Philadelphia Cnty. C.P. CP-Trial Division-Civil 16

examination which is the subject matter of the complaint? (B) If the answer to (A) is in the affirmative, state:

(1) The name, address, and employer of all persons who conducted any investigations;

(2) The dates of the investigations, and

(3) The dates of any reports of any investigations and the identity of the persons who have possession thereof.

(4) Please consider this a Request to Produce your in vestigation reports, except those portions wh ich are

protected from discovery by Pennsylvania Rule of Civil Procedure 4003.3.

Experts

17.

(a) State the name and address of each person whom you expect to call as expert witnesses at trial and state

the subject matter on which the expert is expected to testify.

(b) For each such expert, state, or have the expert state, the substance of the facts and opinions to which the

expert is expected to testify and summarize the grounds for each such opinion. (Expert’s reports containing

the same information may be attached in lieu of an answer).

(c) If the expert is employed and/or self-employed, identify the employer and the nature of employ ment

thereof.

(d) Identify all documents submitted to the expert and all products and/or locales inspected by the expert in

connection with preparations for his or her testimony.

(e) Set forth the qualifications of each expert, listing the schools attended, years of attendance, degrees

received, experience in any particular field of specialization or expertise, all publications authored, including

the title of the work and the book in which it was printed giving the date of publication.

18. State the specific facts known to you or anyone acting on your behalf upon which you base each claim of

negligence or malpractice alleged in this action.

19.

(a) Were the injuries you allege in this action caused in part by sickness, disease, abnormality or injury

other than the injuries you claim resulted from the treatment, surgery or examination upon which this action

is based.

(b) If so, state specifically the nature of each such sick ness, disease, abnormality or injury and how each

affected you.

(c) Are there any medical, X-rays, hospital or other reports which indicate the nature of each such sick ness,

disease or abnormality or injury and how each affected you.

(d) If so, where and when was each report made and what is the name and present or last know n address of

the person who made each such report and each such person who has custody or possession of each such

report or any copy thereof?

(e) Have you been furnished any such information in any way other than by the documents referred to in this

Interrogatory? If so, how, when, where and by whom?

20. Do you claim that an alleged agent of the defendant caused your injuries because:

(a) He/She was not qualified to undertake the type of treatment, surgery or examination he gave?

(b) He/She failed to diagnose correctly?

(c) He/She did not obtain proper consent or authorization?

(d) He/She did not maintain proper standards of hygiene or sterilization?

(e) He/She failed to use modern techniques and procedures?

(f) He/She did not give the correct treatment?

(g) He/She failed to observe proper pre-operative, operative or post-operative procedures, specifying which?

(h) He/She was otherwise negligent, specifying the nature of the negligence.

(i) Identify the alleged agent.

21. Do you claim that an individual defendant caused the injuries because:

(a) He was not qualified to undertake the type of treatment, surgery or examination he gave?

(b) He/She failed to diagnose correctly?

(c) He/She did not obtain proper consent or authorization?

(d) He/She did not maintain proper standards of hygiene or sterilization?

(e) He/She failed to use modern techniques and procedures?

(f) He/She did not give the correct treatment?

(g) He/She failed to observe pre-operative, operative, or post-operative procedures, specifying which?

(h) He was otherwise negligent, specifying the nature of the negligence.

Note: Former Rule 145A, adopted by the Board of Judg es, November 18, 1983, effective January 3, 1983.

Amended November 14, 2014, effective February 17th, 2015.

PLAINTIFF’(S’) STANDARD FORM INTERROGATORIES

TO DEFENDANT(S) IN MEDICAL CASES

I. Addressed to the Hospital

1. Identify each and every contract or other document establishing or otherwise referring to the r elationship

between _____________________(Hospital) and ________________________ (Doctor), and/ or document

relating to the privileges granted by ________________________________(Hospital) to

______________________________ (Doctor).

2. Set forth the dates you had professional contact with the plaintiff.

(a) Please consider this a Request to Produce all records relating to said professional contact.

3. State whether you were covered by or were the sub ject of any policy of liability insurance for the injuries

arising out of the instant case.

4. If the answer to interrogatory #3 is in the affirma tive, state the following as to each such policy of

insurance:

(a) the name of each insured under the policy;

(b) the period of the policy;

(c) the amount of coverage provided by the policy for bodily injury liability for each person, for each

occurrence and in the aggregate;

(d) the amount of coverage remaining for satisfaction of judgment in this case;

(e) the type of policy; and

(f) the name of the carrier by which the policy was issued.

5. If the answer to interrogatory #4 is in the affirma tive, state whether any Exclusion under the policy is or

may be applicable to any claim presented by plaintiff’s Complaint.

6. If the answer to interrogatory #5 is in the affirma tive, state the precise language of each Exclusion which

is or may be applicable, and in summary form, the facts on the basis of which it is contended each such

Exclusion is or may be applicable.

7. State whether this case is being defended by the at torney who has entered his or her appearance on your

behalf subject to a reservation of rights agreement between you and your insurance carrier.

8. If the answer to interrogatory #7 is in the affirma tive, as to ea ch Reservation of Rights Agreement, state

the following:

(a) the name of each party to the Agreement;

(b) the date the Agreement was entered into; and

(c) according to your information, what is the stated position of the carrier as to the Reserva tion of Rights?

Answer only if informed consent is pleaded in the Complaint.

9. With respect to any conversations of which you are aware, in which the nature of, alternatives to and/or

risks of the procedure in questions were discussed with the patient, set forth:

(a) the date(s) of each conversation;

(b) the substance of each conversation;

(c) the identity of each party to the conversation;

(d) the identity of each witness to the conversation; and

(e) were there any documents relating to the na ture of, alternative to, and/or risk of the proce dure presented

to the patient? If so, please consider this a Request to Produce such docu ment or documents.

10. State the name and last known address of each person who (a) was a witness to the treatment, surgery or

examination through sight or hearing; and (b) has knowledge of f acts concerning the happening of the

treatment, surgery or examination or condi tions or circumstances at the time of the treatment, surgery or

examination prior to, after, or at time of the accident, excepting those persons who acquired such knowledge

during the course of this litigation.

11. With respect to each person identified in the answer to interrogatory #10(a), state that person’s exact

location and activity at the time of the treatment, surgery or examination.

12. Have you or anyone acting on your behalf obtained from any person any statement concerning this action

or its subject matter? If so, state:

(a) the name and last known address of each such person;

(b) when, where, by whom and to whom each statement was made, and whether it was reduced to writing or

otherwise recorded; and

(c) the name and address of any person who has custody of any such statements that were reduced to writing

or otherwise recorded.

(d) Please consider this a Request to Produce those statements referred to in the above answer.

13. Have you given any statement concerning this action or its subject matter? If so, state:

(a) the name and address of each person to whom a statement was given; and

(b) when and where each statement was given.

(c) Please consider this a Request to Produce the statements referred to in the above answer.

14. Do you know of the existence of any photographs, diagrams or models of the surrounding area or the

areas of the treatment, surgery or examination or any oth er matters or things involved in this treat ment,

surgery or examination?

15. If the answer to interrogatory #14 is in the affirmative, state:

(a) the date(s) when such photographs, diagrams or models were made;

(b) the name and address of the party making them,

(c) where they were made; and

(d) the object(s) or subject(s) each photograph, diagram or model represents.

(e) Please consider this a Request to Produce the photographs, diagrams and/or models referred to in the

above.

16. Have you, or anyone on your behalf, conducted any investigations of the treatment, surgery or exami -

nation which is the subject matter of the complaint?