Medical Malpractice Declaration

The assignment content is a legal document, specifically a declaration by Ronald Golden, MD, FACS, a defendant in a lawsuit filed by Nicolette Brand against Refresh Medical Spa and others. The declaration describes the events surrounding a cosmetic procedure performed on Ms. Brand at the medical spa, where she unexpectedly suffered an allergic reaction to the regional anesthesia. Dr. Golden details his actions in attempting to save her life, including performing a tracheotomy with the assistance of another medical professional, Dr. Liu.

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GAIL GREENE (98765)
XIAO JIN(76543)
GREENE & JIN
A Professional Corporation
5998 Alcala Park
San Diego, CA 92110
619.260.2791
Attorneys for Defendant Anna Liu
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN DIEGO
NICOLETTE BRAND, an individual,
Plaintiff,
vs.
REFRESH MEDICAL SPA, et al,
Defendants.
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Case No.: 14-3-456789-1
DECLARATION OF RONALD GOLDEN, M.D., FACS
I, RONALD GOLDEN, M.D., FACS, declare:
1. I am a defendant in this action. I have personal knowledge of the
following facts. If called as a witness before this court, I can and will competently
testify to the following facts under oath.
2. I am a physician licensed to practice medicine in the state of
California. I am also a board certified cosmetic surgeon and a member of the American
Academy of Cosmetic Surgeons.
3. Cosmetic surgery is a discipline of medicine focused on the enhancing of
appearance through surgical and medical techniques.
4. As part of my training, I completed medical school at UCLA and a
residence program at Hope Hospital in San Diego in plastic surgery. I obtained board
certification in plastic surgery from the American Board of Plastic Surgery in 1994.
DECLARATION OF RONALD GOLDEN, M.D., FACS
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I continued to train in cosmetic surgery and was certified by the American Board of
Cosmetic Surgery in 1996.
5. I have been working as a cosmetic surgeon at the Refresh Medical Spa
since 2007 where I am a physician-owner.
6. On April 10, 2016, I was in the Surgical Procedure Room 4 at the Refresh
Medical Spa, where I was about to perform an elective cosmetic procedure on Ms.
Nicolette Brand, age 42.
7. In preparation for the procedure, Ms. Brand was to receive a regional
anesthetic to her neck and facial area rather than a general anesthetic. This blocks
the nerve supply to the face during the surgery, which means the patient is not in any
pain during the procedure, but has the advantage of allowing the patient to be awake
during the procedure and speeds up the recovery process.
8. Although we had conducted exploratory blood tests before this procedure,
Ms. Brand unexpectedly appeared to suffer a severe allergic reaction to the regional
block. She began thrashing around and gasping for breath. It was apparent to me that
she was suffering an anaphylactic reaction.
9. I requested a shot of epinephrine to be administered by the surgical
nurse, but Ms. Brand was thrashing around so wildly that the syringe was knocked from
the nurse’s hands, and the contents spilled on the nurse and equipment and the floor.
10. When I saw that Ms. Brand’s heart rate was rapidly increasing, her blood
pressure was dropping, and she was becoming cyanotic, I believed I needed to act right
away to save her life by performing a tracheotomy.
11. A tracheotomy involves inserting a breathing tube into the neck of the
patient, just under the larynx (the voice box).
12. Because the surgical nurse, Ms. Lorene Black, was busy dealing with the
epinephrine spill, I called for help from any other medical professional who may have
been nearby in an office, consulting or operating room. Luckily Dr. Liu was nearby
and came to my aid.
DECLARATION OF RONALD GOLDEN, M.D., FACS
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13. I asked Dr. Liu to hold down Ms. Brand’s arms while I cut an opening in
Ms. Brand’s neck and inserted the tracheotomy tube.
14. The tracheotomy was successful and Ms. Brand was able to get oxygen
delivered to her lungs by breathing through the tube because her air passages were
still blocked.
15. Shortly afterwards, I was able to administer a series of shots of
epinephrine to Ms. Brand and I removed the tracheotomy tube when I saw she could
breathe through her normal air passages.
16. [rest of declaration omitted].
I declare under penalty of perjury under the laws of the State of California
that the foregoing is true and correct.
Dated: August 19, 2016
RONALD GOLDEN M.D., FACS
DECLARATION OF RONALD GOLDEN, M.D., FACS
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