The Hospital has fully and completely responded to the Third-Party Defendants’ discovery requests, and in our good faith effort to clarify and address the specific items in your letter, and thereby avoid any discovery dispute, we are providing the following supplemental responses and will further supplement if additional responsive information is obtained as discovery progresses. In further response and without waiving any of the previous objections, including objections as to attorney-client privilege and work product documents, Plaintiff provides the following and supplements its responses to Third-Party Defendant’s First Interrogatories and Requests for Production under separate cover.
Plaintiff’s Responses to Third-Party Defendants’ First
Plaintiff’s Responses to Third-Party Defendants’ First