The mother presented to the local area hospital for the birth of her daughter. During the delivery, a shoulder dystocia was encountered, and maneuvers were made by the obstetrician to free the impacted shoulder and to deliver the baby. She was born with a brachial plexus injury. Plaintiff alleged that excessive traction was used to free the impacted right shoulder which resulted in the brachial plexus injury in her right arm. The child has a permanent injury in her right arm which affects her activities of daily living. Nicholas T. Motherway represented the plaintiffs. The case was filed in DuPage County.