Preview
FILED
8/22/2023 9:47 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS 00., TEXAS
Ricky Brashear DEPUTY
Cause No. DC-23-01413
HIWOT MIRACH, Individually and as Next § IN THE DISTRICT COURT OF
Friend of N.S and A.B., minors §
Plaintiffiv §
§ 298th JUDICIAL DISTRICT
V. §
§
JULIO ANTONIO VICENTE RODAS § DALLAS COUNTY, TEXAS
Defendant §
PLAINTIFFS’ WITNESS LIST
TO THE HONORABLE JUDGE OF SAID COURT:
Plaintiffs provide this Witness List which identifies the persons they will or may call at
the time of trial. This Witness List identifies the persons Plaintiffs expect to present at the time
of trial or may call if the need arises. Plaintiffs also identify the witnesses whose testimony is
expected to be presented by means of a deposition, such designation by reference to page and
line of the testimony to be offered filed concurrently herewith.
FACT WITNESSES PERSONS WITH KNOWLEDGE 0F
RELEVANT FACTS
Hiwot Mirach Plaintiff
N.S. Minor Plaintiff
A.B. Minor Plaintiff
Julio Antonio Vicente Rodas Defendant
Zebiba Habte Passenger in Plaintiff’s vehicle
Nhuyen D. Nguyen, DC Plaintiff” s treating healthcare provider
PLAINTIFF HIWOT MIRACH’S PERSONS WITH KNOWLEDGE OF
HEALTHCARE PROVIDERS RELEVANT FACTS
City of Allen (Allen Fire and Rescue) Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
Texas Health, Allen Emergency Dept. Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
Texas Medicine Resources - Allen Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
Texas Radiology Associates, LLP Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
First Medical Group Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
DFW MRI Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
Texas Healthcare Neck & Back Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
ASP Cares Pharmacy Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
PLAINTIFF N.S.’S HEALTHCARE PERSONS WITH KNOWLEDGE OF
PROVIDERS RELEVANT FACTS
Texas Health, Allen Emergency Dept. Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
Texas Medicine Resources - Allen Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
Texas Healthcare Neck & Back Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
PLAINTIFF A.B.’S HEALTHCARE PERSONS WITH KNOWLEDGE OF
PROVIDERS RELEVANT FACTS
Texas Health, Allen Emergency Dept. Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
Texas Medicine Resources - Allen Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
Texas Healthcare Neck & Back Knowledge of the medical care and/or treatment of
Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the
Custodian of Business and/or Official business, medical and/or official records of their
Records respective employers and the content of the said
records.
All witnesses and experts named by any other parties in this lawsuit and any rebuttal witness
which Plaintiffs do not know the identity of.
Respectfully submitted,
By:
NEJAT AHMED
Texas State Bar No. 24034304
JENNIFER B. LeMASTER
Texas State Bar No. 24041063
jennifer@lalawtx.com
JOEY MALDONADO, JR.
Texas State Bar No. 24039474
LEMASTER & AHMED PLLC
5700 Tennyson Parkway, Suite 310A
Plano, TX 75024
Telephone: 972.666.7219
Facsimile: 972.483.0413
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was served on all
parties or counsel of record electronically through the electronic filing manager, in person, by
mail, by commercial delivery service, by fax, by e-mail, by hand delivery, or by certified U.S.
mail, return receipt requested, pursuant to TEX. R. CIV. P. 21, 21a, on this the 22nd day of
August, 2023.
Javier Gonzalez Via Eserve: KADallasEservz'ce@kemper. com
The Law Office of Chrysti Bryant javier. gonzalez@kemper. com
83 60LBJ Freeway, Suite 410
Dallas, TX 75243
WM
JOEY MALDONADO
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.
