First Set of Interrogatories to Methodist Hospital of Gary

     [||5c9e8aa0-9b55-4379-af88-0394cb155335||] PCED IN THE UNITED STATES DISTRICT COURT "=" 

FOR THE NORTHERN DISTRICT OF INDIANA/AY g 1977 

HAMMOND DIVISION BA ii M 

ERANCIS T. GRANDYS, oer u. S. DISTRIC 

RICHARD GORDON HATCHER, CT COURT 
WILLIE LEE PAGE, 

METRO CORPS OF GARY, INC., A 

Not-for-Profit Corporation 
and others similarly situated Civil Action No. 

Plaintiffs   

dhs fo: Tl 1S 
METHODIST HOSPITAL OF GARY, 

INC., An Indiana Not-for- 
Profit Corporation and DENIS 
E. RIBORDY, as President of 
the Board of Directors, et al 

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Defendants 

FIRST SET OF INTERROGATORIES 

TO METHODIST HOSPITAL OF GARY, INC. 

Plaintiffs request that defendant Methodist Hospital of Gary, 

Inc., and its agents and employees (hereinafter "Methodist 

Hospital”) answer under oath, pursuant to Rule 33 of the Federal 

sales of Civil Procedure, the following interrogatories, and re- 

quest separate, complete written responses to each within forty- 

five (45) days after their service. With respect to each inter- 

rogatory please state the source of the answer given or, if 

appropriate, the name and title of the officer, agent or employee 

having knowledge of the facts. 

These interrogatories are to be deemed continuing in nature 

and supplemental answers shall be required of you if prior to 

trial you directly or indirectly obtain further or different in- 

formation from that contained in the answer.       
 



  

In answering each interrogatory defendants are requested to 

identify in a manner suitable for use as a description in a sub- 

poena or notice for production of documents, or to produce: all 

of the information (whether documentary, human or otherwise) and 

all records maintained by, and/or in the possession or control of 

defendants or any other person or organization which pertain or 

relate to the information called for by each IR CG 

whether or not such identification or production is specifically 

requested in that interrogatory. 

A. 

1. Describe the complete organizational structure of 

Methodist Hospital, specifying all officers, boards of directors 

and trustees, divisions, sections, committees, offices, units, 

and all other organizational substructures, including the medical 

staff, any volunteer and any fund-raising organization, divisions, 

committees or units of Methodist Hospital. Include whether, how 

and why the organizational structure has changed since 1965, and 

indicate for all organizational substructures where they pertain 

to, have authority over, or otherwise operate with respect to Gary 

Methodist Hospital, Broadway Methodist Hospital, or both. 

2. Describe briefly, but completely, the functions of the 

various levels of each organizational substructure or unit 

specified in Interrogatory 1 above; the scope of each function 

specified; whether the various levels function with respect to 

part or to all of the hospitals operated by Methodist Hospital, 

and whether, how and why each function has changed since 1965. 

3. Describe all laws, statutes, regulations or other 

authority pursuant to which Methodist Hospital is organized or 

carries out its functions; all governmental agencies, organ- 

izations or other bodies which regulate, supervise, monitor or 

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otherwise govern the organizational structure of Methodist 

Hospital specified in Interrogatory 1 above, and functions of 

Methodist Hospital specified in Interrogatory 2. 

4. Describe all incorporation, charter, commission, regula- 

tion, by-law or other documents which state the organization of 

Methodist Hospital specified in Interrogatory 1 above. 

5. With reference to the organizational structure set forth 

in the answers to Interrogatories 1 and 2, state: 

(2) name, position, level or title, race, national 

orgin, sex, term or length of tenure of the head 

of each office, board, division, section, committee, 

unit or other substructure (hereinafter referred to 

as "division") identified in the answer to 

Interrogatory 1; 

(b) the specific responsibility or function assigned 

to each head identified in the answer to Interrog- 

atory 5 (a); whether the responsibility or function 

assigned pertains to Gary Methodist Hospital, to 

Broadway Methodist Hospital, or to both hospitals; 

and whether how, and why each function or respon- 

sibility has changed since 1965; 

(c) the first time, if any, such office job or other 

position was held by a black person. 

6. Identify each position specified in Interrogatories 1 

and 5 in ascending order of responsibility in the Methodist 

Hospital hierarchy, indicating for each position the specific 

organizational unit(s) in which it is placed. 

7. Describe the complete organizational structure of Gary 

“3 

  

 



      

specifying all offices, units, committees, divisions and all 

other organizational substructures. Include whether, how and 

why the organizational structure of Gary Methodist Hospital has 

changed since 1965. 

8. Describe the complete organizational structure of 

Broadway Methodist Hospital, specifying all officers, units, 

committees, divisions and all other organizational substructures. 

Include the dates on which all organizational substructures at 

Broadway Methodist Hospital were conveived, organized and put 

into operation, and whether, how and why the structure has 

changed since the dates they were conceived. 

9. With respect to the organizational structure of Gary 

Methodist Hospital set forth in the answer to Interrogatory 7, 

state: 

(2a) the name, position, level or title, race, national 

origin, sex, term or length of tenure, and any 

other employment affiliation of the head of each 

office, department, unit, committee, division, and 

all other substructures. 

(b) the date that each person identified in the answer 

to Interrogatory 9(a) assumed his or her position; 

(c) the name, race, national origin, sex and term or 

length of employment of the predecessor of each 

person identified in the answers to Interrogatory 

9(a); 

(d) the specific responsibility or function assigned 

to each person identified in the answers to 

Interrogagory 9(a); and whether, how and why each 

dln 

  

 



      

10. With 

function or responsibility of the person identi- 

fied in the answer to Interrogatory 9(a) has 

changed. 

respect to the organizational structure of 

Broadway Methodist Hospital set forth in the answer to Interroga- 

tory 8, state: 

(a) 

(b) 

(ec) 

(4d) 

11, List 

origin and sex 

the name, position, level or title, race, national 

origin, sex, term or length of tenure, and any 

other employment affiliation of the head of each 

office, department, unit, committee, division and 

all other substructures: 

the date that each person identified in the answer 

to Interrogatory 10 (a) assumed his or her position; 

the name, race, national origin, sex and term or 

length of employment of the predecessor of each 

person identified in the answers to Interrogatory 

10 (a). 

the specific responsibility or function assigned 

to each person identified in the answers to 

InterrogatorylO (a); and whether, how and why each 

function or responsibility of the person identi- 

fied in the answer to Interrogatory 10 (a) has 

changed. 

the name, residence, occupation, race, national 

of each member of the Board of Directors of 

Methodist Hospital and their terms of office or tenure for the 

following periods: 

(a) as of the time these Interrogatories are answered; 

Be 

  

 



      

(bp): as of January 1, 1976; 

{c) as of Jamuary 1, 1975; 

(d) as of January 1, 1974; 

(e) as of January 1, 1971; 

(£) as of January 1, 1970; and 

{(g) as of January 1, 1966. 

