Preview
FILED
9/23/2020 5:13PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Kevin Molden DEPUTY
CAUSE NO. DC-20-08041
ZENA DAWSON; § IN THE DISTRICT COURT 0F
Plaintiff, g
VS. g DALLAS COUNTY, TEXAS
ERIN BROWN; g
Defendant. g 192“” JUDICIAL DISTRICT
PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING
RECORD AFFIDAVITS
Plaintiff Zena Dawson files with the Court the attached record affidavits:
MEDICAL RECORDS:
1. ECCARE HEALTH CENTERS AFFIDAVIT DATED 09-22-2020
2. LONE STAR RADIOLOGY AFFIDAVIT DATED 09-22-2020
3. NORTH TEXAS OPEN AIR MRI AFFIDAVIT DATED 08-12-2020
BILLING RECORDS:
ECCARE HEALTH CENTERS AFFIDAVIT DATED 09-22-2020
LONE STAR RADIOLOGY AFFIDAVIT DATED 09-22-2020
:“SDNT‘
NORTH TEXAS OPEN AIR MRI AFFIDAVIT DATED 08-12-2020
TARRANT NEUROLOGY CONSULTANTS AFFIDAVIT
DATED 09-23-2020
RADIOLOGY IMAGING:
1. ENVISION IMAGING OF HULEN AFFIDAVIT DATED 05-14-2020
2. NORTH TEXAS OPEN AIR MRI AFFIDAVIT DATED 08-12-2020
By copy of this notice, opposing counsel is notified that these affidavits are
being filed with the Court pursuant to TRE 902. The records/radiology
corresponding to the enclosed affidavits will be kept in Plaintiff's counsel’s office for
use at trial. Opposing counsel has been previously provided with a copy of the
affidavits and corresponding records/radiology listed above.
PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING RECORD
AFFIDAVITS AND CERTIFIED COPIES — Page 1
Respectfully submitted,
WITHERITE LAW GROUP, PLLC
By: /s/ Rob Loar
ROB LOAR
State Bar N0. 24081007
rob.Ioar@witheritelaw.com
SHELLY GRECO
State Bar No. 24008168
shelIv.qreco(o)witheritelaw.com
10440 N. Central Expressway
Suite 400
Dallas, TX 75231-2228
214/378-6665
214/378-6670 (fax)
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
|hereby certify that a true and correct copy of the foregoing has been
forwarded to all counsel of record on this 23rd day of September, 2020 pursuant
to Rule 21a of the Texas Rules of Civil Procedure.
/s/Ro—bLoar
Rob Loar
Chad Kimble
Law Office of Chad Kimble, PC
1204 S. White Chapel Boulevard
Southlake, TX 76092
Attorney for: Defendants
PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING RECORD
AFFIDAVITS AND CERTIFIED COPIES — Page 2
MEDICAL RECORDS AFFIDAVIT OF ECCARE HEALTH CENTERS
REGARDING PATIENT ZENA DAWSON
STATE 0F TEXAS §
§
COUNTY OF E )fl‘ Lfifi §
BEFORE ME, the undersigned authority, personally appeared
Dob res Q ingle‘lbn .who, being by me duly sworn, deposed as follows:
My name is Dobres f3 (‘nq‘e‘ibn .i am of sound mind, capable of making
this Affidavit, and personally acquainted Mm the facts herein stated:
Iam the custodian of the records of EcCare Health Centers. Attached hereto are records from
EcCare Health Centers regarding Zena Dawson. These records are kept by EcCare Heaith Centers in
the regular course of business. and itwas in the regular course of business for an employee or
representative with knowledge of the act, event. condition, opinion, or diagnosis recorded to make the
record or to transmit infonnation thereof to be included in such record; and the record was made at or
near the time of the event recorded or reasonably soon thereafter. The records attached hereto are the
C/
original or exact dupiicates of the original.
/;7
CUSTODIAN—OF MEDICAL RECORDS
SWORN T0 AND SUBSCRIBED before me on the gday of afiflkj ’
20$
NOTARYPUBLfc IMHO FOR THE STATE 0F TEXAS:
“fin. MELISSA M ENNIS
J" "n Notary In #2287117
I -~
My CommissionExpires
V
\~‘ June 11,2023
fa!-
mc‘cssg M‘ E(‘ntfi
NOTARY'S PRINTED NAME:
MY COMMISSION EXPIRES: é ”I [920923
10440 N. CENTRAL EXPRESSWAY SUITE 400, DALLAS. TX 75231 |
WIIHERIYELAWSOM
)
)
Plaintiff, )
) IN THE DISTRICT COURT
VS.
)
) DALLAS COUNTY, TEXAS
)
)
Defendant, )
)
AFFIDAVIT OF CUSTODIAN 0F RECORDS
FOR THE AUTHENTICATION 0F BUSINESS RECORDS
Before me, the undersigned authority, on this day personally appeared DR.
