Requests to Produce 2 - sample from med mal suit

Download PDF Version


A Response to this Request shall be filed and served within twenty-eight (28) days after the service of this Request.

1. All medical records and notes in your possession regarding the plaintiff, d.o.b. , from [date] to the present.

2. All written policies, procedures and guidelines regarding the manner in which you provide care to patients presenting to the emergency room of Hospital with fractured femurs, (other injuries) as of [date].

3. All written policies, procedures and guidelines regarding the manner in which you provide care to patients presenting to the emergency room of Hospital following (name of treatment or service provided), as of [date].

4. All written policies, procedures and guidelines regarding discharge instructions to be given patients following open reduction and internal fixation of the femoral shaft as of [date].

Client Reviews
Jonathan Rosenfeld was professionally objective, timely, and knowledgeable. Also, his advice was extremely effective regarding my case. In addition, Jonathan was understanding and patient pertaining to any of my questions or concerns. I was very happy with the end result and I highly recommend Jonathan Rosenfeld.
★★★★★
Extremely impressed with this law firm. They took control of a bad motorcycle crash that left my uncle seriously injured. Without any guarantee of a financial recovery, they went out and hired accident investigators and engineers to help prove how the accident happened. I am grateful that they worked on a contingency fee basis as there was no way we could have paid for these services on our own. Ethan Armstrong, Google User
★★★★★
This lawyer really helped me get compensation for my motorcycle accident case. I know there is no way that I could have gotten anywhere near the amount that Mr. Rosenfeld was able to get to settle my case. Thank you. Daniel Kaim, Avvo User
★★★★★
Jonathan helped my family heal and get compensation after our child was suffered a life threatening injury at daycare. He was sympathetic and in constant contact with us letting us know all he knew every step of the way. We were so blessed to find Jonathan! Giulia, Avvo User
★★★★★
Jonathan did a great job helping my family navigate through a lengthy lawsuit involving my grandmother's death in a nursing home. Through every step of the case, Jonathan kept my family informed of the progression of the case. Although our case eventually settled at a mediation, I really was impressed at how well prepared Jonathan was to take the case to trial. Lisa, Avvo User
★★★★★
Contact Us for a Free Consultation (888) 424-5757
Chicago Office Map