12. Describe briefly, but completely, the process of re- 

cruitment, selection, appointment and/or selection to the Board 

of Directors of Methodist Hospital. 

13. State whether Methodist Hospital has now or has ever 

had any policy or program to prefer or encourage minority persons 

for membership or a position on the Board of Directors of 

Methodist Hospital. 

14. With reference to the organizational structure of Gary 

Methodist Hospital set forth in the answers to Interrogatory 7 

identify the positions and levels of employment in each division, 

including all medical, nursing and other positions. 

15, State by race, national origin and sex (i.e., white 

males, white females, black males, black females, etc.,) the 

number of employees in each position and level by division at 

Gary Methodist Hospital as identified in the answer to Interroga- 

tory 14; 

(a) As of the time these Interrogatories are answered; 

(b) As of January 1, 1976; 

(¢) As of January 1, 1975; 

(d) As of January 1, 1974; 

(e) As of January 1, 1973; 

(E) As of January 1, 1972; 

(J) As of Jannnary 1, 1971; 

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(h) As of January 1, 1970; and 

(i) As of January 1, 1965. 

16. With reference to the organizational structure of 

Broadway Methodist Hospital set forth in the answers to 

Interrogatory 8 identify the positions and levels of employment 

in each division, including all medical, nursing and other 

positions. 

17. State by race, national origin and sex the number of 

employees in each position and level by division at Broadway 

Methodist Hospital as identified in the answers to Interrogatory 

15; 

(a) as of the time these Interrogatories are answered; 

and 

(b) as of Jammary 1, 1975, 

18. State whether Methodist Hospital has now or has ever 

had ay program to prefer or encourage minority persons as em- 

ployees for the purpose of increasing the number of minority 

group employees at either Gary Methodist Hospital, Broadway 

Methodist Hospital or both hospitals. 

19. If the answer to Interrogatory 18 is affirmative, 

describe in fail detail the duration, scope and nature of each 

such program and its result. 

20. If the answer to Interrogatory 18 is negative, state 

the reason why no such program has been undertaken. 

21. State whether any agency, commission, organization, 

official, or other party (including the defendants) has made any 

investigation, evaluation, assessment, recommendation or other 

report concerning employment opportunities, conditions of emplow 

ment, resolution of charges of discrimination, affirmative action 

i       
 



      

programs, upward mobility programs, community attitudes, or other 

subjects related to employment of minority persons at Gary 

Methodist Hospital and/or Broadway Methodist Hospital. 

22. For each investigation, evaluation, assessment, rec- 

ommendation in Interrogatory 21 produce it or state: 

(a) the date or dates covered in each study or re- 

port: 

(b) the parties or agencies who prepared each study 

or report, and the date(s) of preparation; 

(¢) a brief summary of each study or report; and 

(d) whether any action was taken regarding the re- 

sults of such study or report; and, if so, 

describe such action in full detail. 

23. Describe briefly, but completely, the criteria, or 

qualifications which individuals must meet in order to be con- 

sidered for hiring to each position and level at Gary Methodist 

Hospital and Broadway Methodist Hospital and state whether, why 

and how such criteria is different for each hospital, or have 

changed since 1970. Identify or produce any studies, evaluations) 

assessments, investigations, or other reports which analyze the 

validity of such criteria or qualifications. 

| 24. Describe briefly, but completely, the process of 

application and acceptance to a position at Gary Methodist 

Hospital and Broadway Methodist Hospital up to and including the 

final acceptance and rejection for hiring, and state whether, why 

and how the process is different for each hospital. 

25. State whether records are maintained of the race, 

national origin and sex of all applicants for hiring: 

be,   
   



      

(a) If such records are maintained, state by race, 

national origin and sex for each of the follow- 

ing periods the number of applicants for hir- 

ing for each position; identify the particular 

hospital, if any, for which the individuals 

applied for the following periods: 

(i) January 1, 1977 to the time these 

Interrogatories are answered; 

(ii) January 1, 1976 to December 31, 1976; 

(iii) January 1, 1975 to December 31, 1975; 

(iv) January 1, 1974 to December 31, 1974: 

(v) January 1, 1973 to December 31, 1973; 

(vi) January 1, 1972 to December 31, 1972: 

(vii) January 1, 1971 to December 31, 1971: 

(viii) Sanasey 1l, 1970 to December 31, 1970: 

and 

(ix) January 1, 1965 to December 31, 1965. 

If no such records are maintained, state 

whether the number, race, national origin and 

sex of applicants can be tabulated, and, if so, 

provide the information requested in Interrog- 

atory 25(a). If your answer is in the nega- 

tive, state the reason for such answer: 

identify all documents which are available per- 

taining to the race, national origin and sex of 

these applicants.   
 



      

26. State by race, national origin and sex and number of 

employees in each unit, division, position and level who applied 

for employment at Gary Methodist Hospital and who were hired for 

employment at Broadway Methodist Hospital. 

27. State by race, national origin and sex and number of 

employees in each unit, division, position and level who applied 

for employment at Broadway Methodist Hospital and who were hired 

for employment at Gary Methodist Hospital. 

28. State whether there is any process of application and 

acceptance for transfer from Gary Methodist Hospital to Broadway 

Methodist Hospital and from Broadway Methodist Hospital to Gary 

Methodist Hospital, and, if the answer is affirmative, describe 

the process briefly, but completely. 

29. State whether black or other minority persons are 

given any preference, consideration, or special treatment in 

hiring, promotions and transfers at Gary Methodist Hospital and/ 

or Broadway Methodist Hospital. 

