SUPERIOR COURT OF THE VIRGIN ISLANDS
                           DIVISION OF ST CROIX
     JACYLN O GARRO,

                                         PLAINTIFF,
                                                      SX 19 CV 112
                            V
                                                      ACTION FOR DAMAGES

                                                      Jury Trial Demanded
     DR GASNEL E BRYAN DR RON
     ANDERS AND THE VIRGIN ISLANDS                    Cite as 2021 VI SUPER 55U
     HOSPITALS AND HEALTH FACILITY
     CORPORATION

                                      DEFENDANTS



  Appearances

  Lee J Rohn, Esq
I 108 King Street Suite 3
56 King Street Third Floor
Christiansted St Croix
WW
For Plamnfl

  Denise N George, Esq
  Assistant Attorney General
  #213 Estate La Reine
  Kingshill V100850
  For Defendant

                                      MEMORANDUM OPINION

  ‘1] WILLOCKS Presiding Judge

  tIII      THIS MATTER is before the Court on Jaclyn O Garro s (hereinafter Plaintiff ) Motion to

  Compel Virgin Islands Hospitals and Health Facilities Corporation (hereinafter Defendant ) to

  Supplement Discovery Responses filed on April 28 2020 Defendant filed an Opposition to Plaintiff’s

  Motion to Compel on May 7 2020

         For the reasons stated herein the Court will GRANT Plaintiff’s Motion to Compel Defendant t0

  Supplement Responses Nos 9 ll 19 and 23 and DENY Nos 5 6 8 12 and 18 Further Nos 20

  22 will be DENIED unless the Defendant with reasonable efforts, can locate the information
Jaclyn 0 Garro v Dr Gasnel E Bryan, Dr Ron Anders and the Virgm Islands Hospitals and
Health Facdzty Corporatzon
SX 19 CV [12
Memorandum Opinion                                                              2021 VI SUPER 55H
Page 2 of 10

      I   Discussion

                       i   Meet and Confer Requirement         VI R Civ P 37 l

112       If a party served fails to make all necessary disclosures as required by V I R Civ P 33, the

party requesting disclosure may move to compel discovery under V I R Civ P 37(a)( l) ' The Motion

must satisfy certain requirements, Specifically, the motion must include a certification that the

movant has in good faith conferred or attempted to confer with the person or party failing to make

disclosure or discovery in an effort to obtain it without court action ’ V I R Civ P 37(a)(l) 3 The

certification must demonstrate in writing that prior to filing, counsel for the parties attempted to meet

and confer in good faith effort to eliminate the necessity for the motion to eliminate as many of the

disputes as possible V I R Civ P 37 [(3) ‘

AWWWmeQ—

Compel p 15) Plaintiff wrote to Defendant with information about its discovery responses (See

Exhibit 1) At the end of the e mail, Plaintiff wrote that a meet and confer could be held regarding the

discovery issues (See Exhibit l p l3) A meet and confer was held on March 17, 2020 at l I 00 a m

and Defendant agreed to supplement some of its responses but not all (See Exhibit 2) The Court finds

this sufficient pursuant to LRCi 37 l

                    ii     Motion to Compel Legal Standard

114       For discovery to progress effectively each party must provide truthful, complete candid and

explicit responses to each individual discovery request M Regarding interrogatories the responding

party must answer each interrogatory separately and fully in writing           unless the responding party




; Crtu, v Vzrgm Islands Water & Power Am}! 2020 V l LEXIS 45 (Super Ct 2020)

15:?
  Id
‘ Id (citing Donastorg 2019 V I LEXIS 66 at IO 20l9 VI SUPER 66U SI 18 at 3)
Jaclvn 0 Garro v Dr Gasnel E Bryan Dr Ron Anders and the Virgin Islands Hospitals and
Health Factltty Corporanon
SX 19 CV 112
Memorandum Opinion                                                            2021 VI SUPER SSU
Page 3 of 10

demonstrates that he cannot do so with the exercise of reasonable efforts 6 See V I R Civ P 33

advisory committee 5 note to subpart (b) 7 Only when the responding party has made this

representation can he state that the answer to an interrogatory may be determined by examining other

documents 3 See V I R Civ P 33 advisory committee’s note to subpart (d) Otherwise, answering an

interrogatory by merely “referring to pleadings or other discovery is insufficient ” 96 A L R 2D 598

