Preview
FILED
1/14/2022 4:40 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
CAROLYN SELLERS DEPUTY
CAUSE NO. DC-21-08674
FRANTEISHA FONTENOT; DARREN IN THE DISTRICT COURT
§§§§§§§§§§§§§
KING; MARVIN PRIDE and YALONDA
WRIGHT, EACH INDIVIDUALLY AND
ON BEHALF OF THE ESTATE OF LINDA
FONTENOT WILLIAMS, DECEASED
VS. 116TH JUDICIAL DISTRICT
DHC OPCO-CARROLLTON, LLC d/b/a
BROOKHAVEN NURSING AND
REHABILITATION CENTER and THI OF
TEXAS AT RICHARDSON, LLC d/b/a THE
VILLAGE AT RICHARDSON DALLAS COUNTY, TEXAS
PLAINTIFFS’ MOTION TO COMPEL DEFENDANT THI OF TEXAS AT
RICHARDSON, LLC d/b/a THE VILLAGE AT RICHARDSON TO PROVIDE
DEPOSITION DATES
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, PLAINTIFFS FRANTEISHA FONTENOT; DARREN KING;
MARVIN PRIDE and YALONDA WRIGHT, EACH INDIVIDUALLY AND ON
BEHALF OF THE ESTATE OF LINDA FONTENOT WILLIAMS, DECEASED, and file
this MOTION TO COMPEL DEFENDANT THI OF TEXAS AT RICHARDSON, LLC
d/b/a THE VILLAGE AT RICHARDSON, to Provide Deposition dates, and in support
thereof, would respectfully show unto the Court as follows:
l. This is a case involving allegations of medical and nursing negligence.
2. On September 9, 2021, September 14, 2021, December 15, 2021, December 17, 2021,
January 6, 2022, January 10, 2022, January 12, 2022, and January l4, 2022, Plaintiffs
requested Defendant provide dates for the deposition of the following individuals:
Bernadette Musa, CNA
a.b.c.d.
Britney Ross, CNA
Evnalen Hild, RN
Israel Lopez, LVN
PLAINTIFFS’ MOTION T0 COMPEL DEFENDANT’S TO PROVIDE DEPOSITION DATES Page 1
Mary Semar, LVN
Pabitra Kadariya, CNA
worm Tanna Coats, CNA
Tristan Smith, CNA
See emails, attached hereto as Exhibit A.
3. Plaintiffs request the Court compel defense counsel to provide dates for the depositions of
these witnesses and/or to provide their last known contact information with permission for
Plaintiffs’ counsel to subpoena them.
WHEREFORE, PREMISES CONSIDERED, Plaintiffs respectfully request that the
Court to Order defense counsel to provide dates for the requested deposition of the above referenced
individuals Within (7) days of the date of this Order, and for such other and further relief, both at
law and in equity, to which Plaintiffs may be justly entitled.
Respectfully submitted,
WORMINGTON & BOLLINGER
By
new
Maria Wormington, R.N., JD
State Bar No. 24013783
maria@wormingtonlegal.com
David Benford, JD
State Bar No. 02132940
david@wormingtonlegal.com
212 East Virginia Street
McKinney, Texas 75069
(972) 569-3930
(972) 547-6440 Facsimile
COUNSEL FOR PLAINTIFFS
PLAINTIFFS’ MOTION T0 COMPEL DEFENDANT’S TO PROVIDE DEPOSITION DATES Page 2
LOCAL RULE g.07 CERTIFICATE OF CONFERENCE
Counsel for Plaintiffs attempted to confer with counsel for Defendant and on regarding
every item in this motion and has not, despite best efforts, received a response whatsoever from
counsel for Defendant; thus presenting this motion to the Court for determination.
Certified to the 14th day of January 2022, by:
new
Maria Wormington, R.N., JD
CERTIFICATE OF SERVICE
This will certify on this day of January 2022, that a true and correct copy of the
14th
foregoing was forwarded to opposing counsel as follows:
Via E—Service:
Frank Alvarez/Megan P. Pharis
Quintairos, Prieto, Wood & Boyer, P.A.
