In a recent court filing, Theresa Coughlin's family has lodged a comprehensive complaint against San Brunoidence OpCo LLC, doing business as San Bruno Skilled Nursing, and several associated entities. The complaint was filed by Kathleen Coughlin, Timothy Coughlin, and Christopher Coughlin in the Superior Court of California, County of San Francisco on May 31, 2024. The defendants named in the case include Providence Healthcare Group LLC, Providence Administrative Consulting Services Inc., PACS Group Inc., PACS Holdings LLC, Providence Group North LLC, Providence Group Inc., Hudson River OpCo LLC, Bay Bridge Capital Partners LLC, Jason Murray, Mark Hancock, Reggie Mano Viray, Kirsten Cruz, Git Mei, John Santos and fifty unnamed individuals.
The plaintiffs allege that Theresa Coughlin suffered severe neglect and abuse while residing at San Bruno Skilled Nursing from June 2 to June 20 in 2022. According to the complaint, Mrs. Coughlin experienced "untold pain, suffering, injury and death" due to the reckless neglect by all named defendants. Kathleen Coughlin asserts that her mother’s health rapidly deteriorated during her stay at the facility due to inadequate care and gross negligence.
The allegations are extensive and grave. They include claims of elder neglect under Welfare and Institutions Code section 15600 et seq., negligence in providing necessary medical care and supervision, fraud through constructive means by misleading Mrs. Coughlin about the quality of care she would receive at the facility, negligent infliction of emotional distress upon her children who witnessed their mother's decline firsthand, violation of patients' rights under state law provisions including Health & Safety Code section 1250(c), and wrongful death.
The plaintiffs assert that San Bruno Skilled Nursing was deliberately understaffed and underfunded as part of a profit-maximizing strategy orchestrated by the corporate defendants. This led to insufficient patient care which directly resulted in Mrs. Coughlin’s rapid health decline and eventual death. They allege that despite numerous red flags indicating serious problems within the facility—including multiple civil lawsuits and state regulatory actions—the corporate defendants continued their practice of accepting high-acuity residents without increasing staffing levels or improving care standards.
Specific incidents cited in the complaint include Mrs. Coughlin experiencing vomiting spells without proper medical assessment or intervention; being left incontinent without appropriate toileting assistance; receiving powerful pain medication like oxycodone without documented reasons; having her advanced directives mismanaged; and showing signs of severe dehydration and malnutrition which were ignored by nursing staff.
The plaintiffs seek various forms of relief from the court including general damages for pain and suffering endured by Mrs. Coughlin before her death; special damages for medical expenses incurred; punitive damages against all defendants for their egregious conduct; attorneys’ fees pursuant to relevant statutory provisions; injunctive relief to prevent future violations at defendants’ facilities; civil fines for each violation of patient rights under Health & Safety Code Section 1430(b); as well as costs associated with bringing this lawsuit.
Representing the plaintiffs are attorneys Edward P. Dudensing (Bar No. 182221), Jay P. Renneisen (Bar No. 173531), Thomas A. Reyda (Bar No. 312632) from Dudensing Law based in Sacramento CA.
The Case ID is CGC-24-615081.