complaint and discovery requests
TRANSCRIPT
8/20/2019 Complaint and Discovery Requests
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IL H BYRD
CUY HOG
COU TY CUERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
urt of mm n Pleas
ew Case Electronically
Filed:
December 21,2015 10:51
By: SU ODH HANDRA 0069233
onfirmation Nbr.
624362
SIMPSON
HUGGINS
vs
THE METROHEALTH SYSTEM
V 15
856035
Judge:
MI HAEL
ASTRAB
Pages Filed:
32
Electronically
Filed 12/21/2015
10:51 /
/
V
15
856035 / onfirmation Nbr.
624362 /
LMKO
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IN
THE
OURT OF MM N LEAS
UYAHOGA
OUNTY,
OH
Simps n
Huggins
III
4849
D n van
Street
leveland, OH
44125, ase N .
Plaintiff,
Judge
vs.
The
Metr Health
System
2500
Metr Health
Drive
leveland,
OH
44109,
Defendant.
plaint
with
Jury
D
e and
ature of actio
1.
This
is
an
action
to
rec ver
for retaliation
under
Ohi
’s
Whistlebl wer
Statute,
R. .
4113.52. Plaintiff Simps n Huggins III
was
retaliated against for
rep rting
crimes he
disc vered
while
perf rming his
duties
as
Direct r
of
Internal
Audit
for
The
Metr Health
System.
After
rep rting
these
crimes to the
Audit
mmittee of the B ard of Trustees
including
theft of B t x
injections
and ther
services
fr m
Metr Health
’
s
Pepper
Pike
Dermat l gy
linic
for
use
by
senior
executives
and
irregularities
with
EO Akram
B utr s
’
s
travel
expenses
and ther
reimbursements Mr. Huggins
was
placed n unpaid
administrative
leave in
retaliation for l king at rec rds he “had n business l king at” and “ verstepping
his b unds” as an empl yee (to qu te Metr Health General unsel Michael D.
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Phillips).
Rather than
address the
issues Mr.
Huggins
raised,
Metr Health ch se to
c me
after
Mr. Huggins.
Such
actions
violate
Ohi law.
Parties
2. Plaintiff Simps n Huggins III is the Direct r of Internal Audit
for
The
Metr Health System. He resides in uyah ga unty.
3. Defendant Metr Health System is a c unty hospital located in uyah ga
unty.
Metr Health
empl yees are
public
empl yees paid by
the
c unty
and
subject
to
Ohi
ethics
laws.
Jurisdiction
and venue
4.
The
urt
has
jurisdiction because
the
suit c ncerns state-law violations
and
the
am unt in
c ntr versy
exceeds $25,000.
5. The urt has pers nal
jurisdiction ver The Metr Health System.
6.
Venue
is
pr per
here
because
the
parties
are
located
in
this
c unty
and
the
events at
issue t k
place here.
Facts
Simpson Huggins becomes Director of nternal udit.
7. Metr Health hired Mr.
Huggins
n appr ximately
June
25,
2012
as
an
audit
manager.
8. In appr ximately March or April
of
2013,
the
Direct r of Internal Audit
resigned. Metr Health put Mr. Huggins in that position n an interim basis.
9. appr ximately July 22, 2013,
Metr Health
made
Mr. Huggins the full
time
Direct r of Internal
Audit.
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10.
The
Direct r of
Internal Audit is resp nsible for a variety
of
duties
including
perf rming an annual financial internal-reporting control
audit.
The
internal-audit
department
c nducts
these
preliminary
tests
as
part of
preparing
for
the
state
auditors to c me in and c nduct their review. Within each
control
testing there are
10-20 individual steps that add up to that control. Part
of
the analysis involves
reviewing acc unts payable for justification as to why expenses are being
reimbursed.
11.
An ther
aspect
of
the
Director
of
Internal
Audit
’
s
duties
is
to
rep rt
to
Metr Health’s
Audit
mmittee
at
quarterly meetings.
Mr.
Huggins has
been
rep rting at these
quarterly meeting
since July
2013.
12. Mr.
Huggins
reports
n
an
administrative
basis
to
hief
Financial
Officer
raig Richm nd.
Mr. Huggins reports functionally to
the
B ard of
Trustees.
Mr
uggins
uncovers
felony
theft
crimes
including
receipt
of
free
Botox
injections
and
other
services
by
certain
senior Metro ealth
employees
and
use of public funds to pay
for
lavish
personal travel
for
the
CEO
13.
As part
of
c nducting his
internal audit,
Mr. Huggins unc vered
a
variety
of
impr per activity and
practices that
constitute felony
theft.
14. One of
the
subjects
of Mr.
Huggins
’
s
audit
was possible fraud and theft at the
Metr Health Pepper Pike Dermat l gy linic. His audit revealed that tw vice
presidents
and at least
ne
empl yee
’
s relative accepted free B t x injections
and
ther services at the Metr Health Pepper
Pike
Dermat l gy linic.1
1 Mr.
Huggins
kn ws
the
names
of the
individuals wh
accepted
these
free
services. And the
d cumentati n
supp rting his audit (which, as described below, Metr Health confiscated)
includes
their
names
as
well.
Mr.
Huggins
is
n t
identifying them
in
this
pleading due to
medical-privacy
concerns.
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15.
Metr Health
empl yees
administered the
free
treatments.
These
empl yees
failed
to
c mply with pr per pr cedures
regarding
rec rding
lot
numbers
and
expiration
dates
for
the
B t x
that
was
administered.
16. The cust mary charge
for
or
value
of a single B t x treatment at the
Metr Health Pepper
Pike
Dermat l gy linic is at least $729.
17. Theft of pr perty or
services
valued at m re than $1,000 is a felony.
18.
B t x is
a
danger us
drug
under
Ohi
law.
19.
Theft
of
a
danger us
drug
is
a
felony.
20. Mr.
Huggins
’s audit
also
revealed
impr per
expenses
including
evidently
pers nal
(non-business) travel
expenses
paid
n behalf
of hief
Executive
Officer
Akram B utr s
and his
wife
including
trips
to
L nd n,
w
Y rk,
Venice,
and
Abu
Dhabi.
These expenditures
exceeded
$1000 each.
21.
Mr.
Huggins
’
s
audit
further
revealed
impr per
pr cedures
regarding
c rp rate
credit-card
usage
and failure
to enforce
the written
policies regarding
submissi n of receipts to
justify
and d cument expenses.
22.
