Preview
Filed
7/8/2021 11:56 PM
Beverley McGrew Walker
RR District Clerk
Fort Bend County, Texas
Ashley Alaniz
CAUSE NO. 21-DCV-281435
DR. JAN LIGHTFOOT, aka IN THE DISTRICT COURT OF
JAN CHRISTOPHER
VERSUS FORT BEND COUNTY, TEXAS
OAKBEND MEDICAL CENTER,
COURTNEY LANDRY, M.D., et al 45874 JUDICIAL DISTRICT
Plaintiff's Motion for Leave to File Late Exhibits to the Plaintiff's Responses to the Second
Motions to Dismiss and for Summary Judgment filed by Defendants Woodham and
Greater Houston Psychiatric Associate:
TO: Defendants ROBERT WOODHAM, M.D. and GREATER HOUSTON PSYCHIATRIC
ASSOCIATES, P.L.L.C. by and through his attorney of record, Noah Meek, Cardwell &
Chang, P.L.L.C., 511 Lovett Boulevard, Houston, Texas 77006, via email:
meek@cardwellchang.com
YOUR HONOR:
The Plaintiff respectfully asks this Court to grant her leave to file late Exhibits. On 6 July
2021, the Plaintiff had timely filed her Responses to the Second Motions filed by Defendants
Woodham and Greater Houston Psychiatric Associates, but failed to attach the attached Exhibits.
Granting such leave would be proper because there is good cause and because there would
be no undue prejudice.
Introduction
1 The Plaintiff filed this lawsuit on 9 March 2021. This lawsuit is only four (4) months old. The
Defendants, however, are attempting to require the Plaintiff to prove her case -- even before
discovery has been conducted. Expert Reports are not due until next month.
The Plaintiff seeks to recover damages resulting from her false imprisonment and illegal
mental health commitment, and from the medical malpractice perpetrated by certain
Defendants, including Dr. Woodham.
The Court has set a hearing on 13 July 2021 at 1:30 p.m. on the Second Motions to Dismiss
and for Summary Judgment filed by Defendants Woodham and GHPA.
4. The Plaintiff had filed her Responses, but without Exhibits, on 6 July 2021.
Authorities and Argument
5. A nonmovant must file and serve her Response and affidavits at least seven days before the
hearing. TEX. R. CIV. P. 166a(c).
The Texas Supreme Court has promulgated that granting leave to file a late response (or
exhibits thereto) is proper if: (1) there is good cause; and (2) there would be undue prejudice.
Wheeler v. Green, 157 8.W.3d 439, 442 (Tex. 2005); see also, Carpenter v. Hydrocarbons, 98
S.W.3d 682,687-688 (holding that the standard for granting leave to file a late response is the
same as the standard for withdrawing deemed admissions).
“Good cause” is established with sworn proof that the nonmovant’s failed to timely respond
(or timely file exhibits thereto) was not intentional or the result of conscious indifference, but
rather, was the result of an accident or mistake. See, Wheeler, 157 S.W.3d at 442. Attached as
EXHIBIT A and incorporated by reference herein is the Affidavit of the Plaintiff's attorney to
establish good cause.
As the Texas Supreme Court announced in Carpenter, 98 S.W.3d at 687-688, the standard for
granting leave to file a late response (or exhibits thereto) is the same as the standard for
withdrawing deemed admissions. The party must state good cause, explaining why it did not
timely serve its responses to the requests for admission. TEX. R. CIV. P 198.3(a); Wheeler,
157 8.W.3d at 442; Wal-Mart Stores v. Deggs, 968 S.W.2d 354, 356 (Tex. 1998). Good cause
can be accident or mistake, as long as it was not intentional or the result of conscious
indifference. Marino v. King, 355 S.W.3d 629, 633 (Tex. 2011); Wheeler, 157 S.W.3d at 442;
e.g., Boulet v. State, 189 $.W.3d 833, 837 (Tex. App. — Houston [1* Dist.] 2006, no pet.)
(holding that a mistake in calendar entry was sufficient to establish good cause). Even a slight
excuse can be enough to establish good cause. Boulet, 189 S.W.3d at 836; In re Kellogg-
Brown & Root,45 §.W.3d 772, 775 (Tex. App. — Tyler 2001, orig. proceeding).
EXHIBIT A confirms the Plaintiffs failure to attach the now attached Exhibits to her
Responses, which it had timely filed on 6 July 2021, was by accident or mistake, and certainly
was not intentional or the result of conscious indifference, and that receiving those Exhibits
would not unduly delay or otherwise injure Defendants Woodham and GHPA.
PRAYER
For these compelling reasons, the Plaintiff respectfully asks this Court to GRANT her Motion for
Leave, and consider the attached Exhibits as timely filed for the hearing on 13 July 2021.
Respectfully submitted,
AQRAWI & ASSSOCIATES, P.L.L.C,
s/s G.N. Lawrence
GN. Lawrence
2
SBOT 12046250
Walat Aqrawi
SBOT 24094515
A.G. Aiken
SBOT 24094514
3033 Chimney Rock Road, Suite 300
Houston, Texas 77056-6257
Telephone: (832) 834-6099
Facsimile: (281) 605-6805
g.lawrence@aqrawilaw.com
ATTORNEYS FOR THE PLAINTIFF
CERTIFICATE OF SERVICE
In compliance with Rules 21a and 21(f(2) of the Texas Rules of Civil Procedure, I hereby
affirm I served a true and correct copy of the foregoing Plaintiff's Motion for Leave to file late
exhibits on the following counsel of record at their email addresses on this 8" day of July 2021:
SERVICE List
John Shepperd Michael Blaise
Christina Huston Lorance Thompson, P.C,
‘Wilson, Elser, Moskowitz, Edelman & 2900 North Loop West, Ste. 500
Dicker LLP Houston, Texas 77092
909 Fannin, Ste. 3300 Tele: (713) 868-5560
Houston, Texas 77010 Fax: (713)864-4671
Tele: (713) 353-2000 mwb@lorancethompson.com
Fax: (713) 785-7780 Attorney for Defendant
John.shepperd@wilsonelser.com Matt Brams
Attorney for Defendants
Courtney Landry, MD and
Rose-Rich EM Physicians, PA
Mark E. Callender Donald S. Stephens
Brett R. Sheneman Stephens & Associates
Benjamin E. Hamel 7930 W. Broadway, Ste. 110
Serpe, Jones, Andrews, Callender & Bell, Pearland, Texas 77581
PLLC Tele: (281) 978-4540
America Tower Fax: (281) 978-4541
2929 Allen Parkway, Ste. 1600 dss@d. hhenslaw.com
Houston, Texas 77019 Attorney of Defendants
Tele: (713) 452-4400 Owen Capocyan, MD and
Fax: (713) 452-4499 Oak Bend Medical Group
meallender@serpejones.com
bsheneman@s ejones.com
bhamel@se: jones.com
Attorney for Defendant
Oakbend Medical Center
Kevin Hedges Suzan Cardwell
Assistant County Attorney Noah Meek
Bridgette Smith-Lawson Cardwell & Chang, PLLC
Fort Bend County Attorney 511 Lovett Blvd.
401 Jackson, 3" Floor Houston, Texas 77006
Richmond, Texas 77469 Tele: (713) 222-6025
Tele: (281) 341-4555 Fax: (713) 222-0938
Fax: (281) 341-4557 cardwell@cardwellchang.com
Kevin. hedges@fortbendcountytx.gov meek@cardwellchang.com
Attorney for Defendants Attorney for Defendants
Fort Bend County Sheriff's Office, Robert Woodham, MD and
Marisa Salas Greater Houston Psychiatric Associates,
PLLC
James B. Edwards
Stacy T. Garcia
Edwards & Garcia
12603 Southwest Freeway, Ste. 200
Stafford, Texas 77477-3809
Tele: (281) 277-4940
Fax: (281) 277-4974
aas(@malpracticedefense.com
ecp(@malpracticedefense.com
e-service@malpracticedefense.com
jbe@malpracticedefense.com
tg@malpracticedefense.com
Attorney for Defendant
Jorge A. Raichman, MD
/s/ G. N. Lawrence
Exhibit
CAUSE 21-DCV-281435
Jan Lightfoot In the District Court of
versus Fort Bend County, Texas
Oak Bend Medical Center, ef al 458" District
AFFIDAVIT OF JAN LIGHTFOOT
State of Texas
County of Harris
Before me, the undersigned Notary in and for the State of Texas, personally appeared Jan
Lightfoot (the “Affiant”) , a person known to me or who showed me her Texas Driver's License
bearing a photograph of herself, After I administered the oathto her, the Affiant testified:
“1, _My.name is Jan Lightfoot. I am over 18 years of age, of sound mind, have never. been convicted.
of committing any crime of moral turpitude, and am capable of making this affidavit. The statements
made in this Affidavit are true and correct, and are within my personal knowledge.
2 Tam a licensed mental health counselor with over 38 years of licensure tenure. I am licensed
as a LCSW Social Worker Emeritus and LPC: Licensed Professional Counselor with psychological
testing authority, I have over 50 years of credible work experience in my fields of study. My past
work experiences include working at Bexar County MHMR, San Antonio College, West Paces Ferry
Hospital in Atlanta Georgia, the Veteran's Administration in Houston, Texas, and the Wholeness
Foundation, an entity of Vine Dweller Ministries, INC—-the charity wherein I presently serve. Tam
ordained under the ecclesiastical authority of Cornerstone Community of Faith Ministries, Dr. B.
