Preview
FILED
8/7/2020 3:55 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
No. DC-20-00255 Martin Reyes DEPUTY
No. DC-20-00255
AMY Martin Reyes
WICKERSHAM AND
AMY VVICKERSHAM AND : THE DISTRICT
IN THE
IN DISTRICT COURT OF
PERRY WICKERSHAM
PERRY WICKERSHAM
'
vs.
VS. : DALLAS
DALLAS COUNTY, TEXAS
BENJAMIN
BENJAMIN BRASHER, MD, GARRY
BRASHER, MD, CARRY GUCE, MD, DANIEL
GUCE, MD, DANIEL
SCHEURICl-l, MD, GUSTAVO N. DEL TORO,
SCHEURICH, MD, CUSTAVO N. DEL TORO, D0, DO, PAULA
PAULA A
A. .
:
GUTTUSO,
CUTTUSO, MD,MD, CHRISTINA
CHRISTINA D.D. WRIGHT, RD,BRASHEAR
WRIGHT, RD, BRASHEAR :
FAMILY
FAMILY MEDICAL, P.A., WELLMED
MEDICAI., P.A., WELL.MED MEDICAL GROUP,
MEDICAI. GROL'P,
D/B/A WELLMED
P.A. D/B/A
P.A. WEI.I.MED AT KAL'FMAK. SOUND INPATIENT
AT KAUFMAN, INPATIENT :
PHYSICIANS INC, DR. GARRY GUCE & ASSOCIATES,
PLLC, TEXAS HEALTH
PLLC, TEXAS HEALTH PHYSICIANS
PHYSICIASS GROUP,
CROUP,
LUMINCARE
LL1hllNCAREPHYSICIAN CROL'P. ARAMARK
PHYSICIAN GROUP, ARAhlARK
HEALTHCARE
HEALTHCARE SUPPORT SERVICES, LLC
SUPPORT SERVICES, AND TEXAS
LLC AND TEXAS
HEALTH PRESBYTERIAN KAUFMAN
HEALTH PRESBYTERIAN KAUFMAN :
44TH
44TH JUDICIAL DISTRICT
NOTICE 0F
NOTICE OF INTENTION
INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS
TO TAKE DEPOSITION QUESTIONS
To
To Defendant
Defendant by
by and
and through
through their
their attorney
attorney 0f
of record: See Attached
record: See Attached Attorney List 'A'
Attorney List 'A'
You
You will
will please
please take
take notice
notice that
that twenty
twenty (20)
(20) days
days from
from the
the service
service of aa copy
copy hereof
hereof with
with attached
attached questions,
questions, aa
deposition by written questions will be
deposition by written questions will be taken
taken of
of the
the Custodian(s)
Custodian(s) of
of Records
Records for:
for:
See Attached
See Attached Location List 'B'
Location List 'B'
before aa Notary
before Notary Public
Public for Carol Davis
for Carol Davis Reporting,
Reporting, Records
Records & Video, Inc.
& Video, Inc. (713)
(713) 647-5100
647-5100 Fax (713) 647-5170
(713) 647—5170
7838 Houston, TX
Hillmont, Houston,
7838 Hillmont, TX 77040
77040
or its
or its designated
designatedagent,
agent, which
which deposition
deposition with
with attached
attached questions
questions may be used
used in
in evidence
evidence upon the
the trial
trial of
of the
the above-
above-
styled and
styled and numbered
numbered cause
cause pending in the
pending in the above
above named court. Notice
court. Notice is further
is hrther given
given that request is
that request hereby made
is hereby madc as
as
authorized under Rule
authorized under Rule 200,
200, Texas Rules of
Texas Rules of Civil Procedure, to
Civil Procedure, to the
the officer
officer taking
taking this deposition t0
this deposition issue aa subpoena
to issue subpoena
duces tecum
duces tecum and
and cause
cause it to
to be
itbe served
served 0n
on the
the witness
witness to
to produce
produce any and all
any and all records
records as described on
as described on the attached
the attached
questions and/or
questions and/or Exhibit(s)
Exhibit(s) and
and any
any other such record
other such record in
in the
the possession,
possession, custody or control
custody or control of
of the
the said
said witness, and
witness, and
every such record to which the witness may
every such record to which the witness have access,
may have pertaining to:
access, pertaining to:
Amy
Amy Wickersham
Wickersham
za:'"is8
and to
and to turn
turn all
all such
such records
records over
over to
to the
the officer
officer authorized
authorized to
to take
take this
this deposition
deposition so
so that
that photographic
photographic reproductions
reproductions of
of
the same
the may be
same may be made
made and attached t0
and attached to said
said deposition.
deposition.
