Saba emphasized that the childcare center failed to provide the necessary level of care and urgent, transparent communication required for a serious medical emergency.
Medical examinations later that morning at a Torrance hospital revealed the boy suffered a concussion, blunt head trauma, and facial abrasions.
Physicians noted these injuries were inconsistent with a low-altitude fall.
The complaint notes that the toddler continues to experience persistent neurological symptoms alongside severe hearing loss.
Representatives from the upscale fitness chain declined to provide specific details regarding the case, citing company policies on active legal proceedings.
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"At the Bay Club, the safety of our members, team members, and the families we serve is our highest priority," said a spokesperson for The Bay Club in an official statement.