Draft a complaint for damages based on the fact pattern you drafted in Assignment 1 to be filed in Indiana state court. Utilize the complaint found below of your text

as guides, but remember that because we are in Indiana state court, you will need to add a proper Indiana caption. You may prepare the complaint to be filed in your home county and utilize the formsfound at https://www.in.gov/courts/publications/forms/civil-criminal/to assist you with your caption.Your complaint will be graded based on your (a) grammar, (b) analysis of the key facts, and (c) application of the legal principles involved. Your complaint should be uploaded as a Word file.

COMPLAINT:

COMMONWEALTH OF MASSACHUSETTS SUFFOLK, ss. SUPERIOR COURT CIVIL DEPARTMENT CIVIL ACTION NO: 00-XXXX Estate of Michael Bonin VS. Chelsea Tinsmith, M.D. COMPLAINT AND DEMAND FOR JURY TRIAL THE PARTIES 1. Michael Bonin was a resident of Massachusetts and is of legal age. 2. Defendant Chelsea Tinsmith, M.D., has a license to practice in the Commonwealth of Massachusetts. Defendant Tinsmith had a place of business in Miskatonic, Massachusetts, during all times stated in this complain

GENERAL ALLEGATIONS 3. On approximately September 19, 1978, Michael Bonin was examined for the first time by Defendant Tinsmith. 4. As a result of medical testing conducted on September 19, 1978, Dr. Tinsmith confirmed a diagnosis that Mr. Bonin suf-fered from Wilson's Disease. 5. Wilson's Disease is a genetic disorder that, if left untreated, will eventually lead to the complete loss of functionality in a person's liver, thereby resulting in death. 6. Mr. Bonin continued to seek medical care from Dr. Tinsmith for approximately the next sixteen years. 7. During that time, Dr. Tinsmith did not discuss with Mr. Bonin the option of getting a liver transplant. 8. During that time, Dr. Tinsmith never discussed with Mr. Bonin any treatment option for his Wilson's Disease. 9. On approximately October 27, 1994, Mr. Bonin experienced bleeding from the throat. 10. Upon hospitalization on October 27, Mr. Bonin received a diagnosis that the bleeding came from high blood pressure which caused the bursting of minor arteries. 11. Within the next week, Mr. Bonin received a further diagnosis that the high blood pressure came because of a significant loss of functionality of his liver. 12. Subsequent testing indicated that the loss of functionality was due to the effects of Wilson's Disease. 13. Mr. Bonin was immediately placed at the head of a list to receive a liver transplant. 14. On February 2, 1995, Mr. Bonin again experienced bleeding from his throat. His circulatory system failed and he died that day. 15. On April 2, 1995, Gibson, J., Suffolk Probate and Family Court, appointed Marc Savignac as executor of the estate of Michael Bonin. NEGLIGENCE 16. Plaintiff, the Estate of Michael Bonin, by reference, restates and reincorporates each and every allegation stated in previ-ous paragraphs. 17. Plaintiff alleges that Dr. Tinsmith was negligent in providing medical care and treatment to Mr. Bonin by not informing Mr. Bonin of the most likely outcome of not treating Wilson's Disease. This was a failure to comply with the standard of care ordinarily exercised by a physician licensed to engage in the practice of medicine in the Commonwealth of Massachusetts. 18. Dr. Tinsmith was negligent in providing medical care and treatment to Mr. Bonin by not informing Mr. Bonin of the op-tions for treating Wilson's Disease, including but not limited to a liver transplant. 19. The negligence of Dr. Tinsmith directly and proximately resulted in the pain and suffering of Mr. Bonin. 20. The negligence of Dr. Tinsmith directly and proximately resulted in the death of Mr. Bonin. WHEREFORE, Plaintiff Estate of Michael Bonin demands judgment against defendant Dr. Chelsea Tinsmith, in the amount of $50,000, to compensate it for the pain, suffering and death