(1964) (collecting cases) 9

Interrogatory No 5

       Interrogatory    No     5    Identify   by   date    and   parties   involved    any    and   all
       communications/consultations regarding the removal of Plaintiffs left and/or right ovary in
       September 2018, among any of the Defendant’s employees contractors associates and others
       including the nature/substance of such communication and/or consultation, the reason for same,
       the results of the same and all actions taken by Defendant any Co Defendant and/or by Plaintiff
       in response to such communication and/or consultation

       Response to Interrogatory No 5 All communications regarding plaintiff’s care while at the
       hospital are contained in the medical records previously produced

lnterrogatory No 6

       lnterrogatory No 6 Describe all verbal and/or written instructions and communications of any
       type whatsoever regarding the removal of her left and/or right ovary provided to Plaintiff by and
       of Defendant 5 employees, contractors associates or and Co Defendant in September 20l8

       Response to lnterrogatory No 6 See response to No S

‘115      Pursuant to the Rules of Civil Procedure “an interrogatory may relate to any matter that may

be inquired into under Rule 26(b) [generally that it is relevant and discoverable] ” V IR Civ P

33(a)(2) Each interrogatory must be answered fully and any grounds for objection must be stated or

it may be waived V I R Civ P 33(b)(3) (4)




6 Id
7 Id
3 Id
‘ Id
Jaclyn 0 Garro v Dr Game] E Bryan Dr Ron Anders and the Virgin Islands Hospitals and
Health Faahtv Corporation
SX 19 CV 112
Memorandum Opinion                                                           2021 VI SUPER SSU
Page 4 of 10

?I6       Regarding interrogatories, the responding party must answer each interrogatory separately

and fully in writing ” unless the responding party demonstrates that he cannot do so ‘with the exercise

of reasonable efforts ” Cru~ v Vlrgm Islands Water and Power Authorttv 2020 LEXIS VI 45 (Super

Ct 2020) See also VI R Civ P 33 advisory committees note to subpart (b) Only when the

responding party has made this representation can he state that the answer to an interrogatory may be

determined by examining other documents See V I R Civ P 33 advisory committee 5 note to subpart

(d)

‘|[7      Defendant alleges that Nos 5 and Nos 6 should not be supplemented because this information

is contained in the medical records which are detailed and self explanatory (See Defendant s Opp p

4) In addition Defendant meets their burden because they represented that it would be unreasonable

WWW

rule Defendant only needs to state why doing 90 cannot be done even with the exercise of reasonable

efforts The Court finds a detailed minute by minute recording to be sufficient to Plaintiff’s

interrogatories and that it would be unreasonable to have Defendant simply narrate what is already

highly detailed Thus the Court will DENY supplementation for interrogatories No 5 and No 6

lnterrogatory No 8

       Interrogatory N0 8 Describe in detail any and all diagnoses made by any of Defendant 5
       employees and/or Co Defendant Dr Gasnel E Bryan and/or Co Defendant Dr Ron Anders
       including but not limited to any and all medical practitioners, physicians and/or surgeons
       concerning Plaintiff, at any time in September 20l8 describe any and all treatment/care
       plans/recommendations made and identify all persons who participated in same and identify all
       criteria/tests relied upon in making said diagnoses and treatment plans

       Response to [nterrogatory No 8 Plaintiffs pre operative diagnoses were (1) progressive pelvic
       pain and (2) pelvic mass Plaintiffs post operative diagnoses are (1) Right tubo ovarian complex
       (2) hemorrhagic cyst of right ovary (3) extensive pelvic adhesions



Interrogatory No 12
 Jaclyn 0 Garro v Dr Camel E Bryan Dr Ron Anders and the Virgin Islands Hospitals and
 Health Fac iliry Corporation
 8X 19 CV 112
 Memorandum Opinion                                                              2021 VI SUPER 55U
 Page 5 0f 10

        Interrogatory No 12 State in complete detail all complaints concerns and/or any statements
        whatsoever made by Plaintiff to Defendant 3 employees and/or to any Co Defendant in this matter
        and/or to any health practitioner physician and/or surgeon concerning the treatment of Plaintiff,
        identify each person to whom the same were made and give a factual summary of the course of
        action treatment, andlor care provided to her as a result, together with applicable dates

