INTERROGATORIES Good Examples

[Rage]

https://www.millerandzois.com/interroga ... tions.html


List of Sample Objections
interrogatoriesSometimes, it is hard to come up with the exact words of why you want to object or to match the feeling that the request is objectionable with the appropriate law. So here are some sample interrogatory objections, a cheat sheet that might help you determine how to object to interrogatories (that can also be applied to other discovery objections):

Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. [This is a classic general objection you should use sparingly. Boilerplate objections do not go over well with judges.]

Plaintiff objects to this interrogatory because it calls for the plaintiff to make a legal conclusion. [Don't go crazy with this one either. “An interrogatory is not objectionable merely because it asks for an opinion or contention that relates to fact or the application of law to fact, but the court may order that the interrogatory need not be answered until designated discovery is complete, or until a pretrial conference or some other time.” Fed. R. Civ. P. 33(a)(2).]

Plaintiff objects because this interrogatory calls for pure conjecture and speculation. It is not the job of the plaintiff to guess what would have happened in an alternative universe.

Plaintiff objects to this interrogatory because this interrogatory is so broad, uncertain, and unintelligible that the plaintiff cannot determine the nature of the information sought. Therefore, the plaintiff cannot provide an answer.

Plaintiff objects to this interrogatory because this interrogatory calls for privileged information within the attorney-client privilege that it seeks information that is in the attorney's work product.

Plaintiff objects because the identification, photocopying, and production of the requested documents would be oppressively burdensome and costly. The information or documents will be made available for review at their storage location during business hours at a mutually convenient time. Alternatively, upon request the plaintiff will provide the defendant with an estimate of what it would cost to procure and produce these documents and the parties can agree on the cost of such a production. (This is usually a defendant's objection, actually. Federal Rule 26(g), requires parties to consider discovery burdens and benefits before requesting discovery or responding or objecting to discovery requests and to certify that their discovery requests, responses, and objections meet the rule requirements.)

Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the plaintiff.

Plaintiff objects because the answer to this question may violate the defendant's protection against self-incrimination. (Boy, you are behind the 8-ball if this is your answer but we have made this response before.)

Plaintiff objects to the entirety of this request because it is not reasonably calculated to lead to admissible evidence. Instead, it was filed for the purpose of harassing, oppressing, embarrassing and annoying a woman who everyone agrees is a victim by seeking discovery of matters that have zero relevance to this lawsuit. [Let's concede this is probably a little much.]

Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.

Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial. [But the evidence marshaling objection will only get you so far.]

Plaintiff objects to this interrogatory because the only possible purpose of this request is to harass and cause hardship to the plaintiff and needlessly increase the cost of litigation to the plaintiff or her counsel.

Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.

Plaintiff objects to this interrogatory because the defendant had exceeded the number of interrogatories allowed by Maryland law.

Plaintiff objects because this request calls for the disclosure of attorney work product prepared in anticipation of litigation or for trial. Moreover, the defendant has failed to demonstrate a substantial need and the substantial equivalent of which the defendant would be unable to obtain by other means without due hardship.

Plaintiff objects to this interrogatory because it contains a compound, conjunctive, or disjunctive questions. [Heads up for defense lawyers using compound interrogatories to end-run limits on the number of interrogatories.]

Plaintiff objects to this question as premature. She has not fully completed discovery and has not completed trial preparation. Further discovery, legal research, and analysis may supply additional information. So the responding party reserves the right to supplement these responses at trial. [This gives you some cover with the jury if you change an interrogatory answer. Some judges will require the party reading the answer to the jury to also read the objections.]

Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence. Instead, it was filed for the purpose of harassing.

[Rage]

BAM!

STATE OF NEW MEXICO
COUNTY OF CHAVEZ
FIFTH JUDICIAL DISTRICT COURT

CHASE XANDER,

Plaintiff,

v. Cause No. D-504-CV-202300223
Judge: James M. Hudson
AMERICAN MEDICAL RESPONSE MEDICAL
SERVICE INC. and EASTERN NEW MEXICO
MEDICAL CENTER, INC.

Defendants.


DEFENDANT AMERICAN MEDICAL RESPONSE MEDICAL SERVICE INC’S
FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION
TO PLAINTIFF CHASE XANDER

TO: Chase Xander
Pro Se




Pursuant to the New Mexico Rules of Civil Procedure, Defendant American Medical Response Medical Service Inc., (hereafter "Defendant AMR") hereby requests that Plaintiff Chase Xander answer the following Interrogatories fully, in writing, under oath, and from all knowledge obtainable from any and all sources available to Plaintiff within thirty (30) days after the service hereof:

INTERROGATORIES
INTERROGATORY NO. 1: Please state the name and address of each person answering these Interrogatories. As to each person giving assistance, please state the numbers of the Interrogatories for which he or she provided assistance.
ANSWER: Chase Xander,

INTERROGATORY NO. 2: Please identify all documents, resources, or other sources of information upon which the individuals identified in response to Interrogatory No. 1 have relied in preparing the answers hereto.
ANSWER: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

INTERROGATORY NO. 3: Pease state full name, any other names/alias used or by which you have been known, Social Security number, date/place of birth, marital status, name(s) of spouse(s), current address, current phone number, cell phone number and carrier at the time of the subject incident, and the name(s), addresses, and ages of children, if any.
ANSWER: Plaintiff objects to the entirety of this request because it is not reasonably calculated to lead to admissible evidence

INTERROGATORY NO. 4: Please list all addresses at which you have resided from 2013 to present, including dates at each address and the names and relationships of all persons who have lived with you at each address.
ANSWER: Plaintiff objects to the entirety of this request because it is not reasonably calculated to lead to admissible evidence

INTERROGATORY NO. 5: Please list all jobs you have held, including current employment, if any, and all employment in the past ten years (including but not limited to self-employment), listing for each the name and address of the employer, dates of hire and termination, job title and duties, rate of pay, supervisor and reason for leaving each position and/or employment.
ANSWER: Plaintiff objects to the entirety of this request because it is not reasonably calculated to lead to admissible evidence

INTERROGATORY NO. 6: Please describe all lawsuits to which you have been a party, including but not limited to disability, worker’s compensation, private civil lawsuits, criminal proceedings, divorce and bankruptcies, including the names of the parties, type of matter, jurisdiction in which each was filed, date of filing, outcome of each proceeding and the names and addresses of all legal counsel for any party.
ANSWER: Plaintiff objects to the entirety of this request because it is not reasonably calculated to lead to admissible evidence
INTERROGATORY NO. 7: Have you ever been (a) arrested; or (b) convicted of a crime punishable by imprisonment in excess of one year, or a crime involving dishonesty or false statement, regardless of the punishment? If your answer is “yes”, list for each such arrest or conviction:
a. The date of arrest/ conviction;
b. The Court/jurisdiction where such arrest/conviction occurred or was entered;
c. The punishment imposed; and
d. The nature of the crime and/or the reason for the arrest.

ANSWER: NO
INTERROGATORY NO. 8: Please state the name, current address and telephone number of all physicians and other healthcare providers (including but not limited to physician offices, hospitals, clinics, emergency facilities, urgent care centers, detoxification facilities, rehabilitation facilities, or other mental or physical healthcare facilities) at which or by whom you have been seen or admitted from 2013 to present. For each provider listed, include reasons for all such consultations and/or admissions and the date of each visit or admission.
ANSWER: Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence.
INTERROGATORY NO. 9: Please give the name, current address and telephone number of all pharmacies where you have had your prescriptions filled from January 2013 to present.
ANSWER: Walgreens South, 1200 S MAIN ST Roswell, NM 88203, 575-624-1439
INTERROGATORY NO. 10: Please state whether at the time of the incidents described in the Complaint, you were suffering from any preexisting physical and/or mental/emotional illness or disability and, if so, describe in detail the time period during which you suffered any such disability or illness, the nature and extent of each such illness or disability, and list the names and current addresses of each healthcare provider who examined or treated you for such illness or disability.
ANSWER: Yes, those are medical questions I am not able to answer, can only be answered by my doctors, and after defendants AMR already filed a medical record of mine I have no intentions of signing releases any time soon.
INTERROGATORY NO. 11: If you are claiming that you required psychological / mental health treatment or counseling of any kind as a result of the subject incidents, please state the name, address and telephone number of any and all physicians, counselors, psychiatrists, psychologists, clergy, therapists and/or outpatient healthcare or mental health facilities in which you received such care and treatment from the date of the first incident to present. Please include the dates of such emotional and/or mental health care and/or treatment and the reason(s) why such care or treatment was needed.
ANSWER: Bill Williams, Azurite Services PC, 613 W 2nd St, Suite 1 Roswell NM 88201, Anxiety, panic attacks, nightmares, symptoms of PTSD, humiliation, fear, inablity to get emergency medical service. Dr Bulumbo, 613 W 2nd St #5, Roswell, NM 88201, (575) 425-6047, Anxiety, panic attacks, nightmares, symptoms of PTSD, humiliation, fear, inablity to get emergency medical service.
INTERROGATORY NO. 12: Please list the name, current address, and telephone number of each person known to you or your counsel who may have knowledge, evidence, or documents in their possession, custody, or control which are relevant to any of the issues involved in this action, and for each person, describe the nature and content of the knowledge possessed and/or the evidence or documentation in his/her possession, custody or control.
ANSWER: Bill Williams, Azurite Services PC, 613 W 2nd St, Suite 1 Roswell NM 88201, has medical records regarding my mental health during this time. Dr Bulumbo, 613 W 2nd St #5, Roswell, NM 88201, (575) 425-6047, has medical records regarding my mental health during this time. Lovelace Regional Hospital 117 E 19th St · (575) 627-7000 has medical records regarding my physical and mental health. ENMMC 405 Country Club Rd · (575) 624-8766 has medical records regarding my physical and mental health.

