Medical Negligence Interrogatories Propounded by Plaintiff to Individual
Defendant
Medical Negligence Interrogatories Propounded by Plaintiff to Corporate
Defendant
Medical Negligence Interrogatories Propounded by Defendant (Injury Case)
Medical Negligence Interrogatories Propounded by Defendant (Death Case)
Definition:
Whenever in these interrogatories you are requested to "identify" some
person, corporation or other organizations, please provide name, address, and
telephone number.
1.
State whether or not, following the date of the occurrence mentioned in
the petition in this case, a statement, interview, or report, or a stenographic
mechanical, electrical, audio, video, motion picture, photograph, or other
recording, or transcription thereof, of the plaintiff, or of a statement made by
the plaintiff and contemporaneously recorded, has been secured from plaintiff or
taken of plaintiff; if so, state the following:
(a)
Date, place, and time taken;
(b)
Name and address of the person or persons connected with taking it;
(c)
Names and addresses of all persons present at the time it was taken;
(d)
Whether the statement was oral, written, shorthand, recorded, taped, etc.;
(e)
Was it signed?;
(f)
Names and addresses of the persons or organizations under whose
direction and upon whose behalf it was taken or made; and,
(g)
Please attach an exact copy of the original of said statement,
interview, report, film, or tape to your answers to these interrogatories; if
oral, please state verbatim the contents thereof.
2.
Experts: List and identify:
(a)
Each person this defendant expects to call as an expert witness at the
trial, whether the witness is a retained expert or non-retained expert,
stating for each such expert:
(i)
Name;
(ii)
Address;
(iii)
Occupation;
(iv)
Place of employment;
(v)
Qualifications to give an opinion (if such information is available on an
expert's curriculum vitae, you may attach a copy thereof in lieu of
answering this interrogatory subpart); and,
(b)
With respect to each expert listed, please state the subject matter on
which the expert is expected to testify and the expert's hourly deposition
fee.
3.
Identify any insurance agreement under which any person carrying on an insurance
business may be liable to satisfy part or all of a judgment which may be entered
in the action or to indemnify or reimburse for payments made to satisfy the
judgment, including any excess coverage or umbrella coverage, and with respect
to each please state:
(a)
The type of insurance which gives rise to the interest, including but
not limited to whether excess or primary;
(b)
Limits of coverage;
(c)
Effective policy period;
(d)
Whether there exist medical pay coverage in addition to coverage listed in (a)
above, and if so, the amount;
(e)
Policy number;
(f)
Identity of all insureds;
(g)
Insurer's identity;
(h)
Is a reservation of rights being made?; and,
(i)
Attach a complete copy of the declaration page and policy of any
insurance agreement identified.
4.
Has the defendant ever been convicted of a criminal offense or pleaded guilty or
nolo contendere (no contest) to a crime consisting of a misdemeanor or felony?
Identify the charge and the court, and state the date of conviction or plea, and
the sentence imposed.
5.
Identify all records the defendant has which pertain to care and treatment of
plaintiff (or plaintiff's decedent) including (select appropriate types: Charts,
ultrasounds, fetal monitoring strips, x-ray films, C.T. scans, M.R.I. scan, PET
scans, nuclear scans, electrocardiogram, EEG, EKG, arteriograms, doppler
reports/data, photographs, videotapes, molds, microscopic slides, tissue blocks,
or _____________). With respect to those records, please state:
(a)
Identify who kept the above designated records, where they were kept, and
state whether they were kept as part of the standard business practice of the
defendant;
(i)
Were the entries made by this defendant or the defendant's office
personnel, made at or near the time of the facts recorded?;
(ii)
Describe any alterations in the record, or any record additions,
subtractions, or changes in entries wherein, the alterations, additions,
subtractions, or changes in entries were not made at or near the time of the
original facts recorded;
(iii)
Were any records lost, misplaced, destroyed or are any records
currently unavailable?
If
5 (a) (iii) is answered affirmatively,
(1)
What record or document?;
(2)
When?;
(3)
Why?;
(4)
By whom?;
(5)
In whose custody was it in at the time?; and,
(6)
State its contents as nearly as practicable.
6.
