Blank Pleading Template With Line Numbering -- Word by kpw16392

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									 1   Hestia F. Kagu-Tsuchi, Esq.
     KAGU-TSUCHI & ASSOCIATES
 2   1271 Aventine Hill
     Halema’uma’u, VULCAN
 3
     Telephone: (900) 388-4830
 4   Facsimile: (900) 344-3476

 5   Attorney for Plaintiff
     VIRGINIA VESTA
 6
                                  UNITED STATES DISTRICT COURT
 7
                                  CENTRAL DISTRICT OF VULCAN
 8
 9
                                                          Case No.: CDV - 125864
10    The Estate of VIRGINIA VESTA
                                                          COMPLAINT FOR COMPENSATORY
11                   Plaintiff,                           DAMAGES and PUNITIVE DAMAGES
             v.
12                                                           1. WRONGFUL DEATH
      PAZHAR BEDA, an individual, AGNI                       2. NEGLIGENCE
13                                                           3. MEDICAL MALPRACTICE
      PAPER COMPANY, a Delaware
14    Corporation, and PELE CLINIC, a private
      clinic located in Halema’uma’u City.                JURY TRIAL DEMANDED
15
                                                          Judge: Hon. Hephaestus Adranus
                     Defendant.
16                                                        Date Action filed:
                                                          Date set for trial:
17
     Plaintiff complains of Defendants and for causes of action alleges:
18
19                                I.      PARTIES AND JURISDICTION

20
      1.    Plaintiff VIRGINIA VESTA (hereinafter Plaintiff) was a resident of Halema’uma’u City,
21
     which is located in the State of Vulcan.
22
23    2.    Plaintiff was an employee at the Halema’uma’u pilot plant which is owned and operated
24
     by the Agni paper company.
25
26    3.    Defendant AGNI PAPER COMPANY (hereinafter AGNI), is a Delaware corporation

27   with its principal place of business in Halema’uma’u, Vulcan. Its primary pilot plant is located
28

                                                    -1-
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1   in Halema’uma’u, Vulcan, and it employs over one thousand employees at its Halema’uma’u

 2   plant.
 3
 4    4.      AGNI specializes in developing fire-resistant stationery for corporations that are

 5   particularly concerned with immortalizing their records for future generations to review. For this

 6   reason, AGNI has a special department that tests the ignition propensity of its final products.
 7
 8    5.      Defendant PAZHAR BEDA (hereinafter BEDA) is also a resident of Halema’uma’u

 9   City, which is located in the State of Vulcan. BEDA was also an employee of AGNI and worked

10   closely on a number of projects in the Pilot Plant with Plaintiff.
11
12    6.      Defendant PELE CLINIC is a private clinic located in Halema’uma’u City, in the State of

13   Vulcan.

14
      7.      All events giving rise to the causes of action that are the subject of this litigation took
15
16   place at the Agni Paper Company Pilot Plant located at 123 Brighid Lane, Halema’uma’u City,

17   Vulcan.
18
                         II.     FACTS COMMON TO ALL CAUSES OF ACTION
19
20    8.      On January 2, 2008, Plaintiff drove to the AGNI Pilot Plant where she parked her car in

21   the company parking lot. After parking her car, she proceeded to her station at the AGNI Pilot
22   Plant, where her job was to sample paper prototypes of various types of stationery that AGNI
23
     produced.
24
25    9.      AGNI is a company known for its fire-resistant stationery. It has developed special
26   patents for certain types of paper with unusually high heat tolerances and also designs custom
27
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                                                        -2-
               PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1   stationery for corporations located in fire-prone areas, who are particularly concerned with

 2   document longevity.
 3
 4    10.    At AGNI’s Pilot Plant, Plaintiff’s main job consisted of testing paper samples for correct

 5   specifications. The primary specification that plaintiff tested for was fire-resistance.

 6
      11.    The likelihood of whether an object will burn under certain circumstances is measured in
 7
 8   terms of ―ignition propensity.‖ Therefore, ignition propensity testing of stationery prototypes

 9   was a large part of Plaintiff’s work.

