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Sample Nursing Home Interrogatories

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

Civil Division

WHITNEY JONES, et al.,
Plaintiffs,

v.

CHERRYWOOD LTD PARTNERSHIP t/a FUTURE CARE – CHERRYWOOD
Defendant.

Case No.:

INTERROGATORIES PROPOUNDED ON DEFENDANT
FUTURE CARE – CHERRYWOOD BY PLAINTIFFS

TO: FUTURE CARE-CHERRYWOOD, Defendant

FROM: WHITNEY JONES, Plaintiff

The Plaintiffs, by and through their attorneys, Miller & Zois, LLC, request that Defendant Future Care – Cherrywood fully, under oath, and in accordance with the Maryland Rule of Civil Procedure, Rule 2-421, answer the following Interrogatories subject to the instructions set forth below:

Instructions

  1. These Interrogatories are continuing in character so as to require you to file supplementary answers if you obtain further or different information before trial.
  2. Unless otherwise stated, these Interrogatories refer to the time, place, and circumstances of the occurrence mentioned or complained of in the Complaint;
  3. Where name and identity of a person is required, please state full name, home address and also business address, if known.
  4. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party’s agents, representatives, and unless privileged, his attorneys. When answer is made by corporate defendant, state the name, address and title of persons supplying the information and making the affidavit, and announce the source of his or her information.
  5. The pronoun “you” refers to the party to whom the Interrogatories are addressed and the parties mentioned in clause (d).
  6. “Identify” when referring to an individual, corporation, or other entity shall mean to set forth the name and telephone number, and if a corporation or other entity, its principle place of business, or if an individual, the present or last known home address, his or her job title or titles, by whom employed and address of the place of employment.

