Example Requests for Admission in Medical Negligence Claim

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
Civil Division

MIKE DOLMAN
Plaintiff,

v.

DAVID B. HARDING, MD
Defendant.

Case No. 34785718V

PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DAVID B. HENDERSON, MD

Now comes Mike Dolman, (hereinafter “Plaintiff”), by and through his attorneys, Rodney M. Gaston and Miller & Zois, LLC, and hereby requests that ALL DEFENDANTS submit responses to the below Request for Admission of Facts in a timely fashion and in accordance with the Maryland Rules of Civil Procedure.

More Information

Unless otherwise indicated, the below Request for Admissions of Fact pertain to the incident complained of in the Plaintiff’s Complaint, and in particular, the medical treatment that Mike Dolman received at the emergency room at St. Agnes Hospital in Baltimore City, Maryland on November 5, 2011.

Requests For Admission

REQUEST NO. 1: That defendant Cindy Jackson was employed by you on November 5, 2011.

REQUEST NO. 2: That defendant Cindy Jackson was working within the scope of his /her employment with you on November 5, 2011, at the St. Agnes Hospital Emergency Room.

REQUEST NO. 3: That defendant Cindy Jackson was working within the scope of his /her employment with you on November 5, 2011, and provided medical care to Mike Dolman on November 5, 2011, at the St. Agnes Hospital Emergency Room.

REQUEST NO. 4: That you were employed by Defendant St. Agnes Healthcare, Inc. on November 5, 2011.

REQUEST NO. 5: That you were employed by Defendant EmCare Physician Services Inc. on November 5, 2011.

REQUEST NO. 6: That you were employed by Defendant Maryland Provo-I Medical Services, P.C. on November 5, 2011.

REQUEST NO. 7: That you were employed by Defendant EmCare Inc. on November 5, 2011.

REQUEST NO. 8: That Defendant Cindy Jackson was employed by Defendant St. Agnes Healthcare, Inc. on November 5, 2011.

REQUEST NO. 9: That Defendant Cindy Jackson was employed by Defendant EmCare Physician Providers Inc. on November 5, 2011.

REQUEST NO. 10: That Defendant Cindy Jackson was employed by Defendant EmCare Physician Services Inc. on November 5, 2011.

REQUEST NO. 11: That Defendant Cindy Jackson was employed by Defendant EmCare Inc. on November 5, 2011.

REQUEST NO. 12: That Defendant David Wasserman was employed by Defendant St. Agnes Healthcare, Inc. on November 5, 2011.

REQUEST NO. 13: That Defendant David Wasserman was employed by Defendant EmCare Physician Providers Inc. on November 5, 2011.

REQUEST NO. 14: That Defendant David Wasserman was employed by Defendant EmCare Physician Services Inc. on November 5, 2011.

REQUEST NO. 15: That Defendant David Wasserman was employed by Defendant Maryland Provo-I Medical Services, P.C. St. Agnes Healthcare on November 5, 2011.

REQUEST NO. 16: That Defendant David Wasserman was employed by Defendant EmCare Inc. on November 5, 2011.

REQUEST NO. 17: That Defendant David Wasserman was employed by Defendant St. Agnes Healthcare, Inc. on November 5, 2011.

REQUEST NO. 18: That Defendant David Wasserman was employed by Defendant EmCare Physician Providers Inc. on November 5, 2011.

REQUEST NO. 19: That Defendant David Wasserman was employed by Defendant EmCare Physician Services Inc. on November 5, 2011.

REQUEST NO. 20: That Defendant David Wasserman was employed by Defendant Maryland Provo-I Medical Services, P.C. St. Agnes Healthcare on November 5, 2011.

REQUEST NO. 21: That Defendant C. Stelle, a.k.a. Caroline Stelle, was employed by Defendant EmCare Inc. on November 5, 2011.

REQUEST NO. 22: That Defendant C. Stelle, a.k.a. Caroline Stelle, was employed by Defendant St. Agnes Healthcare, Inc. on November 5, 2011.

REQUEST NO. 23: That Defendant C. Stelle, a.k.a. Caroline Stelle, was employed by Defendant EmCare Physician Providers Inc. on November 5, 2011.