10
      12.    A stationery’s ignition propensity is tested in a machine called the ―Molins Hopper‖ (also
11
12   known as the ―Molins Machine‖, ―MH‖ or the ―hopper‖ – hereinafter the ―hopper‖). The hopper

13   examines each sheet of paper, burns a portion of a paper sample, and the crumples the unburned

14   portion of the sample into a paper ball called a ―muppet.‖ Muppets are subsequently weighed to
15
     determine the level of the sample’s fire-resisting properties. Following muppet-weighing, grades
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     are allocated to various varieties of stationery according to their ignition propensity
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     measurements.
18
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      13.    During their initial training, employees are instructed to open all windows during the
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     testing of stationery prototypes to ensure that there is an adequate amount of oxygen in the plant.
21
     As a fire precaution, they are further instructed to remove all loose paper and debris from the
22
23   surrounding area before ignition propensity testing is initiated.

24
      14.    AGNI claims that these instructions are in their employee handbook.
25
26    15.    Plaintiff believes that these instructions do not appear in the employee handbook, and that
27
     their only reference is oral.
28

                                                      -3-
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1    16.    At approximately 3:00pm on January 2, 2008, Plaintiff and BEDA were engaged in

 2   testing the ignition propensity of two particular grades of stationery: C2F and Straight Grade.
 3
 4    17.   Plaintiff recommended that all debris and loose paper be removed from the surrounding

 5   areas prior to testing the sample. However, BEDA refused, saying that they should just push the

 6   samples through since there were only a small number of samples in this batch and the hopper
 7
     rarely caught on fire. He assured Plaintiff that this would be safe, and that it would also save
 8
     them a lot of time.
 9
10    18.   Notwithstanding BEDA’s assurances, Plaintiff insisted on removing the surrounding
11
     debris and loose paper per standard company policy. However, there were no supervisors in the
12
     immediate vicinity to whom Plaintiff could turn for support.
13
14    19.   Within a minute of the disagreement, BEDA had already commenced with the ignition
15
     propensity testing himself and had ignored Plaintiff’s pleas to take the recommended
16
     precautions.
17
18    20.   The first several samples proceeded smoothly. However, all of a sudden the hopper
19
     jammed and there was a huge explosion which caused the west wall to collapse.
20
21    21.   Both Plaintiff and BEDA sustained serious burns and injuries as a result of the explosion,
22   and Plaintiff’s car was crushed by the collapsing wall.
23
24    22.   Plaintiff also suffered from the preexisting condition of chronic asthma, making the

25   inhalation of debris from the explosion particularly dangerous.
26
      23.   Immediately following the explosion, co-workers called an ambulance.
27
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                                                     -4-
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1    24.     The ambulance intended to take Plaintiff to a nearby state-of-the-art hospital. However,

 2   that hospital did not accept Plaintiff’s health insurance so Plaintiff insisted that the ambulance
 3
     take her to PELE CLINIC which was the only medical treatment facility that AGNI health
 4
     insurance plan covered.
 5
 6    25.     At Plaintiff’s request, the ambulance took her to PELE CLINIC (hereinafter ―CLINIC‖).
 7
 8    26.     The CLINIC was at capacity and unable to assist Plaintiff for five hours. When the

 9   CLINIC finally had room to provide Plaintiff with a bed, Plaintiff was unable to breathe and her

10   burn wounds had already started to bleed.
11
12    27.     At the CLINIC, nurses placed Plaintiff directly onto a bed without changing the previous

13   sheet.

14
      28.     The nurses failed to ask Plaintiff whether she had asthma, and hooked Plaintiff up to an
15
16   IV that administered fluids which gave her an allergic reaction.

17
      29.     Due to the severity of Plaintiff’s burn wounds and the negative impact of the unknown IV
18
     medication, Plaintiff’s health deteriorated. She lived long enough to provide a full account of
19
20   her experiences, but died following a serious asthma attack and the onset of infection a week

21   later.
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                                                      -5-
              PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1
 2
                                     IV. FIRST CAUSE OF ACTION:
 3
 4                                         WRONGFUL DEATH

 5                                    (Alleged against all Defendants)

 6
      30.   Plaintiff incorporates by reference all paragraphs above as though fully set forth herein.
 7
 8    31.   AGNI failed to provide written safety instructions to its employees concerning the safe
 9   operation of testing equipment in addition to its oral instructions.
10
11    32.   AGNI failed to provide strict supervision of dangerous testing operations.

