Preview
FILED
3/21/2022 1:23 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Darling Tellez DEPUTY
CAUSE NO. DC-21-16487
CHRISTOPHER WEBB, ANTHONY § IN THE DISTRICT COURT
PATTERSON AND DEMETAR §
MATHIS, §
Plaintiffs, §
§ 44th JUDICIAL DISTRICT
v. §
§
MICHAEL BENNETT, §
Defendant. § DALLAS COUNTY, TEXAS
______________________________________________________________________________
PLAINTIFFS’ NOTICE OF FILING OF AFFIDAVITS
______________________________________________________________________________
Pursuant to 18.001 of the Texas Civil Practice & Remedies Code, you hereby notified that Plaintiffs,
Christopher Webb, Anthony Patterson and Demetar Mathis, have filed in the above-entitled and
numbered cause, certain billing records and medical records affidavits. Said affidavits are listed below:
1. Medical Billing Affidavit from Injury Clinic of Dallas regarding Plaintiff Christopher Webb;
2. Medical Records Affidavit from Injury Clinic of Dallas regarding Plaintiff Christopher
Webb;
3. Medical Billing Affidavit from Injury and Radiology Solutions regarding Plaintiff
Christopher Webb;
4. Medical Records Affidavit from Injury and Radiology Solutions regarding Plaintiff
Christopher Webb;
5. Medical Billing Affidavit from Momentum Spine & Joint regarding Plaintiff Christopher
Webb;
6. Medical Records Affidavit from Momentum Spine & Joint regarding Plaintiff Christopher
Webb;
7. Medical Billing Affidavit from Medical City Dallas regarding Plaintiff Anthony Patterson;
8. Medical Records Affidavit from Medical City Dallas regarding Plaintiff Anthony Patterson;
9. Medical Billing Affidavit from Injury Clinic of Dallas regarding Plaintiff Anthony
Patterson;
10. Medical Records Affidavit from Injury Clinic of Dallas regarding Plaintiff Anthony
Patterson;
11. Medical Billing Affidavit from MRI Centers of Texas regarding Plaintiff Anthony Patterson;
12. Medical Records Affidavit from MRI Centers of Texas regarding Plaintiff Anthony
Patterson;
13. Medical Billing Records from Uptown Radiology regarding Plaintiff Anthony Patterson;
14. Medical Records Affidavit from Uptown Radiology regarding Plaintiff Anthony Patterson;
15. Medical Billing Affidavit from Momentum Spine & Joint regarding Plaintiff Anthony
Patterson;
16. Medical Records Affidavit from Momentum Spine & Joint regarding Plaintiff Anthony
Patterson;
17. Medical Billing Affidavit from Memorial Care Pharmacy regarding Plaintiff Anthony
Patterson;
18. Medical Billing Affidavit from Medical City Dallas regarding Plaintiff Demetar Mathis;
19. Medical Billing Affidavit from Injury Clinic of Dallas regarding Plaintiff Demetar Mathis;
20. Medical Records Affidavit from Injury Clinic of Dallas regarding Plaintiff Demetar Mathis;
21. Medical Billing Affidavit from Elevate Health Clinics regarding Plaintiff Demetar Mathis;
22. Medical Records Affidavit from Elevate Health Clinics regarding Plaintiff Demetar Mathis;
23. Medical Billing Affidavit from Momentum Spine & Joint regarding Plaintiff Demetar
Mathis;
24. Medical Records Affidavit from Momentum Spine & Joint regarding Plaintiff Demetar
Mathis;
25. Medical Billing Affidavit from ASP Cares regarding Plaintiff Demetar Mathis;
26. Medical Billing Affidavit from Memorial Care Pharmacy regarding Plaintiff Demetar
Mathis;
27. Medical Records Affidavit from Memorial Care Pharmacy regarding Plaintiff Demetar
Mathis.
These records will be offered in evidence on the trial of the above captioned case.
Respectfully submitted,
RAFI DEBOSE, PLLC
/s/ Kyle DeBose_____________
Kyle DeBose
State Bar Number 24084302
kdebose@rafidebose.com
Ayesha Rafi
State Bar Number 24060455
arafi@rafidebose.com
8330 LBJ Freeway, Suite 820
Dallas, Texas 75243
Telephone: (214) 224-0064
Facsimile: (214) 224-0064
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this the 21st day of March 2022, a true and correct copy of
the foregoing document was served on the following counsel of record:
Mark A. Teague Via E-Serve
LeCrone Law Firm, PC
Wall Street Plaza
123 N. Crockett St., Suite 200
Sherman, TX 75090
Certified on this 21st day of March, 2022, by:
/s/ Kyle DeBose_____________
Kyle DeBose
AFFIDAVIT
TEXAS
STATE OF __________________ §
§
DALLAS
COUNTY OF ________________ §
BEFORE ME, the undersigned authority, on this day personally appeared
AMY LOPEZ
_________________________, who, being by me duly sworn, stated as follows:
AMY LOPEZ
My name is _________________________. I am of sound mind and capable of making
this affidavit, and personally acquainted with the facts herein stated.
I am the billing records custodian for MRI CENTERS OF TEXAS. Attached to this affidavit
are records that provide an itemized statement of the service and the charges for the service that
MRI CENTERS OF TEXAS provided to, ANTHONY PATTERSON for the dates of service from
01/22/2020
____________ 01/22/2020
to ____________. The attached records are part of this affidavit.
The attached records are kept by MRI CENTERS OF TEXAS in the regular course of business,
and it was the regular course of business of MRI CENTERS OF TEXAS for an employee or
representative of MRI CENTERS OF TEXAS with knowledge of the service provided, to make the
record or to transmit information to be MRI CENTERS OF TEXAS 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 was provided. The records are the original or a duplicate of the original.
The services provided were necessary and the amount charged for the services was
reasonable at the time and place that the services were provided.
.0.00
The total amount paid for the services was $__________ and the amount currently unpaid
but which MRI CENTERS OF TEXAS has a right to be paid after any adjustments or credits is
9600.00
$__________.
AFFIANT
28
SWORN TO AND SUBSCRIBED before me on this _____ DECEMBER
day of ____________________,
2021
.
TEXAS
NOTARY PUBLIC, STATE OF ____________
Printed Name: NINA IDRIS
Commission Expires: 06/14/2024
Charge Verification Sheet
01/22/2020 01/22/2020
DATES OF SERVICE: FROM______________TO_________________
TOTAL CHARGE: 9600.00
________________
TOTAL INSURANCE PAYMENTS: 0.00
________________
TOTAL MEDICARE PAYMENTS: 0.00
________________
TOTAL MEDICAID PAYMENTS: 0.00
________________
WRITE OFFS OR ADJUSTMENTS: 0.00
________________
TOTAL PATIENT PAID: 0.00
________________
TOTAL BALANCE: 9600.00
________________
AFFIDAVIT
TEXAS
STATE OF __________________ §
§
DALLAS
COUNTY OF ________________ §
BEFORE ME, the undersigned authority, on this day personally appeared
AMY LOPEZ
_________________________, who, being by me duly sworn, stated as follows:
AMY LOPEZ
My name is _________________________. I am over 21 years of age, competent to make
this affidavit, and personally acquainted with the facts stated herein:
I am the custodian of records of MRI CENTERS OF TEXAS a healthcare provider or physician
of ANTHONY PATTERSON. Attached hereto are records which are kept by me in the regular course
of business, and it was the regular course of business of MRI CENTERS OF TEXAS for an employee
or representative of MRI CENTERS OF TEXAS 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
record; and the record was made at or near the time or reasonably soon thereafter. The records
attached hereto are the original or exact duplicates of the original.
__________________________________
AFFIANT
28
SWORN TO AND SUBSCRIBED before me on this _____ DECEMBER
day of ____________________,
2021.
__________________________________
TEXAS
NOTARY PUBLIC, STATE OF________
Printed
NINA IDRIS
Name:_____________________________
06/14/2024
Commission Expires:_________________
BILLING RECORDS AFFIDAVIT
(Pursuant to Tex. R. Evid. 902)
ANTHONY PATTERSON
1969-07-14
STATE OF TEXAS §
COUNTY OF HARRIS §
Before me, the undersigned authority, personally appeared AMANDA RODRIGUEZ_
who, being by me duly sworn, deposed as follows:
My name is _AMANDA RODRIGUEZ__. I am of sound mind and capable of making
this affidavit, and personally acquainted with the facts herein stated:
I am the custodian of billing records for UPTOWN RADIOLOGY ASSOCIATES. I
am familiar with the manner in which the facility’s billing records are created and maintained by
virtue of my duties and responsibilities. Attached hereto are 2 pages of billing records from
UPTOWN RADIOLOGY ASSOCIATES. These billing records are kept in the regular course
of business, and it was the regular course of business for an employee or representative of
UPTOWN RADIOLOGY ASSOCIATES, with knowledge of the act, event, condition, opinion,
or diagnosis, recorded to make the billing records or to transmit information thereof to be included
in such records; and the billing records were made at or near the time or reasonably soon thereafter.
The billing records attached hereto are the original or exact duplicates of the original.
1. Total charges for the services rendered: $2,100.00
2. The amount actually paid by the patient or on the patient’s behalf: $0.00
3. Amount, if any, adjusted or written off: $0.00
4. Any amount currently unpaid but which the facility has a right to be paid after any
adjustments or credits: $2,100.00
_______
Affiant
SWORN TO AND SUBSCRIBED before me on the 17 day of JANUARY, 2022.
Notary Public, State of Texas
MEDICAL RECORDS AFFIDAVIT
(Pursuant to Tex. R. Evid. 902)
ANTHONY PATTERSON
1969-07-14
STATE OF TEXAS §
COUNTY OF HARRIS §
Before me, the undersigned authority, personally appeared _AMANDA RODRIGUEZ_
who, being by me duly sworn, deposed as follows:
My name is _AMANDA RODRIGUEZ__. I am of sound mind and capable of making
this affidavit, and personally acquainted with the facts herein stated:
I am the custodian of the records of UPTOWN RADIOLOGY ASSOCIATES. Attached
hereto are 8 pages of records from UPTOWN RADIOLOGY ASSOCIATES. These said 8 pages
of records are kept by UPTOWN RADIOLOGY ASSOCIATES in the regular course of
business, and it was the regular course of business of UPTOWN RADIOLOGY ASSOCIATES
for an employee or representative of UPTOWN RADIOLOGY ASSOCIATES, 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 record; and the record was made at or near the time or
reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the
original.
________________________________
Affiant
SWORN TO AND SUBSCRIBED before me on the 17 day of JANUARY, 2022.
________________________________
Notary Public, State of Texas
Notary's printed name: LORI MAI PHAM
My commission expires: 2/2/2022
BILLING RECORDS AFFIDAVIT
(Pursuant to Tex. R. Evid. 902)
DEMETAR MATHIS
1/23/1972
STATE OF TEXAS §
COUNTY OF HARRIS §
Before me, the undersigned authority, personally appeared Alex Vazquez, who, being
by me duly sworn, deposed as follows:
My name is Alex Vazquez. I am of sound mind and capable of making this affidavit,
and personally acquainted with the facts herein stated:
I am the custodian of billing records for MEMORIAL CARE PHARMACY. I am
familiar with the manner in which the facility’s billing records are created and maintained by
virtue of my duties and responsibilities. Attached hereto are 1 pages of billing records from
MEMORIAL CARE PHARMACY. These billing records are kept in the regular course of
business, and it was the regular course of business for an employee or representative of
MEMORIAL CARE PHARMACY, with knowledge of the act, event, condition, opinion, or
diagnosis, recorded to make the billing records or to transmit information thereof to be included
in such records; and the billing records were made at or near the time or reasonably soon
thereafter. The billing records attached hereto are the original or exact duplicates of the original.
1. Total charges for the services rendered: $379.20
2. The amount actually paid by the patient or on the patient’s behalf: $0.00
3. Amount, if any, adjusted or written off: $0.00
4. Any amount currently unpaid but which the facility has a right to be paid after any
adjustments or credits: $379.20
Affiant
SWORN TO AND SUBSCRIBED before me on the 9 day of February , 2022.
Notary Public, State of Texas
MEDICAL RECORDS AFFIDAVIT
(Pursuant to Tex. R. Evid. 902)
DEMETAR MATHIS
1/23/1972
STATE OF TEXAS §
COUNTY OF HARRIS §
Before me, the undersigned authority, personally appeared Alex Vazquez, who, being
by me duly sworn, deposed as follows:
My name is Alex Vazquez. I am of sound mind and capable of making this affidavit,
and personally acquainted with the facts herein stated:
I am the custodian of the records of MEMORIAL CARE PHARMACY. Attached
hereto are 3 pages of records from MEMORIAL CARE PHARMACY. These said 3 pages of
records are kept by MEMORIAL CARE PHARMACY in the regular course of business, and it
was the regular course of business of MEMORIAL CARE PHARMACY for an employee or
representative of MEMORIAL CARE PHARMACY, 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 record; and the record was made at or near the time or reasonably soon
thereafter. The records attached hereto are the original or exact duplicates of the original.
_____________________________
Affiant
SWORN TO AND SUBSCRIBED before me on the _9__day of _February _, 2022.
_____________________________
Notary Public, State of Texas
Notary's printed name: Kyle Tecson
My commission expires: 08-29-2022
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.
Ayesha Rafi on behalf of Kyle DeBose
Bar No. 24084302
arafi@rafilegal.com
Envelope ID: 62789339
Status as of 3/21/2022 2:02 PM CST
Associated Case Party: CHRISTOPHER WEBB
Name BarNumber Email TimestampSubmitted Status
Ayesha Rafi 24060455 arafi@rafidebose.com 3/21/2022 1:23:45 PM SENT
Associated Case Party: MICHAEL BARNETT
Name BarNumber Email TimestampSubmitted Status
Mark A.Teague eservice@lecronelaw.com 3/21/2022 1:23:45 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Kyle DeBose kdebose@rafidebose.com 3/21/2022 1:23:45 PM SENT
Mayra Guandique mayra@rafidebose.com 3/21/2022 1:23:45 PM SENT