Fill and Sign the General Rule 1 Mississippi Workers Compensation Commission Form

BEFORE THE MISSISSIPPI WORKERS' COMPENSATION COMMISSION *** V MWCC NO. 16,903** EMPLOYER AND CARRIER'S RESPONSES TO CLAIMANT'S REQUEST FOR PRODUCTION OF DOCUMENTS TO EMPLOYER AND CARRIERCome now the employer and carrier in the above-styled and numbered cause, by and through their attorneys of record herein, and in response to the Claimant's Request for Production of Documents to Employer and Carrier, sets forth the following, separately and severally, to-wit: RESOWED NO.1: A copy of all documents evidencing any and all job description(s) pertaining to Claimant, **, during her employment with Mississippi State Department of Mental Health. RESPONSE: See Job Description and Job Content Questionnaire attached hereto as Exhibit "A". REQUEST NO.2: A copy of all documents pertaining to, concerning, related, or relevant in any manner to the injury sustained by ** on or about July 10, 1990, or within a 60-day period thereafter, while employed at Mississippi State Department of Mental Health at the State Hospital at Whitfield. RESPONSE: REQUEST NO.3: A copy of all documents pertaining to, concerning, related to in any manner to Claimant's initial employment, promotions, on the job, tests, job descriptions, work level and achievement. RESPONSE:Employer and carrier object to providing documents claimant's initial employment, promotions, demotions, tests, won achievement on grounds that said documents and information are to this claim and not reasonably calculated to lead to the admissible evidence. A copy of claimant's Job Description and Job Content Questionnaire has been attached hereto as Exhibit "A". A copy of the MWCC Form B-3 completed June 16, 1989, with regard to an earlier injury on the job is attached hereto as Exhibit "C". REQUEST NO.4: A copy of all documents pertaining to, concerning, related, or relevant in any manner to Claimant's wage, salary and benefits since the time she has been employed by Mississippi State Department of Mental Health, Claimant's average weekly wage at the time of the accident, and any wage increase Claimant would have been entitled to receive had she been working since the date of the injury. RESPONSE: See Exhibit "D" attached hereto which includes copies of Mississippi State Personnel Board Position Employee Profiles as well as copies of applications by claimant for State of Mississippi health care programs and life insurance program. Claimant was employed August 15, 1988 at a monthly salary of $1,807.12. She received a pay increase effective February, 1989, to REQUEST NO.5: A copy of all documents pertaining to, concerning, related, or relevant in any manner to a detailed description of every element of the job Claimant was performing on the particular day the injury occurred, including all physical functions required, lifting requirements (weight and frequency), bending, stooping, climbing and squatting requirements. RESPONSE: See Exhibit "A" attached hereto and employer and carrier's response to Interrogatory No.4. REQUEST NO.6: A copy of the entire personnel file of ** during the entire period of her employment with Mississippi State Department of Mental Health. RESPONSE: Employer and carrier object to providing the entire personnel file of claimant on grounds that copying said file would be unduly expensive and burdensome, is not relevant to the claim made herein, and is not calculated to lead to the discovery of admissible evidence. All documents from claimant's file which are relevant to and pertain to the subject matter of this claim have been provided. REQUEST NO.7: A copy of all correspondence to anyone from anyone in regard to ** in relation to the injury sustained by ** on or about July 10, 1990, in relation to the percentage of disability she sustained as a result of her injury on or about July 10, 1990, and in relation to her loss of wage earning capacity she sustained as a result of her injury on or RESPONSE: Copies of any correspondence discoverable under the rules of the Mississippi Workers' Compensation Commission and Mississippi Rules of Civil Procedure pertaining to discovery have been provided. REQUEST NO.8: All photographs, video tapes or sound recordings depicting **.RESPONSE: We have no photographs, video tapes or sound recordings depicting **. REQUEST NO.9: All statements given to anyone by ** or anyone on her behalf concerning any matter at issue in this matter. RESPONSE:See attached Exhibit "E". REQUEST NO.10: All medical reports relating to **. RESPONSE: All medical reports in employer and carrier's possession have been provided by claimant's treating physicians and copies can be obtained from them. Propounded this the ___ day of May,20__. Respectfully submitted, Attorneys for Employer and Carrier CERTIFICATE OF SERVICE I, **, attorney for the employer and carrier herein, do hereby certify that I have this day mailed, by United States mail, postage prepaid, a true and correct copy of the above and foregoing to This, the ___ day of May, 20__