LOU SAUCEDO, JR., D.C., who, being me
by duly sworn, deposed as follows:
10
My name is DR. LOU SAUCEDO, JR., D.C., am
I of sound mind, capable of
11
making this affidavit, and personally acquainted with the fact s here in
state d:
12
I am the custodian of healthcare treatment records for LONE STAR RADIOLOGY,
and I am familiar with the manner in which such records are crea ted and
l3 maintained by virtue of my duties and responsibilities.
l4 Attached hereto are _06_ pages of records from 10/11/2018, pertaining to
ZENA DAWSON. These are exact duplicates of the original records.
15
It is the regular practice of LONE STAR RADIOLOGY to make this type of
record at or near time of each act, event,
l6 condition, opinion, or diagnosis
set forth in the record. It is the regular practice of LONE STAR RADIOLOGY
for this type of record to be made
17
by, or from information tran smit ted
persons with knowledge by,
of the matters set forth in them.
18 It is the regular practice of LONE STAR RADIOLOGY to keep this type of
record in the course of its regularly conducted business activ ity, an is
l9 the regular practice of LONE STAR RADIOLOGY to make the records.
20
Affiant(Custodian of Records)
21
22
23
SWORN 'ro AND SUBSCRIBED before me on the carday of mm, 2020.
Notary P lic, State of Texa
24 Notary's printed name and
commission expires:05—13—23
25
_,‘.‘
LILYSALINAS
My Notary ID # 130225380
Expires
May 2023
13,
, ) Cause No.:
)
Plaintiff, }
) IN THE DISTRICT COURT
vs. )
) DALLAS COUNTY, TEXAS
I )
)
Defendant, )
“
)
AFFIDAVIT OF CUSTODIAN 0F RECORDS
FOR THE AUTHENTICATION 0F BUSINESS RECORDS
Before me, the underéigned authority, on this day personally appeared DR.
LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows:
10
My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of
ll
making this affidavit, and personally acquainted with the facts herein
stated:
12 am the custodian of
I healthcare treatment records for NORTH TEXAS OPEN AIR
MRI, and I am familiar with the manner in which such records are created and
l3 maintained by virtue of my duties and responsibilities.
14 Attached hereto are i06_ pages of records from 10/09/2018, pertaining to
ZENA DAWSON. These are exact duplicates of the original records.
15
It is the regular practice of NORTH TEXAS OPEN AIR MRI to make this type of
record at or near time of each act, event, condition, opinion, or diagnosis
16
set forth in the record. It is the regular practice of NORTH TEXAS OPEN AIR
MRI for this type of record to be made by, or from information transmitted
17 by, persons with knowledge of the matters set forth in them.
18 It is the regular practice of NORTH TEXAS OPEN AIR MRI to keep this type of
record in the course of its regularly conducted business activity, a it is
l9
the regular practice of NORTH TEXAS OPEN AIR MRI to make the rec
20
lant(Custodian of Records)
21
22
23 Notary P lic, State of Texas
Notary’s printed name and
24
commission expires:05—13—23
25
LlYSAUNAS
My NotaryID# 130225380
ExpiresMay 13.2023
AFFIDAVIT OF RECORDS CUSTODIAN OF ECCARE HEALTH CENTERS
REGARDING PATIENT ZENA DAWSON
STATE OF TEXAS §
§
COUNTY OF nfil fi"
‘ §
BEFORE ME the undersigned authority, personalty appeared DOlDr‘ejs 6i flfild’fifl ,
who being by me duly sworn deposed as follows: x.)
My name is 063love?) Difmlejbfl |am of sound mind capable of making
this Affidavit and personally acquainted With the facts herein stated
| am a custodian of records for EcCare Health Centers. Attached to this Affidavit are records that
provide an itemized statement of the service and the charge for the service that EcCare Heatth Centers
provided to Zena Dawson on 9/29/201 8 to present. The attached records are a part of this affidavit.
The attached records are kept by EcCare Health Centers in the reguiar course of business, and
itwas the reguiar course of business of EcCare Health Centers for an empioyee or representative of
EcCare Health Centers, with knowledge of the service provided, to make the record or to transmit
information to be included in the record. The records were made inthe regular course of business at or
near the time or reasonably soon after the time the serv§ce was provided. The records are the originai or
a duplicate of the original.
The services provided were necessary and the amount charged for the service was reasonabie
at the time and ptace that the services were provided.
which
The
EcCare
tote! amount
MEUSSA M ENNIS
paid for the
Health Centers has a
services
right to
WWX
be
was $ ,ZiQBE i331 and
padi
cusmemWECORDs
SWORN TO AND SUBSCRiBED before me on the
NOTARY PUBLiC
aftgr
the
any adjustments or
i;
IN‘"AND
day of
amount
\
credits
currently
Seffifi‘flbfl”,
FOR THE STATE 0F TEXAS:
is$ 3‘-
unpaid
“
20 9.5
but
.
