On October 23, 2018 a
Party Discovery
was filed
involving a dispute between
County Of Dallas,
and
Actavis Inc,
Actavis Llc,
Actavis Pharma, Inc. F K A Watson Pharma, Inc.,,
Allergan Finance Llc (F K A Actavis Inc F K A Watson Pharmaceuticals,
Allergan Plc F K A Actavis Plc,
Amerisourcebergen Corporation,
Amerisourcebergen Drug Corporation,
Andrews, Richard,
Cardinal Health 110 Llc,
Cardinal Health Inc,
Endo Health Solutions Inc,
Endo Pharmaceuticals Inc,
Janssen Pharmaceutica Inc,
Janssen Pharmaceuticals Inc,
Johnson & Johnson,
Mckesson Corporation,
Okechuku, Theodore,
Ortho-Mcneil-Janssen Pharmaceuticals Inc (N K A Janssen,
Padron, Nicolas,
Watson Laboratories, Inc.,,
Watson Pharmaceuticals Inc,
Purdue Pharma Inc,
Purdue Pharma L P,
The Purdue Frederick Company Inc,
for MDL - Opioid Litigation
in the District Court of Harris County.
Preview
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
ERKAA AA RAA AA EAR AAR REE REAR AAR AR ERA R ARERR EERE ELE REEL LER RARER R EERIE EERE IIT
MASTER FILE NO. 2018-63587
IN THE DISTRICT COURT
IN RE: TEXAS OPIOID
LITIGATION § 152nd JUDICIAL DISTRICT
HARRIS COUNTY, TEXAS
FI IRI IRR HI III RR II III RK IRI IR IR IRI RII II II III III IIIA AAI IAAI A IAAI AI AISI AS AS.
SUBPOENA FOR DEPOSITION ON WRITTEN QUESTIONS (WITH DUCES TECUM)
TO BAYLOR MEDICAL CENTER AT IRVING DBA BAYLOR SCOTT & WHITE
MEDICAL CENTER - IRVING*
TO Baylor Medical Center at Irving
dba Baylor Scott & White Medical Center - Irving
c/o its registered agent, CSC-Lawyers Incorporating Service Company
211 E. 7th Street, Suite 620
Austin, Texas 78701
' 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 BSW-IRVING Page 1
cm: 3leete3e (2:30!
Greetings:
YOU ARE COMMANDED to appear for a deposition on written questions of the
custodian of records for the Baylor Medical Center at Irving dba Baylor Scott & White Medical
Center— Irving 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
confinement, 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
I, and Kroger Texas L.P.
SUBPOENA DUCES TECUM TO BS W-IRVING 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.con
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 BSW-IRVING Page 3
IN THE 116 JUDICIAL DISTRICT
DALLAS COUNTY, TEXAS
MDL PRETRIAL CAUSE NO: 2018-77098
COUNTY OF DALLAS
vs
PURDUE PHARMA, L.P., ET AL
ae
MASTER FILE NO: 2018-63587
IN THE 152%° JUDICIAL DISTRICT
HARRIS COUNTY, TEXAS
IN RE: TEXAS OPIOID LITIGATION
RETURN
Came to my hand: 03/23/2023 ,at 12:30 o'clock P.M.
. Subpoena for Deposition on Written Questions (With Duces Tecum) to Baylor
Medical Center at Irving, dba Baylor Scott & White Medical Center — Irving
. $11
Executed by me on 3/23/2023 sat 3:08 o'clock 7M at
211 E. 7™ STREET, SUITE 620, AUSTIN, TX 78701, within the county of TRAVIS, by
delivering to BAYLOR MEDICAL CENTER AT IRVING dba BAYLOR SCOTT & WHITE
Mi IEDICAL CENTER - IRVING, by delivering to its registered agent, CSC-LAWYERS
Ni ICORPORATING SERVICE COMPANY, by delivering to employee/managing agent,
in person, a true copy of the above specified
item(s).
| am over the age of 18, not a party to nor interested in the outcome of the above styled and numbered
suit ; and | certify that the facts of service reported herein are true and correct.
