Correspondence from Hussey to All Counsel; Defendants' Answer to Plaintiffs' Second Set of Interrogatories as Amended

     [||a6e3c131-f19e-4bfc-be88-4c8e865df89d||] HobDGES, Davis, GRUENBERG, COMPTON & SAYERS WILLIAM F. HODGES-1954 

C.V.RIDGELY-1963 ATTORNEYS AT LAW 
THOMAS M. HODGES-1969 RICHARD S. MELVIN 
HERSCHEL B. DAVIS 5525 BROADWAY OF COUNSEL 
GILBERT GRUENBERG GARY. INDIANA 
CLYDE D.COMPTON 2 
WILLIAM B. DAVIS 46410 AREA CODE 219 
BRUCE E.SAYERS TELEPHONE 
EARLE F. HITES 

081-2557 
EDWARD J. HUSSEY 

November 1, 1977 

TO ALL COUNSEL OF RECORD 

RE: Richard Gordon Hatcher, et al 

vs. Methodist Hospital of Gary, Inc. 

Barbara Leek Wesson, et al 

vs. Methodist Hospital of Gary, Inc. 

Enclosed please find a copy of Defendants' Answers to Plaintiffs’ 
Second Set of Interrogatories as amended and exhibits thereto. 
In addition, I am enclosing copies of our cover letters to Beth 
Lief for your reference. We anticipate that the Second Set of 
Interrogatories will generate other materials in the future. 
We will keep you informed. 

If you have any questions regarding this material, please do not 
hesitate to contact me. 

Very truly yours, 

Edward J. Hussey 

EJH/db 

Enclosures 

 



  

IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., 

Plaintiffs 

METHODIST HOSPITAL OF GARY, INC., 

at. -al.,, 

Defendants 

RICHARD GORDON HATCHER, et ale, 

Plaintiffs 

METHODIST HOSPITAL OF GARY, INC., 

et al. 

Defendants 

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NO. H 76-373 

NO. H 77-154 

DEFENDANTS' ANSWERS TO PLAINTIFFS® 

SECOND SET OF INTERROGATORIES AS AMENDED 
  

Come now the Defendants' Methodist Hospital of Gary, Inc. and 

Denis E. Ribordy and files answers to Second Set of Interrogatories 

as amended, propounded to Defendants by Plaintiffs herein. 

l. State the name of the data base, either as it is referred 

to in the defendant's customary data processing operation or so 

that it can be uniquely identified in subsequent answers or pleadings. 

See Exhibit A ANSWER: 

 



  

2. Which categories of employees are included in the data 

base. 

ANSWER: See Exhibit A 

3. When was the data base first created, and when was it last 

used. 

ANSWER: See Exhibit A 

4. If volumes, version, or generations of the data base are 

(were) periodically produced, state: 

(a) how often a copy is produced. 

(b) what period of time is covered by each volume. 

(c) in what ways any of the answers to questions in Part I 

differ between different volumes of the data base. 

(d) by volume serial or other unique identifier, the volumes 

still extant and the contents and dates thereof, retained, 

and if so, 

(e) identify any volumes scheduled for destruction within the 

next twelve months. 

ANSWER: See Exhibit A 

5. If entries in the data base are periodically updated, without 

a new volume or copy being created (such as the weekly updating of a 

disk master file), state: 

(a) how often the data base is updated. 

(b) which fields or records are subject to revision. 

(c) whether complete copies are made and retained, and if so, 

(d) state by volume or other unique identifier the volumes 

still extant, the contents and dates thereof, and any 

proposed destruction dates. 

 



  

(e) 

(£) 

ANSWER: 

whether changed or purged entries are maintained in 

computer-readable form, and if so, 

answer all applicable questions in Part I for any files 

containing these purged entries. 

See Exhibit A 

6. Provide the following for all fields found within each 

different record structure within the data base. In the alternative, 

a "record layout" for the file may be produced, providing it supplies 

each requested item of information in a clear, legible, and unambigous 

format: 

(a) 

(b) 

(c) 

(d) 

(e) 

(Ff) 

(9) 

its location within the record. 

a brief description of its contents. 

a brief description of its function and significance, 

if not immediately obvious (such as name, race). 

the physical representation of its contents (character, 

zoned decimal, packed decimal, signed decimal, binary, 

floating point, location of assumed decimal point, lo- 

cating of sign, right - or left - justified, strictly 

numeric, numeric with blanks, etc.). 

the sign codes used for decimal fields As. IBM 

gtandards hexadecimal "CY or "Pp" for plus, hex "D" 

for minus). 

the status of the field; whether data was always entered, 

was sometimes entered (was optional), or was never en- 

tered (space was provided, but field was not used). 

for each field which contains "coded" entries, such as 

a field for race containing a "1" for white and a "2" 

 



  

for black, or numbers representing department titles, 

provide a translation table which contains each possible 

entry and its English translation or literal meaning. 