1700 Pacific Avenue, Suite 4545
Dallas, Texas 75201
Counsel for Defendant DHC OPCO-Carrollton, LLC d/b/a Brookhaven Nursing and
Rehabilitation Center
Via E-Service:
Arlene A. Wiese
Fundamental Administrative Services, LLC
5700 Tennyson Parkway, Suite 300
Plano, Texas 75024
Counsel for Defendant THI of Texas at Richardson, LLC d/b/a The Village at Richardson
jefl/
Maria Wormington, R.N., JD
PLAINTIFFS’ MOTION T0 COMPEL DEFENDANT’S TO PROVIDE DEPOSITION DATES Page 3
EXHIBIT
Pearl
To: Pearl
Subject: RE: Williams Mediation 12/13——CANCELLED
From: Pearl
Sent: Friday, January 14, 2022 2:45 PM
To: Arlene Wiese
Cc: Maria Wormington
Subject: RE: Williams Mediation 12/13--CANCELLED
Ms. Wiese — See attached motion to compel we intend to file today.
Sincerely,
Pearl Weatherford, Paralegal
Wormington & Bollinger
212 East Virginia Parkway
McKinney, Texas 75069
Phone: (972) 569-3930
E-Mail: pearl@wormin9tonlegal.com
http://www.wormingtonlegal.com
*Please send us documents for download to https://wormington-law-group.filemail.c0m/
CONFIDENTIALITY NOTICE: This communication is intended only for the use of the individual or entity to which it is addressed
and may contain information that is privileged, confidential, and exempt from disclosure under applicable law. If you are not the
intended recipient, you are notified that any use, dissemination, distribution, or copying of the communication is strictly prohibited. If
you have received this communication in error, please immediately notify us by return email or telephone at 972-569-3930.
Pearl
To: Arlene Wiese
Cc: Frank Alvarez; Roseann Gonzales; Sonya A. Haley; Megan P. Pharis; Maria Wormington
Subject: RE: Williams Mediation 12/13-—CANCELLED
From: Pearl
Sent: Friday, January 14, 2022 10:03 AM
To: Arlene Wiese
Cc: Frank Alvarez ; Roseann Gonzales ; Sonya A.
Haley ; Megan P. Pharis ; Maria Wormington
Subject: RE: Williams Mediation 12/13--CANCELLED
Hope you are feeling better. Any update on dates?
From: Arlene Wiese
Sent: Wednesday, January 12, 2022 2:16 PM
To: Pearl
Subject: RE: Williams Mediation 12/13--CANCELLED
| am home sick with CoVid symptoms; hopefully will be well enough tomorrow.
Arlene Wiese, Esq.
Senior Litigation Counsel
Fundamental Administrative Services, LLC
5700 Tennyson Parkway Suite 300
Plano, TX 75024
Phone: 469-525-0300
Fax: 469-722-6903
arlene.wiese@fundltc.com
From: Pearl
Sent: Wednesday, January 12, 2022 10:20 AM
To: Arlene Wiese
Cc: David Benford ; Frank Alvarez ; Roseann Gonzales
; Sonya A. Haley ; Maria Wormington
; Megan P. Pharis
Subject: RE: Williams Mediation 12/13--CANCELLED
:EXTERNAL EMAIL: This email originated from outside of Fundamental's email system. DO NOT click links, open
Iattachments or take action unless you recognize the sender and know the content is safe.
Can we finalize dates today?
From: Arlene Wiese
Sent: Monday, January 10, 2022 9:58 AM
To: Pearl
Cc: David Benford ; Frank Alvarez ; Roseann Gonzales
; Sonya A. Haley ; Maria Wormington
; Megan P. Pharis
Subject: RE: Williams Mediation 12/13--CANCELLED
I will check on it after our depos today.
Arlene Wiese, Esq.
Senior Litigation Counsel
Fundamental Administrative Services, LLC
5700 Tennyson Parkway Suite 300
Plano, TX 75024
Phone: 469-525-0300
Fax: 469-722-6903
arlene.wiese@fundltc.com
From: Pearl
Sent: Monday, January 10, 2022 9:50 AM
To: Arlene Wiese
Cc: David Benford ; Frank Alvarez ; Roseann Gonzales
; Sonya A. Haley ; Maria Wormington
; Megan P. Pharis
Subject: RE: Williams Mediation 12/13——CANCELLED
:EXTERNAL EMAIL: This email originated from outside of Fundamental's email system. D0 NOT click links, open
:attachments or take action unless you recognize the sender and know the content is safe.
Any update on this?
