-against-

PLAINTIFF'S ANSWERS
TO DEFENDANT'S FIRST
SET OF INTERROGATORIES
AND REQUEST FOR
PRODUCTION OF DOCUMENTS
Index No. ______
Assigned Judge:
_______________________

Plaintiff Vassar Brothers Hospital, by its attorneys, Daniels and
Daniels, responds to Defendant's First Set of Interrogatories and
Request for Production of Documents dated November 17. 1989, as
follows:

  1.  Identify all monthly reports...............

           (paragraphs 1 - 34 are not included here)

  35.  Set forth each negligent action or failure to act on
  the part of Butterfield which resulted in damages to
  Butterfield as alleged in Paragraph 33 of the Reply.

Butterfield did not require all Board members to attend meetings of
the Board on a regular basis; certain Board members were frequently
absent from Board meetings.  They failed to give adequate direction
to Butterfield's administrators with respect to the administration
and management of the Hospital, in particular the financial
management of the Hospital.  They rejected a 1985 proposal by
Vassar to provide financial management services to Butterfield and
chose instead to hire Prewitt and Sovia.  They failed to hold
and/or to attend finance committee meetings on a consistent or
regualr basis.  They failed to evaluate and/or properly to evaluate
the performance of the administrators of the Hospital.  They failed
to elect officers of the Board on a timely basis.  They failed to
properly monitor the financial condition of the Hospital.  They
failed to review Vassar's performance under the Financial Contract,
as provided therein.  They interfered with the day to day
operations of Butterfield, including, without limitation,
questioning and conversing with employees and ex-employees of the
Hospital regarding matters within the purview of administration.
They interfered with Butterfield's efforts to
collect bills by instructing administration not to pursue
collection efforts against friends and/or acquaintances of certain
members of the Board.  They failed to recruit and/or elect
competent board members.  In response to
administration's expense cutting reports outlining the need to
decrease expenditures, the Board responded by stating that the
Emergency Room physician fees would need to be increased.  They
rejected an expense reduction plan proposed by administration and
unilaterally reinstated employees who had been terminated by
administration pursuant to said plan, by calling these employees at
their homes the weekend after they had been terminated.  Upon
information and belief, they took action at ad hoc meetings which
were not legally held in that all Board members were not given
notice of such meetings.  Physician board members used threatened
resignation from the Medical Staff and/or Board of the Hospital in
order to obtain leverage regarding hospital policy decisions.

                        VERIFICATION  (of above)
      STATE OF NEW YORK )
                        )   ss:.
      COUNTY OF DUTCHESS)
      ___Thomas A. Dee_______, being duly sworn deposes and says:

     That he is Vice President of Vassar Brothers Hospital,
     the plaintiff in this action; that he has read the
     foregoing Answers to Defendant's First Set of
     Interrogatories; and that the answers provided therein
     true to his knowledge, except as to matters therein
     stated upon information and belief and that as to those
     matters, he believes them to be true.
                                           signed
                                  _____________________________
                                  Thomas A. Dee
      Sworn to and
      subscribed before me this
      26th day of January, 1990.
      H. Joseph Duffy notary