BAPTIST MEDICAL CENTER, INC., DEFENDANTS MISSISSIPPI BAPTIST HEALTH SYSTEMS, INC., THE AMERICAN HOSPITAL ASSOCIATION AND JOHN DOES A THROUGH Z CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) AND NOTICE OF PLAINTIFFS' INTENT TO SEEK THE FOLLOWING DISCOVERY: PLAINTIFFS' FIRST SET OF INTERROGATORIES AND PLAINTIFFS ' FIRST REQUEST FOR PRODUCTION OF DOCUMENTS AND PLAINTIFFS' FIRST REQUEST FOR ADMISSIONS AND NOTICES OF VIDEO DEPOSITIONS The Plaintiffs file this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and allege the following: I. INTRODUCTION
  
  
• Baptist Health: Class Action Complaint (0.97 MB)
  Aua-13-2004 12:10 From-BOSWELL TUCKER & BREWSTER 5018474354 T-857 P.002 F-0 EASTERN AUXANSfiS AUG I um JAMES By: THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION DARLENE DALY, on behalf of herself and all oihcis similarly situated, Plaintiff, vs. BAPTIST HEALTH and AMERICAN HOSPITAL ASSOCIATION, Defendanzs 4-04- CV-?89 QH •*'"*•* Civil No. Class Action Jury Trial Demand This enso a^'jr.ed to District J 3nd to M,i j :.i: -no Juaje, CLASS ACTION COMPLAINT Plaintiff Darlene Daly, on behalf of herself and all others similarly situated, files this Class Action Complaint, seeking monetary damages, mjunctive and other equitable relief against Defendants Baptist Health ("Baptist"), and the American Hospital Association ("AHA"), and hereby alleges the following on information and belief. Aug-13-2004 1Z: 11 From-BOSWELL TUCKER & BREWSTER 5018474354 T-857 P.003/022 F-99B INTRODUCTION 1.
  
  
• Inova Health Care Services: Class Action Complaint (5.38 MB)
  I.N THE UNITED STATES DISTRICT COURT FILED EOK THE EASTERN DISTRICT OF VIRGINIA PAUL SHIPMAN, On Behalf of Himself and All Others Similarly Situated, Plaintiff, vs. INOVA HEALTH (ARE SERVICES; INOVA HEALTH SYSTEMS FOUNDATION; AMERICAN HOSPITAL ASSOCIATION, and JOHN DOES I THROUGH 10. Defendants. CLASS ACTION COMPLAINT I.IURV TRIAL DEMANDED) The Plaintiff Paul Shipman files this Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and alleges the following based on information and belief: I. I.MKOUUCITUN :. Defendants Inova Health Care Services, Inc. and Inova Health Systems Foundaion [collectively referred to as "Inova") have operated free from federal and state taxes because they promised the government that they would operate as a charity provider of health care for the uninsured and that it would not engage in business "directly or indirectly, for die benefit of private interests." In reality. Inova docs just the opposite: they charge Uieir
  
  
• Christus Health: Class Action Complaint (1.08 MB)
  Rug 11 2004 2:33PM RG8.E 3374341145 p.2 'COPY UNITED STATES DISTRICT COURT 0USDc1iD/LA MIDDLE DISTRICT COURT OF LOUISIANA ^ AUG -5 P 3= 5^ AUTUMN KLOSTERMAN HARRISON, on behalf of herself and al] others similarly situated, Plaintiff, vs. CHRISTUS HEALTH; CHRISTUS HEALTH SOUTHWESTERN LOUISIANA; CHRISTUS ST. PATRICK HOSPITAL; AMERICAN HOSPITAL ASSOCIATION; and JOHN DOES 1-10, Defendants. civil No.Q4-S5Q-g,-/4JL Jury Trial Class Action CLASS ACTION COMPLAINT Plaintiff Autumn Klosterman Harrison, on behalf of herself and all others similarly situated, files this Class Action Complaint pursuant to Louisiana state law, seeking monetary damages, injunctive and other equitable relief against Defendants Christus Health, Christus Health Southwestern Louisiana, Christus St. Patrick Hospital, the American Hospital Association, and John Does 1 through 10 and hereby alleges the following on information and belief. INTRODUCTION 1. Christus Health, Christus Health Southwestern Louisiana, a
  
  
• Baystate Medical Center: Complaint (180 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS DIANE HARRINGTON, On Behalf of ) Herself and All Others Similarly Situated, ) ) Civil Action No.: 04-11663RCL Plaintiff ) ) vs. ) COMPLAINT-CLASS ACTION ) BAYSTATE MEDICAL CENTER, ) BAYSTATE HEALTH SYSTEM, INC., ) AMERICAN HOSPITAL ASSOCIATION, and ) JOHN DOES 1 THROUGH 10. ) ) Defendants. ) __________________________________________ ) COMPLAINT (JURY TRIAL DEMANDED) I. INTRODUCTION 1. Defendants Baystate Medical Center and Baystate Health System, Inc. (“the Baystate Health Defendants”) have operated free from federal and state taxes because they promised the government that they would operate as a charity provider of health care for the uninsured
  
  
• St. Dominic Health Services, Inc.: First Amended Class Action Complain (Jury Trial Demanded) And Notice Of Plaintiffs' Intent To Seek The Following Discover; Plaintiffs' First Set Of Interrogatories And Plaintiffs' First Request For Production Of Document... (1.93 MB)
  IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI JACKSON DIVISION SOUTHERN DISTRICT OF MISSISSIPPI FILED JUL 2 2 2004 BY_ J T. NOBUN, CLERK _________DEPUTY DOROTHY WRIGHT, LOUIE TURNER, PLAINTIFFS and KIMBERLY KING, On Behalf of Themselves and All Others Similarly Situated VS. Civil Action No.: 3:04CV521LN ST. DOMINIC HEALTH SERVICES, INC., ST. DOMINIC- JACKSON MEMORIAL HOSPITAL, THE AMERICAN HOSPITAL ASSOCIATION and JOHN DOES A THROUGH Z DEFENDANTS FIRST AMENDED CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) AND NOTICE OF PLAINTIFFS* INTENT TO SEEK THE FOLLOWING DISCOVERY: PLAINTIFFS' FIRST SET OF INTERROGATORIES AND PLAINTIFFS' FIRST REQUEST FOR PRODUCTION OF DOCUMENTS AND PLAINTIFFS' FIRST REQUEST FOR ADMISSIONS AND NOTICES OF VIDEO DEPOSITIONS The Plaintiffs file this Class Action Complaint seeking m
  
  
• Lee Memorial Health System: Amended Class Action Complaint (116 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION WAYNE D. NASH, on behalf of ) himself and all others similarly situated ) ) PLAINTIFF ) ) vs. ) Civil Action No.: ) 2:04-cv-369-FLM-29-DNF ) LEE MEMORIAL HEALTH SYSTEM, ) and AMERICAN HOSPITAL ASSOCIATION, ) ) DEFENDANTS. ) AMENDED CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL COMES NOW, the Plaintiff WAYNE D. NASH, by and through the undersigned counsel of record, and files this Amended Class Action Complaint, adding as a Defendant, American Hospital Association (hereinafter referred to as AHA). The Plaintiff is seeking monetary damages, injunctive and other equitable relief against the Defendants LEE MEMORIAL HEALTH SYSTEM (hereinafter referred to as “LMHS”) and AHA; and in support thereof would show unto the Court the following to-wit: I. In
  
