Affidavit of Davis A. Sanders

     [||a3ee399f-f8a3-417f-8d7d-1c762dccfd8a||] IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

  

BERNICE TERRY, ef al., 

Plaintiffs No. i 76-373 

VS. 

METHODIST HOSPITAL OF GARY, INC., 
et al. 

Defendants 

RICHARD GORDON HATCHERS, et al., : No. H 77-154 

Plaintiffs 

VS. 

IETHODIST HOSPITAL OF GARY, INC., 
et al., 

Defendants 

  

COUNTY OF COOK ) 
) Ss. 

STATE OF ILLINOIS ) 

AFFIDAVIT OF DAVIS A. SANDERS   

Davis A. .Sandeys, belng first duly sworn, states and avers that: 

l. I have been employed by the Office for Civil Rights, Region V, | 

of the Department of Health, Education, and Welfare since March 1966, 

and as Deputy Director of the Office for Civil Rights in Region V con- 

tinuously from April 1974 to the present time. 

2. Since September 1977 I have been the official in charge of the 

gPfice for Civil Rizhbs team engaged in a Title VI (Title V1 of the 

. Civil Rights Act of 1964) and Section 504 (Section 504 of the Rehabili- 

tation Act of 1973) review of hospitals located in Lake County, Indiana, 

including Gary Methodist Hospital and Broadway Methodist Hospital. 

 



  

4 nN 

3. In order to fully assess certain questions relating to 

whether Methodist Hospital of Gary, Inc. ,~has complied with and is 

Coen with Title VI of the civil Rights Act of 1964 and Section 

504 of the Rehabilitation Act of 1973, the review team of which I 

am in charge needs all year-end coples from 1973 and a current copy 

of the payroll file and, "GEOS5MSTG" which is on computer tape now in 

the possession of Health Information Services, according to the para- 

meters specified in Interrogatory 16 of Plaintiff's Second Set of 

Interrogatories served on September 20, 1977. 

4. In order to fully assess certain questions relating to whether 

Methodist Hospital of Gary, Inc., has complied with and is complying 

with Title VI of the Civil Rights Act of 1964 and Section 504 of the 

Rehabilitation Act of 1973, the review team needs the PAS file, now in 

the possession of the Commission on Professional and Hospital Activities, 

for all patients within the parameters: 

"Copy on magnetic tape 9-tract in E.B.C.D.I.C. 
character code of all the patients in the PAS 
file for Gary Methodist Hospital and Broadway 
Methodist Hospital." 

5. The inability of the review team to have access to the computer 

tapes described in paragraphs 3 and 4 has hampered and will continue 

to seriously hamper the review team's ability to fully assess certain 

questions and will result in a substantial delay in its ability to issue 

findings with regard to these questions. 

Further affiant sayeth not. 

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Davis A. Sanders 
  

Sworn to before me this 

rl 2 C 7 > day of January, 1973 

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