Wesley Austin, Jr, CPE Clinical Supervisor and Pastoral Care—a cooperative program of the
Southern Baptist Church,
3 The only mental illness I suffered from since 24 December 2018 to present has been severe
depression, or MDD and PTSD due to childhood and workplace traumas, I have never been properly
diagnosed with bipolar disorder or psychosis and these diagnoses have been ruled out. Attached as
EXHIBIT A is a letter and medical report from my current healthcare professional at UTMB on my
mental condition. Ii is a true and correct copy of the actual letter. Also attached are EXHIBIT B and
EXHIBIT C, EXHIBIT B is true and correct copy of the actual letter from psychiatrist Dr. Xu.
EXHIBIT C is a true and correct copy of the actual letter from my psychologist, Dr. Vietor N. Hirsch.
4 As of 24 December 2018, Dr. Robert L, Woodham, MD had been my psychiatrist for over nine
(9) years, beginning on 24 April 2009. He managed my medication for the work-related injury I had
sustained on 15 July 1989. The Department of Labor had accepted that injury as a mental health
condition—Major Depression Disorder (MDD).
5 I continued to see Dr. Weodham during 2018. He had scheduled me for an appointment on 27
December 2018,
Page
1 of 3
6. On 24 December 2018, I had made seven (7) distress calls to him, because he was my
psychiatrist, | made those seven distress calis from 0900 hours through 1700 hours — before 1 was
illegally and involuntarily committed to Oak Bend Medical Center.
7 On 6 February 2019, I discharged Dr. Woodham as my psychiatrist.
8 While | was a patient of Dr. Woodham’s, he had the name and telephone number of my
emergency contact, Ms. Velma McCoy.
9. On 30 July 2019, Gerry, a member of the Greater Houston Psychiatric Associates, P.L.L.C.
(“GHPA”), had called Ms. McCoy not once, but twice, requesting the name and phone number of
my closest living relative about my ability to take care of myself and my safety.
10. Why Dr. Woodham would have a GHPA employee call my emergency contact Ms. McCoy
was very suspicious to me, because there was no emergency, the question of me taking care of myself
never surfaced, and because he had not seen me in over six (6) months. Ifhe were genuinely concerned
about my well-being, he could have called me directly, or called Dr. Hirsh, my treating psychologist,
whose contact information is in his notes.
8. After Ms. McCoy had told me she had received those two calls from GHPA, I filed a Police
Report with the Houston Police Department, whose investigating officer concluded the calls were
forgery/fraud, and it should not have contacted Ms. McCoy regarding my medical care, because Lam.
a competent person in charge of my own medical care.
9. Until I had discharged him on 6 February 2019, Dr. Woodham had misdiagnosed me. He never
did his own assessment of me, but instead merely continued the diagnoses and treatment plan of Dr.
Rahn K. Bailey, my former psychiatrist who was a specialist in Dissociative Identity Disorder
(“DID”), Post Traumatic Stress Disorder, and Trauma. Dr. Bailey had diagnosed me with DID. DID
is not a delusional disorder, and is not Schizophrenia; instead, it is a brain’s defense mechanism
resulting from my childhood trauma and work-related injury. Dr. Woodham did not provide any
medication for that diagnosis, because it does not respond to medication. Both Dr. Hirsh, the
psychologist, and Dr. X, the psychiatrist whom I had hired to replace Dr. Woodham, disagreed with
Dr. Woodham’s diagnoses and choice of medications.
10. Dr. Woodham made false statements to Adult Protective Services in July 2019. I had informed
him on 14 January 2019 that my Baylor doctor had tapered me off Lamictal and I was therefore no
longer taking it. Instead of reporting the results of his notes from my last office visit on 6 February
2019, he reported to Adult Protective Services that I was off my medications, was a gun threat, and
needed either guardship or involuntary commitment — even though he had not seen me for over six
(6) months,
il. In April 2021, Dr. Woodham finally provided his records to me, but the records he had provided
do not in fact match the records he had provided to the Department of Labor ECOMP files pertaining
to my work-related injury. He therefore produced two (2) different set of records.
Page 2 of 3
12. On 8 April 2021, Dr. Woodham produced a fabricated telephone message dated 12/26/2018.
That telephone message is not a part of the original or scanned records into the Department of Labor's
ECOMP files nor in the original and scanned record in my possession. This document is labeled as
Exhibit E in Defendant’s TCPA Motion to Dismiss and Motion for Summary Judgement. The
telephone message is fabricated because it alleges, 1 had called Dr. Vernon Walling of GHPA on 26
December 2018, to merely tell Dr. Woodham that I was staying at Oak Bend Medical Center. I did
not make any such a call on 26 December 2018. What's more, nowhere in Dr. Woodham’s notes did
he report my seven distress calls on 24 December 2018 — before I was illegally and involuntarily
committed in Oak Bend Medical Center.”
Jafy Lightfoot
SWORN TO AND SUBSCRIBED IN MY PRESENCE on th day of July 2021.
wi i, LEZANNE DENNIS Ay
i
Lh anne
223 Reblic in and for the State of Texas
|
Notary Public, State of Te:
Comm. Expires 08-05-2024
ae et Notary 1D 129074758
Commission expires on g [5 of
Page 3 of 3
Exhibit
Health = myChart
Name: Jan Christopher | DOB: 3/6/1951 | MRN: 592883N | PCP: Madhumita Banga, MD
Letter Details
Wane Health
June 23, 2021
To Whom It May Concern:
RE; Jan Christopher
12319 Chesterbrook Dr
Houston TX 77031
The person named above is my patient at the UTMB Primary Care Clinic in Webster, TX and has been
treated at UTMB since 2016,
She has been diagnosed with Major Depressive Disorder [ MDD ] and this condition is stable,
MDD Is a disabling condition that prevents Ms Christopher from performing gainful work but she is able to
engage in productive activities at her own pace as long as her disabilities are accommodated. She does not
have any cognitive defects, paranoia, hallucinations, organic conditions, delusions, or threatening behavior.
She does not have Schizophrenia as per her records and my Clinical assessment, nor any behavioral
disturbance or character flaws,
There Is no record to substantiate that she Is self-neglecting, unable to care for herself, a danger to herself or
others, needs guardianship, involuntary commitment or Nursing Home placement. She is independent and
has continuously been discharged to self-care.
Her Medical condition is also stable at this time [ see recent Medical evaluation notes J, and she Is motivated
for treatment, and responsibly manages her care.
As her Primary Care Provider, | certify this to be a true statement, and Invite you to please contact our Office
if you have any questions.
Sincerely,
Cy
Madhumita Banga, MD
UTMB Health Adult Primary Care- Webster
Christopher, Jan MRN: 592883N
Banga, Madhumita, MD Progress Notes Encounter Date: 6/24/2021
STAFF Signed
Specialty: FM-FAMILY MEDICINE
Ce:
Chief Complaint
Patient presents with
* Follow-up
Jan Christopher is a 70 year old femate.
She is here today for a follow up visit and to get her Chart updated.
Her Behavioral Heaith conditions are stable currently with Sertraline, taking medications for
panic attacks prn ( Alprazolam ). She is getting psychotherapy and neurotherapy for this, does
not use Alprazolam unless needed as a last resort.
She was diagnosed with DID ( dissociative Identity Disorder ) which was treated with therapy
successfully and she has no symptoms now.
Medications
Outpatient Medications Prior to Visit
Medication Si Dispense Refill
* QUEtiapine 25 mg tablet Take 1 tablet by mouth 30 tablet 4
at bedtime. For sleep
+ meloxicam 15 mg tablet Take 1 tabletby
mouth.
+ SERTraline 100 mg tablet Take 1 tablet by mouth
daily.
+ losartan-hydrochlorothiazide 100- Take 1 tablet by mouth 90 tablet
25 mg per tablet ily.
* famotidine 40 mg tablet Take 1 tablet by mouth 90 tablet
daily.
* fluticasone propionate 50 Use 2 Sprays in each 16g
meg/actuation nasal spray nostril 2 (two) times
laily.
* ketorolac 10 mg tablet Take 1 tabletby mouth 10 tablet
every 8 (eight) hours
as needed for Pain
(scale 4-6).
+ dicyclomine 10 mg capsule Take 1 capsule by 30 capsule
mouth 3 (three) times
daily as needed for
Abdominal pain.
* topiramate 50 mg tablet Take 1 tablet by mouth 60 tablet
2 (two) times daily.
* zolpidem 10 mg tablet Take 0.5 tablets by 30 tablet
mouth at bedtime as
needed for Insomnia.
» methocarbamoL (ROBAXIN) 500 Take1 tabletby mouth 30 tablet
mg tablet 4 (four) times daily.
+ albuterol 1.25 mg/3 mL nebulizer Inhale 3 mL every 6 3mt
solution (six) hours as needed
for Wheezing,
Shortness of Breath or
Chast tightness.
+ levocetirizine 5 mg tablet Take 1 tablet by mouth 90 tablet
every evening.
* montelukast 70 mg fablet Take 1 tablet by mouth 90 tablet
daily.
+ butalbital-acetaminophen-caff 50- Take 1 tablet by mouth 30 tablet
325-40 mg tablet every 6 (six) hours as
needed for Other
(headache).
* mupirocin 2 % ointment Apply to area(s) 3 229
(three) times daily.
* celecoxib 100 mg capsule Take 1 capsule by 60 capsule
mouth 2 (two) times
daily with meals.
« latanoprost 0.005 % ophthalmic Place 1 Drop in both 2.5 mL
drops. eyes every evening.