Audit reports typically include ne of the following ratings:
mmendable,
Satisfactory,
Needs
Impr vement,
Needs
Significant
Impr vement,
or
Unsatisfactory.
23. hief
Financial
Officer raig Richm nd
instructed
Mr. Huggins n t
to
sh w
any rep rt ratings in his
presentati n
to the Audit mmittee.
24. Mr. Richm nd
also
instructed Mr.
Huggins
to
withh ld
any Executive
Summaries
for
audit
reports
and n t to
present
the
findings
in Open
F rum.
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25. Mr. Richm nd
further
instructed
Mr.
Huggins
to
present
the
observations,
findings,
and rec mmendati ns nly in
Executive
Session.
Mr.
uggins
blows
the
whistle
on criminal
activity
26. December 15, 2015, Mr. Huggins delivered a presentati n to the Audit
mmittee in which he detailed a variety
of
concerns. Param unt in his rep rt
was
his disc very regarding the B t x theft at the
Pepper
Pike Dermat l gy linic. He
also
c vered
impr per
payment of
pers nal
travel
expenses
for
Dr. B utr s.
27.
During
the
Audit
mmittee
meeting
n
December
15,
2015,
Audit r
Bryan
Licht,
at
Mr.
Huggins
’
s
direction,
sent a
c py
of
the
written
audit rep rt
regarding
the
B t x and impr per B utr s
expenditures
to
raig Richm nd ( hief
Financial
Officer),
Dan Lewis
( hief
Operating
Officer),
Alfred
nners
( hief
Quality
Officer), Abel T rres (Executive Direct r and hairman for Dermat l gy), and
Brendan
Patters n
( linical
Service
Line
Leader
for
Dermat l gy).
28.
Mr.
Huggins exercised due diligence and reas nable care
in
investigating
the
violations he raised
in
his presentati n at the Audit
mmittee
meeting and in his
written audit
report.
The retaliation
begins
while
Mr.
uggins
is
in the
midst
of
reporting
his
findings
to
the
udit
Committee.
29.
During
Mr.
Huggins
’
s
rep rt
to
the
Audit
mmittee,
Metr Health
General
unsel
Michael
D.
Phillips
left
the
meeting
r m.
M ments
later,
Mr.
Huggins
’s
email and
system-netw rk
access
was
terminated.
30.
Mr.
Huggins typically participates in
the
Finance
mmittee meeting that
follows the Audit
mmittee meeting.
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31.
At Audit mmittee
meeting ’s c nclusi n
n December 15,
2015,
Mr.
Huggins
was
preparing
to
participate
in
the
Finance mmittee
meeting
when
hief
Financial
Officer
raig Richm nd
told
Mr.
Huggins
that
he sh uld
n t
participate in the Finance meeting. Mr. Huggins, initially misunderstanding
because he is a regular participant in the Finance mmittee meeting, assured Mr.
Richm nd that he w uld stay and that staying was n t a pr blem. Mr. Richm nd
repeated several times that Mr. Huggins sh uld n t
participate
and that he sh uld
“
just
g
ahead
and
leave.
”
32.
Mr.
Huggins
f ll wed Mr.
Richm nd
’s
unusual instruction and
left
the
meeting area.
uma Resources,
the
General Counsel,
and
a
hospital detective
escort
Mr uggins to the legal department, hassle him about his audit, and place
him
on unpaid administrative
leave
33.
After
leaving
the
meeting
area,
Vice
President
of
H man
Res urces
Deb
Warman,
General unsel
Michael
D.
Phillips,
and a
hospital detective
c nfr nted
Mr.
Huggins
in
the
hallway utside
the
b ardr m.
They asked Mr.
Huggins
to
c me
with
them
to
a
c nference
r m
in
the legal
office.
Mr.
Huggins c mplied
with
that instruction.
34. During
the
meeting in
the
c nference r m in the legal office, Ms. Wa man
told Mr.
Huggins that
there
had been a
c mplaint
ab ut his w rk.
35. Mr. Phillips c mplained that Mr. Huggins
was
l king
at
rec rds that he
“had n business l king at” and
“
verstepping
his b unds” as
an
empl yee.
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36.
Mr.
Phillips
asked Mr.
Huggins
questi ns
ab ut why
he
was
accessing certain
rec rds
ab ut Dr.
B utr s
’s
expenses
and making copies
of
certain
files
regarding
th se
expenditures.
37. In Mr. Huggins ’s capacity as
an
auditor, he reviews financial things like
expenses pr cessed thr ugh acc unts payable. Mr. Huggins explained that, under
the Internal Audit harter, the Audit mmittee of the Metr Health B ard of
Trustees
has granted
permissi n
for
his
department
to review all d cuments and
records,
b th
pers nal
and
property,
within
the
system.
38.
Mr.
Phillips
asked Mr.
Huggins
why he used
a flash
drive
to
store
files when
he had rem te access.
39.
Mr.
Huggins
explained
that
he
used a flash drive because he had b th
a
deskt p
and a lapt p c mputer and
the
flash drive all wed him to easily transition
between
the
two.
40.
Mr.
Phillips
asked Mr.
Huggins
if
he
was
aware
of
any
illegal activity that
Mr. Phillips
sh uld
be
made
aware
f.
41.
In
resp nse,
Mr.
Huggins reiterated his
earlier
reports and also referenced
Mr.
Phillips’
s
practice
of
signing
the
invoices
to appr ve payment to his
wn
private
law
firm.
42.
Mr.
Phillips told
Mr.
Huggins that
he
was
being
placed
n administrative
leave
pending
an “investigation.”
43. Ms.
Wa an
inf rmed Mr.
Huggins that
the
administrative leave w uld be
unpaid.
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44.
Mr.
Huggins
asked Ms.
Wa man
if
he w uld use pers nal time
off (PTO)
during
the
leave
(as
he was
aware
ther empl yees
had
been
permitted to
do).
The
head
of
H man
Res urces
said that she did n t
kn w
if
Mr.
Huggins
c uld use PTO
for
this
purp se.
45.
At
the meeting ’s conclusion, Ms. Wa man confiscated Mr. Huggins ’s keys to
his office and desk, his hospital ID, his silver SanDisk ruzer flash drive, and the
materials fr m the audit meeting
that Mr. Huggins
had in
his
possession.
46.
Bef re
being
escorted
off
of
hospital
property,
Mr.
Huggins
was
n t
permitted
to retrieve
pers nal
items fr m his
office.
