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FILED
11/10/2020 1:14 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
John P White DEPUTY
CAUSE NO. DC—20-12372
SELENA HERNANDEZ,
Plaintiff IN THE DISTRICT COURT
vs. DALLAS COUNTY, TEXAS
BRIAN WOLFE AND MIDWAY AUTO 193“” JUDICIAL DISTRICT
SUPPLY, INC.,
Defendant
PLAINTIFF SELENA HERNANDEZ’S NOTICE OF FILING AFFIDAVITS
TO: Defendant, Midway Auto Supply, Inc., by and through her attorney of record, Adam B.
LeCrone, The LeCrone Law Firm, PC, 123 North Crockett Street, Suite 200, Sherman, TX
75090.
You are hereby notied that Plaintiff, Selena Hernandez, has led in the above entitled and
numbered cause, the following records, pursuant to Chapter 18 of the Texas Civil Practice &
Remedies Code and Rule 902 of the Texas Rules of Evidence:
1. Accident & Injury Chiropractic (Billing)
These records (or portions thereof) will be offered as evidence at the trial on the merits ofthis
case .
Plaintiff’s Notice of Flling Affidavits Page 1
DATE; November 10 , 2020
'tate Bar N0. 116 8563
Lavern D. Richards, Jr.
State Bar N0. 2400791 0
DAVID S. KOHM & ASSOCIATES
1414 W. Randol Mill Road, Suite 118
Arlington, Texas 76012
Tel: (81 7) 226—8100 Fax: (817) 200-01 11
Email: lit-ele@attorneykohm.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE QF SERVICE
Ihereby certify that on this 10th day of November , 2020 a true and correct copy of
the above and foregoing document was served via (as indicated below):
Via E-Filer Service
Adam B. LeCrone
The LeCrone Law Firm, PC
123 North Crockett Street, Suite 200
Sherman, TX 75090
(903)813-1900
(903)813-1944 facsimile
eservice®lecronelaw.com
ATTORNEYS FOR DEFENDANT(S)
ATTORNEY FOR PLAINTIFF
Plaintiff’s Notice of Filing Affidavits Page 2
) Cause No:
)
)
Plaintiff, ) IN THE DISTRICT COURT or
)
VS. ) DALLAS COUNTI, TEXAS
)
)
)
Defendant, )
AFFIDAVIT REGARDING MEDICAL EXPENSES
(Tex. Civ. Prac. & Rem. Code, Sec. 18.002(b—1)
Before me, the undersigned authority, on this day personally appeared DR.
lO LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows:
ll My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of
making this affidavit, and personally acquainted with the facts herein
12
stated:
I am the custodian of billing records for ACCIDENT & INJURY CHIROPRACTIC.
l3 Attached to this affidavit are records that provide an itemized statement of
the service(s)and charge(s) for the service(s) that ACCIDENT a INJURY
14 CHIROPRACTIC provided to SELENA HERNANDEZ from 04/11/2019 THRU 09/05/2019.
The attached records are a part of this affidavit.
15
The attached records are kept by ACCIDENT & INJURX CHIROPRACTIC in the
16 regular courseof business, and it was the regular course of business of
ACCIDENT & INJURY CHIROPRACTIC for an employee or representative of ACCIDENT
a INJURY CHIROPRACTIC with knowledge of the service provided, to make the
17 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
18 soon after the time the service was provided. The records are a duplicate of
the original.
19
The services provided were necessary and the amount charged for the
20
services was reasonable at the time and place that the services were
provided.
21 The total amount paid for the services was $0.00 and the amount currently
unpaid but which ACCIDENT a INJURY CHIROPRACTIC has a right to be paid after
22 any adjustments or credits is $11,545.00. This amount may include a Records
Summary Report fee of $150.00.
23
24
25
FIANTtCustodian Of Records)
SWORN TO AND SUBSCRIBED before me on the Z
0 day
Notary Pu lie, State of Texas
Notary's printed name and
commission expires : 05-13—2023
um SALINAS
My Notary
in 1; 130225330
2023
Expires May 13.
10
ll
12
l3
l4
l5
l6
17
18
l9
20
21
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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.
