On March 12, 2021 a
Party Statement
was filed
involving a dispute between
Watson, Shante,
and
Brown, Joshua,
Town East Heating & Air Condition Co, Llc,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
1/12/2023 5:10 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Terri Kilgore DEPUTY
CAUSE NO. DC-21-03224
SHANTE WATSON; THE DISTRICT COURT OF
§§§§§§§§§§§
IN
Plaintiff,
VS. DALLAS COUNTY, TEXAS
JOSHUA BROWN; AND TOWN
EAST HEATING & AIR
CONDITIONING CO., LLC;
Defendants. 134T” JUDICIAL DISTRICT
PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING
RECORD AFFIDAVITS
Plaintiff Shante Watson files with the Court the attached record affidavits:
MEDICAL RECORDS:
Glen Oaks Hospital records affidavit dated 6/8/2022
BILLING RECORDS:
Glen Oaks Hospital records affidavit dated 6/16/2022
By copy of this notice, opposing counsel are notified that these affidavits are
being filed with the Court pursuant to TRE 902. The records and radiology
corresponding to the enclosed affidavits will be kept in Plaintiff's counsel’s office for
use at trial. Opposing counsel have been previously provided with a copy of the
affidavits and corresponding records/radiology listed above.
PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING RECORD
AFFIDAVITS — Page 1
Respectfully submitted,
WITHERITE LAW GROUP, PLLC
By: /s/ Adewale Odetunde
ADEWALE ODETUNDE
State Bar No. 24088146
adewale.odetunde@witheritelaw.com
SHELLY GRECO
State Bar No. 24008168
shel|v.qreco@witheritelaw.com
10440 N. Central Expressway
Suite 400
Dallas, TX 75231-2228
214/378-6665
214/378-6670 (fax)
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
l hereby certify that a true and correct copy of the foregoing has been
forwarded to all counsel of record on this 12th day of January, 2023, pursuant to
the Texas Rules of Civil Procedure.
/s/ Adewale Odetunde
Adewale Odetunde
Sandra Liser
Naman Howell Smith & Lee, PLLC
Fort Worth Club Building
306 West 7th Street, Suite 405
Fort Worth, TX 76102-4911
J.Brantley Saunders
Saunders, Walsh & Beard
6850 TPC Drive
Suite 210
McKinney, TX 75070
PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING RECORD
AFFIDAVITS — Page 2
MEDICAL RECORDS AFFIDAVIT OF GLEN OAKS HOSPITAL
REGARDING PATIENT SHANTE WATSON
STATE OF TEXAS §
k §
'
COUNTY OF HD 5
BEF ME. the undersigned authority. personally
. , who. being by me duly sworn. deposed as follows:
..—-—\
My name ls . I am of sound mind, capable
this Affidavit, and personally acquainted with the facts herein stated:
I am the custodian of the records of Glen Oaks Hospital. Attached hereto are records
Oaks Hospital regarding Shente Watson. These records are kept by Glen Oaks Hospital in
course of business, and It was in the regular course of business for an employee or represel
knowledge of the act, event. condition, opinion, or diagnosis recorded to make the record or
information thereof to be Included In such record; and the record was made at or near the
event recorded or reasonably soon thereafter. The records attached hereto are the origin
duplicates of the original.
IAN OF MEDICAL RECORDS
SWORN TO AND SUBSCRIBED before me on the Q
.-
NOTARY PUBLIC IN A D FOR THE STATE OF‘TEXAE
MICHELLE EEAINE mm
432$ Notary Public. State at NOTARY’S PRINTED NAME:
1 Texas
“fig Comm. Expires 08-22-2022
Notary ID 129929951
MY COMMISSION EXPIRES:
AFFIDAVR' 0F RECORQS CUSTODiAN OF GLEN OAKS HOSPBTAL
REGARDiNG PATIENT SHANTE WATSOE
STATE OF TEXAS §
§
comm or: flint §
BEFORE ME, the undersigned authority, personally appeared
who, being by me duly swam, deposed as follows: '
My name is ._SA!VWMV pit” Dhu . i am of sound mind, capable
this Affidavit and personally acquainted With the facts herein stated.
i am a custodian of records for Gian Oaks
Hospitai. Attached to this Affidavit are n
provide an itemized statement of the service and the charge for the service that Glen ()3!
provided to Shanta Watson on 8115:2020 to present. The attached records are a part of this i
The attached records are kept by Stan Oaks Hospltei in the
regular course of busir
was the regular coarse of business of Glen Oaks
Hoepitai for an employee or representat
Oaks Hospitai, with knowledge of the service provided. to make the record or to transmit
infi
be included in the record. The records were made in the
reguiar course of business at or he
or reasonably soon after the time the service was provided. The records are the
' origins! or a c
the original.