State whether you were incorporated at any time that this defendant or any of
his/her agents, servants, or employees rendered any care and treatment to
plaintiff, and if so, state, with respect to each said corporation, the
following:
(a)
The inclusive dates of said corporation;
(b)
The exact corporate name;
(c)
The state of incorporation;
(d)
Any other names under which you or the corporation have done business
at any time the corporation or any of its agents, servants, or employees
rendered any care and treatment to plaintiff and the dates of said use;
(e)
The names and addresses of your corporate officers;
(f)
The name and address of your registered agent;
(g)
The name and address of your registered office;
(h)
State your corporate purpose during all periods of your existence; and,
(i)
If during any part of the year 19___ [year(s) during which acts of
negligence alleged in petition occurred] you were not operating as a
corporation, as set forth in answers above, state your exact status during
that year and the names and addresses of all partners at the time, if
applicable.
7.
Do you specialize now or have you ever specialized or sub-specialized in your
practice? If so, identify the specialty or specialties and the inclusive dates
of each such specialization.
8.
Answer the following questions regarding your background or, alternatively,
please attach a current copy of your Curriculum Vitae and provide any of the
following information that is not contained in your Curriculum Vitae:
(a)
Name, address, dates, major and degree that you obtained from any
school of higher education;
(b)
Name and address of each medical school attended, including:
(i)
Dates attended;
(ii)
Whether said school or schools are outside the United States, and if so, are
said school or schools accredited, and if so, name and address of
accrediting agencies;
(iii)
The degree(s) received and date each degree(s) were received;
(c)
Name, address and dates of any medical institutions at which you served
your internship, residency, or fellowships;
(d)
For each internship, residency, and/or fellowship state:
(i)
The specialty involved;
(ii)
Whether the program if outside the United States was accredited, and if so,
the name and address of accrediting agency;
(e)
Are you now or have you ever been a diplomate or any specialty board?If
so, state the name and address of the board, the date you acquired membership
or diplomate status, and the number of attempts it took to pass said specialty
boards;
(f)
What states are you presently and at any time in the past licensed to
practice medicine and state that date the license was granted;
(g)
Have you now or at any time in your career had your license or staff
privileges revoked, terminated, suspended, or limited in any way, and if so,
state:
(i)
The date or dates of said action;
(ii)
What action was taken;
(iii)
For what reason(s);
(h)
Identify the name and current address of defendant's spouse at time of the act
of neglect in plaintiff's petition.
9.
List by date and time, each occasion which you saw plaintiff during the course
of your professional relationship with plaintiff, and the location of each
visit, other than visits listed in this defendant's medical records and visits
listed in any hospital records.
10.
During the course of your professional relationship with plaintiff, state
the name and address of any health care provider(s) you referred plaintiff to or
consulted with at any time and the date(s) and purpose of said referral or
consultation.
11.
During the course of your professional relationship with plaintiff, state
whether you were supervised by anyone, and if so, the name and residential
address of the person(s) exercising said supervision, and the dates of said
supervision.
12.
During the course of your professional relationship with plaintiff, state
whether any care and treatment of plaintiff was provided as part of employment
and/or an association with any entity.If so, state the name and address of said
entity and describe the employment and/or association.
13.
State the date your professional relationship with plaintiff ended,
including the date you last had contact with plaintiff (including telephone or
written communication).
14.
With respect to plaintiff's allegation contained in plaintiff's
pleadings, state the full name and last known address of each person who:
(a)
Witnessed or claims to have witnessed the event or occurrence wherein
plaintiff alleges an act of negligence occurred?;
(b)
Was present or claims to have been present at the scene of the event or
occurrence immediately before, at the time of, or immediately after the time
plaintiff alleges an act of negligence occurred.
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Definition:
Whenever in these interrogatories you are requested to "identify" some
person, corporation or other organizations, please provide name, address, and
telephone number.
1.
State whether or not this defendant is being sued in its full and correct name.
If not, state the full and correct name of this defendant.
2.
Please state the name and present business of each and every individual who
supplied information used to answer these interrogatories and identify his, her
or their legal capacity within defendant's corporate administration.
3.
