[vc_row][vc_column][vc_column_text]On Tuesday, June 11, students at Tampa’s Middleton High School were engaged in after-school football drills when 14-year-old Hezekiah Walters suddenly collapsed. Coaches quickly called 911, and he was taken to a local hospital, where he was sadly pronounced dead.
Walters collapsed about 30 minutes into an outdoor practice that included weightlifting and wind sprints. Medical examiners are still determining his cause of death, but heat stroke and exertion-related heart attacks caused 9 out of 13 football-related deaths in 2017.
“We are devastated by the death of one of our students,” said Tanya Arja, a spokesperson for the county’s public schools. “This student was an amazing young man who was loved by his friends, teachers and staff at school.”
It’s not clear from initial media reports whether an AED (automated external defibrillator) was deployed, or attempted to be deployed. AEDs are used to shock the heart when it is in defibrillation, or in other words, when it is in cardiac arrest and not beating properly. In Florida, all public schools are required to have an AED, and it’s a good safety precaution to have a mobile AED nearby any time students are exercising.
If the school did not have an AED, or if an AED was not retrieved or attempted to be used, or if the AED had malfunctioned, there may be a liability case against the school for wrongful death.
Florida Schools Need to “Get the Message”: Have an AED on Hand At All Times!
We have litigated dozens of cases against schools, hospitals, sporting facilities, and other public places for negligence in not having or not using an AED when a victim on premises suddenly succumbs to sudden cardiac arrest. The laws in Florida are nuanced, and this type of litigation is very difficult. That is why it is important to hire an experienced attorney in this area of law.
Experts say having an AED (defibrillator) on hand at athletic facilities can help save a life if an athlete experiences a sudden cardiac arrest, as paramedics may not arrive in time.[/vc_column_text][/vc_column][/vc_row]
Brian Smart, 24, a high school athletic trainer who trained and mentored young athletes, tragically died on Sunday, May 5, when he suffered a cardiac arrest during the Philadelphia 10-Mile Broad Street Race.
Smart worked as an athletic trainer at the Darby Street School District. Coworkers say he was in excellent shape, and the heart attack was completely unexpected.
“He was in great shape, was running at a good pace for the Broad Street Run. He wasn’t showing any signs of any laboring, from what I was told. Just a shock,” Frank Nunan, athletic director of the Upper Darby School District, told a local news station. The school district also put out a statement saying that Smart was beloved by students.
Smart’s father also issued a statement through the school district, noting his son’s passion for teaching and working with students: “The world certainly lost a good one yesterday. Brian really enjoyed working in UD, working with you and the students of Upper Darby.”
Sudden cardiac arrest is often surprising when it happens to someone young and athletic, like Smart. However, it can happen to anyone at any time. The last person to die in the Broad Street Race was a 29-year-old athlete who collapsed shortly after crossing the finish line in 2007. Having an AED defibrillator on hand at races can save a person’s life in the event of a cardiac arrest. If the race organizers were negligent in preparing for possible medical emergencies, Smart’s family may have a legal case for wrongful death.
Introduction to this Developing Area of Civil Litigation
In 1990, the American Heart Association challenged the medical device industry to develop a state of the art AED capable of being used by virtually anyone. The industry responded in a timely manner, leading to significant advances in AED technology in the last three decades. Manufacturers such as Cardiac Science, Medtronic, Zoll, Hewlett-Packard, and many others have produced lightweight, affordable AEDs for use in a variety of public and private settings.
In an article dated August 5, 1996, the Wall Street Journal stated: “Now, a new wave of small, portable defibrillators is being developed…Manufacturers even envision a day when the devices, technically known as automatic external defibrillators…will be as common as fire extinguishers.” Since this article was published more than twenty years ago, AEDs have become more and more common in gyms, sports facilities, restaurants, airports, and a vast number of other public venues.
It appears that the Wall Street Journal’s prediction was right. With the increasing popularity of these devices, the standard of care has developed to the point that both common law and statutory regulation are beginning to require that AEDs are present in a variety of public places across the United States.
The Medical Problem: Sudden Cardiac Arrest
According to the Sudden Cardiac Arrest Association, sudden cardiac arrest is the leading cause of death in the United States, killing over 320,000 Americans each year.[ii] Sudden cardiac arrest kills more people than breast cancer, lung cancer, and HIV/AIDS combined. Use of an AED device is appropriate when sudden cardiac arrest occurs, which is an electrical malfunction of the heart that triggers a fatally abnormal heart rhythm or a complete stoppage of electrical activity.