Claim
:
Whistleblower Retaliation under R C 4113 52( )
47.
Plaintiff
inc rp rates
all
previ us
allegations.
48.
In the c urse
of
Mr. Huggins ’s empl yment, he
became
aware
of crimes that
Metr Health had
the
auth rity
to
correct.
49.
In
the
c urse of
Mr.
Huggins
’s
empl yment,
he became aware
of
violations
of
state law by fellow empl yees.
50. Mr.
Huggins
made
reas nable and good-faith
efforts
to determine the
accuracy of the inf rmati n he reported.
51.
Mr.
Huggins
reas nably
believed
that
the
c nduct
he
identified
during
the
Audit mmittee meeting and in his audit report regarding the theft of B t x
was
a
felony.
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52.
Mr.
Huggins
reas nably
believed that
the
c nduct he identified during
the
Audit
mmittee
meeting
and
in
his
audit
report
regarding
Dr.
B utr s a
public
empl yee
accepting
payment for
pers nal
travel
expenses
was a felony.
53. December 15, 2015, Mr. Huggins gave a presentati n to the Audit
mmittee of the B ard of Trustees in which he notified resp nsible officers of the
violations.
54.
Mr. Huggins ’s oral
rep rt
at
the Audit mmittee meeting satisfied the
oral-
report
requirements
of
R. .
4113.52(A)(1)(a).
55.
Mr.
Huggins
’s oral
rep rt
at
the
Audit
mmittee
meeting
satisfied
the
oral-
report
requirements
of
R. . 4113.52(A)(3).
56.
Mr.
Huggins
also
sent
a
written
a
written
rep rt pr viding
sufficient
detail to
identify and describe
the
violations to
the
following resp nsible
officers:
raig
Richm nd
( hief
Financial
Officer);
Dan
Lewis
( hief
Operating
Officer);
Al
nners ( hief
Quality Officer); Abel T rres
(Executive Direct r and
hairman for
Dermat l gy);
and Brendan Patters n
( linical
Service Line Leader
for
the gr up
ver
Dermat l gy).
57.
Mr.
Huggins
’s written
audit
rep rt
satisfied the
written-report
requirements
of
R. . 4113.52(A)(1)(a).
58.
Mr.
Huggins
’s written
audit
rep rt
satisfied the
written-report
requirements
of R. . 4113.52(A)(3).
59. Rather than make a good-faith effort to correct the violations
Mr.
Huggins
reported,
Metr Health
placed him n
unpaid
administrative
leave.
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60.
Mr.
Huggins
was
n t
permitted
to use
T during his administrative leave.
61.
Metr Health
retaliated
against
Mr.
Huggins
because he rep rted criminal
activity.
62. As a direct and pr ximate result
of
Metr Health’s illegal actions, Mr.
Huggins has suffered ec n mic and n n-ec n mic damages in
an
am unt to be
determined at trial.
63.
Mr. Huggins is entitled to punitive
damages
based
n Metr Health’s
intentional
and
malici us
acts.
P ye fo el ef
F r
the
reas ns
state ab ve,
Plaintiff
respectfully requests
the
following relief
fr m
the
ourt:
A. Declare that Defendants acts
and c nduct
constitute
violations
of Ohi
law;
B. Enter judgment in Plaintif
f
s fav r as to all claims for relief;
. Award Plaintiff full c mpensat ry damages, ec n mic and n n-ec n mic,
including,
but
n t
limited to, back pay,
front
pay, damages
for
pain and
suffering,
mental
anguish,
em ti nal
distress,
humiliation,
and
inc nvenience
that Plaintiff
has
suffered and is
reas nably
certain
to
suffer
in
the
future;
D.
Award
Plaintiff
punitive
damages
for intentional
and
malici us violations
of
Ohi
law;
E.
Award
pre-judgment
and
p st-judgment
interest at
the
highest
lawful
rate;
F.
Award
Plaintiff
his
reas nable
att rneys
fees
(including expert fees)
and
all ther costs of suit;
G.
Order
Metr Health
to
return Mr.
Huggins
’s
pers nal
property;
H.
Award
all ther relief in law or equity to which Plaintiff is
entitled and
that
the urt deems equitable,
just,
or
proper.
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Jury
dem d
Plaintiff demands
a trial
by
jury n all issues within this mplaint.
Dated: December 21,
2015
Respectfully submitted,
Subodh C an ra_ _ _ _ _ _ _ _ _ _ _ _
Sub dh
handra (0069233)
Ashlie
ase
Sletvold
(0079477)
Harris n
Blythe
(00093851)
THE
HANDRA
W FIRM, LL
1265
W. 6
th St.,
Suite 400
leveland,
OH
44113-1326
216.578.1700 Ph ne
216.578.1800 Fax
Sub dh. handra@ handraLaw.c m
Ashlie.Sletv ld@ handraLaw.c m
Harris n.Blythe@ handraLaw.c m
Attorney
for Plaintiff
Simp on Huggin
III
equest
for
ervice
T
the
clerk:
Please
issue
the
Summ ns
and mplaint and
serve the
mplaint
and
acc mpanying disc very requests
at
the addresses listed ab ve, making
return
acc rding
to law.
Subodh
C an ra
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
One
of
the attorney for
Plaintiff Simp on Huggin III
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IN
THE
OURT OF MM N LEAS
UYAHOGA
OUNTY,
OH
Simpson
Huggins
III
Plaintiff, ase No.
vs.
Judge
The MetroHealth System
Defendant.
P intiff
First et of Requests for dmission Directed to Defend nt
T
he Metro
e th ystem
under
Ohio C
iv
R 36
Under Ohio Rule of ivil Procedure 36, Plaintiff requests that Defendant
respond
to Plaintiff’s First Set of Requests for Admission within 8 days
of
service.
These
requests
are
to
be
answered
completely
and
fully,
in
writing,
and
under
oath.
f
timely
responses
are
not
received,
the
requests
will
be admitted
consistent
with iv.R. 36.
STRUCT O S
A. Definitions. In answering each request, use the following definitions:
1. The word “MetroHealth” refers to Defendant The MetroHealth System.
2.
“And
”
and
“or”
shall be construed
either
disjunctively
or
conjunctively
as
necessary
to
bring
within
the
scope
of
the
request
all
responses
that might
otherwise
be
construed to
be
outside its
scope.
3.
“Any
”
includes the
word
“all,
”
and “all” includes
the
word
“any.
”
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B.
