The death of a mother and her unborn infant resulted in lawsuits under COBRA against a number of defendants. In addition, there were numerous state law claims made by P. P represented four parties in the action with some in Georgia and the others in Alabama. (Surviving spouse, sole surviving parent of the unborn infant, administrator of the estate of Paulette Palmer, and as personal representative of the next friend of the unborn infant. One of the defendants was a doctor, Bates, who was eventually dismissed from the case because it was ultimately determined that COBRA did not apply to doctors. P appealed that decision claiming that the trial court still held supplemental jurisdiction over the doctor for the state law claims.

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