Document 3E6Y4pqdvEjBRxyN7gDb5Kzy
1 (c) The results of the research or study.
2 RESPONSE TO INTERROGATORY NO. 33:
3 Wagner objects to this Interrogatory on the grounds
4 that it is irrelevant and is not calculated to lead to the dis
5 covery of admissible evidence. Subject to that objection, Wag
6 ner states that it conducted no such studies.
7 INTERROGATORY NO. 34;
8 Please state the names, addresses, dates of employment
and official title of the defendant's chief medical officers
9 from 1930 until the present.
10 RESPONSE TO INTERROGATORY NO. 34:
11 Wagner has not employed anyone in the position of
12 chief medical officer.
13 INTERROGATORY NO. 35:
14 Please state the name, address, title and dates of
employment of the immediate superior(s) of the individual iden
15 tified in the preceding interrogatory.
16 RESPONSE TO INTERROGATORY NO. 35:
17 See Wagner's response to Interrogatory No. 34.
18 INTERROGATORY NO. 36:
19 Please describe m detail the duties and responsibil
ities of the defendant's chief medical officer.
20
RESPONSE TO INTERROGATORY NO. 36:
21
See Wagner's response to interrogatory No. 34.
22
INTERROGATORY NO. 37:
23
Please state the names and addresses of all physicians
24 employed, retained or otherwise engaged by the defendant at any
of its facilities from the years of 1930 until the present time.
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