Interrogatories

  1. Set forth in detail your full name, address, date of existence, and identify the corporate representative that has knowledge of the procedures, protocols, and safeguards at your facility for the prevention of bed sores, the prevention of ulcers and wound care prevention and care.
  2. If you intend to offer any expert opinion in the case at bar (to specifically include whether you and any and all of your employees/agents followed the applicable standard of medical care) or intend to offer or rely upon the opinion of any expert witness, then name all experts you propose to call as witnesses and for each describe the nature of their specialties, their experience, training and medical affiliations, all opinions which they have reached/rendered and the factual basis for each such opinion. Attach to your answers copies of all written reports made by each expert.
  3. State the name, address, and telephone number of each person having personal knowledge of facts material to this case. For each person please indicate the nature of that person’s knowledge and whether that person is still your employee.
  4. Name all persons who are or have been investigating for you the cause and circumstances of the occurrence referenced in Plaintiffs’ Complaint, including the issues of liability and damages.
  5. If you have obtained any written or recorded statements concerning the occurrence referenced in Plaintiffs’ Complaint, set forth the name and address of the person who gave the statement, the name and address of the person who recorded the statement and wrote it, the date of the statement, the content of the statement, and the present custodian of the statement.
  6. If you contend that the late Natalie Jones, or any of the Plaintiffs, acted in such a manner as to cause or contribute to the occurrence alleged in the Plaintiffs’ Complaint or her subsequent medical condition and death, please set forth in a complete statement of the facts upon which you rely to support your contention and provide the name, address, and telephone number of each person who has personal knowledge of the facts upon which you so rely.
  7. If you contend that a party or person or other legal entity, not a party to this action acted in such a manner as to cause or contribute to the occurrence referenced in the Plaintiffs’ Complaint, then give a complete statement of facts upon which you rely and provide the name, address and telephone number of any persons with personal knowledge of facts upon which you so rely.
  8. If you contend that the late Natalie Jones’s injuries and subsequent death were the result of prior or subsequent injuries, diseases, medical conditions, or medical care provided by someone other than your employees/agents, give a complete statement of the facts upon which you rely.
  9. If you know of the existence of any pictures, movies, computer generated evidence, electronically stored data, videotapes, diagrams, x-rays, documents, medical records, reports, or objects (real evidence), medical journals, or written procedures relative to the occurrence or the issue of damages, then state the nature, subject matter, title, object, thing, the date produced or obtained, and the name and address of the present custodian of each.
  10. Set forth in detail the following information pertaining to all policies or agreements of liability insurance covering or pertaining to acts or omissions committed by or on your behalf as a result of providing health care services at the time of the occurrence referenced in the Plaintiffs’ Complaint, designating which, if any, are primary coverage and which are excess coverage: name and address of the insurance carrier, all limits of liability coverage, name and address of the named insured and policy number, full descriptions of acts or omissions to which coverage extends, full description of any and all exclusions, the dates of coverage, and the present custodian of the policy, and list any other claims made against you which are also covered by these policies in question.
  11. State whether you were a partnership, professional association, professional corporation, or any other legal entity providing health care at any time during your treatment and examination of the late Natalie Jones. If yes, indicate the name of such partnership, professional association, professional corporation, or legal entity and provide the names and addresses of each partner, president, treasurer, or shareholder, indicate the nature and degree of interest in such partnership, professional association, professional corporation or legal entity. If said partnership, professional association, professional corporation, or legal entity is no longer in existence, then indicate the date and manner of dissolution.
  12. Identify and give the substance of each statement, action or omission, and declaration against interest, whether oral or written, by conduct, silence or otherwise, which you contend was made by or on behalf of the late Natalie Jones and the Plaintiffs and provide the time, place and date when each such statement was made and to whom the statement was made.
  13. Please list any and all precautions and actions that you and any of your medical staff took to prevent the late Natalie Jones from developing bed sores and/or ulcers.
  14. State whether you have in your hospital or facility any policy, rule, regulation, procedure, protocol, guideline, form, or standard, concerning or referring to the evaluation of patients to determine their potential for developing bed sores and/or ulcers and the treatment of bed sores and/or ulcers. If so, describe same in detail, and indicate whether these policies, regulations, forms, and guidelines are in any written form or other form that is electronically stored on any computer o
    r other data storage device.
  15. State whether you contend in any way that the court in which the Plaintiffs have filed the complaint does not properly have jurisdiction over this action, and if you so contend, specify the reasons and bases you assert for challenging jurisdiction (e.g., service of process of pleadings, sufficiency of any expert certificate, expert report, filing of pleadings, etc.). This interrogatory is specifically asked to prevent the defense from delaying challenges to any expert certificates or reports so as to assert later an argument that this action is barred by limitations.
  16. State whether you contend in any way that the expert certificate(s) and/or expert report(s) filed by Plaintiffs in this action in the Health Care Alternative Dispute Resolution Office and in this Court are in any way insufficient and do not satisfy applicable statutory requirements, and specify in detail the bases and reasons for your contentions. This interrogatory is specifically asked to prevent the defense from delaying challenges to any expert certificate(s) or report(s) so as to assert later an argument that this action is barred by limitations.
  17. Do you agree that the late Natalie Jones’s death was proximately caused by complications that arose from her developing bed sores while under your care? If your answer is no, then please state what you contend is the proximate cause of the late Natalie Jones’s death and any and all experts who will render this opinion.
  18. Please indicate where precisely in the medical chart (the date, time and page) that any of your employees and medical staff first discovered that the late Natalie Jones had a bed sore on her body, to include the location of the bed sore and/or ulcer the size of the bed sore and/or ulcer.
  19. Please state what action and medical treatment plan you and your medical staff developed and took to prevent the bed sore/ulcer referenced in your answer to interrogatory number 18 from becoming worse.
  20. If you assigned or had any nurse or medical staff that had specialized training in wound care, such as a “wound care nurse” or “wound care doctor” please state the name and addresses of that person, and whether that person was or still is your employee or an independent contractor.
  21. Please state the very first date and time that any person identified in answer to interrogatory number 20 actually provided any medical care to the late Natalie Jones.
  22. Do you admit that the standard of medical care that was applicable to you and your medical staff and employees for the medical care provided to the late Natalie Jones while she was a patient in your facility is the same standard of care followed whether she was a patient at your nursing home or any other nursing home in Maryland. If your answer is no then please explain why you contend and believe the standard of care is different at your facility than at any other similar nursing home in the state of Maryland and the expert witnesses who will provide opinions on this different standard of care.
  23. Please state any and all dates and times wherein any of the Plaintiffs met with you or any of your employees, nurses, Board of Directors, President, Director of Medical Services wherein the situation regarding the bed sores and/or ulcer on the late Natalie Jones were discussed. Please state any and all conversations by and between the Plaintiffs and your employees, Board of Directors, President, Director of Medical Services and what any of your employees, Board of Directors, President, Director of Medical Services said to the Plaintiffs.
  24. If you are aware of any alterations, modifications, deletions, or changes to the late Natalie Jones’s medical chart, please state each such alteration, modification, deletion, and/or change, by the exact page in the medical chart, state the record that was changed, altered, modified or deleted, who performed the modification/alteration/deletion/change and the reason why the chart was altered/modified/deleted/ changed.
  25. If you, or any of your employees and experts disagree with any of the statements contained in Natalie Jones’s death certificate, or contend that the cause of death as indicated in the death certificate is incorrect, please state each statement that you disagree with, the reason for the disagreement, what you believe and contend the statement should be,and what you claim was the proximate cause of the death of the late Natalie Jones.

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