COMES NOW, Plaintiff by and through her attorney of record and requests Defendant [redacted] (“Defendant”) to produce the following documents pursuant to the Missouri Rules of Civil Procedure:

1. A complete copy of all written investigations, in Defendant’s possession or control regarding the care, treatment and/or condition of Plaintiff which were filed with Defendant at any time during her residency.
2. All documents, statements, electronic messages (e-mails), interviews, reports, or stenographic, mechanical, electrical, audio, video, motion picture, photograph or other recording, or transcription thereof, in Defendant’s possession or control regarding the number of staff or budgeting for staff at [redacted] during 2012 and 2013.
3. All documents, statements, electronic messages (e-mails), interviews, reports, or stenographic, mechanical, electrical, audio, video, motion picture, photograph or other recording, or transcription thereof, in Defendant’s possession or control regarding training or in-service for staff at [redacted] during 2012 and 2013.
4. All written reports in Defendant’s possession or control concerning or involving Plaintiff made by Defendant pursuant to RSMo. § 198.070.
5. Provide a blank exemplar of all written reports of incidents, complaints, accidents or injuries utilized by [redacted] in 2013.
6. A copy of any photographs, slides, negatives, videotapes, or other graphic depictions in Defendant’s possession or control which pertain to Plaintiff and/or to the allegations of the Complaint.
7. Any and all records or documentation of any kind in Defendant’s possession or control kept outside the official “medical record” of Defendant [redacted], including but not limited, to CNA charting and/or documentation, CNA Profile Sheets, and medication/pharmacy logs, pertaining to Plaintiff.
8. All correspondence including, but not limited to, electronic mail and faxes by and between any agents, employees, officers, directors, or managing agents or any other representatives of Defendant, concerning the care, treatment or medical condition of Plaintiff.
9. All [redacted] Newsletters from for the years 2011 and 2013.
10. Copy of all contracts and agreements by and between Defendant and [redacted].
11. All documents and handouts provided to the facility’s RN, LPN, CNA, MDS Coordinators, CMT, charge nurse, and nursing personnel who are responsible for chart checks and monthly Physician’s Order Sheets, for the development and improvement of skills appropriate for their job function during the time period from one month before Plaintiff’s admission to one month after Plaintiff’s discharge at [redacted].
12. All orientation materials (including Defendant’s employee handbook regarding Defendant’s employment practices, policies and procedures) provided to new employees of Defendant.
13. All emails, letters, and documents relating to any employee, agent, or representative of Defendant concerning Plaintiff.
14. The daily posting of staffing ratios for all dates from 7/1/13 to 12/1/13.
15. A copy of any and all contracts and/or agreements between the Administrator of [redacted] and Defendant.
16. A copy of any and all contracts and/or agreements between the Medical Director of [redacted] and Defendant.
17. A copy of any and all contracts and/or agreements between the Director of Nursing of [redacted] and Defendant.