that Mrs. Oberlin was to "continue on bed rest." Dr. Rinaldi wrote a note for Dr. Vincent, Mrs. Oberlin's obstetrician back in Alexandria, Louisiana. (Exhibit 4, pp. 1, 8).
11. The final diagnosis was "questionable premature rupture of membranes (high leakage: unproven)." (Exhibit 4, pg. 1).
12. On 12/5/76 Mrs. Oberlin left Langley, Virginia and flew home to Alexandria, Louisiana.
13. On 12/7/76 Mrs. Oberlin saw her attending obstetrician, Dr. Vincent. Dr. Vincent examined Mrs. Oberlin, diagnosed leaking membranes and referred Mrs. Oberlin to the Ochsner Clinic in New Orleans, Louisiana that same day. (Exhibit 5, p. 1 and Exhibit 6, p. 1).
14. Mrs. Oberlin was admitted to the Ochsner Clinic on 12/7/76, under the care of Dr. William Geary. Mrs. Oberlin was diagnosed as having premature rupture of the membrane (PROM). (Exhibit 6, p. 1).
15. At the time of admission to the Ochsner Clinic, Mrs. Oberlin was afebrile, with a normal white count (i.e. in the range of 14,000). She was to be kept on bed rest. (Exhibit 6, p. 1).
16. On 1/7/77 Mrs. Oberlin spiked a fever and her white count rose to 17,000, indicating an infection. She went into premature labor. Vaginal examination revealed an unfavorable cervix, and her treating physicians elected to deliver by C-section. (Exhibit 6, p. 1).
17. Minor-plaintiff Maureen Oberlin was born prematurely (34 weeks gestation) on 1/7/77. (Exhibit 6, p. 1).
18. Minor-plaintiff Maureen Oberlin was diagnosed as having an infection in the first week of life, which was treated by antibiotics and resolved. (Exhibit 6, p. 1).
19. On 1/29/77 minor-plaintiff Maureen Oberlin was discharged from the Ochsner Clinic at 3 weeks of age, with a prognosis of excellent. (Exhibit 6, p. 2).
20. At around age six months, minor-plaintiff Maureen Oberlin began to exhibit signs of developmental delay. (Exhibit 7).
21. On 11/4/77 minor-plaintiff Maureen Oberlin underwent a neurological evaluation by Carmela L. Tardo, M.D. Dr. Tardo diagnosed mild cerebral palsy. (Exhibit 7).
22. Virginia Oberlin has believed, since 1976, that a vaginal examination at Langley Air Force Base Hospital resulted in premature rupture of her membranes.
23. Maureen Oberlin's parents have believed, since 1978, that Maureen's prematurity, infection and Cerebral Palsy were all connected to the premature rupture of Virginia Oberlin's membranes.
24. The Oberlins did not seek legal advice concerning their belief that vaginal examination(s) at Langley Air Force Base Hospital caused premature rupture of membranes because they believed that the vaginal examinations at Langley were necessary.
25. In 1985, Virginia Oberlin came to believe that the vaginal examinations at Langley Air Force Base were contraindicated because she learned that digital vaginal examinations should not be given to women with third trimester bleeding. As a result of this impression, the Oberlins contacted an attorney in 1986.
26. On 6/16/86 plaintiff William Oberlin filed an administrative claim with the U.S. Air Force alleging that the digital examinations performed by Dr. Rinaldi on Virginia Oberlin at Langley had "resulted in the rupture of membranes" and that "despite the rupture, Mrs. Oberlin was discharged to travel to Louisiana." The claim further alleges that Maureen's "cerebral palsy was caused by the prematurity, infection and other circumstances directly related to the premature rupture of the membranes." (Exhibit 1).
27. Following discussions with a number of obstetricians, the Oberlin's attorney concluded that the opinion within the medical community was unanimous that the vaginal examinations at Langley Air Force Base had not caused the premature rupture of Mrs. Oberlin's membranes, and that the temporal relationship between the examinations and the rupture was coincidental.
28. On 2/17/87 plaintiff's administrative claim was denied. (Exhibit 2).
29. On 7/21/87 the Oberlin's attorney asked for reconsideration of their administrative claim, alleging a new theory of liability in that physicians at Clark Air Force Base and England Air Force Base had been negligent in 1972 and 1974 respectively in failing to diagnose and to correct a "uterine septum" which allegedly predisposed Mrs. Oberlin to PROM. (Exhibit 2).
30. Plaintiffs' request for reconsideration of their claim alleging a new theory of liability was accepted. After investigation, the United States denied this resubmitted claim on 8/1/88.
31. On 2/14/89, plaintiffs filed the within Complaint, alleging that Dr. Rinaldi's failure to diagnose P.R.O.M. when Mrs. Oberlin first presented at Langley, and subsequent discharge to travel to Louisiana, deprived Mrs. Oberlin of a chance that her membranes would reseal.
32. During discussions with obstetricians, plaintiff's attorney was informed that the failure of Langley Air Force Base physicians to place Mrs. Oberlin on total bedrest, and their discharge of Mrs. Oberlin to return to Louisiana from Virginia, reduced the likelihood that Mrs. Oberlin's membranes would reseal, thus increasing the likelihood of premature birth/infection/Cerebral Palsy in Maureen Oberlin.
33. Until Mrs. Oberlin was informed, by her attorney, in 1986/1987 that failure of Langley physicians to place her on total bedrest may have prevented a resealing of her membranes, she had no suspicion that this failure may have been causally related to Maureen's Cerebral Palsy.
34. Until 1986/1987, Mrs. Oberlin was not aware that ruptured membranes could reseal, and thereby avoid prematurity, infection and Cerebral Palsy.
35. Because Mrs. Oberlin was not aware that ruptured membranes could reseal until 1986/1987, she was not aware of the causal connection between the defendant's physician's failure to place her on total bedrest and the injury to her daughter until 1987.
36. While it is possible for ruptured membranes to reseal with total bedrest, it is not probable that ruptured membranes will reseal with total bedrest.
37. The plaintiffs can produce expert testimony that:
a. Premature rupture of the membranes (P.R.O.M.) is defined as rupture of membranes prior to the onset of uterine contractions. The two major risks of PROM are infection and premature labor.
b. Physicians at Langley Air Force Base Hospital departed from appropriate standards concerning steps that should have been taken to determine whether Mrs. Oberlin's membranes had prematurely ruptured.