Preview
FILED
6/12/2023 11:24 AM
FELICIA PITRE
NO: DC—22-05999 DISTRICT CLERK
DALLAS CO., TEXAS
Terri Kilgore DEPUTY
“Tang, Quishi In the District Court of Dallas County,
Plaintiffls),
Texas 101st J uéicial District
VS.
lVIaverick Utility
Defenéanfls).
OFFICERS CERTIFICATION PURSUANT TO TEXAS RULE OF CIVIL
PROCEDURE 203
That pursuant to Texas Rules of Civii Procedure 203, the undersigned Notary Pubiic and for the State of Texas, do
|
hereby certify:
1. That on 0512412023, Bianca Reyes was duly caused and sworn to testify the truth, the whole truth and nothing but
the truth.
2. That the foregoing transcript is a true record of the testimony given by Bianca Reyes.
Custodian of Records for: Wellspine, PA - Medical
3. That the charges for my preparation of the compieted written question deposition transcript and for any required
copies of the exhibits there totai $44.00.
PERTAINING TO: Quishi Wang
4. That on 05/24/2023 the deposition transcript was submitted to Bianca Reyes for examination, signature, and
return to me by 0512412023.
5. That Bianca Reyes has not made changes in the foregoing transcript. The changes, if any, are reflected on _
page of the transcript.
6. That Bianca Reyes returned the transcript to me on 05/24/2023 has returned the examined and signed transcript
to me.
7. The originai transcript, or a copy of the originai transcript if the originai was not returned, together with copies of
ali exhibits thereto, was delivered by certified maii or hand delivery.
Paid by: Chrissy Russo, Attorney for Defendant, Maverick Utiiity Construction, State Bar#: 24127061
Law Office of Brian Judis
700 N. Pearl Street, Suite 425
Dailas, TX 75201
Emaii: christina.russo@cna.com
8. That a copy of this certificate was served by certified mail, teiephonic document transfer or hand deiivered to:
Chrissy Russo
Kurt Arnold Fax: (713) 222-3850
GIVEN UNDER MY HAND AND SEAi. of office on May 25, 2023.
Kata/14.5w
NOTARY PUBLIC FOR THE STATE OF TEXAS
1‘4?» LOU ELLEN lARRETT ABI Document Support Services
7
I 7993479
.
«army rouse. sure or nus 1401 1 PARK DRIVE, SUITE 201
NV COMMISSION EXPIRES
”at
AUGUST 9, 2026 TOMBALL, TEXAS 77377
281 -357-8080
OrderfififiTmQS—i 5/Texas411‘1
NO: DC-22-05999
Wang, Quishi In the District Court of Dallas County,
Plaintiff(s),
Texas 101st Judicial District
VS.
Maverick Utility
Defendant(s).
NOTICE OF INTENTION TO TAKE
DEPOSITION BY WRITTEN QUESTIONS
TO: Plaintiff, Wang, Quishi, by and through his/her counsel of record; Kurt Arnold, 6009 Memorial Drive, Houston,
TX 77007.
You will take notice that in twenty (20) days and after the service of a copy hereof, and of the attached questions,
the answers of the witness, custodian of records for: Wellspine, PA - Medical, as to such questions will be taken
before a Notary Public and representative of ABI Document Support Services, 14011 PARK DRIVE, SUITE 201,
TOMBALL, TEXAS 77377 to be used in the above styled and numbered cause.
Pursuant to Rule 200 and Rule 205 of the Texas Rules of Civil Procedure, a subpoena duces tecum is requested
and the officer is requested to direct the witness to produce at a time and place specified by such officer any and
all records, including, but not limited to all hospital records, x-ray reports, office notes, patient information
sheets, nurses notes, reports, test and all documents relating to any test performed, test results, physical
therapy, rehabilitation, evaluations, diagnostic studies, prescription records, computer data, computer
print outs, counseling, and correspondence, etc. (including any notes, records, reports, correspondence,
etc. that were received) pertaining to Quishi Wang, DOB: July 22, 1991, ID# XXX-XX-1263, patient treated by
Francisco Batlle, MD, in the possession, custody or control of the said witness and every such records to which
the witness may have access and to turn all such records over to the officer authorized to take this deposition so
that photographic reproduction of the same may be made attached to said deposition.
Respectfully Submitted,
/S/ Chrissy Russo
Chrissy Russo
State Bar#: 24127061
Law Office of Brian Judis
700 N. Pearl Street, Suite 425
Dallas, TX, 75201
Phone: (214) 220-5600
Fax: (214) 775-4124
Email: christina.russo@cna.com
Attorney for Defendant, Maverick Utility
Construction
Order#:6670195-15/Texas17A1
lhereby certify that a true and correct copy of the foregoing instrument has been served on all parties or their
attorneys of record in compliance with TRCP Rule 21(a), by hand delivery, telephonic document transfer,
certified mail, return receipt requested, on this day.
February 2, 2023
cc: Chrissy Russo
Kurt Arnold
ABl Document Support Services
14011 PARK DRIVE, SUITE 201
TOMBALL, TEXAS 77377
281 -357-8080
Order#:6670195-15/Texas17A2
ELECTRONIC DISCLOSURE NOTICE
Required Posting under HB300, effective 9/1/12 Texas Health and Safety Code Sec. 181.154
Requires NOTICE AND AUTHORIZATION FOR ELECTRONIC DISCLOSURE OF
PROTECTED HEALTH INFORMATION;
(a) A covered entity shall provide notice to an individual for Whom the covered entity
creates or receives protected health information if the individual's protected health
information is subject to electronic disclosure. A covered entity may provide general notice
by: (1) posting a written notice in the covered entity's place of business;
(b) May not electronically disclose an individual‘s protected health information to any
person Without a separate authorization from the individual or the individual's legally
authorized representative for each disclosure. An authorization for disclosure under this
subsection may be made in written or electronic form or in oral form if it is documented in
writing by the covered entity.
(c) The authorization for electronic disclosure of protected health information described by
Subsection (b) is not required if the disclosure is made: to another covered entity, as that term
is defined by Section 181.001, or to a covered entity, as that term is defined by Section
602.001, Insurance Code, for the purpose of: (A) treatment; (B) payment; (C) health care
operations; or (D) performing an insurance or health maintenance organization function
described by Section 602.053, Insurance Code; or as otherwise authorized or required by
state or federal law.
Order#:6670195-15/TXEDN"1
DEPOSITION SUBPOENA TO TESTIFY OR PRODUCE DOCUMENTS OR THINGS
THE STATE OF TEXAS
COUNTY OF DALLAS
To any Sheriff or constable of the State of Texas or other person authorized to serve subpoenas under Rule 176
T.R.C.P.
- GREETING:
YOU ARE HEREBY COMMANDED TO SUBPOENA AND SUMMON the following witness, Custodian of Records for:
Wellspine, PA - Medical
To appear before a Notary Public of my designation for ABl Document Support Services, 14011 PARK DRIVE,
SUITE 201, TOMBALL, TEXAS 77377 on the day of March 8, 2023 at the office of the witness and there to make
answers under oath of certain written questions to be propounded to the Custodian of Records and to bring and
produce for inspection and photocopying any and all records, including, but not limited to all hospital records,
x-ray reports, office notes, patient information sheets, nurses notes, reports, test and all documents relating
to any test performed, test results, physical therapy, rehabilitation, evaluations, diagnostic studies,
prescription records, computer data, computer print outs, counseling, and correspondence, etc. (including
any notes, records, reports, correspondence, etc. that were received) pertaining to Quishi Wang, DOB: July
22, 1991, ID# XXX-XX-1263, patient treated by Francisco Batlle, MD, and every such records to which the witness
may have access at any time whatsoever. 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. Then and
there to give evidence at the instance of the Defendant, Maverick Utility by and through their attorney of records;
Chrissy Russo, Law Office of Brian Judis, 700 N. Pearl Street, Suite 425, Dallas, TX 75201 pending in that certain
cause No. DC-22-05999, In the District Court of Dallas County, Texas 101st Judicial District this subpoena is issued
under and by virtue of authority of a notice duly served and on file with the above named court, in which
Wang, Quishi
ls the Plaintiff and
Maverick Utility
ls the Defendant and there remain from day to day and time to time until discharged according to law.
WITNESS MY HAND on February 8, 2023.
g JUDY FRANK
1mm x
NOTARY PUBLIC, STATE OF
MY COMMISSION EXPIRESTEXAS‘
{GOES AUGUST 11. 2023 NOTARY PUBLIC FOR THE STATE OF TEXAS
ABI Document Support Services, 14011 PARK DRIVE, SUITE 201, TOMBALL, TEXAS 77377
(281)357-8080
OFFICERS RETURN
Came to hand this the day of , 20 executed this the day of
, 20 , in the following manner: By delivering to the within named witness
a true copy hereof, and tendering $ 1.00 which
has accepted.
Returned this the day of , 20
Witness Fee $ Mileage $ Service $ Process $ .
Order#:6670195-15/Texas23_FI|||n"1
(9 05-24-2023 04:02 PM 4693265101 —3 2813578086 pg 7 of 11
CAUSE NO. DC-22~05999
Wong, Quislti § In the District Court of
i’lnintili‘, §
§
VS. § Dallas County, Texas
ii
Maverick Utility §
Defendant. § l0 lst Judicial District
§
Wltl'l‘i'l-iN QUESTIONS TO Bil PROPOUNDED TO THE Wi'l‘Nl-ESS,
CUS’I‘ODMN 0F RECORDS FOR:
Wellspine, PA - Medical, 12655 North Central Expressway. Suite. 650, Dallas, TX 75243
I occupation.’
State your full name, residence phone number and
WIM
ANSWER Etanw lac-«3 llwcfiVSN (Wm! 19W 2'4 @6701!”me
2. this Qulshi Wong ever been examined, treated, counseled or cvniuotcd by Weihtpine, PA - Medical?
ANSWER:
W9 PA -
3. Has Wetlspine, Medical made or c used to he made any notes, records, reports, diagnostic studies and
correspondence oftite examination, treatment andlor cvnlun ion ol’snid patient?
Answnn:
S
4. Are the entries manic on these notes. records, report. diagnostic studies, and correspondence ad the time or sitottly allot
the time of the transaction recorded by these entries?
ANSWER:
5.
W
Were these notes. records, reports, diagnostic stud es and correspon deuce mode or caused to he mode by Wellsptne.
I’A - Medical in the course oi‘n regularly conducted httsioe 5 activity?
ANSWER: W3
6. Was Itin the mgulnt course of business of Wellsptnc PA - Medical for the hospital, doctor, employee or representative
of theirs having personal knowledge ot the act event 0 inion, diagnosis or condition recorded in the records you have
ftmtlshed the Nolttrv Public to make such memorandum o? retéord or to transmit inl‘onntttion thereof to be included itt such
memorandum or record?
ANSWt-sn:
7.
W
Are these notes records, reports diagnostic studies and correspondence underwritten: supervision direction
custody
nod control?
ANSWER:
Vacs
OMEN” 1115-1 We: 0:65” F ‘i
(5 05-24-2023 04:02 PM 4693265101 -> 2813578086 pg 8 of 11
8. Were these records kept as described above?
ANSWER:
i: S
9. Does the source
,
of the information or the method of preparing these records indicate the records are of n tmstwortlty
nature?
ANSWER:
i068
l0. l’lcttsc hand any and all reeurds, including, but not Ii oiled to all hospital records, x-roy reports. ofl‘icc traits. patient information
sheets, nurses notes. reports. test and all documents relating. to a ty test performed. test results. physical therapy. rehabilitation. evaluations.
diugnozttie studies, prescription records, computer data, compo er print outs. counseling. and correspondence, etc. (including any notes,
records, reports. correspondence, etc. that were received) perttt tting to Quislti Wong, DOB: July 22, 199t, [Dd XXX-XX-Iltfi. patient
treated by Francisco Bottle. MD,
ANSWER: /
NOTE: Please do not use your own judgment as to what documents you prodoeo; You are required under the
subpoena to produce ALL documents in your custody and possession regarding Quishi Wang.
I t. Have you handed over everything as requested in the preceding question? if not, why not?
ANSWERMCS
l2. Htts Wellsptne. PA - Medical and/or ttny ol‘ the employees extracted anything from the records of Qutshi Wang
medical records prior to the copying and/or filming of his/get record?
ANSWER: iii)
13. Docs Wellsptne, Pi,“ - Medlettl have It records retention policy and “'50, please state how long recordsihillsfmdiology
are retained prior to destruction.
Records retention?! m’ 3
Bill retention: m5
Radiology records rot tion:
14. Are there any further documents of any nature or tsoever regarding Qu Ishi Wang? trim. were they ltttndeti over? If
not. why not?
ANSWER: n0
WITNESSICUSTODI AN
t, WW4. R0518
answers ol‘the witness, the Custodian
. tl
ot'Re-wrd
nutty Public in the State of TEXAS, do hereby earth}! that the
were by the said witness made before and sworn to and subscribed
foregoing
before too by the snid witness. The records attached hereto are exact duplicates oftlte original records.
GIVEN omen MY HAND AND SEAL or OFFtCE this ".3213 ll or, I if )[4- ,2 2Q.
A4
§g*%g
_
s‘fiizgwg,
’2) M3375:
‘__*—‘=—'-1
SANDRA nose
Notary Public. State 0! Texas
Comm. EXplras “3-21-2028
AW
NO'i'ARY PUBLIC FOR THE STATE OF TEXAS
’bfl'olf‘u‘o ”only ID 130000452
Ordudmntfl- Momma
(9 05-24-2023 04:02 PM 4693265101 -> 2813578086 pg 6 of 11
NO: DC -22~05999
Wang, Qulslti tn the District Court of Dallas County,
Piaintifi'ts).
'l'cxns Itlist Judicial District
VS.
Maverick Utility
Dct‘cndnutts).
M Iii DAVIT
Type (if Records: any and MI records, including, but t' ot limited to all hospital records. .wny reports. ot‘t’lcc note-s. patient
information sheets, nurses moms, reports. test and all do ciimeuts relating to any test perforated. test results. physical therapy.
rehabilitation. evaluations. diagnostic studies, prescripli records. computer (into. computer print outs, counseling. and
correspondence, etc. (including any notes. records. rcpoins. cortesp_0tttiefl€¢, etc. that wen: recon-ed) pertaining to Quislii Wang.
-
DOB: July 22. |99I . IDIf XXX-XXII263, patient treated by Francisco Battle. MD.
llct'orc me, the undersigned authority, on this t lay personally appeared Idt’lm ,who.
being by me. duly sworn, deposed as follows:
Iaflfili
“I, the undersigned, run over 18 years of age. of sound mind. capable of making this allidtwit, and
Persunotl )' ttc uuinted with the facts herein statt d:
am the records custodian olWVellttpine, PA - M as such[ It vc ustorl fthc records
”02 Mia
I
conucming Quishi Wong for the period dicitlondZ of“
Olaf?» .lam had
familiar with the manner in which Weltspine, PA— Medical's records0
are created:
a nd maintained by
virtue ot‘my duties and responsibilities.
Attached hereto are 3: pages of records from \Veilspinc, PA Medical litese said 3”.“
pages of records are kept by Wellsplne, I’A - Medical'1n the regular course of business andit WttIi
the regular course of business of Wellspine, PA - Medical for an employee or representative oi
Weltspine. PA ~ Medical with knowledge ot't act , event. Condition, opinion or diagnosis, recorded
to make. the record or to transmit information by persons with knowledge of the matters act forth;
kept in the course of regularly conducted bum"ass
It: activity; and are the original is or the exact
duplicates of original records.
Wat/neg
Ad" I EANI
SWORN T0 AND SUBSCRIBE D before me on LN.... day 01'
gm Wm
. 201?
r
I
\|
SANDRA HOSE
537”
m,
:3?&
€05:.No
w..‘{\\ \\\
“mm,I,
”0:6
O
NOTARY PUBLIC. STATE OF ’r‘EX/Is
69,”le
Notary Public State of Texas
.
Comm Expires 10-21-2026
”no Prim Notatv ID 130000452
11
My commission expires: io‘ Zi’ 0210
Order” MTDIBS-ISFTEXASI I1
n)
wit
Preview
FILED 6/12/2023 11:24 AM FELICIA PITRE NO: DC—22-05999 DISTRICT CLERK DALLAS CO., TEXAS Terri Kilgore DEPUTY “Tang, Quishi In the District Court of Dallas County, Plaintiffls), Texas 101st J uéicial District VS. lVIaverick Utility Defenéanfls). OFFICERS CERTIFICATION PURSUANT TO TEXAS RULE OF CIVIL PROCEDURE 203 That pursuant to Texas Rules of Civii Procedure 203, the undersigned Notary Pubiic and for the State of Texas, do | hereby certify: 1. That on 0512412023, Bianca Reyes was duly caused and sworn to testify the truth, the whole truth and nothing but the truth. 2. That the foregoing transcript is a true record of the testimony given by Bianca Reyes. Custodian of Records for: Wellspine, PA - Medical 3. That the charges for my preparation of the compieted written question deposition transcript and for any required copies of the exhibits there totai $44.00. PERTAINING TO: Quishi Wang 4. That on 05/24/2023 the deposition transcript was submitted to Bianca Reyes for examination, signature, and return to me by 0512412023. 5. That Bianca Reyes has not made changes in the foregoing transcript. The changes, if any, are reflected on _ page of the transcript. 6. That Bianca Reyes returned the transcript to me on 05/24/2023 has returned the examined and signed transcript to me. 7. The originai transcript, or a copy of the originai transcript if the originai was not returned, together with copies of ali exhibits thereto, was delivered by certified maii or hand delivery. Paid by: Chrissy Russo, Attorney for Defendant, Maverick Utiiity Construction, State Bar#: 24127061 Law Office of Brian Judis 700 N. Pearl Street, Suite 425 Dailas, TX 75201 Emaii: christina.russo@cna.com 8. That a copy of this certificate was served by certified mail, teiephonic document transfer or hand deiivered to: Chrissy Russo Kurt Arnold Fax: (713) 222-3850 GIVEN UNDER MY HAND AND SEAi. of office on May 25, 2023. Kata/14.5w NOTARY PUBLIC FOR THE STATE OF TEXAS 1‘4?» LOU ELLEN lARRETT ABI Document Support Services 7 I 7993479 . «army rouse. sure or nus 1401 1 PARK DRIVE, SUITE 201 NV COMMISSION EXPIRES ”at AUGUST 9, 2026 TOMBALL, TEXAS 77377 281 -357-8080 OrderfififiTmQS—i 5/Texas411‘1 NO: DC-22-05999 Wang, Quishi In the District Court of Dallas County, Plaintiff(s), Texas 101st Judicial District VS. Maverick Utility Defendant(s). NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS TO: Plaintiff, Wang, Quishi, by and through his/her counsel of record; Kurt Arnold, 6009 Memorial Drive, Houston, TX 77007. You will take notice that in twenty (20) days and after the service of a copy hereof, and of the attached questions, the answers of the witness, custodian of records for: Wellspine, PA - Medical, as to such questions will be taken before a Notary Public and representative of ABI Document Support Services, 14011 PARK DRIVE, SUITE 201, TOMBALL, TEXAS 77377 to be used in the above styled and numbered cause. Pursuant to Rule 200 and Rule 205 of the Texas Rules of Civil Procedure, a subpoena duces tecum is requested and the officer is requested to direct the witness to produce at a time and place specified by such officer any and all records, including, but not limited to all hospital records, x-ray reports, office notes, patient information sheets, nurses notes, reports, test and all documents relating to any test performed, test results, physical therapy, rehabilitation, evaluations, diagnostic studies, prescription records, computer data, computer print outs, counseling, and correspondence, etc. (including any notes, records, reports, correspondence, etc. that were received) pertaining to Quishi Wang, DOB: July 22, 1991, ID# XXX-XX-1263, patient treated by Francisco Batlle, MD, in the possession, custody or control of the said witness and every such records to which the witness may have access and to turn all such records over to the officer authorized to take this deposition so that photographic reproduction of the same may be made attached to said deposition. Respectfully Submitted, /S/ Chrissy Russo Chrissy Russo State Bar#: 24127061 Law Office of Brian Judis 700 N. Pearl Street, Suite 425 Dallas, TX, 75201 Phone: (214) 220-5600 Fax: (214) 775-4124 Email: christina.russo@cna.com Attorney for Defendant, Maverick Utility Construction Order#:6670195-15/Texas17A1 lhereby certify that a true and correct copy of the foregoing instrument has been served on all parties or their attorneys of record in compliance with TRCP Rule 21(a), by hand delivery, telephonic document transfer, certified mail, return receipt requested, on this day. February 2, 2023 cc: Chrissy Russo Kurt Arnold ABl Document Support Services 14011 PARK DRIVE, SUITE 201 TOMBALL, TEXAS 77377 281 -357-8080 Order#:6670195-15/Texas17A2 ELECTRONIC DISCLOSURE NOTICE Required Posting under HB300, effective 9/1/12 Texas Health and Safety Code Sec. 181.154 Requires NOTICE AND AUTHORIZATION FOR ELECTRONIC DISCLOSURE OF PROTECTED HEALTH INFORMATION; (a) A covered entity shall provide notice to an individual for Whom the covered entity creates or receives protected health information if the individual's protected health information is subject to electronic disclosure. A covered entity may provide general notice by: (1) posting a written notice in the covered entity's place of business; (b) May not electronically disclose an individual‘s protected health information to any person Without a separate authorization from the individual or the individual's legally authorized representative for each disclosure. An authorization for disclosure under this subsection may be made in written or electronic form or in oral form if it is documented in writing by the covered entity. (c) The authorization for electronic disclosure of protected health information described by Subsection (b) is not required if the disclosure is made: to another covered entity, as that term is defined by Section 181.001, or to a covered entity, as that term is defined by Section 602.001, Insurance Code, for the purpose of: (A) treatment; (B) payment; (C) health care operations; or (D) performing an insurance or health maintenance organization function described by Section 602.053, Insurance Code; or as otherwise authorized or required by state or federal law. Order#:6670195-15/TXEDN"1 DEPOSITION SUBPOENA TO TESTIFY OR PRODUCE DOCUMENTS OR THINGS THE STATE OF TEXAS COUNTY OF DALLAS To any Sheriff or constable of the State of Texas or other person authorized to serve subpoenas under Rule 176 T.R.C.P. - GREETING: YOU ARE HEREBY COMMANDED TO SUBPOENA AND SUMMON the following witness, Custodian of Records for: Wellspine, PA - Medical To appear before a Notary Public of my designation for ABl Document Support Services, 14011 PARK DRIVE, SUITE 201, TOMBALL, TEXAS 77377 on the day of March 8, 2023 at the office of the witness and there to make answers under oath of certain written questions to be propounded to the Custodian of Records and to bring and produce for inspection and photocopying any and all records, including, but not limited to all hospital records, x-ray reports, office notes, patient information sheets, nurses notes, reports, test and all documents relating to any test performed, test results, physical therapy, rehabilitation, evaluations, diagnostic studies, prescription records, computer data, computer print outs, counseling, and correspondence, etc. (including any notes, records, reports, correspondence, etc. that were received) pertaining to Quishi Wang, DOB: July 22, 1991, ID# XXX-XX-1263, patient treated by Francisco Batlle, MD, and every such records to which the witness may have access at any time whatsoever. 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. Then and there to give evidence at the instance of the Defendant, Maverick Utility by and through their attorney of records; Chrissy Russo, Law Office of Brian Judis, 700 N. Pearl Street, Suite 425, Dallas, TX 75201 pending in that certain cause No. DC-22-05999, In the District Court of Dallas County, Texas 101st Judicial District this subpoena is issued under and by virtue of authority of a notice duly served and on file with the above named court, in which Wang, Quishi ls the Plaintiff and Maverick Utility ls the Defendant and there remain from day to day and time to time until discharged according to law. WITNESS MY HAND on February 8, 2023. g JUDY FRANK 1mm x NOTARY PUBLIC, STATE OF MY COMMISSION EXPIRESTEXAS‘ {GOES AUGUST 11. 2023 NOTARY PUBLIC FOR THE STATE OF TEXAS ABI Document Support Services, 14011 PARK DRIVE, SUITE 201, TOMBALL, TEXAS 77377 (281)357-8080 OFFICERS RETURN Came to hand this the day of , 20 executed this the day of , 20 , in the following manner: By delivering to the within named witness a true copy hereof, and tendering $ 1.00 which has accepted. Returned this the day of , 20 Witness Fee $ Mileage $ Service $ Process $ . Order#:6670195-15/Texas23_FI|||n"1 (9 05-24-2023 04:02 PM 4693265101 —3 2813578086 pg 7 of 11 CAUSE NO. DC-22~05999 Wong, Quislti § In the District Court of i’lnintili‘, § § VS. § Dallas County, Texas ii Maverick Utility § Defendant. § l0 lst Judicial District § Wltl'l‘i'l-iN QUESTIONS TO Bil PROPOUNDED TO THE Wi'l‘Nl-ESS, CUS’I‘ODMN 0F RECORDS FOR: Wellspine, PA - Medical, 12655 North Central Expressway. Suite. 650, Dallas, TX 75243 I occupation.’ State your full name, residence phone number and WIM ANSWER Etanw lac-«3 llwcfiVSN (Wm! 19W 2'4 @6701!”me 2. this Qulshi Wong ever been examined, treated, counseled or cvniuotcd by Weihtpine, PA - Medical? ANSWER: W9 PA - 3. Has Wetlspine, Medical made or c used to he made any notes, records, reports, diagnostic studies and correspondence oftite examination, treatment andlor cvnlun ion ol’snid patient? Answnn: S 4. Are the entries manic on these notes. records, report. diagnostic studies, and correspondence ad the time or sitottly allot the time of the transaction recorded by these entries? ANSWER: 5. W Were these notes. records, reports, diagnostic stud es and correspon deuce mode or caused to he mode by Wellsptne. I’A - Medical in the course oi‘n regularly conducted httsioe 5 activity? ANSWER: W3 6. Was Itin the mgulnt course of business of Wellsptnc PA - Medical for the hospital, doctor, employee or representative of theirs having personal knowledge ot the act event 0 inion, diagnosis or condition recorded in the records you have ftmtlshed the Nolttrv Public to make such memorandum o? retéord or to transmit inl‘onntttion thereof to be included itt such memorandum or record? ANSWt-sn: 7. W Are these notes records, reports diagnostic studies and correspondence underwritten: supervision direction custody nod control? ANSWER: Vacs OMEN” 1115-1 We: 0:65” F ‘i (5 05-24-2023 04:02 PM 4693265101 -> 2813578086 pg 8 of 11 8. Were these records kept as described above? ANSWER: i: S 9. Does the source , of the information or the method of preparing these records indicate the records are of n tmstwortlty nature? ANSWER: i068 l0. l’lcttsc hand any and all reeurds, including, but not Ii oiled to all hospital records, x-roy reports. ofl‘icc traits. patient information sheets, nurses notes. reports. test and all documents relating. to a ty test performed. test results. physical therapy. rehabilitation. evaluations. diugnozttie studies, prescription records, computer data, compo er print outs. counseling. and correspondence, etc. (including any notes, records, reports. correspondence, etc. that were received) perttt tting to Quislti Wong, DOB: July 22, 199t, [Dd XXX-XX-Iltfi. patient treated by