Authorized Pers6n Jemy Mel ber
STATE OF TEXAS }
VERIFICATION
Before me, a notary public, on this day personally appeared the above named Authorized person, known
to me to be the person whose name is subscribed to the foregoi document and, being by me first duly
sworn, declared that the statements and facts therein contained are within his/her personal knowledge
and exper ce to be true and correct. Given under my hand and seal of office on this the 23*: day of
2023
pasanansanaad
Dana L. McMichael r
ID #4733578
My Commission Expires
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23, 2024
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Preview
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 ERKAA AA RAA AA EAR AAR REE REAR AAR AR ERA R ARERR EERE ELE REEL LER RARER R EERIE EERE IIT MASTER FILE NO. 2018-63587 IN THE DISTRICT COURT IN RE: TEXAS OPIOID LITIGATION § 152nd JUDICIAL DISTRICT HARRIS COUNTY, TEXAS FI IRI IRR HI III RR II III RK IRI IR IR IRI RII II II III III IIIA AAI IAAI A IAAI AI AISI AS AS. SUBPOENA FOR DEPOSITION ON WRITTEN QUESTIONS (WITH DUCES TECUM) TO BAYLOR MEDICAL CENTER AT IRVING DBA BAYLOR SCOTT & WHITE MEDICAL CENTER - IRVING* TO Baylor Medical Center at Irving dba Baylor Scott & White Medical Center - Irving c/o its registered agent, CSC-Lawyers Incorporating Service Company 211 E. 7th Street, Suite 620 Austin, Texas 78701 ' 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 BSW-IRVING Page 1 cm: 3leete3e (2:30! Greetings: YOU ARE COMMANDED to appear for a deposition on written questions of the custodian of records for the Baylor Medical Center at Irving dba Baylor Scott & White Medical Center— Irving 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 confinement, 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 I, and Kroger Texas L.P. SUBPOENA DUCES TECUM TO BS W-IRVING 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.con 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 BSW-IRVING Page 3 IN THE 116 JUDICIAL DISTRICT DALLAS COUNTY, TEXAS MDL PRETRIAL CAUSE NO: 2018-77098 COUNTY OF DALLAS vs PURDUE PHARMA, L.P., ET AL ae MASTER FILE NO: 2018-63587 IN THE 152%° JUDICIAL DISTRICT HARRIS COUNTY, TEXAS IN RE: TEXAS OPIOID LITIGATION RETURN Came to my hand: 03/23/2023 ,at 12:30 o'clock P.M. . Subpoena for Deposition on Written Questions (With Duces Tecum) to Baylor Medical Center at Irving, dba Baylor Scott & White Medical Center — Irving . $11 Executed by me on 3/23/2023 sat 3:08 o'clock 7M at 211 E. 7™ STREET, SUITE 620, AUSTIN, TX 78701, within the county of TRAVIS, by delivering to BAYLOR MEDICAL CENTER AT IRVING dba BAYLOR SCOTT & WHITE Mi IEDICAL CENTER - IRVING, by delivering to its registered agent, CSC-LAWYERS Ni ICORPORATING SERVICE COMPANY, by delivering to employee/managing agent, in person, a true copy of the above specified item(s). | am over the age of 18, not a party to nor interested in the outcome of the above styled and numbered suit ; and | certify that the facts of service reported herein are true and correct. Authorized Pers6n Jemy Mel ber STATE OF TEXAS } VERIFICATION Before me, a notary public, on this day personally appeared the above named Authorized person, known to me to be the person whose name is subscribed to the foregoi document and, being by me first duly sworn, declared that the statements and facts therein contained are within his/her personal knowledge and exper ce to be true and correct. Given under my hand and seal of office on this the 23*: day of 2023 pasanansanaad Dana L. McMichael r ID #4733578 My Commission Expires : AprileT 23, 2024 V TET TTT } Notary Public 52791-1 he ™} a e wt TSO “ v veel fiesta? see] ve ” ee YES eRe te & ashe a Wf ON