October 7,1998

Dear Congresswoman Julia Carson,

We are writing to you today in the hopes of having healthcare providers held accountable for the devastating damages that medical malpractice victims suffer from daily. On December 4,1997 I went into labor with my third child, Robert James Rollins,lll. Our precious son suffered from severe irreversible brain damage during his birth attended by doctor, Dr. Robert J. Morgan. Our son came home from the Neonatal Intensive Care Unit when he was two weeks old in a comatose state. His brain stem was seriously damaged and we were told that his quality of life would be very poor. We wonder if he was ever able to see the love in his Mommy and daddy's eyes or hear the many loving words said to him by so many people? We will never know. Baby Robbie's gag reflex was severally damaged so he had to take his nutrients through a nasal tube. His digestive system did not function properly so we gave him medication before each feeding to assist in keeping his food down. Baby Robbie was on Phenobarbital in order to control his seizures.

When this no longer worked he was then also put on Valium. He suffered from daily bouts of Apnea, which he would turn either blue or purple, leaving us constantly in turmoil. We rode the roller coaster ride of baby Robbie's life. We didn't have a choice but more importantly- he didn't have a choice. We suffer everyday from the loss of our precious son, for not being able to hold him, love him, sing to him, or nurture him. We were blessed with a beautiful baby boy that was taken from us because of , what we believe to be, a doctor's negligence. We live with the guilt that we unknowingly put his precious life in the hands of a negligent physician. We, as parents, are supposed to protect our son but were unable to because we did not have this information of our doctor's malpractice history available to us before his birth. The thought of baby Robbie struggling for oxygen while trapped inside his mommy's abdomen is unbearable.

We grieve for our daughters that had to watch their brother struggle for every breath. As we fell deeper in love with him each passing moment, he was slipping further from us. Losing a child for any reason would be difficult. For us, it is incomprehensible that our son died because we were not given proper medical treatment.

After our son's birth we stumbled across information that made us alarmed and outraged. We then discovered that our doctor, Dr.Robert J. Morgan, had a long list of medical malpractice casualties. At the time of our son's birth he had twenty-one malpractice claims and has never been disciplined. The State of Indiana has allowed this doctor and others like him to continue to practice regardless of the cost to consumers. The offices that are supposed to police the doctor's in order to protect the public have turned a blind eye to this devastating injustice for too long.

After two and a half months of suffering ,we found our beautiful precious Angel lifeless in his crib. Our Angel had received his wings and would no longer have to suffer because of a doctor's negligence. That memory will be imbedded in our hearts and our young daughters for the rest of our lives. If this doctor would have been held accountable for his many previous malpractice findings our baby would probably be in our arms surrounded by the love that he deserved. Instead, our baby is one of thousands that die annually as a result of medical malpractice. Dr. Robert J. Morgan and many other doctors with outrageous medical malpractice claims are STILL practicing while the number of casualties continues to increase. Baby Robbie did not have a voice to be heard but he did have a life. Please make his life count by changing the laws to protect the patients and hold the health profession accountable for their actions.

Thank You,

Baby Robbie's Mommy & Daddy Lori & Robert Rollins

March 17, 1998

HAND-DELIVERED AND VIA CERTIFIED MAIL

Indiana State Medical Association
322 Canal Walk
Indianapolis, IN 46202-3268

Indianapolis (Marion) Medical Society
63 1 East New York Street
Indianapolis, IN 46202-3706

Health Care Professions Bureau
Indiana Government Center South
402 W. Washington Street, Rm. 041
Indianapolis, IN 46204

Attorney General

Attn: Consumer Protection Division/James Oliver

Indiana Government Center South
402 W. Washington Street, 5th Floor
Indianapolis, IN 46204

RE: Consumer Complaint of Lori Rollins and Robert Rollins Jr. V. Robert J. Morgan, M.D.

Our File No.: 97-408

Dear Ladies and Gentleman:

The purpose of this letter is to formally communicate to you a patient consumer complaint on bc half of my clients, Lori Rollins and Robert Rollins Jr. against Robert J. Morgan, M.D. Dr. Morgan is an obstetrician/'gynecologist whose offices are located at
Street, Indianapolis, Indiana.