  
• Florida Hospital Healthcare System, Inc.: First Amended Class Action Complaint (115 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION EDWARD C. JELLISON, and NICOLAS ) ARZATE, on behalf of themselves and all ) others similarly situated ) ) PLAINTIFFS ) ) vs. ) Civil Action No.: ) 6:04-cv-1021-ORL-28-KRS ) FLORIDA HOSPITAL HEALTHCARE ) SYSTEM, INC. d/b/a FLORIDA HOSPITAL; ) ADVENTIST HEALTH SYSTEM/SUNBELT, ) INC.; and AMERICAN HOSPITAL ) ASSOCIATION ) ) DEFENDANTS. ) FIRST AMENDED CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL COMES NOW, the Plaintiff EDWARD C. JELLISON, by and through the undersigned counsel of record, and files this his First Amended Class Action Complaint, adding as a Plaintiff NICOLAS ARZATE, and adding as a party Defendant AMERICAN HOSPITAL ASSOCIATION. The Pl
  
  
• Florida Hospital Healthcare System, Inc: First Amended Class Action Complaint (122 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION EDWARD C. JELLISON, and NICOLAS ) ARZATE, on behalf of themselves and all ) others similarly situated ) ) PLAINTIFFS ) ) vs. ) Civil Action No.: ) 6:04-cv-1021-ORL-28-KRS ) FLORIDA HOSPITAL HEALTHCARE ) SYSTEM, INC. d/b/a FLORIDA HOSPITAL; ) and ADVENTIST HEALTH ) SYSTEM/SUNBELT, INC. ) ) DEFENDANTS. ) FIRST AMENDED CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL COMES NOW, the Plaintiff EDWARD C. JELLISON, by and through the undersigned counsel of record, and files this his First Amended Class Action Complaint, adding as a Plaintiff NICOLAS ARZATE, and adding as a party Defendant AMERICAN HOSPITAL ASSOCIATION. The Plaintiffs are seeking mon
  
  
• BJC Health System: Amended Class Action Complaint (1.13 MB)
  IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI DWIGHT L. QUINN, FREIDA EYSTER, DAVID W. KUNEMAN On Behalf of Themselves and All Others Similarly Situated PLAINTIFFS, vs. BJC HEALTH SYSTEM DBA BJC HEALTHCARE, a Missouri Non-Profit Corporation, BARNES-JEWISH HOSPITAL, Serve: K. Scott Gronowski 3015 North Ballas Road St. Louis, Missouri 63131 AMERICAN HOSPITAL ASSOCATION, Serve: James A. Henderson One North Franklin Street Suite 2700 Chicago, IL 60606 and JOHN DOES 1 THROUGH 10 DEFENDANTS. Case No. 4:4cv768 ERW JURY TRIAL DEMANDED AMENDED CLASS ACTION COMPLAINT Plaintiffs file this Amended Class Action Complaint seeking monetary damages, injunctive and other equitable relief against Defendants and allege the following: {508808 / 041084} -1- I. Introduction Defendant BJC Health System and each of its affiliated hospitals and service institutions, including Defendant Barnes-Jewish Hospital ("Barnes"), commonly referred to as the BJC Health S
  
  
• Albert Einstein Medial Center: Class Action Complaint (1.96 MB)
  IN THE TJN1TED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF FEINNSYLVANIA HARRY HUTT> On Behalf ofHaaself and All Often Similarly Situated, Plaintiff vs, ALBERT EINSTEIN MEDICAL CENTER, ALBERT EINSTEtN HEALTHCARE NETWORK, JEFFERSON HEALTH SYSTEM, AMERICAN HOSPITAL ASSOCIATION and JOHN DOES 1 THROUGH 10. Defendants. CLASS ACTION COMPLAINT The Plaintiff Harry Hint files this Class Action Complain! seeking monetary damages* i njunctive and other equitable relief against foe Defendants And alleges the following; L 1. Defendants Albert Einstein Medical Center, Albert Einstein Healthcare Network, and Jefferson Health System ("the Jefferson Heal* Defendants1") have operated free from federal and state taxes because they promised the government that they would operate as a Charity provider of health care for the uninsured and that it would not engage in business "directly Of indirect! v, for the benefit of private interests" In reality, the Jeffereon Health Defendants dojusi JK OvU Action N
  
  
• Trinity Health-Michigan, Inc.: Class Action Complaint (194 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN APRIL GRANT, VELISIA LEGRAND, and ) ROBERT HOULE, On Behalf of Herself and ) All Others Similarly Situated, ) ) Civil Action No.: Plaintiffs ) ) Judge ___________________ vs. ) ) TRINITY HEALTH-MICHIGAN, INC.; ) CLASS ACTION TRINITY HEALTH CORPORATION; ) AMERICAN HOSPITAL ASSOCIATION; and ) JURY TRIAL DEMANDED JOHN DOES 1 THROUGH 10. ) ) Defendants. ) __________________________________________ ) Kelley Cawthorne, PLLC Frank J. Kelley (P15818) Steven D. Weyhing (P30749) Attorneys for Plaintiffs Kelley Cawthorne, PLLC 101 S. Washington Square 9th Floor Lansing, MI 48917 ______________________________________________________________________________
  
  
• Integris Health, Inc.: First Amended Class Action Complaint (131 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA CLAYTON WOODRUM, ARMANDO ) MARTINEZ, KENNETH L. THOMAS, and ) MIKE L. SHANNON on behalf of themselves ) and allothers similarly situated ) ) PLAINTIFFS ) ) vs. ) Civil Action No.: 5:04-cv-835 ) INTEGRIS HEALTH, INC; and AMERICAN ) HOSPITAL ASSOCIATION. ) ) DEFENDANTS. ) FIRST AMENDED CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL COME NOW, the Plaintiffs CLAYTON WOODRUM, ARMANDO MARTINEZ, KENNETH L. THOMAS, and MIKE L. SHANNON, by and through their undersigned counsel of record, and file this First Amended Class Action Complaint, adding as a Defendant AMERICAN HOSPITAL ASSOCIATION (hereinafter referred to as AHA). The Plaintiffs are seeking monetary damages, injunctive and other equitable relief against the Defendant INTEGRIS HEALTH, INC. (herei
  
  
• Promedica Health System, Inc.: Class Action Complaint (2.20 MB)
  IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION JILL SHRINER, On Behalf of Herself and All Others Similarly Situated, 4747 Luann Toledo, OH 43623 Plaintiff, vs. PROMEDICA HEALTH SYSTEM, INC., Jeffrey C. Kuhn, Registered Agent 2121 Hughes Dr. Floor E Toledo, Ohio 43606 and AMERICAN HOSPITAL ASSOCIATION, James A. Henderson, Registered Agent One North Franklin Street Suite 2700 Chicago, IL 60606 and JOHN DOES 1 THROUGH 10, Defendants. L CSselNo: JUDGE:1 fy f j t CLASS ACTION COMPLAINT (Jury Demand Endorsed Hereon) The Plaintiff files this Class Action Complaint seeking monetary damages, injunctive, and other equitable relief against the Defendants and alleges the following: -1- I. Introduction Defendant ProMedica Health System. Inc. holds itself out as a charitable non-profit entity. In exchange for its promise to operate as a charitable, non-profit entity, ProMedica receives millions of dollars each year in Federal State and local tax exemptions.
  
