On February 27, 2019 a
Other - NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS
was filed
involving a dispute between
Cisneros, Roberto,
and
Navarro, Andres Matthew,
for Injury or Damage - Motor Vehicle (OCA)
in the District Court of Hidalgo County.
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Electronically Submitted
4/14/2020 11:37 AM
Hidalgo County Clerk
NO- CL'19'1213'A Accepted by: Samantha Martinez
§ IN THE COUNTY COURT 0F
ROBERT CISNEROS §
§
VS. § HIDALGO COUNTY, TEXAS
§
ANDRES NAVARROS §
§ COUNTY COURT AT LAW NO. 1
NOTICE OF INTENTION
T0 TAKE DEPOSITION BY WRITTEN QUESTIONS
To Plaintiff(s) by and through their attorney(s) of record: GRACIELA MARROQUIN
To other party/parties by and through their attorney(s) of record:
You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition
by written questions will be taken of Custodian of Records for:INSIGHT DIAGNOSTICS AND IMAGING CENTER.
before a Notary Public for Compex Legal Services, Inc. 3201 Cherry Ridge Drive, Suite B207, San Antonio, TX 78230-4825
or its designated agent, which deposition with attached questions may be used in evidence upon and
the trial of the above-styled
numbered cause pending in the above named court.
Notice isfurther given that requestishereby made as authorized under Rules 176 and 200, Texas Rules of Civil
Procedure, to the officer taking the deposition to issue a subpoena duces tecum and cause it to be served on the witness to produce
COPIES 0f alloriginal x—rays films, CT scans, MRIs and any other scans 0r images maintained; and all radiological reports
and records maintained, including a comprehensive list0f alldates and body parts of all films, CT scans, MRIs and all
other images 0r scans taken and/or maintained, pertaining t0 Robert Cisneros from 05/25/2017 only And to turn all such
records over to the officer authorized to take this deposition so that photographic reproductions of the same may be made and
attached to said deposition.
MICHAEL GUERRA
SUSAN L. FLORENCE & ASSOCIATES
W
200 SOUTH 10TH STREET, SUITE 1402
MCALLEN, TX 78501
956-630-6039 FAX 877-697-1295
ATTORNEY FOR DEFENDANT
STATE BAR#: 24032375
I hereby certify thata true and correct copy 0f the foregoing instrument has been forwarded to allCounsel of Record by hand
delivery,
Dated:
FAX, and/or certified mail, return receipt requested, on this day.
4/13/20 W $24M
Compex Order No. TX0028016-001
EMAIL: TEXASCS@COMPEXLEGAL.COM
Electronically Submitted
4/14/2020 11:37 AM
Hidalgo County Clerk
NO- CL'19'1213'A Accepted by: Samantha Martinez
§ IN THE COUNTY COURT OF
ROBERT CISNEROS §
§
vs. § HIDALGO COUNTY, TEXAS
§
ANDRES NAVARROS §
§ COUNTY COURT AT LAW NO. 1
DIRECT QUESTIONS TO BE PROPOUNDED TO
THE CUSTODIAN OF RECORDS FOR:
INSIGHT DIAGNOSTICS AND IMAGING CENTER
From 05/25/2017 t0 05/25/2017
1. Please state yourfullname, occupation and official title.
Answer:
2. Please stateby whom you are employed and the business address.
Answer:
3. Did you receive a subpoena for the production 0f records pertaining t0Robert Cisneros ?
Answer:
4. Are the documents and or things pertaining t0Robert Cisneros ,
as outlined in thesubpoena duces tecum, inyour custody 0r
subj ect t0 your control, supervision or direction?
Answer:
5. Have you provided copies 0f the documents and or things as listed in the subpoena, t0 be attached to this deposition?
If not,
Why not?
Answer:
6. If youanswered “yes” to question no. 5,are the documents and 0r things Which you have provided trueand correct copies 0f
the originals?
Answer:
7. Were such documents and or things kept in the regular course of business of this facility?
Answer:
8. Was it knowledge of the
regular course 0f business of this facility for a person With opinion
acts, events, conditions, or
recorded to make record 0r t0 transmit information thereof t0 be included in such record?
Answer:
Compex Order N0. TX0028016-001
Page 1 of 2
Electronically Submitted
4/14/2020 11:37 AM
9. Were the entries0n these records made time 0f the transaction recorded?
at 0r shortly after the
Accepted by:
gédrSIaggtfiguhr/‘grtfikeer;
Answer:
10. Was themethod 0f preparation of these records trustworthy?
Answer:
WITNESS (Custodian 0f Records)
Before me, the undersigned authority, on this day personally appeared
known t0me to be the person whose name is subscribed to the foregoing instrument in the capacity therein stated,who being first
duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct.Ifurther certify that the
records attached hereto are exact duplicates 0f the original records.