These
requests
for admissi n shall be
deemed
c ntinuing
in nature and
are
to
be
supplemented
as
additional
inf rmati n pertinent to any request is obtained,
including,
but
n t
limited
to,
additional
inf rmati n that adds to
a previ us
resp nse, corrects a previ us resp nse, and/ r clarifies a previ us response.
. If objection is made, the reas ns
for
y ur objection shall be stated.
The
answer shall specifically deny the matter or set forth in detail the reas ns why y u
cann t
truthfully
admit
or
deny
the matter. A denial
shall fairly
meet the substance
of
the
requested
admissi n,
and
when
g d
faith
requires
that
y u
qualify
y ur
answer,
or
deny
nly
a part of
the
matter
of
which an
admissi n
is
requested,
y u
shall
specify so
much of
it as
is
true and
qualify or
deny
the
remainder.
Y u
y
n t
give lack of
inf rmati n or kn wledge
as
a
reas n
for
failure to
admit
or deny
unless
y u state that y u have
made
reas nable inquiry and that
the
inf rmati n
kn wn
or
readily
btainable
by
y u
is
insufficient
to
enable
y u
to
admit
or
deny.
If
y u
c nsider
that
a
matter
of
which
an
admissi n has been
requested presents
a
genuine issue for trial, y u y not, n that gr und alone, object to the request; y u
may,
subject to the provisions of
iv.R. 37( ),
deny
the matter
or
set
forth
reas ns
why y u cann t
admit
or
deny
it.
REQUESTS
FOR
DMISSIO
1.
Admit
that
Simps n
Huggins
as
of
December
15,
2015 was
the Director
of
Internal Audit
for
Metr Health.
RESPO SE:
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2. Admit that in December
2015,
Metr Health General
unsel Michael D.
Phillips told Simps n Huggins that he had “n business l king at” records
regarding expenditures for Metr Health
hief
Executive Officer Akram
B utr s.
ESPO SE:
3.
Admit that
in
December 2015,
Metr Health
General
unsel
Michael D.
Phillips
told Simps n
Huggins
that
he
had
“
verstepped
his
b unds”
regarding
his audit of
expenditures
for
Metr Health
hief
Executive Officer
Akram B utr s.
ESPO SE:
4.
Admit
that
n
December
15,
2015,
Metr Health
placed
Simps n
Huggins
n
unpaid
administrative leave.
ESPO SE:
5.
Admit
that
Metr Health
pr m ted
Simps n
Huggins
to
the
position
of
Direct r of Internal Audit n appr ximately July 22,
2013.
ESPO SE:
6. Admit that
ne of
Simps n
Huggins
’s
duties as the
Direct r
of
Internal Audit
is
perf rming
an
annual
financial
internal
rep rting
control
audit.
ESPO SE:
7. Admit that
ne
of Simps n Huggins ’s duties as the Direct r of
Internal Audit
is rep rting to
the
Audit mmittee of
the B ard of
Trustees
regarding
the
results of his auditing activity.
ESPO SE:
8. Admit that n December
15,
2015,
Simps n
Huggins
made
a
presentati n
to
the
Audit
mmittee
of
the
B ard
of
Trustees.
ESPO SE:
9.
Admit that n December 15, 2015,
Simps n Huggins rep rted to
Michael
Phillips,
Dan
Lewis,
Alfred
nn rs,
raig
Richm nd,
Abel Torres,
Brendan
Patterson,
and Mary Legerski that he had unc vered
theft
at
the
Metr Health Pepper Pike Dermat l gy linic.
ESPO SE:
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10. Admit that
n December
15,
2015,
Simps n
Huggins
rep rted
to
Michael
Phillips,
Dan Lewis, Alfred nn rs, raig Richm nd, Abel Torres, Brendan
Patterson,
and
Mary
Legerski that he had
unc vered
theft at the
Metr Health
Pepper
Pike
Dermat l gy
linic,
including
the
fact
that
tw
Metr Health
vice
presidents
had
received
free
B t x injections.
ESPO SE:
11.
Admit that n December
15,
2015,
Simps n
Huggins
rep rted to
Michael
Phillips,
Dan Lewis, Alfred
nn rs,
raig
Richm nd, Abel Torres,
Brendan
Patterson, and
Mary
Legerski that he had
unc vered
theft at the
Metr Health Pepper
Pike
Dermat l gy linic, including the fact that a
relative
of
a Metr Health
resident
had received free B t x injections.
ESPO SE:
12.
Admit that n
December
15,
2015,
Simps n
Huggins
rep rted
to
Michael
Phillips,
Dan
Lewis,
Alfred nn rs, raig Richm nd, Abel Torres,
Brendan
Patterson,
and
Mary
Legerski
and
that he
had unc vered theft
at
the
Metr Health Pepper
Pike
Dermat l gy linic,
including
the fact that
the
Metr Health
empl yee
administering free B t x injections had failed to
rec rd the lot number and expiration dates for the vials used.
ESPO SE:
13.
Admit
that
the
standard
charge
for
a
single
B t x
treatment
at
Metr Health
Pepper
Pike
Dermat l gy
linic
is
appr ximately
$729.
ESPO SE:
14. Admit that theft of
pr perty or services valued at m re than $1,000 is
a
felony.
ESPO SE:
15.
Admit that B t x is
a
“
danger us
drug
”
as
that
term
is used
in
Ohi ’s theft
statute,
R. .
2913.02.
ESPO SE:
16. Admit that theft of a “danger us
drug
”
(as that
term
is used in Ohi
’s
theft
statute, R. . 2913.02) c uld
be c nsidered a felony.
ESPO SE:
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17. Admit that
Dr.
B utr s
’s
kn wing receipt of
public hospital funds
to pay for
pers nal travel
expenses
c uld be c nsidered a felony.
ESPO SE:
18. Admit that during
Simps n
Huggins ’s
presentati n
to the
Audit mmittee
of the B ard of Trustees
n
December 15,
2015,
Simps n Huggins
rep rted
that he had unc vered impr per controls by
Metr Health
executives.
ESPO SE:
19.
Admit
that
during
Simps n
Huggins
’
s
presentati n
to the
Audit mmittee
of the B ard of Trustees n
December
15, 2015,
Simps n Huggins
rep rted
that he had unc vered impr per pr cedures regarding c rp rate credit-card
usage.
