IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
MUNICIPAL DEPARTMENT, FIRST DISTRICT
ILLINOIS MASONIC MEDICAL CENTER,)
)
Plaintiff,
)
)
v.
)
)
ROBERT MURPHY,
)
)
Defendant.
)
No. 98 M1 177555
DEFENDANT'S INTERROGATORIES
AND DOCUMENT REQUESTS
TO:
Ghengis Goldberg
Levanh, Merty & Ghiterz P.C.
135 S. LaSalle
Chicago, IL 60603
Defendant, Robert Murphy, by his counsel, THE LEGAL ASSISTANCE
FOUNDATION OF METROPOLITAN CHICAGO, and pursuant to Supreme Court
Rules 213 and 214 request that the Plaintiff answer the following
Interrogatories in writing, under oath, and further request that
plaintiff produce for inspection and photocopying the following
documents, production to be made at the office of the Legal Assistance
Foundation of Chicago, 111 West Jackson Suite 300, Chicago, Illinois
60604, within twenty-eight (28) days of service hereof or five (5)
days prior to trial, whichever is sooner.
DEFINITIONS AND INSTRUCTIONS
A.
"Plaintiff" means or refers to Illinois Masonic Medical
Center an Illinois corporation, the Plaintiff in the above-entitled
cause, its divisions, parents, subsidiaries, related companies or
corporations, predecessors, successors, and all present and former
officers,
directors,
shareholders,
agents,
employees,
representatives and attorneys and all other persons acting or
purporting to act on behalf of any of them.
B.
"Defendant"
means
or
refers
to
ROBERT
MURPHY,
the
Defendant in the above-entitled cause.
C.
"Communications"
means
or
refers
to
all
inquiries,
discussions, conversations, negotiations, agreements, understandings,
meetings,
telephone
conversations,
letters,
notes,
telegrams, advertisements, or other form of verbal intercourse,
whether oral or written.
D.
"Documents" means or refers to all written or graphic
matter of every kind or description, however produced or reproduced,
whether draft or final, original or reproductions, and all tangible
things within the scope of the Illinois Supreme Court Rules
(especially Rules 201 and 214), specifically including but not
limited to:
papers, photographs, films, recordings, memoranda,
books, records, accounts, communications, abstracts, acceptances,
advertisements, agreements, appointment records, articles, articles
of incorporation, audio recordings (whether transcribed or not),
audits, balance sheets, bankchecks, bills, bills of lading, blanks,
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blueprints,
booklets,
books
of
accounts,
budgets,
bulletins,
by-laws, cablegrams, cards, certificates, charters, charts, checks,
circulars, computer programs, computer printouts, contract and
subcontracts,
confirmations,
correspondence,
data
compilations
(from which information can be obtained or translated through
detection devices) transcriptions or summaries of conversations,
credit files, daguerrotypes, delivery records, desk calendars,
diaries, directions, directives, drafts, drawings, discs, disks,
electronic or mechanical recordation in whatever medium, entries,
estimates, evaluations, expense reports, field notes, financial
statements, forms, graphs, handbooks, income statements, indices,
instruments,
intra-office
and
inter-office
communications,
invoices, itemizations, journals, ledgers, letters, licenses, logs,
magazines,
mail,
mailgrams,
microfilm,
minutes,
manuals,
negotiable
maps,
instruments,
meeting
reports,
news
releases,
newspapers, notes, notices, offers, opinions, order forms, orders,
pamphlets, payroll records, periodicals, permits, phonorecords,
photocopies,
plans,
planographs,
projections,
prospectuses,
postcards,
publications,
press
receipts,
releases,
records
of
account, regulations, releases, reports, requisition, resolutions,
rules, sketches, slides, specifications, statements, statistical
records, stenographic notes, stock, studies, summaries, surveys,
system analyses, tapes, telexes, telegrams, telephone messages,
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tests, time records, training manuals and materials, transcripts,
vouchers, warehouse receipts, worksheets, x-rays, and any other
electronic or mechanical recordings or transcripts or any other
instrument or device from which information can be perceived, or
which is used to memorialize human thought, speech or action, in the
possession, custody, or control of the party producing the documents,
wherever located.
