IN THE STATE COURT OF LOWNDES COUNTY
`STATE OF GEORGIA
`
`LOWNDES COUNTY, GEORGIA
`Lowndes County - State Court
`2020SCV0475
`11/13/2020 9:27 AM
`Beth C. Greene
`Clerk of Superior State Juvenile Courts
`Reviewed by: Lindsey Tutt
`
`GUILLERMO SAURINA, M.D.,
`
`
`Plaintiff,
`
`v.
`
`HOSPITAL AUTHORITY OF
`VALDOSTA AND LOWNDES COUNTY,
`GEORGIA, d/b/a SOUTH GEORGIA
`MEDICAL CENTER; and BRIAN
`DAWSON, M.D.,
`
`Defendants.
`
`2020SCV0475
`Civil Action No.
`
`COMPLAINT FOR DAMAGES
`
`Plaintiff Dr. Guillermo Saurina, M.D., hereby files this his Complaint against
`
`Defendants Hospital Authority of Valdosta and Lowndes County, Georgia, d/b/a South
`
`Georgia Medical Center; and Brian Dawson, M.D., showing this Honorable Court as
`
`follows:
`
`I. PARTIES, JURISDICTION & VENUE
`
`1.
`
`Plaintiff Dr. Guillermo Saurina, M.D., is a citizen and resident of Lowndes
`
`County, Georgia.
`
`2.
`
`Defendant Hospital Authority of Valdosta and Lowndes County, Georgia, d/b/a
`
`South Georgia Medical Center (“SGMC”), is a hospital authority governed by
`
`OCGA § 31-7-72. SGMC’s principal place of business is in Lowndes County,
`
`Georgia. Upon information and belief, SGMC can be served with process through
`
`its chairman, Sam Allen, who can be served with process at 306 Jennifer Circle,
`
`Valdosta, GA 31605-6832.
`
`3.
`
`Defendant Dr. Brian Dawson, M.D., is a citizen and resident of Lowndes County,
`
`
`STATE OF GEORGIA
`
`LOWNDES COUNTY, GEORGIA
`Lowndes County - State Court
`2020SCV0475
`11/13/2020 9:27 AM
`Beth C. Greene
`Clerk of Superior State Juvenile Courts
`Reviewed by: Lindsey Tutt
`
`GUILLERMO SAURINA, M.D.,
`
`
`Plaintiff,
`
`v.
`
`HOSPITAL AUTHORITY OF
`VALDOSTA AND LOWNDES COUNTY,
`GEORGIA, d/b/a SOUTH GEORGIA
`MEDICAL CENTER; and BRIAN
`DAWSON, M.D.,
`
`Defendants.
`
`2020SCV0475
`Civil Action No.
`
`COMPLAINT FOR DAMAGES
`
`Plaintiff Dr. Guillermo Saurina, M.D., hereby files this his Complaint against
`
`Defendants Hospital Authority of Valdosta and Lowndes County, Georgia, d/b/a South
`
`Georgia Medical Center; and Brian Dawson, M.D., showing this Honorable Court as
`
`follows:
`
`I. PARTIES, JURISDICTION & VENUE
`
`1.
`
`Plaintiff Dr. Guillermo Saurina, M.D., is a citizen and resident of Lowndes
`
`County, Georgia.
`
`2.
`
`Defendant Hospital Authority of Valdosta and Lowndes County, Georgia, d/b/a
`
`South Georgia Medical Center (“SGMC”), is a hospital authority governed by
`
`OCGA § 31-7-72. SGMC’s principal place of business is in Lowndes County,
`
`Georgia. Upon information and belief, SGMC can be served with process through
`
`its chairman, Sam Allen, who can be served with process at 306 Jennifer Circle,
`
`Valdosta, GA 31605-6832.
`
`3.
`
`Defendant Dr. Brian Dawson, M.D., is a citizen and resident of Lowndes County,
`
`
`
`Georgia. Upon information and belief, Dr. Dawson can be served with process at
`
`603 Gornto Road, Valdosta, GA 31602-1604.
