PADM

December 17, 2017 Medical

DRP. Elizabeth Mann 5. State the name and address of each physician or other practitioner of the healing arts not named in response to Interrogatory Number 4 who has examined you or who has consulted regarding any other injuries or medical conditions within the ten (10) years preceding filing f your Complaint, and briefly describe the injury or condition, the approximate date each physician was consulted, and the treatment received. Attach copies of any medical records in the possession of you or your attorney with respect to any such treatments or consultations.

State the name and address of each hospital or clinic in which you have received treatment, consultation, examination or advice for the injuries or medical conditions mentioned in the Complaint or for any injuries you received or diseases or medical conditions from which you suffered at any time within the ten (10) years preceding filing of the Complaint. Attach copies of any medical records in the possession of you or your attorney with respect to any such treatments or consultations.

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Methodist Lee Bonjour Germantown Hospital 7691 poplar Eave. Germantown, TN 38138 7. Itemize and attach copies of all bills or other relevant documents reflecting the cost and expense of all medical treatment and services rendered and medicine received as a result of the injuries or medical conditions described in the Complaint. As to each item, list the person or firm with whom such expense was paid or incurred, the date or period on or during which it was incurred and the amount. ANSWER: 8.

Have you ever received any money, whether by settlement, trial, insurance payment or otherwise, for any personal injury? If so, as to each, describe the injury, the amount of payment made, the approximate date or dates. Attach copies of any documents in the possession of you or your attorney pertaining to such claims and payments. ANSWER: 9. Has any physician or other practitioner of the healing arts ever evaluated you for disability or for impairment in connection with any injury or condition?

If so, provide the name and address of the physician, the approximate date of the evaluation, and the disability of impairment assigned, if any. Attach copies of any written reports or records of such evaluations in the possession of you or your attorney. 10. Apart from the present civil action, has any other civil action ever been filed on your behalf against anyone? If so, as to each, explain briefly the nature of the action, the county and state in which it was filed, approximately when it was filed, and the name and address of the attorney who represented you or is representing you.

Have you ever made a claim against any other party or insurance company in connection with the matter out of which this action rises? If so, as to each such claim, state the name of the party or the name of the insurance company and its insured and its policy number or claim number, the amount of money received to date as a result of the claim, and the date and recipient of any release, trust agreement, covenant not to sue, or other agreement discharging or limiting liability which you have executed.

Attach copies of any documents pertinent to such claims in the possession of you or your attorney. 12. Please identify any accidents involving motor vehicles in which you have been involve d, excluding the accident which is the subject f this lawsuit, providing: (a) the date and location; (b) the nature of any personal injury sustained; and (3) whether you received any payment related to property damage or personal injury as a result of the accident. 13.

Have you ever made any claim for any of the following benefits: workers’ compensation, disability insurance, Social Security Disability, payments under any other government or insurance program or employment benefit program for any injury or disability, or any service-connected disability? If so, as to each such claim, state the nature and extent of the injury, approximately when the claim was dad, the address at which you were living when the claim was made, and with what company, firm, governmental agency or person the claim was filed.

Attach copies of any documents pertinent to any such claim in the possession of you or your attorney. 14. List chronologically all employments you have had in the past ten (10) years prior to filing this Complaint and up to the present, including name and address of employer, name of supervisor, position held, dates the employment began and ended, and reason for termination of the employment. ANSWER: The Life Church of Memphis 1806 N. Germantown Poky. Cordovan, TN 2006-2008 Teacher/East. & Director- Resigned Mime Farmer- Director Baptist Memorial Hospital 6019 walnut Grove Memphis, TN 2008-2013 Crossroad’s Hospice 2013-2014 15.

Since the happening of the matters mentioned in the Complaint, have you applied for employment anywhere? If so, state the name and address of each person or firm to whom you have applied for employment. ANSWER: yes, SEC Federal 225 Humphrey Blvd. Memphis, TN 38120 16. State all facts supporting any claim that you lost any pay or that you are entitled to any compensation for loss of earning capacity, including how much and for what period of time, and attach any documents pertinent to this claim. 17.

State the gross amount of your earnings from all employments and attach copies of your federal income tax returns, W-2 Forms, and 1099 Forms of the five (5) previous calendar years. 18. Describe where you had been and what you had been doing for twenty-four (24) hours preceding the accident in this matter, where you were going at the time of the accident, the purpose of such trip and your expected time of arrival there. ANSWER: I was headed home to my family and was expected there by 5:app. . 19.

Provide a narrative statement of how, when, where and why the accident for which you are making this claim occurred. ANSWER: The motorist was not paying attention and driving extremely fast. 20. State whether you consumed any intoxicating beverage within twelve (12) hours prior to the incident and if so, specify: The type of beverage or beverages; the quantity of each; the time and place each beverage was consumed; and the identity and location of each person known to you who was present when each beverage was consumed.

ANSWER: None List all person with whom you were with within twelve (12) hours prior to the accident, giving their street address and phone 21. Number. ANSWER: James Williams and Derrick Dotson 22. List all persons, entities, or things which you believe contributed to cause this accident and state all facts supporting your belief as to each. ANSWER: Nathan -rat 23.

State the name and address of each person who (a) was, or was reported to be, an eyewitness to the accident; (b) was at or near the accident scene shortly before or after the accident; (c) has, or may have, knowledge concerning the identity of other witnesses; (d) dad or has possession of any photographs of the accident scene, or of any person (including yourself) allegedly injured in the accident; (e) heard any witness or any party make any statement concerning the accident or concerning the facts and circumstances surrounding it; (f) has, or may have, knowledge concerning the facts and circumstances surrounding the accident or your injuries, illnesses or conditions before and after the accident, but whose name has not been provided in answers to any of the questions above.

ANSWER: James Williams and Derrick Dotson. 24. State the name and address of each person who reportedly heard or claims to know that any Defendant or representative thereof in this action made any statement, declaration or admission as to liability, responsibility or fault with regard to the accident out of which this action arises. Y Please state the names and addresses of all persons, whether or not you intend to call them as witnesses at trial, including 25. Plaintiff, who have knowledge of facts pertaining to the allegations of Plaintiffs Complaint, and provide a general summary of the facts of which you understand each such person is knowledgeable. 6.

Please state the name, present employer and address of all persons who Plaintiff intends to call as expert witnesses at trial or has consulted with Plaintiff and with respect to each such witness; (a) State the subject matter on which the expert witness is expected to testify; (b) State the substance of the facts and opinions to which the expert witness is expected to testify; (c) State a summary of the grounds of each opinion. 27. Itemize and explain in detail any claim you made in this action for financial loss or damage which has not been explained in answer to questions above. 28. Fully describe each and every way in which you have been adversely affected by this accident, including but not limited to pain and suffering and the parts of your body affected thereby, loss of enjoyment of life, permanent injury, disfigurement or impairment, loss of mental faculties or capacity, impairment of earning capacity, and modification or cessation of activities. 29. Have you ever been charged with, convicted of, or plead guilty too crime?

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