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CAUSE NO. 153-232668-08
VIRGINIA 0. KINSEL, ET AL * IN THE DISTRICT COURT OF
*
vs. * TARRAMT COUNTY, TEXAS
*
JANE 0. LINDSEY, ET AL * 153RD JUDICIAL DISTRICT
NOTICE OF DEPOSITION UPON WRITTEN QUESTIONS TO
CUSTODIAN OF RECORDS FOR ERROL BRYCE, M.D.
TO: Virginia 0. Kinsel, by and through her attorney of record, J. Lyndell Kirkley,
KIRKLEY & BERRYMAN, 100 North Forest Park Blvd., Suite 220, Fort Worth, Texas
76102.
PLEASE TAKE NOTICE that twenty (20) days after the date of service of this
Notice upon you, the answers, which are to be used in the above-entitled and numbered
case, of the witness, CUSTODIAN OF MEDICAL RECORDS, ERROL BRYCE, M.D.,
1622 Eighth Avenue, Suite 110, Fort Worth, Texas 76104 to written questions, a copy of
which is attached to this Notice, as authorized by Rule 200 ofthe Texas Rules of Civil
Procedure, will be issued directing the Custodian of Records for the above-named
corporation to produce all records as requested in the attached Exhibit "A."
By: C~ ~u. .N:P~ ~
By permission: (
Colin Murchison , f)
JACKSONWALKER 1\A ·~u-4
State Bar No. 24049780
301 Commerce, Suite 2400
Fort Worth, Texas 76102
Phone: (817) 334-7200
---·· ..
N
ATTORNEY FOR RESPONDENT~/ _...... 0
Or7lGlNA~
CERTIFICATE OF SERVICE
THIS IS TO CERTIFY that on the 21ST day of September, 2009, a true and correct copy
of the foregoing Notice of Deposition Upon Written Questions was forwarded by
facsimile to the following:
Virginia 0. Kinsel, by and through her attorney of record, J. Lyndell Kirkley, KIRKLEY
& BERRYMAN, 100 North Forest Park Blvd., Suite 220, Fort Worth, Texas 76102.
By: C.~ JYlt.Hof•Nt:lc By permission: (
Colin Murchison ~ .._,:; '
JACKSONWALKER -/""0~
State Bar No. 24049780
301 Commerce, Suite 2400
Fort Worth, Texas 76102
Phone: (817) 334-7200
ATTORNEY FOR RESPONDENT
.... ·
EXHIBIT A
In regard to the materials requested to be produced below, please note the following:
The term "document" as used herein shall mean anything that is contained on any piece
of paper, or anything that is capable of being reduced to writing, including matters which
are capable of being reproduced audibly of visually.
The term "possession" shall mean that a document or tangible thing is within a person's
possession, custody or control even though such person does not have actual physical
possession of such document or tangible thing as long as the person has a superior right
to compel the production from a third party (including an agency, authority, or
representative).
Pursuant to and as authorized by Rule 200, Texas Rules of Civil Procedure, a Subpoena
Duces Tecum is desired and, in that connection, the Witness shall be commanded to
produce on or after twenty (20) days from the date of service of this Notice, the following
documents:
1. All medical records.
.
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-.
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CAUSE NO. 153-232668-08 VIRGINIA 0. KINSEL, ET AL * IN THE DISTRICT COURT OF * vs. * TARRAMT COUNTY, TEXAS * JANE 0. LINDSEY, ET AL * 153RD JUDICIAL DISTRICT NOTICE OF DEPOSITION UPON WRITTEN QUESTIONS TO CUSTODIAN OF RECORDS FOR ERROL BRYCE, M.D. TO: Virginia 0. Kinsel, by and through her attorney of record, J. Lyndell Kirkley, KIRKLEY & BERRYMAN, 100 North Forest Park Blvd., Suite 220, Fort Worth, Texas 76102. PLEASE TAKE NOTICE that twenty (20) days after the date of service of this Notice upon you, the answers, which are to be used in the above-entitled and numbered case, of the witness, CUSTODIAN OF MEDICAL RECORDS, ERROL BRYCE, M.D., 1622 Eighth Avenue, Suite 110, Fort Worth, Texas 76104 to written questions, a copy of which is attached to this Notice, as authorized by Rule 200 ofthe Texas Rules of Civil Procedure, will be issued directing the Custodian of Records for the above-named corporation to produce all records as requested in the attached Exhibit "A." By: C~ ~u. .N:P~ ~ By permission: ( Colin Murchison , f) JACKSONWALKER 1\A ·~u-4 State Bar No. 24049780 301 Commerce, Suite 2400 Fort Worth, Texas 76102 Phone: (817) 334-7200 ---·· .. N ATTORNEY FOR RESPONDENT~/ _...... 0 Or7lGlNA~ CERTIFICATE OF SERVICE THIS IS TO CERTIFY that on the 21ST day of September, 2009, a true and correct copy of the foregoing Notice of Deposition Upon Written Questions was forwarded by facsimile to the following: Virginia 0. Kinsel, by and through her attorney of record, J. Lyndell Kirkley, KIRKLEY & BERRYMAN, 100 North Forest Park Blvd., Suite 220, Fort Worth, Texas 76102. By: C.~ JYlt.Hof•Nt:lc By permission: ( Colin Murchison ~ .._,:; ' JACKSONWALKER -/""0~ State Bar No. 24049780 301 Commerce, Suite 2400 Fort Worth, Texas 76102 Phone: (817) 334-7200 ATTORNEY FOR RESPONDENT .... · EXHIBIT A In regard to the materials requested to be produced below, please note the following: The term "document" as used herein shall mean anything that is contained on any piece of paper, or anything that is capable of being reduced to writing, including matters which are capable of being reproduced audibly of visually. The term "possession" shall mean that a document or tangible thing is within a person's possession, custody or control even though such person does not have actual physical possession of such document or tangible thing as long as the person has a superior right to compel the production from a third party (including an agency, authority, or representative). Pursuant to and as authorized by Rule 200, Texas Rules of Civil Procedure, a Subpoena Duces Tecum is desired and, in that connection, the Witness shall be commanded to produce on or after twenty (20) days from the date of service of this Notice, the following documents: 1. All medical records. . •-, -.