2nd Rogs to Fall Case
IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI
AT KANSAS CITY
PLAINTIFF’S SECOND 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:
State the name, address and position held of the person certifying the accuracy and truthfulness of CMS Form 2540 on behalf of [redacted] for the year 2013.
ANSWER
INTERROGATORY NO. 2:
State the name, address and position held of the person certifying the accuracy and truthfulness of CMS Form 2540 on behalf of Defendant for the year 2013.
ANSWER:
INTERROGATORY NO. 3:
State the name, address and position held of the person completing the “Resident Fall Risk” contained in the medical chart, page [redacted] 114.
ANSWER:
INTERROGATORY NO. 4:
State the name, address and position held of the person completing the “Restraint Assessment” contained in the medical chart, pages [redacted] 118-120.
ANSWER:
INTERROGATORY NO. 5:
State the name, address (or last known address) and position held of the person completing the Resident Care Plan contained in the medical chart, pages [redacted] 162-172.
ANSWER:
INTERROGATORY NO. 6:
According to the 42 CFR483.75, please list the members of Defendant governing body for the year 2013.
ANSWER:
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:
State the name, address and position held of the person certifying the accuracy and truthfulness of CMS Form 2540 on behalf of [redacted] for the year 2013.
ANSWER
INTERROGATORY NO. 2:
State the name, address and position held of the person certifying the accuracy and truthfulness of CMS Form 2540 on behalf of Defendant for the year 2013.
ANSWER:
INTERROGATORY NO. 3:
State the name, address and position held of the person completing the “Resident Fall Risk” contained in the medical chart, page [redacted] 114.
ANSWER:
INTERROGATORY NO. 4:
State the name, address and position held of the person completing the “Restraint Assessment” contained in the medical chart, pages [redacted] 118-120.
ANSWER:
INTERROGATORY NO. 5:
State the name, address (or last known address) and position held of the person completing the Resident Care Plan contained in the medical chart, pages [redacted] 162-172.
ANSWER:
INTERROGATORY NO. 6:
According to the 42 CFR483.75, please list the members of Defendant governing body for the year 2013.
ANSWER:
