Please help me draft a complaint that can be filed with the Clerk's Office in Pinellas County for ANY POTENTIAL available causes of action

Mr. Jim Binion has come into my office noting the facts as listed below regarding his situation. My legal nurse consultant has gathered some additional information and expert witnesses if trial is necessary. I have spoken briefly to the other attorneys regarding this case as they are fully expecting suit to be filed. We would obviously like to settle, but we will pursue suit if necessary. Please read the following and see below for the information I will need in return:

On Friday, June 23, 2023, Jim Binion's wife went to Jones Pharmacy ("Pharmacy ") to refill his prescription for Dymelor, an oral medication for the control of diabetes mellitus. Originally diagnosed as a noninsulin-dependent diabetic in 1990, Binion's disease had been under control for approximately 10 years. Maintaining control of noninsulin-dependent diabetes requires a careful balancing of daily food and insulin requirements. Dymelor stimulates an underproducing pancreas to produce a sufficient amount of insulin. Generally, Binion took five Dymelor tablets a day.

At the Pharmacy, Binion's Dymelor prescription bottle was filled with Aldomet, a prescription drug used to reduce blood pressure in individuals suffering from high blood pressure. Aldomet tablets are a slightly different color, shape and size from Dymelor tablets. In taking Aldomet instead of Dymelor, Binion was not producing sufficient insulin to maintain control of his diabetes and he was receiving an Aldomet dosage significantly greater than the maximum recommended dosage for an individual suffering from high blood pressure. Binion did not suffer from high blood pressure.

Within 24 hours, Binion began experiencing chills, shakes, drowsiness and a general decrease in appetite. These symptoms continued through June 27, 2023, when Binion felt too ill to go to work and contacted Central Florida Clinic ("Clinic") to make an appointment with his physician. Binion was informed that his physician was on vacation and was referred to Dr. Smith, also a Clinic employee. Binion saw Dr. Smith on the morning of June 27, 2023.

During the office visit, Binion complained of chills, shakes, dizziness, fatigue and seeing bright flashing lights. Dr. Smith conducted a clinical examination which revealed that Binion had a slight fever and a blood pressure of 100/60. Although a blood pressure of 100/60 is low for a man of Binion's age and general medical condition, it is still within the normal range. Binion's pulse rate was 140 which is quite rapid. Normal pulse rates range between 60 and 80. A blood count revealed no infection. Based on Binion's diabetic history, Dr. Smith ordered a blood sugar test which revealed a blood sugar level of 307 milligrams per deciliter. Normal blood sugar levels range from 65 to 110 milligrams per deciliter. Dr. Smith diagnosed Binion as suffering from diabetes out of control with a fever of unknown origin and suggested hospitalization to conduct additional tests and to re-establish control of his diabetes. Neither Dr. Smith nor Binion were aware that Binion had been receiving the wrong medication.

Binion was admitted to Good Samaritan Hospital in Largo, Florida on June 27, 2023, where additional tests were performed. Dr. Smith ordered blood sugar level and ketone body checks four times per day. The first two tests performed on June 27, 2023, revealed blood sugar levels of four plus on a scale of zero to four and were negative for ketone bodies. A four plus blood sugar level indicates diabetes out of control. Test results negative for ketone bodies indicates that Binion was not in ketoacidosis, a breakdown of body fats which results in diabetic coma. The third test was three plus on a scale from zero to four for ketone bodies which is an indication of dehydration. An electrolytes balance test was normal which is an indication that Binion was not suffering from dehydration. A lipid profile indicated that his triglycerides were quite elevated. High triglycerides are consistent with the diagnosis of diabetes out of control. All other tests returned normal findings.

On June 28, 2023, Binion's wife realized that the development of his symptoms coincided with the recent refill of his Dymelor prescription and that he had mentioned the refill pills were a slightly different shape from his previous pills. Suspecting the possibility of a medication error, she took some of the pills to the hospital on June 29, 2023, when she went to visit her husband. Dr. Smith identified the pills as Aldomet, a prescription medication for high blood pressure, and indicated that he would contact Pharmacy concerning the prescription refill. Dr. Smith did not inform Binion of his ownership interest in Pharmacy. June 29, 2023, is the first time anyone knew there had been a medication error.

In the hospital, Binion was removed from all medication and placed on a controlled diabetic diet and a sliding scale of insulin to determine his daily insulin requirement. Although his blood sugar level continued to drop, it remained above the normal range. By July 6, 2023, the date of his release, Binion's blood sugar level of 155 was still above normal, but Dr. Smith considered it an acceptable level to allow discharge. Throughout his hospitalization, Binion's blood pressure remained consistently low. Although within the generally accepted normal range, it was notably low for a man of his age and medical history. Additionally, his past blood pressure readings had been significantly higher. No additional tests were performed to determine the reason for his consistently low blood pressure, and on the date of release, Binion's blood pressure was 98/60, the lowest it had been since he entered the hospital.

On the morning of July 6, 2023, Binion was released from the hospital. Sometime late that evening or early the next morning, Binion suffered a cerebral infarction, or stroke, resulting in a permanent loss of function to his right side, disorientation, and general debility. A CT scan revealed that a major area of his left frontotemporal lobe had been destroyed. Binion's disabilities include partial paralyzation of parts of the right side of his body and the left side of his face, difficulty in speaking, memory tending to fade as he speaks and inability to perform even simple manual labor. He was readmitted to Good Samaritan Hospital under the care of Dr. Trivedi.

