Professional Documents
Culture Documents
24-03-25-Lowe - COMP (FSC)
24-03-25-Lowe - COMP (FSC)
COMES NOW Plaintiff Betty Lowe, as the Next-of-Kin of Paul Lowe, and as the Executor
of The Estate of Paul Lowe, and files her Complaint for Damages and Demand for Jury Trial
against Piedmont Eastside Hospital, Inc., Piedmont Healthcare, Inc., AYA Healthcare, Inc.,
Anemonefish Inpatient Services, Inc., Anwer Ali Bhamani, M.D., Viju Varghese, M.D., Ravish
Patel, M.D., Abigail Arko-Asiamah, RN, Stephanie Bullard, RN, Kenia M. Gonzales-Conception,
This is a medical malpractice and negligence action arising out of the care and treatment
of Paul Lowe at Piedmont Eastside Hospital in May of 2023. Paul Lowe suffered pain, discomfort
and died after being administered a lethal dose of morphine while a patient of Piedmont Eastside.
On May 30, 2023, nurses at Piedmont Eastside administered nearly sixty (60) times the amount of
morphine that Mr. Lowe had been ordered to receive. Prior to his death, nurses and physicians
learned of the overdose of morphine that Mr. Lowe had been given but intentionally failed to take
any action to reduce his pain, save his life or notify his family of his impending death. After Mr.
Lowe died on May 31, 2023, Mr. Lowe’s family was given false information by the medical
providers and wrongly told that Mr. Lowe had died of natural causes.
Plaintiff Betty Lowe, as the Next-of-Kin of Paul E. Lowe and as the Executor of the Estate
of Paul E. Lowe, seeks recovery of damages related to the pain and suffering or Paul E. Lowe, the
full value of his life, punitive damages and all other damages allowed under Georgia law.
1. This Court has subject-matter jurisdiction over this action for money damages arising from
the medical malpractice and negligence of the Defendants that proximately caused pain
and suffering and death to Paul Lowe. GA. CONST. ART. VI, § 3, ¶ 1.
2. Venue is proper in this Court as one or more of the Defendants has a principal place of
business and retains a registered agent within Cobb County. GA. CONST. ART. VI, § 2,
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PARTIES
3. Plaintiff Betty Lowe is a resident of the State of Georgia and is subject to the jurisdiction
of this Court.
corporation licensed to do business in the State of Georgia with its registered agent’s
address located within Cobb County. Piedmont Eastside may be served with process via
its registered agent, CSC of Cobb County, Inc., located at 192 Anderson Street, SE, Suite
licensed to do business in the State of Georgia with its registered agent’s address located
within Cobb County. Piedmont Healthcare may be served with process via its registered
agent, CSC of Cobb County, Inc., located at 192 Anderson Street, SE, Suite 125, Marietta,
Georgia 30060.
business in the State of Georgia with its registered agent’s address located within Cobb
County. AYA may be served with process via its registered agent, Legalinc Corporate
Services, Inc., 1870 The Exchange, Suite 200, #44, Atlanta, Georgia 30339.
corporation licensed to do business in the State of Georgia with its registered agent’s
address located within Cobb County. Anemonefish may be served with process via its
registered agent, CSC of Cobb County, Inc., located at 192 Anderson Street, SE, Suite
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8. Defendant Anwer Ali Bhamani, M.D., is a medical doctor licensed to practice in the State
of Georgia and is a citizen and resident of Fulton County. Defendant Bhamani is subject
to the jurisdiction of this Court and may be personally served with process at his residential
address located at 3165 Saint Ives Country Club Parkway, Johns Creek, Georgia 30097.
9. Defendant Viju Varghese, M.D., is a medical doctor licensed to practice in the State of
Georgia and is a citizen and resident of Fulton County. Defendant Varghese is subject to
the jurisdiction of this Court and may be personally served with process at his residential
address located at 950 West Peachtree Street, Unit 801, Atlanta, Georgia 30309.
10. Defendant Ravish Patel, M.D., is a medical doctor licensed to practice in the State of
Georgia and is a citizen and resident of Gwinnett County. Defendant Varghese is subject
to the jurisdiction of this Court and may be personally served with process at his residential
11. Defendant Abigail Arko-Asiamah, RN, is a registered nurse licensed to practice in the
State of Georgia and is a citizen and resident of Gwinnett County. Defendant Arko-
Asiamah is subject to the jurisdiction of this Court and may be personally served with
process at her residential address located at 3901 Lantern Hill Drive, Dacula, Georgia
30019.
12. Defendant Stephanie Bullard, RN, is a registered nurse licensed to practice in the State of
Georgia and is a citizen and resident of Jackson County. Defendant Bullard is subject to
the jurisdiction of this Court and may be personally served with process at her residential
in the State of Georgia and is a citizen and resident of Gwinnett County. Defendant
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Gonzalez-Conception is subject to the jurisdiction of this Court and may be personally
served with process at her residential address located at 3259 Vail Court, Snellville,
Georgia 30078.
14. Defendant Chante Harvey, RN, is a registered nurse licensed to practice in the State of
Georgia and is a citizen and resident of Gwinnett County. Defendant Harvey is subject to
the jurisdiction of this Court and may be personally served with process at her residential
15. Defendant Alegre Bailey, RN, is a registered nurse licensed to practice in the State of
Georgia and is a citizen and resident of Gwinnett County. Defendant Bailey is subject to
the jurisdiction of this Court and may be personally served with process at her residential
16. At all times relevant to the care and treatment of Mr. Lowe, Anwer Ali Bhamani, M.D
was an employee and/or agent and/or ostensible agent of Defendant Piedmont Eastside
Piedmont Healthcare and/or Anemonefish is liable for Defendant Bhamani’s acts and
omissions of negligence and malpractice under the theories of agency and respondeat
superior.
17. At all times relevant to the care and treatment of Mr. Lowe, Viju Varghese, M.D was an
employee and/or agent and/or ostensible agent of Defendant Piedmont Eastside and/or
Healthcare and/or Anemonefish are liable for Defendant Varghese’s acts and omissions
of negligence and malpractice under the theories of agency and respondeat superior.