12
      33.   AGNI failed to adequately test and maintain its Molins Hopper.
13
14    34.   BEDA failed to follow the standard practice of removing debris and loose paper from the
15   testing area prior to starting the sample testing, and furthermore ignored Plaintiff’s instructions
16
     that debris and loose paper be removed prior to testing the samples.
17
18    35.   CLINIC failed to provide prompt service to Plaintiff, notwithstanding Plaintiff’s
19   diagnosis of serious burns.
20
21    36.   CLINIC failed to ask Plaintiff whether she had asthma, resulting in the use of IV

22   medication that gave her an allergic reaction and caused her health to deteriorate.
23
      37.   CLINIC failed to provide sanitary sheets for Plaintiff’s bed, notwithstanding its
24
25   knowledge of Plaintiff’s open wounds, making Plaintiff particularly susceptible to infection.

26
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                                                      -6-
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1    38.    As a proximate cause of Defendants’ acts and omissions, individually and jointly,

 2   Plaintiff endured physical suffering, and died as a result of burns and injuries sustained in the
 3
     explosion as well as substandard medical treatment received at the CLINIC afterwards.
 4
 5    39.    Plaintiff has a surviving spouse, and 2 children for which she was the sole supporter.

 6
                                   V. SECOND CAUSE OF ACTION:
 7
                                              NEGLIGENCE
 8
 9                                    (Alleged against all Defendants)

10
11
      40.    Plaintiff incorporates by reference all above paragraphs as though fully set forth herein.
12
13    41.    AGNI had a duty to provide written safety instructions to its employees concerning the

14   safe operation of testing equipment in addition to its oral instructions. AGNI failed to do so.
15
16    42.    AGNI had a duty to provide strict supervision of dangerous testing operations. AGNI

17   failed to do so.
18
      43.    AGNI had a duty to adequately test and maintain its Molins Hopper. AGNI failed to do
19
20   so.

21
      44.    BEDA had a duty to comply with the standard company practice of removing debris and
22
     loose paper from the surrounding areas prior to testing the ignition propensity of samples.
23
24   Furthermore, he either knew or should have known that it was unsafe to operate the hopper

25   without first removing all debris and loose paper per Plaintiff’s instructions. BEDA failed to do
26   so.
27
28

                                                     -7-
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1    45.   CLINIC had a duty to provide prompt service to Plaintiff, to ask Plaintiff whether she

 2   suffered from asthma, and to follow standard sanitation procedures prior to admitting Plaintiff
 3
     for treatment. CLINIC failed to do so.
 4
 5    46.   As a proximate cause of Defendants’ acts and omissions, individually and jointly, a

 6   serious explosion resulted, causing Plaintiff to endure physical suffering, burns, and other
 7
     injuries, and eventually her subsequent death as a result of infection from inadequate sanitation
 8
     at the CLINIC that treated her after the incident.
 9
10    47.   As a proximate result of Defendants’ conduct, Plaintiff has incurred actual, incidental,
11
     and consequential damages according to proof. Plaintiff died as a proximate result of the
12
     incident, and Plaintiff’s car was destroyed during the explosion.
13
14                                  VI. THIRD CAUSE OF ACTION:

15                                     MEDICAL MALPRACTICE
16
                                       (Alleged against the CLINIC)
17
      48.   Plaintiff incorporates by reference all above paragraphs as though fully set forth herein.
18
19
      49.   The CLINIC had a duty of care to Plaintiff once they admitted her for treatment.
20
21    50.   The CLINIC had a duty to ask Plaintiff whether she suffered from asthma upon admitting
22   her for treatment in order to make sure that medications provided did not cause Plaintiff to have
23
     an allergic reaction. CLINIC failed to do so.
24
25    51.   The CLINIC had a duty to provide fresh linens to Plaintiff, as part of standard sanitation
26   procedures that are recognized across the medical profession. This was particularly important in
27
28

                                                     -8-
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1   Plaintiff’s case where she had open burn wounds, making her particularly susceptible to

 2   infection.
 3
 4    52.   As a direct result of the CLINIC’s actions, Plaintiff contracted an infection from which

 5   she subsequently died. Accordingly, Plaintiff’s estate has incurred actual, incidental, and

 6   consequential damages according to proof.
 7
                                     XVIII. PRAYER FOR RELIEF
 8
            WHEREFORE, Plaintiff prays judgment against DEFENDANTS as follows:
 9
10    1.    For compensatory damages, according to proof;
11
12    2.    For punitive damages, as to each of the Defendants, in an amount determined to be