A cerebral infarction, more commonly called a stroke, is the death of brain tissue by one of three general mechanisms, all of which involve depriving the brain of an adequate blood supply and the oxygen it carries. Central nervous system tissue, of which the brain is a major portion, is extremely sensitive to oxygen deprivation. If the brain is completely deprived of oxygen for more than four minutes, a person will die. In a stroke, a portion of the brain is deprived of oxygen long enough for tissue death to occur. Brain tissue is unique in that it has no capacity for regeneration. Although post-stroke recovery is possible, such recovery involves utilizing undamaged cells or re-learning, not the healing of damaged cells.

An elementary understanding of the different types of stroke is necessary. There are three types of stroke: hemorrhagic, embolic and thrombotic. A hemorrhagic stroke results from the rupture of a blood vessel or aneurysm. Brain tissue normally supplied by the ruptured vessel is deprived of its blood supply and dies. Hemorrhagic strokes are rare and sudden in onset with little or no pre-warning. Binion did not suffer a hemorrhagic stroke. In an embolic stroke, a small embolus, a free-floating piece of plaque, lipid or blood clot, breaks loose from somewhere else within the circulatory system and eventually lodges in a smaller vessel, thus depriving brain tissue of its blood supply. Medical conditions that predispose an individual to an embolic stroke include phlebitis, heart murmurs, atrial fibrillation and arteriosclerosis. Embolic strokes occur suddenly with no forewarning. Binion was suffering from arteriosclerosis wherein the blood vessel walls become less elastic and the diameter is narrowed because of deposits of cholesterol, and defendants contend that he suffered an embolic stroke which they could neither predict nor prevent. A thrombotic or occlusive stroke occurs when a blood vessel closes off because of a collapse in the vessel, a build-up of lipids (fatty deposits) or plaque, or the formation of a blood clot which prevents the passage of blood. A thrombotic stroke develops gradually and is often indicated by transient ischemic attacks (TIA's). A TIA is the transient loss of neurologic function and occurs because the blood vessel is narrowing and the brain is not receiving enough blood to function at 100 percent, but it is receiving enough blood to keep the tissue alive. Because the area of the brain that is not being completely profused with blood is the same area that will be damaged by any thrombotic stroke, the accompanying TIA's are evidenced by short-term losses in the same functions. TIA's may be evidenced by garbled speech, behavior changes, and paralyzation or weakness. Binion contends that he suffered a thrombotic stroke which the doctors could have prevented with proper medical treatment.

Dr. Howard Schwartz, Director of Emergency Medical Services at Tampa General Hospital, a board certified toxicologist who teaches at University of South Florida Medical School, is prepared to testified for Binion. Dr. Schwartz claims that, based on a review of the hospital records, Dr. Smith failed to meet the standard of care required of a physician in providing care and treatment to a diabetic presenting Binion's symptomatology. Based on the signs, symptoms and tests given, Dr. Schwartz claims that Binion was dehydrated when he entered the hospital on June 27, 2023 and that he was still dehydrated when he was discharged nine days later on July 6, 2023. Dr. Schwartz claims that any diabetic out of control is dehydrated and that the effect of taking a blood pressure reducing medication like Aldomet would be to increase that dehydration. The records show that Binion had an elevated urine specific gravity, rapid pulse, abnormally low blood pressure for a man of his age and medical history, and fever, all indications of dehydration. Dr. Schwartz claims that this prolonged period of dehydration resulted in a reduction of the actual volume of blood in Binion's circulatory system, and insufficient blood volume combined with the lowered blood pressure to cause clotting of blood vessels in the brain which, in turn, resulted in a thrombotic stroke. Normally, blood within the blood stream remains liquid and does not clot; however, when there is low blood volume and low blood pressure, clotting can occur. Dr. Schwartz claims that failure to provide I.V. fluids deviated from both the proper national standard of care and from the standard of care in central Florida as he knows it. Dr. Schwartz further claims that had I.V. fluids been administered to replace lost fluids, the medical probability is that the stroke would not have occurred. Additionally, Dr. Schwartz claims that releasing Binion on July 3, 2022, was a deviation from the proper standard of care since Binion's blood pressure on that date was at its lowest recorded reading. Finally, in his opinion, Dr. Schwartz claims that TIA's would have been additional indications of low blood volume and low blood pressure resulting in poor profusion of the brain and the potentiality of a thrombotic stroke. Dr. Schwartz noted that the symptomatology as reported by Binion's wife were TIA's consistent with Binion's eventual stroke damage.

Dr. Samuel Bernstein, the Executive Director of Jewish Employment and Vocational Service, a comprehensive vocational rehabilitation agency, is prepared to testify for Binion concerning his employability and the extent of his disability. Dr. Bernstein has conducted extensive testing and interviewing and determined that Binion is unemployable, with no future prospects of employability. Dr. Bernstein further claims that Binion is totally and permanently disabled.

According to his attorney, Dr. Smith is prepared to testify as to his opinions and the care he provided Binion. He claims that Binion was not dehydrated, did not require I.V. fluids and that there was no evidence of TIA's. In his opinion, Binion suffered an embolic stroke as a result of the dislodging of a piece of arteriosclerosis plaque from his left carotid artery. Additional witnesses for the doctors will include four treating nurses who claim that they did not notice any TIA's; one of Binion's business associates who saw him on July 6, 2023, and claims that he did not notice any indications of TIA's; and Dr. Pritam S. Sahni, also an employee of the Clinic, who claims he was a post-stroke occurrence witness.

Binion wants to sue any and all parties involved due to his stroke.