Form 222. Plaintiff’s Requests for Production—

Plaintiff’s Requests for Production— Medical Negligence—Health Care Provider No. CV- : SUPERIOR COURT (Plaintiff) : JUDICIAL DISTRICT OF VS. : AT (Defendant) : (Date) The Plaintiff(s) hereby request(s) that the Defendant (Defendant Health Care Provider’s Name) provide counsel for the Plaintiff(s) with copies of the documents described in the following requests for production, or afford counsel for said Plaintiff(s) the opportunity or, if necessary, 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 on (day), (date) at (time). In answering these production requests, the Defendant(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. Definition: ‘‘You’’ or ‘‘your’’ shall mean the Defendant to whom these interrogatories are directed, except that if the Defendant has been sued as the representative of the estate of a decedent, ward, or incapable person, ‘‘you’’ or ‘‘your’’ shall also refer to the Defendant’s decedent, ward or incapable person unless the context of an interrogatory clearly indicates otherwise. (1) All documents (excluding privileged documents, such as attorney-client, work product, and peer review documents) that you know of, possess, or have power to obtain, concerning the Plaintiff’s care, scheduling, appointments, treatment, evaluation, diagnosis, consultation or referral to others including but not limited to: (a) All documents normally maintained as part of a patient’s designated health record; (b) Office management records including jackets, file covers, face sheets, transmittal documents for any requests for studies or consultations, and/or transportation records; (c) Nursing notes; (d) Hospital records; (e) Laboratory records; (f) Testing records; (g) Radiology requisitions, reports, images/studies (lossless images), and audio recordings of radiology reviews; (h) Notes, sticky notes or written markings; (i) Pharmacy medication records; (j) Automated medication dispensing system records;