Answers to Defendant's First Set of Interrogatories and Request for Production of Documents

     [||80e6a60c-3464-4830-aea0-650c4ea81d8f||] IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., 

Plaintiffs 

VS. 

METHODIST HOSPITAL OF GARY, 

INC. , ef al., 

Defendants 

RICHARD GORDON HATCHER, 

et al., 

Plaintiffs 

VS. 

METHODIST HOSPITAL OF GARY, 

INC., et al., 

Defendants 

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NO. H 76-373 

NO. H 77-154 

ANSWERS TO DEFENDANT METHODIST HOSPITAL OF GARY, 

INC.'S FIRST SET OF INTERROGATORIES AND REQUEST 

FOR PRODUCTION OF DOCUMENTS 
  

Comes now the plaintiff, Richard Gordon Hatcher, and 
pursuant to Federal Rules of Civil Procedure, Rule 33, files 
1ts answers to defendant, Methodist Hospital of Gary, Inc.'s 
first set of interrogatories and request for production of 
documents. 

 



  

i. With regard to paragraph 3 of the complaint in 
Cause No. 77-154 state the following: See page 2a and 2b 

a. The names and addresses of Black and Hispanic 
residents of Gary who are or have been injured 
by the creation, perpetuation and expansion 
of the hospital system and the number of 
Black and Hispanic residents who will be 
injured by defendant's actions, and indicate 
what surveys or studies have been made to 
determine such numbers. If surveys or studies 
have been made, attach copies. 

b. The nature and extent of the alleged present 
and future injuries for each individual and 
class of plaintiffs. 

C. The names and addresses of handicapped residents 
of Gary who use or have used the facilities 
at Gary Methodist Hospital and the number 
who will use such facilities, and indicate 
what surveys or studies have been made to 
determine such numbers. If such surveys 
or studies have been made, attach copies 
of same. 

d. The exact nature and extent of the alleged 
present and future injuries to such handicapped 
residents as a result of the placement, removal 
to or expansion of facilities at Broadway 

~ Methodist Hospital. 

e. The specific ways and means whereby ‘handicapped 
and/or minority residents are better served 
by facilities located in Gary. 

£. The specific instances wherein handicapped 
and/or minority residents received better 
service at Gary Methodist Hospital as opposed 
to Broadway Methodist Hospital. 

2e State the name and addresses of minority and/ 
or handicapped citizens of Gary who have been denied medical 
services by Broadway Methodist Hospital and state the date 
on which services were denied and the services denied in 
each instance. gee page 2b 

Su Have plaintiffs made any surveys or investigations 
as to the number of Black, Hispanic or handicapped individuals 
who are effectively prevented from seeking services at Broadway 
Methodist Hospital? If the answer is affirmative, attach 
copies of such surveys and/or the results of such investigations 
to the answer. See page 2b 

4, State the names and addresses of minority and 
handicapped citizens who are effectively discouraged from 
seeking medical services at Broadway Methodist Hospital 
because of the difficulty, time and/or expense of commuting 
from the City of Gary to Broadway Methodist Hospital. 
See page 2b ; 

Di 

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la. Plaintiff Hatcher does not know the names and 
addresses of all Black and Hispanic residents of 
Gary who are or have been or will be injured by 
defendant's actions. The names and addresses of 
the persons Plaintiff Hatcher does know include: 

Anna Brooks WEEKS WEEKLY VISITS 
2608 Lincoln St. 1/25/77 3 

BEGAN: 7/25/77 8/1/77 5 
END: 8/12/77 8/8/77 5 

Joe Marks WEEKS WEEKLY VISITS 
1921 Washington St. 3/3/77 2 
BEGAN: 3/3/77 3/7/77 5 
END: 4/13/77 3/14/77 5 

3/21/77 5 

Jessie Holden WEEKS WEEKLY VISITS 

401 Jefferson St. 8/1/77 5 
BEGAN: 8/1/77 8/8/77 5 
END: 8/15/77 

Willie Bell WEEKS WEEKLY VISITS 
2625 Mass. St. 6/7/17 5 
BEGAN: 6/7/77 6/13/7777 5 
END: 1/5/77 6/20/77 5 

