CJ-2026-1280 - Krystal Traylor v. Oklahoma Heart Hospital South, LLC

What's This Case About?

Thirteen trips to the hospital. Thirteen times a woman walked back into the same heart center, clutching her chest, begging for answers after open-heart surgery — only to be sent home again and again, until they finally told her she was dying and couldn’t be saved. That’s not the plot of a medical drama. That’s real life in Oklahoma City, where Edna M. Hardison Williams didn’t just die — she allegedly bled out slowly, over months, while doctors allegedly looked the other way. Now, her daughter is suing not one, not two, but ten defendants — a hospital, a physician group, and eight medical providers — for what she says wasn’t just incompetence, but willful disregard for her mother’s life.

Let’s meet the players. On one side: Krystal Traylor, daughter and now legal representative of Edna M. Hardison Williams, a woman who lived in Oklahoma County and, in October 2023, underwent coronary artery bypass graft (CABG) surgery — otherwise known as open-heart surgery — at Oklahoma Heart Hospital South. On the other side? A medical dream team that sounds more like a corporate-owned assembly line: Oklahoma Heart Hospital South, LLC (the facility), OHH Physicians, LLC (the doctor group), and a roster of eight named providers — including six doctors, two nurse practitioners, and enough initials after their names to fill a pharmacy label. Dr. Ian Parker, Dr. Agha Khan, Dr. Steven Miller, Dr. Kevin Hoos, APRN Candace Becker, APRN Amber Garretson, Dr. Randall Henderson, and Dr. James Fitzgerald, Jr. — all allegedly involved in Edna’s care at various points. They weren’t just her doctors; they were the gatekeepers to her survival. And according to the lawsuit, they failed — catastrophically.

Here’s how it went down. Edna had her CABG surgery on October 16, 2023. Great. Standard procedure, right? Except almost immediately after, she started having chest pain — not the garden-variety soreness you’d expect after cracked ribs and open-heart work, but ongoing, alarming symptoms that screamed “something’s wrong.” Instead of brushing it off, she did the responsible thing: she went back. And back. And back. Thirteen times between November 9, 2023, and February 24, 2024, Edna returned to Oklahoma Heart Hospital South, each time complaining of chest pain and other red flags pointing to post-surgical complications. Thirteen visits. Thirteen chances to catch whatever was going wrong. Thirteen opportunities to intervene. And every single time, she was reportedly seen by one of the defendant providers — only to be sent home again, with no diagnosis, no emergency imaging, no surgical follow-up. Just pain, dismissal, and the creeping dread that something was very, very wrong.

Then, on February 24, 2024 — nearly four months after surgery — they finally found it. A mediastinal hemorrhage. That’s medical speak for “bleeding in the space between the lungs,” often a life-threatening complication after heart surgery. And in Edna’s case, it was so severe they told her it couldn’t be repaired. Her condition was terminal. The same hospital that had sent her home a dozen times was now prepping hospice. She died eight days later, on March 3, 2024. The petition claims the cause wasn’t just bad luck — it was negligence. That the defendants failed to diagnose and treat her for months, despite clear symptoms, and that their actions (or inaction) directly caused her prolonged suffering and premature death. The lawsuit doesn’t mince words: it calls the conduct “gross, willful, and wanton,” suggesting this wasn’t just a mistake — it was a pattern of indifference.

So why are we in court? Legally, the plaintiff is making two big claims: medical negligence and wrongful death — repeated six times across the petition, because apparently, suing ten defendants requires some legal redundancy. In plain English: Edna’s daughter is saying the doctors and hospital didn’t meet the basic standard of care expected in medicine. They missed a life-threatening bleed for months. That’s negligence. And because that negligence allegedly led to Edna’s death, it’s also wrongful death — which allows surviving family members to sue for their own losses: funeral costs, emotional pain, the loss of a mother’s love and companionship. The legal doctrine of respondeat superior is also invoked — a fancy way of saying “the employer is responsible for the employees.” So not only are the individual doctors and nurse practitioners on the hook, but so are the hospital and physician group that employed and credentialed them. The lawsuit even claims the institutions negligently retained these providers — implying they should’ve known better than to let them practice unsupervised.