INTERROGATORY NO. 13: Have you, during the time of the incident in question up until the current date, had accounts on any social media sites, dating sites, blogs, or apps, including, but not limited to, Facebook, Facebook Messenger, Snapchat, Pinterest, Instagram, Twitter, Linkedin, Google+, Classmates, Meetme, Tumbler, Match, YouTube, Reddit, Flickr, Foursquare, Swarm, Pheed, eHarmony, PlentyOfFish, Zoosk, OK Cupid, ChristianMingle, DateHookup, Chemistry, SpeedDate, Spark, Tinder, Blendr, Farmers Only, Kik, Whisper, Ask.fm, Skout, Playstation Network, X-Box Live, or Myspace. If so, please provide the name of each site or app, and your screen name(s) or account name(s) for each. Further, you are advised to not delete or remove any information from any social media site, dating site, or app during the pendency of this litigation. If you have already made such deletions, please provide the substance of each part deleted and date of deletion.
ANSWER: Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence.
INTERROGATORY NO. 14: Please list the name and current address of each expert witness that you or your counsel will or may call at the trial of this action, and as to each expert, please specify:
a. The subject matter on which the expert is expected to testify;
b. The substance of the facts to which the expert is expected to testify;
c. All opinions to which the expert is expected to testify;
d. A summary of the grounds for each opinion;
e. A list of all publications authored by the witness within the preceding ten (10) years;
f. Identification of all documents, facts or data that were provided to the expert and that the expert considered in forming opinions to be expressed in this case;
g. All assumptions that were provided to the expert and that the expert relied upon in forming opinions to be expressed in this case; and
h. A listing of all other cases in which the witness has testified as an expert at trial or by deposition within the preceding four (4) years.

ANSWER: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

INTERROGATORY NO. 15: Please identify and describe all information furnished to, or otherwise compiled, generated, reviewed, or relied upon by each such expert in the formation of his/her opinions herein.
ANSWER: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

INTERROGATORY NO. 16: Please identify any treating provider of Plaintiff that she intends to call as a witness at the trial of this matter. For each treating provider identified, please state the following:
a. The substance of all communications the Plaintiff, Plaintiff’s counsel, or anyone on behalf of Plaintiff has had with the treating provider, including the dates of communications;
b. The subject matter on which each such treating provider is expected to present evidence or testimony;
c. A summary of the facts and opinions to which each such treating provider is expected to testify;
d. The compensation to be paid to each such treating provider, if any, for review or testimony; and
e. Identification of all documents, facts or data that were provided to each such treating provider; and
f. Whether each such treating provider will give opinions on causation and, if so, a summary of those opinions.

ANSWER: Bill Williams, Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial. Azurite Services PC, 613 W 2nd St, Suite 1 Roswell NM 88201

INTERROGATORY NO. 17: Please list the name and current address of each lay witness that you will or may call at the trial of this action, and as to each witness, please state the nature of each witness' testimony, the witness’ relationship to you, and the issues about which each witness will testify.
ANSWER: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

INTERROGATORY NO. 18: Please list and describe adequately for identification all exhibits which you will or may use at the trial of this action.
ANSWER: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

INTERROGATORY NO. 19: Please identify all medical literature upon which you or your experts intend to refer at depositions or the trial of this matter.
ANSWER: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession
INTERROGATORY NO. 20: Please identify all medical charges (whether it be for services, equipment or medications), you contend were generated as a result of Defendants’ alleged negligence. For each charge, please state the following:
a. The amount of the charge;
b. The individual or entity who generated the charge;
c. The date on which the charge was generated;
d. The purpose of the charge;
e. The amounts of the charges that have been paid;
f. The identity of all third parties who have paid any of the charges along with the dates and amount of charges paid;
g. The amount of charges that were written off or adjusted by your healthcare providers;
h. The holder and the current amount of any liens asserted by any person or entity;
i. The basis for your allegations that but for Defendants’ alleged negligence, you would not have required the charge.

ANSWER: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession
INTERROGATORY NO. 21: Please state whether or not any of your special damages have been paid or reimbursed, or are subject to payment or reimbursement, by yourself, an employer, insurance company or governmental agency (including Medicare and/or Medicaid). If so, please state:
a Name and address of all such companies, agencies or employers;
b The reason for the payment or reimbursement;
c The amount paid or subject to reimbursement;
d Whether a lien exists and the amount of the lien.

ANSWER: MEDICAID
INTERROGATORY NO. 22: Please state whether or not you are claiming any loss of earnings or earning capacity as a result of the incident and injuries alleged in your Complaint. If so, please state:
a) The amount and manner of computation;
b) The period for which loss is claimed;
c) The name and address of the employer or business involved;
d) The name, address and telephone number of the person who presently has possession or custody of any records or documents in support of your claim for lost wages or earning capacity.

ANSWER: NO EARNINGS LOST
INTERROGATORY NO. 23: Do you contend that you will need future medical and/or mental health treatment as a result of the alleged negligence, harassment, battery and/or discrimination of Defendant(s)? If so, please identify all future treatment and associated costs of same. Please also identify every witness you contend will support your claim for future medical and/or mental health treatment.
ANSWER: Mental Health Treatment, Bill Williams, Azurite Services PC, 613 W 2nd St, Suite 1 Roswell NM 88201, Dr Bulumbo, 613 W 2nd St #5, Roswell, NM 88201, (575) 425-6047,
INTERROGATORY NO. 24: Please state whether you have applied for short or long term disability benefits at any time during your life. If so, please provide the date of application, the name, address and telephone number of the facility where you applied for said benefits, the reason for the application, and whether disability benefits were received.
ANSWER: YES 1991
INTERROGATORY NO. 25: Have you entered into any settlement agreement with any individual or entity with respect to claims arising out of the incident described in your Complaint? If your answer is "yes," please state the details of the settlement agreement as well as the policy limits of any applicable insurance policy.
ANSWER: NO

INTERROGATORY NO. 26: Have you or has any person, firm, business or entity retained by you or your counsel obtained any statement from any person, oral, written or recorded, regarding any of the facts surrounding the incident? If so, identify each such statement obtained by stating the name and address of the person giving the statement; the name, address and present position or relationship to you, of the person taking the statement; the date of the statement; the circumstances under which the statement was obtained; the substance of the statement; and the identity of the person presently having custody or a copy of the statement, if written or recorded, or knowledge with regard to any oral statement.
ANSWER: NO


REQUESTS FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 1: Please produce copies of all documents or pleadings pertaining in any way to any arrests or criminal convictions, other civil or criminal lawsuit, bankruptcy, divorce and/or other legal or administrative proceeding (including Worker’s Compensation) in which you have been involved as a party.
RESPONSE: Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence.
REQUEST FOR PRODUCTION NO. 2: Please produce copies of all medical and/or mental health records and reports from each healthcare or counseling-type provider who has examined or treated you during the time period 2013 to the present.
RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.
REQUEST FOR PRODUCTION NO. 3: Please produce all correspondence between you, or anyone on your behalf, and your healthcare providers during the time period 2013 to the present.
RESPONSE: Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence.
REQUEST FOR PRODUCTION NO. 4: For all prescription and over-the-counter medications you are currently taking, please produce copies of labels and package inserts (if any) for all such medications.
RESPONSE: Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence.
REQUEST FOR PRODUCTION NO. 5: Please sign and produce the attached forms authorizing counsel for Defendants to obtain medical records and mental health records and written information from your healthcare providers for the time period 2013 to the present.
RESPONSE: Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. And defendants AMR have already filed a medical record of mine a serious violation of HIIPA one I intend to sue for.
REQUEST FOR PRODUCTION NO. 6: Please produce copies of any written or recorded reports, interviews, opinions or correspondence of any lay or expert witness which pertains in any way to events related to the incident which is the subject of this lawsuit.
RESPONSE: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.
REQUEST FOR PRODUCTION NO. 7: Please produce a color copy of any medical or psychiatric records related to or concerning you in the possession or under the control of you or your counsel.
RESPONSE: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.
REQUEST FOR PRODUCTION NO. 8: Please produce copies of all bills, expenses, or other documentation pertaining to any damages you allege are a result of the incidents described in Plaintiff’s Complaint. Each bill or statement should reflect total amount charged, total amount paid, and total amount adjusted/written off.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.
REQUEST FOR PRODUCTION NO. 9: If Medicare provided payment to any medical providers, physicians, or suppliers of medical equipment or medications for any treatment at issue in this matter, please produce the Medicare Summary Notices memorializing those payments by Medicare.
RESPONSE: NO MEDICARE

REQUEST FOR PRODUCTION NO. 10: Please produce a copy of all correspondence between you, or anyone on your behalf, and the Centers for Medicare and Medicaid Services relating to the reporting of the claim at issue in this case.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.

