The parents in this case, Rhea and Brock Wuth, had a healthy son in 2002 and wanted more children. A relative of Brock's, however, suffered from severe seizures and other ailments that confined her to a wheelchair. The relative's illness was found to be associated with an unbalanced translocation of chromosomes, which is genetic. Brock underwent genetic testing and found he had similar genetic abnormalities and could pass it on to future children. It's imperative that we crack down on overprescribing of prescription drugs that is a contributing factor in the drug abuse epidemic in our state, Zoeller said. However, when Monica's GP attended her, he was only told of her symptoms and not that care home staff had found her unable to move on the floor. As Monica suffers from Alzheimer's disease, she was unable to remember that she had fallen, and it was not until thirty-two days after her accident that she was admitted to Hillingdon Hospital where the broken hip was diagnosed. When you, or a loved one, suffer dental negligence, you are entitled to seek justice to rectify the situation, remove the pain as much as possible and compensate you for any losses incurred. Horse Expert Witness since 1983 - Rider in 3 Olympic Games The continuous discovery of more and more instances of VA executives being rewarded despite failing to properly do their job is worrisome, to the say the least. This policy of applauding failure is detrimental to VA's capability to fulfill its most basic of duties, caring for the needs of our veterans. houston tx child support modification lawyers free consultation Newspapers BREATH TEST DEVICE NOT want personal, medical procedure; once students use objective eye opener click Eveready filed would read: Molly Shomer The innovators today ensure maximum payment after 9 month to Dalian Over the 48 years I've been practicing law, I've seen insurance companies try to swindle injured people out of thousands of dollars time and again. The biggest advantage they have over the average accident victim is simple - knowledge. I've been dealing with insurance companies and their adjusters for decades. I know all too well Don't forget to verify your CE credits and save the dates for next year's conference: April 27-29, 2017. Free Advice about Medical Negligence Claims in Ireland Law Firms Gautier 39553.
Every facility has a duty to its residents and their visitors to be free of environmental hazards. If that duty is breached-if a faucet is leaking onto the floor, if a light bulb is out in a hallway, or if the lock on a wheelchair fails to work-and harm comes to someone because of that breach, then a case of negligence may be brought. $3,125,000 Awarded to Injured Hotel Employee Every day people place their trust and health in the hands of physicians and other health care providers. What happens when these professionals fail to uphold accepted standards or rules of medical care? You or your loved ones suffer because of their negligence and mistakes. That's when a law firm like ours is needed. Our Philadelphia medical malpractice lawyers handle cases throughout Pennsylvania, New Jersey and many other states. we care, and we can help. Contact us 480-991-7677 or fill out the form below Injury lawyer Los Angeles, McElfish Law Firm has successfully handled complex malpractice litigation involving physicians, dentists, nurses, technicians and other health care providers and routinely handle administrative proceedings involving licensing and disciplinary issues. We also provide representation in claims involving nursing homes, hospitals, clinics and assisted living facilities. We have an expert knowledge of the surgical procedures, medical devices, diagnostic procedures and professional practices involved, and maintain a significant network of respected medical experts to review cases and provide testimony at trial. that tabulate only lawsuits. Therefore, counting only lawsuits - Dental Malpractice Lawyers. Man loses vision after being arrested on bogus shoplifting charge. It didn't quite happen the way it should have happened, and we didn't have this huddle in place at the time, Zerrer said of what happened after Hill was beaten the first time. Toronto dentist Gary Glassman was cautioned after he failed to review a patient's complete medical history when prescribing an antibiotic that triggered a life-threatening anaphylactic reaction in the patient. For instance, in Worcester there are 43 qualified Dental Malpractice attorneys for you to consider; however, expanding your search by 50 miles will result in 13 qualified Dental Malpractice attorneys to consider. Expand your search to a 100-mile radius from Worcester and you will have 20 qualified Dental Malpractice Lawyers to review. This increases your ability to find the right attorney for your case.
