Preview
FILED
1/27/2022 10:10 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Darling Tellez 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. 1 16TH JUDICIAL DISTRICT
DHC OPCO-CARROLLTON, LLC d/b/a
BROOKHAVEN NURSING AND
REHABILITATION CENTER and
THI OF TEXAS AT RICHARDSON, LLC
dm/a THE VILLAGE AT RICHARDSON DALLAS COUNTY, TEXAS
DEFENDANT DHC OPCO-CARROLLTON, LLC D/B/A BROOKHAVEN NURSING
AND REHABILITATION CENTER’S OBJECTION S AND RESPONSES TO
PLAINTIFF’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION OF
NGOZI OBI, L.V.N. WITH SUBPOENA DUCES TECUM
TO: Plaintiffs, Franteisha Fontenot, Darren King, Marvin Pride, and Yalonda Wright,
Individually and on behalf of the Estate of Linda Fontenot Williams, by and through their
counsel, Maria Worthington and David Benford, Worthington & Bollinger, 212 East
Virginia Street, McKinney, TX 75069.
COME NOW Defendant DHC OpCo-Carrollton, LLC d/b/a Brookhaven Nursing and
Rehabilitation Center and serve their Objections and Responses to Plaintiff’s Notice of Intention
to Take the Oral Deposition of Ngozi Obi, LVN with Subpoena Duces Tecum.
Defendant was served a Notice of Intention to take the Oral Deposition of Ngozi Obi, LVN
with Subpoena Duces Tecum on December 15, 2021. Defendant responds as follows:
1. Any and all medical records 0r other documents reviewed by you regarding
LINDA FONTENOT WILLIAMS.
Defendant objects to this Request as it is overly broad, vague, and unduly burdensome,
especially as it pertains to “other documents.” Further, Defendant objects to this Request to the
extent it is seeks information protected by attorney-client privilege or work product privilege.
DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTE‘F’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION
LVN WITH SUBPOENA DUCES TECUM — PAGE l
OF NGOZI OBI,
Subject to the foregoing objections and without waiving same, Ms. Obi reviewed portions
of the medical record of Ms. Fontenot Williams from Brookhaven Nursing and Rehabilitation
Center, already in Plaintiff’s possession. The pages Ms. Obi reviewed are Bates labeled as follow:
BROOKHAVEN 000145-151, 156-162, 165-179, 188-195, 211, 288-292, 300-306.
2. Any and all documents reviewed by you in preparation for your deposition.
Defendant objects to this Request as it is overly broad, vague, and unduly burdensome,
especially as it pertains to “any and all documents.” Further, Defendant objects to this Request to
the extent it is seeks information protected by attomey-client privilege or work product privilege.
Subject to the foregoing objections and Without waiving same, Ms. Obi reviewed portions
of the medical record of Ms. Fontenot Williams from Brookhaven Nursing and Rehabilitation
Center, already in Plaintiff‘s possession. The pages Ms. Obi reviewed are Bates labeled as follow:
BROOKHAVEN 000145-151, 156-162, 165-179, 188-195, 211, 288-292, 300-306.
3. A copy of your current CV.
Ms. Obi does not have a current resume to produce.
4. A copy of your current nursing license.
See the personnel file of Ms. Obi, LVN previously produced.
5. Any and all photographs, Polaroid or otherwise, in the possession of the
witness regarding LINDA FONTENOT WILLIAMS.
None.
6. Any and all correspondence including electronic correspondence (email);
reports and/0r memoranda between you and any third party (with the
exception of your attorney) regarding the care and treatment of LINDA
FONTEN OT WILLIAMS.
Defendant objects to this Request as it is overly broad, vague, and unduly burdensome,
especially as it pertains to “any and all correspondence.” Further, Defendant objects to this
DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTE‘F’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION
LVN WITH SUBPOENA DUCES TECUM — PAGE 2
OF NGOZI OBI,
Request to the extent it is seeks information protected by attorney-client privilege or work
product privilege.
Subject to the foregoing objections and without waiving same, none.