  
• Resurrection Medial Center: Amended Class Action (6.75 MB)
  .;.-, ..-"' GSB/cal #10999 ' ^TIUG IN THE UNITED STATES DISTRICT COURT '>: 35 FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION----- WOJCIECH CYGAN, on Behalf of Himself and All Others Similarly Situated, Plaintiffs, vs. RESURRECTION MEDICAL CENTER, an Illinois not-for-profit corporation, RESURRECTION HEALTH CARE, an Illinois not-for-profit corporation, AMERICAN HOSPITAL ASSOCIATION, an Illinois not-for-profit corporation and JOHN DOES 1 THRU 10, Defendants. " ' ° Civil Action No. 04 C 4168 Jury Trial Demanded AMENDED CLASS ACTION COMPLAINT Plaintiff WOJCIECH CYGAN, by and through his attorneys, CLIFFORD LAW OFFICES, P.C., and SCRUGGS LAW FIRM, P.A., files this Amended Class Action Complaint seeking monetary damages, injunctive and other equitable relief against RESURRECTION MEDICAL CENTER, an Illinois not-for-profit corporation, RESURRECTION HEALTH CARE, an Illinois not-for-profit corporation, AMERICAN HOSPITAL ASSOCIATION, an Illinois not-for-profit corporation and JOHN DOES 1 THRU 10, and in su
  
  
• Provena Health: Amended Class Action Complaint (7.49 MB)
  GSB/cal #10999 r~i 1- C ¦t * '"'"-•¦•-'- IN THE UNITED STATES DISTRICT COURT. . FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION JOSEPH DUMAS, SR. and LA VERNE DUMAS, on Behalf of Themselves and All Others Similarly Situated, Plaintiffs, vs. PROVENA HEALTH, an Illinois not-for-profit corporation, PROVENA HOSPITALS, an Illinois not-for-profit corporation, AMERICAN HOSPITAL ASSOCIATION, an Illinois not-for-profit corporation and JOHN DOES 1 THRU 10, Defendants. Civil Action No.: 04 C 4063 Jury Trial Demanded AMENDED CLASS ACTION COMPLAINT Plaintiffs DUMAS, by and through their attorneys, CLIFFORD LAW OFFICES, P.C., and SCRUGGS LAW FIRM, P.A., file this Amended Class Action Complaint seeking monetary damages, injunctive and other equitable relief against PROVENA HEALTH, an Illinois not-for-profit corporation, PROVENA HOSPITALS, an Illinois not-for-profit corporation, AMERICAN HOSPITAL ASSOCIATION, an Illinois not-for-profit corporation, and JOHN DOES 1 THRU 10, and in support thereof a
  
  
• Advocate Health Care Network: Amended Class Action Complaint (8.04 MB)
  GSB/cal r"--.'¦"' '. IN THE UNTTED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION ^ ¦ j JANNIE WATTS and KATHERINE A. MAZUR, On Behalf of Themselves and All Others Similarly Situated, Plaintiffs vs. ADVOCATE HEALTH CARE NETWORK, an Illinois not-for-profit corporation, and ADVOCATE HEALTH AND HOSPITALS CORPORATION, an Illinois not-for-profit corporation, AMERICAN HOSPITAL ASSOCIATION, an Illinois not-for-profit corporation, and JOHN DOES 1 THROUGH 10 Civil Action No.: 04 C 4062 Jury Trial Demanded AMENDED CLASS ACTION COMPLAINT Plaintiffs, JANNIE WATTS and KATHERINE A. MAZUR, by and through their attorneys, CLIFFORD LAW OFFICES, P.C., and SCRUGGS LAW FIRM, P.A., file this Amended Class Action Complaint seeking monetary damages, injunctive and other equitable relief against ADVOCATE HEALTH CARE NETWORK, an Illinois not-for-profit corporation, ADVOCATE HEALTH AND HOSPITALS CORPORATION, an Illinois not-for-profit corporation, AMERICA HOSPITAL ASSOCI
  
  
• Cleveland Clinic Foundation: Class Action Complaint (0.85 MB)
  IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION MITULKUMAR PATEL, On Behalf of himself and All Others Similarly Situated Plaintiff S04CV1330 JUDGE MATIA JUDGE: (Jury Demand Endorsed Hereon) vs. CLEVELAND CLINIC FOUNDATION, CLEVELAND CLINIC HEALTH SYSTEM, FA1RVIEW HOSPITAL and JOHN DOES 1 THROUGH 10 Defendants The Plaintiff files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and alleges the following: I. Introduction Defendants, The Cleveland Clinic Foundation and The Cleveland Clinic Health System (hereinafter collectively referred to as "CCF") holds itself out as a charitable non-profit entity. In exchange for its promise to operate as a charitable, non-profit entity, CCF receives millions of dollars each year in Federal, State and local tax exemptions. In reality, CCF is anything but charitable. While it promises to provide affordable care to the uninsured poor, CCF has and continue
  
  
• Ochsner Clinic Foundation: Complaint (1.44 MB)
  I'S.P.'STRICT COURT CAST {.STRICT OF LA ::"i .r.:.*' i:¦•'-. w* ti^TTAG.WMYTE CLERK UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA EILEEN MALDONADO, On Behalf of ) Herself and All Others Similarly Situated ) ) vs. ) Civil Action No.: 04-1987 ) OCHSNER CLINIC FOUNDATION ) and JOHN DOES 1 THROUGH 10 ) SECTFMAi.3 COMPLAINT - CLASS ACTION f JURY TRIAL DEMANDED^ The Plaintiff, Eileen Maldonado, hereby files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and alleges the following; I. Introduction Defendant Ochsner Clinic Foundation has operated free from federal and state taxes because it promised the government that it would operate as a charity provider of health care for the uninsured and that it would not engage in business "directly or indirectly, for the benefit of private interests."
  
  
• New York-Presbyterian Hospital: Class Action Complaint For Violations Of The Unfair Debt Collection Practices Act (15 U.S.C. 1692 Et Seq.), Breach Of Contract, Breach Of Duty Of Good Faith And Fair Dealing, Violations Of New York General Business Law 349;... (0.73 MB)
  4/% BERNSTEIN LIEBHARD & LIFSHITZ, Keith M. Fleischman (KF-0199) Ronald J. Aranoff (RA-4690) 10 East 40th Street, 22nd Floor New York, New York 10016 Telephone: (212)779-1414 Facsimile: (212) 779-3218 P5^ £5-i» *f&\ f> Attorneys for Plaintiff UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORKU.S -DC. S.D. N.Y. SHKELQIM KOLARI on Behalf of Himself and All Others Similarly Situated Plaintiffs, v. NEW YORK-PRESBYTERIAN HOSPITAL, NEW YORK-PRESBYTERIAN HEALTH CARE SYSTEM, INC., and JOHN DOES 1-10, Defendants, CIVIL ACTION NO. CLASS ACTION COMPLAINT FOR VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT (15 U.S.C. § 1692 etseq.), BREACH OF CONTRACT, BREACH OF DUTY OF GOOD FAITH AND FAIR DEALING, VIOLATIONS OF NEW YORK GENERAL BUSINESS LAW § 349; UNJUST ENRICHMENT, CONSTRUCTIVE TRUST, INJUNCTIVE RELIEF AND DECLARATORY RELIEF JURY TRIAL DEMANDED Plaintiff Shkelqim Kolari, by his attorneys, brings this action on behalf of himself and all other persons similarly situated for his claim u
  
  
• William Beaumont Hospital: Class Action Complaint (197 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN JENNIFER BURTON, FRANCIS BURTON, and NIA BURTON, by her next friend, FRANCIS BURTON, On Behalf of Themselves and All Others Similarly Situated, Plaintiffs vs. WILLIAM BEAUMONT HOSPITAL; BEAUMONT PROPERTIES, INC.; AMERICAN HOSPITAL ASSOCIATION; JOHN DOES 1 THROUGH 10. Civil Action No.: Judge __________________ ) JURY TRIAL DEMANDED CLASS ACTION Defendants. __________________________________________________) Kelley Cawthorne, PLLC Frank J. Kelley (P15818) Steven D. Weyhing (P30749) Attorneys for Plaintiffs Kelley Cawthorne, PLLC 101 S. Washington Square 9th Floor Lansing, MI 48917 ______________________________________________________________________________________________ CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) The Plaintiffs Jennifer Burton and Francis Burton file this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and allege the following: INTRODUCTION 1. Defendants Wi
  
