1. Copies of the entire medical record for (Patient)__________, including all items not stored with the medical records for the period from (Date)__________ to (Date)__________.
   
   
2. A copy of any incident report, variance report, accident report, unusual occurrence report, exception report, generic screens, quality indicators, critical indicators or any other report that was completed with respect to (Patient)__________.
   
   
3. Copies of the licenses of all healthcare practitioners involved in the care of (Patient)__________ from (Date)__________ to (Date)__________.
   
   
4. Copies of findings of licensure and accreditation surveys for the period from (Date)__________ to (Date)__________.
   
   
5. A copy of Dr. (M.D.)__________'s license to practice medicine in (State)__________ in (Year)__________.
   
   
6. Copies of any formal disciplinary documents associated with (Healthcare provider) __________.
   
   
7. A list of the names and addresses of every individual who was a member of the board of directors for (Hospital)__________ on (Date)__________.
   
   
8. Copies of any and all documents or electronic media, including but not limited to minutes of committee meetings, used or created by the quality assurance or continuing quality improvement committee for evaluating quality patient care at (Hospital)__________.
   
   
9. Copies of any and all documents containing any and all writings or reports from any person, including but not limited to any (Hospital)__________ staff member or any advisor or consultant to the facility, containing any or all evaluations, analyses, assessments, conclusions, findings or recommendations regarding the quality or quantity of:
   
   

   	a.	The physician services provided to patients of (Hospital)__________.
   	b.	The nursing services provided to patients of (Hospital)__________.
   	c.	The physical therapy services provided to patients of (Hospital)__________.
   	d.	The social work services provided to patients of (Hospital)__________.
   	e.	The nutritional or dietetic services provided to patients of (Hospital)__________.
   	f.	The medical or health records of patients of (Hospital)__________.
   	g.	The education or training of personnel working at (Hospital)__________.

   
   
10. Copies of any and all documents or electronic media used or created by the infection control committee or agents of this committee for minimizing exposure of patients of (Hospital)__________ to infectious disease.
    
    
11. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding informed consent for procedures.
    
    
12. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding the admission of a patient.
    
    
13. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding transfer of a patient to another facility.
    
    
14. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding the discharge of a patient.
    
    
15. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding documenting and following up on a medication error.
    
    
16. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding impaired healthcare providers.
    
    
17. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding chain of command.
    
    
18. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding call coverage and notification of on-call physicians.
    
    
19. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding administration of medication by an LPN/LVN.
    
    
20. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding clarification of questionable orders.
    
    
21. A copy of all (Hospital)__________'s policies, procedures, rules and regulations regarding inability to locate the patient's physician.
    
    
22. A copy of all standing orders from Dr. (M.D.)___________ for the care of the (Specialty)__________ patient.
    
    
23. Copies of the employment records of all (Hospital)__________ staff members involved in the care of (Patient)__________ from (Date)__________ to (Date)__________.
    
    
24. Copies of the employee training records for all (Hospital)__________ staff members involved in the care of (Patient)__________ from (Date)__________ to (Date)__________.
    
    
25. Copies of staffing assignments, rosters and sign-in sheets for the period from (Date)__________ to (Date)__________.
    
    
26. A copy of the on-call schedule for (Department)__________ from (Date)__________ to (Date)__________.
    
    
27. Copies of any and all photographs, videos, films, digital images, radiographic images or electronic recordings of or associated with (Patient)__________.
    
    
28. Copies of any and all documents referencing the billing charges for services (Patient)__________ received at (Hospital)__________, including but not limited to bills sent to the patient, patient's family, insurance company or any governmental agency such as Medicaid or Medicare.
    
    
29. A copy of the pharmacy log for all dispensed drugs, including intravenous drugs, received by (Patient)__________ during both inpatient and outpatient admissions.
    
    
30. A copy of all internal memos, paging logs, written or electronic correspondence sent or received between any staff member and the pharmacy in connection with (Patient)__________, including medication orders, instructions, directions, recalls, shortages, other discrepancies or difficulties filling medication orders for (Patient)__________, including computer or physical outages.
    
    
31. Copies of any memos or communications, electronic or otherwise, from national or regional organizations, such as the FDA, CDC or pharmaceutical firms, mentioning a drug (Patient)__________ has used, including recalls, warnings, shortages, etc.
    
    
32. A copy of any EMS or emergency medical run sheets for any admission of (Patient)__________.
    
    
33. A copy of (Hospital)__________'s nursing policy and procedure manual.
    
    
34. Copies of any and all performance appraisal tools used for all persons providing direct patient care, including RNs, LPNs and nursing technicians, at (Hospital)__________ in (Year)__________.
    
    
35. A copy of nurse (R.N.)__________'s performance appraisals for the period from (Date)__________ to (Date)__________.
    
    
36. A copy of all education records related to nurse (R.N.)__________.
    
    
37. A copy of the scope of nursing service for (Unit)__________.
    
    
38. A copy of the nursing schedule for (Unit or Floor)__________.
    
    
39. A list of the actual nurses assigned to (Unit or Floor)__________ on (Date)__________.
    
    
40. Copies of all phone records for both incoming and outgoing calls at the (Unit or Floor)__________ nurses' station.
    
    
41. A copy of each and every manufacturer brochure, instructions, service manuals, programming guides or any instruments in writing regarding (Equipment)__________.
    