13   appropriate by the court;

14
      3.    For exemplary damages as to each of the Defendants, in an amount determined to be
15
16   appropriate by the court;

17
      4.    For reasonable statutory attorney’s fees according to proof;
18
19    5.    For costs of suit; and
20
      6.    For such other and further relief as the court may deem proper.
21
22
     DATED: ________________, 2008
23
24                                                        HESTIA & ASSOCIATES

25
                                                          _________________________,
26                                                        Hestia F. Kagu-Tsuchi, Esq.
                                                          Attorney for Plaintiff
27                                                        VIRGINA VESTA
28

                                                    -9-
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1   Hestia F. Kagu-Tsuchi, Esq.
     KAGU-TSUCHI & ASSOCIATES
 2   1271 Aventine Hill
     Halema’uma’u, VULCAN 70024
 3
     Telephone: (900) 388-4830
 4   Facsimile: (900) 344-3476

 5   Attorney for Plaintiff
     VIRGINIA VESTA
 6
                                   UNITED STATES DISTRICT COURT
 7
                                   CENTRAL DISTRICT OF VULCAN
 8
 9
                                                           Case No.: CDV - 125864
10    The Estate of VIRGINIA VESTA
                                                           PLAINTIFF VIRGINIA VESTA’S
11                    Plaintiff,                           REQUESTS FOR PRODUCTION FROM
              v.                                           DEFENDANT AGNI PAPER
12                                                         COMPANY (SET ONE).
      PAZHAR BEDA, an individual, AGNI
13
      PAPER COMPANY, a Delaware
14    Corporation, and PELE CLINIC, a private
      clinic located in Halema’uma’u City.
15                                                         JURY TRIAL DEMANDED
                      Defendant.
16                                                         Judge: Hon. Hephaestus Adranus
                                                           Date Action filed:
17                                                         Date set for trial:
18
19
     ASKING PARTY:                  Plaintiff VIRGINIA VESTA
20   ANSWERING PARTY                Defendant AGNI PAPER COMPANY
     SET NUMBER ONE.
21
22   Plaintiff requests that on ________ (date), on or before _______ (time), that Defendant AGNI
     PAPER COMPANY identify, produce and permit the inspection, copying or photographing of
23
     the following documents, papers, books, photographs, objects, or tangible things at KAGU-
24
     TSUCHI & ASSOCIATES, located at 1271 Aventine Hill Halema’uma’u, VULCAN 70024.
25
     AGNI PAPER COMPANY is requested to produce all documents, objects, and things described
26
     herein that are in its possession, custody, or control. It is also requested to produce all
27   documents, objects, and things described herein that are in the possession, custody or control of
28   its agents, employees and attorneys.

