Notice of Intention to Take Deposition on Written Questions - WITH QUESTIONS - 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                             §


                           DWQ TO CUSTODIAN OF RECORDS FOR
                           UT HEALTH RGV SURGICAL SPECIALTY


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 contracts in
which UT HEALTH RGV SURGICAL SPECIALTY is a party with Aetna, Blue Cross Blue Shield,
Humana, United Healthcare, Cigna, Medicare, and Medicaid, and the annual cost report you are
required to provide to a Medicare Administrative Contractor as a Medicare certified institut…