Notary ID #22371
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NOTARYS
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MY COMMISSION EXPIRES: éA I
@0625
10440 N. CENTRAL EXPRESSWAY SUITE 400. DALLAS. TX 7523'! |
WITHERIIELAW£0M
) Cause No:
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Plaintiff, IN THE
) DISTRICT COURT 0F
vs-
DALLAS COUNTY, TEXAS
~ Vvvvvv
Defendant,
AFFIDAVIT REGARDING MEDICAL EXPENSES
(Tex. Civ. Prac. & Rem. Code, Sec. 18.002(b—1)
Before me, the undersigned authority, on this day personally appeared DR.
10 LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows:
ll My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of
making this affidavit, and personally acquainted with the facts herein
stated:
12
I am the custodian of billing records for LONE STAR
l3 RADIOLOGY. Attached to
this affidavit are records that provide an itemized statement of the
service(s)and charge(s) for the service(s) that LONE STAR RADIOLOGY provided
14 to ZENA DAWSON from 10/11/2018. The attached records are a part of this
affidavit.
15
The attached records are kept by LONE STAR RADIOLOGY in the regular course
of business, and it was the regular course of business
16 of LONE STAR RADIOLOGY
for an employee or representative of LONE STAR RADIOLOGY with knowledge of
the service provided, to make the record or to transmit
l7 information to be
included in the record. The records were made in the regular course of
business at or near the time or reasonably soon after the time the service
18 was provided. The records are a duplicate of the original.
l9 The services provided were necessary and the amount charged for the
services was reasonable at the time and place that the services were
20
provided.
The total amount paid for the services was $0.00 and
21 the amount currently
unpaid but which LONE STAR RADIOLOGY has a right to be paid after any
adjustments or credits is $396.00. This amount may include
22
a Records Summary
Report fee of $150.00.
23
24
25 AFFIANT(Custodian Of Records)
) Cause No
l ,
)
)
2 Plaintiff, ) IN THE DISTRICT COURT OF
)
3 VS» ). DALLAS COUNTY, TEXAS
3
4 ,
)
)
5 Defendant, )
6
7 AFFIDAVIT REGARDING MEDICAL EXPENSES
8 (Tex. Civ. Prac. & Rem. Code, Sec. 18.002(b—1)
9 .
Before me, the undersigned authority, on this day perSonally appeared DR.
10 LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows:
11 My name is DR. LOU SAUCEDO, JR.; D.C., I am of sound mind, capable of
making this affidavit, and personally acquainted with the facts herein
gtated:
12
I am the custodian of billing records for NORTH TEXAS OPEN AIR MRI.
13 Attached to this affidavit are records that provide an itemized statement of
the service(s)and charge(s) for the service(s) that NORTH TEXAS OPEN AIR MRI
l4 provided to ZENA DAWSON from 10/09/2018. The attached records are a part of
this affidavit.
15 ‘
The attached recgrds are kept by NORTH TEXAS OPEN AIR MRI 1n the regular
course of business, and it was the regular course of business of NORTH TEXAS
l6
OPEN:AIR MRI for an employee or representative of NORTH TEXAS OPEN AIR MRI
with'knowledge of the service provided, to make the record or to transmit
l7 information to be included in the record. The records were made in the
regular course of business at or near the time or reasonably soon after the
18 time the service was provided. The records are a duplicate of the original.
19 The services provided were necessary and the amount charged for the
services was reasonable at the time and place that the services were
provmded.
20
The total amount paid for the services was $0.00 and the amount currently
21 unpaid but which NORTH TEXAS OPEN AIR MRI has a ri‘éfitflfibfl p i'awaftérany—
adjustments or credits is $8,784.00. This amount may include a Records
22 Summary Report fee of $150.00.
23
24
65353:;3§%IANT(Custodian Of Records)
25
AFFIDAVIT 0F RECORD§ CQ§| ODIAN OF TARRANT HEURDLDGY CDNfiuLTafllfi
REGARDI T ZENA D
STATE DF TEXAS 5
COUNTY OF g
_
BEFORE ME, the undersigned authority,
who. being by ma duly sworg, deposed as followa:
personally appeamd F -S
My
thl$ Affidavit
name is WW
and parsunally acqualntalj with the
V Y“ S .I am
facts heraln stated.
of sound mind. capable of making
Iam a custadlan of racerds fur Tarrant Naumlogy Consultants. Attached to this Affidavit are
records that provlde an Itemized .statemant of the Service and the charge for the service that Tarrant
Neurology Cansultanta pravlded to Zena Dawson on 912912013 to present. Tha attached ramrds are a
part of this affldavlt.
