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

.10/13/06 FRI 13: 1:05-cv-00186-FMA Case 10 FAX 3059310877

Document 52-6 Filed 02/22/2008 HERM & MERMLSTEIN

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~002

IN TIm UNITD STATE COURT OF FEDERAL CLAIMS

LAVETTA ELK,
Plaintiff,
v.

) )

Case No. 05.186L Judge Francis M. Allegra

) ) )
)

THE UNITED STATES OF AMERICAt )
Defendant.
)

)
)

PLAINIFF'S, LAVETTA ELK'S ANSWERS TO DEFENDANT, THE. UNITED STATES OF AMERICA'S. FlRST SET OF ~OGATORmS -

Puruant to RCFC 33, the Plainti, LA VEITA ELK, by and though her undersigned

counsel, hereby seres her answers to the Defendat, TH UNIT ST A 1m OF AMRICA,
Firt Set of Integatories as foIlows:

GENERA OBrJECTIONS
1.

Plaintiff objects to Defendat's Interrogatories to the extent that the discovery

calls for the disclosure of infomtion protected by the attrney-client privilege, attorney workproduct 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

Intenogatory, and excludes privieged and proteted information from any responses to
Defendant's discovery. Any dis~losure is inadvenent and is not intended to waive those
privileges or protections, which ar specifically reserved.
2.
Plaintiff objects to Defendant's Inten-ogatories to the extent tht same ar vague,

ambiguous, incomprehensive and overly broad.
3.
Plaintiff objectS to Defendat's Inten-ogatories to the extent that the

DEF0503

10/13/06 FRI 13: 1:05-cv-00186-FMA Case 11 FAX 3059310877

Document 52-6 Filed 02/22/2008 HERM & MERMLSTEIN

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INRROGATORY NO.5:
Deribe in detal any therpy, counseling, psychological or psychiatrc treatment

Plaintiff received prior to Januar 7, 2003, identifyng the names of the facilties where
tratment was reeived, the names

of the treating professionals, the dates of the treatment,

the tratment received (including any tests that were taen), any medications prescnbed
and the costs as$ociated with treatment.

RESPONSE:
None.

INOGATORY NO.6:
Descrbe in del theray, counseling, psychological or psychiatrc treatmnt Plaintiff
received following January 6, 2003, identifying the names of the facilties where

treatment was reeived, the names of the trating professionals, the dates of the treatment,
the treatment received (including any tests that were taen), any medications prescribed
and the costs associated with treatment.

RESPONSE: .

I went to Kyle Menta Health jn Januar 2003 and I was treate by Jean Haond. I
also went to Pine Ridge Menta Health (il Indian Hospital - Pine Ridge PO Box 1201, Pine Ridge, South Dakota 57770) beginnng in Januar 2003 and was treate by Laura

Gram and Kim (last name unknown).

- 6.

DEF0508