IN THE CIRCUIT COURT FOR DAVIDSON COUNTY, TENNESSEE GEORGIA LONG, individually, and Surviving Spouse to the Deceased, ROBERT LONG,
) ) ) Plaintiff, ) ) v. ) ) HCA HEALTH SERVICES OF ) TENNESSEE, INC. d/b/a CENTENNIAL ) MEDICIAL CENTER; DAVID HUNEYCUTT, ) M.D.; and CENTENNIAL HEART, LLC, d/b/a ) CENTENNTIAL HEART CARDIOVASCULAR ) CONSULTANTS, ) ) Defendants. )
MEDICAL MALPRACTICE AND PERSONAL INJURY JURY DEMAND
______________________________________________________________________________ COMPLAINT ______________________________________________________________________________ The Plaintiff, Georgia Long, for her causes of action against the Defendants, respectfully states to the Court and Jury the following: PARTIES, VENUE, AND JURISDICTION 1.
The Plaintiff, Georgia Long, is the surviving wife of Robert Long, and she is an
adult citizen and resident of Dickson County, Tennessee. 2.
Defendant HCA Health Services of Tennessee Inc., d/b/a Centennial Medical
Center (“Centennial,” “Centennial Medical Center,” or “CMC”), is a general hospital, licensed by the Tennessee Department of Health Board for Licensing Health Care facilities. Centennial is a “health care provider,” as that term is defined by Tenn. Code Ann. §29-26-101(2)(B). 3.
Centennial is a Tennessee corporation, with its principal place of business in
Nashville, Davidson County, Tennessee. Its main office, out of which it conducts most of its business (including that related to this case) is in Davidson County, Tennessee.