Preview
FILED
7/16/2020 3:40 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
pC-20-09420
CAUSE NO. DC-20-09420 Kari Malone DEPUTY
ROZ C. LYLES,INDIVIDUALLY
C. LYLES, AI\D AS
INDIVIDUALLY AND $
§ IN THE DISTRICT COURT
TIIE DISTRICT COT]RT
REPRESENTATIVE TIIE ESTATE OF
REPRESENTATIVE OF THE s
§
WILLIAM LYLES, DECEASED,
DECEASED, Kari Malone
s
§
Plaintiff(s),
Plaintiff(s), $
§
vs.
VS. s
§ 44T't JUDICIAL
44TH JTIDICIAL DISTRICT
SSCMCKIIINEY OPERATING COMPANY,
MCKINNEY COMPAIIY, s
§
LLC d/b/a IIEALTH AND
dlbla NORTH PARK HEALTH ANI) s
§
REHABILITATION CENTER,
REHABILITATION CENTE& et al.,
et al., s
§
Defendant(s).
Defendant(s). $
§ DALLAS CO[}NTY, TEXAS
DALLAS COUNTY,
RETURN
RETTTRN OF SERVICE
Came toto my hand on Monday, July 13,
Monday, July 13,2020 at 2:18
2020 at 2:18 PM,
1999 BRYAN STREET, SUITE 900,
at:1999
Executed at: DALLAS' TX 75201
900, DALLAS, 75201
within the
Within of DALLAS at
county of
the county at 11:55 July 14,
Tuesday, July
11:55 AM, on Tuesday, 14' 2020,
2020,
by delivering
by delivering to within named:
the within
to the
MPD OPERATORS BELTERRA HEALTH & REHAB
OPERATORS MCKINNEY, LLC D/B/A BELTERRA
By delivering
delivering to
to its Agent, CT CORPORATION SYSTEM
Registered Agent,
its Registered SYSTEM
-
personally delivering
By personally to its
delivering to its Authorized Agent, ANTOINETTE WILLIAMS
Authorized Agent,
true copy
a true of this
copy of this
ORIGINAL PETITION AND REQUEST
CITATION, PLAINTIFF'S ORIGINAL
CITATION, DISCLOSURE, AND
REQUEST FOR DISCLOSURE, ANI)
EXHIBIT A
EXHIBIT
having first endorsed
having first the date
thereon the
endorsed thereon of the
date of delivery.
the delivery.
BEFORE
BEFORE ME, the the undersigned authority, on this
undersigned authority, this day personally appeared
day personally Adil Tadli
appeared Adi] Tadli who
whci after duly sworn on oath
being duly
after being oath
states: "My name is
states: is Adi] Tadli. II am a person
Adil Tadli. not less
person not than eighteen
less than (18) years
eighteen (18) of age and II am
years of am competent to make this
competent to this
oath, II am
oath. of the
resident of
am aa resident the State
State of Texas. II have personal
of Texas. personal knowledge of of the
the facts
facts and statements
statements contained herein and
contained herein
aver'that each
avel’that each correct. II am not
true and correct.
is true
is party to
not aa party to nor
nor related
related or with any
affiliated with
or affiliated any party to this
party to suit. II have no interest
this suit. interest
in theoutcome of
'in the‘
butcome of the suit. II have never
the suit. never been convicted
convicted ofof a felony
felony or misdemeanor involving
of a misdemeanor
or of involving moral
moral turpitude.
turpitude. I am
I
familiar with
familiar with the
the Texas
Texas Rules
Rules ofof Civil
Civil Procedure,
Procedure, and the Texas
and the Civil Practice
Texas Civil and Remedies Codes as
Practice and they apply
as they apply toto
service of
service process. II am
of process. certified by
am certified by the
the Judicial Certification Commission to
Judicial Branch Cettification to deliver other notices
citations and other
deliver citations notices
from any
from District, County
any District, County and Justice in and for
Courts in
Justice Courts the State
for the of Texas in
State of with rule
in compliance with rule 103
103 and 501.2 of the
501.2 of the
TRCP."
