How to write an application for medical malpractice appraisal on the medical side

Application for medical malpractice appraisal Applicant: ××××, male, ×××× born in ××× month ××, ethnicity: Han, ID card number: ×××××××××××, living in ×× unit C, room 702, contact phone: ×××××××× Respondent: ××× People's Hospital, legal representative: ×××, position: ×××, contact phone: ××××××, address: ××× ××On xxx xxx xxx, the Applicant underwent laparoscopic stone removal surgery. ×××× On xxx xxx xxx, the applicant was subjected to a failed open repair of the common bile duct and the right and left hepatic ducts. On ×××××××, the Applicant was transferred to the Second Affiliated Hospital of Kunming Medical College for resuscitation in the Department of Dry Surgery due to bile duct injury, abdominal infection, bilateral pleural effusion, severe infection of the incision and repeat incision, and severe anemia and severe malnutrition. After more than 60 days of intensive rescue and treatment, his life was saved. The applicant is now in the recovery stage and will need to undergo a biliary anastomosis operation in half a year's time. Based on the above facts, the applicant believes that: a. On October 10, the applicant was pushed into the operating table to undergo laparoscopic lithotripsy, and the stone was found to be too large during the operation (with a diameter of more than 3C), and the respondent didn't change the surgical plan in time, and still used laparoscopy with a diameter of only 0.3-1C to extract the stone savagely, which resulted in the applicant's common bile duct and the left and right hepatic ducts being broken, and the respondent did not The Respondent did not make timely repairs before concluding the surgery. The Respondent violated the medical routine, blindly operated on the Claimant without making a detailed and comprehensive diagnosis of the Claimant, and did not adjust the surgical plan in time when problems were found during the operation, and used the laparoscopic head of 0.3-1C in diameter to remove the stone of a diameter of more than 3C without any objective basis, relying on the subjective assumption, and blindly did it in a hasty manner. The fact that the injury to the applicant's bile and liver ducts was caused by the respondent's negligent behavior is sufficiently clear. Second, x x x x x x x, the applicant began to appear bile leakage and jaundice symptoms, the respondent to the applicant for open sewing bile duct surgery, absurd, the respondent can not be competent bile duct repair surgery, but insisted on open abdominal. Later, on the grounds that the bile duct was not found, no bile drainage was carried out and the incision was stitched up, resulting in the applicant developing severe peritonitis combined with bilateral pleural effusions. In the case of neither consulting a higher doctor, nor timely transfer of the applicant, let the applicant lie in the ward for three days, until his condition worsened on the verge of death, had no choice but to leave the ward on the second day after the operation to go to the old respondent doctor in charge of the hospital rushed back to the hospital, the applicant was transferred to the Second Affiliated Hospital of Kunming Medical College Dry Surgery Department, after all efforts to save the life of the hospital more than 60 days after the hospitalization. This damage is caused by the Respondent's violation of the technical specifications and medical practice. And the respondent doctor in charge of a serious violation of the "Chinese people's *** and the state practitioners law", no due diligence for the patient service. Third, after the operation, the Respondent failed to carry out incision debridement and drainage in a timely manner, resulting in heavy infection of the applicant's incision and repeated incisions, and the Respondent's failure to fulfill its due diligence in medical treatment and nursing care, which was one of the main causes of the multiple damages to the applicant's person. Fourthly, the Respondent failed to fulfill its duty to inform the Applicant of the possible serious consequences in a timely manner, knowing that the Applicant's condition was already very serious, so that the Applicant, unknowingly, received hasty medical treatment and care, resulting in the Applicant's bodily damage, rapid deterioration of his condition, and being on the verge of death. In summary, the Respondent and its staff were seriously irresponsible, violated medical and nursing routines, made errors in diagnosis and examination, made surgical errors, failed to rescue, failed to make a timely transfer to a hospital, and failed to fulfill the obligation to inform, causing the applicant Personal injury, and deterioration of the applicant's condition (although rescued from danger, it was necessary to carry out another bile and intestinal anastomosis surgery.) Causal relationship is obvious. In view of the above facts and reasons, in order to more clearly and explicitly confirm the respondent's fault behavior, hereby filed an application for medical malpractice appraisal, requesting your office to give the appraisal in accordance with the law. ×××× People's Court ×××× year x x month x x day.