Party Discovery: COUNTY OF DALLAS vs. ALLERGAN FINANCE LLC (F/K/A ACTAVIS INC F/K/A WATSON PHARMACEUTICALS

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                                THE STATE OF TEXAS

                              SUBPOENA DUCES TECUM PURSUANT TO
                        RULE 176 OF THE TEXAS RULES OF CIVIL PROCEDURE


                                  MDL PRETRIAL CAUSE NO. 2018-77098

COUNTY          OF DALLAS,                          §                IN THE DISTRICT COURT

           Plaintiff,

vs.                                                 §                116th JUDICIAL DISTRICT

PURDUE PHARMA L.P., et al.,

           Defendants.                                               DALLAS       COUNTY,       TEXAS

HRA      AA AHHH        LARA AAR AA AA ALAA   ARE K AEE HERA   REE E AKER ERI AR ERE          IIIA IIE II IIIS
                                      MASTER FILE NO. 2018-63587

                                                                     IN THE DISTRICT COURT

IN RE: TEXAS             OPIOID
LITIGATION                                                           152nd JUDICIAL DISTRICT


                                                                     HARRIS COUNTY, TEXAS

HHA RAHI           IR   III    K HH IIE EER I IRR HRI HK III IRIE IAI III III SII IIASA II AIA AAAI ASAI.


SUBPOENA FOR DEPOSITION ON WRITTEN QUESTIONS (WITH DUCES TECUM)
   TO COLUMBIA HOSPITAL AT MEDICAL CITY DALLAS SUBSIDIARY, L.P.
               DBA MEDICAL CITY DALLAS HOSPITAL!



TO         Columbia Hospital at Medical City Dallas Subsidiary, L.P.
           dba Medical City Dallas Hospital
           c/o its registered agent, C T Corporation System
           1999 Bryan Street, Suite 900
           Dallas, Texas 75201


1 This document is issued subject to and without waiver of the Pharmacy Defendants’ motion to stay discovery,
which is currently pending with the Court. If the Court grants that motion and stays discovery, we will promptly
notify   you.



SUBPOENA DUCES TECUM TO MEDICAL CrTY DALLAS HOSPITAL                                                      Page     1
Greetings:

          YOU   ARE   COMMANDED           to appear    for a deposition   on written questions    of the

custodian of records for the Columbia Hospital at Medical City Dallas Subsidiary, L.P. dba

Medical City Dallas Hospital in accordance with Rule 200 of the Texas Rules of Civil Procedure.

The topics on which the designated person(s) will be examined are described in Schedule A to this

subpoena. The deposition will take place before a court reporter at a time convenient to the witness

within twenty (20) days of receipt of said subpoena.

          YOU ARE FURTHER COMMANDED                   to appear and produce with You at the deposition

on written questions all of the documents        in Your possession, custody, or control that are

responsive to the document requests set forth on the Schedule             B (DUCES   TECUM)      attached

hereto.

          Failure by any person without adequate excuse to obey a subpoena served upon that

person may be deemed a contempt of the court from which the subpoena is issued or a

district court in the county in which the subpoena is served, and may be punished by fine or

 onfinement, or both.

ISSUED March 22, 2023.

SUBPOENA ISSUED BY:
          /s/_ Kimberly P. Harris
          KIMBERLY P. HARRIS
          State Bar No. 24002234
          kharris@qslwm.com
          GREGORY M. SUDBURY
          State Bar No. 24033367
          gsudbury@qslwm.com
          QUILLING, SELANDER, LOWNDS, WINSLETT & MOSER, P.C.
          2001 Bryan Street, Suite 1800
          Dallas, Texas 75201
          (214) 871-2100 (Telephone)
          Attorneys
                  for The Kroger Co., Kroger Limited Partnership I, Kroger Limited Partnership
          II, and Kroger Texas L.P.



