Case 2023CV000345 Document 25 Filed 05-15-2023 Page 1 of 19

FILED
05-15-2023
Clerk of Circuit Court
STATE OF WISCONSIN - CIRCUIT COURT- OUTAGAMIE COUNTY
Outagamie County
2023CV000345
SCOTT SCHARA,
Plaintiff,
and Case No. 2023-CV-345
Case Codes: 30103, 30104,
30105, 30701
WISCONSIN DEPARTMENT OF HEALTH SERVICES,

Involuntary Plaintiff,
vs.

ASCENSION HEALTH, GAVIN SHOKAR, M.D.,

DAVID BECK, M.D., DANIEL LEONARD, M.D.,
KARL BAUM, M.D., RAMANA MARADA, M.D.,
HOLLEE MCINNIS, R.N., ALISON BARKHOLTZ, R.N.,
INJURED PATIENTS AND FAMILIES COMPENSATION FUND,
and JOHN DOES 1, 2, 3 and 4,

Defendants.

ANSWER OF DEFENDANT
INJURED PATIENTS AND FAMILIES COMPENSATION FUND TO COMPLAINT

NOW COMES the above-named defendant, Injured Patients and Families

Compensation Fund, by its attorneys Nash, Spindler, Grimstad & McCracken, LLP, and

by way of an answer to the plaintiffs’ complaint respectfully admits, denies and alleges as

follows:

GENERAL DEFENSES TO “INTRODUCTION”

(General Paragraph and Paragraphs 1 to 4)

Answering the preliminary paragraph of “Introduction” section of the plaintiff’s

complaint, answering defendant is without information sufficient to form a belief and,

therefore, denies the allegations contained in said paragraph.

1. Answering paragraph 1 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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2. Answering paragraph 2 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

3. Answering paragraph 3 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

4. Answering paragraph 4 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

GENERAL DEFENSES TO “THE PARTIES, VENUE AND JURISDICTION”

ALLEGATIONS
(Paragraphs 5 to 18)

5. Answering paragraph 5 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

6. Answering paragraph 6 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph. Further answering, affirmatively assert that Ascension Health is not a

Fund participant.

7. Answering paragraph 7 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

8. Answering paragraph 8 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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9. Answering paragraph 9 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

10. Answering paragraph 10 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

11. Answering paragraph 11 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

12. Answering paragraph 12 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph. Further answering, affirmatively assert that Hollee McInnis, RN is not a

Fund participant.

13. Answering paragraph 13 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph. Further answering, affirmatively assert that Alison Barkholz, RN is not a

Fund participant.

14. Answering paragraph 14 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

15. Answering paragraph 15 of the Complaint, deny as phrased and allege that

the Injured Patients and Families Compensation Fund is a risk-sharing pool whose rights

and obligations are set forth in Wis. Stats. Ch. 655 and related provisions, and its liability

is subject to certain terms, conditions, qualifications, restrictions, exclusions and

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limitations of liability, as outlined in Chapter 655, Wis. Stats. and its companion statutes,

and to the extent the allegations contained in paragraph 15 of plaintiffs’ complaint are

inconsistent, the same are denied. Further answering said paragraph, denies that

Ascension Health, Hollee McInnis, RN and Allson Barkholz, RN are Fund participants.

16. Answering paragraph 16 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

17. Answering paragraph 17 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

18. Answering paragraph 18 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

GENERAL DEFENSES TO “FACTS” ALLEGATIONS

(Paragraphs 19 to 77)

19. Answering paragraph 19 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

20. Answering paragraph 20 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

21. Answering paragraph 21 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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22. Answering paragraph 22 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

23. Answering paragraph 23 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

24. Answering paragraph 24 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

25. Answering paragraph 25 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

26. Answering paragraph 26 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

27. Answering paragraph 27 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

28. Answering paragraph 28 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

29. Answering paragraph 29 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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30. Answering paragraph 30 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

31. Answering paragraph 31 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

32. Answering paragraph 32 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

33. Answering paragraph 33 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

34. Answering paragraph 34 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

35. Answering paragraph 35 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

36. Answering paragraph 36 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

37. Answering paragraph 37 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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38. Answering paragraph 38 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

39. Answering paragraph 39 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

40. Answering paragraph 40 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

41. Answering paragraph 41 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

42. Answering paragraph 42 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

43. Answering paragraph 43 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

44. Answering paragraph 44 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

45. Answering paragraph 45 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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46. Answering paragraph 46 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

