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Prior to on (b)(6) 2020, plaintiff was diagnosed with cancer.The treatment for plaintiff's cancer included chemotherapy.In order to administer the chemotherapy medications to plaintiff, her physicians had a port-a-catheter placed in her right upper chest.On or about on (b)(6) 2020, plaintiff underwent placement of the following angiodynamics' port inf ct titanium 8fr, inventory item: port inf ct titanium 8fr implant name: port inf ct titanium 8fr - log280066 model/cat no.: h787ct80stpdo, manufacturer: angiodynamics, for the purposes of plaintiff's chemotherapy.On or about on (b)(6) 2020, the device at issue was implanted by (b)(6), md at (b)(6) center in (b)(6) for the purposes indicated above.The defendants, directly or through their agents, apparent agents, servants, or employees, designed, manufactured, marketed, advertised, distributed, and sold the port inf ct titanium 8fr that was implanted in (b)(6).Upon information and belief, on (b)(6) 2020, plaintiff presented to (b)(6) center in (b)(6) where plaintiff was seen for an extremely high fever and evidence of sepsis.On or about april, plaintiff was also treated for a suspected infection at the port site with antibiotics.Upon information and belief, plaintiff's port-a-cath at issue was removed due to the above, at (b)(6) center.
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