Notices to Take Depositions Upon Oral Examination

     [||3ea5f922-a7ee-44fb-ae6e-cff21de82eed||] IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., 

Plaintiffs 

vs. 

METHODIST HOSPITAL OF GARY, 

et al., 

Defendants 

INC., 

RICHARD GORDON HATCHER, et al., 

Plaintiffs 

vs. 

METHODIST HOSPITAL OF GARY, 

et al., 

Defendants 

INC, , 

No. H 76-373 

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No. H 77-154 

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NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION 
  

Julian B. Allen es oO e
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Attorney for Plaintiffs 
2009 Broadway 
Gary, Indiana 

Beth J. Lief 
Attorney for Plaintiffs 
10 Columbus Circle 
New York, New York 10019 

Richard Gordon Hatcher 

Deponent 

c/o Julian Allen 
2009 Broadway 

Indiana Gary, 

Please take notice that at 9:00 A.M., on Tuesday, October 25, 

1577, ax the offices of Hodges, Davis, Gruenberg, Compton & 

Sayers, at 5525 Broadway, Gary, Indiana, The Methodist Hospital 

Inc. of Gary, and Denis E. Ribordy, defendants in the above- 

 



  

# Be 

entitled action will take the deposition of Willie Lee Page, 

plaintiff in the above-entitled action, pursuant to the Federal 

Rules of Civil Procedure before some officer authorized by 

law to administer oaths. The oral examination will continue 

from day to day until completed. As attorneys for the plaintiffs, 

you are invited to attend and cross-examine. 

HODGES, DAVIS, GRUENBERG, COMPTON & SAYERS 

Attorneys for Defendant, Methodist 

Hospital of Gary, Inc. 
a — amm— 

D < Po 

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BY: AD Anos on lal] 2 N © Armee 
  

\ Bruce E. Sayers 
5525 Broadway 
Gary, Indiana 46410 
Phone: 981-2557 

 



  

IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, ef al. 

Plaintiffs 

vs. No. H 76-373 

METHODIST HOSPITAL OF GARY, INC., 

et al., 

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Defendants 

RICHARD GORDON HATCHER, et al., 

Plaintiffs 

VS. No. H 77-154 

METHODIST HOSPITAL OF GARY, INC., 

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Defendants 

AFFIDAVIT OF SERVICE 
  

Bruce E. Sayers, first being duly sworn upon his oath, 
alleges and says as follows: 

1. That he is one of the attorneys for the defendant, 
Methodist Hospital of Gary, Inc. 

2. That on the 6th day of October, 1977, he served 

a copy of Notice to Take Deposition Upon Oral Examination of 
the plaintiff, WILLIE LEE PAGE, upon the following named 
attorneys of record in this matter, to-wit: 

Julian B. Allen Beth J. Lief 
Attorney at Law Attorney at Law 
2009 Broadway 10 Columbus Circle 
Gary, Indiana New York, New York 10019 

and upon Willie Lee Page, Deponent 
c/o Attorney Julian B. Allen 
2009 Broadway 
Gary, Indiana 

 



. * 

  

and also upon the following counsel of record: 

Rebecca L. Ross, Esq. 
Department of Justice 
10th and Pennsylvania Avenue, N.W. 
Washington, D. C. 

Marvin G. Garvin and Edward L. Koven 
Regional Attorney & General Attorney 
Department of Health, Education and Welfare 
300 South Wacker Drive, 18th Floor 
Chicago, Illinois 

Fred W. Grady 
Assistant United States Attorney 
United States District Court 
Northern District of Indiana 
Federal Building, 507 State Street 
Hammond, Indiana 46325 

Marilyn G. Rose 
Christine B. Hickman 
1751 N Street, N.W. 
Washington, D.C. 20036 

Theodore Sendak 

Attorney General 
State House 

Indianapolis, Indiana 46320 

Anthony DeBonis 
720 West Chicago Avenue 
East Chicago, Indiana 

by depositing same in the United States Mail, postage prepaid, 
and addressed to each of the above-named individuals. 

3. Further affiant sayeth not. 

  

AdS—e~—C 
or E. Sayers 
  

Subscribed and sworn to before me, a Notary Public, this 
6th day of October, 1977. 

(FA 

ST ETE far, Notary Public 

  

  

My Commission Expires: 

March 2, 1981 

 



  

IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., 

Plaintiffs 

VS. No. H 76-373 

METHODIST HOSPITAL OF GARY, INC., 

aef-al., 

Defendants 

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RICHARD GORDON HATCHER, et 81 

Plaintiffs 

vs. No. H 77-154 

METHODIST HOSPITAL OF GARY, INC., 

et al,., 

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Defendants 

AFFIDAVIT OF SERVICE 
  

Bruce E. Sayers, first being duly sworn upon his oath, 
alleges and says as follows: 

1. That he is one of the attorneys for the defendant, 
Methodist Hospital of Gary, Inc. 

2. That on the 6th day of October, 1977, he served 
a copy of Notice to Take Deposition Upon Oral Examination of 
the plaintiff, RICHARD GORDON HATCHER, upon the following 
named attorneys of record in this matter, to-wit: 

Julian B. Allen Beth J. Lief 
Attorney at Law Attorney at Law 
2009 Broadway 10 Columbus Circle 
Gary, Indiana New York, New York 10019 

 



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and also upon the following counsel of record: 

Rebecca L. Ross, Esq. 
Department of Justice 
10th and Pennsylvania Avenue, N.W. 
Washington, D. C. 

Marvin G. Garvin and Edward L. Koven 
Regional Attorney & General Attorney 
Department of Health, Education and Welfare 
300 South Wacker Drive, 18th Floor 
Chicago, Illinois 

Fred W. Grady 
Assistant United States Attorney 
United States District Court 
Northern District of Indiana 
Federal Building, 507 State Street 
Hammond, Indiana 46325 

Marilyn G. Rose 
Christine B. Hickman 
1751 N Street, N.W. 
Washington, D.C. 20036 

Theodore Sendak 
Attorney General 
State House 
Indianapolis, Indiana 46320 

Anthony DeBonis 
720 West Chicago Avenue 
East Chicago, Indiana 

by depositing same in the United States Mail, postage prepaid, 
and addressed to each of the above-named individuals. 

3. Further affiant sayeth not, 

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b A % ANA <Q L 

Bruce E. Sayers 

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Subscribed and sworn to before me, a Notary Public) this 
6th day of October, 1977. 

  

ABhitley gmar, Notary Public 

My Commission Expires: 

March 2, 1981 

 



  

IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., 

Plaintiffs 

VS. No. H 76-373 

METHODIST HOSPITAL OF GARY, INC., 

et ‘al... 

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Defendants 

RICHARD GORDON HATCHER, et al., 

Plaintiffs 

vs. No. BR 77-154 

METHODIST HOSPITAL OF GARY, INC., 

et &al., : 

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Defendants 

NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION 
  

TO: Julian B. Allen : Beth J. Lief 
Attorney for Plaintiffs Attorney for Plaintiffs 
2009 Broadway 10 Columbus Circle 
Gary, Indiana New York, New York 10019 

Richard Gordon Hatcher 
Deponent 

Municipal Building 
11 East 4th Avenue 
Gary, Indiana 

Please take notice that at 9:00 A.M., on Tuesday, October 25, 

1977, at the offices of Hodges, Davis, Gruenberg, Compton & 

Sayers, at 5525 Broadway, Gary, Indiana, The Methodist Hospital 

of Gary, Inc. and Denis E. Ribordy, defendants in the above- 

 



  

entitled action will take the deposition of Richard Gordon 

Hatcher, plaintiff in the above-entitled action, pursuant to 

the Federal Rules of Civil Procedure before some officer authorized 

by law to administer oaths. The oral examination will continue 

from day Lo day until completed. As attorneys for the plaintiffs, 

you are invited to attend and cross-examine. 

HODGES, DAVIS, GRUENBERG, COMPTON & SAYERS 

Attorneys for Defendant, Methodist 
Hospital of Gary, Inc. 

a5 No AA ——— - 

CoA _ 
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BY DN A i 
  

5525 Broadway: 
Gary, Indiana 46410 
Phone: 981-2557 

“Bruce E. Sayers” / 

 



  

IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., 

Plaintiffs 

VS. No. H 76-373 

METHODIST HOSPITAL OF GARY, INC., 

et al., 

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Defendants 

RICHARD GORDON HATCHER, et al., 

Plaintiffs 

VS. No. H 77-154 

METHODIST HOSPITAL OF GARY, INC., 

et al., 

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Defendants 

AFFIDAVIT OF SERVICE 
  

Bruce E. Sayers, first being duly sworn upon his oath, 
alleges and says as follows: 

1. That he is one of the attorneys for the defendant, 
Methodist Hospital of Gary, Inc. 

2. That on the 6th day of October, 1977, he served 
a copy of Notice to Take Deposition Upon Oral Examination of 
the plaintiff, METRO CORPS OF GARY, INC., upon the following 
named attorneys of record in this matter, to-wit: 

Julian B. Allen Beth J. Lief 
Attorney at Law Attorney at Law 
2009 Broadway 10 Columbus Circle 
Gary, Indiana New York, New York 10019 

 



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and also upon the following counsel of record: 

Rebecca L. Ross, Esq. 
Department of Justice 

10th and Pennsylvania Avenue, N.W. 
Washington, D. C. 

