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`Ryan M. Best, WSBA 33672
`Michael R. Merkelbach, WSBA 55389
`Jacob A. Mark, WSBA 54280
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`Best Law PLLC
`905 W. Riverside, Suite 409
`Spokane, WA 99201
`Phone: (509) 624-4422
`Fax: (509) 703-7957
`Email: ryan.best@bestlawspokane.com
`Attorney for Plaintiffs
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`IN UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF WASHINGTON
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND
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`RUSSELL JONES,
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`Plaintiff,
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`vs.
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`GRANT COUNTY HOSPITAL DIST.
`NO. 1 d/b/a SAMARITAN
`HOSPITAL, a Washington
`Municipality, JULIE WEISENBURG,
`individually and as an agent of
`GRANT COUNTY HOSPITAL DIST.
`NO. 1 d/b/a SAMARITAN
`HOSPITAL, and JULIE
`WEISENBURG and JOHN DOE
`WEISENBURG, the marital
`community thereof.
`
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`Defendants.
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`Plaintiff Russell Jones, by and through his attorneys, Ryan Best, Jacob Mark,
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`and Michael Merkelbach, of Best Law, PLLC, and for causes of action against the
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`above-named Defendants, complains and alleges as follows:
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-1
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`Case 2:21-cv-00285 ECF No. 1 filed 09/29/21 PageID.2 Page 2 of 14
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`I. PARTIES, JURISDICTION, AND VENUE
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`1.1 Russell Jones is a resident of Grant County, which is within the
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`Eastern District of Washington.
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`1.2 Russell Jones (hereinafter “Mr. Jones”) is an Advanced Registered
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`Nurse Practitioner and worked for Defendant Grant County Public Hospital
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`District No. 1 d/b/a Samaritan Healthcare (“Samaritan”) from July 24, 2017 until
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`Samaritan simultaneously terminated his employment and revoked his clinical
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`privileges on April 5, 2019 – ten days before Mr. Jones was to start his new
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`position with Sound Physicians Emergency Medicine of Washington, PLLC using
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`his clinical privileges at Samaritan Hospital.
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`1.3 Samaritan is a Washington Municipality conducting business within
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`the Eastern District of Washington and previously employing Russell Jones.
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`1.4 Julie Weisenburg and John Doe Weisenburg are married residents of
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`Grant County.
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`1.5 Julie Weisenburg is an employee and agent of Defendant Samaritan.
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`1.6 Plaintiff brings
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`this action against Julie Weisenburg as an
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`employee/agent of Samaritan and in her individual capacity.
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`1.7 The Defendants’ alleged unlawful acts and omissions were committed
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`within the jurisdiction of the United States District Court for the Eastern District
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`of Washington.
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-2
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`Case 2:21-cv-00285 ECF No. 1 filed 09/29/21 PageID.3 Page 3 of 14
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`1.8 The Federal Court for the Eastern District of Washington has
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`jurisdiction over this matter pursuant to 28 U.S.C. § 1331.
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`1.9 Venue is proper in the Federal Court for the Eastern District of
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`Washington under 28 U.S.C. § 1391(b)(1) and 28 U.S.C. § 1391(b)(2) as the
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`Defendant resides in the Eastern district of Washington and the acts and omissions
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`took place within the Eastern District of Washington.
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`1.10 Jurisdiction and Venue are thus proper.
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`II. FACTS
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`2.1 Mr. Jones started working at Samaritan as an ARNP on July 24, 2017.
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`2.2 On February 12, 2019, Sound Physicians Emergency Medicine of
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`Washington, PLLC (“Sound Physicians”) – the soon-to-be new owner of
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`Samaritan Hospital – offered Mr. Jones a position as a Nurse Practitioner starting
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`April 15, 2019.
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`2.3 A true and correct copy of Sound Physicians’ February 12, 2019 job
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`offer to Mr. Jones is attached to this Complaint as Exhibit 1.
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`2.4 On March 18, 2019, Mr. Doe1 came to the Samaritan Hospital
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`1 The actual patient’s name is known to all parties and is only withheld from this
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`pleading to protect the privacy of the patient. The actual patient will be referred
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`to as Mr. Doe and the patient’s spouse will be referred to as Mrs. Doe.
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-3
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`Case 2:21-cv-00285 ECF No. 1 filed 09/29/21 PageID.4 Page 4 of 14
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` emergency department seeking treatment (a second time) for rectal bleeding that
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`had worsened since his first treatment at Samaritan Hospital.
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`2.5 On March 7, 2019, Samaritan first treated Mr. Doe for rectal bleeding.
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`2.6 At 5:04 p.m. on March 18, 2019, Mr. Doe returned to the Samaritan
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`Hospital Emergency Department because the bleeding had worsened.
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`2.7 Dr. Frank was the doctor assigned to Mr. Doe’s treatment.
