Form 221

(e) The name(s) and address(es) of any person(s) having custody or copies of the statement(s).

(13) Did you create, use, or maintain any ‘‘electronic protected health information’’ (hereinafter ‘‘health

information’’), as defined in 45 C.F.R. § 160.103, during the treatment of the Plaintiff?

(14) If the answer to the previous interrogatory is in the affirmative, list the names and versions of

any and all electronic ‘‘information system(s)’’ (hereinafter ‘‘EMR system(s)’’), as defined in 45 C.F.R.

§ 164.304, that contain or previously contained the health information of the Plaintiff.

(15) Indicate whether you were accredited by the Joint Commission (formerly Joint Commission on

Accreditation of Healthcare Organizations (JCAHO)) during the time of the negligence alleged in

the Complaint.

(16) With respect to the negligence alleged in the Complaint, state whether you had any manuals,

directives, instructions, guidelines, and/or written or unwritten protocols related to specific allegations

of negligence in the Complaint that were in effect at the office, hospital, or other medical facility where

the defendant physician or health care provider practiced at the time of the negligence alleged in the

Complaint concerning:

(a) Care, treatment, monitoring, evaluation, diagnosis, consultation or referral to others, at the time

of the event(s) that is (are) the subject of this litigation;

(b) Training requirements and/or protocols for any physician or health care provider, including but

not limited to medical staff, caring for, evaluating, diagnosing, consulting or referring patients either in

the facility, department, or unit where the care, treatment, evaluation, diagnosis, consultation or referral

to others at issue took place; and

) that is (are) the subject of this litigation;

(b) Training requirements and/or protocols for any physician or health care provider, including but

not limited to medical staff, caring for, evaluating, diagnosing, consulting or referring patients either in

the facility, department, or unit where the care, treatment, evaluation, diagnosis, consultation or referral

to others at issue took place; and

(c) Reporting and/or investigation of adverse events at the facility, department, or unit where the

care, treatment, evaluation, diagnosis, consultation or referral to others at issue took place.

COMMENT:

There is no corresponding request for production to Interrogatory #16, but documents may be pursued by way of supplemental discovery.

(17) Identify surveillance material discoverable under Practice Book Section 13-3 (c), by stating the

name and address of any person who obtained or prepared any and all recordings, by film, photograph,

video, audio or any other digital or electronic means, of any party concerning this lawsuit or its subject

matter, including any transcript thereof which are in your possession or control or in the possession

or control of your attorney, and state the date on which each such recordings were obtained and the

person or persons of whom each such recording was made.

PLAINTIFF,

BY