Please state whether or not [individual doctor, nurse, etc.] was this
defendant's employee, agent, or servant at [the time and place of the occurrence
described in plaintiff's petition], and if not, please state the following:
(a)
How their services were charged to plaintiff;
(b)
How [individual doctor, nurse, etc.] was paid or reimbursed by this defendant
for any of [individual doctor, nurse, etc.] services performed on or to
plaintiff;
(c)
Whether or not this defendant deducted any social security, income tax, or any
other deductions of any kind from [individual doctor, nurse, etc.] remuneration;
(d)
Whether there are or were any written contracts, agreements of employment, or
indemnification agreements for such services in existence. If so, in whose
custody are they at the present time; and,
(e)
Was a W-2 form made by this defendant for any individual listed herein? If so,
which persons?
4.
Please state whether or not [individual doctor, nurse, etc.] maintained any type
of staff privileges whereby he/she would be allowed to admit patients and render
treatment thereto while inpatients or outpatients at your facilities, and if
your answer to this interrogatory is "yes", please state the
following:
(a)
The exact nature of staff privileges granted;
(b)
Whether those privileges were limited to any particular areas of medicine or
specialties in medicine;
(c)
Whether or not those privileges included [e.g., surgical] privileges, and if so,
please state the general nature and subject matter of the areas or specialties
in which those [e.g., surgical] privileges were granted; and,
(d)
Please describe the manner or method in which staff privileges are granted by
defendant to physicians.
5.
State whether or not, following the date of the occurrence mentioned in the
petition in this case, a statement, interview, or report, or a stenographic
mechanical, electrical, audio, video, motion picture, photograph, or other
recording, or transcription thereof, of the plaintiff, or of a statement made by
the plaintiff and contemporaneously recorded, has been secured from plaintiff or
taken of plaintiff; if so, state the following:
(a)
Date, place, and time taken;
(b)
Name and address of the person or persons connected with taking it;
(c)
Names and addresses of all persons present at the time it was taken;
(d)
Whether the statement was oral, written, shorthand, recorded, taped, etc.;
(e)
Was it signed?;
(f)
Names and addresses of the persons or organizations under whose direction and
upon whose behalf it was taken or made; and,
(g)
Please attach an exact copy of the original of said statement, interview,
report, film, or tape to your answers to these interrogatories; if oral, please
state verbatim the contents thereof.
6.
Experts:
List
and identify:
(a)
Each person this defendant expects to call as an expert witness at the trial,
whether the witness is a retained expert or non-retained expert, stating for
each such expert:
(i)
Name;
(ii)
Address;
(iii)
Occupation;
(iv)
Place of employment;
(v)
Qualifications to give an opinion (if such information is available on an
expert's curriculum vitae, you may attach a copy thereof in lieu of answering
this interrogatory subpart); and,
(b)
With respect to each expert listed, please state the subject matter on which the
expert is expected to testify and the expert's hourly deposition fee.
7.
Identify any insurance agreement under which any person carrying on an insurance
business may be liable to satisfy part or all of a judgment which may be entered
in the action or to indemnify or reimburse for payments made to satisfy the
judgment, including any excess coverage or umbrella coverage, and with respect
to each please state:
(a)
The type of insurance which gives rise to the interest, including but not
limited to whether excess or primary;
(b)
Limits of coverage;
(c)
Effective policy period;
(d)
Whether there exists medical pay coverage in addition to coverage listed in (a)
above, and if so, the amount;
(e)
Policy number;
(f)
Identity of all insureds;
(g)
Insurer's identity;
(h)
Is a reservation of rights being made?; and,
(i)
Attach a complete copy of the declaration page and policy of any insurance
agreement identified.
8.
Identify all records the defendant has which pertain to care and treatment of
plaintiff (or plaintiff's decedent) including (select appropriate types: Charts,
ultrasounds, fetal monitoring strips, x-ray films, C.T. scans, M.R.I. scan, PET
scans, nuclear scans, EEGs, EKGs, arteriograms, doppler reports/data,
photographs, videotapes, molds, microscopic slides, tissue blocks, or
_____________). With respect to those records, please state:
(a)
Identify who kept the above designated records, where they were kept, and state
whether they were kept as part of the standard business practice of the
defendant;
(i)
Were the entries made by this defendant or the defendant's office personnel,
made at or near the time of the facts recorded?;
(ii)
Describe any alterations in the record, or any record additions, subtractions,
or changes in entries wherein, the alterations, additions, subtractions, or
changes in entries were not made at or near the time of the original facts
recorded;
(iii)
Were any records lost, misplaced, destroyed or are any records currently
unavailable?