The attached records are kept by Tarrant Neurology Consultants In the regular courae 0f
business and It was the regular course of business of Tarrant Neurology Consultanm fur an employee
0r rapramntatlve of Tarrant Neurology Consultants with knawledga of the service pruvldad. to maka the
record or to transmit information to be included in tha racord. The records ware mada In the regular
course of business at or near the time or reasonably soun after the time the service was provlded. The
racorda are the urlglnal 0r a duplicate of the nrlglnal.
The services provided were necessary and the amaunt charged for the service was raasnnabla
at the tlme and placa that the services ware provided.
The total amaunt paid for tha sarvlces was $1M 32.1 and the amount currently unpaid but
w [ch rrant Naurnlngy Gonaultants has a right to be after any adjustmenm 0r credits ls
$ »
.
l—
\w: I
CST DIA
“13%
OPE WING RECORDS
f‘fli'fa,
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a?"
.
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KRYSTAL MAME MAYES
fiNotary Public
Comm
State of Tunas
Expires 01 45 2024
Notarym 130510133
‘
,_
NOTAW PUBLIC
m
NDTARY'S HRINTED NAME:
Ww
IN AND FOR THE STATE 0F TEXAS:
10440 N. CENTRAL EXPRESSWAY SUITE 400. DALLAS. TX 75331 I
WITHERITELAWEOM
RIDIOLOGY RECORDS AFFIDAVIT OF EHWSION IMAGING - Hug"
REGHDIHG PATIENT EMA DMSON
STATE OFW 00‘9“?“
§
§
counrrv 0F El P350 §
BEFORE RE. the undersigned authority. personahy appearad
chamgg Mggman “who bamg by me duty sworn deposed as fiolkmrs.
M; name is Chariton McGowan . l am 0t sound mind. capable at making
this Afltdavit. and parsonaily acquainted with the lacls herflin stated:
2
Iam me custodian unne records oi Erm‘sion Imagmg -
Hum Attached hereto are mms
lrom Envision tnaglng - Hulen regarding Zena Dawson. These said films are kept by Envision Imaging
v Hulan inthe regular courseaf Dusmess. and :twas m the regular caurse of bummss far an ampbyee
or repreaenlallue with kncwfadgna of lhe ant. went. condition. opinion. Dr diagnosis recorded m make
such. films or tn cause Such films to be made and me fiims were made at or near ma hme of the act
event. common. opumon or diagnosns. or reasonably soon thereafter. The films attached harem are me
original or exact duplicates aflhe
mw MW
originals.
CUSTODIAN OF RADQLOGY
SWDRN TO m SLBSCRBED bdore me on thew day of n}fi#
I
. 20
Z (J
7M)”m
NOTJR‘I' FUBLE N FOR TIE
I
STATE
OW £3
Xflrucx-L Ut {\A‘n—K
7
r
NOTARVS PRNTED NINE:
MY GDMSION EKPRES:
X)?(767Q
,
) Cause No.:
)
Plaintiff, )
) IN THE DISTRICT IN AND FOR COUNTY,
vs. TEXAS
)
)
I
)
)
Defendant )
)
RADIOLOGY DISC AFFIDAVIT
Before me, the undersigned authority, on this day personally appeared DR. LOU
SAUCEDO, JR., who, being by me duly sworn, deposed as follows:
My name is DR. LOU SAUCEDO, JR., I am of sound mind, capable of making this
affidavit, and personally acquainted with the
10 facts herein state d:
I am the custodian of radiology disc for NORTH TEXAS
ll OPEN AIR MRI, regarding
records from 09/24/1965 pertaining to ZENA DAWSON, DOB: 09/24/1965, SSN: N/A.
12 Attached hereto is __1__ radiology disc from NORTH TEXAS OPEN AIR MRI
pertaining to ZENA DAWSON. These said __1__ radiology disc are kept by NORTH
13 TEXAS OPEN AIR MRI in the regular course of business, and it was the regul ar
course of business of NORTH TEXAS OPEN AIR MRI for an employee or
14
representative of NORTH TEXAS OPEN AIR MRI with knowledge of the act, event,
condition, opinion, or diagnosis recorded to make the record or to transmit
information thereof to be included in such
15 record; and the record was made at
or near the time or reasonably soon thereafter.
I
l6 The films attached hereto are the original or exact duplicates of the
original.
17
18
19
swoan To AND SUBSCRIBED before me on the £ day of '4LLLI.,.L 1 ,
Affiant
2020.
