Interrogatories 4 - plaintiffs answers to defendants interrogatories in med mal suit

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Plaintiffs' Answers to Defendant, Eileen Murphy, M.D.'s, Interrogatories

Dudley & Lake LLC, 100 E. Cook Avenue, 2nd Floor, Libertyville, IL 60048.

1. Please identify the person answering those Interrogatories.

ANSWER: Debra White 1447 S. Clark Street Chicago, IL 60602

2. Identify the minor plaintiff and state all residences of the minor plaintiff from birth to present.

ANSWER: Payton White 1447 S. Clark Street Chicago, IL 60602

3. List all witnesses and persons with knowledge of relevant facts.

ANSWER: Charles White 1447 S.Clark Street Chicago, IL 60602

Eileen A. Murphy, M.D. 333 E. Superior Street Suite 454 Chicago, IL 60611

Melvyn A. Bayly, Jr., M.D. Nita S. Karnik, M.D. 333 E. Superior Street Suite 454 Chicago, IL 60611

Euguene Pergament, M.D. Kristin DeMarco, MS Northwestern Medical Faculty Foundation, Inc. Dept. of Obstetrics & Gynecology 333 E. Superior St. Prentice Pavilion, Ste. 1521 Chicago, IL 60611

Investigation continues.

4. Identify all witnesses and persons with knowledge of relevant facts.

ANSWER: See Answer to Interrogatory #3 above.

5. Identify all witnesses who will be called at trial.

ANSWER: Disclosures will be made in accord with court order.

6. Identify all statements of witnesses, whether in writing, recorded or verbal, and attach a copy of all written statements.

ANSWER: Those that may be construed as statements in the medical records.

7. Describe the injuries claimed to have been suffered by the minor plaintiff as a result of the treatment of incident alleged in the complaint.

ANSWER: Cerebral palsy

Seizures

Brain damage

Investigation continues.

8. Identify each health care provider who was consulted and/or rendered treatment to the minor plaintiff regarding injuries claimed to have been suffered as a result of the facts, treatment or incident alleged in the complaint, including the dates of treatment or contact, an itemization of the charges rendered by each health care provider, and whether the charges have been paid and by whom.

ANSWER: Karen L. Wilson, M.D. 1030 N. Clark Street, #400 Chicago, IL 60610

David G. Ritacco, M.D. Children's Memorial Hospital Division of Pediatric Neurology 2300 Children's Plaza Box 51 Chicago, IL 60614-3394 9/24/01-10/15/02

Michael G. Chez, M.D. Wayne Langburt, M.D. Pediatric Neurology, S.C. 40 E. Scranton Lake Bluff, IL 60044 10/21-11/29/02

Northwestern Memorial Hospital 251 E. Huron Street Chicago, IL 60611-2908 8/6/01-8/15/01

Northwestern Memorial Hospital Developmental Evaluation Clinic Deborah Gaebler-Spira, M.D. Phyllis Ladd, L.C.S.W. Elizabeth Overland, PT 251 E. Huron St. Chicago, IL 60611-2908

Rehabilitation Links Angela Searcy, M.S. Laurel Malibiran, P.T.

Fetima R. Davis, OTR/L 1431 Huntington Drive Calumet City, IL 60409-5465 11/19/01-4/23/02

Dr. Shaun Centers Osteopathic Center for Children 4135 54th Place San Diego, CA 92105

Dr. Coralee Thompson, M.D. IAHP 8801 Stenton Avenue Wyndmoon, PA 19038

Susan Altents Psychotherapist & Feldenkris Practioner 200 Dempster Evanston, IL 60202

Investigation continues.

9. Identify each health care provider who was consulted and/or rendered treatment to the minor plaintiff for the fiver years prior to the incident alleged in the complaint to the present for any reason whatsoever, excluding those named in the response to Interrogatory #8, stating the dates of treatment or contact, and the reason for treatment or consultation.

ANSWER: See Answer to Interrogatory No. 8 above.

10. List all damaged claimed were incurred on behalf of the minor plaintiff as a result of the occurrence, including, but not limited to, medical expenses (naming each of the health care providers and amounts incurred), wage loss (including dates of lost time from work), estimated future expenses (stating what the future treatment that will be required), all other expenses of any nature.

ANSWER: Prescription expenses.

Investigation continues.

11. Has the minor plaintiff ever made a claim or filed any other suit for personal injuries, and, if so, state:

a. The court, commission, or insurance company in which the suit or claim was made or filed;

b. The year in which each was made or filed;

c. The title and docket number of each; and

d. The name and address of any attorney representing the plaintiff.

ANSWER: No

12. Has the minor plaintiff been prevented from attending school at any time as a result of the injuries claimed to have been sustained as a result of this defendant's conduct?

ANSWER: Payton White is not yet of school age, but would have started pre-school this fall with his peers in the neighborhood. Obviously, we cannot do this as he is barely crawling, has very little speech, and is not potty trained due to his injuries.

13. Identify every person, other than your attorney who has ever stated or implied that that defendant committed malpractice or otherwise carelessly, wrongfully, or negligently treated the plaintiff.

ANSWER: Investigation continues.

14. Please state who has paid for each of the expenses claimed to have been incurred by or on the behalf of the minor plaintiff as a result of the alleged injuries, including the specific amounts paid on each expense.

ANSWER: Cigna Health Care has paid the medical bills thus far as well as the patents.

Investigation continues.

15. Pursuant to Supreme Court Rule 213(f), provide the name and address of each independent and controlled opinion witness who will offer any testimony and state:

a. The subject matter on which the opinion witness is expected to testify;

b. The conclusions and/or opinions of the opinion witness and basis therefor, including reports of the witness, if any;

c. The qualifications of each opinion witness, including a curriculum vitae and/or resume, if any;

d. The identify of any written reports of the opinion witness regarding this occurrence; and

e. The documents, records or other materials reviewed by the opinion witness.

ANSWER: Disclosures will be made in accord with court order.

Debra White, being first duly sworn on oath deposes and says that I have read the above and foregoing Answers to Interrogatories by me subscribed, and the same are true and correct.

Subscribed and sworn to before me this 21st day of April 2004.

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