                                                      - 10 -
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1
                                               DEFINITIONS
 2
        1. ―The company‖ refers to Defendant AGNI PAPER COMPANY, and all of its affiliates,
 3
            laboratories, plants, factories and related distributors.
 4
        2. ―Correspondence‖ refers to any form of written communication, including, but not
 5
            limited to mailed correspondence, drafts of correspondence, emails, and or other recorded
 6
            forms of communication such as memoranda, interoffice correspondence, transcripts of
 7
            telephone conversations and any written record reflecting other interactions between
 8
            parties.
 9
        3. ―Document‖ refers to any designated document or electronically stored information —
10
            including, but not limited to writings, drawings, graphs, charts, photographs, sound
11
            recordings, images, and other data or data compilations — stored in any medium from
12
            which information can be obtained either directly or, if necessary, after translation by the
13
            responding party into a reasonably usable form.
14
15
                                    REQUESTS FOR PRODUCTION
16
17
     REQUEST FOR PRODUCTION NO.1 (TOPIC 105):
18
     Please produce all reports, written memoranda, correspondence, and other documents related to
19
     building design compliance or noncompliance with structural standards, and compliance or
20
     noncompliance with structural regulations.
21
22
     REQUEST FOR PRODUCTION NO.2 (TOPIC 106):
23
     Please produce all reports, written memoranda, correspondence, and other documents related to
24
     job descriptions for testing or manufacturing positions.
25
26
27
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                                                     - 11 -
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1
     REQUEST FOR PRODUCTION NO.3 (TOPIC 107):
 2
     Please produce all reports, written memoranda, correspondence, and other documents related to
 3
     the ―Molins Machine‖, the ―Molins Hopper‖, and ―MH‖ in the context of manufacturing and
 4
     equipment, or the ―hopper.‖
 5
 6
     REQUEST FOR PRODUCTION NO.5 (TOPIC 109):
 7
     Please produce all reports, written memoranda, correspondence, and other documents related to
 8
     success or failure in complying with OSHA standards.
 9
10
     REQUEST FOR PRODUCTION NO.6 (TOPIC 110):
11
     Please produce all reports, written memoranda, correspondence, and other documents related to
12
     employment safety standards.
13
14
     REQUEST FOR PRODUCTION NO.9 (TOPIC 113):
15
     Please produce all reports, written memoranda, correspondence, and other documents related to
16
     paper testing procedures and protocols.
17
18
     REQUEST FOR PRODUCTION NO.10 (TOPIC 114):
19
     Please produce all reports, written memoranda, correspondence, and other documents related to
20
     ignition propensity testing.
21
22
     REQUEST FOR PRODUCTION NO.11 (TOPIC 115):
23
     Please produce all reports, written memoranda, correspondence, and other documents related to
24
     supervision requirements pertaining to the operation of machinery in manufacturing and testing
25
     facilities.
26
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                                                     - 12 -
              PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1
     REQUEST FOR PRODUCTION NO.12 (TOPIC 116):
 2
     Please produce all reports, written memoranda, correspondence, and other documents related to
 3
     fire safety procedures advocated, required or followed.
 4
 5
     REQUEST FOR PRODUCTION NO.14 (TOPIC 118):
 6
     Please produce all reports, written memoranda, correspondence, and other documents related to
 7
     past incidents involving the malfunction of machinery in connection with manufacturing or
 8
     testing activities, or which occurred within manufacturing or testing facilities.
 9
10
     REQUEST FOR PRODUCTION NO.15 (TOPIC 119):
11
     Please produce all reports, written memoranda, correspondence, and other documents related to
12
     any complaints, inspection reports, or warnings received from any governmental agency
13
     concerning working environment or conditions, or standards violations related to safety.
14
15
16
     REQUEST FOR PRODUCTION NO. 16 (TOPIC 120):
17
     Please produce all reports, written memoranda, correspondence, and other documents related to
18
     development or engineering of fire resistant or ―fire-safe‖ products.
19
20
     REQUEST FOR PRODUCTION NO.17 (TOPIC 121):
21
     Please produce all reports, written memoranda, correspondence, and other documents related to
22
     any insurance policy, including fire insurance.
23
24
25
     REQUEST FOR PRODUCTION NO.18 (TOPIC 122):
26
     Please produce all reports, written memoranda, correspondence, and other documents related to
27
     health insurance provided to employees.
28

                                                       - 13 -
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1
 2
     REQUEST FOR PRODUCTION NO.19 (TOPIC 123):
 3
     Please produce all reports, written memoranda, correspondence, and other documents regarding
 4
     communications with OSHA.
 5
 6
 7   Dated: June 15, 2008                KAGU-TSUCHI & ASSOCIATES

 8
                                                 __________________________,
 9
                                                 Hestia F. Kagu-Tsuchi, Esq.
10                                               Attorney for Plaintiff
                                                 VIRGINIA VESTA
11
12
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                                                   - 14 -
            PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1   Hestia F. Kagu-Tsuchi, Esq.
     KAGU-TSUCHI & ASSOCIATES
 2   1271 Aventine Hill
     Halema’uma’u, VULCAN 70024
 3
     Telephone: (900) 388-4830
 4   Facsimile: (900) 344-3476

