IN THE DISTRICT COURT IN AND FOR TULSA COUNTY
STATE OF OKLAHOMA
STEPHANIE NICHOLE ADAMS, individually,
Plaintiff,
v.
BELLE MEDICAL TULSA, LLC, an Oklahoma Limited Liability Company; BLATCHFORD, INC., a Kansas Corporation, d/b/a Chestnut Wellness; PATRICK BLATCHFORD, M.D., an Individual; and DOES 1–20,
Defendants.
Case No. CJ-2026-01858
ATTORNEY LIEN CLAIMED
RICHARD HATHCOAT
PETITION
COMES NOW Plaintiff Stephanie Nichole Adams, individually, by and through her attorneys of record, and for her causes of action against Defendants Belle Medical Tulsa, LLC; Blatchford, Inc. d/b/a Chestnut Wellness; Patrick Blatchford, M.D.; and DOES 1–20, alleges and states as follows:
PARTIES, JURISDICTION AND VENUE
1. Plaintiff Stephanie Nichole Adams is an individual and resident of Bixby, Tulsa County, Oklahoma.
2. Defendant Belle Medical Tulsa, LLC ("Belle Medical") is an Oklahoma Limited Liability Company organized and existing under the laws of the State of Oklahoma, with its registered agent Northwest Registered Agent LLC, 9905 S Pennsylvania Ave, Suite A, Oklahoma City, Oklahoma 73159. At all times relevant herein, Belle Medical owned, operated, managed, and/or controlled the cosmetic medical clinic located at 4521 E 91st Street, Suite 251, Tulsa, Oklahoma 74137, at which the acts and omissions giving rise to this action occurred.
3. Defendant Blatchford, Inc. d/b/a Chestnut Wellness ("Chestnut Wellness") is a Kansas Corporation doing business as Chestnut Wellness, with its principal place of business at 119 E Chestnut Avenue, Arkansas City, Kansas 67005. Chestnut Wellness employed, contracted with, and/or provided the services of Defendant Patrick Blatchford, M.D., to patients in Oklahoma, including Plaintiff, through its relationship with Belle Medical.
4. Defendant Patrick Blatchford, M.D. ("Dr. Blatchford") is an individual licensed to practice medicine in the State of Oklahoma, who at all times relevant herein provided surgical and medical services to Plaintiff at the Belle Medical clinic in Tulsa, Oklahoma.
5. DOES 1–10 represent agents, employees, contractors, and/or servants, and all other medical providers who provided negligent care and treatment to Plaintiff, and DOES 11–20 represent employers, contracting agencies, organizations, and/or corporate entities that employed, contracted with, and/or acted as an agency for the named Defendants and/or DOES 1–10, which are currently unknown and/or unconfirmed to Plaintiff. Upon information and belief that will be confirmed through discovery, each of these Defendants is in some way liable for the acts and/or omissions referred to herein and caused damage to Plaintiff. Plaintiff will amend this Petition and insert the correct names and capacities of those Defendants when they are discovered.
6. The injuries that are the subject of this dispute occurred in Tulsa County, Oklahoma.
7. This Court has jurisdiction and venue is proper in Tulsa County, Oklahoma.
STATEMENT OF FACTS
8. Paragraphs 1 through 7 above are incorporated herein by reference.
9. In late 2024, Plaintiff sought to have breast implant removal and, at the same time, undergo body contouring procedures including liposuction and autogenous fat grafting to the breasts.
10. Plaintiff identified Belle Medical, located at 4521 E 91st Street, Suite 251, Tulsa, Oklahoma 74137, as a provider of those services. Belle Medical held out Dr. Blatchford as a board-certified surgeon qualified to perform the procedures Plaintiff sought.
11. Plaintiff attended an initial consultation at Belle Medical Tulsa on or about December 30, 2024. At that consultation, the procedure plan was discussed and finalized. Plaintiff contracted for, and paid for, a combined procedure that expressly included a general anesthetic to be administered by a board-certified anesthesiologist.
12. On February 19, 2025, Plaintiff presented to the Belle Medical clinic for her scheduled procedure. Pre-procedure medications were administered, including alprazolam, hydromorphone, and metoclopramide. The scheduled anesthesiologist did not appear. Defendants proceeded with the full multi-procedure surgical session without a licensed anesthesiologist or Certified Registered Nurse Anesthetist present, performing the procedure under ketamine sedation and tumescent local anesthesia only.
