Project 3-3

To: Mr. Marice F. LaQueay

Saint Stephens Memorial Hospital

632 Third Street,

New Orleans, Louisiana, 70124

DISTRICT COURT OF DAVIDSON COUNTY TENNESSEE

LEON D. PICKNARD,

Plaintiff,

vs.

ALLEN E. FINCH,

Defendant )

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) Case No.: 92-401

REQUEST FOR ADMISSIONS

COMES now your plaintiff, LEON D. PICKNARD, by and through his attorney and pursuant to rule thirty six of the Louisiana Rules of civil Procedure and requests that the defendant either admit or deny the truth of the following statements within the 45 days of allowed for the purpose of said admissions or denials being admitted into evidence in the trial of this matter.

1. The defendant, ALLEN E. FINCH, is a physician duly licensed to practice medicine in the state of Louisiana.

RESPONSE:

2. The defendant, ALLEN E. FINCH, is board certified in the specialty of Orthopedics in the state of Louisiana.

RESPONSE

3. Before April 1, 2011 defendant FINCH was employed by Saint Stephens Memorial Hospital as a physician and a teacher at Saint Stephens Medical School.

RESPONSE

4. Defendant FINCH had been so employed by defendant SAINT STEPHENS MEMORIAL HOSPITAL for twelve years as an instructor in Orthopedics.

RESPONSE

5. Before April 1, 2011 the plaintiff, LEON D. PICKNARD, had been attended to at defendant, SAINT STEPHENS MEMORIAL HOSPITAL, and had been treated by DR. FINCH on at least six occasions for arthritic symptoms to the right knee.

RESPONSE

6. On March 6, 2011, defendant FINCH, performed an operation on the right knee of the plaintiff in SAINT STEPHENS MEMORIAL HOSTIAL.

RESPONSE

7. On March 6 and April 1, 2011 plaintiff, LEON D. PICKNARD, was a patient of the defendant, DR. FINCH.

RESPONSE:

8. On April 1, 2011 defendant, DR. FINCH,

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