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Nursing Home Requests for Production Model

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1. IDENTIFICATION: State the name, current address, date of birth, current employer, marital status, and social security number of all persons providing factual basis to the Answers to these Interrogatories.

2. STATEMENTS: Identify each and every statement known to you and/or your attorneys taken from a party or non-party regarding matters at issue in this litigation. Indicate:

a. By whom the statement was taken and his or her employment capacity;

b. The date the statement was taken;

c. The subject matter of the statement; and

d. The identity (including full name and current or last known address) of each and every person present when the statement was taken.

ATTACH to your Answers to these Interrogatories an accurate and complete copy of each statement identified.

3. PHOTOGRAPHS: Identify any photographs, films, videotapes, or motion pictures which relate to the subject matter of this litigation, which you, your agents, or attorney have taken, are aware of, and/or have in your/their possession.

ATTACH to your Answers to these Interrogatories copies of each identified item.

4. WITNESSES: With respect to any person who witnessed or otherwise has knowledge about any fall incident involving [PLAINTIFF], including but not limited to the fall incidents identified in Paragraph [#] of Plaintiff's complaint, state the following:

a. Full name;

b. Current or last known address and phone number;

c. The subject of the information that each witness claims to possess.

5. EXPERT WITNESSES: Identify each person whom you expect to call as an expert witness at trial. With respect to each such expert:

a. State the substance of the facts and opinions to which the expert is expected to testify;

b. Provide a summary of the grounds for each opinion.

ATTACH to your Answers to these Interrogatories copies of any report prepared by any identified expert witness.

6. INSURANCE: Identify any and all insurance coverages, including, but not limited to, liability and umbrella coverages, which may indemnify you for the acts or omissions alleged in the Complaint, and state the following:

a. The name of the insurance company;

b. The policy number;

c. The amount and nature of such coverage;

d. The amount of any self-retention or deductible factor; and

e. Whether your insurance company has indicated any possibility that they may deny coverage with respect to the incident which is the subject of this litigation.

ATTACH to your Answers to these Interrogatories an accurate and complete copy of the declaration sheet of each applicable insurance coverage.

7. [PLAINTIFF'S] RECORDS: Produce all documents created, received, utilized and/or maintained by[DEFENDANT] relating in any way to [PLAINTIFF]'s care, treatment, condition, conduct, and residence at that facility, including but not limited to the following:

a. Admission screening, admission notes, admission agreements, admission contracts, and any other documents related in any way to the admission of [PLAINTIFF] to [DEFENDANT].

b. Physicians orders, physicians reports, physicians notes, medical exam documents, telephone message slips, facsimile documents, facsimile logs, and any other documents relating in any way to physician services provided to[PLAINTIFF] and/or to communications in writing, by phone, by facsimile transmission, or in person between[DEFENDANT] and any physician regarding [PLAINTIFF].

c. Activities of Daily Living records and other charts prepared or filled in by CNA's.

d. Care notes, progress notes, weekly notes and other notes and/or documentation written by RN's, LVN's, RNA's, and CNA's relating to [PLAINTIFF].

e. Medical history of [PLAINTIFF].

f. Physical and other therapy evaluations, reports, notes, recordings, sheets or other documents relating to such therapy recommended for and/or given to [PLAINTIFF].

g. Resident assessment documents (e.g., "ADL"—Activities of Daily Living records, "MDL"—Minimum Data Set records, and "RAP"—Resident Assessment Protocol records) relating to [PLAINTIFF], any notes, rough drafts or other documents prepared for the purpose of or in anticipation of generating documentation for [PLAINTIFF], and any other assessment documentation created by nurses, administrators, and other personnel of [DEFENDANT]relating to [PLAINTIFF].

h. [PLAINTIFF]'s care plan and revisions thereto, and any notes, rough drafts, or other documents prepared for the purpose of, utilized in the preparation of, or created in anticipation of use in generating or evaluating [PLAINTIFF]'s care plan.

i. Resident profile, activities program information, and activities progress notes relating to [PLAINTIFF].

j. Social and psycho-social assessments and progress notes relating to [PLAINTIFF].

k. Discharge planning documentation relating to [PLAINTIFF].

l. Dietary assessment and progress notes relating to [PLAINTIFF].

m. Medication records, nurse's medication notes, medication administration documents, pharmacy and/or in-house medication orders and/or documentation, and any other documents relating in any way to medication prescribed for, given to, and/or ordered or requested for [PLAINTIFF].

n. Incident reports relating to [PLAINTIFF].

o. Notes, memoranda and other documents relating to [PLAINTIFF]'s departure from [DEFENDANT].

p. Notes, memoranda and other documents relating to complaints made by or on behalf of [PLAINTIFF] to any person or entity regarding her care or condition.

q. All documents relating to any communications between [DEFENDANT] employees and [PLAINTIFF] or with any relative, friend, neighbor or other person relating to [PLAINTIFF].

r. All documents relating to any communications between [DEFENDANT] and any local, state, federal or community agency, entity or organization relating to [PLAINTIFF].