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18. At all times relevant to the care and treatment of Mr. Lowe, Rivish Patel, M.D was an
employee and/or agent and/or ostensible agent of Defendant Piedmont Eastside and/or
Healthcare and/or Anemonefish is liable for Defendant Patel’s acts and omissions of
negligence and malpractice under the theories of agency and respondeat superior.
19. At all times relevant to the care and treatment of Mr. Lowe, Abigail Arko-Asiamah, RN
was an employee and/or agent and/or ostensible agent of Defendant Piedmont Eastside
and/or Piedmont Healthcare and/or AYA. As such, Piedmont Eastside and/or Piedmont
Healthcare and/or AYA are liable for Defendant Arko-Asiamah’s acts and omissions of
negligence and malpractice under the theories of agency and respondeat superior.
20. At all times relevant to the care and treatment of Mr. Lowe, Stephanie Bullard, RN was
an employee and/or agent and/or ostensible agent of Defendant Piedmont Eastside and/or
Healthcare and/or AYA is liable for Defendant Bullard’s acts and omissions of negligence
21. At all times relevant to the care and treatment of Mr. Lowe, Defendant Kenia M.
Piedmont Eastside and/or Piedmont Healthcare and/or AYA is liable for the negligent acts
respondeat superior.
22. At all times relevant to the care and treatment of Mr. Lowe, Defendant Chante Harvey,
RN was an employee and/or agent and/or ostensible agent of Defendant Piedmont Eastside
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and/or Piedmont Healthcare and/or AYA. As such, Piedmont Eastside and/or Piedmont
Healthcare and/or AYA is liable Defendant Harvey’s acts and omissions of negligence
23. At all times relevant to the care and treatment of Mr. Lowe, Defendant Alegre Bailey, RN
was an employee and/or agent and/or ostensible agent of Defendant Piedmont Eastside
and/or Piedmont Healthcare and/or AYA. As such, Piedmont Eastside and/or Piedmont
Healthcare and/or AYA is liable Defendant Bailey’s acts and omissions of negligence and
FACTS
24. On or around May 24, 2023, Paul Lowe was evaluated at Piedmont Eastside Emergency
Department after a ground level fall. He was noted to be complaining of right rib and
25. The results of a chest x-ray were concerning for pneumonia and Mr. Lowe was admitted
to the hospitalist service by Tejal B. Patel, DO, with diagnoses of sepsis, pneumonia,
26. From May 24, 2023 to May 30, 2023, Mr. Lowe’s condition worsened despite treatment
27. On or around May 30, 2023 at or around 11:25 a.m., Arjun Ghodasara, M.D., a
pulmonary and critical care specialist, evaluated Mr. Lowe in consultation for possible
intubation. Dr. Ghodasara noted that per his family, Mr. Lowe had “…previously
expressed he would not want to be kept alive on life support.” Per this request, Dr.
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Lowe’s current treatment with antibiotics and supplemental oxygen and to consider
28. At or around 12:30 p.m., Dr. Haritha Sajja met with Mr. Lowe and his family.
29. Based on Mr. Lowe’s continued hypoxia and his wish to avoid mechanical ventilation, a
decision was made to place Mr. Lowe in inpatient hospice care where he would remain
at Piedmont Eastside while the family made arrangements for long term hospice care at
30. At or around 4:51 p.m., Dr. Sajja wrote a summary discharging Mr. Lowe from the
inpatient hospitalist team and transferring his care to the inpatient hospice team. Dr. Sajja
noted in her discharge summary that Mr. Lowe had a blood pressure of 145/65, pulse of
76, SpO2 90% (on supplemental oxygen), respirations of 20 and was in no acute distress
31. At or around 5:25 p.m., Mr. Lowe’s care was transferred within Piedmont Eastside
Medical Center to Anwar Bhamani, M.D. who wrote orders admitting Mr. Lowe as an
inpatient hospice patient, estimating that the length of stay would be “Greater than or
equal to 2 midnights.”
32. Dr. Bhamani wrote several other orders at the same time, including that Mr. Lowe
receive morphine 1 mg/mL in sodium chloride 0.9% 50mL continuous infusion, that Mr.
Lowe receive oxygen therapy as needed via a nasal cannula at a rate of 2-4 L/min.
33. Upon Mr. Lowe’s care being transferred to Dr. Bhamani, no History and Physical was
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documented in the medical records was not filed by Dr. Bhamani until June 6, 2023,
34. In the “History and Physical” filed on June 6, 2023, Dr. Bhamani noted that as of May
30, 2023, Mr. Lowe had a heart rate of 76, respirations of 20, blood pressure of 145/65,
and an oxygen saturation of 100%. However, these numbers differ from the flowsheet
records at this time which were noted to be heart rate of 74, respirations 37, and oxygen
saturation of 91%. Dr. Bhamani also noted that Mr. Lowe was unresponsive and in no
acute distress at the time of his exam. Dr. Bhamani wrote that Mr. Lowe was receiving
Intravenous, Continuous.” (However, the morphine had not yet been started at the time
35. At or around 6:10 p.m. Mr. Lowe began receiving morphine at a dose of .07 mg/kg/hr at
a rate of 4.4 ml/hr. Morphine was prescribed to Mr. Lowe to reduce pain and air hunger
Gonzalez Concepcion R.N. with a dual signoff by Nurse Alegre Bailey, R.N. At this
36. At or around 6:13 p.m. Mr. Lowe’s respiratory rate was 40 breaths per minute and his
37. At or around 6:37 p.m., Nurse Kenia Gonzalez Concepcion recorded that Mr. Lowe had
a pulse of 80, a respiratory rate of 38, and an oxygen saturation of 89%. This is the last
time that a respiratory rate was recorded. No supplemental oxygen was given.
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38. At or around 7:30 p.m. Nurse Abigail Arko-Asiamah, R.N. noted that she checked the
morphine gtt (drip) order and infusion dose/rate on the pump with day-shift RN for
handoff and that both the order and pump values matched.