20
Ir
21
‘
Notary
.I,‘
P
’1‘ 4/4
olic,
ll
State
‘
1
of Texa
22 Notary’s printed name and
commission expires:05—13-2023
23
-.E LlYSAUNAS
24 {.5 My Notary ID # 130225380
+‘
\- ExpiresMay 13,2023
25 .4..—
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Erica Lisenbe on behalf of Rob Loar
Bar No. 24081007
Erica.Lisenbe@witheritelaw.com
Envelope ID: 46533551
Status as of 9/24/2020 4:22 PM CST
Associated Case Party: ZENA DAWSON
Name BarNumber Email TimestampSubmitted Status
Rob Loar Rob.Loar@witheritelaw.com 9/24/2020 11:42:14 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Robert Chad Kimble 24007483 eservice@chadkimblelaw.com 9/24/2020 11:42:14 AM SENT
Kyle Smith 24102512 kyle@chadkimblelaw.com 9/24/2020 11:42:14 AM SENT
Preview
FILED 9/23/2020 5:13PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Kevin Molden DEPUTY CAUSE NO. DC-20-08041 ZENA DAWSON; § IN THE DISTRICT COURT 0F Plaintiff, g VS. g DALLAS COUNTY, TEXAS ERIN BROWN; g Defendant. g 192“” JUDICIAL DISTRICT PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS Plaintiff Zena Dawson files with the Court the attached record affidavits: MEDICAL RECORDS: 1. ECCARE HEALTH CENTERS AFFIDAVIT DATED 09-22-2020 2. LONE STAR RADIOLOGY AFFIDAVIT DATED 09-22-2020 3. NORTH TEXAS OPEN AIR MRI AFFIDAVIT DATED 08-12-2020 BILLING RECORDS: ECCARE HEALTH CENTERS AFFIDAVIT DATED 09-22-2020 LONE STAR RADIOLOGY AFFIDAVIT DATED 09-22-2020 :“SDNT‘ NORTH TEXAS OPEN AIR MRI AFFIDAVIT DATED 08-12-2020 TARRANT NEUROLOGY CONSULTANTS AFFIDAVIT DATED 09-23-2020 RADIOLOGY IMAGING: 1. ENVISION IMAGING OF HULEN AFFIDAVIT DATED 05-14-2020 2. NORTH TEXAS OPEN AIR MRI AFFIDAVIT DATED 08-12-2020 By copy of this notice, opposing counsel is notified that these affidavits are being filed with the Court pursuant to TRE 902. The records/radiology corresponding to the enclosed affidavits will be kept in Plaintiff's counsel’s office for use at trial. Opposing counsel has been previously provided with a copy of the affidavits and corresponding records/radiology listed above. PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND CERTIFIED COPIES — Page 1 Respectfully submitted, WITHERITE LAW GROUP, PLLC By: /s/ Rob Loar ROB LOAR State Bar N0. 24081007 rob.Ioar@witheritelaw.com SHELLY GRECO State Bar No. 24008168 shelIv.qreco(o)witheritelaw.com 10440 N. Central Expressway Suite 400 Dallas, TX 75231-2228 214/378-6665 214/378-6670 (fax) ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE |hereby certify that a true and correct copy of the foregoing has been forwarded to all counsel of record on this 23rd day of September, 2020 pursuant to Rule 21a of the Texas Rules of Civil Procedure. /s/Ro—bLoar Rob Loar Chad Kimble Law Office of Chad Kimble, PC 1204 S. White Chapel Boulevard Southlake, TX 76092 Attorney for: Defendants PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND CERTIFIED COPIES — Page 2 MEDICAL RECORDS AFFIDAVIT OF ECCARE HEALTH CENTERS REGARDING PATIENT ZENA DAWSON STATE 0F TEXAS § § COUNTY OF E )fl‘ Lfifi § BEFORE ME, the undersigned authority, personally appeared Dob res Q ingle‘lbn .who, being by me duly sworn, deposed as follows: My name is Dobres f3 (‘nq‘e‘ibn .i am of sound mind, capable of making this Affidavit, and personally acquainted Mm the facts herein stated: Iam the custodian of the records of EcCare Health Centers. Attached hereto are records from EcCare Health Centers regarding Zena Dawson. These records are kept by EcCare Heaith Centers in the regular course of business. and itwas in the regular course of business for an employee or representative with knowledge of the act, event. condition, opinion, or diagnosis recorded to make the record or to transmit infonnation thereof to be included in such record; and the record was made at or near the time of the event recorded or reasonably soon thereafter. The records attached hereto are the C/ original or exact dupiicates of the original. /;7 CUSTODIAN—OF MEDICAL RECORDS SWORN T0 AND SUBSCRIBED before me on the gday of afiflkj ’ 20$ NOTARYPUBLfc IMHO FOR THE STATE 0F TEXAS: “fin. MELISSA M ENNIS J" "n Notary In #2287117 I -~ My CommissionExpires V \~‘ June 11,2023 fa!