        Response to Interrogatory No 12 None that we are aware of except this lawsuit

 ‘l[8      This Court has held when a response is blatantly insufficient it will be ordered to be

 supplemented See Kralzk v Osage SIX Holdings LLC 2020 VI SUPER 69 (Super Ct 2020) (holding

 responses were blatantly insufficient» The Court does not find Plaintiff’s reasoning for compelling

 supplementation on No 8 or No 12 to be instructive here because the Defendant does not need to

 show that information would be unreasonable          Defendant simply answered the interrogatory Thus,

 the Court will DENY supplementation on No 8 and No 12

—_W
        Interrogatory No 9 Identify any and all lawsuits claims and complaints alleging negligence or
        malpractice in connection with failing to remove the correct organ/body part and/or removing the
        incorrect organ/body part at the Juan Luis Hospital during the past 5 years and as to each state the
        names of the parties the court and docket number where filed the nature of the allegations, and
        the ultimate disposition or status of the matter

        Response to Interrogatory No 9 Objection Overbroad and irrelevant

 ‘l[9      Pursuant to the Rules of Civil Procedure     an interrogatory may relate to any matter that may

 be inquired into under Rule 26(b) [generally that it is relevant and discoverable] ’ V IR Civ P

 33(a)(2) Each interrogatory must be answered fully and any grounds for objection must be stated or

 it may be waived V I R Civ P 33(b)(3) (4) The Court determines whether information is relevant

 by the standard provided by Virgin Islands Rule of Evidence 401 See Donastorg 2019 V I LEXIS

 66 at 5 6 2019 VI SUPER 66U ‘][l l at 2 Under this rule relevant information is that which has the

  tendency to make the existence of any fact that is of consequence to the determination of the action

 more or less probable than it would be without [it]      Donastorg 2019 V I LEXIS 66 at *6 2019 VI

 SUPER 66U t1|12 at *2 See also Thomas v People ofthe VI 60 V I 183 196 (V I 2013)
    Jaclyn 0 Garro v Dr Game] E Bryan Dr Ron Anders and the Vtrgm Islands Hospitals and
    Health Faetltty Corporation
    SX 19 CV 1 12
    Memorandum Opinion                                                                       2021 VI SUPER SSU
    Page 6 of 10

    ‘IIIO      The Court finds this interrogatory relevant because the fact that medical malpractice in the form

    of negligent removal of a body part within Juan Luis Hospital has happened before may make it more

    likely it has happened again At this point in the discovery process this information should be available

    to the Plaintiff, however it does not have to mean this information would be admissible in evidence '0

    Thus the will GRANT supplementation on Interrogatory No 9

    Interrogatory No 10

            Interrogatory No 10 State whether the Defendant’s business and/or operator’s license to practice
            has ever been limited, restricted denied, revoked, or suspended and/or compromised, and if so
            state the applicable dates each reason for same, the current status of such business and/or
            operator’s license, and the identity of the person, committee board or other such entity initiating
            each and every such action against the business and/or operator’s license

            Interrogatory No 10 Objection irrelevant

—_1nmaammn.
           Interrogatory No 11 State whether the Defendant’s accreditation has ever been limited, delayed
           restricted denied, taken away revoked reduced or suspended and/or compromised and if so, state
           the applicable dates each reason for same the identity of the person, committee board or entity
           initiating each and every such action relating to accreditation and the current status of each such
           accreditation action

            Response to lnterrogatory No 11 Objection irrelevant


    1111       Again this is relevant to the claim of medical malpractice and the answer has a tendency to

    make the fact Juan Luis Hospital was negligent more likely Defendant makes the argument that

    because accreditation is peer review” it is not discoverable but fails to cite to any law or policy that

    would persuade this Court May the Court set this as a reminder to Defendant and other litigants during

    the discovery process that the Court will not make arguments for them Therefore and pursuant to the




    '” lnfonnation within this scope of discovery need not be admissible in evidence to be discoverable Dallaslorg v
    Walker No ST 17 CV 393 20l9Vl LEXIS 66 20|9 VI SUPER 96U fill at2 (VI Super Ct July ll 20l9)
Jaclyn 0 Garro v Dr Game! E Bryan Dr Ron Anders and the Virgin Islands Hospitals and
Health Facdlty Corporation
SX 19 CV 112
Memorandum Opinion                                                          2021 VI SUPER 55U
Page 7 0f 10

Virgin Islands Rules of Evidence 401 the Court will GRANT supplementation on Interrogatory No

 Il

Interrogatory No 18

        Interrogatory No 18 Please identify and describe with particularity any and all acts and/or
        omissions on the part of Plaintiff that Defendant contends caused and/or contributed in any
        manner to the failure of Defendants to properly recognize and address Plaintiffs concerns as
        set forth in Plaintiffs First Amended Complaint identify all persons who will testify to this
        effect and identify all documents test results and/or medical literature relied upon in support
        of any and/or all of these contentions/facts

