On December 28, 2021 a
Party Statement
was filed
involving a dispute between
Langley, Robyn,
and
Newcrestimage Holdings, Llc,
Newcrestimage Management, Llc D B A Ac Hotel Downtown Dallas,
Thomas Protection Group, Llc,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
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FILED
5/27/2022 10:23 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jenifer Trujillo DEPUTY
CAUSE NO. DC-21-18263
ROBYN LANGLEY, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § DALLAS COUNTY, TEXAS
§
NEWCRESTIMAGE MANAGEMENT, §
LLC D/B/A AC HOTEL DOWNTOWN §
DALLAS, §
Defendant. § 193m JUDICIAL DISTRICT
PLAINTIFF’S NOTICE OF FILING AFFIDAVITS
Please take notice that pursuant to Rules 803(6) and 902(10) of the Texas Rules of
Evidence, and pursuant to §18.001 of the Texas Civil Practice and Remedies Code, Plaintiff is
filing with papers of this cause the following affidavits for medical records and for billing records
affidavits. Said afiidavits were served on March 30, 2021 and May 27, 2022.
Affidavit Establishing the Necessity and Reasonableness of Services and Charges from
Azouz Plastic & Cosmetic Surgery;
Affidavit of Medical Records from Azouz Plastic & Cosmetic Surgery;
Affidavit Establishing the Necessity and Reasonableness of Services and Charges from
Dr. Caroline Bullen;
Affidavit of Medical Records from Dr. Caroline Bullen;
Affidavit Establishing the Necessity and Reasonableness of Services and Charges from
ER Near Me;
Affidavit of Medical Records from ER Near Me;
Affidavit Establishing the Necessity and Reasonableness of Services and Charges from
Highland Park ER;
Affidavit of Medical Records from Highland Park ER;
Affidavit Establishing the Necessity and Reasonableness of Services and Charges from
Quantas Emergency Physicians;
Affidavit Establishing the Necessity and Reasonableness of Services and Charges from
Dr. Thania Quesada;
Affidavit of Medical Records from Dr. Thania Quesada.
PLAINTIFF’S NOTICE OF FILING AFFIDAVITS
PAGE 1 0F 2
Further, pursuant to Rule 902(10)(a) of the Texas Rules of Civil Evidence, these records
will be made available by the Clerk of the Court to counsel for all parties to this litigation for
inspection and copying at the expense of the counsel requesting such copies.
Respectfully submitted,
Wolf Law, PLLC
By: W mask
Julie Mn
Texas Bar No. 24051542
julie@wolflaypllc.com
12222 Merit Dr., Suite 1200
Dallas, Texas 75251
Tel. (972) 338-4477
Fax. (972) 338-5044
Attorney for Plaintifl
CERTIFICATE OF SERVICE
I certify that on this day of May, 2022, a true and correct copy of the aforementioned
document was served on all counsel of record, in accordance with the Texas Rules of Civil
Procedure.
U
Julia Wolf
PLAINTIFF’S NOTICE 0F FILING AFFIDAVITS
PAGE 2 0F 2
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.
Julie Wolf on behalf of Julie Wolf
Bar No. 24051542
julie@wolflawpllc.com
Envelope ID: 64920414
Status as of 5/27/2022 10:25 AM CST
Associated Case Party: ROBYN LANGLEY
Name BarNumber Email TimestampSubmitted Status
Wolf Law PLLC service@wolflawpllc.com 5/27/2022 10:23:03 AM SENT
Associated Case Party: NEWCRESTIMAGE MANAGEMENT, LLC D/B/A AC HOTEL
DOWNTOWN DALLAS
Name BarNumber Email TimestampSubmitted Status
Christine YDuperroir cduperroir@bbarr.com 5/27/2022 10:23:03 AM SENT
Melanie Baker mbaker@bbarr.com 5/27/2022 10:23:03 AM SENT
Autumn Herron aherron@bbarr.com 5/27/2022 10:23:03 AM SENT
Document Filed Date
May 27, 2022
Case Filing Date
December 28, 2021
Category
OTHER PERSONAL INJURY
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FILED 5/27/2022 10:23 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jenifer Trujillo DEPUTY CAUSE NO. DC-21-18263 ROBYN LANGLEY, § IN THE DISTRICT COURT Plaintiff, § § v. § DALLAS COUNTY, TEXAS § NEWCRESTIMAGE MANAGEMENT, § LLC D/B/A AC HOTEL DOWNTOWN § DALLAS, § Defendant. § 193m JUDICIAL DISTRICT PLAINTIFF’S NOTICE OF FILING AFFIDAVITS Please take notice that pursuant to Rules 803(6) and 902(10) of the Texas Rules of Evidence, and pursuant to §18.001 of the Texas Civil Practice and Remedies Code, Plaintiff is filing with papers of this cause the following affidavits for medical records and for billing records affidavits. Said afiidavits were served on March 30, 2021 and May 27, 2022. Affidavit Establishing the Necessity and Reasonableness of Services and Charges from Azouz Plastic & Cosmetic Surgery; Affidavit of Medical Records from Azouz Plastic & Cosmetic Surgery; Affidavit Establishing the Necessity and Reasonableness of Services and Charges from Dr. Caroline Bullen; Affidavit of Medical Records from Dr. Caroline Bullen; Affidavit Establishing the Necessity and Reasonableness of Services and Charges from ER Near Me; Affidavit of Medical Records from ER Near Me; Affidavit Establishing the Necessity and Reasonableness of Services and Charges from Highland Park ER; Affidavit of Medical Records from Highland Park ER; Affidavit Establishing the Necessity and Reasonableness of Services and Charges from Quantas Emergency Physicians; Affidavit Establishing the Necessity and Reasonableness of Services and Charges from Dr. Thania Quesada; Affidavit of Medical Records from Dr. Thania Quesada. PLAINTIFF’S NOTICE OF FILING AFFIDAVITS PAGE 1 0F 2 Further, pursuant to Rule 902(10)(a) of the Texas Rules of Civil Evidence, these records will be made available by the Clerk of the Court to counsel for all parties to this litigation for inspection and copying at the expense of the counsel requesting such copies. Respectfully submitted, Wolf Law, PLLC By: W mask Julie Mn Texas Bar No. 24051542 julie@wolflaypllc.com 12222 Merit Dr., Suite 1200 Dallas, Texas 75251 Tel. (972) 338-4477 Fax. (972) 338-5044 Attorney for Plaintifl CERTIFICATE OF SERVICE I certify that on this day of May, 2022, a true and correct copy of the aforementioned document was served on all counsel of record, in accordance with the Texas Rules of Civil Procedure. U Julia Wolf PLAINTIFF’S NOTICE 0F FILING AFFIDAVITS PAGE 2 0F 2 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. Julie Wolf on behalf of Julie Wolf Bar No. 24051542 julie@wolflawpllc.com Envelope ID: 64920414 Status as of 5/27/2022 10:25 AM CST Associated Case Party: ROBYN LANGLEY Name BarNumber Email TimestampSubmitted Status Wolf Law PLLC service@wolflawpllc.com 5/27/2022 10:23:03 AM SENT Associated Case Party: NEWCRESTIMAGE MANAGEMENT, LLC D/B/A AC HOTEL DOWNTOWN DALLAS Name BarNumber Email TimestampSubmitted Status Christine YDuperroir cduperroir@bbarr.com 5/27/2022 10:23:03 AM SENT Melanie Baker mbaker@bbarr.com 5/27/2022 10:23:03 AM SENT Autumn Herron aherron@bbarr.com 5/27/2022 10:23:03 AM SENT