Plaintiff alleged injuries in connection with the developing and worsening of heel ulcers. With expert support, Jaclyn established the facility’s compliance with the standard of care as well as plaintiff’s non-compliance and ability to independently reposition themselves while in bed. Plaintiff filed a separate motion for summary judgment based on testimony from a previous case. The Court granted summary judgment to the defense and denied plaintiff’s motion in its entirely finding an absence of any credible arguments to raise an issue of fact.