30. Describe briefly, but completely, whether and how the 

number or percentage of any employees holding positions identi- 

fied in the answers to Interrogatories 14 and 16 are restricted 

or limited. Identify or produce any studies, evaluations, ass- 

essments, investigations or other reports analyzing the validity 

of such restriction or limitation. 

31. Identify or produce any documents which relate to any 

restriction or limitation identified in Interrogatory 30, in- 

cluding persons denied employment, promotion or transfer on such 

basis by position and level, name, race, national origin, sex and 

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date. 

32. State whether any facilities operated by Methodist 

Hospital are now used or have ever been used on a racially seg- 

regated basis. If the answer is in the affirmative, identify 

and give the reason for such usage. 

33. Describe briefly, but completely, the procedure used 

in filling permanent job vacancies. State whether any prefer- 

ence is given to present employees or their relatives or to per- 

sons living within the vicinity of Gary Methodist Hospital and 

Broadway Methodist Hospital. 

34. Describe separately, briefly, but completely the 

" function, purpose and significance of voluntary, temporary and 

part-time positions at Gary Methodist Hospital and Broadway 

Methodist Hospital; and whether, how and why the function, pur- 

puse and significance has changed at Gary Methodist Hospital 

since 1975. 

35. Describe briefly, but completely, by each unit, posi- 

tion and level, the process of application and acceptance for 

voluntary, temporary and part-time positions at Gary Methodist 

Hospital and Broadway Methodist Hospital; whether there is one 

process for both hospitals, and whether, how and why the process 

has changed since 1975. 

36. State whether records are maintained of the race, 

national origin and sex of all persons who have sought appoint- 

ment to voluntary, temporary and part-time positions at Gary 

Methodist Hospital: 

(a) if such records are maintained, state by race, 

national origin and sex for each of the follow- 

ing periods the numbers of persons who have 

wile 

  

 



    

sought such appointments, identifying the position 

sought; the number who were qualified or eligible for 

such appointment; the basis of selection: officials or 

supervisors in charge of selection; and the number 

accepted and rejected: 

(i) January 1, 1977 to the time these Interroga- 

tories are answered; 

(ii) January 1, 1976 to December 31, 1976: 

(iii) January 1, 1975 to December 31, 1975: 

(iv) January 1, 1974 to December 31, 1974: 

(v) January 1, 1973 to December 31, 1973; 

(vi) January 1, 1972 to December 31, 1972: 

(vii) January 1, 1971 to December 31, 1971: 

(viii) January 1, 1970 to December 30, 1970: 

(ix) January 1, 1965 to December 31, 1965. 

(b) If no records are maintained, state whether the race, 

national origin and sex of those who have sought such appointment 

can be tabulated, and, if so. provide the information requested 

in Interrogatory 36(a). If your answer is in the negative, 

identify all documents which are available pertaining to the race, 

national origin and sex of those who have sought such appointment; 

the total number who have sought such appointment, the number who 

qualified or were eligible for such appointment, the basis for 

selection, officials or supervisors in charge of selection, and 

the number accepted and rejected for each of the periods set forth 

in Interrogatory 36 (a). 

37. State whether black or other minority group members are 

given any preference, consideration, or special treatment in 

appointment to voluntary, temporary, and part-time employment, at 

Wi,     
 



      

either Gary Methodist Hospital, Broadway Methodist Hospital or 

both. Include any special programs, or other policies or prac- 

tices designed to affirmatively relieve racial imbalance in var- 

ious positions and levels at each hospital. 

38. Describe briefly, but completely, the geographic area 

from which Methodist Hospital draws its employees: 

(a) for each position and level at Gary Methodist 

Hospital; 

(b) for each position and level at Broadway Methodist 

Hospital. 

39. Describe separately for each hospital the process, 

criteria and standards of recruitment, application and selection 

of registered nurses, licensed practical nurses, graduate student 

nurses and nurses aides at Gary Methodist Hospital and Broadway 

Methodist Hospital, including whether, why and how the process, 

criteria and standards differ for the two hospitals and whether, 

why and how the process, criteria and standards have changed 

since 1975. 

40. Describe briefly, but completely, the conditions, per- 

quisities and/or requirements of employment for registered nurses 

and nurses aides at Gary Methodist Hospital, including but not 

limited to ki availability of housing, transportation and meals. 

State the date on which each such condition, perquisite and/or 

requirement was instituted, whether, how and why they have changed 

and the number of persons at each level, by race, national origin 

and sex who are subject to, take advantage of or utilize such 

conditions and facilities from: 

~13 

  

 



      

(a) January 1, 1977 to the time these Interrogatories 

are answered: 

(b) January 1, 1976 to December 31, 1976; 

(c) January 1, 1975 to December 31, 1975; 

(d) January 1, 1974 to December 31, 1974; 

(e) January 1, 1973 to December 31, 1973; 

(£) January 1, 1972 to December 31, 1972: 

(g) January 1, 1971 to December 31, 1971; 

(h) January 1, 1970 to December 31, 1970: 

(1) January 1, 1965 to December 31, 1965. 

41. Dssarive briefly, but completely, the conditions, per- 

quisites and/or requirements of employment for registered nurses, 

licensed practical nurses, graduate student nurses, and nurses 

aides at Broadway Methodist Hospital, including but not limited 

to the availability of housing, transportation and meals. State 

the date on which each such condition, perquisite and/or require- 

ment of ane LaEenE was instituted; whether, how and why they diffe: 

from those at Gary Methodist Hospital; the number of persons at 

each level, by race, national origin and sex who are subject to, 

take advantage of, or utilize such conditions and facilities since 

December, 1975. 

B. 

42. Describe separately for each hospital, the process, 

criteria and standards for determining the number of employees on 

the nursing staff of Gary Methodist Hospital and Broadway 

Methodist Hospital, including the separate process, criteria and 

standards with respect to registered nurses, licensed practical 

nurses, graduate student nurses, nurses aides and non-medical and 

non-nursing staff. State whether, why and how the process, 

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criteria and standards differ for the two hospitals, and whether, 

why and how the process, criteria and selection has changed since 

1975. 