  
• Integris Health, Inc.: Class Action Complaint (1.11 MB)
  07/08/04 THU 09:26 FAX 4052365499 Rex K. Travis L&IUOl ¦ ¦¦ and aU others i&*il^iysltu.afTed" •: ; vs. ; . '"'''¦•'¦'¦¦'¦ -y^0lM0£^;¦¦¦¦¦''¦¦::/-¦ ¦'¦; TO: :i Tntiftpis'fteaftl^ _ ..:¦¦ = -YOih^aMi^^ '¦.:.¦¦:;:.¦¦::.¦:¦: ;^ •:/;:::-'.:^ •/Attorney for'Heiii^fe' ".'\ an-aiiswet-tfrtfa&'eon^ of this . i sunnrions-upoujmi. e'xx^ defewll.will ';:' be utfceMgainsryati'fd^ ¦""¦>-"..¦¦¦ ¦;:.--¦•¦:¦:.:''" ;¦)-.'; .:.¦-• ¦';;¦¦;:';..¦..¦¦•-¦¦.¦* ''.. ¦ ) ' .'-.:-¦¦¦¦¦¦¦.-':¦¦: -.¦):--: ¦'¦ .-•¦"" ,.-•*•¦"" "¦ )'.'. ••¦•:-Sf6*:.".v:"/¦•..:•-•-•:.. •..¦-: JUL-07-2004 09 = 37 4052365499 9?>S
  
  
• Lee Memorial Health System: Class Action Complaint (1.06 MB)
  Jul 08 04 10:3Ga CRRLTONiCflRLTON 1941B3908G2 P.3 ¦VA.0 "W.rt (Rev. M/?3J Summon* in n Civil Aut.li«i MIDDLE United states district Court Disra.a of FLORIDA WAYNE NASH, on behalf of himself and all others similarly situated V. SUMMONS IN A CIVIL CASE LEE MEMORIAL HEALTH SYSTEM CA *S£ ^^ -b^- 3&1 #tM-29DNF TO! (N"P* and (idrtr=Ki of Dcfsiidnnl) LEE MEMORIAL HEALTH SYSTEM, 636 DEL PRADO BLVD. CAPE CORAL, FLORIDA 33902 YOU ARE HEREBY SUMMONED and required to serve upcm PLAINTIFF'S ATTORNEY (^eomimM,™,) MARK B, SAINE, DAVID P. CARLTON, Carlton & Carlton Attorneys at Law, P.A., 260 W. Olynapia Ave., Punta Gorda, FL 33950; ARCHIE C. LAMB, JR., A. DAVID FAWAL, CHRIS W. CANTRELL, Law Offices of Archie Lamb, LLC, 2017-2nd Avenue North, Birmingham, AL 35203; and E. KIRK WOOD, P.O. Box 3 82434, Birmingham, AL 35238. .days after service of this 20 mi miswer to Oic complaint which is hsTowitb served Tiponyou, within _______________ summon? upcuxyou, exclusive or the day of
  
  
• Florida Hospital Healthcare System, Inc.: Class Action Complaint (1.14 MB)
  Jul 08 04 10:44a CflRLTON&CRRLTOH 194163908G2 "&..A.0 rtlO (ti.\sv. H1/93J JSi'mroc-ti* i'i * Civil Mi'mn United States District Court MIDDLE_____________District of FLORIDA_______ EDWARD C. JELLISON , on behalf of himself and all others similarly situated SUMMONS m A CTVTL CASE v. FLORIDA HOSPITAL HEALTHCARE / ¦ n J g \f _ /QQ.J ~ #/2 L - o? * U1 " SYSTEMS, INC. d/b/a FLORIDA HOSPITAL; and ADVENT1ST HEALTH SYSTEM/SUNBELT, INC. T0:(>j nmc rnd adcU'Sii. of Defendant) FLORIDA HOSPITAL HEALTHCARE SYSTEM, INC. d/b/a FLORIDA HOSPITAL, 601 EAST ROLLINS STREET, ORLANDO, FLORIDA 32803 YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY (..omc *d «»<«.,) MARK B. SAINE, DAVID P. CARLTON, Carlton & Carlton Attorneys at Law, P. A., 260 W. Olympia Ave., Punta Gorda, FL 33950; ARCHIE C. LAMB, JR., A. DAVID FAWAL, CHRIS W. CANTRELL
  
  
• MCG Health, Inc.: Class Action Complaint (1.39 MB)
  us r>!:-:'*SD IN THE UNITED STATES DISTRICT COURT ' FOR THE SOUTHERN DISTRICT OF GEORGIA 2$ J& -7 ^ BRIDGET LIVELY, On Behalf of Herself and AH Others Similarly Situated, Plaintiff vs. MCG HEALTH, INC.; MEDICAL COLLEGE OF GEORGIA FOUNDATION, INC.; and JOHN DOES 1 THROUGH 10. Defendants. Civil Action No.: COMPLAINT-CLASS ACTION CV104-113 CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) The Plaintiff Bridget Lively files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and alleges the following: I. INTRODUCTION Defendants MCG Health, Inc. and Medical College of Georgia Foundation, Inc. ("the MCG Health Defendants") have operated free from federal and state taxes because they promised the government that they would operate as a charity provider of health care for the uninsured and that it would not engage in business "directly or indirectly, for the benefit of private interests." In reality, the M
  
  
• Baptist Health System, Inc.: First Amended Class Action Complaint (1.02 MB)
  UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION FILED OUJUL-l PH3--5U iv q tvsTRlCT COUR Civil Action No.:04-BE-1247-S RHONDA KIZZIRE, LARRY CALVIN MARTIN, and MICHAEL R. DENNIS, on behalf of themselves and all others similarly situated, PLAINTIFFS vs. BAPTIST HEALTH SYSTEM, INC.; DEFENDANT. FIRST AMENDED CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED^ COMES NOW, the Plaintiff RHONDA KIZZIRE, by and through her undersigned counsel of record, and pursuant to Fed. R. Civ. P. 15(a), files this her First Amended Class Action Complaint, adding as plaintiffs LARRY CALVIN MARTIN and MICHAEL R. DENNIS. The Plaintiffs are seeking monetary damages, injunctive and other equitable relief against the Defendant BAPTIST HEALTH SYSTEM, INC. (hereinafter referred to as "BHS") and in support thereof would show unto the Court the following to-wit: I. Introduction Baptist Health System, Inc. ("BHS") is the largest health care system in Alabama and one of the state's largest employers
  
  
• Baptist Health System, Inc.: Class Action Complaint (267 KB)
  UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION RHONDA KIZZIRE, on behalf of ) herself and all others similarly situated ) ) PLAINTIFF ) vs. ) Civil Action No.: ________________ ) BAPTIST HEALTH SYSTEM, INC.; ) ) DEFENDANT. ) CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) COMES NOW, the Plaintiff RHONDA KIZZIRE, by and through the undersigned counsel of record, and files this Class Action Complaint, seeking monetary damages, injunctive and other equitable relief against the Defendant BAPTIST HEALTH SYSTEM, INC. (hereinafter referred to as “BHS”) and in support thereof would show unto the Court the following to-wit: I. Introduction Baptist Health System, Inc. (“BHS”) is the largest health care system in Alabama and one of the state’s largest employers. BHS is a not-for-profit, 501(
  
