On July 10, 2020 a
Party Discovery
was filed
involving a dispute between
Lyles, Roz C,
and
Frazier, Allen J, Rn,
Keng, Jr., Moses J, Md,
Mobile Md Pa,
Mpd Operators Mckinney, Llc,
Ssc Mckinney Operating Company, Llc,
Zafar, Zahid N, Md,
for MEDICAL MALPRACTICE
in the District Court of Dallas County.
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FILED
11/12/2020 8:05 AM
FELICIA PITRE
DISTRICT CLERK
L E XI TA S Miri‘héni’bé’
E
325 N. St. Paul Street
Suite 1900
Dallas, TX 75201
800-497-7618
800-311-8300 (fax)
CLERK OF THE 44TH JUDICIAL DISTRICT COURT
600 COMMERCE STREET
5TH FLOOR
DALLAS TX, 75202
CAUSE NO. DC—20-09420
ROZ C. LYLES, INDIVIDUALLY AND AS THE DISTRICT COURT
W
IN
REPRESENTATIVE OF THE ESTATE OF
WILLIAM LYLES, DECEASED DALLAS COUNTY, TEXAS
VS
SSC MCKINNEY OPERATING COMPANY, LLC
D/B/A NORTH PARK HEALTH AND
REHABILITATION CENTER; MPD OPERATORS
MCKINNEY, LLC D/B/A BELTERRA HEALTH
& REHAB; ZAHID A. ZAFAR, M.D.; MOBILE AND
PA; MOSES J. KENG, JR, M.D. AND ALLEN J.
FRAZIER, R.N.M.D. 44TH JUDICIAL DISTRICT
Regarding Deposition by Written Questions
Directed to the Custodian of Records for: MEDICAL CITY MCKINNEY
Pertaining to WILLIAM LVLES
The witness was duly sworn and the transcript attached is a true record of the testimony given by the witness. The deposition was signed by
the witness and returned on 11/11/2020. Changes made by the witness, if any, in the transcript are attached or incorporated hereto. The
original deposition transcript, together with copies of all exhibits, were provided to the attorney or party who asked the first questior
appearing in the transcript for safekeeping and use at trial. The charges for the preparation of the completed deposition transcript and any
copies of the exhibits are to be paid for by the attorney for the Defendant and total $352.56.
Attorneys of Record follow:
KIMBERLY SUSAN MARIA HEATHER
CORMIER COOLEY WORMINGTON KANNY
kcormier@thetexasrm.com scooley@schellcooley.com maria@wormingtonlegal.com hkanny@mayerllp.com
|
certify that a true and correct copy of the foregoing instrument was mailed to the respective parties attorneys of record,
postage prepaid, was hand delivered, or transmitted by facsimile. -
j
AFFIANT U
mm}
ISM
Y P of, CHERI COLLEEN SHEE-
"
.Natary Public. 513:9 of 78x35
' Comm. SWORN TO AND SUBSCRIBED BEFORE ME ON 11/12/2020
Expires 1142-2020
‘I h.-
t \
”m 1m“
I
Notary ED 2092-115 1
Notary Public in and for
The State of Texas
91147-1-726678
Document Filed Date
November 12, 2020
Case Filing Date
July 10, 2020
Category
MEDICAL MALPRACTICE
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FILED 11/12/2020 8:05 AM FELICIA PITRE DISTRICT CLERK L E XI TA S Miri‘héni’bé’ E 325 N. St. Paul Street Suite 1900 Dallas, TX 75201 800-497-7618 800-311-8300 (fax) CLERK OF THE 44TH JUDICIAL DISTRICT COURT 600 COMMERCE STREET 5TH FLOOR DALLAS TX, 75202 CAUSE NO. DC—20-09420 ROZ C. LYLES, INDIVIDUALLY AND AS THE DISTRICT COURT W IN REPRESENTATIVE OF THE ESTATE OF WILLIAM LYLES, DECEASED DALLAS COUNTY, TEXAS VS SSC MCKINNEY OPERATING COMPANY, LLC D/B/A NORTH PARK HEALTH AND REHABILITATION CENTER; MPD OPERATORS MCKINNEY, LLC D/B/A BELTERRA HEALTH & REHAB; ZAHID A. ZAFAR, M.D.; MOBILE AND PA; MOSES J. KENG, JR, M.D. AND ALLEN J. FRAZIER, R.N.M.D. 44TH JUDICIAL DISTRICT Regarding Deposition by Written Questions Directed to the Custodian of Records for: MEDICAL CITY MCKINNEY Pertaining to WILLIAM LVLES The witness was duly sworn and the transcript attached is a true record of the testimony given by the witness. The deposition was signed by the witness and returned on 11/11/2020. Changes made by the witness, if any, in the transcript are attached or incorporated hereto. The original deposition transcript, together with copies of all exhibits, were provided to the attorney or party who asked the first questior appearing in the transcript for safekeeping and use at trial. The charges for the preparation of the completed deposition transcript and any copies of the exhibits are to be paid for by the attorney for the Defendant and total $352.56. Attorneys of Record follow: KIMBERLY SUSAN MARIA HEATHER CORMIER COOLEY WORMINGTON KANNY kcormier@thetexasrm.com scooley@schellcooley.com maria@wormingtonlegal.com hkanny@mayerllp.com | certify that a true and correct copy of the foregoing instrument was mailed to the respective parties attorneys of record, postage prepaid, was hand delivered, or transmitted by facsimile. - j AFFIANT U mm} ISM Y P of, CHERI COLLEEN SHEE- " .Natary Public. 513:9 of 78x35 ' Comm. SWORN TO AND SUBSCRIBED BEFORE ME ON 11/12/2020 Expires 1142-2020 ‘I h.- t \ ”m 1m“ I Notary ED 2092-115 1 Notary Public in and for The State of Texas 91147-1-726678