From: Arlene Wiese
Sent: Thursday, January 6, 2022 12:14 PM
To: Pearl
Cc: David Benford ; Frank Alvarez ; Roseann Gonzales
; Sonya A. Haley ; Maria Wormington
; Megan P. Pharis
Subject: RE: Williams Mediation 12/13--CANCELLED
Will check on this.
Arlene Wiese, Esq.
Senior Litigation Counsel
Fundamental Administrative Services, LLC
5700 Tennyson Parkway Suite 300
Plano, TX 75024
Phone: 469-525-0300
Fax: 469-722-6903
arlene.wiese@fundltc.com
From: Pearl
Sent: Thursday, January 6, 2022 12:08 PM
To: Arlene Wiese
Cc: David Benford ; Frank Alvarez ; Roseann Gonzales
; Sonya A. Haley ; Maria Wormington
; Megan P. Pharis
Subject: RE: Williams Mediation 12/13--CANCELLED
:EXTERNAL EMAIL: This email originated from outside of Fundamental's email system. DO NOT click links, open
Zattachments or take action unless you recognize the sender and know the content is safe.
Thanks, per our calendar today, we are available Feb. 21-24 and Feb. 28.
Please confirm dates (2 people per day) asap as our calendar is filling up fast.
Pearl
To: Arlene Wiese
Subject: RE: Williams Mediation 12/13——CANCELLED
From: Pearl
Sent: Friday, December 17, 2021 10:20 AM
To: Arlene Wiese
Cc: David Benford ; Frank Alvarez ; Roseann Gonzales
; Sonya A. Haley ; Maria Wormington
; Megan P. Pharis
Subject: RE: Williams Mediation 12/13--CANCELLED
Ms. Wiese —
please respond to our request for deposition dates below.
From: Pearl
Sent: Wednesday, December 15, 2021 1:00 PM
To: Arlene Wiese
Cc: David Benford ; Frank Alvarez ; Roseann Gonzales
; Sonya A. Haley ; Maria Wormington
; Megan P. Pharis
Subject: RE: Williams Mediation 12/13--CANCELLED
Thanks, what about your client’s staff deposition dates?
I Copez, LVN — need first name
Mary Semar, LVN
Evnalen Hild, RN
Tristan Smith, CNA
Britney Ross, CNA
Tanna Coats, CNA
Bernadette Musa, CNA
Pabitra Kadariya, CNA
Pearl
To: Arlene Wiese
Subject: RE: dc-21—08674 Franteisha Fontenot et al v DHC OPCO—Carrollton, LLC et al
From: Pearl
Sent: Tuesday, September 14, 2021 9:20 AM
To: Megan P. Pharis ; Maria Wormington ; Frank
Alvarez ; Arlene Wiese
Cc: Leticia Ortega
Subject: Re: dc-21-08674 Franteisha Fontenot et al v DHC OPCO-Carrollton, LLC et al
Following up on deposition and mediation dates please.
From: Megan P. Pharis
Sent: Friday, September 10, 2021 8:48 AM
To: Maria Wormington ; Frank Alvarez ; Arlene Wiese
,- Pearl
Cc: Leticia Ortega
Subject: RE: dc-21-08674 Franteisha Fontenot et al v DHC OPCO-Carrollton, LLC et al
Understood. We are checking with our client and will let y’all know.
Thanks,
Megan
From: Maria Wormington
Sent: Friday, September 10, 2021 8:46 AM
To: Megan P. Pharis ; Frank Alvarez ; Arlene
Wiese ; Pearl
Cc: Leticia Ortega
Subject: RE: dc-21-08674 Franteisha Fontenot et a1 V DHC OPCO-Carrollton, LLC et a1
This is Arlene’s preference on behalf of her client.
I am asking if that is your client’s preference as well — i.e. schedule a mediation first with depositions scheduled
behind it in the event the mediation is not successful. If that is not what your client wants to do that is fine —
just let me know.
Sincerely,
Maria Wormington, RN JD
Wormington & Bollinger
212 East Virginia Street
McKinney, Texas 75069
972 569 3930
972 547 6440(fax)
maria@wormingtonlegal.com
www.wormingtonlegal.com
CONFIDENTIALITY NOTICE: This communication is intended only for the use of the individual or entity to
Which it is addressed and may contain information that is privileged, confidential, and exempt from disclosure
under applicable law. If you are not the intended recipient, you are notified that any use, dissemination,
distribution, or copying of the communication is strictly prohibited. If you have received this communication in
error, please immediately notify us by return email or telephone at 972-5 69-3 930.
From: Megan P. Pharis
Sent: Friday, September 10, 2021 8:44 AM
To: Frank Alvarez ; Maria Wormington ;
Arlene Wiese ; Pearl
Cc: Leticia Ortega <1eticia.ortega@qpwblaw.com>
Subject: RE: dc-21-08674 Franteisha Fontenot et a1 V DHC OPCO-Carrollton, LLC et a1
Maria,
I believe we all agreed to depose the Plaintiffs on November 9 and 10. Are you saying you want to delay those
until after a November mediation?
From: Frank Alvarez
Sent: Thursday, September 9, 2021 5:15 PM
T0: 'Maria Wormington' ; Arlene Wiese ; Pearl
; Megan P. Pharis
Cc: Leticia Ortega <1eticia.ortega@qpwblaw.com>
Subject: RE: dc-21-08674 Franteisha Fontenot et a1 V DHC OPCO-Carrollton, LLC et a1
We will check with the client.
A- -
Frank Alvarez Managing Partner-Dallas Office
I
Quintairos, Prieto, Wood & Boyer, P.A.
QPWB
.
I.
Licensed in Texas and New Mexico
V 1700 Pacific Avenue, Suite 4545, Dallas, Texas 75201
Ph: (214) 754-8755 x2202 Fax: (214) 754-8744
NAWOLF
Email: frank.alvarez@nnwblaw.com Web: www.qpwb|aw.com LAW FIRM MEMSER
Mobile: (214) 394.6554
Arizona O California O Florida Q Georgia O Illinois O Indiana O Kentucky O Maryland Q Michigan
Mississippi O Nevada O New Jersey O New York O Oklahoma Q Tennessee O Texas Q USVI
NOTICE: Quintairos, Prieto, Wood & Boyer, P. A. is a debt collector and any information obtained may be used for that purpose. This e-mail message
and any attachment to this e-mail message contains confidential information that may be legally privileged. If you are not the intended recipient, you
must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. If you received this e-mail in error.
please notify us immediately by return e-mail or by telephone at (855)287-0240 and delete this message. Please note that if this e-mail message
contains a fonNarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been
produced by Quintairos, Prieto Wood & Boyer, P. A.
From: Maria Wormington Imailto:Maria@Worminqtonleqal.coml
Sent: Thursday, September 09, 2021 5:09 PM
To: Arlene Wiese; Frank Alvarez; Pearl; Megan P. Pharis
Cc: Leticia Ortega
Subject: RE: dc-21-08674 Franteisha Fontenot et al v DHC OPCO-Carrollton, LLC et al
Mike Pennick is available for a November mediation as follows:
November 8,9,11,15,16,18,22,23 and 30.
Do any of these dates work for you and your clients?
Frank/Megean — Arlene and I discussed scheduling an early mediation (in November to permit time to review
the medical and billing I provided with my disclosures) and scheduling depositions behind that. Let me know if
that plan works for you.
Sincerely,
Maria Wormington, RN JD
Wormington & Bollinger
212 East Virginia Street
McKinney, Texas 75069
972 569 3930
972 547 6440(fax)
maria@wormingtonle2al.com
wwwwormingtonlegalcom
CONFIDENTIALITY NOTICE: This communication is intended only for the use of the individual or entity to
which it is addressed and may contain information that is privileged, confidential, and exempt from disclosure
under applicable law. If you are not the intended recipient, you are notified that any use, dissemination,
distribution, or copying of the communication is strictly prohibited. If you have received this communication in
error, please immediately notify us by return email or telephone at 972-569-3 930.
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.
Pearl Weatherford on behalf of Maria Wormington
Bar No. 24013783
pearl@wormingtonlegal.com
Envelope ID: 60851923
Status as of 1/18/2022 12:56 PM CST
Associated Case Party: FRANTEISHA FONTENOT
Name BarNumber Email TimestampSubmitted Status
Maria Wormington maria@wormingtonlegal.com 1/14/2022 4:40:03 PM SENT
David Benford david@wormingtonlegal.com 1/14/2022 4:40:03 PM SENT
Associated Case Party: DHC OPCO-CARROLLTON, LLC
Name BarNumber Email TimestampSubmitted Status
Frank Alvarez frank.alvarez@qpwblaw.com 1/14/2022 4:40:03 PM SENT
Megan Pharis megan.pharis@qpwblaw.com 1/14/2022 4:40:03 PM SENT
Roseann Gonzales roseann.gonzales@qpwblaw.com 1/14/2022 4:40:03 PM SENT
Associated Case Party: THl OF TEXAS AT RICHARDSON, LLC
Name BarNumber Email Timestam pSubmitted Status
Arlene Wiese arlene.wiese@fu ndltc.com 1/14/2022 4:40:03 PM SENT
Preview
FILED 1/14/2022 4:40 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS CAROLYN SELLERS DEPUTY CAUSE NO. DC-21-08674 FRANTEISHA FONTENOT; DARREN IN THE DISTRICT COURT §§§§§§§§§§§§§ KING; MARVIN PRIDE and YALONDA WRIGHT, EACH INDIVIDUALLY AND ON BEHALF OF THE ESTATE OF LINDA FONTENOT WILLIAMS, DECEASED VS. 116TH JUDICIAL DISTRICT DHC OPCO-CARROLLTON, LLC d/b/a BROOKHAVEN NURSING AND REHABILITATION CENTER and THI OF TEXAS AT RICHARDSON, LLC d/b/a THE VILLAGE AT RICHARDSON DALLAS COUNTY, TEXAS PLAINTIFFS’ MOTION TO COMPEL DEFENDANT THI OF TEXAS AT RICHARDSON, LLC d/b/a THE VILLAGE AT RICHARDSON TO PROVIDE DEPOSITION DATES TO THE HONORABLE JUDGE OF SAID COURT: COME NOW, PLAINTIFFS FRANTEISHA FONTENOT; DARREN KING; MARVIN PRIDE and YALONDA WRIGHT, EACH INDIVIDUALLY AND ON BEHALF OF THE ESTATE OF LINDA FONTENOT WILLIAMS, DECEASED, and file this MOTION TO COMPEL DEFENDANT THI OF TEXAS AT RICHARDSON, LLC d/b/a THE VILLAGE AT RICHARDSON, to Provide Deposition dates, and in support thereof, would respectfully show unto the Court as follows: l. This is a case involving allegations of medical and nursing negligence. 2. On September 9, 2021, September 14, 2021, December 15, 2021, December 17, 2021, January 6, 2022, January 10, 2022, January 12, 2022, and January l4, 2022, Plaintiffs requested Defendant provide dates for the deposition of the following individuals: Bernadette Musa, CNA a.b.c.d. Britney Ross, CNA Evnalen Hild, RN Israel Lopez, LVN PLAINTIFFS’ MOTION T0 COMPEL DEFENDANT’S TO PROVIDE DEPOSITION DATES Page 1 Mary Semar, LVN Pabitra Kadariya, CNA worm Tanna Coats, CNA Tristan Smith, CNA See emails, attached hereto as Exhibit A. 3. Plaintiffs request the Court compel defense counsel to provide dates for the depositions of these witnesses and/or to provide their last known contact information with permission for Plaintiffs’ counsel to subpoena them. WHEREFORE, PREMISES CONSIDERED, Plaintiffs respectfully request that the Court to Order defense counsel to provide dates for the requested deposition of the above referenced individuals Within (7) days of the date of this Order, and for such other and further relief, both at law and in equity, to which Plaintiffs may be justly entitled. Respectfully submitted, WORMINGTON & BOLLINGER By new Maria Wormington, R.N., JD State Bar No. 24013783 maria@wormingtonlegal.com David Benford, JD State Bar No. 02132940 david@wormingtonlegal.com 212 East Virginia Street McKinney, Texas 75069 (972) 569-3930 (972) 547-6440 Facsimile COUNSEL FOR PLAINTIFFS PLAINTIFFS’ MOTION T0 COMPEL DEFENDANT’S TO PROVIDE DEPOSITION DATES Page 2 LOCAL RULE g.07 CERTIFICATE OF CONFERENCE Counsel for Plaintiffs attempted to confer with counsel for Defendant and on regarding every item in this motion and has not, despite best efforts, received a response whatsoever from counsel for Defendant; thus presenting this motion to the Court for determination. Certified to the 14th day of January 2022, by: new Maria Wormington, R.N., JD