And what does Krystal Traylor want? $150,000 — split evenly between $75,000 in actual damages and $75,000 in punitive damages. Now, let’s be real: in the world of medical malpractice, $150,000 is not a jackpot. It’s not even close. A single day in the ICU can cost tens of thousands. Funeral expenses alone can top $10,000. And when you’re talking about months of untreated hemorrhaging, emotional devastation, and the loss of a parent? That number feels… modest. Almost symbolic. The punitive damages — meant to punish especially reckless behavior — suggest this isn’t just about compensation. It’s about accountability. She’s not asking for a mansion or a private island. She’s asking for acknowledgment that her mother’s suffering mattered, and that the system that failed her should pay a price.

Our take? Look, we’re not doctors. We’re not lawyers. We’re just people who read court filings and ask, “What in the actual hell happened here?” And the most absurd, gut-wrenching part of this case isn’t the medical jargon or the ten defendants — it’s the thirteen visits. Thirteen times Edna showed up, in pain, seeking help. Thirteen times the system failed her. You don’t need a medical degree to know that when someone keeps coming back with chest pain after open-heart surgery, you do more than send them home. You run tests. You check for bleeds. You treat the human in front of you like they might actually be telling the truth. Instead, Edna was allegedly treated like a nuisance, a chart, a revolving door patient — until it was too late. We’re not rooting for a payout. We’re rooting for someone to finally say, “You’re right. We should’ve listened.” Because in a system that’s supposed to heal, the worst diagnosis isn’t mediastinal hemorrhage. It’s indifference. And that’s a disease no stethoscope can fix.

Case Overview

$150,000 Demand Jury Trial Petition

Jurisdiction

Oklahoma County District Court, Oklahoma

Filing Attorney

L. Justin Lowe

Justin Lowe & Associates

Relief Sought

$75,000 Monetary

$75,000 Punitive

Plaintiffs

Krystal Traylor individual
Rep: L. Justin Lowe, OBA #18958

Defendants

Oklahoma Heart Hospital South, LLC business
OHH Physicians, LLC business
Ian J. Parker, D.O. individual
Agha K. Khan, M.D. individual
Steven D. Miller, M.D. individual
Kevin C. Hoos, D.O. individual
Candace A. Becker, APRN-CNS individual
Amber Garretson, APRN-CNS individual
Randall Henderson, D.O. individual
James Fitzgerald, Jr., D.O. individual

Claims

#	Cause of Action	Description
1	Medical Negligence	Plaintiff alleges Defendants' negligence led to the untimely and wrongful death of Edna M. Hardison Williams.
2	Wrongful Death	Plaintiff alleges Defendants' negligence led to the untimely and wrongful death of Edna M. Hardison Williams.