+ Polyethylene Glycol 3350 Take 1 Packet by 14 Packet
(MIRALAX) 17 gram powder mouth daily.
* sucralfate 100 mg/mL suspension Take 10 mL by mouth 420 mL
before’ meals and-at-
bedtime.
+ QUEtiapine 25 mg tablet Take 1 tablet by mouth 30 tablet
at bedtime.
+ lovastatin 20 mg tablet Take 1 tablet by mouth 90 tablet
at bedtime.
* Polyethylene Glycol 3350 17 gram Take 17 g by mouth.
powder
* BLUE-GREEN ALGAE, Take by mouth.
SPIRULINA, ORAL
+ butterbur root extract Take by mouth.
(PETADOLEX ORAL)
* TURMERIC ORAL Take by mouth.
« nitroglycerin 0.3 mg sublingual Place 0.3 mg under the
tablet tongue every 5 (five)
minutes as needed for
Chest pain (take every
5 minutes times 3).
Indications: chest pain
+ diphenhydrAMINE (BENADRYL) Take 50 mg by mouth
25 mg capsule at bedtime as needed
for Allergies.
+ linaclotide (LINZESS) 72 meg Cap Take 7 capsule by
mouth daily.
* albuterol (VENTOLIN) 90 Inhale 2 Puffs every 6
mcg/actuation inhaler (six) hours as needed
for Wheezing or
Shortness of Breath.
No facility-administered medications prior to visit.
Review of Systems
Psychiatric/Behavioral: Positive for sleep disturbance. Negative for agitation, behavioral
problems, confusion, decreased concentration, dysphoric mood, hailucinations, self-injury and
suicidal ideas. The patient is not nervous/anxious.
Vital Signs
BP 139/83 | Pulse 66 | Temp 36.4 °C (97.5 °F) | Resp 16 | Ht5' 9" (1.753 m) | Wt 198 Ib
(89.8 kg) | SpO2 99% | BMI 29.24 kg/m?
Physical Exam
Pulmonary:
Effort: Pulmonary effort is normal.
Neurological:
General: No focal deficit present.
Mental Status: She is alert.
Psychiatric:
Mood and Affect: Mood normal.
Thought Content: Thought content normal.
Judgment: Judgment normal.
Assessment/Plan
Jan was seen today for follow-up.
Diagnoses and all orders for this visit:
insomnia, unspecified type
Comments:
Chronic
Stable, taking Quetiapine and also Melatonin
Continue same, take Ambien prn if these do not help
Episode of recurrent major depressive disorder, unspecified depression episode severity
Comments:
Chronic
Stable at this time.
Continue Sertraline.
Anxiety
Comments:
Chronic
Stable, having some panic attacks sometimes.
Seeing Dr. Hirsch, Psychologist, getting Therapy which helps.
Continue Xanax pm
Dissociative identity disorder
I
Co!
Past diagnosis, resolved
Stable, with Therapy.
No medications indicated for this.
She is not having any symptoms.
{ spent a total of 30 minutes on the day of the visit.
The time spent for patient care includes:
Performing a medically appropriate examination and/or evaluation, Counseling and educating
the patient/family/caregiver, Documenting clinical information in the electronic or other health
record and Care coardination (not separately reported).
Office Visit on Note viewed by patient
6/24/2021
17448 Highway 3, 2nd Floor
Webster TX 77598-4187
Dept: 832-505-1748
Dept Fax: 281-333-2772
This letter was initially viewed by Jan Christopher at 6/23/2021 10:51 PM,
MyChart® licensed from Epic Systems Corporation © 1999 - 2020
Exhibit
Whole Health PLLC
Huiping Xu M.D. M.S Psychiatry
Address; 6100 Corporate Dr Suite 238# Houston TX 77036
T 7139994111 | F 866 666 7216 | email: drxu@houston-psychiatrist.com
04/25/19
To whom it may concern
Janice Christopher iDig0210900 DOI 06/15/1989
Jan Christopher is a patient of since mine 04/24/2019. She is currently being
treated for the occupational illness under OWCP F33.9 Major Depressive disorder.
We will continue medication management as needed. We have prescribed the
following medications
Topriamate 50 mg {one tablet po BID)
Seroquel 25mg (one tablet po ghs)
Ambien 10mg (one tablet po ghs)
Please feel free to give us a call if you have any additional questions.
Huiping Xu M.D
Lae a
Whole Health PLLC
Huiping Xu M.D. M.S Psychiatry
Address: 6100 Corporate Dr Suite 238# Houston TX 77036
7 7139994111 | F 866 666 7216 | email: drxu@houston-psychiatrist.com
May 28, 2019
RE: Janice Christopher (No. 16-0210900)
Date of injury: 6/15/1989
U.S. DOL/OWCP
DFEC CENTRAL MAILROOM ~ 16
P.O. Box 8300
LONDON, KENTUCKY 40742
Attn: Ms. Kim H.
To Whom it May Concern:
Tam writing this letter on behalf of Ms. Janice Christopher who is a 68-year-old, divorced,
Black American, female who has been under my care since April 24, 2019 when I first examined
her on April 24, 2019 and on May 28, 2019. 1 sent a letter to your office dated April 25, 2019
advising you that I am the treating psychiatrist for her occupational illness. Our examination and
review of Ms. Christopher's record indicates that she has been in Psychiatric Care for this work-
related condition since 1989 and she continues in treatment to the present time. According to my
examination and of her medical and DOL/OWCP records, Ms. Christopher has been disabled from
engaging in her regular work since her medical retirement from her VA job in 1992 due to above
referenced work injury. I concur that the patient remains disabled from her regular work due to her
work-related injury. Relative to the causal relationship between her present condition and the
original injury, per the DOL Ruling dated Nov. 28, 1994, “the employment aggravated,
accelerated, or combined with the condition to produce the disability, expressed as the employer
takes the employee as he find him; thus the entire disability is compensable and no attempt is to
made to weight the relative contribution of the accident to the preexisting condition to the final
lof2
disability or death," (See Ruling Attached). Thus, since the predisposing conditions
and the work-
injury are inseparable, her accepted conditions are and will remain related to her work
injury.
TREATMENT PLAN: ! concur with the DOL accepted condition for her Axis | Diagnosi
s of Major
Depression, Recurrent (F33.9). She is also diagnosed with Anxiety, PTSD and Gastritis
related to her
Occupational iliness. Her physicians will treat her Gastritis and she will continue with Psychoth
erapy with
her Psychologist. Medication Management: Medications include: Zolpidern 10mg PO QHS;
Seroquel 25mg
PO QHS; Topiramate 50 PO BID; Lorazepam 0.5mg BID PRN. Recent events have aggrava
ted
the conditions
of her work-related injury and caused a setback in her ability to return to work. Present symptom
s include
depression, anxiety, insomnia, gastro distress, headaches, syncopal episodes, and panic attacks.
Therefore, at this time, she cannot engage in her regular work due to the residual effects
of her
occupational injury due to the medical conditions for which she was medically retired. Her
ability to
engage in other gainful work must be evaluated. Ms. Christopher's period of disability
from her regular
work is from 4/27/92 thru the present date and medical records of her treatmen
t for this work-related
condition date back to 1989 to the present date.
if you would kindly assist Ms. Christopher with any eligible benefit, it would greatly help her
to
improve her condition and the quality of life. Please. contact_our. office if.you have. questions or need
further information. Thank you for assisting this patient.
Sincerely,
Dr. Huiping XU, M.D
J 2—
~
20f2
Wt
Huiping i4 V 3 + ft
Address: 6100 Corporate Dr Suite 238# Houston TX 77036
T 7139994111 | F 866 666 7216 | email: drxu@houston-psychiatrist.com
August 7, 2020
To Whom It May Concern:
Janice Christopher 1D160210900 DO! 06/15/1989
Janice Christopher is a patient of mine since 4-24-2019. | am the treating psychiatrist for
her occupational illness. This letter supplements previous correspondence dated May 28,
2019, April 25, 2019, and March 10, 2020, to update this patient's medication regimen and
to clarify her work status, Our office is treating her accepted condition, Major Depressive
Disorder (F33.9), and related/residuai conditions. These conditions are: Anxiety, PTSD,
and Gastritis. She is seen by a Clinical Psychologist, Dr. Victor Hirsch, PhD, for her
Depression and PTSD and by her PCP, Dr. Madhumita Banga, MD, for her Gastritis.
Regarding her work status, she has been out of work for 30 years medically retired.
Therefore, | agree with her Chaplaincy Supervisor, PCP, and Psychologist that Ms.
Christopher may be capable of doing light duty up to "10 hours per week as tolerated as
long as her disability is accommodated.” However, this does not allow her to engage in
doing Social Work, which would be too stressful. She loves doing chaplain work and plays
music and teaches lessons at church on Sundays. Still, she remains medically disabled
due to residuals of her work injury, has not demonstrated the capacity to engage in her
regular work, and cannot return to full-time or gainful work as reported on 3/10/20. Any
assistance you can give with any eligible benefits would improve the quality of her life. We
have prescribed the following medications: Topiramate 50 mg (one tablet po BID);
Seroquel 25 mg ( one table po QHS); Ambien 10mg (one tablet po QHS); Wellbutrin XL
180mg qdaily). Please feel free to give us a call if you have any additional questions.
