By DONNA KENNY KIRWAN

PAWTUCKET — A formal complaint for damages and demand for a jury trial has been filed in state Superior Court in the case of the late Maria G. Carvalho, a 53-year-old dialysis patient who bled to death last September 20 while waiting for an ambulance to arrive.

The wrongful death complaint, filed on Feb. 26, was brought by Joao Carvalho, Maria’s husband, on behalf of all of the heirs. It brings suit against the City of Pawtucket through Ronald Wunschel in his capacity as treasurer for the city. Also named as defendants are former Pawtucket firefighters, Christopher Jeffrey and Sean Mooney, who were the dispatchers involved in the case, as well as Fire Chief Timothy McLaughlin, Assistant Chief Richard J. Renzi, and Battalion Chief Ronald Doire, in their capacities as city employees as well as in their individual capacities.
Although the amount of damages is not stated in the complaint, the family is seeking $4 million for wrongful death action, alleging negligence on the part of the defendants, and a survivor action for reimbursement of medical expenses, funeral and burial expenses, and pain and suffering, according to Carvalhos’ attorney, Stephen M. Rappoport.
On Jan. 7, the $4 million claim for damages was submitted to the City Council, where it was subsequently rejected. However, councilors on the city’s Claims Committee categorized this action as a formality, given the amount of testimony and evidence that will have to be gathered in relation to the case.
The complaint outlines the alleged circumstances leading to Carvalho’s death, beginning with her suffering a spontaneous bleed from a dialysis shunt located in her arm. It details the three 911 calls that were made by neighbor Yvette LeBlanc and Joao Carvalho to summon a rescue, and alleges that had the rescue been dispatched earlier, Carvalho’s life could have been saved.
The complaint alleges that “due to defendants’ gross, willful or wanton negligence a rescue did not arrive until after 18 minutes from the receipt of the first 911 call and as a direct and proximate result decedent Maria G. Carvalho bled to death.”
In the court documents for “Count I” of the wrongful death action, it is alleged that the City of Pawtucket allowed 911 calls, emergency medical dispatching and emergency medical services to be handled in a negligent manner, and
failed to properly develop policies and procedures for receiving, processing and handling 911 calls, and emergency medical dispatching and services provided by the Pawtucket Fire Department.
It is further alleged that the city failed to follow National Standards relative to emergency medical dispatching and also failed to follow or adhere to, if any, resuscitation measures, pursuant to Rhode Island’s pre-hospital care protocols.
As the dispatchers working that morning,  Sean Jeffrey and Christopher Mooney are accused of negligence in their failure to handle 911 calls “in a prudent, proper and professional manner,” failure to properly dispatch a rescue upon receipt of a 911 call necessitating such action, and failure to remain on the line to monitor the well being of Maria Carvalho until the emergency medical technicians (EMTs) arrived.
Further, Jeffrey and Mooney are cited for failure “to appreciate the seriousness and true nature” of Carvalho’s condition, thereby failing to provide medical instructions which could have included applying direct pressure to the wound until EMTs arrived.
It is also alleged that the two dispatchers, “permitted the decedent to languish without proper emergency medical services,” thereby allowing her medical condition to deteriorate. It further states that Jeffrey and Mooney failed “to exercise reasonable care and caution in the conduct, advice and services” rendered to Carvalho.
The complaint individually cites Fire Chief Timothy McLaughlin, Assistant Chief Richard J. Renzi, and Battalion Chief Ronald Doire for “failure to properly train members of his fire department in receiving, processing and/or handling 911 calls, and/or emergency medical dispatching and medical services.”
It also faults all three administrators for “failure to ensure that experienced and/or fully trained members of his fire department were placed in charge” of receiving 911 calls and dispatching emergency medical services, and also “failure to supervise” the firefighters while handling such calls and dispensing services.
The complaint further alleges a failure on the part of the three supervisors in developing proper policies and procedures, and for failing to ensure that such policies were in place, and asserts that the state’s pre-hospital care protocols were not followed.
In “Count II” under the survivor action, the court document realleges the charges of negligence on the part of the defendants, and asserts that as a result of this negligence, Maria Carvalho “sustained severe, grievous and fatal injuries and suffered great pain of body and mind” and incurred bills for medical care and funeral and burial expenses that diminished her estate. It further reasoned that Carvalho “suffered meotional distress, up until the time of her death.”
In “Count III”, the negligent infliction of emotional distress, the court document again outlines the alleged negligence on the part of the defendants, and maintained that as a further consequence, Joao Carvalho “helplessly and desperately witnessed his wife’s demise.” As a result, the complaint maintains that Joao Carvalho “has sustained grevious injuries, suffered great pain of body and mind and incurred bills for medical care and treatment of said injuries and will continue to do so into the future.”