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8/25/2023 9:32 AM
FELICIA PITRE
DISTRICT CLERK
ww DALLAS CO., TEXAS
Rosa Delacerda DEPUTY
CAUSE NO. DC-21-11344
BARBARA DALBY IN THE DISTRICT COURT OF
Plaintiff,
v. 116TH JUDICIAL DISTRICT
HUNT OIL COMPANY AND
MIKEAL CROSSON
Defendants. DALLAS COUNTY, TEXAS
PLAINTIFF’S NOTICE OF FILING OF MEDICAL AFFIDAVITS
TO THE HONORABLE JUDGE OF SAID COURT:
Pursuant to Rule 902(10)(a) of the Texas Rules of Evidence and Section 18.001 of the
Texas Civil Practice and Remedies Code, you are hereby notified that Plaintiff, Barbara Dalby,
has filed in the above-numbered and entitled cause business records affidavits as executed by
their custodians of record, for the following entities:
1 Medical Bill Affidavit - Medical Center Hospital - Odessa
2 Medical Record Affidavit - Medical Center Hospital - Odessa
3 Medical Bill Affidavit — City of Odessa Fire - EMS
These medical and billing records may be offered in evidence on the trial of the above-
captioned cause.
The affidavits are filed pursuant to Rule 902(10)(a) of the Texas Rules of Evidence and
Section 18.001 of the Texas Civil Practice and Remedies Code. The affidavits and the
underlying medical and billing records have been served on counsel of record for Defendants
concurrently with the filing of this Notice.
Page 1
Respectfully submitted.
GOUDARZI & YOUNG, L.L.P
P. O. Drawer 910
Gilmer, Texas oa
Telephone: Me 544
Facsimile: 2026
EService:goudar/ / 7 darzi-young.com
By
ent iL
‘tate Bar No. 0 E
Marty Young
State Bar No. 24010502
ATTORNEYS FOR PLAINTIFF
Page 2
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Plaintiff's Notice of Filing
Medical Affidavits was forwarded to the following counsel of record for Defendants by E-serve
this 25" day of August, 2023
Scott Zimmer
Megan Reinkemeyer
Kean Miller LLP
711 Louisiana Street, Suite 1800
Houston, Texas 77002
William M. Toles
Kelly E. Wise
Munsch Hardt Kopf & Harr, P.C.
500 N. Akard, Suite 3800
Dallas, Texas 75201
Douglas Fletcher
Jeffrey Smith
Joseph Harrison
LU
Fletcher, Farley, Shipman & Salinas, LLP
9201 N. Central Expressway, Suite 600
Dallas, Texas 75231
[rious |
Page 3
[ED Fm —MED NTER AL,- OD!
THE STATE
OF TEXAS §
COUNTY OF
Before me, the undersigned authority, personally appeared
‘who, being by me duly swom, deposed as follows:
My y nameis elallypse . tho : I am of sound mind, capable of making
herein stated.
this affidavit, and acquainted with the facts
.
I am a custodian of records for MEDICAL CENTER HOSPITAL - ODESSA
an itemized statemen t of the service and
Attached to this affidavit are billing records that provide
provided to
the charge for the service that MEDICAL CENTER HOSPITAL - ODESSA
BARBARA DALBY on the dates reflected in the attached billing records. The attached billing
records are a part of this affidavit.
The attached billing records are kept by MEDICAL CENTER HOSPITAL - ODESSA
in the regular course of business, and it was the regular course of business of MEDICAL
CENTER HOSPITAL - ODESSA for an employee or representative of MEDICAL CENTER
HOSPITAL - ODESSA, with knowledge of the service provided, to make the record or to
transmit information to be included in the record. The records were made in the regular course of
business at or near the time or reasonably soon after the time the service was provided. The
billing recordsare the original or a duplicate of the original.
The services provided were necessary and the amount charged for the services was
reasonable at the time and place that the services were provided.
The total amount PAID for the services was $. 11. $S , and the amount currently
unpaid but which MEDICAL CENTER HOSPITAL - ODESSA has a RIGHT TO BE PAID
after any adjustments
or credits is $ Z.,| 22. 0!
Uo
SWORN_TO AND _— by an
on this the day of.
ic, State of Texas
.