  
• Long Island Jewish Medical Center: Class Action Complaint For Violations Of The Fair Debt Collection Practices Act (15 U.S.C. 1692 Et Seq.), Breach Of Contract, Breach Of Duty Of Good Faith And Fair Dealing, Violations Of New York General Business Law Sec... (1.00 MB)
  BERNSTEIN LIEBHARD & LIFSHITZ, LLP Keith M, Fleischman (KF-0199) Robert J. Berg (RB-8542) Ronald J. Aranoff (RA-4690) 10 East 40th Street, 22nd Floor New York, New York 10016 Telephone: (212)779-1414 Facsimile: (212) 779-3218 U& DISTRICT COURT. EDJNY * JUL 2 12004 *" BROOKLYN OFFICE Attorneys for Plaintiffs UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK SANDRA CARLSON and MARJORIE CUMMINGS, on Behalf of Themselves and All Others Similarly Situated, Plaintiffs, v. LONG ISLAND JEWISH MEDICAL CENTER, NORTH SHORE UNIVERSITY HOSPITAL IN MANHASSET, NORTH SHORE-LONG ISLAND JEWISH HEALTH SYSTEM, INC., AMERICAN HOSPITAL ASSOCIATION, and JOHN DOES 1-10, ILA ASS ACTION COMPLAINT FOR VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT (15 U.S.C, § 1692 etseq.), BREACH OF CONTRACT, BREACH OF DUTY OF GOOD FAITH AND FAIR DEALING, VIOLATIONS OF NEW YORK GENERAL BUSINESS LAW SECTION 349, UNJUST ENRICHMENT, CONSTRUCTIVE TRUST, INJUNCTIVE RELIEF AND DECLARATORY RELIEF Defendants. JURY TRIAL DEMAND
  
  
• Orlando Regional Healthcare System, Inc.: Class Action Complaint (116 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION GEORGE R. KABELLER, PEDRO ) GONZALEZ and ALEXANDER KINGHORN, ) on behalf of themselves and all others similarly ) situated, ) ) PLAINTIFFS ) vs. ) Civil Action No.: ________________ ) ORLANDO REGIONAL HEALTHCARE ) SYSTEM, INC; and AMERICAN HOSPITAL ) ASSOCIATION, ) ) DEFENDANTS. ) CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL COME NOW, the Plaintiffs GEORGE R. KABELLER, PEDRO GONZALEZ and ALEXANDER KINGHORN, by and through the undersigned counsel of record, and file this Class Action Complaint, seeking monetary damages, injunctive and other equitable relief against the Defendants ORLANDO REGIONAL HEALTHCARE SYSTEM, INC., (hereinafter referred to as “ORHS”) and AMERICAN HOSPITAL ASSO
  
  
• Presbyterian Healthcare Services: Class Action Complaint (104 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT NEW MEXICO RICHARD GARCIA, on behalf of ) himself and all others similarly situated; ) ) PLAINTIFF ) ) vs. ) Civil Action No.: ) ) PRESBYTERIAN HEALTHCARE ) SERVICES; and AMERICAN HOSPITAL ) ASSOCIATION, ) ) DEFENDANTS. ) CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) COMES NOW, the Plaintiff RICHARD GARCIA , by and through the undersigned counsel of record, and files this Class Action Complaint, seeking monetary damages, injunctive and other equitable relief against the Defendants PRESBYTERIAN HEALTHCARE SERVICES (hereinafter referred to as “Presbyterian Health”) and AMERICAN HOSPITAL ASSOCIATION (hereinafter “AHA”) and in support thereof would show unto the Court the following to-wit: I. Introduction
  
  
• Centura Health Corporation: Second Amended Class Action Complaint (128 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO GEORGE SCOTT FERGUSON, on behalf of ) himself and all others similarly situated; ) ADRIAN LINARES, on behalf of ) himself and all others similarly situated; and ) GARY STOEBER, on behalf of ) himself and all others similarly situated; ) GINGER GENTRY, on behalf of ) herself and all others similarly situated; ) ) PLAINTIFFS ) ) vs. ) ) CENTURA HEALTH CORPORATION; ) CATHOLIC HEALTH INITIATIVES; ) CATHOLIC HEALTH INITIATIVES ) COLORADO; PORTERCARE ADVENTIST ) HEALTH SYSTEM; and AMERICAN ) HOSPITAL ASSOCIATION. ) ) DEFENDANTS. ) SECOND AMENDED CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) COMES NOW, the Plaintiffs GEORGE SCOTT FERGUSON,
  
  
• Centura Health Corporation: Amended Class Action Complaint (142 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO GEORGE SCOTT FERGUSON, on behalf of himself and all others similarly situated; ADRIAN LINARES, on behalf of himself and all others similarly situated; and GARY STOEBER, on behalf of himself and all others similarly situated; GINGER GENTRY, on behalf of herself and all others similarly situated; vs. PLAINTIFFS CENTURA HEALTH CORPORATION; CATHOLIC HEALTH INITIATIVES; CATHOLIC HEALTH INITIATIVES COLORADO; and PORTERCARE ADVENTIST HEALTH SYSTEM DEFENDANTS. Civil Action No.: 04-M-1285 (PAC) AMENDED CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) COMES NOW, the Plaintiffs GEORGE SCOTT FERGUSON, ADRIAN LINARES, GARY STOEBER, and GINGER GENTRY (hereinafter collectively referred to as “Plaintiffs”), by and through the undersigned counsel of record, and file this Class Action Complaint, seeking monetary damages, injunctive and other equitable relief against the Defendants CENTURA HEALTH CORPORATION (hereinafter referred to as “Centura Health”
  
  
• Sutter Health: Class Action Complaint For Damages And Injunctive Relief: 1) Third Party Breach Of Contract 2) Breach Of Contract 3) Breach Of Duty Of Good Faith And Fair Dealing 4) Breach Of Charitable Trust 5) Violation Of The California Unfair Competiti... (0.61 MB)
  6 7 8 9 10 11 [i 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 y? . _** ii Elizabeth J. Cabraser, SBN 83151 Bill Lann Lee, SBN 108452 Kelly M. Dermody, SBN 171716 Caryn Becker, SBN 196947 LIEFF, CABRASER, HEIMANN & BERNSTEIN, LLP 275 Battery Street, 30th floor San Francisco, California 94111-3339 Telephone: (415)956-1000 Facsimile: (415)956-1008 Attorneys for Plaintiff Duane Darr °4 , - C, a. . o. [Additional Names of Plaintiff's Counsel appear on Signature Page] UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA DUANE DARR, on behalf of himself and all others similarly situated, Plaintiff, vs. SUTTER HEALTH; and DOES USD, inclusive. Defendants. Case No.: 'i.j- CLASS ACTION COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF; 1) THIRD PARTY BREACH OF CONTRACT 2) BREACH OF CONTRACT 3) BREACH OF DUTY OF GOOD FAITH AND FAIR DEALING 4) BREACH OF CHARITABLE TRUST 5) VIOLATION OF THE CALIFORNIA UNFAIR COMPETITION ACT (BUSINESS AND PROFESSIONS CODE § 17200, ET
  
