A Kentucky Request for Production of Documents — Injury to Child at Day Care is a legal document used in Kentucky to request specific documents related to an injury sustained by a child at a day care facility. This request is often made during the pre-trial discovery phase of a personal injury lawsuit filed on behalf of the injured child and their family. In such cases, the plaintiff's attorney sends the Request for Production of Documents to the defendant's attorney, outlining the specific documents they seek to obtain. The purpose of this request is to gather evidence and information relevant to the child's injury, such as: 1. Incident Reports: Requesting any incident reports or notifications related to the child's injury that the day care facility may have on file. These reports may include details about the circumstances of the injury, witnesses present, and any actions taken by the day care staff. 2. Medical Records: Seeking all medical records related to the child's injury, including hospital records, emergency room records, physicians' notes, diagnostic tests, imaging results, treatment plans, medication records, and any correspondence between medical professionals involved in the child's care. 3. Staff Training Records: Requesting documentation regarding the training and qualifications of the day care staff members who were present when the injury occurred. This may include records of training programs attended, certifications obtained, and any relevant qualifications necessary for child care providers. 4. Day Care Policies and Procedures: Seeking copies of the day care facility's policies and procedures manual, safety protocols, and any specific guidelines related to child supervision, accident prevention, emergency response plans, and incident reporting. 5. Surveillance Footage: If the day care facility has surveillance cameras installed, the request may ask for copies or access to any recorded footage from the date and time of the child's injury. This can provide visual evidence of the incident or help recreate the sequence of events leading up to the injury. 6. Witness Statements: Requesting written statements or recorded interviews from witnesses who were present during the child's injury. These statements may include firsthand accounts of what they observed, any conversations they had with day care staff, or any information relevant to the incident. It's important to note that the specific documents requested may vary depending on the details of the case and the strategy of the plaintiff's attorney. The above examples provide a general overview of the types of documents typically requested in a Kentucky Request for Production of Documents — Injury to Child at Day Care.