Jose Maldonado on behalf of Jose Maldonado
Bar No. 24039474
joey@lalawtx.com
Envelope ID: 78772015
Filing Code Description: Witness List
Filing Description: PLAINTIFF
Status as of 8/22/2023 10:26 AM CST
Associated Case Party: JULIOANTONIOVICENTE RODAS
Name BarNumber Email TimestampSubmitted Status
Lisa Fenty lisa.fenty@kemper.com 8/22/2023 9:47:46 AM SENT
Javier Gonzalez javier.gonzalez@kemper.com 8/22/2023 9:47:46 AM SENT
Brenda Wadsworth brenda.wadsworth@kemper.com 8/22/2023 9:47:46 AM SENT
Associated Case Party: HIWOT MIRACH
Name BarNumber Email TimestampSubmitted Status
Jennifer LeMaster jennifer@lalawtx.com 8/22/2023 9:47:46 AM SENT
Nejat Ahmed nejat@lalawtx.com 8/22/2023 9:47:46 AM SENT
Debbie Johnson debbie@|alawtx.com 8/22/2023 9:47:46 AM SENT
Tisha Orchosky tisha@lalawtx.com 8/22/2023 9:47:46 AM SENT
Joey Maldonado joey@lalawtx.com 8/22/2023 9:47:46 AM SENT
Rachel Contreras rachelc@lalawtx.com 8/22/2023 9:47:46 AM SENT
Preview
FILED 8/22/2023 9:47 AM FELICIA PITRE DISTRICT CLERK DALLAS 00., TEXAS Ricky Brashear DEPUTY Cause No. DC-23-01413 HIWOT MIRACH, Individually and as Next § IN THE DISTRICT COURT OF Friend of N.S and A.B., minors § Plaintiffiv § § 298th JUDICIAL DISTRICT V. § § JULIO ANTONIO VICENTE RODAS § DALLAS COUNTY, TEXAS Defendant § PLAINTIFFS’ WITNESS LIST TO THE HONORABLE JUDGE OF SAID COURT: Plaintiffs provide this Witness List which identifies the persons they will or may call at the time of trial. This Witness List identifies the persons Plaintiffs expect to present at the time of trial or may call if the need arises. Plaintiffs also identify the witnesses whose testimony is expected to be presented by means of a deposition, such designation by reference to page and line of the testimony to be offered filed concurrently herewith. FACT WITNESSES PERSONS WITH KNOWLEDGE 0F RELEVANT FACTS Hiwot Mirach Plaintiff N.S. Minor Plaintiff A.B. Minor Plaintiff Julio Antonio Vicente Rodas Defendant Zebiba Habte Passenger in Plaintiff’s vehicle Nhuyen D. Nguyen, DC Plaintiff” s treating healthcare provider PLAINTIFF HIWOT MIRACH’S PERSONS WITH KNOWLEDGE OF HEALTHCARE PROVIDERS RELEVANT FACTS City of Allen (Allen Fire and Rescue) Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. Texas Health, Allen Emergency Dept. Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. Texas Medicine Resources - Allen Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. Texas Radiology Associates, LLP Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. First Medical Group Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. DFW MRI Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. Texas Healthcare Neck & Back Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. ASP Cares Pharmacy Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. PLAINTIFF N.S.’S HEALTHCARE PERSONS WITH KNOWLEDGE OF PROVIDERS RELEVANT FACTS Texas Health, Allen Emergency Dept. Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. Texas Medicine Resources - Allen Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. Texas Healthcare Neck & Back Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. PLAINTIFF A.B.’S HEALTHCARE PERSONS WITH KNOWLEDGE OF PROVIDERS RELEVANT FACTS Texas Health, Allen Emergency Dept. Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. Texas Medicine Resources - Allen Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. Texas Healthcare Neck & Back Knowledge of the medical care and/or treatment of Employees, Agents, Representatives, or Plaintiff. Knowledge as to the authenticity of the Custodian of Business and/or Official business, medical and/or official records of their Records respective employers and the content of the said records. All witnesses and experts named by any other parties in this lawsuit and any rebuttal witness which Plaintiffs do not know the identity of. Respectfully submitted, By: NEJAT AHMED Texas State Bar No. 24034304 JENNIFER B. LeMASTER Texas State Bar No. 24041063 jennifer@lalawtx.com JOEY MALDONADO, JR. Texas State Bar No. 24039474 LEMASTER & AHMED PLLC 5700 Tennyson Parkway, Suite 310A Plano, TX 75024 Telephone: 972.666.7219 Facsimile: 972.483.0413 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on all parties or counsel of record electronically through the electronic filing manager, in person, by mail, by commercial delivery service, by fax, by e-mail, by hand delivery, or by certified U.S. mail, return receipt requested, pursuant to TEX. R. CIV. P. 21, 21a, on this the 22nd day of August, 2023. Javier Gonzalez Via Eserve: KADallasEservz'ce@kemper. com The Law Office of Chrysti Bryant javier. gonzalez@kemper. com 83 60LBJ Freeway, Suite 410 Dallas, TX 75243 WM JOEY MALDONADO 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. Jose Maldonado on behalf of Jose Maldonado Bar No. 24039474 joey@lalawtx.com Envelope ID: 78772015 Filing Code Description: Witness List Filing Description: PLAINTIFF Status as of 8/22/2023 10:26 AM CST Associated Case Party: JULIOANTONIOVICENTE RODAS Name BarNumber Email TimestampSubmitted Status Lisa Fenty lisa.fenty@kemper.com 8/22/2023 9:47:46 AM SENT Javier Gonzalez javier.gonzalez@kemper.com 8/22/2023 9:47:46 AM SENT Brenda Wadsworth brenda.wadsworth@kemper.com 8/22/2023 9:47:46 AM SENT Associated Case Party: HIWOT MIRACH Name BarNumber Email TimestampSubmitted Status Jennifer LeMaster jennifer@lalawtx.com 8/22/2023 9:47:46 AM SENT Nejat Ahmed nejat@lalawtx.com 8/22/2023 9:47:46 AM SENT Debbie Johnson debbie@|alawtx.com 8/22/2023 9:47:46 AM SENT Tisha Orchosky tisha@lalawtx.com 8/22/2023 9:47:46 AM SENT Joey Maldonado joey@lalawtx.com 8/22/2023 9:47:46 AM SENT Rachel Contreras rachelc@lalawtx.com 8/22/2023 9:47:46 AM SENT