Drafting the Killer Complaint in Nursing Home Abuse Cases
What makes a nursing home abuse complaint not just good, but killer? The strength of a legal complaint can set the tone for the entire case, especially in situations as serious as nursing home abuse. Crafting a compelling, thorough complaint is key to holding negligent facilities accountable. In this week’s episode, nursing home abuse lawyer Rob Schenk welcomes guest Atty. Matthew Mooney to discuss the essential elements of a powerful legal complaint in nursing home abuse cases, providing insights on how to effectively initiate legal action that commands attention and drives results.
ATTY. MOONEY:
And most of the nursing home specific terminology that we hear in particular is not something that most people have an understanding of. And so you got to take that step back and remember that a lot of your audience, they don’t have that background of knowledge that we have from having usually will lean towards getting the full truth out there.
We want people to have a complete understanding.
SCHENK:
Hi everybody. Welcome back to the Nursing Home Abuse podcast. My name is Rob. I will be your host for this episode. We are gonna be talking about drafting visually compelling, emotionally compelling. Complaints in nursing home cases. And I, like when we, when I, when we go into the interview when I’m talking to Matt, I’m gonna seem like a crazy person.
But you have to check out the show notes. You have to check out this man’s in this man’s work this law firm’s work. ’cause I’ve also had Michael Hill in the show as well for Michael Hill’s trial law. But these are. Put together complaints at least way beyond what I’m doing. And so I became a fan and that’s why I wanted to have them on.
So anyway, I’m doing a lot of fanboying on this guy who actually incidentally looks a lot like actor Nicholas Holt. I. Who is I guess he’s going to be the new Lex Luther, although I look more like Lex Luther than he does. He actually looks like Clark Kent. Anyway stick around for that.
SCHENK:
All right. That was an extraordinarily painful amount of talking for the nursing home regulation question of the week, but now it’s time to get into the actual substance of the episode, what everybody has tuned in for. But let me tell you a little bit about our guest, Matt Mooney. I. Matt Mooney is a trial lawyer specializing in nursing home neglect and abuse.
His passion for advocacy began during his five years as a nurse assistant caring for victims of neglect. Now with Michael Hill trial law, Matt has secured multiple seven figure settlements and successfully tried high stakes cases, including a landmark $26 million verdict against a nursing home. He is dedicated to seeking justice.
Visit Protect Seniors Online for resources and tips on safeguarding the rights and well-being of seniors.
For injured residents and their family, and we are so happy to have ’em on the show today. Matt, welcome to the show.
ATTY. MOONEY:
Thanks, Rob. Appreciate you having me. Okay, so full disclosure I’m a LinkedIn nut. I’m always on LinkedIn. For some reason I think it’s because I disallowed myself from going on TikTok or Instagram or Facebook and just by default I’m on LinkedIn all the time.
And so lo and behold, I came across one of your posts which detailed. A case that you had? I believe it was a pressure injury case, and it was probably the most beautiful complaint I’ve ever seen. So I couldn’t believe it. It was like, we’ll, and we’ll talk about it, but I thought, there’s a guy out of, I think his, I think he’s out of Ohio, but his name is Jonathan Steele, and he makes brilliant complaints.
Like I go online, he doesn’t even know I’m going on like pacer and stuff, and finding his work and downloading it. I thought that he was the man, you’re the man. Not that he’s not good. You. It was amazing. So I, first thing I was like, I’m talking to this guy, I’m getting him on the podcast. So let me just start with this.
There are, there is a, some school of thought, which is we wanna file a complaint, we wanna draft the lawsuit. And just provide enough information to meet the pleading requirements. This person hurt me. I’m hurt this much. End of story. On the other end of the spectrum, you like, there’s me, which is, I’m giving as much data as I possibly can, but almost like a robot.
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Like I’m not telling a story in a linear sense, just boom. Fact, because I wanna try to get admissions. You’re neither one of those. You are almost telling a story. Tell me about, and I’ve been talking for eight minutes and I’m glad that you came on the show, so I can talk to you for eight minutes but it’s just because I’m so excited about it Anyway.
What is your general philosophy for the complaint?
Tell me about your philosophy of the complaint and how you approach it and talk about your complaints.