Re ectfully s bmitted,
c.c.
QuiSéY-C'L
,
ohn A. aVIS,
Davis &
Davis & Davis
Davis
440 Louisiana
440 Louisiana Suite
Suite 1850
1850
Houston, TX
Houston, TX 77002
77002
(713) 781-5200
(713) 781-5200 Fax
Fax (713)
(713) 781-2235
781-2235
Attorney for Plaintiff
Attorney for Plaintiff
Amy
Amy Wickersham
Wickersham
SBA ## 05512300
SBA 05512300
hereby certify
I hereby
I certify that
that aa true
true and
and correct
correct copy
copy of
of the
the foregoing
foregoing instrument
instrument has been forwarded
has been forwarded toto all
all Counsel
Counsel of
of Record
Record byby hand
hand
delivery, telephonic documenttransfer,
delivery, telephonicdocument courierreceipted
transfer, courier receipted delivery
deliveryand/or
andor certified mail, return
certified mail return receipt requested, on
receipt requested, this day.
on this day.
Dated:
OrderNo.
Order
Mm
No. 01-4065
01-40651-001
(I
010
thru 010
l -001 thru
24220
for
by L&me
Mr. John
for Mr. John A Davis, Jr.
A. Davis, Jr.
UMK
Order No.
Order 01-40651-001 thru
No. 01-40651-001 thru 010
010
ATTORNEY LIST 'A'
'A'
Ms. Missy
Ms. Atwood-Hospitalist Medicine
Missy Atwood-Hospitalist Physicians of
Medicine Physicians of Texas,
Texas, PLLC,
PLLC, Sound
Sound Physicians
Physicians ofTexas
of Texas III, Stephen Royce
111, Stephen Royce Parish, M.D.
Parish, M.D.
and
and Usman Chaudhry, M.D.- Defendants
Chaudhry, M.D.- Defendants
Ms. Cathy F.
Ms. Cathy F. Bailey-Benjamin
Bailey—Benjamin Brashear,
Brashear, M.D. and Brashear
M.D. and Brashear Family
Family Medical, PA-Defendants
Medical, P.A.-Defendants
Mr. Ty
Mr. Ty Bailey—Rockwall
Bailey-Rockwall Regional
Regional Hospital, d/b/a Texas
Hospital, LLC d/b/a Texas Health
Health Presbyterian
Presbyterian Hospital
Hospital Rockwall, Mary Schoen,
Rockwall, Mary Schoen, R.D.,
R.D., L.D.
L.D.
and Nichole
and Anguiano, R.
Nichole Anguiano, D., L.D.-Defendants
R. D., LD-Defendants
Ms.
Ms. Kimberly
Kimberly K. K. Bocell-WellMed Medical Group,
Bocell-WellMed Medical Group, P.A.
P.A. dhla WellMed at
d/b/a WellMed at Kaufman-Defendants
Kaufman-Defendants
Mr. Alan L.
Mr. Alan L. Campbell-Paul Guttuso, M.D.,
Campbell—Paul Guttuso, Texas Health
M.D., Texas Health Physicians
Physicians Group,
Group, Christina
Christina D.
D. Wright, R.D., and
Wright, R.D., and Texas
Texas Health
Health
Presbvterian
Mr. Michael
Hosoital Kauh-Defendants
Presbyterian Hospital
Mr. Michael L.
Kaufinan-Defendants
L. Hurst-Daniel Scheurich, M.D.-Defendant
Hurst-Daniel Scheurich, M.D.-Defendant
I
Mr.
Mr. Rayshun
Rayshun Jackson-Gany Guce, M.D.
Jackson—Garry Guce, M.D. and Gany Guce
and Gany Guce Associates,
Associates, PLLC.-Defendants
PLLC.-Defendants
Ms. Jennifer
Ms. Jennifer A.