SUV AUa, GLYNA A WILLIAMS-MONTEMAYOR
ee
ss)
a
Notary Public, State of Texss|
"Age “Noun
0 tame.
MCHS FAXSERVER 12/20) pee i 22 1. aM ;PAGE 4£/4005\__Fax Server
CAL RECORD —M OD
Te
me
_THESEATE. OF TEXAS 4
' COUNTY OF ECTO toa "
Before me, ustertigned al AMANDA MANCHA
who; being by:ine. ‘sworn, dep:
-My name is. ‘AMANDA MANCHA ; and’ am over eighteen 18) ears of age, of
‘sound mind, capable. of making ‘this’ acquainted ‘the facts herein
vi 1 am. the re 5 “oustodian fr. MEDICAL [HOSEITAL ODESSA.
hereto. ‘pages medical reeérds, for ARB These.
of records 7 iy MED ESSA. inthe: regular
‘course
of business, and the regi.
HOSPITAL. ~ ODESSA for'an employee;6; Tepies dootor-péermitted to practice
in said
swith ‘personal, knowledge ‘of the act, event, ondition recorded to make. the
randum orrecord or-to transmit information theréof to-be included in such memorandum
record; and the memGrandum: 6r. record was made. at. a eee
ition recorded:or. sonably soan thereafter.
The service. wes necessary
and the, charged Ice, WAS
reat able. at the time and ‘place; that ‘SCKVICe
. Was 'p! ‘The-records
attaphed hereto are
ext duplicates. of. the originals,. it’ e tule. of MEDICAL: CENTER HOSPITAL«
LODESSA:to not: perme the originals, the office.
ror. Wanthe
aa. TO,AND SUBSCRIBED, BEFORE ME?:by: AMANDA MANCHA.
on ithis the. of-_. DECEMBER 5 2022.
4
i
Mn uMan (UL Ve
ary Public, State of ‘Texas.
te
"ama WILUAMS.M0)
35
oF S| tary Public,
No
Stato of Texa
‘Comm, eon 01-29.2025 s
ae = 2808266
na
i
a
~
\ww/
MEDICAL LAF = F OD) AL
THE STATE OF TEXAS §
COUNTY OF §
Before me, the undersigned authority, personally appeared One Sannor_
who, being by me duly sworn, deposed as follows:
My name is . Lam ofsound mind, capable of making
this affidavit, and perso: lly acquainted with the facts herein stated.
Jam a custodian of records for CITY OF ODESSA FIRE-EMS. Attached to this
affidavit are billing records that provide an itemized statement ofthe service and the charge for
the service that CITY OF ODESSA FIRE-EMS provided to BARBARA DALBY on the dates
reflected in the attached billing records. The attached billing records are a part of this affidavit.
The attached billing records are kept by CITY OF ODESSA FIRE-EMS in the regular
course of business, and it was the regular course of business of CITY OF ODESSA FIRE-EMS
for an employee or representative of CITY OF ODESSA FIRE-EMS, with knowledge of the
service provided, to make the record or to transmit information to be included in the record. The
records were made in the regular course of business at or near the time or reasonably soon after
the time the service was provided. The billing records are the original or a duplicate of the
original.
The services provided were necessary and the amount charged for the services was
reasonable at the time and place that the services were provided.
The total amount PAID for the services was $, | RS and the amount currently
unpaid but which CITY OF OD. A FIRE-EMS has a RIGHT TO BE PAID after any
adjustments or credits is $. .
Chul Sumo
SWORN TO AND SUBSCRIBED BEFORE ME by -Coystal Samora.
on this the dayof 2022.
wt pm, Wathdin
a
tate
Mitty, JESSICA WATKINS
lotary Public, State of Texas} Public, State of Texas
Comm. Expires 11-22-2025
“aia Notary ID 13345833-7
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.