Petition Text

3,092 words

IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA KRYSTAL TRAYLOR, individually and as next of kin of EDNA M. HARDISON WILLIAMS, deceased, Plaintiff, v. OKLAHOMA HEART HOSPITAL SOUTH, LLC; OHH PHYSICIANS, LLC; IAN J. PARKER, D.O.; AGHA K. KHAN, M.D.; STEVEN D. MILLER, M.D.; KEVIN C. HOOS, D.O.; CANDACE A. BECKER, APRN-CNS; AMBER GARRETSON, APRN-CNS; RANDALL HENDERSON, D.O.; and JAMES FITZGERALD, JR., D.O., Defendants. PETITION COMES NOW, the Plaintiff, Krystal Traylor, as next of kin of Edna M. Hardison Williams, deceased, and for her cause of action against the Defendants, Oklahoma Heart Hospital South, LLC (hereinafter known as “OHH South”); OHH Physicians, LLC (hereinafter known as “OHH Physicians”); Ian J. Parker, D.O. (hereinafter “Dr. Parker”); Agha K. Khan, M.D. (hereinafter “Dr. Khan"); Steven D. Miller, M.D. (hereinafter “Dr. Miller”); Kevin C. Hoos, D.O. (hereinafter “Dr. Hoos”); Candace A. Becker, APRN-CNS (hereinafter “APRN Becker”); Amber Garretson, APRN-CNS (hereinafter “APRN Garretson”); Randall Henderson, D.O. (hereinafter “Dr. Henderson”); and James Fitzgerald, Jr., D.O. (hereinafter “Dr. Fitzgerald”) states as follows: JURISDICTION AND VENUE 1. Plaintiff, Krystal Traylor, is presently a resident of Oklahoma County, State of Oklahoma. 2. The decedent, Edna M. Hardison Williams, was at all times relevant herein, a resident of Oklahoma County, State of Oklahoma. 3. Defendant, OHH South, is presently, and was at all times relevant herein, a corporation and medical facility licensed to practice healthcare and do business in Oklahoma County, State of Oklahoma. 4. Defendant, OHH Physicians, is presently, and was at all times relevant herein, a corporation owned by physicians and/or employing physicians licensed to practice medicine in Oklahoma County, State of Oklahoma. 5. Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr. Henderson, and Dr. Fitzgerald, are presently, and were at all times relevant herein, physicians or nurse practitioners licensed to practice medicine in Oklahoma County, State of Oklahoma. 6. This Court has jurisdiction over the matters and the parties herein, as the acts occurred in Oklahoma County, Oklahoma. 7. The Plaintiff consents to this Court’s jurisdiction. GENERAL ALLEGATIONS 8. Edna M. Hardison Williams, deceased, was a patient of Defendants when she underwent a CABG surgery on October 16, 2023 at OHH South and performed by the Defendant physicians, agents and employees of Defendant, OHH Physicians. 9. Almost immediately after said surgery, Edna M. Hardison Williams began experiencing pain in her chest and other symptoms indicative of complications from the CABG surgery. 10. Ms. Williams returned to OHH South thirteen (13) separate times between November 9, 2023 and February 24, 2024 complaining of chest pain and other symptoms indicative of complications from the CABG surgery and was seen by Defendant physicians and/or nurse practitioners at each visit. 11. On February 24, 2024, Ms. Williams again returned to Defendant, OHH South, and was diagnosed with a mediastinal hemorrhage that could not be repaired and she was told her condition was terminal. Defendant physicians and nurse practitioners were in the process of setting up hospice care in anticipation of discharging Ms. Williams when she died on March 3, 2024. 12. The care and treatment rendered by Defendants, OHH South, OHH Physicians, and each of the Defendant physicians and nurse practitioners fell below acceptable medical standards. 13. Defendants’ negligence was gross, willful and/or wanton, and displayed a willful disregard for the welfare, wellbeing, and life and Edna M. Hardison Williams, deceased 14. As a direct and proximate result of Defendants’ negligence, Edna M. Hardison Williams, deceased, was forced to undergo months of pain and suffering and anxiety that would not have ordinarily occurred in the absence of medical negligence. 15. Defendants grossly, willfully, wantonly, and negligently failed to timely diagnose and/or treat Edna M. Hardison Williams’ medical condition thereby causing her untimely death on March 4, 2024. 16. As a direct and proximate result of the Defendants’ negligence, Edna M. Hardison Williams, deceased, endured great pain and suffering prior to her death; extreme mental anguish and anxiety at her impending death; and incurred medical expenses and other financial damages, all resulting from an act, omission, or instrumentality under the exclusive control and management of Defendants, and that the events causing Ms. Williams’ death and other damages were of a kind which ordinarily do not occur in the absence of negligence by Defendants. 