Philadelphia Cnty. C.P. CP-Trial Division-Civil 22

For each of the above Interrogatories, please pro vide the name, address and position of the person who

supplied the information in the foregoing Interrogatories.

II. Addressed to the Doctor

1. Set forth the following details regarding your medical education and preparation for practice:

(a) medical school(s) attended, dates of attendance and year of graduation;

(b) place and period of internship;

(c) nature of subjects covered during internship;

(d) names and specialties of physicians who trained you during internship;

(e) place and period of residency;

(f) subject of residency;

(g) names and specialties of physicians who trained you during residency;

(h) nature and period of any graduate studies and where they were pursued;

(i) inclusive dates of any armed forces service; and

(j) nature of armed forces service, including nature of any medical experiences.

2. Set forth the name of each medical organization with which you are affiliated or of which you are a

member.

3. If you have ever been certified by any specialty board, or if you are now or have ever been a mem ber of

any specialty board, set forth the following:

(a) the name and address of each specialty board;

(b) the date you were certified or became a member; and

(c) if you are no longer certified or a member, give the date your certification or membership was terminated

and the reason for the same.

4. Identify all publications, including but not limited to papers, journal articles, letters to the editor, textbooks,

symposiums, etc., which you authored or contributed to, including the title of the work, the name of the

periodical or book in which it was printed, the pages you wrote and the date of its printing.

5. Identify by author, title and year of publica tion, every textbook in (subject/specialty) which you had in

your office from (relevant years).

6. Identify by author, title and year of publication, every textbook in (subject/specialty) which you regularly

referred to and/or relied upon in the (relevant years).

7. Set forth the name of each medical journal you subscribed to in (relevant years).

8. Set forth the name of each medical journal you read regularly in (relevant years).

9. Identify each office, clinic or other location relat ing to the practice of medicine maintained by you, or in

which you otherwise worked, subsequent to your internship or residency and set forth the inclusive dates you

maintained each such location.

10. Set forth the names of all hospitals with which you were affiliated prior to (relevant years);

(a) with respect to each such hospital set forth your positions and responsibilities.

11. Set forth the names of all hospitals with which you are presently affiliated;

(a) with respect to each hospital set forth your position(s) and responsibilities.

12. Were you associated, or in partnership with any other medical practitioner at the time of the occurrences

which are the subject of this action?

13. If so, state:

(a) the name, address, specialty and qualificati ons of each person with whom you were associat ed or in

partnership;

(b) the nature of your business relationship to such person;

(c) the terms and conditions of the relationship;

(d) the date you formed the relationship;

(e) whether the relationship still exists, and if not, the reason and date it was terminated; and

(f) whether any written agreement existed be tween you and your associates or partners, and if so, the name

and address of the person who has custody of the agreement.

14. Identify each and every contract or other document establishing or otherwise referring to the relationship

between ___________________________ (Hospital) to ______________________________ (Doctor).

15. 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.

16. State whether you were covered by or were the subject of any policy of liability insurance for the injuries

arising out of the instant case.

17. If the answer to interrogatory #16 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 aggregated;

(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.

18. If the answer to interrogatory #16 is in the affirmative, state whether any Exclusion under the policy is or

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

19. If the answer to interrogatory # 18 is in the affirma tive, state the precise language of each Exclusion

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

such Exclusion is or may be applicable.

20. 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.

21. If the answer to interrogatory #20 is in the affirmative, as to each 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.

22. With respect to any conversations of which you are aware, in which the na ture of, alternatives to and/or

risks of the procedure in question 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.