Exhibit to Memorandum of Points and Authorities in Opposition to Motion to Dismiss

     [||653cf507-c7af-47e9-8395-715b07c8000d||] IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

  

BERNICE TERRY, et al. 

Plaintiffs, 

Vv. Lr : No. H 76-373 

METHODIST HOSPITAL OF GARY, ING., £8 

Defendants. 

  

  

RICHARD GORDON HATCHER, et al., 

Plaintiffs, 

v.. A No natn 

METHODIST HOSPITAL OF GARY, et al., ! 

Defendants. 

  

EXHIBIT TO MEMORANDUM OF POINTS AND AUTHORITIES 

IN OPPOSITION TO MOTION TO DISMISS OF DEFENDANTS METHODIST 

HOSPITAL OF GARY, INC. AND DENIS E. RIBORDY 

Respectfully submitted, 

: ‘i whi io Se ————————— 

Date: August 16, 1977 JACK GREENBERG 

| BETH J. LIEF 
10 Columbus Circle 

New York, New York 1001S 

  

Th, 2) PE 
A 

JULIAN ALLEN 

. 2009 Broadway 

Gary, Indiana 46407 

MARILYN G. ROSE 
CHRISTINE B. HICKMAN 

1751 N Street, N. W. 

washington, D. C. 20036 

Attorneys for Plaintiffs 

 



  

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names Aon Aid we cen put ehom Go DAE 3 T4328 

and jobs. 

MS. ROBE: Ietl's gat the angigroasy 

of everybody on 504; beginning date and the poor Je kl SA RT WE end iv - | RAS - - . J 

have been terminated, the date «N
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wei * AT wy Vo 4S so ay 

2 Lormination 

were going. from March of 1976. 

To the prasent? 

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¥S. ROES: And vou are talking ahout people In the wsuhns) 

0 Why don't you state to the Lest of your Inowleldgne 

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tha understanding that there will maybe be a co rrecksd Adocumant - jv. A «SS 

that will clarify, who are the curreni people working unde 

your supervision in 504, ildantitying which of those people work ey 

completely in develoning the ragulation, which of those work. 

conpletaly in investigating commlaints. And if 

who is half end half ox 25/75, identify then al 

A Let me start by giving you an idea of 

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we have used in develeping a final regulation. 

thera ig anybody 

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UA, MOVES PVR hh. ARIES TONS a «2 AAR ra. em SOO Rw 

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of my stalf members respon sinilie for nianboorh, to grodene all 

hat wr have oalled subsnotion of the comments, to make up wnat 

  

sheets for each subsection in the agulation, suiting forth tho 

comments and the name of the 0x rganination =m not nll of thom 

: if there are several i rhe same comments, you will say, like, 

1 eight TI and maybe 2 couple of name 28, ha i ia faaviy 

Hi time-consuming. | 

go during that time a couple of the people whoso named | | 

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ah will mention were not working as actively in the complaint 

area as they are now. : 

Now, we have nyself, Aun TA Wn "B48 Linch, Raymoud Raith, i 

Gwen Atkins, Howard Bennett, working of the final regulaiion, 

Now, that will not go on too much longer hecauss we hope to have     
the final regulation out in January. a 

5 in- the complaint area, Max Honimond, Sally Foley and Charles 

Howell did have regponsibility fox subparts and, therefora, ave 

involved in the final regulation to an extent. I can't give 

§ you percentages. That's just too arbitrary. Part of their time. 

at any rate. But priwary responsibility for complaints. Yo 

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addition, I have two new stafi members who have heen transferred. 

| T don't know if their paners have actually gone through vet. Jot 

they are de facto working on this. They came out of Health and Ey 

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Social Services Divigion. 

Q Those two naw 3ULf people Ox doing wnt? 

A Complaints. ;   4
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Q 13 that your total staff? 

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A I aiso have someone from the General (ounuelts Office 

who is working almost full time on complaints. 

Q is that your total staff in the 504 progam? 