17. As a direct and proximate result of the Defendants’ negligence, Plaintiff, Krystal Traylor, and other family members of Edna M. Hardison Williams, deceased, Emerson, were forced to incur funeral and burial expenses; were deprived of the companionship and love of their mother; and forced to endure the loss of the parent-child relationship, all as a result of the untimely and wrongful death of Edna Williams. 18. At the time of the events giving rise to this action, Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald were employed by Defendant, OHH Physicians, and privileged, credentialed and otherwise entrusted to care and treat the patients at Defendant, OHH South. 19. Defendants, OHH South and OHH Physicians, negligently retained, supervised, privileged, credentialed, and otherwise entrusted the care and treatment of their patients to Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald. 20. Upon information and belief, Defendants, OHH South and OHH Physicians were negligent under the Doctrine of Respondeat Superior for the actions of their employees and/or agents, Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald. FIRST CAUSE OF ACTION MEDICAL NEGLIGENCE BY ALL DEFENDANT PHYSICIANS AND NURSE PRACTIONERS NAMED HEREIN Plaintiff re-alleges and incorporates by reference herein all of the allegations contained in paragraphs 1-20 above. 21. Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, were negligent in their care and treatment of the decedent, Edna M. Hardison Williams, in that they failed to timely diagnose Ms. Williams; failed to care for and treat her in accordance with the standard of care and skill required of, and ordinarily exercised by the average qualified physician engaged in medical practice at the professional level, such as that in which, Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, are engaged. 22. As a direct and proximate result of the negligence of Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, Edna M. Hardison Williams, incurred medical bills and other financial damages, and was forced to endure extreme pain, suffering, and mental anguish prior to her untimely death, and as a direct and proximal result of Defendants', Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, negligence. 23. The injuries and damages sustained by Edna M. Hardison Williams were the direct and proximal result of the negligent actions of Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, without any act or omission on the part of Edna M. Hardison Williams directly thereunto contributing. Edna M. Hardison Williams did not assume the risk of her injuries or damages. SECOND CAUSE OF ACTION MEDICAL NEGLIGENCE BY OHH SOUTH Plaintiff re-alleges and incorporates by reference herein all of the allegations contained in paragraphs 1-20 above. 24. Defendant, OHH South, was negligent in its care and treatment of decedent, Edna M. Hardison Williams, in that it failed to care for and treat her in accordance with the standard of care and skill required of, and ordinarily exercised by the average clinic, hospital, or medical facility engaged in medical practice at the professional level, such as that in which, Defendant, OHH South, is engaged. 25. As a direct and proximate result of the negligence of Defendant, OHH South, decedent, Edna M. Hardison Williams, incurred medical bills and other financial damages, and was forced to endure extreme pain, suffering, and mental anguish prior to her untimely death, and as a direct and proximal result of Defendant, OHH South's, negligence. 26. The injuries and damages sustained by Edna M. Hardison Williams were the direct and proximal result of the negligent actions of Defendant, OHH South, without any act or omission on the part of Edna M. Hardison Williams directly thereunto contributing. Edna M. Hardison Williams did not assume the risk of her injuries or damages. 27. Plaintiff asserts a claim against Defendant, OHH South, under the Doctrine of Respondeat Superior and asserting Defendant negligently retained, supervised, privileged, credentialed and otherwise entrusted the care and treatment of their patients to Defendants, OHH Physicians and Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald. THIRD CAUSE OF ACTION MEDICAL NEGLIGENCE BY OHH PHYSICIANS Plaintiff re-alleges and incorporates by reference herein all of the allegations contained in paragraphs 1-20 above. 28. Defendant, OHH Physicians, was negligent in its care and treatment of decedent, Edna M. Hardison Williams, in that it failed to care for and treat her in accordance with the standard of care and skill required of, and ordinarily exercised by the average clinic, hospital, medical group, or medical facility engaged in medical practice at the professional level, such as that in which, Defendant, OHH Physicians, is engaged. 