43. Describe briefly, but completely, the training and ex- 

perience (i.e., student, foreign-trained, what country, American- 

trained, licenses, etc.) of each registered nurse, practical nurse, 

aide, and other member of the nursing staff at Gary Methodist 

Hospital who was employed or worked from: 

(a) January 1, 1977 to the time these Interrogatories 

are answered: 

(b) January 1, 1976 to December 31, 1976: 

(c¢) January 1, 1975 to December 31, 1975: 

(d) January 1, 1974 to December 31, 1974: 

(e) January 1, 1973 to December 31, 1973: 

(f£) January 1, 1972 to December 31, 1972: 

(g) January 1, 1971 to December 31, 1971: 

(h) January 1, 1970 to December 31, 1970: 

(1) January 1, 1976 to December 31, 1965. 

44. Describe briefly, but completely, the training and ex- 

perience of each registered nurse, practical nurse, nurses aide, 

and each other member of the nursing staff at Broadway Methodist 

Hospital wi was employed or worked from: 

(2) January 1, 1977 to the time these Interrogatories 

are answered, and 

(b) from January 1, 1976 to December 31, 1976. 

45. Identify the number of physicians employed on the med- 

ical staff of Gary Methodist Hospital by name, address, specialty, 

national origin and sex, specifying whether each is a specialist, 

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physician who has completed training, resident, intern, extern or 

consultant for the periods from: 

(a) January 1, 1977 to the time these Interrogatories 

are answered; 

(b) January 1, 1976 to December 31, 1976; 

(¢) January 1, 1975 to December 31, 1975; 

(d) January 1, 1974 to December 31, 1974; 

(e) January 1, 1973 to December 31, 1973; 

(£) January 1, 1972 to December 31, 1972; 

(g) January 1, 1971 to December 31, 1971: 

(h) January 1, 1970 to December 31, 1970; 

1, (1) January 1965 to December 31, 1965. 

46. Identify the number of physicians employed on the med- 

ical staff of Broadway Methodist Hospital by name, address, 

specialty, race, national origin and sex, specifying whether each 

is a specialist, physician who has completed training, resident, 

intern, extern or consultant for the periods from: 

(a) January 1, 1977 to the time these Interrogatories 

are answered: 

(b) January 1, 1976 to December 31, 1976. 

47. Identify the number of physicians with staff privileges 

at Gary ettiodict Nospital by name, address, specialty, race, 

national origin and sex, specifying whether each is a specialist, 

‘physician who has completed training, resident, intern, extern 

or consultant for the periods from: 

(a) January 1976 to December 31, 1976; 

(b) January 1975 to December 31, 1975; 

(c) January 1974 to December 31, 1974; 

(e) January 1972 to December 31, 1972; 

1971 to December 31, 1971: 

1, 

1, 

1, 

(d) January 1, 1973 to December 31, 1973; 

1, 

(£) January 1, 

1, (g) January 1970 to December 31, 1970. 

as 1 

  

 



      

@ ie 

48. Identify the number of physicians with staff privileges 

at Broadway Methodist Hospital by name, address, specialty, race, 

national origin and sex, specifying whether each is a specialist, 

physician who has completed training, resident, intern, extern 

or consultant for the following periods: 

(a) January 1, 1977 to the time these Interrogatories 

are answered; 

(b) January 1, 1976 to December 31, .1976. 

49. Describe briefly, but completely, the training and 

experience of each specialist, physician who has completed train- 

ing, resident, intern, medical aide, extern, consultant and other 

member of the medical staff at Gary Methodist Hospital, including 

place of educational training, date of graduation, years and type 

of experience, professional titles and board certification, if 

any, and specialty. 

50. Describe briefly, but completely, the training and 

experience of each specialist, physician who has completed trainin 

resident, intern, medical aide, extern, consultant and other mem- 

ber of the medical staff at Broadway Methodist Hospital, including 

place of educational training, date of graduation, years and type 

of experience, professional titles and board certification, if 

any, and specialty. 

51. State whether Gary Methodist Hospital and/or Broadway 

Methodist Hospital has or had any arrangement with a medical 

school under which the facility or students provide or have pro- 

vided services at the hospital and/or the hospital provides ser- 

vices to the medical school. 

52. If the answer to Interrogatory 51lis affirmative; 

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(a) describe briefly, but completely, the arrangement, 

specifying all aspects including, but not limited 

to the name and location of the school, the type of 

services, the extent of services, the period of 

time such arrangement has lasted or did last, which 

hospital or hospitals the arrangement covers, and 

whether any document describes, outlines, memorial- 

izes or governs such arrangement; 

(b) state separately by category and hospital, the num- 

ber of physicians, externs and interns who are af- 

filiated with the medical schools which have a 

current arrangement with the hospitals. 

53. If the answer to Interrogatory 51 is affirmative for 

one hospital only, state why arrangement were made for that one 

hospital only. 

54. State whether Gary Methodist Hospital and/or Broadway 

Methodist Hospital has or had any arrangement with a nursing 

school under which the facility and students provide or have pro- 

vided services at the hospital and/or the hospital provides or 

has provided services to the medical school. 

55. If the answer to Interrogatory 54 is in the affirmative, 

describe briefly, but completely, all terms of the arrangement, 

including but RoE limited to the name and location of the school, 

the extent and nature of the services, the period of time such 

arrangement has lasted or did last, which hospital or hospitals 

the arrangement covers, and whether any document describes, out- 

lines, memorializes or governs such arrangement. 

56. If the answer to Interrogatory 54 is affirmative for 

-18-       
 



      

one hospital only, state why arrangements were made for that one 

hospital only. 

57. Separately state the ratio of registered nurses, 

licensed practical nurses, nurses aides and student nurses to 

patients at Gary Methodist Hospital: 

(a) as of the time these Interrogatories are answered} 

(b) as of January 1, 1977; 

(c) as of January 1, 1976; 

(d) as of January 1, 1975; 

(e) as of January 1, 1974: 

(Ff) as of January 1, 1973; 

(g) as of January 1, 1970. 

58. Separately state the ratio of registered nurses, 

licensed practical nurses, nurses aides and student nurses to 

patients at Broadway Methodist Hospital: 

(a) as of the time these Interrogatories are answered 

(b) as of January 1, 1977; 

(c) as of January 1, 1976. 

