Orange County Superior Court
(Central Justice Center)

Case No. 00CC00796

Filed: January 11, 2000

Marc Bluestone
Attorney for the Plaintiff:
Robert Newman
Newman & Newman
1913 E. 17th Street, Suite 212
Santa Ana, CA 92705

Craig S. Bergstrom, D V M
Robert L. Rooks, D V M
All-Care Animal Referral Center

Attorney for the Defendant:
Elaine Regan
Shupe & Regan
333 Civic Center Drive West
Santa Ana, CA 92701

Complaint for Damages:
1) Negligence/Veterinary Malpractice
2) Trespass to Chattel
3) Negligence
4) Conversion
5) Deceit

Summary of Case: On or about January 13, 1999, Plaintiff presented his female dog "Shane" to the defendants at the defendants hospital for a check up and advice as to recommendations regarding general care and symptoms manifested by "Shane". Plaintiff was advised that the dog needed to have a course of examinations, treatment (s), and care.

Plaintiff did not know the risks about to be taken and the consequences likely and certain to follow such recommended procedures undertaken; and did not realize that the defendants did not have the expertise that they claimed they and their hospital had; nor that the work about to be undertaken was not advisable, and was dangerous to the life, health, and well being of his dog. Nor did Plaintiff have any idea that defendants did not have the qualifications represented.

From January 13, 1999 through the end of March 1999, the defendants, and each of them, worked on "Shane", incorrectly diagnosing the dog and applying treatments in such a grossly negligent manner as to cause her extreme injuries and damages, of temporary and permanent nature, and her untimely demise.

Court case pending.