ESPO SE:
20. Admit that during Simps n Huggins ’s presentati n to the Audit
mmittee
of the B ard
of Trustees
n
December 15,
2015,
Simps n
Huggins
rep rted
that he
had
unc vered
failure
to enforce written policies regarding
submissi n of
receipts
to justify and
d cument expenses.
ESPO SE:
21.
Admit
that
n
December
15,
2015,
Bryan
Licht,
at
Simps n
Huggins
’
s
direction,
emailed
a
c py
of
Mr.
Huggins
s
written
audit
report
regarding
B t x theft and impr per expenditures n behalf of
Dr.
B utr s
to raig
Richm nd, Dan Lewis, Al nners, Abel Torres, and Brendan Patterson.
ESPO SE:
22. Admit that
Simps n
Huggins
exercised
due
diligence
and reas nable care in
investigating
the violations he
raised
in his
presentati n
at
the
Audit
mmittee meeting n December
15, 2015 and in his
written
audit report
pr vided that same day.
ESPO SE:
23. Admit that during
the Audit mmittee meeting n December 15, 2015,
Metr Health terminated Simps n Huggins
’s
email access.
ESPO SE:
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24. Admit that
during
the c urse
of
his empl yment with
Metr Health,
Simps n
Huggins typically attended the Finance
mmittee
meeting that follows the
Audit
mmittee
meeting.
ESPO SE:
25.
Admit that n December
15,
2015,
hief
Financial
Officer
raig
Richm nd
repeatedly told Simps n Huggins that he sh uld
n t
participate in
the
Finance mmittee meeting
that
day.
ESPO SE:
26. Admit that following
the Audit mmittee
meeting
n December
15, 2015,
hief Financial Officer raig Richm nd told
Simps n Huggins that he sh uld
“
just
g
ahead
and
leave
”
and
n t
participate
in
the
Finance
mmittee
meeting
that
day.
ESPO SE:
27.
Admit that following
the Audit mmittee
meeting
n December
15, 2015,
Vice
President for H man Res urces Deb Wa man and General unsel
Michael Phillips
met
with Simps n Huggins.
ESPO SE:
28.
Admit
that
during
the
meeting
with
Simps n
Huggins,
Deb
Warman,
and
Michael
Phillips
n December 15, 2015,
Mr. Phillips
questi ned
Mr.
Huggins
ab ut why he was
accessing
certain
records.
ESPO SE:
29. Admit that
during
the
meeting with
Simps n
Huggins,
Deb
Warman,
and
Michael Phillips n
December 15, 2015,
Mr. Phillips questi ned Mr. Huggins
ab ut why he was c pying certain files.
ESPO SE:
30.
Admit
that
during
the
meeting
with
Simps n
Huggins,
Deb
Warman,
and
Michael Phillips n December 15, 2015, Mr. Phillips questi ned Mr. Huggins
ab ut why
he
was
using
a flash drive.
ESPO SE:
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31.
Admit that
during
the
meeting with
Simps n
Huggins,
Deb
Warman,
and
Michael Phillips n December 15,
2015,
Mr. Phillips and/ r Ms. Wa an
confiscated Mr. Huggins ’s
flash drive.
ESPO SE:
32.
Admit that during
the meeting
with
Simps n Huggins,
Deb Warman,
and
Michael Phillips n
December
15,
2015,
Mr. Phillips and/ r Ms. Wa an
confiscated
Mr.
Huggins
’
s
hospital
identification card.
ESPO SE:
33. Admit that during
the meeting
with
Simps n Huggins,
Deb Warman,
and
Michael Phillips n December 15, 2015,
Mr. Phillips
and/ r Ms. Wa an
confiscated
Mr.
Huggins
’
s
keys
to
his
office
filing
cabinet.
ESPO SE:
34. Admit that during the meeting with Simps n Huggins, Deb
Warman,
and
Michael
Phillips
n December 15, 2015,
Mr. Phillips
and/ r Ms.
Wa an
confiscated d cuments Mr.
Huggins had received
during
the Audit
mmittee
meeting.
ESPO SE:
35.
Admit
that
during
the
meeting
with
Simps n
Huggins,
Deb
Warman,
and
Michael
Phillips
n
December
15,
2015,
Mr.
Phillips
asked
Mr.
Huggins
if
there
was
any illegal activity of which Mr. Phillips sh uld
be
aware.
ESPO SE:
36. Admit that during the meeting with Simps n Huggins, Deb Warman, and
Michael
Phillips
n December 15, 2015,
in
resp nse
to Mr.
Phillips’s
questi n
ab ut
whether
was
any
illegal activity of
which
he sh uld be aware, Mr.
Huggins
resp nded
by
referencing
the
B t x theft
and
Mr.
Phillips’
s practice
of
signing
the invoices to
appr ve
payment
to
his
wn
law
firm.
ESPO SE:
37. Admit that during
the meeting with Simps n Huggins, Deb Warman, and
Michael Phillips n December 15, 2015,
Mr.
Phillips
and/ r Ms. Wa an told
Mr. Huggins that he
was
being placed n unpaid
administrative
leave.
ESPO SE:
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38.
Admit that
n December
15,
2015,
Metr Health placed
Simps n
Huggins
n
unpaid
administrative
leave.
ESPO SE:
39.
Admit that following the
meeting with
Simps n
Huggins,
Deb
Warman,
and
Michael Phillips
n
December 15, 2015,
Mr. Huggins
was
esc rted
fr m the
building
with ut
being permitted to retrieve his pers nal items fr m his
office.
ESPO SE:
40. Admit that Simps n Huggins
c nducted
internal audits
at
Metr Health
in
the c urse of his empl yment.
ESPO SE:
41. Admit that during
the
c urse
of
Simps n Huggins ’s empl yment, he became
aware of crimes that Metr Health had
the
auth rity to correct.
ESPO SE:
42.
Admit that during the c urse of
Simps n
Huggins
’s
empl yment, he became
aware
of
violations by state
law by fellow
empl yees.
ESPO SE:
43. Admit that Simps n Huggins made
reas nable
and good-faith efforts to
determine
the
accuracy of
the
inf rmati n that
he
rep rted to Metr Health
n December 15,
2015.
ESPO SE:
44.
Admit that it was reas nable for
Simps n
Huggins
to
believe that the theft of
B t x and ther services fr m the Metr Health Pepper
Pike
Dermat l gy
linic
was
a felony.
ESPO SE:
45.
Admit
that
it was reas nable for
Simps n
Huggins to
believe that the use
of
public hospital funds to pay for Dr.
