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STATE OF NORTH CAROLINA

COUNTY OF DURHAM

 


IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
      FILE NO.

_____________, Administratrix of the )
Estate of ___________________, )
deceased, and ____________, )
)

Plaintiffs,

)
)
         vs. )

PLAINTIFFS' FIRST SET

)

OF INTERROGATORIES TO

_______________________, Inc. and )

DEFENDANT ____________

____________,
)

________________, INC.

Defendants.

)
_____________________________ ___ )

          Pursuant to the provisions of Rule 33 of the North Carolina Rules of Civil Procedure, plaintiffs request that the Defendant,  ____________, answer the following Interrogatories under oath within forty-five (45) days of service hereof.
          As used in these Interrogatories, the term, "defendant" includes, in addition to the named defendant, attorneys, agents, servants, employees, representatives, private investigators, or others who are in the possession of or who may have obtained information for or on behalf of the named defendants. Furthermore, the meaning of the word "document" shall include, but not be limited to, writings, drawings, graphs, charts, photographs, reports, computer disks, and other data compilations from which information can be obtained or translated, if necessary, through devices or other equipment into reasonable, usable form.
          If the information furnished is not within the personal knowledge of the person who verifies the responses to this discovery request, please state the name, if known, of each person to whom the informavtion is a matter of personal knowledge.
          "Identify" when used to refer to a person, means to state the person's name, job title, business and residential addresses, and telephone number.
          "Identify" when used to refer to a document, means to state the title or description of the document, to identify the author, the date the document was authored, and to identify the present custodian of the document.
          As used herein, "____________" refers to the defendant, "____________, Inc.
          In order to make your answers fully understandable, plaintiffs request that you provide your answer in the space following each Interrogatory, or precede each answer by a restatement of the Interrogatory.

          1.     Identify by name, address, professional title, and specialty area all persons who you know participated in the medical and nursing care and treatment rendered ____________ from March, 2000 through May, 2000.
          RESPONSE:



          2.     Other than any individuals identified in your answer to Interrogatory No. 1, please identify by name, address, and job title all persons who you believe have or are likely to have knowledge of the medical and nursing care and treatment rendered to __________ from March, 2000 through May, 2000, including but not limited to health care providers who may have witnessed, but not participated in, the care rendered.
          RESPONSE:



          3.     Identify and state the contents of all insurance agreements under which any person or entity carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse for payment made to satisfy the judgment.
          RESPONSE:




          4.     Identify all documents containing written rules, regulations, by-laws, procedures, policies, and standing orders governing or pertaining to nurses and other employees practicing or working for __________ from March, 2000 through May, 2000.
          RESPONSE:



          5.     Identify all documents relating to the nursing care provided to __________, and plans to provide __________ home health care services, including, but not limited to, documents, records, nursing notes, other notes, communications, including telephone records and notes of telephone conversations, and correspondence between __________ and any other health care providers, governmental agencies, and any other persons, firms or corporations relating to __________ during the period of time between November 29, 1999 and the date of your response to these interrogatories.
          RESPONSE:



          6.     Identify all records and documents relating to applications for employment, hiring, retaining, evaluation of job performance, training, orientation, supervision, and employment of ____________ by __________.
          RESPONSE:





          7.     Identify all documents relating to payments received by ____________ for services provided to ____________.
          RESPONSE:




          8.     Identify all documents and records relating to time records, hours worked, and compensation of ____________during the period of time between March 1, 2000 and the date of your response to these interrogatories.
          RESPONSE:




          9.     Identify all documents relating to applications for licenses and accreditations, surveys, inspections, risk management programs, and quality assurance programs of __________ from January 1, 1998 to the date of your response to these interrogatories.
          RESPONSE:





          10.     Identify all documents relating to any investigation(s) conducted into the care __________ received during May of 2000, including, but not limited to, any communications to your insurance companies, attorneys, nursing board, governmental agencies, and/or any other investigation into such care.
          RESPONSE:



          11.     Identify the owner(s) of __________ from March 1, 2000 to the date of your response to these interrogatories.
          RESPONSE:





          12.     State whether or not __________ had been subjected to, and was in compliance with, the standards and regulations promulgated by the Joint Commission on the Accreditation of Healthcare Organizations (JCAHO) as of March 1, 2000.
          RESPONSE:






          13.     With respect to the care of __________ during May,2000, identify any incident report made concerning the events described in the Complaint, including, but not limited to, the nursing care provided to __________ on the evening of May 7, 2000, and on the morning of May 8, 2000, and all documents relating to this incident that were generated in compliance with your risk management program.
          RESPONSE:






          14.     State whether defendant ____________ was ever cited, reprimanded or disciplined in any way by __________ during the time she was associated with __________. If the answer is "yes," describe the dates, action(s) taken, and reasons therefor.
          RESPONSE:





          15.     Describe all lawsuits and complaints, written or oral, legal, administrative, or otherwise, brought by anyone against __________ because of an alleged negligent act, or on some other ground, in connection with services rendered by __________, and/or any of its agents and/or employees, regardless of the date of such lawsuit or complaint, stating the name and address of the person who so complained, the entity or person against whom the lawsuit or complaint was made, the basis of the lawsuit or complaint, the date that the lawsuit or complaint was commenced, the title and address of the court or other authority before whom the lawsuit or complaint was heard, and the final disposition of the matter. Identify all documents which record or contain such information.
          RESPONSE:





          16.     Identify any evaluation or investigation conducted in connection with the care provided to __________ by __________ and/or any of its agents and/or employees during May of 2000, including the date the evaluation or investigation was conducted and the names, titles, addresses, and telephone numbers of each person involved in conducting the evaluation or investigation, and identify all documents generated by any such evaluation or investigation.
          RESPONSE:




          17.     Identify any reports, statements, recordings, memoranda, or testimony concerning the facts in this action, obtained prior to the institution of this action by plaintiffs, by the defendants or anyone acting on defendants' behalf, from any witness or person, whether or not such documents are signed, and whether or not prepared by someone other than the said witness, stating specifically the name, address, and telephone number of the witness referred to, the date that such information was obtained, the name, address, and phone number of the person who now has possession of the information or materials, the name, address, phone number, and employer of the person who obtained the information or materials, the name, address, and employer of the person at whose request the information was obtained, and the contents of each such statement, report, recording, memoranda, or testimony.
          RESPONSE:





          18.     Please state whether or not __________, and/or any of its employees and/or agents have knowledge of any written report, statement, memorandum, recording, or testimony, whether signed or not, from the plaintiff ________________ or anyone associated with her concerning the matters made the basis of this action, and, if so, state the name and address of the person receiving such information, the date that such information was obtained, the name and address of the person currently in possession of the information, the name, address, employer, and telephone number of the person who obtained the information, and the name, address, and employer of the person at whose request the information was obtained.
          RESPONSE:






          19.     Identify all documents pertaining to "contingencies" in accreditation with respect to __________ identified by the Joint Commission on Accreditation of Healthcare Organizations from January 1, 1998 through the present date.
          RESPONSE:





          20.     Identify each expert whom you anticipate calling as a witness at trial, stating each expert's name, address, occupation and specialty area, the subject matter on which the expert is expected to testify, the substance of the facts and opinions to which the expert is expected to testify, and a summary of the grounds for each opinion.
          RESPONSE:



          21.     Identify by name, title, and address each person who assisted or participated in preparing and/or supplying any of the information given in answer to or relied upon in preparing answers to these Interrogatories.
          RESPONSE:



          This the __________ day of _________________, 2003

 
BENTLEY LAW OFFICES, P.A.

_____________________________
Charles A. Bentley, Jr. Post Office Box 52089 Durham, North Carolina 27717 (919) 682-3700

Michael Sosna 4001 Hampton Drive Rocky Mount, NC 27803 (252) 937-1090

Attorney for Plaintiffs

 


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