REQUEST FOR PRODUCTION NO. 11: Please produce a copy of all notices of Medicare liens and/or documents pertaining to any other liens, rights of reimbursement, or rights of subrogation against any recovery that you may have regarding the claims at issue in this matter.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.

REQUEST FOR PRODUCTION NO. 12: If you received medical assistance, including but not limited to Medicaid, SCHIP, CHIP, and/or any county indigent fund, relative to the treatment at issue in this matter, please produce a copy of all communications in this regard.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.

REQUEST FOR PRODUCTION NO. 13: Please provide all documents in your possession that evidence any insurance payments for any and all healthcare services provided to you for the time period 2022 to the present.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.

REQUEST FOR PRODUCTION NO. 14: Please sign and produce the attached release authorizing Defendant(s) to obtain insurance payment records for you for the time period 2022 to the present.
RESPONSE: NO

REQUEST FOR PRODUCTION NO. 15: If you are claiming lost wages/income as damages in this action, please produce copies of all federal and state income tax returns jointly or separately filed by you for the years 2018 to present. If the returns are not available, please produce all documents in your possession or control which reflect the income that you earned each year. In the alternative, please sign and produce the attached forms (IRS Form 4506 and SSA Form 7050-F4) authorizing counsel for Defendants to obtain tax returns and earnings information for the years 2018 to present.
RESPONSE: NO LOST WAGES
REQUEST FOR PRODUCTION NO. 16: Please produce every memorandum, note, summary, report, letter, email, invoice, correspondence or other such document pertaining to this matter generated by or at the direction of any lay witness you or your counsel may or will call at trial.
RESPONSE: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.
REQUEST FOR PRODUCTION NO. 17: For each of your retained experts, provide copies of the following:
a A current curriculum vitae

b A list of all cases in which the expert has testified, by deposition or otherwise, as an expert witness within the past four years. This list should identify the cases by name, and should also identify the names of the attorneys representing the parties thereto.

c A colored copy of the expert’s complete file, including correspondence and original working papers relating to the expert’s retention in this matter, the expert’s evaluation of this matter, or the expert’s expected testimony in this matter. This should include, without limitation, hard copies of any and all electronic correspondence.

d Any and all documents, records, photographs, videotapes, drawings, deposition transcripts, articles, treatises, reports, prints or other tangible materials which the expert has reviewed, consulted, or relied upon in connection with this matter.

e All reports prepared by the expert concerning this matter, including any and all drafts thereof, in any format.

f All writings provided to the expert by, or on behalf of, the party who retained the expert to testify as an expert or by or on behalf of any party or former party to this litigation, including, without limitation, Plaintiff(s), and his/her attorney(s), their staff, etc.

g All writings, time sheets, and billing records showing or depicting the amount of time the expert devoted to this matter and the amount charged.

h All handwritten notes, computations, and drafts prepared by the expert in connection with the expert’s work on this matter, whether handwritten, electronic or other.

i Any and all materials provided to the expert relating to this case, including but not limited to, any and all materials provided by or relating to Plaintiff(s).

j Any and all documents, records, photographs, videotapes, drawings, diagnostic films, or other tangible materials which the expert plans to use during the course of the expert’s testimony at trial.

k Any and all publications authored by the expert in the last ten years.

l Any and all medical journals, texts, or documents of any sort upon which the expert has relied in formulating his/her opinions in this case.

m Any and all articles, treatises, publications, etc. which support any of the opinions provided in the expert’s report and/or affidavit.

n All written or electronic communications between the expert and counsel for Plaintiff, or their employees, including but not limited to e-mails and text messages.

RESPONSE: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.
REQUEST FOR PRODUCTION NO. 18: Please produce all memoranda, notes, correspondence, claims and other documents pertaining in any way to any claim for insurance benefits or other benefits filed by you and/or your counsel as a result of the incidents alleged in Plaintiff’s Complaint.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.
REQUEST FOR PRODUCTION NO. 19: Please produce copies of all documents, photographs or other tangible items which pertain to any item of damages to which you claim you are entitled as a result of the incidents alleged in Plaintiff’s Complaint.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.
REQUEST FOR PRODUCTION NO. 20: Please produce all documents or tangible items which you or your counsel will attempt to or may introduce as exhibits at trial.
RESPONSE: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.
REQUEST FOR PRODUCTION NO. 21: Please produce any journals, diaries, notes, calendars or other memoranda in any form, including but not limited to computer files, e-mail, disks, logs, Facebook posts, Facebook Messenger posts, Tweets, Snapchat posts, Instagram photos, Myspace posts, other blogs, etc., authored by you on your accounts or authored by you on another user’s account, or any posts authored by other witnesses concerning this action, including events leading up to the this action or its subject matter, or containing photographs or videos of you taken during the time period 2020 to present. For all documents/photos/videos produced, please provide the date of each entry and the date each photo/video was taken.
RESPONSE: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.
REQUEST FOR PRODUCTION NO. 22: Please produce any and all correspondence between yourself, or anyone on your behalf, and Defendants or any of Defendants’ agents, servants, employees or representatives.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the plaintiff
REQUEST FOR PRODUCTION NO. 23: Please produce any correspondence between yourself or your counsel and any medical, nursing or hospital regulatory agency, board or department, which relates to the events made the basis of this lawsuit.
RESPONSE:
REQUEST FOR PRODUCTION NO. 24: Please produce any documents that you or your counsel have obtained from agents, employees, or representatives of this Defendant, or any other Defendant, prior to filing this lawsuit, which relate to the events made the basis of this lawsuit.
RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.

REQUEST FOR PRODUCTION NO. 25: Please produce any documents you provided to any agents, employees, or representatives of this Defendant, or any other Defendant, prior to filing this lawsuit, which relate to the events made the basis of this lawsuit.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the plaintiff
REQUEST FOR PRODUCTION NO. 26: Please produce all documents provided to or received from the Social Security Administration, insurance company, employer or other entity, pertaining to any disability claim or disability benefits made or received by you, including but not limited to, medical records, applications, questionnaires, consultative examination reports, determinations, notices of decisions, OHA psychiatric review technique forms, exhibits, disability reports, correspondence, claimant’s statements, reports, letters or other documentation from healthcare providers.
RESPONSE:
REQUEST FOR PRODUCTION NO. 27: If you have ever filed for any short or long term disability benefits at any time, please sign and produce the attached forms authorizing counsel for Defendants to obtain disability records and written information.
RESPONSE: NO
REQUEST FOR PRODUCTION NO. 28: If you are claiming lost wages or wage earning capacity as part of your damages, please sign and produce the attached form authorizing Defendants to obtain your employment records.
RESPONSE: NO LOST WAGES
REQUEST FOR PRODUCTION NO. 29: Please produce all photographs and/or videos of you illustrating any injuries you contend you sustained as a result of the events alleged in Plaintiff’s Complaint.
RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.
REQUEST FOR PRODUCTION NO. 30: Please produce all photographs which you or your counsel intend to introduce at the trial of this matter.
RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.
REQUEST FOR PRODUCTION NO. 31: Please produce a true and correct copy of each and every exhibit that you or your counsel plan to introduce at the trial of this matter.
RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.
REQUEST FOR PRODUCTION NO. 32: Please produce all documents, statements, records, etc. concerning AMR that you or your counsel plan to use during deposition or the trial of this matter.
RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.
REQUEST FOR PRODUCTION NO. 33: Please produce copies of all documents and other materials which you used or referred to in any way in preparing your Answers to Defendant AMR’s First Set of Interrogatories and Requests for Production of Documents.
RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.
REQUEST FOR PRODUCTION NO. 34: Please sign and produce the attached form authorizing counsel for Defendant AMR to obtain your education records.
RESPONSE: NO
REQUEST FOR PRODUCTION NO. 35: Please produce a color copy of any law enforcement report, correspondence, documentation or any other communication Plaintiff or Plaintiff’s counsel has in their possession or control related to the incident made the basis of this suit.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the plaintiff



Respectfully submitted,

ATWOOD, MALONE, TURNER & SABIN, P.A.

Electronically Submitted /s/
Carla Neusch Williams, Esq.
Post Office Drawer 700
Roswell, NM 88202-0700
(575) 622-6221
Attorneys for Defendant American Medical Response



I will sue Atwood Malone Turner & Sabin for filing my medical records in court without a release.

Thing with interrogatories is this- first time i was hit with them i answered EVERY QUESTION, and expected the defense would do the same with my interrogatories for them. NOT THE CASE, they didn't answer one single thing just objected to everything.

FOR THE RECORD from what i have seen with professional attorneys interrogatories mean 30 reasons why the answer is no.






TAKE A DRINK EVERY TIME I OBJECT JUST LIKE A PROFESSIONAL ATTORNEY, YOU ARE DRUNK MY FRIEND. CHECK THIS SHIT OUT

[Rage]

I need to do ENMMC's Roggs to me...i keep procrastinating. Hopefully i will get it done this morning

[Rage]

ENMMC ROGS TO ME

STATE OF NEW MEXICO
COUNTY OF CHAVEZ
FIFTH JUDICIAL DISTRICT COURT

CHASE XANDER,

Plaintiff,

v. Cause No. D-504-CV-202300223
Judge: James M. Hudson
AMERICAN MEDICAL RESPONSE MEDICAL
SERVICE INC. and EASTERN NEW MEXICO
MEDICAL CENTER, INC.

Defendants.


DEFENDANT AMERICAN MEDICAL RESPONSE MEDICAL SERVICE INC’S
FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION
TO PLAINTIFF CHASE XANDER



Pursuant to the New Mexico Rules of Civil Procedure, Defendant American Medical Response Medical Service Inc., (hereafter "Defendant AMR") hereby requests that Plaintiff Chase Xander answer the following Interrogatories fully, in writing, under oath, and from all knowledge obtainable from any and all sources available to Plaintiff within thirty (30) days after the service hereof:

INTERROGATORIES
INTERROGATORY NO. 1: Please state the name and address of each person answering these Interrogatories. As to each person giving assistance, please state the numbers of the Interrogatories for which he or she provided assistance.
ANSWER: Chase Xander,

INTERROGATORY NO. 2: Please identify all documents, resources, or other sources of information upon which the individuals identified in response to Interrogatory No. 1 have relied in preparing the answers hereto.
ANSWER: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

INTERROGATORY NO. 3: Please state full name, any other names/alias used or by which you have been known, Social Security number, date/place of birth, marital status, name(s) of spouse(s), current address, current phone number, cell phone number and carrier at the time of the subject incident, and the name(s), addresses, and ages of children, if any.
ANSWER: Chase Xander,
Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence.

INTERROGATORY NO. 4: Please list all addresses at which you have resided from 2013 to present, including dates at each address and the names and relationships of all persons who have lived with you at each address.
ANSWER: Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence.

INTERROGATORY NO. 5: Please list all jobs you have held, including current employment, if any, and all employment in the past ten years (including but not limited to self-employment), listing for each the name and address of the employer, dates of hire and termination, job title and duties, rate of pay, supervisor and reason for leaving each position and/or employment.
ANSWER: I am disabled, I do not work, and have not worked one day in probably 30 years but certainly I have not worked one day in 10 years.

INTERROGATORY NO. 6: Please describe all lawsuits to which you have been a party, including but not limited to disability, worker’s compensation, private civil lawsuits, criminal proceedings, divorce and bankruptcies, including the names of the parties, type of matter, jurisdiction in which each was filed, date of filing, outcome of each proceeding and the names and addresses of all legal counsel for any party.
ANSWER: I am my own legal consultant- Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

INTERROGATORY NO. 7: Have you ever been (a) arrested; or (b) convicted of a crime punishable by imprisonment in excess of one year, or a crime involving dishonesty or false statement, regardless of the punishment? If your answer is “yes”, list for each such arrest or conviction:
a. The date of arrest/ conviction;
b. The Court/jurisdiction where such arrest/conviction occurred or was entered;
c. The punishment imposed; and
d. The nature of the crime and/or the reason for the arrest.

ANSWER: HARD NO NEVER

INTERROGATORY NO. 8: Please state the name, current address and telephone number of all physicians and other healthcare providers (including but not limited to physician offices, hospitals, clinics, emergency facilities, urgent care centers, detoxification facilities, rehabilitation facilities, or other mental or physical healthcare facilities) at which or by whom you have been seen or admitted from 2013 to present. For each provider listed, include reasons for all such consultations and/or admissions and the date of each visit or admission.
ANSWER: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

INTERROGATORY NO. 9: Please give the name, current address and telephone number of all pharmacies where you have had your prescriptions filled from January 2013 to present.
ANSWER: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

INTERROGATORY NO. 10: Please state whether at the time of the incidents described in the Complaint, you were suffering from any preexisting physical and/or mental/emotional illness or disability and, if so, describe in detail the time period during which you suffered any such disability or illness, the nature and extent of each such illness or disability, and list the names and current addresses of each healthcare provider who examined or treated you for such illness or disability.
ANSWER: Post Traumatic Stress Disorder I was diagnosed when I was 22, then my doctor got me on disability, I didn’t even know disability was a thing. It was getting better until all of this started about 10 years ago. I never needed medical attention often before look how much I have had since. This is a provable FACT, before, I never needed much medical attention. Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

INTERROGATORY NO. 11: If you are claiming that you required psychological / mental health treatment or counseling of any kind as a result of the subject incidents, please state the name, address and telephone number of any and all physicians, counselors, psychiatrists, psychologists, clergy, therapists and/or outpatient healthcare or mental health facilities in which you received such care and treatment from the date of the first incident to present. Please include the dates of such emotional and/or mental health care and/or treatment and the reason(s) why such care or treatment was needed.
ANSWER: I have provided medical releases.

INTERROGATORY NO. 12: Please list the name, current address, and telephone number of each person known to you or your counsel who may have knowledge, evidence, or documents in their possession, custody, or control which are relevant to any of the issues involved in this action, and for each person, describe the nature and content of the knowledge possessed and/or the evidence or documentation in his/her possession, custody or control.
ANSWER: I have provided medical releases.

INTERROGATORY NO. 13: Have you, during the time of the incident in question up until the current date, had accounts on any social media sites, dating sites, blogs, or apps, including, but not limited to, Facebook, Facebook Messenger, Snapchat, Pinterest, Instagram, Twitter, Linkedin, Google+, Classmates, Meetme, Tumbler, Match, YouTube, Reddit, Flickr, Foursquare, Swarm, Pheed, eHarmony, PlentyOfFish, Zoosk, OK Cupid, ChristianMingle, DateHookup, Chemistry, SpeedDate, Spark, Tinder, Blendr, Farmers Only, Kik, Whisper, Ask.fm, Skout, Playstation Network, X-Box Live, or Myspace. If so, please provide the name of each site or app, and your screen name(s) or account name(s) for each. Further, you are advised to not delete or remove any information from any social media site, dating site, or app during the pendency of this litigation. If you have already made such deletions, please provide the substance of each part deleted and date of deletion.
ANSWER: Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence
INTERROGATORY NO. 14: Please list the name and current address of each expert witness that you or your counsel will or may call at the trial of this action, and as to each expert, please specify:
a. The subject matter on which the expert is expected to testify;
b. The substance of the facts to which the expert is expected to testify;
c. All opinions to which the expert is expected to testify;
d. A summary of the grounds for each opinion;
e. A list of all publications authored by the witness within the preceding ten (10) years;
f. Identification of all documents, facts or data that were provided to the expert and that the expert considered in forming opinions to be expressed in this case;
g. All assumptions that were provided to the expert and that the expert relied upon in forming opinions to be expressed in this case; and
h. A listing of all other cases in which the witness has testified as an expert at trial or by deposition within the preceding four (4) years.

ANSWER: Councilors Doug Southern, Bill Williams, Doctor Sparkman possibly Dr Vega
A. my mental and physical health and how the abuse by both defendants have effected me.
B. I have been greatly damaged.
C. I have been greatly damaged.
D. The Witnesses are doctors and councilors
Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.

INTERROGATORY NO. 15: Please identify and describe all information furnished to, or otherwise compiled, generated, reviewed, or relied upon by each such expert in the formation of his/her opinions herein.
ANSWER: My medical records and their expert opinions.

INTERROGATORY NO. 16: Please identify any treating provider of Plaintiff that she intends to call as a witness at the trial of this matter. For each treating provider identified, please state the following:
a. The substance of all communications the Plaintiff, Plaintiff’s counsel, or anyone on behalf of Plaintiff has had with the treating provider, including the dates of communications;
b. The subject matter on which each such treating provider is expected to present evidence or testimony;
c. A summary of the facts and opinions to which each such treating provider is expected to testify;
d. The compensation to be paid to each such treating provider, if any, for review or testimony; and
e. Identification of all documents, facts or data that were provided to each such treating provider; and
f. Whether each such treating provider will give opinions on causation and, if so, a summary of those opinions.

ANSWER: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

INTERROGATORY NO. 17: Please list the name and current address of each lay witness that you will or may call at the trial of this action, and as to each witness, please state the nature of each witness' testimony, the witness’ relationship to you, and the issues about which each witness will testify.
ANSWER: My caregiver Christine who works for agape home health care.