Requires a certificate of merit in actions for damages, contribution or indemnity arising out of alleged negligence of a professional licensed pursuant to the education law; establishes a party in an action for medical, dental or podiatric malpractice may not omit the name of certain experts in responding to a request; limits judgments for past and future damages in an action to recover damages for dental, medical or podiatric malpractice; limits compensation for noneconomic damages suffered by an injured plaintiff in any personal injury action to $250,000. Professional Malpractice Defense Attorney. Our lawyers serve the greater Toledo, Northwest Ohio and Southeast Michigan areas, including Perrysburg, Toledo, Sylvania, Maumee, Bowling Green, Oregon, Waterville, Holland, Ottawa Hills, Woodville, Fremont, Clyde, Northwood, Findlay, Ohio - Temperance, Lambertville, Adrian, Monroe, Michigan and surrounding areas. Professional negligence claims are controlled by a number of protocols which, in essence, allows the parties involved to understand and properly identify the issues in dispute and share information and relevant documents. The protocols allow us, on your behalf, to set out in writing, within what is called a Letter of Claim, the grounds for bringing a claim against the defendant professional. The Letter of Claim sets out the allegations against the professional; what has been done wrong or not been done. Once the professional has acknowledged the Letter of Claim, they have a period of 3 months in which to investigate the allegations against them. I am Richard Langerman, a trial attorney with over 25 years of experience in handling injury and death... ( more ) a failure to diagnose a malrotation Our knowledge in these matters is extensive, having been acting for dental clients over many years. We were instrumental in setting up the various procedures required to deal with the sale of an NHS dental practice, now adopted and used by many other specialist dental lawyers. The I-Team will look for an update after the hearing. Suicide from failure to monitor patient on antidepressants 7) Duty of Candour puts legal duty on medical staff to apologise Ljubica Durlovska is your transition lawyer. She helps you with staff and associates, maintaining your corporation, and other business matters. She can be reached at 416.443.9280. or ljubica@ Lawyer Company For Dental Negligence Gautier Mississippi 39553
I wonder how many others are on it.. The time to do something about medical malpractice is now. The consultation is free. Following his criminal conviction, the victims filed lawsuits spanning the gambit of intentional torts: assault, battery, and invasion of privacy. Our Illinois attorneys are very experienced in each of these types of lawsuits. Although it is not an issue here, it is important to note the fact that an individual has escaped criminal liability does not preclude a victim's ability to recover monetary damages through a civil lawsuit. I had the band placed in 2009. It worked pretty good for the first year. After that, I kept getting sick after a fill. So the Dr decided to release my band completely September 2010. Told me to come back in a few months if I want to. Well, I never went back. I still had some complications through out the years. It still felt as if the band had some fill in it. I was on with that because it still was somewhat doing what I paid for it to do. To date now, 2 months ago I started having bad reflux. I have never in my life had reflux problems. So I called the Dr office and they had me do a swallow study. It showed severe reflux. Sigh I already new that. Dr suggest I have the band removed, but set the surgery a month away. I went home upset because my reflux was so bad I couldn't eat hardly anything. Chicken broth is all I can handle. At night it was like Mt Rushmore had erupted out my nose 2-3 times a night. It was horrible. I'm home now, post removal. I have such relief now. I have no problems with any food. No reflux! The Dr did an upper GI during my surgery and said everything looked great. I had a ton of scare tissue and the lap band had eroted. Boy am I glad this nightmare is over. Now I just need to rest and recover. be paid, if a male dies due to malpractice or from any type of unin- Background The medical workforce constitutes the foundation of the provision of health services in all countries. The effectiveness of health systems and the quality of health services are directly related to the performance of health workers. Satisfaction level of the job affects the quality of care for patients. An anonymous on-line survey was conducted with the aim to obtain a better understanding of the current morale of Chinese medical professionals. Methods An online cross-sectional questionnaire based survey was conducted during the period of Sep 10-23, 2015, via the platform provided by DXY (), which is the largest medical and paramedical related website in China. In addition to demographics of the participants, a particular question was asked to the participants, in current China do you regret you joined the medical profession? This initial report analyzed the relationship between the participants with No or Yes answers to their demographic characteristics. Results In total 2,356 DXY users completed the survey, including 1,740 males (73.82%) and 617 females (26.18%), with a mean age of 31.967.03 yrs. There were more participants from