39. At or around 7:44 p.m., Nurse Arko-Asiamah noted that she reached out to the pharmacy
via phone to clarify the morphine gtt (drip) order, bringing it to the attention of the
pharmacy that the patient’s morphine was infusing at a rate of 0.07mg/kg/hr, but that the
order also stated to start the infusion at a 1mg/hr. She also questioned the titration order
since the order gave permission to titrate the rate of infusion but no titration parameters
were given. She was told by the pharmacy to change the rate to 1mg/hr and to reach out
40. At or around 7:53 p.m., Nurse Abigail Arko-Asiamah noted that she changed the
morphine infusion rate to 1mg/hr per the pharmacy’s instruction. The Medical
Administration Record (MAR) reflects this note by Nurse Arko-Asiamah with a dual
signoff by Chante Harvey, RN. However, when she made this change, she actually
41. At 7:53 p.m. Nurse Abigail Arko-Asiamah noted that Mr. Lowe’s family was at his
bedside reporting that Mr. Lowe was in distress and requested that he have increased
42. At or around 8:02 p.m. Nurse Arko-Asiamah noted that she “…reached out to Dr.
Patel…” for morphine order clarification and was told by Dr. Patel that he’d
communicated with the someone in the ICU who told him to titrate 0.1 at a time “till pt
is comfortable …” and also that the pharmacy confirmed this approach with him.
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43. At or around 8:30 pm. Nurse Arko-Asiamah noted that Dr. Patel was at Mr. Lowe’s
bedside with her and that Dr. Patel indicated the morphine infusion rate should be
changed to 1mg/mL/hr and Nurse Arko-Asiamah wrote, ”RN notified Dr. Patel the
morphine is currently infusing at 1mg/ml/hr.” Dr. Patel did not write a note indicating he
44. At or around 8:32 p.m. Mr. Lowe began receiving supplemental oxygen at a rate of 4
45. At or around 9:02 p.m. Nurse Arko-Asiamah noted that she received a new bag of I.V.
fluids containing morphine from the pharmacy. This new bag is also recorded in the
MAR. Nurse Arko-Asiamah noted that in preparing to administer the fluids to Mr.
Lowe, she wasted 20 mL of the fluid in priming the tubing. This is when Nurse Arko-
Asiamah notes that she realized the Alaris pump was infusing morphine at a rate of 1
milligram per kilogram per hour. Mr. Lowe’s weight was approximately 63.5 kg. At
this time, she notes that she changed the pump settings to 1 mg/hr to match the MAR
order.
46. At or around 10:53 p.m., nearly two hours after the events, Nurse Arko-Asiamah notified
Dr. Varghese of the morphine wastage and the incorrect morphine infusion rate. She
wrote in her note that she inquired of Dr. Varghese whether Narcan (an opioid antagonist
Varghese’s response was that Mr. Lowe was a comfort care patient, and Narcan was not
part of the protocol. From 6:10 p.m. until 10:53 p.m., Mr. Lowe received between 70 to
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morphine during this time period based on the order that Dr. Bhamani entered at 5:25
p.m.
47. At or around 10:55 p.m., Dr. Varghese placed an order for a third bag of morphine, to be
48. No vitals assessment of Mr. Lowe occurred from 12:13 a.m. until his recorded time of
49. Dr. Varghese and Nurse Arko-Asiamah knew of the overdose of morphine that Mr.
Lowe had been given at least by 10:53 p.m., but failed to notify Mr. Lowe’s wife, who
50. Medical care providers knew that Mr. Lowe would most likely die within minutes or
hours of being given this overdose of morphine if no action was taken to administer
51. Medical care providers failed to notify Mrs. Lowe that her husband’s death was
imminent or consult her in any way regarding options for treating the overdose.
52. Mrs. Lowe was awoken at approximately 3:45 and informed that her husband had died.
53. Medical care providers told Mrs. Lowe that her husband had died of natural causes and
kept the truth hidden from her that her husband had been euthanized by being given an
COUNT ONE
MEDICAL MALPRACTICE
54. Plaintiff repeats, realleges and incorporates by reference paragraphs 1 through 53 above
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55. Defendant Bhamani owed a duty to Mr. Lowe to provide the degree of care and skill
exercised by physicians generally who treated patients under the same or similar
circumstances as those that existed when he treated Mr. Lowe in May of 2023.
56. Defendant Varghese owed a duty to Mr. Lowe to provide the degree of care and skill
exercised by physicians generally who treated patients under the same or similar
circumstances as those that existed when he treated Mr. Lowe in May of 2023.
57. Defendant Patel owed a duty to Mr. Lowe to provide the degree of care and skill exercised
by physicians generally who treated patients under the same or similar circumstances as
58. Defendant Arko-Asiamah owed a duty to Mr. Lowe to provide the degree of care and skill
exercised by registered nurses generally who treated patients under the same or similar
circumstances as those that existed when she treated Mr. Lowe in May of 2023.
59. Defendant Bullard owed a duty to Mr. Lowe to provide the degree of care and skill
exercised by registered nurses generally who treated patients under the same or similar
circumstances as those that existed when she treated Mr. Lowe in May of 2023.
60. Defendant Gonzalez-Conception owed a duty to Mr. Lowe to provide the degree of care
and skill exercised by registered nurses generally who treated patients under the same or
similar circumstances as those that existed when she treated Mr. Lowe in May of 2023.
61. Defendant Harvey owed a duty to Mr. Lowe to provide the degree of care and skill
exercised by registered nurses generally who treated patients under the same or similar
circumstances as those that existed when she treated Mr. Lowe in May of 2023.
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62. Defendant Bailey owed a duty to Mr. Lowe to provide the degree of care and skill
exercised by registered nurses generally who treated patients under the same or similar
circumstances as those that existed when she treated Mr. Lowe in May of 2023.
Bailey and Harvey, breached the duty they owed to Mr. Lowe by failing to exercise a
reasonable degree of care and skill applicable to physicians and RNs generally, and such
64. The care given to Mr. Lowe by Defendant Arko-Asiamah, Defendant Bullard, Defendant
Harvey, Defendant Gonzalez-Conception and Defendant Bailey fell below the standard of
minimum care and treatment required of a registered nurse, including in the following
specific ways:
a. setting the Alaris pump used to administer morphine to Mr. Lowe to the wrong
infusion rate;
b. failing to note that the Alaris pump used to administer morphine to Mr. Lowe was
c. failing to inform the treating physician, Dr. Varghese, of the error involving the
setting of the morphine pump and the fact of the overdoes of morphine once it was
recognized;
d. failing to give Mr. Lowe supplemental oxygen prior to 8:30 p.m. as ordered by Dr.
e. failing to inform Mr. Lowe’s wife after realizing that Mr. Lowe had been given an
overdose of morphine.