59. If the entire or part of the physician staff of 

Methodist Hospital has joint staff privileges or employment on 

the staffs of Gary Methodist Hospital and Broadway Methodist 

Hospital, state whether records are maintained which indicate the 

time allocated by the medical staff as between the two hospitals: 

(a) if such records are maintained, identify each 

physician by race, national origin and sex and 

state tne number of patients admitted by each 

physician and patient days by payment and race;and 

the amount of days he or she has worked at Gary 

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Rr 0 " . rr . rr x. 

y i 45 rs / er @ Ra Tae 

Methodist Hospital, on the one hand, and Broadway 

Methodist Hospital, for the following periods: 

(i) January 1, 1977 to March 30, 1977: 

(ii) January 1, 1976 to December 31, 1976: and 

(iii) January 1, 1976 to June 1, 1976. 

(b) if no such records are maintained, state whether the 

information requested in Interrogatory 59 (a). 

can be tabulated and, if so, provide it. If your 

answer is in the negative, state the reason for such 

answer; identify all documents which are available 

pertaining to the information requested in 

Interrogatory 59(a). 

60. If there are separate medical staffs at Gary Methodist 

Hospital and Broadway Methodist Hospital: 

(a) separately state the ratio of specialists, indicat- 

ing specialities, physicians who have completed 

training, residents, externs and interns to patients 

at Gary Methodist Hospital: 

(1) as of the time these Interrogatories are 

answered: 

(ii) as of January 1, 1976; 

(iii) as of January 1, 1975; 

(iv) as of January 1, 1974; 

(v) as of January 1, 1973; 

(vi) as of January 1, 1972; 

(vii) as of January 1, 1971; and 

(viii) as of January 1, 1970. 

(b) separately state the ratio of specialists, indica- 

ting specialties, physicians who have completed 

Ws 

  

 



  

training, residents, externs and interns to pa- 

tients at Broadway Methodist Hospitals: 

(i) as of the time these Interrogatories are 

answered; 

(ii) as of January 1, 1977; 

(iii) as of January 1, 1976; and 

{iv) as of January 1, 1975, 

6l. Separately state the ratio of social service staff and 

volunteers to patients at Gary Methodist Hospital: 

(a) as of the time these Interrogatories are answered; 

(b) as of January 1, 1977; 

(c) as of January 1, 1976; 

(d) as of January 1, 1975; 

(e) as of January 1, 1974; 

(f) as of January 1, 1973; 

(g) as of January 1, 1972; 

(h) as of January 1, 1971; and 

(1) as of January 1, 1970. 

62. Separately state the ratio of soaisl service staff and 

volunteers to patients at Broadway Methodist Hospital: 

(a) as of the time these Interrogatories are answered: 

(b) as of January 1, 1977; and 

(c) as of January 1, 1976. 

63. Identify all physicians who do not admit patients but 

perform services (e.g., anesthesiology) upon a referral, con- 

tractual or employment relationship with other physicians at Gary 

Methodist Hospital by name, race, national origin, sex and 

specialty. 

Wh       
 



    

64. Identify all physicians who do not admit patients but 

perform services (e.g., anesthesiology) upon a referral, contract- 

ual or employment relationship with other physicians at Broadway 

Methodist Hospital by name, rage, national origin, sex and special- 

ty. 

65. State whether records are maintained which indicate the 

time spent by the individuals identified in the answers to 

Interrogatories g3 and Gat 

(a) if such decoras are maintained, identify the amount 

of time, in days, that each physician performed 

services, and specify the type of service performed 

at Gary Methodist Hospital for the following periods; 

(1) January 1, 1977 to the time these Interrog- 

atories are answered: 

(11) January 1, 1976 to Decenber 31, 1976; 

(iii) January 1, 1975 to December 31, 1975; 

(iv) January 1, 1974 to December 31, 1974; 

(v) January 1, 1970 to December 31, 1970; 

(vi) January 1, 1965 to December 31, 1965. 

(b) if such records are maintained, identify the amount 

of time, in days, that each physician performed ser- 

vices, and specify the type of service performed at 

Broadway Methodist Hospital for the following 

periods; 

(i) January 1, 1977 to the time these 

Interrogatories are answered; and 

(ii) January 1, 1976 to December 31, 1975. 

-     
 



  

(c¢) if no such records are maintained, state whether 

the information requested in Interrogatory 65 (a) 

and (b) can be tabulated and, if so, provide it. 

If your answer is in the negative, state the reason 

for such answer; identify all documents which per- 

tain to the information requested. 

66. State the total capacity and actual complement of beds 

at Broadway Methodist Hospital, specifying, if applicable, the de- 

partment to which the beds are assigned (e.g., 20 beds - obstetrics, 

10 beds - ICU, etc.), and whether the beds are in private rooms, 

semi-private, 3-bed, 4-bed or more than 4-bed rooms: 

(a) as of the time these Interrogatories are answered; 

(b) as of January 1, 1977; and 

{c) as of January 1, 1976. 

67. State the total bed capacity and actual complements of 

beds at Gary Methodist Hospital, specifying, if applicable, the 

departments or service to which the beds are assigned and whether 

the beds are in private rooms, semi-private, 3-bed, 4-bed or more 

than 4-bed rooms: 

(a) as of the time these Interrogatories are answered: 

(b) as of January 1, 1977; 

(c) as of January 1, 1976; 

(d) as of January 1, 1975; 

(e) as of January 1, 1974; 

(f) as of January 1, 1973; 

{g) ‘as of Jamwuary 1, 1972: 

(h) as of January 1, 1971; and 

(1) as of January 1l, 1970. 

D3       
 



  

68. State the following information for Gary Methodist 

Hospital for each year (either calendar year or fiscal year, but 

specify which) for the years 1977, 1976, 1975, 1974, 1973, 1970, 

and 1965 for Gary Methodist Hospital and for the years 1977, 1976 

for Broadway Methodist Hospital: 

(a) the total number of inpatients and inpatient days, 

clinic patients and clinic visits, ambulatory care 

patients and patient visits, and emergency room 

patients and patient visits; 

(b) with respect to inpatients, for each inpatient ser- 

vice unit, the number of patients and patient days, 

by race, national origin and sex; by patient's home 

zop code, and by source of admission (physician re- 

ferrel, outpatient clinic, emergency room, neighbor- 

hood health facility, other), and by means of pay- 

ment (private insurance, Medicare, Medicaid, Title V, 

self pay, free care, other); 

(c) with respect to outpatient clinic patients, for each 

outpatient clinic, the number of patients and (if 

different) patient visits, by race, national origin 

and sex, by patientt*s home zip code, and by means of 

payment. 

