Here are some suggestions for interrogatories that secure basic Medicare information and seek to confirm that no exposure took place on or after Dec. 5, 1980.

1. Are you eligible to receive Medicare benefits?
2. Has Medicare provided any benefits to you or any of your health-care providers related to your medical treatment for alleged injuries that are the subject of this lawsuit?
3. If you answered yes to either 1 or 2 above (regardless of the alleged dates of exposure), please provide the following information:
   
   1. Your HICN or Medicare number;
   2. Your date of birth;
   3. Your Social Security number; and
   4. Any ICD-9 diagnosis code(s) pertaining to your treatment.
4. Do you contend that on or after Dec. 5, 1980, you were exposed to any asbestos-containing products manufactured by this Defendant?
5. If you contend that you were exposed to any asbestos-containing products manufactured by this Defendant on or after Dec. 5, 1980, please provide all information relevant to items 1 – 132 of the Medicare Claim Input File Detail Record, as provided in the MMSEA Section 111 Medicare Secondary Payer Mandatory Reporting, Liability Insurance (Including Self-Insurance), No-Fault Insurance, and Workers’ Compensation.