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STATE OF MICHIGAN IN THE CIRCUIT COURT FOR INGHAM COUNTY JAMES ST, CLAIR COMPLAINT AND JURY DEMAND a File No. 19- | 5 > NI y stomanf@ellITON CANADY I} JOHN LAURAIN, indi ally, EDWARD W. SPARROW HOSPITAL ASSOCIATION, a domestic nonprofit corporation d/b/a SMG LANSING INTERNAL MEDICINE, and EDWARD W. SPARROW HOSPITAL ASSOCIATION, a domestic nonprofit corporation, ‘Defendants. Manvir 8, Grewal, Sr. (P48082) Nolan L. Erickson (P72661) GREWAL LAW, PLLC a Attomey for Plaintiff 2290 Science Pkwy Okemos, MI 48864 (517) 393-3000 There is no other pending or resolved civil action arising outof the transaction or occurrence alleged in the complaint. COMPLAINT AND JURY DEMAND NOW COMES Plaintiff James St. Clair, by and through his attomeys, GREwaL LAW, PLLC, and for the General Allegations of his Complaint states as follows: GENERAL ALLEGATIONS AND. UE 1. Plaintiff James St. Clair (“Plaintiff”), at all times relevant herein, was a resident of the City of Lansing, Ingham County, Michigan. 10. A 12. Defendant John Laurain (“Defendant Laurain”), at all times relevant herein, was an employee at Sparrow Hospital in Lansing, Michigan and was a resident of the City of Mason, Ingham County, Michigan. Defendant Edward W. Sparrow Hospital Association d/b/a SMG Lansing Intemal Medicine and Defendant Edward W. Sparrow Hospital Association (collectively “Defendant Sparrow”) is domestic nonprofit corporation authorized and licensed to, and doing business in Ingham County, Michigan. The incidents which are the subject matter of this lawsuit occurred in Ingham County, Michigan, ‘Venue in Ingham County, Michigan is proper pursuant to MCL 600.1621 (a), (b) and MCL. 600.1627. This Honorable Court has personal jurisdiction over all Defendants in this action pursuant to MCL 600.705. ‘The amount in controversy exceeds the sum of Twenty-Five Thousand ($25,000) Dollars. SPECIFIC FACTUAL ALLEGATIONS Plaintiff incorporates the preceding paragraphs by reference as if fully set forth herein. Atall times relevant herein, Defendant Laurain was under the direction, supervision, and/or control of Defendant Sparrow as its employee, agent, and/or ostensible agent. Atall times relevant herein, Defendant Laurain was board certified in internal medicine. At the time of the incident, Plaintiff’ primary care physician for approximately two years.) Prior to the incident, Defendant Laurain had a disciplinary action filed against him through the Michigan Department of Licensing and Regulatory Affairs (“LARA”) in July of 2011. 13. 14, 15. 16. On February 27, 2017, Plaintiff had his first appointment with Defendant Laurain at Sparrow to receive an annual examination. Plaintiff informed Defendant Laurain that he had a very painful rash on his suprapublic, inguinal region. Defendant Laurain diagnosed the rash as being chronic acne vulgaris and hydradenitis and prescribed Plaintiff an antibiotic for aene treatment, On July 28, 2017, Plaintiff had another appointment with Defendant Laurain at Sparrow and presented with complaints of severe rectal pain accompanied with a burning sensation. Defendant Laur subsequently performed a prostate exam without using gloves and, on physical examination, the following was noted: “Rectum normal, prostate normal and penis normal. No penile tenderness.” On August 17, 2017, Plaintiff was evaluated by nursing staff at Sparrow and was complaining of severe rectal pain and a burning sensation in the area. The nursing staff noted that Plaintiff was being treated on this date for multiple problems including the herpes simplex virus, acne, fatigue, vitamin D deficiency, poor nutrition, and tobacco dependence. Plaintiff informed the nursing staff that other healthcare providers from a different facility had informed him that he had anal pockets and that he should have HPV testing done. Plaintiff was instructed to follow up with Defendant Laurain for the testing and was later tested for HPV, yeast infection, HSV I, and HSV II of the perianal region, none of which were positive, On September 15, 2017, Plaintiff was evaluated by Defendant Laurain and presented with continual perianal pain and buming. Defendant Laurain again performed a prostate exam without using gloves and failed to examine or take a culture of Plaintiff's anal region. Defendant Laurain’s notes indicated that Plaintiff had medication induced erectile