REQUEST NO. 24: That Defendant C. Stelle, a.k.a. Caroline Stelle was employed by Defendant EmCare Physician Services Inc. on November 5, 2011.

REQUEST NO. 25: That Defendant C. Stelle, a.k.a. Caroline Stelle was employed by Defendant Maryland Provo-I Medical Services, P.C. on November 5, 2011.

REQUEST NO. 26: That Defendant C. Stelle, a.k.a. Caroline Stelle was employed by Defendant EmCare Inc. on November 5, 2011.

REQUEST NO. 27: That Defendant C. Stelle, a.k.a. Caroline Stelle provided discharge instructions to Mike Dolman on December 23, 2009 at St Agnes Hospital

REQUEST NO. 28: That Defendant Cindy Jackson did not review Mike Dolman’s medical chart on November 5, 2011.

REQUEST NO. 29: That Defendant Cindy Jackson was licensed to practice medicine in the State of Maryland on November 5, 2011.

REQUEST NO. 30: That Defendant David Wasserman was a licensed Physician’s Assistant on November 5, 2011.

REQUEST NO. 31: That Defendant C. Stelle a/k/a/ Caroline Stelle was a licensed registered nurse on November 5, 2011.

REQUEST NO. 32: That you provided medical care to Mike Dolman on November 5, 2011, at St. Agnes Hospital Emergency Room.

REQUEST NO. 33: That C. Stelle a.k.a Caroline Steele signed page 0007 of Exhibit 1 attached hereto.

REQUEST NO.34: That an employee of Defendant St. Agnes Health Care Inc. conducted a triage assessment of Mike Dolman on November 5, 2011, at St. Agnes Hospital Emergency Room.

REQUEST NO. 35: That an employee of Defendant St. Agnes Health Care Inc. read x-rays taken of Mike Dolman on November 5, 2011 while Mike Dolman was in St. Agnes Hospital Emergency Room.

REQUEST NO. 36: That Dae H. Bang, M.D. was an employee of Defendant St. Agnes Health Care Inc. on November 5, 2011.

REQUEST NO. 37: That Dae H. Bang, M.D. read x-rays taken of Mike Dolman on November 5, 2011, while Mike Dolman was in St. Agnes Hospital Emergency Room.

REQUEST NO. 38: That Defendant Cindy Jackson discussed the results of the x-rays taken of Mike Dolman with Dae H. Bang on November 5, 2011 before Mike Dolman was discharged.

REQUEST NO. 39: That after Dae H. Bang, M.D. read x-rays taken of Mike Dolman on November 5, 2011, while Mike Dolman was in St. Agnes Hospital Emergency Room; he prepared the radiology report attached hereto as page 3 of Exhibit 1.

REQUEST NO. 40: That page 3 of Exhibit 1 contains the interpretation of the x-rays taken of Mike Dolman reached by Dae H. Bang.

REQUEST NO. 41: That no medical provider at St. Agnes Hospital emergency room ordered a dopler study of Mike Dolman’s right knee and leg November 5, 2011.

REQUEST NO. 42: That no medical provider that examined Mike Dolman on November 5, 2011, at St. Agnes Hospital emergency room ordered any radiological study for the purpose of measuring/checking the flow of blood into Mike Dolman’s right leg.

REQUEST NO. 43: That Exhibit 1, attached hereto and incorporated by reference herein, are true and genuine medical records for patient Mike Dolman.

REQUEST NO. 44: That you have no evidence to suggest that That Exhibit 1, attached hereto and incorporated by reference herein, are not true and genuine medical records for patient Mike Dolman.

REQUEST NO. 45: That it was David Wasserman’s decision to discharge Mike Dolman from the emergency room at St. Agnes Hospital on November 5, 2011.

REQUEST NO. 46: That Defendant David Wasserman did not consult with Cindy Jackson before making the decision to discharge Mike Dolman from the emergency room on November 5, 2011.

REQUEST NO. 47: That David Wasserman spoke with Cindy Jackson on November 5, 2011, regarding Mike Dolman’s medical condition while Mike Dolman was in the emergency room.

REQUEST NO. 48: That by and through your employees, you provided medical care to Mike Dolman on November 5, 2011, at St. Agnes Hospital Emergency Room.