7. All writings in your possession or that of your attorneys reflecting any
disciplinary action taken against you by any governmental agency, licensing
or certifying agency (or equivalent body) and/or any other peer review
organization(s).
Defendant objects to this Request to the extent it seeks to violates the peer review privilege,
the medical committee privilege, and/or the hospital committee privilege afforded to this
Defendant under Texas Occupations Code, §160.001, et seq., Texas Health & Safety Code,
§l61.03l, et seq., and 42 U.S.C., §11101, et seq. Further, see Brownwood Reg ’l Hosp. v. The
Eleventh Court ofAppeals, 927 S.W.2d 24 (Tex. 1996).
Subject to the foregoing objections and without waiving same, none.
8. Any and all documentation evidencing seminars, conventions, and/or courses
at which this witness has attended that addressed the issues made the basis of
this lawsuit.
Defendant objects to this Request as it is overly broad, vague, and unduly burdensome,
especially as it pertains to “any and all documentation.”
Subject to the foregoing objections and without waiving same, see personnel file of Ms.
Obi, LVN, previously produced.
9. Any and all reports, drawings, diagrams, models, maps, and charts prepared
by or for the witness which relate to or express the findings and conclusions of
this witness regarding this case.
Defendant objects to this Request as it is overly broad, vague, and unduly burdensome,
especially as it pertains to “any and all reports, drawings, diagrams, models, maps, and charts.”
Further, Defendant objects to this Request to the extent it is seeks information protected by
DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTE‘F’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION
LVN WITH SUBPOENA DUCES TECUM — PAGE 3
OF NGOZI OBI,
attorney-client privilege or work product privilege. Still further, Defendant objects to this Request
as this Witness is a fact Witness, not an expert witness, and therefore has no findings and
conclusions.
Subject to the foregoing objections and Without waiving same, none.
10. All standards, codes and/or statues relied upon by you in formulating opinions
in this case.
Defendant objects to this Request as it is overly broad, vague, and unduly burdensome,
especially as it pertains to “all standards, codes and/or statutes.” Further, Defendant objects to this
Request as this Witness is a fact witness, not an expert witness, and therefore has not formulated
opinions in this matter.
Subject to the foregoing objections and without waiving same, none.
11. A copy of any and all scientific, technical, medical and/or other professional
publications claimed by Defendant(s) and/or this witness to be relevant to the
subject matter in this case.
Defendant objects to this Request as it is overly broad, vague, and unduly burdensome,
especially as it pertains to “any and all scientific, technical, medical and/or professional
publications.”
Subject to the foregoing objections and without waiving same, none.
12. Copies of all text messages between you and anyone, including but not limited
to, any treating healthcare provider of LINDA FONTENOT WILLIAMS or
her family (excluding your attorney), regarding your care and treatment of
LINDA FONTENOT WILLIAMS. This does not seek attorney/client
privileged information.
None.
13. Any emails, correspondence or notes from any conversation with any
individual other than your attorneys, regarding LINDA FONTENOT
WILLIAMS or regarding this matter.
DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTEF’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION
LVN WITH SUBPOENA DUCES TECUM — PAGE 4
OF NGOZI OBI,
None.
14. Any documents in your possession including emails or text messages regarding
any disciplinary action or write ups taken against you at any employment.
Defendant objects to this Request as it is overly broad, vague, and unduly burdensome,
especially as it pertains to “any and all documents.” Further, Defendant objects to this Request to
the extent it seeks to violates the peer review privilege, the medical committee privilege, and/or
the hospital committee privilege afforded to this Defendant under Texas Occupations Code,
§160.001, et seq., Texas Health & Safety Code, §161.03 1, et seq., and 42 U.S.C., §11101, et seq.
Further, see Brownwood Reg ’l Hosp. v. The Eleventh Court of Appeals, 927 S.W.2d 24 (Tex.
1996).
Subject to the foregoing objections and without waiving same, none.
15. Any text messages or emails received or sent by you regarding LINDA
FONTENOT WILLIAMS.
None.