Taylor Brown on behalf of David Kohm
Bar No. 11658563
taylorb@attorneykohm.com
Envelope ID: 47971457
Status as of 1 1/1 1/2020 9:37 AM CST
Associated Case Party: MIDWAY AUTO SUPPLY INC
Name BarNumber Email TimestampSubmitted Status
Adam LeCrone eservice@lecronelaw.com 11/1 0/2020 1:14:39 PM SENT
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FILED 11/10/2020 1:14 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS John P White DEPUTY CAUSE NO. DC—20-12372 SELENA HERNANDEZ, Plaintiff IN THE DISTRICT COURT vs. DALLAS COUNTY, TEXAS BRIAN WOLFE AND MIDWAY AUTO 193“” JUDICIAL DISTRICT SUPPLY, INC., Defendant PLAINTIFF SELENA HERNANDEZ’S NOTICE OF FILING AFFIDAVITS TO: Defendant, Midway Auto Supply, Inc., by and through her attorney of record, Adam B. LeCrone, The LeCrone Law Firm, PC, 123 North Crockett Street, Suite 200, Sherman, TX 75090. You are hereby notied that Plaintiff, Selena Hernandez, has led in the above entitled and numbered cause, the following records, pursuant to Chapter 18 of the Texas Civil Practice & Remedies Code and Rule 902 of the Texas Rules of Evidence: 1. Accident & Injury Chiropractic (Billing) These records (or portions thereof) will be offered as evidence at the trial on the merits ofthis case . Plaintiff’s Notice of Flling Affidavits Page 1 DATE; November 10 , 2020 'tate Bar N0. 116 8563 Lavern D. Richards, Jr. State Bar N0. 2400791 0 DAVID S. KOHM & ASSOCIATES 1414 W. Randol Mill Road, Suite 118 Arlington, Texas 76012 Tel: (81 7) 226—8100 Fax: (817) 200-01 11 Email: lit-ele@attorneykohm.com ATTORNEYS FOR PLAINTIFF CERTIFICATE QF SERVICE Ihereby certify that on this 10th day of November , 2020 a true and correct copy of the above and foregoing document was served via (as indicated below): Via E-Filer Service Adam B. LeCrone The LeCrone Law Firm, PC 123 North Crockett Street, Suite 200 Sherman, TX 75090 (903)813-1900 (903)813-1944 facsimile eservice®lecronelaw.com ATTORNEYS FOR DEFENDANT(S) ATTORNEY FOR PLAINTIFF Plaintiff’s Notice of Filing Affidavits Page 2 ) Cause No: ) ) Plaintiff, ) IN THE DISTRICT COURT or ) VS. ) DALLAS COUNTI, TEXAS ) ) ) Defendant, ) AFFIDAVIT REGARDING MEDICAL EXPENSES (Tex. Civ. Prac. & Rem. Code, Sec. 18.002(b—1) Before me, the undersigned authority, on this day personally appeared DR. lO LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows: ll My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of making this affidavit, and personally acquainted with the facts herein 12 stated: I am the custodian of billing records for ACCIDENT & INJURY CHIROPRACTIC. l3 Attached to this affidavit are records that provide an itemized statement of the service(s)and charge(s) for the service(s) that ACCIDENT a INJURY 14 CHIROPRACTIC provided to SELENA HERNANDEZ from 04/11/2019 THRU 09/05/2019. The attached records are a part of this affidavit. 15 The attached records are kept by ACCIDENT & INJURX CHIROPRACTIC in the 16 regular courseof business, and it was the regular course of business of ACCIDENT & INJURY CHIROPRACTIC for an employee or representative of ACCIDENT a INJURY CHIROPRACTIC with knowledge of the service provided, to make the 17 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 18 soon after the time the service was provided. The records are a duplicate of the original. 19 The services provided were necessary and the amount charged for the 20 services was reasonable at the time and place that the services were provided. 21 The total amount paid for the services was $0.00 and the amount currently unpaid but which ACCIDENT a INJURY CHIROPRACTIC has a right to be paid after 22 any adjustments or credits is $11,545.00. This amount may include a Records Summary Report fee of $150.00. 23 24 25 FIANTtCustodian Of Records) SWORN TO AND SUBSCRIBED before me on the Z 0 day Notary Pu lie, State of Texas Notary's printed name and commission expires : 05-13—2023 um SALINAS My Notary in 1; 130225330 2023 Expires May 13. 10 ll 12 l3 l4 l5 l6 17 18 l9 20 21 22 23 24 25 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. Taylor Brown on behalf of David Kohm Bar No. 11658563 taylorb@attorneykohm.com Envelope ID: 47971457 Status as of 1 1/1 1/2020 9:37 AM CST Associated Case Party: MIDWAY AUTO SUPPLY INC Name BarNumber Email TimestampSubmitted Status Adam LeCrone eservice@lecronelaw.com 11/1 0/2020 1:14:39 PM SENT