If
8 (a) (iii) is answered affirmatively,
(1)
What record or document?;
(2)
When?;
(3)
Why?;
(4)
By whom?;
(5)
In whose custody was it in at the time?; and,
(6)
State its contents as nearly as practicable.
9.
State whether you were incorporated at any time that this defendant or any of
this defendant's agents, servants, or employees rendered any care and treatment
to plaintiff, and if so, state, with respect to each said incorporation, the
following:
(a)
The inclusive dates of said corporation;
(b)
The exact corporate name;
(c)
The state of incorporation;
(d)
Any other names under which you or the corporation have done business at any
time the corporation or any of its agents, servants, or employees rendered any
care and treatment to plaintiff and the dates of said use;
(e)
The names and addresses of your corporate officers;
(f)
The name and address of your registered agent;
(g)
The name and address of your registered office;
(h)
State your corporate purpose during all periods of your existence; and,
(i)
If during any part of the year 19___ [year(s) during which acts of negligence
alleged in petition occurred] you were not operating as a corporation, as set
forth in answers above, state your exact status during that year and the names
and addresses of all partners at the time, if applicable.
10.
During the course of this defendant's health care provider relationship with
plaintiff, and while acting through this defendant's agents, servants, and/or
employees, state the name and address of any health care provider(s) this
defendant referred plaintiff to at any time and the date(s) and purpose of said
referral.
11. State the date this defendant's health care provider relationship
with plaintiff ended, including the date this defendant, by its agents,
servants, and employees, last had contact with plaintiff (including telephone or
written communication).
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interrogatories in Microsoft Word format (select "save target as" in
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Definitions:
1.
"Health care provider" shall refer to any medical doctor, osteopath,
chiropractor, therapist, psychiatrist, psychologist, social worker, counselor,
hospital, medical clinic, or any other provider of diagnostic or therapeutic
services.
2.
"Injury" or "injured" shall refer to any harm or damage to
the plaintiff's physical or emotional well being.
Interrogatories:
1.
Please provide the following information:
(a)
Your full name, social security number, place and date of birth, present
address, and any other names you have used;
(b)
If you have ever been married, state the full name of each spouse, the date of
your marriage to each spouse, the date on which your marriage to each spouse
ended, the present address of each spouse and the names, birth dates, and
present addresses of each child you had with each spouse;
(c)
Each and every address at which you have resided in the past twenty years
including the dates of your residence at each address and the names of all
persons residing with you at each address;
(d)
The highest grade of formal schooling completed by you, the institution at which
it was completed, and any certificates or degrees you have received including
any vocational or specialized education or training in a trade, business or the
military;
(e)
Whether you have been convicted of or pled guilty to a crime consisting of a
misdemeanor or felony and, if so, the offense for which you were convicted, or
to which you pled guilty, the date of conviction or plea, and the name and
address of the court where you were convicted or pled guilty;
(f)
Whether you have ever been a plaintiff in a personal injury suit, proceeding for
workers' compensation benefits, or a proceeding for social security benefits
and, if so, when, where and in what court the action was commenced; and,
(g)
Whether you have ever served in the Armed Forces of the United States or of a
foreign country.
2.
List any job or position of employment, including self-employment, held by you
during the period beginning twenty years before the first act of negligence
alleged in your petition and continuing through the present date, stating as to
each the following:
(a)
The name and address of the employer;
(b)
The date of commencement and termination of employment;
(c)
The place of employment;
(d)
The nature of employment and the duties performed;
(e)
The name and address of your immediate supervisor;
(f)
If you are alleging a loss of income as a result of the acts of negligence
alleged in your petition, the rate of pay or compensation received; and,
(g)
The reason for termination.
3.
Do you claim to have lost time from gainful employment and/or the opportunity
for advancement or promotion as a result of the act(s) of negligence alleged in
your petition? If so, state:
(a)
The dates on which and the employment from which said time was lost;
(b)
Your rate of pay at the time of said loss, the total amount of your loss and
your method of computation;
(c)
The specific condition which you claim caused the loss of time;
(d)
The name and address of the custodian of wage records at each employer from whom
you claim to have suffered a loss of wages;
(e)
The opportunities which you claim would have been available had the alleged
act(s) of negligence not taken place; and,
(f)
The name and address of your immediate supervisor or other official your place
of employment who would be responsible for recommending a promotion or
advancement.
