Plaintiff's Response to APTVC, LLC's Motion to Compel

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Angela Claiborne                                           IN THE DISTRICT COURT        OF

       Plaintiff

Vv.                                                        HARRIS COUNTY,       TEXAS

APTVC, LLC
       Defendant                                           190    JUDICIAL DISTRICT

             Plaintiff’s Response to APTVC, LLC’s Motion to Compel

       Defendant APTVC, LLC’s (““APTVC”) Motion to Compel should be denied because:

       Plaintiff timely responded that she does not have any responsive documents to
       APTVC’s Third Set of Requests for Production. Because APTVC has
       Plaintiff's medical record authorization, the documents sought in APTVC’s
                                          ion are equally available to Defendants.

       The documents requested in APTVC’s Fourth Set of Requests for P
       are inadmissible and irrelevant under the collateral source rule.

       For these reasons, APTVC’s motion should be denied.




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