None of the maneuvers listed below will actually deliver the child, as their goal is simply to dis-impact the impacted shoulder(s).

... Number 73-3 Page 154 of 200 reported similar results among fetuses with estimated birth weights of 4,000 g or more; in that study, an addi- tional 76 cesarean deliveries would have prevented only five cases of shoulder dystocia, none ...

NBPP occurred in 8% (14) of cases of shoulder dystocia and none of controls (►Table 1).

None of the maneuvers listed below will actually deliver the child, as their goal is simply to dis-impact the impacted shoulder(s).

... Number 74-4 Page 154 of 200 reported similar results among fetuses with estimated birth weights of 4,000 g or more; in that study, an addi- tional 76 cesarean deliveries would have prevented only five cases of shoulder dystocia, none ...

NBPP occurred in 8% (14) of cases of shoulder dystocia and none of controls (►Table 1).

The Plaintiffs, Kenyatta and Jason Beard, as the Parents and Natural Guardians of J.B., a Minor, brings this Action against the Defendants, Palmetto Health and Shawnequa Brown, and would respectfully show unto this Honorable Court:

The Plaintiffs, Kenyatta and Jason Beard, are the Parents and Natural Guardians of J.B., a Minor (“Minor Plaintiff”), and are citizens and residents of the State of Pennsylvania.

Beard was counseled as to the risk vs. benefit of vaginal vs. cesarean section given poorly controlled diabetes and a large baby.

Beard; d. Failing to acknowledge that with poorly controlled diabetes, a large for gestational age baby, and excessive maternal weight gain, Ms.

WHEREFORE, the Plaintiffs pray judgment against the Defendants, both jointly and severally for ACTUAL, CONSEQUENTIAL, and PUNITIVE DAMAGES, together with costs of this action, and for such other and further relief as this Court may deem fit, just and proper.

In theCourt of Appeals

_ Court of Common Pleas The Honorable D. Craig Brown, Circuit Court Judge Civil Case No. 20l6—CP-40-02459 1544 Appellate Case No. 2016-00 Sean Lyons, Appellant,

Sean Lyons 8310 Two Notch Road Columbia SC 29223 Re: Sean Lyons V Palmetto Richland Springs Appellate Case No. 2016-001544 Dear Mr. Lyons: Upon reviewing your record on appeal, the following deficiency has been noted under the South Carolina Appellate Court Rules (SCACR), and any deficiency must be corrected within ten (10) days of the date of this letter or your appeal will be dismissed: 0 Pursuant to Rule 267(a), SCACR, the name, address, and phone number of all counsel in the case should be included on the record on appeal.

Information for counsel for respondent, Shelton Haile and Michelle Kelley, are missing from the record on appeal.

In the Court ofAppeals ‘

Court of Common Pleas

SC CCU” Of The Honorable D. Craig Brown, Circuit Court Judge Civil Case No. 2016-CP-40-02459 Appellate Case No. 2016-001544 Sean Lyons, - Appellant,

I, Sean Lyons, certify that I have served the FINAL BRIEF OF APPELLANT, pursuant to Rule 262(b), SCACR, on Palmetto Richland Springs by depositing a copy of each document in "the United States Mail, postage prepaid, on December 31 2016 addressed to their attorney of record, Shelton W. Haile, 1900 Bamwell Street, Columbia, SC 29201.

On March 3, 2016 the Application of Involuntary Emergency Hospitalization for Mental Illness came before the Associate Probate Judge Jacqueline Belton.

You have to remember that when you’re in a mental hospital, it’s not like jail, you don’t get access to a law library, writing utensils, mail system, or court.

This is due to the fact that the Respondent did not provide any access-to any legal documents, experts, and is attempting to deny Lyons of his right to appeal through constructive tactics.

Generally, “[T]he courts will not inquire into the wisdom of the legislative decision in establishing the period of legal bar, unless the time allowed is manifestly so insufficient that the statute becomes a denial ofjustice."