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65. The care given to Mr. Lowe by Defendant Patel fell below the standard of minimum care
and treatment required of a physician in the following, but not limited ways:
a. failing to confirm for himself that the Alaris pump was set to a rate of 1mg/ml/hr of
b. failing to examine Mr. Lowe to determine his level of distress and failure to adjust hospice
therapy.
66. The care given to Mr. Lowe by Defendant Bhamani fell below the standard of minimum
care and treatment required of a physician in the following, but not limited ways:
a. Prescribing Morphine to a patient with renal failure. The FDA has issued Black Box
metabolites are cleared by the kidneys and will accumulate in patients with renal
failure. This accumulation led to increased toxicity in Mr. Lowe and likely
paradoxical pain based on Mr. Lowe’s continued elevation of respiratory rate despite
67. The care given to Mr. Lowe by Defendant Varghese fell below the standard of minimum
care and treatment required of a physician in the following ways but not limited to:
a. failing to notify Mr. Lowe’s wife of the Morphine overdose of Mr. Lowe;
b. failing to give medical advice and options to Mrs. Lowe; including failing to take
any steps to advice Mrs. Lowe on the possibility of giving Narcan to reverse the
effect of the morphine overdose and/or allowing Mr. Lowe to have his family with
68. Under the theory of respondeat superior, Defendants Piedmont Eastside and/or Piedmont
Healthcare and/or Anemonefish and/or AYA may be held liable for the negligent acts and
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Defendants Bhamani, Arko-Asiamah, Varghese, Bullard, Gonzalez-Conception, Patel,
69. As a direct and proximate result of the Defendants’ acts and omissions, Mr. Lowe suffered
71. As a direct and proximate result of Defendants’ professional negligence, Betty Lowe, As
Executor of the Estate of Paul Lowe is entitled to an award of special damages for medical
expenses and funeral expenses in an amount to be shown at trial, and general damages for
Mr. Lowe’s conscious pain and suffering, all in an amount in excess of Fifteen Thousand
Dollars ($15,000.00).
72. This action includes, but is not limited to, claims for professional malpractice under
the Affidavit of Matthew Tuck, M.D., an expert witness competent to testify in this matter,
which sets forth specifically at least one of the alleged negligent acts and omissions for
each Defendant, which form the basis of Plaintiff’s Complaint against the Defendants, and
includes the factual basis for such claims as set forth in the Complaint.
COUNT TWO
WRONGFUL DEATH
73. Plaintiff repeats, realleges and incorporates by reference paragraphs 1 through 72 above
74. As a direct and proximate cause of the negligence and professional negligence of
Defendants, Mr. Lowe suffered a wrongful death, entitling Betty Lowe, as the Next-of-
Kin of Mr. Lowe to an award of general damages for the full value of Mr. Lowe’s life in
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COUNT THREE
NEGLIGENCE OF PIEDMONT EASTSIDE AND PIEDMONT HEALTHCARE
75. The prior allegations are hereby incorporated by reference paragraphs 1 through 74 above
76. Piedmont Eastside and/or Piedmont Healthcare employees and agents, including but not
Conception, Patel and Harvey, violated Georgia law, Georgia regulations, as well as their
own job descriptions and policies in failing to give proper care to Mr. Lowe.
77. Piedmont Eastside and/or Piedmont Healthcare had a duty to exercise ordinary care in the
companies who provided care to Mr. Lowe while a patient of Piedmont Eastside,
including, but not limited to, employees or agents of Piedmont Eastside, Piedmont
78. Piedmont Eastside and/or Piedmont Healthcare, through their employees and agents,
failed to adequately credential, hire, train and supervise its medical doctors, residents,
79. Piedmont Eastside and/or Piedmont Healthcare are directly liable for their negligent acts
and omissions that caused injury to Plaintiff, including, but not limited to failing to
establish, implement, communicate and enforce adequate policies and procedures in order
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COUNT FOUR
NEGLIGENCE OF
AYA
80. The prior allegations are hereby incorporated by reference paragraphs 1 through 79 above
81. Aya employees and agents, including but not limited to, Defendants Arko-Asiamah,
regulations, job descriptions, and their own policies in failing to give proper care to Mr.
Lowe.
82. Aya employees and agents, including but not limited to, Defendants Arko-Asiamah,
adequately credential, hire, train and supervise the Aya employees who were responsible
83. Aya employees and agents failed to adequately credential, hire, train and supervise Aya
84. Aya is directly liable for the negligent acts and omissions that caused injury to Plaintiff,
including, but not limited to failing to establish, implement, communicate and enforce
adequate policies and procedures in order to provide Mr. Lowe appropriate care and
treatment.
COUNT FIVE
NEGLIGENCE OF ANEMONEFISH
85. The prior allegations are hereby incorporated by reference paragraphs 1 through 84 above
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86. Anemonefish employees and agents, including but not limited to, Defendants Bhamani,
Varghese and Patel violated Georgia law and Georgia regulations, job descriptions, and
87. Anemonefish employees and agents, including but not limited to, Defendants Bhamani,
Varghese, and Patel had a duty to exercise ordinary care to adequately credential, hire,
train and supervise the Anemonefish employees who were responsible for providing care
to Mr. Lowe.
88. Anemonefish employees and agents failed to adequately credential, hire, train and
supervise Anemonefish employees who were responsible for providing care to Mr. Lowe.
89. Anemonefish is directly liable for the negligent acts and omissions that caused injury to
Plaintiff, including, but not limited to failing to establish, implement, communicate and
enforce adequate policies and procedures in order to provide Mr. Lowe appropriate care
and treatment.
