Pursuant to Rule 34 of the North Carolina Rules of Civil Procedure, plaintiffs request that the defendant ______________________. ("______________") produce, for inspection and copying, the following documents which are in the possession, custody or control of defendant within forty-five (45) days of the service of this request at the offices of Bentley Law Offices, P.A., 400 West Main Street, Suite 501, Durham, North Carolina, at 10:00 o'clock, a.m. or at a time and place agreeable to the parties.


         1.      Please produce all documents pertaining to __________'s efforts to obtain accreditation from, and to remove contingencies created by, the Joint Commission on Accreditation of Healthcare Organizations from January 1, 1998, through the date of your response to this request, including, but not limited to, applications, attachments, correspondence, reports, findings, and documents relating to site visits and surveys. If such documents are not in your possession, state the name, address, and title of the persons or entities whom you believe have custody of such documents.
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         2.      All nursing staff guidelines, all personnel policies, all policy and procedure manuals. 
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         3.       All documents regarding orientation of nurses. 
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         4.      All statements obtained by you, whether written, typewritten, tape-recorded, transcribed from a tape recording or by stenographic means, or in any other form, or anyone acting on your behalf, in connection with the matters complained of in this action.
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         5.     All reports prepared by any and all expert witnesses you expect to call to testify at the trial of this action. 
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         6.      Any and all documents, including, but not limited to, medical records, in which the _____________ is mentioned or discussed in any way or which relate in any way to _________________'s medical and/or nursing care or treatment from __________ from January, 2000 through the present. 
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        7.       All physicians' orders regarding the care to be provided to ____________ at any time. 
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         8.        All nursing plans, assessments and notes regarding care provided to ____________. 
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         9.        Any and all documents regarding any investigation made by you or on your behalf regarding ____________and ____________'s medical and/or nursing care and treatment from __________ from January, 2000 through the present. 
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         10.      Any and all reports or notices concerning any of the occurrences complained of in this action given to any person or organization including, but not limited to, insurance companies or agents of any insurance company. 
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         11.    Any and all documents in connection with all lawsuits, other than the instant action, in which __________ was or is a party. 
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         12.      All written memoranda and minutes made of any meetings or other discussions held by any organization at which the occurrences complained of in this action were discussed. 
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         13.       All progress notes, reports, x-ray reports, correspondence, x-ray requisition forms, appointment records, computer disks, notes and records of telephone conversations and other records and documents relating to the care, treatment, and diagnosis of ____________ from January, 2000 through July, 2000 from __________ other than those previously requested. 
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         14.      Applications for employment and all other related documents, regarding the application for employment by __________ of __________ 
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         15.      All documents submitted and/or obtained by __________ in connection with the application for employment of __________.
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         16.      Complete copies of all documents in __________'s personnel file.
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         17.      All documents and records pertaining to the supervision of __________.
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         18.      A copy of the nursing license(s) of __________. 
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         19.       Please produce a copy of all applications, attachments and documents submitted by __________ to the North Carolina Department of Human Resources Division of Facility Services and to any other state and federal agencies or departments for the purposes of licensure, licensure renewal, and health care financing during the period from January 1, 1998, through the date of your response to this request.
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         20.       Please produce all medical, nursing and billing records, documents and correspondence relating to such records and statements of account, including the results of all diagnostic studies, concerning the plaintiff _______________. 
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         21.      All documents identified in or relied upon by you in your responses to Plaintiffs' First Set of Interrogatories to Defendant __________, Inc. 
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         22.     Please produce copies of all insurance policies under which __________ and/or any of its employees, agents, or officers, is or may be insured for liability with respect to the care and/or treatment of ____________. 
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         23.     Please produce copies of all Articles of Incorporation, Amendments, and By-Laws of __________ that have been in effect during 1998 through the date of your response to this request. 
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         This the __________ day of _________________, 2003.