ATTY. MOONEY:
I appreciate the praise, Rob. And I gotta say, I’m with you. I came from the school of thought that a complaint, it’s a very limited tool. It’s just what you do to open the gates to the courthouse and get your client’s case initiated.
But then, Michael and I, we’ve been we’ve been taking a step back and thinking to ourselves, that’s one use for this tool, but really what is a complaint? It’s that initial opportunity that we have as trial attorneys to tell our client’s story, and I think as trial lawyers, that’s a lot of what we focus our attention on is becoming better storytellers for our client’s sake.
And the complaints our first chance, our first opportunity to get that story straight, get that story out there, make sure that there’s an understanding on the part of the judge and the judicial staff and the defendants, that we control the narrative here, we’re in the right and really the facts, they paint a very clear picture of neglect here.
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And so it’s something that we acknowledge the. The terminally online culture that we have, the very accessible internet culture that we have, all these courts are just about all of ’em. Their docket’s, publicly accessible, and that complaint is out there for all the world to view. You might Google this particular institution and see that, hey, there’s this complaint, very detailed complaint about, Matt and Michael’s clients who were pretty badly injured there.
And we think that’s a big part of what we as attorneys are looking for, is to get people. Within our society to acknowledge that there is a problem in these nursing homes. Make sure that their loved ones don’t run into the same problems that, that, our clients unfortunately did.
SCHENK:
And I guess that’s, I guess that’s the, that would be the striking difference then is that your audience is not necessarily the judge.
Your audience is not necessarily the opposing counsel or the facility your audience, the people that you’re writing that complaint to is the public at large. Is that I guess that’s what I’m hearing.
ATTY. MOONEY:
That’s absolutely right. Absolutely right. The public loves courtroom drama. My, my wife is a huge true crime fan.
You talk to folks some of their favorite shows or suits or law and order, they love getting an inside look at what happens in the courtrooms in our country. And so people are curious and they wanna look at what’s going on in their neighborhood, and we want them, when they look at what happens to our clients, we want them to have the complete story and a complete understanding of what happened.
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SCHENK:
So talking about the complete story, typically in a traditional lawsuit, a traditional complaint, ’cause it’s state dependent. You have introduction paragraph, this person is seeking this for this reason, and then a bunch of numbered paragraphs that just state things typically. At least in my experience, not a lot of graphic, not a lot of pictorial representations or pictures or things like that.
And then depending on what stage you’re in, there’s an affidavit of merit attached by some expert. If it’s a, if it’s a illegal or not illegal, but if it’s a professional malpractice case tell me about. What you’re adding on top of that and we’ll get to the narrative and I understand the audience is the public at large, and so you make the language simple to and easy to understand, but what else are you adding to that? How are you making it visually striking?
ATTY. MOONEY:
That’s a good point. We’re visual learners. Most of us, even those of us that like to get into the detail and really into the mustardy. Parts of what we do, I think we all can acknowledge that a picture speaks volumes more than a bunch of very bland and ordinary text on a page, right?
And so we include photographs of our client’s injuries. For instance, you mentioned the bed sore case. I think a lot of lay people, they don’t understand that a bedsore in their mind, that conjures up an image of someone laying in bed and maybe they get an ache in their body from it. Maybe we’ve all been there, laid the wrong way in bed and got a stiff neck.
Oh, bedsores. They’re pretty horrific and they’re terrible injuries. A stage four bedsore that can lead to exposed muscle and bone, and we can write those words on the page, but until the clients can see, or I’m sorry, until the people can see what a bedsore is, and specifically the bedsore that happened to our client, they’re not really gonna have a true grasp of how horrific an injury that is.
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So we’ll put images of the injuries in there. We’ve had fall cases where there’s been a broken hip. Again, you look at someone with a broken hip and maybe if you’re a medical professional, you can see that there’s a non-displaced fracture or a displaced fracture, but those words don’t mean much to someone who doesn’t have a medical education.
And so you put that x-ray image up, showing those bones in that patient’s leg, you know where they’re displaced in. They’re clearly jagged bones and places that even you and I can tell they don’t belong. People are gonna understand the pain that our client’s been through because of that. Internal bleeding, subdural, hematomas, we have a lot of fall cases where someone suffered a head injury and a subdural bleed.
Most people aren’t gonna understand what that means until you show them that picture, that bleed in their head, pushing against their brain, that CT image. And we think that’s good, not just to educate the public, but it helps to bring your judges up to speed too. They’re your audience as well as you said.