- mc‘cssg M‘ E(‘ntfi NOTARY'S PRINTED NAME: MY COMMISSION EXPIRES: é ”I [920923 10440 N. CENTRAL EXPRESSWAY SUITE 400, DALLAS. TX 75231 | WIIHERIYELAWSOM ) ) Plaintiff, ) ) IN THE DISTRICT COURT VS. ) ) DALLAS COUNTY, TEXAS ) ) Defendant, ) ) AFFIDAVIT OF CUSTODIAN 0F RECORDS FOR THE AUTHENTICATION 0F BUSINESS RECORDS Before me, the undersigned authority, on this day personally appeared DR. LOU SAUCEDO, JR., D.C., who, being me by duly sworn, deposed as follows: 10 My name is DR. LOU SAUCEDO, JR., D.C., am I of sound mind, capable of 11 making this affidavit, and personally acquainted with the fact s here in state d: 12 I am the custodian of healthcare treatment records for LONE STAR RADIOLOGY, and I am familiar with the manner in which such records are crea ted and l3 maintained by virtue of my duties and responsibilities. l4 Attached hereto are _06_ pages of records from 10/11/2018, pertaining to ZENA DAWSON. These are exact duplicates of the original records. 15 It is the regular practice of LONE STAR RADIOLOGY to make this type of record at or near time of each act, event, l6 condition, opinion, or diagnosis set forth in the record. It is the regular practice of LONE STAR RADIOLOGY for this type of record to be made 17 by, or from information tran smit ted persons with knowledge by, of the matters set forth in them. 18 It is the regular practice of LONE STAR RADIOLOGY to keep this type of record in the course of its regularly conducted business activ ity, an is l9 the regular practice of LONE STAR RADIOLOGY to make the records. 20 Affiant(Custodian of Records) 21 22 23 SWORN 'ro AND SUBSCRIBED before me on the carday of mm, 2020. Notary P lic, State of Texa 24 Notary's printed name and commission expires:05—13—23 25 _,‘.‘ LILYSALINAS My Notary ID # 130225380 Expires May 2023 13, , ) Cause No.: ) Plaintiff, } ) IN THE DISTRICT COURT vs. ) ) DALLAS COUNTY, TEXAS I ) ) Defendant, ) “ ) AFFIDAVIT OF CUSTODIAN 0F RECORDS FOR THE AUTHENTICATION 0F BUSINESS RECORDS Before me, the underéigned authority, on this day personally appeared DR. LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows: 10 My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of ll making this affidavit, and personally acquainted with the facts herein stated: 12 am the custodian of I healthcare treatment records for NORTH TEXAS OPEN AIR MRI, and I am familiar with the manner in which such records are created and l3 maintained by virtue of my duties and responsibilities. 14 Attached hereto are i06_ pages of records from 10/09/2018, pertaining to ZENA DAWSON. These are exact duplicates of the original records. 15 It is the regular practice of NORTH TEXAS OPEN AIR MRI to make this type of record at or near time of each act, event, condition, opinion, or diagnosis 16 set forth in the record. It is the regular practice of NORTH TEXAS OPEN AIR MRI for this type of record to be made by, or from information transmitted 17 by, persons with knowledge of the matters set forth in them. 18 It is the regular practice of NORTH TEXAS OPEN AIR MRI to keep this type of record in the course of its regularly conducted business activity, a it is l9 the regular practice of NORTH TEXAS OPEN AIR MRI to make the rec 20 lant(Custodian of Records) 21 22 23 Notary P lic, State of Texas Notary’s printed name and 24 commission expires:05—13—23 25 LlYSAUNAS My NotaryID# 130225380 ExpiresMay 13.2023 AFFIDAVIT OF RECORDS CUSTODIAN OF ECCARE HEALTH CENTERS REGARDING PATIENT ZENA DAWSON STATE OF TEXAS § § COUNTY OF nfil fi" ‘ § BEFORE ME the undersigned authority, personalty appeared DOlDr‘ejs 6i flfild’fifl , who being by me duly sworn deposed as follows: x.) My name is 063love?) Difmlejbfl |am of sound mind capable of making this Affidavit and personally acquainted With the facts herein stated | am a custodian of records for EcCare Health Centers. Attached to this Affidavit are records that provide an itemized statement of the service and the charge for the service that EcCare Heatth Centers provided to Zena Dawson on 9/29/201 8 to present. The attached records are a part of this affidavit. The attached records are kept by EcCare Health Centers in the reguiar course of business, and itwas the reguiar course of business of EcCare Health Centers for an empioyee or representative of EcCare Health Centers, with knowledge of the service provided, to make the record or to transmit information to be included in the record. The records were made inthe regular course of business at or near the time or reasonably soon after the time the serv§ce was provided. The records are the originai or a duplicate of the original. The services provided were necessary and the amount charged for the service was reasonabie at the time and ptace that the services were provided. which The EcCare tote! amount MEUSSA M ENNIS paid for the Health Centers has a services right to WWX be was $ ,ZiQBE i331 