The opinion of the court was delivered by: Judge Virginia M. Kendall
MEMORANDUM OPINION AND ORDER
Plaintiff Elizabeth Awalt ("Plaintiff") brought this suit against Grundy County, its Sheriff, and employees of the Grundy County Jail (collectively "the Grundy County Defendants"), as well as Correctional Healthcare Companies, Inc. and Health Professionals, Ltd., two companies that provide medical services to the Grundy County Jail, and their employees (collectively "the Medical Care Defendants"). Plaintiff's claims arise out of the death of her husband, Robert Awalt ("Mr. Awalt"), who died while in the custody of the Grundy County Jail ("the GCJ"). Plaintiff alleges Defendants violated her husband's federal constitutional rights and asserts claims under 42 U.S.C. § 1983 for denial of medical care, conspiracy, and failure to intervene. Plaintiff also alleges several supplemental state-law claims. Plaintiff now moves to compel discovery of various documents relating to medical care provided at the GCJ.*fn1 For the reasons stated below, Plaintiff's Motion to Compel Discovery is granted in part and denied in part.
I. Grundy County Jail's Filing System
The Grundy County Sheriff's Office maintains an "inmate file" for each inmate detained at the GCJ. This file, which is created upon the inmate's first detention, contains all documentation related to the detainee with the exception of medical records. Inmate Screening Forms, which are used by GCJ booking officers upon intake and contain detainees' statements about their medical condition, are considered part of the inmate file and are not kept with the detainee's medical records. Approximately 15,000 inmate files are currently maintained at the jail. According to Plaintiffs, this includes files for inmates detained at the GCJ at any point from the mid-1980s through the present.
In addition to the inmate file, a "medical file" is maintained by the Medical Care Defendants for any detainee who receives medical care or prescription medication at the GCJ. These files are kept in a designated medical room, and contain medical records from outside treaters, progress notes written by any nurse or physician who treats the detainee at the jail, medical requests (also known as "Sick Call Request Forms") submitted by the detainee, and any general inmate request forms that relate solely to medical care. The medical files also contain detainees' Medical Administration Record ("MAR"), which documents the provision of prescription medication to each detainee. Plaintiff estimates that the GCJ maintains approximately 1,000 medical files. Both inmate and medical files at the GCJ are filed alphabetically and in paper form only.
II. Plaintiff's Motion to Compel Discovery
In her Motion to Compel, Plaintiff seeks production of the following: (1) all documents relating to any and all complaints by detainees or any other person alleging inadequate medical care, denial of medical care, or denial of medication at the GCJ, including officer notes reporting medical care, for the five-year period from September 14, 2005 to September 19, 2010;*fn2 (2) documents from inmate files at the GCJ indicating a detainee had any medical issue, took medication, or needed medication, including Inmate Screening Forms, MARs, medical progress notes, prescriptions, and communications between detainees and the GCJ nurse or doctor for the five-year period from September 14, 2005 to September 19, 2010; (3) MARs for any detainee present at the GCJ on any date between September 1, 2010 and September 30, 2010; (4) any and all documents showing the number of detainees at GCJ who were receiving or supposed to be receiving Dilantin (or phenytoin) or Topamax (or topirmate) from August 14, 2010 through September 20, 2010;*fn3 and (5) any and all Sick Call Request Forms, or other documents requesting to be placed on sick call, obtain medication, or be seen by a nurse or doctor, for any detainee at the GCJ dating from August 14, 2010 through September 30, 2010.
III. Parties' Subsequent Discussions
Pertaining to Plaintiff's Motion By the time Plaintiff's Motion was fully briefed, the parties had already resolved many of the disputes related to Plaintiff's discovery requests. The Medical Care Defendants agreed to fully comply with the third, fourth, and fifth requests described above. Furthermore, the Defendants do not deny that documents falling within Plaintiff's first and second request may lead to evidence that is relevant and admissible at trial, and have agreed to produce detainees' grievances alleging inadequate medical care, denial of medical care, and denial of medication from December 1, 2008 to December 31, 2010, provided that an appropriate protective order is entered. This includes formal written grievances, Sick Call Request Forms, and general request forms that reflect medical care complaints. The Grundy County Defendants have also agreed to produce all oral complaints made to jail and medical staff that were later reduced to writing in the form of "pass on notes" from December 1, 2008 to September, 2010. Lastly, it is the Court's understanding that the Medical Care Defendants have agreed to produce the file containing "officers' notes" describing medical care as reflected in Plaintiff's Motion to Compel at page 7.*fn4
The Defendants object, however, to Plaintiff's request for documents dated before December 1, 2008. According to the Defendants, Plaintiff's request for the production of documents that predate December 1, 2008 is overly broad because it encompasses an irrelevant time period during which Grundy County Sheriff's Office did not use the Medical Care Defendants for medical care at the GCJ. The Defendants also argue that Plaintiff's definition of "medical complaints" is overly broad and would lead to an unduly burdensome and expensive document production that is not reasonably calculated to lead to the discovery of admissible evidence. Specifically, Defendants argue that Plaintiff's request for Inmate Screening Forms and documents related to "any medical issues" a detainee at the GCJ may have had is overly broad because those documents do not reflect detainees' actual complaints about the care they were receiving. The Defendants propose that discovery in this area be limited to medical grievances submitted by detainees, sick call requests, and general request forms that contain medically-related complaints.
Given that the parties have resolved most of the issues presented in Plaintiff's Motion to Compel Discovery, the Court is left to decide the following: (1) whether Plaintiff is entitled to documents related to "any medical issue" a detainee may have had at the GCJ or only those documents that reflect actual complaints filed by detainees for inadequate medical care; and (2) whether the relevant period for Plaintiff's Monell discovery of medical care at the GCJ reasonably includes the time period between September 14, 2005 to December 1, 2008, despite the fact that this time period predates the GCJ's contract with the Medical Care Defendants.
The federal notice pleading system contemplates that parties will have broad discovery to investigate the facts and to help define and clarify the issues. Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978); United States v. Farley, 11 F.3d 1385, 1390 (7th Cir. 1993). Accordingly, Federal Rule of Civil Procedure 26(b)(1) gives broad power to discover information "regarding any non-privileged matter that is relevant to any party's claim or defense...." Fed.R.Civ.P. 26(b)(1). "Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence." Id. See also Oppenheimer, 437 U.S. at 351 (information is relevant if it "bears on" or might reasonably lead to information that "bears on" any material fact or issue in the action); EEOC v. Konica Minolta Bus. Solutions U.S.A., Inc., 639 F.3d 366, 369 (7th Cir. 2011). Because discovery is concerned with "relevant information"-not "relevant evidence"-the scope of relevance for discovery purposes is necessarily broader than it is for trial ...