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N re Westchester County Medical Center, 72 N.Y.2d 517 (1988). In that case the Court established the need for clear and convincing evidence of a patient s wishes and stated that the ideal situation is one in which the patient s wishes were expressed in some form of writing, perhaps a living will. PRINT YOUR NAME I, , being of sound mind, make this statement as a directive to be followed if I become permanently unable to parti.

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