16. A copy of any policy and procedure addressing the issues in this case, including
the accompaniment of a mobility impaired and visually impaired patient into
the examination chair.
Defendant objects to this Request as it is overly broad, vague, and unduly burdensome,
especially as it pertains to the term “any documents.” FuIther, Defendant objects to this Request,
as it is not limited in time or scope and, as worded, is seemingly seeking information that is not
relevant and not reasonably calculated to lead to the discovery of admissible evidence, as it
addresses topics completely irrelevant to this matter.
Subject to the foregoing objections and without waiving same, none.
17. Any documents indicating any training you received the issues in this case,
including the accompaniment of a mobility impaired and visually impaired
patient into the examination chair.
DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTEF’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION
LVN WITH SUBPOENA DUCES TECUM — PAGE 5
OF NGOZI OBI,
Defendant objects to this Request as it is overly broad, vague, and unduly burdensome,
especially as it pertains to the term “any documents.” Further, Defendant objects to this Request,
as it is not limited in time or scope and, as worded, is seemingly seeking information that is not
relevant and not reasonably calculated to lead to the discovery of admissible evidence, as it
addresses topics completely irrelevant to this matter.
Subject to the foregoing objections and without waiving same, none.
Respectfully submitted,
QUINTAIROS PRIETO WOOD & BOYER, P.A.
By: /s/Megan Pharis
FRANK ALVAREZ
State Bar No. 00796122
frank.alvarez@qpwblaw.com
MEGAN P. PHARIS
State Bar No. 24117991
megan.pharis@qpwblaw.com
1700 Pacific Ave, Suite 4545
Dallas, Texas 75201
Telephone: (214) 754-8755
ATTORNEYS FOR DEFENDANT
DHC OPCO-CARROLLTON, LLC DBA
BROOKHAVEN NURSING AND
REHABILITATION CENTER
DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTE‘F’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION
LVN WITH SUBPOENA DUCES TECUM — PAGE 6
OF NGOZI OBI,
CERTIFICATE OF SERVICE
The undersigned certifies that on the 27th day of January 2022, a true and correct copy of
the foregoing document was served in compliance with the Texas Rules of Civil Procedure upon
all counsel of record, as indicated below:
Maria Worrnington Arlene Wiese
David Benford Fundamental Administrative Services, LLC
Wormington & Bollinger 5700 Tennyson Parkway, Suite 300
212 East Virginia Street Plano, TX 75024
McKinney, TX 75069 Telephone: (469) 525-0300
Telephone: (972) 569-3930 Facsimile: (469) 722-6903
Facsimile: (972) 547-6440 arlene.wiese@fundltc.com
Maria@wormingtonlegal.com
David@ wormingtonlegal.com Attorney for Defendant
THI of Texas at Richardson d/b/a
Attorneys for Plaintifl The Village at Richardson
/s/ Megan P. Pharis
Megan P. Pharis
DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTE‘F’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION
LVN WITH SUBPOENA DUCES TECUM — PAGE 7
OF NGOZI OBI,
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.