A. King-HealthTexas
King-HealthTexas Provider
Provider Network d/b/a Baylor
Network d/b/a Scott & White
Baylor Scott White Primary
Primary Care
Care Associates
Associates and
and d/b/a
d/b/a Baylor
Baylor Scott
Scott
& White Pulmonary
&White Pulmonary Care
Care Consultants
Consultants and
and Delano
Delano Soriano
Soriano Fabro,
Fabro, Jr.,
Jr., DO
Ms. Michele
Ms. Michele Quattlebaum-Erik Tijerina, FNP-Defendant
Quattlebaum—Erik Tijerina, FNP-Defendant
Stan Thiebaud-Gustavo
Mr. Stan
Mr. Thiebaud-Gustavo DelDel Toro,
Toro, DO-Defendants
DO-Defendants
OrderNo.
Order No. 01-40651-001
01-40651-00] thru 010
thru 010
LOCATION 'B'
LOCATION LIST 'B'
Baylor Scott
Baylor &
Scott & White
White Medical — Waxahachie
Center -
Medical Center Waxahachie (Medical)
(Medical)
2400 N. I-35E
2400 N. Waxahachie, TX 75165
I-35E Waxahachie, 75 165
Baylor Scott & White Medical
Baylor Scott Center —
Medical Center Waxahachie (Billing)
- Waxahachie (Billing)
2400 N.
2400 N. I-35E
I-35E Waxahachie,
Waxahachie, TX 75165
75 165
Legend Oaks
Legend Oaks Healthcare and Rehabilitation
Healthcare and Rehabilitation of
of Ennis (Medical)
Ennis (Medical)
1400 Medical Center
1400 Medical Center Drive Ennis, TX 751
Drive Ennis, 75 119
l9
Legend Oaks Healthcare
Legend Healthcare and
and Rehabilitation of Ennis
Rehabilitation of Ennis (Billing)
(Billing)
1400 Medical
1400 Center Drive
Medical Center Drive Ennis,
Ennis, TX 751 19
75 1 19
Medical City
Medical City Dallas
Dallas (Medical)
(Medical)
7777 Forest
7777 Forest Lane
Lane Dallas, 75230
Dallas, TX 75230
Medical City Dallas
Medical City (Billing)
Dallas (Billing)
7777 Forest
7777 Lane Dallas,
Forest Lane 75230
Dallas, TX 75230
Mesquite Specialty
Mesquite Specialty Hospital
Hospital (Medical)
(Medical)
1024
1024 N.
N. Galloway Avenue Mesquite,
Galloway Avenue Mesquite, TX 75149
75149
Mesquite Specialty Hospital
Mesquite Specialty (Billing)
Hospital (Billing)
1024
1024 N. Galloway Avenue
N. Galloway Avenue Mesquite,
Mesquite, TX 75 75149
149
Joseph
Joseph Beshay,
Beshay, M.D. (Medical)
(Medical)
7777
7777 Forest Lane, Suite
Forest Lane, Suite A-337
A-337 Irving, 75060
Irving, TX 75060
Joseph Beshay,
Joseph Beshay, M.D. (Billing)
(Billing)
7777 Forest
7777 Forest Lane,
Lane, Suite
Suite A-337 Irving, TX 75060
A-337 Irving, 75060
No.
No. DC-20-00255
AMY WICKERSHAM AND : IN THE DISTRICT COURT OF
PERRY WICKERSHAM
VVICKERSHAM ‘
VS.
vs. : DALLAS COUNTY, TEXAS
BENJAMIN BRASHER, MD, GARRY CARRY GUCE, MD, DANIEL
SCHLUHICII,MD,
SCHEURICH, m , GUSTAVO v.\ ~DEL
G L S I ~ . \N. TORO, DO, PAUL A.
DEI. TORO,
GL'TTL'SO.
GUTTUSO, MD,hln. CHRISTINA
CHHISl'ISA D.D. WRIGHT, KV. BRASHEAR
\VRICHT. RD, BHASHE,\R :
FAMILY MEDICAL, P.A.,P.A., WELLMED MEDICAL GROUP,
P.A. D
P.A. B A VVELLMED
D/B/A KAUFMAN, SOUND
\\'ELL\IED AT KACF\I.AY, SOl'ND INPATIENT
IVP.+TIENT :
PHYSICIAVS INC.,
PHYSICIANS GARRY GUCE
ISC.. DR. GAUHI' GIJCE & ASSOCIATES,
ASSOCIATES.
