COMES NOW Plaintiff and propounds the following request for documents to Defendant [redacted] (“Defendant”) to be answered separately and fully in writing as required by law. All documents should be produced, pursuant to Kansas law, to [redacted] or at such other place as maybe mutually agreed upon by counsel for the parties.

REQUESTS

1. All nursing and medical records, including lab work in Defendant’s possession and control regarding Plaintiff.
2. An itemized bill setting forth the detail of the specific charges made by Defendant in connection with Plaintiff’s residency.
3. The personnel files of all nurses or other staff members, who to Defendant’s knowledge witnessed or claimed to have witnessed Plaintiff’s health deteriorate from the dates of December 1, 2012 through December 7, 2012 through December 7, 2012. The personal files may be redacted to exclude financial, medical or other information unrelated to patient care as long as any such documents are identified in a timely and appropriate privilege log.
4. The personnel files of all nurses or other staff members, who were responsible for creating and/or updating Plaintiff’s care plan from December 1, 2012 through December 7, 2012. The personal files may be redacted to exclude financial, medical or other information unrelated to patient care as long as any such documents are identified in a timely and appropriate privilege log.
5. The personnel files of all nurses or other staff members, who were responsible for supervising and/or training Defendant’s staff about resident care planning and policies and procedures regarding the care, treatment, and monitoring of diabetic patients in 2012. The personal files may be redacted to exclude financial, medical or other information unrelated to patient care as long as any such documents are identified in a timely and appropriate privilege log.
6. The job descriptions of each nurse or other staff member who to Defendant’s knowledge, having knowledge of facts relating to the implementation of staff intervention, medication administration, nutrition management, glucose management and monitoring and other means to control Plaintiff’s blood sugar levels from December 1, 2012 through December 7, 2012.
7. The job descriptions of each nurse or other staff member who were responsible for creating and/or updating dating Plaintiff’s care plan from December 1, 2012 through December 7, 2012.
8. All policies, procedures, rules, regulations, bylaws, and guidelines relating to the care and treatment of diabetic residents in effect in 2012.
9. All policies, procedures, rules, regulations, bylaws, and guidelines relating to physician notification and/or implementation of physician’s orders in effect in 2012.
10. All policies, procedures, rules, regulations, bylaws, and guidelines regarding the staff requirements for staying up to date on Defendant’s policies and procedures in effect in 2012.
11. A complete copy of any insurance policy potentially providing coverage for the matters alleged in the Petition.
12. Defendant’s by-laws as they existed in 2012.
13. The table of contents for all of Defendant’s policies and procedures as they existed in 2012.
14. The following policies and procedures and documents relating thereto as they existed in 2012, and any amendment since that time:
    1. Care planning;
    2. Care of diabetic residents;
    3. Glucose monitoring;
    4. Nutrition Management;
    5. Implementation of physician’s orders;
    6. Communications between Defendant’s staff and outside personnel, including but not limited to: pharmacy staff;
    7. Communications between Defendant’s staff and resident’s physicians and/or other health care providers;
    8. Oversight, monitoring, and/or supervision of Defendant’s staff;
    9. Documentation and/or charting;
    10. Incident reports;
    11. Physician notification;
    12. Transfers; and
    13. Discharge planning;
15. All changes to policies and procedures previously identified in the last five (5) years.
16. All audit trails for all electronic records pertaining to Plaintiff.
17. All documents setting forth the training provided to nursing staff and other employees regarding Defendant’s policies and procedures in 2012.
18. All documents in your custody or right of control relating in any way to the care and/or treatment of Plaintiff.
19. All documents identified in Defendant’s responses to Plaintiff’s Interrogatories.
20. All documents within Defendant’s custody or right of control pertaining to the incident which is the subject of Plaintiff’s Petition, including but not limited to:
    1. Incident reports;
    2. Written or otherwise recorded statements by Defendant’s personnel;
    3. Any and all reports, statements, memoranda, proceedings, findings and/or other records reviewed by any review committee; and
    4. All sentinel event reports created by you.
21. All records, correspondence, photographs or other documents of any sort or type regarding Plaintiff, which were created before suit was filed and which are not a part of Plaintiff’s chart and/or medical records. To the extent you claim any such documents are protected by a privilege, please provide a privilege log.
22. All documents concerning Defendant’s review, adoption, or approval process of policies and procedures in place at Defendant’s facility in 2012.
23. All standards, internal rules, regulations, guidelines, policies, procedures and/or protocols pertaining to the hiring, retention and termination of individuals rendering care to patients in effect in 2012.
24. All documents showing any accreditation or licensure of Defendant by any organization and/or regulatory body during 2012.
25. All documents supporting any claim that Plaintiff’s injury or injuries were caused, in whole or in part, by the action or inaction of any other person or entity.
26. The specific records in Plaintiff’s chart to which any alterations, additions, subtractions, corrections or changes have been made.
27. All documents, contracts or agreements setting forth the responsibilities, if any, of Defendant to train, supervise, monitor, and/or evaluate its nursing staff and nursing personnel in 2012.
28. Copies of all petitions or complaints filed against Defendant within the past five years.
29. All writings (including emails and other forms of electronic documentation) prepared by any employee or agent of defendant pertaining to the injuries sustained by Plaintiff while a resident at Defendant’s facility.
30. All reports assessing staff adequacy at Defendant’s facility from January 1, 2012, until the time of Plaintiff’s final discharge from the facility.
31. Programs, textbooks, manuals, or other materials in connection with training given to employees and agents of Defendant responsible for nursing services in 2012, such employees including, but not limited to, Director of Nursing and assistants, Health Service Supervisor and assistants, staff nurses, charge nurses, certified medication technicians, certified medication aides; certified nurses’ aides, nurses’ aides, social service workers, activity directors, and restorative aides.
32. Copy of any agreement entered into by and between Defendant and any other person and/or entity for the management of the facility known as Defendant during the calendar year 2012.
33. Staffing goals and guidelines of Defendant’s facility for each wing on each shift, for every day of the week, for calendar year 2012.
34. Copies of resident council committee minutes during calendar year 2012.
35. Complaints made to Defendant regarding injuries sustained by residents of Defendant’s facility during calendar year 2012.
36. Copies of agreements, minutes and notes of Advisory Board and Resident Care Policy Committees during calendar year 2012.
37. Any committee recommendations as to how the death of Plaintiff in 2012 could have been prevented.
38. Records of all in‑service meetings held from January 1, 2012, through December 31, 2012 at Defendant’s facility and records of attendance at said meetings, and records of persons excused from said meetings by the administrator and/or Director of Nursing.
39. Copies of the daily and weekly census sheets for the year 2012 while Plaintiff resided at Defendant’s facility. You are instructed to delete resident names or other identifiable information.
40. Copies of the educational programs for annual training seminars provided to nursing personnel, including Director of Nursing and assistants, Health Service Supervisor and assistants, staff nurses, charge nurses, certified medication technicians, certified medication aides, certified nurses’ aides, nurses’ aides, social service workers, activity directors, and restorative aides, and agency personnel for calendar year 2012 at Defendant’s facility.
41. Monthly meeting minutes of utilization review committee during calendar year
42. Produce copies of the Policy and Procedure Manual(s) used by the Administrator at Defendant’s facility during calendar year 2012.
43. Reports prepared by consultants, employees, or independent contractors in any way relating to resident safety for Defendant’s facility for calendar years 2008, 2009, 2010, 2011, and 2012.
44. Copies of corporate policies and procedures in effect during calendar year 2012 regarding:
    1. Hiring, retention, and termination of employees;
    2. Notification to physician’s resident and/or resident’s family of changes in the resident’s medical condition;
    3. Duties and responsibilities of the administrator; and
    4. Falsification of resident records.
45. Public relations, yellow pages advertising and advertising brochures/programs directed to hospitals, retirement villas, long‑term residential facilities, families of residents, and/or facilities, pertaining to the service provided by Defendant during calendar year 2012.
46. A copy of any and all agreements entered into between Defendant and either co-defendant that would have been in effect in 2012.
47. A copy of any and all agreements entered into between Defendant and its administrator that would have been in effect in 2012.
48. A copy of the administrator’s license(s) for Defendant’s facility for calendar year 2012.
49. A copy of the Director of Nursing’s nursing license(s) who acted in such capacity during the time Plaintiff was a resident at Defendant’s facility.
50. A copy of all written, recorded or transcribed statements by Plaintiff, her family members, Defendant, or any witnesses to the events which are the subject of this action and which were obtained by any representatives and/or agents of Defendant or in the possession of the attorneys or agents of said Defendant and obtained prior to the notification of the lawsuit.