A study conducted in 2010 estimated that only 8% of those who suffer an out-of-hospital sudden cardiac arrest will survive the event. However, medical studies indicate that a large percentage of these individuals could be saved by the timely application of an AED to restart the heart. Although there are several different causes and types of electric failure, timely defibrillation will result in saving the victim’s life in a variety of situations.
The Cost of AEDs has Significantly Decreased and AEDs are Easy to Use
Once costing more than $3,000, AEDs now cost as little as a third or less, due to competition in the marketplace and emerging technologies. Because of simple human body diagrams (which are located on the pads to be placed on the body) and the use of voice prompts with the current AED models, these devices are so easy to use that recent medical studies show that children as young as sixth graders can use them. Current AED models even administer the “shock” without human intervention or having to push a button when a shock is indicated. Consequently, user error is extremely unlikely.
The Federal Government and All 50 States Have Enacted Laws Relating to AEDs and AED Usage
AEDs are required in airports
Under federal laws, federal buildings and all large commercial airplanes must have AEDs. All airports under FAA jurisdiction must also have AEDs. In fact, one of the first studies of public defibrillation’s effectiveness was conducted in Chicago’s O’Hare Airport. First published in 2002, this study supported the effectiveness of AED use in saving lives.
The Cardiac Arrest Survival Act, passed in 2000, established some of the first national standards for Good Samaritan Protection, which protects lay users of AEDs from civil liability. As of 2001, all fifty states had enacted state statutes or adopted regulations in this area of law. Every state has its own Good Samaritan Act and its own body of appellate law regarding duty, breach, and causation. In fact, in 41 of 50 states, (more than 80% of state jurisdictions), untrained lay rescuers are protected from civil action in the majority of circumstances.
Laws typically focus on where AEDs are required, guidelines for their maintenance and use, and protection for lay users and business owners. Under state laws, AEDs are often required in businesses, including common carriers, innkeepers (hotels), commercial businesses, and doctors’ offices. Even where they are not required, forensic experts may testify that the common law has developed so that a business should have had an AED despite the lack of a law requiring that business to do so.
Recent Trends in Legislative Activity in the 50 States
In 2015-2016, state legislators across the United States increased their focus on the requirement of having AEDs at primary and secondary school athletic activities, including games off school property. Louisiana, Massachusetts, Maine, Rhode Island, and Washington, DC enacted such laws during this time period.
What are the Common Fact Patterns, and is the Public Aware of this Area of Litigation?
There are several common fact patterns in these types of cases. However, in this author’s experience, three scenarios are the most common:
The first scenario is where no AED was present at the premises. The plaintiff may allege that there should have been an AED present under a common law duty. However, absent a statutory requirement, the case where there is no AED present is a very difficult case, as juries do not want to penalize businesses for not having a device if it was not required by law.
The second scenario is where an AED was present at the premises but the employees/staff did not know where it was or were improperly trained in its use. These cases are often successful, because a life saving device was purchased, was available, and was simply not used or not used correctly.
The third common scenario is where an AED malfunctioned, the battery was dead, or some other failure to maintain the device occurred. In these situations, the family of the deceased might become aware of potential liability because the failure is evident at the scene.
In general, the public does not usually think “lawsuit” when a loved one dies of sudden cardiac arrest. However, the question of “did they have an AED?” is now becoming more common when a person dies in a public place. In addition, public information campaigns by AED manufacturers, lawyers, and organizations such as the American Heart Association have increased the public’s awareness of the need for AEDs in public places.
The Elements of Civil Litigation: Duty, Breach, Causation, and Damages
Duty and Breach: Even absent a requirement under statute or ordinance, experts in the standard of care will often testify that an AED should have been present at certain public places, thus allowing the plaintiff’s attorney to defeat summary judgment or a motion to dismiss on the issue of duty. The battle usually involves the duty established by the Restatement of Torts, Section 324, which addresses the applicable duty in emergency situations.