SUBPOENA DUCES TECUM TO MEDICAL CITY DALLAS HOSPITAL                                                Page 2
This Subpoena has also been issued by the following counsel

   By:/s/ Bradley A. Monk
       Bradley A. Monk
       Texas Bar No. 24077502
       Hilgers Graben PLLC
       7859 Walnut Hill Lane, Suite 335
       Dallas, TX 75230
       469-640-6842
       bmonk@hilgersgraben.com
       Attorneys for Walgreen Co., Walgreen Eastern Co., Inc., and Walgreens Boots Alliance,
       Inc.


    By: /s/ Katrina G. Eash
        Katrina G. Eash
        WINSTON & STRAWN LLP
        2121 N. Pearl Street, Suite 900
       Dallas, TX 75201
       (214) 453-6500
       KEash@winston.com

       Christopher B. Essig
       Scott M. Ahmad
       WINSTON & STRAWN LLP
       35 W. Wacker Drive
       Chicago, IL 60601
       (312) 558-5600
       CEssig@winston.com
       SAhmad@winston.com

       Counsel for Defendant West-Ward Pharmaceuticals
       Corporation n/k/a Hikma Pharmaceuticals USA Inc.




SUBPOENA DUCES TECUM TO MEDICAL CiTy DALLAS HOSPITAL                                     Page 3
IN THE 116TH JUDICIAL DISTRICT COURT
                                                    COUNTY OF DALLAS STATE OF TEXAS
                                                MDL PRE TRIAL CAUSE NO. 2018-77098
                                                   COUNTY OF DALLAS, PLAINTIFF
                                                                vs.
                                              PURDUE PHARMA L.P., ET AL, DEFENDANTS

                                                         MASTER FILE NO. 2018-63587
                                                      IN THE 152ND JUDICIAL DISTRICT
                                                    COUNTY OF HARRIS, STATE OF TEXAS
                                                      IN RE: TEXAS OPIOID LITIGATION

                                                                   RETURN

 Came to my hand: 3/23/2023 AT 12:47 PM,
» 11,00 WITNESS FEE
» NOTICE OF SUBPOENA FOR DEPOSITION ON WRITTEN QUESTIONS (WITH DUCES TECUM) TO COLUMBIA HOSPITAL AT
     MEDICAL CITY DALLAS SUBSIDIARY, L.P. DBA MEDICAL CITY DALLAS HOSPITAL
+    SUBPOENA FOR DEPOSITION ON WRITTEN QUESTIONS (WITH DUCES TECUM) TO COLUMBIA HOSPITAL AT MEDICAL CITY
   DALLAS SUBSIDIARY, L.P. DBA MEDICAL CITY DALLAS HOSPITAL
 Executed by me on: 3/23/2023 AT 1:54 PM
 Executed at: 1999 BRYAN ST #900 DALLAS, TEXAS 75201 within the county of DALLAS by delivering to COLUMBIA HOSPITAL AT
 MEDICAL CITY DALLAS SUBSIDIARY, LP D/B/A MEDICAL CITY DALLAS HOSPITAL by delivering to its registered agent CT
 CORPORATION SYSTEM, by delivering to its employee, GEORGE MARTINEZ, in person, a true copy of the above specified
 documents.

      | am over the age of       18; and 1am not a party to nor interested in the outcome of the above styled and numbered suit, and |
                                       declare under penalty of perjury that the foregoing is true and correct.




                                                                                                                               ~2025
                                                                            Abraham Rojas                           Date
                                                                            PSC#20788 EXP: 2/29/2024

                                                                            c/o
                                                                            ASSURED CIVIL PROCESS AGENCY
                                                                            5926 BALCONES DRIVE, SUITE 290
                                                                            AUSTIN, TX 78731
    STATE OF TEXAS          }

                                                                 VERIFICATION
    Before me, a notary public, on this day personally appeared the above named person, known to me to be the person whose
    name is subscribed to the foregoing document and, being by me first duly sworn, declared that the statements and facts therein
    contained are within his personal knowledge to be true and correct. Given under my hand and seal of office on this the (23) day
    of (MARCH), 2023




                                                                                    fig ld Pry
                       ay         Peyton Hutchinson
                                © My Commission Expires
                                & 09/21/2024
                  tee             ID No 129114138
                                                                                                                      Notary Public