Plaintiff also fell several times while at Defendant’s facility, which falls could, and should have, been prevented had the staff provided proper care. Defendant’s staff knew that Plaintiff was a fall risk, and they also knew she had poor balance and poor safety awareness, according to their own admission assessments. Notwithstanding the same, staff failed to address Plaintiff’s fall risk in the initial care plan, or the 5/16/06 care plan, or the 5/24/06 care plan. Defendant’s staff finally addressed fall risk in a 5/31/06 care plan update. At that time, staff documented that Plaintiff continually attempted to get out of bed and out of her wheelchair without the assistance of staff. This is documented throughout the nurse’s notes as well. As a result, alarms were applied to Plaintiff’s bed and her wheelchair. Staff, however, repeatedly failed to respond, or failed to timely respond, to Plaintiff’s alarms when they sounded. The nurse’s notes document, for example, that the family complained to staff that Plaintiff’s alarm would go off, but no staff ever came to assist her. The nurse’s notes also document Plaintiff’s roommate in the hallway calling for staff when Plaintiff’s alarm went off, again because staff failed to provide assistance when the alarms sounded. In addition to failing to respond to Plaintiff’s bed and chair alarms, the staff also repeatedly failed to assist her to the bathroom as needed. Plaintiff was unable to toilet herself and required the assistance of staff. She did not get that assistance. Further, staff failed to monitor Plaintiff sufficiently, given her known risk for falling and suffering injury.
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