Huiping Xu, MD, Psychiatrist
aS
u =
Exhibit
Victor N. Hirsch, PhD, Clinical Psychologist
Hirsch & Associates
1025 E, Main St, Suite 100
League City, TX. 77573
vhofficemanager@yahoo,com
281-332-3852
U, 8, DEPARTMENT OF LABOR
OFFICE OF WORKER’ COMPENSATION PROGRAMS
P. O. BOX 8300 DISTRICT 16 DAL
LONDON, KY 40742-8300
March 27, 2020
Re: Jan Christopher, Janice B. Christopher
a.k.a. Jan Lightfoot (Maiden Name)
OWCP#: 160210900
OPM#; CSA80280570
Second Opinion Evaluation
Request for Reasonable
Ascommodations/Modifications
To Whom It May Concern:
This letter responds a second opinion appointment made for a work-related condition for the
above referenced employes to request reasonable accommodations for medical reasons to
prevent abroactions and retraumatization of this employes who is my patient and has been under
my care since June 2014, I provide Psychotherapy treatment to Ms, Christopher for her work-
related mental health condition, she receives Medication Maintenance from hor Psychiatrist who
concurs with these diagnoses, and she reccives treatment for Gastritis from her PCP, Her
conditions are related to traumatic childhood and lace traumas, She meets diagnostic
criteria for Major Depressive Disorder, Recurrent (F33.9) and PTSD (F43.10) deriving from
traumatic experiences, Since treating her, | have not seen any symptoms of Bi-Polar and when
this diagnosis curfaced, medical records indicate her reaction was related to stress, Her treating
Psychiatrist's concurs with the diagnoses: MDD and Anxicty/PTSD as work-related mental
health diagnoses (report attached), Ms. Christopher is motivated for treatment, is compliant, and
attentive
to her care, She has responded well to EMDR Therapy, Present residual
effects of her
work injury include depression, anxisty, insomnia, gastro distress, headaches, syncope episodes,
and panic attacks, She does not have current suicidal ideation, hallucinations or delusions, she is
not paranoid, and presents no behavioral risks, but has physical responses to real life situations.
She also suffers triggers of the past and flashbacks, which are quite disabling and at times induce
life-threatening physical responses. For these reasons this accommodations request is being made
for medical reasons,
1of3
A 1
Ms, Christopher has had significant episodes of panic wherein she passed out while driving,
standing, and while sitting, Records show these episodes have been evaluated as anxiety related
and medical records reveal no physical etiology, She manages these symptoms fairly well by
engaging in activities at her own pace but this pace is not conducive to gainful employment. In
recent years, she had at least four or moro significant syncope episodes resulting in periods of
unconsciousness with the last occurring on Dec. 20, 2019 requiring CPR, I have been working
with ber on a therapy modality which requires climinating talking about her past traumatizing
experiences as this causes severe physical responses, She is an intelligent woman who presents
herself well; however she can quickly and without warning physically deteriorate to the point of
cardiac unresponsiveness. Therefore, at this time, she cannot engage in her regular work due to
the residual offects of her occupational injury and her ability to engage in other gainful work
other than Social Work is unlikely as well.
Qn April 30, 1992, Ms. Christopher's employer evaluated her and the determination of VA
Empleyee Health Physician, Dr, Charles Shaw in a Fitness for Duty Examination was that she
was incapable of performing her duties, Depression, anxicty, and PTSD were related to her
injury. Records dating back to 1989 show she experienced some cardiac episodes on the job
(palpitations, elevated heart and blood pressure rates) wherein she fainted, coded, and had
periods of immobilization and- unresponsiveness; This -has-not-changed but -has-worsened-in-
severity, She has gotten older and her depressive symptoms are experienced as sadness, anxiety,
insomnia, fatigue, spontaneous abreactions, and low energy which adversely affect ber heart. Dr.
Rahn K, Bailey accurately describes this process as, depressive and anxiety symptoms evidenced
in physical symptoms, as elevated blood pressure and heart palpitations wherein physical
impairment has not been found to account for the spontaneous biological responses (2008).
Therefore she is presently disabled and a change in her ability to be gainfully employed is
unlikely,
Relative to the causal relationship between her present condition and the original injury, per the
DOL Ruling dated Nov, 28, 1994, "the emplayment aggravated, accelerated, or combined with
the condition to produce the disability, expressed as the employer takes the employee as he finds
him; thus the entire disability is compensable and no attempt is to made to weight the relative
contribution of the aceldent to the preexisting condition to the final disability or death," (See
Ruling Attached). Thus, since the predisposing conditions and the work-injury are inseparable,
the accepted conditions and residuals are and will remain related to her work injury and cannot
be separated from her pre-existing condition, also per this ruling,
According to medical and VA records the patient was retired from her VA job in 1992 duc to a
work injury and she has been on a medical retirement since that time. Medical records of
treatment for this work-related injury are available from 1989 to the present date. All records
indicate she has not recovered from this mental health condition since first diagnosed in 1990 by
Dr, G, K, Ravichandran. The IME of Dr. Peter B, Polatin, MD, seems to present a fairly
complete history of her treatment up until 2005 including the records of psychiatrists, beginning
with Dr. G. K. Ravichandran (1990 thru 1997), reports from 2nd opinions evaluations, treatment
from Dr. Rahn K. Bailey (1997 through 2008), She was in treatment for a brief period with an
internist, Dr, Ben Echols in 2008 who treated both her itis and depression until she became
the patient of Dr. Robert Woodham from 2009 through 2019; then she transferred her care to Dr,
20f3
Victor N. Hirach, PhD, Clinical Psychologist
& Associates
1025 H, Main St, Suite 100
League City, TX
281-332-3852
AFF VITO} fc RE MEN)
I, Victor N, Hirsch, PhD, Clinical Psychologist,do certify
nnder oath the
im hie ny It td em hey ae Fan 916, 7 ve
to Ms, Christopher for her work-related mental health condition. 1 met
‘Ms, Christopher when she sought treniment from our office for a sifustion which exacerbated
conditions associated with her work injury, Her condition is related tp traumatic childhood and
Schizophrenia, not a delusional disorder, and not 2 paranoid disontes;
tather she mess dingnostic criteria for Major Depressive Disorder, Recurrent (F33.9) and PSD
(F43.10). Fler peychiatrist provides mainenance conditions
and our
Cheistopher
is motivated for treatment, is
Sees, eet oe tet Oars cl we ae ea
aad panic attacks and she manages these symptoms well by
‘Acconting-to-medical-and
VA: records the patient-was
spe ein o to a work injusy and she has been on a medical retirement
since shat time, ‘There is no history of previous meatal health treatment before 1989. Ms.
engages in activities which allow hor to manage her health care needs, Therefore,
her prognosis for maintaining a wholesome quality of life and decreasing stress is good,
The attached medical reconds of Jan Christopher (Lightfoot: Maiden Name) constitute 2 true and
copy of his/her medical records reganiing the referenced treatment andl are kept in the
eeaiery Sours He Paso
THIS THE payor Martel 207.
VICTORN. HIRSCH, PHD, Clinical Psychologist
om ubseribed potore me tis the \Z tay ot er), aman
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Me ted AON Qu NOrary PUBLIC
My ca expires:_} W2.| LOVA
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| eet, ELZASETH DORTHEA AWN
Notary Public, State of
‘Comm, Expiras 02:20-2034
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—-
—
Exhibit
CAUSE 21-DCV-281435
Jan Lightfoot In the District Court of
VErSUS Fort Bend County, Texas
Oak Bend Medical Center, ef al 458" District
AFFIDAVIT OF VELMA MCCOY
State of Texas
County of Harris
Before me, the undersigned Notary in and for the State of Texas, personally appeared Velma McCoy
(the “Affiant”), a person known to me or who showed me her Texas Driver’s License bearing a photograph
of herself, After I administered the oath to her, the Affiant testified:
1 My name is Velma McCoy. | am over 18 years of age, of sound mind, have never been convicted of
committing any crime of moral turpitude, and am capable of making this affidavit. The statements
made in this Affidavit are true and correct, and are within my personal knowledge.
Dr. Jan Lightfoot (maiden name), a/k/a/, Jan Christopher (retirement/former married), hereafter
named, JL, listed my name and phone number on Dr. Robert Woodham and other doctors recorded
as the person to call if there were an emergency.
3. On Dee, 24, 2018, I received a call from JL around 7:00am, Jan stating she had headache and was
going to drive herself to Oak Bend Medical Center where she’s gone many years for ER services but
not to see her regular doctors there. [ was nearby and visited her to make sure she could drive or iff
should drive her, I stopped by and 1 felt confident that she could drive herself; I went back to work,
Later that morning Jan called me saying Oak Bend would not let her leave, had placed an IV in her
arm to give her Haldol in her veins for no reason, staying she was delusional about being ina bully-
class, not trusting her family, about her being a PhD, and a pastor, working for Bush and Trump, and
saying they were saying she was delusional because she believed (with good reason) the hospital
would kill her by putting Haldol into her veins because she knew this is prohibited and causes *sudden
death.*
I'd seen JL that morning, spoke with her via phone the duration of her confinement, and was present
at the hospital speaking with her. JL was not was delusional, was not cursing, was not pacing, was
not anxious, but remained calm, She accepted that she'd be able to see the judge and be released,
JL made many calls to her Psychiatrist, to the hospital, and to law-enforcement to be released but she
was unsuccessful, Oak Bend would not release JL to me was unlike any other admission Oak Bend
released JL to me in 2012 from a medical unit at Oak Bend when JL accidentally took too much of
her meds trying to get some sleep after her father died. [See 8-17-12 release to me]. Oak Bend released
JL to me the next day, but would not release herto me and | was right there until a policemen escorted
her to the behavioral unit after 5:00PM,
I was present with Ms. Lightfoot on December 24, 2019 and visited and spoke with her
everyday while she was confined in Oak Bend Hospital. I made many calls requesting that she
be released to me, to allow me to take her to her appointment on December 27, 2018 with Dr.