The
term
"documents"
shall
include
copies
containing
information in addition to or in any way different from that contained
on the original and all the attachments, enclosures, or documents
referred to in any documents produced pursuant to this Request.
If
any tape, disc, card, wire or other electronic or mechanical
recording or transcript or any computer program is produced, the
party producing the documents shall also produce such documents or
devices as are necessary for the decoding, playing back, printing
out and/or interpretation thereof, and any other documents or devices
which are necessary to convert such information into a useful and
usable format, and the file folders, binders, separators or indexes
in which such "documents" are held or stored.
E.
"Relate to," including but not limited to its various forms
such as "relating to," shall mean consist of, refer to, reflect or
be in any way logically or factually connected with the matter
discussed.
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F.
"Identify," when used with respect to an individual means
to state the person's full name, race, present business affiliation
and position, if known, and present home address, past position and
business affiliation, if any, with any of the parties herein.
G.
"Identify," when used with respect to a company or other
business entity, means to state the company's legal name, the names
under which it does business, its form (partnership, corporation,
etc.), and to identify its principal proprietors, officers or
directors.
H.
"Identify," when used with respect to a document, means
to state the date, author, addressee, type of the document (e.g.,
"letter"), and to identify its last known custodian and location.
In lieu of identifying any document, you may make the document or
documents available for inspection and copying by so stating in your
answer.
I.
"Identify," when used with respect to a communication,
means to state the date and type of communication (e.g., "letter",
"telephone conversation" or "personal meeting"), to identify the
participants and to summarize the content of the communication.
If
the communication is also a document, or if any document confirms,
memorializes, reports or otherwise relates to the communication,
identify all such documents.
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J.
Whenever appropriate, the singular form of a word should
be interpreted in the plural and vice versa.
All words and phrases
shall be construed as masculine, feminine, or neuter gender,
according to the context.
"And" as well as "or" shall be construed
either disjunctively or conjunctively as necessary to bring within
the scope of this request any documents which might otherwise be
construed to be outside of the scope.
K.
The period of time encompassed by each request shall be
from January 1, 1995 to the date of these interrogatories, unless
otherwise limited by specific language.
L.
These Interrogatories and Document Requests shall be
deemed continuing so as to require further and supplemental answers
if information is obtained after the time of compliance herewith,
the answer of which would otherwise have been required by these
Interrogatories, or production of which would have been required by
these Document Requests.
M.
Defendants request, pursuant to Rule 214, that Defendant
furnish an affidavit stating whether the production is complete in
accordance with the requests herein.
INTERROGATORIES
1.
Describe the intake and admissions procedures followed
with regard to Defendant, including but not limited to:
dates of
services, manner in which Defendant’s source of payment and financial
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status was determined and the manner in which Defendant were informed
of possible costs.
2.
Identify all persons involved in the intake and admission
of Defendant at Illinois Masonic Medical Center.
3.
Identify all documents related to the intake and admission
of Defendant at Illinois Masonic Medical Center.
4.
State whether Defendant executed any written contract or
agreement to pay for services rendered by Plaintiff.
If the answer
is "yes, identify all such contracts or agreements.
5.
Identify all laboratory procedures and services provided
to Defendants by Plaintiff and state: (a) the cost to Plaintiff of
each such service or procedure; (b) the cost charged to Defendants
for each such service or procedure.
6.
Identify
each
and
every
medical
supply
provided
to
Defendants by Plaintiff and for each such supply state: (a) the cost
of such supply to Plaintiff: (b) the amount charged for such supply
to Defendants.
7.
Identify all pharmacy charges made to Defendants by
Plaintiff as summarized in Plaintiff's Exhibit A attached to its
Complaint and for each such charge state: (a) who ordered the
pharmaceutical material to be supplied to Defendants; (b) the purpose
of such pharmaceutical material; (c) the cost charged to Defendants
for each such pharmaceutical material.
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8.
Identify all communications (see Definition "I" above) by
Plaintiff to Defendants regarding payment for services received from
Plaintiff.
9.
Describe the market basis or other rationale for each of
the charges assessed against Defendants during the period of July
28, 1997 through August 6, 1997.
10.