Marvin G. Garvin and Edward L. Koven 
Regional Attorney & General Attorney 
Department of Health, Education and Welfare 
300 South Wacker Drive, 18th Floor 
Chicago, Illinois 

Fred W. Grady 
Assistant United States Attorney 
United States District Court 
Northern District of Indiana 
Federal Building, 507 State Street 
Hammond, Indiana 46325 

Marilyn G. Rose 
Christine B. Hickman 
1751 N Street, N.W. 
Washington, D.C. 20036 

Theodore Sendak 
Attorney General 
State House 

Indianapolis, Indiana 46320 

Anthony DeBonis 
720 West Chicago Avenue 
East Chicago, Indiana 

by depositing same in the United States Mail, postage prepaid, 
and addressed to each of the above-named individuaic, 

3. Purther affiant sayeth not. 

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BYE: Fins i ih 

Subscribed and sworn to before me, a Notary Public, /this 
6th day of October, 1977. 

  

     Shirley i ik Notary Public 

My Commission Expires: 

March 2, 1981 

 



  

IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., 

Plaintiffs 

VS. No. BH 76-373 

METHODIST HOSPITAL OF GARY, INC., 

et al., 

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Defendants 

RICHARD GORDON HATCHER, et al., 

Plaintiffs 

VS. No. H 77-154 

METHODIST HOSPITAL OF GARY, INC., 

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et al., 

Defendants 

NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION 

™: Julian B. Allen Beth J. Lief 
Attorney for Plaintiffs Attorney for Plaintiffs 
2009 Broadway 10 Columbus Circle 

Gary, Indiana New York, New York 10019 

Plaintiff, Metro Corps of Gary, Inc., pursuant to the 

Federal Rules of Civil Procedure, Rules 30 and 30(b) (6), is 

requested to designate one or more officers, directors or managing 

agents, members, executive officers or other persons, duly 

authorized and consenting to testify on its behalf to testify 

 



  

as to matters known or available to said organization at 9:00 

A.M., on Thursday, October 27, 1977, at the offices of Hodges, 

Davis, Gruenberg, Compton & Sayers, at 5525 Broadway, Gary, 

Indiana, concerning the following matters: 

1. Any allegations or information concerning purported 
violations of the civil rights or rights under the 
Rehabilitation Act of 1973 of its constituent members 
or any citizens of the City of Gary, Indiana, by defendant 
Methodist Hospital of Gary, Inc. or defendant Denis E. 

Ribordy. 

Any studies, reports, findings, or projections with 
regard to civil rights violations or violations of 
Section 504 in the delivery of health care services 
in the City of Gary, Indiana. 

Any studies, reports, findings or projections with 
regard to the optimal or preferable system for the 
delivery of health care services in Lake County, 
Indiana. Such studies, reports, findings or projec- 
tions may be those currently existing, those currently 
being developed, or those which have been developed 

in the past, whether implemented or not. 

Any programs operated by or contemplated by the plaintiff 
with regard to the transportation of minority, elderly 
or handicapped persons to hospitals or other medical 
facilities, whether said facilities are located within 
Lake County or the City of Gary, Indiana, or outside 
of Lake County, Indiana; or any other programs operated 
by or contemplated by the plaintiff which might in 
some way directly or indirectly affect the delivery 
of health care to the citizens of Gary, Indiana, 
and/or the citizens of Lake County, Indiana. 

The history, corporate status, corporate makeup, 
the purposes and the objectives of Metro Corps of 
Gary, Inc. 

The relationship between Metro Corps of Gary, Inc. 
and various governmental and quasi-governmental entities. 

The financial status of Metro Corps of Gary, Inc. 
and the finanancial structure utilized by Metro Corps 
of Gary, Inc. to obtain funds, including but not 
limited to the structure outlined in plaintiffs’ 
Memorandum in Support of Certification of this action 
as a class action and the interrelationships, if 
any, with the organizations and entities enumerated 

therein by the plaintiffs. 

 



  

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Metro Corps of Gary, Inc. is further requested to designate 

in writing the individual or individuals who will appear and 

testify on behalf of Metro Corps of Gary, Inc. as to the matters 

specified above. If more than one individual is named, you 

are requested to identify each person and the matters on which 

they will testify. In the event more than one person is called, 

the other person's deposition will be taken at the conclusion 

of the previous person's deposition. Each deposition will 

be adjourned and continued from hour to hour and day to day 

until completed. Said deposition upon oral examination shall 

be taken by defendants, Methodist Hospital of Gary, Inc. and 

Denis E. Ribordy 

HODGES, DAVIS, GRUENBERG, COMPTON & SAYERS 

Attorneys for Defendant, Methodist 

Hospital of Gary, Inc. 

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FS i — 
By: AN Not 3 ( ( ey A ee 

Bruce E. Sayers o 
5525 Broadway / 
Gary, Indiana 464 
Phones: 981-2557 [||3ea5f922-a7ee-44fb-ae6e-cff21de82eed||]