and padi cusmemWECORDs SWORN TO AND SUBSCRiBED before me on the NOTARY PUBLiC aftgr the any adjustments or i; IN‘"AND day of amount \ credits currently Seffifi‘flbfl”, FOR THE STATE 0F TEXAS: is$ 3‘- unpaid “ 20 9.5 but . Notary ID #22371 17 ' Wim‘fiifam'“ _. mo] {fig NOTARYS M PRINTED Ems NAME; MY COMMISSION EXPIRES: éA I @0625 10440 N. CENTRAL EXPRESSWAY SUITE 400. DALLAS. TX 7523'! | WITHERIIELAW£0M ) Cause No: , ) n u ) Plaintiff, IN THE ) DISTRICT COURT 0F vs- DALLAS COUNTY, TEXAS ~ Vvvvvv Defendant, AFFIDAVIT REGARDING MEDICAL EXPENSES (Tex. Civ. Prac. & Rem. Code, Sec. 18.002(b—1) Before me, the undersigned authority, on this day personally appeared DR. 10 LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows: ll My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of making this affidavit, and personally acquainted with the facts herein stated: 12 I am the custodian of billing records for LONE STAR l3 RADIOLOGY. Attached to this affidavit are records that provide an itemized statement of the service(s)and charge(s) for the service(s) that LONE STAR RADIOLOGY provided 14 to ZENA DAWSON from 10/11/2018. The attached records are a part of this affidavit. 15 The attached records are kept by LONE STAR RADIOLOGY in the regular course of business, and it was the regular course of business 16 of LONE STAR RADIOLOGY for an employee or representative of LONE STAR RADIOLOGY with knowledge of the service provided, to make the record or to transmit l7 information to be included in the record. The records were made in the regular course of business at or near the time or reasonably soon after the time the service 18 was provided. The records are a duplicate of the original. l9 The services provided were necessary and the amount charged for the services was reasonable at the time and place that the services were 20 provided. The total amount paid for the services was $0.00 and 21 the amount currently unpaid but which LONE STAR RADIOLOGY has a right to be paid after any adjustments or credits is $396.00. This amount may include 22 a Records Summary Report fee of $150.00. 23 24 25 AFFIANT(Custodian Of Records) ) Cause No l , ) ) 2 Plaintiff, ) IN THE DISTRICT COURT OF ) 3 VS» ). DALLAS COUNTY, TEXAS 3 4 , ) ) 5 Defendant, ) 6 7 AFFIDAVIT REGARDING MEDICAL EXPENSES 8 (Tex. Civ. Prac. & Rem. Code, Sec. 18.002(b—1) 9 . Before me, the undersigned authority, on this day perSonally appeared DR. 10 LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows: 11 My name is DR. LOU SAUCEDO, JR.; D.C., I am of sound mind, capable of making this affidavit, and personally acquainted with the facts herein gtated: 12 I am the custodian of billing records for NORTH TEXAS OPEN AIR MRI. 13 Attached to this affidavit are records that provide an itemized statement of the service(s)and charge(s) for the service(s) that NORTH TEXAS OPEN AIR MRI l4 provided to ZENA DAWSON from 10/09/2018. The attached records are a part of this affidavit. 15 ‘ The attached recgrds are kept by NORTH TEXAS OPEN AIR MRI 1n the regular course of business, and it was the regular course of business of NORTH TEXAS l6 OPEN:AIR MRI for an employee or representative of NORTH TEXAS OPEN AIR MRI with'knowledge of the service provided, to make the record or to transmit l7 information to be included in the record. The records were made in the regular course of business at or near the time or reasonably soon after the 18 time the service was provided. The records are a duplicate of the original. 19 The services provided were necessary and the amount charged for the services was reasonable at the time and place that the services were provmded. 20 The total amount paid for the services was $0.00 and the amount currently 21 unpaid but which NORTH TEXAS OPEN AIR MRI has a ri‘éfitflfibfl p i'awaftérany— adjustments or credits is $8,784.00. This amount may include a Records 22 Summary Report fee of $150.00. 