Form 223. Plaintiff’s Requests for Production—

Plaintiff’s Requests for Production— Medical Negligence—Hospital/Medical Group No. CV- (Plaintiff) VS. (Defendant) : SUPERIOR COURT : JUDICIAL DISTRICT OF (l) Pathology reports; (m) Drafts and/or audio recordings of pathology reports; (n) Quality improvement documents related to root cause analysis; (o) Documents provided in connection with a peer review; (p) Intradepartment transportation records; (q) Laboratory test results; (r) Documents and communications concerning the subject matter of the Complaint; and (s) Investigations or reports concerning the Plaintiff and the allegations in the Complaint. COMMENT: Where privilege is claimed, counsel shall follow the relevant Practice Book rule(s). This request contemplates production of all medical records and documents, not limited to the treatment related to the allegations in the Complaint, subject to the Plaintiff providing a Health Insurance Portability and Accountability Act compliant authorization if necessary. (2) Each document identified in response to Interrogatory #5. (3) A copy of the declaration page(s) of each insurance policy identified in response to Interrogatories #6 and #7. (4) If the answer to Interrogatory #8 is in the affirmative, a copy of the complete policy contents of each insurance policy identified in response to Interrogatories #6 and #7. (5) Each nonprivileged statement identified in response to Interrogatories #10 and #12. (6) 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 lawsuit concerning this lawsuit or the subject matter thereof, including any transcript of such recording. PLAINTIFF, BY___________________________ CERTIFICATION I certify that a copy of this document was or will immediately be mailed or delivered electronically or non-electronically on (date) ______ to all attorneys and self-represented parties of record and that written consent for electronic delivery was received from all attorneys exempt from e-filing and self-represented parties of record who received or will immediately be receiving electronic delivery.