And they might not have that medical background or medical knowledge to know these cases and these injuries like we do, who we spend our whole lives in it. And it really helps to bring them up to speed as well.
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SCHENK:
I think that’s that what’s interesting on top of that, I. Is that we’re not talking about exhibits, like your complaints.
The images are w are in the complaint itself. It’s not like such and such a person got a stage four bedsore, stage four bet. Soar is et cetera, C exhibit A. Like you’re literally putting the image in the text of the lawsuit.
ATTY. MOONEY:
Exactly right. Exactly right. Because you get that textual description and then that image is right there where anyone who’s just read it can see, instead of referencing exhibits down at the end of the document.
They get that image associated with the description right out of the gate.
SCHENK:
How are you making these decisions? What kind of questions do you ask yourself when it comes to, okay do I what deserves visual representation versus not? And then am I going too far with this picture versus this picture?
ATTY. MOONEY:
That’s a great question and a lot of it is judgment based and I think that having an understanding that most of the medical terminology that we hear and most of the nursing home specific terminology that we hear in particular is not something that most people have an understanding of. And so you gotta take that step back and remember that a lot of your audience, they don’t have that background of knowledge that we have from having seen so many of these cases.
Find out who investigates a nursing home abuse case and what the process involves on Who Investigates a Nursing Home Abuse Case?.
So that’s something that we give a lot of consideration to think about it with fresh eyes. I didn’t know from experience what this term meant or what these injuries are. What would I want to see to understand it better? And so that’s a big part of what we think about when we put those that, that graphic imagery into the complaint.
And you’re right, some of it is a weight of, is this too much? Are we going over the top here? Are we being, disrespectful to our audience by exposing too much? And so we do make some decisions based on our judgment there. Do we want the most horrific pictures out there? Or do we have some images that just show enough to get the idea across of what happened?
Usually we’ll lean towards getting the full truth out there. We want people to have a complete understanding.
What is the minimum info (i.e. affidavits, etc) needed in order file in your state?
SCHENK:
So tell me then about and, we’ll, if you don’t mind, I think you discussed, we would look at one, but before we pull one up and start talking about it. Like, how long are you spending?
How long are you spending on drafting one of your complaints?
ATTY. MOONEY:
That’s a great question because it does vary. Some cases it’s very intuitive and it’s very simple, and you don’t have a very complex set of facts and you can get that information on the page pretty quickly. And then others, you’ve gotta engage in a little bit of a strategic analysis, right?
How much of that information do we want in our opponent’s hands right out of the gate? How much are we gonna hold back for cross examination? It does vary. But I think, our complaints, we’ve put a lot of effort into ’em, and a lot of that comes from our pre-suit work to understand the case completely.
And as we’re building the case from the ground up, from the initiation phase, we start to get our idea of what we’re gonna put into the complaint. And even what we’re gonna put into our opening and closing statements at trial together. And that bringss in a lot of ways what we want into that complaint.
What we want to hit the record first, how we capture that narrative right out of the gate.
Read about the potential damages recoverable in a nursing home abuse lawsuit at What Kind of Damages Can I Recover from a Nursing Home Abuse Case?.
SCHENK:
Putting all that thinking into the complaint, and again, I understand that you’ve put a lot of work into it already, if you’ve already sent a demand, if you send demands. So you’ve already done a lot of work. But the, I guess the value of putting that much time and effort into the complaint is valuable in and of itself, however.
Are you doing anything else with that complaint? Is this what you show a mediator or tell me about the, does that document get seen anywhere else or used anywhere else specifically for you guys?
ATTY. MOONEY:
Absolutely. A lot of what, a lot of what we’re working towards with preparing our complaint is also part of what we’re striving to accomplish in settlement negotiations, if we wanna expect case to push towards mediation and resolution.
We also are trying to preserve those arguments for those cases that we want to go to trial for potential pre-judgment interest and that fake claims after the verdict, right? We want there to be a, we want the judge that’s ruling on that to have a complete understanding of how much information these defendants had in hand and still did not engage in meaningful settlement negotiation.
Right? And so those documents they’re not something that we just fire off under the docket and then tuck away. We bring those back up, we present ’em to the mediator, we’ll attach them to our settlement demands. We’ll produce them to our experts. Of course. There’s a lot of uses for the complaint.
