Plaintiffs' Third Interrogatories to Defendant Methodist Hospital of Gary, Inc.

     [||8c4e3b44-85f4-41d0-bd4a-91ee918340a3||] IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

  
  

BERNICE TERRY, et al., 

Plaintiffs, 

7, : NO. H 76-373 

METHODIST HOSPITAL OF GARY, INC., 

et. -al., 

Defendants. 

  
  

  
  

RICHARD GORDON HATCHER, et al... 

Plaintiffs, 

v. : NO. H 77-154 

METHODIST HOSPITAL OF GARY, INC., 

et al., 

Defendants. 

  

PLAINTIFFS' THIRD INTERROGATORIES TO DEFENDANT 

METHODIST HOSPITAL OF GARY, INC. 

  

 



  

Please take notice that the Plaintiffs request, pursuant 

to Rule 33, Federal Rules of Civil Procedure, that the Defendant 

answer separately and fully in writing, under cath, within 10 

days after service hereof, the following written Interrogatories. 

Identify, separately and in a manner suitable for use as 

a description in a subpoena or a Rule 34 request for production, 

all sources of information and all records upon which Defendant 

relied in answering the Interrogatories or which pertain to or 

relate to the information called for by the Interrogatory. Said 

sources include the individual person who supplies the informa- 

tion and all documents associated with said answer. 

1 With respect to all witnesses whom Defendant will or 

may call as experts to give opinion and testimony in the trial 

of this matter, state the Lolidwing: 

(2a) Name and address; 

(b) Name and address of his or her employer or 

the organization with which he or she is associated in 

any professional capacity; 

{c) The field in which he or she is to Ve iguslified 

as an expert; 

(d) A summary of his or her qualifications within 

the field in which testimony is expected to be given; 

(e) The substance of the facts with respect to which. 

testimony is expected: 

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(f) The substance of the opinions ‘as to which | 

I testimony is expected and a summary of the grounds for each 

| such Spinto and 

(g) The dates and recipients of all reports rendered 

by such experts in connection with this matter. 

I 2. As to each person referred to by Defendant in its 

| Answer to Interrogatory Number 1, state specifically and com- 

| prehensively: 

I (a) The educational background of each such witness; 

| (b) The employment history of each such witness; and 

(c) All writings authored or contributed to by each | 

| such witness relating to the subject matter with respect to | 

| which the witness is expected to testify, including a sumr 
| \ 

| mary of the contents, the location of each such document, 

| and the identity of the present custodian of such document. 

3. As to each person identified in response to Inter- 

1 rogatory Number 1 above, please state each occasion on which 

I’ the witness has been called upon to testify as an expert in a 

(| lawsuit involving Title VI of the Civil Rights Act of 1964, 

any other state or federal law or regulation dealing with | 

discrimination in health care on the basis of race, cclor, 

I religion, sex or national origin, health planning, or quality 

of care in the delivery of hospital and health services, and 

as to each such occasion please state: oe 

(a) The style of the case including the names of 

the Plaintiff (s) and the Defendant(s); 

(b) The designation of the Court of Record in which | 

I the case was tried: 

(c) The identity of the party on whose behalf the 

  

 



ed 

  

| expert was called as a witness; 

(d) The date of trial; and : 

(e) The present status of the case; i.e., pending 

decision, pending appeal, ended, etc. 

4. As to each such person identified in response to 

I Interrogatory Number 1 above, please state each occasion on 

I which the witness has been retained for consultation in a law- | 

H suit involving Title VI of the Civil Rights Act of 1964, any 

other state or federal law or regulation dealing with discrimi- 

| nation in employment on the basis of race, color, religion, sex 

| or national origin, health planning or quality of care, in the | 

| delivery of hospital and health services but in which: the 

witness has not testified as an expert. As to each such occa- 

I sion, please state: 

I (a) The style of the case including the names of ‘the 

I Plaintiff (s) and Defendant (s): 

(b) The designation of the Court of Record in which 

the suit is filed; 

IB (c) The party on whose behalf the expert has been 

retained for consultation and/or for prospective use as a 

| witness; and 

(d) The present status of the case; i.e., dismissed 

prior to trial, pending trial, ended by way of compromise | 

1 settlement, etc, 

  

 



  

  
  

| Jack Greenberg 
| Beth J. Lief 

| | Brent Simmons 

Charles William III 

10 Columbus Circle 

New York, New York 10019 

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I Julian Allen 
: | | 2009 Broadway 

| Gary, Indiana 46407 

| Marilyn G. Rose 

1751 N Street, N.W. 

Washington, D.C. 20036 

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| Certificate of Service t func- | 

| I hereby certify that a copy of the foregoing '. | 
iH 

Chaba 

1 
| 

| PIAINTIFFS' THIRD INTERROGATORIES TO DEFENDANT 

| METHODIST HOSPITAL OF GARY, INC., | 

| was served by United States mall, postage prepaid, on" 

| the: ‘24 day. of March’ , 1978, on counsel for | 
| ae ! 
| defendants as follows: | 

I | 

| Rebecca L. Ross, Esq. | 

1 Department of Justice 
10th and Pennsylvania Avenue 
Washington D.C. 

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

| Regional Attorney and General Attorney 
| Department of Health, Education and Welfare 
I 300 South Wacker Drive, 18th Floor 

Chicago, Illinois 

ll Fred W. Grady, Esq. 
Assistant United States Attorney 
Northern District of Indiana 

|i 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 

I Gary, Indiana 46401 

I Attorneys for Defendant Methodist Hospital 
of Gary, Inc. | 

| 

| Theodore L. Sendak, Esqg. | 

| Assistant Attorney General of Indiana | 
1 219 State House | | 

Indianapolis, Indiana 

I Attorneys for State Defendants 

  

  

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Attorney for plaintiffs [||8c4e3b44-85f4-41d0-bd4a-91ee918340a3||]