  
• Banner Health: Class Action Complaint (1.26 MB)
  Barry G. Reed, AZ Bar No. 020906 Hart L. Robinovitch, AZ Bar No. 020910 ZIMMERMAN REED P.L.L.P. 14646 N. Kierland Boulevard, Suite 145 Scottsdale, AZ 85254 . (480) 348-6400 (480) 348-6415 Facsimile Grant Woods, P.C., AZ Bar No. 006106 ATTORNEY AT LAW Brennan House 1726 North Seventh Street, Suite 3 Phoenix, AZ 85006-2230 (602) 258-2599 (602) 258-5070 Facsimile UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA GREGORY JAMES FIELDS, On Behalf of Himself and All Others Similarly Situated, Plaintiff, v. BANNER HEALTH, Defendant. No. CLASS ACTION COMPLAINT JURY TRIAL DEMANED Plaintiff Gregory James Fields files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendant and alleges the following: I. Introduction 1. Defendant Banner Health, a Phoenix-based healthcare provider, represents to the public, through its federal filings, that it has a charitable mission and that it fulfills this mission by providing services to patient
  
  
• Baylor Health Care System: Class Action Complaint (2.61 MB)
  •> ¦ IN THE UNITED STATES DISTRICT COURT | FOR THE NORTHERN DISTRICT OF DALLAS | JUN 2 jmi JANAY CARGTLE, BARBARA CLINTON, RAUL ARRIAGA, AND MI HEE LEE On Behalf of Themselves and All Others Similarly Situated vs. BAYLOR HEALTH CARE SYSTEM, BAYLOR UNIVERSITY MEDICAL CENTER, BAYLOR MEDICAL CENTER AT GARLAND, and JOHN DOES 1 THROUGH 10 " '^.WMklCTCOL-Kf Uc^uij PLAINTIFFS Civil Action No.: 8-04CV-IS A DEFENDANTS CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) The Plaintiffs file this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against Baylor Healthcare System, Baylor University Medical Center, and Baylor Medical Center at Garland (hereinafter collectively referred to as "Defendant Baylor") and allege the following' I. Introduction Defendant Baylor has operated free from federal taxes because it promised the government that it would operate as a charity provider ofhealth care for the uninsured and that it would not engage in business "directly
  
  
• Resurrection Medical Center: Class Action Complaint (8.19 MB)
  GSB/cal 010999 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION RECEIVED »HUN 2 2 2004 MICHAEL W. DOBBINS CLERK. U.S. DISTRICT COURT WOJCIECH CYGAN, on Behalf of Himself and All Others Similarly Situated, Plaintiffs, vs. RESURRECTION MEDICAL CENTER, an Illinois not-for-profit corporation, RESURRECTION HEALTH CARE, an Illinois not-for-profit corporation, and JOHN DOES 1 THRU 10, Defendants. Civil Action No.: 04C 416 8 Jury Trial Demanded JUDGE G0TTSCHALC MAGISTRATE JUDGE MASON CLASS ACTION COMPLAINT Plaintiff WOJCIECH CYGAN, by and through his attorneys, CLIFFORD LAW OFFICES, P.C., and SCRUGGS LAW FIRM, P.A., files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and in support thereof alleges the following: I. Introduction Defendants RESURRECTION MEDICAL CENTER and RESURRECTION HEALTH CARE ("Resurrection"), both of which are registered as Illinois not-for-profit corporations, ho
  
  
• Centura Health Corporation: Class Action Complaint (89 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO GEORGE SCOTT FERGUSON, on behalf of ) himself and all others similarly situated ) vs. ) PLAINTIFF ) ) Civil Action No.: ________________ CENTURA HEALTH CORPORATION; ) CATHOLIC HEALTH INITIATIVES; ) CATHOLIC HEALTH INITIATIVES ) COLORADO; and PORTERCARE ) ADVENTIST HEALTH SYSTEM ) DEFENDANTS. ) CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) COMES NOW, the Plaintiff GEORGE SCOTT FERGUSON, by and through the undersigned counsel of record, and files this Class Action Complaint, seeking monetary damages, injunctive and other equitable relief against the Defendants CENTURA HEALTH CORPORATION (hereinafter referred to as ACentura Health@); CATHOLIC HEALTH INITIATIVES (hereinafter referred to as ACHI@); CATHOLIC HEALTH INITIATIVE
  
  
• Athens Regional Health Services, Inc.: Class Action Complaint (1.45 MB)
  IUN-30-E004 17:46 FROM:UROON 8, CRONGEYER,LL 4046076711 T0:9166E£81131£ P.E'E8 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA KIMBERLY HOGLAND, On Behalf of Herself and All Others Similarly Situated, Plaintiff vs. ATHENS REGIONAL HEALTH SERVICES, INC.; ATHENS REGIONAL MEDICAL CENTER, INC., and JOHN DOES 1 THROUGH 10. Defendants. Civil Action No.:' irr'!y::o CLCuf/w ¦-!' r XE U_. 17 Pil ^05 r o. :¦'¦ ¦.:: wr.i ¦¦.IDDLTni'^'J-TCKC^GIA .3 : O*"*.^^^ COMPLAINT - CLASS ACTION CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) The Plaintiff Kimberly Hogland files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and alleges the following: 1. INTRODUCTION Defendants Athens Regional Health Services, Inc. and Athens Regional Medical Center, Inc. ("the Athens Regional Defendants'") have operated free from federal and state taxes because they promised the government that they would operate as charity providers of he
  
  
• East Texas Medical Center Regional Healthcare System: Class Action Complaint (1.08 MB)
  JUN-16-2004 WED 05:00 PM THF ^CHARDS LAW FIRM FAX NO. 4 P. 07 IN THIS UNITED STATES DISTRICT COURT 0£ ,h ' L0{Jl FOR THE EASTERN DISTRICT OF TEXAS v°'* J6 flu p, MARSHALL DIVISION /TlM i» '' ^ Og fly " LASTfa CRYSTAL LYNN McCOY and CORA ''"¦¦... ' :/|(V FAY EDISON, On Behalf of ) Themaolvcfj and All others ) Similarly Situated, ) PLAINTIFFS ) > Civil Action No. P'0^' C{/ ^3 ) RAST TEXAS MBUICAL CENTER ) REGIONAL HRATiTHCARE SYSTEM j HAST TflXAS MEDICAL CENTER - ) JACKSONVILLE, and EAST TEXAS ) MEDICAL CENTER, ) DEFENDANTS cuis s a av i on compl a tnt (JURY TRIM, DEMAND
  
  
• St. Thomas Hospital, Inc.: Class Action Complaint (0.56 MB)
  THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE AT NASHVILLE PATRICK HAGEDORN, on behalf of himself i and all others similarly situated, Plaintiff, vs. ST. THOMAS HOSPITAL, INC. and JOHN DOES 1-10, Defendants. CLASS ACTION COMPLAINT Now into Court comes Plaintiff, by and through counsel and on behalf of himself and all others similarly situated, and files this Complaint, seeking monetary damages, injunctive and other equitable relief against the Defendants St. Thomas Hospital, Inc. ("Defendant") and John Does 1 through 10 and hereby alleges the following on information and belief. INTRODUCTION 1. Defendant holds itself out as a charitable non-profit entity. In exchange for its promise to operate as a charitable, non-profit entity, Defendant receives millions of dollars each year in federal, state and local tax exemptions. 2. In reality, Defendant is anything but charitable. While it promises to provide affordable care to the uninsured poor, Defendant has an
  