6/27/77 5 

Rev. Oliver Thomas WEEKS WEEKLY VISITS 
3724 NW. : 24th 5/9/77 5 
BEGAN: 5/9/77 5/16/77 5 
‘END: 7/13/77 5/23/77 5 

5/30/77 5 
6/4/77 5 

Mary Wagner 

1720 Harrison St. 20 Times 

No dates of starting time 

Ruth Frisbee WEEKS WEEKLY VISITS 
112. W. 8th 2/21/77 5 
BEGAN: 2/2/77 2/7/77 5 
END: 3/2/77 2/14/77 5 

2/21/77 5 
3/1/77 5 
5/10/77 Monthly Checkup 

William Austin WEEKS WEEKLY VISITS 
1917 Adams St. 4/1/77 5 
BEGAN: 4/1/77 4/11/77 5 
END: 5/20/77 4/18/77 5 

4/28/77 5 
5/2/77 5 
9/7/77 1 Checkup 

Charles Giran WEEKS WEEKLY VISITS 
2517 Adams St. 7/1/77 1 
BEGAN: 7/1/77 7/5/77 2 (Mon. & Pri.) 
END: 7/25/77 ! 7711/17 3 {Mon., Wed. & Fri.) 

7/18/77 3 n " n | 

1/25/77 3 Ww " yd n P 

; 8/1/77 3 n " " 

9/21/77 1 Checkup 

Ethel Vaughn 

2301 Penn. St. 10/19/77 13 Times 

Lucille George 
1968 Delaware St. 10/19/77 20 Times 

 



  

1b. 

1c. 

1d. 

Blanche Maclin 10/26/77 11 Times 
1708 Hayes St. 

Jeff Smith 11/14/77 4 Times 

555 Adams St. 

The injuries suffered by Plaintiff Hatcher are 
stated in paragraph 4 of the complaint in H77-154. In 
addition, Metro Corps has had to devert funds, 

staff and buses from other services, particularly 

its program of providing meals to the elderly, 
in order to transport persons to Broadway 
Methodist who are and were in need of critical 
radiation therapy not provided at Gary Methodist 
and who are and were unable to obtain transporta- 
tion to that facility. Because of the diversion 
of funds, it has been forced to terminate its 
preparation of the Loaves and Fishes Program, which 
provides meals for the elderly, with a consequent 
loss of quality to needed service. 

The injury to the plaintiff class is the loss of 
civil rights suffered by a segregated hospital 
system; the past, present and planned diversion 
of funds from Gary for use at Broadway; the 
inaccessability by virtue of its location and lack 
of public or hospital sponsored transportation to 
Broadway from Gary; the refusal of Methodist Hospital 
of Gary, Inc. to implement building and services 
programs which were and are recognized as necessary 
at Gary; the lack of adequate community knowledge and 
‘participation in the building programs of Methodist 
Hospital; the underrepresentation of minority members 
on the Board of Directors of Methodist Hospital; 
the failure effectively to recruit medical manpower 
to Gary; the failure to insure adequate medical 
coverage at Gary Methodist Hospital; the planned 
removal of the laundry from Gary to Broadway 
which will remove needed jobs from minorities; 
the further plans to duplicate services at Broadway 
and Gary which will agravate segregation and in 
violation of the civil rights assurances signed in 
1973, all of which have the effect of discriminating 
in purpose and effect against the plaintiff class. 
Additional instances of injury may surface during 
the discovery process and plaintiffs do not deem 
themselves foreclosed from supplementing this 
answer. 

Unable to provide. 

Lack of access by transportation to Broadway Methodist 
Hospital by public or hospital sponsored transportation; 
placement of linear accelerator at Broadway. 

Facilities located at Gary are accessable to the 
minority and handicapped residents of Gary. 

Unknown. 

Unknown 

No. 

The meaning of "effectively discouraged" is unclear. 
Unknown to all who are discouraged from seeking treatment, 
but see answer to la as to those whom Plaintiff Hatcher 

has knowledge. 

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5. 

Cause No. 

6. 

Cause No. 