        Response to lnterrogatory No 18 Defendants did not fail to recognize and address Plaintiff 8
        concerns All caretakers will testify to that

Interrogatory No 19

        lnterrogatory No 19 If Defendant contends that the treatment of Plaintiff by Co Defendants
        in September 2018 met or exceeded the appliable medical standard of care, please identify this

        two (2) persons who will testify to these facts and identify all documents test results, and
        medical literature relied upon in support of any and/or all of these contention/facts

        Response to Interrogatory No 19 The applicable standard of care is contained in the AGOG
        guidelines on ovarian cysts

(l[12   In the absence of a demonstrated need for the specific information sought, a request can be

overbroad and unduly burdensome Sheeslev 2018 V I LEXIS 42 (Super Ct 2018) With regard to

Interrogatory No 18 this Court finds that Defendant has sufficiently answered the Interrogatory and

the Court will not compel a party to answer in an opposite way Supplementation of an interrogatory

should not be used for any other purpose than to require an answer when there is an insufficient

response Therefore the Court will DENY Plaintiff’s request on No 18

([[13   This Court has held when a response is blatantly insufficient it will be ordered to be

supplemented See Kraltk v Osage SIX Holdings LLC 2020 VI SUPER 69 (Super Ct 2020) (holding

responses were blatantly insufficient» The Court finds this to be the case here Defendant 5 response

is insufficient because it does not even describe what the AGOG is and it does not answer the
          Jaclyn 0 Garro v Dr Game! E Bryan Dr Ron Anders and the Virgin Islands Hospitals and
          Health Fatality Corporation
          SX 19 CV l 12
          Memorandum Opinion                                                              2021 VI SUPER SSU
          Page 8 of 10

          statement and the Court finds this relevant to Plaintiff’s medical malpractice claim The Court will

          GRANT Plaintiff’s motion to compel 0n Interrogatory No 19

          lnterrogatory No 20

                  Interrogatory No 20 Please identify any and all Medical Malpractice Review Committees that
                  were convened to review/investigate in any manner the claims made by Plaintiff concerning
                  Defendant, identify all persons who sat as members on this committee identify any and all reports
                  prepared by this committee, and describe in detail any and all findings and/or conclusions reached
                  by this committee and if no Medical Malpractice Review Committee was so convened state all
                  reasons why this was not done

                  Response to Interrogatory No 20 I do not have any information on the actions of the MMARC


          Interrogatory No 21

                  lnterrogatory No 21 Please identify any and all Medical Malpractice Review Committees that
were convened to review/investigate in any manner that claims made by Plaintiff concerning Co
Mam
                  identify any and all reports prepared by this committee and describe in detail any and all findings
                  and/or conclusions reached by this committee, and if no Medical Malpractice Review Committee
                  was so convened state all reasons why this was not done

                  Response to Interrogatory N0 21 I do not have any information on the actions of the MMARC


          Interrogatory No 22

                     lnterrogatory No 22 Please identify any and all Medical Malpractice Review Committees
                     that were convened to review/investigate in any manner the claims made by Plaintiff
                     concerning Co Defendant Dr Ron Anders identify all persons who sat as members on this
                     committee, identify any and all reports prepared by this committee and describe in detail any
                     and all findings and/or conclusions reached by this committee and if no Medical Malpractice
                     Review Committee was so convened state all reasons why this was not done

                     Response to Interrogatory No 22 I do not have any information on the actions of the
                     MMARC


          ‘l[l4      Plaintiff basically contends that the Medical Malpractice Action Review Committee

          (hereinafter ‘MMARC ’) does not even exist (See Plaintiff’s Reply p 2) Plaintiff also claims that if

          the MMARC does exist that it is not confidential (See Plaintiff 3 Reply p 2 3) Plaintiff is correct in
Jaclyn 0 Garro v Dr Gasnel E Bryan Dr Ron Anders and the Virgin Islands Hospttals and
Health Faetltty Corporation
SX 19 CV ll2
Memorandum Opinion                                                           2021 VI SUPER 55U
Page 9 of 10

arguing that the information and decisions by the MMARC are intended to be open to the claimant and

shared with the claimant See V 1 Code Title 27 §l66i (a) However if the Defendant claims they have

no information the Court cannot compel Defendant to provide something they do not have The Court

finds that Defendant did not specify that they could not with reasonable efforts obtain that

information

(Ills   Therefore the Court will DENY Plaintiff’s Motion to Compel on Nos 20 22 only to the extent

that Defendant cannot reasonably obtain the MMARC information If Defendant obtains any

information or has in their possession information that would answer Plaintiff’s Interrogatories than it

should be submitted to Plaintiff and filed as a Notice to the Court within fourteen (14) days of date

of entry of this Order If Defendant does not find any information after reasonable efforts, file a Notice