13. The procedure performed on February 19, 2025, consisted of bilateral breast implant removal, bilateral autogenous fat grafting to the breasts, liposuction of the upper and lower abdomen, flanks, and suprapubic region, BodyTITE radiofrequency skin tightening, and Renuvion helium plasma skin tightening. This combined procedure was performed by Dr. Blatchford in an office-based room.
14. Dr. Blatchford is board-certified as a general surgeon, with specialty listings of General Surgery, Gastroenterology, and Bariatric Medicine on his Oklahoma Medical Board
profile. Dr. Blatchford holds no board certification in plastic surgery or any aesthetic surgical specialty and lists no hospital privileges at any hospital or facility on his Oklahoma Medical Board profile.
15. During the implant removal on February 19, 2025, Defendants caused real injury to Plaintiff by rupturing her left breast implant during extraction. Due to inadequate sedation, Plaintiff was conscious and acutely aware of the rupture and the pain associated with it.
16. At the conclusion of the procedure on February 19, 2025, Plaintiff's vital signs were abnormal, reflecting elevated blood pressure and an elevated heart rate. Plaintiff was discharged from the office without further evaluation or monitoring of these findings.
17. In the days following the February 19, 2025, procedure, Plaintiff developed progressive bilateral breast erythema, induration, pain, foul-smelling purulent drainage, and increasing systemic symptoms consistent with bilateral surgical site infection.
18. On February 21, 2025, Plaintiff presented to the Belle Medical clinic for her scheduled post-operative visit. Plaintiff reported soreness rated 9 out of 10. No changes were made to Plaintiff's treatment plan, and no follow-up appointment was scheduled at the conclusion of that visit.
19. In the days that followed, Plaintiff recorded and transmitted a video to the Belle Medical clinic, documenting the appearance of the wound, including dark brown purulent drainage with a foul odor. Plaintiff was told by clinic staff that the drainage was normal. No clinical evaluation was performed, and no changes were made to Plaintiff's treatment plan.
20. On February 26, 2025, as her symptoms worsened, Plaintiff returned to the Belle Medical office. Dr. Blatchford examined both breasts and found purulent fluid bilaterally, with greater involvement on the left side. Dr. Blatchford performed an in-office incision and drainage
(I&D) of both breasts without anesthesia and/or analgesia of any kind. A Saint Francis Hospital South nursing note dated March 1, 2025, documented that “surgeon drained breast fluid without any pain meds or anesthetic”.
21. Despite finding bilateral purulent fluid requiring surgical drainage, Dr. Blatchford discharged Plaintiff without directing her to seek emergency or inpatient evaluation. The Belle Medical chart note for the February 26 encounter characterized the wound findings as “early signs of infection.”
22. Plaintiff’s condition continued to deteriorate. On March 1, 2025, Plaintiff presented to the Saint Francis Hospital South Emergency Department with bilateral breast pain, purulent drainage, and systemic symptoms of infection, and was subsequently transferred to Saint Francis Hospital Main for inpatient admission.
23. The consulting plastic surgeon, who documented that both procedures had been performed by Dr. Blatchford in an office setting, recorded formal clinical impressions of bilateral mastitis, postoperative mastodynia, and failed autogenous fat grafting.
24. Plaintiff remained hospitalized for six days. At discharge, examination documented bilateral breast deflation, bilateral inframammary crease scarring and induration, and bilateral inframammary crease contraction.
25. As a direct and proximate result of the combined negligence of Defendants and their agents, employees, contractors, and/or servants, Plaintiff suffered severe and permanent injuries, impairments, and deformities, including but not limited to:
a. bilateral breast pocket infection with bilateral mastitis requiring inpatient hospitalization;
b. polymicrobial postoperative wound infection requiring intravenous antibiotic treatment and inpatient hospitalization;
c. complete failure of bilateral autogenous fat grafting, resulting in loss of the transferred fat and bilateral breast deflation;
d. bilateral breast disfigurement including bilateral inframammary scarring, induration, and crease contraction; and
e. persistent bilateral breast pain requiring narcotic analgesic management.