INTERROGATORY NO. 18: Please list and describe adequately for identification all exhibits which you will or may use at the trial of this action.
ANSWER: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

INTERROGATORY NO. 19: Please identify all medical literature upon which you or your experts intend to refer at depositions or the trial of this matter.
ANSWER: Mayo Clinic- https://www.mayoclinic.org/

INTERROGATORY NO. 20: Please identify all medical charges (whether it be for services, equipment or medications), you contend were generated as a result of Defendants’ alleged negligence. For each charge, please state the following:
a. The amount of the charge;
b. The individual or entity who generated the charge;
c. The date on which the charge was generated;
d. The purpose of the charge;
e. The amounts of the charges that have been paid;
f. The identity of all third parties who have paid any of the charges along with the dates and amount of charges paid;
g. The amount of charges that were written off or adjusted by your healthcare providers;
h. The holder and the current amount of any liens asserted by any person or entity;
i. The basis for your allegations that but for Defendants’ alleged negligence, you would not have required the charge.

ANSWER: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

INTERROGATORY NO. 21: Please state whether or not any of your special damages have been paid or reimbursed, or are subject to payment or reimbursement, by yourself, an employer, insurance company or governmental agency (including Medicare and/or Medicaid). If so, please state:
a) Name and address of all such companies, agencies or employers;
b) The reason for the payment or reimbursement;
c) The amount paid or subject to reimbursement;
d) Whether a lien exists and the amount of the lien.

ANSWER:

INTERROGATORY NO. 22: Please state whether or not you are claiming any loss of earnings or earning capacity as a result of the incident and injuries alleged in your Complaint. If so, please state:
a) The amount and manner of computation;
b) The period for which loss is claimed;
c) The name and address of the employer or business involved;
d) The name, address and telephone number of the person who presently has possession or custody of any records or documents in support of your claim for lost wages or earning capacity.

ANSWER: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

INTERROGATORY NO. 23: Do you contend that you will need future medical and/or mental health treatment as a result of the alleged negligence, harassment, battery and/or discrimination of Defendant(s)? If so, please identify all future treatment and associated costs of same. Please also identify every witness you contend will support your claim for future medical and/or mental health treatment.
ANSWER: Yes Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.

INTERROGATORY NO. 24: Please state whether you have applied for short or long term disability benefits at any time during your life. If so, please provide the date of application, the name, address and telephone number of the facility where you applied for said benefits, the reason for the application, and whether disability benefits were received.
ANSWER: Yes my doctor got SSI for me when I was approximately 23
Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.

INTERROGATORY NO. 25: Have you entered into any settlement agreement with any individual or entity with respect to claims arising out of the incident described in your Complaint? If your answer is "yes," please state the details of the settlement agreement as well as the policy limits of any applicable insurance policy.
ANSWER: yes, I settled with Chaves County and their Sheriffs Office it was the federal case-
Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants. I also have a gag order on another case against a councilor.

INTERROGATORY NO. 26: Have you or has any person, firm, business or entity retained by you or your counsel obtained any statement from any person, oral, written or recorded, regarding any of the facts surrounding the incident? If so, identify each such statement obtained by stating the name and address of the person giving the statement; the name, address and present position or relationship to you, of the person taking the statement; the date of the statement; the circumstances under which the statement was obtained; the substance of the statement; and the identity of the person presently having custody or a copy of the statement, if written or recorded, or knowledge with regard to any oral statement.
ANSWER: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.


REQUESTS FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 1: Please produce copies of all documents or pleadings pertaining in any way to any arrests or criminal convictions, other civil or criminal lawsuit, bankruptcy, divorce and/or other legal or administrative proceeding (including Worker’s Compensation) in which you have been involved as a party.
RESPONSE: Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence.

REQUEST FOR PRODUCTION NO. 2: Please produce copies of all medical and/or mental health records and reports from each healthcare or counseling-type provider who has examined or treated you during the time period 2013 to the present.
RESPONSE: I have signed all medical releases given to me.

REQUEST FOR PRODUCTION NO. 3: Please produce all correspondence between you, or anyone on your behalf, and your healthcare providers during the time period 2013 to the present.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

REQUEST FOR PRODUCTION NO. 4: For all prescription and over-the-counter medications you are currently taking, please produce copies of labels and package inserts (if any) for all such medications.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

REQUEST FOR PRODUCTION NO. 5: Please sign and produce the attached forms authorizing counsel for Defendants to obtain medical records and mental health records and written information from your healthcare providers for the time period 2013 to the present.
RESPONSE: I have signed all medical releases.

REQUEST FOR PRODUCTION NO. 6: Please produce copies of any written or recorded reports, interviews, opinions or correspondence of any lay or expert witness which pertains in any way to events related to the incident which is the subject of this lawsuit.
RESPONSE: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

REQUEST FOR PRODUCTION NO. 7: Please produce a color copy of any medical or psychiatric records related to or concerning you in the possession or under the control of you or your counsel.

RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

REQUEST FOR PRODUCTION NO. 8: Please produce copies of all bills, expenses, or other documentation pertaining to any damages you allege are a result of the incidents described in Plaintiff’s Complaint. Each bill or statement should reflect total amount charged, total amount paid, and total amount adjusted/written off.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

REQUEST FOR PRODUCTION NO. 9: If Medicare provided payment to any medical providers, physicians, or suppliers of medical equipment or medications for any treatment at issue in this matter, please produce the Medicare Summary Notices memorializing those payments by Medicare.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

REQUEST FOR PRODUCTION NO. 10: Please produce a copy of all correspondence between you, or anyone on your behalf, and the Centers for Medicare and Medicaid Services relating to the reporting of the claim at issue in this case.
RESPONSE: I will look and attach them to this document.

REQUEST FOR PRODUCTION NO. 11: Please produce a copy of all notices of Medicare liens and/or documents pertaining to any other liens, rights of reimbursement, or rights of subrogation against any recovery that you may have regarding the claims at issue in this matter.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

REQUEST FOR PRODUCTION NO. 12: If you received medical assistance, including but not limited to Medicaid, SCHIP, CHIP, and/or any county indigent fund, relative to the treatment at issue in this matter, please produce a copy of all communications in this regard.
RESPONSE: I have medicaid.

REQUEST FOR PRODUCTION NO. 13: Please provide all documents in your possession that evidence any insurance payments for any and all healthcare services provided to you for the time period 2022 to the present.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

REQUEST FOR PRODUCTION NO. 14: Please sign and produce the attached release authorizing Defendant(s) to obtain insurance payment records for you for the time period 2022 to the present.
RESPONSE: I have signed all releases and will continue to release any medical records needed.

REQUEST FOR PRODUCTION NO. 15: If you are claiming lost wages/income as damages in this action, please produce copies of all federal and state income tax returns jointly or separately filed by you for the years 2018 to present. If the returns are not available, please produce all documents in your possession or control which reflect the income that you earned each year. In the alternative, please sign and produce the attached forms (IRS Form 4506 and SSA Form 7050-F4) authorizing counsel for Defendants to obtain tax returns and earnings information for the years 2018 to present.
RESPONSE: No lost wages.
REQUEST FOR PRODUCTION NO. 16: Please produce every memorandum, note, summary, report, letter, email, invoice, correspondence or other such document pertaining to this matter generated by or at the direction of any lay witness you or your counsel may or will call at trial.
RESPONSE: Here is MY note- I will call Christine my caregiver to testify to the pain and suffering I go through on a daily basis. She will state I am in physical and mental pain.
REQUEST FOR PRODUCTION NO. 17: For each of your retained experts, provide copies of the following:
a) A current curriculum vitae

b) A list of all cases in which the expert has testified, by deposition or otherwise, as an expert witness within the past four years. This list should identify the cases by name, and should also identify the names of the attorneys representing the parties thereto.

c) A colored copy of the expert’s complete file, including correspondence and original working papers relating to the expert’s retention in this matter, the expert’s evaluation of this matter, or the expert’s expected testimony in this matter. This should include, without limitation, hard copies of any and all electronic correspondence.

d) Any and all documents, records, photographs, videotapes, drawings, deposition transcripts, articles, treatises, reports, prints or other tangible materials which the expert has reviewed, consulted, or relied upon in connection with this matter.

e) All reports prepared by the expert concerning this matter, including any and all drafts thereof, in any format.

f) All writings provided to the expert by, or on behalf of, the party who retained the expert to testify as an expert or by or on behalf of any party or former party to this litigation, including, without limitation, Plaintiff(s), and his/her attorney(s), their staff, etc.

g) All writings, time sheets, and billing records showing or depicting the amount of time the expert devoted to this matter and the amount charged.

h) All handwritten notes, computations, and drafts prepared by the expert in connection with the expert’s work on this matter, whether handwritten, electronic or other.

i) Any and all materials provided to the expert relating to this case, including but not limited to, any and all materials provided by or relating to Plaintiff(s).

j) Any and all documents, records, photographs, videotapes, drawings, diagnostic films, or other tangible materials which the expert plans to use during the course of the expert’s testimony at trial.

k) Any and all publications authored by the expert in the last ten years.

l) Any and all medical journals, texts, or documents of any sort upon which the expert has relied in formulating his/her opinions in this case.

m) Any and all articles, treatises, publications, etc. which support any of the opinions provided in the expert’s report and/or affidavit.

n) All written or electronic communications between the expert and counsel for Plaintiff, or their employees, including but not limited to e-mails and text messages.