B utr s’
s
pers nal travel
expenses
was
a
felony.
ESPO SE:
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46.
Admit that
n December
15,
2015,
Simps n
Huggins
orally
notified
resp nsible
officers at Metr Health of potential felony criminal activity.
ESPO SE:
47.
Admit that Simps n
Huggins ’
s
presentati n
to
the Audit
mmittee
n
December
15,
2015
satisfied the
oral-report requirements
of
R. .
4113.52(A)(1)(a).
ESPO SE:
48.
Admit
that
Simps n
Huggins ’
s
presentati n
to
the
Audit
mmittee
n
December 15, 2015
satisfied the oral-report
requirements
of
R. . 4113.52(A)(3).
ESPO SE:
49. Admit that Simps n Huggins ’
s
written audit
report
transmitted n
December
15, 2015 satisfied
the
written-report
requirements of R. . 4113.52(A)(1)(a).
ESPO SE:
50.
Admit that
Simps n
Huggins ’
s
written
audit
report transmitted n December
15,
2015 satisfied the written-report
requirements
of R. .
4113.52(A)(3).
ESPO SE:
51. Admit that General unsel Michael D. Phillips is
a
“resp nsible officer” of
Metr Health
as
that term
is used
in
R. .
4113.52(A)(1)(a) and R. .
4113.52(A)(3).
ESPO SE:
52.
Admit that hief
Operating
Officer Dan Lewis is a
“
resp nsible
officer
” of
Metr Health as that term is used
in
R. .
4113.52(A)(1)(a) and R. .
4113.52(A)(3).
ESPO SE:
53.
Admit
that
hief
Quality
Officer Alfred
nn rs
is
a
“
resp nsible
officer
”
of
Metr Health
as that term is used
in
R. .
4113.52(A)(1)(a) and R. .
4113.52(A)(3).
ESPO SE:
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54.
Admit that hief
Financial
Officer
raig
Richm nd
is a
“
resp nsible
officer”
of Metr Health as that term is used in R. . 4113.52(A)(1)(a) and R. .
4113.52(A)(3).
ESPO SE:
55.
Admit that
Executive
Direct r and
hairman
for Dermat l gy Abel
T rres
is
a
“resp nsible officer” of
Metr Health
as that term is used in R. .
4113.52(A)(1)(a) and R. .
4113.52(A)(3).
ESPO SE:
56. Admit that linical Services
Line
Leader Brendan Patters n is
a
“resp nsible
officer” of Metr Health as that term is used in R. . 4113.52(A)(1)(a) and R. .
4113.52(A)(3).
ESPO SE:
57. Admit that hief mpliance Officer
Mary
Legerski is a “resp nsible officer
”
of
Metr Health as
that
term
is
used in
R. .
4113.52(A)(1)(a)
and
R. .
4113.52(A)(3).
ESPO SE:
58.
Admit that
Simps n Huggins ’
s
written
audit
report
n
December
15,
2015
pr vided
sufficient
detail
to
identify
and
describe
the
potential
felony
criminal
activity
he
had
unc vered
during
his audit.
ESPO SE:
59.
Admit that
Metr Health
retaliated against
Simps n
Huggins because he
rep rted felony criminal activity.
ESPO SE:
60.
Admit that
Metr Health
did
n t
notify
Simps n
Huggins, in writing,
of
any
effort
of
Metr Health
to
correct the violations
he
had reported.
ESPO SE:
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December 21, 2015
Respectfully submitted,
Subodh
Chandra
_ _ _ _ _ _ _ _ _ _ _ _
Sub dh
handra
(0069233)
Ashlie
ase
Sletvold
(0079477)
Harris n Blythe
(00093851)
THE
HANDRA
W
FIRM,
LL
1265 W. 6th St., Suite 400
leveland, OH
44113-1326
216.578.1700
Ph ne
216.578.1800
Fax
Sub dh. handra@ handraLaw.c m
Ashlie.Sletv ld@ handraLaw.c m
Harris n.Blythe@ handraLaw.c m
Coun el for
Plaintiff
Simp on
Huggin
III
ertificate
of ervice
I
certify
that the ab ve
disc very requests
were
submitted
to the lerk’s
Office to
be
served with the Summ ns
and mplaint.
bodh
Chandra
_ _ _ _ _ _ _
One of the
attorney
for
Plaintiff
Simp on
Huggin
III
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IN
THE
OURT OF MM N LEAS
UYAHOGA
OUNTY,
OH
Simpson
Huggins
III
Plaintiff, ase No.
vs.
Judge
The MetroHealth System
Defendant.
P intiff First et of equests for Production of ocuments irected
to efend nt
T
he
Metro e th ystem
under
Ohio
iv
6
Under Ohio Rule of ivil Procedure 34, Plaintiff requests that Defendant
respond
to
Plaintiff’s
First Requests for
Production
of
Documents within 28
days
of
service.
instructions
A.
Definitions. In
answering
each request,
use the following definitions:
1. The
words
“you
”
or “MetroHealth
”
refer
to
Defendant The MetroHealth
System, the party responding to these requests, and/or its agents, employees,
attorneys, representatives, and/or assigns.
2.
The
terms
“document,”
“documents,
” “record,”
or
“
records
”
mean
the
original and
a copy,
regardless
of origin
or
location,
of
any
writing or
records of
any
type
or
description,
whether official
or
unofficial,
including,
but
not limited to,
the
original
and any copy of
any
book,
pamphlet,
periodical, letter, memorandum,
telegram,
report,
record, study,
inter- or intra-office communication,
handwritten
or
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ther
note,
w rking
paper,
publication,
permit,
ledger
and/ r
journal,
whether
general
or
special,
chart,
paper, graph,
survey,
index tape,
disk,
data
sheet,
or
data-
pr cessing card,
or
any
ther
written,
recorded,
transcribed,
filed,
or graphic
matter, h wever pr duced or repr duced, to which Defendant had access or n w has
access. “D cument” or “d cuments” also includes any magnetically, mechanically,
and/ r electronically stored, maintained, and/ r rec rded data, whether the
data
consists of
w rds, symb ls,
numbers,
graphs,
or
ther matters,
including
but
n t
limited
to
email.
3.
“
And
”
and “or
”
shall
be c nstrued
either
disjunctively or conjunctively
as
necessary
to bring within
the
sc pe of
the
request all resp nses
that might
therwise
be c nstrued to be
utside
its
scope.
4.