Causation: Does the Medical Research Support Causation and Prevent-ability of Death? Whether timely use of an AED would have saved the victim is typically the area of greatest debate in litigation. Studies by the American Heart Association have long supported the premise that for every minute of delay in getting a person with a “shockable rhythm” adequate defibrillation, their chance of survival decreases by 7-10%. Thus, after about five minutes, the person’s chance of survival becomes less than 50%. According to the Florida Department of Health, the average EMS response time is nearly eleven minutes.
However, after ten minutes have elapsed from the moment of the sudden cardiac arrest, the patient has a less than afive percent chance of survival. Thus, survivability and prevent-ability of death is usually not difficult to prove through expert testimony from a qualified cardiologist. Cardiologists, electrophysiologists, and forensic pathologists can thus support, through medical evidence, an opinion that if an AED had been used on the right type of sudden cardiac arrest patient, then the patient could have been saved. For causation purposes, a timeline of events must be established.
In most cases, local EMS arrives at the scene within about ten minutes and administers their own defibrillator, which analyzes the victim’s heart rhythm. The EMS report will contain an EKG reading, which the plaintiff’s expert can then use to see if the particular heart rhythm was one that an AED could have successfully shocked back to normalcy. This EMS report can also establish the exact delay caused by the premises’ failure to have an AED or the failure to use the AED that was on the premises.
Once the precise time of the person’s cardiac arrest is established through witness testimony, the plaintiff can then establish how quickly the person could have been saved if an AED would have been immediately available. In addition, in most cases the dying person is taken to the hospital where another EKG is performed. These EKG strips can also identify the specific type of electrical disturbance, further assisting the expert(s) in their evaluation.
Damages: Most cases involving cardiac arrest involve either death or some sort of neurological injury caused by lack of blood flow to the brain. Thus, the damages in these cases are always significant. The author of this article has handled cases of victims ranging from ages 11 to those in their 90s.
Emerging Trends in AED legislation and civil litigation
In 1997, Lufthansa paid the first judgment in this area of law, after a federal judge awarded $2.4 million dollars to the plaintiff, who successfully argued, among other theories of liability, the failure of the defendant to have an AED on one of its airplanes.
After the Lufthansa case, litigation in this area of law has now become common, either for the failure of a premises owner to have an AED when required (under common law, state statute, or municipal/county ordinance), the negligent failure to properly find or use an AED when it is already present on the premises, or for a defect or malfunction in the device itself. Recent cases involving the deaths of individuals on airplanes, the deaths of Tim Russert, Michael Jackson, Carrie Fisher, and the deaths of professional athletes, have brought this area of law to the forefront in the last decade.
For a comparison of each state’s law, go to the National Conference of State Legislature’s website, which has a page where you can see each state’s Good Samaritan Act and its subsection regarding AEDs.
What is the future in this area of law?
The author of this article publicizes this area of law in publications, lectures, and through public information campaigns in the form of lectures to condominiums, gyms, and various other organizations to promote the purchase of these life-saving devices. By encouraging the widespread use of AEDs to save lives, we can all help establish a standard of care that encourages AED use in a variety of settings, while maintaining common sense liability protection for lay users.
Hopefully, in time the Wall Street Journal article from 1996 will ring true and AEDs will become as common as fire extinguishers.
[vc_row][vc_column][vc_column_text]A West Virginia family is grieving the loss of their previous 8 year-old boy, Caleb Ray, after he suddenly collapsed on a soccer field in Lincoln County. The father was there by his side within seconds, and CPR was administered while the ambulance rushed to the scene. Unfortunately, Caleb could not be saved. The family has been quoted as believing that the cause of death was Sudden Cardiac Arrest (SCA).
The boy’s surviving parents describe the scene of the incident as being on a soccer field. Young Caleb was just starting the first practice session of his soccer season. Though the details have not been released, it appears that he had joined a little league team, and may have been on the premises owned either by the city, or a youth athletic organization.
It also appears there was no Automated External Defibrillator (or “AED”) present. These life-saving devices counter-act sudden cardiac arrest by delivering a shock to the heart that normalizes heart rhythms.
Why there may be a potential liability case
There maybe a potential liability case against the owner(s) of the field that the incident occurred on for not having an AED present. West Virginia state laws dictate how and when AEDs should be present and used. A theory of liability may lie in the statute.
West Virgina does have a Good Samaritan law, but that may only apply in situations in which an AED is used. Further, it is unclear on first reading of WV laws what facilities or organizations may by required to have an AED on site. If an AED was required, and one was not present when Caleb experienced SCA, the owners and/or managers of the property on which the incident occurred may be held liability.