Woodham, or to allow me to take her, and give any care she would need. But Oak Bend refused.
Then when it came time for her to go to court, Oak Bend staff and her court-appointment
attorney called me asking me to pick her up because JL no longer had a case. So, saying to me
and to JL, “You cannot leave until you see the judge,” there was no case and no judge.
\(dheo.
Velma McCoy
Ha
SWORN TO AND SUBSCRIBED IN MY PRESENCE on t! day of July 2021.
.
Ayre _|
NE DENNIS Notary POblic in and for the State of
Preview
Filed 7/8/2021 11:56 PM Beverley McGrew Walker RR District Clerk Fort Bend County, Texas Ashley Alaniz CAUSE NO. 21-DCV-281435 DR. JAN LIGHTFOOT, aka IN THE DISTRICT COURT OF JAN CHRISTOPHER VERSUS FORT BEND COUNTY, TEXAS OAKBEND MEDICAL CENTER, COURTNEY LANDRY, M.D., et al 45874 JUDICIAL DISTRICT Plaintiff's Motion for Leave to File Late Exhibits to the Plaintiff's Responses to the Second Motions to Dismiss and for Summary Judgment filed by Defendants Woodham and Greater Houston Psychiatric Associate: TO: Defendants ROBERT WOODHAM, M.D. and GREATER HOUSTON PSYCHIATRIC ASSOCIATES, P.L.L.C. by and through his attorney of record, Noah Meek, Cardwell & Chang, P.L.L.C., 511 Lovett Boulevard, Houston, Texas 77006, via email: meek@cardwellchang.com YOUR HONOR: The Plaintiff respectfully asks this Court to grant her leave to file late Exhibits. On 6 July 2021, the Plaintiff had timely filed her Responses to the Second Motions filed by Defendants Woodham and Greater Houston Psychiatric Associates, but failed to attach the attached Exhibits. Granting such leave would be proper because there is good cause and because there would be no undue prejudice. Introduction 1 The Plaintiff filed this lawsuit on 9 March 2021. This lawsuit is only four (4) months old. The Defendants, however, are attempting to require the Plaintiff to prove her case -- even before discovery has been conducted. Expert Reports are not due until next month. The Plaintiff seeks to recover damages resulting from her false imprisonment and illegal mental health commitment, and from the medical malpractice perpetrated by certain Defendants, including Dr. Woodham. The Court has set a hearing on 13 July 2021 at 1:30 p.m. on the Second Motions to Dismiss and for Summary Judgment filed by Defendants Woodham and GHPA. 4. The Plaintiff had filed her Responses, but without Exhibits, on 6 July 2021. Authorities and Argument 5. A nonmovant must file and serve her Response and affidavits at least seven days before the hearing. TEX. R. CIV. P. 166a(c). The Texas Supreme Court has promulgated that granting leave to file a late response (or exhibits thereto) is proper if: (1) there is good cause; and (2) there would be undue prejudice. Wheeler v. Green, 157 8.W.3d 439, 442 (Tex. 2005); see also, Carpenter v. Hydrocarbons, 98 S.W.3d 682,687-688 (holding that the standard for granting leave to file a late response is the same as the standard for withdrawing deemed admissions). “Good cause” is established with sworn proof that the nonmovant’s failed to timely respond (or timely file exhibits thereto) was not intentional or the result of conscious indifference, but rather, was the result of an accident or mistake. See, Wheeler, 157 S.W.3d at 442. Attached as EXHIBIT A and incorporated by reference herein is the Affidavit of the Plaintiff's attorney to establish good cause. As the Texas Supreme Court announced in Carpenter, 98 S.W.3d at 687-688, the standard for granting leave to file a late response (or exhibits thereto) is the same as the standard for withdrawing deemed admissions. The party must state good cause, explaining why it did not timely serve its responses to the requests for admission. TEX. R. CIV. P 198.3(a); Wheeler, 157 8.W.3d at 442; Wal-Mart Stores v. Deggs, 968 S.W.2d 354, 356 (Tex. 1998). Good cause can be accident or mistake, as long as it was not intentional or the result of conscious indifference. Marino v. King, 355 S.W.3d 629, 633 (Tex. 2011); Wheeler, 157 S.W.3d at 442; e.g., Boulet v. State, 189 $.W.3d 833, 837 (Tex. App. — Houston [1* Dist.] 2006, no pet.) (holding that a mistake in calendar entry was sufficient to establish good cause). Even a slight excuse can be enough to establish good cause. Boulet, 189 S.W.3d at 836; In re Kellogg- Brown & Root,45 §.W.3d 772, 775 (Tex. App. — Tyler 2001, orig. proceeding). EXHIBIT A confirms the Plaintiffs failure to attach the now attached Exhibits to her Responses, which it had timely filed on 6 July 2021, was by accident or mistake, and certainly was not intentional or the result of conscious indifference, and that receiving those Exhibits would not unduly delay or otherwise injure Defendants Woodham and GHPA. PRAYER For these compelling reasons, the Plaintiff respectfully asks this Court to GRANT her Motion for Leave, and consider the attached Exhibits as timely filed for the hearing on 13 July 2021. Respectfully submitted, AQRAWI & ASSSOCIATES, P.L.L.C, s/s G.N. Lawrence GN. Lawrence 2 SBOT 12046250 Walat Aqrawi SBOT 24094515 A.G. Aiken SBOT 24094514 3033 Chimney Rock Road, Suite 300 Houston, Texas 77056-6257 Telephone: (832) 834-6099 Facsimile: (281) 605-6805 g.lawrence@aqrawilaw.com ATTORNEYS FOR THE PLAINTIFF CERTIFICATE OF SERVICE In compliance with Rules 21a and 21(f(2) of the Texas Rules of Civil Procedure, I hereby affirm I served a true and correct copy of the foregoing Plaintiff's Motion for Leave to file late exhibits on the following counsel of record at their email addresses on this 8" day of July 2021: SERVICE List John Shepperd Michael Blaise Christina Huston Lorance Thompson, P.C, ‘Wilson, Elser, Moskowitz, Edelman & 2900 North Loop West, Ste. 500 Dicker LLP Houston, Texas 77092 909 Fannin, Ste. 3300 Tele: (713) 868-5560 Houston, Texas 77010 Fax: (713)864-4671 Tele: (713) 353-2000 mwb@lorancethompson.com Fax: (713) 785-7780 Attorney for Defendant John.shepperd@wilsonelser.com Matt Brams Attorney for Defendants Courtney Landry, MD and Rose-Rich EM Physicians, PA Mark E. Callender Donald S. Stephens Brett R. Sheneman Stephens & Associates Benjamin E. Hamel 7930 W. Broadway, Ste. 110 Serpe, Jones, Andrews, Callender & Bell, Pearland, Texas 77581 PLLC Tele: (281) 978-4540 America Tower Fax: (281) 978-4541 2929 Allen Parkway, Ste. 1600 dss@d. hhenslaw.com Houston, Texas 77019 Attorney of Defendants Tele: (713) 452-4400 Owen Capocyan, MD and Fax: (713) 452-4499 Oak Bend Medical Group meallender@serpejones.com bsheneman@s ejones.com bhamel@se: jones.com Attorney for Defendant Oakbend Medical Center Kevin Hedges Suzan Cardwell Assistant County Attorney Noah Meek Bridgette Smith-Lawson Cardwell & Chang, PLLC Fort Bend County Attorney 511 Lovett Blvd. 401 Jackson, 3" Floor Houston, Texas 77006 Richmond, Texas 77469 Tele: (713) 222-6025 Tele: (281) 341-4555 Fax: (713) 222-0938 Fax: (281) 341-4557 cardwell@cardwellchang.com Kevin. hedges@fortbendcountytx.gov meek@cardwellchang.com Attorney for Defendants Attorney for Defendants Fort Bend County Sheriff's Office, Robert Woodham, MD and Marisa Salas Greater Houston Psychiatric Associates, PLLC James B. Edwards Stacy T. Garcia Edwards & Garcia 12603 Southwest Freeway, Ste. 200 Stafford, Texas 77477-3809 Tele: (281) 277-4940 Fax: (281) 277-4974 aas(@malpracticedefense.com ecp(@malpracticedefense.com e-service@malpracticedefense.com jbe@malpracticedefense.com tg@malpracticedefense.com Attorney for Defendant Jorge A. Raichman, MD /s/ G. N. Lawrence Exhibit CAUSE 21-DCV-281435 Jan Lightfoot In the District Court of versus Fort Bend County, Texas Oak Bend Medical Center, ef al 458" District AFFIDAVIT OF JAN LIGHTFOOT State of Texas County of Harris Before me, the undersigned Notary in and for the State of Texas, personally appeared Jan Lightfoot (the “Affiant”) , a person known to me or who showed me her Texas Driver's License bearing a photograph of herself, After I administered the oathto her, the Affiant testified: “1, _My.name is Jan Lightfoot. I am over 18 years of age, of sound mind, have never. been convicted. of committing any crime of moral turpitude, and am capable of making this affidavit. The statements made in this Affidavit are true and correct, and are within my personal knowledge. 2 Tam a licensed mental health counselor with over 38 years of licensure tenure. I am licensed as a LCSW Social Worker Emeritus and LPC: Licensed Professional Counselor with psychological testing authority, I have over 50 years of credible work experience in my fields of study. My past work experiences include working at Bexar County MHMR, San Antonio College, West Paces Ferry Hospital in Atlanta Georgia, the Veteran's Administration in Houston, Texas, and the Wholeness Foundation, an entity of Vine Dweller Ministries, INC—-the charity wherein I presently serve. Tam ordained under the ecclesiastical authority of Cornerstone Community of Faith Ministries, Dr. B. Wesley Austin, Jr, CPE Clinical Supervisor and Pastoral Care—a cooperative program of the Southern Baptist Church, 3 The only mental illness I suffered from since 24 December 2018 to present has been severe depression, or MDD and PTSD due to childhood and workplace traumas, I have never been properly diagnosed with bipolar disorder or psychosis and these diagnoses have been ruled out. Attached as EXHIBIT A is a letter and medical report from my current healthcare professional at UTMB on my mental condition. Ii is a true and correct copy of the actual letter. Also attached are EXHIBIT B and EXHIBIT C, EXHIBIT B is true and correct copy of the actual letter from psychiatrist Dr. Xu. EXHIBIT C is a true and correct copy of the actual letter from my psychologist, Dr. Vietor N. Hirsch. 