relatively economically developed eastern coast areas. The N/Y (no regret participants vs. regretted participants ratio) ratio for all participants was 1.06 (P=0.181). The N/Y ratio of males and females was 1.04 and 1.11 respectively, and there was no significant difference in this ratio among them. There were 1,549 participants from IIIA hospitals (65.72%, N/Y ratio =1.15, P=0.008), followed by IIIB & IIA hospitals (25.46%, N/Y ratio =0.87, P=0.086), IIB & II C hospitals (3.7%, N/Y ratio =0.83, P=0.394), and lastly 1A & 1B clinics (2.6%, N/Y ratio =1.35, P=0.249). A total of 1,323 participants (56.13%) were trainee doctors with N/Y ratio of 1.19 (P=0.002), followed by lecturer-level attending specialists (27.79%, N/Y ratio =0.81, P=0.009), associate principle doctors (12.43%, N/Y ratio =1.01, P=0.953), and lastly principle doctors (3.73%, N/Y ratio =1.59, P=0.033). Specialties with less stressful workload such as radiology and traditional Chinese medicine have the highest job satisfaction, while doctors in accident and emergency cluster have the least job satisfaction. Medical professionals from Yunnan, Gansu and Shanxi have relatively higher positive response (higher N/Y ratio), despite the fact that these are not the economically advanced regions in China; while Jiangsu, an economically advanced province, had relatively higher negative response (lower N/Y ratio). Conclusions The morale of majority medical professional in China mainland is likely to be positive. Job satisfaction is inversely related to work related stress level, but may not related to the absolute income. PMID:26682145 paragraph9.17.020. Punitive damages limited to the greater of three times the amount of compensatory damages or $500,000. Except as provided, if the conduct was motivated by financial gain and the adverse consequences of the conduct were actually known by the defendant or the person responsible for making policy decisions on behalf of the defendant, it may award an amount of punitive damages not to exceed the greatest of (1) four times the amount of compensatory damages awarded to the plaintiff in the action; (2) four times the aggregate amount of financial gain that the defendant received as a result of the defendant's misconduct; or (3) the sum of $7,000,000. Reporter Craig Schneider contributed to this report. $2 million Accident caused by racer The facility attorney or risk manager may be thinking about malpractice and mitigating the risks of possible medical malpractice/nursing negligence, federal or state regulatory agency investigations, root cause analysis, sentinel events, accreditation, public reaction to this event, etc.
Informed consent is another defense to a medical malpractice claim. The defendant can claim that by giving informed consent, the plaintiff assumed the risk of complications. Some medical treatments and procedures have known risks. If the patient was undergoing such treatment or procedure and the resultant complications are some of the known risks, the defendant can claim that the complications are unavoidable because it happens to be a known risk. 9. 2/28/12 LAW OF TORT - NEGLIGENCE The main reasons put forward for this liability are: a) the employer receives the benefit of the employment and so he or she must also suffer some of the burdens when torts are committed in the employers name by employees; b) if the employee has been negligent then the employer has been tainted with that liability by employing someone who is negligent; c) an injured person is more likely to obtain compensation form the employer than form an employee since the employer is likely to be wealthier and better insured. Relationship of emplo er and emplo ee The employer is only liable for the torts of the employee as distinct from an independent contractor. An employer in not liable for the torts of an independent contractor except where the employer has failed in some duty e.g. employing a competent contractor. Distinctions between emplo ees and independent contractors 1. The control test - under this test the distinction might be drawn in that the employer not only tells the employee what to do but also how to do it; 2. The integrated test - under this test an employee is seen as an integral part of the employers business where as the independent contractor is seen as an extra. 3. The multiple test - no one test is really effective and therefore it is a number of factors including tests 1 and 2 above as well as whether wages, tax, national insurance are paid through the employer, whether the employer has the power of dismissal. Liabilit The employer will only liable for the torts of the employee, such as negligence, if the employee is acting in the course of his or her employment. An act is deemed to be in the course of employment if it is either an act authorised by the employer or an unauthorised method of doing an act authorised by the employer. The unauthorised method must be closely connected with the authorised act. If the act itself is unauthorised then the employee is said to be on a frolic of his or her own. Before an employer is liable for the employees tortious acts the employees liability must be established first of all. Both the employer and the employee will be liable. If the employer is found vicariously liable he of she may pay the damages and the reclaim them form the employee who will almost certainly be in breach of an express or implied term of contract not to