PLLC, TEXAS HEALTH PHYSICIANS GROUP,
1.UMINCARE PHYSICIAN
LUMINCARE P...\., ARAMARK
PHI'SICIAN GROUP, P.A., AK.A\IARK
HEAI.TIIC,\KE SUPPORT
HEALTHCARE SFR\'ICLS. LLC AND
SL'PPORT SERVICES, 4 S D TEXAS
HEALTH PRESBYTERIAN KAUFMAN : 44TH JUDICIAL DISTRICT
PROPOUNDED TO THE WITNESS
DIRECT QUESTIONS TO BE PROPOUNDED
Custodian of Records
Custodian of Records for:
for: Baylor Scott & White Medical Center -
Baylor Scott — Waxahachie
Records Pertaining
Records To: Amy Wickersham
Penaining To:
Type of
Type of Records: any and
Records: any all records
and all as requested
records as in Attachment A from 01/06/2018
requested in 01/06/2018 to the present,
to the present, pertaining
pertaining to
to Amy
Wickersham.
1.
l. Please state your
Please state your full
full name. (Please
(Please print)
print)
Answer:
Answer:
2. Please
2. state by
Please state by whom you are employed
you are employed and the business address.
the business address. (Please
(Please print)
print)
Answer:
Answer:
3. What is
3. is the
the title of your
title of your position?
position?
Answer:
Answer:
4.
4. Did you
you receive a subpoena
receive a subpoena to
to appear
appear and bring
bring with
with you
you for
for inspection
inspection and
and photocopying
photocopying any
any and all
all of
of the
the patient
patient records,
records,
as requested in
as requested in Attachment A, pertaining
Attachment A, pertaining to
to Amy Wickersham?
Wickersham?
Answer:
Answer:
5 . Are
5. Are you
you the Custodian of
the Custodian of Records
Records or
or one
one of the
the persons has supervision
persons who has supervision of,
of, control
control of,
of, or
or access
access to
to the
the patient
patient records,
records, as
as
requested in
requested in Attachment
Attachment A, pertaining to
A, pertaining to the
the above-named
above-named person?
person?
Answer:
Answer:
6 . In
6. your capacity
In your capacity as Custodian of
as Custodian of Records,
Records, state
state if it is
if it is the regular practice
the regular of your business
practice of business activity
activity to
to keep
keep notes, records,
notes, records,
reports
reports call slips, narratives,
call slips, narratives, letters and communications
letters and between the
communications between patient, the
the patient, lawyer, any
the lawyer, any insurance companies, the
insurance companies, the
employer and
employer and any other doctor,
any other doctor, and
and any
any and
and all
all reports,
reports, consultations
consultations or records contained
or records in your
contained in your file
file from
from any
any source
source along
along
with all reports,
with all reports, notes, and charts
notes, and charts that
that are generated in
are generated in the treatment of the patient.
the treatment patient.
Answer:
Answer:
Order No. 01-40651-001
Order No. 01-40651-001
Are such
7 . Are such records
records created
created and
and maintained
maintained in
in the
the course
course of
of your
your regularly
regularly conducted
conducted business
business activity?
activity?
Answer:
Answer:
Are the
8. Are the entries
entries made
made at
at or
or near
near the
the time
time of
of the
the transactions
transactions which
which are
are being
being recorded?
recorded?
Answer:
Answer:
Are the
9. Are the entries
entries made
made by
by or
or from
from information
information transmitted
transmitted by
by aa person
person with
with knowledge
knowledge of
of the
the information
information which
which is
is being
being
recorded?
recorded?
Answer:
Answer:
LO. Do you
10. have such
you have such records as described
records as described in Attachment A on
in Attachment on the above-named person?
the above-named person?
Answer:
111.
1. Were these
these records created and
records created and maintained
maintained as
as described
described above?
above?
Answer:
Answer:
12. Please hand
12. Please hand to
to the
the Officer
Officer taking
taking this deposition aa copy
this deposition copy of
of aIl
all records
records pertaining
pertaining to
to the
the above-named
above-named person,
person, as
as outlined
outlined in
in the
the
Subpoena Duces
Subpoena Duces Tecum, for inspection
Tecum, for inspection and
and marking
marking asas Exhibits
Exhibits to
to be
be attached
attached to
to this
this deposition.
deposition.
Answer:
Answer:
13. Have
13. Have you done as
you done as requested in the
requested in preceding question?
the preceding question? If
If not,
not, why not?
not?