The family is doing the right thing
The surviving parents are doing the right thing by advocating for the widespread adoption of AEDs. With an AED present, the chances for survival for a victim of SCA tops 90% when used within three minutes of the onset of the sudden attack.
The family has received donations to help buy AEDs to be present at youth sports games.
It is imperative that the family seek legal advice from an experienced law firm in this area of law. These consultations are completely confidential and free.
As the founder of the Law Offices of Craig Goldenfarb, P.A., Mr. Goldenfarb manages the daily operations of all of the many departments of the law firm.
Craig M. Goldenfarb, Esq. has been practicing personal injury law, and specifically, AED litigation, for almost 20 years.
Mr. Goldenfarb is the former Chairperson of the AED Litigation Committee of the American Association of Justice (AAJ), a nationally recognized civil trial lawyers group.
Mr. Goldenfarb has represented dozens of families of victims of Sudden Cardiac Arrest in wrongful death litigation for incidents in which fatal SCA occurs and there is no AED available, or the AED malfunctions.
He is also the founder of Heart of the Game, a national 501(c)(3) non-profit dedicated to providing free AEDs and emergency medical training to recreational youth sports programs.[/vc_column_text][/vc_column][/vc_row]
The family of a young man is seeking answers in the sudden death of their 14-year old boy, Kamarr Scott, while on school property.
News reports say that the young man was participating in P.E. class at Somerset Academy Village, a public charter school in Wilton Manors.
The young man had apparently been doing laps around the track field when he collapsed without warning. He was rushed off to the hospital, where he later died. The family says he has no history of poor health, and that Kamarr was a sweet, loving child.
The circumstances surrounding what happened to Kamarr seem to indicate that he died of Sudden Cardiac Arrest (SCA), a condition in which the heart suddenly stops functioning correctly. SCA can quickly lead to permanent brain damage, or worse, in a very short amount of time if not quickly reversed with an AED.
Could an AED have saved Kamarr’s life, and was an AED used by school staff?
Somerset Academy may have been required to keep an AED (automated external defibrillator) on school premises at all times. Further, the school may have been subject to laws which extend a “duty of care” to the teachers and staff.
That means that if an AED was not present on campus grounds, or if it was present but was not used on Kamar as we experienced SCA, the family may have a Wrongful Death claim against the school.
Often, AED’s are required to be present in places like public schools, including public charter schools, but aren’t always functional, or they aren’t always used. That may create liability on the part of the school and staff for the negligent death of a child due to SCA.
Whether or not a case exists in any particular situation is the responsibility of a personal injury law firm with experience in AED law and heart attacks in public places to figure out.
Consultations for matters similar to the unfortunate circumstances of young Kamarr are free and confidential for surviving family members of children who died due to SCA, or an AED not being used.
If you or someone you know has lost a child on school property due to SCA, please give our law firm a call as soon as possible to find out if we can help.
A Jacksonville, Florida high school sophomore has died from what doctors are calling sudden cardiac arrest (SCA) while he was working out in the weight room of Fleming Island High School. Ben Johnson was a beloved football and basketball player, and a highly respected student, according to the outpouring of love on the school’s social media pages.
Officials say he “suddenly collapsed” and went unconscious. It is not clear from reports whether he was alone or in the company of others at that time, and it’s also not clear if an automated external defibrillator (AED) was present, or whether an attempt was made to administer a life-saving shock from the device.
Could the death of Ben Johnson have been prevented?
Ben Johnson’s death highlights the importance for public schools to be well aware and trained on the issue of sudden cardiac arrest among student athletes.
In Florida, an AED is required to be present in school facilities, however, there is no explicit duty to use an AED to save a student’s life. But that’s beginning to change with current case law. A court recently ruled in the Limones case, in which a young student athlete in Miami died from SCA because no one bothered to use an AED that was present, that a duty to use the AED does exists when there is a special relationship in place, such as the relationship between a school district employee and a student.
Because Fleming Island High School is a public high school, and AED must have been present on campus somewhere. Was it present in the weight room? And if not, should there have been one present?
Another potential act of negligence among the school’s staff could be the inability or unwillingness of pre-participating testing for student athletes. An EKG test, for example, if performed on Mr. Johnson and other student athletes, possibly could have detected an abnormality in his heart rhythms.