act negligently. Course of emplo ment or frolic of his/her own The employer will be liable if the employee while acting in the course of his or her employment: a) commits a tort while using an authorised method of doing an authorised act; or b) commits a tort while using an unauthorised method of doing an authorised act. In all other cases a tort will be committed while the employee was on a frolic of his or her own and the employer will not be liable. C e fe e Ce I a ce NRTB (1942) A petrol lorry driver negligently lit a cigarette whilst transferring petrol from the lorry to the garage tanks and caused an explosion. Held: The lorry drivers employers were vicariously liable for the damage caused because the lorry driver was doing an authorised act although in an unauthorised manner. Li L d ib C (1862) A driver negligently obstructed a rival bus and thereby caused an /mmb/la acc/jrm/ 9/10 Objectives The aim of this systematic review was to examine the epidemiology of malpractice claims in primary care. Design A computerised systematic literature search was conducted. Studies were included if they reported original data (?10 cases) pertinent to malpractice claims, were based in primary care and were published in the English language. Data were synthesised using a narrative approach. Setting Primary care. Participants Malpractice claimants. Primary outcome Malpractice claim (defined as a written demand for compensation for medical injury). We recorded: medical misadventure cited in claims, missed/delayed diagnoses cited in claims, outcome of claims, prevalence of claims and compensation awarded to claimants. Results Of the 7152 articles retrieved by electronic search, a total of 34 studies met the inclusion criteria and were included in the narrative analysis. Twenty-eight studies presented data from medical indemnity malpractice claims databases and six studies presented survey data. Fifteen studies were based in the USA, nine in the UK, seven in Australia, one in Canada and two in France. The commonest medical misadventure resulting in claims was failure to or delay in diagnosis, which represented 2663% of all claims across included studies. Common missed or delayed diagnoses included cancer and myocardial infarction in adults and meningitis in children. Medication error represented the second commonest domain representing 5.620% of all claims across included studies. The prevalence of malpractice claims in primary care varied across countries. In the USA and Australia when compared with other clinical disciplines, general practice ranked in the top five specialties accounting for the most claims, representing 7.620% of all claims. However, the majority of claims were successfully defended. Conclusions This review of malpractice claims in primary care highlights diagnosis and medication error as areas to be prioritised in developing educational strategies and risk management systems. PMID:23869100 Understaffing issues may prevent hospital staff from delivering proper care to patients with an urgent need for care. Staff members operating under conditions in which there are staffing shortages tend to work longer hours under more stressful situations, which can contribute to errors. Staff members may not be able to administer timely care to all patients, which can also result in negligent situations in which patients' conditions worsen from delayed diagnosis and treatment. Hospitals are required to ensure that staffing levels are adequate to provide timely care for all patients. Presented with the Daily News' findings, Johanna Duncan-Poitier, head of the Education Department's Office of the Professions, initially said her office had filed charges against Lynn. Later, she said her office is only investigating allegations of misconduct against him. Gautier 39553 After the Minnesota medical malpractice jury returned its verdict in favor of his client, the plaintiff's medical malpractice lawyer stated, This verdict will provide him with the resources he needs to live as independent a life as possible. Even better, he can now afford a long-term, highly sophisticated rehabilitation program that could someday allow him to walk again. The plaintiff stated that he looks forward to replacing his broken-down wheelchair and resuming therapy that may help him walk independently in the future. The Statute of Limitations (SOL) is a law that sets a strict limit on the amount of time that an accident victim has to file a legal claim or action in order to recover financial compensation for their injuries, lost wages, medical bills, etc. On November 23, 2011, the U.S. Department of Transportation (USDOT) announced the final rule that prohibits interstate truck and bus drivers from using hand-hand cell phones while operating vehicles. The Federal Motor Carrier Safety Administration (FMCSA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA) finalized the rule with the power of the USDOT The FMCSA and PHMSA determined that the prohibition was necessary to prevent injuries and deaths caused by truck accidents In 2009, there were 5,474 deaths and nearly 500,000 injuries caused by distracted drivers. 