  
• Advocate Health Care Network: Class Action Complaint (1.37 MB)
  JN-16-2004 03:Z1I FR0M-28th Fl 312 7826857 T-803 P.DD2/00Z F-DOS GSB/cal IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION RECEIVED 'JUN 1 6 2004 MICHAEL W. DOBBINS CLERK. U.S. DISTRICT COURT JANNIE WATTS and KATHERINE A. MAZUR, On Behalf of Themselves and AH Others Similarly Situated, Plaintiffs vs. ADVOCATE HEALTH CARE NETWORK, an Illinois not-for-profit corporation, and ADVOCATE HEALTH AND HOSPITALS CORPORATION, an Illinois not-for-profit corporation, and JOHN DOES 1 THROUGH 10 04C 4062 Civil Action No. Jury Trial Demanded JUDGE G0TTSCHAL& i iJRB^fRATE JUDGE BOBMCR CLASS ACTION COMPLAINT Plaintiffs, JANNIE WATTS and KATHERINE A. MAZUR, by and through their attorneys, CLIFFORD LAW OFFICES, P.C., and SCRUGGS LAW FIRM, P.A,, File this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against ADVOCATE HEALTH CARE NETWORK, an Illinois not-for-profit corporation, ADVOCATE HEALTH AND HOSPITALS CORPORATION
  
  
• Wellstar Health Systems, Inc.: Class Action Complaint (1.29 MB)
  U.S.D.C. Atlanta IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA JUN/1 g 2004 UFTHqft D. JTHOMAS, Gtasfc JOHN R. CRUZ and DARINKA MARIA CRUZ, On Behalf of Themselves and AH Others Similarly Situated, Plaintiffs vs. WELLSTAR HEALTH SYSTEMS, INC., DOUGLAS HOSPITAL, INC., KENNESTONE HOSPITAL, INC., COBB HOSPITAL, INC., and JOHN DOES 1 THROUGH 10. Defendants. CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) The Plaintiffs file this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and allege the following: I. INTRODUCTION Defendants Wellstar Health System, Inc.. Douglas Hospital. Inc.. Kennestone Hospital. Inc.. and Cobb Hospital. Inc. ("the Wellstar Group") have operated free from federal and state taxes because they promised the government that they would operate as a charity provider of health care for the uninsured and that it would not engage in business "directly or indirectly, for the benefit of pr
  
  
• Phoebe Putney Health Systems, Inc.: Class Action Complaint (1.41 MB)
  IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA FILED us Trryi.:rcourt i - ' u ¦ ? i a DEBORAH GAIL ELLIS, On Behalf of Herself and All Others Similarly Situated, Plaintiff vs. PHOEBE PUTNEY HEALTH SYSTEMS, INC.;PHOEBE PUTNEY MEMORIAL HOSPITAL, INC.; and JOHN DOES 1 THROUGH 10. Defendants. QU m 16 PM 3: 31 , (3LFUTV CLERK Civil Action No.: 1 '. o4 -CA/-g9-3 CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) The Plaintiff Deborah Gail Ellis files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and alleges the following: I. INTRODUCTION Defendants Phoebe Putney Health System, Inc. and Phoebe Putney Memorial Hospital, Inc. ("the Phoebe Putney Defendants") have operated free from federal and state taxes because they promised the government that they would operate as a charity provider of health care for the uninsured and that it would not engage in business "directly or indirectly, for the benefit of private interests." In reali
  
  
• Medical Center Of Central Georgia, Inc.: Class Action Complaint (1.38 MB)
  IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA KATffi M. WASHINGTON, Individually and On Behalf of TERRELL WASHINGTON, a Minor, On Behalf of Themselves and All Others Similarly Situated, Plaintiffs vs. MEDICAL CENTER OF CENTRAL GEORGIA, INC., CENTRAL GEORGIA HEALTH SYSTEMS, INC., MEDCEN COMMUNITY HEALTH FOUNDATION, INC., and JOHN DOES 1 THROUGH 10. Defendants. Civil Action No. FiL.ro U s ^!r;iR:r;T (T'JRT i-: '!:i-. c-Tna a Ok M I 6 PH 3: 30 DEPJJ7Y CLERK 5 "0 4-CV-0185-2 CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) The Plaintiffs file this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and allege the following: I. Introduction Defendants Medical Center of Central Georgia, Inc., Central Georgia Health System, Inc., and Medcen. Community Health Foundation, Inc., ("the MCCG Defendants") have operated free from federal and state taxes because they promised the government that they would operate as a charity
  
  
• Baptist Health System, Inc: Class Action Complaint (1.18 MB)
  JUN-15-2004 16=14 ARCHIE LAMB LLC 205 324 4S49 P.02 UNITED STATES DISTRICT COURT l\ i - NORTHERN DISTRICT OF ALABAMA ,„ SOTTTWlTON mVIKTHN ""* J^J I 6 Pi"'] J: i 5 U. vJ. Li. .' i ;.'': '' T ' V'l |DT H.D.O'f ALABAMA RHONDA KIZZIRE, on behalf of herself and all others similarly situated CV-04-BE-1247-S PLAINTIFF vs. BAPTIST HEALTH SYSTEM, INC.; DEFENDANT. CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED^ COMES NOW, the Plaintiff RHONDA KIZZIRE, by and through the undersigned counsel of record, and files this Class Action Complaint, seeicing monetary damages, injunctive and other equitable reHef against the Defendant BAPTIST HEALTH SYSTEM, INC. (hereinafter referred to as "BHS") and in support thereof would show unto the Court the following to-wit: L INTRODUCTION Baptist Health System, Inc. ("BHS") is the largest health, care system in Alabama and one of the state's largest employers. BHS is a not-for-profit, 501 (c) charitable, tax-exempt corporation that owns and manages hos
  
  
• Allina Health System: Class Action Complaint (0.92 MB)
  RECEIVFD IN THE UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA n, II K P- - ' <"> PAUL KERN, On Behalf of Court File No. °LE , , , lT III f <{ ' Himself and All Others Similarly Situated " - Plaintiff vs. ALLINA HEALTH SYSTEM Defendants CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) Plaintiff files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and alleges the following: I. Introduction 1. Defendant Allina Health System, a Minneapolis based healthcare provider, represents to the public, through its federal filings, that it provides "charity care" in its hospitals "to all citizens, regardless of an individual's ability to pay." Allina defines charity care as "the cost of care which is provided to persons willing, but unable, to pay." Unless other specified, a
  
  
• Baptist Hospital Of Miami, Inc.: Class Action Complaint (183 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA MIRIAM SABETA and BARBARA COLOMAR, On Behalf of Themselves and All Others Similarly Situated, Plaintiffs vs. BAPTIST HOSPITAL OF MIAMI, INC.; BAPTIST HEALTH SOUTH FLORIDA, INC.; and JOHN DOES 1 THROUGH 10. Defendants. 04-21437 avii Action €I\LJQBJ3AN COMPLAINT-CLASS ACTION MAGISTRATE JUDGE BROWN ,a n , r~ r- ~" o» Dj: CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) _-" f-i i.:... The Plaintiffs file this Class Action Complaint seeking monetary damages, Itifuncfive alid o other equitable relief against the Defendants and allege the following: I. INTRODUCTION Defendants, Baptist Hospital of Miami, Inc. and Baptist Health South Florida, Inc. ("the Baptist Defendants"), have operated free from federal and state taxes because they advertised to the public and their patients, and promised to the government that they would operate as a charity provider of health care for the uninsured and that it would not
  
