Form 219. Defendant’s Requests for Production—

Defendant’s Requests for Production— Medical Negligence No. CV- : SUPERIOR COURT (Plaintiff) : JUDICIAL DISTRICT OF VS. : AT (Defendant) : (Date) The Defendant(s) hereby request(s) that the 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) All hospital records relating to treatment received as a result of the negligence alleged in the Complaint, and to injuries, diseases or defects to which reference is made in the answers to Interrogatories #6 and #24 (exclusive of any records relating to mental health injuries or conditions), or written authorization, sufficient to comply with the provisions of the Health Insurance Portability and Accountability Act (HIPAA), to inspect and make copies of the hospital records. Information obtained pursuant to the provisions of HIPAA shall not be used or disclosed by the parties for any purpose other than the above captioned action. (2) All reports and records of all physicians and other health care providers relating to treatment allegedly received by the Plaintiff(s) as a result of the negligence alleged in the Complaint and to the injuries, diseases or defects to which reference is made in the answers to Interrogatories #7, #22, and #24 (exclusive of any records relating to mental health injuries or conditions) or written authorization, sufficient to comply with the provisions of the Health Insurance Portability and Accountability Act (HIPAA) to inspect and make copies of said reports. Information obtained pursuant to the provisions of HIPAA shall not be used or disclosed by the parties for any purpose other than the above captioned action. (3) If a claim of impaired earning capacity or lost wages is being alleged, 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 negligence alleged in the Complaint and for all years subsequent to the date of the negligence alleged in the Complaint through the time of trial. (4) If a claim for lost wages or lost earning capacity is being made, 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 negligence alleged in the Complaint and for all years subsequent to the date of the negligence alleged in the Complaint. (5) A copy of any nonprivileged statement, as defined in Practice Book Section 13-1, of any party to this lawsuit concerning this action or its subject matter. (6) All medical bills that are claimed to have been incurred as a result of the negligence alleged in the Complaint or written authorization, sufficient to comply with the provisions of the Health Insurance