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THE STATE OF TEXAS
SUBPOENA IN A CIVIL CASE
CAUSE No. 153-232668-08
VIRGINIA 0. KINSEL, as Attorney-in-Fact for § IN THE DISTRICT COURT
J. FRANK KINSEL, §
J. FRANK KINSEL, JR., Individually, §
CAROLE K. EDWARDS, Individually, and §
CATHERINE K. COLLINS, Individually, §
§
Plaintiffs, §
§ OF TARRANT COUNTY, TEXAS
vs. §
§
JANE 0. LINDSEY, Individually and as §
Co-Trustee of the Lesey B. Kinsel Trust, §
and ROBERT N. OLIVER, §
§
Defendants. § 153rd JUDICIAL DISTRICT
SUBPOENA DUCES TECUM FOR HEARING ON PLAINTIFFS' APPLICATION FOR
A TEMPORARY INJUNCTION
To: Any person authorized to serve and execute subpoenas as provided in Texas
Rule of Civil Procedure 176.5.
YOU ARE COMMANDED to summon the CUSTODIAN OF RECORDS for
TEXAS HEALTH RESOURCES,600 E. Border Street, Suite 1200, Arlington, Texas 75060,
to appear in the Courtroom ofthe 153'd District Court of Tarrant County, Texas, located on the
7111 Floor ofthe Tarrant County Justice Center, 401 West Belknap, Fort Worth, Texas 76196-
0225, on Friday, September 19, 2008 at 10:00 a.m., before The Honorable Ken Curry, to
attend and give testimony on behalf of Plaintiffs at the hearing on Plaintiffs' Application for a
Temporary Injunction, and to remain in attendance from day to day until lawfully discharged.
THE CUSTODIAN OF RECORDS for TEXAS HEALTH RESOURCES IS
COMMANDED to produce and permit inspection and copying of the following documents or
tangible things at the time and date set forth above and in the Courtroom set forth above: A
complete copy ofTexas Health Resources's file on Lesey B. Kinsel (born August 31, 1912)
("Lesey"), and specifically including, but not limited to, any file or files pertaining to Lese~:Jhat
are in Texas Health Resources's possession, custody, or control, which were created ore:,($ ~
maintained by any other entity or individual, and further including, but not limited to, QD.~ ed!}i
;;;; .,.c,.,&;>
rs- V) :]]
SUBPOENA DUCES TECUM
or handwritten medical records, memoranda, reports, or notes pertaining to Lesey and any billing
records for services provided to Lesey by any individual or entity.
CONTEMPT. Failure by any person without adequate excuse to obey a subpoena
served on that person may be deemed a contempt of the court from which the subpoena was
issued or a district court in the county in which the subpoena is served, and may be punished by
fine or confinement, or both. Tex. R. Civ. P. 176.8(a).
ISSUED on September \~2008.
By:
Texas State Bar No. 11523000
B. Dan Berryman
Texas State Bar No. 00793338
Kelly B. Gibbons
Texas State Bar No. 24055548
KIRKLEY & BERRYMAN, L.L.P.
100 N. Forest Park Blvd., Suite 220
Fort Worth, Texas 76102
Telephone: 817.335.3311
Facsimile: 817.335.7733
ATTORNEYS FOR PLAINTIFFS
This subpoena is issued at the request of Plaintiffs VIRGINIA 0. KINSEL, as Attorney-in-
Fact for J. FRANK KINSEL, J. FRANK KINSEL, JR., Individually, CAROLE K. EDWARDS,
Individually, and CATHERINE K. COLLINS, Individually, whose attorneys of record are KIRKLEY
& BERRYMAN, L.L.P., 100 N. Forest Park Blvd., Suite 220, Fort Worth, Texas 76102, telephone
number 817.335.3311, facsimile number 817.335.7733.
SUBPOENA DUCES TECUM PAGE2
ACCEPTANCE OF SERVICE OF SUBPOENA DUCES TECUM BY WITNESS
I hereby accept service of the foregoing Subpoena Duces Tecum. The Custodian of
Records for Texas Health Resources will appear as directed in this Subpoena Duces Tecum and
will produce and permit inspection and copying of the documents described in this Subpoena
Duces Tecum, as directed in this Subpoena Duces Tecum. The Custodian of Records for Texas
Health Resources hereby acknowledges receipt of a Witness fee in the amount of $11.00.
Name
Title
Printed Name
Date
RETURN OF SERVICE OF SUBPOENA DUCES TECUM
I, t!f2e H"'rYiiut , delivered a copy of this Subpoena - Hr'-r/1{
Duces Tecum to L orl,.t ArHo{fnnt~ I If' AN,,-4
c.. f'IIJp(.·,, ~ TeKa{ e::: in person at tff'{tt
y;
S"c?O~E. Border Street, Suite 1200, Ariington, Texas 75060, on the 17 day of September, 2008 at 11
l'r'f
7: 10 o'clock _f___.m. and tendered to the Witness a fee of$11.00.
By: Perso~or~~o has no
interest in the lawsuit and is at least 18
years old
ATTACHMENT: WITNESS FEE ($11.00)
SUBPOENA DUCES TECUM PAGE3