With regard to paragraph 4 of the complaint in 
77-154, state the following: gee page 3a 

de. The specific instances where plaintiff Hatcher's 
enforcement of his responsibilies have been 
obstructed by the actions of defendant, Methodist 
Hospital of Gary, Inc. 

The specific dates on which plaintiff Hatcher 
has sought and/or obtained the use of health 
facilities at Gary Methodist Hospital and/or 
Broadway Methodist Hospital. 

The nature and extent to which plaintiff 
Hatcher has been harmed or will be harmed 
by the actions of defendant. 

With regard to paragraph 14 of the complaint in 
77-154 state: gee page 3a- 

de. State all the facts known to plaintiffs upon 
which the allegation that Merrillville, Lake 
County, Indiana, is "an overwhelmingly white 
suburb" is based and attach to the answers 
any surveys and/or studies and all written 
documents prepared by plaintiffs or other 
persons upon which the allegations are based. 

Whether plaintiffs made any surveys or investi- 
gations to determine that "63% of the population 
of Gary, Indiana is Black and Hispanic". 
If the answer is affirmative, attach copies 
of such surveys to the answers. 

The definition of "elderly" residents, the 
basis for that definition and whether plaintiffs 
have made any surveys and investigations 
to determine that "72% of the elderly residents 
of the areas served by both facilities reside 
in the City of Gary". If such surveys have 
been made, attach copies of the surveys to 
the answers. 

The exact geographic areas referred to as 
"areas served by both facilities," and what 
surveys and/or studies have been made to 
determine those areas. 

The number and names and addresses of "elderly" 
residents who suffer physical disabilities, 
whether plaintiffs have made any surveys 
or investigations to determine those numbers, 
the nature and extent of the physical disabilities 
suffered by each of the elderly residents 
referred to and the provisions of §504 relied 
upon to support plaintiffs' allegations in 
paragraph 14. Attach to the answers all 
such surveys, investigations or other written 

 



  

5a. 

5b. 

5C. 

54. 

6a. 

6b. 

6c. 

6d. 

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By reducing services at the Gary facility, by erecting, 

maintaining and seeking to expand a superior facility 
at Broadway, some 15 miles south of the area of need. 

Plaintiff Hatcher has not needed such services. 

By requiring plaintiff to seek services not available 
in Gary. 

By restricting admission to those patients who can 
afford private rooms. By spending more for improvements 
at Broadway than at Gary. 

1970 census data. 

1970 census data. 

65 and older; 1970 census data; no surveys made. 

Gary, Crown Point, Merrillville, Glen Park, Griffith, 
Highland, Schereville, St. John, Dyer, Lowell, Leroy, 

Cedar Lake, Hebron, Kouts, Demotte. Information 

derived from suburbian fund drive brouchure 

Project 71%, page 17. 

The names and addresses requested are unknown, execept 
for information in answer to Interrogatory 1. No 
surveys have been made. The provision of Sec. 504 
relied upon is at 29 U.S.C. Sec. 794. 

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material upon which plaintiffs based their 
allegations in paragraph 14 of the complaint. 

7. With regard to paragraph 15 of the complaint in 
Cause No. 77-154 and paragraph 11 of the amended complaint 
in Cause No. 76-373 state: See page 4a 

a. Whether plaintiffs have made any surveys 
or investigations to determine the allegations 
that eighty percent of the patients treated 
at Gary Methodist Hospital are Black and 
Hispanic while only 10% of the patients treated 
at Broadway Methodist Hospital are Black 
and Hispanic. If the answer is affirmative, 
attach all such surveys or other written 
information to the answers. 

bh. Whether plaintiffs have made any studies 
or investigations to determine the percentage 
of staff members which are Black and Hispanic 
at each facility. If the answer is affirmative, 
attach to the answers all surveys, studies 
or other written material upon which plaintiffs 
based their allegations in paragraph 15 of 
the complaint. 

C. If no such studies or investigations as set 
out in a or b above have been made, state 
all facts and circumstances that you took 
into account in making the allegations set 
forth in paragraph 15 of the complaint in 
Cause No. 77-154 and in paragraph 11 of the 
amended complaint in Cause No. 76-373. 