Answer:
Answer:
14. Was the
l4. method of
the method of preparation
preparation of
of these
these records
records trustworthy?
trustworthy?
Answer:
Answer:
15. Describe in detail any
15. Describe in detail any documents
documents relating to this
relating to this patient
patient in
in any
any manner which
which you
you are
are withholding.
withholding.
Answer:
Answer:
16.
16. Do you
you understand
understand that
that perjury
perjury is
is a
a wime?
crime?
Answer:
Answer:
17.
l7. Do you
you swear
swear to
to the
the pains
pains and
and penalties
penalties of perjury that
ofperjury that you
you are
are turning
turning over the
the entire
entire file
file and all
all documents
documents of any
any type
type
whatsoever
whatsoever related
related to
to this
this patient
patient at
at this
this time?
time?
Answer:
Answer:
Order
Order NO.
No. 01-40651-001
01-40651-001
18. Are
18. Are there
there any
any records that you
records that you have witbheld fiom
have withheld 6om any
Preview
FILED 8/7/2020 3:55 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS No. DC-20-00255 Martin Reyes DEPUTY No. DC-20-00255 AMY Martin Reyes WICKERSHAM AND AMY VVICKERSHAM AND : THE DISTRICT IN THE IN DISTRICT COURT OF PERRY WICKERSHAM PERRY WICKERSHAM ' vs. VS. : DALLAS DALLAS COUNTY, TEXAS BENJAMIN BENJAMIN BRASHER, MD, GARRY BRASHER, MD, CARRY GUCE, MD, DANIEL GUCE, MD, DANIEL SCHEURICl-l, MD, GUSTAVO N. DEL TORO, SCHEURICH, MD, CUSTAVO N. DEL TORO, D0, DO, PAULA PAULA A A. . : GUTTUSO, CUTTUSO, MD,MD, CHRISTINA CHRISTINA D.D. WRIGHT, RD,BRASHEAR WRIGHT, RD, BRASHEAR : FAMILY FAMILY MEDICAL, P.A., WELLMED MEDICAI., P.A., WELL.MED MEDICAL GROUP, MEDICAI. GROL'P, D/B/A WELLMED P.A. D/B/A P.A. WEI.I.MED AT KAL'FMAK. SOUND INPATIENT AT KAUFMAN, INPATIENT : PHYSICIANS INC, DR. GARRY GUCE & ASSOCIATES, PLLC, TEXAS HEALTH PLLC, TEXAS HEALTH PHYSICIANS PHYSICIASS GROUP, CROUP, LUMINCARE LL1hllNCAREPHYSICIAN CROL'P. ARAMARK PHYSICIAN GROUP, ARAhlARK HEALTHCARE HEALTHCARE SUPPORT SERVICES, LLC SUPPORT SERVICES, AND TEXAS LLC AND TEXAS HEALTH PRESBYTERIAN KAUFMAN HEALTH PRESBYTERIAN KAUFMAN : 44TH 44TH JUDICIAL DISTRICT NOTICE 0F NOTICE OF INTENTION INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS TO TAKE DEPOSITION QUESTIONS To To Defendant Defendant by by and and through through their their attorney attorney 0f of record: See Attached record: See Attached Attorney List 'A' Attorney List 'A' You You will will please please take take notice notice that that twenty twenty (20) (20) days days from from the the service service of aa copy copy hereof hereof with with attached attached questions, questions, aa deposition by written questions will be deposition by written questions will be taken taken of of the the Custodian(s) Custodian(s) of of Records Records for: for: See Attached See Attached Location List 'B' Location List 'B' before aa Notary before Notary Public Public for Carol Davis for Carol Davis Reporting, Reporting, Records Records & Video, Inc. & Video, Inc. (713) (713) 647-5100 647-5100 Fax (713) 647-5170 (713) 647—5170 7838 Houston, TX Hillmont, Houston, 7838 Hillmont, TX 77040 77040 or its or its designated designatedagent, agent, which which deposition deposition with with attached attached questions questions may be used used in in evidence evidence upon the the trial trial of of the the above- above- styled and styled and numbered numbered cause cause pending in the pending in the above above named court. Notice court. Notice is further is hrther given given that request is that request hereby made is hereby madc as as authorized under Rule authorized under Rule 200, 200, Texas Rules of Texas Rules of Civil Procedure, to Civil Procedure, to the the officer officer taking taking this deposition t0 this deposition issue aa subpoena to issue subpoena duces tecum duces tecum and and cause cause it to to be itbe served served 0n on the the witness witness to to produce produce any and all any