Free Answering Brief in Opposition - District Court of Delaware - Delaware

. Case 1 :04-cv-01540-Gl\/IS Document 60-2 Filed OQ/13/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
GLADYS BAILEY, as the Administratrix :
ofthe Estate of DEBBIE BAILEY, deceased, 1
and DOMINICK BAILEY, DEMETRIA BAILEY, 2 C.A. No.04—l540
Individually and as guardian for AMBER 1
BAILEY, a minor, and TIA BAILEY :
Plaintiffs TRIAL BY JURY
: DEMANDED
v. :
RONALD I. LEBMAN, MD.
and :
PAUL EMERY, MD. :
c/o KENT GENERAL HOSPITAL :
and 1
DELMARVA EMERGENCY PHYSICIANS, LLP :
c/o THE CORPORATION TRUST COMPANY :
and 1
BAYHEALTH MEDICAL CENTER, INC. :
d.»'b.»’a KENT GENERAL HOSPITAL
PLAINTIFFS’ ANSWERS TO DEFENDANT BAYHEALTH MEDICAL CENTER, INC’S
REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTI FFS
I . All documents referred to, or identified in, plaintiffs answers to interrogatories.
ANSWER(S) See attached medical records, autopsy report and death certificate.
2. Copies of all bills and receipts evidencing payment of bills for which plaintiffs seek
compensation in this lawsuit.
ANSWER(S) None as ofthis date. Plaintiff will supplement.
3. Copies of all doctors' reports, hospital reports and any other records reflecting health care
services received by the decedent, Debbie Bailey, from January 1, l995 through the time
of her death.
ANSWER(S) See attached medical records

I it Case 1 :04-cv-01540-GIVIS Document 60-2 Fl|ecl._;@{13/2005 Page 2 of 2
4. Copies of all health care records reflecting any health care services received by any
named plaintiff subsequent to the death of the decedent as a result other death.
ANSWER(S) See attached medical records
5. lf-you claim any loss of income, loss of earning capacity or loss of future income as a
result of the death of the decedent, please produce her federal and state income tax retums
for the years 1998 through 2002.
ANSWER(S) Plaintiff is claiming past and future loss of earnings. Plaintiff will
supplement this request.
6. Copies of all photographs, diagrams, radiology films and any other pictorial
representation ofany matter in issue in this lawsuit.
ANSWER(S) None as oftliis date.
7. Copies of all documents filed with the Register of Wills in connection with the probate of
the estate of the decedent, including the inventory and any accountings.
Al\lSWER(S) Plaintiff will supplement upon receipt.
Si Copies ofall documents and materials submitted to any person to review as a potential
expert witness in connection with the claims asserted in this lawsuit.
ANSWER(S): Expert witnesses are undetermined at this time. Plaintiff will identify
expert witnesses in accordance with Pa. R.C.P. once determined.
KLINE PECTER, P.C.
. BY· . ________
Ci HUA VAN NAARDEN
A torney for Plaintiffs