(d) With respect to emergency room patients, the number 

of patients and (if different) patient visits, by 

race, national origin and sex, by means of payment 

and patient's home zip code. 

(e) with respect to emergency room patients, the number 

admitted as inpatients; 

Dhue       
 



i ® a TIN YEA OR 2 aly tg 52 pe wr aie Aine Cb i SR ( } Tr A SRA SN tae 4 tw 3 

  

(£) with respect to ambulatory patients, for each ambu- 

latory service, the number of patients and (if 

different) patient visits by race, national origin 

and sex, by patients zip code, and by means of pay- 

ment: 

(g) identify and attach copies of all studies, documents) 

and reports in which any of the above or comparable 

information for the specified years is set forth, 

and which Methodist Hospital considered and/or sub- 

mitted to any governmental or regulatory body prior 

to or with reference to the construction of 

Broadway Methodist Hospital and the proposed expan- 

sion of Broadway Methodist Hospital. 

. 69. Describe specifically the type and number of non-medical 

services and facilities available to patients at Gary Methodist 

Hospital (e.g., telephones, color televisions, black and white 

televisions, radios, library, solarium, day room, etc.). Include 

whether there are sufficient numbers of such facilities so that 

they may be utilized by each patient; and whether, why and how 

the number and type of services and facilities have changed during 

the periods: 

(2) from January 1, 1977 to the time these Interroga- 

tories are answered: 

(b) from January 1, 1976 to December 31, 1976: 

(c) from January 1, 1975 to December 31, 1975; 

(d) from January 1, 1974 to December 31, 1974; 

(e) from January 1, 1973 to December 31, 1973; 

(f) . from January 1, 1972 to December 31, 1972: 

-25.       
 



    

(g) from January 1, 1971 to December 31, 1971: 

(e) from January 1, 1970 to December 31, 1970; 

(£) from January 1, 1965 to December 31, 1965. 

70. Describe specifically the type and number of non-medical 

services available to patients at Broadway Methodist. Include 

whether there are sufficient numbers of such facilities so that 

they may be utilized by each patient; and whether, why and how the 

number and type of services and facilities have changed during the 

periods: 

(a) from January 1, 1977 to the time these Interroga- 

tories are answered; and 

(b) from January 1, 1976 to December 31, 1976. 

71. Describe specifically the type and number of services 

and facilities available to the non-medical staff at Gary 

Methodist Hospital (e.g., cafeteria, lounges, color or black-and- 

white television, etc.). Include whether these services and 

facilities are available to all non-medical staff or part of the 

non-medical staff and, if part, which part, how and why. State 

whether, how and why these services and facilities have changed 

during the periods: 

(a) from January 1, 1977 to the time these Interroga- 

tories are answered; 

(b) from January 1, 1976 to December 31, 1976: 

(c) from January 1, 1975 to December 31, 1975: 

(d) from January 1, 1974 to December 31, 1974; 

(e) from January 1, 1973 to December 31, 1973: 

(£) from January 1, 1972 to December 31, 1972: 

(g) from January 1, 1971 to December 31, 1971: 

(h) from January 1, 1970 to December 31, 1970: 

5 we   
  

 



      

(i) from January 1, 1965 to December 31, 1965. 

72. Describe specifically the type and number of services 

and facilities available to the non-medical staff at Broadway 

Methodist Hospital. Include whether these services and facilities 

are available to all or part of the non-medical staff and, if in 

part, how and why. State whether, how and why these services and 

facilities have changed during the periods: 

(a) from January 1, 1977 to the time these Interroga- 

tories are answered: and 

(b) from January 1, 1976 to December 31, 1976. 

73. Describe the services and facilities available to the 

medical staff at Gary Methodist Hospital. State whether, how and 

why these services and facilities have changed during the periods: 

(2) from January 1, 1977 to the time these Interroga- 

tories are answered; 

(b) from January 1, 1976 to December 31, 1976; 

(c) from January 1, 1975 to December 31, 1975; 

(d) from January 1, 1974 to December 31, 1974: 

(e) from January 1, 1973 to December 31, 1973; 

(f) from January 1, 1972 to December 31, 1972: 

(g) from January 1, 1971 to December 31, 1971: 

(h) from January 1, 1970 to December 31, 1970; 

(1) from January 1, 1965 to December 31, 1965. 

74. Describe the services and facilities available to the 

medical staff at Broadway Methodist Hospital. State whether, how 

and why these services and facilities have changed during the 

periods: 

(a) from January 1, 1977 to the time these Interroga- 

tories are answered: and 

7 

  

 



  
    

(b) from January 1976 to December 31, 1976. 

75. Separately state any restrictions on physicians with 

staff privileges and physicians employed at Gary Methodist 

Hospital including (1) method of admission and type of patients 

at either hospital (ii) location of their offices, and (iii) af- 

filation with other hospitals. 

76. List all inpatient, outpatient clinic, ambulatory, 

emergency room, laboratory departments and services provided by 

Broadway Methodist Hospital. State whether, how and why these ser 

vices have changed since the opening of Broadway Methodist 

Hospital. 

77. List all inpatients, outpatient clinic, ambulatory, 

emergency room, laboratory departments and services provided by 

Gary Methodist Hospital. State whether, how and why these ser- 

vices have changed: 

(2a) since the opening of Broadway Methodist Hospital; 

(b) from January 1, 1970 to December 31, 1975: and 

(c) from January 1, 1965 to December 31, 1970. 

78. Separately list the type of surgery that is performed at 

Gary Methodist Hospital and Broadway Methodist Hospital. 

79. For each type of surgery listed in the answers to 

Interrogatory 78, separately identify for each hospital the 

number of surgery operations performed for the years 1977, 1976, 

1975, 1974 and 1973. 

80. Separately list all diagonistic x-ray facilities and 

radiation facilities at Gary Methodist Hospital and Broadway 

Methodist Hospital. 

8l. Separately state the number of operating rooms at Gary 

Methodist Hospital and Broadway Methodist Hospital. 

Wy:   
 



      

82. Describe specifically and completely the number and type 

of post-operative units and the equipment contained in each at 

Gary Methodist Hospital and Broadway Methodist Hospital. 

83. List all dental and physical therapy departments and 

services provided at Gary Methodist Hospital and Broadway 

Methodist Hospital. 