and all records records as described on as described on the attached the attached questions and/or questions and/or Exhibit(s) Exhibit(s) and and any any other such record other such record in in the the possession, possession, custody or control custody or control of of the the said said witness, and witness, and every such record to which the witness may every such record to which the witness have access, may have pertaining to: access, pertaining to: Amy Amy Wickersham Wickersham za:'"is8 and to and to turn turn all all such such records records over over to to the the officer officer authorized authorized to to take take this this deposition deposition so so that that photographic photographic reproductions reproductions of of the same the may be same may be made made and attached t0 and attached to said said deposition. deposition. Re ectfully s bmitted, c.c. QuiSéY-C'L , ohn A. aVIS, Davis & Davis & Davis Davis 440 Louisiana 440 Louisiana Suite Suite 1850 1850 Houston, TX Houston, TX 77002 77002 (713) 781-5200 (713) 781-5200 Fax Fax (713) (713) 781-2235 781-2235 Attorney for Plaintiff Attorney for Plaintiff Amy Amy Wickersham Wickersham SBA ## 05512300 SBA 05512300 hereby certify I hereby I certify that that aa true true and and correct correct copy copy of of the the foregoing foregoing instrument instrument has been forwarded has been forwarded toto all all Counsel Counsel of of Record Record byby hand hand delivery, telephonic documenttransfer, delivery, telephonicdocument courierreceipted transfer, courier receipted delivery deliveryand/or andor certified mail, return certified mail return receipt requested, on receipt requested, this day. on this day. Dated: OrderNo. Order Mm No. 01-4065 01-40651-001 (I 010 thru 010 l -001 thru 24220 for by L&me Mr. John for Mr. John A Davis, Jr. A. Davis, Jr. UMK Order No. Order 01-40651-001 thru No. 01-40651-001 thru 010 010 ATTORNEY LIST 'A' 'A' Ms. Missy Ms. Atwood-Hospitalist Medicine Missy Atwood-Hospitalist Physicians of Medicine Physicians of Texas, Texas, PLLC, PLLC, Sound Sound Physicians Physicians ofTexas of Texas III, Stephen Royce 111, Stephen Royce Parish, M.D. Parish, M.D. and and Usman Chaudhry, M.D.- Defendants Chaudhry, M.D.- Defendants Ms. Cathy F. Ms. Cathy F. Bailey-Benjamin Bailey—Benjamin Brashear, Brashear, M.D. and Brashear M.D. and Brashear Family Family Medical, PA-Defendants Medical, P.A.-Defendants Mr. Ty Mr. Ty Bailey—Rockwall Bailey-Rockwall Regional Regional Hospital, d/b/a Texas Hospital, LLC d/b/a Texas Health Health Presbyterian Presbyterian Hospital Hospital Rockwall, Mary Schoen, Rockwall, Mary Schoen, R.D., R.D., L.D. L.D. and Nichole and Anguiano, R. Nichole Anguiano, D., L.D.-Defendants R. D., LD-Defendants Ms. Ms. Kimberly Kimberly K. K. Bocell-WellMed Medical Group, Bocell-WellMed Medical Group, P.A. P.A. dhla WellMed at d/b/a WellMed at Kaufman-Defendants Kaufman-Defendants Mr. Alan L. Mr. Alan L. Campbell-Paul Guttuso, M.D., Campbell—Paul Guttuso, Texas Health M.D., Texas Health Physicians Physicians Group, Group, Christina Christina D. D. Wright, R.D., and Wright, R.D., and Texas Texas Health Health Presbvterian Mr. Michael Hosoital Kauh-Defendants Presbyterian Hospital Mr. Michael L. Kaufinan-Defendants L. Hurst-Daniel Scheurich, M.D.-Defendant Hurst-Daniel Scheurich, M.D.-Defendant I Mr. Mr. Rayshun Rayshun Jackson-Gany Guce, M.D. Jackson—Garry Guce, M.D. and Gany Guce and Gany Guce Associates, Associates, PLLC.-Defendants PLLC.