Frank Alvarez on behalf of Frank Alvarez
Bar No. 00796122
frank.alvarez@qpwblaw.com
Envelope ID: 61200781
Status as of 1/27/2022 2:02 PM CST
Associated Case Party: DHC OPCO-CARROLLTON, LLC
Name BarNumber Email TimestampSubmitted Status
Frank Alvarez frank.alvarez@qpwblaw.com 1/27/2022 10:10:24 AM SENT
Megan Pharis megan.pharis@qpwblaw.com 1/27/2022 10:10:24 AM SENT
Roseann Gonzales roseann.gonzales@qpwblaw.com 1/27/2022 10:10:24 AM SENT
Associated Case Party: FRANTEISHA FONTENOT
Name BarNumber Email TimestampSubmitted Status
Maria Wormington maria@wormingtonlegal.com 1/27/2022 10:10:24 AM SENT
David Benford david@wormingtonlegal.com 1/27/2022 10:10:24 AM SENT
Associated Case Party: THl OF TEXAS AT RICHARDSON, LLC
Name BarNumber Email Timestam pSubmitted Status
Arlene Wiese arlene.wiese@fu ndltc.com 1/27/2022 10:10:24 AM SENT
Preview
FILED 1/27/2022 10:10 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Darling Tellez 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. 1 16TH JUDICIAL DISTRICT DHC OPCO-CARROLLTON, LLC d/b/a BROOKHAVEN NURSING AND REHABILITATION CENTER and THI OF TEXAS AT RICHARDSON, LLC dm/a THE VILLAGE AT RICHARDSON DALLAS COUNTY, TEXAS DEFENDANT DHC OPCO-CARROLLTON, LLC D/B/A BROOKHAVEN NURSING AND REHABILITATION CENTER’S OBJECTION S AND RESPONSES TO PLAINTIFF’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION OF NGOZI OBI, L.V.N. WITH SUBPOENA DUCES TECUM TO: Plaintiffs, Franteisha Fontenot, Darren King, Marvin Pride, and Yalonda Wright, Individually and on behalf of the Estate of Linda Fontenot Williams, by and through their counsel, Maria Worthington and David Benford, Worthington & Bollinger, 212 East Virginia Street, McKinney, TX 75069. COME NOW Defendant DHC OpCo-Carrollton, LLC d/b/a Brookhaven Nursing and Rehabilitation Center and serve their Objections and Responses to Plaintiff’s Notice of Intention to Take the Oral Deposition of Ngozi Obi, LVN with Subpoena Duces Tecum. Defendant was served a Notice of Intention to take the Oral Deposition of Ngozi Obi, LVN with Subpoena Duces Tecum on December 15, 2021. Defendant responds as follows: 1. Any and all medical records 0r other documents reviewed by you regarding LINDA FONTENOT WILLIAMS. Defendant objects to this Request as it is overly broad, vague, and unduly burdensome, especially as it pertains to “other documents.” Further, Defendant objects to this Request to the extent it is seeks information protected by attorney-client privilege or work product privilege. DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTE‘F’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION LVN WITH SUBPOENA DUCES TECUM — PAGE l OF NGOZI OBI, Subject to the foregoing objections and without waiving same, Ms. Obi reviewed portions of the medical record of Ms. Fontenot Williams from Brookhaven Nursing and Rehabilitation Center, already in Plaintiff’s possession. The pages Ms. Obi reviewed are Bates labeled as follow: BROOKHAVEN 000145-151, 156-162, 165-179, 188-195, 211, 288-292, 300-306. 2. Any and all documents reviewed by you in preparation for your deposition. Defendant objects to this Request as it is overly broad, vague, and unduly burdensome, especially as it pertains to “any and all documents.” Further, Defendant objects to this Request to the extent it is seeks information protected by attomey-client privilege or work product privilege. Subject to the foregoing objections and Without waiving same, Ms. Obi reviewed portions of the medical record of Ms. Fontenot Williams from Brookhaven Nursing and Rehabilitation Center, already in Plaintiff‘s possession. The pages Ms. Obi reviewed are Bates labeled as follow: BROOKHAVEN 000145-151, 156-162, 165-179, 188-195, 211, 288-292, 300-306. 3. A copy of your current CV. Ms. Obi does not have a current resume to produce. 4. A copy of your current nursing license. See the personnel file of Ms. Obi, LVN previously produced. 