some form of systemic negligence by the hospital, and is not simply a vicarious theory of liability based on the negligence of its employees. See Edwards v. Brandywine Hosp., 438 Pa.Super. 673, 652 A.2d 1382, 1386-87 (1995). 1. Robert Stroud Adequately Pled Corporate Negligence Hospital’s first challenge to Robert Stroud’s Second Amended Complaint is that it fails to state a claim for corporate negligence against Hospital. (Doc. 69 at 6.) Relying on Pennsylvania Superior Court precedent, Hospital argues that Plaintiff has failed to adequately plead that it knew or reasonably should have known of the alleged failings in its patient care procedures upon which Plaintiffs corporate negligence claim is based. See Kennedy v. Butler Mem’l Hosp., 901 A.2d 1042, 1046 (Pa.Super.2006) (<HOLDING>). (Doc. 69 at 7.) Plaintiff counters that he
holding that a fraudulent transfer claim against a corporate debtors control person belongs to the corporate debtor not to specific creditors holding that the general corporate laws are incorporated into the corporate charter holding that a complaint against a hospital containing averments that appear to meld the two causes of action for vicarious liability and corporate negligence with no averment pertaining to the hospitals knowledge  fails to state a claim of corporate negligence holding that the basis of liability is negligence and not injury holding that ordinary negligence and gross negligence are not separate causes of action