Francisco Bottle. MD, ANSWER: / NOTE: Please do not use your own judgment as to what documents you prodoeo; You are required under the subpoena to produce ALL documents in your custody and possession regarding Quishi Wang. I t. Have you handed over everything as requested in the preceding question? if not, why not? ANSWERMCS l2. Htts Wellsptne. PA - Medical and/or ttny ol‘ the employees extracted anything from the records of Qutshi Wang medical records prior to the copying and/or filming of his/get record? ANSWER: iii) 13. Docs Wellsptne, Pi,“ - Medlettl have It records retention policy and “'50, please state how long recordsihillsfmdiology are retained prior to destruction. Records retention?! m’ 3 Bill retention: m5 Radiology records rot tion: 14. Are there any further documents of any nature or tsoever regarding Qu Ishi Wang? trim. were they ltttndeti over? If not. why not? ANSWER: n0 WITNESSICUSTODI AN t, WW4. R0518 answers ol‘the witness, the Custodian . tl ot'Re-wrd nutty Public in the State of TEXAS, do hereby earth}! that the were by the said witness made before and sworn to and subscribed foregoing before too by the snid witness. The records attached hereto are exact duplicates oftlte original records. GIVEN omen MY HAND AND SEAL or OFFtCE this ".3213 ll or, I if )[4- ,2 2Q. A4 §g*%g _ s‘fiizgwg, ’2) M3375: ‘__*—‘=—'-1 SANDRA nose Notary Public. State 0! Texas Comm. EXplras “3-21-2028 AW NO'i'ARY PUBLIC FOR THE STATE OF TEXAS ’bfl'olf‘u‘o ”only ID 130000452 Ordudmntfl- Momma (9 05-24-2023 04:02 PM 4693265101 -> 2813578086 pg 6 of 11 NO: DC -22~05999 Wang, Qulslti tn the District Court of Dallas County, Piaintifi'ts). 'l'cxns Itlist Judicial District VS. Maverick Utility Dct‘cndnutts). M Iii DAVIT Type (if Records: any and MI records, including, but t' ot limited to all hospital records. .wny reports. ot‘t’lcc note-s. patient information sheets, nurses moms, reports. test and all do ciimeuts relating to any test perforated. test results. physical therapy. rehabilitation. evaluations. diagnostic studies, prescripli records. computer (into. computer print outs, counseling. and correspondence, etc. (including any notes. records. rcpoins. cortesp_0tttiefl€¢, etc. that wen: recon-ed) pertaining to Quislii Wang. - DOB: July 22. |99I . IDIf XXX-XXII263, patient treated by Francisco Battle. MD. llct'orc me, the undersigned authority, on this t lay personally appeared Idt’lm ,who. being by me. duly sworn, deposed as follows: Iaflfili “I, the undersigned, run over 18 years of age. of sound mind. capable of making this allidtwit, and Persunotl )' ttc uuinted with the facts herein statt d: am the records custodian olWVellttpine, PA - M as such[ It vc ustorl fthc records ”02 Mia I conucming Quishi Wong for the period dicitlondZ of“ Olaf?» .lam had familiar with the manner in which Weltspine, PA— Medical's records0 are created: a nd maintained by virtue ot‘my duties and responsibilities. Attached hereto are 3: pages of records from \Veilspinc, PA Medical litese said 3”.“ pages of records are kept by Wellsplne, I’A - Medical'1n the regular course of business andit WttIi the regular course of business of Wellspine, PA - Medical for an employee or representative oi Weltspine. PA ~ Medical with knowledge ot't act , event. Condition, opinion or diagnosis, recorded to make. the record or to transmit information by persons with knowledge of the matters act forth; kept in the course of regularly conducted bum"ass It: activity; and are the original is or the exact duplicates of original records. Wat/neg Ad" I EANI SWORN T0 AND SUBSCRIBE D before me on LN.... day 01' gm Wm . 201? r I \| SANDRA HOSE 537” m, :3?& €05:.No w..‘{\\ \\\ “mm,I, ”0:6 O NOTARY PUBLIC. STATE OF ’r‘EX/Is 69,”le Notary Public State of Texas . Comm Expires 10-21-2026 ”no Prim Notatv ID 130000452 11 My commission expires: io‘ Zi’ 0210 Order” MTDIBS-ISFTEXASI I1 n) wit