Nursing Home Interrogatories 3 - Plaintiff's Interrogatories and Defendant Nursing Home's Responses

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Defendant, Willowcreek Rehabilitation and Nursing Center's Answers to Plaintiff's Interrogatories

Burroughs, Hepler, Broom, MacDonald, Hebrank & True, LLP, Paul W. Johnson, #06193774, Kristen L. Dieterich, #06255849, 103 West Vandalia, Suite 300, P.O. Box 510, Edwardsville, IL 62025-0510, 618/656-0184, 618/656-1364 - fax, Attorneys for Defendant - Willowcreek Rehabilitation and Nursing Center, LLC.

COME NOW defendant, WILLOWCREEK REHABILITATION AND NURSING CENTER, LLC, (hereinafter referred to as “Willowcreek”) by and through its attorneys, BURROUGHS. HEPLER BROOM, MacDONALD, HEBRANK & TURE, LLP, and answers plaintiff's Interrogatories, as follows:

1. State the true and full corporate name of the Defendant, identifying the date of incorporation, the officers of the corporation, the registered agent, the date of dissolution (if any) and the principal place of business.

ANSWER: Willowcreek Rehabilitation and Nursing Center, L.L.C.

2. During the term of Plaintiff's employment at the subject nursing home, please identify her employers and the dates of employment.

ANSWER: Willowcreek Rehabilitation and Nursing Center, LLC 12/19/00 to the present.

3. Please identify the various types of insurance offered by Plaintiff's employer to the Plaintiff For each such type of insurance, please identify the corporate employer which provided them to the Plaintiff, the name and address of the insurance company to whom the premiums were paid, the amount of the premiums of Plaintiff's insurance coverage, the amount of premium that Plaintiff paid through the payroll deduction for each type of insurance coverage, and the agent for the insurance company who sold and/or provided said insurance coverage.

ANSWER: Defendant objects to this Interrogatory on the basis that it is overly broad, unduly burdensome, not limited in scope, and seeks information which is irrelevant and not likely to lead to the discovery of admissible evidence. Without waiving said objections, medical, dental, life, short-term disability and long-term disability insurance were offered to Venita Burns through her employer, Willowereek Rehabilitation and Nursing Center, LLC.

Medical and Dental Insurance 12/19/00 - 9/1/03

United Healthcare of Chicago

22703 Network Pl.

Chicago, IL 60673

Plaintiff's Amount of Premiums (per month)

$238.00 medical

$27.56 dental

Amount of premiums paid through payroll deduction (per month)

$78.14 medical

$25.44 Dental

Agent do not recall

Medical and Dental Insurance 9/1/03-current date

United Healthcare of St. Louis

Department CH 10 151

Palatine, IL 60055

Plaintiff's Amount of Premiums (per month)

Medical and Dental $403.99

Amount of premiums paid through payroll deduction (per month)

$0 Medical

$0 Dental

Agent - Jeff Schneiderman

Short-Term Disability Long-Term Disability, and Life Insurance- 12/1/01-9/1/03

American United Life Insurance Company

I American Square

P.O. Box 6123

Indianapolis, IN 46206

Plaintiff's Amount of Premiums (per month)

$28.12 Short-term disability

(Bums coverage $384/week)

$17.38 Long-term disability

(Bums coverage $2,773.00/month)

$50.48 Life

(Bums coverage up to $100,000)

Amount of premiums paid through payroll deduction (per month)

$16.30 Short-term disability

$7.68 Long-term disability

$46.52 Life

Agent - Mark Schmitke - sales rep.

Short-Term Disability, Long-Term Disability, and Life Insurance 9/1/03 - current

The Guardian Life Insurance

P.O. Box 95101

Chicago, IL 60694

Plaintiff's Amount of Premiums (per month)

The total monthly premium for the short-term disability, long-term disability, and life insurance is $49.03. No money has been deducted from Burns' paychecks to put toward the payment of this total premium amount.

Agent - Jeff Schneiderman

4. Please identify by name, residential address, position or title and name of employer, or any person who has knowledge as to the reason why the disability insurance provided through Plaintiff's employer lapsed and/or was cancelled.

ANSWER:

Michael Parentin, CFO of Bridgemark, LLC, 11970 Borman Drive, Suite 250, St. Louis, Missouri, 63146 (office).

Cherie Horschman, Human Resource Supervisor for Willowcreek, 40 North 64th Street, Belleville, Illinois, 62223 (office).

5. Please state the true reason why the disability insurance offered through Plaintiff's employer providing coverage to the Plaintiff was not in effect on August 24, 2003.

ANSWER: Willowcreek learned several months after August 24, 2003 that the premiums for Plaintiff's disability insurance had not been paid and, therefore, insurance was not in effect on August 24, 2003.

6. please state the identity of any and all entities that have any type of ownership interest in the subject nursing home located at 40 North 64th Street, Belleville, Illinois. For each such individual and/or entity, please identify the specific ownership interest, the full and complete name of the individual and/or entity, the principal place of address for that person and/or entity, and the name of the primary contact (if a corporation).

ANSWER: Defendant objects to this Interrogatory on the basis that it is overly broad, unduly burdensome, not limited in scope, and seeks information which is irrelevant and not likely to lead to the discovery of admissible evidence. Without waiving said objections.

Willowcreek Rehabilitation and Nursing Center, LLC

Mr. David Meisles - 96%

5218 14th Avenue

Brooklyn, NY 11219

Beth Benoudiz -- 4%

Recently moved to Washington, D.C.

7. Please state the identity of any and all entities that operates or has any interest in operating in the subject nursing home located at 40 North 64th Street, Belleville, Illinois. For each such individual and/or entity, please identify the specific ownership interest, the full and complete name of the individual and/or entity, the principal place of address for that person and/or entity, and the name of the primary contact (if a corporation).

ANSWER: Defendant objects to this Interrogatory on the basis that it is overly broad, unduly burdensome, not limited in scope, and seeks information which is irrelevant and not likely to lead to the discovery of admissible evidence. Without waiving said objections, Willowcreek has hired several management companies during the course of Plaintiff's employment with Willowcreek to manage its operations. The following is the list of management companies from 1999-today:

Quality Care Management, LLC (6/1/96-11/30/02)

701 Lee Street

Des Plaines, IL 60016 (current)

Contract with Quality Care Management, LLC to provide management services from 9/1/01 -- 11/30/02

Boulevard Healthcare Management, LLC

8950 Gross Pointe Road, Suite 600

Skokie, IL 60077

Sherrie Noone (HR)

Platinum Healthcare (12/1/02-4/30/03)

640 Pearson Street

Des Plaines, IL 60016

David Duncan (CFO)

Bridgemark, LLC (5/1/03- present)

11970 Borman Drive, Suite 250

St. Louis, MO 63146

Michael Parentin (CFO)

8. From the period of December 2000 through the current date, please state whether the Defendant obtained individual insurance policies for each employee, or whether group insurance was purchased for employees collectively.

ANSWER: Group

9. From the period of December 2000 through the current date, please provide the identity of any and all insurers who provided any type of insurance coverage for any of Defendant's employees which was obtained by the Defendant. Please identify each type of insurance obtained, and whether the insurance was paid for in part by payroll deduction by employee's wages, and the policy limits and/or amounts of insurance obtained.

ANSWER: See Willowcreek's objection and answer to Interrogatory Number 3.

10. From the period of December 2000 through the current date, please provide the identity of any and all insurers who provided any type of insurance coverage for Plaintiff which was obtained by the Defendant. Please identify each type of insurance obtained, and whether the insurance was paid for in part by payroll deductions by employee's wages, and the policy limits and/or amounts of insurance obtained.

ANSWER: See Willowcreek's objection and answer to Interrogatory Number 3.

11. Please stale whether the Defendant notified the Plaintiff that her disability insurance was no longer in effect prior to August 24, 2003.

ANSWER: Willowcreek did not know prior to August 24, 2003 that Plaintiff's disability insurance was no longer in effect and, therefore, could not notify Plaintiff of something it did not know.

12. Please state the name, address, whom employed by and title, of any person who knew that the disability insurance providing coverage to the Plaintiff and provided by the Defendant had lapsed or was cancelled prior to August 24, 2003. For each such person, please state the substance of their knowledge.

ANSWER: None.

13. Please state the name, address of the Defendant's employee who was responsible for timely paying any insurance premiums for insurance coverage to Defendant's employees.

ANSWER: Defendant objects to this Interrogatory on the basis that it is overly broad, unduly burdensome, not limited in scope, and seeks information which is irrelevant and not likely to lead to the discovery of admissible evidence. Without waiving said objections, Willowcreek hires a management company to oversee its' operations and ensure bills, including insurance premiums, are timely paid. See answer to Interrogatory Number 7 for list of management companies.

14. (A) Pursuant to Illinois Supreme Court Rule 213(f), provide the name and address of each witness who will testify at trial and state the subject of each witnesses' testimony.

(B) For each “Lay Witness,” please identify the subject on which the witness will testify.

(C) For each “Independent Expert Witness,” please identify the subjects on which the witness will testify and the opinions the party expects to elicit.

(D) For each “Controlled Expert Witness,” please identify:

(1) The subject matter on which the witness will testify;

(2) The conclusions and opinions of the witness and the bases there for;

(3) The qualifications of the witness; and

(4) Any reports of the witness prepared by the witness about the case.

ANSWER: Unknown at this time. Defendant's investigation is continuing and it will supplement in accordance with the deadline provided in the court's scheduling order.

15. 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) .

ANSWER: None.

BURROUGHS, HEPLER, BROOM, MacDONALD, HEBRANK & TRUE, LLP

By: <<signature>>

PAUL W. JOHNSON, #06193774
KRISTEN L. DIETERICH, #06255849
103 West Vandalia, Suite 300
P.O. Box 510
Edwardsville, IL 62025-0510
618/656-0184
618/656-1364 - fax
ATTORNEYS FOR DEFENDANT - WILLOWCREEK REHABILITATION AND NURSING CENTER, LLC

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