`
`4.
`
`The events that form the basis of this Complaint occurred in Lowndes County,
`
`Georgia.
`
`5.
`
`Jurisdiction and venue are proper in this Honorable Court.
`
`II. FACTUAL ALLEGATIONS
`
`6.
`
`Dr. Saurina is an infectious diseases doctor who previously practiced medicine at
`
`SGMC, in Valdosta, Georgia.
`
`7.
`
`From August 2015 to November 2018, Dr. Saurina wrote numerous letters to
`
`various SGMC officers, notifying them of a number of problems with SGMC’s lab
`
`and pharmacy.
`
`8.
`
`On August 24, 2015, for example, Dr. Saurina wrote to SGMC’s then-chief
`
`medical officer that patients at SGMC’s lab were being given false lab results.
`
`(Exhibit A). Upon information and belief, one patient was told he or she was
`
`negative for hepatitis B when in fact he or she was positive, and another patient
`
`was told he or she was positive for HIV when in fact he or she was negative. (Id.).
`
`9.
`
`On January 27, 2017, Dr. Saurina wrote to the then-Chief of SGMC’s Medical
`
`Executive Committee, stating, “The auto-stop orders by pharmacy, continues
`
`[sic] to put patients lives at risk, as well as our licenses.” (Exhibit B).
`
`10.
`
`On October 23, 2018, Dr. Saurina wrote to SGMC’s then-CEO, explaining, “The
`
`problems with microbiology persist. They are compromising patient care and
`
`length of stay.” (Exhibit C).
`
`11.
`
`On November 19, 2018, Dr. Saurina sent another letter to SGMC’s then-CEO,
`
`-2-
`
`
`
`with the subject line, “Poor quality of the lab putting patients’ lives at risk and
`
`increasing length of stay.” (Exhibit D).
`
`12.
`
`In response to these notices, SGMC not only failed to remedy the issues raised by
`
`Dr. Saurina, SGMC targeted Dr. Saurina.
`
`13.
`
`Upon information and belief, during this time, SGMC was close to losing its
`
`accreditation by the Joint Commission for Hospital Accreditation (JCHA), a basic
`
`standard for hospitals. In September of 2018, the JCHA issued a preliminary
`
`denial of accreditation. (“SGMC Under Scrutiny,” Valdosta Daily Times, Sep 20,
`
`2018, attached hereto as Exhibit E). A few weeks later, SGMC’s chairman, Sam
`
`Allen, declared that the culture at SGMC must change or there will be
`
`consequences. (“Chairman: Culture at SGMC must change,” Valdosta Daily
`
`Times, Sep 24, 2018, attached hereto as Exhibit F).
`
`14.
`
`To that end, upon information and belief, SGMC tasked Defendant Dr. Brian
`
`Dawson with disciplining all of SGMC’s “unruly” doctors. Also upon information
`
`and belief, Defendants planned to single out one or two doctors to intimidate all
`
`other doctors.
`
`15.
`
`Defendants then determined to make an example out of Dr. Saurina, and to turn
`
`him into scapegoat for the problems uncovered by the JHCA.
`
`16.
`
`Upon information and belief, Dr. Dawson or people associated with him
`
`instructed nurses to lodge complaints against Dr. Saurina. Dr. Dawson often went
`
`to the floors himself to drum up complaints against Dr. Saurina.
`
`17.
`
`From that point onward, approximately every two weeks, SGMC and/or Dr.
`
`Dawson lodged a formal complaint against Dr. Saurina for Dr. Saurina’s alleged
`
`-3-
`
`
`
`behavioral issues. These complaints were fabricated, over trivial matters, or both.
`
`18.
`
`Each time SGMC and/or Dr. Dawson filed a complaint against Dr. Saurina, Dr.
`
`Saurina was forced to spend considerable time and energy defending himself in
`
`front of a physician complaint committee.
`
`19.
