Defendant, Dr. Mandy Moore, by and through her attorneys, Vincent Chase and Ari Gold, requests complete responses to his Requests for Production of Documents:
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REQUEST NO. 1: All photographs, sketches or diagrams relating in any way to the allegations of the Plaintiff’s Complaint.
RESPONSE NO. 1:
REQUEST NO. 2: Any and all documents identified by the Plaintiff in response to the interrogatories propounded by this Health Care Provider.
RESPONSE NO. 2:
REQUEST NO. 3: Any and all reports from any experts retained by the Plaintiff in preparation or for testimony at trial.
RESPONSE NO. 3:
REQUEST NO. 4: any and all documents, photographs, diagrams and any and all other tangible pieces of evidence which the Plaintiff intends or expects to introduce as evidence at the trial of this occurrence.
RESPONSE NO. 4:
REQUEST NO. 5: All records of any special damages claimed, including, but not limited to, invoices, statements, receipts for payment and insurance vouchers.
RESPONSE NO. 5:
REQUEST NO. 6: All signed and recorded statements relative to this occurrence given by the Defendant or by and of his alleged agents, servants or employees or by any other health care practitioner or any other person.
RESPONSE NO. 6:
REQUEST NO. 7: Any documents, reports, or other records concerning or otherwise giving evidence to the nature and amount of expenses or losses made or incurred by the Plaintiff or for which you intend to make claim, including past, present and future expenses, losses and damages.
RESPONSE NO. 7:
REQUEST NO. 8: Any economic or other reports predicting or in any way relating to future expenses, losses or damages for which you intend to make claim.
RESPONSE NO. 8:
REQUEST NO. 9: Any and all diaries, journals or other documents created by you or on your behalf which in any way memorialize or document your recollection of any events relating to the allegations in the Complaint, including any damages claimed.
RESPONSE NO. 9:
REQUEST NO. 10: Any and all documents and materials provided to or reviewed by any expert witness whom you expect to call at trial, without regard to whether any document forms the basis of the expert’s opinion, or whether or not said documents were found by the expert to be helpful.
RESPONSE NO. 10:
REQUEST NO. 11: Any and all documents and materials (including all drafts and working papers thereof) prepared by any person whom you expect to call as an expert witness at trial.
RESPONSE NO. 11:
REQUEST NO. 12: The most recent curriculum vitae of your certifying expert and any person whom you expect to call as an expert witness at trial.
RESPONSE NO. 12:
REQUEST NO. 13: Any and all documents which you received from the Defendant, or anyone you contend to be his agent, servant or employee, which you contend relates to your allegations.
RESPONSE NO. 13:
REQUEST NO. 14: Any and all documents which you contend to be (or which you contend contain) an admission or statement against interest of this Defendant, or his agent, servant and/or employee.
RESPONSE NO. 14:
REQUEST NO. 15: Any and all documents which support, refer to, relate to or otherwise document any position you intend to take, or any claim for damages you intend to make in this action.
RESPONSE NO. 15:
REQUEST NO. 16: Any release, settlement agreement or other document which limits, reduces or extinguishes (and/or potentially reduces or extinguishes) the actual and/or potential liability of any other party to this matter.
RESPONSE NO. 16:
REQUEST NO. 17: Any and all articles, treatises, texts, abstract or other publications which you or your experts contend are reliable and/or authoritative on any of the issues in this case.
RESPONSE NO. 17:
REQUEST NO. 18: Any and all documents which prove, verify or substantiate any fact which you contend is relevant to your allegations.
RESPONSE NO. 18:
REQUEST NO. 19: Records of any telephone calls made by you, or on your behalf, to any health care provider regarding the medical care which forms the basis of your complaint. Such records shall include, without limitation, cellular phone bills, long distance phone records or notes or other documentation of any aspect of such telephone calls.
RESPONSE NO. 19:
REQUEST NO. 20: Records of any telephone calls made to you, or anyone else on your behalf, by any health care provider regarding the medical care which forms the basis for your complaint. Such records shall include, without limitation, cellular phone bills, long distance phone records or notes or other documentation of any aspect such as telephone calls.
RESPONSE NO. 20:
REQUEST NO. 21: All medical records, mental records, financial records, bills, invoices, writing, notes or memoranda relating in any way to all of the decedent’s physical, mental or medical conditions, illnesses or disabilities, including but not limited to those of doctors, nurses, practitioners, hospitals, clinics, institutions or other health care providers or third party private or governmental health or accident insurers, without regard to whether it is the Plaintiff’s contention that such physical, mental or medical conditions, illnesses, or disabilities were cause in any way by the Defendant or any agent or employee of the Defendant for a period of ten (10) years before and up to the date of the decedent’s death.
With regard to any medical or hospital records referred to in this Request which are in existence but are not physically in the possession or custody of the Plaintiff or the Plaintiff’s attorney but which are in the Plaintiff’s control, the Defendant requests that the Plaintiff execute authorizations to each doctor or hospital where such records exist to allow the Defendant to obtain and examine copies of said records.
RESPONSE NO. 21:
REQUEST NO. 22: Copies of any and all of your medical insurance cards, including Medicare and Medical Assistance, in effect for the occurrence, from the time of the occurrence up to and including the present.
RESPONSE NO. 22:
REQUEST NO. 23: For th
e past 10 years, all employment records relating in any way to your employment or self-employment, including the name and address of all employers, the dates of employment with each employer (i.e., date of hire, date of employment ended), the records of the dates absent from work for any reason whatsoever, the records relating to the fact and duration of any unemployment, the records of workers’ compensation claims, unemployment insurance claims, welfare applications, and applications for assistance from any governmental agency because of unemployment or ill health, and all payroll records.
With regard to any employment records referred to in the preceding paragraph which are in existence but are not physically in the possession or custody of the Plaintiff or the Plaintiff’s attorney but which are in the Plaintiff’s control, the Defendant requests that the Plaintiff execute authorizations to allow the Defendant to examine and obtain copies of said records.
RESPONSE NO. 23:
REQUEST NO. 24: All of your federal and state tax returns for a period of ten (10) years prior to the occurrence to the present.
With regard to any tax returns referred to in the preceding paragraph which are in existence but are not physically in the possession or custody of the Plaintiff or the Plaintiff’s attorney but which are in the Plaintiff’s control, the Defendant requests that the Plaintiff execute authorizations to allow the Defendant to examine and obtain copies of said records.
RESPONSE NO. 24:
REQUEST NO. 25: All documents referring or relating to any settlement, loan receipt, subrogation agreement, release, or similar agreement between you and any person or persons with respect to the alleged malpractice or injuries sustained by you.
RESPONSE NO. 25:
REQUEST NO. 26: All of your records of workers’ compensation claims, unemployment insurance claims, welfare applications, social security disability claims, and applications for assistance from any governmental agency because of unemployment, disability or ill health.
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Respectfully submitted,
Defendant’s Malpractice Lawyers
Note: This is a sample of the Defendant’s medical malpractice lawyers request for production of documents in a medical malpractice case.