[redacted] to be answered separately and fully in writing as required by law. All documents should be produced, pursuant to Missouri 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 x-rays, 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 pressure sores in September of 2013. 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 dating Plaintiff’s care plan in 2012 and 2013. 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, skin ulceration prevention, physician notification requirements, dietary services, hydration, bowel and bladder management, infection control and/or skin ulceration treatment and management of residents in 2012 and 2013. 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 disciplinary files of all nurses or other staff members, who to Defendant’s knowledge, witnessed or claimed to have witnessed Plaintiff’s pressure sore in September of 2013. 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.
7. The disciplinary files of all nurses or other staff members, who were responsible for creating and/or updating dating Plaintiff’s care plan in 2012 and 2013. 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.
8. The disciplinary files of all nurses or other staff members, who were responsible for supervising and/or training Defendant’s staff about resident care planning, skin ulceration prevention, physician notification requirements, dietary services, hydration, bowel and bladder management, infection control and/or skin ulceration treatment and management of residents in 2012 and 2013. 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.
9. The job descriptions of each nurse or other staff member who to Defendant’s knowledge, witnessed or claimed to have witnessed any change in Plaintiff ’s condition or health status including weight loss, dehydration, infection and other issues relating to the deterioration of her health beginning in January of 2013 and pressure sore in September of 2013.
10. The job descriptions of each nurse or other staff member who were responsible for creating and/or updating dating Plaintiff’s care plan in 2012 and 2013.
11. The job descriptions of each nurse or other staff member who were responsible for supervising and/or training Defendant’s staff about resident care planning, skin ulceration prevention, physician notification requirements, dietary services, hydration, bowel and bladder management, infection control and/or skin ulceration treatment and management of residents in 2012 and 2013.
12. A complete copy of any insurance policy potentially providing coverage for the matters alleged in the Petition.
13. Defendant’s by-laws as they existed at all times during Plaintiff’s residency at Defendant’s nursing home facility.
14. The table of contents for all of Defendant’s policies and procedures as existed during Plaintiff’s residency at Defendant’s nursing home facility.
15. The following policies and procedures and documents relating thereto as they existed during Plaintiff’s residency at Defendant’s nursing home facility, and any amendment since that time:
    1. Dietary/Nutrition Management;
    2. Hydration Management;
    3. Bowel and Bladder Management;
    4. Infection Control;
    5. Skin ulceration prevention;
    6. Pressure sore prevention;
    7. Decubitus ulcer prevention
    8. Care planning;
    9. Skin ulceration, pressure sore and/or decubitus ulcer assessment and evaluation;
    10. Skin ulceration, pressure sore and/or decubitus ulcer treatment;
    11. Communications between Defendant’s staff and outside personnel relating to resident care;
    12. Communications between Defendant’s staff and resident’s physicians and/or other health care providers;
    13. Oversight, monitoring, and/or supervision of Defendant’s staff;
    14. Documentation and/or charting;
    15. Incident reports;
    16. Physician notification;
    17. Transfers; and
    18. Discharge planning;
16. All changes to policies and procedures previously identified in the last five (5) years.
17. All audit trails for all electronic records pertaining to Plaintiff.
18. All documents setting forth the training provided to nursing staff and other employees regarding Defendant’s policies and procedures in 2012 and 2013.
19. All documents in your custody or right of control relating in any way to the care and/or treatment of Plaintiff.
20. All documents identified in Defendant’s responses to Plaintiff’s Interrogatories.
21. All documents within Defendant’s custody or right of control pertaining to Plaintiff’s pressure sore, 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.
22. 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.
23. All documents concerning Defendant’s review, adoption, or approval process of policies and procedures in place at Defendant’s facility in the years 2012 and 2013.
24. 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 during the years 2012 and 2013.
25. All documents showing any accreditation or licensure of Defendant by any organization and/or regulatory body during the calendar years 2012 and 2013.
26. 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.
27. The specific records in Plaintiff’s chart to which any alterations, additions, subtractions, corrections or changes have been made.
28. 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 and 2013.
29. Copies of all petitions or complaints filed against Defendant within the past five years.
30. 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.
31. All reports assessing staff adequacy at Defendant’s facility from January 1, 2012, until the time of Plaintiff’s final discharge from the facility.
32. Programs, textbooks, manuals, or other materials in connection with training given to all employees and agents of Defendant responsible for nursing services, 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.
33. Copy of any agreement entered into by and between Defendant and any other person and/or entity for the management of Defendant’s nursing home facility during the calendar years 2012 and 2013.
34. Staffing goals and guidelines of Defendant’s facility for each wing on each shift, for every day of the week, for calendar years 2012 and 2013.
35. Copies of resident council committee minutes during calendar year 2012 and 2013.
36. Complaints made to Defendant regarding injuries sustained by residents of Defendant’s facility during calendar years 2012 and 2013.
37. Produce copies of the weekly/monthly/annual pressure sore report logs or listings of Defendant’s facility for the years 2012 and 2013.
38. Copies of agreements, minutes and notes of Advisory Board and Resident Care Policy Committees during calendar years 2012 and 2013.
39. Any committee recommendations as to how any nutrition/hydration problems, skin problems, bowel and bladder problems and infections suffered by Plaintiff in 2012 and 2013 could have been prevented.
40. Records of all in‑service meetings held from January 1, 2012, through December 31, 2013 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.
41. Copies of the daily and weekly census sheets for the years 2012 and 2013 while Plaintiff resided at Defendant’s facility. You are instructed to delete resident names or other identifiable information.
42. 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 years 2012 and 2013, at Defendant’s facility.