51. Records, correspondence, or other tangible documents regarding the investigation and/or finding by any local, State or Federal Agencies regarding the death of Plaintiff, including any responses provided by defendant to any State or Federal agencies.
52. Records, correspondence, or other tangible documents regarding the investigation and/or finding by any local, State or Federal Agencies regarding harm suffered by any resident of Defendant in the years 2008, 2009, 2010, 2011, and 2012, including any responses provided by Defendant to any State or Federal agencies, relating to glucose monitoring.
53. Any and all material used by Defendant’s nursing personnel as it relates to care of diabetic residents in 2012.
54. A copy drawn to scale of the floor plan of Defendant’s facility during the time Plaintiff resided at the facility.
55. A copy of the operating budget, including any drafts and amendments, for Defendant’s facility, during the time Plaintiff resided at the facility.
56. A copy of the job description and duties of the employees who charted the nursing care to Plaintiff, including the responsibilities and duties of the administrator and Director of Nursing, during the time Plaintiff resided at the facility.
57. Copies of any agreements with consultants related to resident care including those dealing with issues pertaining care of diabetic residents during calendar year 2012.
58. A copies of all Incident/Accident Reports pertaining to any incidents/injuries sustained by Plaintiff while a resident at Defendant’s facility.
59. Copies of any and all investigative reports conducted by defendant, other than those conducted by or at the instruction of counsel, or in anticipation of litigation, pertaining to the death of Plaintiff while residing at Defendant’s facility.
60. Produce the employee file of any and all employees at Defendant’s facility who provided care to Plaintiff in October of 2012 through December of 2012. As it relates to the employee file, you are requested to produce evaluations, performance assessments, suspensions, disciplinary proceedings, termination letters and/or resignation letters.
61. Produce a copy of any and all records including “studies” maintained at the corporate office regarding the care of diabetic resident in any facility owned, operated and/or managed by Defendant.
62. All records which would identify the rationale in support of the amount which was budgeted for nursing services, and any amendments thereto, during calendar year 2012.
63. Any and all records which would identify the amount which was spent for nursing services, during calendar year 2012.
64. Any and all records which would identify the amount which was budgeted for Agency Services to provide nursing services, and any amendments thereto, during calendar year 2012.
65. Any and all records which would identify the amount which was spent for Agency Services to provide nursing services, and any amendments thereto, during calendar year 2012.
66. Any and all records which would reflect management and/or nursing personnel requests for additional funding to provide additional nursing staff during calendar year 2012.
67. Mortality statistics of any facility owned, operated and/or managed by Defendant during calendar year 2012, month‑to‑month, for residents who died in any such facility or died in the hospital after transfer from any such facility.
68. Please produce the acuity reports prepared at or for Defendant’s facility during calendar year 2012. For purposes of this request you are specifically instructed to delete the name of every resident from the documents.
69. All materials included in the packages supplied to employees regarding bonus for administrators and/or Directors of Nursing during calendar year 2012.
70. A copy of all correspondence, memoranda or written materials sent by Defendant’s administrator and/or the Director of Nursing to Defendant’s corporate offices or corporate representatives, and responses this to regarding the quality of care provided to its residents, as well as staffing levels, budgets, finances and acuity of the resident census, for calendar year 2012. For the purpose of this request you are instructed to delete the name or other identifiable information pertaining to each individual resident.
71. A copy of the cost reports submitted to the State of Kansas and/or the Kansas Department of Aging during calendar year 2012 relating to resident care at Citizens Medical Center, Inc. d/b/a Prairie Senior Living Complex.
72. A copy of the agency employees’ employment records, vouchers, invoices submitted to agencies for work performed by the agency personnel at Defendant’s facility during calendar year 2012.
73. A copy of the Contract(s) entered into by and between Defendant with any agency or company that provided personnel to perform nursing services and/or therapy services at Citizens Medical Center, Inc. d/b/a Prairie Senior Living Complex during calendar year 2012, including but not limited to: pharmacy services and/or physician services.
74. A copy of the document retention policy at Defendant during calendar year 2012.
75. Produce any and all letters written by the Medical Director regarding quality of care provided to residents of Citizens Medical Center, Inc. d/b/a Prairie Senior Living Complex during calendar year 2012. For purposes of this request you are specifically instructed to delete the name of every resident (except Plaintiff) from the documents.
76. Produce a copy of Defendant’s organization structure.
77. Produce a copy of Defendant’s organization structure within Defendant.