It’s not a stale document that we just fire off and forget.
Listen to a detailed discussion on the Stages of a Nursing Home Abuse Lawsuit.
What exhibits do you include, if any?
SCHENK:
I know if you’re listening to this, if you’re an attorney or if you’re in if, and especially if you’re in the plaintiff’s bar, like it sounds like it’s the d plus student talking to the A plus student, but I’m like, I’m serious.
This is next. These are L for me. I don’t know, I’ve been doing this for a little bit, but like these are next level and that’s why I wanted to have him on. So we’re actually gonna have Matt pull this up. And if you’re listening to this, like driving to work or whatever, we’re gonna do the best that we can to talk about what we’re looking at.
But it might be better if you see. So go to YouTube or go to our website and watch this podcast. So Matt, let’s go ahead and pull, let’s pull up the, let’s pull up that complaint.
ATTY. MOONEY:
There are some pretty graphic images I’m about to show you, which are what we incorporate into our complaint.
SCHENK:
Alright?
ATTY. MOONEY:
And this particular. This particular complaint, this is a case that came to us brief rundown of the facts. This was a patient who was recovering from a knee replacement. The aide had placed her in a wheelchair to wheel her into the bathroom to help her use the restroom, and the aid wheeled that wheelchair right into a metal toilet paper rod holder, and it broke open her her recently repaired knee surgical site causing pretty.
Infection. Yeah. And so what we’re looking at here, and I’ll be candid with you, Rob. Until I saw these photos thankfully the patient survived. She was very fortunate, had to have a revised knee replacement, a lot longer rehab course. And, I was listening to those facts and I was thinking to myself, that’s gonna be a tough case on damages.
An elderly person getting the knee replacement’s gonna have a long course anyway. As soon as she sent me these images, I knew, this is the story right here. This is really contextualizing just how severe her injuries were. So we have here some, we incorporate right into the complaint after we discuss a little bit about what happened.
Explore how attorneys decide to take on nursing home cases in the podcast episode, How Does an Attorney Make the Decision to Take a Nursing Home Case?.
We will incorporate right below those paragraphs right in there in the complaint, the images that the client had sent to me, showing that, that opened incision line and that beginning of the infection right there in the complaint. And we’ll put a caption just to make clear about when this happened, where it happened, and what it’s showing, the date that the images were taken, right?
So if it’s very clear. Then as we talk and as we get into the next stage of the complaint here, we just walk through a little bit again of the factual background leading to the point where the client has, at this point a very svi, very severe, very significant infection. The complete knee revision of that knee replacement she just had, and they placed a wound vac.
And I don’t know if you’ve ever seen wound vacs in place at their. They’re pretty scary to see. And obviously that infection opened up that store pretty substantially that incision line pretty substantially. We wanted people to have a clear understanding of what that meant, what that looked like.
What information will you typically include?
SCHENK:
Yep. And let me ask this again. Sound like a dumb question, but I guess, I guess this would be different depending on what jurisdiction you’re in. Do you have the plaintiff affirm or certify the facts in the complaint? Because you’re putting so much of this kind of additional things in it ’cause I know that in Georgia you, you don’t necessarily have to affirm the facts of the complaint, but you can is how do you handle that if at all.
ATTY. MOONEY:
Yeah, and Ohio’s much like Georgia, it’s pretty much when the attorney put, puts together a complaint, puts facts together within the complaint. You’re bound by Rule 11 to ensure that you’ve got a good basis for the assertion of those facts and those claims. There’s no additional certifications that you need from the plaintiff themself.
You don’t have to have an affidavit of establishing the accuracy of what we’re, of what I see we’re seeing. And, but it’s pretty much Rule 11 based. Now, of course, you gotta consider that if you’re in a different jurisdiction, you know your requirements your pleading requirements to make sure all that’s well established.
Sure. But in Ohio at least just like Georgia you don’t necessarily need that. So we’ll do like for instance, we’ll grab the death certificate, something that we typically incorporate too, if we’ve got a solid death certificate. This will be something where let’s say we anticipate. The defendants might be trying to argue what they usually do in these cases, right?
That our client was elderly, they were towards the end of their life, and really, you can’t say definitively what caused their passing or that it was their negligence. We’ve got a good, strong death certificate, something that’s been prepared by the county coroner or medical examiner that points to exactly what happened in this case being the cause of death.