23 24 65353:;3§%IANT(Custodian Of Records) 25 AFFIDAVIT 0F RECORD§ CQ§| ODIAN OF TARRANT HEURDLDGY CDNfiuLTafllfi REGARDI T ZENA D STATE DF TEXAS 5 COUNTY OF g _ BEFORE ME, the undersigned authority, who. being by ma duly sworg, deposed as followa: personally appeamd F -S My thl$ Affidavit name is WW and parsunally acqualntalj with the V Y“ S .I am facts heraln stated. of sound mind. capable of making Iam a custadlan of racerds fur Tarrant Naumlogy Consultants. Attached to this Affidavit are records that provlde an Itemized .statemant of the Service and the charge for the service that Tarrant Neurology Cansultanta pravlded to Zena Dawson on 912912013 to present. Tha attached ramrds are a part of this affldavlt. The attached records are kept by Tarrant Neurology Consultants In the regular courae 0f business and It was the regular course of business of Tarrant Neurology Consultanm fur an employee 0r rapramntatlve of Tarrant Neurology Consultants with knawledga of the service pruvldad. to maka the record or to transmit information to be included in tha racord. The records ware mada In the regular course of business at or near the time or reasonably soun after the time the service was provlded. The racorda are the urlglnal 0r a duplicate of the nrlglnal. The services provided were necessary and the amaunt charged for the service was raasnnabla at the tlme and placa that the services ware provided. The total amaunt paid for tha sarvlces was $1M 32.1 and the amount currently unpaid but w [ch rrant Naurnlngy Gonaultants has a right to be after any adjustmenm 0r credits ls $ » . l— \w: I CST DIA “13% OPE WING RECORDS f‘fli'fa, -fffi a?" . w“ :9? KRYSTAL MAME MAYES fiNotary Public Comm State of Tunas Expires 01 45 2024 Notarym 130510133 ‘ ,_ NOTAW PUBLIC m NDTARY'S HRINTED NAME: Ww IN AND FOR THE STATE 0F TEXAS: 10440 N. CENTRAL EXPRESSWAY SUITE 400. DALLAS. TX 75331 I WITHERITELAWEOM RIDIOLOGY RECORDS AFFIDAVIT OF EHWSION IMAGING - Hug" REGHDIHG PATIENT EMA DMSON STATE OFW 00‘9“?“ § § counrrv 0F El P350 § BEFORE RE. the undersigned authority. personahy appearad chamgg Mggman “who bamg by me duty sworn deposed as fiolkmrs. M; name is Chariton McGowan . l am 0t sound mind. capable at making this Afltdavit. and parsonaily acquainted with the lacls herflin stated: 2 Iam me custodian unne records oi Erm‘sion Imagmg - Hum Attached hereto are mms lrom Envision tnaglng - Hulen regarding Zena Dawson. These said films are kept by Envision Imaging v Hulan inthe regular courseaf Dusmess. and :twas m the regular caurse of bummss far an ampbyee or repreaenlallue with kncwfadgna of lhe ant. went. condition. opinion. Dr diagnosis recorded m make such. films or tn cause Such films to be made and me fiims were made at or near ma hme of the act event. common. opumon or diagnosns. or reasonably soon thereafter. The films attached harem are me original or exact duplicates aflhe mw MW originals. CUSTODIAN OF RADQLOGY SWDRN TO m SLBSCRBED bdore me on thew day of n}fi# I . 20 Z (J 7M)”m NOTJR‘I' FUBLE N FOR TIE I STATE OW £3 Xflrucx-L Ut {\A‘n—K 7 r NOTARVS PRNTED NINE: MY GDMSION EKPRES: X)?(767Q , ) Cause No.: ) Plaintiff, ) ) IN THE DISTRICT IN AND FOR COUNTY, vs. TEXAS ) ) I ) ) Defendant ) ) RADIOLOGY DISC AFFIDAVIT Before me, the undersigned authority, on this day personally appeared DR. LOU SAUCEDO, JR., who, being by me duly sworn, deposed as follows: My name is DR. LOU SAUCEDO, JR., I am of sound mind, capable of making this affidavit, and personally acquainted with the 10 facts herein state d: I am the custodian of radiology disc for NORTH TEXAS ll OPEN AIR MRI, regarding records from 09/24/1965 pertaining to ZENA DAWSON, DOB: 09/24/1965, SSN: N/A. 12 Attached hereto is __1__ radiology disc from NORTH TEXAS OPEN AIR MRI pertaining to ZENA DAWSON. These said __1__ radiology disc are kept by NORTH 13 TEXAS OPEN AIR MRI in the regular course of business, and it was the regul ar course of business of NORTH TEXAS OPEN AIR MRI for an employee or 14 representative of NORTH TEXAS OPEN AIR MRI with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit information thereof to be included in such 15 record; and the record was made at or near the time or reasonably soon thereafter. I l6 The films attached hereto are the original or exact duplicates of the original. 17 18 19 swoan To AND SUBSCRIBED before me on the £ day of '4LLLI.,.L 1 , Affiant 2020. 20 Ir 21 ‘ Notary .I,‘ P ’1‘ 4/4 olic, ll State ‘ 1 of Texa 22 Notary’s printed name and commission expires:05—13-2023 23 -.E LlYSAUNAS 24 {.5 My Notary ID # 130225380 +‘ \- ExpiresMay 13,2023 25 .4..— Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Erica Lisenbe on behalf of Rob Loar Bar No. 24081007 Erica.Lisenbe@witheritelaw.com Envelope ID: 46533551 Status as of 9/24/2020 4:22 PM CST Associated Case Party: ZENA DAWSON Name BarNumber Email TimestampSubmitted Status Rob Loar Rob.Loar@witheritelaw.com 9/24/2020 11:42:14 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Robert Chad Kimble 24007483 eservice@chadkimblelaw.com 9/24/2020 11:42:14 AM SENT Kyle Smith 24102512 kyle@chadkimblelaw.com 9/24/2020 11:42:14 AM SENT