47. Answering paragraph 47 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

48. Answering paragraph 48 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

49. Answering paragraph 49 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

50. Answering paragraph 50 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

51. Answering paragraph 51 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

52. Answering paragraph 52 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

53. Answering paragraph 53 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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54. Answering paragraph 54 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

55. Answering paragraph 55 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

56. Answering paragraph 56 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

57. Answering paragraph 57 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

58. Answering paragraph 58 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

59. Answering paragraph 59 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

60. Answering paragraph 60 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

61. Answering paragraph 61 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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62. Answering paragraph 62 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

63. Answering paragraph 63 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

64. Answering paragraph 64 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

65. Answering paragraph 65 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

66. Answering paragraph 66 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

67. Answering paragraph 67 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

68. Answering paragraph 68 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

69. Answering paragraph 69 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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70. Answering paragraph 70 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

71. Answering paragraph 71 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

72. Answering paragraph 72 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

73. Answering paragraph 73 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

74. Answering paragraph 74 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

75. Answering paragraph 75 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

76. Answering paragraph 76 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

77. Answering paragraph 77 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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GENERAL DEFENSES TO “CLAIM I: WRONGFUL DEATH” ALLEGATIONS

(Paragraphs 78 to 82)

78. Answering paragraph 78 of the Complaint, answering defendant realleges

and incorporates, as if fully set forth herein, all paragraphs of the above answer.

79. Answering paragraph 79, answering defendant is without information

sufficient to form a belief and, therefore, denies the allegations contained in said

paragraph and alleges that said paragraph fails to state a claim as a matter of law.

80. Answering paragraph 80 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

81. Answering paragraph 81 of the Complaint, denies and alleges that said

paragraph fails to state a claim as a matter of law

82. Answering paragraph 82 of the Complaint and all of its subparts, denies and

alleges that said paragraph/subparts fail to state a claim as a matter of law.

GENERAL DEFENSES TO “CLAIM II: MEDICAL NEGLIGENCE” ALLEGATIONS

(Paragraphs 83 to 91)

83. Answering paragraph 83 of the Complaint, answering defendant realleges

and incorporates, as if fully set forth herein, all paragraphs of the above answer.

84. Answering paragraph 84, answering defendant is without information

sufficient to form a belief and, therefore, denies the allegations contained in said

paragraph.

85. Answering paragraph 85 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

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86. Answering paragraph 86 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

87. Answering paragraph 87 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

88. Answering paragraph 88 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

89. Answering paragraph 89 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

90. Answering paragraph 90 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

91. Answering paragraph 91 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

GENERAL DEFENSES TO “CLAIM III: MEDICAL BATTERY” ALLEGATIONS

(Paragraphs 92 to 99)

92. Answering paragraph 92 of the Complaint, answering defendant realleges

and incorporates, as if fully set forth herein, all paragraphs of the above answer.

93. Answering paragraph 93, answering defendant denies as phrased and

alleges that this is an incomplete statement of law or standard.

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94. Answering paragraph 94, allege that Wis. Stat. § 448.30 contains specific

language which, together with caselaw, speaks for itself and therefore denies the

paragraph as phrased.

95. Answering paragraph 95, allege that Wis. Stat. § 448.30 contains specific

language which, together with caselaw, speaks for itself and therefore denies the

paragraph as phrased.

96. Answering paragraph 96 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

97. Answering paragraph 97 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

98. Answering paragraph 98 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

99. Answering paragraph 99 of the Complaint, denies.

GENERAL DEFENSES TO “CLAIM IV: NEGLIGENT INFLICTION OF EMOTIONAL

DISTRESS” ALLEGATIONS
(Paragraphs 100 to 106)

100. Answering paragraph 100 of the Complaint, answering defendant realleges

and incorporates, as if fully set forth herein, all paragraphs of the above answer.

101. Answering paragraph 101, answering defendant denies as phrased and

alleges that this is an incomplete statement of law or standard.

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102. Answering paragraph 102, answering defendant is without information

sufficient to form a belief and, therefore, denies the allegations contained in said

paragraph.

103. Answering paragraph 103 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

104. Answering paragraph 104 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations and alleges

that said paragraph fails to state a claim as a matter of law.

105. Answering paragraph 105 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations and alleges

that said paragraph fails to state a claim as a matter of law.

106. Answering paragraph 106 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations and alleges

that said paragraph fails to state a claim as a matter of law.