'IRCP.”
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Adil Tadli-- Psc 1206
Adit Tadli 1206-- EMS‘IIS/zo
served@specialdelivery.com
served@specialdelivery.com
Subscribed and Sworn to
Subscribed to by Adit Tadli,
by Adi] Tadlin Before
Before Me, the
the undersigned authority, on
undersigned authority, this
this I@Uu,
1[Omday
of July,2020.
of July, 2020.
0 OD Notarv Public in and for the tate of Texas
Notary Public
SIATS 0F
STATE OF TEXAS
to# 13056732-6
low 13058732-B
Comma. March 17,2024 '
FORM NO. 353-3 CITATION -
12.513.337.12
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THE STATE OF TEXAS
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MPD OPERATORS MCKINNEY, LLC D/B/A BELTERRA HEALTH & REHAB
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SERVING REGISTERED AGENT CT CORPORATION SYSTEM
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DC-20-09420
1999 BRYAN ST SUITE 900
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DALLAS TEXAS 75201
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ROZ C LYLES
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GREETINGS:
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vs.
You have been sued. You may employ an attorney. your attorney d0 not file a written
If you 0r
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answer with the
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clerk Who issued this citation by 10
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expiration oftwenty days after you were served this citation and petition, a default judgment may be
taken against you. Your answer should be addressed to the clerk of the 44th District Court at 600
Commerce Street, Ste. 101, Dallas, Texas 75202.
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ISSUED THIS
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13th day of July, 2020
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Said Plaintiff being ROZ C. LYLES, INDIVIDUALLY AND AS REPRESENTATIVE OF THE ESTATE OF 'v/
8E
WILLIAM LYLES, DECEASED
ii
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FELICIA PITRE
Filed in said Court 10th
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7
day 0f July, 2020 against
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Clerk District Courts,
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Dallas County, Texas
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MCKINNEY OPERATING COMPANY, LLC D/B/A NORTH PARK HEALTH AND
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REHABILITATION CENTER, MPD OPERATORS MCKINNEY, LLC D/B/A BELTERRA HEALTH &
REHAB, ZAHID N. ZAFAR, M.D., MOBILE MD PA, MOSES J. KENG, JR, M.D. AND ALLEN J.
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FRAZIER, R.N. By: DANIEL MACIAS, Deputy
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For Suit, said suit being numbered DC-20-09420, the nature 0f which demand is as follows:
t
Suit on Attorney for Plaintiff
cs
MEDICAL MALPRACTICE etc. as shown on said petition REQUEST FOR DISCLOSURE, a
-,
copy 0f which accompanies this citation. If this citation is not served, it shall be returned unexecuted. MARIA L WORMINGTON
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WARMINGTON & BOLLINGER
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WITNESS: FELICIA PITRE, Clerk ofthe District Courts 0f Dallas, County Texas. 212 EAST VIRGINIA STREET
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Given under my hand and the Seal of said Court at office this 13th day ofJuly, 2020. MCKINNEY TX 75069