26. As a result of the combined negligence of Defendants, their agents, employees, contractors, and/or servants, Plaintiff suffered actual damages including, but not limited to, personal injury, bilateral breast disfigurement, past and future medical expenses, past and future physical and mental pain and suffering, loss of enjoyment of life, and other actual damages in excess of $75,000.00.
CAUSES OF ACTION
COUNT I
NEGLIGENCE
(AS TO ALL DEFENDANTS)
27. Paragraphs 1 through 26 above are incorporated herein by reference.
28. Defendants, and their agents and employees, owed a duty to Plaintiff to provide reasonable medical and surgical care and treatment, using the best judgment and applying, with ordinary care and diligence, the knowledge and skill possessed by other similarly situated providers in the medical community.
29. Defendants, and their agents and employees, breached the duty owed to Plaintiff, including but not limited to:
a. proceeding with a multi-procedure in a clinic without a licensed anesthesiologist or Certified Registered Nurse Anesthetist present after the contracted anesthesiologist failed to appear;
b. failing to obtain Plaintiff's informed consent for the material change in the anesthetic plan from a general anesthetic to ketamine sedation without licensed anesthesia coverage;
c. performing bilateral breast implant removal and bilateral autogenous fat grafting to the breasts as a general surgeon with no board certification in plastic surgery or any aesthetic surgical specialty and no hospital privileges;
d. failing to recognize and appropriately escalate bilateral surgical site infection when clinical findings – including bilateral purulence, foul odor, and worsening pain – were communicated by Plaintiff on or about February 21, 2025, and confirmed by direct examination on February 26, 2025;
e. performing an in-office bilateral incision and drainage of infected breast surgical sites on February 26, 2025, without anesthesia or analgesia;
f. failing to direct Plaintiff to seek emergency or inpatient evaluation when clinical findings on February 26, 2025, demonstrated established bilateral postoperative infection requiring surgical drainage in a patient who had failed outpatient antibiotic treatment; and
g. failing to maintain adequate sterile technique in an office-based surgical setting.
30. These breaches were the actual and proximate causes of Plaintiff’s injuries and damages.
31. Defendants are vicariously liable for the negligence of their employees and agents, including but not limited to Dr. Blatchford and DOES 1–10, pursuant to the legal doctrines of respondeat superior and/or ostensible agency.
32. As a result of the combined negligence of Defendants, their agents, employees, contractors, and/or servants, Plaintiff suffered actual damages including, but not limited to, personal injury, bilateral breast disfigurement, past and future medical expenses, past and future physical and mental pain and suffering, loss of enjoyment of life, and other actual damages in excess of $75,000.00.
COUNT II
NEGLIGENT HIRING, CREDENTIALING,
RETENTION, AND SUPERVISION
(AS TO DEFENDANTS BELLE MEDICAL, CHESTNUT WELLNESS, AND DOES 11–20)
33. Paragraphs 1 through 32 above are incorporated herein by reference.
34. Defendants Belle Medical, Chestnut Wellness, and DOES 11–20 each owed a direct duty to Plaintiff to appropriately credential, hire, train, and supervise their physician and medical staff agents/employees/contractors such that their physician and medical staff agents/employees/contractors would not cause injury or harm to Plaintiff, or any other persons in the community.
35. Defendants Belle Medical, Chestnut Wellness, and DOES 11–20 breached the duty owed to Plaintiff by credentialing, employing, contracting with, and/or retaining Dr. Blatchford to perform complex cosmetic breast procedures — including bilateral implant removal, bilateral autogenous fat grafting, and energy-based skin tightening — despite his credentials being limited to general surgery with no board certification in plastic surgery or any aesthetic surgical specialty and no hospital privileges, and by failing to establish or enforce adequate credentialing standards for providers performing invasive cosmetic breast and body contouring procedures in an office-based setting
36. These breaches were the actual and proximate causes of Plaintiff’s injuries and damages.
37. As a result of the combined negligence of Defendants, their agents, employees, contractors, and/or servants, Plaintiff suffered actual damages including, but not limited to, personal injury, bilateral breast disfigurement, past and future medical expenses, past and future physical and mental pain and suffering, loss of enjoyment of life, and other actual damages in excess of $75,000.00.
