Plaintiffs' Second Set of Interrogatories and Request to Produce to Indiana State Board of Health

     [||2e142b99-734c-4ce2-bdfc-514fb0f0446d||] IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

  

  

  

BERNICE TERRY, et al., | 

Plaintiffs, : | 

v. %. 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. s 

  

PLAINTIFFS' SECOND SET OF 

INTERROGATORIES AND REQUEST 

TO PRODUCE TO INDIANA STATE 

BOARD OF HEALTH 

Plaintiffs respectfully request, pursuant to Rules 33 and 34 

of the Federal Rules of Civil Procedure, that defendant Indiana 

State Board of Health, its directors, agents and employees, answer 

interrogatories and produce documents, as set forth below, within. 

i ten (10) days. 

 



  

1. Attach all documents and correspondence both from and to 
| 

| Methodist Hospital of Gary, Inc. concerning a proposed 100 bed 

| expansion at Broadway Methodist Hospital. 

  2. State the names of all persons and/or departments, 
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| within the Indiana State Board of Health, to whom Methodist Hos- 
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pital submitted any documents or correspondence concerning the 

| Svrpases expansion, and state for what purposes those documents 

were submitted. 

3. State whether or not the Indiana State Board of Health 

it 

| contacted any other governmental agencies, including the Northern 

| Indiana Health Systems Agency and the Department of Health, 

| Education and Welfare, concerning the proposed expansion. If the 

1 answer is affirmative, identify which agencies were contacted, 
{ 

when they were contacted, and why, and attach copies of all 

written communications. 

4. State whether or not any approval, for any purpose, 

related to the proposed 100 bed expansion, was given by any depart-   | ment of the State of Indiana. 

| 5. If the answer to No. 4, above, is affirmative, identify 

what person and/or department granted such approval, when such 

approval was granted, for what purpose it was granted, and attach 

copies of all written approvals. 

| 6. If the answer to No. 4, above, is negative, state the 

| current status of any such proposed expansion at Broadway Methodist 

| -=i.e., whether such application is slated to be approved, when   
such approval is to be granted, and for what purpose. 

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I 7. Explain the medicaid/medicare reimbursement policy of the 

| State of Indiana for (a) hospitals with only private rooms; (b) 

| hospitals with semi-private rooms; (c) hospitals with both private | 
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| and semi-private rooms. Attach copies of all relevant statutory 

| provisions and regulations. 

| 8. Attach copies of all documents and correspondence 

concerning medicaid/medicare reimbursement to Broadway Methodist 

|| Hospital and the policy of reimbursement established. 

Respectfully submitted, 

A 

  

"JACK GREENBERG 
BETH J. LIEF 

BRENT E. SIMMONS 

10 Columbus Circle 

New York, New York 10019 

  

i JULIAN B. ALLEN 
I 2009 Broadway 

Gary, Indiana 46407 

Attorneys for Plaintiffs 

CERTIFICATE OF oFRVICE 
  

I hereby certify that a copy of the foregoing Plaintiffs   
Second Set of Interrogatories and Request to Produce to Indiana 

State Board of Health was served by United States mail, postage 

prepaid, on the 3rd day of January, 1978, on counsel .for 

defendants as follows: 

Rebecca L. Ross, Esq. 

Department of Justice 

10th and Pennsylvania Avenue 
I Washington, D. C. 20530 

Marvin G. Garvin, Esg. and 

i Edward L. Koven, Esq. 

i Regional Attorney and General Attorney 
1 Department of Health, Education and Welfare 

| 300 South Wacker Drive, 18th Floor 
i Chicago, Illinois 60606 

 



  

  

  
  

Fred W. Grady, Esq. 

Assistant United States Attorney 

Northern District of Indiana 

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 

Gary, Indiana 46401 

Attorneys for Defendant Methodist Hospital 

of Gary, Ino. 

Theodore L. Sendak, Esq. 

Assistant Attorney General of Indiana 

219 State House 

Indianapolis, Indiana 46204 

Attorney for State Defendants 

Anthony DeBonis, Jr., Esq. 

Joseph E. Costanza, Esq. 

Murphy, McAtee, Murphy & Costanza 

First National Bank Building 

720 West Chicago Avenue 

East Chicago, Indiana 46312 

Attorneys for Defendant Kipton Kaplan 

tr’ 
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Attorney for Plaintiffs [||2e142b99-734c-4ce2-bdfc-514fb0f0446d||]