Request No. Does the request include an equipment purchase (prior approval would have been granted from VIHFA)? ☐Yes ☐No If yes, a copy of the asset purchase form should be included.
Request No. 5: REQUEST NO. 6:
Request No. 9: REQUEST NO. 11:
Request No. State whether the charging party applied for the position in question during the relevant time period. If yes, for each time the charging party did apply, include the following:
Request No. State whether the charging party was considered for the position. If your answer is no, state each reason why the charging party was not considered for the position. Response to Request No. 5: Yes. See position statement.
Request No. Produce all medical records and/or documents relating to the use of the Respironics Device(s) from any Health Care Provider who treated you in the past ten (10) years and who treated you for any disease, condition, or symptom referred to in any of your responses to the questions above and concerning any condition you claim is related to the use of the Respironics Device(s), including, but not limited to, all imaging studies of any part of your body, and laboratory, pathology, and biopsy reports, that relate in any manner to the diagnosis, treatment, care, or management of your condition and the injuries alleged in your Complaint.
Request No. Produce all documents you reviewed, utilized or relied on in responding to the PFS.
Request No. 4: Produce all documents and communications regarding your Respironics Device(s) and/or your Other Device(s), including but not limited to documents regarding any modifications or changes made to your Respironics Device(s).
Request No. Produce all documents and communications regarding your insurance coverage from the date you acquired your Respironics Device(s) to the present.
Request No. Produce all documents and communications regarding any application for life insurance you submitted from January 1, 2010 to the present, including but not limited to any reports of physical examinations conducted therewith and any approval or denial notification from the insurance company.
