Joint Motion for an Order for the Production of Documents

     [||23008402-59b7-44cd-b5fe-e022138f72d9||] IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., 

Plaintiffs, 

Civil No. H76-373 Ve. 

METHODIST HOSPITAL OF 

CARY, INC., et al., 

Defendants. 

RICHARD GORDON HATCHER, 

et. .al., 

Plaintiffs, 

METHODIST HOSPITAL OF 

) 
) 
) 
) 
) 

Vv. ) Civil No. H77-154 
) 
) 

GARY, INC., et al., ) 
) 
) Defendants. 

JOINT MOTIO:i TOR AN ORDER 

FOR THE PRODUCTION OF DOCUMENTS 
  

COME NOW Defendants METHODIST HOSPITAL OF GARY, INC. , 

and DENIS E. RIBORDY, and Plaintiffs TERRY, HATCHER et al., 

by their respective attorneys, and pursuant to Rule 37(a) of 

the Federal Rules of Civil Procedure hereby move the Court 

for an order requiring Defendant CALIFANO to produce and 

permit counsel for the moving parties to inspect and copy 

each of the following documents: 

 



  

l. Office of Civil Rights’ or Health and Social Service 

Branch's Complaint Handling Guidelines issued between 

September, 1977 and February 4, 1278, and currently in use. 

2. Office of Civil Rights' or Health and Social Service 

Branch's Handling Guidelines issued on or about January 19, 

1973. 

3. The two most recent position descriptions for the 

Chief, Health and Social Services Branch, Office of Civil 

Rights, Region V, the Director, Office of Civil Rights, 

Region V, and the Chief, Health Care Facilities Branch, 

Public Health Service, Region V. 

4. Annual Operating Plans, Office of Civil Rights, for 

Fiscal Years 1974 through the present date. 

5. Office of Civil Rights Draft Guidelines for State 

Agencies. 

6. "Final Report" regarding complaint of Gary Human 

Relations Commission versus Methodist Hospital of Gary, Inc., 

prepared by Alfred J. Sanchez in May or June 1977. 

7. Memorandum from Alfred J. Sanchez to Davis Sanders 

regarding Sanchez' "concerns" about the mental health and 

family practice aspects of Methodist Hospital of Gary's 

application for Projects 212 and 213. 

8. Letter from the Northern Indiana Health Systems Agency 

to Michael Kruley dated on or about August 2%, 1976, regarding 

Methodist Hospital of Gary, Inc. 

 



  

9. Kits of documents distributed at National Office of 

Civil Rights Conferences held in Dallas, Atlanta, and 

New Orleans since 1970. 

During the depositions conducted on February 22 and 23, 

1978, of Alfred J. Sanchez and George Hurney, officials of 

the Department of Health, Education and Welfare, respective 

counsel for Defendants Methodist Hospital of Aer Tani and 

Denis E. Ribordy, and Plaintiffs did request that counsel for 

Defendant Califano provide certain documents for discovery 

and inspection. These requests subsequently were manifested 

and formalized in a Request for Production of Documents, 

which has been served upon Defendant Califano. A copy of 

this Request for Production of DoCUnenLS is attached hereto 

as Exhibit A. At the time of moving parties’ oral requests 

during. the Sanchez and Hurney depositions, counsel for Defendant 

Califano orally responded to the requests, objecting to the 

requests Posed Bove and stating that Some. Or all of the 

requested documents will be withheld for various reasons 

including "intra-governmental communication" and attorney- 

client privileges. 

Each of the documents does in fact constitute or contain 

evidence relevant and material to a matter involved in this 

action and cannot be obtained from other sources and, therefore, 

Defendants Methodist Hospital of Gary, Inc., and Denis E. Ribordy, 

and Plaintiffs submit that Defendant Califano should be required 

 



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to Produce the same and permit inspection and copying by the 

moving parties or their representatives. 

Respectfully submitted, 

  

Bruce E. Sayers 

  

Marc S. Krass 

HODGES, DAVIS, GRUENBERG, 

COMPTON & SAYERS 

5525 Broadway : 

Gary, Indiana 46410 

{219) 981-2557 

SEYFARTH, SHAW, FAIRWEATHER & 

GERALDSON 

55 East Monroe Street 

Suite 4200 

Chicago, Illinois 60603 

pes (312) 346-8000 

Attorneys for Defendants Methodist 

Hospital Of Gary, iInc., and 

Denis E. Ribordy 

  

Beth J. Lief 

10 Columbus Circle 

New York, New, York 10019 

(212) 586-8397 

Attorney for Plaintiffs [||23008402-59b7-44cd-b5fe-e022138f72d9||]