WWWWWW—

Interrogatory No 23

        Interrogatory No 23 Please identify any and all insurance funds established by the
        Government of the Virgin Islands for medical malpractice claims the date that said funds were
        established identify any and all reports made by Defendant and/or the Government of the
        Virgin Islands to any representative of the funds and state the date and content of each such
        report

        Response to Interrogatory No 23 The fund established to pay malpractice claims is
        governed by statute 19 V I C l66e

‘1116   This response is blatantly insufficient The Defendant gives no explanation as to why they

answered in this way because it does not reasonably answer Interrogatory No 23 nor does it explain

why Defendant could not do so with reasonable efforts Thus the Court will GRANT supplementation

on Interrogatory No 23
Jaclyn 0 Garro ‘ Dr Game! E Bryan, Dr Ron Anders and the Vargm Islands Hospitals and
Health Fm 1111‘)! Corporanon
SX 19 CV 1 l2
Memorandum Opinion                                                        2021 VI SUPER SSU
Page 10 of 10

 11      CONCLUSION

      Thus the Court will GRANT Plaintiff’s Motion to Compel Defendant to Supplement Responses

      Nos 9 l 1 l9 and 23 and DENY Nos 5 6 8 12 and 18 Nos 20 22 will be DENIED unless the

      Defendant, with reasonable efforts, can locate information

         It is hereby                          %

         DONE and so ORDERED this 9&7 day of% 2021



                                                      HAROLD W L WILLOCKS
                                               Presiding Judge of the Superior Court




ATTES'I
Tamara Charles, Clerk of Court


gate
m
Supervisor WfldZ-E
                 SUPERIOR COURT OF THE VIRGIN ISLANDS
                         DIVISION OF ST CROIX
 JACLYN 0’ GARRO,

                                      PLAINTIFF,   SX 19 CV 00112

                         v                         ACTION FOR DAMAGES

                                                   Jury Trial Demanded

                                                   Cite as 
2021 VI Super 55U
 DR GASNEL E BRYAN DR RON
 ANDERS AND THE VIRGIN ISLANDS
 HOSPITALS AND HEALTH FACILITY
 CORPORATION

                                    DEFENDANT


                                              ORDER

       AND NOW consistent with this Court 5 Memorandum Opinion entered in the above
captioned matter on even date, it is hereby

ORDERED Plaintiff’s Motion to Supplement Interrogatory No 5 is DENIED it is further

ORDERED Plaintiff’s Motion to Supplement Interrogatory N0 6 is DENIED it is further

ORDERED Plaintiff 5 Motion to Supplement [nterrogatory No 8 is DENIED it is further

ORDERED Plaintiff’s Motion to Supplement Interrogatory No 12 is DENIED it is further

ORDERED Plaintiff’s Motion to Supplement Interrogatory No 18 is DENIED it is further

ORDERED Interrogatory N0 9 shall be supplemented it is further

ORDERED Interrogatory No 11 shall be supplemented it is funher

ORDERED Interrogatory No 19 shall be supplemented it is further

ORDERED Interrogatory No 23 shall be suppiemented it is further
Jaclyn 0 Garro 1 Dr Game! E Bryan Dr Ron Anders and the Virgin Islands Hospitals and
Health Facility Corporation
SX 19 CV 112
Order
Page 2 of 2

ORDERED Interrogatory Nos 20 22 are DENIED only to the extent that Defendant cannot

reasonably obtain the MMARC information If Defendant obtains any information or has in their

possession information that would answer Plaintiff s Interrogatories than it should be submitted to

Plaintiff and by Notice to the Court within fourteen (14) days of the filing of this Order [f

Defendant does not find any information after reasonable efforts they should Motion to the

Plaintiff and file a Notice with the Court that no information was found within the fourteen (14)

day timeframe

       It is hereby

       DONE and so ORDERED this 9e“day of 140%                            2021


                                          O                  /              /             (
                                          Am
                                                    HAROLD W L WILLOCKS
                                             Presiding Judge of the Superior Court

ATTEST
TAMARA CHARLES
Clerk of Court


épervisor Wm f ”6

fi/Agéfiz/
Date