-Defendants Ms. Jennifer Ms. Jennifer A. A. King-HealthTexas King-HealthTexas Provider Provider Network d/b/a Baylor Network d/b/a Scott & White Baylor Scott White Primary Primary Care Care Associates Associates and and d/b/a d/b/a Baylor Baylor Scott Scott & White Pulmonary &White Pulmonary Care Care Consultants Consultants and and Delano Delano Soriano Soriano Fabro, Fabro, Jr., Jr., DO Ms. Michele Ms. Michele Quattlebaum-Erik Tijerina, FNP-Defendant Quattlebaum—Erik Tijerina, FNP-Defendant Stan Thiebaud-Gustavo Mr. Stan Mr. Thiebaud-Gustavo DelDel Toro, Toro, DO-Defendants DO-Defendants OrderNo. Order No. 01-40651-001 01-40651-00] thru 010 thru 010 LOCATION 'B' LOCATION LIST 'B' Baylor Scott Baylor & Scott & White White Medical — Waxahachie Center - Medical Center Waxahachie (Medical) (Medical) 2400 N. I-35E 2400 N. Waxahachie, TX 75165 I-35E Waxahachie, 75 165 Baylor Scott & White Medical Baylor Scott Center — Medical Center Waxahachie (Billing) - Waxahachie (Billing) 2400 N. 2400 N. I-35E I-35E Waxahachie, Waxahachie, TX 75165 75 165 Legend Oaks Legend Oaks Healthcare and Rehabilitation Healthcare and Rehabilitation of of Ennis (Medical) Ennis (Medical) 1400 Medical Center 1400 Medical Center Drive Ennis, TX 751 Drive Ennis, 75 119 l9 Legend Oaks Healthcare Legend Healthcare and and Rehabilitation of Ennis Rehabilitation of Ennis (Billing) (Billing) 1400 Medical 1400 Center Drive Medical Center Drive Ennis, Ennis, TX 751 19 75 1 19 Medical City Medical City Dallas Dallas (Medical) (Medical) 7777 Forest 7777 Forest Lane Lane Dallas, 75230 Dallas, TX 75230 Medical City Dallas Medical City (Billing) Dallas (Billing) 7777 Forest 7777 Lane Dallas, Forest Lane 75230 Dallas, TX 75230 Mesquite Specialty Mesquite Specialty Hospital Hospital (Medical) (Medical) 1024 1024 N. N. Galloway Avenue Mesquite, Galloway Avenue Mesquite, TX 75149 75149 Mesquite Specialty Hospital Mesquite Specialty (Billing) Hospital (Billing) 1024 1024 N. Galloway Avenue N. Galloway Avenue Mesquite, Mesquite, TX 75 75149 149 Joseph Joseph Beshay, Beshay, M.D. (Medical) (Medical) 7777 7777 Forest Lane, Suite Forest Lane, Suite A-337 A-337 Irving, 75060 Irving, TX 75060 Joseph Beshay, Joseph Beshay, M.D. (Billing) (Billing) 7777 Forest 7777 Forest Lane, Lane, Suite Suite A-337 Irving, TX 75060 A-337 Irving, 75060 No. No. DC-20-00255 AMY WICKERSHAM AND : IN THE DISTRICT COURT OF PERRY WICKERSHAM VVICKERSHAM ‘ VS. vs. : DALLAS COUNTY, TEXAS BENJAMIN BRASHER, MD, GARRY CARRY GUCE, MD, DANIEL SCHLUHICII,MD, SCHEURICH, m , GUSTAVO v.\ ~DEL G L S I ~ . \N. TORO, DO, PAUL A. DEI. TORO, GL'TTL'SO. GUTTUSO, MD,hln. CHRISTINA CHHISl'ISA D.D. WRIGHT, KV. BRASHEAR \VRICHT. RD, BHASHE,\R : FAMILY MEDICAL, P.A.,P.A., WELLMED MEDICAL GROUP, P.A. D P.A. B A VVELLMED D/B/A KAUFMAN, SOUND \\'ELL\IED AT KACF\I.AY, SOl'ND INPATIENT IVP.+TIENT : PHYSICIAVS INC., PHYSICIANS GARRY GUCE ISC.. DR. GAUHI' GIJCE & ASSOCIATES, ASSOCIATES. PLLC, TEXAS HEALTH PHYSICIANS GROUP, 1.UMINCARE PHYSICIAN LUMINCARE P...\., ARAMARK PHI'SICIAN GROUP, P.A., AK.A\IARK HEAI.TIIC,\KE SUPPORT HEALTHCARE SFR\'ICLS. LLC AND SL'PPORT SERVICES, 4 S D TEXAS HEALTH PRESBYTERIAN KAUFMAN : 44TH JUDICIAL DISTRICT PROPOUNDED TO THE WITNESS DIRECT QUESTIONS TO BE PROPOUNDED Custodian of Records Custodian of Records for: for: Baylor Scott & White Medical Center - Baylor Scott — Waxahachie Records Pertaining Records To: Amy Wickersham Penaining To: Type of Type of Records: any and Records: any all records and all as requested records as in Attachment A from 01/06/2018 requested in 01/06/2018 to the present, to the present, pertaining pertaining to to Amy Wickersham. 1. l. Please state your Please state your full full name. (Please (Please print) print) Answer: Answer: 2. Please 2. state by Please state by whom you are employed you are employed and the business address. the business address. (Please (Please print) print) Answer: Answer: 3. What is 3. is the the title of your title of your position? position? Answer: Answer: 4. 