Form 211. Defendant’s Requests for Production—

Defendant’s Requests for Production— Workers’ Compensation Benefits—Intervening Plaintiff No. CV- : SUPERIOR COURT (Plaintiff) : JUDICIAL DISTRICT OF VS. : AT (Defendant) : (Date) The Defendant(s) hereby request(s) that the Intervening Plaintiff provide counsel for the Defendant(s) with copies of the documents described in the following requests for production, or afford counsel for said Defendant(s) the opportunity or, where requested, sufficient written authorization, to inspect, copy, photograph or otherwise reproduce said documents. The production of such documents, copies or written authorizations shall take place at the offices of not later than sixty (60) days after the service of the Requests for Production. In answering these production requests, the Plaintiff(s) are required to provide all information within their possession, custody or control. If any production request cannot be answered in full, answer to the extent possible. (1) Produce a copy of the First Report of Injury (Form FRI), Notice of Claim for Compensation (Form 30C), Notice of Intention to Reduce or Discontinue Benefits (Form 36), and Notice to Administrative Law Judge and Employee of Intention to Contest Employee’s Right to Compensation Benefits (Form 43). (2) Produce a copy of all of the approved voluntary agreements, approved stipulations to date, approved full and final stipulations, findings and awards, and findings and denials that relate to one or more of the claims referenced in your answer to Interrogatory #2 on Form 210. (3) Produce a copy of all reports of medical exams requested by the administrative law judge, respondent and/or employer that were prepared concerning any of the claims referenced in your answer to Interrogatory #2 on Form 210. (4) Produce a copy of your workers’ compensation lien calculations. COMMENT: These standard requests for production are intended to tailor the discovery from the intervening compensation carrier to the limited role and limited material information in the workers’ compensation lien holder’s file. The existing standard requests for production directed to the Plaintiffs place an unnecessary burden on the parties, result in discovery disputes, and require the compensation carrier to produce information and documentation, in many instances, that is duplicative of the responses engendered by the same requests for production served upon the Plaintiff in the case. DEFENDANT, BY