RESPONSE: Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence.

REQUEST FOR PRODUCTION NO. 18: Please produce all memoranda, notes, correspondence, claims and other documents pertaining in any way to any claim for insurance benefits or other benefits filed by you and/or your counsel as a result of the incidents alleged in Plaintiff’s Complaint.
RESPONSE: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

REQUEST FOR PRODUCTION NO. 19: Please produce copies of all documents, photographs or other tangible items which pertain to any item of damages to which you claim you are entitled as a result of the incidents alleged in Plaintiff’s Complaint.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

REQUEST FOR PRODUCTION NO. 20: Please produce all documents or tangible items which you or your counsel will attempt to or may introduce as exhibits at trial.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

REQUEST FOR PRODUCTION NO. 21: Please produce any journals, diaries, notes, calendars or other memoranda in any form, including but not limited to computer files, e-mail, disks, logs, Facebook posts, Facebook Messenger posts, Tweets, Snapchat posts, Instagram photos, Myspace posts, other blogs, etc., authored by you on your accounts or authored by you on another user’s account, or any posts authored by other witnesses concerning this action, including events leading up to the this action or its subject matter, or containing photographs or videos of you taken during the time period 2020 to present. For all documents/photos/videos produced, please provide the date of each entry and the date each photo/video was taken.
RESPONSE: www.chavescounty.org Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence

REQUEST FOR PRODUCTION NO. 22: Please produce any and all correspondence between yourself, or anyone on your behalf, and Defendants or any of Defendants’ agents, servants, employees or representatives.
RESPONSE: Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

REQUEST FOR PRODUCTION NO. 23: Please produce any correspondence between yourself or your counsel and any medical, nursing or hospital regulatory agency, board or department, which relates to the events made the basis of this lawsuit.
RESPONSE: I will try to attach the emails between me and ENMMC’s legal department since 2017, including when the hospital almost killed me with 500 Ketamine.

REQUEST FOR PRODUCTION NO. 24: Please produce any documents that you or your counsel have obtained from agents, employees, or representatives of this Defendant, or any other Defendant, prior to filing this lawsuit, which relate to the events made the basis of this lawsuit.
RESPONSE: Plaintiff objects because this has been asked above.

REQUEST FOR PRODUCTION NO. 25: Please produce any documents you provided to any agents, employees, or representatives of this Defendant, or any other Defendant, prior to filing this lawsuit, which relate to the events made the basis of this lawsuit.
RESPONSE: Plaintiff objects to this question as premature. She has not fully completed discovery and has not completed trial preparation. Further discovery, legal research, and analysis may supply additional information. So the responding party reserves the right to supplement these responses at trial

REQUEST FOR PRODUCTION NO. 26: Please produce all documents provided to or received from the Social Security Administration, insurance company, employer or other entity, pertaining to any disability claim or disability benefits made or received by you, including but not limited to, medical records, applications, questionnaires, consultative examination reports, determinations, notices of decisions, OHA psychiatric review technique forms, exhibits, disability reports, correspondence, claimant’s statements, reports, letters or other documentation from healthcare providers.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.

REQUEST FOR PRODUCTION NO. 27: If you have ever filed for any short or long term disability benefits at any time, please sign and produce the attached forms authorizing counsel for Defendants to obtain disability records and written information.
RESPONSE: I will sign that release.
REQUEST FOR PRODUCTION NO. 28: If you are claiming lost wages or wage earning capacity as part of your damages, please sign and produce the attached form authorizing Defendants to obtain your employment records.
RESPONSE: No job no lost wages.

REQUEST FOR PRODUCTION NO. 29: Please produce all photographs and/or videos of you illustrating any injuries you contend you sustained as a result of the events alleged in Plaintiff’s Complaint.
RESPONSE: No photos or videos of me illustrating any injury.
REQUEST FOR PRODUCTION NO. 30: Please produce all photographs which you or your counsel intend to introduce at the trial of this matter.
RESPONSE: Plaintiff objects to this question as premature. She has not fully completed discovery and has not completed trial preparation. Further discovery, legal research, and analysis may supply additional information. So the responding party reserves the right to supplement these responses at trial

REQUEST FOR PRODUCTION NO. 31: Please produce a true and correct copy of each and every exhibit that you or your counsel plan to introduce at the trial of this matter.
RESPONSE: Plaintiff objects to this question as premature. She has not fully completed discovery and has not completed trial preparation. Further discovery, legal research, and analysis may supply additional information. So the responding party reserves the right to supplement these responses at trial

REQUEST FOR PRODUCTION NO. 32: Please produce all documents, statements, records, etc. concerning AMR that you or your counsel plan to use during deposition or the trial of this matter.
RESPONSE: Plaintiff objects to this question as premature. She has not fully completed discovery and has not completed trial preparation. Further discovery, legal research, and analysis may supply additional information. So the responding party reserves the right to supplement these responses at trial

REQUEST FOR PRODUCTION NO. 33: Please produce copies of all documents and other materials which you used or referred to in any way in preparing your Answers to Defendant AMR’s First Set of Interrogatories and Requests for Production of Documents.
RESPONSE: Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendants.

REQUEST FOR PRODUCTION NO. 34: Please sign and produce the attached form authorizing counsel for Defendant AMR to obtain your education records.
RESPONSE: I was in college on the National Dean's Honor List, but never got a degree.

REQUEST FOR PRODUCTION NO. 35: Please produce a color copy of any law enforcement report, correspondence, documentation or any other communication Plaintiff or Plaintiff’s counsel has in their possession or control related to the incident made the basis of this suit.
RESPONSE: Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence



Respectfully submitted,

ATWOOD, MALONE, TURNER & SABIN, P.A.

Electronically Submitted /s/
Carla Neusch Williams, Esq.
Post Office Drawer 700
Roswell, NM 88202-0700
(575) 622-6221
Attorneys for Defendant American Medical Response

[Rage]

i did AMR's rogs twice gotta do enmmc's now

[Rage]

EASY PEASY LEMON SQUEEZEY

FIRST SET OF INTERROGATORIES TO PLAINTIFF CHASE XANDER
INTERROGATORY NO. 1: Please state your full name, date of birth and Social Security number. Please state all names by which you have been known, dates of marriages and divorces, if any, and names and addresses of any ex‑spouses and children.

ANSWER: Chase Xander, 11/30/1967, my name has been Chase Xander over 10 years
Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence.


INTERROGATORY NO. 2: Please state the name, address, telephone number and specialty of each physician or health care provider you consulted, specifying as to each occasion the purpose for which the physician or health care provider was consulted on and the dates of each such consultation, for the ten (10) years preceding the events underlying the Complaint and for the time period between the events underlying the Complaint and the present.

ANSWER: Plaintiff objects because she has already provided all this information to the defendant ENMMC.


INTERROGATORY NO. 3: State the names, addresses and present ages of your spouse and any former spouse, and any children or other persons with whom you reside or who are dependent upon you for support or maintenance, in whole or in part.

ANSWER: I live alone.


INTERROGATORY NO. 4: Do you claim that ENMMC did not meet the appropriate standard of care required of reasonably-well qualified health care providers under similar circumstances, giving due consideration to the locality involved? If so, please sate:

A. The specific details of your claim, including whom you allege to be negligent;
B. A description of how ENMMC and its providers’ conduct deviated from the appropriate standard of care;
C. The date, time, and place of each act you claim fell below the standard of care;
D. References to any medical literature you are aware of that supports your claim ENMMC and its providers fell below the appropriate standard;
E. A description of ENMMC and its providers’ conduct as you claim it should have been so as to not cause the injury alleged; and
F. Any other information supporting your claim.

ANSWER: Yes.
A. I have been abused by ENMMC on almost every visit to them, they have always refused to call my insurance when I was discharged from the hospital. They have falsely detained me on multiple occasions. ENMMC’s er doctor gave me 500mg of Ketomine enough to kill a person. Nurse Greg Doe has been the worst, but none of the care I have received has been up to standards.

B. ENMMC employees but especially Nurse Greg Doe have been extremely hostile to me, they have discriminated against me because of my disability. All of them seen me as alone, poor and crazy, and they could treat me anyway they liked because I could never hire an attorney to do anything about it. Your employees judged this book by the cover and it was the most costly mistake they will ever make.

C. Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendant.

D. Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.

E. The employees of ENMMC should not have detained me illegally on multiple occasions. The employees of ENMMC should have acted and treated me professionally instead of harassing me. The employees of ENMMC should not have given me enough ketomine to kill someone. The employees of ENMMC should have called my insurance company each time I asked (every time) like is policy and they follow that policy in their sunrise unit. Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.

F. Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.





INTERROGATORY NO. 5: Do you claim that any employee of ENMMC was negligent or fell below the appropriate standard of care? If so, for each such employee, please state:

A. The employee’s name. job title, and if applicable, where that person charted in the medical record;
B. The specific act or actions that you claim were negligence and how those actions fell below the appropriate standard of care;
C. The time and location of each act or action you claim was negligent;
D. Any reference to the medical literature you will rely on to support the contention that such acts constituted negligence;
E. The specific damages or harm that was allegedly caused by each such act or action.