8. With regard to paragraph 16 of the complaint in 
Cause No. 77-154 state any other alleged actions by Methodist 
Hospital other than those set forth in paragraphs 16 (a), 
(b) , (c) and (d) which have the purpose and effect of creating 

a hospital system which excludes persons from, denies them 
the benefit of, and otherwise discriminates against and 
segregates them on the basis of race, national origin or 
physical handicap; if any studies or investigations were 
undertaken to discover such alleged actions and/or gauge 
the force and effect of such action, and, if such studies 
or investigations were undertaken, attach a copy Of such 
study or the results of such investigation and any memoranda, 
report or other recorded documents detailing such study 
and/or investigation. See page 4a: 

9. With regard to paragraph 16(a) of the complaint 
in Cause No. 77-154 and 12(a) of the amended complaint in 
Cause No. 76-373 state all the facts known upon which 
plaintiffs based their allegations therein, and attach to 
the answer all surveys, studies or other written documents 
prepared by plaintiffs or other persons upon which the allegations 
are based. See page 4a- 

10. With regard to paragraph 16(b) of the complaint 
in Cause No. 77-154 and 12(d) of the amended complaint in 
Cause No. 76-373 state all the facts known to the plaintiffs 
upon which plaintiffs based their allegations therein and 
attach to fhe answers all surveys, studies or other written 1 See page 4a : q 

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7a. 

7b. 

No. 

No. 

Methodist Hospital EEO-1 Report; Survey by Methodist 
Hospital of patient census in early months of 1976 
taken in response to request by HEW. 

See answer to Interrogatory lb. No studies were 
undertaken. 

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1970 census data; visual inspection. 

EEO-1 Reports of Methodist Hospital; Methodist 
Hospital's answer to plaintiffs' interrogatories. 
While these are the facts known at the present time, 
discovery is still in progress and plaintiffs do 
not deem themselves foreclosed from supplementing 
their facts. 

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documents prepared by plaintiffs or other persons upon which 
allegations are based. gee page 4a“ 

11. With regard to paragraph 16(c) of the complaint 
in Cause No. 77-154 and 12(c) of the amended complaint in 
Cause No. 76-373 state all the facts known to plaintiffs 
upon which plaintiffs based their allegation that the facilities 
located at the Broadway facility "are not accessible to - 
the minority and handicapped residents of Gary by public 
transportation” and attach to the answers all surveys, studies 
or other written documents prepared by plaintiffs or other 
persons upon which the allegations are based. See page 5a. 

12. With regard to paragraph 16(d) of the complaint 
in Cause No. 77-154 state: See page 5a : 

a. The policies and practices allegedly adopted 
by defendant "to assure racial segregation 
and discrimination." 

b. The exact ways defendant allegedly designed 
the new facility "so as to assure racial 
segregation and discrimination.” 

13. With regard to paragraph 17 of the complaint in 
Cause No. 77-154 attach any and all letters, studies, memoranda, 
minutes, summaries or other recorded documentation of the 
allegation that the designated State planning agencies named 
therein, failed to consider the impact of the new facility 
described therein on the minority and handicapped residents 
of Gary, Indiana. See page 5a 

14. State all the facts known to plaintiffs ‘upon which 
the allegations of paragraph 18 of the complaint in Cause 
No. 77-154 and paragraph 14 of the amended complaint in 
Cause No. 76-373 are based and attach to the answers all l 
written documents prepared by plaintiffs or other persons 
upon which the allegations are based. See page 5a 

15. State all the facts known to plaintiffs upon which 
the allegations of paragraph 20 of the complaint in Cause 
No. 77-154 are based and attach to the answers all written Pg 
documents prepared by plaintiffs or other persons upon which 
the allegations are based. See page 5a" 

16. State all the facts known to plaintiffs upon which 
the allegations of paragraph 21 of the complaint in Cause / 
No. 77-154 are based and attach to the answers all written V4 
documents prepared by plaintiffs or other persons upon which 
the allegations are based. See page 5b 

17. With regard to paragraph 22 of the complaint in 
Cause No. 77-154 and paragraph 16 of the amended complaint 
in Cause No. 76-373 state the following: See page 5b 

a. The names and addresses of all individuals, 
organizations or groups who objected to HEW 
to the approval of Hill-Burton funds for 
Methodist Hospital of Gary, Inc., the dates 
on which each objection was made and whether 
the objections were made orally or in writing. 
If made orally, state the entire nature of 

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11. 