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`2.8 Samaritan, through Dr. Frank and Mr. Jones, performed several tests,
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`including a mandatory digital rectal examination, to diagnose and treat Mr. Doe’s
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`rectal bleeding.
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`2.9 At 6:14 p.m., Mr. Jones ordered the following tests:
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`2.9.1
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`CBC, PLT, & Auto Diff;
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`2.9.2
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`Comprehensive Metabolic Panel;
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`2.9.3
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`Partial Thromboplastin Time; and
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`2.9.4
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`Prothrombin Time.
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`2.10 At 7:05 p.m. on March 18, 2019, Mr. Jones discussed the test results
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`with Mr. and Mrs. Doe in the Doe’s hospital room.
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`2.11 Between 7:13 p.m. and 7:14 p.m. on March 18, 2019, Samaritan
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`discharged Mr. Doe, provided Mr. Doe with his discharge paperwork, and took
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`vitals for Mr. Doe at discharge.
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`2.12 Mr. Doe was in the emergency department for over two hours.
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-4
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`2.13 In the two hours that Mr. Doe was present, no Samaritan employee
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`heard or saw anything suggesting that Mr. Jones assaulted, or in any way
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`mistreated, Mr. Doe – as verified by two separate investigations; one performed
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`by Samaritan and one performed by the Nursing Care Quality Assurance
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`Commission (“NCQAC”).
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`2.14 At approximately 8:45 p.m. on May 18, 2019, Mrs. Doe sent a
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`complaint, through Facebook Messenger, alleging that Mr. Jones sexually
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`assaulted Mr. Doe.
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`2.15 After learning of the allegation against Mr. Jones, Defendants
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`Weisenburg and Samaritan suspended Mr. Jones’s employment, pending the result
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`of Samaritan’s investigation of the allegations.
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`2.16 Defendants Samaritan and Weisenburg chose to handle the March 18,
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`2019 allegation “via employment versus on the medical side of things.”
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`2.17 Despite allegedly finding the Mrs. Doe sexual assault allegations to be
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`credible, Samaritan did not report Mr. Jones to the police, did not report Mr. Jones
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`to the NCQAC for sexual misconduct, nor did Samaritan revoke Mr. Jones’s
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`clinical privileges in order to protect the public.
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`2.18 On April 4, 2019, Samaritan informed Mr. Jones that it planned on
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`terminating his employment at Samaritan, and Samaritan invited Mr. Jones to
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`defend his employment the next day at a hearing on April 5, 2019.
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-5
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`2.19 A true and correct copy of Samaritan’s April 4, 2019 letter is attached
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`to this Complaint as Exhibit 2.
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`2.20 On April 5, 2019, Defendants Samaritan and Weisenburg terminated
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`Mr. Jones’s employment at Samaritan.
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`2.21 Mr. Jones’s being employed at Samaritan was not a condition for his
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`being eligible to start his new position as a Nurse Practitioner for Sound
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`Physicians, scheduled to begin 10 days after Ms. Weisenburg fired him.
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`2.22 Defendants Samaritan and Weisenburg simultaneously revoked Mr.
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`Jones’s clinical privileges at Samaritan Hospital and terminated Mr. Jones’s
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`employment at Samaritan Hospital on April 5, 2019.
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`2.23 Samaritan testified that it has a policy to routinely revoke a provider’s
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`clinical privileges automatically when Samaritan terminates a provider’s
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`employment.
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`2.24 Samaritan intentionally handled Mr. Jones’s termination process “via
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`employment versus on the medical side of things.”
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`2.25 Because Samaritan was not using “the medical side of things,”
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`Samaritan never initiated the peer-review process.
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`2.26 Defendants Samaritan and Ms. Weisenburg knew that terminating Mr.
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`Jones’s employment and revoking his clinical privileges would require them to
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`“pursue 2 paths simultaneously 1) HR [and] 2) Medical Staff . . . peer review[.]”
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-6
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`2.27 Despite knowing it needed to pursue a peer review process to revoke
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`Mr. Jones’s clinical privileges, Defendant Samaritan never gave Mr. Jones notice
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`that it was considering revoking Mr. Jones’s clinical privileges at Samaritan
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`Hospital.
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`2.28 Defendant Samaritan never gave Mr. Jones the opportunity to defend
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`his clinical privileges at Samaritan Hospital before Ms. Weisenburg revoked his
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`clinical privileges on April 5, 2019.
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`2.29 Defendants Samaritan and Ms. Weisenburg intended to revoke Mr.
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`Jones’s clinical privileges without ever pursuing the required peer review process.