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ATTEST: FELICIA PITRE, Clerk of the District Courts of Dallas, County, Texas age
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OFFICER'S RETURN
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Case No. DC-20-09420‘
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Preview
FILED 7/16/2020 3:40 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS pC-20-09420 CAUSE NO. DC-20-09420 Kari Malone DEPUTY ROZ C. LYLES,INDIVIDUALLY C. LYLES, AI\D AS INDIVIDUALLY AND $ § IN THE DISTRICT COURT TIIE DISTRICT COT]RT REPRESENTATIVE TIIE ESTATE OF REPRESENTATIVE OF THE s § WILLIAM LYLES, DECEASED, DECEASED, Kari Malone s § Plaintiff(s), Plaintiff(s), $ § vs. VS. s § 44T't JUDICIAL 44TH JTIDICIAL DISTRICT SSCMCKIIINEY OPERATING COMPANY, MCKINNEY COMPAIIY, s § LLC d/b/a IIEALTH AND dlbla NORTH PARK HEALTH ANI) s § REHABILITATION CENTER, REHABILITATION CENTE& et al., et al., s § Defendant(s). Defendant(s). $ § DALLAS CO[}NTY, TEXAS DALLAS COUNTY, RETURN RETTTRN OF SERVICE Came toto my hand on Monday, July 13, Monday, July 13,2020 at 2:18 2020 at 2:18 PM, 1999 BRYAN STREET, SUITE 900, at:1999 Executed at: DALLAS' TX 75201 900, DALLAS, 75201 within the Within of DALLAS at county of the county at 11:55 July 14, Tuesday, July 11:55 AM, on Tuesday, 14' 2020, 2020, by delivering by delivering to within named: the within to the MPD OPERATORS BELTERRA HEALTH & REHAB OPERATORS MCKINNEY, LLC D/B/A BELTERRA By delivering delivering to to its Agent, CT CORPORATION SYSTEM Registered Agent, its Registered SYSTEM - personally delivering By personally to its delivering to its Authorized Agent, ANTOINETTE WILLIAMS Authorized Agent, true copy a true of this copy of this ORIGINAL PETITION AND REQUEST CITATION, PLAINTIFF'S ORIGINAL CITATION, DISCLOSURE, AND REQUEST FOR DISCLOSURE, ANI) EXHIBIT A EXHIBIT having first endorsed having first the date thereon the endorsed thereon of the date of delivery. the delivery. BEFORE BEFORE ME, the the undersigned authority, on this undersigned authority, this day personally appeared day personally Adil Tadli appeared Adi] Tadli who whci after duly sworn on oath being duly after being oath states: "My name is states: is Adi] Tadli. II am a person Adil Tadli. not less person not than eighteen less than (18) years eighteen (18) of age and II am years of am competent to make this competent to this oath, II am oath. of the resident of am aa resident the State State of Texas. II have personal of Texas. personal knowledge of of the the facts facts and statements statements contained herein and contained herein aver'that each avel’that each correct. II am not true and correct. is true is party to not aa party to nor nor related related or with any affiliated with or affiliated any party to this party to suit. II have no interest this suit. interest in theoutcome of 'in the‘ butcome of the suit. II have never the suit. never been convicted convicted ofof a felony felony or misdemeanor involving of a misdemeanor or of involving moral moral turpitude. turpitude. I am I familiar with familiar with the the Texas Texas Rules Rules ofof Civil Civil Procedure, Procedure, and the Texas and the Civil Practice Texas Civil and Remedies Codes as Practice and they apply as they apply toto service of service process. II am of process. certified by am certified by the the Judicial Certification Commission to Judicial Branch Cettification to deliver other notices citations and other deliver citations notices from any from District, County any District, County and Justice in and for Courts in Justice Courts the State for the of Texas in State of with rule in compliance with rule 103 103 and 501.2 of the 501.2 of the TRCP." 