STATE OF MINNESOT} Case Type: Wrongful Death DISTRICT COURT COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT Michael A. Zimmer as trustee for the next of kin of Prince Rf deceased, ws Jowa Health System, d, Health, Walgreen Co., gers Nelson, COMPLAINT Plaintiffs, i//a UnityPoint IMichael T. , M.D., ald North ‘Memorial Health Care| intitt Mi Nelson, deceased, for I Defendants. A. Zimmer as trustee for the next of Iin of Prince Rogers is claims for relief alleges as follows: PARTIES AND JURISDICTIONAL FACTS. Prince Rogers Nelson (héreinafter referred to as Prince} was born and raised in Hennepin County, Misnesota, and died in Carver County, Minnesota on April 21, 2016. Pursuant to tht was subsequently ay ‘Minnesota Wrongful Death Act, plaintiff Michael A, Zimmer inted as trustee for Prince's next of kin by Order-of the District Court of the First Judjcial District of Minnesota. The next of kin) Sharon Nelson, Jackson and Omarr Bf County, Minnesota, of Missouri. lof Prince are his six sisters and brothers: Norrine Nelson, Tyka Nelson, John Rodger Nelson, Alfred jaker. Of these six brothers and sisters, four reside in Hennepin he in Washington County, Minnesota and one in Kansas City,Defendant lowa, Health System, d/b/a UnityPoint Health (hereinafter UnityPoint an emergency departmpnt and a pharmacy. UnityPoint Health also does business in Hennepin County, Mi attached}. HealthPa: .esota as HealthPartners UnityPoint Health (see Exhibit A sfers is @ health care provider and insurance company based in Hennepin County, Minnesota. Defendant Walgfeen Co. is a corporation with its headquarters at 200 Wilmot Road in Deerfield, Iinbis, which operates a multitude of Walgreens Pharmacies throughout the United|States, including in Hennepin County, Minnesota. 7, Schulenberg, M.D. is a medical doctor licensed to practice times relevant hereto practiced in Hennepin County, physicians, including #t all times relevant hereto defendant Michael T. Schulenberg, MD. H FACTS For an unknowh but considerable period of time before his death on April 21, 2016, Prince suffered from addiction to opioid pain medications. The cause of his death on that date wag an unintentional overdose of an opioid drug called fentanyl, In the weeks immediately preceding his death, Prince received professional health care services frpm all of defendants.On April 8, 2011 Schulenberg, acting as On April 14, 20: UnityPoint Health In providing had a duty to provide medical praétice. He treat and counsel Prin take appropriate and addiction. ‘These substantial part ia by Health care prof department and pharn} Center in Rock Island, he feceived professional health care services from Dr. employee of North Memorial Health Care. , and possibly before that date, Prince received narcotic from Walgreen Store #9511 in Bloomington, Minnesota. /acting as an employee of North Memorial Health Care, |, 2016, Prince received prescription medications from m CLAIMS ts had an opportunity and duty during the weeks before ee and treat Prince’s opioid addiction, and to prevent his 80, .asional health care services to Prince, defendant Schulenberg, quality of care consistent with the standard of acceptable led to do 60. He failed to appropriately evaluate, diagnose, de for his recognizable opioid addiction, and further failed to able steps to prevent the foreseeably fatal result of that 3 ftom the standard of acceptable medical practice had a jg about Prince’s death. fessionals who treated Prince in the hospital emergency acy operated by defendant UnityPoint Health at Trinity Medical Intinois had a duty to provide thie quality of care consistent with