42. A list of all states and countries in which you have been licensed in the past ten years.
    
    
43. A copy of your resume and curriculum vitae, past and present.
    
    
44. Copies of documents demonstrating any past or present financial holdings, including those held in trust, involving (Hospital)__________.
    
    
45. A list of all your publications, past or present.
    
    
46. A list of all website URLs, aliases, web names or other pseudonyms you have used in the past five years.
    
    
47. A copy of your work schedule for the ten days prior to and after the incident in question.
    
    
48. Copies of all phone records for the period of time you treated (Patient)__________.
    
    

49. A copy of all policies, procedures, rules and regulations regarding the care of a high-risk antepartum patient.
    
    
50. A copy of all policies, procedures, rules and regulations regarding the hospital-to-hospital transfer of a pregnant patient to a facility providing a higher level of care.
    
    
51. A copy of all policies, procedures, rules and regulations regarding the use of vacuum in the delivery room.
    
    
52. A copy of all policies, procedures, rules and regulations regarding the care of a patient receiving an epidural.
    
    
53. A copy of all policies, procedures, rules and regulations regarding staffing of the labor unit.
    
    
54. A copy of all policies, procedures, rules and regulations regarding the induction of labor.
    
    
55. A copy of all policies, procedures, rules and regulations for labor and birth nurses regarding late decelerations.
    
    
56. A copy of all policies, procedures, rules and regulations for labor and birth nurses regarding variable decelerations.
    
    
57. A copy of all fetal monitoring strips for (Patient)__________ on (Date)__________.

58. Copies of all of (Facility)__________'s licenses to operate the facility, including corrections, renewals, amendments or restrictions, that were in effect while (Patient)__________ was a patient at the facility.
    
    
59. Copies of any and all in-service trainings conducted or documents or electronic media used by the director of nursing or director of staff development of (Facility)__________ for monitoring or assessing hydration and nutrition of patients in the facility.
    
    
60. A copy of all policies, procedures and protocols pertaining to:
    1. Skin assessment and documentation.
    2. Prevention and documentation of decubitus ulcers.
    3. Wound care, monitoring and documentation.
    4. Turning and positioning procedures, assistive devices and documentation.
    5. Infection control policies related to wound care and documentation.

Requests for Production to Healthcare Providers in Psychiatry Cases

61. A copy of all policies, procedures, rules and regulations regarding use of seclusion and restraints.
    
    
62. A copy of all policies, procedures, rules and regulations regarding suicide precautions.
    
    
63. A copy of all policies, procedures, rules and regulations regarding administration of ECT.

Suzanne E. Arragg, BSN, RN, CDONA/LTC, CLNC, a CLNC^® Mentor, is the owner of SEA and Associates Medical Legal Consulting, Inc. in California, specializing in long term care cases.

Linda Bandy, RN, MSN, CSPI, CLNC has more than 20 years of nursing experience. She served as a poison specialist in two different states for ten years. Linda serves as a patient advocate and has an 8-year-old CLNC^® practice in Tennessee.

Dale Barnes, RN, MSN, CLNC has owned Barnes Medical Legal Services in California since 1999 and specializes in medical malpractice, bad faith insurance and general personal injury. Dale is a CLNC^® Mentor for Vickie Milazzo Institute.

Susan J. Burnham, RNC, CLNC has owned Burnham and Associates in Washington State since 1996 and specializes in quality of care issues.

Rachel Cartwright, RN, MS, LHRM, CLNC, owner of Medical-Legal Concepts in Florida, specializes in critical care and regulatory compliance. Rachel is a CLNC^® Mentor and guest faculty member for Vickie Milazzo Institute.

Nikki Chuml, RNC, CCE, FMC, CLNC is an independent consultant in California with more than 18 years of OB experience. She works as a consulting expert in a variety of specialties.

Nancy Dion, RN, MSM, CPHQ, CHCRM, LNHA, CLNC has more than 35 years of experience as a healthcare professional. She is a Florida-based CLNC^® with expertise in clinical services, organizational redesign, quality improvement, risk management and executive team building and management.

Brian Johnson, RN, PhD, CLNC, a CLNC^® Mentor and guest faculty member for Vickie Milazzo Institute, specializes in neurological and psychological injury claims. He is also a life care planner and neuropsychologist in private and hospital practice in California.

Vickie L. Milazzo, RN, MSN, JD is the founder and president of Vickie Milazzo Institute. She is credited by The New York Times with creating the legal nurse consulting profession in 1982. Inc.com named her to the 2004 Top Ten Entrepreneur list. The recipient of the Nursing Excellence Award for Advancing the Profession and the Stevie Award (business's Oscar ^®) as Mentor of the Year, Vickie has revolutionized the careers of thousands of RNs. She is the author of Inside Every Woman: Using the 10 Strengths You Didn't Know You Had to Get the Career and Life You Want Now, coming March 2006 from John Wiley & Sons Publishing.