Kim married her high school sweetheart, Kanye, in June 2020. In August 2020, they discovered that they were going to have a baby. Kim had a rather difficult pregnancy, having been diagnosed with pre-eclampsia early into her second trimester. On 11 April 2021, Kim began to feel contractions and went to the maternity ward at the Pacifica Private Hospital (PPH) at 1:22 PM. April is the hospital's busiest month so the maternity ward at the hospital was busier than usual. Kim was attended to by Nurse Taylor, a registered nurse who had worked for PPH for ten years. Nurse Taylor had recently moved to the maternity ward from the general surgical ward. During the evaluation, Kim informed Nurse Taylor that she was in a considerable amount of pain. The pain was so great that Kim did not inform Nurse Taylor that she had pre-eclampsia. Nurse Taylor did not consult Kim's chart or check the baby while conducting the initial assessment. After concluding her assessment, Nurse Taylor classified Kim as a low risk pregnancy. According to the Pacific Standard Emergency Management in Obstetrics, Gynecology and Neonates (PSEMOGN) which applied to all Pacifica Hospitals, the standard procedure for low-risk pregnancies was to keep the expectant mother and the fetus under observation for eight hours. If the next assessment showed no signs of active labour, then the patient would be advised to head home. However, since the maternity ward was at full capacity, Nurse Taylor instructed Kim to go home. She told Kim that if her condition did not improve then she should come back to the hospital. At 8:11 PM, Kim came back to the hospital. She informed the staff that she was in an unbearable amount of pain. Nurse Taylor, who was still on duty, conducted another assessment and found that Kim's cervix had not dilated since her assessment in the morning. Although she heard some irregularities in the baby's heartbeat, she did not think it was of concern. She did not consult Kim's chart again and had decided that Kim was exaggerating her pain because this was her first pregnancy. She tried to send Kim back home, but Kanye demanded that Kim be seen by a doctor. Around 11:00 PM, Kim was finally seen by Dr. Piers. Dr. Piers consulted Kim's medical chart and saw that she had been previously diagnosed with pre-eclampsia. He further had difficulty finding the baby's heartbeat. He immediately admitted Kim and booked her for an emergency C-section. Under the PSEMOGN, pregnancies where the mother has been diagnosed with pre-eclampsia are high-risk and require supervision. Kim's son, South, is born at 11:45 PM. He dies an hour later at 12:45 AM. The medical Examiner's report stated that there were two reasons why the child may have been in distress: (1) the delayed delivery and (2) a congenital heart problem. The Medical Examiner was unable to determine which of the two reasons caused the child to be in distress. A month after the death of Baby South, Kim falls violently ill and is admitted to PPH. The doctors are unable to diagnose the cause of her sickness and she dies. The medical examiner later finds a gauze pad and needle in Kim's abdomen at the site of the C-section. Kanye is aggrieved and would like to sue for the deaths of his wife and son. Assuming that the duty of care has been proven, Nurse Taylor, Dr. Piers and the Pacifica Private Hospital breached their duty of care to Kim and South.

You are the lawyer for Pacifica Private Hospital. How would you frame your arguments in relation to causation? USE IRAC TO ANSWER AND CASELAWS WHERE POSSIBLE. USE LAWS FROM FIJI JURISDICTION.