 5   Attorney for Plaintiff
     VIRGINIA VESTA
 6
                                  UNITED STATES DISTRICT COURT
 7
                                  CENTRAL DISTRICT OF VULCAN
 8
 9
                                                         Case No.: CDV - 125864
10    The Estate of VIRGINIA VESTA
                                                         PLAINTIFF VIRGINIA VESTA’S
11                   Plaintiff,                          REQUESTS FOR PRODUCTION FROM
             v.                                          DEFENDANT PELE CLINIC (SET
12                                                       ONE).
      PAZHAR BEDA, an individual, AGNI
13
      PAPER COMPANY, a Delaware
14    Corporation, and PELE CLINIC, a private
      clinic located in Halema’uma’u City.
15                                                       JURY TRIAL DEMANDED
                     Defendant.
16                                                       Judge: Hon. Hephaestus Adranus
                                                         Date Action filed:
17                                                       Date set for trial:
18
19
     ASKING PARTY:                 Plaintiff VIRGINIA VESTA
20   ANSWERING PARTY               Defendant PELE CLINIC
     SET NUMBER ONE.
21
22   Plaintiff requests that on ________ (date), on or before _______ (time), that Defendant PELE
     CLINIC identify, produce and permit the inspection, copying or photographing of the following
23
     documents, papers, books, photographs, objects, or tangible things at KAGU-TSUCHI &
24
     ASSOCIATES, located at 1271 Aventine Hill Halema’uma’u, VULCAN 70024. PELE CLINIC
25
     is requested to produce all documents, objects, and things described herein that are in its
26
     possession, custody, or control. It is also requested to produce all documents, objects, and things
27   described herein that are in the possession, custody or control of its agents, employees and
28   attorneys.

                                                    - 15 -
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1
                                               DEFINITIONS
 2
        4. ―The clinic‖ refers to Defendant PELE CLINIC, as well as all of its doctors, nurses, other
 3
            medical staff, administrative staff, interns, residents and other employees or individuals
 4
            affiliated with the clinic or authorized to act on behalf of the clinic.
 5
        5. ―Correspondence‖ refers to any form of written communication, including, but not
 6
            limited to mailed correspondence, drafts of correspondence, emails, and or other recorded
 7
            forms of communication such as memoranda, interoffice correspondence, transcripts of
 8
            telephone conversations and any written record reflecting other interactions between
 9
            parties.
10
        6. ―Document‖ refers to any designated document or electronically stored information —
11
            including, but not limited to writings, drawings, graphs, charts, photographs, sound
12
            recordings, images, and other data or data compilations — stored in any medium from
13
            which information can be obtained either directly or, if necessary, after translation by the
14
            responding party into a reasonably usable form.
15
16
                                    REQUESTS FOR PRODUCTION
17
     REQUEST FOR PRODUCTION NO. 20 (TOPIC 124):
18
     Please produce all reports, written memoranda, forms, diagrams, handbooks, correspondence,
19
     and other documents related to standard emergency procedures.
20
21
     REQUEST FOR PRODUCTION NO.21 (TOPIC 125):
22
     Please produce all reports, written memoranda, forms, handbooks, correspondence, and other
23
     documents related to any standard warnings, precautions or other information measures taken to
24
     inform patients of health risks associated with treatment.
25
26
27   REQUEST FOR PRODUCTION NO. 22 (TOPIC 126):

28

                                                     - 16 -
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES
 1
     Please produce all reports, written memoranda, forms, correspondence, and other documents
 2
     related to any waivers, caveats, or other disculpatory statements provided to patients prior to
 3
     receiving treatment.
 4
 5
     REQUEST FOR PRODUCTION NO. 23 (TOPIC 127):
 6
     Please produce all reports, written memoranda, labels, handbooks, diagrams, correspondence,
 7
     and other documents related to sanitation procedures upon admission for treatment.
 8
 9
     REQUEST FOR PRODUCTION NO. 24 (TOPIC 128):
10
     Please produce all reports, written memoranda, warnings, procedures, instructions, labels,
11
     correspondence, diagrams and other documents related to medication or treatment provided to
12
     patients exposed to hazardous substances that may have been inhaled.
13
14
15
     REQUEST FOR PRODUCTION NO. 25 (TOPIC 129):
16
     Please produce all reports, written memoranda, correspondence, procedures, instructions, labels,
17
     warnings, diagrams and other documents related to the special treatment of patients suffering
18
     from asthma and limitations on what medications they can be administered.
19
20
21
22
     Dated: June 15, 2008                  KAGU-TSUCHI & ASSOCIATES
23
24                                                 __________________________,
25                                                 Hestia F. Kagu-Tsuchi, Esq.
                                                   Attorney for Plaintiff
26                                                 VIRGINIA VESTA
27
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                                                    - 17 -
             PLAINTIFF VIRGINIA VESTA’S COMPLAINT FOR COMPENSATORY, EXEMPLARY & PUNITIVE DAMAGES

								
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