Interrogatories 6 - sample interrogatories to defendants from plaintiff in med mal suit

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Plaintiff's Interrogatories to Defendants

Matthew M. Rundio, Kurt D. Lloyd, Matthew M. Rundio, Lloyd & Cavanagh, 200 W. Madison St., Suite 2050, Chicago, IL 60606, (312) 425-1900, Firm I.D.: 37258.

Plaintiff, ROBERT MIELKE, Special Administrator of the Estate of PAUL J. MIELKE, Deceased, through his attorneys, LLOYD & CAVANAGH, hereby propounds the following Interrogatories to be answered by Defendants, SHERMAN HOSPITAL, INC., an Illinois Corporation, SHERMAN HEALTH SYSTEMS, INC., an Illinois Corporation, SHERMAN HEALTH FOUNDATION, an Illinois not-for-profit Corporation, and MIDWEST HEART SPECIALISTS, LTD., d/b/a MIDWEST HEART SPECIALISTS, an Illinois Corporation, under oath and answers to be delivered to our offices within twenty-eight (28) days of receipt.

1. State the name, business address, job title and area of specialty, if any, and employer of each person participating in the preparation of the answers to these interrogatories.

ANSWER:

THE OCCURRENCE

2. State whether you have statements from any individual who claims to have knowledge of the facts relating to the occurrence in question, except for those statements contained in the medical records of Paul J. Mielke. If the answer is yes, identify each person's name and address and the nature of the statement and attach a copy to these answers.

ANSWER:

3. State the name and address of each nurse or other health care worker employed by this defendant who provided any care or treatment to Paul J. Mielke and for each person state:

a) the nature of the care and treatment provided;

b) the name, address, medical specialty and job title of each person who provided care and treatment

c) any orders or instructions that were made and given to the patient;

Please do not answer by referring to plaintiff's chart.

ANSWER:

4. State the name and address of any attending or resident physicians who provided care and treatment to Paul J. Mielke. For all physicians identified, please state the date of treatment and the nature of the treatment provided.

ANSWER:

5. Do you contend that the conduct of Paul J. Mielke was partly responsible for the occurrence or the extent of injuries suffered by him? If the answer is yes, please describe the conduct in detail and state the basis of your contention that such conduct caused or contributed to cause injury to the minor plaintiff.

ANSWER:

6. Do you contend that the conduct of a person not employed by this defendant was partly or wholly responsible for the occurrence or injuries suffered by Paul J. Mielke? If the answer is yes, state: a) the name, address and medical specialty of any such person; b) the conduct involved; and c) the basis of your contention that such conduct caused or contributed to cause injury to the plaintiff.

ANSWER:

7. State whether Douglas Tomasian, M.D. was employed by Defendant on January 28, 2004.

ANSWER:

8. State the name, address, date of birth, Social Security number, name and address of employer of the director of the cardiac catheterization laboratory/operating room at Sherman Hospital at all times from January 1, 2000 to the present date.

ANSWER:

9. State the name, address, date of birth, Social Security number, name and address of employer of any and all individuals who were responsible for ordering, stocking, re-stocking, and/or otherwise determining what operative supplies, equipment, and items, including all types of stents, would be stored or otherwise available at the cardiac catheterization laboratory/operating room at Sherman Hospital at all times from January 1, 2000 to the present date.

ANSWER:

10. State whether there were any written policies, supply lists, supply protocols, or other documents indicating what operative supplies, equipment, and items, including all types of stents, would be stored or otherwise available at the cardiac catheterization laboratory/operating room at Sherman Hospital at all times from January 1, 2000 to the present date.

ANSWER:

11. State the name and address of any and all individuals and entities that provided stents for the Sherman Hospital cardiac catheterization laboratory/operating room from January 1, 2000 to present date.

ANSWER:

INSURANCE COVERAGE

12. State whether you were named or covered under any primary policy or policies of liability insurance which apply(s) to this occurrence (including any and all occurrence policies and/or claims-made policies or both), and if so, state the name of each company, the policy number, the effective period and the maximum liability limits for each person and each occurrence or claim.

ANSWER:

13. State whether you were named or covered under any excess policy or policies of liability insurance which apply(s) to this occurrence (including any and all occurrence policies and/or claims-made policies or both; and with respect to each and every such policy all layers of insurance), and if so, state the name of each company, the policy number, the effective period and the maximum liability limits for each person and each occurrence or claim.

ANSWER:

14. Identify any statements, information and/or documents known to you and requested by any of the foregoing interrogatories which you claim to be work product or subject to any common law or statutory privilege, and with respect to each interrogatory, specify the legal basis for the claim as required by Illinois Supreme Court Rule 201(n).

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