12a. 

125%. 

13. 

14. 

15. 

o * 
Plaintiffs believe there is no dispute that there is 
no public transportation from Gary to Broadway 
Methodist Hospital. In addition, transportation 
studies are available for inspection at the offices 
of Shropshire & Allen, 2009 Broadway, Gary, Indiana. 

The facts are that: The location of Gary Methodist 
and Broadway Methodist Hopsitals in segregated 
neighborhood; 1972 survey of where doctors would 
practice, attached to Everett Johnson's 1972 
long-range program of Methodist Hospital; 
foreseeability of white flight; the refusal to 
implement needed renovatio and modernization 
programs at Gary Methodist; the erection, maintenance 
and attempt to expand a superior facility at 
Broadway Methodist Hospital; the failure to implement 
a transportation system between Gary and Broadway 
Methodist Hospitals that was recognized as needed. 
Plaintiffs are still conducting discovery and 
do not deem themselves foreclosed from supplementing 
further facts. 

See answer to Interrogatory lb. 

The answers of Northern Indiana Health Systems 
Agency to plaintiffs' interrogatories and attachments 
20, 21, 22, and 26, of which defendant has copies. 
See State Exhibit 25 in response to plaintiffs’ 
interrogatories. Plaintiffs believe defendant has 
a copy of this document. If defendant does not have 
a copy and is unable to obtain one, plaintiffs will 
‘make the exhibit, which is voluminous, available 
for inspection upon reasonable notice. Plaintiffs 
are still conducting discovery and do not deem 
themselves foreclosed from adducing further facts. 

HEW approved the Hill-Burton application without 
first requiring any assurances that would, inter 
alia, effectively assure equality of facilities 
and services at Gary Methodist hospital and 
Broadway, integration of the patient and staff 
populations, implementation of renovation and 
remodeling programs at Gary; adequate medical 
manpower at Gary despite the fact that segregation 
and deterioration of Gary Methodist Hospital was 
foreseeable. Plaintiffs only last week received 
documents from HEW in response to their request 
for production of documents filed two (2) months 
ago and as yet have not analyzed them. Therefore, 
attachment of documents is not possible at this 
time. Some documents are part of State Exhibit 25 
produced in response to plaintiffs' interrogatories. 
For production of these documents, see answer to 
Interrogatory 13. 

See the reviews by the staff of the Northern 
Indiana Health Services Agency, Inc. of Methodist 
Hospital's 1976 proposals; the minutes of the 
NIHSA concerning those proposals; and the 
answers by NIHSA to plaintiffs' interrogatories. 

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Plaintiffs believe that defendant has obtained 
copies of the above from NIHSA. If this belief 
is mistaken, plaintiffs will cooperate in securing 
copies for defendant. 

Plaintiff are still in discovery and 4o not deem , 
themselves foreclosed from adducing further facts. 

16. See Exhibits 25 and 26 attached to the answers 
of the State defendants to plaintiffs' interrogatories. 
Plaintiffs believe that the defendant has obtained 
copies of such Exhibits; if this belief is mistaken, 

plaintiffs will make these voluminous exhibits 
available upon reasonable notice. Since plaintiffs 
have received these documents only last week, they 
are unable at this time to penpoint specific problems 
of those exhibits in response to this interrogatory. 

Plaintiffs are still in discovery and do not deem 
themselves foreclosed from adducing further facts. 

l7a. See Exhibit C to complaint H76-373. Written 
copies of communications are contained in State 
Exhibit 25 and in documents received last week 
from HEW. Plaintiffs believe that defendant has 
obtained copies of all documents received by 
plaintiffs; if this belief is inaccurate, 
plaintiffs will make such documents available upon 
reasonable notice. 

a
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the conversation, the mode of communication 
and to whom the objection was made. If the 
complaint was in writing, attach to the answers / 
such written communications. L 

b. The dates on which HEW replies were made 
and the name(s) of those individuals to whom 
the reply was made and whether the reply 
was made orally or in writing. If HEW made 
an oral reply state the entire nature of / 
the conversation and the mode of communication’ 
If the reply was made in writing, attach 
to the answers all such written replies. See page 6a 