Delve into the complexities and challenges that make a nursing home case difficult to handle in the podcast episode, What Makes a Nursing Home Case Difficult?.
We make sure that’s front and center. We put that out there. And so you have here, this is a case that we filed again, be in the Cleveland area where the death certificate was absolutely unequivocal, that the fall of it happened at the defendant’s facility, was the cause of death. And that’s something that we think really clears up for anyone that might read this complaint.
Hey, this isn’t a question of an elderly person who was just succumbed to their maladies or their age. The defendant caused this person’s death.
SCHENK:
And I think and again, like I, it’s not just, you’re not just making decisions on which pictures of the gross wound to put in the complaint.
You’re putting in bits of the medical record, you’re putting in bits of certificates. And I could be making this up, like I said, is I like you’re putting in information about the facilities. Corporate structures like, but it’s visual. Like it’s not just telling the story, like you’re seeing the story as well.
And that’s what makes it so cool. And I get, maybe I’m slow on the uptick, but I have, I don’t normally do that in my complaints. Like sometimes if I’m, I got a crazy hair, I’ll do it in my motions and stuff. I’ll obviously certainly do it at mediation or, opening and closing statements, making the visual, but like in the complaints, I just, it’s so cool.
ATTY. MOONEY:
I think that’s great what y’all are doing and, to show you a little bit, as you said, sometimes we put information in there that you might not been, might not even really think is something that would be very interesting. Or, it’s certainly not graphic and attention grabbing, but it helps to lay out the story in a way that puts into context the misconduct of the defendants, for instance.
Let’s see. We have, I’ll show, oh, I’ll show you this. This is great. The Medicare compare, so I’m sure you’re familiar, Rob and anyone that’s done a lot of nursing, home practice, nursing home litigation practice is probably aware of the Medicare Compare webpage where they take all of that really.
Kind of inaccessible data that the nursing homes are required to provide to Medicare. And they put it into very consumer friendly, easy to read visual information, the star ratings about what kind of facility we’re talking about. Now, this is a case. We’ve got a facility here. This is actually a pretty shocking case.
They had an instance where there was another resident who had some serious delirium problems that was coming into and assaulting our client’s. Loved one, and ultimately. Caused a fatal humerus fracture in the arm. It was such a significant fracture that the client passed away as a result. But we wanted the jury, or no, I’m sorry, not the jury.
We wanted anyone who was to read this complaint to understand that this is not just a one-off incident. This is a systemic practice at this facility to understaff the facility and not provide enough monitoring to prevent those kind of exact scenarios from occurring. So we go to the Medicare Compare website.
We take a look at this particular facility. It’s just as part of our initial investigation of the case, and we find, they’ve got a one star overall rating.
Learn about the criteria attorneys use to select nursing home cases in the podcast, How to Select Nursing Home Cases.
SCHENK:
And if you’re, and if you’re, and if you’re not, if you’re still not able to watch this episode and you’re listening, you’re driving in your car you, you’re in this, you’re in the drive through at Starbucks.
It’s the, it is essentially a screenshot from the Medicare compare website. Just as you can picture it in your mind. But the, it’s a one star on all the things, and there’s a visual representation of it. Like it’s obviously he’s, Matt has written it into the complaint Beautifully is written into it, but the lay person sees, oh, one star.
I don’t know what that means, but it’s bad. So it’s I don’t know, like it’s, at least it’s, I’m, I guess I’m a visual person, so it’s very striking to me.
ATTY. MOONEY:
You and I both rob and especially, the Medicare Compare website. I love it. It’s great because it makes consumers it makes the information very accessible to consumers and people like me who are not, statistician gurus.
And then right under the staffing rating it says much below average. That’s what one star means. I think anybody can understand that. So that’s, we incorporate that into our complaints just about every single case that we have.
SCHENK:
Excellent.
ATTY. MOONEY:
Now, let’s see. I. We’ve got this is, this actually is a very interesting complaint because we’ve got because of Esther Law, Esther’s law in Ohio, a lot of a lot of family members and folks in the nursing home have started, putting cameras in their residence area, their loved one’s rooms, and that’s a right, that’s preserved by statute in Ohio.