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`2.30 Neither Defendant Samaritan nor Defendant Ms. Weisenburg
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`provided Mr. Jones with notice informing him that Defendants suspended his
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`clinical privileges pending the results of a post-deprivation hearing, or some other
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`formal hearing wherein Mr. Jones could advocate for his innocence and defend his
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`clinical privileges, his professional reputation, and/or his eligibility for his new job
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`with Sound Physicians.
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`2.31 Neither Defendant Samaritan nor Defendant Ms. Weisenburg
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`provided Mr. Jones with notice informing him that his clinical privileges were
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`potentially going to be revoked on April 5, 2019.
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`2.32 Because Defendants Samaritan and Weisenburg revoked Mr. Jones’s
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`clinical privileges at Samaritan Hospital simultaneously when they terminated Mr.
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-7
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`Jones’s employment at Samaritan Hospital on April 5, 2019, Mr. Jones could no
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`longer satisfy section 1.A.iii of his Employment Agreement with Sound
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`Physicians, one of the conditions Mr. Jones was required to satisfy in order to be
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`eligible to start working for Sound Physicians as a Nurse Practitioner at Samaritan
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`Hospital.
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`2.33 Because Sound Physicians required Mr. Jones to have clinical
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`privileges at Samaritan Hospital and Defendants Samaritan and Weisenburg
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`revoked Mr. Jones’s clinical privileges at Samaritan Hospital 10 days before Mr.
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`Jones’s new job was supposed to start, Sound Physicians rescinded its job offer
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`for Mr. Jones to work as a Nurse Practitioner at Samaritan Hospital.
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`2.34 Had Samaritan not wrongfully terminated his privileges, Mr. Jones
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`would have started work for Sound Physicians on April 15, 2019.
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`2.35 Defendants Samaritan and Weisenburg knew that Mr. Jones’s
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`Employment Agreement with Sound Physicians was scheduled to start on April
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`15, 2019.
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`2.36 If Mr. Jones started his Nurse Practitioner job with Sound Physicians,
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`Defendants Samaritan and Weisenburg would not be able to terminate Mr. Jones’s
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`employment as easily as they did.
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`2.37 On March 18, 2019, Defendants Samaritan and Weisenburg knew that
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-8
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`Samaritan would not be able to conduct a peer-review process and perform an
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`“employment matter” investigation before April 15, 2019.
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`2.38 Defendants Samaritan and Weisenburg knew that there were separate
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`procedures for terminating non-provider employees and medical providers whose
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`clinical privileges were at risk of revocation.
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`2.39 Despite knowing about the separate procedures, Defendants chose not
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`to pursue “the medical provider side of things” when handling the March 18, 2019
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`allegations against Mr. Jones.
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`2.40 Defendants Samaritan and Weisenburg used the March 18, 2019
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`allegations against Mr. Jones as a pretext to terminate Mr. Jones’s employment at
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`Samaritan, and used the employment termination to terminate Mr. Jones’
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`privileges at Samaritan Hospital without due process to terminate his ability to
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`work at Samaritan Hospital.
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`2.41 Defendants Samaritan and Weisenburg used Mr. Jones’s employment
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`termination as a basis for revoking his clinical privileges at Samaritan Hospital.
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`2.42 Defendant could have suspended Mr. Jones’s clinical privileges and
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`scheduled a post-deprivation hearing, but since Samaritan’s investigation of the
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`March 18, 2019 allegations against Mr. Jones could not be corroborated, and
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`because Mr. Doe’s statements were contradicted by all available independent
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-9
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`evidence, Defendants knew that a peer-review would not result in the revocation
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`of Mr. Jones’s clinical privileges at Samaritan Hospital.
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`2.43 Further, Defendants needed to terminate Mr. Jones’ privileges prior to
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`his beginning work for Sound Physicians.
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`2.44 If Mr. Jones’s clinical privileges were not terminated, he would have
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`been able to start his new Nurse Practitioner job with Sound Physicians, and
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`Defendants would not have been able to stop Mr. Jones from working for Sound
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`Physicians.
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`III. CAUSES OF ACTION
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`A. Violations of 42 U.S.C. § 1983 Civil Rights – Samaritan Intentionally
`Denied Mr. Jones’s Due Process Rights
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`3.1 Mr. Jones’s employment arrangement with Samaritan is distinct from
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`his clinical privileges at Samaritan.
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`3.2 Mr. Jones’s clinical privileges and medical reputation are protected
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`property interests subject to procedural protections separate from the procedural
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`protections for Mr. Jones’s employment arrangement with Samaritan.
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`3.3 Samaritan simultaneously revoked Mr. Jones’s privileges when it and
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`Ms. Weisenburg terminated Mr. Jones on April 5, 2019.
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`3.4 Samaritan never gave Mr. Jones notice of a post-deprivation hearing
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`after revoking Mr. Jones’s privileges on April 5, 2019.