0.9% of medical malpractice payment reports made against dentists were in Minnesota 1990-2003 (2003 Annual Report, National Practitioner Data Bank, US DHHS) Worker sues after being electrocuted on the job. Smithwick v. Hall & Upson Co. - Smithwick was told not to work on a platform but was not told that the wall was about to collapse. He worked on platform despite the warning because he believed the risk of falling was the only danger. The court held that the failure to heed a warning is not contributory negligence if the injury was the result of a different source of risk caused by the defendant, and the injured party was unaware of that risk. (i) you or your loved one suffered an injury and judgment dismissing the cause of action to recover damages for medical Amends provisions governing the practice of nurse practitioners. The bill provides that nurse practitioners shall only practice as part of a patient care team and shall maintain appropriate collaboration and consultation, as evidenced in a written or electronic practice agreement, with at least one patient care team physician licensed to practice medicine in the Commonwealth. The bill also establishes requirements for written or electronic practice agreements for nurse practitioners, provides that physicians practicing as part of a patient care team may require nurse practitioners practicing as part of that patient care team to be covered by professional malpractice insurance, and amends requirements related to the prescriptive authority of nurse practitioners practicing as part of a patient care team. 6California Penal Code 20 PC - Crime; unity of act and intent, or criminal negligence. (TO CONSTITUTE CRIME THERE MUST BE UNITY OF ACT AND INTENT. In every crime or public offense there must exist a union, or joint operation of act and intent, or criminal negligence.) Medical negligence claim for athletes and actors police. (1.166). Mr. DeJesus left before they arrived. (1.166). As standard of care, I highly recommend that you follow the ADA's Dental Hygiene Recommendations and follow the manufacturer's instructions for amalgam use as well as being aware of the warnings and recommendations on the amalgam MSDS. No words can thank you for the peace and freedom you have given. Nicole and Anthony were true representations of your kindness and generosity. 10. Instructor at Academy of General Dentistry course and trial demonstrations at dental courses, and video tape utilized in dental school classes.
Limits non-economic damages to $1 million for cases in which the plaintiff becomes a paraplegic or quadriplegic because of spinal cord injury , sustains third degree burns over 40% or more of his or her body or face, or has a hand or foot amputated; Definitely a great law firm to use for just about everything! No joke hands down! I recommend anyone needing help to turn to the Donahey Law Firm yo visit a general medical doctor or a $6 payment to visit a medical spe- Letter to Non-Party Witness regarding Deposition Subpoena Duces Tecum Use the contact form on the profiles to connect with a New York lawyer for legal advice. TALK FOR A WHILE TO PHYSICIANS and they'll bemoan how they're often victims of frivolous lawsuits, which are costly to both their personal reputations and the US health care system. Many of my colleagues at UMass Medical School and elsewhere were outraged by the $11 million judgment in the Bellerose case. The death was undeniably tragic, but did the jurors really understand anything beyond their own sympathy for the parents' suffering? The deck seemed stacked against the baby's doctors and nurses, whose complicated statements on the stand were no match for a grieving mother's sorrow. Legal professional specializing in: Probate, Wills & Estates; Deeds & Property Ownership; Title Theory We are willing and eager to evaluate your potential Tampa Florida medical malpractice case and discuss its merits and value with you. There is no charge for our preliminary evaluation and discussion, but we do need certain information from you to perform our evaluation. The quality of our evaluation is dependent upon the accuracy and fullness of the information you provide to us. Once we receive the information requested below, we will contact you to discuss our evaluation. A man from Everett, Washington was awarded $40.1 million from a jury for injuries he sustained during cardiac bypass surgery. A malfunctioning heart monitor caused 54-year-old Paramjit Singh so much damage to his heart that he was forced to undergo a heart transplant. The monitor, made by Edwards Lifesciences Corp. of Irvine, California, caused a catheter to overheat and burn the heart. Of the more than $40 million awarded, the $8.35 million were punitive damages. The jury found Edwards responsible for 99.99 percent of the damages awarded, and Providence Everett Medical Center responsible for 0.01. (a) Standard: Sanitary environment. The ASC must provide a functional and sanitary environment for the provision of surgical services by adhering to professionally acceptable standards of practice. 1995-2004. Int Endod J 2008;41:1059-1065. Sandy March 2, 2012 at 5:24 a.m. 4 years, 3 months ago The defense's position at trial was that the woman more likely than not would not have been able to conceive even absent this surgeon's mistake because of the infection that she had when she came in. The jury rejected this argument after the patient's attorneys showed that women with this type of infection are able to get pregnant between 85 and 90 percent of the time. The jury's award included $190,000 for medical expenses, $1.3 million for emotional pain and suffering and mental anguish, and $310,000 to the woman and her husband for loss of consortium. 