4.
State the name and address of each health care provider who has examined or
treated you during the period beginning twenty years before the first act of
negligence alleged in your petition and continuing through the present date. For
each health care provider identified, state:
(a)
The date of each examination or treatment;
(b)
The injury, illness, condition, complaint or other reason for which each
examination or treatment was conducted; and,
(c)
Whether the injury, illness, condition or complaint for which examination or
treatment was performed has been relieved, and if so, the approximate date of
relief.
5.
State the name and address of each hospital at which you have been examined or
treated during the period beginning twenty years before the first act of
negligence alleged in your petition and continuing through the present date. For
each hospital identified, state:
(a)
If admitted, the date of your admission and the date of your discharge;
(b)
If not admitted, the date of your visit; and,
(c)
The injury, illness, condition, complaint or other reason for your
hospitalization or visit.
6.
State whether during the period beginning twenty years before the first act of
negligence alleged in your petition and continuing through the present day, you
have suffered any injury or illness for which you were evaluated or treated by a
physician or other health care provider. If so, as to each said injury or
illness, state:
(a)
The date on which the injury took place or illness began;
(b)
The parts of your body injured or affected; and,
(c)
The name and address of each health care provider who treated you for the injury
or illness.
7.
Describe each injury you claim to have suffered as a result of the act(s) of
negligence alleged in your petition, and for each such injury state:
(a)
Whether the injury is currently causing you any pain or suffering;
(b)
Whether you claim the injury will cause you any pain and suffering in the
future;
(c)
Whether you claim any disability because of the injury, and if so, the nature
and extent of the disability;
(d)
Whether you claim you will be required to undergo any further treatment and if
so, the nature of any such treatment and the name and address of any health care
provider who has recommended such treatment; and,
(e)
Whether you claim the injury is permanent, and if so, the name and address of
any health care provider who has expressed this opinion.
8.
State whether you have been examined or treated by any health care provider for
injury(ies) you claim to have suffered as a result of the act(s) of negligence
alleged in your petition and for each such injury state:
(a)
The name and address of each health care provider who examined or treated you;
(b)
The name and address of each hospital, or clinic where you were examined or
treated either as an impatient or outpatient; and,
(c)
The dates of your first and most recent examination or treatment by each health
care provider, the dates of each examination or treatment as an outpatient at
any hospital or clinic and the dates of admission and discharge for each
admission at any hospital or clinic.
9.
State whether you have incurred any other expenses not listed in answers to
interrogatories numbers 3 and 8 which you claim were necessitated by or
attributable to the act(s) of negligence alleged in your petition. If your
answer is in the affirmative, please state:
(a)
The product or service for which the expense was incurred;
(b)
The name and address of the person or entity from whom the product or service
was purchased;
(c)
The date upon which said product or service was purchased; and,
(d)
The amount charged for the product or service purchased.
10.
State the full name and last known address of each person who:
(a)
Witnessed or claims to have witnessed any act of negligence alleged in your
petition;
(b)
Was present or claims to have been present at the scene immediately before, at
the time of or immediately after any act of negligence alleged in your petition;
(c)
Has personal knowledge or claims to have personal knowledge of the nature and
extent of the injuries you claim to have suffered as a result of the act(s) of
negligence alleged in your petition; and,
(d)
Has or claims to have personal knowledge of any act of negligence alleged.
11.
Experts:
List
and identify:
(a)
Each person this defendant expects to call as an expert witness at the trial,
whether the witness is a retained expert or non-retained expert, stating for
each such expert:
(i)
Name;
(ii)
Address;
(iii)
Occupation;
(iv)
Place of employment;
(v)
Qualifications to give an opinion (if such information is available on an
expert's curriculum vitae, you may attach a copy thereof in lieu of answering
this interrogatory subpart); and,
(b)
With respect to each expert listed, please state the subject matter on which the
expert is expected to testify and the expert's hourly deposition fee.
12.