REQUEST NO. 49: That you had/have a written agreement with defendant St. Agnes Health Care, Inc. to provide physicians to staff the Hospital Emergency Room at St. Agnes Hospital for the date of November 5, 2011 .

REQUEST NO. 50: That you had/have a written agreement with defendant EmCare Physician services to provide physician to staff the Hospital Emergency Room at St. Agnes Hospital

REQUEST NO. 51: That Defendant Cindy Jackson signed pages 00011, 00012, 00013 and 00015 of Exhibit 1attached hereto on December 13, 2009.

REQUEST NO. 52: That Defendant Cindy Jackson did not actually read pages 00011, 00012, 00013, and 00015 of Exhibit 1 attached hereto until after Mike Dolman right St. Agnes Hospital Emergency room on December 3, 3009.

REQUEST NO. 53: That before Cindy Jackson signed pages 00011, 00012, 00013, and 00015 of Exhibit 1 he was aware that Mike Dolman had returned to St. Agnes emergency room for medical care after being discharged on November 5, 2011.

REQUEST NO. 54: That on November 5, 2011, no medical provider or defendant made the diagnoses that the blood flow to Kevin Toslon’s right lower extremity had been compromised in any way as a result of the trauma to his right knee and right leg.

REQUEST NO. 55: That on November 5, 2011, the blood flow to Kevin Toslon’s right lower extremity had been compromised due to the traumatic injury to Mike Dolman’s right knee and leg.

REQUEST NO. 56: That on November 5, 2011, Mike Dolman sustained a traumatic injury to his right knee.

REQUEST NO. 57: That no orthopedic surgeon examined Mike Dolman while he was St. Agnes Emergency Room on November 5, 2011.

REQUEST NO. 58: That no vascular surgeon examined Mike Dolman on November 5, 2011 while he was at St. Agnes Emergency Room.

REQUEST NO. 59: That Defendant David Wasserman did not request that an orthopedic surgeon examine Mike Dolman on November 5, 2011 while Mike Dolman was in the emergency room at St Agnes Hospital.

REQUEST NO. 60: That Defendant Cindy Jackson did not request that an orthopedic surgeon examine Mike Dolman on November 5, 2011, while Mike Dolman was in the emergency room at St. Agnes Hospital.

REQUEST NO. 61: That Defendant David Wasserman did not request that a vascular surgeon examine Mike Dolman on November 5, 2011 while Mike Dolman was in the emergency room at St. Agnes Hospital.

REQUEST NO. 62: That Defendant Cindy Jackson did not request that a vascular surgeon examine Mike Dolman on November 5, 2011 while Mike Dolman was in the emergency room at St. Agnes Hospital.

REQUEST NO. 63: That Cindy Jackson was Mike Dolman’s attending physician on November 5, 2011, while Mike Dolman was at St. Agnes Hospital emergency room.

REQUEST NO. 64: That Cindy Jackson was David Wasserman’s supervising physician on November 5, 2011, during the time that Mike Dolman was receiving medical care at St. Agnes Hospital emergency room.

REQUEST NO. 65: That Defendant David Wasserman provided medical care to Mike Dolman on November 5, 2011, in the emergency room of St. Agnes Hospital under the supervision of Cindy Jackson.

REQUEST NO. 66: That you are aware of the names of the medical providers who provided medical care and treatment to Mike Dolman in the emergency room at St. Agnes Hospital on November 5, 2011.

REQUEST NO. 67: That Dr. Donald K. Wilkerson was employed by Defendant Saint Agnes Health Care Inc. on November 10,2011.

REQUEST NO. 68: That Donald K. Wilkerson, M.D. was acting within the scope of his employment with Defendant St. Agnes Health care Inc. when he provided medical care to Mike Dolman on November 10,2011.

REQUEST NO. 69: That the medical care Mike Dolman received at St. Agnes Hospital from November 5, 2011 - January 1, 2013 was reasonable and necessary in light of his medical condition.

REQUEST NO. 70: That the medical care that Mike Dolman received at St. Agnes Hospital from November 5, 2011 – January 1, 2013 arose from a traumatic injury to Mike Dolman’s knee and leg that occurred on November 5, 2011.

REQUEST NO. 71: That Mike Dolman experienced conscious pain and suffering as a direct and proximate result of the amputation of his right leg.

