Form 209. Defendant’s Supplemental Requests for Production—

Defendant’s Supplemental Requests for Production—

Workers’ Compensation Benefits—No Intervening Plaintiff

No. CV-

: SUPERIOR COURT

(Plaintiff)

: JUDICIAL DISTRICT OF

VS.

: AT

(Defendant)

: (Date)

The Defendant(s) hereby request(s) that the Plaintiff provide counsel for the Defendant(s) with

copies of the documents described in the following requests for production, or afford counsel for said

Defendant(s) the opportunity or, where requested, sufficient written authorization, to inspect, copy,

photograph or otherwise reproduce said documents. The production of such documents, copies or

written authorizations shall take place at the offices of

not later than sixty (60) days

after the service of the Requests for Production.

In answering these production requests, the Plaintiff(s) are required to provide all information within

their possession, custody or control. If any production request cannot be answered in full, answer to

the extent possible.

(1) Produce a copy of the First Report of Injury (Form FRI), Notice of Claim for Compensation (Form

30C), Notice of Intention to Reduce or Discontinue Benefits (Form 36), and Notice to Administrative

Law Judge and Employee of Intention to Contest Employee’s Right to Compensation Benefits (Form 43).

(2) Produce a copy of all of the approved voluntary agreements, approved stipulations to date,

approved full and final stipulations, findings and awards, and findings and denials that relate to one

or more of the claims referenced in your answer to Interrogatory #2 on Form 208.

(3) Produce a copy of all reports of medical exams requested by the administrative law judge,

respondent and/or employer that were prepared concerning any of the claims referenced in your answer

to Interrogatory #2 on Form 208.

ll and final stipulations, findings and awards, and findings and denials that relate to one

or more of the claims referenced in your answer to Interrogatory #2 on Form 208.

(3) Produce a copy of all reports of medical exams requested by the administrative law judge,

respondent and/or employer that were prepared concerning any of the claims referenced in your answer

to Interrogatory #2 on Form 208.

(4) If you are unable to specify the amount of medical benefits, loss of income benefits, and specific

award benefits paid on your behalf, provide an authorization for the same.

COMMENT:

These supplemental requests for production are specifically directed at eliciting information about any workers’ compensation

claims, benefits and agreements. Unless the compensation carrier is a party to the action, it can be difficult to obtain this

information. Often the Plaintiff’s lawyers do not represent the client in the workers’ compensation case, and although this

information is available in the workers’ compensation file, providing these records to lawyers not involved in the compensation

case could be time-consuming for the workers’ compensation office staff. If compensation benefits were paid, these supplemental

requests for production may be served on the Plaintiff without leave of the court if there is no Intervening Plaintiff in the action.

DEFENDANT,

BY

CERTIFICATION

I certify that a copy of this document was or will immediately be mailed or delivered electronically

or non-electronically on (date)

to all attorneys and self-represented parties of record and that

written consent for electronic delivery was received from all attorneys exempt from e-filing and self-represented parties of record who received or will immediately be receiving electronic delivery.