This action for malpractice involves a severe brain injury to the newborn plaintiff, that was the result of a failure of hospital L&D nursing staff and OB/GYN, Ling Chen, MD, to appreciate abnormal fetal heart rate (FHR) patterns, leading to overuse of Pitocin, and culminating in a sinusoidal followed by a bradycardic pattern of Category III, in which cesarean delivery occurred too late for the infant to avoid injury. Delivery occurred on 1/9/18, at Good Samaritan Hospital in San Jose.