`
`In the 17 years Dr. Saurina practiced with SGMC before Defendants began
`
`targeting him, Dr. Saurina received approximately four or five complaints. After
`
`Defendants targeted Dr. Saurina, over the course of six months, at least 12
`
`complaints were lodged against him.
`
`20.
`
`SGMC and/or Dr. Dawson’s complaints against Dr. Saurina were for things like
`
`wearing too much cologne and wearing an NRA hat while off duty in the hospital.
`
`21.
`
`Neither Defendant ever disclosed to Dr. Saurina the source of any of the
`
`complaints.
`
`22.
`
`At one point Defendants suspended Dr. Saurina’s privileges at SGMC. During this
`
`time, Dr. Saurina still had to pay his employee’s salaries while not earning any
`
`income.
`
`23.
`
`Defendants further humiliated Dr. Saurina by forcing him to undergo a
`
`psychological evaluation.
`
`24.
`
`Eventually, Dr. Saurina could not take it any more. Although Dr. Saurina still has
`
`privileges at SGMC, in November of 2019, he terminated his contractual
`
`relationship with SGMC pursuant to a provision in his contract requiring him to
`
`give 90-days’ notice.
`
`25.
`
`In a final gesture of ill will, SGMC did not pay Dr. Saurina for his last month of
`
`work at the hospital. This despite the fact that Dr. Saurina provided his services
`
`-4-
`
`
`
`for that month.
`
`III. INJURIES AND DAMAGES
`
`26.
`
`Through their harassment and persecution of Dr. Saurina, Defendants essentially
`
`ran Dr. Saurina out of Valdosta and Lowndes County.
`
`27.
`
`As a result of Defendants’ wrongful conduct toward Dr. Saurina, he almost had to
`
`close his medical practice in Valdosta and start all over in new cities, Tifton and
`
`Adel, Georgia. Dr. Saurina now only works half an afternoon per week in
`
`Valdosta, and he has had to move the vast majority of his practice to Tifton and
`
`Adel.
`
`28.
`
`As a result of Defendants’ wrongful conduct, including banishing Dr. Saurina’s
`
`medical practice from Valdosta and Lowndes County, Dr. Saurina has lost wages
`
`in the approximate amount of $261,000. Also, Dr. Saurina is expected to lose
`
`additional wages in the future.
`
`29.
`
`Starting over again in Tifton, every day Dr. Saurina has to commute from Hahira
`
`to Tifton. This results in Dr. Saurina having to spend an extra hour and a half per
`
`day, six days per week, commuting. Dr. Saurina could otherwise spend this time
`
`working, at a rate of $400 per hour.
`
`30. Moreover, through their incessant investigations and abuse of Dr. Saurina,
`
`Defendants damaged Dr. Saurina’s reputation and inflicted severe emotional
`
`distress on him.
`
`WHEREFORE, Plaintiff Guillermo Saurina, M.D., prays:
`
`a.
`
`That summons and process be issued and served upon Defendants SGMC
`
`and Dr. Dawson;
`
`-5-
`
`
`
`b.
`
`c.
`
`For a trial by a jury of 12 people;
`
`That Plaintiffs recover attorneys’ fees, all costs of litigation, and punitive
`
`damages against Defendants; and
`
`d.
`
`That Plaintiffs recover such other and further relief as the Court deems
`
`just and proper.
`
`Respectfully submitted this 13th day of November, 2020.
`
`/s/ Brent J. Savage
`Brent J. Savage
`Georgia Bar No. 627450
`Samuel L. Mikell
`Georgia Bar No. 241146
`
`SAVAGE, TURNER, DURHAM, PINCKNEY & SAVAGE
`P.O. Box 10600
`Savannah, GA 31412
`(912) 231-1140
`Fax: (912) 232-4212
`smikell@savagelawfirm.net
`
`
`
`Sam D. Dennis
`Georgia Bar No. 218315
`
`SAM D. DENNIS, P.C.
`1107 N. Patterson Street
`P.O. Box 1865
`Valdosta, Georgia 31603-1865
`(229) 244-4428
`
`-6-
`
`
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