State whether or not, following the act(s) of negligence alleged in your
petition, a statement, interview, or report, or a stenographic, mechanical,
electrical, audio, video, motion picture, photograph or other recording, or
transcription thereof, of the defendant or any of defendant's agents, servants
and employees or of a statement made by the defendant or any of defendant's
agents, servants and employees and contemporaneously recorded, has been secured
or taken from defendant or any of defendant's agents, servants, and employees;
if so, state the following:
(a)
Name of person from whom secured or taken;
(b)
Date, place and time taken;
(c)
Name and address of the person or persons connected with taking it;
(d)
Name and address of all persons present at the time it was taken;
(e)
Whether the statement was oral, written, shorthand, recorded, taped, etc.;
(f)
Was it signed? and,
(g)
Names and addresses of the persons or organizations under whose direction and
upon whose behalf it was taken or made.
13.
Identify every person, firm or corporation other than your attorney and persons
mentioned in answers to other interrogatories, to whom you have made any
statement or given information relating to your physical condition or ability to
work in connection with any application for employment, disability benefits or
pecuniary payments of any nature, since the date of the act(s) of negligence
alleged in your petition including, but not limited to, any insurance company.
14.
State whether there exists any photographs, x-rays, motion pictures, videotapes,
drawings or other visual reproductions of any type depicting the injury(ies)
described in your petition and if so, for each set, state:
(a)
The name and address of the person making the visual reproduction(s) and the
date thereof;
(b)
What each visual reproduction depicts; and,
(c)
The name and address of the person having custody of each said visual
reproduction.
15.
State whether, as a result of the act(s) of negligence or injuries alleged in
your petition, you have received settlement monies, received any Medicare and/or
Medicaid payments, have had Medicare, Medicaid, or other payments made on your
behalf, or have received anything whatever of value and, if your answer is in
the affirmative, please state:
(a)
The nature of the payment (i.e. settlement money, Medicare payment, Medicaid
payment, or the like);
(b)
The name of the person, firm, association, company, corporation or other entity
paying the amount and the name of the recipients; and,
(c)
The date said amount was paid and/or received.
16.
State whether you have entered into any type of settlement agreement, release,
covenant-not-to-sue, covenant-not-to-enforce-judgment, an agreement in the
nature of a "Mary Carter Agreement," a covenant-to-sue, or contract to
limit recovery to specified assets, with any person, firm, corporation, insurer,
or any other entity relating in any way to any of the incidents or injuries
mentioned in your petition or any of the damages claimed under this lawsuit. If
so, please state as to such settlement, agreement release, covenant, or
contract: the date; the amount of consideration involved; and the complete legal
name and present address of the person or entity involved.
17.
What dollar amount of damages are you seeking in this lawsuit?
18. State the names and addresses of all persons residing in Boone County
who are related to plaintiff by blood or marriage.
Right-click here to download the
foregoing interrogatories in Microsoft Word format (select "save target
as" in Internet Explorer or "save link as" in Netscape).
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Definitions:
1.
"Health care provider" shall refer to any medical doctor, osteopath,
chiropractor, therapist, psychiatrist, psychologist, social worker, counselor,
hospital, medical clinic, or any other provider of diagnostic or therapeutic
services.
2.
"Injury" or "injured" shall refer to any harm or damage to
the plaintiff's decedent's physical or emotional well being.
Interrogatories:
1.
Please state the following information concerning yourself and the plaintiff's
decedent:
(a)
Full name, social security number, place and date of birth, present address,
and any other names used;
(b)
If you or plaintiff's decedent have ever been married, state the full name of
each spouse, the date of marriage to each spouse, the date on which each
marriage ended, the present address of each spouse and the names, birth dates,
and present addresses of each child had with each spouse;
(c)
Each and every address at which you or plaintiff's decedent have resided in
the past twenty years including the dates of your residence at each address
and the names of all persons residing at each address;
(d)
The highest grade of formal schooling completed, the institution at which it
was completed, and any certificates or degrees received including any
vocational or specialized education or training in a trade, business or the
military;
(e)
Whether you or plaintiff's decedent have been convicted of or pled guilty to a
crime consisting of a misdemeanor or felony and, if so, the offense for which
convicted, or to which a guilty plea was entered, the date of conviction or
plea, and the name and address of the court where the conviction or plea was
entered;
(f)
Whether plaintiff's decedent was ever a plaintiff in a personal injury suit,
proceeding for workers' compensation benefits, or a proceeding for social
security benefits and, if so, when, where and in what court the action was
commenced; and,
(g)
Whether you or plaintiff's decedent have ever served in the Armed Forces of
the United States or of a foreign country.
