1 in the CIRCUIT COURT of MORGAN COUNTY, ALABAMA JANE DOE on Behalf of Herself and As Guardian and Next Friend of MARY DOE, BREN
DOCUMENT 136 ELECTRONICALLY FILED 7/16/2019 2:44 PM 52-CV-2018-900276.00 CIRCUIT COURT OF MORGAN COUNTY, ALABAMA CHRIS PRIEST, CLERK IN THE CIRCUIT COURT OF MORGAN COUNTY, ALABAMA JANE DOE on behalf of herself and as ) guardian and next friend of MARY DOE, ) BRENDA BOE, CARLA COE, FRANCIS ) FOE, GRACE GOE, KATIE KOE, LAURA ) LOE, MABEL MOE, NANCY NOE, ) JILL JOE, PAIGE POE, RUTH ROE ) SUSAN SOE, VICKI VOE, WENDY WOE, ) YANA YOE, ZANA ZOE, BRENDA BAY ) CATIE CAY, DEBBIE DAY, FANNIE FAY ) HANNAH HAY, JENNY JAY. KATHY ) KAY, MARTHA MAY, NINA NAY, PATTY ) PAY, ROSIE RAY, SARAH SAY, and TINA ) TAY on behalf of themselves and others ) similarly situated, ) ) PLAINTIFFS, ) ) CASE NO.: CV 2018-900276 v. ) ) CLASS ACTION MICHAEL DICK, ALABAMA MEDICINE ) & RHEUMATOLOGY, INC., and ) FICTITIOUS PARTY DEFENDANTS A, B, ) C, D, and E, being those individuals or ) entities who negligently, recklessly, and/or ) wantonly injured Plaintiffs or contributed to ) injuries Plaintiffs suffered by standing idly ) by and enabled his/her co-Defendants to ) harm them; their identities are currently ) unknown but will become named defendants ) to this action once their identities are ) discovered pursuant to ALA.R.CIV.P. 9(h), ) ) DEFENDANTS. THIRD AMENDED CLASS ACTION COMPLAINT COME NOW, Plaintiffs, via pseudonyms, and file their Third and Class Action Complaint against Michael Dick (hereinafter “Dick”), Alabama Medicine & Rheumatology, Inc. (hereinafter “AM&R”), and Fictitious Party Defendants A, B, C, D, and E, and, in support thereof, show as follows: 1 DOCUMENT 136 INTRODUCTION My goal will be to help, or at least do no harm.1 The prohibition against sexual contact between a physician and a patient is well established and is embodied in the oath taken by physicians, the Hippocratic Oath.2 Prior to his license being revoked by the Alabama Board of Medical Examiners, Michael Dick did business out of Alabama Medicine & Rheumatology, Inc.
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