The services provided were necessary and the amount charged for the service was
at the time and place that the services were provided
The total amount paid for the services Was $
I and the amount wrrentiy
which Glen Oaks Hospital has a right be paid after any 9
diastments or credits is $
STODiAN 0F BiLLiNG RECORDS
SWORN TO AND SUBSCRIBED before . , onthe “Q dayof Jungg I .
«WNW; LEEANN c. ATHERTON
Notary Public. State oi Texts
\“ml II],
455.2.No
.
°"‘e"fi°'€’é"g
v
.55 Comm. Expires 06-08-202 RY PU 1N AND FOR TH TATE OF TEXA:
:'9'."
5w“ Notary ID 132511450
1"1m
[ream mime“.
NOTARY'S PRINTED NAME:
,.
MY COMMISSION EXPIRES:
la} SEQ
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.
Amy Peacock on behalf of Adewale Odetunde
Bar No. 24088146
amy.peacock@witheritelaw.com
Envelope ID: 71761756
Status as of 1/13/2023 10:01 AM CST
Associated Case Party: JOSHUA BROWN
Name BarNumber Email TimestampSubmitted Status
Grant Liser gliser@namanhowell.com 1/12/2023 5:10:44 PM SENT
Sandra Liser sliser@namanhowell.com 1/12/2023 5:10:44 PM SENT
Associated Case Party: TOWN EAST HEATING & AIR CONDITION CO, LLC
Name BarNumber Email TimestampSubmitted Status
David Kennedy david@saunderswalsh.com 1/12/2023 5:10:44 PM SENT
Liz Jobes liz@saunderswalsh.com 1/12/2023 5:10:44 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Adewale WaleOdetunde Adewale.Odetunde@witheritelaw.com 1/12/2023 5:10:44 PM SENT
Document Filed Date
January 12, 2023
Case Filing Date
March 12, 2021
Category
MOTOR VEHICLE ACCIDENT
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FILED 1/12/2023 5:10 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Terri Kilgore DEPUTY CAUSE NO. DC-21-03224 SHANTE WATSON; THE DISTRICT COURT OF §§§§§§§§§§§ IN Plaintiff, VS. DALLAS COUNTY, TEXAS JOSHUA BROWN; AND TOWN EAST HEATING & AIR CONDITIONING CO., LLC; Defendants. 134T” JUDICIAL DISTRICT PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS Plaintiff Shante Watson files with the Court the attached record affidavits: MEDICAL RECORDS: Glen Oaks Hospital records affidavit dated 6/8/2022 BILLING RECORDS: Glen Oaks Hospital records affidavit dated 6/16/2022 By copy of this notice, opposing counsel are notified that these affidavits are being filed with the Court pursuant to TRE 902. The records and radiology corresponding to the enclosed affidavits will be kept in Plaintiff's counsel’s office for use at trial. Opposing counsel have been previously provided with a copy of the affidavits and corresponding records/radiology listed above. PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS — Page 1 Respectfully submitted, WITHERITE LAW GROUP, PLLC By: /s/ Adewale Odetunde ADEWALE ODETUNDE State Bar No. 24088146 adewale.odetunde@witheritelaw.com SHELLY GRECO State Bar No. 24008168 shel|v.qreco@witheritelaw.com 10440 N. Central Expressway Suite 400 Dallas, TX 75231-2228 214/378-6665 214/378-6670 (fax) ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE l hereby certify that a true and correct copy of the foregoing has been forwarded to all counsel of record on this 12th day of January, 2023, pursuant to the Texas Rules of Civil Procedure. /s/ Adewale Odetunde Adewale Odetunde Sandra Liser Naman Howell Smith & Lee, PLLC Fort Worth Club Building 306 West 7th Street, Suite 405 Fort Worth, TX 76102-4911 J.Brantley Saunders Saunders, Walsh & Beard 6850 TPC Drive Suite 210 McKinney, TX 75070 PLAINTIFF'S THIRD SUPPLEMENTAL NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS — Page 2 MEDICAL RECORDS AFFIDAVIT OF GLEN OAKS HOSPITAL REGARDING PATIENT SHANTE WATSON STATE OF TEXAS § k § ' COUNTY OF HD 5 BEF ME. the undersigned authority. personally . , who. being by me duly sworn. deposed as follows: ..