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`COMPLAINT FOR DAMAGES
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`3.5 To date, Samaritan has never performed a peer-review of Mr. Jones
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`related to Samaritan’s April 5, 2019 revocation of Mr. Jones’s privileges.
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`3.6 Ms. Weisenburg who is not a physician terminated Mr. Jones’s
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`privileges based on her sworn testimony or Samaritan as Samaritan’s corporate
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`representative.
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`3.7 By revoking Mr. Jones’s clinical privileges at Samaritan Hospital on
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`April 5, 2019, Mr. Jones could not satisfy the section 1.A.iii of his Employment
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`Agreement with Sound Physicians.
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`3.8 Samaritan has a custom and policy of revoking a provider’s clinical
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`privileges without medical review whenever Samaritan terminated a provider’s
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`employment, as testified by Samaritan’s 30(b)(6) designee.
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`3.9 Samaritan’s established custom or practice of simultaneously
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`revoking clinical privileges and terminating employment of a medical provider,
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`even when Samaritan denied the medical provider a separate opportunity to defend
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`his clinical privileges – or advocate for himself at all regarding his defense of his
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`clinical privileges – deprived Mr. Jones of his constitutional right to due process.
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`3.10 Neither Samaritan nor Ms. Weisenburg provided Russell Jones notice
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`or an opportunity to participate in Samaritan’s privilege processes prior to
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`Defendants’ terminating his employment and simultaneously revoking his clinical
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`privileges based on his employment termination.
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-11
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`3.11 Neither Samaritan nor Ms. Weisenburg provided Russell Jones notice
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`or meaningful opportunity to participate in a peer-review proceeding to defend his
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`clinical privileges.
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`3.12 On April 5, 2019, Samaritan and Ms. Weisenburg terminated Mr.
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`Jones and simultaneously revoked his clinical privileges at Samaritan Hospital
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`based substantially on a March 18, 2019 patient complaint that Samaritan never
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`fully investigated and which the Department of Health dismissed for insufficient
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`evidence.
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`3.13 After March 18, 2019, Samaritan chose to pursue discipline against
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`Mr. Jones as an “employment matter” and chose not to pursue a peer-review driven
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`method of discipline.
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`3.14 Mr. Jones was damaged due to these institutional policies utilized by
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`Samaritan.
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`3.15 Defendants intentionally deprived Mr. Jones of his constitutional right
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`to due process by acknowledging the need to perform a peer review, choosing to
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`remain silent about any peer review process, provided no notice of its intent to
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`revoke Mr. Jones’s clinical privileges, and revoking Mr. Jones’s privileges without
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`allowing him to advocate for himself or defend his license and without review by
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`any medically trained personnel. All of this resulted in damages to Mr. Jones and
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`the loss of his employment with Sound Physicians.
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-12
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`Case 2:21-cv-00285 ECF No. 1 filed 09/29/21 PageID.13 Page 13 of 14
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`IV. PRAYER FOR RELIEF
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`Mr. Jones respectfully demands a jury trial and further compensation for all
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`injury and damages suffered. To wit:
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`A. Both economic and non-economic damages suffered individually and
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`by the marital community in amounts to be proven at trial including, but not
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`limited to: the salary Mr. Jones would have earned had he not lost his clinical
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`privileges without due process, the cost of searching for a new job without the
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`benefit of having existing clinical privileges, months of utilizing savings to
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`supplement living expenses after Defendants disqualified Mr. Jones for the job
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`scheduled to start on April 15, 2019, mental anguish and emotional distress,
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`feelings of unjust treatment, reputational harm, anxiety, humiliation, and personal
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`indignity.
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`B. Liquidated damages, interest, and all other damages as allowed under
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`the law to all Plaintiffs;
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`C. The payment of attorney fees, costs, litigation expenses, expert
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`witness costs, adverse tax consequences, front pay, back pay, and all other
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`damages allowed under the law and equity including 42 U.S.C. § 1988; and
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`D. Punitive Damages for Defendants’ reckless and callous indifference to
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`Mr. Jones’s constitutional right to due process and for Defendants’ evil intent to
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`deprive him of his right.
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`COMPLAINT FOR DAMAGES
`AND JURY DEMAND-13
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`Case 2:21-cv-00285 ECF No. 1 filed 09/29/21 PageID.14 Page 14 of 14
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`Dated this 29th day of September 2021.
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` BEST LAW PLLC
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` /s/ Ryan M. Best
`By:
`Ryan M. Best, WSBA 33672
`Michael R. Merkelbach, WSBA 55389
`Jacob A. Mark, WSBA 54280
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`Best Law PLLC
`905 W. Riverside, Suite 409
`Spokane, WA 99201
`Phone: (509) 624-4422
`Fax: (509) 703-7957
`Email: bestlawpllc@bestlawspokane.com
`Attorneys for Plaintiffs
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`COMPLAINT FOR DAMAGES
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