Preview
Electronically Filed
10/19/2022 10:08 PM
Hidalgo County District Clerks
Reviewed By: Mia Castillo
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. §
SALINAS § 206TH JUDICIAL DISTRICT
AMENDED NOTICE OF INTENTION TO TAKE DEPOSITION
BY WRITTEN QUESTIONS
TO:
JAIME A. GONZALEZ, JR. CATHERINE W. SMITH CONSUELITO MARTINEZ
EZEQUIEL REYNA, JR.
You will take notice that after 20 days from the service of a copy hereof with attached questions, a deposition by written questions
will be taken of the CUSTODIAN OF MEDICAL RECORDS for:
FAMILY MEDICAL & SPECIALTY CLINIC
2790 PHARMACY ROAD
RIO GRANDE, TX 78582
at the offices of the Custodian, or at another agreed upon time and/or place before a Notary Public, an Officer of the State of Texas
and employee of Law & Order Record Retrieval, or their designated agent.
Which deposition, with attached questions, may be
used in evidence upon the trial of the above styled and numbered cause pending in the above named Court.
Notice is further given that request is here made as authorized under Rule 200, Texas Rules of Court, to the Officer authorized to
take this deposition to issue a SUBPOENA DUCES TECUM and cause to be served on the witness to produce for inspection and
photocopying: ANY AND ALL MEDICAL RECORDS FROM 12/07/2015 UP THROUGH 12/07/2020 INCLUDING BUT NOT
LIMITED TO THE FOLLOWING: patient intake and/or history forms, applications, questionnaires, payment agreements,
authorizations, admission records, hospital records, prescription records, physical therapy records, photographs, office
notes, reports and correspondence, any and all medical reports or records, diagnostic studies, clinical abstracts, histories,
charts, admission sheets, system history or system review, summary sheet, medical service sheets, nurses' notes,
discharge notes, chronological summary, consultant reports, any patient records not located in the medical record library
(such as emergency room records), records maintained by EMR (electronic medical record), and any correspondence,
including any handwritten or typed notes to or from any nurse, doctor, physician, surgeon, or any other person, and any
other information, documents and opinions relevant to past, present and future physical condition, treatment, care or
hospitalization regardless of whether said records were created by you or your facility. (IF RECORDS ARE MAINTAINED
DIGITALLY AND/OR ELECTRONICALLY, PLEASE PRODUCE DIGITAL OR ELECTRONIC)
Pertaining To: NOEL ARTURO ZAMORA, JR., DOB: 01/24/1983 and turn all such records over to the Officer authorized to take
this deposition for inspection and photocopying, the same may be made by him and attached to said deposition.
Larry J. Goldman /s/
LARRY J. GOLDMAN, SBID: 08093450
GOLDMAN & PETERSON PLLC
10100 REUNION PL STE 800
SAN ANTONIO, TX 78216
Ph: (210) 340-9800 Fax: (210) 340-9888
mail@ljglaw.com
ATTORNEY FOR THE DEFENDANT
CERTIFICATE OF SERVICE
I certify that a true and exact copy of the foregoing Notice of Intention to Take Deposition by Written Questions was provided to the
respective parties or attorneys of record, pursuant to Rule 21a, by mail, by commercial delivery service, by e-service, by fax, by
email, or hand delivered.
Date: 10/19/2022 By: Larry J. Goldman /s/
LARRY J. GOLDMAN
224258.2 File #: 27000.1761 ADO
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.