2.
List any job or position of employment, including self-employment, held by
plaintiff's decedent during the period beginning twenty years before the first
act of negligence alleged in your petition and continuing through the present
date, stating as to each, the following:
(a)
The name and address of the employer;
(b)
The date of commencement and termination of employment;
(c)
The place of employment;
(d)
The nature of employment and the duties performed;
(e)
The name and address of decedent's immediate supervisor; and,
(f)
If a loss of support claim is being made, state the decedent's rate of pay or
compensation received.
3.
State the name and address of each health care provider who has examined or
treated plaintiff's decedent during the period beginning twenty years before the
first act of negligence alleged in your petition and continuing through the
present date. For each health care provider identified, state:
(a)
The date of each examination or treatment;
(b)
The injury, illness, condition, complaint or other reason for which each
examination or treatment was conducted; and,
(c)
Whether the injury, illness, condition or complaint for which examination or
treatment was performed has been relieved, and if so, the approximate date of
relief.
4.
State the name and address of each hospital at which plaintiff's decedent had
been examined or treated during the period beginning twenty years before the
first act of negligence alleged in your petition and continuing through the
present date. For each hospital identified, state:
(a)
If admitted, the date of admission and the date of discharge;
(b)
If not admitted, the date of the visit; and,
(c)
The injury, illness, condition, complaint or other reason for the
hospitalization or visit.
5.
State whether, during the period beginning twenty years before the first act of
negligence alleged in the petition and continuing through the present day,
plaintiff's decedent had suffered any medical significant injury or illness. If
so, as to each said injury or illness, state:
(a)
The date on which the injury took place or illness began;
(b)
The parts of the decedent's body which were injured or affected; and,
(c)
The name and address of each health care provider who treated the plaintiff's
decedent for the injury or illness.
6.
State whether plaintiff's decedent had been examined or treated by any health
care provider following the occurrence(s) mentioned in your petition and for
each, state:
(a)
The name and address of each health care provider who examined or treated the
decedent;
(b)
The name and address of each hospital, or clinic where the decedent was
examined or treated either as an impatient or outpatient;
(c)
Describe the treatment or examination rendered; and,
(d)
The total amount of charges by each health care provider, hospital or clinic
for services rendered.
7.
What expenses, listing them item by item, were incurred in connection with the
funeral, burial, cremation or other means of attending to the decedent's remains
and what is the name and address of each person incurring liability for such
expenditures?
8.
State whether you have incurred any other expenses not listed in answers to the
previous interrogatories which you claim were necessitated by or attributable to
the act(s) of negligence alleged in your petition. If your answer is in the
affirmative, please state:
(a)
The product or service for which the expense was incurred;
(b)
The name and address of the person or entity from whom the product or service
was purchased;
(c)
The date upon which said product or service was purchased; and,
(d)
The amount charged for the product or service purchased.
9.
State the full name and last known address of each person who:
(a)
Witnessed or claims to have witnessed any act of negligence alleged in your
petition;
(b)
Was present or claims to have been present at the scene immediately before, at
the time of or immediately after any act of negligence alleged in your
petition;
(c)
Has personal knowledge or claims to have personal knowledge of the nature and
extent of the injuries you claim decedent to have suffered as a result of the
act(s) of negligence alleged in your petition; and,
(d)
Has or claims to have personal knowledge of any act of negligence alleged.
10.
Experts: List and identify:
(a)
Each person this defendant expects to call as an expert witness at the trial,
whether the witness is a retained expert or non-retained expert, stating for
each such expert:
(i)
Name;
(ii)
Address;
(iii)
Occupation;
(iv)
Place of employment;
(v)
Qualifications to give an opinion (if such information is available on an
expert's curriculum vitae, you may attach a copy thereof in lieu of
answering this interrogatory subpart); and,
(b)
With respect to each expert listed, please state the subject matter on which
the expert is expected to testify and the expert's hourly deposition fee.
11.
