1st Rogs to Facility’s Corp Owner Fall Case

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI
AT KANSAS CITY

PLAINTIFF’S FIRST INTERROGATORIES TO

DEFENDANT 

[redacted]

COMES NOW, Plaintiff by and through her attorney of record and submit to Defendant [redacted], the following interrogatories to be answered, in writing, under oath, as provided by the Missouri Rules of Civil Procedure:

INTERROGATORY NO. 1:

Please state:

1. Whether Defendant is being sued in its full and correct name and, if not, please provide the full and correct name;
2. Defendant’s present address;
3. Any other addresses at which Defendant has been located during the past ten (10) years.

ANSWER

INTERROGATORY NO. 2:

State the name, address and position held of the person answering these interrogatories on behalf of Defendant, and state whether the person answering these interrogatories has made a due and diligent search of all documents containing information which are the subject of these interrogatories.

ANSWER:

INTERROGATORY NO. 3:

State the name, job title, and employer(s) of each person that contributed in any way to gathering of the information upon which you answers to these Interrogatories are based.

ANSWER:

INTERROGATORY NO. 4:

For each owner of this Defendant for the time period of 2013, please state:

1. Name;
2. Job Title;
3. Job Description;
4. The specific service the individual performed for the benefit of The Facility;
5. The approximate number of hours per week performing tasks for the benefit of The Facility;
6. Last known address; and
7. Percent of ownership.

ANSWER:

INTERROGATORY NO. 5:

For each officer of this Defendant for the time period of 2013, please state

1. Name;
2. Job Title;
3. Job Description;
4. The specific service the individual performed for the benefit of The Facility;
5. The approximate number of hours per week performing tasks for the benefit of The Facility;
6. Last known address; and
7. Percent of ownership.

ANSWER:

INTERROGATORY NO. 6:

For each employee of this Defendant for the time period of 2013, please state

1. Name;
2. Job Title;
3. Job Description;
4. The specific service the individual performed for the benefit of The Facility;
5. The approximate number of hours per week performing tasks for the benefit of The Facility;
6. Last known address; and
7. Percent of ownership.

ANSWER:

INTERROGATORY NO. 7:

With regard to this Defendant, please state the following:

1. The State and date of registration;
2. The names and addresses of the shareholders and their respective percentage of ownership from the date of registration to date;
3. The names and addresses of the officers and directors of the corporation or LLC from the date of registration to date;
4. The date defendant began operating the facility;
5. The names and addresses of all other skilled nursing, intermediate care, residential care, and/or extended care facilities owned or operated by defendants; and
6. Whether defendants are a parent or subsidiary of any other company or corporation. If so, identify each and every said parent or subsidiary company or corporation.

ANSWER:

INTERROGATORY NO. 8:

With regard to any insurance policy, primary or excess, with provides or may provide coverage to this Defendant, please state:

1. All applicable policies by the name of the insurer, policy number, and effective policy period;
2. The total amount of the policy for each applicable period;
3. Whether or not the policy is considered to be a “wasting” policy;
4. The maximum liability limits for each person and each occurrence, including umbrella and excess liability coverage; and
5. The name insured(s) under each policy.

ANSWER:

INTERROGATORY NO. 9:

Please describe each and every service this Defendant performed for The Facility during the period 2013.

ANSWER:

INTERROGATORY NO. 10:

For the time period of 2013, please state whether there were any written agreements between this Defendant and The Facility. If so, please identify:

1. The name of the person(s) who signed the agreement(s) on behalf of this Defendant;
2. The job title of the person(s) who signed the agreement(s) on behalf of this Defendant;
3. The name of the person(s) who signed the agreement(s) on behalf of The Facility; and
4. The job title of the person(s) who signed the agreement(s) on behalf of The Facility; and
5. The current location of all current and former versions of all written agreements.

ANSWER:

INTERROGATORY NO. 11:

Please identify any amounts paid between this Defendant and [redacted] for any services provided during the calendar year 2013.

ANSWER:

INTERROGATORY NO. 12:

State the name and last known address of any individual who has held position of Director of Operations with [redacted] at any time during 2013 and specify the dates such person(s) held the position.

ANSWER:

INTERROGATORY NO. 13:

State whether a statement, interview, report, or a stenographic, mechanical, electrical, audio, video, motion picture, photograph or other recording, or transcription of Plaintiff, Plaintiff, or any representative of Plaintiff was taken by this Defendant, and if so, state the following:

1. Date, place and time taken;
2. Name(s), address(es) and telephone number(s) of the person(s) connected with taking it;
3. Name(s), address(es) and telephone number(s) of the person(s) present at the time it was taken;
4. Whether the statement was oral, written, shorthand, recorded, taped, etc.;
5. Was it signed;
6. Name(s), address(es) and telephone number(s) of the person(s) or organization(s) under whose direction and upon whose behalf it was taken or made; and
7. Please attach an exact copy of the original of said statement, interview, report, file, or tape to your answers to these Interrogatories; if oral, please state verbatim the contents thereof.

ANSWER:

INTERROGATORY NO. 14:

Was any action taken by the state, federal or other governmental unit relating in whole or in part to the treatment rendered by Defendant to Plaintiff? If so, state the following:

1. The unit of government taking the action;
2. The date the action was taken; and
3. A description of the nature of the action taken.

ANSWER:

INTERROGATORY NO. 15:

Identify the amount and source of any money received by Defendant on behalf of Plaintiff as consideration for her residency and treatment at The Facility.

ANSWER

INTERROGATORY NO. 16:

Please state the following for each person you expect to call as a retained or non-retained expert witness at trial:

1. Name;
2. Address;
3. Occupation;
4. Place of employment;
5. Qualifications to give an opinion; and
6. General nature of the subject matter on which the expert is expected to testify.

ANSWER:

INTERROGATORY NO. 17:

If you contend that any of the injuries alleged by Plaintiffs in the petition were caused by the negligence or fault of any person or healthcare provider, please identify that person or provider by name, address and occupation, and indicate the factual basis for your contention.

ANSWER:

INTERROGATORY NO. 18:

List the name, address and last known telephone number of all persons who are former employees of Defendant (other than persons heretofore listed) who have knowledge of the facts of the care and treatment complained of in the Petition and/or the injuries claimed to have resulted therefrom.

ANSWER:

INTERROGATORY NO. 19:

Identify any statements, information and/or documents known to you and requested by any of the foregoing interrogatories or the accompanying request for production of documents which you claim to be work product or subject to any common law or statutory privilege, and with respect to each such statement, information, or document, specify the legal basis for the claim.

ANSWER:

INTERROGATORY NO. 20:

Identify the name, address and title of all principals, including but limited to officer, director, owner, partner, key employee or other person with primary management or supervisory responsibilities, in the operation of The Facility.

ANSWER: