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Odom v. Fairbanks Memorial Hospital Lutheran Health Systems3/17/2000
e termination of plaintiff's staff privileges and membership at Fairbanks Memorial Hospital resulted in his exclusion from the practice of anesthesiology. Plaintiff's capability to continue his surgery center project has been severely hampered by his loss of financial capacity and reputation. If successful in preventing Plaintiff from completing his project, Defendants will have deprived many individual patients and referring physicians of access to alternative operating room services for a substantial period of time.
146. Paragraphs 1 through 46 and 65 through 145 are repeated and realleged as if set forth in full herein.
147. Defendants, as originators of the wrongful termination and withdrawal of privileges, and other defamatory conduct and statements set forth herein, knew that plaintiff would be compelled to disclose the contents of such conduct and statements to third parties in connection with applications for hospital medical staff privileges, malpractice insurance, membership in professional organizations, business loan applications, stock offerings, and related purposes.
148. Plaintiff in fact has been compelled to disclose the defamatory conduct and statements made about him to third parties in connection with discussions for employment, malpractice insurance, licensing, business loans, and related purposes, and will be compelled to make further disclosures of this type in the future.
149. The defamatory statements set forth herein were motivated by Defendants' malice, ill will, personal spite, or in the alternative by defendants' culpable recklessness or gross negligence.
150. By reason of the foregoing, Defendants have uttered and published false and defamatory statements about Plaintiff in writing and, upon information and belief, orally, with respect to Plaintiff's conduct, employment, career, and fitness to practice medicine, and have compelled Plaintiff to repeat Defendants' defamation to others in connection with his professional career, all damaging plaintiff.
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