Wrongful death claims in Florida and AED use
Wrongful death claims relating to the loss of a student athlete’s life while on campus grounds is a new and growing area of personal injury law in Florida, and across the country. Instances of SCA-related deaths among student athletes is become more prevalent, and pressure is increasing to hold staff and the school district responsible when a young man or woman dies from SCA on campus.
Wrongful death laws in Florida allow surviving family members to make a claim for the loss of a loved one due to the negligence of another (in this case, the potential negligence of the Clay County School District.) But these are complicated areas of law, so hiring an experienced lawyer with a reputation and history of winning these cases is extremely important.
Our law firm represents families who have lost loved one’s due to SCA on public grounds, such as a high school. Give our firm a call for a free consultation with an experienced and caring attorney.
When a young student athlete collapses and dies from an unknown medical condition, it is a shock to their family, friends, the athletic staff and fellow teammates, and the community at large. And sadly, it is becoming more familiar.
About 1 in 90 student athletes in the U.S. will suffer from Sudden Cardiac Arrest during a period of invigorating exercise, such as football practice.
This week, another young, promising athlete collapsed and died possibly due to an unknown and potentially undiagnosed heart condition on the Stetson University football field in Deland, Florida. He was 19-year old football player Nick Blakely.
The Importance of Heart Screenings and Whether Stetson University Conducts Them
Sudden Cardiac Arrest is, by definition, difficult to predict, but there are measures universities and athletic programs can and should be taken to protect their students, such as health screenings that include baseline heart exams.
It may be the responsibility of the university to ensure that these baseline heart exams and screenings were performed to help identify any potential heart risks or conditions among it’s varsity student body. Whether those screenings were performed on Mr. Blakely prior to him joining the Stetson University’s football team is unknown, and that should be investigated by a personal injury law firm.
Why Hire a Personal Injury Law Firm?
Where there is potential negligence that results in the death of a loved one, there may be Wrongful Death claim made under the law of the state of Florida. Universities are not exempt from their obligation to adhere to measures that reduce the risk of injury or death to their students, and those on their university grounds.
But personal injury claims as they relate to the sudden cardiac death are particularly difficult cases to prove, so it is important that if you are going to hire a lawyer, that you hire a lawyer with years’ of sufficient experience and knowledge in this area of law, known as Heart Attacks in Public Places.
If there was a negligent action that lead to the untimely death of Nick Blakely, such as lax health screenings, or a lack of a standardized heart examination process for all student athletes, there may be a personal injury claim, if in fact Mr. Blakely’s death is determined to be due to sudden cardiac arrest.
If you or someone you know lost a loved one due to sudden cardiac arrest at a public place such as a university or school, please contact our law firm for a free legal consultation.
Gwinnett County teen Michael Jones passed away on the morning of Saturday, July 29th, 2017 on a soccer field in Duluth, GA. Jones was reportedly playing in a scrimmage game with his recreational soccer team when he suddenly collapsed due to cardiac arrest.
At least one coach from the Atlanta Fire United Club, the club that organized the game Jones was playing in, apparently attempted CPR to resuscitate Jones. An ambulance arrived, but it’s not clear from media reports when Jones was pronounced dead.
CPR can help, but far more effective in saving the lives of teens who collapse during recreation sports is the use of an AED. Some states require that AEDs be present during recreational sporting events. The Jones’ family should be asking: was there an automated external defibrillator (AED) available when Michael collapsed, and if not, why?
An AED could have saved Michael Jones’ life
AEDs save the lives of people undergoing a cardiac arrest by shocking the heart back into a normal pulmonary rhythm. If used within three minutes of the onset of the cardiac arrest, the survival rate can be as high as 90%.
As a personal injury law firm that specializes in cases involving AEDs and sudden cardiac arrest, we often ask in these situations: why wasn’t an AED present? And if an AED was present, what wasn’t it used on Michael Jones?
Student athletes suddenly collapsing while in practice, or a game, or in scrimmage is becoming increasingly common place throughout the country. Not all students who experience it die; many are saved by the use of AEDs.
Jones was just about to begin his junior year of high school when we died. He was a member of Atlanta Fire United Soccer Club, self-described on the club’s website as the largest non-profit soccer club in the state of Georgia. Atlanta United Fire offers soccer programs to more than 3,760 children and more than 200 adults annually.