COUNT SIX
PUNITIVE DAMAGES
90. Defendants’ actions, inactions and omissions demonstrate gross negligence, willful
misconduct, malice, wantonness, oppression, and an entire want of care giving rise to the
91. In addition to the acts and omissions of all Defendants subject to punitive damages
pursuant to O.C.G.A. 51-12-5.1, § (b); the acts and omissions of Dr. Patel, Dr. Varghese
and Nurse Arko-Asiamah show a specific intent to cause harm by failing to take any action
to reverse the effects of the morphine overdose after they were aware that the overdose
had occurred.
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92. Pursuant to O.C.G.A. 51-12-5.1, § (f), there is no limitation regarding the amount which
may be awarded as punitive damages against an active tortfeasor and the active tortfeasors
for punitive damages related to specific intent to cause harm are Dr. Patel, Dr. Varghese
93. Mr. Lowe experienced pain and suffering and death as a result of Defendants’ wrongful
conduct.
94. Defendants knew that giving an overdose of morphine to Mr. Lowe would cause him
pain, suffering and death and intentionally failed to give appropriate management and care
of Mr. Lowe, knowing their actions would serious and avoidable injury and death to Mr.
Lowe.
95. Defendants Patel, Varghese and Arko-Asiamah knew that Mr. Lowe had received an
overdose of morphine and knowingly failed to administer Narcan or take any actions to
96. Defendants Patel, Varghese and Arko-Asiamah knew that Mr. Lowe had received an
overdose of morphine and knowingly failed to notify his wife or family of the overdose of
morphine or that Mr. Lowe would die within hours of the overdose of morphine.
97. As a result of the foregoing, Plaintiffs are entitled to an award of punitive damages from
the Defendants in an amount sufficient to punish Defendants and deter the Defendants
WHEREFORE, Plaintiff demands a trial by jury, that summons issue, that judgment be
entered in her favor and against the Defendants and that the following relief be granted:
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(a) That Plaintiff Betty Lowe, Executor of the Estate of Paul Lowe, be awarded special
damages in the amount proved at trial, and general damages in an amount to be determined by a
jury of her peers, against Defendants in excess of Fifteen Thousand ($15,000.00) Dollars;
(b) That Plaintiff Betty Lowe, as the Next-of-Kin of Paul Lowe and as the Executor of
the Estate of Paul Lowe, be awarded general damages in an amount to be determined by a jury of
(c) That Plaintiff Betty Lowe, as the Next-of-Kin of Paul Lowe and as the Executor of
the Estate of Paul Lowe be awarded punitive damages against all Defendants pursuant O.C.G.A.
51-12-5.1, § (b)
(d) That Plaintiff Betty Lowe, as the Next-of-Kin of Paul Lowe and as the Executor of
the Estate of Paul Lowe be awarded punitive damages pursuant O.C.G.A. 51-12-5.1, § (f) against
(e) And That Plaintiff be awarded such other and further relief as the Court deems just
and proper.
Respectfully submitted,
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EXHIBIT
A
EXHIBIT
1
As of March 29, 2023
Curriculum Vitae
1) Personal Data:
Matthew Grayson Tuck, M.D., M.Ed., F.A.C.P.
GWID#
2) Education:
Postgraduate Training
3) Employment:
Academic Appointments:
4) Scholarly Publications:
Redinger, J.W., Heppe, D.B., Albert, T.J., Tuck, M. et al. What internal medicine
attendings talk about at morning report: a multicenter study. BMC Med Educ 23, 84
(2023).
Yang G, Alarcon C, Friedman P, Tuck, M. et al. The Role of Global and Local
Ancestry on Clopidogrel Response in African Americans. Pac Symp Biocomput.
2023;28:221-232.
2
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
Education: Results of a National Survey of Internal Medicine Residency Program
Directors. American Journal of Hospital Medicine. 2022 April; 6 (2).
Thomas, A., Fang, M., Kong, S., Hubbard, C., Friedman, P., Gong, L., Klein, T.,
Nutescu, E., O’Brien, T., Tuck, M., Perera, M., Schwartz, J. Apixaban concentrations in
routine clinical care of older adults with non-valvular atrial fibrillation. JACC Advances.
2022;1(2), 100039.
Burstein DS, Chretien KC, Puchalski C, Teufel K, Aivaz M, Kaboff A, Tuck MG.
Internal Medicine Residents' Experience Performing Routine Assessment of What
Matters Most to Patients Upon Hospital Admission [published online ahead of print,
2022 Jan 22]. Teach Learn Med. 2022;1-12.
Heppe DB, Beard AS, Cornia PB, et al. A Multicenter VA Study of the Format
and Content of Internal Medicine Morning Report [published online ahead of print, 2020
Aug 10]. J Gen Intern Med. 2020;10.1007/s11606-020-06069-6.
Nooruddin M, Scherr C, Perera M, Friedman PN, Subrahmanyam R, Banagan J,
Moreno D, Sathyanarayanan M, Nutescu E, Jeyaram T, Harris M, Zhang H, Rodriguez A,
Shaazuddin M, Tuck M. Why African Americans say “No”: A study of
pharmacogenomic research participation. Ethnicity & Disease. 2020 Apr 2;30(Suppl
1):159-166.
Friedman PN, Shaazuddin M, Gong L, Grossman RL, Harralson AF, Klein TE,
Lee NH, Miller DC, Nutescu EA, O'Brien TJ, O'Donnell PH, O'Leary KJ, Tuck M,
Meltzer DO, Perera MA. The ACCOuNT Consortium: a model for the discovery,
translation and implementation of precision medicine in African Americans. Clin Transl
Sci. 2018 Dec 28.
3
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
Chretien KC, Tuck MG, Simon M, Singh LO, Kind T. A digital ethnography of
medical students who use Twitter for professional development. Journal of General
Internal Medicine. 2015 Nov;(11): 1673-80.
Hernandez, W., Gamazon, E., Aquino-Michaels, K., Patel, S., O'Brien, T.,
Harralson, A., Kittles, R., Barbour, A., Tuck, M.G., McIntosh, S., Douglas, J., Nicolae,
D., Cavallari, L., Perera, M. Ethnicity-specific pharmacogenetics: the case of warfarin in
African Americans. Pharmacogenomics Journal. 2014 Jun;14(3): 223-8.