Envelope ID: 78910381
Filing Code Description: Affidavit
Filing Description: PLAINTIFF'S NOTICE OF FILING OF MEDICAL
AFFIDAVITS
Status as of 8/25/2023 9:42 AM CST
Associated Case Party: BARBARA DALBY
Name BarNumber | Email TimestampS ubmitted Status
Daryl L.Derryberry did@ dzwlaw.com 8/25/2023 9:32:48 AM SENT
Stace Thiem stacie@ dzwlaw.com 8/25/2023 9:32:48 AM SENT
Tom Reardon treardon@ goudarzi-young.com 8/25/2023 9:32:48 AM SENT
Brent Goudarzi goudarziyoung@ goudarzi-young.com | 8/25/2023 9:32:48 AM SENT
Case Contacts
Name BarNumber | Email TimestampSubmitted Status
Douglas DF letcher sheila.landua@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT
Rosa Lavin rosa.lavin@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT
Deborah Stick deborah.stick@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT
Sandra Mireles sandra.mireles@ keanmiller.com 8/25/2023 9:32:48 AM SENT
Megan Reinkemeyer megan.reinkemeyer@ keanmiller.com 8/25/2023 9:32:48 AM SENT
Alexandra Griffiths alexandra.griffiths
@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT
DARYL DERRYBERRY did@ dzwlaw.com 8/25/2023 9:32:48 AM SENT
J effrey Smith jeffrey.smith@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT
Joe) Harrison joe.harrison@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT
Karina Ragha karina.ragha@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT
Associated Case Party: HUNT OIL COMPANY
Name BarNumber | Email TimestampS ubmitted Status
William MToles wtoles@ munsch.com 8/25/2023 9:32:48 AM SENT
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.
Envelope ID: 78910381
Filing Code Description: Affidavit
Filing Description: PLAINTIFF'S NOTICE OF FILING OF MEDICAL
AFFIDAVITS
Status as of 8/25/2023 9:42 AM CST
Associated Case Party: HUNT OIL COMPANY
Kelly Wise kwise@ munsch.com 8/25/2023 9:32:48 AM SENT
Alex Mahachek amahachek@ munsch.com 8/25/2023 9:32:48 AM SENT
Scott L.Zimmer scott.zimmer@ keanmiller.com 8/25/2023 9:32:48 AM SENT
Deondrey Evans DEvans@ munsch.com 8/25/2023 9:32:48 AM SENT
Christopher C.White chris.white@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT
Katherine Compton katherine.compton@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT
Terre Meza terre.meza@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT
J eanette Adams jeanette.adams@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT
Michael Lilley michael.lilley@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT
Yolanda White Y olanda.White@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT
SJ Eservice DAL.E-Service@ Steptoe-| ohnson.com 8/25/2023 9:32:48 AM SENT
Preview
l 8/25/2023 9:32 AM FELICIA PITRE DISTRICT CLERK ww DALLAS CO., TEXAS Rosa Delacerda DEPUTY CAUSE NO. DC-21-11344 BARBARA DALBY IN THE DISTRICT COURT OF Plaintiff, v. 116TH JUDICIAL DISTRICT HUNT OIL COMPANY AND MIKEAL CROSSON Defendants. DALLAS COUNTY, TEXAS PLAINTIFF’S NOTICE OF FILING OF MEDICAL AFFIDAVITS TO THE HONORABLE JUDGE OF SAID COURT: Pursuant to Rule 902(10)(a) of the Texas Rules of Evidence and Section 18.001 of the Texas Civil Practice and Remedies Code, you are hereby notified that Plaintiff, Barbara Dalby, has filed in the above-numbered and entitled cause business records affidavits as executed by their custodians of record, for the following entities: 1 Medical Bill Affidavit - Medical Center Hospital - Odessa 2 Medical Record Affidavit - Medical Center Hospital - Odessa 3 Medical Bill Affidavit — City of Odessa Fire - EMS These medical and billing records may be offered in evidence on the trial of the above- captioned cause. The affidavits are filed pursuant to Rule 902(10)(a) of the Texas Rules of Evidence and Section 18.001 of the Texas Civil Practice and Remedies Code. The affidavits and the underlying medical and billing records have been served on counsel of record for Defendants concurrently with the filing of this Notice. Page 1 Respectfully submitted. GOUDARZI & YOUNG, L.L.P P. O. Drawer 910 Gilmer, Texas oa Telephone: Me 544 Facsimile: 2026 EService:goudar/ / 7 darzi-young.com By ent iL ‘tate Bar No. 0 E Marty Young State