Nursing Home Requests for Admissions Model

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REQUESTS FOR ADMISSIONS OF FACT TO [defendant nursing home]

REQUEST No. 1: Admit or deny that defendant was and is licensed, certified, and accredited in the state of to exclusively care for and treat residents suffering from Alzheimer's disease.

REQUEST No. 2: Admit or deny that plaintiff was admitted as a resident of defendant on [date].

REQUEST No. 3: Admit or deny that at the time of plaintiff's admission and at all times thereafter, defendant had notice that plaintiff was suffering from Alzheimer's disease and had a propensity to wander and potentially elope from defendant nursing home.

REQUEST No. 4: Admit or deny that pursuant to plaintiff's admission agreement or contract, and for a valuable consideration, defendant owed plaintiff a duty of care to prevent her elopement from defendant nursing home.

REQUEST No. 5: Admit or deny that pursuant to [state nursing home regulatory statute, and applicable sections], defendant owed plaintiff a duty of care to prevent her elopement from defendant nursing home.

REQUEST No. 6: Admit or deny that pursuant to [federal OBRA nursing home regulatory statute, and applicable sections], defendant owed plaintiff a duty of care to prevent her elopement from defendant nursing home.

REQUEST No. 7: Admit or deny that pursuant to the applicable standard of nursing home care in the state of , defendant owed plaintiff a duty of care to prevent her elopement from defendant nursing home.

REQUEST No. 8: Admit or deny that defendant was required to promulgate and enforce policies to prevent the elopement of its residents, including plaintiff.

REQUEST No. 9: Admit or deny that plaintiff eloped to the outside of defendant nursing home on [date] and [date].

REQUEST No.10: Admit or deny that defendant failed in its duty of care to prevent plaintiff's elopement from defendant nursing home pursuant to REQUEST Nos. 4, 5, 6, 7, and 8, in that plaintiff eloped to the outside of defendant nursing home on [date] and [date].

REQUEST No. 11: Admit or deny that plaintiff's elopement to the outside of defendant nursing home on [date] and [date] was caused solely by defendant's negligence and lack of due care in preventing such elopements.

REQUEST No. 12: Admit or deny that plaintiff's elopement to the outside of defendant nursing home on [date] and [date] was caused solely by defendant's negligence and lack of due care in preventing such elopements, in the following respects:

(a)
Failure to prepare and effectuate a proper care treatment plan for plaintiff.
(b)
Failure to provide resident secure units.
(c)
Failure to provide Alzheimer's resident secure units.
(d)
Failure to promulgate and enforce elopement prevention strategies.
(e)
Failure to use physical restraints.
(f)
Failure to provide and maintain departure alert systems.
(g)
Failure to identify sundowning behavior.
(h)
Failure to provide proper resident monitoring.
(i)
Failure to provide time specific monitoring.
(j)
Failure to provide resident bed checks.
(k)
Failure to provide resident activity checks.
(l)
Failure to provide resident room checks.
(m)
Failure to provide resident supervision.
(n)
Failure to provide resident one-on-one supervision.
(o)
Failure to provide video cameras.
(p)
Failure to provide window and screen coverings.
(q)
Failure to provide elevator security.
(r)
Failure to provide and maintain exit alarm systems.
(s)
Failure to provide elopement drills.
(t)
Failure to provide an elopement security plan.
(u)
Failure to provide adequate staffing.
(v)
Failure to provide an adequate staff to resident ratio.
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