29. As a direct and proximate result of the negligence of Defendant, OHH Physicians, decedent, Edna M. Hardison Williams, incurred medical bills and other financial damages, and was forced to endure extreme pain, suffering, and mental anguish prior to her untimely death, and as a direct and proximal result of Defendant, OHH Physicians', negligence. 30. The injuries and damages sustained by Edna M. Hardison Williams were the direct and proximal result of the negligent actions of Defendant, OHH Physicians, without any act or omission on the part of Edna M. Hardison Williams directly thereunto contributing. Edna M. Hardison Williams did not assume the risk of her injuries or damages. 31. Plaintiff asserts a claim against Defendant, OHH Physicians, under the Doctrine of Respondeat Superior and asserting Defendant negligently retained, supervised, privileged, credentialed and otherwise entrusted the care and treatment of their patients to Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald. FOURTH CAUSE OF ACTION WRONGFUL DEATH BY ALL DEFENDANT PHYSICIANS AND NURSE PRACTITIONERS NAMED HEREIN Plaintiff re-alleges and incorporates by reference herein all of the allegations contained in paragraphs 1-20 above. 32. Defendants’, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, negligence caused the untimely and wrongful death of Edna M. Hardison Williams. 33. As a direct and proximate result of the Defendants’, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, negligence, and the untimely and wrongful death of Edna M. Hardison Williams, the Plaintiff, Krystal Traylor, and other family members of Edna M. Hardison Williams, were forced to incur funeral and burial expenses; were deprived of the companionship and love of their mother; and forced to endure the loss of the parent-child relationship, all as a result of the untimely and wrongful death of Edna Williams. 34. As a direct and proximate result of the Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, negligence, and the untimely and wrongful death of Edna M. Hardison Williams, the Plaintiff, Krystal Traylor, and other family members of Edna M. Hardison Williams, were forced to endure extreme mental anguish, and will endure future mental anguish, due to the untimely and wrongful death of Edna M. Hardison Williams. 35. The untimely and wrongful death of Edna M. Hardison Williams was the direct and proximate result of the negligent actions of Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, without any action or omission on the part of Edna M. Hardison Williams, and without any action or omission on the part of Plaintiff, Krystal Traylor or the other family members of Edna M. Hardison Williams, deceased, directly thereunto contributing. Edna M. Hardison Williams did not assume the risk of her injuries or untimely and wrongful death. 36. Plaintiff, Krystal Traylor, as the next of kin of Edna M. Hardison Williams, asserts a claim against Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, for the untimely and wrongful death of Edna M. Hardison Williams. FIFTH CAUSE OF ACTION WRONGFUL DEATH BY OHH SOUTH Plaintiff re-alleges and incorporates by reference herein all of the allegations contained in paragraphs 1-20 above. 37. Defendant, OHH South’s, negligence caused the untimely and wrongful death of Edna M. Hardison Williams. 38. As a direct and proximate result of the Defendant, OHH South’s, negligence, and the untimely and wrongful death of Edna M. Hardison Williams, the Plaintiff, Krystal Traylor, and other family members of Edna M. Hardison Williams, were forced to incur funeral and burial expenses; were deprived of the companionship and love of their mother; and forced to endure the loss of the parent-child relationship, all as a result of the untimely and wrongful death of Edna Williams. 39. As a direct and proximate result of the Defendant, OHH South’s, negligence, and the untimely and wrongful death of Edna M. Hardison Williams, the Plaintiff, Krystal Traylor, and other family members of Edna M. Hardison Williams, deceased, were forced to endure extreme mental anguish, and will endure future mental anguish, due to the untimely and wrongful death of Edna M. Hardison Williams. 40. The untimely and wrongful death of Edna M. Hardison Williams was the direct and proximate result of the negligent actions of Defendant, OHH South’s, without any action or omission on the part of Edna M. Hardison Williams, and without any action or omission on the part of Plaintiff, Krystal Traylor, or other family members of Edna M. Hardison Williams, deceased, directly thereunto contributing. Edna M. Hardison Williams did not assume the risk of her injuries or untimely and wrongful death. 