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CIVIL DISTRICT COURT FOR THE PARISH OF ORLEANS FILED DEPUTY CLERK PLAINTIFF'S INTERROGATORIES TO DEFENDANT Plaintiff, , through undersigned counsel, propounds the following Interrogatories to defendant, Touro Infirmary, to be answered fully, separately, in writing, and under oath, within the delays allowed by law: State when the accident referred to in the Petition for Damages first came to the attention of the defendant or any employee or company representative of the defendant, by whom it was reported, to whom it was reported, and the means used in the reporting, whether oral or in writing. List the name, address, job title, employer, location, and activity at the time of the accident asserted by plaintiff of all persons known or believed by defendant to have: a) Eyewitnessed or have been within sight or hearing of the accident; b) First hand knowledge of the facts and circumstances of the accident or the events leading up to and following the accident, or of the conditions at the accident scene. Provide the names and addresses of all persons (including but not limited to the plaintiff) from whom written or recorded statements, reports, memoranda, or testimony has been obtained by defendant or any person working on behalf of defendant, pertaining to the accident or damages asserted by plaintiff in the petition for damages, the events preceding the accident, and / or events following the accident, and identify the date of the taking of the statement (s), the location where the statement was taken and the person taking the statement (s). Please explain in complete detail your routine inspection and maintenance procedures of all hospital beds, prior to and at the time of the incident made subject of this litigation. Please state if any meetings or discussions were held or conducted before or after the incident in question, specifically regarding the procedure for locking and unlocking beds, identify the names of all participants, the subject matter of any such meetings or discussions, the person (s) providing any information or documentation, or bulletins, etc. , discussed, all person (s) receiving any information or exchanging any information, the date (s) and times of the meeting (s) and any actions taken as the result of the meetings, or conclusions or policy changes made as a result of meetings. Discuss, in detail, any and all policies, standards, regulations, and / or procedures promulgated by and / or adhered to by defendant, regarding the performance of bed weights of patients and safety procedures, if any, on unlocking and locking of beds.
Please identify by name, last known address, last known telephone number, employment title, and employment status with Touro Infirmary as of the date of these Interrogatories, the person (s) who performed a bed weight on the patient in room M 419 on the date of the incident made subject of this litigation. Please identify by name, last known address, last known telephone number, employment title, and employment status with Touro Infirmary at the time of these Interrogatories, of each and every person on duty on the ward that includes room M 419 at the time of the incident made subject of this litigation. Please identify by name, last known address, last known telephone number, employment title, and employment status with Touro Infirmary of each and every person believed to have knowledge of the incident made subject of this litigation, other than those persons previously identified in answers to interrogatories, including, but not limited to emergency room staff, radiology staff, and risk management staff. Have any other incidents or injuries occurred in the same or similar manner as the incident made the subject of this litigation? If so, state the names of the person (s) injured, date injured, last known address (s), and last known telephone number (s), and state whether litigation resulted therefrom, and if so, the name, place and docket number of any law suit.
Please state if Touro Infirmary owned, rented, leased, or in any other way possessed a HOYER-LIFT, or some other similar device utilized in the act of lifting persons, on the date of the incident made subject of this litigation. If so, state the exact location of said device at the time of the incident made subject of this ligation. Please identify by name, address, telephone number, and job title each and every person who you currently anticipate may be called as a witness at trial, and the substance of each witnesses' testimony. Please identify each and every document you currently anticipate introducing into evidence at trial. Please fully identify any and all liability insurance policies in effect at the time of the incident made subject to this litigation. I HEREBY CERTIFY that a copy of the foregoing has this day been mailed to all counsel of record by depositing same in the United States Mail, postage prepaid and properly addressed.
New Orleans, Louisiana, this day of, 1999. Bibliography:
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