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Prior to 2024, plaintiff was diagnosed with breast cancer.Plaintiff's cancer treatment included chemotherapy.In order to administer chemotherapy medications, plaintiff's physicians placed a port catheter in her chest.On or about (b)(4) 2024, plaintiff underwent placement of an angio dynamics "smart port," identified as follows: upn: h787ct66ltpd0; lot number: al624008; manufacturer: angio dynamics, inc.The smart port was placed at (b)(6) in (b)(6) for purposes of administering plaintiff's chemotherapy.On or about (b)(6) 2024, plaintiff presented to (b)(6) with discomfort extending from the left side of her neck to her ear and shoulder region, down to the axilla, as well as a sensation of pressure at the site where the port had been placed.Plaintiff was diagnosed with acute embolism and thrombosis of the left subclavian vein, left axillary vein, and left internal jugular vein.(b)(4) ,1319211-2026-00322).On or about (b)(6) 2024, plaintiff was diagnosed with deep vein thrombosis ("dvt") and continued treatment with eliquis, 5 mg.(b)(4),1319211-2026-00323).On or about (b)(6) 2024, plaintiff underwent removal of the smart port at (b)(6).
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