Plaintiff, by and through her attorney of record, submits to Defendant                                                 the following interrogatories to be answered, in writing, under oath, as provided by Rule 57.01 of the Missouri Rules of Civil Procedure:

INTERROGATORIES

1. 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:

2. With regard to 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 from the date of registration to date;
   4. The names and addresses of all other skilled nursing, intermediate care, residential care, and/or extended care facilities owned or operated by Defendant; and
   5. Whether Defendant is a parent or subsidiary of any other company or corporation. If so, identify each and every said parent or subsidiary company or corporation.

ANSWER:

3. State the name and last known address of any individual who has held position of Administrator of Defendant at any time between September 1, 2013 and December 1 2013, and specify the dates such person held the position.

ANSWER:

4. State the name and last known address of any individual who has held the position of Director of Nursing of Defendant at any time between September 1, 2013 and December 1 2013, and specify the dates such person held the position.

ANSWER:

5. State the name and last known address of any individual who has held the position of Medical Director of Defendant at any time between September 1, 2013 and December 1 2013, and specify the dates such person held the position.

ANSWER:

6. Identify the name and business office of any physician who was either employed by Defendant or was retained for patient care for patients of Defendant at any time between September 1, 2013 and December 1 2013, and specify the dates such person held the position.

ANSWER:

7. Please identify any agents, employees or servants of Defendant whose termination or whose voluntary resignation was in any way related to Defendant’s investigation into the care and treatment provided to Plaintiff.

ANSWER:

8. State the name, last known address, and the beginning and ending dates of employment of each and every registered nurse, licensed practical nurse, certified nurse aide, and restorative aide or other direct care provider who was employed at [redacted] between and including September 1, 2013 and December 1 2013.

ANSWER:

9. Identify all individuals, whether they be an administrator, doctor, nurse, nurses aide, or other staff member, who were directly responsible for providing monitoring, assessment, care and/or treatment of Plaintiff between and including September 1, 2013 and December 1 2013.

ANSWER:

10. List the name and address of all persons (other than persons heretofore listed) who have knowledge of the facts of the care and treatment complained of in the Petition filed herein and/or the injuries claimed to have resulted therefrom.

ANSWER:

11. Please identify the person for Defendant with the most knowledge as to the numbers of nursing personnel, including nurses, nurse aides, medication aides, etc., on duty at [redacted] between September 1, 2013 and December 1 2013.

ANSWER:

12. Have you (or has anyone acting on your behalf) had any conversations with any person (other than your attorney) at any time with regard to the injuries complained of in the Petition or the manner in which the care and treatment alleged in the Petition was provided, or are you aware of any statement made by any persons at any time with regard to the injuries complained of in the Petition or the manner in which the care and treatment alleged in the Petition was provided? If so, please state:
    1. The date or dates of such conversation(s) and/or statement(s);
    2. The place of such conversation(s) and/or statement(s);
    3. All persons present for the conversation(s) and/or statement(s);
    4. The matters and things stated by the person in the conversation(s) and/or statement(s);
    5. Whether the conversation(s) was oral, written and/or recorded; and
    6. Who has possession of the statement(s) if written and/or recorded.

ANSWER:

13. If you notified a physician or family member of Plaintiff of any significant change in Plaintiff’s condition between September 1, 2013 and December 1 2013, and said notification is not specifically documented in Plaintiff’s medical records, please identify each such notification by stating the date, time, person who made the communication, the physician who received it, and the substance of such communication.

ANSWER:

14. Has Defendant or any of its employees been named as a Defendant in a lawsuit arising from alleged malpractice or professional negligence during the five (5) year period preceding the filing of this lawsuit? If so, identify the court, the caption, and the case number for such lawsuit.

ANSWER:

15. State whether Defendant was named or covered under any policy or policies of insurance which may indemnify Defendant in whole or in part against the payment of any judgment or settlement in this cause. If so, state for each policy:

a. The name of the insurance company;

b. The policy number;

c. The effective policy period;

d. The maximum liability limits for each person and each occurrence, including umbrella and excess liability coverage; and

e. The name insured(s) under each policy.

ANSWER:

16. Were any photographs, movies, and/or videotapes taken of Plaintiff or of the care and treatment received by Plaintiff while a resident of [redacted]? If so, state the date(s) on which such photographs, movies and/or videotapes were taken, who is displayed therein, who now has custody of them, and the name, address and occupation of the person taking them.

ANSWER:

17. 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:

18. 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:

19. 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:

20. State the net worth of the Defendant for each of the last five (5) years.

ANSWER:

21. State the gross income of Defendant for each of the last five (5) years.

ANSWER:

22. State the net income of the Defendant for each of the last five (5) years.

ANSWER:

23. 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:

24. 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: