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  • CHRISTOPHER WEBB, et al  vs.  MICHAEL BARNETTMOTOR VEHICLE ACCIDENT document preview
  • CHRISTOPHER WEBB, et al  vs.  MICHAEL BARNETTMOTOR VEHICLE ACCIDENT document preview
  • CHRISTOPHER WEBB, et al  vs.  MICHAEL BARNETTMOTOR VEHICLE ACCIDENT document preview
  • CHRISTOPHER WEBB, et al  vs.  MICHAEL BARNETTMOTOR VEHICLE ACCIDENT document preview
  • CHRISTOPHER WEBB, et al  vs.  MICHAEL BARNETTMOTOR VEHICLE ACCIDENT document preview
  • CHRISTOPHER WEBB, et al  vs.  MICHAEL BARNETTMOTOR VEHICLE ACCIDENT document preview
  • CHRISTOPHER WEBB, et al  vs.  MICHAEL BARNETTMOTOR VEHICLE ACCIDENT document preview
  • CHRISTOPHER WEBB, et al  vs.  MICHAEL BARNETTMOTOR VEHICLE ACCIDENT document preview
						
                                

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