State whether or not, following the act(s) of negligence alleged in your
petition, a statement, interview, or report, or a stenographic, mechanical,
electrical, audio, video, motion picture, photograph or other recording, or
transcription thereof, of the defendant or any of defendant's agents, servants
and employees or of a statement made by the defendant or any of defendant's
agents, servants and employees and contemporaneously recorded, has been secured
or taken from defendant or any of defendant's agents, servants, and employees;
if so, state the following:
(a)
Name of person from whom secured or taken;
(b)
Date, place and time taken;
(c)
Name and address of the person or persons connected with taking it;
(d)
Name and address of all persons present at the time it was taken;
(e)
Whether the statement was oral, written, shorthand, recorded, taped, etc.;
(f)
Was it signed? and,
(g)
Names and addresses of the persons or organizations under whose direction and
upon whose behalf it was taken or made.
12.
Identify every person, firm or corporation other than your attorney and persons
mentioned in answers to other interrogatories, to whom you or the decedent made
any statement or given information relating to the decedent's physical condition
or ability to work in connection with any application for employment, disability
benefits or pecuniary payments of any nature, since the date of the act(s) of
negligence alleged in your petition including, but not limited to, any insurance
company.
13.
State whether there exists any photographs, x-rays, motion pictures, videotapes,
drawings or other visual reproductions of any type depicting the alleged
injury(ies) and damages described in your petition and if so, for each, state:
(a)
The name and address of the person making the visual reproduction(s) and the
date thereof;
(b)
What each visual reproduction depicts; and,
(c)
The name and address of the person having custody of each said visual
reproduction.
14.
State whether, as a result of the act(s) of negligence or injuries alleged in
your petition, you or plaintiff's decedent have received settlement monies,
received any Medicare and/or Medicaid payments or had Medicare and/or Medicaid
payments made on your behalf, or have received anything whatever of value and,
if your answer is in the affirmative, please state:
(a)
The nature of the payment (i.e. settlement money, Medicare payment, Medicaid
payment, or the like);
(b)
The name of the person, firm, association, company, corporation or other
entity paying the amount and the name of the recipients; and,
(c)
The date said amount was paid and/or received.
15.
State whether you have entered into any type of settlement agreement, release,
covenant-not-to-sue, covenant-not-to-enforce-judgment, an agreement in the
nature of a "Mary Carter Agreement," a covenant-to-sue, or contract to
limit recovery to specified assets, with any person, firm, corporation, insurer,
or any other entity relating in any way to any of the incidents or injuries
mentioned in your petition or any of the damages claimed under this lawsuit. If
so, please state as to such settlement, agreement release, covenant, or
contract: the date; the amount of consideration involved; and the complete legal
name and present address of the person or entity involved.
16.
What dollar amount of damages is plaintiff seeking in this lawsuit?
17.
What was the date, time and place of decedent's death and the immediate cause of
death?
18.
Was a death certificate prepared after the death of the decedent? If so, state:
(a)
Whether it was filed;
(b)
The office in which it was filed; and,
(c)
The address of the person listed on the certificate as informant.
19.
Was an autopsy performed on the body of the decedent? If so, state:
(a)
The name, address and official capacity of each person authorizing or ordering
the autopsy;
(b)
Why the autopsy was performed;
(c)
The name and address of the person performing the autopsy;
(d)
The date and time the autopsy was performed; and,
(e)
The name and address of each person having custody of the results of the
autopsy.
20.
State whether you claim to have lost any pecuniary value from the death of your
decedent as the result of the alleged negligence of these defendants and, if so,
state with specificity the amount claimed to be lost and describe in exact
detail how said value was calculated.
21.
State whether your decedent's estate is being administered and, if so, state the
following:
(a)
The name of the estate and file number; and,
(b)
The City, County and State of administration and the name and address of the
applicable court.
22.
State the name and address of every person who supported the decedent, in whole
or in part, and as to each person named, state the following:
(a)
The relationship between the decedent and the person; and,
(b)
The amount of support in dollars, for the three years preceding the date of
the decedent's death.
23.
State the name and address of each person who the decedent supported, in whole
or in part, and as to each person named, state the following:
(a)
The relationship between the decedent and the person; and,
(b)
The amount of support in dollars, for the three years preceding the date of
the decedent's death.
24.
State the names and addresses of
all persons residing in Boone County who are related to plaintiff by blood or
marriage.
25.
Pursuant to Section 573.080 RSMo., state the name and address of all persons
entitled to seek damages for the alleged wrongful death which is the subject
matter of this lawsuit.
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