4 As of 24 December 2018, Dr. Robert L, Woodham, MD had been my psychiatrist for over nine (9) years, beginning on 24 April 2009. He managed my medication for the work-related injury I had sustained on 15 July 1989. The Department of Labor had accepted that injury as a mental health condition—Major Depression Disorder (MDD). 5 I continued to see Dr. Weodham during 2018. He had scheduled me for an appointment on 27 December 2018, Page 1 of 3 6. On 24 December 2018, I had made seven (7) distress calls to him, because he was my psychiatrist, | made those seven distress calis from 0900 hours through 1700 hours — before 1 was illegally and involuntarily committed to Oak Bend Medical Center. 7 On 6 February 2019, I discharged Dr. Woodham as my psychiatrist. 8 While | was a patient of Dr. Woodham’s, he had the name and telephone number of my emergency contact, Ms. Velma McCoy. 9. On 30 July 2019, Gerry, a member of the Greater Houston Psychiatric Associates, P.L.L.C. (“GHPA”), had called Ms. McCoy not once, but twice, requesting the name and phone number of my closest living relative about my ability to take care of myself and my safety. 10. Why Dr. Woodham would have a GHPA employee call my emergency contact Ms. McCoy was very suspicious to me, because there was no emergency, the question of me taking care of myself never surfaced, and because he had not seen me in over six (6) months. Ifhe were genuinely concerned about my well-being, he could have called me directly, or called Dr. Hirsh, my treating psychologist, whose contact information is in his notes. 8. After Ms. McCoy had told me she had received those two calls from GHPA, I filed a Police Report with the Houston Police Department, whose investigating officer concluded the calls were forgery/fraud, and it should not have contacted Ms. McCoy regarding my medical care, because Lam. a competent person in charge of my own medical care. 9. Until I had discharged him on 6 February 2019, Dr. Woodham had misdiagnosed me. He never did his own assessment of me, but instead merely continued the diagnoses and treatment plan of Dr. Rahn K. Bailey, my former psychiatrist who was a specialist in Dissociative Identity Disorder (“DID”), Post Traumatic Stress Disorder, and Trauma. Dr. Bailey had diagnosed me with DID. DID is not a delusional disorder, and is not Schizophrenia; instead, it is a brain’s defense mechanism resulting from my childhood trauma and work-related injury. Dr. Woodham did not provide any medication for that diagnosis, because it does not respond to medication. Both Dr. Hirsh, the psychologist, and Dr. X, the psychiatrist whom I had hired to replace Dr. Woodham, disagreed with Dr. Woodham’s diagnoses and choice of medications. 10. Dr. Woodham made false statements to Adult Protective Services in July 2019. I had informed him on 14 January 2019 that my Baylor doctor had tapered me off Lamictal and I was therefore no longer taking it. Instead of reporting the results of his notes from my last office visit on 6 February 2019, he reported to Adult Protective Services that I was off my medications, was a gun threat, and needed either guardship or involuntary commitment — even though he had not seen me for over six (6) months, il. In April 2021, Dr. Woodham finally provided his records to me, but the records he had provided do not in fact match the records he had provided to the Department of Labor ECOMP files pertaining to my work-related injury. He therefore produced two (2) different set of records. Page 2 of 3 12. On 8 April 2021, Dr. Woodham produced a fabricated telephone message dated 12/26/2018. That telephone message is not a part of the original or scanned records into the Department of Labor's ECOMP files nor in the original and scanned record in my possession. This document is labeled as Exhibit E in Defendant’s TCPA Motion to Dismiss and Motion for Summary Judgement. The telephone message is fabricated because it alleges, 1 had called Dr. Vernon Walling of GHPA on 26 December 2018, to merely tell Dr. Woodham that I was staying at Oak Bend Medical Center. I did not make any such a call on 26 December 2018. What's more, nowhere in Dr. Woodham’s notes did he report my seven distress calls on 24 December 2018 — before I was illegally and involuntarily committed in Oak Bend Medical Center.” Jafy Lightfoot SWORN TO AND SUBSCRIBED IN MY PRESENCE on th day of July 2021. wi i, LEZANNE DENNIS Ay i Lh anne 223 Reblic in and for the State of Texas | Notary Public, State of Te: Comm. Expires 08-05-2024 ae et Notary 1D 129074758 Commission expires on g [5 of Page 3 of 3 Exhibit Health = myChart Name: Jan Christopher | DOB: 3/6/1951 | MRN: 592883N | PCP: Madhumita Banga, MD Letter Details Wane Health June 23, 2021 To Whom It May Concern: RE; Jan Christopher 12319 Chesterbrook Dr Houston TX 77031 The person named above is my patient at the UTMB Primary Care Clinic in Webster, TX and has been treated at UTMB since 2016, She has been diagnosed with Major Depressive Disorder [ MDD ] and this condition is stable, MDD Is a disabling condition that prevents Ms Christopher from performing gainful work but she is able to engage in productive activities at her own pace as long as her disabilities are accommodated. She does not have any cognitive defects, paranoia, hallucinations, organic conditions, delusions, or threatening behavior. She does not have Schizophrenia as per her records and my Clinical assessment, nor any behavioral disturbance or character flaws, There Is no record to substantiate that she Is self-neglecting, unable to care for herself, a danger to herself or others, needs guardianship, involuntary commitment or Nursing Home placement. She is independent and has continuously been discharged to self-care. Her Medical condition is also stable at this time [ see recent Medical evaluation notes J, and she Is motivated for treatment, and responsibly manages her care. As her Primary Care Provider, | certify this to be a true statement, and Invite you to please contact our Office if you have any questions. Sincerely, Cy Madhumita Banga, MD UTMB Health Adult Primary Care- Webster Christopher, Jan MRN: 592883N Banga, Madhumita, MD Progress Notes Encounter Date: 6/24/2021 STAFF Signed Specialty: FM-FAMILY MEDICINE Ce: Chief Complaint Patient presents with * Follow-up Jan Christopher is a 70 year old femate. She is here today for a follow up visit and to get her Chart updated. Her Behavioral Heaith conditions are stable currently with Sertraline, taking medications for panic attacks prn ( Alprazolam ). She is getting psychotherapy and neurotherapy for this, does not use Alprazolam unless needed as a last resort. She was diagnosed with DID ( dissociative Identity Disorder ) which was treated with therapy successfully and she has no symptoms now. Medications Outpatient Medications Prior to Visit Medication Si Dispense Refill * QUEtiapine 25 mg tablet Take 1 tablet by mouth 30 tablet 4 at bedtime. For sleep + meloxicam 15 mg tablet Take 1 tabletby mouth. + SERTraline 100 mg tablet Take 1 tablet by mouth daily. + losartan-hydrochlorothiazide 100- Take 1 tablet by mouth 90 tablet 25 mg per tablet ily. * famotidine 40 mg tablet Take 1 tablet by mouth 90 tablet daily. * fluticasone propionate 50 Use 2 Sprays in each 16g meg/actuation nasal spray nostril 2 (two) times laily. * ketorolac 10 mg tablet Take 1 tabletby mouth 10 tablet every 8 (eight) hours as needed for Pain (scale 4-6). + dicyclomine 10 mg capsule Take 1 capsule by 30 capsule mouth 3 (three) times daily as needed for Abdominal pain. * topiramate 50 mg tablet Take 1 tablet by mouth 60 tablet 2 (two) times daily. * zolpidem 10 mg tablet Take 0.5 tablets by 30 tablet mouth at bedtime as needed for Insomnia. » methocarbamoL (ROBAXIN) 500 Take1 tabletby mouth 30 tablet mg tablet 4 (four) times daily. + albuterol 1.25 mg/3 mL nebulizer Inhale 3 mL every 6 3mt solution (six) hours as needed for Wheezing, Shortness of Breath or Chast tightness. + levocetirizine 5 mg tablet Take 1 tablet by mouth 90 tablet every evening. * montelukast 70 mg fablet Take 1 tablet by mouth 90 tablet daily. + butalbital-acetaminophen-caff 50- Take 1 tablet by mouth 30 tablet 325-40 mg tablet every 6 (six) hours as needed for Other (headache). * mupirocin 2 % ointment Apply to area(s) 3 229 (three) times daily. * celecoxib 100 mg capsule Take 1 capsule by 60 capsule mouth 2 (two) times daily with meals. « latanoprost 0.005 % ophthalmic Place 1 Drop in both 2.5 mL drops. eyes every evening. + Polyethylene Glycol 3350 Take 1 Packet by 14 Packet (MIRALAX) 17 gram powder mouth daily. * sucralfate 100 mg/mL suspension Take 10 mL by mouth 420 mL before’ meals and-at- bedtime. + QUEtiapine 25 mg tablet Take 1 tablet by mouth 30 tablet at bedtime. + lovastatin 20 mg tablet Take 1 tablet by mouth 90 tablet at bedtime. * Polyethylene Glycol 3350 17 gram Take 17 g by mouth. powder * BLUE-GREEN ALGAE, Take by mouth. SPIRULINA, ORAL + butterbur root extract Take by mouth. (PETADOLEX ORAL) * TURMERIC ORAL Take by mouth. « nitroglycerin 0.3 mg sublingual Place 0.3 mg under the tablet tongue every 5 (five) minutes as needed for Chest pain (take every 5 minutes times 3). Indications: chest pain + diphenhydrAMINE (BENADRYL) Take 50 mg by mouth 25 mg capsule at bedtime as needed for Allergies. + linaclotide (LINZESS) 72 meg Cap Take 7 capsule by mouth daily. * albuterol (VENTOLIN) 90 Inhale 2 Puffs every 6 mcg/actuation inhaler (six) hours as needed for Wheezing or Shortness of Breath. No facility-administered medications prior to visit. Review of Systems Psychiatric/Behavioral: Positive for sleep