O'Brien TJ, Kidd RS, Richard CA, Ha NH, Witcher P, Tran LV, Barbour A, Tuck
M, McIntosh SD, Douglas JN, Harralson AF. First report of warfarin dose requirements
in patients possessing the CYP2C9*12 allele. Clin Chim Acta. 2013 Sep 23;424: 73-5.
4
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
Albores-Saavedra, J., Tuck, M., McLaren, B., Carrick, K., Henson, D. Papillary
carcinomas of the gallbladder: analysis of noninvasive and invasive types. Archives of
Pathology & Laboratory Medicine. 2005 Jul; 129(7): 905-9.
Bass, E., Tuck, M., and Redmond, N. Q & A with SGIM’s CEO and the Chairs of
the 2022 Annual Meeting Program Committee. SGIM Forum, 45 (8), Aug 2022, pp 9 –
15.
Tuck, M., Redmond, N., Melissari, C, and Russell, J. The 2022 SGIM Annual
Meeting will Impact the Dimensions of Your Career. SGIM Forum, 44 (12), Dec 2021,
pp 5-13.
Tuck MG. Law ups ante on nitrous oxide possession and distribution. Journal of
Dental Technology. 17(7):34, 2000 Sep-Oct.
c. Chapters in Books
5
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
e. Abstracts
Friedman, P., Alarcon, C., Nooruddin, M., Gong, L., Harrison, A., O'Brien, T.,
Barbour, A., Nutescu, E., Tuck, M., Meltzer, D. and Perera, M.A., 2019, March.
PHENOTYPIC VARIABILITY IN ANTIPLATELET AND ANTICOAGULANT
THERAPY IN AFRICAN AMERICANS: AN ACCOUNT CONSORTIUM STUDY.
In CLINICAL PHARMACOLOGY & THERAPEUTICS (Vol. 105, pp. S67-S67). 111
RIVER ST, HOBOKEN 07030-5774, NJ USA: WILEY.
Hodge, Daniel K.; Kallus, Samuel J.; Tuck, Matthew. Beer Belly Without the
Beer: Tense Ascites as a Presenting Manifestation of SLE, American Journal of
Gastroenterology. October 2015 - Volume 110 - Issue - p S410-S412.
Tuck, Matthew. “The Risk Ratio, T1N1/T1N0, Correlates With Tumor Prognostic
Markers, Host Factors, and Overall Survival in Bronchogenic Lung Cancer: A Seer
(Surveillance, Epidemiology, and End Results) Study.” CHEST Journal (2006): n. pag.
Print.
6
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
f. Invited Publications:
Tuck, M, et. al. Society of General Internal Medicine. Five things physicians and
patients should question. Choosing Wisely. Revised January 17, 2023. Downloaded
January 25, 2023 from: https://www.choosingwisely.org/societies/society-of-general-
internal-medicine/.
g. Letters
Tuck MG, Holmes-Maybank K. Equal rights for general internists? J Gen Intern
Med. 2018 May 31.
h. Book Reviews
Robinson, S., Dew, A., Tuck, M. Panuveitis and rash in a man with HIV. Journal
of General Internal Medicine Clinical Images. July 28, 2017.
5) Presentations
a. Regional
7
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
Arundel, C., Logan, J., McIntosh, M., Tuck, M. “Update in Hospital Medicine.”
Grand Rounds, Washington DC VA Medical Center, May, 2017.
Arundel, C., Logan, J., McIntosh, M., Tuck, M. “Update in Hospital Medicine.”
Grand Rounds, Virginia Hospital Center, March, 2017.
Arundel, C., Logan, J., McIntosh, M., Tuck, M. “Update in Hospital Medicine.”
Grand Rounds, Washington DC VA Medical Center, June, 2016.
Ratner, L., MacDowell, S., An, D., Paal, E., and Tuck, M. “Maybe it Runs in the
Family: A case of TTR Subtype Cardiac Amyloidosis.” Poster presented at the
Georgetown University Research Day, May 5, 2016.
Kallus, S. and Tuck, M. “Beer Belly Without the Beer: Tense Ascites as a
Presenting Manifestation of SLE.”Poster presented at the Georgetown University
Hospital Research Day, May 7, 2015.
Tuck, M. “Conflict Management and the Kolb Learning Style.” Three 1-hour
workshops for Internal Medicine Residents at the George Washington University, April,
2015.
Tuck, M. “Evidence Based Medicine: Diagnosis.” Invited 1-hour lecture for the
Graduate Medical Education Community at The George Washington University, January,
2015.
Tuck, M. “Learning Proclivities and the Kolb Learning Style Inventory.” Three 1-
hour workshops for Internal Medicine Residents at the George Washington University,
September – October, 2014
8
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
Tuck, M. “Leadership: Skills and Strategies for Rising Senior Residents.”
Workshop for Internal Medicine Residents at the George Washington University, May
2014.
Mrkoci, D., Tuck, M., Arundel, C., Greysen, R., McIntosh, M. (2011). A Patient
Safety Curriculum Integrated into Noon Conference to Educate Faculty and Housestaff.
Poster presented at annual mid-Atlantic regional meeting of the Society for General
Internal Medicine, March 18, 2011.
Tuck, M., Sandler, N., Keiser, J., Roberts, A., Kalwaney, S. (2007). An unusual
prostate infection in a man returning from El Salvador. Poster presented, and first place
awarded at the American College of Physicians District of Columbia Scientific Meeting
in Bethesda, Maryland, November 2-3, 2007
9
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
b. National
10
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
Kurland, K., Barbour, A., Amdur, R., Kuang, X., Tuck, M. Congruence Between
Attending Physician and Patient Feedback of Residents as Patient Educators. Poster
presented at the Society of General Internal Medicine National Meeting, Denver, CO,
April 13, 2018.
Burstein, D., Chretien, K., Puchalski, C., Aivaz, M., Kaboff, A., Tuck, M.
Assessment of patients' values and goals upon admission to internal medicine services:
Experiences & Applications. Poster presented at the Society of General Internal Medicine
National Meeting, Denver, CO, April 13, 2018.
Arundel, C., Logan, J., McIntosh, S., Tuck, M. “Working Smarter: Tools to
Enhance Learning and Feedback.” Workshop presented at the Society of General Internal
Medicine National Meeting, April 11 – 14, 2018.