SWORN TO AND SUBSCRIBED before me this day 0f ,
20
NOTARY PUBLIC
Compex Order N0. TX0028016-001
Page 2 of 2
Document Filed Date
April 14, 2020
Case Filing Date
February 27, 2019
Category
Injury or Damage - Motor Vehicle (OCA)
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Electronically Submitted 4/14/2020 11:37 AM Hidalgo County Clerk NO- CL'19'1213'A Accepted by: Samantha Martinez § IN THE COUNTY COURT 0F ROBERT CISNEROS § § VS. § HIDALGO COUNTY, TEXAS § ANDRES NAVARROS § § COUNTY COURT AT LAW NO. 1 NOTICE OF INTENTION T0 TAKE DEPOSITION BY WRITTEN QUESTIONS To Plaintiff(s) by and through their attorney(s) of record: GRACIELA MARROQUIN To other party/parties by and through their attorney(s) of record: You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition by written questions will be taken of Custodian of Records for:INSIGHT DIAGNOSTICS AND IMAGING CENTER. before a Notary Public for Compex Legal Services, Inc. 3201 Cherry Ridge Drive, Suite B207, San Antonio, TX 78230-4825 or its designated agent, which deposition with attached questions may be used in evidence upon and the trial of the above-styled numbered cause pending in the above named court. Notice isfurther given that requestishereby made as authorized under Rules 176 and 200, Texas Rules of Civil Procedure, to the officer taking the deposition to issue a subpoena duces tecum and cause it to be served on the witness to produce COPIES 0f alloriginal x—rays films, CT scans, MRIs and any other scans 0r images maintained; and all radiological reports and records maintained, including a comprehensive list0f alldates and body parts of all films, CT scans, MRIs and all other images 0r scans taken and/or maintained, pertaining t0 Robert Cisneros from 05/25/2017 only And to turn all such records over to the officer authorized to take this deposition so that photographic reproductions of the same may be made and attached to said deposition. MICHAEL GUERRA SUSAN L. FLORENCE & ASSOCIATES W 200 SOUTH 10TH STREET, SUITE 1402 MCALLEN, TX 78501 956-630-6039 FAX 877-697-1295 ATTORNEY FOR DEFENDANT STATE BAR#: 24032375 I hereby certify thata true and correct copy 0f the foregoing instrument has been forwarded to allCounsel of Record by hand delivery, Dated: FAX, and/or certified mail, return receipt requested, on this day. 4/13/20 W $24M Compex Order No. TX0028016-001 EMAIL: TEXASCS@COMPEXLEGAL.COM Electronically Submitted 4/14/2020 11:37 AM Hidalgo County Clerk NO- CL'19'1213'A Accepted by: Samantha Martinez § IN THE COUNTY COURT OF ROBERT CISNEROS § § vs. § HIDALGO COUNTY, TEXAS § ANDRES NAVARROS § § COUNTY COURT AT LAW NO. 1 DIRECT QUESTIONS TO BE PROPOUNDED TO THE CUSTODIAN OF RECORDS FOR: INSIGHT DIAGNOSTICS AND IMAGING CENTER From 05/25/2017 t0 05/25/2017 1. Please state yourfullname, occupation and official title. Answer: 2. Please stateby whom you are employed and the business address. Answer: 3. Did you receive a subpoena for the production 0f records pertaining t0Robert Cisneros ? Answer: 4. Are the documents and or things pertaining t0Robert Cisneros , as outlined in thesubpoena duces tecum, inyour custody 0r subj ect t0 your control, supervision or direction? Answer: 5. Have you provided copies 0f the documents and or things as listed in the subpoena, t0 be attached to this deposition? If not, Why not? Answer: 6. If youanswered “yes” to question no. 5,are the documents and 0r things Which you have provided trueand correct copies 0f the originals? Answer: 7. Were such documents and or things kept in the regular course of business of this facility? Answer: 8. Was it knowledge of the regular course 0f business of this facility for a person With opinion acts, events, conditions, or recorded to make record 0r t0 transmit information thereof t0 be included in such record? Answer: Compex Order N0. TX0028016-001 Page 1 of 2 Electronically Submitted 4/14/2020 11:37 AM 9. Were the entries0n these records made time 0f the transaction recorded? at 0r shortly after the Accepted by: gédrSIaggtfiguhr/‘grtfikeer; Answer: 10. Was themethod 0f preparation of these records trustworthy? Answer: WITNESS (Custodian 0f Records) Before me, the undersigned authority, on this day personally appeared known t0me to be the person whose name is subscribed to the foregoing instrument in the capacity therein stated,who being first duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct.Ifurther certify that the records attached hereto are exact duplicates 0f the original records. SWORN TO AND SUBSCRIBED before me this day 0f , 20 NOTARY PUBLIC Compex Order N0. TX0028016-001 Page 2 of 2