REQUEST NO. 72: That had the injury to Mike Dolman’s popliteal artery in his right leg been discovered during the time he was in the emergency room at St. Agnes Hospital on November 5, 2011, more likely than not, he would not have underwent an amputation of his right leg below the knee.

REQUEST NO. 73: If the injury to Mike Dolman’s popliteal artery in his right leg been discovered during the time he was in the emergency room at St. Agnes Hospital on November 5, 2011, more likely than not, he would have underwent an amputation of his right leg above the knee.

REQUEST NO. 74: That Mike Dolman’s popliteal artery in his right leg/knee was damaged as a result of the injury he sustained to his right knee and leg on November 5, 2011.

REQUEST NO. 75: That Kevin Toslon had a decrease in the flow of blood into his right lower extremity while he was in the emergency room at St. Agnes Hospital on November 5, 2011.

REQUEST NO. 76: That you have no independent recollection of providing medical care and treatment to Mike Dolman on November 5, 2011.

REQUEST NO. 77: That Defendant David Wasserman could have ordered a test to measure the flow of blood in Kevin Toslon’s right leg while he was in the emergency room at St. Agnes Hospital on November 5, 2011, if he/she believed the test was medically necessary.

REQUEST NO. 78: That Defendant David Wasserman could have ordered an arteriogram to measure the flow of blood in Kevin Toslon’s right leg while he was in the emergency room at St Agnes Hospital on November 5, 2011, if he/she believed the test was medically necessary.

REQUEST NO. 79: That Defendant Cindy Jackson could have ordered a test to measure the flow of blood in Kevin Toslon’s right leg while he was in the emergency room at St. Agnes Hospital on November 5, 2011, if he/she believed the test was medically necessary.

REQUEST NO. 80: That Defendant Cindy Jackson could have ordered an arteriogram to measure the flow of blood in Kevin Toslon’s right leg while he was in the emergency room at St. Agnes Hospital on November 5, 2011, if he/she believed the test was medically necessary.

REQUEST NO. 81: That Defendant David Wasserman is not qualified to interpret the x-rays taken of Mike Dolman on November 5, 2011 while he was in the emergency room at St. Agnes Hospital.

REQUEST NO. 82: That Defendant Prudence Jasckson is not qualified to interpret the x-rays taken of Mike Dolman on November 5, 2011 while he was in the emergency room at St. Agnes Hospital.

REQUEST NO. 83: That David Wasserman approved the discharge of Mike Dolman from the emergency room at St. Agnes Hospital on November 5, 2011.

REQUEST NO. 84: That Defendant Cindy Jackson approved the discharge of Mike Dolman from the emergency room at St. Agnes Hospital on November 5, 2011.

REQUEST NO. 85: That you cannot remember whether or not Mike Dolman told you his right foot was cold on November 5, 2011, while he was in the emergency room at St. Agnes Hospital.

REQUEST NO. 86: That you cannot remember whether or not Mike Dolman told you he could not move the toes in his right foot on November 5, 2011, while he was in the emergency room at St. Agnes Hospital.

REQUEST NO. 87: You are unable to recall any conversation on November 5, 2011 with any person who accompanied Mike Dolman to the emergency room.

REQUEST NO. 88: That you personally touched Mike Dolman’s right foot while he was in the emergency room on November 5, 2011.

REQUEST NO. 89: That Mike Dolman should not have been discharged from the emergency room on November 5, 2011, if his foot was cold to the touch at the time of his discharge.

REQUEST NO. 90: You have no independent recollection if Mike Dolman’s right foot was cold to the cough when he was discharged from the emergency room on November 5, 2011.

REQUEST NO. 91: That on November 5, 2011, at the emergency room at St. Agnes Hospital, you had available to you the medical equipment necessary to conduct an evaluation of Mike Dolman’s right leg knee and leg to determine if the structures, veins, and arteries, inside of his leg were damaged.

REQUEST NO. 92: An MRI can be used to detect damage to the ligaments inside a patient’s leg and knee.

REQUEST NO. 93: A dopler study can be used to measure the flow of bold inside a patient’s leg.

REQUEST NO. 94: A decrease in the flow of blood in a patient’s leg can be one indication of a damaged artery.

REQUEST NO. 95: That the Plaintiff has complied with all Maryland statutory pre-conditions to filing this action in the Circuit Court for Baltimore City.