84. For each inpatient service unit or department at Gary 

Methodist Hospital and Broadway Methodist, separately state: 

(a) the number of patients and patient days for the 

years 1977, 1976, 1975, 1974 and 1973: 

(b) the major equipment and age of such equipment used 

in connection with the service; 

(c) during any one rotation the number of residents, 

interns and externs assigned to the service: 

(d) during any one rotation the number of registered 

nurses, licensed practical nurses and nurses aides 

assigned to the service; 

(e) the physicians (not including those in training) by 

specialty and name who admitted their private pa- 

tients to the service unit during the years 1976, 

1975 and 1974, and the number of patients thus ad- 

mitted: and 

(f) the physicians (not including those in training) by 

specialty and name, who were assigned or assumed 

responsibility for patients without private physi- 

cians, or patients admitted from the outpatient 

clinics, and the number of patiens admitted. 

85. State the cost per room of all rooms by type of room 

We 

  

 



[} ¢ PRON A AE LSI SPAN ro Rl EE I REE S20 Rl Tn SARL « = AEB SEY . : ee Be 

  

(private, semi-private, 3-bed ward, etc.) at; 

(a) Gary Methodist Hospital; 

(1) as of the time these Interrogatories are answered; 

(ii) as of January 1, 1976; 

(iii) as of January 1, 1975; and 

(iv) as of January 1, 1974; 

(b) Broadway Methodist Hospital; 

(1) as of the time these Interrogatories are answered; 

and 

(ii) as of Janvaryv 1, 19756, 

86. State whether Gary Methodist Hospital and Broadway 

Methodist are accredited by any governmental, regulatory or pri- 

vate agencies, associations or groups, including the Joint 

Commission on Accreditation of Hospitals (JCAH), the State Board 

of Health, the Department of the Fire Marshal of the State of 

Indiana, and the United States Department of Health, Education and 

Welfare, and, if so, state the names of the agencies, associa- 

tions or groups. 

87. Describe briefly, but completely, the dates and findings 

of the most recent reports made or issued by each agency, associa- 

tion or group set forth in the answer to Interrogatory 86, in- 

cluding whether each particular service reviewed was found in full) 

substantial or minimal compliance with the standards of each 

agency, association or group. 

88. Separately state for Gary Methodist Hospital and 

Broadway Methodist Hospital all plans, procedures, regulations, 

rules and guidelines regarding the present provision of free ser- 

vices to persons unable to pay in whole or in part for services 

30       
 



      

SERIE é PCRS en BT PE a Se ol Sa Ee Re HB RR En Sa SHIR 

(either by their own resources or by third party reimbursement) 

and state whether, how and why such plans and procedures have 

changed since 1975. 

89. For each outpatient clinic at Gary Methodist Hospital 

and Broadway Methodist Hospital separately state: 

(a) the days and hours of operation for the years 1977, 

1976, 1975, 1974 and 1973; 

(b) the procedures and treatment available in each 

clinic; 

(¢) the major equipment and age of such equipment used 

in connection with the service: 

(d) the number of visits during each of the years 1977, 

1976, 1975, 974 and 1973; 

(e) the physicians (not including those in training) 

assigned to each clinic (identifying by name and 

specialty and hours spent in the clinic on a weekly 

basis during the most recent complete two fiscal 

years, and whether employed by the hospital or af- 

filiated via a grant of staff privileges): 

(£) during any one rotation the number of residents, 

interns, and externs assigned to the clinic; 

(g) the physician in charge of the overall operation of] 

the clinic and the hours he (she) spent on a weekly 

basis during the most recent two complete fiscal 

years. 

90. For each ambulatory service department at Gary Methodist 

Hospital and Broadway Methodist Hospital, separately state: 

wd   
 



      

(a) 

(b) 

(ec) 

(d) 

(e) 

(£) 

(9) 

CEL SRE Ak Fo REF (CET ERIS ST Le in. ian si 5 eB Sm RT EN HA 

the days and hours of operation for the years 1977, 

1976, 1975, 1974 and 1973; 

the procedures and treatment available in each de- 

partment; 

the major equipment and age of such equipment used 

in connection with the service: 

the physicians (not including those in training) 

assigned to each department (identifying by name 

and specialty and hours spent in the claims on a 

weekly basis during the most recent complete two 

fiscal years and whether employed by the hospital 

or affiliated via a grant of staff privileges): 

during any one rotation the number of residents, 

interns, and externs assigned to the department: 

the number of visits during the most recent com- 

plete two fiscal years; 

the physican in charge of the overall operation of 

the department and the hours he (she) spent on a 

weekly basis during the most recent complete two 

fiscal years. 

91. For each emergency room at Gary Methodist Hospital and 

Broadway Methodist Hospital, separately state: 

(a2) 

(b) 

(c) 

(d) 

all services, procedures, and treatment available: 

the major equipment and age of such equipment used 

in connection with the service: 

the number of patient visits during the years 1977, 

1976, 1975, 1974 and 1973; 

the physicians (not including those in training) 

assigned during each shift (identifying by name, 

“33 

  

 



x é oa mn a a WEERA a Fe BR ei Se Rm SS ra AE Ba 2 Ww A RR FSR a La HB EER Ae ERT i Re a a Ra AR 

  

number, and specialty, and hours of responsibility, 

whether employed by the hospital or affiliated via 

a grant of staff privileges); and 

(e)during any one rotation the number of residents, 

interns, and externs each shift. 

92. Describe briefly, but completely, any fund-raising 

campaigns in which Methodist Hospital, or any of its sub-organiza- 

tions, agents, employees or organizations or persons working in 

its behalf participated or are participating since 1965. For each 

such campaign state: 

(a) the name, if any, given the campaign; 

(b) the persons, groups, businesses or organizations 

responsible for organizing the campaign; 

(c) the recipients of funds received from the campaign; 

(d) the stated purpose of the campaign; 

(e) the geographical area, businesses, organizations 

and individuals from which funds were solicited 

and toward which the campaign was directed; 

(f£) the specific use to which Methodist Hospital put 

funds received. 

Ce 

93. State, in order of descending responsibility or author- 

ity, the organizational units, boards, committees, and/or divi- 

sions which had responsibility for or authority over the decision 

to construct Broadway Methodist Hospital. 