I’m not sure if it’s the same in Georgia, but I’m hoping that I’m hoping that other states are on board with this because it really does change quite a bit. The way that the nursing home is able to hide what happens to the people within their own. And so here we have the actual video footage still frames from the video footage that was captured by the the camera that was in the residence room, showing the actual incident that led to the residence passing.
And you see here it’s a still frame. We’ve described, minute by minute what the video shows. And then when we get to the most important moments of the video, we’ve included the still frame. Here is. Here’s that resident with delirium who had been, essentially assaulting our client’s mother for some time.
The facility was aware of it, but did not do much, really anything to prevent it. She came into her room in the middle of the night one night and started trying to drag her out of the bed. And here’s our here’s our decedent. The client’s mother here. The resident with delirium.
This is her trying to pull her out of the bed. Then we go on to the next frame of the video. This is her yelling at her, trying to get her out of the bed. And then we move on to where she’s actually physically grabbing our client’s mother and pulling her from the bed, choking her, covering her mouth to prevent her from yelling, and then pulling her from the bed onto the floor.
In the process, fracturing her humerus and that fracture was ultimately what led to her passing.
SCHENK:
My goodness. That’s awful.
ATTY. MOONEY:
It’s terrible. And it’s evidence that we don’t always have, and it really completely undermines the story that the nursing home was telling the family and what we anticipated they were going to say to the judge, to the jury at trial.
And we wanna make very clear that is just not actually accurate. And so we put that evidence right out there. There’s one last thing. You mentioned, medical records, I’ll show you real quick. You know if your medical records are particularly striking about some of the aspects of the neglect.
Now, this is a bedsore case, and in this case, the facility was hiding the fact that this patient had a bedsore from their family, right? And not only were they hiding it from the resident’s family, they were hiding it from CMS, hiding it from Medicare as well. For instance, the skin and wound evaluation document.
If they were to check off in this document, which is a it’s a standard document within the point click care system. If they were to check off under this type of wound in the skin evaluation, any kind of preventable injury, like a pressure injury or a burn, something that would’ve occurred that as a result of their neglect, that triggers something within the MDS nurse, the nurse that puts together that MDS documentation, CMS document that wound.
It could potentially be an impact on their quality measure scores, that star rating about the quality of outcomes of their facility. Here are the nurses. They’re documenting, at least verbally saying that this patient has wound a bed, sore, open, sore, but they don’t click anything on the sheet.
There’s really no logical explanation for it. That’s, it’s for some time it persists that they’re not clicking any of these wound categories here. The only reason that we can conclude is because they don’t want that to hit the MDS and ding the facility.
Understand the types of damages involved in nursing home cases and what they mean for clients in What Are Damages in a Nursing Home Case? What Does That Mean?.
SCHENK:
It’s one thing to say there’s an absence of record and there’s another thing to actually put the record up there that shows nothing.
So I think that’s an excellent that’s an excellent illustration. And look, I, we didn’t get, we didn’t have enough time to get into the, I don’t know the skill at the narrative you’re the writing from what I am seeing and what I have seen from you. I.
It’s beautiful. Like it’s very good. It’s like pros. So maybe we’ll have you on again to talk about, I don’t use chat GPT, it’s coming from my brain, all that kind of stuff. But maybe we’ll have you on again to talk about, the decisions you make and what substantively to put in. But I really appreciate you coming on and talking to us this week and sharing your knowledge, Matt.
ATTY. MOONEY:
I appreciate it, Rob. Thanks for the opportunity and again, I hope that we can, reach some folks in the practice to understand that this complaint, this tool, they can accomplish a lot more than what we just initially set out to try and get the case into the courtroom. There’s a lot more that can be done with these complaints.
I’m glad I got the opportunity to speak with you.
SCHENK:
I hope that you found this episode educational and entertaining. If you did, please let me know. If you have any ideas for topics that you would like for me to cover, please let me know. If you have any ideas for people that you want me to talk to, lemme know that as well.
New episodes of the Nursing Home Abuse Podcast for the time being come out every Monday wherever you get your podcasts from. And I guess even specifically for this episode, you should go to YouTube and try to watch it. It’s more of a visual episode. A lot of it’s really cool what Matt is doing in these complaints.
But anyway, with that folks. We’ll see you next time.
Atty. Matthew Mooney’s Contact Information: