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FELICIA PITR‘E
DISTRICT CLERK
Margaret Thomas
No. Dc-17-11588
PATRICIA HUBBARD IN THE DISTRICT COURT OF
VS.
WWWWWWW’
DALLAS COUNTY, TEXAS
LEONARDO LUNA
11 6TH JUDICIAL DISTRICT
NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To Plaintiff(s) by and through their attorney(s) of record: Jill Herz
To other party/parties by and through their attorney(s) of record:
You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition
by written questions wit! be taken of Custodian of Records for:
Baylor Scott & White MedProvider (Radiology Films)
Before a Notary Public for:
Compex LegaIServices,lnc. (210)646-6424 Fax(210)599-7621
3201 Cherry Ridge Drive, Suite 3207 San Antonio, TX 78230-4825
,
or its designated agent, which deposition with attached questions may be used in evidence upon the trial of the above-
styled and numbered cause pending in the above named court. Notice is further given that request is hereby made as
authorized under Rules 176 and 200. Texas RuIes of Civil Procedure, to the officer taking this deposition to issue a
subpoena duces tecum a'nd cause it to be served on the witness to produce any and all RADIOLOGY FILMS (CD
(DICOM) preferred, if available), any and all reports, radiology reports, radiology films, pathology reports, X-ray
reports, MRl's, MRI reports, CT's, CT scan reports, ultrasounds, ultrasound reports pertaining to the examination
and/or treatment of: Patricia Hubbard from 01/05/2013 to present and to turn all such records over to the officer
authorized to take this deposition so that photographic reproductions of the same may be made and attached to said
deposition.
Chad Archibald
Susan L. Florence & Associates
1201 Elm Street, Suite 5050
Dallas, TX 75270-21 04
(214) 659-4352 Fax (877) 678-4763
Attorney for Defendant
State Bar # 241 05434
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Compex Order No. J68974 w» (I N53 f
No. DC-1 7-1 1 588
PATRICIA HUBBARD § IN THE DISTRICT COURT OF
§
vs. §
§ DALLAS COUNTY, TEXAS
LEONARDO LUNA §
§
§ 116TH JUDICIAL DISTRICT
CERTIFICATE 0F SERVICE
Ihereby certify that a true and correct copy of the foregoing Notice of Intention to Take Deposition upon Written
Questions was served to the respective p rties and/or attorneys of record by certified mail, return receipt
requested, or hand delivery, or fax.
.
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Dated: I
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Chad Archibald
Compex Order No. J68974
ATTORNEYS OF RECORD
Chad Archibald
Susan L. Florence & Associates
1201 Elm Street, Suite 5050
Dallas, TX 75270-2104 (214) 659-4352 Fax (877) 678—4763
Attorney for Defendant
Jill Herz
Jill Herz, Attorney at Law, PC
900 Jackson Street,
430 Founders Square
Dallas, TX 75202 (214) 745—4567 Fax (214) 745-1 156
Attorney for Plaintiff
No. DC-1 7-1 1 588
PATRICIA HUBBARD lN THE DISTRICT COURT OF
VS.
WWWWWW‘O’
DALLAS COUNTY, TEXAS
LEONARDO LUNA
116TH JUDICIAL DISTRICT
DIRECT QUESTIONS T0 BE PROPOUNDED TO
THE CUSTODIAN OF RECORDS FOR:
Baylor Scott & White MedProvider (Radiology Films)
from 01/05/2013 to present
Please state your fult name, occupation and official title.
Answer:
Please state by whom you are employed and the business address.
Answer:
Did you receive a subpoena for the production of Radiology Films pertaining to Patricia Hubbard?
Answer:
Are the documents and or things pertaining to Patricia Hubbard, as outlined in the subpoena duces tecum, in
your custody or subject to your control, supervision or direction?
Answer:
Have you provided copies of the documents and or things as listed in the subpoena, to be attached to this
deposition? lf not, why not?
Answer:
lf you answered “yes" to question no. 5, are the documents and or things which you have provided true and
correct copies of the originals?
Answer:
Were such documents and or things kept in the regutar course of business of this facility?
Answer:
8. Was it in the regular course of business of this facility for a person with knowledge of the acts, events,
conditions, or opinion recorded to make record or to transmit information thereof to be inciuded in such
record?
Answer:
9. Were the entries on these records made at or shortly after the time of the transaction recorded?
Answer:
10. Was the method of preparation of these records trustworthy?
Answer:
WITNESS (Custodian of Records)
Before me, the undersigned authority, on day personally appeared
this
. known to me to be the person whose name is subscribed to the
foregoing instrument in the capacity therein stated, who being first duly sworn, stated upon his/her oath that the
answers to the foregoing questions are true and correct. I further certify that the records attached hereto are
exact duplicates of the original records.
SWORN TO AND SUBSCRIBED before me this day Of . 20
NOTARY PUBLIC
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FELICIA PITR‘E DISTRICT CLERK Margaret Thomas No. Dc-17-11588 PATRICIA HUBBARD IN THE DISTRICT COURT OF VS. WWWWWWW’ DALLAS COUNTY, TEXAS LEONARDO LUNA 11 6TH JUDICIAL DISTRICT NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To Plaintiff(s) by and through their attorney(s) of record: Jill Herz To other party/parties by and through their attorney(s) of record: You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition by written questions wit! be taken of Custodian of Records for: Baylor Scott & White MedProvider (Radiology Films) Before a Notary Public for: Compex LegaIServices,lnc. (210)646-6424 Fax(210)599-7621 3201 Cherry Ridge Drive, Suite 3207 San Antonio, TX 78230-4825 , or its designated agent, which deposition with attached questions may be used in evidence upon the trial of the above- styled and numbered cause pending in the above named court. Notice is further given that request is hereby made as authorized under Rules 176 and 200. Texas RuIes of Civil Procedure, to the officer taking this deposition to issue a subpoena duces tecum a'nd cause it to be served on the witness to produce any and all RADIOLOGY FILMS (CD (DICOM) preferred, if available), any and all reports, radiology reports, radiology films, pathology reports, X-ray reports, MRl's, MRI reports, CT's, CT scan reports, ultrasounds, ultrasound reports pertaining to the examination and/or treatment of: Patricia Hubbard from 01/05/2013 to present and to turn all such records over to the officer authorized to take this deposition so that photographic reproductions of the same may be made and attached to said deposition. Chad Archibald Susan L. Florence & Associates 1201 Elm Street, Suite 5050 Dallas, TX 75270-21 04 (214) 659-4352 Fax (877) 678-4763 Attorney for Defendant State Bar # 241 05434 h ff ‘ —~,---. #553—5 nul—n-v-I-..” r .__I s7 ’9’ ff a l/ . :zswiib— .fijm: ~Pr9—W—m .9" vga- TEXASCS@COMPEXLEGAL.COM Compex Order No. J68974 w» (I N53 f No. DC-1 7-1 1 588 PATRICIA HUBBARD § IN THE DISTRICT COURT OF § vs. § § DALLAS COUNTY, TEXAS LEONARDO LUNA § § § 116TH JUDICIAL DISTRICT CERTIFICATE 0F SERVICE Ihereby certify that a true and correct copy of the foregoing Notice of Intention to Take Deposition upon Written Questions was served to the respective p rties and/or attorneys of record by certified mail, return receipt requested, or hand delivery, or fax. . ‘ “EM”- Dated: I ’ I 5’ I a #w-y’ g If f «L .£::»~’—~—H~--~*W f “'fi ' p "’ Chad Archibald Compex Order No. J68974 ATTORNEYS OF RECORD Chad Archibald Susan L. Florence & Associates 1201 Elm Street, Suite 5050 Dallas, TX 75270-2104 (214) 659-4352 Fax (877) 678—4763 Attorney for Defendant Jill Herz Jill Herz, Attorney at Law, PC 900 Jackson Street, 430 Founders Square Dallas, TX 75202 (214) 745—4567 Fax (214) 745-1 156 Attorney for Plaintiff No. DC-1 7-1 1 588 PATRICIA HUBBARD lN THE DISTRICT COURT OF VS. WWWWWW‘O’ DALLAS COUNTY, TEXAS LEONARDO LUNA 116TH JUDICIAL DISTRICT DIRECT QUESTIONS T0 BE PROPOUNDED TO THE CUSTODIAN OF RECORDS FOR: Baylor Scott & White MedProvider (Radiology Films) from 01/05/2013 to present Please state your fult name, occupation and official title. Answer: Please state by whom you are employed and the business address. Answer: Did you receive a subpoena for the production of Radiology Films pertaining to Patricia Hubbard? Answer: Are the documents and or things pertaining to Patricia Hubbard, as outlined in the subpoena duces tecum, in your custody or subject to your control, supervision or direction? Answer: Have you provided copies of the documents and or things as listed in the subpoena, to be attached to this deposition? lf not, why not? Answer: lf you answered “yes" to question no. 5, are the documents and or things which you have provided true and correct copies of the originals? Answer: Were such documents and or things kept in the regutar course of business of this facility? Answer: 8. Was it in the regular course of business of this facility for a person with knowledge of the acts, events, conditions, or opinion recorded to make record or to transmit information thereof to be inciuded in such record? Answer: 9. Were the entries on these records made at or shortly after the time of the transaction recorded? Answer: 10. Was the method of preparation of these records trustworthy? Answer: WITNESS (Custodian of Records) Before me, the undersigned authority, on day personally appeared this . known to me to be the person whose name is subscribed to the foregoing instrument in the capacity therein stated, who being first duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct. I further certify that the records attached hereto are exact duplicates of the original records. SWORN TO AND SUBSCRIBED before me this day Of . 20 NOTARY PUBLIC