—-—\ My name ls . I am of sound mind, capable this Affidavit, and personally acquainted with the facts herein stated: I am the custodian of the records of Glen Oaks Hospital. Attached hereto are records Oaks Hospital regarding Shente Watson. These records are kept by Glen Oaks Hospital in course of business, and It was in the regular course of business for an employee or represel knowledge of the act, event. condition, opinion, or diagnosis recorded to make the record or information thereof to be Included In such record; and the record was made at or near the event recorded or reasonably soon thereafter. The records attached hereto are the origin duplicates of the original. IAN OF MEDICAL RECORDS SWORN TO AND SUBSCRIBED before me on the Q .- NOTARY PUBLIC IN A D FOR THE STATE OF‘TEXAE MICHELLE EEAINE mm 432$ Notary Public. State at NOTARY’S PRINTED NAME: 1 Texas “fig Comm. Expires 08-22-2022 Notary ID 129929951 MY COMMISSION EXPIRES: AFFIDAVR' 0F RECORQS CUSTODiAN OF GLEN OAKS HOSPBTAL REGARDiNG PATIENT SHANTE WATSOE STATE OF TEXAS § § comm or: flint § BEFORE ME, the undersigned authority, personally appeared who, being by me duly swam, deposed as follows: ' My name is ._SA!VWMV pit” Dhu . i am of sound mind, capable this Affidavit and personally acquainted With the facts herein stated. i am a custodian of records for Gian Oaks Hospitai. Attached to this Affidavit are n provide an itemized statement of the service and the charge for the service that Glen ()3! provided to Shanta Watson on 8115:2020 to present. The attached records are a part of this i The attached records are kept by Stan Oaks Hospltei in the regular course of busir was the regular coarse of business of Glen Oaks Hoepitai for an employee or representat Oaks Hospitai, with knowledge of the service provided. to make the record or to transmit infi be included in the record. The records were made in the reguiar course of business at or he or reasonably soon after the time the service was provided. The records are the ' origins! or a c the original. The services provided were necessary and the amount charged for the service was at the time and place that the services were provided The total amount paid for the services Was $ I and the amount wrrentiy which Glen Oaks Hospital has a right be paid after any 9 diastments or credits is $ STODiAN 0F BiLLiNG RECORDS SWORN TO AND SUBSCRIBED before . , onthe “Q dayof Jungg I . «WNW; LEEANN c. ATHERTON Notary Public. State oi Texts \“ml II], 455.2.No . °"‘e"fi°'€’é"g v .55 Comm. Expires 06-08-202 RY PU 1N AND FOR TH TATE OF TEXA: :'9'." 5w“ Notary ID 132511450 1"1m [ream mime“. NOTARY'S PRINTED NAME: ,. MY COMMISSION EXPIRES: la} SEQ 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. Amy Peacock on behalf of Adewale Odetunde Bar No. 24088146 amy.peacock@witheritelaw.com Envelope ID: 71761756 Status as of 1/13/2023 10:01 AM CST Associated Case Party: JOSHUA BROWN Name BarNumber Email TimestampSubmitted Status Grant Liser gliser@namanhowell.com 1/12/2023 5:10:44 PM SENT Sandra Liser sliser@namanhowell.com 1/12/2023 5:10:44 PM SENT Associated Case Party: TOWN EAST HEATING & AIR CONDITION CO, LLC Name BarNumber Email TimestampSubmitted Status David Kennedy david@saunderswalsh.com 1/12/2023 5:10:44 PM SENT Liz Jobes liz@saunderswalsh.com 1/12/2023 5:10:44 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Adewale WaleOdetunde Adewale.Odetunde@witheritelaw.com 1/12/2023 5:10:44 PM SENT