CERTIFICATE OF SERVICE This will certify on this day of January 2022, that a true and correct copy of the 14th foregoing was forwarded to opposing counsel as follows: Via E—Service: Frank Alvarez/Megan P. Pharis Quintairos, Prieto, Wood & Boyer, P.A. 1700 Pacific Avenue, Suite 4545 Dallas, Texas 75201 Counsel for Defendant DHC OPCO-Carrollton, LLC d/b/a Brookhaven Nursing and Rehabilitation Center Via E-Service: Arlene A. Wiese Fundamental Administrative Services, LLC 5700 Tennyson Parkway, Suite 300 Plano, Texas 75024 Counsel for Defendant THI of Texas at Richardson, LLC d/b/a The Village at Richardson jefl/ Maria Wormington, R.N., JD PLAINTIFFS’ MOTION T0 COMPEL DEFENDANT’S TO PROVIDE DEPOSITION DATES Page 3 EXHIBIT Pearl To: Pearl Subject: RE: Williams Mediation 12/13——CANCELLED From: Pearl Sent: Friday, January 14, 2022 2:45 PM To: Arlene Wiese Cc: Maria Wormington Subject: RE: Williams Mediation 12/13--CANCELLED Ms. Wiese — See attached motion to compel we intend to file today. Sincerely, Pearl Weatherford, Paralegal Wormington & Bollinger 212 East Virginia Parkway McKinney, Texas 75069 Phone: (972) 569-3930 E-Mail: pearl@wormin9tonlegal.com http://www.wormingtonlegal.com *Please send us documents for download to https://wormington-law-group.filemail.c0m/ CONFIDENTIALITY NOTICE: This communication is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential, and exempt from disclosure under applicable law. If you are not the intended recipient, you are notified that any use, dissemination, distribution, or copying of the communication is strictly prohibited. If you have received this communication in error, please immediately notify us by return email or telephone at 972-569-3930. Pearl To: Arlene Wiese Cc: Frank Alvarez; Roseann Gonzales; Sonya A. Haley; Megan P. Pharis; Maria Wormington Subject: RE: Williams Mediation 12/13-—CANCELLED From: Pearl Sent: Friday, January 14, 2022 10:03 AM To: Arlene Wiese Cc: Frank Alvarez ; Roseann Gonzales ; Sonya A. Haley ; Megan P. Pharis ; Maria Wormington Subject: RE: Williams Mediation 12/13--CANCELLED Hope you are feeling better. Any update on dates? From: Arlene Wiese Sent: Wednesday, January 12, 2022 2:16 PM To: Pearl Subject: RE: Williams Mediation 12/13--CANCELLED | am home sick with CoVid symptoms; hopefully will be well enough tomorrow. Arlene Wiese, Esq. Senior Litigation Counsel Fundamental Administrative Services, LLC 5700 Tennyson Parkway Suite 300 Plano, TX 75024 Phone: 469-525-0300 Fax: 469-722-6903 arlene.wiese@fundltc.com From: Pearl Sent: Wednesday, January 12, 2022 10:20 AM To: Arlene Wiese Cc: David Benford ; Frank Alvarez ; Roseann Gonzales ; Sonya A. Haley ; Maria Wormington ; Megan P. Pharis Subject: RE: Williams Mediation 12/13--CANCELLED :EXTERNAL EMAIL: This email originated from outside of Fundamental's email system. DO NOT click links, open Iattachments or take action unless you recognize the sender and know the content is safe. Can we finalize dates today? From: Arlene Wiese Sent: Monday, January 10, 2022 9:58 AM To: Pearl Cc: David Benford ; Frank Alvarez ; Roseann Gonzales ; Sonya A. Haley ; Maria Wormington ; Megan P. Pharis Subject: RE: Williams Mediation 12/13--CANCELLED I will check on it after our depos today. Arlene Wiese, Esq. Senior Litigation Counsel Fundamental Administrative Services, LLC 5700 Tennyson Parkway Suite 300 Plano, TX 75024 Phone: 469-525-0300 Fax: 469-722-6903 arlene.wiese@fundltc.com From: Pearl Sent: Monday, January 10, 2022 9:50 AM To: Arlene Wiese Cc: David Benford ; Frank Alvarez ; Roseann Gonzales ; Sonya A. Haley ; Maria Wormington ; Megan P. Pharis Subject: RE: Williams Mediation 12/13——CANCELLED :EXTERNAL EMAIL: This email originated from outside of Fundamental's email system. D0 NOT click links, open :attachments or take action unless you recognize the sender and know the content is safe. Any update on this? From: Arlene Wiese Sent: Thursday, January 6, 2022 12:14 PM To: Pearl Cc: David Benford ; Frank Alvarez ; Roseann Gonzales ; Sonya A. Haley ; Maria Wormington ; Megan P. Pharis Subject: RE: Williams Mediation 12/13--CANCELLED Will check on this. Arlene Wiese, Esq. Senior Litigation Counsel Fundamental Administrative Services, LLC 5700 Tennyson Parkway Suite 300 Plano, TX 75024 Phone: 469-525-0300 Fax: 469-722-6903 arlene.wiese@fundltc.com From: Pearl Sent: Thursday, January 6, 2022 12:08 PM To: Arlene Wiese Cc: David Benford ; Frank Alvarez ; Roseann Gonzales ; Sonya A. Haley ; Maria Wormington ; Megan P. Pharis Subject: RE: Williams Mediation 12/13--CANCELLED :EXTERNAL EMAIL: This email originated from outside of Fundamental's email system. DO NOT click links, open Zattachments or take action unless you recognize the sender and know the content is safe. Thanks, per our calendar today, we are available Feb. 21-24 and Feb. 28. Please confirm dates (2 people per day) asap as our calendar is filling up fast. Pearl To: Arlene Wiese Subject: RE: Williams Mediation 12/13——CANCELLED From: Pearl Sent: Friday, December 17, 2021 10:20 AM To: Arlene Wiese Cc: David Benford ; Frank Alvarez ; Roseann Gonzales ; Sonya A. Haley ; Maria Wormington ; Megan P. Pharis Subject: RE: Williams Mediation 12/13--CANCELLED Ms. Wiese — please respond to our request for deposition dates below. From: Pearl Sent: Wednesday, December 15, 2021 1:00 PM To: Arlene Wiese Cc: David Benford ; Frank Alvarez ; Roseann Gonzales ; Sonya A. Haley ; Maria Wormington ; Megan P. Pharis Subject: RE: Williams Mediation 12/13--CANCELLED Thanks, what about your client’s staff deposition dates? I Copez, LVN — need first name Mary Semar, LVN Evnalen Hild, RN Tristan Smith, CNA Britney Ross, CNA Tanna Coats, CNA Bernadette Musa, CNA Pabitra Kadariya, CNA Pearl To: Arlene Wiese Subject: RE: dc-21—08674 Franteisha Fontenot et al v DHC OPCO—Carrollton, LLC et al From: Pearl Sent: Tuesday, September 14, 2021 9:20 AM To: Megan P. Pharis ; Maria Wormington ; Frank Alvarez ; Arlene Wiese Cc: Leticia Ortega Subject: Re: dc-21-08674 Franteisha Fontenot et al v DHC OPCO-Carrollton, LLC et al Following up on deposition and mediation dates please. From: Megan P. Pharis Sent: Friday, September 10, 2021 8:48 AM To: Maria Wormington ; Frank Alvarez ; Arlene Wiese ,- Pearl Cc: Leticia Ortega Subject: RE: dc-21-08674 Franteisha Fontenot et al v DHC OPCO-Carrollton, LLC et al Understood. We are checking with our client and will let y’all know. Thanks, Megan From: Maria Wormington Sent: Friday, September 10, 2021 8:46 AM To: Megan P. Pharis ; Frank Alvarez ; Arlene Wiese ; Pearl Cc: Leticia Ortega Subject: RE: dc-21-08674 Franteisha Fontenot et a1 V DHC OPCO-Carrollton, LLC et a1 This is Arlene’s preference on behalf of her client. I am asking if that is your client’s preference as well — i.e. schedule a mediation first with depositions scheduled behind it in the event the mediation is not successful. If that is not what your client wants to do that is fine — just let me know. Sincerely, Maria Wormington, RN JD Wormington & Bollinger 212 East Virginia Street McKinney, Texas 75069 972 569 3930 972 547 6440(fax) maria@wormingtonlegal.com www.wormingtonlegal.com CONFIDENTIALITY NOTICE: This communication is intended only for the use of the individual or entity to Which it is addressed and may contain information that is privileged, confidential, and exempt from disclosure under applicable law. If you are not the intended recipient, you are notified that any use, dissemination, distribution, or copying of the communication is strictly prohibited. If you have received this communication in error, please immediately notify us by return email or telephone at 972-5 69-3 930. From: Megan P. Pharis Sent: Friday, September 10, 2021 8:44 AM To: Frank Alvarez ; Maria Wormington ; Arlene Wiese ; Pearl Cc: Leticia Ortega <1eticia.ortega@qpwblaw.com> Subject: RE: dc-21-08674 Franteisha Fontenot et a1 V DHC OPCO-Carrollton, LLC et a1 Maria, I believe we all agreed to depose the Plaintiffs on November 9 and 10. Are you saying you want to delay those until after a November mediation? From: Frank Alvarez Sent: Thursday, September 9, 2021 5:15 PM T0: 'Maria Wormington' ; Arlene Wiese ; Pearl ; Megan P. Pharis Cc: Leticia Ortega <1eticia.ortega@qpwblaw.com> Subject: RE: dc-21-08674 Franteisha Fontenot et a1 V DHC OPCO-Carrollton, LLC et a1 We will check with the client. A- - Frank Alvarez Managing Partner-Dallas Office I Quintairos, Prieto, Wood & Boyer, P.A. QPWB . I. Licensed in Texas and New Mexico V 1700 Pacific Avenue, Suite 4545, Dallas, Texas 75201 Ph: (214) 754-8755 x2202 Fax: (214) 754-8744 NAWOLF Email: frank.alvarez@nnwblaw.com Web: www.qpwb|aw.com LAW FIRM MEMSER Mobile: (214) 394.6554 Arizona O California O Florida Q Georgia O Illinois O Indiana O Kentucky O Maryland Q Michigan Mississippi O Nevada O New Jersey O New York O Oklahoma Q Tennessee O Texas Q USVI NOTICE: Quintairos, Prieto, Wood & Boyer, P. A. is a debt collector and any information obtained may be used for that purpose. This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail or any attachments to it. If you received this e-mail in error. please notify us immediately by return e-mail or by telephone at (855)287-0240 and delete this message. Please note that if this e-mail message contains a fonNarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Quintairos, Prieto Wood & Boyer, P. A. From: Maria Wormington Imailto:Maria@Worminqtonleqal.coml Sent: Thursday, September 09, 2021 5:09 PM To: Arlene Wiese; Frank Alvarez; Pearl; Megan P. Pharis Cc: Leticia Ortega Subject: RE: dc-21-08674 Franteisha Fontenot et al v DHC OPCO-Carrollton, LLC et al Mike Pennick is available for a November mediation as follows: November 8,9,11,15,16,18,22,23 and 30. Do any of these dates work for you and your clients? Frank/Megean — Arlene and I discussed scheduling an early mediation (in November to permit time to review the medical and billing I provided with my disclosures) and scheduling depositions behind that. Let me know if that plan works for you. Sincerely, Maria Wormington, RN JD Wormington & Bollinger 212 East Virginia Street McKinney, Texas 75069 972 569 3930 972 547 6440(fax) maria@wormingtonle2al.com wwwwormingtonlegalcom CONFIDENTIALITY NOTICE: This communication is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential, and exempt from disclosure under applicable law. If you are not the intended recipient, you are notified that any use, dissemination, distribution, or copying of the communication is strictly prohibited. If you have received this communication in error, please immediately notify us by return email or telephone at 972-569-3 930. 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. Pearl Weatherford on behalf of Maria Wormington Bar No. 24013783 pearl@wormingtonlegal.com Envelope ID: 60851923 Status as of 1/18/2022 12:56 PM CST Associated Case Party: FRANTEISHA FONTENOT Name BarNumber Email TimestampSubmitted Status Maria Wormington maria@wormingtonlegal.com 1/14/2022 4:40:03 PM SENT David Benford david@wormingtonlegal.com 1/14/2022 4:40:03 PM SENT Associated Case Party: DHC OPCO-CARROLLTON, LLC Name BarNumber Email TimestampSubmitted Status Frank Alvarez frank.alvarez@qpwblaw.com 1/14/2022 4:40:03 PM SENT Megan Pharis megan.pharis@qpwblaw.com 1/14/2022 4:40:03 PM SENT Roseann Gonzales roseann.gonzales@qpwblaw.com 1/14/2022 4:40:03 PM SENT Associated Case Party: THl OF TEXAS AT RICHARDSON, LLC Name BarNumber Email Timestam pSubmitted Status Arlene Wiese arlene.wiese@fu ndltc.com 1/14/2022 4:40:03 PM SENT