8. BILLING RECORDS: Produce all billing records, invoices, statements, and other documents relating to anyrequests for payment submitted to [PLAINTIFF], to [PLAINTIFF]'s representatives and family members, and/or to any government agency or fiscal intermediary for any services rendered by [DEFENDANT] and its employees, venders and/or contractors to or on behalf of [PLAINTIFF].

9. MANUALS, PROCEDURES: Produce all policy manuals, guidance, guidelines, procedures, rules, regulations and other documents in use by management and employees of [DEFENDANT] during the time that [PLAINTIFF]was a resident of [DEFENDANT], relating to nursing and care, resident assessment, medication control, safety, administration, management, personnel, staffing training, billing, admission, discharge, and ancillary services.

10. FACILITY AND TRAINING: Produce all records pertaining to any facility meetings, training sessions, classes and/or inservices held by [DEFENDANT] since 1996 which identify any of the following: date, subject matter, names and/or job titles of persons who attended; and all handouts, syllabi and other training materials and/or learning aids provided to the attendees at such meetings, classes and sessions.

11. PATIENT CARE TRAINING: Produce all reports prepared by trainers, consultants and other individuals contracted, hired or retained by you to provide training, advice, assistance and recommendations to [DEFENDANT]and/or its employees regarding patient care and services at [DEFENDANT] from January 1, 1996 through December 31, 1998.

12. MEDICAL DIRECTOR: Produce all contracts and agreements between [DEFENDANT] and its medical director(s) in effect at any time between January 1, 1996 and December 31, 1998 and produce all documents that describe the duties and responsibilities of such medical director(s).

13. OWNERSHIP: Identify by name, address, telephone number and ownership interest, each person or entity with an ownership interest in the facility known as [DEFENDANT] in [CITY, STATE], at any time between January 1, 1997 and the present. For each entity with an ownership interest:

a. Define whether it is a corporation, partnership, sole proprietorship, or joint venture;

b. For each entity that is a corporation, identify the state in which incorporated, the date on which incorporated, your principal place of business, the names and addresses of all officers, and when the corporation was licensed to do business in the State of [STATE];

c. For each entity that is a partnership, identify the names and addresses of each partner, whether general or limited, and the official business address of the partnership;

d. For each entity that is a sole proprietorship, identify the name and address of each owner; and

e. For each entity that is a joint venture, identify the name address of each joint venturer.

14. OWNERSHIP/LICENSE TRANSFER: Produce all documents relating in any way to terms and conditions of the transfer of ownership and license for [DEFENDANT] since January 1, 1996 (including any other name by which the facility was known during that time period).

15. MARKETING DOCUMENTS: Produce all brochures, fliers, advertisements and any other documents in effect in 1993 and/or 1994 by or on behalf of [DEFENDANT] for purposes of advertising, marketing, public relations and business generation, and all communications between [DEFENDANT] and any health care provider or health facility which describe the services, care and treatment offered by [DEFENDANT].

16. EMPLOYEE DOCUMENTATION: Identify the name, last known home address and home telephone numbers of[DEFENDANT] staff (including employees and independent contractors) who worked at [DEFENDANT] and were responsible for [PLAINTIFF]'s care at any time on June 6, 1998, September 25, 1998, October 12, 1998, October 17, 1998, October 28, 1998 through October 30, 1998, or on any other date on which [PLAINTIFF] fell while a resident of [DEFENDANT].

ATTACH to your Answers to these Interrogatories an accurate and complete copy of the following facility records for the above-referenced dates:

a. Employee time cards;

b. Staffing assignment and schedules;

c. Daily Station assignment forms;

d. Division of nursing hours for certified/non-certified; and

e. Patient census data.

f. Also ATTACH job descriptions for all categories of staff who worked at [DEFENDANT] during the time that[PLAINTIFF] was a patient, including "employees" and "independent contractors."

17. ORGANIZATION CHARTS: Produce all organization charts for [DEFENDANT] and any other corporate entity with which [DEFENDANT] has been affiliated in effect at any time between January 1, 1996 and December 31, 1998.

18. COMPARATIVE FAULT: If it is your contention that [PLAINTIFF] was in any degree responsible for the damages alleged in Plaintiff's Complaint, please set forth in detail the facts upon which you base that claim. Identify all persons by name, last known address and telephone number who maintain knowledge of the facts alleged.

19. ADDITIONAL TORTFEASORS: If it is your contention that any other person or entity is in any degree responsible for the damages alleged in Plaintiff's Complaint, please set forth in detail the facts upon which you base that claim. Identify all persons by name, current or last known address and telephone number, who maintain knowledge of the facts alleged.

20. CLAIMS AND LAWSUITS: Identify all claims and/or lawsuits that have been made or instituted with respect to residents of [DEFENDANT] as a result of falling. For each:

a. Set forth the names, current or last known addresses and telephone numbers of all persons involved;

b. If any such individual is or was represented by counsel, set forth the name, address and telephone number of the attorney; and

c. In the event that litigation proceedings were instituted, set forth the case name, court name and court file number of such lawsuit.

21. INVESTIGATION REPORTS: Describe any investigation report prepared by you, your insurance company or any other entity regarding any incident in which [PLAINTIFF] fell, claimed to fall, or was otherwise believed to have fallen as a resident at [DEFENDANT].

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