For a recreational soccer club of that size, it would be a stunning revelation if it turns out that the organization did not provide portable AEDs to their coaches and players, on site, on the sidelines of the fields. AEDs cost only about $1,000, and have been scientifically proven to save the lives of children, teens, and adults who experience sudden cardiac arrest.
The family of Gwinnett County teen Michael Jones deserves to know why an AED was not available to save the life of the promising young high schooler. That may only be discovered if and when the family hires a personal injury law firm to investigate the incident.
Craig Goldenfarb, Esq. has been handling cases involving sudden cardiac arrest and AEDs for twenty years, which is a highly specialized area of law.
Nearly 300,000 Americans collapse each year when their hearts stop pumping in a normal rhythm. Without immediate medical attention, they are at risk of death from cardiac arrest. Automated external defibrillators (AED’s) are portable devices used to treat heart arrhythmia by shocking the heart back into a normal rhythm. An AED offers the best chance of survival after a heart attack. However, malfunctioning AEDs can cost lives rather than saving them.
Between 2005 and 2010, the Food and Drug Administration (FDA) received more than 28,000 reports of malfunctioning defibrillators and 68 AED recalls were issued.
How does the FDA receive these reports and how are recalls issued?
The Safe Medical Devices Act is a federal law that was enacted in 1990. The SMDA was an update to the Federal Food, Drug and Cosmetic Act, which had not been modified since 1976. Before 1990, there was no way for the government to track defective medical devices that could potentially cause injury.
The SMDA requires health-care professionals to report deaths or injuries that may be related to a particular medical device to the Food and Drug Administration (FDA). Adverse events must be reported even if the doctor is uncertain that the product caused the event. Reports are made through a medical reporting program called MEDWATCH. The FDA must follow up on all reports of medical device malfunctions and issue a recall if there is a risk of injury from the device.
Consumers may also make a report on the MedWatch website or by calling 1-800-FDA-1088.
If you have lost a loved one because of a malfunctioning AED, an AED lawsuit may bring accountability for your loss. West Palm Beach heart attack injury attorney Craig Goldenfarb has led the efforts to improve AED safety and save lives.
Significant advances in AED technology during the last 20 years have led to a new wave of small, portable defibrillators being developed.
A Wall Street Journal article in 1996 stated, in part, that manufacturers of these automatic external defibrillators envision a day not far off when AEDs will be as common as fire extinguishers. With the increasing popularity of these devices, the standard of care has developed to the point that both common law and statutory regulation are beginning to demand that AEDs are present in a variety of public places.
According to the American Red Cross, more than 300,000 Americans die each year of cardiac arrest. The medical studies indicate that a large percentage of these individuals could be saved by the timely application of an AED to restart the heart. The AED device is appropriate for the occurrence of a “sudden cardiac arrest,” which is an electrical malfunction of the heart that triggers a fatally abnormal heart rhythm.
AEDs now cost as little as $1,000 and are so easy to use that even children can use them by following diagrams and voice prompts on the new AED models.
Lawsuits have now become common, either for the failure of premises owners to have AEDs when required by law, or in the negligent failure to properly find or use an AED when it is already on the premises.
Recent cases involving the deaths of individuals on airplanes, the death of Tim Russert, Michael Jackson, and the deaths of professional athletes have prompted the establishment of Good Samaritan laws in all 50 states.
Who must have AEDs?
Federal buildings
Certain commercial airplanes, and others may be required
Common carriers
Hotels
Commercial businesses
Doctors’ offices
West Palm Beach attorney Craig Goldenfarb has handled many cases where compensation has been awarded to the families of the deceased for either not having an AED present at the premises, for employees/staff not knowing where the AED was located, or not having someone properly trained to use it. Goldenfarb lectures nationally to condominiums, gyms, and various other organizations, to promote the purchase of these life-saving devices. By encouraging the widespread use of AEDs to save lives, we can all help establish a standard of care that encourages AED use n a variety of settings.
Craig Goldenfarb has been chairperson of the American Association for Justice’s AED Litigation Group since 2009. Contact him for a free evaluation of your case to determine if you are entitled to compensation for the loss of a loved one whose life might have been saved by the use of an AED.
Order Goldenfarb’s free book, What the Insurance Companies Don’t Want You to Know.