If such translation table exists in computer-readable 

form, answer all appropriate questions in Part I con- 

cerning the table. 

ANSWER: See Exhibit A 

7. If the file is composed of records differing in form from 

one another, provide the record layout for each possible record entry, 

(c.f. question 6) and state how the format appropriate to any par- 

ticular record can be ascertained. If the file is "hierarchical" 

in structure (i.e., it contains an unpredictable number of minor-level 

records related in some manner to a preceeding major-level record), 

describe in detail the structure of the file, and state how different 

record types and levels can be recognized. | 

ANSWER: See Exhibit A 

8. State the approximate number of logical records in the data 

base. 

ANSWER: See Exhibit A 

9. Describe the storage device or medium. 

ANSWER: See Exhibit A 

10. State the: 

(a) logical record length. 

(b) physical record length (blocksize). 

(c) record format (fixed length, variable length, spanned, 

blocked. 

 



  

(d) file organization (sequential, indexed, direct, VSAM) . 

(e) recording code (EBCDIC, ASCII, BCD, Hollerith, 

column binary). 

ANSWER: See Exhibit A 

11. State the programming language or retrieval system used to 

create and access the data base. 

ANSWER: See Exhibit A 

12. If the data base is generated or accessed by a program which 

is part of a formal or documented processing system, provide a "flow- 

chart" for that system, showing the flow of information (files) from 

program to program. 

ANSWER: See Exhibit A 

13. If on magnetic tape, state the density (bits per inch), the 

number of tracks (7.9), the recording technique (parity, translation, 

conversion, character code ) if on 7 track, the form of internal 

identifying labels (IBM standars, non-labelled, IBM 1400 series, 

Burroughs standard, etc.), and the format of block prefixes if ASCII. 

ANSWER: See Exhibit A 

14. With reference to the fields enumerated in the answer to 

Question 6, describe the order in which records in the data base are 

sorted. 

ANSWER: See Exhibit A 

15. Briefly describe each of the defendant's computer facilities, 

including: 

(a) manufacturer. 

(b) model number. 

 



  

(c) name and release of operating system. 

(d) type and number of each input/out/put device. 

ANSWER: See Exhibit A 

16. If the defendant's curtent conbies system is not capable of 

copying each of the data bases identified in Part I according to 

the following parameters, state why not, and state what alternatives 

are avallable for each of the parameters listed: 

(a) onto magnetic tape. 

(hb) 9 track. 

{c) at 800, 1600, or 6250 bpi. 

(d) in EBCDIC character code. 

(e) with IBM standard OS labels. 

ANSWER: See Exhibit A 

17. For each information retrieval program or report generator 

(i.e., software capable of producing a multitude of different reports, 

depending on control information entered) available, Whether purchased, 

leased, or written locally, 

(a) identify its name or title, vendor or author, and any 

optional features installed. 

(b) identify which of the data bases named in Part I the 

program operates on, and whattype of reports it is capable 

of generating. 

(c) Identify and describe all documents, reference manuals 

or texts which describe the program and its operation. 

ANSWER: See Exhibit A 

 



  

18. If defendant 

agency for processing 

(a) describe 

(b) indicate 

contracts with an outside service bureau or 

of data bases identified in Part I, 

those services completely. 

which data bases identified in Part I are in 

the possession of such bureau or agency. 

(c) answer all parts of questions 15 and 16 concerning the 

bureau's data processing capabilities. 

ANSWER: See Exhibits A and B 

19. Give the name, business address, job title, and job function 

of: 

(a) the manager of defendant's data processing operation. 

(b) each analyst or programmer who has intimate knowledge 

of the contents or function of each data base identified 

in Part I (specify which). 

(c) the person (s) who answered these Interrogatories. 

ANSWER: See Exhibits A and B 

HODGES, DAVIS, GRUENBERG, COMPTON & SAYERS 
ATTORNEYS FOR D Alves, 

  

Edward J. fus%ey 
5525 Broadway 
Gary, Indiana 46410 
Phone: 981-2557 [||a6e3c131-f19e-4bfc-be88-4c8e865df89d||]