disturbance. Negative for agitation, behavioral problems, confusion, decreased concentration, dysphoric mood, hailucinations, self-injury and suicidal ideas. The patient is not nervous/anxious. Vital Signs BP 139/83 | Pulse 66 | Temp 36.4 °C (97.5 °F) | Resp 16 | Ht5' 9" (1.753 m) | Wt 198 Ib (89.8 kg) | SpO2 99% | BMI 29.24 kg/m? Physical Exam Pulmonary: Effort: Pulmonary effort is normal. Neurological: General: No focal deficit present. Mental Status: She is alert. Psychiatric: Mood and Affect: Mood normal. Thought Content: Thought content normal. Judgment: Judgment normal. Assessment/Plan Jan was seen today for follow-up. Diagnoses and all orders for this visit: insomnia, unspecified type Comments: Chronic Stable, taking Quetiapine and also Melatonin Continue same, take Ambien prn if these do not help Episode of recurrent major depressive disorder, unspecified depression episode severity Comments: Chronic Stable at this time. Continue Sertraline. Anxiety Comments: Chronic Stable, having some panic attacks sometimes. Seeing Dr. Hirsch, Psychologist, getting Therapy which helps. Continue Xanax pm Dissociative identity disorder I Co! Past diagnosis, resolved Stable, with Therapy. No medications indicated for this. She is not having any symptoms. { spent a total of 30 minutes on the day of the visit. The time spent for patient care includes: Performing a medically appropriate examination and/or evaluation, Counseling and educating the patient/family/caregiver, Documenting clinical information in the electronic or other health record and Care coardination (not separately reported). Office Visit on Note viewed by patient 6/24/2021 17448 Highway 3, 2nd Floor Webster TX 77598-4187 Dept: 832-505-1748 Dept Fax: 281-333-2772 This letter was initially viewed by Jan Christopher at 6/23/2021 10:51 PM, MyChart® licensed from Epic Systems Corporation © 1999 - 2020 Exhibit Whole Health PLLC Huiping Xu M.D. M.S Psychiatry Address; 6100 Corporate Dr Suite 238# Houston TX 77036 T 7139994111 | F 866 666 7216 | email: drxu@houston-psychiatrist.com 04/25/19 To whom it may concern Janice Christopher iDig0210900 DOI 06/15/1989 Jan Christopher is a patient of since mine 04/24/2019. She is currently being treated for the occupational illness under OWCP F33.9 Major Depressive disorder. We will continue medication management as needed. We have prescribed the following medications Topriamate 50 mg {one tablet po BID) Seroquel 25mg (one tablet po ghs) Ambien 10mg (one tablet po ghs) Please feel free to give us a call if you have any additional questions. Huiping Xu M.D Lae a Whole Health PLLC Huiping Xu M.D. M.S Psychiatry Address: 6100 Corporate Dr Suite 238# Houston TX 77036 7 7139994111 | F 866 666 7216 | email: drxu@houston-psychiatrist.com May 28, 2019 RE: Janice Christopher (No. 16-0210900) Date of injury: 6/15/1989 U.S. DOL/OWCP DFEC CENTRAL MAILROOM ~ 16 P.O. Box 8300 LONDON, KENTUCKY 40742 Attn: Ms. Kim H. To Whom it May Concern: Tam writing this letter on behalf of Ms. Janice Christopher who is a 68-year-old, divorced, Black American, female who has been under my care since April 24, 2019 when I first examined her on April 24, 2019 and on May 28, 2019. 1 sent a letter to your office dated April 25, 2019 advising you that I am the treating psychiatrist for her occupational illness. Our examination and review of Ms. Christopher's record indicates that she has been in Psychiatric Care for this work- related condition since 1989 and she continues in treatment to the present time. According to my examination and of her medical and DOL/OWCP records, Ms. Christopher has been disabled from engaging in her regular work since her medical retirement from her VA job in 1992 due to above referenced work injury. I concur that the patient remains disabled from her regular work due to her work-related injury. Relative to the causal relationship between her present condition and the original injury, per the DOL Ruling dated Nov. 28, 1994, “the employment aggravated, accelerated, or combined with the condition to produce the disability, expressed as the employer takes the employee as he find him; thus the entire disability is compensable and no attempt is to made to weight the relative contribution of the accident to the preexisting condition to the final lof2 disability or death," (See Ruling Attached). Thus, since the predisposing conditions and the work- injury are inseparable, her accepted conditions are and will remain related to her work injury. TREATMENT PLAN: ! concur with the DOL accepted condition for her Axis | Diagnosi s of Major Depression, Recurrent (F33.9). She is also diagnosed with Anxiety, PTSD and Gastritis related to her Occupational iliness. Her physicians will treat her Gastritis and she will continue with Psychoth erapy with her Psychologist. Medication Management: Medications include: Zolpidern 10mg PO QHS; Seroquel 25mg PO QHS; Topiramate 50 PO BID; Lorazepam 0.5mg BID PRN. Recent events have aggrava ted the conditions of her work-related injury and caused a setback in her ability to return to work. Present symptom s include depression, anxiety, insomnia, gastro distress, headaches, syncopal episodes, and panic attacks. Therefore, at this time, she cannot engage in her regular work due to the residual effects of her occupational injury due to the medical conditions for which she was medically retired. Her ability to engage in other gainful work must be evaluated. Ms. Christopher's period of disability from her regular work is from 4/27/92 thru the present date and medical records of her treatmen t for this work-related condition date back to 1989 to the present date. if you would kindly assist Ms. Christopher with any eligible benefit, it would greatly help her to improve her condition and the quality of life. Please. contact_our. office if.you have. questions or need further information. Thank you for assisting this patient. Sincerely, Dr. Huiping XU, M.D J 2— ~ 20f2 Wt Huiping i4 V 3 + ft Address: 6100 Corporate Dr Suite 238# Houston TX 77036 T 7139994111 | F 866 666 7216 | email: drxu@houston-psychiatrist.com August 7, 2020 To Whom It May Concern: Janice Christopher 1D160210900 DO! 06/15/1989 Janice Christopher is a patient of mine since 4-24-2019. | am the treating psychiatrist for her occupational illness. This letter supplements previous correspondence dated May 28, 2019, April 25, 2019, and March 10, 2020, to update this patient's medication regimen and to clarify her work status, Our office is treating her accepted condition, Major Depressive Disorder (F33.9), and related/residuai conditions. These conditions are: Anxiety, PTSD, and Gastritis. She is seen by a Clinical Psychologist, Dr. Victor Hirsch, PhD, for her Depression and PTSD and by her PCP, Dr. Madhumita Banga, MD, for her Gastritis. Regarding her work status, she has been out of work for 30 years medically retired. Therefore, | agree with her Chaplaincy Supervisor, PCP, and Psychologist that Ms. Christopher may be capable of doing light duty up to "10 hours per week as tolerated as long as her disability is accommodated.” However, this does not allow her to engage in doing Social Work, which would be too stressful. She loves doing chaplain work and plays music and teaches lessons at church on Sundays. Still, she remains medically disabled due to residuals of her work injury, has not demonstrated the capacity to engage in her regular work, and cannot return to full-time or gainful work as reported on 3/10/20. Any assistance you can give with any eligible benefits would improve the quality of her life. We have prescribed the following medications: Topiramate 50 mg (one tablet po BID); Seroquel 25 mg ( one table po QHS); Ambien 10mg (one tablet po QHS); Wellbutrin XL 180mg qdaily). Please feel free to give us a call if you have any additional questions. Huiping Xu, MD, Psychiatrist aS u = Exhibit Victor N. Hirsch, PhD, Clinical Psychologist Hirsch & Associates 1025 E, Main St, Suite 100 League City, TX. 77573 vhofficemanager@yahoo,com 281-332-3852 U, 8, DEPARTMENT OF LABOR OFFICE OF WORKER’ COMPENSATION PROGRAMS P. O. BOX 8300 DISTRICT 16 DAL LONDON, KY 40742-8300 March 27, 2020 Re: Jan Christopher, Janice B. Christopher a.k.a. Jan Lightfoot (Maiden Name) OWCP#: 160210900 OPM#; CSA80280570 Second Opinion Evaluation Request for Reasonable Ascommodations/Modifications To Whom It May Concern: This letter responds a second opinion appointment made for a work-related condition for the above referenced employes to request reasonable accommodations for medical reasons to prevent abroactions and retraumatization of this employes who is my patient and has been under my care since June 2014, I provide Psychotherapy treatment to Ms, Christopher for her work- related mental health condition, she receives Medication Maintenance from hor Psychiatrist who concurs with these diagnoses, and she reccives treatment for Gastritis from her PCP, Her conditions are related to traumatic childhood and lace traumas, She meets diagnostic criteria for Major Depressive Disorder, Recurrent (F33.9) and PTSD (F43.10) deriving from traumatic experiences, Since treating her, | have not seen any symptoms of Bi-Polar and when this diagnosis curfaced, medical records indicate her reaction was related to stress, Her treating Psychiatrist's concurs with the diagnoses: MDD and Anxicty/PTSD as work-related mental health diagnoses (report attached), Ms. Christopher is motivated for treatment, is compliant, and attentive to her care, She has responded well to EMDR Therapy, Present residual effects of her work injury include depression, anxisty, insomnia, gastro