Bar No. 24010502 ATTORNEYS FOR PLAINTIFF Page 2 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Plaintiff's Notice of Filing Medical Affidavits was forwarded to the following counsel of record for Defendants by E-serve this 25" day of August, 2023 Scott Zimmer Megan Reinkemeyer Kean Miller LLP 711 Louisiana Street, Suite 1800 Houston, Texas 77002 William M. Toles Kelly E. Wise Munsch Hardt Kopf & Harr, P.C. 500 N. Akard, Suite 3800 Dallas, Texas 75201 Douglas Fletcher Jeffrey Smith Joseph Harrison LU Fletcher, Farley, Shipman & Salinas, LLP 9201 N. Central Expressway, Suite 600 Dallas, Texas 75231 [rious | Page 3 [ED Fm —MED NTER AL,- OD! THE STATE OF TEXAS § COUNTY OF Before me, the undersigned authority, personally appeared ‘who, being by me duly swom, deposed as follows: My y nameis elallypse . tho : I am of sound mind, capable of making herein stated. this affidavit, and acquainted with the facts . I am a custodian of records for MEDICAL CENTER HOSPITAL - ODESSA an itemized statemen t of the service and Attached to this affidavit are billing records that provide provided to the charge for the service that MEDICAL CENTER HOSPITAL - ODESSA BARBARA DALBY on the dates reflected in the attached billing records. The attached billing records are a part of this affidavit. The attached billing records are kept by MEDICAL CENTER HOSPITAL - ODESSA in the regular course of business, and it was the regular course of business of MEDICAL CENTER HOSPITAL - ODESSA for an employee or representative of MEDICAL CENTER HOSPITAL - ODESSA, with knowledge of the service provided, to make the record or to transmit information to be included in the record. The records were made in the regular course of business at or near the time or reasonably soon after the time the service was provided. The billing recordsare the original or a duplicate of the original. The services provided were necessary and the amount charged for the services was reasonable at the time and place that the services were provided. The total amount PAID for the services was $. 11. $S , and the amount currently unpaid but which MEDICAL CENTER HOSPITAL - ODESSA has a RIGHT TO BE PAID after any adjustments or credits is $ Z.,| 22. 0! Uo SWORN_TO AND _— by an on this the day of. ic, State of Texas . SUV AUa, GLYNA A WILLIAMS-MONTEMAYOR ee ss) a Notary Public, State of Texss| "Age “Noun 0 tame. MCHS FAXSERVER 12/20) pee i 22 1. aM ;PAGE 4£/4005\__Fax Server CAL RECORD —M OD Te me _THESEATE. OF TEXAS 4 ' COUNTY OF ECTO toa " Before me, ustertigned al AMANDA MANCHA who; being by:ine. ‘sworn, dep: -My name is. ‘AMANDA MANCHA ; and’ am over eighteen 18) ears of age, of ‘sound mind, capable. of making ‘this’ acquainted ‘the facts herein vi 1 am. the re 5 “oustodian fr. MEDICAL [HOSEITAL ODESSA. hereto. ‘pages medical reeérds, for ARB These. of records 7 iy MED ESSA. inthe: regular ‘course of business, and the regi. HOSPITAL. ~ ODESSA for'an employee;6; Tepies dootor-péermitted to practice in said swith ‘personal, knowledge ‘of the act, event, ondition recorded to make. the randum orrecord or-to transmit information theréof to-be included in such memorandum record; and the memGrandum: 6r. record was made. at. a eee ition recorded:or. sonably soan thereafter. The service. wes necessary and the, charged Ice, WAS reat able. at the time and ‘place; that ‘SCKVICe . Was 'p! ‘The-records attaphed hereto are ext duplicates. of. the originals,. it’ e tule. of MEDICAL: CENTER HOSPITAL« LODESSA:to not: perme the originals, the office. ror. Wanthe aa. TO,AND SUBSCRIBED, BEFORE ME?:by: AMANDA MANCHA. on ithis the. of-_. DECEMBER 5 2022. 