Notice of Intention to Take Deposition on Written Questions - MED-CARE EMS - Noel A Zamora, Jr. VS. Reynaldo Salinas-Reyna, Reynaldo R. Salinas

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On February 9, 2021 a case was filed by Zamora, Noel A, Jr., represented by Jaime A. Gonzalez, Jr., against Reynaldo R. Salinas, and Salinas-Reyna, Reynaldo, represented by Ericka I Ramirez, Ericka I. Ramirez, and Larry J. Goldman, in the jurisdiction of Hidalgo County. Judge Rose Guerra Reyna presiding.

                        
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                                                    CAUSE NO. C-0474-21-D
                                    §
NOEL ARTURO ZAMORA, JR.             §        IN THE DISTRICT COURT
                                    §
VS                                  §        HIDALGO COUNTY, TEXAS
                                    §
REYNALDO SALINAS-REYNA,             §
INDIVIDUALLY AND REYNALDO R.        §        206TH JUDICIAL DISTRICT
SALINAS                             §


                    QUESTIONS TO BE PROPOUNDED TO THE WITNESS,
                THE CUSTODIAN OF MEDICAL RECORDS FOR: MED-CARE EMS


1. Please state your full name, occupation, and/or official title.

ANSWER:

2. Have you been served with a Subpoena Duces Tecum for the production of: ANY AND ALL MEDICAL
RECORDS FROM 12/07/2010 TO THE PRESENT INCLUDING BUT NOT LIMITED TO THE FOLLOWING:
patient intake and/or history forms, applications, questionnaires, payment agreements, authorizations,
admission records, hospital records, prescription records, physica…