Ramani, S., Tuck, M., Chretien, K., Sullivan, G. “What Counts Cannot Always
Be Measured: Principles of Qualitative Research and Introduction to Qualitative
Analysis.” Workshop presented at the Society of General Internal Medicine National
Meeting, April 19 – 22, 2017.
Ramani, S., Chretien, K., Sullivan, G., Tuck, M., “Moving Beyond Numbers:
Applying Qualitative Methodology to Expand the Scope of Research and Scholarship.”
Workshop presented at the Society for General Internal Medicine National Meeting, May
11-14, 2016.
Chretien, K., Tuck, M., Simon, M., Kind, T. Medical Students on Twitter: A
Digital Ethnography. Poster invited at the Alliance for Academic Internal Medicine
National Meeting, Washington, DC, September 11 – 13, 2014.
11
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
Wenndy Hernandez, Ph.D., Eric R. Gamazon, Ph.D., Keston Aquino-Michaels,
B.A., Shitalben Patel, M.S., Travis J. O’Brien, Ph.D., Art F. Harralson, Pharm.D., Rick
A. Kittles, Ph.D., April Barbour, M.D., Matthew Tuck, M.D., Samantha D. McIntosh,
M.D., Jacqueline N. Douglas, Pharm.D., Dan Nicolae, Ph.D., and Larisa H. Cavallari,
Pharm.D., Minoli A. Perera, Pharm.D, Ph.D. Liver eQTLs for warfarin dose response
genes reveal susceptibility to venous thromboembolism among African Americans.
Invited as an oral presentation and recipient of the ASCPT Presidential Trainee Award at
the American Society for Clinical Pharmacology and Therapeutics. March 21, 2014,
Atlanta, Georgia.
Harold, R. & Tuck, M. (2012). Dabigatran toxicity in a 65 year old male who
failed other anti-coagulation methods. JGIM, Volume 27, Supplement 2 / July 2012.
Poster presented at the Society for General Internal Medicine National Annual Meeting in
Orlando, Florida, May 9-12, 2012.
Chretien, C., Arundel, C., Cayea, D., Swenson, R., Tuck, M., "The A Team,"
Workshop presented at the Society for General Internal Medicine National Meeting, May
9-12, 2012.
Schwartz, A., Henson, D., and Tuck, M. (2006). The risk ratio, T1N1/T1N0,
correlates with tumor prognostic markers, host factors, and overall survival in
bronchogenic lung cancer: A SEER (surveillance, epidemiology, and end results) study.
[Abstract] Chest, 130, 232S.
Poster presented at the Annual meeting of the American College of Chest
Physicians in Salt Lake City, Utah, October 2006
Poster presented at Annual Research Day, George Washington University, 2007
Schwartz A., Henson D., Tuck M. (2004). Risk factors associated with lymph
node metastasis in bronchogenic lung cancer: A SEER (surveillance, epidemiology and
end results) study. [Abstract] Chest, 126, 851S.
Poster presented at Annual convention of the American Medical Student
Association, March 16 -20, 2005
Poster presented at Annual Research Day, George Washington University, 2005
12
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
Poster presented at 2004 Annual meeting of the American College of Chest
Physicians, October 23 – 28
Tuck M., Rosser T., McClintock W., Elling N., Pearl P. (2004). Epilepsy
characteristics in a population of 69 patients with tuberous sclerosis. [Abstract] Annals of
Neurology, 56, S8, S117-118.
Poster presented, and first place awarded at Annual Pediatric Research Poster Day
at Children’s National Medical Center, May 11, 2004
Poster presented at annual meeting of American Neurological Association,
October 3 – 6, 2004.
Poster presented at Annual Research Day, George Washington University, March
26, 2004.
c. International
13
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
warfarin dose in
African-
Americans
Medical Students Clerkship 4/01/13 – $5,000 Co-I No salary
who use Twitter Directors of 12/31/13 support
for Education: A Internal
Twethnography Medicine
African American National 9/1/16 – $1.5 Co-I 1.2
Cardiovascular Institute on 5/31/21 million calendar
pharmacogenetic Minority months
Consortium Health and
(ACCOuNT) Health
Disparities
Caring in Clinical Universal 1/24/17 – $2,000 PI No salary
Practice: Health 2019 support
Doctoring that Services
considers the
disease as well as
the person who
has the disease
Pharmacogenomic Sanford 12/14/20 – $88,000 Site 1.2
Testing for Laboratories 5/31/23 Champion calendar
Veterans months
(PHASeR)
Targeting high Veterans 3/1/22 – $38,378 PI 1.2
risk individuals Affairs 9/30/22 calendar
for gene-drug National months
interactions using Oncology
VIONE Program
A Primary Role Department 10/1/23 – $55,621 Co-I 1.2
for the of Defense 9/30/28 calendar
Circulatory months
Microenvironment
in African
American Prostate
Cancer
Disparities?
14
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
2011 – Present Society of General Internal Medicine, Appointed to the
Academic Hospitalist Task Force 2012 – present; co-Chair
2015 – 2017; Chair 2017 – 2019; National Program
Committee Chair 2021 – 2022.
a. Departmental
2009 – 2010 Telemetry committee
2009 – 2010 Housestaff schedule coordinator
2009 – 2010 Hospitalist attending schedule coordinator
2009 – 2010 Nonteaching service coordinator
2009 – 2013 Nurse-Physician collaborative committee; Chair (2012-
2013)
2011 Missing patient committee
2011- Present Alternate Voting Member, Research & Development
Committee
2012 – 2014 Emergency-Cardiology-Hospital Medicine collaborative
committee, Chair
2014 – Present Physician Utilization Management Advisor
2017 – Present Institutional Review Board Committee Member
2018 – 2021 Strategic Analytics for Improvement and Learning
committee member
2018 – Present Utilization Management Advisory Committee, Chair
2019 – Present Geographic Rounds workgroup, Chair
15
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
10) Educational Achievements:
a. Courses Taught
2009 – Present Ward attending for inpatient wards; Direct supervision,
education, and evaluation of ward team at the VA Medical
Center
2009 – Present Student lectures for students on their internal medicine
clerkship at the VA Medical Center twice a week
2009 – 2019 Bedside physical diagnosis rounds; faculty mentor for
medical students up to three times a month
2011 – Present Junior Medicine Seminar Lecturer for Uniformed Services
University of Health Sciences third year medical students,
guest lecturer
2013 – Present Duke University, "Teaching and Leading Evidence-based
Practice,” core faculty
2014 – 2017 Public Health 201: Introduction to Evidence-based
medicine, developed a longitudinal curriculum for first year
medical students at the George Washington University
2015 Preceptor, 3rd year Uniformed Services University of
Health Sciences Students, Internal Medicine Clerkship
2015 – 2016 “The face of HIV,” Small group discussion leader for film
How to Survive and Plague and anthology Still Here: A
Post-cocktail AIDS Anthology for first-year medical
students at the George Washington University
2016 Pharm 6116: Pharmacogenomics and Personalized
Medicine, invited 2.5 hour lecture to the George
Washington University School of Medicine and Health
Sciences graduate students
2016 Obesity Critical Literature Review Session for 2nd year
medical students, George Washington University, April 19,
2016
2016 The Practice of Medicine, Intersession III for medical
students, George Washington University, June 23, 2016
2012- 2019 Residents as Young Educators Curriculum for Internal
Medicine Residents, George Washington University.
16
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
Medicine, developed a longitudinal curriculum for first and
second year medical students at the George Washington
University
c. Academic Advisement
2011 Rahul Vanjani, Medical Student, matched internal medicine
resident at Columbia Presbyterian University
2012 Rachel Harold, Medical Student, matched internal medicine
resident at Georgetown University
2012 Allison Bush, Medical Student, matched internal medicine
resident at Walter Reed
2013 Richard Crawford, Medical Student, Annual Shadowing
Program for Office of Student Professional Enrichment at
the George Washington University; matched to MedStar
Georgetown University Hospital for psychiatry residency
2013 Rishi Sood, Medical Student, matched radiology at George
Washington University
2014 Jaspreet Suri, Medical Student, matched at Temple
University Hospital for Internal Medicine
2014 Rajeev Samtani, Medical Student, matched at Icahn School
of Medicine at Mount Sinai for Internal Medicine
2014 Jane Lim, Medical Student, matched at Cedars-Sinai
Medical Center for Internal Medicine. Served as research
mentor. Supervised research and manuscript preparation.
2014 Dalya Elhady, Medical Student, matched at University of
Florida for anesthesiology residency. Served as research
mentor for Dr. Elhady’s research. Supervised research on
the Residents as Young Educators curriculum, including
research design, data entry, analysis, abstract and poster
presentation, as well as manuscript preparation.
2015 Sara MacDowell, Medical Student, case series cardiac
amyloid
2015 Maria Henry, Medical Student, served as research mentor
for Maria’s research, supervised research on the Residents
as Young Educators curriculum, including research design,
data entry and manuscript preparation
2015 Alvin Kim, Medical Student, Matched to anesthesiology at
Columbia University
2016 Katherine Harmon, Medical Student, matched to pediatrics
At Childrens Hospital-LA in California
2016 - 2019 Kyle Kurland, Medical Student. Served as research mentor
for Kyle’s research. Supervised research on the Residents
as Young Educators curriculum, including data collection
and data entry
2017 Anthony Rowe, Medical Student, matched to Georgetown
University Internal Medicine residency
17
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
2017 Alex Dew and Sara Robinson, Residents, served as
research mentor, supervised research and manuscript
preparation
2017 Marudeen Aivaz, Medical Student, served as research
mentor, supervised research methods and qualitative
interviews
2017 - 2019 David Burstein, Resident, served as research mentor.
Supervised grant submission, IRB submission, research
methods, qualitative interviews, data analysis and
manuscript preparation; provided career advice; matched to
Northwestern University General Internal Medicine
Fellowship 2019
2018 - 2020 Heather Briggs, MD, PhD, UTHSCSA faculty member,
served as faculty mentor through Society of General
Internal Medicine’s Career Advising Program, promoted to
Associate Professor of Medicine at UTHSCSA in 2019
2018 David Agdashian, Medical student, shadowed in summer
2018
2018 Richard Ryngel, pre-medical student, shadowed in summer
2018.
2018 – Present Jeff Banagan, MS; provided career and research
mentorship; provided oversight of laboratory work,
research coordination duties, and creation of abstract
presented at VA Research Day in 2019
2019 Muhammed Shand, medical student; career advice;
matched ENT, University of Nevada Las Vegas School of
Medicine
2019 Kyle Costenbader, medical student; career advice; matched
to Medicine-preliminary, Greater Baltimore. Medical
Center and to Radiology, University of Maryland
2020 Caylynn Yao, medical student; career advice; matched to
anesthesiology MedStar Georgetown University Hospital
2020 Ari Mandler, medical student; career advice; matched to
internal medicine residency at Cornell
2020 Tucker Smith, pre-medical student; career advice;
matriculated to Virginia Commonwealth University School
of Medicine
2021 Sumedha Singh, MD, resident; career advice; mentor;
fellowship advice; match to gastroenterology fellowship at
Einstein Hospital
2021 Katrina Naik, MD, resident; mentor; matched to
gastroenterology fellowship at University of Nevada
2021 Andres Garza, MD, resident; mentor; matched to
pulmonary/critical care fellowship at Baylor University
2021 Sangeetha Isaac, MD, internal medicine resident at North
Alabama Medical Center; mentor on research
18
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
2021 Afraz Pasha, MD, internal medicine resident at North
Alabama Medical Center; mentor on research
d. Educational Awards
19
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
20
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
hospital-outcomes-through-patient-engagement-i-hope-
study
b. Regional
21
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
2004 – 2005 University Senator to the Student Assembly, Finance
Committee; represented the School of Medicine to the
University Student Assembly
2016 – 2017, 2019 Medical Education Research Grant Reviewer, The George
Washington University
22
Matthew Tuck, M. D., M.Ed., F.A.C.P.
Curriculum Vitae as of March 29, 2023
2020 Flu Clinic provider, George Washington University
community outreach
23