OAKLAND (CBS SF) — The family of an Oakland teenager who was declared brain-dead plans to file a lawsuit Tuesday against UCSF Benioff Children’s Hospital Oakland with new details about the allegedly botched surgery.

The Oakland Tribune reports the 12-page complaint, which seeks unspecified damages, documents the family’s hours following 13-year-old Jahi McMath’s surgery. It details the loss of at least 2 pints of blood, her heart attack, a doctor arriving hours later and the hospital’s plans to shut off the machines to harvest her organs.

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“If you read the medical records, it’s just a pretty cavalier approach to the whole thing,” the family’s attorney, Bruce Brusavich, a Southern California medical malpractice attorney told the Oakland Tribune.

For the first time, the lawsuit provides the family’s account of what happened after Jahi underwent a tonsillectomy and tissue removal at Children’s Hospital in Oakland in December 2013 to treat sleep apnea.

The girl suffered massive bleeding, had a heart attack and was declared brain-dead Dec. 12.

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The family says it all could have been prevented. They blame hospital staff for performing a dangerous surgery, lacking communication with each other and putting pressure on the family to pull Jahi off life support.

Her family battled to keep her on a ventilator and to have breathing and feeding tubes surgically inserted. Under a court agreement, the family and the hospital agreed that Jahi’s mother, Nailah Winkfield, could remove her from the hospital if she took responsibility for the girl’s care.

Over year later, Jahi remains on a ventilator and hooked to feeding tubes at a New Jersey apartment, and her case has ignited a debate over the definition of brain death.

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Officials from the hospital, aside from earlier court declarations, have not commented because the family would not release them from federal patient confidentiality laws.