43. Monthly meeting minutes of utilization review committee during calendar years 2012 and 2013.
44. Produce copies of the Policy and Procedure Manual(s) used by the Administrator at Defendant’s facility during calendar years 2012 and 2013.
45. Reports prepared by consultants, employees, or independent contractors in any way relating to resident safety for Defendant’s facility for calendar years 2009, 2010, 2011, 2012, and 2013.
46. Copies of corporate policies and procedures in effect during calendar year 2012 and 2013 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.
47. 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 years 2011, 2012 and 2013.
48. A copy of any and all agreements entered into between Defendant and its administrator that would have been in effect in 2012 and 2013.
49. A copy of the administrator’s license(s) for Defendant’s facility for calendar year 2012 and 2013.
50. 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.
51. 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.
52. Records, correspondence, or other tangible documents regarding the investigation and/or finding by any local, State or Federal Agencies regarding the injuries suffered by Plaintiff, including any responses provided by defendant to any State or Federal agencies.
53. Records, correspondence, or other tangible documents regarding the investigation and/or finding by any local, State or Federal Agencies regarding any injuries suffered by any resident of Defendant in the years 2009, 2010, 2011, 2012, and 2013, including any responses provided by Defendant to any State or Federal agencies.
54. Any and all material used by Defendant’s nursing personnel as it relates to the resident care planning, prevention and/or treatment of pressure sores, physician notification requirements, dietary services, hydration, bowel and bladder management, infection control and/or skin ulceration treatment and management of residents in 2012 and 2013.
55. A copy drawn to scale of the floor plan of Defendant’s facility during the time Plaintiff resided at the facility.
56. A copy of the operating budget, including any drafts and amendments, for Defendant’s facility, during the time Plaintiff resided at the facility.
57. 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.
58. Copies of any agreements with consultants related to resident care including those dealing with issues pertaining to the resident care planning, prevention and/or treatment of pressure sores, physician notification requirements, dietary services, hydration, bowel and bladder management, infection control and/or skin ulceration treatment during calendar years 2012 and 2013.
59. A copies of all Incident/Accident Reports pertaining to any incidents/injuries sustained by Plaintiff while a resident at Defendant’s facility.
60. 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 injuries sustained by Plaintiff while residing at Defendant’s facility.
61. Produce the employee file of any and all employees at Defendant’s facility who provided care to Plaintiff in September of 2013. As it relates to the employee file, you are requested to produce evaluations, performance assessments, suspensions, disciplinary proceedings, termination letters and/or resignation letters.
62. A copy of all claims that have been filed against Defendant pertaining to the care provided to residents of any [redacted] facility during the last seven years.
63. Produce a copy of any and all records including “studies” maintained at the corporate office regarding prevention and/or treatment of pressure sores, physician notification requirements, dietary services, hydration, bowel and bladder management, infection control and/or pressure sores and/or pressure sore prevention in any [redacted] facility owned, operated and/or managed by Defendant.
64. All records which would identify the rationale in support of the amount which was budgeted for nursing services, and any amendments thereto, during calendar years 2012 and 2013.
65. Any and all records which would identify the amount which was spent for nursing services, during calendar years 2012 and 2013.
66. Any and all records which would identify the amount which was budgeted for _______________ to provide nursing services, and any amendments thereto, during calendar years 2012 and 2013.
67. Any and all records which would identify the amount which was spent for ______________ to provide nursing services, and any amendments thereto, during calendar years 2012 and 2013.
68. Any and all records which would reflect management and/or nursing personnel requests for additional funding to provide additional nursing staff during calendar years 2012 and 2013.
69. Mortality statistics of any [redacted] facility owned, operated and/or managed by Defendant during calendar years 2012 and 2013, month‑to‑month, for residents who died in any such facility or died in the hospital after transfer from any such facility.
70. Please produce the acuity reports prepared at or for Defendant’s facility during calendar years 2012 and 2013. For purposes of this request you are specifically instructed to delete the name of every resident from the documents.
71. Please produce the information in support of the monies utilized-spent by defendant at [redacted] in the training of nurse’s aides for calendar years 2012 and 2013.
72. Please produce the information in support of the monies utilized-spent by defendant by any [redacted] facility owned, operated, or managed by Defendant in the training of nurse’s aides for calendar years 2012 and 2013.
73. Please produce any resignation letters provided by any employees at [redacted] during calendar years 2012 and 2013 which in any way relates to resident care.
74. All materials included in the packages supplied to employees regarding bonus for administrators and/or Directors of Nursing during calendar years 2012 and 2013.
75. 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 thereto regarding the quality of care provided to its residents, as well as staffing levels, budgets, finances and acuity of the resident census, for calendar years 2012 and 2013. For the purpose of this request you are instructed to delete the name or other identifiable information pertaining to each individual resident.
76. A copy of the cost reports submitted to the State of Missouri and/or the Missouri Department of Health and Senior Services during calendar years 2012 and 2013.
77. 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 years 2012 and 2013.
78. A copy of the Contract(s) entered into by and between Defendant with any agency that provided personnel to perform nursing services and/or therapy services at [redacted] during calendar years 2012 and 2013.
79. A copy of the document retention policy at [redacted] during calendar years 2012 and 2013.
80. Produce any and all letters written by the Medical Director regarding quality of care provided to residents of [redacted] during calendar years 2012 and 2013. For purposes of this request you are specifically instructed to delete the name of every resident (except Plaintiff) from the documents.
81. Produce all “confidential files” maintained by defendant regarding the injuries sustained by Plaintiff while a resident at [redacted]. If objection to said request is based upon privilege, please provide a privilege log as required by Missouri law.
82. Produce a copy of Defendant’s organization structure.