'IRCP.” 44%» Adil Tadli-- Psc 1206 Adit Tadli 1206-- EMS‘IIS/zo served@specialdelivery.com served@specialdelivery.com Subscribed and Sworn to Subscribed to by Adit Tadli, by Adi] Tadlin Before Before Me, the the undersigned authority, on undersigned authority, this this I@Uu, 1[Omday of July,2020. of July, 2020. 0 OD Notarv Public in and for the tate of Texas Notary Public SIATS 0F STATE OF TEXAS to# 13056732-6 low 13058732-B Comma. March 17,2024 ' FORM NO. 353-3 CITATION - 12.513.337.12 r.-rl ct atF >t THE STATE OF TEXAS Z in c4IF: 3 Er ‘ CITATION T0: n MPD OPERATORS MCKINNEY, LLC D/B/A BELTERRA HEALTH & REHAB !l SERVING REGISTERED AGENT CT CORPORATION SYSTEM I I al U '+ GI DC-20-09420 1999 BRYAN ST SUITE 900 ? DALLAS TEXAS 75201 E-,= fr? FgiI 2F,= ROZ C LYLES 3 GREETINGS: -Lc-9L vs. You have been sued. You may employ an attorney. your attorney d0 not file a written If you 0r \., a U) z, iZ U Z (, SSC v6 MCKINNEY OPERATING COMPANY, AJ = answer with the gE U; --- =-i clerk Who issued this citation by 10 o'clock a.m. of the Monday next following the = X \J-i otFe 3,&a al utt LLCet expiration oftwenty days after you were served this citation and petition, a default judgment may be taken against you. Your answer should be addressed to the clerk of the 44th District Court at 600 Commerce Street, Ste. 101, Dallas, Texas 75202. qE ii€: l:;: f;g;; ISSUED THIS lEl €Fg: -.c F ulo i ql 13th day of July, 2020 F= : ) >, o,_ lL Said Plaintiff being ROZ C. LYLES, INDIVIDUALLY AND AS REPRESENTATIVE OF THE ESTATE OF 'v/ 8E WILLIAM LYLES, DECEASED ii 7 i€gi q FELICIA PITRE Filed in said Court 10th il 7 day 0f July, 2020 against -6o Clerk District Courts, g :l7!O LL(J? gft Dallas County, Texas <== EzF SSC uDx P=,6 MCKINNEY OPERATING COMPANY, LLC D/B/A NORTH PARK HEALTH AND uo d;-E REHABILITATION CENTER, MPD OPERATORS MCKINNEY, LLC D/B/A BELTERRA HEALTH & REHAB, ZAHID N. ZAFAR, M.D., MOBILE MD PA, MOSES J. KENG, JR, M.D. AND ALLEN J. a J 9 q A = z. + rJ FRAZIER, R.N. By: DANIEL MACIAS, Deputy ii. i-i iiFE For Suit, said suit being numbered DC-20-09420, the nature 0f which demand is as follows: t Suit on Attorney for Plaintiff cs MEDICAL MALPRACTICE etc. as shown on said petition REQUEST FOR DISCLOSURE, a -, copy 0f which accompanies this citation. If this citation is not served, it shall be returned unexecuted. MARIA L WORMINGTON lgg r.r WARMINGTON & BOLLINGER - z<_ BN WITNESS: FELICIA PITRE, Clerk ofthe District Courts 0f Dallas, County Texas. 212 EAST VIRGINIA STREET fritt Given under my hand and the Seal of said Court at office this 13th day ofJuly, 2020. MCKINNEY TX 75069 q; uFZPc o3=:= 972—569-3930 % I; - : H s: x > z s- 5 F=XxxR E : rIEgFg E3 I lig; ;=i rII n; E=ii -riE;g rt i >?;='i: ;; : maria@wormingtonlegal.com .EtiZF_-ry E:Z? I 6) €g:p;ilH ATTEST: FELICIA PITRE, Clerk of the District Courts of Dallas, County, Texas age x /— a FIE II H * ' / L i“ I=EEgriilllai;,*a , Deputy J tF EsE# q iia iEi iF*i By | g? W its;€s,!aigiiEiEtEil= . z Eer= iE€gf :ei=;i E!t:rs'-l^ z <‘ , fix iIJi ei EN DAMEL MACIAS g , “$5? wk}; awe» :9“ fizfi‘lg: , =ii E3E .%*'w ia ,'E ffi fmmgwm ffi tr fiékmg 6333?"? **ffi 4sB EERWCE FEE$ d#$s $ffiffi *ffiffi Sffie sSF* Ra? Ffii’fi L' It r- (-. L. -rt tv. V) r--l rl. Z (.) OFFICER'S RETURN ^t : TJ Case No. DC-20-09420‘ -':-:th NV 6ar, JJ=V \J(ra ..sN oq4 ',i E = ;z& Court No.44th District Court 3 =+ Style: ROZ C LYLES vs. rl a rtl U) J J z (J F ri Z 7 U EI r-\ Z U b O SSC MCKINNEY OPERATING COMPANY, LLCet al ; ; d 2 6 E U cG to I_o hand on the X - @ Came o'clock i; day of ,