distress, headaches, syncope episodes, and panic attacks, She does not have current suicidal ideation, hallucinations or delusions, she is not paranoid, and presents no behavioral risks, but has physical responses to real life situations. She also suffers triggers of the past and flashbacks, which are quite disabling and at times induce life-threatening physical responses. For these reasons this accommodations request is being made for medical reasons, 1of3 A 1 Ms, Christopher has had significant episodes of panic wherein she passed out while driving, standing, and while sitting, Records show these episodes have been evaluated as anxiety related and medical records reveal no physical etiology, She manages these symptoms fairly well by engaging in activities at her own pace but this pace is not conducive to gainful employment. In recent years, she had at least four or moro significant syncope episodes resulting in periods of unconsciousness with the last occurring on Dec. 20, 2019 requiring CPR, I have been working with ber on a therapy modality which requires climinating talking about her past traumatizing experiences as this causes severe physical responses, She is an intelligent woman who presents herself well; however she can quickly and without warning physically deteriorate to the point of cardiac unresponsiveness. Therefore, at this time, she cannot engage in her regular work due to the residual offects of her occupational injury and her ability to engage in other gainful work other than Social Work is unlikely as well. Qn April 30, 1992, Ms. Christopher's employer evaluated her and the determination of VA Empleyee Health Physician, Dr, Charles Shaw in a Fitness for Duty Examination was that she was incapable of performing her duties, Depression, anxicty, and PTSD were related to her injury. Records dating back to 1989 show she experienced some cardiac episodes on the job (palpitations, elevated heart and blood pressure rates) wherein she fainted, coded, and had periods of immobilization and- unresponsiveness; This -has-not-changed but -has-worsened-in- severity, She has gotten older and her depressive symptoms are experienced as sadness, anxiety, insomnia, fatigue, spontaneous abreactions, and low energy which adversely affect ber heart. Dr. Rahn K, Bailey accurately describes this process as, depressive and anxiety symptoms evidenced in physical symptoms, as elevated blood pressure and heart palpitations wherein physical impairment has not been found to account for the spontaneous biological responses (2008). Therefore she is presently disabled and a change in her ability to be gainfully employed is unlikely, Relative to the causal relationship between her present condition and the original injury, per the DOL Ruling dated Nov, 28, 1994, "the emplayment aggravated, accelerated, or combined with the condition to produce the disability, expressed as the employer takes the employee as he finds him; thus the entire disability is compensable and no attempt is to made to weight the relative contribution of the aceldent to the preexisting condition to the final disability or death," (See Ruling Attached). Thus, since the predisposing conditions and the work-injury are inseparable, the accepted conditions and residuals are and will remain related to her work injury and cannot be separated from her pre-existing condition, also per this ruling, According to medical and VA records the patient was retired from her VA job in 1992 duc to a work injury and she has been on a medical retirement since that time. Medical records of treatment for this work-related injury are available from 1989 to the present date. All records indicate she has not recovered from this mental health condition since first diagnosed in 1990 by Dr, G, K, Ravichandran. The IME of Dr. Peter B, Polatin, MD, seems to present a fairly complete history of her treatment up until 2005 including the records of psychiatrists, beginning with Dr. G. K. Ravichandran (1990 thru 1997), reports from 2nd opinions evaluations, treatment from Dr. Rahn K. Bailey (1997 through 2008), She was in treatment for a brief period with an internist, Dr, Ben Echols in 2008 who treated both her itis and depression until she became the patient of Dr. Robert Woodham from 2009 through 2019; then she transferred her care to Dr, 20f3 Victor N. Hirach, PhD, Clinical Psychologist & Associates 1025 H, Main St, Suite 100 League City, TX 281-332-3852 AFF VITO} fc RE MEN) I, Victor N, Hirsch, PhD, Clinical Psychologist,do certify nnder oath the im hie ny It td em hey ae Fan 916, 7 ve to Ms, Christopher for her work-related mental health condition. 1 met ‘Ms, Christopher when she sought treniment from our office for a sifustion which exacerbated conditions associated with her work injury, Her condition is related tp traumatic childhood and Schizophrenia, not a delusional disorder, and not 2 paranoid disontes; tather she mess dingnostic criteria for Major Depressive Disorder, Recurrent (F33.9) and PSD (F43.10). Fler peychiatrist provides mainenance conditions and our Cheistopher is motivated for treatment, is Sees, eet oe tet Oars cl we ae ea aad panic attacks and she manages these symptoms well by ‘Acconting-to-medical-and VA: records the patient-was spe ein o to a work injusy and she has been on a medical retirement since shat time, ‘There is no history of previous meatal health treatment before 1989. Ms. engages in activities which allow hor to manage her health care needs, Therefore, her prognosis for maintaining a wholesome quality of life and decreasing stress is good, The attached medical reconds of Jan Christopher (Lightfoot: Maiden Name) constitute 2 true and copy of his/her medical records reganiing the referenced treatment andl are kept in the eeaiery Sours He Paso THIS THE payor Martel 207. VICTORN. HIRSCH, PHD, Clinical Psychologist om ubseribed potore me tis the \Z tay ot er), aman @ Me ted AON Qu NOrary PUBLIC My ca expires:_} W2.| LOVA Enck Patient Medical Recoris Tork Carticulum Vitas oor ty Le | eet, ELZASETH DORTHEA AWN Notary Public, State of ‘Comm, Expiras 02:20-2034 ne Notary(D 332887758 —- — Exhibit CAUSE 21-DCV-281435 Jan Lightfoot In the District Court of VErSUS Fort Bend County, Texas Oak Bend Medical Center, ef al 458" District AFFIDAVIT OF VELMA MCCOY State of Texas County of Harris Before me, the undersigned Notary in and for the State of Texas, personally appeared Velma McCoy (the “Affiant”), a person known to me or who showed me her Texas Driver’s License bearing a photograph of herself, After I administered the oath to her, the Affiant testified: 1 My name is Velma McCoy. | am over 18 years of age, of sound mind, have never been convicted of committing any crime of moral turpitude, and am capable of making this affidavit. The statements made in this Affidavit are true and correct, and are within my personal knowledge. Dr. Jan Lightfoot (maiden name), a/k/a/, Jan Christopher (retirement/former married), hereafter named, JL, listed my name and phone number on Dr. Robert Woodham and other doctors recorded as the person to call if there were an emergency. 3. On Dee, 24, 2018, I received a call from JL around 7:00am, Jan stating she had headache and was going to drive herself to Oak Bend Medical Center where she’s gone many years for ER services but not to see her regular doctors there. [ was nearby and visited her to make sure she could drive or iff should drive her, I stopped by and 1 felt confident that she could drive herself; I went back to work, Later that morning Jan called me saying Oak Bend would not let her leave, had placed an IV in her arm to give her Haldol in her veins for no reason, staying she was delusional about being ina bully- class, not trusting her family, about her being a PhD, and a pastor, working for Bush and Trump, and saying they were saying she was delusional because she believed (with good reason) the hospital would kill her by putting Haldol into her veins because she knew this is prohibited and causes *sudden death.* I'd seen JL that morning, spoke with her via phone the duration of her confinement, and was present at the hospital speaking with her. JL was not was delusional, was not cursing, was not pacing, was not anxious, but remained calm, She accepted that she'd be able to see the judge and be released, JL made many calls to her Psychiatrist, to the hospital, and to law-enforcement to be released but she was unsuccessful, Oak Bend would not release JL to me was unlike any other admission Oak Bend released JL to me in 2012 from a medical unit at Oak Bend when JL accidentally took too much of her meds trying to get some sleep after her father died. [See 8-17-12 release to me]. Oak Bend released JL to me the next day, but would not release herto me and | was right there until a policemen escorted her to the behavioral unit after 5:00PM, I was present with Ms. Lightfoot on December 24, 2019 and visited and spoke with her everyday while she was confined in Oak Bend Hospital. I made many calls requesting that she be released to me, to allow me to take her to her appointment on December 27, 2018 with Dr. Woodham, or to allow me to take her, and give any care she would need. But Oak Bend refused. Then when it came time for her to go to court, Oak Bend staff and her court-appointment attorney called me asking me to pick her up because JL no longer had a case. So, saying to me and to JL, “You cannot leave until you see the judge,” there was no case and no judge. \(dheo. Velma McCoy Ha SWORN TO AND SUBSCRIBED IN MY PRESENCE on t! day of July 2021. . Ayre _| NE DENNIS Notary POblic in and for the State of