“Any
” includes
the
w rd “all,” and “all” includes
the
w rd “any.
”
5.
“
Regarding
”
means
relating
to,
c ncerning,
containing,
consisting
f,
referring
to,
reflecting,
supporting,
dem nstrating, sh wing,
identifying,
menti ning,
contradicting,
prepared
in
c nnecti n with, used
in
preparati n for,
pertaining to, having any
relationship
to, evidencing, constituting evidence f, or
being
in any
way
legally,
logically,
or factually
c nnected
with
the
matter
discussed.
B.
These
requests
seek
electronic c mmunicati ns
n t nly
fr m w rk email
addresses but
also
pers nal
addresses.
. F r each request or part of a request that Defendant refuses to answer n
gr unds of
burdens meness,
state:
1.
The
number of files and/ r
d cuments
needed
to
be
searched;
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2.
The location of such files; and
3. The
appr ximate
time it w uld
take
to c nduct a
search
for
the
requested
information.
D. These requests
for
pr ducti n shall be deemed c ntinuing in nature and
Defendant’s resp nses are to be supplemented as additional inf rmati n or
d cuments pertinent to a request is btained or created, including, but n t limited
to, additional inf rmati n
that
adds
to
a
previ us resp nse, corrects
a
previ us
resp nse,
and/ r
clarifies
a
previ us
response.
E. Privileges
1. F r each
request
or
part
of
a request that Defendant refuses
to
answer
n gr unds
of
privilege,
state:
a. The
specific
privilege asserted;
b.
The
basis
for
the
privilege;
and
c.
The
identity
of the d cuments
and/ r
inf rmati n
claimed
to
be
privileged.
F.
Inf rmati n
requested
is any and all inf rmati n within the kn wledge of
Defendant resp nding to these
requests
and/ r
its
agents,
empl yees,
attorneys,
representatives,
and/ r
assigns.
G.
Plaintiff
requests that,
to preserve paper and reduce c pying costs,
where
feasible, d cuments resp nsive to the requests bel w be pr vided n D, n t in a
hard-c py paper f rmat.
Plaintiff
requests that,
with the excepti ns
n ted bel w,
each
page of
each
d cument
be
Bates-stamped
for
identification.
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H.
S me
of these requests
are
directed to electronically
stored information,
including emails and
w rd-pr cessing
d cuments
stored n Defendant
’s
c mputers,
where practical,
resp nsive
inf rmati n
sh uld
be pr duced in
native
f rmat, n t
c nverted to images or printouts. Plaintiff d es n t require that such d cuments be
pr duced with Bates-stamps, pr vided each d cument has a unique file name. In
the event of high costs of pr ducti n costs
(exceeding
$250), Plaintiff requests that
Defendant
’s c unsel appr ach
Plaintiff’s
c unsel to
confer
regarding
cost-saving
or
cost-sharing
measures
(including
narr wing
the
bel w
requests)
bef re
g ing
f rward with production.
requests
for product o
of
docume s
Please pr duce
the
following:
1.
F r
each
request
for admissi n
that
y u
denied, pr vide
all
d cuments that
tend to
supp rt y ur denial.
ESPO SE:
2.
The
internal
auditing
control
rep rt
prepared
by Simps n Huggins and
transmitted
by email fr m Bryan Licht to raig
Richm nd, Dan Lewis,
Al
nners,
Adel
Torres,
and Brendan
Patters n
at appr ximately
1:00 p.m. n
December
15,
2015.
ESPO SE:
3. Rec rds Simps n
Huggins
relied on, reviewed,
or referenced to prepare
the
internal
auditing
control
rep rt
referenced in
Request
N .
2 above.
ESPO SE:
4.
Rec rds
confiscated fr m Simps n Huggins by Deb Wa man (Vice President
of H man
Res urces)
yesterday
during
the meeting
where
he
was
put
n
unpaid
administrative
leave
including
the
following:
a.
ntents
of
Simps n
Huggins
’
s flash drive (a
silver
Sandisk
attached
to his lanyard with his hospital ID);
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b. Rep rts
for
audit
c mmittee,
rep rt for finance c mmittee,
rep rt that
RMS (external auditors) gave, c mpliance department update; and
HI AA privacy update.
ESPO SE:
5. Rec rds
regarding
the
theft
of
B t x and/ r services
relating
to
B t x
injections
(or ther injectables) pr vided with ut charge to Metr Health
empl yees
or relatives
of
Metr Health
empl yees (patient-identifying
inf rmati n ay
be redacted;
dates of
service, pr viding physician, and
location
are
n t
exempted and must be
made
available).
ESPO SE:
6.
Rec rds
regarding
trips
taken
by
Dr.
Akram
B utr s
and/ r
his
wife
that
were funded by Metr Health or the Metr Health F undati n (including trips
to
Venice,
L nd n, New
Y rk, and
Abu
Dhabi).
ESPO SE:
7.
Rec rds
regarding
any expenditures by
Metr Health
n Dr.
B utr s
’
s
behalf
related
to
his
New
Y rk
medical
license (including
expenses
for m nthly trips
to New
Y rk
to meet the
requirements
to maintain
his
out-of-state
medical
license).
ESPO SE:
8.
Rec rds
regarding
any ther expenditures by
Metr Health
n Dr. B utr s’s
behalf.
ESPO SE:
9. Rec rds
regarding misuse of
Metr Health credit cards by Metr Health
empl yees fr m July 2013-the
present.
ESPO SE:
10.
Rec rds
regarding
failure
to
follow
Metr Health
pr cedures
regarding
payment of credit-card
bills
with ut pr per
receipts
or
d cumentati n
that
the expenditures were appr priate fr m July 2013-the present.
ESPO SE:
11. Rec rds regarding
the
Audit mmittee
meeting
held yesterday at n n
including n tes
taken
by any participant.
ESPO SE:
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12. Rec rds
regarding
the
decision to curtail
Simps n
Huggins
’s
email or
c mputer access and the implementati n of that decision (including all
c mmunicati ns
such as
emails
or
text
messages).
ESPO SE:
13. Rec rds
regarding
the
decision
to
exclude
Simps n
Huggins
fr m
the
Finance
mmittee
meeting that
immediately
f ll wed
yesterday
’s Audit mmittee
meeting (including
all
c mmunicati ns
such
as
emails
or text
messages).
ESPO SE:
14. The entire
c ntents
of
Simps n Huggins ’s
Metr Health
“
drive.”
