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 correspondence or communications between Defendant and Plaintiff, her agent(s) and/or family members.
2. All documents provided to Plaintiff, her agent(s) or family members prior to June 20, 2012.
3. All documents regarding any representation made to Plaintiff, her agent(s) and/or family members prior to June 20, 2012.
4. All informational, marketing, and advertising materials provided to Plaintiff, her agent(s) and/or family members prior to June 20, 2012.
5. All informational, marketing, and advertising materials provided to potential residents from January 1, 2012 to the present.
6. All documents regarding Defendant’s “Family Decision Guide” from January 1, 2012 to the present.
7. All documents regarding Defendant’s “Personal Decision Guide” from January 1, 2012 to the present.
8. Copies of all manuals, booklets, pamphlets, written instructions, training and educational materials provided to employees and/or agents of Defendant regarding the marketing and advertising of Defendant’s facility from January 1, 2012 to the present.
9. Copies of all manuals, booklets, pamphlets, written instructions, training and educational materials provided to employees and/or agents of Defendant regarding “tours” of Defendant’s facility from January 1, 2012 to the present.
10. All documents regarding any tour Defendant gave of its facility to Plaintiff, her agent(s) and/or family members prior to June 20, 2012.
11. All documents regarding Defendant’s “testimonials” located on its website at [redacted] from January 1, 2012 to the present.
12. All documents regarding Defendant’s representation(s) that it offers “assistance with activities of daily living” from January 1, 2012 to the present.
13. All documents provided to potential residents, their agents, or family members in response to a “Request for Information” from January 1, 2012 to the present.
14. All documents regarding any reprimand, action, complaint, or discovery actions taken against Defendant for its marketing or advertising practices by any state or federal entity.
15. All written or oral complaints made by any resident, his or her agent(s), or family members concerning the services offered by your facility from January 1, 2012 to the present that are related to resident safety and/or well-being.
16. All documents supporting Defendant’s representation(s) that “[o]ur safe, residential environment is staffed by an expert team that provides support and assistance when you need it” from January 1, 2012 to the present.
17. All documents evidencing the qualifications of Defendant’s staff members, who would have comprised the “expert team” responsible for providing support and assistance to Plaintiff when she needed it during her residency at [redacted].