Form 216

(8) If a claim for lost wages or lost earning capacity has been made as a result of the alleged incident, copies of, or sufficient written authorization to inspect and make copies of the wage and employment records of all employers of the Plaintiff(s) for three (3) years prior to the date of the incident and for all years subsequent to the date of the incident to and including the date hereof. (9) If a claim of impaired earning capacity or lost wages has been made as a result of the alleged incident, copies of, or sufficient written authorization to obtain copies of, that part of all income tax returns relating to lost income filed by the Plaintiff(s) for a period of three (3) years prior to the date of the incident and for all years subsequent to the date of the incident through the time of trial. (10) All property damage bills that are claimed to have been incurred as a result of the alleged incident. (11) All medical bills that are claimed to have been incurred as a result of this incident or written authorization, sufficient to comply with the provisions of the Health Insurance Portability and Accountabil- ity Act (HIPAA), to inspect and make copies of said medical bills. Information obtained pursuant to the provisions of HIPAA shall not be used or disclosed by the parties for any purpose other than the litigation or proceeding for which such information is requested. (12) All bills for each item of expense that is claimed to have been incurred in the answer to Interrogatory #23, and not already provided in response to Production Requests #10 and #11. (13) Copies of all documentation of claims of right to reimbursement provided to the Plaintiff by third- party payors, and copies of, or written authorization, sufficient to comply with provisions of the Health Insurance Portability and Accountability Act (HIPAA), to obtain any and all documentation of payments made by a third party for medical services received or premiums paid to obtain such payment. Informa- tion obtained pursuant to the provisions of HIPAA shall not be used or disclosed by the parties for any purpose other than the litigation or proceeding for which such information is requested. (14) All documents identified or referenced in your answer to Interrogatories #32 and #33. (15) A copy of any nonprivileged statement, as defined in Practice Book Section 13-1, of any party in this action concerning this action or its subject matter. (16) Any and all photographs or recordings identified in response to Interrogatory #38. (17) A copy of all records of blood alcohol testing or drug screens referred to in the answer to Interrogatory #39, or a signed authorization, sufficient to comply with the provisions of the Health Insurance Portability and Accountability Act (HIPAA) or those of the Public Health Service Act, whichever is applicable, to obtain the same. Information obtained pursuant to the provisions of HIPAA or the Public Health Service Act shall not be used or disclosed by the parties for any purpose other than the litigation or proceeding for which such information is requested. (18) A copy of each and every recording of surveillance material discoverable under Practice Book Section 13-3 (c), by film, photograph, video, audio or any other digital or electronic means, of any party to this action concerning this action or the subject matter thereof, including any transcript of such recording. (19) 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) referenced in your answer to Interrogatory #34.