A Yen, it im,   FIRE Te Ji og i, Bi x h PL aL I TE Sry tL aS en I ig de ons APTN ¥ 

Q vou have not filled 23 person vears in I[anl? You Gon 

have 29 persons? IT assume a perscn year ig a parson. 

  

ey ar pg way vag. 0 alan ind TY fw « 5 . ot, JOTI, on i oy, HE oe Yh 

A Or savaeral paris of moveral persons, I don’t we 

fe Low . om yo ~ 
gLalf, ag you an ges, no, 

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Q During the months of August and Septomben Of 1275, 

ware all the persons On your eLaff working on the regulation? 

A During Septomher «- 

Q puring August and September of 1976. And if dni 

different for each menth, August from Saptember, please aiate 

- . : ; Yoo va Th . UR IEE 10 At. 7! SP 

A T's hard “oo break avery staff member's tie doi an 

  

segments, 50 let me jasht kind of give you a little genaral anewnx 
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PII. a ip wit ond . We gp 
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 £0 that. Our primary mise: 

o member in it; our priority. numbon ona, in to aol the ragulniion 

out by January, which 1a an incredibles time frame, cian the 

number of comments and so forth and the fac 

41 | the experts such as yourself giving ug inpul, naling chengsa, 

based on that expertise. But there are other shlLigationz ao 

ell, and those include complaints. And Sally Foley, Maw 

Honemond and Gwen Atkins have spent a good deal of thaoir Line 

during those months on complaints as well as on tho remliaklon, 

Now, in August Ann Beckmann, myself, and to an cxbani   
Howard Bennett and Bud Reith were involved in the town moeshings 

  

Xz and that, of ccursge, was almost full time during at leant part 

of August and ~~ I'm bad on date 1g; I'm just not sure whathar 

we did those ~-~ whether we started in July or noi. I'm not 

sure. There is a pericd of time, possibly going into the first 

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part of September, when that was almost full time, where yon 

kind of hop from city £0 city. 

Q You have a Sonic Of that that could clanify 17 

A Yes.   
) T rewember when it was, bui I think you should 

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testify, not myself. 

A All I remeuk2y is citles and airports and not a lot about 

   



  

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CERTIFICATE OF SERVICE 
  

I hereby certify that a copy of the foregoing Exhibit 

to Memorandum of Points and Authorities in Opposition to 

Motion to Dismiss of Defendants Methodist Hospital of Gary, 

Inc. and Denis E. Ribordy, was served by United States mail, 

- postage prepaid, on the Jgth day of August, 1977, on counsel 

for defendants as follows: 

Rebecca L. Ross, Esq. 

‘Department of Justice 

- 10th and Pennsylvania 

washington, D. C. 

Marvin G. Garvin, Esqg., and Edward L. Koven, Esq. 

Regional Attorney and General Attorney 

Department of Health, Education and welfare 

300 South Wacker Drive, 18th Floor 

Chicago, Illinois 

Fred W. Grady, Esd. 
Assistant United States Attorney 

North=2rn District of Indiana 

Federal Building, 502 State Street 

Hammond, Indiana 46325 

Attorneys for Defendant Secretary of Health, Education 

and Welfare 

Hodges, Davis, Gruenberg, Compton & Sayers 

Bruce E. Sayers, Esq. 

5525 Broadway 

Gary, Indiana 

Attorneys for Defendant Methodist Hospital 

of Gary, Inc. | 

Theodore L. Sendak, Esq. 
Assistant Attorney General of Indiana 

219 State House 

Indianapolis, Indiana 

Attorneys for State Defendants 

Anthony DeBonis, Jr., Esq. 

Joseph E. Costanza, Esq. 

Murphy, McAtee, Murphy & Costanza 

First National Bank Building 

720 W. Chicago Avenue 

East Chicago, Indiana 46312 

Attorneys for Defendant Kipton Kaplan 

tL 

4 770 oJ J: x) 

  

  

Irs yn /G. ROG! [||653cf507-c7af-47e9-8395-715b07c8000d||]