COUNT III
NEGLIGENT/INTENTIONAL MISREPRESENTATION
(AS TO ALL DEFENDANTS)
38. Paragraphs 1 through 37 above are incorporated herein by reference.
39. Defendants Belle Medical, Chestnut Wellness, and Dr. Blatchford, individually and collectively, made material misrepresentations to Plaintiff regarding Dr. Blatchford’s qualifications and credentials, including but not limited to representing and marketing him as a “Cosmetic Surgeon” and as qualified to perform the procedures sought by Plaintiff.
40. Defendants made these representations intentionally and/or without reasonable grounds to believe them to be true, in that Dr. Blatchford is a general surgeon with no board certification in plastic surgery or any aesthetic surgical specialty and no listed hospital privileges – and therefore did not hold the credentials of a cosmetic surgeon as represented.
41. Plaintiff justifiably relied on these representations in selecting Belle Medical and Dr. Blatchford to perform her surgical procedures, and in consenting to procedures she believed would be performed by a credentialed cosmetic surgery specialist.
42. As a direct and proximate result of Defendants’ misrepresentations, Plaintiff underwent procedures performed by a surgeon unqualified by training or credentials to perform them and suffered the injuries and damages described herein.
43. As a result of the intentional and/or negligent misrepresentations of Defendants Belle Medical, Chestnut Wellness, and Dr. Blatchford, Plaintiff suffered actual damages including, but not limited to, personal injury, bilateral breast disfigurement, past and future medical expenses, past and future physical and mental pain and suffering, loss of enjoyment of life, and other actual damages in excess of $75,000.00.
COUNT IV
JOINT VENTURE
(AS TO ALL DEFENDANTS)
44. Paragraphs 1 through 43 above are incorporated herein by reference.
45. Upon information and belief that will be confirmed through discovery, Defendants had a joint interest in the proceeds from Plaintiff's care.
46. Upon information and belief that will be confirmed through discovery, Defendants had an express or implied agreement to share the proceeds from Plaintiff's care.
47. Upon information and belief that will be confirmed through discovery, Defendants' conduct demonstrates cooperation towards a joint venture.
48. As a proximate result of Defendants' failures arising from their joint venture, Plaintiff suffered actual damages including, but not limited to, personal injury, bilateral breast disfigurement, past and future medical expenses, past and future physical and mental pain and suffering, loss of enjoyment of life, and other actual damages in excess of $75,000.00.
COUNT V
PUNITIVE DAMAGES
(AS TO ALL DEFENDANTS)
49. Paragraphs 1 through 48 above are incorporated herein by reference.
50. The conduct of Defendants, and their agents and employees, in performing a multi-hour combined cosmetic surgical procedure without licensed anesthesia coverage; in performing complex cosmetic breast surgery using a surgeon without plastic surgery training or credentials while misrepresenting his qualifications to the public; in performing complex cosmetic breast surgery in an office-setting; in failing to appropriately recognize and escalate a known and documented bilateral postoperative wound infection over the course of multiple days; and in performing a bilateral incision and drainage without anesthesia or analgesia – was intentional, reckless, and demonstrated a conscious and deliberate disregard for the health, safety, and rights of Plaintiff.
51. The acts and omissions of Defendants were wrongful, culpable, and so egregious that punitive damages in a sum that exceeds Seventy-Five Thousand Dollars ($75,000.00) should be awarded against Defendants to set an example to others similarly situated that such conduct will not be tolerated in our community.
WHEREFORE, based on the foregoing, Plaintiff prays that this Court grant her the relief sought, including but not limited to actual damages in excess of $75,000.00, punitive damages in excess of $75,000.00, costs, attorney fees, and such other relief as the Court deems just and equitable.
Respectfully submitted,
SMOLEN | LAW, PLLC
[Signature]
Donald E. Smolen, II, OBA #19944
Lance Freije, OBA #18559
SMOLEN LAW, PLLC
611 S. Detroit Ave.
Tulsa, OK 74120
P: (918) 777-4LAW (4529)
F: (918) 890-4529
[email protected]
[email protected]
Attorneys for Plaintiff
