____________________ ________________________

FILED DEPUTY CLERK

PLAINTIFF'S INTERROGATORIES TO DEFENDANT

Plaintiff,, through undersigned counsel, propounds the following Interrogatories to defendant, Touro Infirmary, to be answered fully, separately, in writing, and under oath, within the delays allowed by law:

State when the accident referred to in the Petition for Damages first came to the attention of the defendant or any employee or company representative of the defendant, by whom it was reported, to whom it was reported, and the means used in the reporting, whether oral or in writing.

List the name, address, job title, employer, location, and activity at the time of the accident asserted by plaintiff of all persons known or believed by defendant to have:

a) Eyewitnessed or have been within sight or hearing of the accident;

b) First hand knowledge of the facts and circumstances of the accident or the events leading up to and following the accident, or of the conditions at the accident scene.

Discuss, in detail, any and all policies, standards, regulations, and/or procedures promulgated by and/or adhered to by defendant, regarding the performance of bed weights of patients and safety procedures, if any, on unlocking and locking of beds.

Please explain in complete detail your routine inspection and maintenance procedures of all hospital beds, prior to and at the time of the incident made subject of this litigation.

Some common words found in the essay are:
Petition Damages, Touro Infirmary, Infirmary Interrogatories, HEREBY CERTIFY, incident subject, subject litigation, DEFENDANT Plaintiff, incident subject litigation, United Mail, Orleans Louisiana, touro infirmary, please identify, name address, TOURO INFIRMARY, please identify name, identify name, address telephone, identify name address, name address telephone, status touro, telephone employment, employment title employment, employment status,
Approximate Word count = 877
Approximate Pages = 4 (250 words per page double spaced)