18. State all the facts known to plaintiffs upon which 
the allegations of paragraph 23 of the complaint in Cause 

- No. 77-154 are based and attach to the answers all written 
documents prepared by plaintiffs or other persons upon which 
the allegations are based. See page 6a" 

19. With regard to plaintiff Hatcher state the following: 

a. The Hatcher family annual income, indicating 
the source of such income. 

b. The number of automobiles owned, leased or 
otherwise available to plaintiff Hatcher 
or his family and the make, model and year 
of such automobiles. 

Co The time to travel from Mr. Hatcher's residence 
to Broadway Methodist Hospital and the route 
taken and the time to travel from Mr. Hatcher's 
residence to Methodist Hospital of Gary and 
the route taken stating the mileage from 
the Hatcher residence to Broadway Methodist 
Hospital. See page 6a 

20. With regard to paragraph 25(a) of the complaint 
in Cause No. 77-154 state the policies and practices alleged 
to have been engaged in by defendant Methodist Hospital 
of Gary which discriminate and segregate persons on the 
basis of race, color, national origin or physical handicap. 
See page 6a V 

21. With regard to paragraph 25(b) of the complaint 
in Cause No. 77-154 state the specific assurances which 
defendant Methodist Hospital allegedly failed to comply 
with. see page 6a 

22. State whether plaintiffs have made any surveys, studies 
or investigations of the demographic projection for Lake 
County, Indiana. If the answer is affirmative, attach to , 
the answers all such surveys, studies or reports on investi- v 
gations. See page 6a 

23. State whether plaintiffs have made any surveys, studies 
or investigations of the racial, ethnic and handicapped / 
population composition of Gary, Indiana and/or Lake County, / 
Indiana. If the answer is affirmative, attach to the answers Vv / 
all such surveys, studies or reports on investigations. 
See page €a 

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17b. 

18. 

19a. 

190. 

1c. 

20. 

21. 

22. 

23. 

24. 

25. 

See report of HEW, Region V, dated October, 1976, 
attached to plaintiffs' Memorandum in Opposition to 
(now withdrawn) Motion of HEW to dismiss or, in the 
alternative for Summary Judgment. 

See HEW, Region V report dated, March, 1977, attached 
to (now withdrawn) Motion of HEW to dismiss or, in 
the alternative for Summary Judgment. Plaintiffs 
have no knowledge of the nature of any oral 
communications. 

See affidavit of Alfred Sanchez, submitted in 
support of (now withdrawn) Motion of HEW to Dismiss 
or, in the alternative, for Summary Judgment; to the 
extent this interrogatory is repetitive of Interrogatory 
8, see answer to Interrogatory 1b. 

Plaintiff Hatcher refuses to answer such question. 
The question is neither material or relevant to the 
issues in this case nor will it lead to relevant 
information. Plaintiff Hatcher is not eligible for 
medicare or medicaid. 

See Answer to interrogatory 19a. 

Plaintiff Hatcher has not yet had to use either facility. 

See answer to interrogatory 5a. 

By violating paragraphs 1, 3, 4, 7, 8 and 9 of the 
1973 Civil Rights Assurances Agreement. 

See Exhibit 11 to plaintiff Metro Corps answers to 
defendant's interrogatories. 

No. 

Plaintiff has filed no amended complaint in H77-154. 

1970 census data. 

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24. With regard to paragraph 3 of plaintiffs' amended 
complaint in Cause No. 77-154 state the following: See page 6a 

a. The exact dates on which plaintiff Hatcher i 
has used the facilities of Gary Methodist 
Hospital. 

b. All the facts known to plaintiffs upon which 
the allegations of paragraph 3 are based 
and attach to the answers all written documents 
prepared by plaintiffs or other persons upon 
which the allegations are based. 

