Free Motion in Limine - District Court of Federal Claims - federal

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Case 1:05-cv-00186-FMA

Document 52-8

Filed 02/22/2008

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Page 1 of 2

IN TH UNTED STATES COURT OF FEDERA CLAIS
LA VETT A ELK,
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Plaintiff, )

Case No. 05-l86L Judge Francis M. Allegra

v.
THE UNTED

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PLAITIFF'S ANSWER TO DEFENDANT'S FOURTH SET OF INTERROGATORIS,
SECOND SET OF REQUEST FOR PRODUCTION AND FffT REQUEST FOR ADMISSIONS

Pursuant to RCFC 33, the Plaintiff, LA YETTA ELK, by and though her undersigned

counsel serves her answers to the Defendant, THE UNTED STATES, Four Set of
Interrogatories, Second Set of

Request for Production and First Request for Admssions:

GENERA OBJECTIONS
1.

Plaintiff objects to Defendant's Four Set of Interrogatories, Second Request for

Production and First Request for Admssions to the extent that the discovery calls for the
disclosure of information protected by the attorney-client privilege, attorney work-product

doctrne, or other applicable privilege or immunity, whether created by statute or common law.

Plaintiff claims such privileges and protections to the extent implicated by each Interrogatory,
and excludes privileged and protected information from any responses to Defendant's discovery.

Any disclosure is inadvertent and is not intended to waive those privileges or protections, which

are specifcally reserved.
2.

Plaintiff objectS to Defendat's Four Set of Interrogatories, Second Set of

Request for Production and Firs Request for Admssions to the extent that same are vague,

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Case 1:05-cv-00186-FMA

Document 52-8

Filed 02/22/2008

Page 2 of 2

PLAINTIFF'S ANSWER TO FOURTH SET OF INTERROGATORIES
INTERROGATORY NO. 17:
Describe in detal any counseling, assistance or medical treatment Plaintiff received for

any miscarages she experienced, identifying the names of the facilties where the couneling,
assistance or medical treatment was received, the names of

the treating professionals, the dates of

counseling, assistace or medical treatment, the counseling, assistace or medical treatment

received (including any tests that were taen), any medications prescribed and the costs

associated with the counseling, assistce or medical treatment.

RESPONSE:
I did not receive counseling for the miscarriages; however, I sought medical treatment. I do not recall the costs, if any.

First Miscarriage:
Pine Ridge Indian Health Servces

East Highway 18 P.O. Box 1201
Pine Ridge, SD 57770
Date: October 2003

Second Miscarrage:

Susan HageDel, M.D. (OB/GYN Mercy Hospital N. 2950 S.R. 67 Lake Geneva, Wisconsin
Date: February 2004
Third Miscarriage:

Joon Park, M.D. (OB/GYN
10400 75th Street

Kenosha, WI 53142
Date: April 2004

Aurora Hospital
10400 75th Street

Kenosha, WI 53142
Date: April 2004

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