4. Did you you receive a subpoena receive a subpoena to to appear appear and bring bring with with you you for for inspection inspection and and photocopying photocopying any any and all all of of the the patient patient records, records, as requested in as requested in Attachment A, pertaining Attachment A, pertaining to to Amy Wickersham? Wickersham? Answer: Answer: 5 . Are 5. Are you you the Custodian of the Custodian of Records Records or or one one of the the persons has supervision persons who has supervision of, of, control control of, of, or or access access to to the the patient patient records, records, as as requested in requested in Attachment Attachment A, pertaining to A, pertaining to the the above-named above-named person? person? Answer: Answer: 6 . In 6. your capacity In your capacity as Custodian of as Custodian of Records, Records, state state if it is if it is the regular practice the regular of your business practice of business activity activity to to keep keep notes, records, notes, records, reports reports call slips, narratives, call slips, narratives, letters and communications letters and between the communications between patient, the the patient, lawyer, any the lawyer, any insurance companies, the insurance companies, the employer and employer and any other doctor, any other doctor, and and any any and and all all reports, reports, consultations consultations or records contained or records in your contained in your file file from from any any source source along along with all reports, with all reports, notes, and charts notes, and charts that that are generated in are generated in the treatment of the patient. the treatment patient. Answer: Answer: Order No. 01-40651-001 Order No. 01-40651-001 Are such 7 . Are such records records created created and and maintained maintained in in the the course course of of your your regularly regularly conducted conducted business business activity? activity? Answer: Answer: Are the 8. Are the entries entries made made at at or or near near the the time time of of the the transactions transactions which which are are being being recorded? recorded? Answer: Answer: Are the 9. Are the entries entries made made by by or or from from information information transmitted transmitted by by aa person person with with knowledge knowledge of of the the information information which which is is being being recorded? recorded? Answer: Answer: LO. Do you 10. have such you have such records as described records as described in Attachment A on in Attachment on the above-named person? the above-named person? Answer: 111. 1. Were these these records created and records created and maintained maintained as as described described above? above? Answer: Answer: 12. Please hand 12. Please hand to to the the Officer Officer taking taking this deposition aa copy this deposition copy of of aIl all records records pertaining pertaining to to the the above-named above-named person, person, as as outlined outlined in in the the Subpoena Duces Subpoena Duces Tecum, for inspection Tecum, for inspection and and marking marking asas Exhibits Exhibits to to be be attached attached to to this this deposition. deposition. Answer: Answer: 13. Have 13. Have you done as you done as requested in the requested in preceding question? the preceding question? If If not, not, why not? not? Answer: Answer: 14. Was the l4. method of the method of preparation preparation of of these these records records trustworthy? trustworthy? Answer: Answer: 15. Describe in detail any 15. Describe in detail any documents documents relating to this relating to this patient patient in in any any manner which which you you are are withholding. withholding. Answer: Answer: 16. 16. Do you you understand understand that that perjury perjury is is a a wime? crime? Answer: Answer: 17. l7. Do you you swear swear to to the the pains pains and and penalties penalties of perjury that ofperjury that you you are are turning turning over the the entire entire file file and all all documents documents of any any type type whatsoever whatsoever related related to to this this patient patient at at this this time? time? Answer: Answer: Order Order NO. No. 01-40651-001 01-40651-001 18. Are 18. Are there there any any records that you records that you have witbheld fiom have withheld 6om any