5. Any and all photographs, Polaroid or otherwise, in the possession of the witness regarding LINDA FONTENOT WILLIAMS. None. 6. Any and all correspondence including electronic correspondence (email); reports and/0r memoranda between you and any third party (with the exception of your attorney) regarding the care and treatment of LINDA FONTEN OT WILLIAMS. Defendant objects to this Request as it is overly broad, vague, and unduly burdensome, especially as it pertains to “any and all correspondence.” Further, Defendant objects to this DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTE‘F’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION LVN WITH SUBPOENA DUCES TECUM — PAGE 2 OF NGOZI OBI, Request to the extent it is seeks information protected by attorney-client privilege or work product privilege. Subject to the foregoing objections and without waiving same, none. 7. All writings in your possession or that of your attorneys reflecting any disciplinary action taken against you by any governmental agency, licensing or certifying agency (or equivalent body) and/or any other peer review organization(s). Defendant objects to this Request to the extent it seeks to violates the peer review privilege, the medical committee privilege, and/or the hospital committee privilege afforded to this Defendant under Texas Occupations Code, §160.001, et seq., Texas Health & Safety Code, §l61.03l, et seq., and 42 U.S.C., §11101, et seq. Further, see Brownwood Reg ’l Hosp. v. The Eleventh Court ofAppeals, 927 S.W.2d 24 (Tex. 1996). Subject to the foregoing objections and without waiving same, none. 8. Any and all documentation evidencing seminars, conventions, and/or courses at which this witness has attended that addressed the issues made the basis of this lawsuit. Defendant objects to this Request as it is overly broad, vague, and unduly burdensome, especially as it pertains to “any and all documentation.” Subject to the foregoing objections and without waiving same, see personnel file of Ms. Obi, LVN, previously produced. 9. Any and all reports, drawings, diagrams, models, maps, and charts prepared by or for the witness which relate to or express the findings and conclusions of this witness regarding this case. Defendant objects to this Request as it is overly broad, vague, and unduly burdensome, especially as it pertains to “any and all reports, drawings, diagrams, models, maps, and charts.” Further, Defendant objects to this Request to the extent it is seeks information protected by DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTE‘F’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION LVN WITH SUBPOENA DUCES TECUM — PAGE 3 OF NGOZI OBI, attorney-client privilege or work product privilege. Still further, Defendant objects to this Request as this Witness is a fact Witness, not an expert witness, and therefore has no findings and conclusions. Subject to the foregoing objections and Without waiving same, none. 10. All standards, codes and/or statues relied upon by you in formulating opinions in this case. Defendant objects to this Request as it is overly broad, vague, and unduly burdensome, especially as it pertains to “all standards, codes and/or statutes.” Further, Defendant objects to this Request as this Witness is a fact witness, not an expert witness, and therefore has not formulated opinions in this matter. Subject to the foregoing objections and without waiving same, none. 11. A copy of any and all scientific, technical, medical and/or other professional publications claimed by Defendant(s) and/or this witness to be relevant to the subject matter in this case. Defendant objects to this Request as it is overly broad, vague, and unduly burdensome, especially as it pertains to “any and all scientific, technical, medical and/or professional publications.” Subject to the foregoing objections and without waiving same, none. 12. Copies of all text messages between you and anyone, including but not limited to, any treating healthcare provider of LINDA FONTENOT WILLIAMS or her family (excluding your attorney), regarding your care and treatment of LINDA FONTENOT WILLIAMS. This does not seek attorney/client privileged information. None. 13. Any emails, correspondence or notes from any conversation with any individual other than your attorneys, regarding LINDA FONTENOT WILLIAMS or regarding this matter. DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTEF’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION LVN WITH SUBPOENA DUCES TECUM — PAGE 4 OF NGOZI OBI, None. 14. Any documents in your possession including emails or text messages regarding any disciplinary action or write ups taken against you at any employment. Defendant objects to this Request as it is overly broad, vague, and unduly burdensome, especially as it pertains to “any and all documents.” Further, Defendant objects to this Request to the extent it seeks to violates the peer review privilege, the medical committee privilege, and/or the hospital committee privilege afforded to this Defendant under Texas Occupations Code, §160.001, et seq., Texas Health & Safety Code, §161.03 1, et seq., and 42 U.S.C., §11101, et seq. Further, see Brownwood Reg ’l Hosp. v. The Eleventh Court of Appeals, 927 S.W.2d 24 (Tex. 1996). Subject to the foregoing objections and without waiving same, none. 15. Any text messages or emails received or sent by you regarding LINDA FONTENOT WILLIAMS. None. 16. A copy of any policy and procedure addressing the issues in this case, including the accompaniment of a mobility impaired and visually impaired patient into the examination chair. Defendant objects to this Request as it is overly broad, vague, and unduly burdensome, especially as it pertains to the term “any documents.” FuIther, Defendant objects to this Request, as it is not limited in time or scope and, as worded, is seemingly seeking information that is not relevant and not reasonably calculated to lead to the discovery of admissible evidence, as it addresses topics completely irrelevant to this matter. Subject to the foregoing objections and without waiving same, none. 17. Any documents indicating any training you received the issues in this case, including the accompaniment of a mobility impaired and visually impaired patient into the examination chair. DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTEF’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION LVN WITH SUBPOENA DUCES TECUM — PAGE 5 OF NGOZI OBI, Defendant objects to this Request as it is overly broad, vague, and unduly burdensome, especially as it pertains to the term “any documents.” Further, Defendant objects to this Request, as it is not limited in time or scope and, as worded, is seemingly seeking information that is not relevant and not reasonably calculated to lead to the discovery of admissible evidence, as it addresses topics completely irrelevant to this matter. Subject to the foregoing objections and without waiving same, none. Respectfully submitted, QUINTAIROS PRIETO WOOD & BOYER, P.A. By: /s/Megan Pharis FRANK ALVAREZ State Bar No. 00796122 frank.alvarez@qpwblaw.com MEGAN P. PHARIS State Bar No. 24117991 megan.pharis@qpwblaw.com 1700 Pacific Ave, Suite 4545 Dallas, Texas 75201 Telephone: (214) 754-8755 ATTORNEYS FOR DEFENDANT DHC OPCO-CARROLLTON, LLC DBA BROOKHAVEN NURSING AND REHABILITATION CENTER DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTE‘F’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION LVN WITH SUBPOENA DUCES TECUM — PAGE 6 OF NGOZI OBI, CERTIFICATE OF SERVICE The undersigned certifies that on the 27th day of January 2022, a true and correct copy of the foregoing document was served in compliance with the Texas Rules of Civil Procedure upon all counsel of record, as indicated below: Maria Worrnington Arlene Wiese David Benford Fundamental Administrative Services, LLC Wormington & Bollinger 5700 Tennyson Parkway, Suite 300 212 East Virginia Street Plano, TX 75024 McKinney, TX 75069 Telephone: (469) 525-0300 Telephone: (972) 569-3930 Facsimile: (469) 722-6903 Facsimile: (972) 547-6440 arlene.wiese@fundltc.com Maria@wormingtonlegal.com David@ wormingtonlegal.com Attorney for Defendant THI of Texas at Richardson d/b/a Attorneys for Plaintifl The Village at Richardson /s/ Megan P. Pharis Megan P. Pharis DEFENDANT’S OBJECTIONS AND RESPONSES TO PLAINTE‘F’S NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION LVN WITH SUBPOENA DUCES TECUM — PAGE 7 OF NGOZI OBI, 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. Frank Alvarez on behalf of Frank Alvarez Bar No. 00796122 frank.alvarez@qpwblaw.com Envelope ID: 61200781 Status as of 1/27/2022 2:02 PM CST Associated Case Party: DHC OPCO-CARROLLTON, LLC Name BarNumber Email TimestampSubmitted Status Frank Alvarez frank.alvarez@qpwblaw.com 1/27/2022 10:10:24 AM SENT Megan Pharis megan.pharis@qpwblaw.com 1/27/2022 10:10:24 AM SENT Roseann Gonzales roseann.gonzales@qpwblaw.com 1/27/2022 10:10:24 AM SENT Associated Case Party: FRANTEISHA FONTENOT Name BarNumber Email TimestampSubmitted Status Maria Wormington maria@wormingtonlegal.com 1/27/2022 10:10:24 AM SENT David Benford david@wormingtonlegal.com 1/27/2022 10:10:24 AM SENT Associated Case Party: THl OF TEXAS AT RICHARDSON, LLC Name BarNumber Email Timestam pSubmitted Status Arlene Wiese arlene.wiese@fu ndltc.com 1/27/2022 10:10:24 AM SENT