ESPO SE:
15. Simps n Huggins ’s
emails (current and archived)
fr m July 2013 to the
present
including emails between or am ng Mr. Huggins and
each
of the
following:
a.
General
unsel
Michael Phillips;
b. Vice President
of
linical Integrated
Operati ns
Dean
R berts n;
c.
Executive Direct r/ hairman Dermat l gy Abel Torres;
d.
Audit
mmittee
hairman
J.B.
Silvers;
e. f rmer
Audit
mmittee
hairman R n F untain;
f. Seni r
Vice President and
hief
Financial
Officer
raig Richm nd; and
g.
Ass ciate General
unsel
S nja Rajki.
ESPO SE:
16. Any internal audit charter applicable to Simps n Huggins w rk
at
Metr Health.
ESPO SE:
17. J b description for Director,
Internal Audit.
ESPO SE:
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18. G vernance rules
and regulati ns
regarding
the
functions
of
the
B ard of
Trustees.
ESPO SE:
19. Finalized
Internal
Audit
reports
and
management
plans
fr m January 2012
to
the
present.
ESPO SE:
20.
All empl yee
expense
files
submitted
to
Simps n
Huggins by
A a da Gibs n
(Director, Acc unting for Disbursements) and/ r
David
rt (Staff
Acc untant) fr m 2012-2015 for Financial Rep rting ntr ls testing.
ESPO SE:
21. Daily visit summaries for Pepper Pike Dermat l gy linic fr m 2013-the
present.
ESPO SE:
22.
Listing
and schedule of residents for Pepper Pike Dermat l gy linic fr m
2013-the present.
ESPO SE:
23.
All
rec rds
regarding
the
decision
to
place
Simps n
Huggins
n
unpaid
administrative
leave (including all c mmunicati ns such as emails
or
text
messages).
ESPO SE:
24. Dr. Akram B utr s’s c mpensati n contracts (including any drafts).
ESPO SE:
25. Dr. Akram B utr s
’s
empl yment contracts
(including any drafts).
ESPO SE:
26.
Empl yee
expense
reimbursements
for Akram B utr s.
ESPO SE:
27.
Rel cati n
expenses paid
by
Metr Health
for
Akram
B utr s (both
m ves).
ESPO SE:
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28. Rec rds
regarding any policies
n empl yee
use
of Metr Health credit
cards.
ESPO SE:
29.
Simps n
Huggins ’s pers nnel rec rds including his pers nnel file
and
any
rec rds
that
w uld
typically
be kept
in
a
pers nnel
file (whether Metr keeps
such
rec rds in
an
empl yee ’
s
pers nnel
file
or
not).
ESPO SE:
30.
Pers nnel rec rds including pers nnel
files
and
any
rec rds that w uld
typically
be kept in a
pers nnel
file
(whether Metr keeps
such
rec rds
in
an
empl yee ’s pers nnel file or not)
for
any
empl yee
placed n paid
or
unpaid
administrative leave fr m January 2012 to the present.
ESPO SE:
31. All credit-card statements fr m
N
related to c rp rate
cards
for all
appr ved Metr Health empl yees (fr m July 2013-December 2014).
ESPO SE:
32.
Rec rds regarding
discipline
of
any
empl yee for failing to c mply with
Metr Health
policies regarding
credit-card
use.
ESPO SE:
33.
Rec rds
regarding discipline of
any empl yee
for
theft of
B t x
or
ther
injectables.
ESPO SE:
34.
Rec rds
regarding payment for legal services
related
to Simps n Huggins
including
but
n t
limited
to
the
decision to place him n unpaid
administrative
leave.
ESPO SE:
35. The c mpetitive sealed pr p sal that created the three-year service contract
between
Metr Health
and
the
Advis ry
B ard
mpany.
ESPO SE:
36.
All
contracts
and
amendments
between
Metr Health
and the
Advis ry
B ard
mpany
fr m
2013-the present.
ESPO SE:
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37.
Rec rds sent to
the
Ohi Att rney General
’s
office regarding
delegating
signat ry auth rity fr m Akram B utr s to Walter Jones, Seni r Vice
President,
ampus
Transf rmati n.
ESPO SE:
38.
All
contracts
signed
by
Walter
J nes
fr m
Oct ber
1,
2014 to
Oct ber
31,
2015.
ESPO SE:
39.
Rec rds
fr m
the
Laws n
system
listing
all
direct
reports
to
raig
Richm nd
(including
race, job pay grade, annual
salary
(excluding
benefits),
and
annual
perf rmance bonus).
ESPO SE:
40.
Rec rds
fr m the Laws n system listing
all
Metr Health empl yees
with
pay
grade
36 (including race, job pay grade, annual
salary
(excluding benefits),
and annual perf rmance bonus).
ESPO SE:
41.
de of
nduct Statements for
2013-2015
for
Akram B utr s, Mary
Weir-
B ylan, Elizabeth Allen,
and Michael
Phillips.
ESPO SE:
42.
onflict of
Interest
Statements
for
2013-2015 for
Akram
B utr s, Mary
Weir-
B ylan,
Elizabeth
Allen, and Michael Phillips.
ESPO SE:
43.
Ethics
Statements for 2013-2015
for
Akram B utr s,
Mary
Weir-B ylan,
Elizabeth Allen, and Michael Phillips.
ESPO SE:
44. Rec rds of any reports submitted to the Ohi Ethics mmissi n
regarding
receipt
of free
B t x
injections
by
any Metr Health
empl yee
or
relative
of
a
Metr Health
empl yee.
ESPO SE:
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December 21, 2015
Respectfully submitted,
Subodh
Chandra
_ _ _ _ _ _ _ _ _ _ _
Sub dh
handra
(0069233)
Ashlie
ase
Sletvold
(0079477)
Harris n Blythe
(00093851)
THE
HANDRA
W
FIRM,
LL
1265 W. 6th St., Suite 400
leveland, OH
44113-1326
216.578.1700
Ph ne
216.578.1800
Fax
Sub dh. handra@ handraLaw.c m
Ashlie.Sletv ld@ handraLaw.c m
Harris n.Blythe@ handraLaw.c m
Coun el for
Plaintiff
Simp on
Huggin
III
ertificate
of ervice
I
certify that
the
ab ve
disc very requests were
submitted to
the
lerk
’
s Office to be
served
with
the Summ ns and mplaint.
bodh
Chandra_ _ _ _ _ _ _
One of the attorney for
Plaintiff
Simp on Huggin III