25. State all facts known to plaintiffs upon which 
the allegations of paragraph 8 of the amended complaint 7 
in Cause No. 76-373 are based and attach to the answers 
all written documents prepared by plaintiffs or other persons 
upon which the allegations are based. gee page 6a 

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26. State all the facts known to plaintiffs upon which 
the allegations of paragraph 9 of the amended complaint t/ 
in Cause No. 76-373 are based and attach to the answers 
all written documents prepared by plaintiffs or other persons 
upon which the allegations are based. See page 7a 

27. State all the facts known to plaintiffs upon which 
the allegations of paragraph 10 of the amended complaint 7 
in Cause No. 76-373 are based and attach to the answers 4 
all written documents prepared by plaintiffs or other persons 
upon which the allegations are based. See page 7a 

28. State all the facts known to plaintiffs upon which 
the allegations of paragraph 11 of the amended complaint 
in Cause No. 76-373 are based and attach to the answers 
all written documents prepared by plaintiffs or other persons 
upon which the allegations are based. See page 7a: 

29. State all facts known to plaintiffs upon which 
the allegations of paragraph 12 of the amended complaint 
in Cause No. 76-373 are based and attach to the answers 
all written documents prepared by plaintiffs or other persons 
upon which the allegations are based and state the specific 
actions by defendant Methodist Hospital over the past ten 
(LO) years which allegedly have demonstrated its intent 
to deprive the Black residents of the City of Gary of adequate 
medical services. See page 7a 

30. State all the facts known to plaintiffs upon which 
the allegations of paragraphs 15 and 19 of the amended complaint 
in Cause No. 76-373 are based and attach to the answers 
all written documents prepared by plaintiffs or other persons 
upon which the allegations are based. See page 7a 

3l. State specifically and in detail each incidence 
of Methodist Hospital's failure to comply with the Rehabilitation 
Act of 1974 (§504), the name and address of the individual 
effected and whether or not such person filed a §504 complaint 
with the Department of Health, Education and Welfare. 
See page 7a : 

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26. 

27. 

28. 

29. 

30. 

31. 

Articles of Incorporation of Gary Fund Drive, submitted 
by defendant Methodist in response to plaintiffs’ 
First Set of Interrogatories. 

See annual report of Gary Fund Drive attached as 
as Exhibit 9 the plaintiff Metro Corps's answer 
to interrogatories. 

See answer to Interrogatory 7c. 

The interrogatory seeks a full statement and 
exhibits of all plaintiffs will seek to prove at 
trial. As such, it is anticipated a pre-trial 
order which plaintiffs are unable to prepare 
until all discovery is complete. 

See answer to Interrogatory lb. See Sec. 1122 
application of Methodist Hospital. 

The incidences and names and addresses of individuals 

are unknown to the plaintiff Hatcher. 

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32. State, in detail, the date, substance and subject 
of any communication whether written or oral, by or between 
the plaintiff Hatcher and the following organizations, corporations, 
entities, agencies and/or commercial enterprises, the owners, 
officers and/or directors thereof, or the stockholders therein 
with regard to the relocation of said entities or any part 
or division thereof from downtown Gary to the surrounding 
suburban area and/or the termination of the operation of 
that entity in the City of Gary (if said communications 
were written, attach a copy of same): See page 8a : 

a. The Gary National Bank. 
be Holiday Inn Inc. (downtown Gary). 
Ce J. C. Penney Co. 

a. Sears, Roebuck & Co. 
e. St. Mary Mercy Hospital, Inc. 

Ee H. Gordon & Son. 

Ge S. S. Kresge Co. (ne K-Mart, Inc.). 
h. The Bank of Indiana N.A. | 

33. The names and addresses of any members of any 
plaintiff class who filed or voiced an objection to the 
placement or expansion of Broadway Methodist Hospital with 
any of the following named agencies, organizations, bodies 

or individuals from January 1, 1963, to the present time: 
See page 8a 

a. The Department of Health, Education and Welfare . 
(if to a particular office or section thereof, 
so state). | 

4 The Northwest Indiana Comprehensive Health 
Planning Agency. 

Co The Northern Indiana Health Systems Agency. 

d. The United States Public Health Service. 

e. The Surgeon General of the United States. 

£. The Methodist Church. 

g. The City of Gary (if to a particular office 
or section thereof, so state). 

kh. The National Association for the Advancement 

of Colored People. 

i. The Internal Revenue Service. 

j. The Joint Committee for the Accreditation 
of Hospitals. 

K. The Governor of the State of Indiana. 

il. The Indiana State Board of Health. 

1m. The Gary Post Tribune. 

n. Any United States Senator or Congressman. 

0. Any other elected or appointed public official. 

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32. 

33a. 

33b-0. 

Plaintiff objects to this question as being neither 
material or relevant to the issues in this case. 

Plaintiff Hatcher notified this department by 
Mailgram and letter, copies of which have been 
furnished to counsel for all parties. 

Plaintiff Hatcher did not notify or voice an objections 
to any of the persons or agencies listed in 33b-o. 

-8a- 

 



  

If any such objections were made, state the date and substance 
of the objection and copies thereof if in writing and the 
date and substance of any response to the objectors and 
attach copies of any memoranda, minutes, letters, studies, 
reports, documents, findings or other recorded documentation 
of such objection, responses or other material generated 
by such objections and/or responses. 

34. State the date, time and location of any meeting, 
hearing or other gathering called for the purpose of, or 
resulting in discussion of any of the following subjects 
by and between the plaintiff, Richard Gordon Hatcher, and 
any citizens groups representing the citizens of Gary or 
Lake County, Indiana or any portion thereof or any representa- 
tives of groups named in Interrogatory Number 31: See page 9a 

a. Health care in the City of Gary and/or Lake 
County, Indiana; 

b. The implementation of §504 of the Rehabilitation 
Act of 1974 in the City of Gary or Lake County, 
Indiana; 

Co Public Transportation in the City of Gary 
or Lake County, Indiana; 

Nd. The establishment of any municipal owned 
health care facilities including but not 
limited to hospitals and clinics; 

If such discussions, negotiations, correspondence, meetings 
or agreements took place or were made, attach a copy of 
all written or recorded minutes, memoranda, letters, agreements, 
studies, surveys, findings or other recorded documentation 
thereof. 

35. Describe the relationship of the Medical Center 
of Gary, Inc. to the City of Gary, if any, and describe 
all funding provided by the City to the Medical Center of 
Gary since the creation of the Medical Center of Gary, Inc. 
See page 9a’. 

36. Have you, as Mayor of the City of Gary, ever appointed 
Dr. Alfonso Holliday to any position of any kind? Specify 
date of appointment and position. gee page 9a 

37. Has Dr. Alfonso Holliday ever contributed to any 
of your political campaigns for Mayor, City Councilman or 
any other position? See page 93 

38. escribe all modes and methods of public transportation 
existing in the City of Gary at the present time and as 
of: See Attachment 39a 

January 1, 1977, January 1, 1976, January 1, 1975, 
January 1, 1974, January 1, 1973, January 1, 1972, 
January 1, 1971, January 1, 1970, January 1, 1967 
and January 1, 1965 

39. Describe all routes of said public transportation 
See Attachment 39a 

 



  

34. Plaintiff Hatcher, as a member of the Common Council 

of the City of Gary from 1964 to 1967 and as Mayor 
of the City of Gary since 1968, has held meetings 
on a weekly basis with citizens and members of his 
staff to discuss all aspects of health care. The 
records of the Common Council and of his office 
are so voluminous that it is not possible to 
produce what defendants ask. The records of the 
Clerk of the Common Council are public records and 
may be inspected or copies by anyone. 

35. The Medical Center of Gary, Inc. has a contract with 
the City to administer the Family Health Center and 
to do the health planning for the City. The funds 
for such contract are from revenue sharing. Since 
1975, the Center has received the following funds: 

1975 $ 50,000.00 
1976 $375,000.00 (250,000.00 of which is to operate 

the Family Health Center) 
1977 $375,000.00 (250,000.00 of which is to operate 

the Family Health Center) 

36. Chairman of Dollars for Decency, Member of the Board 
of Trustees, School City of Gary. 

37. Plaintiff Hatcher objects to this question as being 
neither material nor relevant to the issues in this 

case. 

Dated this day of y. 3977. 
  

I affirm under the penalty for perjury that the foregoing 
statements are true. 

  

RICHARD GORDON HATCHER, Plaintiff [||80e6a60c-3464-4830-aea0-650c4ea81d8f||]