Envelope ID: 69394001
Status as of 10/20/2022 1:35 PM CST
Associated Case Party: NoelAZamora
Name BarNumber Email TimestampSubmitted Status
Consuelito Martinez consuelito.martinez@farmersinsurance.com 10/19/2022 10:08:18 PM SENT
Consuelito Martinez rose.m.madrigal@farmersinsurance.com 10/19/2022 10:08:18 PM SENT
Consuelito Martinez 24095835 texnewmexlegal@farmersinsurance.com 10/19/2022 10:08:18 PM SENT
Associated Case Party: Reynaldo Salinas-Reyna
Name BarNumber Email TimestampSubmitted Status
Linda San Miguel lsmiguel@zreynalaw.com 10/19/2022 10:08:18 PM SENT
Desi Olivarez dolivarez@zreynalaw.com 10/19/2022 10:08:18 PM SENT
Richard NicolasMoore rnmoore@zreynalaw.com 10/19/2022 10:08:18 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
JAIME GONZALEZ JAIME@JAGLAWFIRM.COM 10/19/2022 10:08:18 PM SENT
CATHERINE SMITH CAT@JAGLAWFIRM.COM 10/19/2022 10:08:18 PM SENT
KATHRYN ashburrn kathryn_ashburn@progressive.com 10/19/2022 10:08:18 PM SENT
CS COURTFILING@JAGLAWFIRM.COM 10/19/2022 10:08:18 PM SENT
JAIME GONZALEZ roxanna@jaglawfirm.com 10/19/2022 10:08:18 PM SENT
Preview
Electronically Filed 10/19/2022 10:08 PM Hidalgo County District Clerks Reviewed By: Mia Castillo 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. § SALINAS § 206TH JUDICIAL DISTRICT AMENDED NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS TO: JAIME A. GONZALEZ, JR. CATHERINE W. SMITH CONSUELITO MARTINEZ EZEQUIEL REYNA, JR. You will take notice that after 20 days from the service of a copy hereof with attached questions, a deposition by written questions will be taken of the CUSTODIAN OF MEDICAL RECORDS for: FAMILY MEDICAL & SPECIALTY CLINIC 2790 PHARMACY ROAD RIO GRANDE, TX 78582 at the offices of the Custodian, or at another agreed upon time and/or place before a Notary Public, an Officer of the State of Texas and employee of Law & Order Record Retrieval, or their designated agent. Which deposition, with attached questions, may be used in evidence upon the trial of the above styled and numbered cause pending in the above named Court. Notice is further given that request is here made as authorized under Rule 200, Texas Rules of Court, to the Officer authorized to take this deposition to issue a SUBPOENA DUCES TECUM and cause to be served on the witness to produce for inspection and photocopying: ANY AND ALL MEDICAL RECORDS FROM 12/07/2015 UP THROUGH 12/07/2020 INCLUDING BUT NOT LIMITED TO THE FOLLOWING: patient intake and/or history forms, applications, questionnaires, payment agreements, authorizations, admission records, hospital records, prescription records, physical therapy records, photographs, office notes, reports and correspondence, any and all medical reports or records, diagnostic studies, clinical abstracts, histories, charts, admission sheets, system history or system review, summary sheet, medical service sheets, nurses' notes, discharge notes, chronological summary, consultant reports, any patient records not located in the medical record library (such as emergency room records), records maintained by EMR (electronic medical record), and any correspondence, including any handwritten or typed notes to or from any nurse, doctor, physician, surgeon, or any other person, and any other information, documents and opinions relevant to past, present and future physical condition, treatment, care or hospitalization regardless of whether said records were created by you or your facility. (IF RECORDS ARE MAINTAINED DIGITALLY AND/OR ELECTRONICALLY, PLEASE PRODUCE DIGITAL OR ELECTRONIC) Pertaining To: NOEL ARTURO ZAMORA, JR., DOB: 01/24/1983 and turn all such records over to the Officer authorized to take this deposition for inspection and photocopying, the same may be made by him and attached to said deposition. Larry J. Goldman /s/ LARRY J. GOLDMAN, SBID: 08093450 GOLDMAN & PETERSON PLLC 10100 REUNION PL STE 800 SAN ANTONIO, TX 78216 Ph: (210) 340-9800 Fax: (210) 340-9888 mail@ljglaw.com ATTORNEY FOR THE DEFENDANT CERTIFICATE OF SERVICE I certify that a true and exact copy of the foregoing Notice of Intention to Take Deposition by Written Questions was provided to the respective parties or attorneys of record, pursuant to Rule 21a, by mail, by commercial delivery service, by e-service, by fax, by email, or hand delivered. Date: 10/19/2022 By: Larry J. Goldman /s/ LARRY J. GOLDMAN 224258.2 File #: 27000.1761 ADO 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. Envelope ID: 69394001 Status as of 10/20/2022 1:35 PM CST Associated Case Party: NoelAZamora Name BarNumber Email TimestampSubmitted Status Consuelito Martinez consuelito.martinez@farmersinsurance.com 10/19/2022 10:08:18 PM SENT Consuelito Martinez rose.m.madrigal@farmersinsurance.com 10/19/2022 10:08:18 PM SENT Consuelito Martinez 24095835 texnewmexlegal@farmersinsurance.com 10/19/2022 10:08:18 PM SENT Associated Case Party: Reynaldo Salinas-Reyna Name BarNumber Email TimestampSubmitted Status Linda San Miguel lsmiguel@zreynalaw.com 10/19/2022 10:08:18 PM SENT Desi Olivarez dolivarez@zreynalaw.com 10/19/2022 10:08:18 PM SENT Richard NicolasMoore rnmoore@zreynalaw.com 10/19/2022 10:08:18 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status JAIME GONZALEZ JAIME@JAGLAWFIRM.COM 10/19/2022 10:08:18 PM SENT CATHERINE SMITH CAT@JAGLAWFIRM.COM 10/19/2022 10:08:18 PM SENT KATHRYN ashburrn kathryn_ashburn@progressive.com 10/19/2022 10:08:18 PM SENT CS COURTFILING@JAGLAWFIRM.COM 10/19/2022 10:08:18 PM SENT JAIME GONZALEZ roxanna@jaglawfirm.com 10/19/2022 10:08:18 PM SENT