94, List the name, race, national origin and occupation of 

members of the Board of Directors of Methodist Hospital and the 

Executive Committee of the Board of Directors for the years 1965 

“33       
 



      

through and including 1975. 

95. Describe briefly, but completely, when, how and why the 

decision to construct a second hospital facility, in addition to 

Gary Methodist Hospital, was made. 

96. Describe briefly, but completely, the factors considered 

by and the decision-making process of each organizational unit, 

board, committee and/or division which determined the location of 

a second hospital facility, in addition to Gary Methodist Hospi- 

tal. 

97. State whether records are maintained of meetings, dis- 

cussions, programs and other times where the decisions and factors 

set forth in the answers to Interrogatories 95 and 96 were dis- 

cussed, mentioned, considered or acted upon. Describe such re- 

cords in a manner sufficient for inclusion in a Rule 34 Motion 

to Produce and disclose the name and address of the custodian in 

whose custody these records lie or attach such records to your 

answers to this discovery instrument. 

98. Describe briefly, but completely, the factors considered 

by each organizational unit, board, committee and/or division 

which determined the initial size, nature, and extent of services 

and facilities at Broadway Methodist Hospital. State whether 

records are maintained of the meetings, discussions, programs and 

other times these faotots were discussed, mentioned, considered or 

acted upon; describe such records in a manner sufficient for in- 

clusion in a Rule 34 Motion to Produce and disclose the name and 

address of the custodian in whose custody these records lie, or 

attach such records to your answers to this discovery instrument. 

99. State the geographical area served by Gary Methodist 

Hospital prior to the construction and operation of Broadway 

“3h 

  

 



      

: i Ww 

ids . REPL Loe APE Lh CI Ss PLE RC BRL i 0 4 hi TIE SER J v asl 

Methodist Hospital, the geographical area served by Gary Methodist 

Hospital since the construction and operation of Broadway 

Methodist Hospital; and the geographical area served by Broadway 

Methodist Hospital. 

100. State whether there are any plans to enlarge or expand 

the facilities, services, number of beds, equipment and size of 

Broadway Methodist Hospital. Describe specifically and completely 

all such plans, including the projected dates of such plans. 

Describe in a manner sufficient for inclusion in a Rule 34 Motion 

to Produce all records of such plans and disclose the name and 

address of the custodian in whose custody these records lie, or 

attach such records to your answers to this discovery instrument. 

101. State whether there ever was or is Briley Pavitolpat 

tion in any decisions concerning the location, construction and 

plans of Broadway Methodist Hospital. If the answer is affirma- 

tive, list all groups of persons, and their Location or residence, 

who participated, and the exact extent, nature and duration of 

such participation. If the answer is negative, state why there 

was no community participation. 

102. State whether any consideration was made or studies 

conducted concerning the economic impact, including upon employ- 

ees, housing, office buildings and business enterprises of: 

(a) the initial construction and operation of 

Broadway Methodist Hospital; and 

(b) any plans for expansion of Broadway Methodist 

Hospital. 

If the answer is affirmative, describe the nature, extent, method- 

ology and findings of all such consideration and studies. De- 

scribe all records of such consideration and studies in a manner 

3B   
 



      

tw rn Ea Se Er ain SARS . a Bald ’ A SERS An ad Aad é SRP SO RC “ 

sufficient for inclusion in a Rule 34 Motion to Produce, disclose 

the name and address of the custodian in whose custody these 

records lie, or attach all such records to your answers to this 

discovery instrument. 

103. State whether any studies were made or utilized by 

Methodist Hospital to determine the effect of the construction 

and operation of Broadway Methodist Hospital on the location of 

the offices of physicians who have, or prior to 1975 had staff 

privileges or are or were employed at Gary Methodist Hospital; 

who have patients who live in Gary; and/or who have patients who 

lieve in Souty and East Lake County. If the answer is affirmative 

describe such studies in a manner sufficient for inclusion in a 

Rule 34 Motion to Produce and disclose the name and address of 

the custodian in whose custody these studies lie, or attach all 

these studies to your answers. 

104. State the cost of construction of Broadway Methodist 

Hospital and specifically identify the amount, source and nature 

of the funds used, including any loans, mortgages, contracts of 

insurance or guarantee or other indebtedness. 

105. Describe specifically the nature, extent, cost, source 

or revenue, function and effect of all renovations made at Gary 

Methodist Hospital since 1962. 

106. State the gross patient revenues by inpatient, out- 

patient, clinic, ambulatory service and emergency room: 

(a) for the years 1977, 1976, 1975, 1974, 1973 and 1970 

for Gary Methodist Hospital; 

(b) for the years 1977 and 1976 for Broadway Methodist 

Hospital. 

3B   
 



      

A J ; EA | Gg —_— ; i = EE ai 

107. State the gross patient revenues, broken down by in- 

patient, outpatient, clinic, ambulatory service and emergency 

room under the Medicare and Medicaid program: 

(a) for the years 1977, 1976, 1975, 1974, 1973 and 

1970 for Gary Methodist Hospital; 

(b) for the years 1977 and 1976 for Broadway Methodist 

Hospital. 

108. State whether any Federal or State agency, since 1965, 

has made an "on-site" investigation or review of Gary Methodist 

Hospital and/or Broadway Methodist Hospital with respect to com- 

pliance with Title VI of the Civil Rights Ach of 1964, If the 

answer is affirmative, state the approximate date of such 

inspections and the findings made as a result. 

109. State whether any Federal or State agency ever request- 

ed or directed Methodist Hospital to take specific action with 

respect to service of patients on the basis of race or national 

origin. If the answer is affirmative, state the agency, the date 

of the request or directive, the nature of the request or di- 

rective, and any actions taken to comply or conform to such 

request or directive. 

Respectfully submitted, 

il lis us riz 
JACK GREENBERG 

MELVYN R, LEVENTHAL 

BETH J. LIEF 

10 Columbus Circle 

New York, New York 10019 

  

JULIAN ALLEN 

2009 Broadway 

Gary, Indiana 46407 

CHARLES B. MILLER 

2009 Broadway 
Gary, Indiana 46407 

37 

  

 



      3G 

MARILYN G. ROSE 

CHRISTINE G. HICKMAN 

1751 N Street, N. W. 

washington, D. C. 20036 

Attorneys for Plaintiffs [||5c9e8aa0-9b55-4379-af88-0394cb155335||]