  
• Catholic Healthcare Partners: Class Action Complaint (0.87 MB)
  IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION ^ '^>, LLOIDA LORENS, On Behalf of Herself and All Others Similarly Situated Plaintiff vs. CATHOLIC HEALTHCARE PARTNERS, COMMUNITY HEALTH PARTNERS, COMMUNITY HEALTH PARTNERS HOSPITAL AND SURGICAL CENTER and JOHN DOES 1 THROUGH 10 Defendants CLASS ACTION COMPLAINT (Jury Demand Endorsed Hereon) MAG. JUDGE McHARGH The Plaintiff files this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and allege the following: I. Introduction Defendant, Catholic Healthcare Partners holds itself out as a charitable non-profit entity. In exchange for its promise to operate as a charitable, non-profit entity, Catholic Healthcare Partners receives millions of dollars each year in Federal, State and local tax exemptions. In reality, Catholic Healthcare Partner is anything but charitable. While it promises to provide affordable care to the uninsured poor, Catholic Health
  
  
• Saint Barnabas Health Care System: Class Action Complaint For Violations Of The Fair Debt Collection Practices Act (15 U.S.C. 1-692 Et Seq.), Breach Of Contract, Breach Of Duty Of Good Faith And Fair Dealing, Violations Of The New Jersey Consumer Fraud Ac... (0.90 MB)
  BERNSTEIN LIEBHARD & LIFSHITZ, LLP Robert J. Berg (RB-8542) Andrea Williams (AW-1798) 2050 Center Avenue, Suite 200 Fort Lee, New Jersey 07024 Telephone: (201) 592-3201 Facsimile: (201) 461-9598 RECEIVED-CLERK;-; U.S. DISTRICT COURT 28BH JUL -1 A % 32 BERNSTEIN LIEBHARD & LIFSHITZ, LLP Keith M. Fleischman (KF-0199) Francis P. Karam (FK-8288) Ronald J. Aranoff (RA-4690) Anne W. Salisbury (AS-7333) 10 East 40th Street, 22nd Floor New York, New York 10016 Telephone: (212)779-1414 Facsimile: (212) 779-3218 Attorneys for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY JOYCE CAMPBELL onBehalf of Herself and All Others Similarly Situated Plaintiffs, v. SAINT BARNABAS CORPORATION d/b/a SAINT BARNABAS HEALTH CARE SYSTEM, and JOHN DOES 1-10, Defendants, CIVIL ACTION NO. CLASS ACTION COMPLAINT FOR VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT (15 U.S.C. § 1692 et seq.), BREACH OF CONTRACT, BREACH OF DUTY OF GOOD FAITH AND FAIR DEALING, VIOLATIONS OF THE NEW JERSEY CONSUMER FRAUD ACT,
  
  
• Fairview Health Services: Second Amended Class Action Complaint (0.95 MB)
  IN THE UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA RACHEL PETERSON and CHAD Court File No. 04-2973 JOHNSON, On Behalf of Themselves (ADM/AJB) and All Others Similarly Situated Plaintiffs vs. FAIRVIEW HEALTH SERVICES Defendants SECOND AMENDED CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) Plaintiffs file this Second Amended Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and alleges the following: I. Introduction 1. Defendant Fairview Health Services ("Fairview"), a Minneapolis based healthcare provider, represents to the public, through its federal filings, that it has a "charitable mission" and that it fulfills this mission by "providing services to patients who are uninsured or underinsured" at a level that is "without charge or at a reduced cost to residents of the community." Unless other specified, all references to "Defendant" in
  
  
• Presbyterian Healthcare Services: Class Action Complaint (135 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT NEW MEXICO RICHARD GARCIA, on behalf of himself and all others similarly situated; PLAINTIFF vs. Civil Action No.: PRESBYTERIAN HEALTHCARE SERVICES; and AMERICAN HOSPITAL ASSOCIATION, DEFENDANTS. CLASS ACTION COMPLAINT (JURY TRIAL DEMANDED) COMES NOW, the Plaintiff RICHARD GARCIA , by and through the undersigned counsel of record, and files this Class Action Complaint, seeking monetary damages, injunctive and other equitable relief against the Defendants PRESBYTERIAN HEALTHCARE SERVICES (hereinafter referred to as “Presbyterian Health”) and AMERICAN HOSPITAL ASSOCIATION (hereinafter “AHA”) and in support thereof would show unto the Court the following to-wit: I. Introduction Presbyterian Healthcare Services, is one the largest health care systems in the State of New Mexico operating approximately eight(8) hospitals in New Mexico which meet 40% of the state’s healthcare needs. Defendant Presbyterian Healthcare Services is a no
  
  
• St. Elizabeth's Hospital Sisters Of The Third Order Of St. Francis: Complaint (162 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS BARBARA SEBREN, on behalf of herself and all others similarly situated, Plaintiffs, vs. ST. ELIZABETH’S HOSPITAL SISTERS OF THE THIRD ORDER OF ST. FRANCIS, d/b/a St. Elizabeth’s Hospital, AMERICAN HOSPITAL ASSOCIATION, and JOHN DOES 1-10 Defendants. Serve Registered Agent: St. Elizabeth’s Hospital Sisters of the Third Order of St. Francis c/o Loe A. Lenn, Registered Agent 4936 Laverna Road P.O. Box 19456 Springfield, IL 62794-9456 American Hospital Association c/o James A. Henderson, Registered Agent 1 North Franklin Street, Suite 2700 Chicago, IL 60606 Civil No. Class Action Jury Trial Demanded COMPLAINT Plaintiff Barbara Sebren, on behalf of herself and all others similarly situated, files this Complaint, seeking monetary damages, injunctive and other equitable relief against Defendants St. Elizabeth’s Hospital Sisters of the Third Order of St. Francis, d/b/a St. Elizabeth’s Hospital (St. Elizabeth’s), the American
  
  
• Protestant Memorial Medical Center, Inc.: Complaint (70 KB)
  IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS ROBERT C. SCHMITT, on behalf of himself and all others similarly situated, Plaintiff, vs. PROTESTANT MEMORIAL MEDICAL CENTER, INC., d/b/a Memorial Hospital, AMERICAN HOSPITAL ASSOCIATION, and JOHN DOES 1-10, Defendants. Serve Registered Agent: Protestant Memorial Medical Center c/o Harry R. Maier, Registered Agent 4500 Memorial Drive Belleville, IL 62223-5399 American Hospital Association c/o James A. Henderson, Registered Agent 1 North Franklin Street, Suite 2700 Chicago, IL 60606 COMPLAINT Plaintiff Robert C. Schmitt, on behalf of himself and all others similarly situated, files this Complaint, seeking monetary damages, injunctive and other equitable relief against Defendants Protestant Memorial Medical Center, Inc., d/b/a Memorial Hospital (“Memorial”), the American Hospital Association (“AHA”), and John Does 1 through 10 and hereby alleges the following on information and belief. Civil No. _______ Class Action Jury Tria
  
  
• Provena Health: Class Action Complaint (149 KB)
  GSB/cal #10999 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION JOSEPH DUMAS, SR. and LAVERNE DUMAS, on Behalf of Themselves and All Others Similarly Situated, Plaintiffs, vs. PROVENA HEALTH, an Illinois not-for-profit corporation, PROVENA HOSPITALS, an Illinois not-for-profit corporation, and JOHN DOES 1 THRU 10, Defendants. Civil Action No.: ________________ Jury Trial Demanded CLASS ACTION COMPLAINT Plaintiffs DUMAS, by and through their attorneys, CLIFFORD LAW OFFICES, P.C., and SCRUGGS LAW FIRM, P.A., file this Class Action Complaint seeking monetary damages, injunctive and other equitable relief against the Defendants and in support thereof allege the following: I. Introduction Defendants PROVENA HEALTH and PROVENA HOSPITALS (“Provena”), both of which are registered as Illinois not-for-profit corporations, hold themselves out as charitable, non-profit entities. In exchange for their promise to operate as a charitable, non-profit entity and th