41. Plaintiff, Krystal Traylor, as the next of kin of Edna M. Hardison Williams, asserts a claim against Defendant, OHH South, under the Doctrine of Respondeat Superior and asserting Defendant negligently retained, supervised, privileged, credentialed and otherwise entrusted the care and treatment of their patients to Defendants, OHH Physicians and Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald. SIXTH CAUSE OF ACTION WRONGFUL DEATH BY OHH PHYSICIANS Plaintiff re-alleges and incorporates by reference herein all of the allegations contained in paragraphs 1-20 above. 42. Defendant, OHH Physicians’, negligence caused the untimely and wrongful death of Edna M. Hardison Williams. 43. As a direct and proximate result of the Defendant, OHH Physicians', negligence, and the untimely and wrongful death of Edna M. Hardison Williams, the Plaintiff, Krystal Traylor, and other family members of Edna M. Hardison Williams, were forced to incur funeral and burial expenses; were deprived of the companionship and love of their mother; and forced to endure the loss of the parent-child relationship, all as a result of the untimely and wrongful death of Edna Williams. 44. As a direct and proximate result of the Defendant, OHH Physicians', negligence, and the untimely and wrongful death of Edna M. Hardison Williams, the Plaintiff, Krystal Traylor, and other family members of Edna M. Hardison Williams, deceased, were forced to endure extreme mental anguish, and will endure future mental anguish, due to the untimely and wrongful death of Edna M. Hardison Williams. 45. The untimely and wrongful death of Edna M. Hardison Williams was the direct and proximate result of the negligent actions of Defendant, OHH Physicians', without any action or omission on the part of Edna M. Hardison Williams, and without any action or omission on the part of Plaintiff, Krystal Traylor, or other family members of Edna M. Hardison Williams, deceased, directly thereunto contributing. Edna M. Hardison Williams did not assume the risk of her injuries or untimely and wrongful death. 46. Plaintiff, Krystal Traylor, as the next of kin of Edna M. Hardison Williams, asserts a claim against Defendant, OHH Physicians, under the Doctrine of Respondeat Superior and asserting Defendant negligently retained, supervised, privileged, credentialed and otherwise entrusted the care and treatment of their patients to Defendants, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald. WHEREFORE, Plaintiff, Krystal Traylor, individually and as next of kin of Edna M. Hardison Williams, prays this Court enter judgment in her favor on behalf of the decedent, Edna M. Hardison Williams, and against the Defendants, OHH South, OHH Physicians, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, for actual damages in an amount to exceed $75,000.00; punitive damages in an amount to exceed $75,000.00 for the medical negligence claims made herein, medical bills incurred, and for the extreme pain, suffering, and mental anguish endured by Edna M. Hardison Williams prior to her untimely and wrongful death; for the reasons set forth above, her costs for bringing this action, and for such other and further relief as this Court may deem just and proper. WHEREFORE, Plaintiff, Krystal Traylor, individually, and as next of kin of Edna M. Hardison Williams, prays this Court enter judgment in her favor and against the Defendants, OHH South, OHH Physicians, Dr. Parker, Dr. Khan, Dr. Miller, Dr. Hoos, APRN Becker, APRN Garretson, Dr Henderson, and Dr Fitzgerald, for actual damages in an amount to exceed $75,000.00; for punitive damages in an amount to exceed $75,000.00 for the untimely and wrongful death of Edna M. Hardison Williams; for the extreme pain, suffering, mental anguish, grief, loss of the companionship and love of their mother, loss of the parent-child relationship; as a result of the untimely and wrongful death of Edna Williams; for the reasons set forth above, her costs for bringing this action, and for such other and further relief as this Court may deem just and proper. Respectfully submitted, [signature] L. Justin Lowe, OBA #18958 JUSTIN LOWE & ASSOCIATES 7320 N. Classen Boulevard Oklahoma City, OK 73116 T: 405.848.7777 F: 405.832.0571 [email protected] Attorney for Plaintiff ORIGINAL VERIFIED ATTORNEY LIEN CLAIMED JURY TRIAL DEMANDED VERIFICATION STATE OF OKLAHOMA ) COUNTY OF OKLAHOMA ) ss. I, Krystal Traylor, of lawful age, being first duly sworn, deposes and states: That I am the Plaintiff in the above-styled and numbered cause of action; that I have read the above and foregoing instrument, and that the information and facts therein contained are true and correct to the best of my knowledge and belief. Plaintiff SUBSCRIBED AND SWORN to before me this 18th day of February, 2026. Cynthia Hall NOTARY PUBLIC My Commission Expires: 6-5-24 My Commission No.: 0000036644