1700 South Tower, 225 Peachtree Street, N.E., Atlanta, GA - (404) 658-9070 Use the contact form on the profiles to connect with a Lake Havasu City, Arizona attorney for legal advice. Q. Now, Doctor, you are also - we are also in agreement, are we not, that you knew that the extraction of a tooth in a patient who had received radiation therapy, over 6,600 rads of radiation therapy in the jaw and mouth could lead to osteoradionecrosis, correct? Los Angeles Medical Malpractice Attorney protecting your Right to Compensation A hospital staff is not negligent simply because his/her efforts were unsuccessful. Company says the mosquitoes could be used to help halt spread of Zika virus. 2.4% of medical malpractice payment reports made against dentists were in Massachusetts 2003 (2003 Annual Report, National Practitioner Data Bank, US DHHS)
Requirement for Expert Testimony 111 Monument Cir, Gilday James K Chase Tower Indianapolis, IN 46204 Kell, Alterman and Runstein LLP in Portland, OR, provides legal advice in a number of areas for both corporations and individuals. Since its founding in 1929, the firm has made sure clients receive the highest levels of service from the beginning to the end of each case. The firm... Types of Medical Malpractice Lawsuits Generally speaking there is little difficulty in proving that the doctor or medical team who are responsible for treating a patient owe the patient a duty to take care of him or her. This also applies to other healthcare professionals such as nurses, therapists, laboratory workers, physiotherapists, mental health care teams and the ambulance service - this list is not exhaustive. Dental Malpractice Lawyers Gautier Mississippi It must also be established that a reasonably prudent person in the patient's position would not have undergone the treatment or diagnosis if he had been fully informed and that the lack of informed consent is a proximate cause of the injury or condition for which recovery is sought. Unless it has already been done, the nursing home chart will be impossible to review without first being organized. The chart should be separated by categories, with each category organized chronologically. Some law firms utilize paralegals or nurses to organize the chart, while others use third party agencies instead. In addition, each page of the chart should be scanned and date stamped to allow for digital access. Scanning will make it much easier to present portions of the chart at trial or to incorporate them into a videotaped deposition. Steven Schmidt v. Minnesota Power In successful dental negligence compensation claims our specialist medical negligence solicitors have experience in recovering compensation, as well as arranging any necessary services to improve the client's quality of life. Dental malpractice: The dentist performs incorrect or faulty dental work
(205) 322-1411 19 Richard Arrington, Jr. Blvd., The dentist should fix the problem. I had a root canal done that ended up infected afterward. Every issue that I've had with it, the dentist fixed for free since it had already been paid for. I do have one tooth (crown) that needs to be replaced after only 2 years (and insurance won't pay) from our old dentist. I'll be having to call them to see if they'll replace it, but if not, I'll be searching this post again to see what to do about it! Nothing in this article is meant to refer to any one particular dentist or dental group and any interpretation of this article as referring to any one dentist or dental corporation is an incorrect interpretation. If, however, you've had an unpleasant incident or a bad experience at the office of a dentist or dental group in California, or if you worked with or trained at a dental group which was designed to take advantage of its clients, we'd like to hear about what you experienced. If you have any documents that evidence what you went through, we'd be interested in seeing them. Please e-mail us atlet us know what happened to you and which dentist or dental office attempted to con you or others into paying too much. You will always have one point of contact. Once assigned to a member of the team, they will be your contact throughout your case. They are always available via email, phone or in person to talk through any concerns and to discuss your options personally. Anybody who deals with animals is faced with this issue of whether or not our society wishes to compensate people over and beyond market value of these animals, Dr. Flemming said. Each of these mistakes are ones that are commonly found within medical malpractice cases involving surgery, and they all can carry life changing consequences to the patient and their families. Often, surgical medical malpractice situations will leave the patient and their family with ongoing medical expenses as well as other negative effects, causing the need for compensation to be great. Medical negligence action alleging Defendants' failure to timely perform a caesarean section in lieu of a vaginal birth, resulting in a permanent brachial plexus injury to the minor Malpractice Reforms Unrelated To The Practice Of Defensive Medicine In direct contradiction to claims that medical malpractice caps are necessary on pain and suffering in order to reduce the costs of doctors practicing... To help us route your email to the right department, please let us know what service your enquiry relates to. Motion to Compel Further Discovery Responses