Lori Rollins sought the professional services of Dr. Robert J. Morgan in April of 1997 for management of her third pregnancy. This pregnancy resulted in a delivery managed by Dr. Morgan at Community Hospital East on December 4, 1997. During this vaginal birth after Cesarean section delivery (VBAC) managed by Dr. Morgan, Lori Rollins suffered a rupture of her uterus and expelling of the infant from her uterus into her abdomen, all of which resulted in substantial hemorrhage to Lori Rollins and a devastating brain injury to infant Robert Rollins III, culminating in the infant's death approximately 60 days post-delivery. We have on this date filed a Proposed Complaint before the Indiana Department of Insurance setting forth specific allegations of negligence in the medical care provided. The Proposed Complaint, a copy of which is enclosed, details the Rollins' allegations.

After enduring the tragic events set forth above, the Rollins were further distressed to learn of a long history of allegations of medical malpractice confronting Robert J. Morgan, M.D. They were shocked to learn of the number of medical review panel opinions finding malpractice on the part of Dr. Morgan. Pertinent opinions, all predating their son's delivery and death, are listed below and have been attached as Exhibits A-F respectively

The unanimous medical review opinion that found Dr. Robert Morgan failed to comply with the appropriate standard of care and that 2 of the 3 panel members found that Community Hospital of Indianapolis, Inc failed to comply with the appropriate standard of care and subsequent settlement for the statutory limits in the matter of Richmond V Robert J Morgan. i\4. D.

The unanimous medical review opinion that found Dr. Robert Morgan failed to comply with the appropriate standard of care and subsequent settlement against Dr. Morgan and Community Hospital of Indianapolis, Inc. for $300,000.00 in the matter of  Anderson V. RobertJ Morgan. M.D

The unanimous medical review opinion that found Dr. Robert Morgan failed to comply with the appropriate standard of care and settlement against Dr. Morgan in the matter of Briscoe v. Robert J Morgan. M D.

The unanimous medical review opinion that found Dr. Robert Morgan failed to comply with the appropriate standard of care and settlement against Dr. Morgan for $ 450,000.00 in the matter of Farrar V. Robert JMorgan. MD.

The unanimous medical review opinion that Dr. Morgan failed to meet the requisite standard of care in patient treatment in the matter of Falvyv RobertJ. N!0rgan. MD.

The unanimous medical review panel opinion that Dr. Morgan failed to meet the requisite standard of care in patient treatment in the matter of Vaughn v. Robert J Morgan. MD.

My clients Lori and Robert Rollins were even more dismayed to learn that an additional five (5) claims were filed against Dr. Morgan in 1997 alleging other issues of medical malpractice. Those are likewise listed below and exhibited to this consumer complaint as Exhibits G-K.

Smith V. RobertJ Morgan. MD.
Lvons V. Robert J Morgan. M D.
Thomas V. Robert j Morgan. MD.
MillerV. RobertJ Morgan. MD.
Cole V. Robert J Morgan. M D.

From review of the history sheets obtained from the Indiana Department of Insurance, which are also attached hereto as Exhibit L, the Rollins were disgusted to find that Dr. Morgan has had 21 medical malpractice complaints. The history sheet for claim filed in December 1997 has not been not completed by the Department at this time, although the actual complaint is attached in Exhibits G-K. All of these complaints were made prior to Dr. Morgan's management of the delivery of their now deceased son. My clients and I would like to know why there has been no review process undertaken to date by the Attorney General's office, the Indianapolis Medical Society or the Health Care Professions Bureau.

On behalf of Lori and Robert Rollins Jr., we request  that  all of  these facts and circumstances receive your prompt  attention. If your evaluation  finds  that a formal review  is warranted, we will be happy to participate fully.

Let me assure you that my clients' request for this investigation concerning Robert J. Morgan, M.D. is not made simply in furtherance of their own Proposed Complaint which has been filed. This request for investigation is submitted not only out of their frustration over not having had this knowledge themselves prior to having Dr. Morgan provide obstetrical services for delivery of their son, but equally out of their concern that others be appropriately informed and protected. On behalf of Mr. and Mrs. Rollins, I do thank you for your prompt attention to this matter and await your reply

Very truly yours,

WILSON KEHOE & WININGHAM

DBK/mjj