ANSWER:

A. Nurse Greg Doe, the doctor who gave me the ketamine, the doctors who sent me to sunrise instead of listening to what I was saying. Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.

B. Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.

C. Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendant.

D. Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.

E. Extreme physical and mental pain and damage.


INTERROGATORY NO. 6: Please state the full names, last known addresses and telephone numbers of all fact witnesses which you or your attorneys intend to call at the time of the trial, and the substance of their expected testimony. Specifically, in addition to other fact witnesses, please identify and list any medical providers, including physicians, nurses or other health care providers, you expect will provide lay witness testimony, along with a brief summary of the testimony you expect them to provide.

ANSWER: Plaintiff objects because she has already provided all this information to the defendant ENMMC.


INTERROGATORY NO. 7: Please state the name, address, occupation and qualifications of any person whose opinion forms the basis of this lawsuit, and/or whose testimony will or may be offered at trial as an expert witness, and, for each, state:
A. Whether the expert has examined the Plaintiff;
B. The subject matter on which such person or expert is expected to testify;
C. Whether the person or expert will render an opinion on standard of care and/or causation;
D. The substance and facts of each opinion to which the person or expert is expected to testify;
E. A summary of the grounds for each opinion;
F. A summary of discussions with Plaintiff and the date and time of the discussions;
G. Specifics upon which the expert relied, including, but not limited to, Plaintiff’s medical records and the date and author of said records, documents, texts, journals, studies or other sources;
H. A list of cases in which the expert has testified in the last five (5) years, including the jurisdiction in which the case was filed, case number and caption, and name of attorney who hired the expert;
I. Pursuant to Rule 1‑034, produce a copy of the expert’s CV;
J. All bills or other accounts of time spent by retained experts and a copy of the expert’s fee schedule.

ANSWER: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.

Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.

INTERROGATORY NO. 8: Please list all sources of your income or support, the intervals when these payments are received (e.g., weekly, monthly, yearly, etc.), the amount received at each interval, the date when each source of income was first received, and the amount received to date from each source of income.

ANSWER: I get aprox $900.00 from SSI within 10 dollars, monthly.


INTERROGATORY NO. 9: Please list any serious illnesses, impairments, physical defects, diseases or surgical operations you had either before or after the incident referred to in your Complaint (in other words at any time in your life), provide the date, place, and a description of each such serious illness, impairment, physical defect, disease or surgery, and the names and addresses of all your treating health care providers, including physicians, surgeons, hospitals, clinics, in‑ or out‑patient facilities and dentists. Please include the names and addresses of any family physicians you have had.

ANSWER: PTSD Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendant.


INTERROGATORY NO. 10: Please list any prior litigation in which you have been involved. This interrogatory is meant to include both criminal and civil litigation, workers’ compensation claims, and any other instance in which you have had contact with the court system. For each, please list the attorneys involved, the date, the state and/or county in which the court was located, the case number, and the outcome or disposition of each.

ANSWER: I am my own legal representative. Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the defendant.


INTERROGATORY NO. 11: Please list any agencies or institutions that currently hold a lien applicable to this litigation. This Interrogatory is inquiring about any unpaid hospital bills, third party insurers with a subrogation interest, Medicare or Medicaid interests in the proceeds, if any, of this litigation. Pursuant to Rule 1‑034, please provide copies of any correspondence indicating the presence of a lien or potential lien.

ANSWER: Possibly Medicaid


INTERROGATORY NO. 12: State the names, addresses and telephone numbers of all pharmacies at which you have had prescriptions filled in the last five (5) years.

ANSWER: Plaintiff objects because she has already provided all this information to the defendant ENMMC.


INTERROGATORY NO. 13: Please list the name, address and telephone number of each person you understand to have personal knowledge of the facts and circumstances surrounding the allegations in your Complaint. For each such person, detail what personal knowledge he or she has of the incident.

ANSWER: My caregiver Cristine who works for Agape home healthcare. Plaintiff objects because she has already provided all this information to the defendant ENMMC.


INTERROGATORY NO. 14: Without simply referring to the Complaint, please identify every fact, witness, document or other item that supports your claim in paragraphs 40, 42, 44, 51, 52 of the Complaint concerning damages incurred that you attribute to ENMMC including medical and nonmedical expenses, pain and suffering, loss of enjoyment of life, the nature, extent, and duration of injuries.

ANSWER: The injuries are ongoing and extreme. Plaintiff objects because she has already provided all this information to the defendant ENMMC. Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed.


INTERROGATORY NO. 15: State separately and identify by date and content each document, photograph, or other tangible thing which is contemplated to be offered as an exhibit at the time of trial in support of your claim in this action. Please attach a copy of each to the original of your Answers to these Interrogatories pursuant to Rule 1‑034 NMRA.

ANSWER: Plaintiff objects because she has already provided all this information to the defendant


INTERROGATORY NO. 16: Please identify by provider name, facility, address, phone number, dates of visit(s) and reason for visit(s) for all health care you claim is related to the alleged negligence of ENMMC.

ANSWER: Plaintiff objects because she has already provided all this information to the defendant


INTERROGATORY NO. 17: Do you claim to have been psychologically or emotionally injured as a result of the occurrence alleged in your Complaint?  If so, please state:

A. Whether you have sought any treatment by a health care provider;
B. The nature and extent of each alleged injury and whether each such injury is temporary or permanent;
C. Whether your alleged condition or injury has been diagnosed by a health care provider;
D. Whether you presently suffer any disability or permanent effects as a result of the alleged injury; and
E. The amount(s) charged by the health care provider for the treatment you received;
F. Whether a health care provider has made a prognosis, and the name of the health care provider who has made such a prognosis; and
G. Whether you are presently suffering from any permanent effects or disability as a result of the occurrence alleged in your Complaint and the nature of the disability.
H. Whether there are any other factors in your life that could contribute to your alleged emotional distress, including but not limited to mental illness, domestic violence, child abuse, or sexual assault at any time in your life.

ANSWER:

A. Yes

B. Extreme Physical and Mental trauma.

C. Yes

D. Yes

E. A LOT

F. Yes Bill Williams, Doctor Loretta Sparkman, others.

G. Yes a LOT

H. Yes, the damage is mitigated.

Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete




INTERROGATORY NO. 18: Please identify with specificity each and every document you, your agents, attorneys and representatives relied upon in answering these Interrogatories. Pursuant to Rule 1‑034, NMRA, please attach copies of the same to these answers.

ANSWER: I just answered the questions.


INTERROGATORY NO. 19: With regard to Medicaid and Medicare, please provided the following information:

A. Are you a Medicaid or Medicare beneficiary, or have you applied to become a Medicaid or Medicare beneficiary?

B. Has Medicaid or Medicare made any payments and/or conditional payments for medical treatment or other services provided to you in connection with any of the injuries alleged in the Complaint? If so please state the dates of treatment or service, the name of the healthcare provider, and the amount of payment by Medicaid or Medicare.

C. Have you or anyone acting on your behalf contacted Medicare or Medicaid to determine the amount of reimbursement, if any, being requested by Medicare or Medicaid to determine the amount of reimbursement, if any, being requested by Medicare with respect to medical treatment or other services provided to you in connection with any of the injuries alleged int eh Complaint? If so, please state the amount of reimbursement being requested.

ANSWER:

A. Yes Medicaid

B. Yes you know medicaid pays my medical bills, you have this information already when I signed the releases.

C. I do not believe that medicaid is seeking reimbursement.

INTERROGATORY NO. 20: If you are making a claim for lost wages, please list the dates on which you allege you were unable to work as a result of the incident that is the subject of your Complaint and the amount of money you allege you lost. State the names, addresses and telephone numbers of all witnesses whose testimony will support your allegations and give a brief summary of the testimony each witness will give. Also, please identify any supporting documents.

ANSWER: No lost wages.


INTERROGATORY NO. 21: If you are making a claim for loss of future earning capacity, please state the dollar amount of annual earnings you believe you will lose as a result of the incident alleged in your Complaint. State the names, addresses and telephone numbers of the witnesses who will support your allegations and provide a brief summary of the testimony each will give. Also, please identify any supporting documents.

ANSWER: No lost earnings.

INTERROGATORY NO. 22: With respect to your employment history, state the names and addresses of every employer you have ever had, beginning with the most recent employer and going back to the first employer.  Also, as to each place of employment, state the dates of each such employment, including month and year, and the reason for leaving each job.

ANSWER: I have not worked one day in 10 years.


INTERROGATORY NO. 23: Please state whether you have ever made a claim for workers’ compensation or Social Security disability. If so, please provide the name, address and telephone number of all persons you interacted with at Workers’ Compensation Administration or Social Security Administration. Identify all physicians that you saw pursuant to your claim and the amount of money you received, if any, from workers’ compensation.

ANSWER: I have been on SSI since I was aprox 22.


INTERROGATORY NO. 24: Without citing the allegations in your Complaint, please specify the basis of your claim for punitive damages. Please indicate each and every factual basis for your claim, the nature, extent, and dollar amount of these alleged damages, the names of any experts upon whom you are relying in determining these damages, and any documents and/or other evidence that you believe tends to prove this item of damages.

ANSWER: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


INTERROGATORY NO. 25: Please state your educational background, provide the names of schools attended; course of study; dates of graduation; and degrees received.

ANSWER: Some college.


INTERROGATORY NO. 26: Please state whether you:

A. Are or were a Medicare and/or Medicaid beneficiary;
B. Are or were a Social Security disability beneficiary;
C. Are or were a Social Security retirement beneficiary;
D. Are or were a Supplemental Security Income beneficiary.
E. Have applied for Social Security benefits or are in the application or appeal process.


ANSWER:

A. Yes Medicaid since I was 22

B. Yes SSI

C. No

D. Yes SSI

E. No, my doctor filled out the paperwork.


INTERROGATORY NO. 27: Has Medicare been notified of your personal injury claim against Defendant pursuant to 42 CFR §411, et seq.? If so, please:

A. Identify the agency that has been notified of the claim;
B. State the amount of any lien asserted by the agency; and
C. Identify all payments for medical care that have been made on your behalf that are related to your claim.

ANSWER: No


INTERROGATORY NO. 28: Please state whether you have any calendars, diaries, writings or recordings that refer in any way to the events underlying the Complaint.

ANSWER: No

INTERROGATORY NO. 29: Please state whether you have any social media accounts including, but not limited to, Facebook, Instagram, TikTok, Discord, Ventrilo, Skype, TeamSpeak, Reddit, YouTube, forum.tribalwars.net, Twitch, Kick, Mumble, Twitter, Snapchat, Justin.tv, Steam, Battle.net, Origin, PlayStation Network, XBOX Live, Pinterest, Tumblr, MySpace, Vimeo, SoundCloud, Periscope, Mojang, Mixer, personal blogs, professional websites and the like. If your answer is yes, please state:

a. the name of each social media account and
b. your screen name (the name that is seen by the public on each website).

If any accounts have been deleted, modified, or privatized since March 8, 2022, please state:

a. the name of each account,
b. the date that each account was changed, and
c. what changes (modification, deletion, etc.) were made, and
d. describe the substance of the deletion, change, modification, etc.

ANSWER: Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence.

INTERROGATORY NO. 30: Please state whether you know or knew any of the named Defendants in this action. If your answer is yes, please state the relationship you had with each of the named Defendants (e.g. professional colleague, co-worker, personal friend, acquaintance, etc.) and the dates encompassing each of these relationships.

ANSWER: No



INTERROGATORY NO. 31: Please state whether there is any family history of genetic disorder in your family. If your answer is yes, please describe in your own words:

a. Your understanding of the nature of each of the disorders and/or disabilities that run in your family;

b. The persons in your family who have been diagnosed or you suspect have the disability; and

c. Describe in your own words the symptoms that you have observed anyone in your family, including yourself, experience or have experienced in the past.

ANSWER: I was adopted.


















FIRST REQUEST FOR PRODUCTION TO PLAINTIFF CHASE XANDER
REQUEST NO. 1: Any and all writings or other documents prepared by you or anyone you are aware of including notes, diaries, logs, timelines, memoranda, calendars, etc., that pertain to any issue raised in this case.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


REQUEST NO. 2: If you are claiming lost wages, produce all federal income tax returns including all schedules and attachments thereto filed by you from 2017 through the tax year 2023, inclusive.

RESPONSE: Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence.


REQUEST NO. 3: If you are claiming lost wages, produce all W-2 forms, 1099 forms, and other evidences and documents of earnings from whatever source indicating earnings by you for the years 2017 through 2023, inclusive.

RESPONSE: No lost wages.


REQUEST NO. 4: If you are claiming lost wages, produce all state income tax returns for the State of New Mexico and any other states for the years 2017 through 2023, inclusive.

RESPONSE: No lost wages


REQUEST NO. 5: If you are claiming lost wages, all check stubs and any other documentary evidence that you may have indicating your earnings from 2017 to 2023.

RESPONSE: No lost wages But my time is worth a LOT of money.


REQUEST NO. 6: All medical bills, invoices, statements, reports or records reflecting medical treatment of you for any physical, neurological, or mental injuries resulting from the incident that is the basis of this lawsuit.

RESPONSE: You have that


REQUEST NO. 7: Copies of all medical records in your possession or your attorney’s possession or under your control that in any way relates to your past medical care.

RESPONSE: You have that.
REQUEST NO. 8: All statements by any of the parties or witnesses relating to the incident that is the basis of this lawsuit.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


REQUEST NO. 9. A copy of any and all documents prepared by any person who investigated the incident alleged in the Complaint.

RESPONSE:
Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete

REQUEST NO. 10: All documents, exhibits or other materials you intend to refer to or use at the trial of this matter.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


REQUEST NO. 11: A HIPAA Compliant Authorization Form for the release of your medical records. A form is attached.

RESPONSE: If I signed that I probably should not have.


REQUEST NO. 12: If you are claiming lost wages, an Authorization for the Release of Employment Records for you. A form is attached.

RESPONSE: NO LOST WAGES


REQUEST NO. 13: True and accurate copies of any and all documents prepared by any expert relied upon or used by any expert and/or any authoritative texts, articles and/or other document ever published and/or presented by each expert.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete

REQUEST NO. 14: An Authorization for the Release of Tax Information. A form is attached.

RESPONSE: Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence.


REQUEST NO. 15: Any and all contracts or fee agreements with the Plaintiff or any third parties for the retention of any and all experts relied upon or retained by the Plaintiff, documents reflecting the expert’s accounting of time spent in reviewing this case and discussing his or her opinion and findings with Plaintiff’s counsel, any and all correspondence, questionnaires, notes, memoranda, addenda or e‑mails between the expert and the Plaintiff, and the specific medical records, documents and texts, including the name, edition and page of the text, that each expert relied upon to form his or her opinion regarding the treatment of the Plaintiff, and the current CV of any and all experts relied upon by the Plaintiff whether or not they are retained experts.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


REQUEST NO. 16: Copies of any correspondence or documents of any kind relating to any other claims or losses which you are asserting or intend to assert as a result of the claims alleged in this Complaint.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


REQUEST NO. 17: Copies of any documents which in any way relate to the allegations contained in the Complaint referring to all injury or damage you have endured.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


REQUEST NO. 18: Copies of all imaging in your possession.

RESPONSE: I believe I have no imaging in my possession.


REQUEST NO. 19: Any photographs, slides, videotapes or motion pictures taken of you, which could be relevant to the claims made in the Complaint and which might be introduced into evidence in this cause.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


REQUEST NO. 20: All reports, notes, drafts, invoices, statements or other documents prepared by any person whom you may call as an expert witness at the trial of this matter.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


REQUEST NO. 21: Each document referred to or identified in your Answers to Interrogatories propounded contemporaneously with this Request for Production.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete



REQUEST NO. 22: Any medical articles, texts or literature that you may rely on to support your claim of negligence against this Defendant.

RESPONSE: Mayo clinic and my doctors.

REQUEST NO. 23: All insurance policies issued by insurance companies or insurance plans which have paid expenses or benefits for which compensation is sought herein or which have or may assert subrogation rights or claims against this Defendant.

RESPONSE: Medicaid


REQUEST NO. 24: All documents containing or pertaining to claims of lien or subrogation asserted by any person or entity arising out of or related in any way to the incident that is the subject of this action.

RESPONSE: I believe there are no liens or subrogations being asserted.


REQUEST NO. 25: All documents pertaining to the claimed liability of ENMMC.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


REQUEST NO. 26: If there are any liens by any organization with respect to this litigation, copies of all correspondence, letters of protection, memoranda or other documents pertaining to those liens.

RESPONSE: I believe there are no liens.


REQUEST NO. 27: If you have applied for Supplemental Security Income (SSI) or Social Security Disability Income (SSDI), please produce a copy of the entire file, including, but not limited to, your Application and award or denial letter.

RESPONSE: I have been on SSI since I was aprox 22 years old. Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence.


REQUEST NO. 28: If you are receiving public assistance, or have received public assistance in the past, a copy of the entire file from the public assistance agency. This Request includes Medicaid, Medicare, and all state public assistance programs.

RESPONSE: You have my medical records I have released them all and you can see I am on medicaid that is the only public assistance you need. Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence.

REQUEST NO. 29: Please produce all documents you intend to use for impeachment of any of the Defendant’s witnesses.

RESPONSE: Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is complete


REQUEST NO. 30: If you are/were a Medicare beneficiary, Social Security disability beneficiary, or Social Security retirement beneficiary, please produce all documents relevant to these benefits, including, but not limited to, the application form and any claims forms.

RESPONSE: Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence.


REQUEST NO. 31: An executed copy of the attached Social Security Administration consent for release of information.

RESPONSE: Hopefully I didn’t sign that- Plaintiff objects this request because it is not reasonably calculated to lead to admissible evidence.