GENERAL DEFENSES TO “CLAIM V: DECLARATORY JUDGMENT”

ALLEGATIONS
(Paragraphs 107 to 113)

107. Answering paragraph 107 of the Complaint, answering defendant realleges

and incorporates, as if fully set forth herein, all paragraphs of the above answer.

108. Answering paragraph 108, answering defendant is without information

sufficient to form a belief and, therefore, denies the allegations contained in said

paragraph.

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109. Answering paragraph 109 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

110. Answering paragraph 110 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

111. Answering paragraph 111 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

112. Answering paragraph 112 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

113. Answering paragraph 113 of the Complaint, answering defendant is without

information sufficient to form a belief and, therefore, denies the allegations contained in

said paragraph.

AFFIRMATIVE DEFENSES TO ALL ALLEGATIONS

Pursuant to the Wisconsin Statutes which obligate the defendants to preserve

affirmative defenses, this answering defendant alleges, on information and belief, as

follows:

114. The plaintiffs’ claims may be subject to the provisions and protections of the

The Public Readiness and Emergency Preparedness (PREP) Act, Wis. Stat. § 895.4801

and/or any similar state or federal law that may have been applicable during the care

alleged in the Complaint.

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115. Any and all injuries or damages sustained by Plaintiffs may be a direct and

proximate result of the negligence and/or decisions made by Plaintiffs.

116. Plaintiff’s condition may have been the result of natural disease progression

beyond the control of, and unrelated to the acts, omissions or conduct of Defendants.

117. Plaintiff’s condition may have been the result of pre-existing conditions

beyond the control of, and unrelated to the acts, omissions or conduct of Defendants.

118. Any and all claims, injuries or damages sustained by the Plaintiffs as alleged

in this action are subject to the protections of, and are strictly limited pursuant to, Chapter

655 and Wis. Stat. §893.55.

119. The liability of answering defendant, if any, is limited, regulated, modified

and controlled by Wisconsin Statute Chapter 655 and other applicable Wisconsin

Statutes.

120. Punitive damages are not available in an action against a health care

provider pursuant to Chapter 655.

121. There may exist a pre-existing, superseding and/or intervening cause of

plaintiffs’ damages or injuries, if any.

122. The Wisconsin Supreme Court has determined non-economic damage

caps to be constitutional under Mayo.

123. The plaintiffs’ claims may be barred by the applicable statute of limitations.

124. The complaint fails to state a claim upon which relief may be granted as to

some or all of the claims, including but not limited to Claim I, Claim IV and Claim V.

125. Subrogated/involuntary plaintiffs are governed by Wis. Stats. §803.03 and

are liable for costs as set forth in Wis. Stats. §814.04 if these answering defendants

prevail regardless of whether the providers participate in trial.

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126. The claims in this case are subject to the exceptions to informed consent

set forth in Wis. Stat. §448.30.

127. The plaintiffs cannot recover medical expenses that have been paid for by

individuals, parties or entities that are not a party to this suit.

128. That Hollee McInnis, RN is not a Fund participant and has no Fund

coverage as pled.

129. That Alison Barkholz, RN is not Fund participant and has no Fund coverage

as pled.

130. That Ascension Health is not a Fund participant and has no Fund coverage

as pled.

131. The summons is defective and therefore the Court may lack personal

jurisdiction at this time.

132. This defendant adopts and incorporates by reference any and all affirmative

defenses asserted by other defendants in this lawsuit to the extent such affirmative

defenses are not raised herein and are not inconsistent with the defenses raised by this

defendant and reserves the right to assert any additional affirmative defenses which may

become available during the pendency of this action. Defendant also joins any motion to

dismiss filed by, or to be filed by, other defendants to this lawsuit.

WHEREFORE answering defendant demands judgment dismissing the plaintiffs’

complaint as to it with costs and disbursements as provided by law.

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Dated this 15th day of May, 2023.

NASH, SPINDLER, GRIMSTAD & MCCRACKEN, LLP

Electronically signed by Jeremy T. Gill

___________________________________
By: Jeremy T. Gill
State Bar No. 1034152
Attorneys for defendant Injured Patients and
Families Compensation Fund

Mailing Address:
PO Box 130
Manitowoc, WI 54221-0130
920-684-3321
Fax: 920-684-0544
[email protected]

DEFENDANT DEMANDS A JURY OF TWELVE (12) PERSONS

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