Complaint (wrongful Birth)

• Library: Elements of Civil Causes of Action (SCBar) (2021 Ed.)

Complaint (Wrongful Birth)

STATE OF SOUTH CAROLINA COUNTY OF __________

__________, Plaintiff(s),

vs.

__________, Defendant(s).

IN THE COURT OF COMMON PLEAS

[Wrongful Birth]

COMPLAINT

The Plaintiffs, complaining of the Defendants above-named, would respectfully show unto this Honorable Court:

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That the Plaintiffs __________ and __________ are husband and wife and citizens and residents of the County of __________, State of South Carolina.

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That the Defendant __________ is a hospital corporation organized and existing under the laws of the State of South Carolina and operates as __________ [name of hospital] at __________ [address], __________ [city] in the County of __________, State of South Carolina. Defendant hospital provides services generally provided by hospitals.

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That the Defendant __________ is a citizen and resident of the County of __________, State of South Carolina, and at all times...