REQUEST NO. 96: That there is no evidence that the Plaintiff’s action bar is barred by any statute of limitations.

REQUEST NO. 97: That there is no evidence that the Plaintiff assumed the risk of the loss of his right leg.

REQUEST NO. 98: That there is no evidence that the Plaintiff was contributorily negligent with respect to the loss of his right leg.

REQUEST NO. 99: That due to the loss of the Plaintiff’s leg he is unable to work more than 40 hours per week.

REQUEST NO. 100: That there is no evidence that the certificate of merits attached to the Plaintiff’s Complaint fail to meet the applicable Maryland statutory requirements for medical malpractice cases.

REQUEST NO. 101: That there is no evidence that the expert reports attached to the Plaintiff’s Complaint fail to meet the applicable Maryland statutory requirements for medical malpractice cases.

REQUEST NO. 102: That you are subject to the jurisdiction of the Circuit Court for Baltimore City Maryland for the incident at bar.

REQUEST NO. 103: That there is no material difference in the standard of medical care applicable to emergency room physicians, nurses, and physician assistants, at St. Agnes Hospital and those emergency room physicians, nurses, and physician assistants who work at Hospital emergency room in the State of Virginia.

REQUEST NO. 104: That there is no material difference in the standard of medical care applicable to emergency room physicians, nurses, and physician assistants, at St. Agnes Hospital and those emergency room physicians, nurses, and physician assistants who work at Hospital emergency rooms in the State of Wisconsin.

REQUEST NO. 105: That there is no material difference in the standard of medical care applicable to emergency room physicians, nurses, and physician assistants, at St. Agnes Hospital and those emergency room physicians, nurses, and physician assistants who work at Hospital emergency rooms in the State of Tennessee.

REQUEST NO. 106: That there is no material difference in the standard of medical care applicable to emergency room physicians, nurses, and physician assistants, at St. Agnes Hospital and those emergency room physicians, nurses, and physician assistants who work at Hospital emergency rooms in Pennsylvania or Florida.

REQUEST NO. 107: You never spoke to Mike Dolman after he was discharged from the emergency room at St. Agnes Hospital on November 5, 2011.

REQUEST NO. 108: That Donald Davis, M.D. was employed by you and working within the scope his employment with you when he operated on Mike Dolman.

REQUEST NO. 109: That the medical care Donald Davis, M.D. provided to Mike Dolman at St. Agnes Hospital ) was reasonable and necessary.

REQUEST NO. 110: That when Mike Dolman returned to St. Agnes Hospital on December 6, 2009, that it was too late to save his right leg from being amputated below the knee.

REQUEST NO. 111: That after Mike Dolman right St. Agnes emergency room on November 5, 2011, and before he returned to St. Agnes emergency room on November 10, 2011, he sustained irreversible physical damage to his right leg.

REQUEST NO. 112: That Mike Dolman will require the use of a prosthetic device on his right leg for the rest of his life.

REQUEST NO. 113: That the medical care Mike Dolman received at University of Maryland Hospital for the injury to his right leg and knee ,which included the amputation of his right leg above his knee, was fair, reasonable, and necessary.

REQUEST NO. 114: That the costs of the medical care that Mike Dolman received at University of Maryland Hospital for the injury to his right leg and knee, which included the amputation of his right leg above his knee, were fair and customary.

REQUEST NO. 115: That you have no evidence that that the medical care Mike Dolman received at University of Maryland Hospital for the injury to his right leg and knee, which included the amputation of his right leg above his knee, was unreasonable, or unnecessary.

REQUEST NO. 116: That you have no evidence that the costs for the medical care that Mike Dolman received at University of Maryland Hospital for the injury to his right leg and knee, which included the amputation of his right leg above his knee, were excessive.

REQUEST NO. 117: That C. Steele a.k.a. Caroline Stone initialed pages 0004, 0005, and 0007 of Exhibit 1 attached hereto.

REQUEST NO. 118: That C. Steele a.k.a. Caroline Stone signed page 00028 of exhibit 1attached hereto.

Respectfully submitted,
MILLER & ZOIS, LLC

Ronald V. Miller, Jr.
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
(410)760-8922 (Fax)
Attorney for the Plaintiff

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