Flores v. County of Los Angeles (2011) 2011 Cal.App. Unpub. LEXIS 9332 (California Court of Appeal, Second Appellate District, Division Two) [unpublished]. Plaintiff sued the GMSR’s client, the County of Los Angeles, for wrongful death after her daughter died in the emergency room at Martin Luther King, Jr./Drew Medical Center from a streptococcus pneumoniae infection. Plaintiff’s original complaint alleged that the emergency room physicians and staff were negligent in treating the decedent. Plaintiff later amended her complaint to add a theory that other County physicians failed to give the decedent a vaccination that would have prevented the infection that ultimately caused her death. In an unpublished decision, the Court of Appeal held that plaintiff’s new failure-to-vaccinate theory was barred because she failed to include it in her government claim filed with the County.
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