If the rationale for any of the charges assessed against
the Defendants during the period of July 28, 1997 through August 8,
1997 is related to or dependent upon the charges assessed by other
hospitals, specify such hospitals and the rates charged by such
hospitals for each service provided to Defendants by Plaintiff.
11.
State the names and last known home addresses of those
hospital employees responsible for establishing the rates or charges
for hospital services rendered to Defendants, and whether said
individuals remain employed by the hospital as of 1999.
12.
Would
any
of
the
charges
or
reimbursement
amounts
specified in answer to Interrogatories No. 5-7 vary if a patient were:
a)
uninsured;
b)
insured by medicaid;
c)
insured by medicare;
d)
insured by a private insurance company such as
Blue Cross/Blue Shield.
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13.
If the answer to Interrogatory No. 12(a), 12(b), 12 (c)
or 12(d) is "yes," provide an itemized list of what the cost or
reimbursement rate of each service rendered to Defendants would have
been if said services had been charged to:
14.
a)
medicaid;
b)
medicare;
c)
private insurance, such as Blue Cross/
Blue Shield;
d)
Defendants.
If the answer to Interrogatory No. 12(a), 12(b), 12(c),
or 12(d) is "yes," please provide the rationale or basis for the
variances in charges.
15.
Did the hospital file a claim with the Illinois Department
of Public Aid/Human Services for medical services rendered to
Defendants during the period of July 28, 1997 through August 8, 1997.
16.
17.
If the answer to Interrogatory No. 19 is "yes,"
a)
upon what basis did the Illinois
Department of Public Aid deny the
claim?
b)
provide a copy of the claim form filed
on behalf of Defendant.
State, for each year from 1997 through 1998, the percentage of patients (a) who
are required to pay the full amount of the hospital’s chargemaster charges; (b) whose bills are
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paid by Medicare; (c) whose bills are paid by Medicaid; (d) who receive discounts by virtue
of agreements with third-party payors; and (e) who receive charitable write-offs or discounts.
If there are other significant categories, identify them as well and state the percentages for these
categories.
DOCUMENT REQUESTS
The definitions and instructions set forth above are hereby
expressly incorporated by reference and made a part of each request
that follows:
1.
All documents or records maintained by Plaintiff's Patient
Accounts Department regarding Defendant.
2.
All documents listing and describing all individual
medical services received by Defendant from Plaintiff upon which
Plaintiff bases its claim against Defendant.
3.
All documents indicating, describing or recording all
financial transactions between Plaintiff and Defendant.
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4.
All
documents
purporting
to
bear
the
signature
of
Defendants.
5.
All
uncompensated
documents
services
or
describing
reduced
the
price
availability
services
offered
of
by
Plaintiff to persons financially unable to pay the ordinary costs
of hospitalization for the years 1995 through 1998.
6.
All
documents,
studies
or
reports
containing
any
description or evaluation of the costs of the particular individual
medical services received by Defendant from Plaintiff.
7.
All documents, studies, or reports comparing the cost of
medical services at Plaintiff to the costs of comparable medical
services available at other hospitals in the Chicago Metropolitan
area, or otherwise, comparing the costs of medical services available
at other hospitals on a local, state, regional or national basis.
8.
All
documents,
reports
or
studies
containing
any
description of any programs or efforts by Plaintiff to analyze or
identify ways of reducing the costs of providing any medical services
to its patients.
9.
All documents describing the manner in which Plaintiff has
determined the costs of each individual medical service it provided
to Defendant.
10.
All documents used in answering or identified in the
Interrogatories.
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11.
All correspondences and documents sent to the Illinois
Department of Public Aid/Human Services by Plaintiff regarding its
claim for medical services rendered to Defendant.
12.
All correspondences and documents received by Plaintiff
form the Illinois Department of Public Aid/Human Services regarding
Plaintiff's claim for medical services rendered to Defendant.
13.
All contracts with the State of Illinois Department of
Public Aid/Human Services ("Agreement for Furnishing Important
Hospital Care") in effect at the time services were rendered to
Defendant.
---------------------------One of Defendants' Attorneys
HIRAM FOLLOGILLAP #91017
LEGAL ASSISTANCE FOUNDATION OF
METROPOLITAN CHICAGO
111 W. Jackson, Suite 300
Chicago, IL 60640
(312) 347-8309
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