4 i Mn uMan (UL Ve ary Public, State of ‘Texas. te "ama WILUAMS.M0) 35 oF S| tary Public, No Stato of Texa ‘Comm, eon 01-29.2025 s ae = 2808266 na i a ~ \ww/ MEDICAL LAF = F OD) AL THE STATE OF TEXAS § COUNTY OF § Before me, the undersigned authority, personally appeared One Sannor_ who, being by me duly sworn, deposed as follows: My name is . Lam ofsound mind, capable of making this affidavit, and perso: lly acquainted with the facts herein stated. Jam a custodian of records for CITY OF ODESSA FIRE-EMS. Attached to this affidavit are billing records that provide an itemized statement ofthe service and the charge for the service that CITY OF ODESSA FIRE-EMS provided to BARBARA DALBY on the dates reflected in the attached billing records. The attached billing records are a part of this affidavit. The attached billing records are kept by CITY OF ODESSA FIRE-EMS in the regular course of business, and it was the regular course of business of CITY OF ODESSA FIRE-EMS for an employee or representative of CITY OF ODESSA FIRE-EMS, with knowledge of the service provided, to make the record or to transmit information to be included in the record. The records were made in the regular course of business at or near the time or reasonably soon after the time the service was provided. The billing records are the original or a duplicate of the original. The services provided were necessary and the amount charged for the services was reasonable at the time and place that the services were provided. The total amount PAID for the services was $, | RS and the amount currently unpaid but which CITY OF OD. A FIRE-EMS has a RIGHT TO BE PAID after any adjustments or credits is $. . Chul Sumo SWORN TO AND SUBSCRIBED BEFORE ME by -Coystal Samora. on this the dayof 2022. wt pm, Wathdin a tate Mitty, JESSICA WATKINS lotary Public, State of Texas} Public, State of Texas Comm. Expires 11-22-2025 “aia Notary ID 13345833-7 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. Envelope ID: 78910381 Filing Code Description: Affidavit Filing Description: PLAINTIFF'S NOTICE OF FILING OF MEDICAL AFFIDAVITS Status as of 8/25/2023 9:42 AM CST Associated Case Party: BARBARA DALBY Name BarNumber | Email TimestampS ubmitted Status Daryl L.Derryberry did@ dzwlaw.com 8/25/2023 9:32:48 AM SENT Stace Thiem stacie@ dzwlaw.com 8/25/2023 9:32:48 AM SENT Tom Reardon treardon@ goudarzi-young.com 8/25/2023 9:32:48 AM SENT Brent Goudarzi goudarziyoung@ goudarzi-young.com | 8/25/2023 9:32:48 AM SENT Case Contacts Name BarNumber | Email TimestampSubmitted Status Douglas DF letcher sheila.landua@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT Rosa Lavin rosa.lavin@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT Deborah Stick deborah.stick@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT Sandra Mireles sandra.mireles@ keanmiller.com 8/25/2023 9:32:48 AM SENT Megan Reinkemeyer megan.reinkemeyer@ keanmiller.com 8/25/2023 9:32:48 AM SENT Alexandra Griffiths alexandra.griffiths @ fletcherfarley.com 8/25/2023 9:32:48 AM SENT DARYL DERRYBERRY did@ dzwlaw.com 8/25/2023 9:32:48 AM SENT J effrey Smith jeffrey.smith@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT Joe) Harrison joe.harrison@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT Karina Ragha karina.ragha@ fletcherfarley.com 8/25/2023 9:32:48 AM SENT Associated Case Party: HUNT OIL COMPANY Name BarNumber | Email TimestampS ubmitted Status William MToles wtoles@ munsch.com 8/25/2023 9:32:48 AM SENT 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. Envelope ID: 78910381 Filing Code Description: Affidavit Filing Description: PLAINTIFF'S NOTICE OF FILING OF MEDICAL AFFIDAVITS Status as of 8/25/2023 9:42 AM CST Associated Case Party: HUNT OIL COMPANY Kelly Wise kwise@ munsch.com 8/25/2023 9:32:48 AM SENT Alex Mahachek amahachek@ munsch.com 8/25/2023 9:32:48 AM SENT Scott L.Zimmer scott.zimmer@ keanmiller.com 8/25/2023 9:32:48 AM SENT Deondrey Evans DEvans@ munsch.com 8/25/2023 9:32:48 AM SENT Christopher C.White chris.white@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT Katherine Compton katherine.compton@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT Terre Meza terre.meza@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT J eanette Adams jeanette.adams@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT Michael Lilley michael.lilley@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT Yolanda White Y olanda.White@ steptoe-johnson.com 8/25/2023 9:32:48 AM SENT SJ Eservice DAL.E-Service@ Steptoe-| ohnson.com 8/25/2023 9:32:48 AM SENT